20110330TFW to Joint Request 51.pdf

McDevitt & Miller LLP
Lawyers
RECE r,
[phone]
[phone] (Fax)
420 W. Bannock Street
P.O. Box 2564-83701 2011 MAR 30 AM 10: 58 Chas. F. McDevitt
Boise, Idaho 83702 Dean J. (Joe) Miler
March 30, 2011
Vïa Hand Delivery
Jean J ewell Secreta
Idaho Public Utities Cotnssion
472 W. Washigton St.
Boise, Idaho 83720
Re: In the Matter of the Application of TracFone Wireless
TFW- T -09-01
Dear Ms. Jewell:
Enclosed for fig, please fid thee (3) copies of TracFone Wireless, Inco's Responses to Second
Joint Production Request of the Idaho Telecom Alnce and CTC Telecom, Inc., dba CTC
Wireless.
Kidly retu a fie stamped copy to me.
Very Truy Yours,
McDevitt & Mier lL
~~
DJM/hh
End.
COpy
Dean J. Miler (ISH No. 1968)
McDEVITT & MILLER LLP
420 West Banock Street
P.O. BOX 2564-83701
Boise, Idaho 83702
Tel: [phone]
Fax: [phone]
ioe~mcdevitt-miler.com
REi'cIVr:r'!l' ,,' vt".; ¡ :\" ~,";r
to! i lUR 30 AM 10: 59
Mitchell F. Brecher (Pro Hac Vice)
Debra McGuire Mercer
GREENBERG TRAURIG, LLP
2101 L Street, NW, Suite 1000
Washington, D.C. 20037
Tel: [phone]
Fax: [phone]
brecherm~gtaw.com
mercerdm~gtiaw.com
Attorneys for TracFone Wireless, Inc.
BEFORE THE IDAHO PUBLIC UTILITIES COMMISSION
IN THE MATTER OF THE APPLICATION
OF TRACFONE WILESS, INC. FOR
DESIGNATION AS AN ELIGIBLE
TELECOMMUICATIONS CARER.
) CASE NO. TFW-T-09-01
)
) TRACFONE WIRELESS, INC.'S
) RESPONSES TO SECOND
) JOINT PRODUCTION
) REQUEST OF THE IDAHO
) TELECOM ALLIANCE AN
) CTC TELECOM, INC., DBA
) CTC WILESS
RESPONSE TO REQUEST NO. 51
TRACFONE WIRELESS, INC.'S RESPONSES TO SECOND JOINT PRODUCTION REQUEST OF THE
IDAHO TELECOM ALLIANCE AND CTC TELECOM, INC., DBA CTC WlRELESS-l
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 offces, 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 inormation 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 partcipated 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 summariing,
confirming or in any manner referrig to said communication.
RESPONSE
In 2010, TracFone employed Mr. Phil Reberger of the firm Sullivan, Reberger and
Eiguen, located in Boise, Idaho as its public afairs representative in Idaho. TracFone engaged
that firm for the purose of obtaining support from elected officials, including Governor C.L.
"Butch" Otter for TracFone's application for designtion as an Eligible Telecommunications
Carer for the purose of providig Lifeline servce to low-income Idaho households.
At TracFone's request, Mr. Reberger orally contacted the offce of Governor C.L."Butch" Otter to explain TracFone's pending Application at the Commission. Mr. Reberger
solicited a supporting letter. Governor Otter's letter, filed with the Commission on April, 19
2010, followed.
Similarly, Mr. Reberger, or a member of his firm, orally contacted Representative Wendy
Jaquet for the same purose. Representative Jaquet's letter, fied with the Commission on May
14,2010, followed.
After fuer investigation, TracFone has leared that Mr. Reberger is curently traveling
outside the United States and is unavailable to provide additional detal regarding his
communcations with Governor Otter and Representative Jacquet on behalf of TracFone.
RESPONDENT: Jose Fuentes, Director of Govemment Relations, [phone].
TRACFONE WIRELESS, INC.'S RESPONSES TO SECOND JOINT PRODUCTION REQUEST OF THE
IDAHO TELECOM ALLIANCE AND CTC TELECOM, INC., DBA CTC WlRELESS-2
CERTIFICATE OF SERVICE
I hereby certify that on the mty of March, 20 I I, I caused to be served, via the
methodes) indicated below, tre and correct copies of the foregoing document, upon:
Jean Jewell, Secreta
Idaho Public Utilties Commission
472 West Washington Street
P.O. Box 83720
Boise,ID 83720-0074
iiewellwuc.state.id. us
Neil Price, Esq.
Idaho Public Utilties Commission
472 West Washington Street
P.O. Box 83720
Boise,ID 83720-0074
Neii.Price~puc.idaho.gov
Molly O'Lear, Esq.
Richardson & O'Lear, PLLC
P.O. Box 7218
Boise, ID 83707
molly~richardsonandolear.com
Cynthia A. Melilo, Esq.
Givens Pursley LLP
601 N. Banock Street
P.O. Box 2720
Boise, ID 8370 I
cam~givenspursley.com
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TRACFONE WIRELESS, INC.'S RESPONSES TO SECOND JOINT PRODUCTION REQUEST OF THE
IDAHO TELECOM ALLIANCE AND CTC TELECOM, INC., DBA CTC WIRLESS-3