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Home My WebLink About20110309Joint ITA-CTC 51 to TFW.pdf(~E\ Cynthia A. Melilo (ISB No. 5819) GIVENS PURSLEY LLP 601 West Bannoc Stret P.O. Box 2720 Boise, 1083701 Telephone: (208) 388-1200 Facsimile: (208) 388-1300 E-Mail: camtmgivenspursley.com Attorneys for Idaho Telecom AJlance LOti MAR -9 Pt\ 2: 18 Molly O'Leary (ISB No. 4996) Richardson & O'Leary PLLC 515 North 27th Street P.O. Box 7218 Boise, 1083707 Telephone: (208) 938-7900 Facsimile: (208) 938-7904 E-Mail: mollyt§richardsonandoleary.com Attorneys for CTC Telecom, fnc. BEFORE THE IDAHO PUBLIC SERVICE COMMISSION IN THE MATTR OF THE APPLICATION OF APPLICANT TRACFONE WIRELESS, INC. FOR OESIGNA TION AS AN ELIGIBLE TELECOMMUNICATIONS CARRIER CASE NO.: TFW-T-09-01 SECOND JOINT PRODUCTION REQUEST OF THE IDAHO TELECOM ALLIANCE AND CTC TELECOM, INC., DBA CTC WIRELESS, TO TRACFONE WIRELESS, INC. The Idaho Telecom Allance, by and through its attrney of record, Givens Pursley LLP, and CTC Telec, Inc., dba CTC Wireless (formerly dba Snake River PCS), by and through its attorney of record, Richardson & O'leary, PLLC, jointly request that TracFone Wireless, Inc. ("TracFone") provide the following documents and information as soon as possible, but no later than twnty-one (21) days from the date of service hereof, in accordance with 10APA 31.01.01.225.03. SECOND JOINT PRODUCTION REQUEST OF THE IDAHO TELECOM ALLIANCE AND eTO TELECOM, INC., OBA eTC WIRELESS, TO TRACFONE WIRELESS, INC. -1 TFW- T -09-01 This Production Request is to be considered continuing, and TracFone is requested to provide, by way of supplementary responses, additional documents that it or any person acting on its behalf may later obtain that wil augment the documents produced. Please provide answers to each question, supporting workpapers that provide detail or are the source of information used in calculations and the name, job title and telephone number of the person preparing the documents. Please identify the name, job title, location and telephone number of the record holder. Please provide all Excel and electronic files on CD with formulas activated. REQUEST NO. 51. Please provide copies of all communications (whether oral, written or otherwise) with Governor C.L. "Butch" Otter and Representative Wendy Jaquet, and/or anyone in their respective offices, that have not otherwise been published on the Commission's website. A request for the description of oral communications shall be deemed to include a request for the following information with respect to each of said oral communications: 1. The date and place of such communication. 2. Whether said communication was in person or by telephone. 3. A description of each person who participated in or heard of said communication. 4. The substance of what was said by each person who participated in said communication. 5. A chronological description of all documents or recordings summarizing, confirming or in any manner referring to said communication. SECOND JOINT PRODUCTION REQUEST OF THE IDAHO TELECOM ALLIANCE AND CTC TELECOM, INC., DBA CTC WIRELESS, TO TRACFONE WIRELESS, INC. - 2 TFW-T-09-01 DATED this 9th day of March 2011. GIVENS PURSLEY LLP Cyn la A. Melilo Attorneys for Idaho Telecom Allance RICHAROSON & O'LEARY, PLLC ¡J iL lJ~ L~ry I Attorneys for CTC Telecom, Inc., dba CTC Wireless SECOND JOINT PRODUCTION REQUEST OF THE IDAHO TELECOM ALLIANCE AND CTC TELECOM, INC., DBA eTC WIRELESS, TO TRACFONE WIRELESS, INC. - 3 TFW-T -0-01 CERTIFICATE OF SERVICE I HEREBY CERTIFY that on the 9th day of March 2011, l caused to be served a true and correct copy of the foregoing by the method indicated below, and addressed to the following: Jean Jewell Idaho Public Utilities Commission 472 West Washington Street Boise, ID 83702 jean.jeweiicapuc.ldeho.gov Mitchell F. Brecher Debra McGuire Mercer GREENBERG TRAURIG, LLP 2101 L Street, NW, Suite 1000 Washington, DC 20037 brechermt§gtlaw.com mercerdmcagtlaw.com Dean J. Miler McDEVlTI & MILLER LLP 420 West Bannock Street Boise, 10 83702 ;oet§mcdevitt-miJer.com D U.S. Mail D Overnight Mail D Hand Delivery DFax ~ Electronic Mail DU.s. Mail D Overnight Mail D Hand Delivery DFax ~ Electronic Mail D U.S. Mail D Overnight MaiJ D Hand Oelivery DFax (g Electronic Mail .1~~cyntia A. Melillo SECOND JOINT PRODUCTION REQUEST OF THE IDAHO TELECOM ALLIANCE AND CTC TELEeOM, INC., DBA CTC WIRELESS. TO TRACFONE WIRELESS, .NC. - 4 TFW-T-09-D1