200310061st Supplemental Response of Clear Talk to Citizens.pdf

Molly O'Leary, Esq. (lSB # 4996)
Richardson & O'Leary, PLLC
99 E. State Street, Suite 200
Eagle, Idaho 83616
[phone]
Sean P. Farrell, Esq.
General Counsel
IAT Communications, Inc.
NTCR-Idaho Inc., dba Clear Talk
703 Pier Avenue, Suite B, PMB 813
Rermosa Beach, CA 90254
[phone]
RECEIVED mFILED
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UTILITIES COr1MiSStOH
BEFORE THE
IDAHO PUBLIC UTILITIES COMMISSION
In the Matter of the Petition ofIAT
Communications, Inc., d.a. NTCR-Idaho, Inc. )
or Clear Talk, for Designation as an Eligible
Telecommunications Carrier.
In the Matter of the Application ofNPCR, INC.
d/bl a NEXTEL PARTNERS
Seeking Designation as an Eligible
Telecommunications Carrier that may receive
Federal Universal Service Support.
CASE NO. Docket No. GNR-O3-
CASE NO. Docket No. GNR-O3-
CLEAR TALK'S SUPPLEMENTAL
RESPONSES TO FIRST SET OF
DISCOVERY REQUESTS FROM
CITIZENS
TELECOMMOUNCA TIONS
COMPANY OF IDAHO
IAT Communications, Inc. ("Clear Talk") hereby responds to Citizens Telecommunications
Company of Idaho s First Set of Discovery Requests as follows:
Request No.Res onse
The persons able to answer questions regarding Clear Talk's responses at a hearingare Larry Curry and Glenn W. Ishihara.
CLEAR TALK'S SUPPLEMENTAL RESPONSES TO
CITIZENS' 1ST SET OF DISCOVERY REQUESTS
3. Identify the number, including zero as appropriate, of current Clear Talk
customers that have a billing address in each respective wire center served by Citizens in
the area in which Clear Talk is not seeking ETC status.
Clear Talk is providing confidential, responsive information on the attached document
identified as "CIT 1-
4. Identify the NP A-NXXs currently assigned to Oear Talk that will be used to
serve customers in the area in which Oear Talk is seeking ETC status.
Clear Talk has previously provided responsive information on the document identified as
CIT 1-4." The NPA-NXXs currently assigned to Clear Talk in Idaho are 208-200 208-212, and
208-223.
5. Identify which NP A-NXXs are currently assigned to customers in each
respective wire center served by Citizens in the area in which Clear Talk is seeking ETC
status.
Clear Talk has previously provided responsive information on the document identified as
CIT 1-" The NPA-NXXs currently assigned to Clear Talk in Idaho are 208-200 208-212, and
208-223.
18. Are there any blind spots in Oear Talk's service area in Idaho that would
prevent Clear Talk from providing those services it must provide to be designated an ETC?
Clear Talk is not aware of any limitations that would prevent Clear Talk from meeting its
obligations as an ETC.
30. Will Clear Talk follow the Idaho Public Utilities Commission s service
quality rules?
The stated rules do not currently apply to Clear Talk. Clear Talk will comply with all
rules that apply to its services.
31. Does Clear Talk plan to open customer service centers in communities
throughout its designated service area?
Clear Talk has previously provided responsive information (on a document identified as
CIT 1-31" regarding the current locations of Clear Talk's customer service centers. Clear Talk
does not currently have plans to immediately add additional customer service center locations.
However, Clear Talk may add additional customer service center locations, and/or add customer
service functions at dealer locations, on an as-needed basis.
CLEAR TALK'S SUPPLEMENTAL RESPONSES TO
CITIZENS' 1ST SET OF DISCOVERY REQUESTS
32. Does Clear Talk plan to comply with the Commission s Customer Relations
Rules, including the Commission s resolution process for complaints escalated to the
Commission?
The stated rules do not currently apply to Clear Talk. Clear Talk will comply with all
rules that apply to its services.
RESPECTFULLY SUBMITTED, this 3rd day of October, 2003.
IAT COMMUNICATIONS, INC.
CLEAR TALK'S SUPPLEMENTAL RESPONSES TO
CITIZENS' 1ST SET OF DISCOVERY REQUESTS
CONFIDENTIAL DOCUMENTS
WERE INCLUDED IN TillS FILING
CERTIFICATE OF SERVICE'
I HEREBY CERTIFY that on this 3rd day of October, 2003, I caused a true and
correct copy of the foregoing. CLEAR TALK'S SUPPLEMENT~ RESPONSES TO
CITIZENS' FIRST SET OF DISCOVERY REQUESTS to be serVed by the method indicated
below, and addressed to the following:
Jean Jewell
Idaho Public Utilities Commission
472 West Washington Street
Post Office Box 83720
Boise, Idaho 83720-0074
(X) u.S. Mail, Postage Prepaid
( )
Hand Delivered
( )
Overnight Mail
( )
Facsimile - .
( ) Electronic Mail
Dean J. Miller, Esq.
420 West Bannock
Post Office Box 2564-83701
Boise, Idaho 83702
[phone] (Fax)
joe~mcdevitt-miller. com
(X) u.S. Mail, Postage Prepaid
( ) Hand Delivered
( )
Overnight Mail
( ) Facsimile
( ) Electronic Mail
Philip R. Schenkenberg, Esq.
2200 First National Bank Building
332 Minnesota Street
St. Paul, Minnesota 55101
p sc henkenberg(g) bri gg s. com
(X) U.S. Mail, Postage Prepaid
( ) Hand Delivered
( )
Overnight Mail
( )
Facsimile
( ) Electronic Mail
* * *
With Confidential Information Redacted
Conley Ward
Givens Pursley LLP
277 North 6th Street, Suite 200
Post Office Box 2720
Boise, Idaho 83701
[phone] (Fax)
mailto: cew(?!)givenspursley. com
(X) U.S. Mail, Postage Prepaid
( ) Hand Delivered
( )
Overnight Mail
( )
Facsimile
( ) Electronic Mail
Lance A Tade, Manager
State Government Affairs
Citizens Telecommunications Company ofIdaho
4 Triad Center, Suite 200
Salt Lake City, UT 84180
ltade~czn. com
(X) U.S. Mail, Postage Prepaid
( ) Hand Delivered
( )
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( ) Facsimile
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CLEAR TALK
CERTIFICATE OF SERVICE - 1
Charles H. Creason, Jr.
President and General Manager
Project Mutual Telephone Cooperative
Association, Inc.
507 G Street
Post Office Box 366
Rupert, Idaho 83350
*** With Confidential Information Redacted
John Hammond, Deputy AG
Idaho Public Utilities Commission
Washington Street
Boise, Idaho 83720-0074
[phone] (Fax)
jhammon~uc. state. id. us
Clay Sturgis, Senior Manager
MOSS ADAMS LLP
601 Riverside, Suite 1800
Spokane, W A 99201-0063
clays~mossadams. com
*** With Confidential Information Redacted
Morgan W. Richards, Esq.
Moffatt, Thomas, Barrett, Rock & Fields
101 S. Capitol Blvd, 10th Floor
P. O. Box 829
Boise, Idaho 83701-0829
[phone] (Fax)
mwr~moffatt.com
Mary S. Hobson
Stoel Rives LLP
101 S. Capitol Blvd, Suite 1900
Boise, Idaho 83702-5958
[phone] (Fax)
mshobson~stoel.com
CLEAR TALK
CERTIFICATE OF SERVICE - 2
(X) u.S. Mai~ Postage Prepaid
( ) Hand Delivered
( )
Overnight Mail
( )
Facsimile
( ) Electronic Mail
(X) u.S. Mail, Postage Prepaid
( ) Hand Delivered
( )
Overnight Mail
( )
Facsimile
( )
Electronic Mail
(X) u.S. Mail, Postage Prepaid
( ) Hand Delivered
( )
Overnight Mail
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Facsimile
( ) Electronic Mail
(X) U.S. Mai~ Postage Prepaid
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( ) Facsimile
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Electronic Mail
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( )
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Robert M. Nielsen
548 E Street
Post Office Box 706
Itupert, Idaho 83350
*** With Confidential Information Redacted
CLEAR TALK
CERTIFICATE OF SERVICE - 3
(X) u.S. Mail, Postage Prepaid
( )
Hand Delivered
( )
Overnight Mail
( ) Facsimile
( ) Electronic Mail
Signed:5t:
Clear Talk