20031103Objections of Citizens to Nextel Requests.pdf

Morgan W. Richards, ISB No. 1913
MOFFATT, THOMAS, BARRETT, ROCK &
FIELDS , CHARTERED
101 S. Capitol Boulevard, 10th Floor
Post Office Box 829
Boise, Idaho 83701
Telephone: [phone]
Facsimile: [phone]
mwr~moffatt.com
15-881.19
RECEIVED
(-- L_
zn03 NOV -3 Pi', 4: 29
;~;
'.) IUDUC
UTILITiES COf11'1iSSION
Attorneys for Citizens Telecommunications
Company of Idaho
BEFORE THE IDAHO PUBLIC UTILITIES COMMISSION
IN THE MATTER OF THE PETITION OF
IAT COMMUNICATIONS, INC., d.
NTCH-IDAHO, INC. OR CLEAR TALK
FOR DESIGNATION AS AN ELIGIBLE
TELECOMMUNICATIONS CARRIER
Case No. GNR-03-
IN THE MATTER OF THE APPLICATION
OF NPCR, INC. d.a. NEXTEL PARTNERS
SEEKING DESIGNATION AS AN
ELIGIBLE TELECOMMUNICATIONS
CARRIER
Case No. GNR-03-
OBJECTIONS OF CITIZENS
TELECOMMUNICATIONS COMPANY
OF IDAHO TO DISCOVERY
REQUESTS OF NEXTEL PARTNERS'
COMES NOW Citizens Telecommunications Company of Idaho ("Citizens ), by
and through its attorneys, and objects to Nextel Partners ' First Discovery Request as follows:
Request No.: Provide all cost studies and other data relied on by Citizens to
support its request to disaggregate its federal universal service. Provide all filings with the FCC
requesting such disaggregation.
OBJECTIONS OF CITIZENS TELECOMMUNICATIONS COMPANY OF IDAHO TO
DISCOVERY REQUESTS OF NEXTEL PARTNERS' - 1 BOI MT2:526973.
RESPONSE NO.: Citizens 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 also on the grounds that the request is burdensome. Notwithstanding
the objection, Citizens will provide filings made with the FCC requestipg disaggreg::iJ:ion.
Request No.: Admit that every rate plan attached to Mr. Peabody s testimony
contains "an amount of local usage " as that phrase is used in 47 CFR 9 54.101 (a). If you do not
admit this, identify which rate plans you claim fail to contain "an amount of local usage" and
explain shy (sic) you make such a claim.
RESPONSE NO.: This Request is denied in part and admitted in part.
Request No.: Provide all supporting data for Mr. Trampush's statements on
page 8, lines 7-19- ITA, and fax page 9, lines 5-11 of his testimony.
RESPONSE NO.: Objection. Part of this Request is burdensome because it
seeks information that this party does not possess relating to another party, the IT
Notwithstanding the objection, Citizens will provide information response to the request that is
specific to its operation
Request No.: Provide all summaries, analyses, or reports that exist that
reference the information compiled in the manner described on page 8 , lines 7-, of
Mr. Tramphush's testimony.
RESPONSE NO.: Objection. This Request is burdensome because it seeks
information that this party does not possess relating to another party, the ITA.
Request No.: Provide a copy of the surveyor surveys that were sent to ITA
members to obtain the information referred to on page 8, lines 7-9 of Mr. Trampush's testimony.
OBJECTIONS OF CITIZENS TELECOMMUNICATIONS COMPANY OF IDAHO TO
DISCOVERY REQUESTS OF NEXTEL PARTNERS' - 2 BOI MT2:526973.
RESPONSE NO.: Objection. This Request is burdensome because it seeks
information that this party does not possess relating to another party, the IT
Respectfully submitted this 3rd day of November, 2003.
MOFFATT, THOMAS, BARRETT, ROCK &
FIELDS, CHARTERED
w' RJl~Morga . Richards - Of the lrm
Attorneys for Citizens
Telecommunications Company of Idaho
OBJECTIONS OF CITIZENS TELECOMMUNICATIONS COMPANY OF IDAHO TO
DISCOVERY REQUESTS OF NEXTEL PARTNERS' - 3 BOI MT2:526973.
CERTIFICATE OF SERVICE
I HEREBY CERTIFY that on this 3rd day of November, 2003, I caused a true
and correct copy of the foregoing OBJECTIONS OF CITIZENS
TELECOMMUNICATIONS COMPANY OF IDAHO TO DISCOVERY REQUESTS OF
NEXTEL PARTNERS' to be served by the method indicated below, and addressed to the
following:
John Hammond, Deputy AG
IDAHO PUBLIC UTILITIES COMMISSION
472 West Washington Street
Post Office Box 83720
Boise, Idaho 83720-0074
(X) US. Mail, Postage Prepaid
( ) Hand Delivered
( ) Overnight Mail
( ) Facsimile
Molly O'Leary, Esq.
RICHARDSON & O'LEARY, PLLC
99 East State Street, Suite 200
Eagle, Idaho 83616
(X) US. Mail, Postage Prepaid
( ) Hand Delivered
( ) Overnight Mail
( ) Facsimile
Sean P. Farrell, Esq.
!AT COMMUNICATIONS, INC.
NTCH-IDAHO INC., DBA CLEAR TALK
703 Pier Avenue, Suite B , PMB 813
Hermosa Beach, California 90254
(X) US. Mail, Postage Prepaid
( ) Hand Delivered
( ) Overnight Mail
( ) Facsimile
Dean J. Miller, Esq.
420 West Bannock
Post Office Box 2564-83701
Boise, Idaho 83702
(X) US. Mail, Postage Prepaid
( )
Hand Delivered
( ) Overnight Mail
( ) Facsimile
Philip R. Schenkenberg, Esq.
BRIGGS AND MORGAN, P.
2200 First National Bank Building
332 Minnesota Street
St. Paul, Minnesota 55101
(X) US. Mail, Postage Prepaid
( ) Hand Delivered
( ) Overnight Mail
( ) Facsimile
Conley Ward
GIVENS PURSLEY LLP
277 North 6th Street, Suite 200
Post Office Box 2720
Boise, Idaho 83701
(X) US. Mail, Postage Prepaid
( ) Hand Delivered
( ) Overnight Mail
( ) Facsimile
OBJECTIONS OF CITIZENS TELECOMMUNICATIONS COMPANY OF IDAHO TO
DISCOVERY REQUESTS OF NEXTEL PARTNERS' - 4 BOI MT2:526973.
Lance A. Tade, Manager
State Government Affairs
CITIZENS TELECOMMUNICATIONS
COMPANY OF IDAHO
4 Triad Center, Suite 200
Salt Lake City, UT 84180
Robert M. Nielsen
548 E Street
Post Office Box 706
Rupert, Idaho 83350
Charles H. Creason, Jr.
President and General Manager
PROJECT MUTUAL TELEPHONE COOPERATIVE
ASSOCIATION, INC.
507 G Street
Post Office Box 366
Rupert, Idaho 83350
Mary S. Hobson
STOEL RIVES, LLP.
101 South Capitol Boulevard, Suite 1900
Boise, Idaho 83702
(X) U.S. Mail, Postage Prepaid
( ) Hand Delivered
( ) Overnight Mail
( ) Facsimile
(X) US. Mail, Postage Prepaid
( ) Hand Delivered
( ) Overnight Mail
( ) Facsimile
(X) U.S. Mail, Postage Prepaid
( ) Hand Delivered
( ) Overnight Mail
( ) Facsimile
(X) US. Mail, Postage Prepaid
( ) Hand Delivered
( ) Overnight Mail
( ) Facsimile
(..1 ~
Morgan . Richards
OBJECTIONS OF CITIZENS TELECOMMUNICATIONS COMPANY OF IDAHO TO
DISCOVERY REQUESTS OF NEXTEL PARTNERS' - 5 BOI MT2:526973.