20050729Reply to staff's answer to petition.pdf

Brad M. Purdy
Attorney at Law
2019 N. 17th St.
Boise, ID. 83702
208-384-1299
Fax: [phone]
Bar No. 3472
bmpurdvcmhotmail.com
Attorney for Petitioner
Matthew Castrigno
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BEFORE THE IDAHO PUBLIC UTILITIES COMMISSION
IN THE MATTER OF THE APPLICATION OF
TAMARACK VIDEO & TELECOM LLC FOR A )
CERTIFICA TE OF PUBLIC CONVENIENCE
AND NECESSITY TO PROVIDE F ACILITIES- )BASED LOCAL EXCHANGE
TAM-05-
MATTHEW CASTRIGNO'
REPLY TO STAFF'
ANSWER TO PETITION
On July 20, 2005, Staff filed an Answer to Matthew Castrigno s alternative
petition for reconsideration/petition for order requiring provision of service. In essence
Staff disagrees that reconsideration of Order No. 29808 is appropriate for a variety of
reasons. Staff does, however, recommend that the Commission open a separate docket to
consider Mr. Castrigno s petition ordering Frontier Telephone Company to provide
service to customers in the Tamarack Resort area stating that such a proposal is "worthy
of investigation.
As stated in Mr. Castrigno ' s petition, the matter was framed in the alternative to
preempt any procedural challenges and to provide the Commission and Staff with greater
latitude in addressing all relevant issues. Without agreeing with Staff s analysis
REPLY TO STAFF'S ANSWER
regarding the merits of reconsideration, Mr. Castrigno is satisfied that opening a separate
docket would be an appropriate means of proceeding forward and has no objection to
Staff's overall recommendation.
RESPECTFULLY SUBMITTED, this 28th day of July, 2005.
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Brad M. Purdy
REPLY TO STAFF'S ANSWER
CERTIFICA TE OF SERVICE
I HEREBY CERTIFY that on the ;ir! ay 0 f2005, I caused to be served the
foregoing MATTHEW CASTRIGNO'S REPLY TO STAFF'S ANSWER TO
PETITION on the following, by fIrst class postage prepaid.
Shelby Weimer
Tamarack Video & Telecom LLC
Suite 100
960 Broadway Ave.
Boise, ID 83706
Conley E. Ward
Givens Pursley, LLP
601 W. Bannock St.
O. Box 2720
Boise, ID 83701-2720
Frontier Communications of Idaho
4 Triad Center, Suite 200
Salt Lake City, UT 84180
Charles Best
4400 NE 77th Ave.
Vancouver, W A 98662
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Brad M. Purdy ~
REPLY TO STAFF'S ANSWER