20240610Staff 1-1 to ZFP.pdf

RECEIVED
2024 June 10, 4:50PM
IDAHO PUBLIC
MICHAEL DUVAL UTILITIES COMMISSION
DEPUTY ATTORNEY GENERAL
IDAHO PUBLIC UTILITIES COMMISSION
PO BOX 83720
BOISE, IDAHO 83720-0074
[phone]
IDAHO BAR NO. 11714
Street Address for Express Mail:
11331 W CHINDEN BLVD, BLDG 8, SUITE 201-A
BOISE, ID 83714
Attorney for the Commission Staff
BEFORE THE IDAHO PUBLIC UTILITIES COMMISSION
IN THE MATTER OF ZIPLY FIBER'S )
APPLICATION FOR DESIGNATION AS AN ) CASE NO. ZFP-T-24-01
ELIGIBLE TELECOMMUNICATIONS )
CARRIER IN THE STATE OF IDAHO TO )
RECEIVE FEDERAL LIFELINE SUPPORT ) FIRST PRODUCTION
REQUEST OF THE
COMMISSION STAFF
TO ZIPLY FIBER PACIFIC,
LLC dba ZIPLY FIBER
Staff of the Idaho Public Utilities Commission, by and through its attorney of record,
Michael Duval, Deputy Attorney General, requests that Ziply Fiber Pacific, LLC dba Ziply Fiber
("Company")provide the following documents and information as soon as possible, but no later
than MONDAY,JUNE 24, 2024.
This Production Request is to be considered as continuing, and the Company is requested
to provide,by way of supplementary responses, additional documents that it, or any person
acting on its behalf, may later obtain that will augment the documents or information produced.
Please provide answers to each question, supporting workpapers that provide detail or are
the source of information used in calculations, and the name,job title, and telephone number of
the person preparing the documents. Please also identify the name,job title, location, and
telephone number of the record holder.
FIRST PRODUCTION REQUEST
TO ZIPLY FIBER 1 JUNE 10, 2024

In addition to the written copies provided as response to the requests, please provide all
Excel spreadsheets and electronic files with formulas intact and enabled.
REQUEST NO. 1: On Page 2 of the Application, it states: "Specifically, ZFP seeks to
be designated as an ETC throughout the area defined by its physical network footprint in Idaho
. . . ." Please provide a reasonably sized and detailed map showing where the Company proposes
to provide service including exchanges, rural zones, and local calling areas.
DATED at Boise, Idaho, this to Nday of June 2024.
Michael DuNral
Deputy Attorney General
I:\Utility\UMISC\PRDREQ\ZFP-T-24-01 PR#l.docx
FIRST PRODUCTION REQUEST
TO ZIPLY FIBER 2 JUNE 10, 2024

CERTIFICATE OF SERVICE
I HEREBY CERTIFY THAT I HAVE THIS DAY OF JUNE 2024,
SERVED THE FOREGOING FIRST PRODUCTION REQUEST OF THE COMMISSION
STAFF TO ZIPLY FIBER PACIFIC, LLC dba ZIPLY FIBER, IN CASE NO. ZFP-T-
24-01, BY E-MAILING A COPY THEREOF TO THE FOLLOWING:
Jessica Epley
Ziply Fiber
135 Lake Street South, Suite 155
Kirkland, WA 98033
Telephone: [phone]
Email:[e-mail]
ztxAC117
PA RICIA JORDAN, CRETARY
CERTIFICATE OF SERVICE