20120409Motion to Withdraw Petition.pdf

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RECEIVFD
ZUI? APR -9 PM 14:52 MC
ATTORNEYS AT LAW ;LSMr
Molly O'Leary flU
Tel: [phone] Fax: [phone]
[e-mail]
P.O. Box 7218 Boise, ID 83707 - 515 N. 27th St. Boise, ID 8370
06 April 2012
Ms. Jean Jewell HAND DELIVERED
Commission Secretary
Idaho Public Utilities Commission
472 W. Washington
Boise, ID 83702
RE: CASE NO. TCS-T-11-01
MOTION TO WITHDRAW PETITION FOR RECONSIDERATION,
CLARIFICATION, OR STAY OF ORDER NO. 32480
Dear Ms. Jewell:
Enclosed please find the above-referenced MOTION TO WITHDRAW PETITION
FOR RECONSIDERATION, CLARIFICATION, OR STAY OF ORDER NO. 32480
for filing on behalf of IC Systems, Inc., in the above-referenced docket. We have
enclosed an original and seven (7) copies, as well as an additional copy for you to
stamp for our records.
Very truly yours,
Molly O'L
Richar n O'Leary, PLLC
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MOLLY O'LEARY [ISB # 49961 RECElWED
Richardson & O'Leary, PLLC
VZ P 0 Box 7218 2 PR 4-.52
Boise, ID 83707
Tel: [phone]
Fax: [phone] iiTILITIES
[e-mail]
Attorneys for TC Systems, Inc
BEFORE THE IDAHO PUBLIC UTILITIES COMMISSION
IN THE MATTER OF THE ) CASE NO TCS-T41-01
APPLICATION OF TC SYSTEMS, )
INC. TO REGISTER AS A ) MOTION TO WITHDRAW PETITION FOR
WHOLESALE PROVIDER OF ] RECONSIDERATION, CLARIFICATION, OR
TELECOMMUNICATIONS ) STAY OF ORDER NO. 32480
SERVICES WITHIN THE STATE )
OF IDAHO )
COMES NOW, TC Systems, Inc. ("TCS" or "Compan)"], by and through
undersigned counsel, and moves to withdraw its PETITION FOR RECONSIDERATION,
CLARIFICATION, OR STAY OF ORDER NO 32480, filed with the Commission on March
27, 2012, for the reason that TCS has resolved the underlying questions raised by the
National Exchange Carrier Association ("NECK] following TCS's March 8, 2012 request to
NECA to receive a Company Code [A Company Code is used to develop an OCN, which
is required to receive numbers from either the North American Numbering Plan
Administrator ["NANPA") or the Number Pooling Administrator ["PA"].)
SIGNATURE PAGE FOLLOWS
PETITION FOR RECONSIDERATION,
CLARIFICATION, OR STAY OF ORDER NO. 32480
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f
RESPECTFULLY SUBMITTED this 6' day of April, 2012.
By - "4' 1
Molly
Richair O'Leai, PLLC
F TC Systems, Inc
PETITION FOR RECONSIDERATION,
CLARIFICATION, OR STAY OF ORDER NO 32480 -2
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CERTIFICATE OF SERVICE
I HEREBY CERTIFY that on this 6' day of April, 2012, I caused a true and correct
copy of the foregoing to be hand-delivered upon the following individual(s)
Jean Jewell
Commission Secretary
Idaho Public Utilities Commission
472 W Washington Street
Boise, ID 83702-5918
Neil Price
Deputy Attorney General
Idaho Public Utilities Commission
472 W. Washington Street
Boise, ID 83702-5918
Molly O'Le
Richardso 'Leary, LC
PETITION FOR RECONSIDERATION,
CLARIFICATION, OR STAY OF ORDER NO. 32480-3