20040819Response to Staff Letter.pdf

JOSEPH MCNEAL, d/b/a P AGED A T A
O. Box 15509
Boise, ill 83715
[phone]
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Attorney Pro Se
BEFORE THE IDAHO PUBLIC UTILITIES COMMISSION
JOSEPH B. MCNEAL, d/b/a P AGED A T A
Respondent.
CASE NO. QWE-03-Complainant
vs.
QWEST CORPORATION
COMPLAINANT'S SUPPLEMENTAL MEMORANDUM
Per the letter from Don Howell, Deputy Attorney General, dated August 10, 2004
requesting the status of Case No. QWE- T -03-, Joseph B. McNeal d/b/a PageData
hereby submits this Supplemental Memorandum to address additional information since
the Complaint was originally filed October 31 , 2003 and the Request for Summary
Judgment was filed January 29, 2004.
COMPLAINT ANT'S SUPPLEMENTAL MEMORANDUM -
In the interim the Idaho Public Utility Commission ("Commission ) has issued
Order No. 29555 on August 2, 2004 . In the Order the Commission recognized that
PageData officially requested a single POI on or about September 1 , 1998 "to take
advantage of the Telecommunications Act's single POI entitlement (47 U.C. *
251(c)(2)(B) and the FCC's regulation 51.703(b) that prohibits Qwest from charging for
delivery of its traffic to (PageData)". (Order No. 29555 at 20)
The Court of Appeals recognized that the facilities and services that Qwest was
providing to Mountain Communications were available at no charge under a single POI?
Likewise the Commission, in agreement with the Court of Appeals, limited the time that
Qwest could charge PageData for facilities used to connect the multiple POls to
months. At some point after September 1998 Qwest was obligated to install the single
POI for PageData, which eliminated the need for the facilities used to connect the
tnultiple POls. (Order No. 29555 at 20 and 21) Using the SGAT as a guideline and the
facilities installed for PageData s single POI now Qwest had 25 days to install the
facilities.
Qwest is rejecting the Commission s Order that Qwest can only charge PageData
for 22 months. Qwest is still trying to charge PageData for not installing the single POI
when originally requested and still charging the transit factor when Qwest has not
provided the originating call data. The Court of Appeals and the Commission recognized
1 In the A/atter of Robert Ryder DBA Radio Paging Service, Joseph B. AfcNeal DBA PageData and
InterPage of Idaho, and Tel-Car, Inc. v. Qwest Corporation, IPUC Case No. USW-99-24 and Supreme
Court Docket No. 29175.2 "Mountain s system of interconnection provided it no advantages other than those to which, presumably,
it is entitled for free." U. S. Court of Appeals, District of Columbia Circuit /n the Matter of Mountain
Communications, Inc. v. Federal C'ommunications Commission No. 02-1255, Decided January 16 2004, at
p7.
COMPLAINTANT'S SUPPLEMENTAL MEMORANDUM - 2
that the originating carrier is ultimately responsible for all charges. The Commission
needs to enforce their Order No. 29555.
Through an informal complaint filed with the Federal Communications
Commission ("FCC"), Qwest was forced to allow PageData to exercise its rights under *
252(i) and adopt the AirTouch/ Arch interconnection agreement in all of Qwest's 14 state
territory. The Commission approved this interconnection agreement on February 25
2003. Also as a result of the informal complaint, Qwest stated that it would not continue
to withhold facilities requested by PageData due to formally disputed outstanding
charges.
In accordance with the interconnection agreement Section 6, Local Transport and
Termination Rates PageData submitted a sample invoice for flat rate 6000 MOU per
trunk reciprocal compensation to Qwest. Qwest approved this sample invoice format on
May 15, 2003 (See Exhibit A, Email from Tom Pontinen).
On June 4, 2003, in response to an informal complaint filed with the FCC
PageData received a settlement agreement from Bob McKenna (See Exhibit B, Email
from Bob McKenna) clarifying Section 2.4 of the interconnection agreement. In its
response, Qwest wanted to make sure that PageData did not charge reciprocal
compensation for terminating Internet traffic. PageData formally submitted this
settlement agreement as an amendment to the interconnection agreement on August 11
2004. Commission staff mediated the installation of the facilities referenced in the
settlement agreement.
On February 12, 2004 PageData received notice from Lori Lydon of Qwest
representing that Qwest had sent a letter to PageData on December 19, 2003 saying all
CO:MPLAINT ANT'S SUPPLEMENTAL MEMORANDUM - 3
reciprocal compensation under PageData s interconnection agreement would be applied
to offset balances with Qwest (See Exhibit C, Email from Lori Lydon). This was the first
time that PageData was made aware of the existence of the letter because PageData had
not previously received this letter. Because PageData was not aware of the letter, Lori
Lydon emailed it on February 12, 2004.
On February 16, 2004 Lori Lydon indicated that Qwest was going to continue
applying the reciprocal compensation to offset accounts (See Exhibit D, Email from Lori
Lydon).
On February 17 2004 Joseph McNeal sent an email to Lori Lydon of Qwest
complaining that Qwest was creating an illusionary billing crisis (See Exhibit E, Email
from Joseph McNeal) because Qwest was not applying the reciprocal compensation
credits as they had stated nor were they sending a check to PageData.
In response, on February 18 , 2004 Lori Lydon sent an email stating that Qwest
would be crediting PageData s account $15 907.85 (according to the spreadsheet attached
to the email showing $15 907.85 as the amount due PageData (at that time) for flat rate
reciprocal compensation under the interconnection agreement approved by the
Commission (See Exhibit F, Email from Lori Lydon).
In response, on February 18 2004 Sharon McNeal sent an email stating how
PageData requested to have the credits applied to two accounts (See Exhibit G, Email
from Sharon McNeal).
Through the assistance of Commission staff mediation Qwest installed
PageData s long requested single point of presence (SPOP) in June 2004 under Account
COMPLAINT ANT'S SUPPLEMENTAL MEMORANDUM - 4
R54-0008-008. PageData has submitted invoices to Qwest for flat rate 6000 MOD per
trunk reciprocal compensation for these Type 2 facilities.
CONCLUSION
To date, PageData has invoiced Qwest a total of $28 473. 18 for flat rate 6000
MOU per trunk reciprocal compensation for PageData s Type 1 facilities and $5 119.
for PageData s Type 2 facilities.
To date Qwest has not issued PageData reciprocal compensation payments for
terminating Qwest originated traffic neither by check nor by crediting accounts requested
by PageData despite several letters from Qwest stating they would credit PageData
account.
PRA YER FOR RELIEF
PageData requests that the Commission order Qwest to remove the transit charges
from accounts 208 R51-0454 454 and R54-0008-008 per the Commission Order No.
29555 because Qwest has not provided any originating call data.
PageData requests that the Commission order Qwest to apply a portion of the
reciprocal compensation credits to 208-375-8896-012B and issue a check for the
remaining reciprocal compensation credit directly to PageData.
LIST OF ATTACHED EXHIBITS
Exhibit A Email from Tom Pontinen (Qwest) dated May 15, 2003
approving PageData sample invoice for reciprocal
compensation using the flat rate 6000 MOU and Sample
Invoice.
Exhibit B Email from Bob McKenna (Qwest) dated June 4, 2003
COMPLAINT ANT'S SUPPLEMENTAL MEMORANDUM - 5
clarifying that if PageData used interconnection facilities for
Internet traffic that traffic would not be eligible for
reciprocal compensation payments.
Exhibit C Email from Lori Lydon (Qwest) dated February 12 2004
with copy of letter dated December 19, 2003 concerning
offsetting PageData s accounts.
Exhibit D Email from Lori Lydon (Qwest) dated February 16 2004
stating that direction with PageData to continue.
Exhibit E Letter from Joseph McNeal (PageData) dated February 17
2004 concerning reciprocal compensation payments.
Exhibit F Email from Lori Lydon (Qwest) dated February 18 2004
with spreadsheet showing $15 907.85 as amount due
PageData (at that time) for reciprocal compensation that
would be credited to PageData s account.
Exhibit G Email from Sharon McNeal (PageData) dated February 18
2004 with spreadsheet showing PageData request for
crediting accounts and amounts.
RESPECTFULLY SUBMITTED this 18th day of August, 2004.
COMPLAINT ANT'S SUPPLEMENTAL MEMORANDUM - 6
CERTIFICATE OF SERVICE
I HEREBY CERTIFY that on the 18th day of August, 2004, 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 Secretary
472 W. Washington Street
PO Box 83720
Boise, ill 83720-0074
- U.S. Mail Fax By Hand
William 1. Batt
Marshall Batt & Fisher, LLP
US Bank Plaza, 5th Floor
101 S. Capitol Blvd.
Boise, ID 83701
S. Mail Fax -=- By Hand
Adam Sherr
Qwest
1600 ih Avenue - Room 3206
Seattle, W A 98191S. Mail Fax By Hand
COMPLAINT ANT'S SUPPLEMENTAL MEMORANDUM - 7
EXHIBIT A
Show Full Headers Subject: Re: Sample Invoice
To: Sharon McNeal
5..S..h a ro n (ID pa 9 ed.a..ta . co m ~I.B
From: .:Jam f:Qntjnen " ~tQ.Q.n.tjn(Wqwest.com~i:!:l
Date: Thu, 15 May 2003 08:41:27 -0600
Move Message To :ON est related emails (88 Message(s), 0 Unread)
Sharon
This format works. Will you be e-mailing each month? We also have a
question about the rates, are you aware of any cost docket rates that may
possibly supercede the recip comp rates?
Thanks,
Tom
Sharon McNeal ~sharon(Q)pagedata.com~ on 05/13/2003 04:24:43
To:
cc:
Tom Pontinen ~tpontin(Q)qwest.com ~
Subject:Sample Invoice
(See attached file: C.htm)
(See attached file: PageData Sample Invoice.xls)
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tA~ Pagella.ta Sample,
L:2I Invoice.xls
REMIT TO:SAMPLE INVOICE
6610 Overland Rd.
Boise ID 83709
[phone]
ACNA: PDD
TO: Qwest Communications
Attn: Tom Pontinen
150 S. 5th Street Rm 550
Minneapolis, MN 55402
email: tpontin~qwest.com
[phone]
[phone]
INVOICE DATE:2/1/03
INVOICE NUMBER:2003651
BILL DUE DATE:3/1/03
TOTAL AMOUNT DUE:022.
Please detach and return top portion with payment.
REIMBURSEMENT FOR TERMINATING QWEST ORIGINATED TRAFFIC
STATE: Idaho Billing Period: 1/01/03-1/31/03
TRUNK CIRCUIT ID DESCRIPTION Type 1/Number of MOU Per Rate Per Compensable Reimbursement
GROUP Type 2 Trunks Trunk Type 1 Trunk Traffic Factor Due (D*
493 208-658-3400 101 T1 BOISIDTHHAA Type 1 6000 $0.003398 76%$371.
237 208-736-5400 Type 1 6000 $0.003398 76%$61.
417 208-234-3800 Type 1 6000 $0.003398 76%$92.
129 208-677-8000 Type 1 6000 $0.003398 76%$30.
104 208-788-6800 Type 1 6000 $0.003398 76%$15.
735 208-525-3000 Type 1 6000 $0.003398 76%$46.
113 208-359-6900 Type 1 6000 $0.003398 76%$30.
334 208-672-3500 102 T1 BOISIDTHHAA Type 1 6000 $0.003398 76%$371.
Subtotal $1,022.
Taxes $0.
Total Monthly Reimbursement Due $1,022.
Previous Balance $0.
Payment Received $0.
Balance Forward $0.
New Charges $1,022.
TOTAL AMOUNT DUE 022.
6610 Overland Rd., Boise ID 83709
[phone]
EXHIBIT B
-----
Original Message-----
From: Bob McKenna (mailto:Bob McKenna
Sent: Wednesday, June 04, 2003 3:02
To: Joseph McNeal
Cc: Christopher Olsen; William Bill Batt; Bryan E Sanderson; Andrea ESanchez; kpettey; dljenni
Subject: WaveSent and PageData
Text item: Message Text
Dear Mr. McNeal:
We have reviewed your May 28 responses to the FCC's questions concerning
interconnection requests by PageData and WaveSent. Upon such review , wehave determined that Qwest will not insist on resolution of Qwest'claims for payment of past amounts as a precondition to either
PageData s or WaveSent's ordering further interconnection facilities andservices from Qwest. Qwest will be willing to process properly
submitted ASRs for interconnection on a timely basis upon submission.
In the past, PageData and WaveSent have had difficulty completing andsubmitting proper ASRs for service. Andrea Sanchez (303.965.1805) willbe available to meet with you to assist you in preparing these
documents. As Qwest has noted in its filings with the Federal
Communications Commission, the ASRs that PageData sent to the Commission
are not complete and do not provide sufficient information on which
Qwest could begin to fill the order. In addition, while Qwest is
willing to provide PageData and WaveSent with the interconnection
facilities and services that they need to provide the services for which
such interconnection can lawfully be utilized , the number of trunks
shown on the two ASRs filed with the FCC is clearly excessive for thepaging services that form the basis of the ASRs. These matters can be
worked out with Ms. Sanchez, who can insure that the ASRs that you
submit are complete and accurate.
Finally, irrespective of disputes over past amounts due, there does notseem to be any dispute that compensation will be necessary for services
provided under current interconnection agreements. Such compensation
can be requited in the case of transiting traffic and WATS or
equivalent facilities, on the one hand , and reciprocal compensation on
the other hand. Should PageData or WaveSent use interconnection
facilities or services for Internet traffic, such traffic would not be
subject to reciprocal compensation payments. Qwest would , of courserun its standard credit
check on WaveSent to determine whether a deposit is necessary. These
and
similar compensation matters likewise can be worked out in advance with
Ms. Sanchez. It makes sense to determine at this time what facilities
and services must be paid for, and by whom.
Please do not hesitate to give me a call with questions. I can be
reached at 303.672.2861.
EXHIBIT C
Show Full Headers:Subject: Page Data Offset Letter
Date: Thu, 12 Feb 2004 15:27:47 -0700
From: Lydonr Lori" C:::Lori.Lydon((j)qwest.com:::.ill
To: c:::Sharon((j)Pagedata.com:::.ill
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Sharon, Attached please find a copy of the letter sent out regarding offsetting Page Data s balanceowed against what we owe. I touched base with Cindy Minor and have sent Barb Newman a email
so I should hear something soon and will let you know. Thanks, Lori
Lori Lydon
Lexcis Parables
Phone: [phone]
FAX' 515-286-4023
Email: Lori.Lydon(!Jqwest.com
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Qwest
Lexcis Payables
Lori Lydon, SDC
900 Keo Way - 4 South
Des A-foines, fA 50309
Phone: [phone]
E Mail: Lori.LydonrEJqwest.com
December 19, 2003
Page Data
6610 Overland Road
Boise, ID 83709
ACNA: PDD
To Whom It May Concern:
Qwest has received and validated your Invoice 2003725. Due to the outstanding balance owed Qwestand subsequent failure to keep your account current, Qwest will apply all monies owed by Page Data. as
an offset to the balance owed Qwest.
This process will continue until your account with Qwest becomes current, but may be reinstated at any
time that your account becomes delinquent.
Pleasefeelfree to contact me if you have any questions.
Sincere (v,
Qwest
Lori Lydon, SDC
cc: Barb Newman
EXHIBIT
Show Full Headers:Subject: Page Data -lCA
Date: Mon, 16 Feb 2004 05:44: 13 -0700
From: Lydon, Lori" ~Lori.Lydon(Q)qwest.com~
To: ~Sharon(Q)paaedata.com~
Cc: Sanderson. Bryan" C:::Bryan.Sanderson(Q)qwest.com~
Move Message To : Inbox (6791Ve~sage(s),3 Unread)
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Sharon, I have made several calls and emails regarding payment of your account. At this time the
direction will continue as in the past since I am being told that Page Data is in the process of
signing an lCA, and no formal decisions have been made at this time. Once directed, I can get
payment processed in 2-3 days. Thanks, Lori Lydon
Lori Lydon
Lexcis Parables
Phone: [phone]
FAX' 515-286-4023
Email: Lori.LydonrPqwest.com
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EXHIBIT E
SENT VIA EMAIL
February 17, 2004
Lori Lydon
Lexcis Payables
Qwest
900 Keo Way - 4 South
Des Moines, IA 50309
515-241-1202
515-286-4023 Fax
RE: PageData Reciprocal Compensation Payments
Dear Ms. Lydon:
Sharon informed me of the email she received from you yesterday. This do nothing policy is
unacceptable.
We were informed through correspondence with Qwest that you were the person designated to
handle this, but now we find that is not so and we are getting the Qwest run-around again. Who
specifically at Qwest is making these decisions so he or she can be held accountable? This
shadowy person needs to come forth.
PageData already has an ICA with Qwest. There are no scheduled negotiations between
PageData and Bryan Sanderson of Qwest at this time.
To date PageData has not received any reciprocal compensation payments. This is in direct
violation of the ICA. Qwest has claimed that it is crediting PageData' s accounts BAN 208 R51-
0454-454 and 208-375-8896, but PageData has not seen Qwest issue credits for the reciprocal
compensation to these accounts and invoices designated by PageData. Every month that
PageData receives invoices fron1 Qwest the balances are increasing, but the balances should be
zero if the reciprocal compensation has been applied. Who specifically is responsible for
crediting these accounts? This individual's failure to credit these accounts only exacerbates the
billing problems in the other Qwest billing departtnents.
It is Qwest's non-responsiveness that is creating an illusionary billing crisis at Qwest. Since
PageData received its first facilities from Qwest, the reciprocal compensation due and owing
PageData has always offset any lawful charges due Qwest by PageData. Qwest has failed to
recognize this point. That is what this billing crisis is about.
PO Box 15509
Boise, Idaho 83715
Telephone [phone]
Facsin1ile [phone]
6610 Overland Road
Boise, Idaho 83709
Page 2
Qwest is expecting payment from PageData while Qwest continues to unlawfully hold reciprocal
compensation from PageData for terminating Qwest originated traffic. This is inconsistent with
resolving the problems on a going forward basis.
Qwest cannot have it both ways. Qwest must either issue payment for reciprocal compensation
directly to PageData or it must apply the reciprocal compensation to BAN 208 R51-0454-454 for
coITected invoices from March 2003 to date and 208-375-8896 from October 2003 to date. Note
that any so-called balances prior to March 2003 on BAN 208 R51-0454-454 and an other
accounts up to date are under active, formal dispute in federal and state court. PageData cannot
be penalized in any way for disputing unlawful charges, as Qwest is attempting to do.
The indecisiveness of the individual(s) at Qwest is generating meetings for Ineetings and endless
paperwork going nowhere rather than resolving the issues. It was our understanding that the
relationship between PageData and Qwest was going to be normalized on a going forward basis
and each party would start paying each other according to the ICA.
Qwest has created this illusionary billing crisis through its old, entrenched, unlawful policies that
were carried out by the previous paging product manager, Sheryl Fraser, in contradiction of the
1996 Telecommunications Act. The recent US Court of Appeals District of Columbia Circuit
decision on January 16, 2004, in the Mountain Communications, Inc. vs. Federal Conl111unication
Commission (Case No. 02-1255) and the US Court of Appeals Fourth Circuit decision on
December 18 2003 in the MCI Metro Access Transmission Services Inc. vs. Ben South
Telecommunications (Case No. 03-1238) have further substantiated PageData s interpretation of
the 1996 Telecommunications Act and rejected Sheryl Fraser's group s interpretation of the 1996
Telecommunications Act. Qwest itself is rejecting its old policies with the availability of the new
ICAs that are more in line with the 1996 Telecommunications Act by including a single point of
presence option and reciprocal compensation. However, individuals inside and outside Qwest are
advising Qwest to continue trying to collect money from PageData for past Qwest billing policies
that the courts have deemed unlawful.
Qwesf s withholding of reciprocal compensation is unlawfully penalizing PageData for
exercising its rights to dispute charges and is the source of the imaginary billing crisis because
Qwest is aware that the reciprocal compensation will be redistributed back to Qwest to pay for
accounts BAN 208 R51-0454-454 and 208-375-8896. CoITecting the billing starts with the
reciprocal compensation. Qwest has refused to COITect the billing through an external process by
paying PageData directly or through an inten1al process of applying the credits to the accounts
and invoices designated by PageData.
In Conclusion
Your letter dated December 19, 2003, that you emailed Sharon on February 12, 2004, is unlawful
for two very important reasons: )) under the ICA, Qwest must issue reciprocal compensation
payments directly to PageData; and 2) Qwest has no legal authority to apply reciprocal
colnpensation due and owing PageData to actively disputed accounts that are before federal and
state court. Further, your letter claims that Qwest has applied monies owed PageData to offset
Page 3
balances, but this has not been done. Why would Qwest issue a legally binding letter and not
apply the credits to the accounts that PageData designates?
We expect this situation to be cotTected. According to Idaho law, if an ILEC such as Qwest is
holding money, Qwest must apply the credits to accounts and items that PageData designates.
The next invokes PageData receives for accounts BAN 208 R51-0454-454 and 208-375-8896
should be zero if Qwest follows through on either one of the two promises it made to PageData
through either your unlawful letter or the ICA.
Sincerely,
Isl Joseph B. McNeal
Joseph B. McNeal
cc:Bryan Sanderson
Sheila Pederson
Vickie Boone
Cindy Minor
EXHIBIT F
Show Full Headers:Subject: Spreadsheet of Outstanding Balances
Date: Wed, 18 Feb 2004 13:51:49 -0700
From: Lydon, Lori" C:::LorLLydon(Ci)qwest.com:::-ill
To: C:::Joseph(Ci)pagedata.com:::-ill
Cc: c:::Sharon(Ci)pagedata.com:::-l:t1, Newman. Barb"
C:::Barb.Newman(Ci)qwest.com:::-l:t1, Boone. Vickie
C:::Vickie.Boone(g)qwestcom:::-l:t1, Minor. Cindy
c:::Cindy.Minor(Ci)qwestcom:::-l:t1, Downey. Linda
c::: Li nda. Downey(Ci)qwest. com:::-l:t1
Move Message To : Inbox (679 Message(s), 3 Unread)
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Joseph and Sharon, Attached please find our spreadsheet showing the amounts that will becredited to your account. We apologize for the confusion and look forward to the opportunity of
working with you in the future. Thanks, Lori Lydon
Lori Lydon
Lexcis Parables
Phone: [phone]
FAX' 515-286-4023
Email: Lori.L ydon(gJqwest. com
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Show Full Headers: Date: Wed, 18 Feb 2004 15:25:54 -0700
From: Sharon McNeal "'sharon(IDpagedata.com~l:t1
To: Lydon ill, Lori "'Lori.Lydon(IDqwest.com~l:t1
Cc: ioseph(IDpagedata.com "'joseph(IDpagedata.com~l:t1, Barbara
Newman "'Barb.Newman(IDqwest.com~L:t1, Vickie BQone
"'vickie.boone(IDawest.com~L:tl, Cindv Minor
"'Cindy.Minor(IDqwest.com~L:tl, Linda Downey
'" Li nda. Downey(IDqwest. com ~L:tl
bject: Re: Spreadsheet of Outstanding Balances
Move Message To : ~X(6 ~~~a ~S).3Unr:~d)
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Lori
I have taken the total amount due PageData ($15 907.85) from your spreadsheet that yousent earlier today and made another spreadsheet, which I have attached, to show how the
reciprocal compensation credits should be applied to the two PageData accounts (BAN 208 R51-0454-454 and 208-375-8896). After applying the credits per the attached spreadsheet, bothaccounts should be current with a zero balance and net reciprocal compensation still due PageData
in the amount of $5,201. 70. Since PageData has not received an invoice for BAN 208 R51-0454-454 since Cindy has entered the corrections to the billings, she will need to verify the outstanding
balance on that account, but our numbers should be very close.
Who will apply these credits to the accounts? Will it be Cindy Minor or you? When will the creditsbe applied? It is my understanding the R51 account will be billing again next week and it would be
beneficial if the credits were applied before the next billing.
Thanks
Sharon McNeal
~ Joseph and Sharon, Attached please find our spreadsheet showing the
~ amounts that will be credited to your account. We apologize for the
~ confusion and look forward to the opportunity of working with you in the
~ future. Thanks, Lori Lydon
~ Lori Lydon
~ Lexcis Payables
~ Phone: [phone]
~ FAX: [phone]
~ Email: LorLLydon(Q)qwest.com
Content-Type: applicationfvnd.ms-excel name=PageData
Accounts to Credit 2-18-04.xls
Content- Transfer-Encodings: base64
Length: 13.5 KB
PageData Accounts to
I:fI Credit2-18-04.xls
PageData Accounts to be Credited
2/18/04
Reciprocal Compensation Due PageData Through February 1 , 2004
Less Balance on BAN 208 R51-0454-454 Through February 2004
Less Balance on 208-375-8896 Through Feb. 7 2004
$15 907.
- $7 854.
- $2 851.
Net Reciprocal Compensation Due PageData = $5,201.