20110315Staff 32-33 to TFW.pdf

NEIL PRICE
DEPUTY ATTORNEY GENERAL
IDAHO PUBLIC UTILITIES COMMISSION
PO BOX 83720
BOISE, IDAHO 83720-0074
[phone]
ISB NO. 6864
j~
201 H;r\R 15 PM I: l 8
Street Address for Express Mail:
472 W. WASHINGTON
BOISE, IDAHO 83702-5983
Attorney for the Commission Staff
BEFORE THE IDAHO PUBLIC UTILITIES COMMISSION
IN THE MATTER OF THE APPLICATION
OF TRACFONE WIRELESS, INC. FOR
DESIGNATION AS AN ELIGIBLE
TELECOMMUNICATIONS CARRER.
)
) CASE NO. TFW-T-09-01
)
)
) SECOND PRODUCTION
) REQUEST OF THE
) COMMISSION STAFF TO
) TRACFONE WIRELESS, INC.
)
The Staff of the Idaho Public Utilties Commission, by and through its attorney of record,
Neil Price, Deputy Attorney General, requests that TracFone Wireless, Inc. (Company; TracFone
Wireless) provide the following documents and information as soon as possible, but no later than
THURSDAY, MARCH 17,2011.
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 and if different the witness who can sponsor the
answer at hearing if need be. Reference IDAPA 31.01.01.228.
This Production Request is to be considered as continuing, and TracFone Wireless 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.
SECOND PRODUCTION REQUEST
TO TRACFONE WIRELESS 1 MARCH 15,2011
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 e,lectronic files on CD with formulas activated.
REQUEST NO. 32: In response to the ITA and CTC's Production Request No. 38,
TracFone states that it relies on a third-pary vendor to validate addresses included on SafeLink
Wireless Lifeline service application. Please identify the third-party vendor and list the services
that wil be provided by the vendor.
REQUEST NO. 33: In response to the ITA and CTC's Production Request No. 39,
TracFone state's that it is allowed to provide service to more than one person at the same
address, only if the address has been flagged intentionally through the "Shelter's Enrollment
Process." Please explain the Shelter's Enrollment Process and provide a copy of the document
that authorizes this process.
DATED at Boise, Idaho, this it; day of March 2011.
N~~ %,(f~Deputy Attorney General
Technical Staff: Grace Seaman
i:umisc:prodreqltfw9.lnpgs prod req2
SECOND PRODUCTION REQUEST
TO TRACFONE WIRELESS 2 MARCH 15,2011
CERTIFICATE OF SERVICE
I HEREBY CERTIFY THAT I HAVE THIS 15TH DAY OF MARCH 2011,
SERVED THE FOREGOING SECOND PRODUCTION REQUEST OF THE
COMMISSION STAFF TO TRACFONE WIRELESS, INC., IN CASE NO.
TFW-T-09-01, BY EMAIL AND MAILING A COPY THEREOF, POSTAGE PREPAID,
TO THE FOLLOWING:
MITCHELL F. BRECHER
DEBRA MCGUIRE MERCER
GREENBERG TRAURIG, LLP
2101 L STREET NW SUITE 1000
WASHINGTON DC 20037
E-mail: brechermßYgtlaw.com
mercerdmßYgtlaw.com
RICHARD B. SALZMAN
TRACFONE WIRELESS INC
9700 NW 11 TH AVENUE
MIAMI, FL 33178 ~
E-mail: rsalzmanßYtracfone.com
MOLLY O'LEARY
RICHARDSON & O'LEARY
PO BOX 7218
BOISE ID 83707
E-mail: mollyßYrichardsonandolear.com
CYNTHIA A MELILLO
GIVENS PURSLEY LLP
PO BOX 2720
BOISE ID 83701
E-mail: camrggivenspursley.com
~~
SECRET Y
CERTIFICATE OF SERVICE