20030429ITA Petition to Intervene.pdf

Conley Ward
GIVENS PURSLEY LLP
277 North 6th Street, Suite 200
O. Box 2720
Boise, ID 83701
[phone]
[phone] (fax)
HECEIVED mF!LED
2003 APR 29 PH 3: 46
iU/'.hJ )JUd LlC
UTILITIES COf1MISSION
Attorneys for Idaho Telephone Association
S:\MACS\CEW\IT A \Nextel\petition to intervene.rtf
BEFORE THE IDAHO PUBLIC SERVICE COMMISSION
IN THE MATTER OF THE APPLICATION OF
NPCR, INC. d/b/a NEXTEL PARTNERS
SEEKING DESIGNATION AS AN ELIGIBLE
TELECOMMUNICATIONS CARRIER THAT
MAY RECEIVE FEDERAL UNIVERSAL
SERVICE SUPPORT
: CASE NO.&IY 1(.'1' tJ.J-
: IDAHO TELEPHONE ASSOCIATION'
: PETITION TO INTERVENE
Idaho Telephone Association ("IT A") petitions this Commission for leave to intervene in
the above entitled proceeding pursuant to Rules 72 and 73 ofthe Commission s Rules of Practice
and Procedure, IDAPA 31.01.01.072 and -073. In support of this Petition, ITA states as
follows:
1. The ITA is an association of independently owned telephone companies providing
local exchange service and other telecommunications services within the state ofIdaho. The
IT A is charged with representing its member companies' interests before the Idaho Public
Utilities Commission and other regulatory agencies.
2. The IT A has a direct and substantial interest in these proceedings because this
Commission s decision may, directly or indirectly, affect the ITA member companies' quality or
cost of telecommunications service.
3. The ITA is unable to state its position at this stage of the proceedings, and therefore
seeks to intervene for the purpose of receiving documents, examining witnesses, and otherwise
participating as its interest may appear.
IT A's PETITION TO INTERVENE - 1
4. The ITA's representatives for the purpose of service of pleadings and other written
materials are:
Conley Ward
GIVENS PURSLEY, LLP
277 North 6th Street, Suite 200
O. Box 2720
Boise, ID 83701
[phone]
[phone] (fax)
Clay R. Sturgis
MOSS ADAMS LLP
601 W. Riverside, Suite 1800
Spokane, W A 99201-0663
[phone]
[phone] (fax)
WHEREFORE, IT A respectfully requests that the Commission grant this Petition to
Intervene and authorize IT A to participate in the above entitled proceedings with full rights as a
formal party.
DATED this day of April 2003.
IT s PETITION TO INTERVENE - 2
CERTIFICATE OF SERVICE
I HEREBY CERTIFY that on the ;;9~ay of April 2003 , I caused to be served a true
and correct copy of the foregoing by the method indicated below, and addressed to the following:
Jean Jewell
Idaho Public Utilities Commission
472 W. Washington Street
O. Box 83720
Boise, ID 83720-0074
u.S. Mail - Fax By Hand
McDevitt & Miller, LLP
Dean J. Miller, Esq.
420 West Bannock Street
O. Box 2564
Boise, ID 83701
u.S. Mail - Fax - By Hand
Briggs and Morgan, P .
Philip R. Schenkenberg
2200 First National Bank Building
332 Minnesota Street
Saint Paul, Minnesota, 55101
u.S. Mail - Fax - By Hand
;'ZL J/r7u
Tina Smith
IT s PETITION TO INTERVENE - 3