Exhibit Mdg 3.0

STATE OF MICHIGAN

BEFORE THE MICHIGAN PUBLIC SERVICE COMMISSION

In the matter of the Application and Complaint of ) WESTPHALIA TELEPHONE COMPANY and ) GREAT LAKES COMNET, INC. against ) Case No. U-17660 LEVEL 3 COMMUNICATIONS, LLC, ) GLOBAL CROSSING LOCAL SERVICES, ) INC. and WILTEL COMMUNICATIONS, LLC

RESPONSE TESTIMONY OF MACK D. GREENE ON BEHALF OF LEVEL 3 COMMUNICATIONS, LLC GLOBAL CROSSING LOCAL SERVICES, INC. and WILTEL COMMUNICATIONS, LLC

EXHIBIT MDG 3.0

Response of Mack D. Greene Level 3 Exhibit MDG 3.0 Public Version

STATE OF MICHIGAN

BEFORE THE MICHIGAN PUBLIC SERVICE COMMISSION

RESPONSE TESTIMONY OF MACK D. GREENE Response of Mack D. Greene Level 3 Exhibit MDG 3.0 Public Version

1 Q. PLEASE STATE YOUR NAME, POSITION, EMPLOYER, AND BUSINESS

2 ADDRESS.

3 A. My name is Mack D. Greene. I am a Director with Level 3 Communications, LLC. My

4 business address is 1025 Eldorado Blvd, Broomfield, Colorado. I am filing this

5 testimony on behalf of Level 3 Communications, Global Crossing Local Services and

6 WilTel Communications.

7 Q. ARE YOU THE SAME MACK GREEN THAT PROVIDED DIRECT

8 TESTIMONY IN THIS CASE ON OCTOBER 2, 2014?

9 A. Yes.

10 Q. WHAT IS THE PURPOSE OF YOUR RESPONSE TESTIMONY?

11 A. I am testifying on behalf of Level 3 Communications, LLC (“Level 3 LLC”), Global

12 Crossing Telecommunications, Inc. (“Global Crossing”), and WilTel Communications,

13 LLC (“WilTel”) (Level 3, Global Crossing and WilTel are together referred to herein as

14 “Level 3”). Each of these companies are Respondents in this case, and each have

15 independent claims to recover excessive access charges paid to Great Lakes Comnet, Inc.

16 (“Great Lakes” or “GLC”) and Westphalia Telephone Company (“Westphalia” or

17 “WTC”). Westphalia and Great Lakes have filed a complaint with the Commission, and

18 Level 3, WilTel and Global Crossing have counterclaimed to recover the excess

19 payments.

20 I previously submitted testimony on October 2, 2014 in support of Level 3’s

21 counterclaims. This response testimony responds to the testimony submitted by GLC and

22 WTC in support of their case in chief. There is some overlap in this responsive testimony

23 with the Direct Testimony I submitted in support of Level 3’s counterclaims. To the Response of Mack D. Greene Level 3 Exhibit MDG 3.0 Public Version

24 extent necessary, I adopt my Direct Testimony for purpose of responding to

25 Complainant’s Direct Testimony of Mr. Fox, Mr. Summersett, and Mr. Eaton. In this

26 testimony, I will provide additional information to respond to the claims made by

27 Complainants. Tim Bruny provided testimony on October 2, 2014 containing accounting

28 of the amounts paid and the refund that is due to Level 3; that testimony also responds to

29 GLC and WTC’s claims of what amounts are claimed to be owed.

30 Q. WHAT IS THE NATURE OF LEVEL 3’S DISPUTE WITH GREAT LAKES AND

31 WESTPHALIA?

32 A. As described in my Direct testimony, in 2010, Level 3 began to see a spike in the volume

33 of calls destined to Level 3’s toll free (888, 800, 866, etc., “8YY”) customers routed

34 through the Great Lakes’ tandem in Westphalia, Michigan. Invoices sent by Great Lakes

35 and Westphalia represent that these telephone calls were originated by Local Exchange

36 Carrier of Michigan (“LEC MI”), but we have learned that LEC MI’s end users did not

37 originate these calls. Great Lakes must demonstrate that the calls originated with an end

38 user placing a call from the LEC MI local exchange. We do not believe, based on the

39 calling party number of the call detail records, and other information developed through

40 discovery, that these calls originate with a LEC MI end user or in the LEC MI local

41 exchange. The list of the LEC MI Local Exchanges is set for in LEC MI’s MPSC Tariff

42 No. 1R, parts of which are submitted as Exhibit Level 3 MDG 3.1. For those calls that do

43 originate in LEC MI’s local exchange, Great Lakes can only charge rates equivalent to

44 the rates charged by the incumbent local exchange carrier (“ILEC”) in the LATA in

45 which the calls originate. In this instance, Michigan Bell Telephone Company (“AT&T

46 Michigan”) is the ILEC in Southfield, and Great Lakes is limited to charge no more than Response of Mack D. Greene Level 3 Exhibit MDG 3.0 Public Version

47 AT&T Michigan’s tandem switched access rates, and the rates per minute per mile for

48 the transport.

49 Q. MR. SUMMERSETT AND MR. FOX ASSERT THAT LEVEL 3 HAS FAILED TO

50 PAY FOR TANDEM SWITCHED AND TRANSPORT SERVICES FOR

51 CERTAIN CALLS. DOES LEVEL 3 DISPUTE THAT MANY OF THE CALLS

52 WERE ACCESS CALLS?

53 A. Yes. Through discovery and admissions made by GLC and WTC, we have come to learn

54 that the telephone calls that are the subject of the dispute are were not telephone calls that

55 were originated by a LEC MI end user, and therefore, neither LEC MI local exchange

56 switch nor the upstream GLC tandem provided Level 3 access to LEC MI’s end users.

57 Recall in my earlier testimony that I described the purpose of access charges. Access

58 charges are intended to compensate the originating local exchange carriers, LEC MI in

59 this instance, and their partners for the network cost it incurs in making its network

60 available so that Level 3 can “access” LEC MI’s end user who wishes to complete a call

61 to Level 3’s 8YY customer. We have come to learn that the vast majority of the charges

62 in questions relate to calls to Level 3 that are not originated by LEC MI’s end users.

63 Q. YOU STATE THAT THERE HAS BEEN A LOT OF TRAFFIC THAT WAS NOT

64 ORIGINATED BY A LEC MI END USER PLACING A CALL TO LEVEL 3. ON

65 WHAT BASIS DO YOU MAKE THAT STATEMENT?

66 A. There are several statements made by GLC and WTC that confirm these facts. GLC

67 exhibit GLC-4 purports to describe the network configuration for the supposed access

68 services provided by LEC MI, GLC and WTC. However, based on the description of the

69 diagram from Mr. Summersett of GLC and Mr. Irvin of LEC MI, the vast majority of the Response of Mack D. Greene Level 3 Exhibit MDG 3.0 Public Version

70 traffic in dispute could not be originated from a LEC MI end user.

71 Mr. Summersett’s exhibit shows two transport lines, which he described as Trunk

72 Group 313 to carry “Southfield All Types” and Trunk Group 331 “8YY Toll” calls.

73 Q. WHAT IS A TRUNK GROUP?

74 A. Calls are routed over physical transport facilities, which can be fiber or copper wire of

75 varying capacities (DS1, DS3, OC-12, etc.) or combinations of these physical facilities.

76 These physical facilities are programed with equipment at each end of the physical route

77 to create virtual call paths. A transport route is like an Interstate highway, while a trunk

78 is like solid white lines painted on the highway to create virtual call paths. Like the

79 physical facility, the trunk groups can also be rated according to capacity, such as a DS1,

80 DS3, or OC-12.

81 Q. WHAT ARE THE TRUNK GROUPS CONNECTING LEC MI’S END OFFICE

82 AND GLC’S TANDEM, AS REFERENCED IN EXHIBIT GLC-4?

83 A. Three things. First, according to Mr. Irvin, Trunk Group 313 was used to route local

84 exchange traffic that originates with a LEC MI end user. This is reflected in the dashed

85 lines of Exhibit GLC-3 in the top of the LEC MI End Office (“EO”). According to Mr.

86 Irvin, LEC MI’s local exchange switch did indeed switch its end user calls and route

87 these calls to Trunk Group 313. The calls that were routed over Trunk Group 313 were

88 connected to local loop facilities connected to its end users located in the local exchange

89 territory of LEC MI.

90 Calls routed over Trunk Group 331 were not from LEC MI end users. Exhibit Response of Mack D. Greene Level 3 Exhibit MDG 3.0 Public Version

91 Level 3 MDG 3.2 (Conf. Irvin Dep. at 51.1) Calls over Trunk Group 331 were not even

92 connected to local loop facilities in the LEC MI end office, nor did the LEC MI end

93 office provide local switching functionality for the calls. Exhibit Level 3 MDG 3.2

94 (Conf. Irvin Dep. at 47, 51.) Instead, these calls were transited through a different piece

95 of equipment that resided across the street from the LEC MI local switch. Exhibit Level

96 3 MDG 3.2 (Conf. Irvin Dep. at 52.) Calls that were routed over Trunk Group 331 were

97 delivered to a session border controller that received traffic from the Internet, and

98 specifically from 7 Internet Protocol (“IP”) addresses. Exhibit Level 3 MDG 3.2 (Conf.

99 Irvin Dep. at 56.) LEC MI did not provide local switching on the calls, and only

100 converted the calls from IP to TDM; LEC MI did not even know that GLC was billing

101 the calls as locally switched. Exhibit Level 3 MDG 3.2 (Conf. Irvin Dep. at 47.) These

102 calls are represented in Exhibit GLC-4 as a cloud with “8YY Toll Call” in the cloud.

103 These calls from the Internet could not physically originate with a LEC MI end user

104 inasmuch as such end users were mapped to Trunk Group 313, and consequently these

105 calls could not technically provide Level 3 with “access” to end users within the LEC MI

local exchange. ***[BEGIN CONFIDENTIAL]

108 [END CONFIDENTIAL]*** Exhibit Level 3 MDG 3.3

109 (Conf. Summersett Dep. at 78-79.2)

1 LEC MI did not identify any of Mr. Irvin’s Deposition testimony as confidential. However, Level 3 has filed this deposition under seal with the MPSC at this time to afford WTC and GLC an opportunity to designate its own information as confidential. Level 3 does not assert that any of the information in the deposition is confidential 2 Level 3 has filed excerpts of the Deposition of Mr. Summersett and Mr. Fox under seal at this time to afford WTC and GLC an opportunity to designate its own information as Response of Mack D. Greene Level 3 Exhibit MDG 3.0 Public Version

110 Second, the capacity of Trunk Group 331 and Trunk Group 313 were significantly

111 different. There were perhaps approximately 2,000,000 minutes of use per month over

112 Trunk Group 313 (Exhibit Level 3 MDG 3.2, Conf. Irvin Dep. at p. 23), representing the

113 calls made from LEC MI’s end users, and up to 9 DS3’s (Exhibit Level 3 MDG 3.2,

114 Conf. Irvin Dep. at 34) (about 81,000,000) minutes of use per month of calls over Trunk

115 Group 331, representing the calls that came over the Internet from 7 IP addresses.

116 Third, Trunk Group 331 and Trunk Group 313 were routed over different physical

117 routes. Trunk Group 331 was routed over fiber facilities that were interconnected in Flint

118 Michigan. Exhibit 3.2 (Conf. Irving Dep. at 30). Trunk Group 313 was transported over

119 other facilities with a point of interconnection between LEC MI and GLC in Lansing.

120 Exhibit 3.2 (Conf. Irving Dep. at 30). Calls over Trunk Group 331 travel on LEC MI’s

121 facilities for approximately 60% of the route and on GLC’s network for 40% of the route.

122 Q. WHAT DOES LEC MI SAY ARE SOME OF THE DIFFERENCES BETWEEN

123 TRUNK GROUP 331 AND TRUNK GROUP 313 THAT RELATE TO WHETHER

124 SWITCHED ACCESS CHARGES ARE OWED TO GLC AND WTC?

125 A. LEC MI in response to discovery requests described that ***[BEGIN

CONFIDENTIAL]

130

confidential. Level 3 does not assert that any of the information in the deposition is confidential. Response of Mack D. Greene Level 3 Exhibit MDG 3.0 Public Version

133

137 [END CONFIDENTIAL]*** as LEC MI’s purported local

138 switched tariff rates. It also demonstrates that the calls were not originating from LEC

139 MI end users.

140 Q. WHO ARE THE REGISTERED PARTIES OF THE 7 IP ADDRESSES?

141 A. In response to the subpoena, LEC MI provided us with the following IP addresses that

142 GLC gave to LEC MI: 199.232.41.195, 199.232.41.197, 68.171.141.8, 68.171.141.9,

143 216.176.1.10, 216.176.1.11, 199.232.41. The IP addresses are registered to a group

144 called Mobile Sphere. Mobile Sphere’s Co-Founder, President and CTO is Toufic

145 Moborak. Toufic Moborak is also the CTO of Nuleef, and Nuleef’s President is James D.

146 Mola, who is also the president of IBDC. Furthermore, for two of the IP Addresses GLC

147 is the referenced contact for abuse and technical issues, reflecting a high degree of

148 management and control over these IP addresses by GLC. Information relating to these

149 IP addresses is submitted as Exhibit Level 3 MDG 3.5.

150 Q. DOES GLC HAVE A CONTRACT WITH SOME OR ALL OF THESE THIRD

151 PARTIES?

A. ***[BEGIN CONFIDENTIAL]

153 Response of Mack D. Greene Level 3 Exhibit MDG 3.0 Public Version

159

162

167

174 [END CONFIDENTIAL]***

175 Q. DID GTC AND WTC PAY COMPENSATION TO THIS INTERMEDIATE

176 CARRIER FOR THE TRAFFIC OVER TRUNK GROUP 331? Response of Mack D. Greene Level 3 Exhibit MDG 3.0 Public Version

A. ***[BEGIN CONFIDENTIAL]

179 [END CONFIDENTIAL]***

180 Q. BASED ON THE FOREGOING, DOES LEVEL 3 AGREE WITH GLC AND

181 WTC’S ASSERTION THAT THE CALLS TRANSITED OVER TRUNK GROUP

182 331 ARE CALLS FOR WHICH “ACCESS SERVICE” IS PROVIDED?

183 A. No. According to Mr. Summersett (Direct Testimony at 4) “[t]he Michigan

184 Telecommunications Act [MCL484.2101 et seq.] defines access service as ‘[a]ccess to a

185 local exchange network for the purpose of enabling a provider to originate or terminate

186 telecommunications services within the local exchange.’” For traffic over Trunk Group

187 331, neither GLC nor WTC provided Level 3 with access to a local exchange network for

188 the purpose of enabling Level 3 to originate telecommunications services within the local

189 exchange.

190 Q. PLEASE DESCRIBE THE ROUTE OF THE 8YY TRAFFIC AT ISSUE HERE.

191 A. The 8YY calls that are the subject of this proceeding are initiated by an end user typically

using a wireless phone. ***[BEGIN CONFIDENTIAL]

195 [END CONFIDENTIAL]*** to either John

196 Lodden’s Michigan Network Services or LEC MI in Southfield. Notably, the calls are

197 not locally switched in Southfield, but rather there is only a conversion of the call from IP

198 format to TDM format. The call is then transported from Southfield to Westphalia, at

199 which point WTC hands the call off to GLC, which carries the call from the exchange Response of Mack D. Greene Level 3 Exhibit MDG 3.0 Public Version

200 boundary of the Westphalia exchange less than one mile to GLC’s tandem switch; and is

201 then – after a dip into the 8YY database – delivered by GLC to Level 3. Exhibit Level 3

202 MDG 3.3 (Conf. Summersett Dep. at 168-169).

203 Q. PLEASE DESCRIBE THE FINANCIAL ARRANGEMENTS OR AGREEMENTS

204 THAT GIVE RISE TO THIS ROUTING PATTERN.

A. We have learned that ***[BEGIN CONFIDENTIAL]

212

218

222 [END CONFIDENTIAL]*** Response of Mack D. Greene Level 3 Exhibit MDG 3.0 Public Version

223 Q. FOR EVERY DOLLAR PAID BY LEVEL 3, WHO RECEIVED WHAT

224 PERCENTAGE?

225 A. We are still trying to unravel the exact compensation, but we believe that ***[BEGIN

CONFIDENTIAL]

228 [END CONFIDENTIAL]*** We are still in the process of

229 identifying the compensation paid to the other players.

230 Q. WHY IS THIS PROBLEMATIC?

231 A. Level 3 submitted ASRs for trunks sufficient to provide access to end users in the local

232 exchange territories of the local carriers that subtend the GLC tandem.. Level 3 did not

233 order access to ***[BEGIN CONFIDENTIAL] [END CONFIDENTIAL]***

234 customers, or the customers of the other carriers that brought traffic through that

235 company. Essentially, GLC performed a bait and switch and received an unlawful

236 increase in the amount of money they attempted to collect as a result of this scheme.

237 Q. IS THERE INFORMATION AVAILABLE ON THE ORIGIN OF THE CALLS?

238 A. Yes. First, Mr. Summersett acknowledges that the calls routed over Trunk Group 331

239 were 8YY calls that originated with wireless carriers. Based on the call detail records

240 that GLC provided to Level 3 and that Level 3 produced in my Direct Testimony (Exhibit

241 MDG 1.2), we know that most of the calls originated with Cricket Wireless. Level 3

242 subpoenaed Cricket Wireless for information on a random sample of 2300 telephone

243 numbers on which GLC and WTC billed access charges to Level 3 for purported access

244 calls in November 2013. The sample was derived using an algorithm (DBMS_Random)

245 built into the Oracle database that housed the call detail records to make sure that the Response of Mack D. Greene Level 3 Exhibit MDG 3.0 Public Version

246 numbers provided to Cricket were random. A copy of the Excel Spreadsheet with these

247 2300 telephone numbers that was submitted to Cricket is attached as Exhibit Level 3

248 MDG 3.10 (Confidential). Cricket Wireless produced call detail records for telephone

249 calls to these calls, and included the state of origin for all calls made by the telephone

250 numbers in November 2013. The records indicate that all of the calls originated outside

251 of the state of Michigan. An Excel spreadsheet of the call detail records produced by

252 Cricket is submitted on a CD-Rom as Exhibit Level 3 MDG 3.11 (Confidential) The

253 following is an example of the information provided in the records produced by Cricket:

254

255 Q. HAS LEVEL CONDUCTED AN ANALYSIS OF THE STATE OF ORIGIN FOR

256 CALLS FOR WHICH ACCESS CHARGES WERE BILLED BY GLC AND WTC?

257 A. Yes, and none of the calls for which GLC and WTC billed access charges on these

258 telephone numbers originated in Michigan. Here is the breakdown of the state of origin

259 for calls on which GLC and WTC billed Level 3 access charges.

Orig State Seconds Minutes % of Total TX 5,565,666 92,761 23% AZ 2,191,035 36,517 9% OH 2,055,607 34,260 8% CA 1,970,621 32,844 8% Response of Mack D. Greene Level 3 Exhibit MDG 3.0 Public Version

PA 1,736,678 28,945 7% CO 1,507,992 25,133 6% OK 1,338,964 22,316 5% MO 1,129,789 18,830 5% NV 1,098,175 18,303 5% AR 980,392 16,340 4% KS 837,657 13,961 3% WI 640,169 10,669 3% (blank) 632,313 10,539 3% UT 548,172 9,136 2% NJ 450,624 7,510 2% NE 400,361 6,673 2% WA 366,064 6,101 2% GA 196,433 3,274 1% IL 164,228 2,737 1% ID 127,336 2,122 1% DE 70,884 1,181 0% MD 67,148 1,119 0% TN 48,302 805 0% IA 41,850 698 0% LA 40,245 671 0% NC 35,966 599 0% MS 26,585 443 0% SC 22,899 382 0% NM 21,868 364 0% KY 19,469 324 0% IN 9,907 165 0% DC 9,022 150 0% OR 5,718 95 0% AL 1,357 23 0% VA 1,111 19 0% Grand 24,360,607 406,010 100% Total

260 This would reflect the state of origin for the other calls billed by GLC and WTC from

261 Cricket Wireless. Exhibit Level 3 MDG 3.11 (Confidential.)

262 Q. IS THERE EVIDENCE THAT DEMONSTRATES THAT GLC

263 INTENTIONALLY DESIGNED THIS IMPROPER TRANSIT ROUTE?

264 A. Yes. First, Mr. Summersett testified, GLC did not have the ability to receive calls

265 delivered to it in IP format 2010 and did not have the ability to convert IP traffic to TDM

266 to route it to Level 3. Exhibit Level 3 MDG 3.3 (Conf. Summersett Dep. at 112.) When Response of Mack D. Greene Level 3 Exhibit MDG 3.0 Public Version

GLC agreed to its contract with ***[BEGIN CONFIDENTIAL]

269 [END CONFIDENTIAL]*** This arrangement allowed GLC to attempt to

270 collect transport fees on 82 miles of distance charges. Mr. Summersett testified that John

271 Lodden’s company, Michigan Network Services was handling the calls because they had

272 a session border controller that could handle the IP formatted traffic. Exhibit Level 3

273 MDG 3.3 (Conf. Summersett Dep. at 113.)

274 Q. WHY DID GLC CREATE THESE TWO TRUNK GROUPS?

275 A. Summerset admitted that he had made a recommendation to put this traffic on a separate

276 trunk group “because it would be easier to identify that traffic being on a separate trunk

277 group.” Exhibit Level 3 MDG 3.3 (Conf. Summersett Dep. at 81.) He further admitted

278 that “we did rely on the different trunk groups for identifying the appropriate billing.”

279 Exhibit Level 3 MDG 3.3 (Conf. Summersett Dep. at 81.)

280 Q. WHAT IS THE SIGNIFICANCE OF THE TWO TRUNK GROUPS?

281 A. Because GLC had separated the traffic into the two trunk groups, GLC could have

282 separately identified this traffic in their bills to Level 3. GLC did not do this. Mr.

283 Summersett states that Level 3 has disputed long distance calls that originate from end

284 users served by LEC MI, as well as the 8YY toll free traffic from wireless users. We

285 have disputed both because GLC and WTC have not segregated the traffic in their bills to

286 Level 3.

287 Q. HAS TRUNK GROUP 331 CHANGED OVER TIME?

288 A. GLC initially changed its route by specifically creating this trunk group for the traffic that

289 is at issue in this case. In addition, GLC increased the size and capacity of Trunk Group Response of Mack D. Greene Level 3 Exhibit MDG 3.0 Public Version

290 331 over time. LECMI testified that at one point in time, the capacity on trunk group 331

291 was up to 9 DS3s (in excess of 81,000,000 minutes of use per month) and that the

292 capacity was changed depending on the volume of traffic traveling through the trunk

293 group. Exhibit Level 3 MDG 3.2 (Conf. Irvin Dep. at 26.)

294 Q. DO YOU HAVE ANY OTHER EVIDENCE OF GLC’S KNOWLEDGE THAT

295 THE CALLS WERE IMPORTED FROM SOURCES OTHER THAN LEC MI

296 END USERS?

297 A. Yes. GLC and WTC originally billed LEC MI’s local switching rate elements on the

298 traffic that was routed over Trunk Group 331. However, in the face of multiple access

299 charge disputes, GLC was forced to acknowledge that the calls did not originate with a

300 local exchange customer of LEC MI, and did not get switched by the LEC MI’s local

301 switch. GLC and WTC, in an attempt to increase the longevity of their scheme, refunded

302 and credited back to Level 3 the local switching rate elements. This action demonstrates

303 that GLC and WTC understood that no local switching was being conducted, and as such,

304 no local end user traffic was being exchange on Trunk Group 331.

305 Q. PLEASE DESCRIBE HOW THAT HAPPENED.

306 A. In 2013, GLC started to credit back local switching rate elements that had been charged

307 to Level 3. GLC had billed Level 3 access charges for WLC, GLC, and LEC MI, but one

308 of the rate elements, local switching, occurred at the LEC MI end office. Beginning in

309 May 2013, after Level 3 challenged these rates, GLC and WTC credited back to January

310 2012, and each month thereafter through February 2014, the LEC MI local switching rate

311 element against Level 3’s unpaid charges. Exhibit Level 3 MDG 3.12 (Confidential)

312 Q. WHY IS THIS SIGNIFICANT? Response of Mack D. Greene Level 3 Exhibit MDG 3.0 Public Version

313 A. By this action, GLC and WTC acknowledged that they recognized that the traffic routed

314 through trunk group 331 was not locally switched and had not originated with an LECMI

315 end user. GLC and WTC have not charged the local switching element since.

316 Q. MR. EATON STATES THAT LEVEL 3 BENEFITED FROM THE GLC

317 TANDEM SWITCHING SERVICES (EATON DIRECT, P. 10). DO YOU AGREE

318 WITH THIS?

319 A. Level 3 did not benefit from the routing of wireless 8YY transported traffic to the GLC

320 tandem. First, that traffic routed over Trunk Group 331 should have been delivered to

321 Level 3 in the local exchange territory in which it originated. Second, Level 3 does not

322 benefit from having the traffic routed over 82 miles of transport facilities. Level 3 and

323 LEC MI are directly connected to each other in Southfield, Michigan. In fact, LEC MI’s

324 local exchange switch is located just 18 feet from the Level 3 point of presence in

325 Southfield. If the traffic was indeed routed through the LEC MI end office, Level 3

326 would have benefited only if that traffic was delivered by LEC MI to Level 3 over the 18

327 feet of transport.

328 Q. MR. SUMMERSETT DISCUSSES THE LOCAL EXCHANGE ROUTING GUIDE

329 (“LERG”). IS THE LERG RELEVANT IN THIS CASE?

330 A. It is relevant to demonstrate that the routing of 8YY wireless calls through Trunk Group

331 331 is not related to Local Exchange Routing. I note that Mr. Summersett sites to the

332 website http://www.trainfo.com/products_services/tra/catalog_details.html for

333 information on the LERG, and has copied information from that website into his

334 testimony. But the website notes that the LERG is for “the current local exchange

335 network.” In the LERG, the GLC tandem was identified as the host tandem switch for Response of Mack D. Greene Level 3 Exhibit MDG 3.0 Public Version

336 certain access calls. But neither ***[BEGIN CONFIDENTIAL] [END

337 CONFIDENTIAL]*** or other carrier that delivered the wireless 8YY toll free calls

338 over the 7 IP addresses is identified as the originating end office for the GLC Tandem.

339 Therefore, the LERG supports Level 3’s view that access charges cannot apply to the

340 traffic routed over Trunk Group 331.

341 Q. MR. SUMMERSETT DISCUSSES THAT LEVEL 3 SUBMITTED ASR’S TO

342 ORDER ACCESS SERVICES. ARE THOSE ASR’S RELEVANT TO THIS

343 CASE?

344 A. Like the LERG, the ASRs are only relevant to demonstrate that Level 3 did not submit

345 ASRs to request access to Cricket Wireless end users, or any of the other carriers whose

346 calls GLC routed over Trunk Group 331.

347 Q. MR. FOX DISCUSSES THAT WTC AND GLC RELY ON CABS BILLING

348 PROCESSES TO BILL THESE SWITCHED ACCESS CHARGES. HAS WTC

349 AND GLC CONDUCTED THE BILLING IN A MANNER THAT IS

350 CONSISTENT WITH INDUSTRY PRACTICE?

351 A. No. First, CABS billing is a process by which originating and terminating access charges

352 are billed. As I discussed before, the calls over Trunk Group 331 are not access calls.

353 Second, WTC and GCL have billed calls under their tariffs as if the calls originated in

354 Michigan, which they do not. Third, when the calling party telephone number is

355 available in the call detail record, the proper way to bill per industry practice and GLC’s

356 own tariff, is to rely on the originating telephone and use the originating telephone

357 number for billing. Thus calls with a phone number issued by LEC MI would be used to

358 identify calls that could be billed as originating with a LEC MI end user in its local Response of Mack D. Greene Level 3 Exhibit MDG 3.0 Public Version

359 exchange territory.

360 Q. MR. FOX ASSERTS THAT GLC AND WTC CAN USE THE PIUs THAT LEVEL

361 3 SUBMITTED TO GLC AND WTC TO IDENTIFY HOW MUCH TO CHARGE

362 FOR INTERSTATE AND INTRASTATE CALLS. IS THAT TRUE?

363 A. PIU’s are to be used either when the originating telephone number is unavailable by

364 virtue of no fault of the originating and intermediate carriers, or after you determine the

365 origin of the call. Once the origin of the call is determined, you can apply the PIUs of the

366 state of origin to those calls where the terminating state cannot be determined, such as on

367 calls to an 8YY subscriber. But what WTC and GLC have done is apply the PIU’s to

368 calls that do not originate in Michigan. If a wireless 8YY call originates in Texas, based

369 on the originating telephone of the local exchange of the originating carrier, then GLC or

370 WTC could apply their Texas tariff to determine which calls are to be billed under the

371 Texas tariff, or GLC or WTC’s FCC tariffs for interstate calls. Level 3’s PIUs were not

372 provided to GLC or WTC to bill for calls that did not originate in Michigan and/or calls

373 that had the originating calling number in the data stream.

374 Q. HASLEVEL3DISPUTEDTHECHARGES?

375 A. Level 3 has disputed the improper charges almost from the beginning, and Mr. Fox

376 recognizes that Level 3 began disputing the charges immediately when there was a spike

377 in 2010. Mr. Fox’s claim that Level 3 did not complain until February 2013 is not

378 accurate. Indeed, Mr. Fox testified in his deposition that he had conversations with Level

379 3 back in 2010 and 2011 about the disputes, but doesn’t specifically remember what was

380 said. Exhibit Level 3 MDG 3.13 (Fox Dep. at 111-112.) Level 3 has disputed the

381 charges since 2010, and informed Mr. Fox and WTC in 2012 and 2013 that the traffic Response of Mack D. Greene Level 3 Exhibit MDG 3.0 Public Version

382 being billed did not originate with the Southfield end office. Id. Level 3 also disputed

383 the rates that WTC and GLC billed at that time. Since at least May 2012, (Exhibit Level

384 3 MDG 3.14, Level 3 and WTC have engaged in a series of efforts to resolve the dispute,

385 but those efforts have proven unsuccessful. Mr. Fox’s claim that Level 3 did not follow

386 the procedures under GLC and WTC’s tariffs for dispute does not apply, because the

387 calls at issue did not originate in Michigan and are not subject to the Michigan tariff.

388 Q. MR. FOX ALSO ASSERTS THAT LEVEL 3 HAS NOT YET ASSERTED A

389 CLAIM AGAINST GLC OR WTC OTHER THAN MICHIGAN IN RELATION

390 TO THE DISPUTED CHARGES? IS THAT STILL TRUE?

391 A. No. In addition to bringing the counterclaims in this case, Level 3 has now initiated the

392 informal complaint procedures to bring this issue to resolution before the FCC. Level 3

393 believes that GLC and WTC’s practices are unlawful and Level 3 will pursue its remedies

394 here and at the FCC.

395 Q. DOES THAT CONCLUDE YOUR TESTIMONY

396 A. Yes it does. STATE OF MICHIGAN

BEFORE THE MICHIGAN PUBLIC SERVICE COMMISSION

RESPONSE TESTIMONY OF MACK D. GREENE ON BEHALF OF LEVEL 3 COMMUNICATIONS, LLC GLOBAL CROSSING LOCAL SERVICES, INC. and WILTEL COMMUNICATIONS, LLC

EXHIBIT MDG 3.1

PUBLIC

STATE OF MICHIGAN

BEFORE THE MICHIGAN PUBLIC SERVICE COMMISSION

RESPONSE TESTIMONY OF MACK D. GREENE ON BEHALF OF LEVEL 3 COMMUNICATIONS, LLC GLOBAL CROSSING LOCAL SERVICES, INC. and WILTEL COMMUNICATIONS, LLC

EXHIBIT MDG 3.1

123.Net, Inc. d/b/a Local Exchange Carriers of Michigan, Inc. Tariff M.P.S.C. No. 1R Original Title Page

123.Net, Inc. d/b/a Local Exchange Carriers of Michigan, Inc.

Regulations and Schedule of Intrastate Charges Applying to Local End-User Telecommunications Service Within the State of Michigan

TARIFF MICHIGAN PUBLIC SERVICE COMMISSION (MPSC) No. 1R

Issued under the authority of the Michigan Public Service Commission in an Order dated April 23, 1999 in Case No. U-11877 and an Order dated July 11, 2001 in Case No. U-12916.

Issued: April 22, 2014 Effective: April 23, 2014

Issued by: James Kandler, Chief Operating Officer E-Mail: [email protected] 24700 Northwestern Hwy., Ste. 700, Southfield, MI 48075 Phone: (248) 724-2201 123.Net, Inc. d/b/a Local Exchange Carriers of Michigan, Inc. Tariff M.P.S.C. No. 1R Table of Contents – Original Page 2

TABLE OF CONTENTS

TABLE OF CONTENTS...... 1

PREFACE...... 1

Check Sheet ...... 1 Explanation of Symbols, Reference Marks, and Abbreviations of Technical Terms Used in This Tariff ...... 2 Application of Tariff...... 3

SECTION 1: DEFINITIONS...... 1

SECTION 2: REGULATIONS...... 1

2.1 Undertaking of the Company...... 1 2.2 Prohibited Uses ...... 12 2.3 Obligations of the Customer ...... 13 2.4 Customer Equipment and Channels – Business Customers ...... 16 2.5 Payment Arrangements...... 19 2.6 Allowances for Interruptions in Service ...... 35 2.7 Restoration of Service...... 39 2.8 Use of Customer’s Service by Others...... 40 2.9 Cancellation of Service...... 41 2.10 Transfers and Assignments...... 42 2.11 Notices and Communications ...... 43 2.12 Formal and Informal Procedures ...... 44 2.13 Customer Access to Information ...... 46

SECTION 3: SERVICE OFFERINGS ...... 1

3.1 General...... 1 3.2 Charges Based on Duration of Use...... 3 3.3 Rates Based on Distance...... 5 3.4 Calculation of Distance...... 6 3.5 Directory Listings ...... 7 3.6 Type of Services Offered...... 8 3.7 Basic Local Exchange Service...... 9 3.8 Directory Assistance Service ...... 13

Issued under the authority of the Michigan Public Service Commission in an Order dated April 23, 1999 in Case No. U-11877 and an Order dated July 11, 2001 in Case No. U-12916.

Issued: April 22, 2014 Effective: April 23, 2014

TABLE OF CONTENTS Continued

SECTION 4: RATES AND CHARGES...... 1

4.1 Basic Local Exchange Service...... 1 4.2 Service Charges ...... 2 4.3 Lifeline Program ...... 6 4.4 Emergency Services...... 10 4.5 Telecommunications Relay Service...... 10 4.6 Telephone Director ...... 10 4.7 Directory Assistance ...... 11 4.8 Call Blocking Service ...... 12 4.9 Rates By Individual Contract Basis ...... 12 4.10 Promotional Offerings ...... 13

SECTION 5: SERVICE AREAS...... 1

5.1 Legal Description and Maps ...... 1 5.2 Local Calling Areas ...... 15 5.3 List of Cities, Villages, and Townships...... 51

Issued under the authority of the Michigan Public Service Commission in an Order dated April 23, 1999 in Case No. U-11877 and an Order dated July 11, 2001 in Case No. U-12916.

Issued: April 22, 2014 Effective: April 23, 2014

SECTION 5 – SERVICE AREAS Continued

5.1 Legal Descriptions and Maps, Cont’d

Exchange Incumbent Local Exchange Carrier SECTION 5 – SERVICE AREAS

5.1 Legal Descriptions and Maps

The Company hereby mirrors the Map and Legal Description listed in the tariff(s) of the Incumbent Local Exchange Carrier, for the exchanges listed below to identify its service territory. Any future modifications to these exchange boundaries or legal descriptions of these boundaries will be automatically mirrored by the Company on a going forward basis. If not mirrored, new detailed maps and legal descriptions on an individual exchange basis will be filed with the MPSC for approval.

Exchange Incumbent Local Exchange Carrier Akron AT&T Michigan Albion AT&T Michigan Algonac AT&T Michigan Amasa AT&T Michigan Ann Arbor AT&T Michigan Applegate AT&T Michigan Armada AT&T Michigan Athens AT&T Michigan Auburn AT&T Michigan Bad Axe AT&T Michigan Baldwin AT&T Michigan Bark River AT&T Michigan Battle Creek AT&T Michigan Bay City AT&T Michigan Bay Port AT&T Michigan Beaverton AT&T Michigan Belding AT&T Michigan Belleville AT&T Michigan Bellevue AT&T Michigan Benton Harbor AT&T Michigan Bergland AT&T Michigan Berrien Springs AT&T Michigan Bessemer AT&T Michigan Beulah AT&T Michigan

Issued under the authority of the Michigan Public Service Commission in an Order dated April 23, 1999 in Case No. U-11877 and an Order dated July 11, 2001 in Case No. U-12916.

Issued: April 22, 2014 Effective: April 23, 2014

SECTION 5 – SERVICE AREAS Continued

5.1 Legal Descriptions and Maps, Cont’d

Exchange Incumbent Local Exchange Carrier Big Bay AT&T Michigan Big Rapids AT&T Michigan Birch Run AT&T Michigan Boyne City AT&T Michigan Brevort AT&T Michigan Brighton AT&T Michigan Buchanan AT&T Michigan Byron AT&T Michigan Cadillac AT&T Michigan Calumet AT&T Michigan Carleton AT&T Michigan Carsonville AT&T Michigan Casnovia AT&T Michigan Cedar Springs AT&T Michigan Champion AT&T Michigan Channing AT&T Michigan Charlevoix AT&T Michigan Charlotte AT&T Michigan Cheboygan AT&T Michigan Chelsea AT&T Michigan Clare AT&T Michigan Clarklake AT&T Michigan Clarksville AT&T Michigan Clio-Mt. Morris AT&T Michigan Coleman AT&T Michigan Coloma AT&T Michigan Coral AT&T Michigan Cornell AT&T Michigan Croswell AT&T Michigan Crystal Falls AT&T Michigan Curtis AT&T Michigan Dansville AT&T Michigan Dexter AT&T Michigan Dimondale AT&T Michigan East Jordan AT&T Michigan

Issued under the authority of the Michigan Public Service Commission in an Order dated April 23, 1999 in Case No. U-11877 and an Order dated July 11, 2001 in Case No. U-12916.

Issued: April 22, 2014 Effective: April 23, 2014

SECTION 5 – SERVICE AREAS Continued

5.1 Legal Descriptions and Maps, Cont’d

Exchange Incumbent Local Exchange Carrier East Tawas AT&T Michigan Eaton Rapids AT&T Michigan Eau Claire AT&T Michigan Elk Rapids AT&T Michigan Engadine AT&T Michigan Escanaba AT&T Michigan Evart AT&T Michigan Fairgrove AT&T Michigan Farwell AT&T Michigan Fenton AT&T Michigan Fife Lake AT&T Michigan Flat Rock AT&T Michigan Flint AT&T Michigan Flushing AT&T Michigan Fountain AT&T Michigan Fowlerville AT&T Michigan Frankenmuth AT&T Michigan Frankfort AT&T Michigan Freeland AT&T Michigan Freeport AT&T Michigan Freesoil AT&T Michigan Fremont AT&T Michigan Fulton AT&T Michigan Gagetown AT&T Michigan Galesburg AT&T Michigan Galien AT&T Michigan Gladstone AT&T Michigan Gladwin AT&T Michigan Grand Blanc AT&T Michigan Grand Haven AT&T Michigan Grant AT&T Michigan Greenville AT&T Michigan Gwinn AT&T Michigan Harbor Springs AT&T Michigan Harrietta AT&T Michigan

Issued under the authority of the Michigan Public Service Commission in an Order dated April 23, 1999 in Case No. U-11877 and an Order dated July 11, 2001 in Case No. U-12916.

Issued: April 22, 2014 Effective: April 23, 2014

SECTION 5 – SERVICE AREAS Continued

5.1 Legal Descriptions and Maps, Cont’d

Exchange Incumbent Local Exchange Carrier Harrison AT&T Michigan Hartland AT&T Michigan Hastings AT&T Michigan Hermansville AT&T Michigan Hillsdale AT&T Michigan Holland AT&T Michigan Holly AT&T Michigan Holt AT&T Michigan Hopkins AT&T Michigan Houghton AT&T Michigan Howell AT&T Michigan Indian River AT&T Michigan Interlochen AT&T Michigan Ionia AT&T Michigan Iron Mountain AT&T Michigan Iron River AT&T Michigan Irons AT&T Michigan Ironwood AT&T Michigan Ishpeming AT&T Michigan Jackson AT&T Michigan Jonesville AT&T Michigan Kalamazoo AT&T Michigan Kalkaska AT&T Michigan Kent City AT&T Michigan Keweenaw AT&T Michigan Lake Leelanau AT&T Michigan Lake Linden AT&T Michigan Lake Odessa AT&T Michigan Lansing AT&T Michigan Lapeer AT&T Michigan Le Roy AT&T Michigan Leslie AT&T Michigan Lexington AT&T Michigan Linwood AT&T Michigan Luther AT&T Michigan

Issued under the authority of the Michigan Public Service Commission in an Order dated April 23, 1999 in Case No. U-11877 and an Order dated July 11, 2001 in Case No. U-12916.

Issued: April 22, 2014 Effective: April 23, 2014

SECTION 5 – SERVICE AREAS Continued

5.1 Legal Descriptions and Maps, Cont’d

Exchange Incumbent Local Exchange Carrier Mackinac Island AT&T Michigan Mackinac City AT&T Michigan Mancelona AT&T Michigan Manchester AT&T Michigan Manistee AT&T Michigan Manton AT&T Michigan Marine City AT&T Michigan Marion AT&T Michigan Marquette AT&T Michigan Marshall AT&T Michigan Martin AT&T Michigan Mason AT&T Michigan Mayville AT&T Michigan Mc Bain AT&T Michigan Menominee AT&T Michigan Michigamme AT&T Michigan Middleville AT&T Michigan Midland AT&T Michigan Milan AT&T Michigan Monroe AT&T Michigan Morley AT&T Michigan Mt. Clemens AT&T Michigan Mulliken AT&T Michigan Napoleon AT&T Michigan Nashville AT&T Michigan Negaunee AT&T Michigan Newaygo AT&T Michigan New Baltimore AT&T Michigan Newberry AT&T Michigan New Boston AT&T Michigan New Buffalo AT&T Michigan New Haven AT&T Michigan Niles AT&T Michigan Northport AT&T Michigan Northville AT&T Michigan

Issued under the authority of the Michigan Public Service Commission in an Order dated April 23, 1999 in Case No. U-11877 and an Order dated July 11, 2001 in Case No. U-12916.

Issued: April 22, 2014 Effective: April 23, 2014

SECTION 5 – SERVICE AREAS Continued

5.1 Legal Descriptions and Maps, Cont’d

Exchange Incumbent Local Exchange Carrier Norway AT&T Michigan Olivet AT&T Michigan Onekama AT&T Michigan Oscoda AT&T Michigan Otsego AT&T Michigan Owendale AT&T Michigan Peck AT&T Michigan Pellston AT&T Michigan Perkins AT&T Michigan Petoskey AT&T Michigan Pinckney AT&T Michigan Plainwell AT&T Michigan Plymouth AT&T Michigan Port Huron AT&T Michigan Portland AT&T Michigan Port Sanilac AT&T Michigan Potterville AT&T Michigan Powers AT&T Michigan Rapid River AT&T Michigan Reed City AT&T Michigan Reese AT&T Michigan Republic AT&T Michigan Richland AT&T Michigan Rock AT&T Michigan Rockwood AT&T Michigan Romeo AT&T Michigan Rosebush AT&T Michigan Saginaw AT&T Michigan St. Charles AT&T Michigan St. Clair AT&T Michigan St. Helen AT&T Michigan St. Ignace AT&T Michigan St. Joseph AT&T Michigan Sand Lake AT&T Michigan Sandusky AT&T Michigan

Issued under the authority of the Michigan Public Service Commission in an Order dated April 23, 1999 in Case No. U-11877 and an Order dated July 11, 2001 in Case No. U-12916.

Issued: April 22, 2014 Effective: April 23, 2014

SECTION 5 – SERVICE AREAS Continued

5.1 Legal Descriptions and Maps, Cont’d

Exchange Incumbent Local Exchange Carrier Saranac AT&T Michigan Sault Ste. Marie AT&T Michigan Scotts AT&T Michigan Scottville AT&T Michigan Sebawaing AT&T Michigan Snover AT&T Michigan South Lyon AT&T Michigan Standish AT&T Michigan Stephenson AT&T Michigan Three Oaks AT&T Michigan Traverse City AT&T Michigan Trout Lake AT&T Michigan Trufant AT&T Michigan Tustin AT&T Michigan Ubly AT&T Michigan Unionville AT&T Michigan Utica AT&T Michigan Vassar AT&T Michigan Vermontville AT&T Michigan Vicksburg AT&T Michigan Wakefield AT&T Michigan Walloon Lake AT&T Michigan Washington AT&T Michigan Watersmeet AT&T Michigan Watervliet AT&T Michigan Wayland AT&T Michigan West Branch AT&T Michigan White Cloud AT&T Michigan Whitmore Lake AT&T Michigan Williamsburg AT&T Michigan Willis AT&T Michigan Wolverine AT&T Michigan Ypsilanti AT&T Michigan Zeeland AT&T Michigan

Issued under the authority of the Michigan Public Service Commission in an Order dated April 23, 1999 in Case No. U-11877 and an Order dated July 11, 2001 in Case No. U-12916.

Issued: April 22, 2014 Effective: April 23, 2014

SECTION 5 – SERVICE AREAS Continued

5.1 Legal Descriptions and Maps, Cont’d

Exchange Incumbent Local Exchange Carrier Detroit District Exchange AT&T Michigan Birmingham Zone AT&T Michigan Centerline Zone AT&T Michigan Detroit Zone AT&T Michigan Farmington Zone AT&T Michigan Livonia Zone AT&T Michigan Romulus Zone AT&T Michigan Roseville Zone AT&T Michigan Royal Oak Zone AT&T Michigan Southfield Zone AT&T Michigan Trenton Zone AT&T Michigan Troy Zone AT&T Michigan Warren Zone AT&T Michigan Wayne Zone AT&T Michigan West Bloomfield Zone AT&T Michigan Wyandotte Zone AT&T Michigan

Grand Rapids District Exchange AT&T Michigan Ada Zone AT&T Michigan Alto Zone AT&T Michigan Byron Center Zone AT&T Michigan Caledonia Zone AT&T Michigan Dorr Zone AT&T Michigan Dutton Zone AT&T Michigan Grand Rapids Zone AT&T Michigan Grattan Zone AT&T Michigan Hudsonville Zone AT&T Michigan Jamestown Zone AT&T Michigan Lowell Zone AT&T Michigan Marne Zone AT&T Michigan Moline Zone AT&T Michigan Rockford Zone AT&T Michigan Sparta Zone AT&T Michigan

Issued under the authority of the Michigan Public Service Commission in an Order dated April 23, 1999 in Case No. U-11877 and an Order dated July 11, 2001 in Case No. U-12916.

Issued: April 22, 2014 Effective: April 23, 2014

SECTION 5 – SERVICE AREAS Continued

5.1 Legal Descriptions and Maps, Cont’d

Exchange Incumbent Local Exchange Carrier Pontiac District Exchange AT&T Michigan Auburn Heights Zone AT&T Michigan Clarkston Zone AT&T Michigan Commerce Zone AT&T Michigan Drayton Plains Zone AT&T Michigan Lake Orion Zone AT&T Michigan Oxford Zone AT&T Michigan Pontiac Zone AT&T Michigan Rochester Zone AT&T Michigan Walled Lake Zone AT&T Michigan

Adrian Frontier North, Inc. Alden Frontier North, Inc. Allegan Frontier North, Inc. Alma Frontier North, Inc. Almont Frontier North, Inc. Alpena Frontier North, Inc. Ashley Frontier North, Inc. Atlanta Frontier North, Inc. Avoca Frontier North, Inc. Bancroft Frontier North, Inc. Bangor Frontier North, Inc. Barryton Frontier North, Inc. Bath Frontier North, Inc. Blissfield Frontier North, Inc. Breckenridge Frontier North, Inc. Britton Frontier North, Inc. Bronson Frontier North, Inc. Brown City Frontier North, Inc. Burr Oak Frontier North, Inc. Capac Frontier North, Inc. Carson City Frontier North, Inc. Caseville Frontier North, Inc. Cass City Frontier North, Inc. Cassopolis Frontier North, Inc.

Issued under the authority of the Michigan Public Service Commission in an Order dated April 23, 1999 in Case No. U-11877 and an Order dated July 11, 2001 in Case No. U-12916.

Issued: April 22, 2014 Effective: April 23, 2014

SECTION 5 – SERVICE AREAS Continued

5.1 Legal Descriptions and Maps, Cont’d

Exchange Incumbent Local Exchange Carrier Central Lake Frontier North, Inc. Centreville Frontier North, Inc. Clam River Frontier North, Inc. Clifford Frontier North, Inc. Clinton Frontier North, Inc. Coldwater Lake Frontier North, Inc. Coldwater Frontier North, Inc. Colon Frontier North, Inc. Columbiaville Frontier North, Inc. Conklin Frontier North, Inc. Constantine Frontier North, Inc. Coopersville Frontier North, Inc. Covert Frontier North, Inc. Davison Frontier North, Inc. Decatur Frontier North, Inc. Deckerville Frontier North, Inc. Dewitt Frontier North, Inc. Dowagiac Frontier North, Inc. Dryden Frontier North, Inc. Dundee Frontier North, Inc. Durand Frontier North, Inc. Eastport Frontier North, Inc. Edmore Frontier North, Inc. Edwardsburg Frontier North, Inc. Elkton Frontier North, Inc. Ellsworth Frontier North, Inc. Elsie Frontier North, Inc. Emmet Frontier North, Inc. Erie Frontier North, Inc. Fairview Frontier North, Inc. Fairview Frontier North, Inc. Fennville Frontier North, Inc. Fenwick Frontier North, Inc. Fowler-Pewamo Frontier North, Inc. Fruitport Frontier North, Inc.

Issued under the authority of the Michigan Public Service Commission in an Order dated April 23, 1999 in Case No. U-11877 and an Order dated July 11, 2001 in Case No. U-12916.

Issued: April 22, 2014 Effective: April 23, 2014

SECTION 5 – SERVICE AREAS Continued

5.1 Legal Descriptions and Maps, Cont’d

Exchange Incumbent Local Exchange Carrier Ganges Frontier North, Inc. Gaylord Frontier North, Inc. Gobles Frontier North, Inc. Goodells Frontier North, Inc. Grand Junction Frontier North, Inc. Grand Ledge Frontier North, Inc. Grass Lake Frontier North, Inc. Grayling Frontier North, Inc. Hamilton Frontier North, Inc. Harbor Beach Frontier North, Inc. Harrisville Frontier North, Inc. Hart Frontier North, Inc. Hartford Frontier North, Inc. Hemlock Frontier North, Inc. Hesperia Frontier North, Inc. Higgins Lakes Frontier North, Inc. Hillman Frontier North, Inc. Holton Frontier North, Inc. Houghton Lake Frontier North, Inc. Howard City Frontier North, Inc. Hubbard Lake Frontier North, Inc. Hubbardston Frontier North, Inc. Hudson Frontier North, Inc. Ida Frontier North, Inc. Imlay City Frontier North, Inc. Ithaca Frontier North, Inc. Jedo Frontier North, Inc. Kingston Frontier North, Inc. Lachine Frontier North, Inc. Laingsburg Frontier North, Inc. Lakeview Frontier North, Inc. Lawton Frontier North, Inc. Lewiston Frontier North, Inc. Lincoln Frontier North, Inc. Linden Frontier North, Inc.

Issued under the authority of the Michigan Public Service Commission in an Order dated April 23, 1999 in Case No. U-11877 and an Order dated July 11, 2001 in Case No. U-12916.

Issued: April 22, 2014 Effective: April 23, 2014

SECTION 5 – SERVICE AREAS Continued

5.1 Legal Descriptions and Maps, Cont’d

Exchange Incumbent Local Exchange Carrier Long Lake Frontier North, Inc. Lost Peninsula Frontier North, Inc. Ludington Frontier North, Inc. Maple Rapids Frontier North, Inc. Marcellus Frontier North, Inc. Mattawan Frontier North, Inc. Maybee Frontier North, Inc. McBride Frontier North, Inc. Memphis Frontier North, Inc. Mendon Frontier North, Inc. Merrill Frontier North, Inc. Metamora Frontier North, Inc. Middleton Frontier North, Inc. Milford-White Lake Frontier North, Inc. Minden City Frontier North, Inc. Mio Frontier North, Inc. Mt. Pleasant Frontier North, Inc. Muir Frontier North, Inc. Muskegon Frontier North, Inc. North Branch Frontier North, Inc. North Sylvania Frontier North, Inc. Onaway Frontier North, Inc. Ortonville Frontier North, Inc. Ossineke Frontier North, Inc. Otisville Frontier North, Inc. Ovid Frontier North, Inc. Owosso Frontier North, Inc. Palo Frontier North, Inc. Paw Paw Frontier North, Inc. Pentwater Frontier North, Inc. Pompeii Frontier North, Inc. Posen Frontier North, Inc. Quincy Frontier North, Inc. Rankin Frontier North, Inc. Ravenna Frontier North, Inc.

Issued under the authority of the Michigan Public Service Commission in an Order dated April 23, 1999 in Case No. U-11877 and an Order dated July 11, 2001 in Case No. U-12916.

Issued: April 22, 2014 Effective: April 23, 2014

SECTION 5 – SERVICE AREAS Continued

5.1 Legal Descriptions and Maps, Cont’d

Exchange Incumbent Local Exchange Carrier Reading Frontier North, Inc. Remus Frontier North, Inc. Richmond Frontier North, Inc. Riverdale Frontier North, Inc. Rogers City Frontier North, Inc. Roscommon Frontier North, Inc. Saline Frontier North, Inc. Saugatuck Frontier North, Inc. Schoolcraft Frontier North, Inc. Shelby Frontier North, Inc. Shepherd Frontier North, Inc. Sheridan Frontier North, Inc. Sidney Frontier North, Inc. Sister Lakes Frontier North, Inc. Six Lakes Frontier North, Inc. Smith Creek Frontier North, Inc. South Haven Frontier North, Inc. St. Johns Frontier North, Inc. St. Louis Frontier North, Inc. Stanton Frontier North, Inc. Stanwood Frontier North, Inc. Sturgis Frontier North, Inc. Swartz Creek Frontier North, Inc. Tecumseh Frontier North, Inc. Temperance Frontier North, Inc. Three Rivers Frontier North, Inc. Tipton Frontier North, Inc. Torch River Bridge Frontier North, Inc. Twin Lake Frontier North, Inc. Union City Frontier North, Inc. Union Frontier North, Inc. Vandalia Frontier North, Inc. Vanderbilt Frontier North, Inc. Vestaburg Frontier North, Inc. Weidman Frontier North, Inc.

Issued under the authority of the Michigan Public Service Commission in an Order dated April 23, 1999 in Case No. U-11877 and an Order dated July 11, 2001 in Case No. U-12916.

Issued: April 22, 2014 Effective: April 23, 2014

SECTION 5 – SERVICE AREAS Continued

5.1 Legal Descriptions and Maps, Cont’d

Exchange Incumbent Local Exchange Carrier White Pigeon Frontier North, Inc. Whitehall Frontier North, Inc. Williamston Frontier North, Inc. Woodland Frontier North, Inc. Yale Frontier North, Inc. Addison Frontier Midstates, Inc. Alger Frontier Midstates, Inc. Baroda Frontier Midstates, Inc. Bridgman Frontier Midstates, Inc. Burlington Frontier Midstates, Inc. Fitchburg Frontier Midstates, Inc. Glenn Frontier Midstates, Inc. Gregory Frontier Midstates, Inc. Homer Frontier Midstates, Inc. Lacota Frontier Midstates, Inc. Lambertville Frontier Midstates, Inc. Lawrence Frontier Midstates, Inc. Lupton Frontier Midstates, Inc. Morenci Frontier Midstates, Inc. Munith Frontier Midstates, Inc. Onondaga Frontier Midstates, Inc. Parma Frontier Midstates, Inc. Prescott Frontier Midstates, Inc. Pullman Frontier Midstates, Inc. Rives Junction Frontier Midstates, Inc. Rose City Frontier Midstates, Inc. Sawyer Frontier Midstates, Inc. Sterling Frontier Midstates, Inc. Stockbridge Frontier Midstates, Inc. Tekonsha Frontier Midstates, Inc. Webberville Frontier Midstates, Inc.

Issued under the authority of the Michigan Public Service Commission in an Order dated April 23, 1999 in Case No. U-11877 and an Order dated July 11, 2001 in Case No. U-12916.

Issued: April 22, 2014 Effective: April 23, 2014

Issued by: James Kandler, Chief Operating Officer E-Mail: [email protected] 24700 Northwestern Hwy., Ste. 700, Southfield, MI 48075 Phone: (248) 724-2201 STATE OF MICHIGAN

BEFORE THE MICHIGAN PUBLIC SERVICE COMMISSION

RESPONSE TESTIMONY OF MACK D. GREENE ON BEHALF OF LEVEL 3 COMMUNICATIONS, LLC GLOBAL CROSSING LOCAL SERVICES, INC. and WILTEL COMMUNICATIONS, LLC

EXHIBIT MDG 3.2

CONFIDENTIAL STATE OF MICHIGAN

BEFORE THE MICHIGAN PUBLIC SERVICE COMMISSION

RESPONSE TESTIMONY OF MACK D. GREENE ON BEHALF OF LEVEL 3 COMMUNICATIONS, LLC GLOBAL CROSSING LOCAL SERVICES, INC. and WILTEL COMMUNICATIONS, LLC

EXHIBIT MDG 3.3

CONFIDENTIAL STATE OF MICHIGAN

BEFORE THE MICHIGAN PUBLIC SERVICE COMMISSION

RESPONSE TESTIMONY OF MACK D. GREENE ON BEHALF OF LEVEL 3 COMMUNICATIONS, LLC GLOBAL CROSSING LOCAL SERVICES, INC. and WILTEL COMMUNICATIONS, LLC

EXHIBIT MDG 3.4

CONFIDENTIAL STATE OF MICHIGAN

BEFORE THE MICHIGAN PUBLIC SERVICE COMMISSION

RESPONSE TESTIMONY OF MACK D. GREENE ON BEHALF OF LEVEL 3 COMMUNICATIONS, LLC GLOBAL CROSSING LOCAL SERVICES, INC. and WILTEL COMMUNICATIONS, LLC

EXHIBIT MDG 3.5

PUBLIC

STATE OF MICHIGAN

BEFORE THE MICHIGAN PUBLIC SERVICE COMMISSION

RESPONSE TESTIMONY OF MACK D. GREENE ON BEHALF OF LEVEL 3 COMMUNICATIONS, LLC GLOBAL CROSSING LOCAL SERVICES, INC. and WILTEL COMMUNICATIONS, LLC

EXHIBIT MDG 3.5

STATE OF MICHIGAN

BEFORE THE MICHIGAN PUBLIC SERVICE COMMISSION

RESPONSE TESTIMONY OF MACK D. GREENE ON BEHALF OF LEVEL 3 COMMUNICATIONS, LLC GLOBAL CROSSING LOCAL SERVICES, INC. and WILTEL COMMUNICATIONS, LLC

EXHIBIT MDG 3.6

CONFIDENTIAL STATE OF MICHIGAN

BEFORE THE MICHIGAN PUBLIC SERVICE COMMISSION

RESPONSE TESTIMONY OF MACK D. GREENE ON BEHALF OF LEVEL 3 COMMUNICATIONS, LLC GLOBAL CROSSING LOCAL SERVICES, INC. and WILTEL COMMUNICATIONS, LLC

EXHIBIT MDG 3.7

CONFIDENTIAL STATE OF MICHIGAN

BEFORE THE MICHIGAN PUBLIC SERVICE COMMISSION

RESPONSE TESTIMONY OF MACK D. GREENE ON BEHALF OF LEVEL 3 COMMUNICATIONS, LLC GLOBAL CROSSING LOCAL SERVICES, INC. and WILTEL COMMUNICATIONS, LLC

EXHIBIT MDG 3.8

CONFIDENTIAL STATE OF MICHIGAN

BEFORE THE MICHIGAN PUBLIC SERVICE COMMISSION

RESPONSE TESTIMONY OF MACK D. GREENE ON BEHALF OF LEVEL 3 COMMUNICATIONS, LLC GLOBAL CROSSING LOCAL SERVICES, INC. and WILTEL COMMUNICATIONS, LLC

EXHIBIT MDG 3.9

PUBLIC

STATE OF MICHIGAN

BEFORE THE MICHIGAN PUBLIC SERVICE COMMISSION

RESPONSE TESTIMONY OF MACK D. GREENE ON BEHALF OF LEVEL 3 COMMUNICATIONS, LLC GLOBAL CROSSING LOCAL SERVICES, INC. and WILTEL COMMUNICATIONS, LLC

EXHIBIT MDG 3.9

123.Net, Inc. d/b/a Local Exchange Carriers of Michigan, Inc. Tariff M.P.S.C. No. 2R Original Title Page

123.Net, Inc. d/b/a Local Exchange Carriers of Michigan, Inc.

Regulations and Schedule of Intrastate Charges Governing the Provision of Switched Access Services Within the State of Michigan

TARIFF MICHIGAN PUBLIC SERVICE COMMISSION (MPSC) No. 2R

Issued under the authority of the Michigan Public Service Commission and PA 179 of 1991, as amended Issued: October 8, 2014 Effective: October 10, 2014

TABLE OF CONTENTS

Table of Contents...... 1 Preface...... 1 Check sheet ...... 1 Explanation of Symbols, Reference Marks, and Abbreviations of Technical Terms used in This Tariff ...... 2 Section 1 - Application of Tariff...... 1 1.1 Application...... 1 1.1.1 General...... 1 1.1.2 Previous Tariffs ...... 2 Section 2 - General Regulations ...... 1 2.1 Undertaking of the Company...... 1 2.1.1 General...... 1 2.1.2 Limitations...... 2 2.1.3 Liability ...... 4 2.1.4 Provision of Service...... 6 2.1.5 Points of Termination ...... 6 2.1.6 Service Maintenance...... 7 2.1.7 Changes and Substitutions...... 9 2.1.8 Refusal and Discontinuance of Service...... 10 2.1.9 Notification of Service-Affecting Activities ...... 13 2.1.10 Coordination with Respect to Network Contingencies...... 13 2.1.11 Provision and Ownership of Telephone Numbers ...... 14 2.1.12 Network Management...... 14 2.1.13 Design Layout Reports...... 15 2.2 Use ...... 16 2.2.1 Interference or Impairment...... 16 2.2.2 Unlawful and Abusive Use...... 16 2.3 Obligations of the Customer ...... 17 2.3.1 Damages ...... 17 2.3.2 Ownership of Facilities...... 17

Issued under the authority of the Michigan Public Service Commission and PA 179 of 1991, as amended Issued: October 8, 2014 Effective: October 10, 2014

SECTION 12 – RATES, CONT’D

12.3 Common Line Access Charges

Originating Terminating

Per minute of use $0.00 $0.00

12.4 Switched Access Service

12.4.1 Non-Recurring Charges

Rate Interim NXX Translation Per Order Per LATA or Market Area $169.60

12.4.2 Local Transport – Tandem

Where the Company is providing the Tandem Service. If another provider is providing Tandem service these services may fall under the tariff of that provider:

Rate Tandem Switched Transport-Tandem Switched Facility: Per Access Minute Per Mile $0.000014

Tandem Switched Termination Per Access Minute Per Termination $0.000018

Tandem Interconnection Charge The Local Switching Rate charged by the Company includes all charges for Tandem Interconnection Charge directly provided by the Company.

Network Blocking Per Blocked Call $0.001088

800 Data Base Access Service Queries Base Query $0.008998 Vertical $0.008998

Issued under the authority of the Michigan Public Service Commission and PA 179 of 1991, as amended Issued: October 8, 2014 Effective: October 10, 2014

SECTION 12 – RATES, CONT’D

12.4 Switched Access Service (Con’t)

12.4.3 Local Transport – End Office

Originating Terminating Rate Rate Local Switching: Per Access Minute $0.003116 $0.002954

The rate charged by the Company includes Information Surcharge and Tandem Interconnection charges for the portion of those services directly provided by the Company. Shared End-Office Shared Trunk Port Per Access Minute $0.0003710 $0.00

Issued under the authority of the Michigan Public Service Commission and PA 179 of 1991, as amended Issued: October 8, 2014 Effective: October 10, 2014

SECTION 12 – RATES, CONT’D

12.5 Local Call Termination Service

12.5.1 LCTS Rate

Per Interconnection Minute $0.004331

12.5.2 LCTS – Other Charges

The charge for all other services required to provide LCTS shall be the same as charges for access service and are determined under the Company’s Tariff, FCC No. 1, Access Service, K. Rates and Charges, excluding Section 1.2 (Local Switching), Section 2 (End User Common Line Charge), and Section 3 (Universal Service Charge).

Issued under the authority of the Michigan Public Service Commission and PA 179 of 1991, as amended Issued: October 8, 2014 Effective: October 10, 2014

SECTION 12 – RATES, CONT’D

12.6 Toll VoIP – PSTN Traffic

Unless the Company and Customer have entered into an arrangement that specifies otherwise, all toll Voice over Internet Protocol to Public Switched Telephone Network (“VoIP-PSTN”) traffic will be billed at the rates set forth in the Company’s Tariff FCC No. 1 in accordance with the FCC’s Order in its WC Docket Nos. 10-90, etc., FCC Release No. 11-161 (Nov. 8, 2011). VoIP-PSTN traffic is defined as traffic exchanged between the Company end user and the customer in time division multiplexing (“TDM”) format that originates and/or terminates in Internet Protocol (“IP”) format. Traffic originates and/or terminates in IP format if it originates from and/or terminates to a customer of a service that requires IP compatible customer premises equipment.

Issued under the authority of the Michigan Public Service Commission and PA 179 of 1991, as amended Issued: October 8, 2014 Effective: October 10, 2014

Issued by: James Kandler, Chief Operating Officer E-Mail: [email protected] 24700 Northwestern Hwy., Ste. 700, Southfield, MI 48075 Phone: (248) 724-2201 STATE OF MICHIGAN

BEFORE THE MICHIGAN PUBLIC SERVICE COMMISSION

RESPONSE TESTIMONY OF MACK D. GREENE ON BEHALF OF LEVEL 3 COMMUNICATIONS, LLC GLOBAL CROSSING LOCAL SERVICES, INC. and WILTEL COMMUNICATIONS, LLC

EXHIBIT MDG 3.10

CONFIDENTIAL STATE OF MICHIGAN

BEFORE THE MICHIGAN PUBLIC SERVICE COMMISSION

RESPONSE TESTIMONY OF MACK D. GREENE ON BEHALF OF LEVEL 3 COMMUNICATIONS, LLC GLOBAL CROSSING LOCAL SERVICES, INC. and WILTEL COMMUNICATIONS, LLC

EXHIBIT MDG 3.11

CONFIDENTIAL STATE OF MICHIGAN

BEFORE THE MICHIGAN PUBLIC SERVICE COMMISSION

RESPONSE TESTIMONY OF MACK D. GREENE ON BEHALF OF LEVEL 3 COMMUNICATIONS, LLC GLOBAL CROSSING LOCAL SERVICES, INC. and WILTEL COMMUNICATIONS, LLC

EXHIBIT MDG 3.12

CONFIDENTIAL STATE OF MICHIGAN

BEFORE THE MICHIGAN PUBLIC SERVICE COMMISSION

RESPONSE TESTIMONY OF MACK D. GREENE ON BEHALF OF LEVEL 3 COMMUNICATIONS, LLC GLOBAL CROSSING LOCAL SERVICES, INC. and WILTEL COMMUNICATIONS, LLC

EXHIBIT MDG 3.13

CONFIDENTIAL STATE OF MICHIGAN

BEFORE THE MICHIGAN PUBLIC SERVICE COMMISSION

RESPONSE TESTIMONY OF MACK D. GREENE ON BEHALF OF LEVEL 3 COMMUNICATIONS, LLC GLOBAL CROSSING LOCAL SERVICES, INC. and WILTEL COMMUNICATIONS, LLC

EXHIBIT MDG 3.14

PUBLIC

STATE OF MICHIGAN

BEFORE THE MICHIGAN PUBLIC SERVICE COMMISSION

RESPONSE TESTIMONY OF MACK D. GREENE ON BEHALF OF LEVEL 3 COMMUNICATIONS, LLC GLOBAL CROSSING LOCAL SERVICES, INC. and WILTEL COMMUNICATIONS, LLC

EXHIBIT MDG 3.14

From: Johnson, Scott Sent: Tuesday, July 31, 2012 3:00 PM To: '[email protected]' Cc: Abeyta, Jamie Subject: RE: Carrier Disputes Attachments: Westphalia dispute 201205.xlsx.html

Hi David

I’m sorry we haven’t sent detail but I tried to contact the only number we had for Westphalia and didn’t get a response.

The attached detail is for the dispute on the May invoice. Our Network does not show the volume of traffic being billed at the Southfield EO. Even if it did, I don’t see how over 80 miles for tandem transport could be justified for a suburb of Detroit. We have paid the Ameritech Tandem rate.

From: Dave Fox [mailto:[email protected]] Sent: Monday, July 30, 2012 4:05 PM To: Dietz, Amber Subject: Carrier Disputes

Hello Amber

We are in receipt of the following dispute notifications from Level 3.

Bill Date: May 1, 2012 32227030000 32227020000

Bill Date: June 1, 2012 32305100000 32306050000

Bill Date: July 1, 2012 32009760000

Please be advised each of these disputes are denied based on a lack of detailed computation and support. Therefore we consider each of these disputes to be closed.

Regards

David A Fox President Westphalia Telephone Co. 989-587-5002 [email protected]

1 From: Johnson, Scott Sent: Monday, December 03, 2012 9:11 AM To: '[email protected]' Cc: Hayward, Mark; Tounget, Rhonda; Sorice, Todd; Abeyta, Jamie; AprilTaylor; '[email protected]'; Scott Subject: RE: Level 3 - Westphalia Dispute Resolution Call

Hi Terri.

Unfortunately I was pulled away from parts of the Friday, November 30 call and wanted to make sure a few points were captured.

In addition to the mileage issue, we are disputing the elements and quantities billed as insertion. We do not pay end office elements such as Local Switching on wireless or inserted traffic. For example, on the November invoice (and only the 9/25-10/24 cycle) of the WCA Ban, over 7M Originating Local Switching minutes were billed at the SFLDMIDICA0 EO. For that period on the Level3 network, we see fewer than 200k minutes Originating from SFLDMI. And for that matter, less than 200k minutes from all of OCN 2550 EOs.

The billing has been inconsistent with Local Switching minutes and the SFLDMI EO billed has ended with the letter “O” and the number “0”. I don’t know if that distinction is intended to represent inserted minutes or not but at this put the minutes billed are so much greater than what we see on the Level3 network for these EOs / OCN, we are disputing 100% of the EO elements billed as insertion. For the Originating traffic, we are disputing down to the RBOC Tandem rate elements- or .0015 (where 8 miles is used for the mileage variable element).

I’d like to see CDRs for this traffic- unless you concede that this traffic is Originating from wireless End Users and or TNs not owned by 2550 per Lerg / NPAC; in which case the CDR study is unnecessary.

Scott Johnson Manager, NetEx Level 3 Communications p: 281.501.0036 e: [email protected]

The linked image can not be d isplayed. The file may have been mov ed, ren amed, or deleted. Verify that the link points to the correct file and location.

1 From: Johnson, Scott Sent: Thursday, January 31, 2013 2:50 PM To: '[email protected]'; Scott Cc: Tounget, Rhonda; Sorice, Todd; '[email protected]'; Abeyta, Jamie; 'Dave Fox'; 'Brian Taylor'; 'John Summersett' Subject: RE: Westphalia Records Associated with Level 3 CABs Now Available on FTP Site Attachments: Westphalia CDR review WCA ban.xlsx.html

Thanks Terri.

I reviewed the WCA file. As expected, a very low % of the Orig numbers are associated with OCN 2550 (Lec of Michigan).

The “Insertion” dispute is grounded in the fact that these calls do not originate from Lec of Michigan end users / End Offices. The majority of calls (over 93% by this sample) Originate somewhere other than OCN 2550, making the End Office charges such as Local Switching invalid. This also explains why we (Level3) don’t see this traffic / cost on our network to be associated with the 2550 OCN. The Access cost for this function is limited to that of the Tandem- which is what we have been paying (with consideration given to the excessive mileage issue) and disputing the rest.

The attached data is the top 2,000 (ordered desc by most mou) Orig numbers from the CDR, ran through the Neustar database to account for porting.

Here are the summary results of the Orig owner:

MOU in the reviewed population: 1,094,505 MOU with LEC of Mich OCN: 73,446 6.71%

NPAC Company Name MOU CRICKET: 0822 - NSR/2 356,542 Denali dba Cricket: 701E - NSR/2 168,575 STX Wireless LLC/2 151,170 Flat Wireless-SVR/2 116,854 LEC of Michigan/1 73,446 Cricket: 561D - NSR/2 65,039 Cricket_Comm-TNS:6017/2 61,435 Cleveland_Unlimited - NSR:8711/2 27,741 Focal-TNS:7058/1 22,991 Level_3_Comm-TNS:8824/1 12,468 LCW dba CRICKET: 862D- NSR/2 11,100 6,225 PTA-FL Inc/2 6,024 T-Mobile US-TSI/2 5,176 Sprint PCS/2 4,539

1 Cingular Wireless/2 2,636 Winn Telecom/1 555 USCC - SVR/2 448 CenturyLink-0661/1 341 Ameritech/1 323 Metro PCS Comm: 392A - NSR/2 317 MCImetro Former Brooks/1 280 Grand Total 1,094,226

From: Terri Firestein [mailto:[email protected]] Sent: Tuesday, January 29, 2013 10:57 AM To: Johnson, Scott; Scott Cc: Tounget, Rhonda; Sorice, Todd; [email protected]; Abeyta, Jamie; Dave Fox; Brian Taylor; John Summersett Subject: Westphalia Records Associated with Level 3 CABs Now Available on FTP Site

Level 3 Team,

Westphalia records associated with Level 3 CABs invoicing have been placed on a FTP site and the information is detailed below. Please let me know if you have any problems with access.

FTP Server: ftpsite.4wbi.net Username: level3cdr Password: sdi2J@i1m29*

After your review please send me any questions and/or clarified concerns you may have regarding the records and the record's association with our on-going dispute negotiations. thanks, Terri K. Firestein Sr. Director CCG Consulting, LLC 301-842-1437 for Westphlaia/GLC