20030825Clear Talk Objections to ITA Requests.pdf

Molly O'Leary, Esq. (ISB # 4996)
Richardson & O'Leary, PLLC
99 E. State Street, Suite 200
Eagle, Idaho 83616
[phone]
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Sean P. Farrell, Esq. (CSB # 186902)
General Counsel
IA T Communications, Inc.
NTCH-Idaho Inc., dba Clear Talk
703 Pier Avenue, Suite B, PMB 813
Hennosa Beach, CA 90254
[phone]
BEFORE THE
IDAHO PUBLIC UTILITIES COMMISSION
In the Matter of IA T Communications, Inc.
a. Clear Talk, Petition For Designation As
An Eligible Telecommunications Carrier
Docket No. GNR-O3-
CLEAR TALK'S OBJECTIONS TO
IDAHO TELEPHONE
ASSOCIATION'S FIRST SET OF
DISCOVERY REQUESTS
IA T Communications Inc. ("Clear Talk") hereby objects to Idaho Telephone
Association s First Set of Discovery Requests as follows:
uest No.Obiection(s)
Please state the total number of Clear Talk subscribers in each of the
requested Designated Areas, identifying these customers as either business or
residence users.
Clear Talk objects to this request on the grounds that it is burdensome insofar as it
seeks a compilation, and Clear Talk does not currently track its customers as business or
residential users. Notwithstanding the foregoing objections, Clear Talk will provide
subscriber counts to the best of its ability.
CLEAR TALK'S OBJECTIONS TO
ITA'S FIRST SET OF DISCOVERY-
Please state the number of Idaho subscribers Clear Talk currently serves in
all areas outside the requested Designated Areas, identifying these customers
as either business or residence users.
Clear Talk objects to this request on the grounds that it seeks information which is
not relevant and/or is not reasonably calculated to lead to the discovery of admissible
evidence, and is intended to vex, annoy or harass the responding party. Insofar as Clear
Talk's Application is limited to the Designated Areas, Clear Talk is not required to
produce information regarding subscribers in other areas.
Please describe the various rate plans and services Clear Talk provides to its
customers, including all rate plans, measured usage services, roaming
charges, product lines, service bundles, and features.
Clear Talk objects to this request on the grounds that it seeks information equally
available to the party requesting such information, insofar as information regarding Clear
Talk's rate plans and service is publicly available on Clear Talk's website
www.cleartalk.net.Notwithstanding the foregoing objection, Clear Talk will produce
retail materials regarding its rate plans and service.
Please provide copies of the documents relating to Clear Talk's decision to
me for ETC status in the state of Idaho, including but not limited to
memorandums, board of director minutes, management presentations,
correspondence and fmancial analysis and forecasts.
Clear Talk objects to this request as improper because it seeks information that is
privileged, including attorney-client communications and attorney work product.
Clear Talk objects to this request on the grounds that it seeks information which is not
relevant and/or is not reasonably calculated to lead to the discovery of admissible
evidence, and is intended to vex, annoy or harass the responding party.
What is Clear Talk's monthly average revenue per Idaho subscriber for the
six month period ending June 30, 2003 and for fiscal years 2002 including in
the calculation all revenues from all classes of plans, features, equipment fees
and sales, roaming charges, and any other subscriber fees.
Clear Talk objects to this request on the grounds that it is compound and would
require a compilation. Notwithstanding the foregoing objections, Clear Talk will provide
information that is responsive to this request.
CLEAR TALK'S OBJECTIONS TO
ITA'S FIRST SET OF DISCOVERY - 2
Please state Clear Talk's total debt-to-equity ratio at June 30, 2003 and state
the dollar amounts supporting such ratio.
Clear Talk objects to this request on the grounds that it seeks information which is
not relevant and/or is not reasonably calculated to lead to the discovery of admissible
evidence, and is intended to vex, annoy or harass the responding party. Clear Talk
objects to this request on the grounds that it seeks information, including financial
information, which is confidential and proprietary in nature.
Please describe each and every loan facility, funding instrument, promissory
note, or other form of short-term or long-term indebtedness incurred by
Clear Talk, including in such description, where applicable, the type of
instrument, the dollar amount, interest rate and due dates, amount of
origination fees, terms governing repayment, collateral subject to securing
agreements, the value of the secured collateral, record of missed payments,
penalties for missed payments, notice of default, and any restrictive
covenants that either cap the company s indebtedness or require the lender
approval prior to assuming more debt.
Clear Talk objects to this request on the grounds that it seeks information which is
not relevant and/or is not reasonably calculated to lead to the discovery of admissible
evidence, and is intended to vex, annoy or harass the responding party. Clear Talk
objects to this request on the grounds that it seeks information, including financial
information, which is confidential and proprietary in nature. Clear Talk objects to this
request on the grounds that it is burdensome and oppressive, and would require a
compilation. Clear Talk objects to this request as improper because it seeks a legal
opinion and/or attorney work product.
Please state Clear Talk's debt-service ratio, meaning the ratio of EBITDA
(Earnings Before Interest, Taxes, Depreciation, and Amortization) to all
principal payments on long-term debt, plus pro forma cash interest expense
for the next succeeding four fiscal quarters.
Clear Talk objects to this request on the grounds that it seeks information which is
not relevant and/or is not reasonably calculated to lead to the discovery of admissible
evidence, and is intended to vex, annoy or harass the responding party. Clear Talk
objects to this request on the grounds that it seeks information, including financial
information, which is confidential and proprietary in nature. Clear Talk objects to this
request on the grounds that it is burdensome and oppressive, would require a compilation
and would require speculation.
Please describe all debt securities issued by Clear Talk, including amounts,
maturities and interest rate or original purchase discount.
Clear Talk objects to this request on the grounds that it seeks information which is
not relevant and/or is not reasonably calculated to lead to the discovery of admissible
CLEAR TALK'S OBJECTIONS TO
ITA'S FIRST SET OF DISCOVERY - 3
evidence, and is intended to vex, annoy or harass the responding party. Clear Talk
objects to this request on the grounds that it seeks information, including financial
information, which is confidential and proprietary in nature. Clear Talk objects to this
request as improper because it seeks a legal opinion and/or attorney work product.
10.Please state whether the loan covenants or stock restriction of any affiliates
in any way restrict or limit Clear Talk's ability to raise capital, whether
through debt or equity, explaining the nature of such restriction or
limitation.
Clear Talk objects to this request on the grounds that it seeks information which is
not relevant and/or is not reasonably calculated to lead to the discovery of admissible
evidence, and is intended to vex, annoy or harass the responding party. Clear Talk
objects to this request on the grounds that it seeks information, including financial
information, which is confidential and proprietary in nature. Clear Talk objects to this
request on the grounds that it is burdensome and oppressive, would require a compilation
and would require speculation. Clear Talk objects to this request as improper because it
seeks a legal contention or opinion and/or attorney work product.
11.Please provide copies of all reports or analysis issued by rating agencies on
Clear Talk, including, but not limited to, Standard & Poors Rating Services
for the prior three years.
Clear Talk is not aware of the existence of such reports, however, to the extent
such reports exist, then such reports are equally available to the requesting party. Clear
Talk therefore objects to this request on the grounds that it seeks information equally
available to the party requesting such information, and is apparently intended to vex
annoy or harass the responding party.
12.Please describe Clear Talk's affiliate status, i.e., explain Clear Talk'
relationship to any up-stream or down-stream affiliates, including any parent
holding company, or cross-affiliate.
Clear Talk objects to this request insofar as it seeks information that is not
relevant to this proceeding. Notwithstanding the forgegoing objection, Clear Talk will
provide responsive information regarding its Idaho markets.
13.Please describe any pending litigation, arbitration or other disputes that
could potentially affect Clear Talk's ability to provide the supported services
in the requested Designated Areas of the state of Idaho.
Clear Talk will provide responsive information regarding this Request.
CLEAR TALK'S OBJECTIONS TO
ITA'S FIRST SET OF DISCOVERY - 4
14.Please provide copies of Clear Talk's financial statements for the six months
ended June 30, 2003 and audited fmancial statements for the fiscal years
2002, 2001, and 2000.
Clear Talk objects to this request on the grounds that it is burdensome insofar as it
requires a compilation and/or seeks materials that may not exist. Clear Talk objects to
this request on the grounds that it seeks information which is not relevant and/or is not
reasonably calculated to lead to the discovery of admissible evidence, and is intended to
vex, annoy or harass the responding party. Notwithstanding the foregoing objections
Clear Talk will produce materials responsive to this request, insofar as such materials
currently exist, to parties who have executed a confidentiality/non-disclosure agreement
acceptable in form to Clear Talk.
15.Please provide copies of all fmancial reports on Clear Talk's operations in
Idaho for the six months ended June 30,2003 and for the fiscal years 2002.
Clear Talk objects to this request on the grounds that it is duplicative of Request
No. 14, and is burdensome and oppressive insofar as it requires a compilation and/or
seeks materials that do not exist. Clear Talk objects to this request on the grounds that it
seeks information which is not relevant and/or is not reasonably calculated to lead to the
discovery of admissible evidence, and is intended to vex, annoy or harass the responding
party.
16.Please provide copies of internal management reports analyzing Clear Talk'
fmancial and operational performance on a monthly, quarterly, or annual
basis for the six months ended June 30, 2003 and for the fiscal years 2002.
Clear Talk objects to this request as improper because it may seek information
that is privileged, including attorney-client communications and attorney work product.
Clear Talk objects to this request on the grounds that it seeks information which is not
relevant and/or is not reasonably calculated to lead to the discovery of admissible
evidence, and is intended to vex, annoy or harass the responding party. Clear Talk
objects to this request on the grounds that it seeks information, including financial
information, which is confidential and proprietary in nature.
17.Please provide details identifying by type of equipment and location of Clear
talk's budgeted capital expenditures for the state of Idaho for fiscal year
2003 and 2004.
Clear Talk objects to this request to the extent it requires a compilation and
requires speculation. Notwithstanding the foregoing objections, Clear Talk intends to
provide information regarding its existing buildout plans to parties who have executed a
confidentiality/non-disclosure agreement acceptable in form to Clear Talk.
CLEAR TALK'S OBJECTIONS TO
ITA'S FIRST SET OF DISCOVERY - 5
18.Please provide copies of Clear Talk's state of Idaho income tax returns for
the fiscal years 2002.
Clear Talk objects to this request on the grounds that it seeks information which is
not relevant and/or is not reasonably calculated to lead to the discovery of admissible
evidence, and is intended to vex, annoy or harass the responding party. Notwithstanding
the foregoing objections, Clear Talk will provide materials responsive to this request.
19.Please provide copies of internal reports analyzing customer service and
billing complaints for the past twenty-four months ending June 30, 2003.
Clear Talk objects to this request on the grounds that it is burdensome insofar as it
requires a compilation and/or seeks materials that may not exist. Clear Talk objects to
this request as improper because it may seek information that is privileged, including
attorney-client communications and attorney work product, and is apparently intended to
vex, annoy or harass the responding party. Notwithstanding the foregoing objections
Clear Talk will produce non-privileged, confidential information in response to this
Request, but only to those parties who have executed a confidentiality/non-disclosure
agreement acceptable in form to Clear Talk.
20.Please provide copies of internal reports analyzing customer churn for the
past twenty-four months ending June 30, 2003.
Clear Talk objects to this request on the grounds that it seeks information which is
not relevant and/or is not reasonably calculated to lead to the discovery of admissible
evidence, and is intended to vex, annoy or harass the responding party. Clear Talk
objects to this request on the grounds that it is burdensome insofar as it requires a
compilation and/or seeks materials that may not exist. Clear Talk objects to this request
as improper because it may seek information that is privileged, including attorney-client
communications and attorney work product.
21.Please provide copies of internal reports or studies analyzing propagation
and wireless coverage in the requested Designated Areas disclosing signal
strength, areas not covered, and dead spots.
Clear Talk objects to this request on the grounds that it seeks information which is
not relevant and/or is not reasonably calculated to lead to the discovery of admissible
evidence, and is intended to vex, annoy or harass the responding party. In particular, the
Federal Communications Commission has already ruled that the issue of alleged "dead
spots" is not applicable for purposes ofE.T.C. designation. Clear Talk further objects to
this request on the grounds that it seeks information, including site location information
which is confidential and proprietary in nature. Clear Talk objects to this request as
improper because it may seek information that is privileged, including attorney-client
communications and attorney work product. Clear Talk objects to this request on the
grounds that it requires speculation and may require a compilation. Notwithstanding the
CLEAR TALK'S OBJECTIONS TO
ITA'S FIRST SET OF DISCOVERY - 6
foregoing objections, Clear Talk will produce non-privileged, confidential information in
response to this Request, but only to those parties who have executed a
confidentiality/non-disclosure agreement acceptable in form to Clear Talk.
22.Please provide copies of fmancial budgets or forecasts detailing or describing
the use of proceeds from the USAC in the event Clear Talk's ETC
application is approved for the requested Designated Areas in Idaho.
Clear Talk objects to this request as improper because it requires speculation and
seeks materials that may not exist. Clear Talk further objects to this request to the extent
it may seek information that is privileged, including attorney-client communications and
attorney work product.
23.Please describe the fmancial and other controls that will be put in place to
ensure that USF funds collected from the USAC are used for their intended
purposes and will not be diverted to other corporate purposes.
Clear Talk objects to this request on the grounds that it is intended to vex, annoy
or harass the responding party, insofar as it presumes that the responding party will
somehow engage in diversion ofUSF funds for improper purposes. Clear Talk objects to
this request to the extent it may seek information that is equally available to the
requesting party, insofar as USAC rules, regulations and statutes are publicly available.
Clear Talk further objects to this request as improper because it requires speculation and
seeks materials that may not exist.
24.Please provide details of Clear Talk's specific plans to extend its network in
each of the requested Designated Areas.
Clear Talk objects to this request to the extent it requires a compilation and
requires speculation, and is duplicative of Request No. 17. Notwithstanding the
foregoing objections, Clear Talk intends to provide information regarding its existing
buildout plans to parties who have executed a confidentiality/non-disclosure agreement
acceptable in form to Clear Talk.
25.Please provide details as to the amount of local usage that will be included in
Clear talk's proposed universal service offering in the requested Designated
Areas.
Clear Talk objects to this request as vague and ambiguous, insofar as "local
usage" may refer to airtime, geographic area, or both. Clear Talk further objects to this
request on the grounds that it requires speculation. Notwithstanding the foregoing
objections, Clear Talk will attempt to provide information responsive to this Request.
26.Please identify each of Clear Talk's competitors in the requested Designated
Areas.
CLEAR TALK'S OBJECTIONS TO
ITA'S FIRST SET OF DISCOVERY - 7
Clear Talk objects to this request on the grounds that it seeks information equally
available to the party requesting such information. Notwithstanding the foregoing
objections, Clear Talk will provide information responsive to this Request.
27.Please provide copies of documents showing Clear Talk's estimated market
share of the entire company, state of Idaho, and in the requested Designated
Areas.
Clear Talk objects to this request as vague and ambiguous. Clear Talk objects to
this request on the grounds that it is burdensome and oppressive, would require a
compilation and would require speculation. Clear Talk objects to this request as
improper in form because the request is compound, conjunctive or disjunctive, contains
subparts, and is not full and complete in and of itself. Clear Talk further objects to this
request on the grounds that it seeks information that is equally available to the requesting
party.
28.Please describe the analysis that will be undertaken when a customer
requests service in an area not currently served by Clear Talk, but within the
requested Designated Areas.
Clear Talk objects to this request as vague and ambiguous. Notwithstanding the
foregoing objection, Clear Talk will attempt to provide information responsive to this
request.
29.Please identify the specific media that would be utilized to advertise the nine
supported service s and the amount of advertising funds that would be
expended during the first twelve months following the Commissions approval
of the application.
Clear Talk objects to this request on the grounds that it requires speculation and
would require a compilation. Notwithstanding the foregoing objections, Clear Talk will
provide information responsive to this Request.
30.Please describe specifically how approval of Clear Talk's application will
increase competition and customer choice.
Clear Talk objects to this request on the ground that it is rhetorical.
Notwithstanding the foregoing objection, Clear Talk will provide information responsive
to this request.
31.Please identify and explain any and all public interests, other than interest in
increased competition, that would be furthered by granting Clear talk's ETC
requests.
Clear Talk objects to this request on the grounds that it requires speculation and a
legal conclusion insofar as the Idaho Public Utilities Commission is authorized to
CLEAR TALK'S OBJECTIONS TO
ITA'S FIRST SET OF DISCOVERY - 8
determine the public interest(s), whereas Clear Talk is not. Notwithstanding the
foregoing objections, Clear Talk will provide information responsive to this request.
32.If Clear Talk is granted ETC status by the Idaho Public Utilities
Commission, would the company comply with quality of service, pricing and
other guidelines and requirements required by the Commission as a
condition of approval of the application.
Clear Talk objects to this question as intending to vex, annoy or harass Clear Talk
insofar as the question presumes that Clear Talk would violate and/or fail to comply with
applicable ETC rules and regulations. Clear Talk further objects to this request on the
grounds that it requires speculation and presumes that the Commission might seek to
impose additional, non-statutory conditions upon any approval of Clear Talk'Application.
33.Please provide details on any known instances in the requested Designated
Areas where end users are currently not receiving the nine supported
services contained in the FCC's defmition of universal service.
Clear Talk objects to this request as vague and ambiguous. Clear Talk further
objects to this request on the grounds that it may seek information equally or exclusively
available to the party requesting such information, e., instances wherein the requesting
party s "end users" - however defined - are not receiving the nine supported services.
Notwithstanding the foregoing objections, Clear Talk will attempt to provide information
responsive to this Request.
34.Does Clear Talk have interconnection agreements with the incumbent LECs
serving the Designated Areas? Please furnish copies of any such agreement.
Clear Talk objects to this request on the grounds that it seeks information equally
available to the party requesting such information. Notwithstanding the foregoing
objection, Clear Talk will provide reference information regarding the interconnection
agreements on file with the Public Utilities Commission and therefore publicly available.
35.Does Clear Talk have reciprocal compensation agreements with the
incumbent LECs serving the Designated Areas? Please furnish copies of any
such agreements. State the amounts paid and received by Clear talk
pursuant to such agreements, by month, for 2002 and the first half of 2003.
Clear Talk objects to this request on the grounds that it seeks information equally
available to the party requesting such information, including interconnection agreements
that are on file with the Public Utilities Commission and therefore publicly available (see
response to Request No. 34). Clear Talk further objects to this request on the grounds
CLEAR TALK'S OBJECTIONS TO
ITA'S FIRST SET OF DISCOVERY-
that it is burdensome and oppressive, may seek materials which do not exist and/or would
require a compilation.
36.If Clear Talk does not have interconnection agreements or reciprocal
compensation agreements with the incumbent LECs in the Designated Areas
please explain how the incumbent LECs are compensated for the termination
of calls originated by Clear Talk customers to the incumbent LECs
customers.
Clear Talk objects to this request on the grounds that it is vague and ambiguous
seeks a legal contention or conclusion, requires speculation and may seek materials that
do not exist.
37.Please explain why requiring equal access to interexchange carriers (LXCs)
for Clear Talk customers as a condition of ETC status would not (1) promote
competition and (2) service the public interest.
Clear Talk objects to this request as vague and ambiguous, and improper because
it seeks a legal contention or conclusion. Clear Talk further objects to this request on the
grounds that it requires speculation and is moot in light of the FCC's recent ruling on or
about July 15 2003 wherein wireless carriers are not required to provide equal access as
a condition of obtaining ETC designation.
38.
39.
40.
Does Clear Talk permit its customers to use dial around calling (10-xxx) to
reach IXCs? If so, what charges do Clear Talk customers incur for dial
around?
Clear Talk will provide information responsive to this request.
Does Clear Talk intend to meet its ETC obligations, in whole or in part, by
reselling or leasing incumbent LEC loops or unbundled network elements?
If so, please describe Clear Talk's plans.
Clear Talk will provide information responsive to this Request.
If Clear Talk is granted ETC status in the Designated Areas, should
subsequent applicants also be granted ETC status upon substantially the
same showing and on similar terms and conditions? Please explain your
answer in detail.
Clear Talk objects to this request as vague and ambiguous and requiring
speculation, and as being overbroad and well beyond the scope of this proceeding.
CLEAR TALK'S OBJECTIONS TO
ITA'S FIRST SET OF DISCOVERY - 10
41.Is there any limit to the number of additional ETC designations that should
be granted in the Designated Areas? Please explain your answer in detail.
Clear Talk objects to this request as vague and ambiguous and requiring
speculation, and as being overbroad and well beyond the scope of this proceeding.
42.If Clear Talk's Application is granted and the ILECs in one or more of the
Designated Areas thereafter decide to relinquish their ETC designations in
the highest cost portions of their service areas, is Clear Talk prepared to, and
willing to, provide carrier of last resort service to all customers in any such
relinquished area without exceptions or preconditions. If your answer is
anything other than "yes , please explain.
Clear Talk objects to this request on the grounds that it requires speculation.
Insofar as Clear Talk is not aware of any showing of a relinquishment - actual or
threatened - by an ILEC(s) in any of the Designated Areas any response to this request
would be purely speculative.
RESPECTFULLY SUBMITTED, this 22ND day of August 2003.
Richardson & O'Leary P .L.L.C.
Molly O'Leary
Attorneys for
IA T Communications, Inc., dba
Clear Talk
CLEAR TALK'S OBJECTIONS TO
ITA'S FIRST SET OF DISCOVERY - 11
CERTIFICATE OF SERVICE
I HEREBY CERTIFY that I have, this 22ND day of August 2003 served the foregoing CLEAR
TALK'S OBJECTIONS TO IDAHO TELEPHONE ASSOCIATION'S FIRST SET OF DISCOVERY
REQUESTS as indicated below:
John Hammond, Deputy AG
Idaho Public Utilities Commission
472 W. Washington Street
Boise, Idaho 83720-0074
[phone] (Fax)
ihammon~puc. state.id.
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Commission Staff
Dean J. Miller
McDevitt & Miller LLP
O. Box 2564
Boise, Idaho 83701
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Counsel for Nextel Partners
Philip R. Schenkenberg
Briggs and Morgan, P.
2200 First National Bank Building
St. Paul, Minnesota 55101
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Counsel for Nextel Partners
Conley E. Ward, Jr.
GIVENS PURSLEY, LLP
O. Box 2720
Boise, Idaho 83701-2720
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Counsel for Idaho Telephone Association
CERTIFICATE OF SERVICE
IA T Communications, Inc. dba Clear Talk
Clay Sturgis, Senior Manager
MOSS ADAMS LLP
601 Riverside, Suite 1800
Spokane, W A 99201-0063
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Counsel for Idaho Telephone Association
Morgan W. Richards, Esq.
Moffatt, Thomas, Barrett, Rock & Fields
101 S. Capitol Blvd, 10th Floor
P. O. Box 829
Boise, Idaho 83701-0829
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Counsel for Citizens Telecommunications Company of Idaho
Lance A. Tade, Manager (vi S. Mail, Postage Prepaid
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Counsel for Citizens Telecommunications Company of Idaho
Mary S. Hobson
Stoel Rives LLP
101 S. Capitol Blvd, Suite 1900
Boise, Idaho 83702-5958
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Counsel for Qwest Corporation
CERTIFICATE OF SERVICE
IA T Communications, Inc. dba Clear Talk
Robert M. Nielsen, Esq.
O. Box 706
Rupert, Idaho 83350
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Counsel for Project Mutual Telephone
Cooperative Association, Inc.
Charles H. Creeson, Jr.
President & General Manager
Project Mutual Telephone Cooperative Association, Inc.
O. Box 366
Rupert, Idaho 83350
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CERTIFICATE OF SERVICE
IA T Communications, Inc. dba Clear Talk