200403291st Request of Staff to OCMC.pdf

JOHN HAMMOND
DEPUTY ATTORNEY GENERAL
IDAHO PUBLIC UTILITIES COMMISSION
PO BOX 83720
BOISE, IDAHO 83720-0074
[phone]
BAR NO. 5470
Street Address for Express Mail:
472 W. WASHINGTON
BOISE, IDAHO 83702-5983
Attorney for the Commission Staff
RECEIVED
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BEFORE THE IDAHO PUBLIC UTILITIES COMMISSION
IN THE MATTER OF STAFF'S PETITION
TO INITIATE A COMMISSION
INVESTIGATION TO DETERMINE IF
OCMC, INc. VIOLATED THE TERMS OF
ITS PRICE LIST AND THE COMMISSION'
0 PERA TO R SER VI CES AND PAY
TELEPHONE RULE 104.
CASE NO. GNR-04-
FIRST PRODUCTION REQUEST
OF COMMISSION STAFF TO
OCMC, INc.
The Staff ofthe Idaho Public Utilities Commission, by and through its attorney of record
John Hammond, Deputy Attorney General, requests that OCMC, Inc. (Company) and any of its
affiliates doing business in the state of Idaho provide the following documents and information
on or before April 12, 2004.
The Company is reminded that responses pursuant to Commission Rules of Procedure
must include the name and phone number of the person preparing the document, and the name
location and phone number of the record holder. See IDAP A 31.01.01.228.
This Production Request is to be considered as continuing, and OCMC, Inc. is requested
to provide, by way of supplementary responses, additional documents that it or any person acting
on its behalf may later obtain that will augment the documents produced.
FIRST PRODUCTION REQUEST
OF COMMISSION STAFF TO
OCMC , INC.MARCH 29, 2004
The answers to each question should be responded to in relation to the operator services
OCMC and its affiliates provide on an intrastate basis in Idaho. Intrastate includes all
intraLATA and interLATA calls handled by OCMC or its affiliates
Please provide answers to each question; supporting workpapers that provide detail or are
the source of information used in calculations; the name and telephone number of the person
preparing the documents; and the name, location and telephone number of the record holder.
For each item, please indicate the name of the person(s) preparing the answers, along
with the job title of such person(s) and the witness who can sponsor the answer at hearing. For
all responses to the following requests, please provide all workpapers on diskettes (3.5 in.
and/or CDs and all underlying formulas in Excel (version 5) language.
Request No.1: Please provide price lists in effect in Idaho for Title 62 intrastate
services between the dates of March 15 2002 and July 29 2003 for OCMC, One Call
Communications, Inc., OPTIC OM, Inc., AdvanTel, LiveTel, SuperTel, RegionTel or 1-800-
MAX-SAVE or any other affiliates in Idaho.
Request No.2: Please provide the total number of intrastate (includes both intraLATA
and interLATA) collect calls that OCMC or its affiliates provided either live or automated
operator services for between March 15 , 2002 until July 29 2003.
Request No.3: Please provide the total amount of gross revenues OCMC received for
the calls identified in Request No.
Request No.4: Please provide copies of any contractual agreements OCMC has had
with third party billing agents, such as ZPDI between March 15 2002 until present. If such
contracts do not include the terms under which the third party is authorized to resolve disputes
with OCMC customers, then please also provide documentation of such terms.
Request No.6: Please provide a comprehensive list of all payphones for which OCMC
or its affiliates is the designated or presubscribed OSP in Idaho.
FIRST PRODUCTION REQUEST
OF COMMISSION STAFF TO
OCMC, INC.MARCH 29, 2004
Request No.7: Please provide documentation concerning any pending litigation before
any federal or state forum involving OCMC or any of its affiliate or agents concerning its
possible non-compliance with OSP price/rate disclosure rules. In addition, please provide all
consent agreements, stipulations or settlement documents entered into by OCMC, its affiliates or
agents meant to settle issues of compliance OSP with price/rate disclosure rules in any federal or
state forum since January of 1996.
Request No.8: Please provide documentation on all complaints and inquiries OCMC
its affiliates or its agents received between March 15 2002 and July 29 2003 regarding OSP
services that OCMC or its affiliates provided to Idaho consumers on intrastate collect calls that
were processed between March 15 2002 and July 29 2003. Please provide the information
responsive to this request in the format provided to Staffby e-mail from counsel for OCMC on
February 13, 2004 and
a) Provide a definition for any descriptive code used.
b) Describe the reasons that justified OCMC, its affiliates or agents providing a credit to
those complaining customer who received one.
c) Describe the reasons that justified OCMC, its affiliates or agent's decision to not
provide a credit to a particular complaining customer.
Request No.9: Please provide copies of all correspondence sent to the Idaho Public
Utilities Staff regarding possible violations of Rule 104.04. Specifically, Staff requests that the
Company provide copies of the following:
1) Letter sent to Wayne Hart by Laura Clore of OCMC on July 16, 2003.
2) Letter and attachments sent to John Hammond by Joe Miller on October 1 2003.
Request No. 10: Please provide copies of all screens, dialogs, training manuals and any
other materials used by live operators in providing operator services for collect calls and the time
when the above were implemented by OCMC.
FIRST PRODUCTION REQUEST
OF COMMISSION STAFF TO
OCMC, INC.MARCH 29, 2004
Request for Admission No.1: Admit that OCMC, its affiliates or agents did not request
an exemption from the application of Rule 104.04 of the Commission s Operator Service and
Payphone Rules for the period of time between March 12, 2002 and July 29 2003.
Dated at Boise, Idaho, this J) r day of March 2004.
ond
ttorney General
Technical Staff: Wayne Hart
bls/M:GNRTO404jh3 _Production Request
FIRST PRODUCTION REQUEST
OF COMMISSION STAFF TO
OCMC, INC.MARCH 29, 2004
CERTIFICATE OF SERVICE
I HEREBY CERTIFY THAT I HAVE THIS 29th DAY OF MARCH 2004, SERVED
THE FOREGOING FIRST PRODUCTION REQUEST OF THE COMMISSION STAFF
TO OCMC. INc., IN CASE NO. GNR-04-BY MAILING A COpy THEREOF
POSTAGE PREPAID , TO THE FOLLOWING:
ANN C. BERNARD
OCMC, INC.
80 I CONGRESSIONAL BLVD.
CARMEL, IN 46032
E-mail: ann.bernard(fl),ocld.com
DEAN 1. MILLER
McDEVITT & MILLER, LLP
420 W. BANNOCK STREET
PO BOX 2564 - 83701
BOISE, ID 83702
E-mail: joe(fl),mcdevitt-miller.com
CT CORPORATION
300 N. 6TH STREET
BOISE, ID 83702
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SECRETARY
CERTIFICATE OF SERVICE