20250910MOTION TO TABLE DELIBERATIONS.pdf

RECEIVED
SEPTEMBER 10,2025
C. Tom Arkoosh, ISB No. 2253 IDAHO PUBLIC
UTILITIES COMMISSION
Nicholas J. Erekson, ISB No. 9325
ARKOOSH LAW OFFICES
913 W. River Street, Suite 450
P.O. Box 2900
Boise, ID 83701
Telephone: [phone]
Facsimile: [phone]
Email: tom.arkoosh(a,arkoosh.com
[e-mail]
Admin copy: [e-mail]
Attorneys for Ziply Fiber
BEFORE THE IDAHO PUBLIC UTILITIES COMMISSION
IN THE MATTER OF ZIPLY FIBER ) Case No. ZFP-T-24-02
PACIFIC, LLC, D/B/A ZIPLY FIBER'S )
APPLICATION FOR DESIGNATION AS ) ZIPLY FIBER'S MOTION TO
AN ELIGIBLE TELECOMMUNICATIONS ) TABLE DELIBERATIONS AT
CARRIER IN THE STATE OF IDAHO TO ) SEPTEMBER 11, 2025, DECISION
RECEIVE FEDERAL LIFELINE SUPPORT ) MEETING
COMES NOW Ziply Fiber Pacific, LLC, d/b/a Ziply Fiber, by and through its counsel of
record, C. Tom Arkoosh and Nicholas J. Erekson of Arkoosh Law Offices, and hereby moves the
Commission to table deliberation scheduled for September 11,2025,until such time as Ziply Fiber
has taken the opportunity to provide any further information the Staff desires for the record in this
matter. It has come to the attention of the undersigned that the Staff feels that certain information
that may be available is not in the record, which information the Staff has described as material
and bearing upon the matters before the Commission.
Ziply Fiber requests that the deliberations in this matter be tabled until such time as the
information the Staff perceives as pertinent is actually included in the record, whether or not the
same has been previously included in the record by reference. Additionally, Ziply Fiber would
request additional time to collaborate with Staff regarding their concerns. Attached hereto as
Exhibit A is a true and correct copy of a letter sent to Adam Triplett, dated August 28, 2025,
requesting a meeting regarding this matter. To date, Ziply Fiber has not received a response.
ZIPLY FIBER'S TO TABLE DELIBERATIONS AT SEPTEMBER 11, 2025,DECISION MEETING
—Page 1

For these reasons, Ziply Fiber respectfully submits that good cause exists to defer
deliberations until Staffs concerns have been fully addressed and the record properly
supplemented, thereby allowing the Commission's decision to rest upon a complete and accurate
record.
DATED this loth day of September 2025. ARKOOSH LAW OFFICES
C. Tom Arkoosh
Attorneys for Ziply Fiber
ZIPLY FIBER'S TO TABLE DELIBERATIONS AT SEPTEMBER 11, 2025,DECISION MEETING
—Page 2

CERTIFICATE OF MAILING
I HEREBY CERTIFY that on the 10'h day of September 2025, 1 served a true and correct
copy of the foregoing document(s)upon the following person(s), in the manner indicated:
Commission Secretary U.S. Mail, Postage Prepaid
Idaho Public Utilities Commission Overnight Courier
11331 W. Chinden Blvd., Building 8, Hand Delivered
Suite 201-A (83714) Via Facsimile
P.O. Box 83720 X_ Email:
Boise, ID 83720-0074 secretary(d),puc.idaho.gov
Adam Triplett U.S. Mail, Postage Prepaid
Deputy Attorney General Overnight Courier
Idaho Public Utilities Commission Hand Delivered
11331 W. Chinden Blvd., Building 8, Via Facsimile
Suite 201-A (83714) X_ Email:
P.O. Box 83720 adam.triplett(c,,puc.idaho.gov
Boise, ID 83720-0074
C. Tom Arkoosh
ZIPLY FIBER'S TO TABLE DELIBERATIONS AT SEPTEMBER 11, 2025,DECISION MEETING
—Page 3

ARKOOSH C. Tom Arkoosh
LAW OFFICES [e-mail]
W16
August 28, 2025
Via Email
Adam Triplett
Deputy Attorney General
Idaho Public Utilities Commission
11331 W. Chinden Blvd., Building 8, Suite 201-A (83714)
P.O. Box 83720
Boise, ID 83720-0074
adam.triplettgpuc.idaho.gov
Re: Ziply Fiber Pacific, LLC d/b/a Ziply Fiber and Ziply Wireless, LLC, d/b/a Ziply
Fiber's Applications for Designation as an Eligible Telecommunications Carrier in
the State of Idaho to Receive Federal Lifeline Support
Case Nos. ZFP-T-24-02 and ZWL-T-24-02
Dear Mr. Triplett,
We write to follow up on Ziply Fiber's Reply Comments, dated April 23, 2025, in the
above-referenced matters, concerning Ziply Fiber's outstanding applications for designation as
Eligible Telecommunications Carriers ("ETC") in the State of Idaho.
Given the significance of this matter to Idaho's low-income and rural communities, we
respectfully request a meeting with you, Commission Staff, and Ms. Jessica Epley and Ms.
Elizabeth Brayman of Ziply Fiber to discuss any outstanding issues and concerns raised by Staff,
in light of the Reply Comments submitted by Ziply Fiber.
We believe a collaborative meeting would provide an opportunity to discuss whether, in
light of the Ziply Fiber's Reply Comments and supporting materials, the Staff would consider
revising its recommendation to the Commission.
Please let us know your availability and that of appropriate Staff members so we can
coordinate schedules with Ms. Epley and Ms. Brayman. We are willing to work cooperatively
toward a resolution if possible.
Sincerely,
ARKOOSH LAW OFFICES
C. Tom Arkoosh Nicholas J. Erekson
CTA/NJE/emc
Cc:Client
913 W.River Street,Suite 450,P.O.Box 2900,Boise,ID 83701 1 Tel:[phone] Fax:[phone] A