U-14678 VZW Motion to Compel by li3490

VIEWS: 64 PAGES: 34

									                                               212 East Grand River Avenue
                                                Lansing, Michigan 48906
                                        Tel. (517) 318-3100 ▪ Fax (517) 318-3099
                                                    www.clarkhill.com


Haran C. Rashes
Phone: (517) 318-3019
E-Mail: hrashes@clarkhill.com
                                                November 9, 2005

BY HAND DELIVERY

Ms. Mary Jo Kunkle
Executive Secretary
Michigan Public Service Commission
6545 Mercantile Way
PO Box 30221
Lansing, MI 48909

         Re: In the Matter of the Petition of Ace Telephone Company, Barry County Telephone
             Company, Deerfield Farmers’ Telephone Company, Kaleva Telephone Company,
             Lennon Telephone Company, Ogden Telephone Company, Pigeon Telephone
             Company, the Upper Peninsula Telephone Company, and Waldron Telephone
             Company, for the Arbitration of Interconnection Rates, Terms, and Conditions and
             Related Arrangements with Verizon Wireless Pursuant to Section 252(b) of the
             Federal Telecommunications Act of 1996
             MPSC Case No. U-14678

Dear Ms. Kunkle:

        Enclosed for filing, please find an original and four copies of Verizon Wireless’ Motion
to Compel Petitioners to Provide Discovery Responses or in the Alternative, Motion To Have
The Arbitration Panel Order Petitioners to Produce Information and Motion for Immediate
Consideration Thereof, and a Notice of Hearing, in the above-captioned proceeding. Proof of
Service upon the Parties of Record is also enclosed. These pleadings have been filed
electronically on the Commission’s Electronic Case Filings System.

                                                 Very truly yours,

                                                CLARK HILL PLC


                                                 Haran C. Rashes
:hcr
Enclosure

cc:      Parties of Record

5205414v.1 09609/101804
                            Detroit, Michigan   Birmingham, Michigan      Lansing, Michigan
                                    STATE OF MICHIGAN

               BEFORE THE MICHIGAN PUBLIC SERVICE COMMISSION

                                             *****

In the Matter of the Petition of Ace Telephone      )
Company, Barry County Telephone Company,            )
Deerfield Farmers’ Telephone Company,               )
Kaleva Telephone Company, Lennon                    )                        Case No. U-14678
Telephone Company, Ogden Telephone                  )
Company, Pigeon Telephone Company, the              )
Upper Peninsula Telephone Company, and              )
Waldron Telephone Company, for the                  )
Arbitration of Interconnection Rates, Terms,        )
and Conditions and Related Arrangements with        )
Verizon Wireless Pursuant to Section 252(b) of      )
the Federal Telecommunications Act of 1996.         )

              VERIZON WIRELESS’ MOTION TO COMPEL PETITIONERS
                      TO PROVIDE DISCOVERY RESPONSES
                           OR IN THE ALTERNATIVE,
               MOTION TO HAVE THE ARBITRATION PANEL ORDER
                   PETITIONERS TO PRODUCE INFORMATION
             AND MOTION FOR IMMEDIATE CONSIDERATION THEREOF

         Verizon Wireless, by and through its attorneys and pursuant to Rules 335 and 317 of the

Rules of Practice and Procedure1 before the Michigan Public Service Commission (“MPSC” or

“Commission”) and MCR 2.313 hereby moves to compel Ace Telephone Company, Barry

County Telephone Company, Deerfield Farmers’ Telephone Company, Kaleva Telephone

Company, Lennon Telephone Company, Ogden Telephone Company, Pigeon Telephone

Company, the Upper Peninsula Telephone Company, and Waldron Telephone Company, the

Petitioners in the above-captioned arbitration proceeding, to provide responses to the attached

discovery requests (Attachment A, hereto), or in the alternative to have the Arbitration Panel

order the Petitioners to produce the information.


1
    1999 MAC R 460.17335 and R 460.17317.


5204722v.1 09609/101804
         The Commission, in its July 16, 1996 Order,2 establishing procedures for Interconnection

Agreement arbitration, and again in its May 18, 2004 Order,3 revising such procedures,

determined that parties to arbitration under Section 252 of the federal Telecommunications Act

of 1996 do not have a right to conduct discovery,4 but either party “may request that the panel

order the production of additional information from the other party.”5 The Commission has also

found that under Section 252, “the state commission may require parties to provide information

that is necessary for a decision.”6 The information that Verizon Wireless requests in this motion

is necessary for the Panel and Commission to reach a decision, and is also necessary for Verizon

Wireless to develop its testimony, present its arguments, and otherwise to get a fair hearing in

this proceeding. The information is in possession of the Petitioners.

         This Arbitration is unlike any other to come before the Commission in recent years. The

main dispute in this instant case is the rate the Petitioners propose to charge for wireless

termination. Thus this Arbitration does not involve terms or conditions of providing service, but

rather requires the Panel and the Commission to delve into the background and basis for the rate

in dispute. In this proceeding, the Petitioners rely upon and ask the Commission to adopt “rates

regarding local switching, local transport-termination, and local transport-facility relative to




2
    MPSC Case No. U-11134, July 16, 1996.
3
    MPSC Case No. U-13774, May 18, 2004.
4
  No court as yet has reviewed the merits of this conclusion. See, SBC Michigan v Public Serv
Comm’n, No. 256177, slip op (Mich Ct App, Nov 3, 2005), where the case was dismissed on a
procedural issue. In this case, Verizon Wireless cannot get a fair hearing without the required
information.
5
    MPSC Case No. U-11134, July 16, 1996, p 2.
6
    MPSC Case No. U-11134, Sept 23, 1996, p 4.
                                                 2

5204722v.1 09609/101804
terminating CMRS traffic,” that the Petitioners allege “are equal to and directly based on

mapping applicable MPSC approved TCLRIC studies.”7

          Before making any decision on this issue, the Panel and Commission must have and

review the Cost Studies upon which the Petitioners relied. This Commission has an affirmative

statutory duty in this Arbitration to establish the rates for transport and termination of traffic

based on the standards set forth in Section 252(d)(2) of the Act8 and the Section 51.705 of the

FCC’s Rules.9 Without access to the Petitioners’ cost studies and information surrounding the

cost studies, neither Verizon Wireless nor the Panel and Commission can apply these statutory

standards and judge the veracity of any statements made by the Petitioners or their witness. In

addition, without access to these studies, and information surrounding them, Verizon Wireless

may not be able to generate testimony or even an accurate position for this Commission to

consider in Arbitration.

          During the course of negotiations, Verizon Wireless has repeatedly requested copies of

the actual cost models used by the Petitioners to arrive at their proposed rates, along with the

associated assumptions and inputs.      The Petitioners have failed to provide the information

requested. (See Attachment B hereto). This continuing failure constitutes a breach of the

Petitioners’ duty to negotiate in good faith pursuant to Section 251(c) of the Act.10 The FCC has




7
    Petition, p 7, ¶22.
8
    47 USC § 252(d)(2).
9
    47 CFR § 51.705.
10
     47 USC § 251(c)(1).
                                                3

5204722v.1 09609/101804
specifically defined this statutory obligation to include a duty “by an incumbent LEC to furnish

cost data that would be relevant to setting rates if the parties were in arbitration.”11

         It is the stated goal of the Commission to encourage full and total disclosure of discovery

issues. Rule 317 of the Commission’s Rules of Practice and Procedure reads as follows:

                 “Discovery shall, as far as practicable, be conducted in the same
                 manner as in the circuit courts of this state pursuant to the
                 Michigan court rules or as otherwise provided by law. When
                 appropriate, the presiding officer shall set time limitations for the
                 conduct of discovery. Every party shall respond promptly and
                 fully to requests for discovery. The parties shall not use discovery
                 to harass or cause needless delay.”12

         In an arbitration proceeding involving the setting of rates, the Federal Communications

Commission allowed discovery and noted that “any other course would result in our having to

resolve the merits of the parties' disagreements without the benefit of cross-examination,

discovery, or briefs, which were critical to our analyses and findings . . .”13 The FCC reiterated

the importance of State Commission fact-finding in its Triennial Review Proceeding, stating that

“State commissions possess the requisite expertise to apply Commission-prescribed standards,

and they routinely utilize the processes and procedures -- including discovery, sworn testimony,

and cross examination on the record -- that are essential to reasoned fact-finding.”14




11
  47 CFR § 51.301(c)(8)(ii). This provision was added after this Commission determined that a
party did not have a right to discovery in an arbitration proceeding. Review of the Section 251
Unbundling Obligations, FCC 03-36, 68 FR 52276, 52294 (2003).
12
     1999 MAC R 460.17317.
13
   Petition of WorldCom, Inc. for Preemption of the Jurisdiction of the Virginia State
Corporation Commission Regarding Interconnection Disputes with Verizon Virginia Inc., FCC
Release No. DA 04-181, 19 FCC Rcd 1259, 1373, (2004).
14
  In the Matter of Review of the Section 251 Unbundling Obligations, FCC 03-36, 18 FCC Rcd
16978, 17288 (2003).
                                                   4

5204722v.1 09609/101804
         As the Commission is aware, Verizon Wireless is required to file “all information upon

which it intends to rely,”15 including its testimony, in this proceeding by Monday, November 28,

2005.16 In order to adequately prepare its positions and testimony, Verizon Wireless needs full

responses to the data requests listed herein.         Therefore, pursuant to Rule 335(3) of the

Commission’s Rules of Practice and Procedure,17 Verizon Wireless respectfully requests that the

normal schedule for briefing this motion be expedited to allow for adequate time for the Panel to

issue an order, the Petitioners to comply with an order compelling it to produce responses, as

well as give Verizon time to review and assimilate the responses into their testimony. Verizon

Wireless makes itself available to the Panel or the Commission for a hearing at their earliest

convenience. In the alternative, Verizon Wireless respectfully requests adequate time following

receipt of the Petitioners’ Discovery Responses to prepare its initial testimony in this proceeding.

         The Petitioners have placed their cost studies, inputs and assumptions at issue in this

proceeding and a failure by the Petitioners to provide the requested discovery, the cost studies,

inputs and assumptions, would, 1) constitute a breach of the Petitioners’ duty to negotiate in

good faith; 2) prevent the Arbitration Panel and the Commission from complying with their

statutory duty in this Arbitration to establish the rates for transport and termination of traffic

based on the standards set forth in Section 252(d)(2) of the Act18 and the Section 51.705 of the

FCC’s Rules;19 and 3) be a manifest injustice and denial of Verizon Wireless’ right to

fundamental fairness and due process.

15
     MPSC Case No. U-11134, July 16, 1996, p 2.
16
  25 Days after the Petition was filed falls on November 25, 2005. Because the Commission is
closed that day, the filing is due the next date upon which the Commission is open.
17
     1999 MAC R 460.17335(3)
18
     47 USC § 252(d)(2).
19
     47 CFR § 51.705.
                                                  5

5204722v.1 09609/101804
        WHEREFORE, Verizon Wireless respectfully requests this Commission expeditiously

enter an order compelling the Petitioners to fully respond to the attached data requests. In order

to allow Verizon Wireless to meet its scheduled testimony date of November 28, 2005, while

still giving the Commission and the Arbitration Panel time to enter an order and Verizon

Wireless the opportunity to review the responses and incorporate them into its positions and

testimony, Verizon Wireless further requests immediate consideration of this Motion.

                                                    Respectfully Submitted,

                                                    CLARK HILL PLC



                                                    By:
                                                          Roderick S. Coy (P12290)
                                                          Haran C. Rashes (P54883)
                                                          212 East Grand River Avenue
                                                          Lansing, Michigan 48906
                                                          (517) 318-3100
                                                          (517) 318-3099 Fax

Date: November 9, 2005                              Attorneys For Verizon Wireless




                                                6

5204722v.1 09609/101804
                                  STATE OF MICHIGAN

               BEFORE THE MICHIGAN PUBLIC SERVICE COMMISSION

                                          *****

In the Matter of the Petition of Ace Telephone   )
Company, Barry County Telephone Company,         )
Deerfield Farmers’ Telephone Company,            )
Kaleva Telephone Company, Lennon                 )      Case No. U-14678
Telephone Company, Ogden Telephone               )
Company, Pigeon Telephone Company, the           )
Upper Peninsula Telephone Company, and           )
Waldron Telephone Company, for the               )
Arbitration of Interconnection Rates, Terms,     )
and Conditions and Related Arrangements with     )
Verizon Wireless Pursuant to Section 252(b) of   )
the Federal Telecommunications Act of 1996.      )

              VERIZON WIRELESS’ MOTION TO COMPEL PETITIONERS
                      TO PROVIDE DISCOVERY RESPONSES
                           OR IN THE ALTERNATIVE,
               MOTION TO HAVE THE ARBITRATION PANEL ORDER
                   PETITIONERS TO PRODUCE INFORMATION
             AND MOTION FOR IMMEDIATE CONSIDERATION THEREOF




                                     ATTACHMENT A

         VERIZON WIRELESS’ FIRST SET OF DISCOVERY TO PETITIONERS




5204722v.1 09609/101804
                                               212 East Grand River Avenue
                                                Lansing, Michigan 48906
                                        Tel. (517) 318-3100 ▪ Fax (517) 318-3099
                                                    www.clarkhill.com


Haran C. Rashes
Phone: (517) 318-3019
E-Mail: hrashes@clarkhill.com
                                                November 9, 2005


BY HAND DELIVERY

Mr. Ronald D. Richards, Jr.
Foster, Swift, Collins & Smith, P.C.
313 S. Washington Square
Lansing, MI 48933

         Re: In the Matter of the Petition of Ace Telephone Company, Barry County Telephone
             Company, Deerfield Farmers’ Telephone Company, Kaleva Telephone Company,
             Lennon Telephone Company, Ogden Telephone Company, Pigeon Telephone
             Company, the Upper Peninsula Telephone Company, and Waldron Telephone
             Company, for the Arbitration of Interconnection Rates, Terms, and Conditions and
             Related Arrangements with Verizon Wireless Pursuant to Section 252(b) of the
             Federal Telecommunications Act of 1996
             MPSC Case No. U-14678

Dear Mr. Richards:

       Enclosed please find Verizon Wireless’ First Set of Discovery to the Petitioners in the
above-captioned proceeding.

                                                 Very truly yours,

                                                CLARK HILL PLC



                                                 Haran C. Rashes


:hcr
Enclosure




5205395v.1 09609/101804

                            Detroit, Michigan   Birmingham, Michigan      Lansing, Michigan
                                   STATE OF MICHIGAN

               BEFORE THE MICHIGAN PUBLIC SERVICE COMMISSION

                                            *****

In the Matter of the Petition of Ace Telephone   )
Company, Barry County Telephone Company,         )
Deerfield Farmers’ Telephone Company,            )
Kaleva Telephone Company, Lennon                 )                            Case No. U-14678
Telephone Company, Ogden Telephone               )
Company, Pigeon Telephone Company, the           )
Upper Peninsula Telephone Company, and           )
Waldron Telephone Company, for the               )
Arbitration of Interconnection Rates, Terms,     )
and Conditions and Related Arrangements with     )
Verizon Wireless Pursuant to Section 252(b) of   )
the Federal Telecommunications Act of 1996.      )

                                VERIZON WIRELESS’
                FIRST SET OF DISCOVERY REQUESTS TO PETITIONERS

         Verizon Wireless, by and through its attorneys, Clark Hill PLC, hereby submits the

following Interrogatories, Requests for Production of Documents, and Requests for Admissions

(hereinafter referred to “Discovery Requests”). As provided for in Rule 317 of the Rules of

Practice and Procedure before the Michigan Public Service Commission, 1999 MAC R

460.17317, interrogatories are submitted in accordance with and pursuant to MCR 2.309,

requests for production of documents are submitted in accordance with and pursuant to MCR

2.310, and requests for admissions are being submitted in accordance with and pursuant to MCR

2.312.

         Each Interrogatory or Request for Admission must be answered separately and fully. The

information sought must be given under oath whether that information is in the possession of, or

secured by, you, your attorney, or any other agent or representative, whether personally known to

you or not.     The person compiling the answer must sign responses to Interrogatories and



5205181v.1 09609/101804
Requests for Admissions. These Discovery Requests are continuing in nature, pursuant to MCR

2.302(E)(1), and supplemental answers are required upon receipt of additional or further

information by you, either directly or indirectly, up to the time of the hearing.

         PLEASE RESPOND TO THESE DISCOVERY REQUESTS WITHIN SEVEN (7)

              CALENDAR DAYS, OR ON OR BEFORE NOVEMBER 16, 2005.

                                            DEFINITIONS

        A.       The term “Document” as used herein means any written or graphic material

however produced or reproduced including, but not limited to, correspondence, telegrams, other

written communications, statements (whether written, recorded or video-taped), contracts,

agreements, memoranda, analysis, projections, studies, work papers, diaries, calendars, lists,

notes, minutes of meetings or telephone conferences, photographs, computerized data (hard or

soft copy), drawings and all other writings including drafts, copies, copies with margin notes or

reproductions thereof.

        B.       When an Interrogatory asks that the document be identified, “Identify” in this

context is defined to include the following information:

                 1.       The title, heading or caption of such document, if any;

                 2.       The identifying number(s), letter(s) or combination thereof, if any, and the

        significance or meaning of such number(s), letter(s) or combination thereof;

                 3.       The date appearing on such document and if no date appears thereon, the

        answer shall so state and shall give the date, or approximate date, on which each

        document was prepared;




                                                   2
5205181v.1 09609/101804
                 4.       The general nature or description of such document (i.e., whether it is a

        letter, memorandum, minutes of a meeting, etc.), and the number of pages of which it

        consists;

                 5.       The name of the person who signed such document and if it was not

        signed, the answer shall so state and shall give the name of the person or persons who

        prepared it;

                 6.       The name of the person to whom such document was addressed and the

        name of each person, other than such addressee, to whom such document or copy thereof

        was sent; and,

                 7.       The name of the person who has custody of such document.

        The foregoing information shall be given in sufficient detail to enable a party or person to

whom a subpoena is directed to identify fully the document sought to be produced, and to enable

parties to determine that such document when produced is in fact the document so described.

        C.       When an Interrogatory asks that a conversation be identified, “Identified” in this

context is defined to include the following information:

                 1.       The date of the conversation;

                 2.       The place of the conversation;

                 3.       The participants in the conversation, to include those who listened but said

        nothing;

                 4.       The witnesses, if any, to such conversations;

                 5.       Whether the conversation took place face-to-face or by telephone, and if

        by telephone who initiated the call;




                                                   3
5205181v.1 09609/101804
                  6.      The substance of the conversation, to include what was said by each

        participant; and,

                  7.      Whether any notes were taken of the conversation and, if so, who has

        custody thereof.

        D.        When an Interrogatory asks that a meeting be identified, “Identified” in this

context is defined to include the following information:

                  1.      The date or dates of the meeting;

                  2.      The place of the meeting;

                  3.      The persons attending the meeting;

                  4.      The person who called the meeting;

                  5.      The purpose of the meeting;

                  6.      What decisions were reached at the meeting; and,

                  7.      Whether any notes, minutes or other memorandum were made to record

        the proceeding of such meeting and, if so, who has custody thereof.

        E.        When an Interrogatory asks that a person be identified, “Identified” in this context

is defined to include the person’s full name, home and business address, telephone number, and

position held with his or her employer.

        F.        Should you deem to be privileged any documents concerning which information

our inspection is requested by any of the following requests, you shall describe such documents

in the matter above indicated and, in addition to supplying the above noted information, shall

indicate that a document is privileged and shall briefly state the ground(s) on which the claim of

privilege rest.




                                                      4
5205181v.1 09609/101804
        G.       Unless a different time is specified in the Discovery Requests, answers are

expected to disclose information as of the time of said answers. In the event information is

stated to be not available at the time of the answer, it is expected that it will be supplied when it

becomes available.




                                                 5
5205181v.1 09609/101804
                                     DISCOVERY REQUESTS

                      REQUESTS FOR PRODUCTION OF DOCUMENTS

VZW-RLECS-1 For each of the three cost studies referenced, and relied on, in Mr.
            McCartney’s testimony,

                          •   MECA’s 1st TSLRIC study MECA conducted in 1998, in conjunction
                              with MPSC Case No. U-11448;
                          •   MECA’s 2nd TSLRIC study MECA conducted in 1999 and 2000, in
                              conjunction with MPSC Case No. U-11448; and,
                          •   Upper Peninsula Telephone Company’s (“UPTC”) TSLRIC study
                              UPTC conducted in 2000 in conjunction with MPSC Case No. U-
                              12471,

                     provide a complete copy of the cost study and supporting documentation. The
                     requested materials include the following:

                     1. A summary of the proposed rates showing the “mapping” of TSLRIC
                           study results to the rates.

                     2. An electronic, executable copy of the cost study or model used to produce
                           the TSLRIC study results.

                     3. Documentation describing cost methods including, but not limited to, the
                           sizing of network elements to serve total demand, the calculation of
                           network element investments and direct costs, the allocation of shared
                           and common costs, and the computation of network element unit costs.

                     4. All work papers used to develop input data used in the model, such as in-
                            service and forecast demand for network elements, network element
                            material costs and other costs of construction, economic lives and
                            capital cost components, operating expense factors, shared cost
                            factors, common cost factors and others. Work papers should indicate
                            the sources and dates of data and provide copies of source documents
                            (vendor quotes, financial accounting, etc.).

VZW-RLECS-2 Please provide the following information for each Petitioner:

                     1. 2003 and 2004 end of year balance sheets.

                     2. 2004 telecommunications plant by FCC USOA account – beginning of
                           year, additions, retirements and end of year amounts.

                     3. 2004 income statement with revenues, expenses, etc. by FCC USOA
                           account.

                     4. Copies of annual reports filed with the MPSC for years 2003 and 2004.

                                                 6
5205181v.1 09609/101804
VZW-RLECS-3 For each Petitioner, provide a current network diagram showing the
            following:

                     1. Location of host and remote switches. Label switches by central office
                           name and CLLI code.

                     2. Location of point(s) of interconnection or meet point(s) with intermediate
                           carriers for transport of Verizon Wireless telecommunications traffic.

                     3. Number of current switched access lines by class of service per host and
                          remote switch.

                     4. Transport systems connecting switches or other network nodes. For
                           example, identify SONET rings, direct point-to-point transport
                           systems, etc.

                     5. Size of transport systems (e.g., DS3, OC3, OC12 or other).

                     6. Interoffice cable route mileage between network nodes.

                     7. Route mileage from Petitioner’s host office to points of interconnection or
                           meet points.

                     8. Other network architectural features that have a bearing on or factor in the
                           calculation of transport plant in the TSLRIC study.

VZW-RLECS-4 For each Petitioner, provide its 2004 intrastate and interstate switched access
            revenues from interexchange carriers and the associated billed switched
            access minutes of use (originating and terminating).

VZW-RLECS-5 Provide either (a) a current vendor quote or (b) the output of a vendor pricing
            tool showing the vendor engineered, furnished and installed (EF&I) cost, with
            detailed breakdown of charges, for the vendor switch types considered to be
            the forward-looking host and remote switch technologies of each Petitioner.
            The quote or pricing tool output should show the total demand values (e.g.,
            lines, busy hour call attempts, busy hour hundred call seconds or others) and
            capacities for which the switches are equipped.

VZW-RLECS-6 Provide an analysis of the forward-looking switch costs in response to the
            preceding data request showing the basis for the usage sensitive versus non-
            usage sensitive switching investment and costs reflected in the TSLRIC study.




                                                  7
5205181v.1 09609/101804
VZW-RLECS-7 Please provide current vendor quotes or other source data for each transport
            transmission equipment component and for transport cable facilities. This
            information is to include:

                     1. Material quantities and prices.

                     2. Vendor engineering and installation charges.

                     3. Other costs of construction.

                     4. Capacities and utilization levels assumed in developing unit investments.

VZW-RLECS-8 Please provide the basis for the cost of debt, debt fraction and cost of equity
            values used in the cost study for each Petitioner.


VZW-RLECS-9 Please provide a schedule for each Petitioner of its current long-term debt
            obligations indicating the dates of issuance of bonds, lender, amount of debt
            obligation and interest rate.

                                      INTERROGATORIES

VZW-RLECS-10 Identify all arbitration cases in which the cost models identified in response to
             Discovery Request VZW-RLECS-1 has been used as the basis of reciprocal
             compensation rates (state, docket number, date, parties involved in the
             arbitration, etc.).

VZW-RLECS-11 Indicate for each Petitioner whether the company has since January 1, 2000,
             installed or ordered a new switching system (host or remote), whether a digital
             circuit switched system or packet switched system. If so, provide the
             following details for the switch(es):

                     1. Date of installation.

                     2. Vendor name and switch type.

                     3. Copy of vendor quote.

                     4. Copy of vendor bills showing total EF&I cost and detailed breakdown.
                           The breakdown should itemize fixed charges, volume-sensitive
                           charges, quantities, unit prices, etc; and

                     5. Specifically identify all software charges, with a breakdown of software
                           purchased. Indicate whether each software charge was capitalized or
                           expensed.




                                                  8
5205181v.1 09609/101804
VZW-RLECS-12 On page 5 at line 12 of Mr. McCartney’s testimony he states, “that the rates
             all Petitioners propose … are equal to and based on MPSC-approved Total
             Element Long Run Incremental Cost (“TSLRIC”) studies,”

                     1. Provide specific references to the MPSC orders or other rulings that
                           approved the TSLRIC studies referred to in Mr. McCartney’s
                           testimony.

                     2. Provide references to MPSC orders, rules or other that prescribe
                           requirements for TSLRIC studies in terms of methods, input data and
                           other relevant aspects of such studies.

VZW-RLECS-13 On page 8 line 1 of Mr. McCartney’s testimony he states that the TSLRIC
             study methodology in Michigan conforms to the FCC’s TELRIC study
             methodology. Please identify any and all differences between the TSLRIC
             methodology employed in the MECA cost studies and the FCC’s requirements
             for TELRIC per 47 CFR 51.505 and 511. Indicate whether the same cost
             result would be produced by the Michigan TSLRIC methodology and the FCC
             TELRIC methodology. If not, explain why in terms of methods or input data.

VZW-RLECS-14 On page 11 at line 22 of Mr. McCartney’s testimony he refers to a “mapping
             approach” used to develop rates in MPSC Case No, U-12130. Provide
             specific references to the documents in this case describing the mapping
             approach and its results, which were approved by the MPSC.

VZW-RLECS-15 Please confirm that the 2nd TSLRIC study described on page 15 beginning at
             line 8 is the basis for the Petitioners’ proposed transport and termination rates.
             If so, confirm that the 1st TSLRIC study is not used in establishing the
             proposed transport and termination rate.

VZW-RLECS-16 Provide the basis for the 19.3633% common cost factor given on line 30, page
             15 of the testimony. The basis includes the methods, algorithms, data and
             assumptions used to derive the common cost factor.

VZW-RLECS-17 Please indicate whether each Petitioner affirms that 19.3633% is
             representative of its company-specific “forward-looking common costs” as
             defined in 47 CFR 51.505 (c).




                                                9
5205181v.1 09609/101804
VZW-RLECS-18 On page 18 at line 10, Mr. McCartney indicates eight miles is used as the
             average interoffice facility distance. Please confirm whether this distance
             represents the average route mileage from the point of interconnection or meet
             point between the Petitioner’s network and the interconnecting carrier’s
             network to the Petitioner’s host end office serving the called subscriber
             (excluding mileage from the host to remote, if applicable).

                                                 Respectfully Submitted,

                                                 CLARK HILL PLC



                                                 By:
                                                       Roderick S. Coy (P12290)
                                                       Haran C. Rashes (P54883)
                                                       212 East Grand River Avenue
                                                       Lansing, Michigan 48906
                                                       (517) 318-3100
                                                       (517) 318-3099 Fax

Date: November 9, 2005                           Attorneys For Verizon Wireless




                                            10
5205181v.1 09609/101804
                                               212 East Grand River Avenue
                                                Lansing, Michigan 48906
                                        Tel. (517) 318-3100 ▪ Fax (517) 318-3099
                                                    www.clarkhill.com


Haran C. Rashes
Phone: (517) 318-3019
E-Mail: hrashes@clarkhill.com
                                                November 9, 2005


BY HAND DELIVERY

Ms. Mary Jo Kunkle
Executive Secretary
Michigan Public Service Commission
6545 Mercantile Way
PO Box 30221
Lansing, MI 48909

         Re: In the Matter of the Petition of Ace Telephone Company, Barry County Telephone
             Company, Deerfield Farmers’ Telephone Company, Kaleva Telephone Company,
             Lennon Telephone Company, Ogden Telephone Company, Pigeon Telephone
             Company, the Upper Peninsula Telephone Company, and Waldron Telephone
             Company, for the Arbitration of Interconnection Rates, Terms, and Conditions and
             Related Arrangements with Verizon Wireless Pursuant to Section 252(b) of the
             Federal Telecommunications Act of 1996
             MPSC Case No. U-14678

Dear Ms. Kunkle:

        Enclosed for filing, please find a copy of the Proof of Service of Verizon Wireless’ First
Set of Discovery to the Petitioners in the above-captioned proceeding. This pleading has been
filed electronically on the Commission’s Electronic Case Filings System.

                                                 Very truly yours,

                                                CLARK HILL PLC



                                                 Haran C. Rashes

:hcr
Enclosure

cc:      Parties of Record


5205409v.1 09609/101804
                            Detroit, Michigan   Birmingham, Michigan      Lansing, Michigan
                                    STATE OF MICHIGAN

               BEFORE THE MICHIGAN PUBLIC SERVICE COMMISSION

In the Matter of the Petition of Ace Telephone   )
Company, Barry County Telephone Company,         )
Deerfield Farmers’ Telephone Company,            )
Kaleva Telephone Company, Lennon                 )                         Case No. U-14678
Telephone Company, Ogden Telephone               )
Company, Pigeon Telephone Company, the           )
Upper Peninsula Telephone Company, and           )
Waldron Telephone Company, for the               )
Arbitration of Interconnection Rates, Terms,     )
and Conditions and Related Arrangements with     )
Verizon Wireless Pursuant to Section 252(b) of   )
the Federal Telecommunications Act of 1996.      )

                                    PROOF OF SERVICE

STATE OF MICHIGAN           )
                            )ss
COUNTY OF INGHAM            )

       Patricia A. Tooker, being first duly sworn, deposes and says that she is an employee of
Clark Hill PLC and that on November 9, 2005, she did cause to be served a copy of Verizon
Wireless’ First Set of Discovery to Petitioners, in the above-captioned proceeding, upon:

                            Ronald D. Richards, Jr
                            Counsel for Petitioners.
                            Foster, Swift, Collins & Smith, P.C.
                            313 S. Washington Square
                            Lansing, MI 48933.

via hand delivery.

                                                     Patricia A. Tooker
Subscribed and sworn to before me
this 9th day of November 2005.


_____________________________________
Haran C. Rashes
Notary Public, Washtenaw County, Michigan
Acting in Ingham County, Michigan
My Commission expires: September 18, 2007




5205432v.1 09609/101804
                                  STATE OF MICHIGAN

               BEFORE THE MICHIGAN PUBLIC SERVICE COMMISSION

                                          *****

In the Matter of the Petition of Ace Telephone   )
Company, Barry County Telephone Company,         )
Deerfield Farmers’ Telephone Company,            )
Kaleva Telephone Company, Lennon                 )        Case No. U-14678
Telephone Company, Ogden Telephone               )
Company, Pigeon Telephone Company, the           )
Upper Peninsula Telephone Company, and           )
Waldron Telephone Company, for the               )
Arbitration of Interconnection Rates, Terms,     )
and Conditions and Related Arrangements with     )
Verizon Wireless Pursuant to Section 252(b) of   )
the Federal Telecommunications Act of 1996.      )

              VERIZON WIRELESS’ MOTION TO COMPEL PETITIONERS
                      TO PROVIDE DISCOVERY RESPONSES
                           OR IN THE ALTERNATIVE,
               MOTION TO HAVE THE ARBITRATION PANEL ORDER
                   PETITIONERS TO PRODUCE INFORMATION
             AND MOTION FOR IMMEDIATE CONSIDERATION THEREOF




                                     ATTACHMENT B

                 REQUESTS FOR INFORMATION SENT TO PETITIONERS




5204722v.1 09609/101804
Rashes, Haran C.
From:               John.Clampitt@VerizonWireless.com
Sent:               Tuesday, October 18, 2005 4:59 PM
To:                 John.Clampitt@VerizonWireless.com; stevegatto@mecaone.com
Cc:                 Elaine.Critides@VerizonWireless.com; Rashes, Haran C.
Subject:            RE: Redline Interconnection Agreement


Hi Steve. Just to make sure we are all on the same page there are some changes that you
proposed that we can accept and I'm making some redline proposed modifications to some of
your other proposals and will have a new redline for your consideration hopefully sometime
tomorrow or Thursday at the latest. I'm hoping we can avoid arbitration and in the
interest of doing that I'm requesting cost data from your respective companies since that
is probably the main sticking point. Please provide the actual cost model used to arrive
at their current proposed rates, the assumptions and the inputs so that our cost person
can review them and help us to understand
any anomalies or differences. Thanks

-----Original Message-----
From: Clampitt, John
Sent: Monday, October 17, 2005 2:51 PM
To: 'stevegatto@mecaone.com'
Cc: Critides, Elaine
Subject: RE: Redline Interconnection Agreement


Hi Steve. Just to clarify I believe the only rural company that you are
representing that has an issue of which tandem traffic should be routed
through is Deerfield. Is that correct? If not, could you provide the other
companies, the tandem they are requesting and what their switch CLLIs are as
well as the tandem CLLI they are requesting? Thanks

-----Original Message-----
From: Clampitt, John
Sent: Monday, October 17, 2005 10:12 AM
To: 'stevegatto@mecaone.com'
Cc: Critides, Elaine
Subject: RE: Redline Interconnection Agreement


Hi Steve. When we last talked I was of the understanding you were going to
go back to your carriers and discuss some movement on the rates and also
provide me information on what the transit rates were from the tandem
provider that was being requested. According to my records the first
request we received was from Barry County Telephone on May 12th with
Deerfield on 5/16, Kaleva on 5/23, Pigeon on 5/24, a second Pigeon on 5/27,
Waldron on 5/25, Ogden on 5/26, Ace on 5/26, and Upper Peninsula on 5/27.
Lennon was received in March prior to the effective date of the T-Mobile
Order, but we responded back on March 30, 2005 indicating we would recognize
the effective date of the T-Mobile Order (April 29, 2005) rather than asking
Lennon to resend a BFR. According to my calculations the window for Lennon
has expired. Next up is Barry County which opened October 4th and closes
October 29. Since all of these were sent Return Receipt and our mail room
signed for them I'm not exactly sure what date they were received by Verizon
Wireless and would ask that you confirm your understanding of the clock
start dates as well as window open and close.

We do not wish to extend the window although I would be willing to do so for
Lennon to bring them into the time frame for Barry County so, if need be, we
can resolve them all at once and not have a straggler.

I'm willing to continue to negotiate, but unless we get movement on rates
and can confirm a reasonable transit charge our last redline offer would
                                                1
stand as our final offer.

In anticipation of potential arbitration I would ask that all companies
provide a recent FCC compliant forward looking cost study to support any
rates above our offer. I would also ask that all companies provide their
ownership relationship with the tandem provider being requested.

-----Original Message-----
From: stevegatto@mecaone.com [mailto:stevegatto@mecaone.com]
Sent: Friday, October 14, 2005 12:57 PM
To: John.Clampitt@VerizonWireless.com
Cc: stevegatto@hotmail.com
Subject: Re: Redline Interconnection Agreement


John,

I though I would check to see if your legal department has finished
reviewing the redline that MECA previously sent to you. Please let me know
the status of the draft agreeement.

Our records indication that MECA is acting on behalf of the following
companies:

Ace
Barry County
Deerfield
Kaleva
Lennon
Ogden
Pigeon
Upper Peninsula
Waldron


Since the negotiations have reached the start date for the arbitration
window. MECA proposes that we enter into an agreement to extend the start
date for the arbitration window to January 4, 2006 and a close date of
January 29, 2006. This will extend the start date of the arbitration window
and will put the companies on the same timeline.

Please let MECA know if Verizon Wireless is agreeable to extending the start
date for the arbitration window to January 4, 2006. If so, MECA will send
an agreement to you for Verizon's signature.

Yours truly,


Steve Gatto



----- In Response To -----

Hi Steve. I cannot find your phone number. Can you provide or give me a
quick call @ 925-279-6266. The overall review is still in Legal, but I
would like to find out how far apart we are on a couple of issues. Thanks

-----Original Message-----
From: stevegatto@mecaone.com [mailto:stevegatto@mecaone.com]
Sent: Tuesday, August 30, 2005 1:01 PM
To: Clampitt, John
Cc: stevegatto@hotmail.com
Subject: Redline Interconnection Agreement


                                            2
John,

Attached is MECA's latest revisions to the draft agreement that Verizon
redlined.


1. Page 4, Section 1.5-added proper name of commission.

2. Page 5, Section 1.12-Added proper tariff title and tariff number.

3. Page 8, Section 3.4- Added proper tariff title and tariff number.

4. Page 8, Section 3.5-Added language that each party will route indirect
traffic to the other party through the tandem designated by the ILEC in the
LERG.

5. Page 15, Section 16.6-Deleted previous language about governing law and
asserted revised language. The jurisdiction language is not necessary in
the governing law section because any remedy sought by either party would
have to meet the jurisdictional requirements of the FCC, MPSC, or State and
Federal Courts anyway.

6. Page 19, Section 17.2; 17.3; 17.4-Added additional language concerning
dispute resolution.

7. Page 21, Section 2.0-We will need to talk about the rates.

8. Page 21-22, Section 2.2-We prefer an estimate for interMTA traffic rather
than a de minimis approach.

9. Page 22, Section 2.3.2-MECA agrees with your method of computation but
not on the traffic factor. We are conducting traffic studies to determine
an appropriate traffic exchange factor. Generally, we have found a higher
traffic exchange factor than 65/35.

10. Page 22, Section 2.3.3-Michigan is a 3 MTA state, obviously there is
some InterMTA traffic. For the lower part of Michigan we usually can agree
to 2-3%. For the Upper Peninsula the multiple MTA's usually have more
interaction and we usually agree to 5%.

11. Page 22-23, Section 2.3.3-As noted above, we prefer an estimate for
interMTA traffic rather than a de minimis approach.

12. Page 23, Section 2.3.4-As noted above, we are conducting traffic studies
to determine an appropriate traffic exchange percentage. Generally, we have
found a higher traffic exchange factor than 65/35.

13. Page 22, Section 2.3.4-MECA will look closer at the actual number for
this factor.


If you have any question, please let me know.




___________________________________________________________________
The information contained in this message and any attachment may be
proprietary, confidential, and privileged or subject to the work
product doctrine and thus protected from disclosure. If the reader
of this message is not the intended recipient, or an employee or
agent responsible for delivering this message to the intended
recipient, you are hereby notified that any dissemination,
distribution or copying of this communication is strictly prohibited.
If you have received this communication in error, please notify me
immediately by replying to this message and deleting it and all
                                            3
copies and backups thereof.   Thank you.




                                           4
Rashes, Haran C.
From:                John.Clampitt@VerizonWireless.com
Sent:                Thursday, October 20, 2005 2:21 PM
To:                  John.Clampitt@VerizonWireless.com; stevegatto@mecaone.com
Cc:                  Elaine.Critides@VerizonWireless.com; Rashes, Haran C.
Subject:             RE: Redline Interconnection Agreement

Attachments:         Michigan Rurals Redline response.doc




Michigan Rurals
Redline respon...
                 Hi Steve. Here is an attachment that is a redline of your redline, so this
should reflect the most recent status. Again, I would request you provide the cost
information requested to see if we can't resolve the issue. thanks

-----Original Message-----
From: Clampitt, John
Sent: Tuesday, October 18, 2005 1:59 PM
To: Clampitt, John; 'stevegatto@mecaone.com'
Cc: Critides, Elaine; Haran Rashes (E-mail)
Subject: RE: Redline Interconnection Agreement


Hi Steve. Just to make sure we are all on the same page there are some
changes that you proposed that we can accept and I'm making some redline
proposed modifications to some of your other proposals and will have a new
redline for your consideration hopefully sometime tomorrow or Thursday at
the latest. I'm hoping we can avoid arbitration and in the interest of
doing that I'm requesting cost data from your respective companies since
that is probably the main sticking point. Please provide the actual cost
model used to arrive at their current proposed rates, the assumptions and
the inputs so that our cost person can review them and help us to understand
any anomalies or differences. Thanks

-----Original Message-----
From: Clampitt, John
Sent: Monday, October 17, 2005 2:51 PM
To: 'stevegatto@mecaone.com'
Cc: Critides, Elaine
Subject: RE: Redline Interconnection Agreement


Hi Steve. Just to clarify I believe the only rural company that you are
representing that has an issue of which tandem traffic should be routed
through is Deerfield. Is that correct? If not, could you provide the other
companies, the tandem they are requesting and what their switch CLLIs are as
well as the tandem CLLI they are requesting? Thanks

-----Original Message-----
From: Clampitt, John
Sent: Monday, October 17, 2005 10:12 AM
To: 'stevegatto@mecaone.com'
Cc: Critides, Elaine
Subject: RE: Redline Interconnection Agreement


Hi Steve. When we last talked I was of the understanding you were going to
go back to your carriers and discuss some movement on the rates and also
provide me information on what the transit rates were from the tandem
                                                  1
provider that was being requested. According to my records the first
request we received was from Barry County Telephone on May 12th with
Deerfield on 5/16, Kaleva on 5/23, Pigeon on 5/24, a second Pigeon on 5/27,
Waldron on 5/25, Ogden on 5/26, Ace on 5/26, and Upper Peninsula on 5/27.
Lennon was received in March prior to the effective date of the T-Mobile
Order, but we responded back on March 30, 2005 indicating we would recognize
the effective date of the T-Mobile Order (April 29, 2005) rather than asking
Lennon to resend a BFR. According to my calculations the window for Lennon
has expired. Next up is Barry County which opened October 4th and closes
October 29. Since all of these were sent Return Receipt and our mail room
signed for them I'm not exactly sure what date they were received by Verizon
Wireless and would ask that you confirm your understanding of the clock
start dates as well as window open and close.

We do not wish to extend the window although I would be willing to do so for
Lennon to bring them into the time frame for Barry County so, if need be, we
can resolve them all at once and not have a straggler.

I'm willing to continue to negotiate, but unless we get movement on rates
and can confirm a reasonable transit charge our last redline offer would
stand as our final offer.

In anticipation of potential arbitration I would ask that all companies
provide a recent FCC compliant forward looking cost study to support any
rates above our offer. I would also ask that all companies provide their
ownership relationship with the tandem provider being requested.

-----Original Message-----
From: stevegatto@mecaone.com [mailto:stevegatto@mecaone.com]
Sent: Friday, October 14, 2005 12:57 PM
To: John.Clampitt@VerizonWireless.com
Cc: stevegatto@hotmail.com
Subject: Re: Redline Interconnection Agreement


John,

I though I would check to see if your legal department has finished
reviewing the redline that MECA previously sent to you. Please let me know
the status of the draft agreeement.

Our records indication that MECA is acting on behalf of the following
companies:

Ace
Barry County
Deerfield
Kaleva
Lennon
Ogden
Pigeon
Upper Peninsula
Waldron


Since the negotiations have reached the start date for the arbitration
window. MECA proposes that we enter into an agreement to extend the start
date for the arbitration window to January 4, 2006 and a close date of
January 29, 2006. This will extend the start date of the arbitration window
and will put the companies on the same timeline.

Please let MECA know if Verizon Wireless is agreeable to extending the start
date for the arbitration window to January 4, 2006. If so, MECA will send
an agreement to you for Verizon's signature.

Yours truly,
                                            2
Steve Gatto



----- In Response To -----

Hi Steve. I cannot find your phone number. Can you provide or give me a
quick call @ 925-279-6266. The overall review is still in Legal, but I
would like to find out how far apart we are on a couple of issues. Thanks

-----Original Message-----
From: stevegatto@mecaone.com [mailto:stevegatto@mecaone.com]
Sent: Tuesday, August 30, 2005 1:01 PM
To: Clampitt, John
Cc: stevegatto@hotmail.com
Subject: Redline Interconnection Agreement


John,

Attached is MECA's latest revisions to the draft agreement that Verizon
redlined.


1. Page 4, Section 1.5-added proper name of commission.

2. Page 5, Section 1.12-Added proper tariff title and tariff number.

3. Page 8, Section 3.4- Added proper tariff title and tariff number.

4. Page 8, Section 3.5-Added language that each party will route indirect
traffic to the other party through the tandem designated by the ILEC in the
LERG.

5. Page 15, Section 16.6-Deleted previous language about governing law and
asserted revised language. The jurisdiction language is not necessary in
the governing law section because any remedy sought by either party would
have to meet the jurisdictional requirements of the FCC, MPSC, or State and
Federal Courts anyway.

6. Page 19, Section 17.2; 17.3; 17.4-Added additional language concerning
dispute resolution.

7. Page 21, Section 2.0-We will need to talk about the rates.

8. Page 21-22, Section 2.2-We prefer an estimate for interMTA traffic rather
than a de minimis approach.

9. Page 22, Section 2.3.2-MECA agrees with your method of computation but
not on the traffic factor. We are conducting traffic studies to determine
an appropriate traffic exchange factor. Generally, we have found a higher
traffic exchange factor than 65/35.

10. Page 22, Section 2.3.3-Michigan is a 3 MTA state, obviously there is
some InterMTA traffic. For the lower part of Michigan we usually can agree
to 2-3%. For the Upper Peninsula the multiple MTA's usually have more
interaction and we usually agree to 5%.

11. Page 22-23, Section 2.3.3-As noted above, we prefer an estimate for
interMTA traffic rather than a de minimis approach.

12. Page 23, Section 2.3.4-As noted above, we are conducting traffic studies
to determine an appropriate traffic exchange percentage. Generally, we have
found a higher traffic exchange factor than 65/35.
                                            3
13. Page 22, Section 2.3.4-MECA will look closer at the actual number for
this factor.


If you have any question, please let me know.




___________________________________________________________________
The information contained in this message and any attachment may be
proprietary, confidential, and privileged or subject to the work
product doctrine and thus protected from disclosure. If the reader
of this message is not the intended recipient, or an employee or
agent responsible for delivering this message to the intended
recipient, you are hereby notified that any dissemination,
distribution or copying of this communication is strictly prohibited.
If you have received this communication in error, please notify me
immediately by replying to this message and deleting it and all
copies and backups thereof. Thank you.




                                            4
Rashes, Haran C.
From:               John.Clampitt@VerizonWireless.com
Sent:               Monday, October 31, 2005 11:28 AM
To:                 stevegatto@mecaone.com
Cc:                 stevegatto@hotmail.com; Rashes, Haran C.; Elaine.Critides@VerizonWireless.com
Subject:            RE: ILECs Final Proposed Interconnection Agreement

Attachments:        ATT2806526.txt




ATT2806526.txt
   (1,009 B)
            Hi Steve. I find the cost information to far from complete and again request
that you provide information regarding the specific cost model used to generate the
figures along with the all of the specific assumptions for inputs into the model. Also,
please provide information for each of the carriers regarding common transport mileage and
whether any of the carriers has broadband or cable affiliates sharing common plant. Also,
please provide the ratio of switch costs associated with lines versus usage sensitive
elements. At this point I do not find the information convincing that it represents an
FCC compliant cost study and must reject this final
offer.

-----Original Message-----
From: stevegatto@mecaone.com [mailto:stevegatto@mecaone.com]
Sent: Friday, October 28, 2005 1:59 PM
To: Clampitt, John
Cc: stevegatto@hotmail.com
Subject: ILECs Final Proposed Interconnection Agreement


John,


Attached is the final proposed agreement for the following telephone
companies:

Ace
Barry County
Deerfield
Kaleva
Lennon
Ogden
Pigeon
Waldron

Although this final proposed agreement contains Deerfield Farmers' Telephone Company's
specific information, the rates, terms and conditions in the agreement will be used by all
the above listed companies for their respective separate interconnection agreements, with
only company specific information to be changed. Thus, this agreement should be considered
the final proposed agreement for all the above listed companies.

Please let me know if Verizon is willing to agree to the interconnection agreements.

Yours truly,

Steve Gatto
Michigan Exchange Carriers Association, Inc.



                                                 1
Rashes, Haran C.
From:               John.Clampitt@VerizonWireless.com
Sent:               Monday, October 31, 2005 3:11 PM
To:                 stevegatto@hotmail.com
Cc:                 MBurzych@fosterswift.com; Elaine.Critides@VerizonWireless.com; Rashes, Haran C.
Subject:            RE: Revised ILEC Interconnection Agreement 103105

Attachments:        ATT2828699.txt




ATT2828699.txt
   (1,009 B)
            Hi Steve. Just to be clear about our request, Verizon Wireless specifically
requests a functioning copy of the cost model used in the cost studies populated with the
inputs used to create the summary pages you sent and all of the supporting documentation.
Thanks

-----Original Message-----
From: Steve Gatto [mailto:stevegatto@hotmail.com]
Sent: Monday, October 31, 2005 10:08 AM
To: Clampitt, John
Cc: MBurzych@fosterswift.com
Subject: Revised ILEC Interconnection Agreement 103105


John,

Attached is a revised Interconnection Agreement for Deerfield Farmers'
Telephone Company and the other ILECs. The previous version had the local switching rate
out to five digits, but the other rates were out to six.
Thus, we revised the local switching rate to six digits in this final Deerfiled and ILEC
agreement to be consistent. This final interconnection agreement will be the final offer
for Deerfield and the other ILECs.


Yours truly,

Steve Gatto

_________________________________________________________________
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                                                 1
                                    STATE OF MICHIGAN

               BEFORE THE MICHIGAN PUBLIC SERVICE COMMISSION

                                          *****

In the Matter of the Petition of Ace Telephone   )
Company, Barry County Telephone Company,         )
Deerfield Farmers’ Telephone Company,            )
Kaleva Telephone Company, Lennon                 )                         Case No. U-14678
Telephone Company, Ogden Telephone               )
Company, Pigeon Telephone Company, the           )
Upper Peninsula Telephone Company, and           )
Waldron Telephone Company, for the               )
Arbitration of Interconnection Rates, Terms,     )
and Conditions and Related Arrangements with     )
Verizon Wireless Pursuant to Section 252(b) of   )
the Federal Telecommunications Act of 1996.      )

                                    PROOF OF SERVICE

STATE OF MICHIGAN           )
                            )ss
COUNTY OF INGHAM            )

       Patricia A. Tooker, being first duly sworn, deposes and says that she is an employee of
Clark Hill PLC and that on November 9, 2005, she did cause to be served a copy of Verizon
Wireless’ Motion to Compel Petitioners to Provide Discovery Responses or in the Alternative,
Motion To Have The Arbitration Panel Order Petitioners to Produce Information and Motion for
Immediate Consideration Thereof, and a Notice of Hearing, in the above-captioned proceeding,
along with a Proof of Service, upon those parties listed on the attached list, in the manner
described on the attached list.



                                                     Patricia A. Tooker
Subscribed and sworn to before me
this 9th day of November 2005.


_____________________________________
Haran C. Rashes
Notary Public, Washtenaw County, Michigan
Acting in Ingham County, Michigan
My Commission expires: September 18, 2007




5205335v.1 09609/101804
                                       Service List
                                   MPSC Case No. U-14678

VIA HAND DELIVERY:                              VIA US MAIL:

Michigan Public Service Commission              Verizon Wireless

Mr. Orjiakor Isiogu                             Ms. Elaine Critides
Director, Communications Division               Senior Attorney, Legal & External Affairs
Michigan Public Service Commission              Verizon Wireless
6545 Mercantile Way                             1300 I Street, NW - Suite 400 West
PO Box 30221                                    Washington, D.C. 20005
Lansing, MI 48909
                                                Mr. John Clampitt
Mr. James Rigas                                 Verizon Wireless
Administrative Law Judge                        2785 Mitchell Dr., MS 7-1
Michigan Public Service Commission              Walnut Creek, CA 94598
6545 Mercantile Way, Suite 14
P.O. Box 30221
Lansing, MI 48911

Petitioners

Mark J. Burzych
Ronald D. Richards, Jr.
Foster, Swift, Collins & Smith, P.C.
313 S. Washington Square
Lansing, MI 48933




5205335v.1 09609/101804

								
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