20030522Citizens Petition to Intervene.pdf

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UTILITIES Cm'H1ISSION
Morgan W. Richards, ISB No. 1913
MOFFATT, THOMAS, BARRETT, ROCK &
FIELDS, CHARTERED
101 S. Capitol Boulevard, 10th Floor
Post Office Box 829
Boise, Idaho 83701-0829
Telephone: [phone]
Facsimile: [phone]
15-881.19
Attorneys for Citizens Telecommunications Company ofldaho
BEFORE THE IDAHO PUBLIC UTILITIES COMMISSION
IN THE MATTER OF THE APPLICATION
OF NPCR, INe. d/b/a NEXTEL PARTNERS
SEEKING DESIGNA nON AS AN ELIGIBLE
TELECOMMUNICA nONS CARRIER THAT
MAY RECEIVE FEDERAL UNIVERSAL
SERVICE SUPPORT
Case No. GNR-03-
PETITION TO INTERVENE
COMES NOW Citizens Telecommunications Company ofldaho ("Citizens ), and
respectfully petitions the Idaho Public Utilities Commission for leave to intervene in the above-
captioned proceeding pursuant to Rules 71 through 75 ofthe Commission s Rules of Procedure
for the following reasons:
Citizens is a corporation authorized to do and are doing business in the
state ofldaho. Citizens is authorized to engage in the furnishing oflocal exchange and
telecommunications services in Idaho.
PETITION TO INTERVENE - 1 BOI MT2:509530.
Citizens desires to intervene in order that they might receive documents
and if its interests require, cross-examine witnesses and present evidence in Case
No. GNR-03-16. The nature and quality of evidence that Citizens will introduce is dependent
upon the nature and effect of other evidence in this proceeding. Consequently, Citizens cannot
inform the Commission of how involved its individual participation in this proceeding will be.
Therefore, Citizens cannot presently inform the Commission as to the type of evidence it will
present, if any, or the length of time necessary for such presentation.
Citizens will be represented in this proceeding by:
Morgan W. Richards
Moffatt, Thomas, Barrett, Rock &
Fields, Chartered
101 South Capitol Boulevard, 10th Floor
Post Office Box 829
Boise, Idaho 83701-0829
Telephone: [phone]
Fax: [phone]
Lance A. Tade, Manager
State Government Affairs
CITIZENS TELECOMMUNICATIONS OF IDAHO
4 Triad Center, Suite 200
Salt Lake City, UT 84180
Telephone: [phone]
Fax: [phone]
Copies of all pleadings, production requests, production responses, Commission orders and other
documents should be provided as noted above.
Without the opportunity to intervene herein, Citizens would be without
any means to protect its interest in the outcome of this proceeding or to determine the impact of
the Commission s determination on it.
PETITION TO INTERVENE - 2 BOI MT2:509530,
Citizens requests the Commission grant this Petition to Intervene and
allege that it has been timely filed. Citizens believes that intervention will not delay the
proceedings nor prejudice the Commission or any party to the case.
WHEREFORE, Citizens requests that this Commission grant its timely Petition to
Intervene in these proceedings and to appear and participate in all matters as may be necessary
and appropriate; and to present evidence, call and examine witnesses, present argument and to
otherwise fully participate in these proceedings.
RESPECTFULLY SUBMITTED this "?lS I day of May, 2003.
MOFFATT, THOMAS, BARRETT, ROCK &
FIELDS, CHARTERED
By
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Morgan W. Richards - Of the Firm
Attorneys for Citizens
PETITION TO INTERVENE - 3 BOI MT2:509530,
CERTIFICATE OF SERVICE
IV I HEREBY CERTIFY that on this day of May, 2003 , I caused to be served
a true copy of the foregoing PETITION TO INTERVENE by the method indicated below.
Jean Jewell
Idaho Public Utilities Commission
472 W. Washington Street
Post Office Box 83720
Boise, Idaho 83720-0074
())J.S. Mail, Postage Prepaid
(0 Hand Delivered
( ) Overnight Mail
( ) Facsimile
Dean J. Miller, Esq.
McDevitt & Miller, LLP
420 West Bannock Street
Post Office Box 2564
Boise, Idaho 83701
~u.S. Mail, Postage Prepaid
( ) Hand Delivered
( ) Overnight Mail
( ) Facsimile
Philip R. Schenkenberg
Briggs and Morgan, P .
2200 First National Bank Building
332 Minnesota Street
St. Paul, Minnesota 55101
/u.s. Mail, Postage Prepaid
( ) Hand Delivered
( ) Overnight Mail
( ) Facsimile
Conley Ward
GIVENS PURSLEY LLP
Post Office Box 2720
Boise, Idaho 83701
/u.s. Mail, Postage Prepaid
( ) Hand Delivered
( ) Overnight Mail
( ) Facsimile
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Morgan w.lfc~:ds
PETITION TO INTERVENE - 4 BOI MT2:509530.