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Home My WebLink About200311141st Response of PMT to Clear Talk.pdf~ - ii: 13 Cii ...: ~ co f-~O .:!: X . ~ ...:: .:!:~ ~ := s 15 ,." q ;::, 23 co f- :.. ~ 0 ~ ;:; 0:: c:: Robert M. Nielsen , Esq. At torney at Law 548 E Street P . O. Box 7 0 6 Rupert, Idaho 83350 Telephone: (208) 436-4678Facsimile: (208) 436- 0551 ISB# 1335 At torney for proj ect Mutual Telephone Cooperative Association , Inc. RECEIYED FILED lOa3 MaV 12 AM 9: IDAhO F)IJF'j 1('UTILITIES COt.fM-ISSION BEFORE THE IDAHO PUBLIC UTILITIES COMMISSION IN THE MATTER OF THE PETITION OF IAT) COMMUNICATIONS, INC., d.a. NTCH- IDAHO , INC., OR CLEAR TALK , FOR DESIGNATION AS AN ELIGIBLE TELECOMMUNICATIONS CARRIER. IN THE MATTER OF THE APPLICATION OF NPCR , INC., DBA NEXTEL PARTNERS SEEKING DESIGNATIONS AS AN ELIGIBLE TELECOMMUNICATIONS CARRIER THAT MAY RECEIVE FEDERAL UNIVERSAL SERVI CE SUPPORT COME S proj ect Mutual and responds to the Discovery Requests which NOW Association Inc" Case No. GNR-T- 03 - 08 Case No. GNR-T- 03 - PMT'S RESPONSE TO CLEAR TALK'S FIRST SET OF DISCOVERY REQUESTS Telephone Cooperative were propounded on it by NTCH-Idaho, Inc. dba Clear Talk , dated October 20, 2003. REQUEST NO.1 :Please identify any upstream or downstream affiliates of proj ect Mutual including any parent and explain the relationship to each such af f i iate, cross - af f il iate PMT's RESPONSE TO CLEAR TALK' FIRST SET OF DISCOVERY REQUESTS holding company or ;;.. ii: 13 :;;: a ~ ~ ~ 0 ..:: x . ~ ...:: .:!:~ ~ := s 15 0:: ;::: f:: 0 ~ 0:: q ~:.. ~ ;:; c:: RESPONSE TO REQUEST NO.None. Please identifyREQUEST all services2 :provided including whether such service availableyourcustomers throughout your service area. RESPONSE telephone2 :Local exchangeREQUESTNO. servlce Long distance internettelephoneserviceand dial- servlce available ourall local exchange and data are areas tel ephone service In addition wireless VOlcearea. services paging services,and cable television service are available in some areas. Please identify by nameREQUEST NO.3 :title,address and tel ephone number each person (s)who participated in preparing responses to these Data Requests. RESPONSE TO REQUEST NO. Charles H. Creason , Jr.President, proj ect Mutual Telephone Box 366 , Rupert , Idaho 83350 208-436-7151 Please identify by name,title, address andREQUEST NO. telephone number each person (s) response to these Data Requests. who can testify regarding each RESPONSE TO REQUEST NO.See Response to Request No. REQUEST proj ectNO.including5 :Mutual itsDoes employees officers,agents or outside consultants,subscribe to Clear Talk's wireless service in Idaho? RESPONSE TO REQUEST NO.5 :See PMT's objections to Clear Talk's First Set of Discovery Requests dated November 3, 2003. If Project MutualREQUEST NO.6 :incl uding its respective employees , officers,subscribe toagents or outside consultants, Clear Talk'wireless service Idaho,please identify such PMT's RESPONSE TO CLEAR TALK' FIRST SET OF DISCOVERY REQUESTS ii: 13 :;;: a ~ ~ g 0 .:!: ~ . ~ c .....~ ~ ::: S ~ ~ d f-:'0:: 0 . ,." f- :.. ~ 0 ~ ;:; 0:: c:: subscribers by name and specify how long they have subscribed to Clear Talk's wireless service in Idaho. RESPONSE TO REQUEST NO.See PMT' s obj ections to Clear6 : Talk's First Set of Discovery Requests dated November 3, 2003. 7 :REQUEST NO.Please identify the wirecenter (s)through which you, including any affiliate (s), provide service. Please provide detailed map of forthe boundaries the wirecenter (s)identified response the foregoing question. Please specify when the foregoing wirecenter (s) was/were established. If the boundaries for the foregoing wirecenter (s)have been changed since the wirecenter (s)any way was / were changes originally established,identifyplease those any made,and when and why changes were made. Please provide a map of your network in the foregoing wirecenter (s) . Please provide a map showing your service coverage in the foregoing wirecenter (s) . Please identify,in terms of percentage of wirecenter area the theserviceextentyourcoverage foregoing wirecenter (s) . Please areasidentify wi thin the foregoingany wirecenter (s)where service is not currently provided by you. Please identify any plans you have to increase service the foregoing wirecenter (s)and the schedule for any planned improvements. receipt service for wirecenterUponrequest served location where notyouyou PMT's RESPONSE TO CLEAR TALK' FIRST SET OF DISCOVERY REQUESTS ~;;.. ii: 13 ~ ~ ...: ~ .:!: X ::. ~ 0 ~ ~ ::: S f;3 23 a ~ 0:: q ~:.. ~ :.. 16 ;:; c:: currently provide service,how long does take for you to provide service to that location? J .have any (i.e.,outstanding unfulfilled)you requests for service in the foregoing wirecenter (s) ? the the above question affirmative,answer please identify each request by location and date of request. have outstanding (i.e.,unfulfilled)you any requests for foregoing wirecenter (s) ,service in the please estimate when each request will be fulfilled. Please providedidentify the \\ local calling area (s)" to your customers in the foregoing wirecenter (s) . What is your average monthly revenue per customer for the foregoing wirecenter (s) . What is the average monthly revenue per customer for the foregoing wirecenter (s) without USF support? Have lost customers sincelinesyouanyaccess Clear Talk began offering service the foregoing wirecenter (s) ? access and/ orhavelostlines customersyouany since Clear Talk began offering theservlce foregoing wirecenter (s) please identify the number lines lost each such wirecenterforcustomers and when such lines and/or customers were reportedly lost. and/ or customershavelost Talk linesyouanyaccess slnce Clear beg an offering theservlce foregoing wirecenter (s) ,for each such wirecenter please provide copies of any documents or materials or analyses which reportedly attribute the loss of lines PMT's RESPONSE TO CLEAR TALK' FIRST SET OF DISCOVERY REQUESTS ;;.. ii: 13 ~ ~ ...: ~ f-~O .:!: X ;i ~ g df- ;::, ... eo: ~f- :.. 16a ~ ;:; 0:: c:: and/or the Clear Talkscustomerspresence wireless service. and/ or customershavelostlinesyouanyaccess since theClearTalkservicebeganoffering foregoing wirecenterwirecenter (s) ,for each such please provide copies of any documents or materials or analyses which reportedly attribute the lineloss of and/or the Clear Talk'customers presence wireless service. I temi ze capi tal expendi t ure s the foregoingyour wirecenter (s) in 2002 and 2003. RESPONSE TO REQUEST NO. a. Please see attached map. b. Dates indicate when each wirecentermap was establ ished. See PMT'obj ections Clear Talk'First Set Discovery Requests dated November 2003. See PMT'obj ect ions Clear Talk'First Set Discovery Requests dated November 2003. See PMT'obj ections Clear Talk'First Set Discovery Requests dated November 2003. See PMT'obj ections Clear Talk'First Discovery Requests dated November 2003. None. See PMT'obj ect ions Clear Talk'First Set Set Discovery Requests dated November 3 , 2003. i. The this depends the type andrequestanswerupon location of the "service request" j. No. k. Not appl icable. 1. Not applicable. PMT's RESPONSE TO CLEAR TALK' FIRST SET OF DISCOVERY REQUESTS ;;.. ii: 13 ~ ~ ...; g ,.. .:!: X :: . ~ c3 ~ ~ ~ ::: S ~ ~ d f-:'~ 0 eo: ~~ f- :.. 16a ~ ;:; 0:: c:: Toll free local call ing wi thin all wirecenters available the following local prefixes:219,300, 312 349,431,434 436 438,531 532 670,638 645 654 673 677 678,679,808 824 862,878. n. See obj ect ions SetPMT'Clear Talk'First Discovery Requests dated November 3 , 2003. o. See obj ect ions SetPMT'Clear Talk'First Discovery Requests dated November 3, 2003. p. See obj ections SetPMT'Clear Talk'First Discovery Requests dated November 3, 2003. obj ect ionsq. See PMT'Clear Talk'First Set Discovery Requests dated November 3, 2003. r. See obj ections SetPMT'Clear Talk'First Discovery Requests dated November 3, 2003. s. See obj ections SetPMT'Clear Talk'First Discovery Requests dated November 3 , 2003. REQUEST NO.9. Upon receipt service forrequest wirecenter location where currently providenotyou service please estimate the associated providingwithcosts service to such a location. RESPONSE TO REQUEST NO.It is impossible to answer this without typeknowingtherequest and locat ion the service request as well as other specifics concerning the same. REQUEST NO. 10:Please describe provide copies your policies or analyses for evaluating service requests for a location where service is not provided. RESPONSE TO REQUEST NO. 10:See attached tariff section REQUEST NO. 11:Please itemize the level of USF support that you receive for each month in 2003. RESPONSE TO REQUEST NO.11:See PMT's objections to Clear Talk's First Set of Discovery Requests dated November 3, 2003. PMT's RESPONSE TO CLEAR TALK' FIRST SET OF DISCOVERY REQUESTS ~;;.. ii: 13 ~ ~ ~ ~ ~ c .:!: X . ~ 0 ..::~ ~ ::: S ~ Z d f-:'0:: c:: . ,." ~ 0:... ~ t: ~ .:!: ~ 0:: REQUEST NO. 12:Please identify the percentage of your NO. subscribers for which you receive USF support. study area receive RESPONSE REQUEST customers federall n our Service Fund support. REQUEST NO. 13: 12 :100% agreements that are not Do you have any Idaho publicly available Public Utilities Commission? RESPONSE TO REQUEST NO. 13: REQUEST NO.14 :you that are not publiclyagreements Public Utilities Commission interconnection agreement (s) . RESPONSE TO REQUEST NO. 14: REQUEST NO. 15:Please long distance products and customers. RESPONSE REQUEST NO. Distance to our customers for 14 cents per minute. andpackagesavailableforare discounted plans. REQUEST NO. 16: No. have any Idaho our 8256 ILEC available please provide federal Universal interconnection through the Idaho Not applicable. provide details interconnection through the Idaho services that you copies such 15 :offer regarding the monthly fee offer your Domestic Long Additional for bundled other carrier Have you ever been approached by Clear wirelessTalkany service in Idaho? RESPONSE TO REQUEST NO. 16: REQUEST NO. 17: question affirmative,did service? RESPONSE TO REQUEST NO.7 : PMT's RESPONSE TO CLEAR TALK' FIRST SET OF DISCOVERY REQUESTS cooperati vely Yes. your answer you decide Yes. offer the foregoing offer wireless ~;;.. ii: 13 ~ ~ ~ ~ ~ c .:!: X :: . ~ ...:: .:!: ~ ~ :: s ~ z 0:: c:: Co? !:;~ ~ :.. ~ ~f- .:!: 0:: c:: REQUEST NO. 18:the foregoingansweryour question negative please explain why you decided against trying to offer wireless service. RESPONSE TO REQUEST NO. 18:Not applicable. REQUEST NO. 19:accessWhat products andInternet services do you offer to your customers. RESPONSE TO REQUEST NO.Dial-up,High speed Wireless19 : and DSL access. REQUEST NO. 20:What access products andInternet services do you plan to offer within the next 12 months to your customers? RESPONSE TO REQUEST NO. 20:See PMT' s obj ections to Clear Talk's First Set of Discovery Requests dated November also see response to Response to Request No. 19. 2003, REQUEST NO. 21:Are you affiliated in any way with any company (ies) that have applied for designation as a competitive wireless Eligible Telecommunications Carrier in any jurisdiction wi thin the United States? RESPONSE TO REQUEST NO. 21:No. REQUEST NO. 22:If you are affiliated in any way with company (ies)that have appl ied for designationany competi ti ve , wireless Eligible Telecommunications Carrier in any jurisdiction company (ies)your wi thin the United please identify the the States, and describe relationship with company (ies) RESPONSE TO REQUEST NO. 22:Not applicable. REQUEST NO. 23:If you are affiliated in any way with any company (ies)that have applied designationfor competi ti ve , wireless Eligible Telecommunications Carrier in any jurisdiction wi thin the Uni ted please identify theStates, applying entity,the authority to which the application (s)was PMT's RESPONSE TO CLEAR TALK' FIRST SET OF DISCOVERY REQUESTS ;;.. ii: 13 ~:;;: ...: ~ f- ~ 0 ..:: x . ~ ...:: ~~ ~ := s t::f-:'--Cf- :.. ~ f- :....:: ;:; 0:: c:: made,the date (s)each application identifying docketany number (s) ,the status of the application proceeding, and whether or not ETC designation has been granted. RESPONSE TO REQUEST NO.3 :Not applicable. REQUEST NO. 24:any company (ies)affiliatedyou with you have applied for designation as a competitive, wireless El igible in any jurisdiction withinTelecommunicationsCarrier the United States, please identify the technology being used, or proposed to be used, of ETCs. to provide the supported services required RESPONSE TO REQUEST NO.4 :No. company (ies)REQUEST NO. 25:affiliatedyouany wi th you have applied for designation as a competitive, wireless El igible Telecommunications Carrier In any jurisdiction wi thin the Uni ted please identifyStates the charges,proposed charge s levied against for the wirelesscustomers universal service offering (s) . RESPONSE TO REQUEST NO.5 :Not applicable. Please identify vendor (s)REQUEST NO.all that26 : provide switching services and/or infrastructure to you. RESPONSE TO REQUEST NO.6 :Syringa Networks , LLC. Please any,identify your efforts,REQUEST NO. 27: in 2002 expand itsand 2003 and/ or to reduce costs,improve service, network offer products servicesandnew your customers. RESPONSE TO REQUEST NO.7 :See PMT' s obj ections to Clear Talk's First Set of Discovery Requests dated November 3, 2003. REQUEST NO. 28:Please provide copies of any memoranda, meeting efforts emails other communications regardingnotes,your reduce improve service,expand your networkcosts, PMT's RESPONSE TO CLEAR TALK' FIRST SET OF DISCOVERY REQUESTS ;;.. ii: 13 :;;: ~ : g ,.. z ~ x . ~ 0 ~ ~ ::: S f;3 23 0 ~0:: q ~:.. ~ ;:; c:: and/or offer new products and services to its customers in 2002 and 2003. RESPONSE TO REQUEST NO.28 :See PMT' s obj ections to Clear Talk's First Set of Discovery Requests dated November 3, 2003. REQUEST NO. 29:Please provide copies and documentation any telephoneallcommunication (s) ,including notes conversations,PUCbetween you and the Idaho regarding Clear Talk's ETC Application. RESPONSE TO REQUEST NO. 29:None, other than the pleadings on file in these proceedings. REQUEST NO. 30:Please provide copies and documentation all communication (s) ,incl uding any telephonenotes conversations between and the Idaho regarding thePUCyou designation of competi ti ve El igible Telecommunications Carriers. RESPONSE TO REQUEST NO.30 :See Response to Request No. 29. REQUEST NO. 31:To the extent that you obj ected to any prior applications and/or stipulations regarding ETC designation between the Idaho PUC and any wireless carrier (s), please state all objections raised by you with respect to the stipulation(s) RESPONSE TO REQUEST NO. 31:Not applicable (none). REQUEST NO. 32:Please provide copies of the documents relating to your decision to challenge Clear Talk's Application for ETC limited managemen t designation in the Idaho,incl uding butstate not memorandums board director minutes, presentations, forecasts. andcorrespondencefinancialandanalysis RESPONSE TO REQUEST NO.32 :See PMT's objections to Clear Talk's First Set of Discovery Requests dated November 3, 2003. Please provide copies ofREQUEST NO. 33:the documents relating to your decision to request and/or accept designation PMT's RESPONSE TO CLEAR TALK' FIRST SET OF DISCOVERY REQUESTS ;;.. ii: 13 ~:;;: ~ ~ g 0 ':;: r- .,. . ~ ~ ~ ~ := s 15 ~ ~ q ~~ ~ :.. ~ .:!: ;:; 0:: c:: as an ETC in the state of Idaho incl uding but not 1 imi ted to memorandums,managementboarddirectorminutes, presentations, forecasts. andcorrespondenceandfinancialanalysis RESPONSE TO REQUEST NO.3 :See PMT' s obj ections to Clear Talk's First Set of Discovery Requests dated November 3, 2003. REQUEST NO. 34:Please provide copies of your financial statements for the six months ended June 30,2003 and audited financial statements for the fiscal years 2002 , 2001 , and 2000. RESPONSE TO REQUEST NO. 34:See PMT's objections to Clear Talk's First Set of Discovery Requests dated November 3, 2003. REQUEST NO. 35:Please provide copies of your state Idaho income tax reports for the fiscal year 2002. RESPONSE TO REQUEST NO.5 :See PMT' s obj ections to Clear Talk's First Set of ~covery Requests dated November 3, 2003. DATED this lIay of November , 2003. bert M. Nie At torney for proj ect Mutual Telephone Cooperative Association, Inc. PMT's RESPONSE TO CLEAR TALK' FIRST SET OF DISCOVERY REQUESTS . . PROJEC'I ;.'tJAL TELE:'ii ~;NE COOPERATIVE ASSOCIATION, INC. LCC:.L EXCHANGE TARIFF Effective:~ober 1, 1994 GENERJ\ L EXCHANGE SERVI CES SECTION 4 CONSTRUCTION CHARGES cant I Estimated construction charges :ire payable in advance and will be finalized upon completion of tL~ construction. The type of construction will be determined by the Company. The customer will be required to pay the additional costs involved if he requests a different type of construction than that proposed by the Company. Construction charges include , but are not limited to , trenching, cable pole setting, labor costs , splicing, all costs associated wi th easements and the securin~, clearing, & retaining of right-of- way. Where builders or developer~ require advance construction of facilities for the anticipated use of others , a guarantee or payment bond satisfactory to the company to cover the cost of such construction, may be required before construction work is started. Construction charges will include only those costs incurred by the Company. 4-2 ... .. ...... ..' .. - . PROJE, ;' hU i L'AL TELEPHONE COOPERATIVE 1\S~30CIATION , INC. LOCAL EXCHANGE TARIFF Effective:October 1 , 1994 GENERAL EXCHANGE SERVICES SECTION 4 CONSTRUCTION CHARGES NElv SERVICE Constructio~ charges related to requests for new service willapply for (~';lstruction in excess of one mile , where such service is 12termined to be for a permanent facility. 2 )OFF-PREMI~:'' :=XTENSION CONSTRUCTION Constructio~ charges related to off-premise extensions will apply for c~nstruction in excess of one-quarter mile, where such extens:cn is determined by the company to be for apermanent fac~lity. 3 )TEMPORARY COnSTRUCTION When construction is required for temporary service (for a period less than 1 year) and there is no immediate prospect (within 6 months of service disconnection) of reusing the plant provided , the customer will be required to bear all of the cost of such construction. 4 )SPECIAL CONSTRUCTION OR MODIFICATIONS TO EXISTING TELEPHONE FACILITIES ~\Then a cust:~er requests special construction or rearrangement of facilities, the customer will be required to bear all of the cost of such construction. Where custo~er-provided telephone systems and facilities within a bu:lding or structure are to be interconnected with Company pro~'~ded facilities , the Company will provide an electrically protected interconnection arrangement conforming to FCC regu:a~ions at a point agreeable to the customer and the Company. The customer will be responsible for the costs associated ~i~h installing the interconnection arrangement. 4-1 ;;.. ii: 13 ~ ~ ~ ~ ~ c z ~ x . ~ 0 ~ ~ ::: S ~ ~ d f-:'f;3 c eo: c::~ f- g: 160 ~ ;:; 0:: c:: Robert M. Nielsen , Esq. Attorney at Law 548 E Street P . O. Box 706 Rupert, Idaho 83350 Telephone: (208) 436-4678Facsimile: (208) 436-0551 ISB# 1335 Attorney for Project Mutual Telephone Cooperative Association, Inc. RECEiVED 0fILED 2003 NOY 12 AM 9: 2 J 10J",I-jO PUBLIC UTILITIES COf1MISSION BEFORE THE IDAHO PUBLIC UTILITIES COMMISSION IN THE MATTER OF THE PETITION OF IAT) COMMUNICATIONS , INC., d.a. NTCH- IDAHO , INC., OR CLEAR TALK , FOR DESIGNATION AS AN ELIGIBLE TELECOMMUNICATIONS CARRIER. IN THE MATTER OF THE APPLICATION OF NPCR , INC., DBA NEXTEL PARTNERS SEEKING DESIGNATIONS AS AN ELIGIBLE TELECOMMUNICATIONS CARRIER. Case No. GNR-T- 03 - 08 Case No. GNR-03- NOTICE OF SERVICE OF PMT' S RESPONSE TO CLEAR TALK' FIRST SET OF DISCOVERY REQUESTS COMES NOW , proj ect Mutual Telephone Cooperative Association Inc., by and through its attorney of record, Robert M. Nielsen and pursuant to The Idaho Public Utility Commission Rules of Procedure, hereby notifies the Commission that on the date below SET the stated he served a copy of PMT'S RESPONSE TO CLEAR TALK'S FIRST DISCOVERY REQUESTS addresses and methods listed below: NOTICE OF SERVICE OF PMT'S RESPONSE TO CLEAR TALK' FIRST SET OF DISCOVERY REQUESTS following theattorneys ;;.. ii: 13 ~ ~ ...: ~ f- ~ c .:!: X :i ~ g z - -,." d f-:'c::::;::: ,." '"' eo: ~ ~ t: :.. 16 .:!: ;:; 0:: ::::: Jean Jewell Idaho Public Utilities Commission 472 W. Washington Street P . O. Box 83 72 0 Boise , ID 83720-0074 (208) 334-3762 (Fax) Molly O'Leary, Esq. Richardson & 0' Leary, PLLC 99 E. State Street, Suite 200 Eagle , ID 83616 n~C2~..!iris:~~S2nan~ole ary, com Sean P. Farrell , Esq. IAT Communications , Inc. NTCH- Idaho Inc., dba Clear Talk 703 pier Avenue , Suite B , PMB 813 Hermosa Beach , CA 90254 Dean J. Miller , Esq. 420 West Bannock P . O. Box 2564 - 8 3 7 0 1 Boise , ID 83702 (208) 336-6912 (Fax) ~~)mcj.e t -=-- mi 1 ~~com Philip R. Schenkenberg, Esq. 2200 First National Bank Building 332 Minnesota Street Saint Paul , MN 55101 ~j~nkenberg~briggs. com Morgan W. Richards Moffatt , Thomas , Barrett , Rock &Fields 101 S. Capitol Blvd., lo th Floor P . O. Box 82 Boise, ID 83701-0829 (208) 385-5384 (Fax) mwr0!moffatt. com Mary S. Hobson Stoel Rives LLP 101 S. Capitol Blvd , Suite 1900 Boise, ID 83702-5958 (208) 389-9010 (Fax) mshobson~stoel. com ........-----....---................----- (x) U. S. Mail , Postage ) Hand Delivered ) Overnight Mail (x) Facsimile ) Electronic Mail ) U: S. Mai 1, Pos tage ) Hand Delivered ) Overnight Mail ) Facsimile (x) Electronic Mail (x) U.S. Mail , Postage ) Hand Delivered ) Overnight Mail ) Facsimile ) Electronic Mail ) U.S. Mail , Postage ( ) Hand Delivered ) Overnight Mail ) Facsimile (x) Electronic Mail ) U.S. Mail , Postage ) Hand Delivered ) Overnight Mail ) Facsimile (x) Electronic Mail ) U.S. Mail , Postage ) Hand Delivered ) Overnight Mail ) Facsimile (x) Electronic Mail ) U.S. Mail , Postage ) Hand Delivered ) Overnight Mail ) Facsimile (x) Electronic Mail NOTICE OF SERVICE OF PMT'S RESPONSE TO CLEAR TALK' FIRST SET OF DISCOVERY REQUESTS Prepaid Prepaid Prepaid Prepaid Prepaid Prepaid Prepaid Z, ii: 13 ~ ~ .... ~ Z ~ ; ..:: x.,.: ;:.- d ;;;~ ~ ::: = I-. z :::: ~ ~ ~ :.. ~ :;: c::: ,." Lance A. Tade, Manager State Government Affairs Ci tizens Telecommunications Company of Idaho 4 Triad Center , Suite 200 Sal t Lake City, UT 84180 1 tade(i.iiczn. com Conley Ward Gi vens Pursley LLP 277 North 6th Street, P . O. Box 272 Boise, ID 83701 (208) 388-1300 (Fax) ~~~~g y~~~p~~~~~~S~~ Suite 200 John Hammond, Deputy AG Idaho Public Utilities Commission 472 West Washington Street Boise , ID 83720-0074 (208) 334-3762 (Fax) jJ1 ~~~ ~~d(~12~~~__~t~d. Clay Sturgis , Senior Manager MOSS ADAMS LLP 601 Riverside , Suite 1800 Spokane , WA 99201-0063 clays~mossadams. com Charles H. Creason , Jr. President & General Manager proj ect Mutual Telephone Cooperative Association , Inc. 507 G Street P . O. Box 3 6 6Rupert, ID 83350 ccreason02pmt . coop ) U.S. Mail , Postage ) Hand Delivered ) Overnight Mail ) Facsimile (x) Electronic Mail ( ) U.S. Mail , Postage ) Hand Delivered ) Overnight Mail ) Facsimile (x) Electronic Mail ) U.S. Mail , Postage ) Hand Delivered ) Overnight Mail ( ) Facsimile (x) Electronic Mail ) u. S. Mai 1 , Pos tage ) Hand Delivered ) Overnight Mail ) Facsimile (x) Electronic Mail ( ) u. S. Mail , Postage ) Hand Delivered ) Overnight Mail ) Facsimile (x) Electronic Mail NOTICE OF SERVICE OF PMT'S RESPONSE TO CLEAR TALK' FIRST SET OF DISCOVERY REQUESTS Prepaid Prepaid Prepaid Prepaid Prepaid ~;;.. ii: 13 ~ ~ ...: ~ f- ~ .,. .:!: X . ~ c ~ ~ ::: S ~ ~ d f-:'~ 0 eo: ~f- :.. 160 ~ 0:: c:: DATED this loth day of November, 2003 . NOTICE OF SERVICE OF PMT'S RESPONSE TO CLEAR TALK' FIRST SET OF DISCOVERY REQUESTS MAPS WERE IN CL UD ED IN THIS FIL IN G ARE IN THE FILE