CAHILL GORDON & REINDEL LLP SUITE 950 1990 K STREET, N.W. AUGUSTINE HOUSE E IGHTY P INE S TREET WASHINGTON, D.C. 20006-1181 6A AUSTIN FRIARS N EW Y ORK, N.Y. 10005-1702 LONDON, ENGLAND EC2N 2HA (212) 701-3000 ______(011) 44.20.7920.9800 FAX: (212) 269-5420 FAX: (011) 44.20.7920.9825 ______TELEPHONE (202) 862-8900 FACSIMILE (202) 862-8958 ______
C HÉRIE R. K ISER │ 202-862-8950 │ [email protected]
January 26, 2009
Via Electronic Mail and Federal Express
Catrice C. Williams Secretary Department of Telecommunications and Cable Two South Station Fourth Floor Boston, Massachusetts 02110
Re: D.T.C. 08-9, Petition for Arbitration of an Interconnection Agreement between Intrado Communications Inc. and Verizon New England Inc. d/b/a Verizon Massachusetts
Dear Secretary Williams:
Intrado Communications Inc. (“Intrado Comm”), by its attorneys, hereby respectfully submits its Response to the First Set of Information Requests of the Department of Telecommunications and Cable.
If you have any questions concerning this matter, please contact the undersigned.
Respectfully submitted,
Chérie R. Kiser
Counsel for Intrado Communications Inc.
Enclosures
cc: Service List
41495.1
Before the COMMONWEALTH OF MASSACHUSETTS DEPARTMENT OF TELECOMMUNICATIONS AND CABLE ______) In the Matter of the Petition of ) Intrado Communications Inc. for Arbitration ) DTC 08-9 Pursuant to Section 252(b) of the Communications Act ) of 1934, as amended, to Establish an Interconnection ) Agreement with Verizon New England Inc. ) d/b/a Verizon Massachusetts ) ______)
INTRADO COMMUNICATIONS INC. RESPONSE TO FIRST SET OF INFORMATION REQUESTS OF THE DEPARTMENT OF TELECOMMUNICATIONS AND CABLE TO INTRADO COMMUNICATIONS INC.
Intrado Communications Inc. (“Intrado Comm”) responds to the First Set of Information
Requests (“Requests”) from the Department of Telecommunications and Cable (“DTC”) as
follows. Any answers provided by Intrado Comm in response to these Requests are provided
subject to, and without waiver of, the following general objections.
GENERAL OBJECTIONS
1. Intrado Comm reserves all objections as to relevance and materiality. Where
Intrado Comm submits responses and produces materials in response to the Requests, it does so without conceding the relevancy or materiality of the information or materials sought or produced, or their subject matter, and without prejudice to Intrado Comm’s right to object to further discovery, or to object to the admissibility of proof on the subject matter of any response, or to the admissibility of any document or category of documents, at a future time. Any disclosure of information not responsive to the Requests is inadvertent and is not intended to waive Intrado Comm’s right not to produce similar or related information or documents.
41493.1 1
2. Intrado Comm objects to the Requests to the extent they seek information
protected by the attorney-client privilege, the work-product doctrine, or other applicable
privileges and protections. Intrado Comm hereby claims all applicable privileges and protections
to the fullest extent implicated by the Requests and excludes privileged information and
materials from its responses. Any disclosure of such information or materials as a result of
Intrado Comm’s responses or otherwise is inadvertent and is not intended to waive any applicable privileges or protections.
3. Intrado Comm objects to all Information Requests that seek information about
Intrado Inc. or any other Intrado Comm affiliate. Intrado Inc. and other affiliates are not parties to this proceeding and information regarding them is beyond the scope of this proceeding and not likely to result in admissible evidence in this proceeding.
Subject to and without waiving the foregoing General Objections, each of which are incorporated by reference into the responses below as if fully restated therein, Intrado Comm
provides the following responses to the Requests. Intrado Comm’s responses are based on the
best information presently available; Intrado Comm reserves the right to amend, supplement, correct or clarify answers if other or additional information is obtained, and to interpose additional objections if deemed necessary.
41493.1 2
REQUESTS
DTC - INTRADO 1-1:
Explain why Intrado requires direct trunking between Verizon End Offices and Intrado’s network. Also explain why the network arrangement which would connect Verizon Selective Router with Intrado’s network is a lesser architectural arrangement. Provide complete and detailed documentation on how reliability and service quality are affected.
INTRADO COMM RESPONSE:
Intrado Comm’s proposed requirement for dedicated direct trunking between Verizon’s end offices and Intrado Comm’s network reflects best possible network interconnection arrangement for the provision of 911/E-911 services to public safety answering points (“PSAPs”) and other public safety agencies. For example, the Standards for Enhanced 911 adopted by the Massachusetts Statewide Emergency Telecommunications Board require “a minimum of two dedicated trunks from each telephone company or Alternative Local Exchange Carrier (ALEC) central office to any tandem” (560 CMR 2.00 - Appendix A, 9-1-1 System Design - Technical Standards at (2)(b)). For purposes of these requirements, a “tandem” is defined as a switching system in the E911 telephone network that establishes 911 call routing. The Massachusetts requirement is similar to requirements in Illinois and Texas. See, e.g., ILL. ADMIN CODE TIT. 83, § 725.500(c), (x) (requiring the use of dedicated direct trunking to the selective router serving the PSAP); Texas P.U.C. SUBST. R. 26.435 (stating that carriers are “responsible for providing such dedicated trunks from the [carrier] switching office or point of presence to the 9-1-1 selective router” and requiring carriers to deploy a minimum of two dedicated trunks to each selective router).
Further, Intrado Comm’s proposed requirement for dedicated direct trunking reflects the 911 interconnection arrangements that are used in Verizon’s network today in order to promote overall 911/E911 network reliability. Verizon uses dedicated direct trunking from its end offices to its selective routers to route 911 calls destined for Verizon’s PSAP customers within its own network. See Verizon Pre-Filed Testimony at 15. Intrado Comm’s proposed language is also consistent with the 911 interconnection arrangements Verizon has adopted for competitors to route their end users’ 911 calls destined for Verizon’s PSAP customers. Specifically, competitors route their end users’ 911 calls to Verizon via direct dedicated trunking from the competitor’s switch or non-911 traffic point of interconnection to the appropriate selective router serving the PSAP to which the call is destined. See Verizon Pre-Filed Testimony at 16.
Presumably, the Statewide Emergency Telecommunications Board and Verizon have implemented these network arrangements because they provide the most reliable and redundant network architecture arrangement for critical 911 services. Best practices used in engineering 911 networks minimize the number of possible points of failure for each circuit carrying originating 911 traffic from an end user’s end office to the 911 selective router. This includes network designs that minimize the number of switching points and facility transport routes necessary to reach the PSAP.
41493.1 3
There is no reason to use different POI or trunking arrangements when Intrado Comm is 911/E-911 service provider. Imposing a different type of interconnection arrangement on Intrado Comm is discriminatory and violates Intrado Comm’s right to interconnection arrangements that are equal in quality to those Verizon provides itself or any other carrier.
Reports or documentation attesting to the reliability of routing all 911/E-911 calls are unavailable to Intrado Comm due to the proprietary nature of such statistics. Further, formal Federal Communications Commission outage reporting statistics also remain confidential and are only available to the reporting incumbent local exchange carrier (“ILEC”).
RESPONSIBLE PERSON: Thomas Hicks, Director-Carrier Relations
41493.1 4
DTC - INTRADO 1-2:
Provide any relevant information and/or documents to compare the reliability of existing 911 networks, which involve direct trunking between selective routers and PSAPs, with Intrado’s proposed Intelligent Emergency Network.
INTRADO COMM RESPONSE:
The highest level of reliability possible for 911 services is an absolute requirement regardless of the type of 911 network used. Intrado Comm has engineered its network to be highly reliable and fully redundant. Intrado Comm employs network design concepts that are consistent with industry-established practices, including the Federal Communications Commission’s Best Practices and recommendations by the National Emergency Number Association. Most notable would be requiring carriers interconnecting with Intrado Comm to utilize dedicated direct trunking from the originating switch to the Intrado Comm selective router serving the PSAP to which the call is directed, as well as employing diversity and redundancy throughout the network.
RESPONSIBLE PERSON: Thomas Hicks, Director-Carrier Relations
41493.1 5
DTC - INTRADO 1-3:
Provide a list of each docketed interconnection agreement arbitration proceeding commenced within the past two (2) years between (a) Intrado and Verizon and (b) Intrado and Embarq. For each proceeding, include the full docket name, docket number, most recent agency action, a copy of the current procedural schedule (if applicable), and the name of the agency overseeing the arbitration (state and/or federal).
INTRADO COMM RESPONSE:
(a) Other than the current proceeding before the Massachusetts Department of Telecommunications and Cable, the docketed arbitration proceedings commenced within the past two years between Intrado Comm and Verizon are as follows:
Agency: Delaware Public Service Commission Docket No.: PSC Docket No. 08-61 Caption: Petition of Intrado Communications Inc. for Arbitration Pursuant to Section 252(b) of the Communications Act of 1934, as amended, to Establish an Interconnection Agreement with Verizon Delaware LLC Recent Agency Action: Hearing Examiner Mark Lawrence approved the Parties’ request to waive the arbitration hearing. Procedural Schedule: See Attachment 1-3 A
Agency: Florida Public Service Commission Docket No.: 080134-TP Caption: Petition by Intrado Communications, Inc. for arbitration to establish an interconnection agreement with Verizon Florida LLC, pursuant to Section 252(b) of the Communications Act of 1934, as amended, and Section 364.162, F.S. Recent Agency Action: The Commission issued an order on January 22, 2009 granting Intrado Comm’s Motion to Hold In Abeyance the arbitration proceeding pending the Florida commission’s consideration of Intrado Comm’s Motions for Reconsideration filed in Docket Nos. 070699-TP (Intrado Comm/Embarq) and 070736-TP (Intrado Comm/AT&T) Procedural Schedule: None pending
Agency: Illinois Commerce Commission Docket No.: 08-0550 Caption: Petition of Intrado Inc. for Arbitration Pursuant to Section 252(b) of the Communications Act of 1934, as amended, to Establish an Interconnection Agreement with Verizon North Inc. and Verizon South Inc. Recent Agency Action: 10/8/2008 – ALJ issued the procedural schedule ordering that the schedule will govern the proceedings
41493.1 6
Procedural Schedule: See Attachment 1-3 B
Agency: Maryland Public Service Commission Docket No.: 9138 Caption: Petition of Intrado Communications Inc. for Arbitration Pursuant to Section 252(b) of the Communications Act of 1934, as amended, to Establish an Interconnection Agreement with Verizon Maryland Inc. Recent Agency Action: Arbitration hearing held January 7, 2009 Procedural Schedule: See Attachment 1-3 C
Agency: North Carolina Utilities Commission Docket No.: P-1187, Sub 3 Caption: Petition of Intrado Communications Inc. for Arbitration Pursuant to Section 252(b) of the Communications Act of 1934, as amended, to Establish an Interconnection Agreement with Verizon South Inc. d/b/a Verizon North Carolina Recent Agency Action: 08/7/2008 – Order Setting Procedural Schedule Procedural Schedule: See Attachment 1-3 D
Agency: Public Utilities Commission of Ohio Docket No.: 08-0198-TP-ARB Caption: Petition of Intrado Communications Inc. for Arbitration Pursuant to Section 252(b) of the Communications Act of 1934, as amended, to Establish an Interconnection Agreement with Verizon North Inc. Recent Agency Action: Arbitration hearing held January 13, 2009. Procedural Schedule: See Attachment 1-3 E
Agency: Public Utility Commission of Texas Docket No.: 36185 Caption: Petition of Intrado Inc. for Arbitration Pursuant to Section 252(b) of the Communications Act of 1934, as amended, to Establish an Interconnection Agreement with GTE Southwest Incorporated d/b/a Verizon Southwest Recent Agency Action: Request for briefs on threshold issues issued Procedural Schedule: None issued to date
Agency: West Virginia Public Service Commission Docket No.: 08-0298-T-PC Caption: Intrado Communications, Inc., and Verizon West Virginia Inc. Petition for arbitration of certain rates, terms and conditions for interconnection and related arrangements with Verizon West Virginia pursuant to Section 252(b) of the Communications Act of 1934, as amended, and Commission Rule 150-6-15
41493.1 7
Recent Agency Action: 12/16/2008 –Commission Order approving Interconnection Agreement Procedural Schedule: None pending
Agency: Federal Communications Commission (standing in shoes of Virginia State Corporation Commission) Docket No.: WC Docket No. 08-185 Caption: Petition of Intrado Communications of Virginia Inc. Pursuant to Section 252(e)(5) of the Communications Act for Preemption of the Jurisdiction of the Virginia State Corporation Commission Regarding Arbitration of an Interconnection Agreement with Verizon South Inc. and Verizon Virginia Inc. (collectively, “Verizon”) Recent Agency Action: 12/08/2008 – Order consolidating proceeding with Embarq arbitration Procedural Schedule: None issued to date
(b) The docketed arbitration proceedings commenced within the past two years between Intrado Comm and Embarq are as follows:
Agency: Florida Public Service Commission Docket No.: 070699-TP Caption: Petition by Intrado Communications, Inc. for arbitration of certain rates, terms, and conditions for interconnection and related arrangements with Embarq Florida, Inc., pursuant to Section 252(b) of the Communications Act of 1934, as amended, and Section 364.162, F.S. Recent Agency Action: 12/19/2008 – Commission Clerk ordered docket to be reopened pending Motion for Reconsideration Procedural Schedule: None pending
Agency: Public Utilities Commission of Ohio Docket No.: 07-1216-TP-ARB Caption: Petition of Intrado Communications Inc. Pursuant to Section 252(b) of the Communications Act of 1934, as amended, to Establish an Interconnection Agreement with United Telephone Company of Ohio and United Telephone Company of Indiana d/b/a Embarq Ohio Recent Agency Action: 12-10-2008 – Entry on Rehearing issued Procedural Schedule: None pending
Agency: Federal Communications Commission (standing in the shoes of the Virginia State Corporation Commission) Docket No.: WC Docket No. 08-33 Caption: Petition of Intrado Communications of Virginia Inc. for Arbitration Pursuant to Section 252(b) of the Communications Act of 1934, as
41493.1 8
amended, to Establish an Interconnection Agreement with Central Telephone Company of Virginia and United Telephone - Southeast, Inc. (collectively, “Embarq”) Recent Agency Action: 12/08/2008 – Order consolidating proceeding with Verizon arbitration Procedural Schedule: None issued to date
RESPONSIBLE PERSON: Robert Currier, Manager - Regulatory and Government Affairs
41493.1 9
DTC - INTRADO 1-4:
Regarding Robert C. Currier’s (“Currier”) testimony on page 4 at lines 19 – 23, page 6 at lines 8 – 15, and page 7 at lines 8 – 12, do any PSAPs or other public safety agencies currently order and use Intrado’s “Intelligent Emergency Network” in the thirty-nine other states in which Intrado is authorized to provide “competitive local telecommunications services?” If so, please list the state(s) in which this service is provided and whether Intrado has Section 251(c) interconnection agreements with the ILECs within those states in order to provide the service.
INTRADO COMM RESPONSE:
Intrado Comm does not provide its 911/E-911 service to public safety agencies in any state today. Intrado Comm is unable to provide its competitive 911/E-911 service to PSAPs and other authorized 911 governmental agencies without having the necessary interconnection arrangements in place. Intrado Comm is currently engaged in 251 negotiations and arbitrations in numerous states with AT&T, Verizon, Embarq, CenturyTel and Frontier/Citizens. Intrado Comm has recently entered into a Section 251(c) interconnection with Cincinnati Bell in Ohio. Intrado Comm is actively engaged in testing and preparing to deploy its 911/E-911 service in numerous locations across the United States. The lack of 251(c) agreements severely limits Intrado Comm’s ability to test and deliver comprehensive 911/E911 service to its public safety customers.
RESPONSIBLE PERSON: Robert Currier, Manager - Regulatory and Government Affairs
Respectfully submitted on behalf of,
INTRADO COMMUNICATIONS INC.
______Chérie R. Kiser Angela F. Collins Cahill Gordon & Reindel LLP 1990 K Street, N.W., Suite 950 Washington, D.C. 20006 202-862-8900 (telephone) 202-862-8958 (facsimile) [email protected] [email protected]
41493.1 10
Intrado Comm Attachment 1-3 A
Intrado Comm Attachment 1-3 B
October 8, 2008
Intrado Inc. : : 08-0550 Petition for Arbitration pursuant to : Section 252(b) of the Communications : Act of 1934, as amended, to Establish : an Interconnection Agreement with : Verizon North Inc. and : Verizon South Inc. :
NOTICE OF ADMINISTRATIVE LAW JUDGES’ RULING AND NOTICE OF SCHEDULE
TO ALL PARTIES OF INTEREST:
Notice is hereby given by the Administrative Law Judges that the attached schedule shall govern all proceedings in Docket 08-0550 unless and until it is expressly modified by the Administrative Law Judges.
Sincerely,
Elizabeth A. Rolando Chief Clerk
EAR:lkb Administrative Law Judges Gilbert & Benn (312)814-6652
Service List – 08-0550
Angela F. Collins & Cherie R. Kiser Attys. for Intrado Inc. Cahill Gordon & Reindel LLP 1990 K St., NW, Ste. 950 Washington, DC 20006 *
Document Processor Intrado Inc. Illinois Corporation Service Company 801 Adlai Stevenson Dr. Springfield, IL 62703-4261 *
Rebecca Ballesteros, Craig W. Donaldson & Thomas Hicks Intrado Inc. 1601 Dry Creek Dr. Longmont, CO 80503 *
Trish Kirby Intrado, Inc. Technologies Management, Inc. PO Drawer 200 Winter Park, FL 32790-0200 *
Philip J. Wood Jr., Vice President Verizon North & Verizon South Inc. Public Affairs Policy & Communications 104 W. Mulberry St. Normal, IL 61761 *
Marci Schroll, Case Manager Illinois Commerce Commission 527 E. Capitol Ave. Springfield, IL 62701 *
Matthew L. Harvey & Megan McNeill Office of General Counsel Illinois Commerce Commission 160 N. LaSalle St., Ste. C-800 Chicago, IL 60601-3104 *
Bonita Benn & David Gilbert Administrative Law Judges Illinois Commerce Commission 160 N. LaSalle St., Ste. C-800 Chicago, IL 60601 *
* Active Parties - 1 -
Intrado Proposed Verizon Illinois Schedule (as of October 6, 2008)
September 24 Petition Filed
October 20 Verizon’s Response to Petition
October 20 Intrado’s Discovery Requests to Verizon
November 3 Verizon’s Responses to Intrado’s Discovery
October 29 Verizon’s Discovery Requests to Intrado
November 10 Intrado’s Responses to Verizon Discovery
November 12 Intrado's Testimony
November 26 Verizon’s Testimony
December 5 Staff’s Discovery Requests to Verizon and Intrado
December 17 Responses to Staff’s Discovery Requests
December 19 Staff’s Testimony
January 5 Verizon and Intrado’s Discovery Requests to Staff
January 20 Staff Responses to Discovery
January 23 Verizon and Intrado’s Testimony Responding to Staff
February 23&24 Hearing
March 17 Initial Briefs
April 13 Reply Briefs
May 8 ALJ Proposed Order
May 15 Brief on Exceptions
June 3 Commission Meeting (discussing decision)
June 9 Commission Meeting (voting on decision)
36863.1
Intrado Comm Attachment 1-3 C IN THE MATTER OF THE PETITION OF * BEFORE THE INTRADO COMMUNICATIONS INC. FOR PUBLIC SERVICE COMMISSION ARBITRATION TO ESTABLISH AN * OF MARYLAND INTERCONNECTION AGREEMENT WITH VERIZON MARYLAND INC. PURSUANT TO * THE FEDERAL TELECOMMUNICATIONS ACT CASE NO. 9138 *
September 9, 2008
HEARING EXMINER'S SCHEDULING NOTICE
Herewith are the procedural dates agreed to by the parties and the Hearing Examiner in the above-entitled matter.
September 12, 2008 - Joint issues matrix.
October 23, 2008 - Direct Testimony due- all parties.
November 20, 2008 - Reply Testimony due- all parties.
December 12, 2008 - Updated joint issues matrix.
January 7-8, 2008 - Hearings
February 20, 2008 - Briefs due.
March 25,2008 - Reply briefs due.
The Hearing on January 7-8, 2008 will be held in the
Commission's 19th floor hearing room, William Donald Schaefer
Tower, 6 St. Paul Street, Baltimore, Maryland commencing at 1:00 p.m. on January 7, 2008 and 10:00 a.m. on January 8, 2008.
Robert H. McGowan Hearing Examiner Public Service Commission of Maryland September 9, 2008
In the matter of the petition of * Intrado Communications Inc. for Case No. 9138 arbitration to establish an * interconnection agreement with Verizon Maryland Inc. Pursuant to * the federal telecommunications act
To All Parties of Record:
Enclosed please find a copy of the "Hearing Examiner's Scheduling Notice" issued today in the above-entitled matter.
Also enclosed is a copy of the preliminary service list for this matter.
Very truly yours,
Leatrice Williams Office Secretary lw Enclosures
Intrado Comm Attachment 1-3 D
Intrado Comm Attachment 1-3 E i BEFORE
THE PUBLIC UnLITIES COMMISSION OF OHIO
In the Matter of the Petitiori of Intrado Communications, Inc. for Arbitration of Intercormection Rates, Terms, and Conditions and Related Arrangements with Case No. 08-198-TP-ARB Verizon North Inc., Pursuant to Section 252(b) of the Telecommimications Act of 1996.
ENTRY
The attorney examiner finds:
(1) On March 5, 2008, Intrado Communications, Inc. (Intrado) filed a petition for arbitration of numerous issues to establish an interconnection agreement with Verizon North Inc. (Verizon North). Intrado filed the petition ptursuant to Section 252(b) of the Telecommimications Act of 1996 (1996 Act).
(2) On March 31,2008, Verizon North filed its response to Intrado's petition for arbitration, as well as a motion to dismiss or stay Intrado's petition for arbitration. First, Verizon North submits that the Commission should not move forward with this proceeding inasmuch as the issue of whether Intrado is entitled to arbitration under Section 252 and interconnection pursuant to Section 251(c) is currently pending before the Federal Communications Commission (FCC). In support of its position, Verizon North states that its recommended approach is reasonable in order to prevent conflict with the FCC's ultimate determination.
Even if the Commission decides to proceed to arbitration without waiting for a ruling from the FCC, Verizon North believes that the Commission should grant an abeyance of some duration in order to allow the parties to continue to negotiate the issues raised in the petition. ^
(3) On April 8, 2008, Verizon North filed a letter indicating that the parties have agreed to stay the arbitration for 60 days in order to allow for further negotiations with the objective of eliminating some issues from the arbitration and to more clearly define the issues that remain. Additionally, Verizon North stated that, in This Is to certify that the images appearing are an sGc^urate and coffl_T5l€^te reproduction ot a case file docuraent delivered ia the regular course of jbusiness. TechniGian___^£2l ^Date Proceafifed SyW/gg 08-198-TF-ARB -2-
light of the parties' agreement to continue to negotiate, the company was withdrawing its motion to dismiss, subject to and conditioned upon the Commission's issuance of an entry accepting the parties' agreement to defer the arbitration for 60 days.
(4) On August 5, 2008, Intrado filed a letter indicating that the parties have agreed to the following schedule:
(a) Discovery cut-off December 9,2008
(b) Arbitration packets December 30,2008
(c) Arbitration hearing January 13-15,2009
(d) Initial briefs February 13,2009
(e) Reply briefs March 6,2009
(5) Upon review, the attorney examiner finds the proposed schedule to be reasonable. The hearing will commence on January 13, 2009, at 10:00 a.m., at the Commission offices, 180 East Broad Street, Columbus, Ohio 43215-3793 in Hearing Room 11-C. For each subsequent day, the hearing shall commence at 9:00 a.m. The arbitration panel will conduct the hearing with prefiled testimony, transcription of the hearing, and cross- examination of witnesses.
(6) As noted above, the parties have agreed to each file their respective arbitration packages on December 30, 2008. The arbitration packages shall include the list of issues to be arbitrated, the party's position on each issue, a list of issues which have been resolved by the parties and a description of the resolution, the party's prefiled testimony specifically identifying the issues to be addressed by each witness, a proposed schedule of witnesses, the exhibits which the party intends to introduce at the hearing, and a list of factual i stipulations upon which the parties have agreed. The prefiled testimony of each witness shall be numbered by line and include specific contract references, as well as an identification of the specific arbitration issues addressed in the testimony. 08-198^TP-ARB -3-
(7) For convenience and because of the short time frames and delays that often accompany mail service, briefs, reply briefs, and other papers shall be provided to the arbitration panel and to opposing counsel electronically, within the specified time frames.
(8) A status conference is scheduled for September 25, 2008, at 10:00 a.m. for the purpose of addressing any remaining procedural issues prior to the arbitration hearing. The parties are to participate by calling (614) 644-1080.
It is, therefore,
ORDERED, That the arbitration hearing is scheduled in accordance vdth Finding (5). It is, further,
ORDERED, That the parties' arbitration packages be filed and a copy served upon the other party on December 30,2008, hi accordance with Finding (5). It is, further,
ORDERED, That initial and reply briefs be filed in accordance with Findings (4). It is, further,
ORDERED, That a status conference call is scheduled for September 25, 2008, in accordance with Finding (8). It is, further,
ORDERED, That a copy of this Entry be served upon all parties of record and interested persons.
THE PUBUC UTILITIES COMMISSION OF OHIO
t ;geb Entered in the Journal HUB20"gW»
Rene^ J. Jenkins Secretary