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Home My WebLink About20040300.tiff • BEFORE THE PUBLIC UTILITIES COMMISSION "I f JF rn„ c` ^� STATE OF COLORADO 20O Orr n p Pfl 4:©l Docket No. 03A-496T NOTICE OF INTERVENTION BY STAFF, ENTRY OF APPEARANCE, NOTICE PURSUANT TO RULE 9(d) AND RULE 24(a)(1) AND REQUEST FOR HEARING IN THE MATTER OF THE JOINT APPLICATION TO EXPAND THE LOCAL CALLING AREA IN NORTHERN COLORADO Staff of the Public Utilities Commission ("Staff"), through its counsel the Colorado Attorney General, intervenes in the above-captioned docket. In accordance with Rule 24(a)(1) and Rule 9(d) of the Commission's Rules of Practice and Procedure, as amended, staff states: 1. Staff contests and will participate in the above-captioned docket. 2. Staff has determined the following are among the issues that it will raise and address. a. any concerns resulting from Staff's review of the costs associated with the implementation of the expanded calling area; b. whether the community of interest standard has been met; c. any technical issues raised by the filing; and d. any and all other issues not raised herein that are relevant to this proceeding. 3. Staff requests a hearing be held regarding the above-captioned docket. 4. Pursuant to Rule 9(d) of the Commission's Rules of Practice and Procedure, as amended, notice is hereby given that staff members Sharon Podein and Gary Klug have been r 2004-0300 assigned as testimonial (litigation) staff in the above-captioned docket. Staff members Becky Quintana and Mike Zimmerman are advisory staff. Commission Counsel Assistant Attorney General Anthony Marquez is assigned as advisory counsel to the Commission. 5. Contact with any member of the testimonial (litigation) staff by counsel for any party in interest must be initiated through the undersigned counsel. 6. Please note the following filing requirement. Rule 7(b)(5) of the Commission's Rules of Practice and Procedure, as amended, provides that: a copy of any pleading or other document filed by any party in a docket shall be delivered to the offices of the Commission at the time of filing addressed to each member of staff acting as testimonial or advisory staff who has been so designated in writing for the record pursuant to Rule 9. Upon this occurrence, the • number of copies of pleadings to be filed under Rule 22(f)(4)(a) shall be reduced to an original and five copies, or to an original and three copies if the matter is assigned to an administrative law judge. (Emphasis supplied.) 7. The undersigned Assistant Attorney General, Anne K. Botterud, enters her appearance in the above-captioned docket on behalf of the staff 8. Please provide copies of filings to Commission litigation and advisory staff at this address: 1580 Logan Street, Office Level 2, Denver, Colorado 80203. 9. If this docket is being heard before the Commission (i.e., the Commission itself is conducting the hearing), please provide copies of filings to Commission counsel at this address: 1525 Sherman Street, 5th Floor, Denver, Colorado 80203. Please do notprovide copies of non- filed documents (i.e. discovery) to Commission counsel. If this docket is being heard by an administrative law judge, please do not provide copies of any pleadings, discovery or any other documentation to advisory Commission counsel. 10. Please provide copies of filings, correspondence, and any other document(s) to staff counsel at this address: 1525 Sherman Street, 5th Floor; Denver, Colorado 80203. DATED this 30th day of December 2003. Respectfully submitted, KEN SALAZAR Attorney General AO,•t, K ;actkt-= ANNE K. BOTTERUD, 20726* Assistant Attorney General Business and Licensing Section • Attorneys for Staff of the Public Utilities Commission 1525 Sherman Street, 5th Floor Denver, Colorado 80203 Telephone: (303) 866-3867 Fax: (303) 866-5691 Email: anne.botterud@state.co.us *Counsel of Record AG ALPHA: RG PU DFDVH AG File: PAR!\RL.ARLISDUNTERVENTIONS\03A-496T INT.DOC CERIThICATE OF SERVICE This is to certify that I have duly served the within NOTICE OF INTERVENTION OF STAFF OF THE PUBLIC UTILTITES COMMISSION, ENTRY OF APPEARANCE AND NOTICE PURSUANT TO 9(d)AND RULE 24(a)(1) AND REQUEST FOR HEARING upon all parties herein by depositing copies of same in the United Stateail, first class postage prepaid, or as otherwise indicated, at Denver, Colorado,this O2 day of �q n t-E _ , l^3 , addressed as follows: • Andrew B. Clauss, Esq. Barry L. Hjort,Esq. Winslow B. Waxter, Esq. P.O. Box 300 David W. McGann, Esq. Littleton, CO 80160 Qwest Services Corporation 1005 17th Street, Suite#200 Denver, CO 80202 David P.Ayraud, Esq. Don F. Williams, City Manager Assistant County Attorney City of Loveland P.O. Box 1606 500 East Third Street Fort Collins, CO 80522 Loveland, CO 80537 Pat Parker Renee Wheeler Office of Consumer Counsel City Manager's Office 1580 Logan Street, Suite 740 500 East 3r° Street Denver, CO 80203 Loveland, CO 80537 BY INTERDEPARTMENTAL MAIL P.B. Schechter G. Harris Adams Office of Consumer Counsel Assistant Attorney General 1580 Logan Street, Suite 740 Department of Law—OCC Unit Denver, CO 80203 1525 Sherman Street, 5th floor BY INTERDEPARTMENTAL MAIL Denver, CO 80203 BY INTRADEPARTMENTAL MAIL Sharon Podein Gary Kim:,Public Utilities Commission Public Utilities Commission 1580 Logan Street, OL-2 1580 Loiran Street, OL-2 Denver, CO 80203 Denver. CO 80203 BY INTERDEPARTMENTAL MAIL BY INTERDEPARTMENTAL MAIL Becky Quintana Mike Zimmerman Advisory Staff Advisory Staff Public Utilities Commission Public Utilities Commission 1580 Logan Street, OL-2 1580 Logan Street, OL-2 Denver, CO 80203 Denver, CO 80203 BY INTERDEPARTMENTAL MAIL BY INTERDEPARTMENTAL MAIL m!7) e 17 j • AG ALPHA:RG PU DFDVH AG FILE: PIRLIRLARLISDIPUCCERTS103A-096T.D0C Hello