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HomeMy WebLinkAbout20131824.tiffma TELEPHONE `HS DATA SYSTI TDS Baja Broadband LLC 525 Junction Road Madison, Wisconsin 53717 608.664.4330 conrad.marks@tdstelecom.com June 7, 2013 Brad Yatabe Assistant Weld County Attorney 1150 O Street PO Box 758 Greeley, CO 80632 Dear Mr. Yatabe: Baja Broadband 1061 —521 Corporate Center Drive, Suite 100 Fort Mill, SC 29707 980.235.7660 kdavis@bajabb.tv In response to your letter of May 9, 2013, Baja Broadband, LLC ("Baja") and TDS Baja Broadband LLC ("TDS Baja") hereby submit the following information in connection with our recent request that the County approve the pending transfer of Baja's cable television system to TDS Baja. Baja currently owns and operates a cable television system that serves approximately 10 cable television customers in the County under a franchise agreement that is up for renewal. Due to the small size of the system, Baja has proposed that the Board renew the franchise agreement for a 10 year period in conjunction with approval of the pending transfer. Although Baja has proposed the extension of the franchise in conjunction with the transfer, please know that the legal standards for transfer are different from renewal and should the Weld County Board of Commissioners prefer to keep the two separate, the parties are, of course, willing to proceed promptly in that direction. It has been our belief that due to the small number of customers the efficiency of combining the two would be helpful to the Board. The standard for transfer of a cable franchise has been established by Congress and the Federal Communications Commission ("FCC"). In reviewing a transfer a local franchising authority may consider the technical, legal and financial capability of the transferee to maintain the cable system. The FCC form 394 was designed to establish that capability. Since Baja and TDS Baja have provided a complete FCC form 394 and are poised to proceed with transfer of the franchise the Board may simply adopt the proposed transfer resolution enclosed with the FCC form 394. The federally established standard for franchise renewal is, you will recall, a standard which includes the test of whether the franchisee has the legal, technical and financial capability to maintain the cable system but also related considerations such as substantial compliance under the franchise. Should the Board wish to include the renewal in the resolution, the parties have provided the information below in response to the questions in your letter of May 9. 2013-1824 AM 20647635.1 Brad Yatabe Assistant Weld County Attorney June 7, 2013 Page 2 1. A summary of the technical, financial and programming history of the network since being transferred to Baja Baja has been operating the cable television system serving Weld County since January, 2012, when Baja took over the operations from US Cable of Coastal, Texas. The system is served from a headend facility located in Fort Collins, CO, which also serves Baja customers in other nearby communities including Johnstown, Ault, Eaton, Larimer County, Milliken, Pierce, Severance and Wellington. The headend facility was recently upgraded to 860 Mhz. Baja has been a leading provider of entertainment, information and communications services in the communities it serves. Since acquiring its first systems in 2006, Baja has focused its efforts on upgrading and improving system infrastructure, adding services and improving customer care. Baja's technical team has focused on hardening and rebuilding its systems and has successfully planned and executed extensive upgrades which include investments to improve Baja's fiber optic infrastructure and investments in improved customer service for video and high speed data technical support. Although Baja serves only a small number of customers in Weld, these customers receive the benefit of being connected with a robust, regional state-of-the-art system, thus ensuring that the system is financially sound and technically advanced. And, although high speed data and telephone services are not deemed to be cable services subject to cable franchises, it is important for the County to know that since taking over the US Cable systems, Baja has interconnected its high speed data and telephone services throughout its Colorado systems. Baja has launched new, increased data speeds in Weld County as shown below: With US Cable, the speeds were: o 2 Mbps o 10 Mbps o 12 Mbps o 20 Mbps Two months after Baja took over, we increased the Internet speed structure to: o 5 Mbps o 10 Mbps o 15 Mbps o 30 Mbps o 60 Mbps o 100 Mbps The programming lineup has not been significantly altered since Baja acquired the cable system. The Hallmark Movie Channel was added to the system in January, 2013. For a complete channel lineup, please see Exhibit 1, attached. AM 20647635.1 Brad Yatabe Assistant Weld County Attorney June 7, 2013 Page 3 2. A record of customer complaints under Baja and the responses by Baja Baja received only four calls from Weld County cable customers since the system was transferred to Baja. Of these four calls, which may not qualify as complaints, three related to non -responding converters, which can occur for a variety of reasons including power outages, and one related to a pay -per -view purchase. All four were routine calls and were promptly addressed. 3. The proposed date when TDS would acquire Baja and the franchise would transfer The closing of the sale from Baja to TDS Baja is currently planned for August 1, 2013. 4. Proposed TDS procedures for receiving, acting upon, and resolving subscriber complaints TDS Baja has no plans to immediately change operating procedures, including customer service procedures. TDS Baja will meet or exceed the customer service standards mandated by the Federal Communications Commission. Please see Exhibit 2, attached and the description in item 6 below regarding customer service operations. The Weld County system is served by Baja's national call center in Alamogordo, NM, which has approximately 40 full-time agents who handle calls 24 hours a day, 7 days a week. All Baja customer service representatives are fully trained to handle all aspects of customer service, thus ensuring a prompt and efficient response to all customer calls. 5. A rate schedule and proposed changes upon transfer from TDS to Baja As we are sure you are aware, federal law has a regulatory scheme separate and apart from transfer and renewal of franchises for rate regulation. In establishing the legal boundaries for franchise transfer proceedings, the FCC in its regulations clarified that a local franchising authority may not in the transfer process seek to circumvent the FCC's jurisdiction over other cable regulations including rate regulations. Nonetheless, please see Exhibit 3, attached, Baja's rate card for this system. TDS Baja has no plans at this time to raise rates. 6. A statement and timetable that outlines all proposed changes, expansion or improvements in the network as to services, programming or technical specifications upon transfer to TDS and during the forthcoming ten-year period. The parent company of TDS Baja, TDS Telecommunications Corp. ("TDS Telecom"), a wholly owned subsidiary of Telephone and Data Systems, Inc. is the seventh largest local exchange telephone company in the U.S. and is headquartered in Madison, Wis. For 44 years, TDS Telecom has been connecting people with high-speed Internet, phone, and TV entertainment services in over a hundred rural, suburban, and metropolitan communities. Today, TDS Telecom has nearly 1 million customer connections in service and 2,500 employees. After the close of the AM 20647635.1 Brad Yatabe Assistant Weld County Attorney June 7, 2013 Page 4 transaction, TDS Telecom will provide the executive, financial, technical, and operational leadership for TDS Baja in operating the acquired Baja cable systems. There are approximately 300 Baja managers, supervisors, and customer -facing employees who will remain with the systems, become employees of TDS Baja and continue to serve customers with their day-to-day operating expertise. The ultimate parent company of TDS Baja, Telephone and Data Systems, Inc. [NYSE: TDS] ("TDS") is a Fortune 500® company that employs more than 12,300 people and provides wireless; broadband, TV and voice; and hosted and managed services to approximately 7 million customers nationwide through its business units, U.S. Cellular, TDS Telecommunications Corp., and TDS Hosted & Managed Services. The company was founded in 1969 and is headquartered in Chicago. As an industry leader in the deployment and operation of sophisticated, advanced telecommunications networks and facilities, TDS intends to build on Baja's accomplishments, with an emphasis on improving broadband capabilities. TDS will employ additional consultants and add employees as necessary to maintain and improve the quality of service in the current franchise areas of Baja Broadband, LLC. The acquisition of the system by TDS Baja will bring new benefits such as having purchasing scale with strategic vendors for data transport, interconnection facilities, core data network equipment, customer premise equipment, and fleet equipment will benefit Baja operations. Baja will also benefit from teams dedicated to video, data, and voice product management, Internet marketing support, and a well -developed commercial product support team. The acquisition by TDS Baja also will offer significant opportunities to expand upon and improve services to customers. TDS brings expertise in application integration such as its call center operations which uses a single nationwide network and system linking 21 offices enabling 350 representatives, supervisors, and managers to seamlessly handle customer sales and billing calls 7x24x365. Additionally, through a single trouble ticketing and dispatch system, TDS has over 300 employees handling customer trouble calls and network alarm monitoring 7x24x365 from point of call or alarm to dispatch to full resolution. Many of the integrations will be possible once the Baja markets are connected to the TDS nationwide multi -gig WAN, for which planning and engineering has already begun. This robust network is in place today for TDS's other markets and provides connectivity and redundancy for customer operations and Internet services through its co -locations in five key data hotels in the U.S. TDS Baja has demonstrated in the filings provided to Weld County that it meets the federal standard for transfer. Further, the parties also believe that the standard for renewal has been met. Nonetheless, should the County wish to separate the processes, as mentioned above, Baja and TDS Baja would appreciate the Board's adoption of the proposed resolution as submitted with the FCC form 394. The Board may also wish to pass the proposed resolution with a simple one or two year extension allowing more time for franchise renewal subsequent to closing. AM 20647635.1 Brad Yatabe Assistant Weld County Attorney June 7, 2013 Page 5 Thank you for your attention to this matter. We will look forward to hearing from you regarding the Board's decision and adoption of a transfer resolution. BAJA BROADBAND, LLC TDS BAJA BROADBAND LLC Sincerely yours, Sincerely, LEI-LsiAa Kathleen Davis Conrad Marks Vice President — Regulatory Affairs Director — Consumer Product Management cc: Mark Barber, TDS Baja Broadband LLC AM 20647635.1 Exhibit 2 FCC Customer Service Standards The Consumer Protection and Col'petition Act of 1992 added section 632 "Consumer Protection and Customer Service" to the Communications Act. This section provides that a LFA may establish and enforce customer service requirements, construction schedules and other construction -related requirements. The provision directs the FCC to establish standards by which cable operators could fulfill their customer service requirements. The federal standards, §76.309 of the FCC rules, went into effect July 1, 1993. Enforcement: LFAs must provide cable operators with 90 days written notice prior to enforcing the standards. This may be accomplished in the franchise or through a separate ordinance. In most franchise renewals subsequent to the promulgation of the FCC standards, LFAs have requested that cable operators incorporate the FCC standards into the franchise. More Stringent Standards: The Communications Act and FCC Regulations further specify that despite the fact that the FCC standards have been adopted, States and LFAs may enact any consumer laws not preempted by the Cable Act, LFAs and cable operators can agree to standards exceeding the FCC standards and LFAs or state law can impose standards exceeding the FCC standards Pass -Through: With the adoption of the standards in the 1992 Act, the FCC established in its rate rules the right of the cable operator to "pass through" to the subscriber any direct and verifiable increased costs due to more stringent customer service requirements. It is helpful in negotioations to make clear to the LFA that an operator has the right to pass through and itemize the increased costs resulting from more stringent standards imposed by the franchise. Office Hours: The FCC Customer Service Standard §76.309 require only that customer service center and bill payment locations are conveniently located and open at lease during normal business hours (§76.309). The following language may be included in a franchise proposal or added upon the request of an LFA: Company will comply with the customer service standards promulgated by the FCC in accordance with Section 632 of the Communications Act. OR Company will comply with the FCC customer service standards and any additional customer service standards attached to this franchise as Exhibit _. To the extent that such additional standards exceed or are more stringent than the FCC customer service standards the City acknowledges that the Company may seek basic rate increases as permitted by FCC rules as a result of such additional or more stringent standards. Attachment to Franchise: If the franchising authority requests that the operator include the FCC Customer Service Standards as an exhibit to the franchise, the following three pages should be used: Exhibit 2 Customer Service Standards FCC Standards Section 76.309 FCC Customer Service Obligations 1. Cable system office hours and telephone availability - A. The cable operator will maintain a local, toll -free or collect call telephone access line which will be available to its subscribers 24 hours a day, seven days a week. i. Trained company representatives will be available to respond to customer telephone inquires during normal business hours. ii. After normal business hours, the access line may be answered by a service or an automated response system, including an answering machine. Inquiries received after normal business hours must be responded to by a trained company representative on the next business day. B. Under normal operating conditions, telephone answer time by a customer representative, including wait time, shall not exceed thirty (30) seconds when the connection is made. If call needs to be transferred, transfer time shall not exceed thirty (30) seconds. These standards shall be met no less then ninety (90) percent of the time under normal operating conditions, measured on a quarterly basis. C. The operator will not be required to acquire equipment or perform surveys to measure compliance with the telephone answering standards above unless an historical record of complaints indicates a clear failure to comply. D. Under normal operating conditions, the customer will receive a busy signal less than three (3) percent of the time. E. Customer service center and bill payment locations will be open at least during normal business hours and will be conveniently located. 2. Installations, outages, and service calls. Under normal operating conditions, each of the following four standards will be met no less than ninety five (95) percent of the time measured on a quarterly basis: A. Standard installations will be performed within seven (7) business days after an order has been placed. "Standard" installations are those that are located up to 125 feet from the existing distribution system. B. Excluding conditions beyond the control of the operator, the cable operator will begin working on "service interruptions" promptly and in no event later than 24 hours after the interruption becomes known. The cable operator must begin actions to correct other service problems the next business day after notification of the service problem. C. The "appointment window" alternative for installations, service calls, and other installation activities will be either a specific time or, at maximum, a four-hour time block during normal business hours. (The operator may schedule service calls and other installation activities outside of normal business hours for the express convenience of the customer.) Exhibit 2 D. An operator may not cancel an appointment with a customer after the close of business on the business day prior to the scheduled appointment. E. If a cable operator representative is running later for an appointment with a customer and will not be able to keep the appointment as scheduled, the customer will be contacted. The appointment will be rescheduled, as necessary, at a time which is convenient for the customer. 3. Communications between cable operators and cable subscribers. A. Notifications to subscribers. 1. The cable operator shall provide written information on each of the following areas at the time on installation of service, at least annually to all subscribers, and at any time upon request: i. products and services offered: ii. prices and options for programming services and conditions of subscription to programming and other services; iii. installation and service maintenance policies; iv. instructions on how to use the cable service; v. channel positions of programming carried on the system; and, vi. billing and complaint procedures, including the address and telephone number number of the local franchise authority's cable office. 2. Customers will be notified of any changes in rates, programming services or channel positions as soon as possible through announcements on the cable system and in writing. Notice must be given to subscribers a minimum of thirty (30) days in advance of such changes if the change is within the control of the cable operator. In addition, the cable operator shall notify subscribers thirty (30) days in advance of any significant changes in the other information required by the preceding paragraph. B. Billing. i. Bills will be clear, concise and understandable. Bills must be fully itemized, with itemizations including, but not limited to, basic and premium service charges and equipment charges. Bills will also clearly delineate all activity during the billing period, including optional charges, rebates and credits. ii. In case of a billing dispute, the cable operator must respond to a written compliant from a subscriber within thirty (30) days. C. Refunds. Refund checks will be issued pro wily, no later than either; i. the customer's next billing cycle following resolution of the request or thirty (30) days, whenever is earlier, or ii. the return of equipment supplied by the cable operator if service is terminated. Exhibit 2 D. Credits- Credits for service will be issued no later than the customer's next billing cycle following the determination that a credit is warranted. 4. Definitions - A. Normal Business Hours. The terms "normal business hours" means those hours during which most similar businesses in the community are open to serve customers. In all cases, "normal business hours" must include some evening hours at least one night per week and/or some weekend hours. B. Normal Operating Conditions. The term "normal operating conditions" means those service conditions which are within the control of the cable operator. Those conditions which are not within the control of the cable operator include, but are not limited, natural disasters, civil disturbances, power outages, telephone network outages, and severe or unusual weather conditions. Those conditions which are ordinarily within the control of the cable operator include, but are not limited to, special promotions, pay -per -view events, rate increases, regular peak or seasonal demand periods, and maintenance or upgrade of the cable system. C. Service Interruption. The term "service interruption" means the loss of picture or sound on one or more cable channels. Broadband Important Before you review these retail rates, call Baja now to take part in our many competitive, permanent bundled and promotional ratesthat are significantly lower than our standard stand-alone retail rates, shown below. The stand-alone rates shown below are before any permanent and/or bundled discounts are applied. Johnstown • Berthoud •Pierce • Ault .Milliken •Eaton • Wellington • Mt. Range Shadows • Coltinsaire •Cloverleaf •Poudre Valtey • Ptarmigan *Severance • LaPorte • Bellevue •Larimer County • Weld County Collie TV Limited Basic Cable Full Basic Cable Baja Broadband Digital Services (a -!a -carte), Family Tier Sports Tier' HBO Multiplex Cinemax Multiplex Showtime Unkmitud Start! Multiplex Baja High-Def€nition & DVR Services- Hat VR Includes Baja Paso HO Progremn§no Tier HO T5er' (Advanced) Baja Broadband Pay -Per -View. Movies, Adults & Events Iglllrlmellt (Rental & Purchase) Digital Cable Receivers Additional Digital Cable Receivers Additional HDtDVR Receiver Cable Modern Rental Internet -only Docsis 2.0 Modem (purchase) Wire Maintenance Fee (per month) 1 4llllhlllellt (Rep=aeernenl Costs Digital Cable Receivers (standard, each) HDEDVR Receiver leach) Remote Control intemet-Only Modern Internet/Phone Modem Wireless Modems Commercial Equipment $8.00 56.00 $12.70 $3.25 345.00 $3.95 $195 00 $526.00 $10.00 Up to 5100.00 Up le S110.00 Up to $120 00 Varies $15.95 $4.95 $15.65 $9.65 $15 65 $10.65 $20.60 Huh Speed Internet $24.95 Econa Internet (5.0 Mbps) $55.20 Premium Internet (10.0 Mbps} Ultra Internet (15.0 Mbps) Turbo Internet (30 0 Mbps) Mach Internet (80.0 Mbps) Warp Internet (100.0 Mbps} Standard Modem Lease Wireless Modem Lease $33.45 $47.20 $59.20 $67.49 $97.99 $197.99 $3.25 $9.95 liclne Fiume Service Unlimited Home Phone Service includes Unlimi€ed Local and Long Distance calling across all 50 states in the United States. $6.00 Unlimited Primary Line Unlimited Additional Line Varies Additional Home Phone Features: Feature Pack 41 Remote cal Forwarding. SIM Ring. Call Return Feature Pack 42 Call' Waiting iD & Cali Name Defreery Call Name Delivery (per phone line) Unlisted number per phone rule) Service Fees Primary Outlet Install Additional Outlets fns:ail Other Service Charge Fees Returned Payment Fee Past Due Fee FCC Fee 341.65 $31.65 $8.00 $3.00 $2.00 $4.50 $39.96 $19.98 Call for details $25.00 $6.00 $0.08 IMPORTANT INrURM4TION Federal law requires subscription to the -mined Basic service jot where not available, The rug Basic Cade service) to receive any oilier level of video service. Depending upon your level of video service. a digital receiver may be required. A) listed prices are for residential custorcers The programs, packages. services, channels, number of channels. cent -ant. format. pricing ace ail other aspects of Bare Broadband's offenses are subject le change or cjscoehnu`ance at arty fig Prices (excluding connection fees, change of service fees_ unretureed equ;ornera. certain m;scellaoeous sires_P?V) are monthly unless otherwise noted. You gave the opeon to purchase sattopsfrom( vendors approved and certified by Baja Broadband. Baja does not gvarentee!his equipment, it must he certfied within inctBaja operaions so ensure compatibility This equipment may not necessarily work in ether cable TV operations other than Baja Broadband. 0r rosy not wor8 with a!? present and suture lechnofcgies aid services at Baja Broadband. You cars contact a xniM1ed Baja Broadband sebfop vendor at Adams Cable Equipment (ask for Jose Floresk felephor:e' n -913.8e& 5100 or h -mad ifferesgadarscableequfpauerttcorn For acre inform -men_ pease fee! free to contact Bap at 1-877-422-5282. All services may not be available in all areas. unless specified on the Service entices & Prices sheetadditonal connector services are genoraffy sited using the navy service charge in 114 hour inaemenls, or other charges depending on the service performed Air prices are subject to change. All prices exclude franchise lees, FCC tess, Broadcaster Retransmission Fee and applicable taxes. Baja Broadband reserves the ngty si.stflure different prices or terms & condiltons for promotional purposes. 'Repuirns subscription to Full Basic Cable. "Requires subscription to Basic HD Programming Tier (HO'DVR) Mod Customer Care: (970) 5872243 Office & Parmenl Center Address: 266 Basher Drive, Uatl 4, Berinoud, CO 80513 Office Moors: Mon • Fri 8:00am - 5:B0pm May 9,2013 WELD COUNTY ATTORNEY'S OFFICE 1150 O STREET P.O. BOX 758 GREELEY, CO 80632-0758 WEBSITE: www.co.weld.co.us PHONE: (970) 336-7235 FAX: (970) 352-0242 Kathleen Davis Vice President, Regulatory Affairs Baja Broadband 1061-521 Corporate Center Drive, Suite 100 Fort Mill, SC 29707 Re: Proposal for Procedure to Renew and Transfer Cable Franchise Kathleen, Because the granting of a franchise renewal is quasi-judicial in nature, meaning the Board of Commissioners is presented with facts pertaining to a particular case before making a decision, my ability to consult with the Board regarding the procedure for renewal and transfer in your case is curtailed. I mention this to fully inform you that my proposal to handle the renewal and transfer may not be acceptable to the Board when presented, and they could dictate that a more extensive procedure be followed. However, the Board puts great emphasis on common sense solutions to issues, a small number of subscribers is involved, and the applicable Code appears to be designed to be flexible for just such circumstances. With that in mind, the following proposal has been crafted to satisfy what I believe will be the Board's concerns and concurrently, to simplify the more extensive process outlined in the Code. The proposal is to request that the Board renew the prior franchise agreement for a 10 year period and authorize the transfer of the franchise to TDS. If you have specific changes to be made to the prior franchise agreement, we can consider adding those by written amendment. To clarify, the prior franchise agreement I am referring to was issued to Fanch Cablevision of Colorado and effective January 1, 1997. Consideration of this request would occur at a hearing wherein the public would have an opportunity to give input and notice by publication and individual mailing to current subscribers would occur prior to the hearing. I suggest that a representative of Baja and TDS be present at the hearing to answer any questions from the Board. In terms of documentation, Baja and TDS should submit brief letters, jointly or separately, prior to the hearing which include the following information: 1. A summary of the technical, financial and programming history of the network since being transferred to Baja; 2. A record of customer complaints under Baja and the responses by Baja; 3. The proposed date when TDS would acquire Baja and the franchise would transfer; Page 1 of 2 4. Proposed TDS procedures for receiving, acting upon, and resolving subscriber complaints; 5. A rate schedule and proposed changes upon transfer from TDS to Baja; 6. A statement and timetable that outlines all proposed changes, expansion or improvements in the network as to services, programming or technical specifications upon transfer to TDS and during the forthcoming ten-year period; Once I receive the letter(s), I will set a hearing date before the Board and arrange for publication of notice of the hearing. At that point, I would ask that you send notice to your subscribers of the hearing in a format that I can provide, and submit proof that such notice was provided. I understand that you are hesitant to release the names and addresses of your subscribers due to privacy regulations. While my reading of the 47 USC § 551 allows for the release of such information under subsection (c)(2)(A), a document indicating that you sent out such notice should be sufficient for the Board along with a copy of the notice without any personal information included. All of these documents, along with the previously supplied maps and FCC Form 394 will be placed in the record for consideration by the Board. Please let me know if you li ve any questions regarding this proposal. Sincerely, Brad Yata Assistant We ounty Attorney Page 2 of 2 From: Kathleen Davis To: Brad Yatabe Subject: RE: Renewal/Transfer Proposed Procedure Date: Thursday, May 09, 2013 2:12:05 PM Brad, Thank you for your email and letter. I will share these with TDS and we will develop a response to your letter. The only question that may be difficult to answer is #6, as I do not believe that TDS has specific plans for changes or improvements at this time. I will let them speak for themselves; however, I would say that our business and technology change so quickly that it would be almost impossible to predict what will happen over the next ten years or to develop a specific timetable. We may need to respond to Question 6 in more general terms, which hopefully will be acceptable to the Board. I will get back to you next week and let you know when we expect to provide the letter or letters, so that we can begin to plan for the public hearing. Best regards, Kathleen Kathleen Davis VP - Regulatory Affairs Baja Broadband 325 Boston Post Road, Suite 2 Sudbury, MA 01776 Phone: 978-440-8144 Fax: 978-440-8155 Email: kdavisnbajabb.ty From: Brad Yatabe [mailto:byatabe@co.weld.co.us] Sent: Thursday, May 09, 2013 3:12 PM To: Kathleen Davis Subject: Renewal/Transfer Proposed Procedure Kathleen, Attached is a letter outlining the procedure that I think will be amenable to the Board of Commissioners. In terms of the letter I've requested from Baja and TDS, I think no more than 2 or 3 pages would be sufficient so long as any additional inquiries from the Board can be answered at the hearing on the matter. I am not sending the attached letter by conventional mail but I certainly can if you so request. Please feel free to share the attached letter with TDS or anyone else. If you have questions, I am happy to discuss. Thank you. Brad Yatabe Assistant Weld County Attorney 1150 O Street Mailing Address: P.O. Box 758, Greeley, CO 80632 tel: (970) 356-4000 ext. 4396 fax: (970) 352-0242 STATEMENT OF CONFIDENTIALITY & DISCLAIMER: The information contained in this email message is attorney privileged and confidential, intended only for the use of the individual or entity named above. If the reader of this message is not the intended recipient, you are hereby notified that any dissemination, distribution or copy of this email is strictly prohibited. If you have received this email in error, please notify us immediately by replying and delete the message. Hello