DTC, MA, GTL Reply Brief, telephone rates, 2016

Type: Trial Briefs • May 23, 2016 • Locations: United States of America -> Massachusetts • Topics: Telephones -> Telephone Rates

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Before the
COMMONWEALTH OF MASSACHUSETTS
DEPARTMENT OF TELECOMMUNICATIONS AND CABLE
Petition of Recipients of Collect Calls from
Prisoners at Correctional Institutions in
Massachusetts Seeking Relief from the
Unjust and Unreasonable Cost of such Calls

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)
)
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D.T.C. 11-16

REPLY BRIEF OF GLOBAL TEL*LINK CORPORATION

David Silverman
Executive Vice President and
Chief Legal Officer
GLOBAL TEL*LINK CORPORATION
12021 Sunset Hills Road, Suite 100
Reston, VA 20190
703-955-3886
dsilverman@gtl.net

Chérie R. Kiser
Angela F. Collins
CAHILL GORDON & REINDEL LLP
1990 K Street, NW, Suite 950
Washington, DC 20006
202-862-8900
ckiser@cahill.com
acollins@cahill.com

Dated: May 23, 2016

Its Attorneys

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TABLE OF CONTENTS
Page
I.

THIS PROCEEDING SHOULD BE CLOSED OR STAYED .......................................... 1

II.

REPLIES ON ISSUES RAISED BY THE NOTICE.......................................................... 3
1. Whether the elimination of the per-call surcharge resolves all concerns regarding the
just and reasonableness of the per-call surcharge rate and warrants the Department
closing that portion of its Investigation. ............................................................................. 3
2..Whether the elimination of the per-call surcharges and the establishment of interim and
final rate caps for ICS service necessitates that the Department investigate whether the
$0.10 per-minute rate cap for all intrastate ICS in Massachusetts remains just and
reasonable. .......................................................................................................................... 5
3.Whether the FCC’s establishment of specific taxes and ancillary service charges with
price caps sufficiently resolved all concerns regarding the service and other fees
contained in ICS providers’ tariffs and warrants the Department closing that portion of its
Investigation. ....................................................................................................................... 6
4.Whether the FCC’s Order resolves concerns about dropped calls and other service
quality issues and warrants the Department closing all or part of that portion of its
Investigation. ....................................................................................................................... 7
5.Whether the FCC’s Order resolves concerns about the adequacy of billing details and
warrants the Department closing that portion of its Investigation. ..................................... 8
6.Whether any changes to the scope of the proceeding would moot any of the pending
discovery requests. .............................................................................................................. 9

CONCLUSION ............................................................................................................................. 10
CERTIFICATE OF SERVICE

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D.T.C. 11-16

REPLY BRIEF OF GLOBAL TEL*LINK CORPORATION
Global Tel*Link Corporation (“GTL”),1 by its attorneys and pursuant to the Notice of
Briefing Schedule issued by the Massachusetts Department of Telecommunications and Cable
(the “Department”),2 hereby submits its Reply Brief with respect to the status of the abovecaptioned proceeding.
I.

THIS PROCEEDING SHOULD BE CLOSED OR STAYED
There is unanimous agreement among the inmate calling service (“ICS”) providers that

this proceeding should be closed in light of the recent Federal Communications Commission
(“FCC”) decisions on ICS matters,3 the resulting court appeals,4 and the lack of “sufficient” and

Although not specifically included as a named party, some of Petitioners’ claims concern DSI-ITI, LLC
(“DSI”), which serves the Norfolk County Correctional Center in Massachusetts. DSI is a wholly owned subsidiary
of GTL. Thus, to the extent necessary, GTL submits this Reply Brief on behalf of DSI as well.
2

D.T.C. 11-16, Petition of Recipients of Collect Calls from Prisoners at Correctional Institutions in
Massachusetts Seeking Relief from the Unjust and Unreasonable Cost of such Calls, Notice of Briefing Schedule
(Mar. 18, 2016) (“Notice”). The Hearing Officer subsequently extended the time for filing briefs to April 25, 2016,
and reply briefs to May 23, 2016. See D.T.C. 11-16, Petition of Recipients of Collect Calls from Prisoners at
Correctional Institutions in Massachusetts Seeking Relief from the Unjust and Unreasonable Cost of such Calls,
Hearing Officer Ruling Securus Technologies Inc. Motion for Extension of Time (Mar. 28, 2016).
3

Rates for Interstate Inmate Calling Services, 28 FCC Rcd 14107 (2013) (“First ICS Order”), pets. for stay
granted in part sub nom. Securus Tech., Inc. v. FCC, No. 13-1280, Order (D.C. Cir. Jan.13, 2014), pets. for review
pending sub nom. Securus Tech., Inc. v. FCC, No. 13-1280 (D.C. Cir. filed Nov. 14, 2013) (and consolidated cases);
Rates for Interstate Inmate Calling Services, 30 FCC Rcd 12763 (2015) (“Second ICS Order”), pets. for stay
granted in part sub nom. Global Tel*Link Corporation v. FCC, No. 15-1461, Order (D.C. Cir. Mar. 7, 2016), Order
(D.C. Cir. Mar. 23, 2016), pets. for review pending sub nom. Global Tel*Link Corporation v. FCC, No. 15-1461
(D.C. Cir. filed Dec. 18, 2015) (and consolidated cases).
4

Securus Tech., Inc. v. FCC, No. 13-1280, Petition for Review (D.C. Cir. filed Nov. 14, 2013) (and
consolidated cases); Global Tel*Link Corporation v. FCC, No. 15-1461, Petition for Review (D.C. Cir. filed Dec.
18, 2015) (and consolidated cases).

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“reasonable”5 information to support Petitioners’ claims.6 In the alternative, the Department
should stay this proceeding pending judicial review of the FCC’s ICS rules.7 It would be
premature and a waste of resources for both the Department and the participants to move forward
with this proceeding given the pending court review of the FCC’s ICS rules.

Even the

Petitioners recognize the future of ICS regulation is unclear.8
The Department previously has “stayed proceedings pending the outcome of FCC
proceedings when it would be unreasonably onerous for the Department to issue a decision
without preceding action by the” FCC.9 If the Department moves forward with this proceeding,
it runs the risk of adopting rules governing ICS that subsequently will be preempted or deemed
to be inconsistent with the FCC’s final rules, which would require the Department to conduct
additional proceedings. While the FCC’s most recent ICS action provides some indication of the
“general approach contemplated by the FCC,” the Department cannot be certain the FCC’s
Second ICS Order rules will not be altered on appeal.10

The Department also has stayed

proceedings when possible action by the FCC or the courts could affect a pending Department
proceeding, preferring instead to let those “[e]vents . . . inform [its] course of action.”11

D.T.C. 09-1, Investigation by the Department of Telecommunications & Cable on its own Motion, pursuant
to General Law Chapter 159, Section 16, of the Telephone Service Quality of Verizon New England, Inc. d/b/a
Verizon Massachusetts, in Berkshire, Hampden, Hampshire, and Franklin Counties, Order to Open Investigation
(June 1, 2009).
6

GTL Initial Brief at 1-2; Securus Initial Brief at 2; ICSolutions Initial Brief at 7.

ICSolutions Initial Brief at 4.

Petitioners’ Initial Brief at 1.

D.T.E. 01-20, Investigation by the Department of Telecommunications & Energy on its own Motion into the
Appropriate Pricing, based upon Total Element Long-Run Incremental Costs, for Unbundled Network Elements &
Combinations of Unbundled Network Elements, & the Appropriate Avoided Cost Discount for Verizon New
England, Inc. d/b/a Verizon Mass. Resale Services in the Commonwealth of Massachusetts, Interlocutory Order on
Part B Motions (Apr. 4, 2001) (“01-20 Interlocutory Order”).
10

01-20 Interlocutory Order at 8.

D.T.E. 03-60, Proceeding by the Department of Telecommunications and Energy on its own Motion to
Implement the Requirements of the Federal Communications Commission Triennial Review Order Regarding

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Accordingly, the Department should close this proceeding for the reasons set forth in the ICS
providers’ Initial Briefs and below or, in the alternative, suspend any further action in this
proceeding until the court completes its review of the FCC’s ICS rules.
II.

REPLIES ON ISSUES RAISED BY THE NOTICE
As the Initial Briefs demonstrate, the four (4) issues identified for investigation in the

September 2013 Ruling12 have been resolved by the FCC or the issues are no longer ripe for
review based on existing law and the record. The Initial Briefs support closing this proceeding.
1.

Whether the elimination of the per-call surcharge resolves all concerns regarding
the just and reasonableness of the per-call surcharge rate and warrants the
Department closing that portion of its Investigation.
All parties agree that the per-call surcharge established as reasonable by the Department13

is no longer permissible under the FCC’s Second ICS Order.14 The FCC’s action to prohibit percall surcharges moots Petitioners’ request that the Department revisit the $3.00 surcharge, and
eliminates the need for the Department to “consider Petitioners’ allegations and examine the
changes to the ICS industry and whether to maintain the per-call surcharge and/or adjust the
maximum rate permitted per call.”15 Therefore, this portion of the Department’s investigation
should be closed.

Switching for Mass Market Customers, Interlocutory Order on Motion to Stay of Verizon New England, Inc. d/b/a
Verizon Massachusetts, 15, 17 (Apr. 4, 2004).
12

D.P.U./D.T.E. 97-88/97-18 (Phase II), Investigation by the Department of Telecommunications and Energy
on Its Own Motion regarding (1) Implementation of Section 276 of the Telecommunications Act of 1996 relative to
Public Interest Payphones, (2) Entry and Exit Barriers for the Payphone Marketplace, (3) New England Telephone
and Telegraph Company d/b/a NYNEX’s Public Access Smart-Pay Line Service, and (4) the Rate Policy for
Operator Services Providers, Order on Payphone Barriers to Entry and Exit, and OSP Rate Cap, at 9-10 (April 17,
1998) (“1998 Rate Cap Order”).
14

Second ICS Order at p.162 (setting forth new rule 47 C.F.R. § 64.6080); Petitioners’ Initial Brief at 3;
Securus Initial Brief at 5-6; ICSolutions Initial Brief at 6; GTL Initial Brief at 5-6.
15

September 2013 Ruling at 26.

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There is no support for Petitioners’ request that the Department “adopt the FCC’s
analysis and prohibit per-call surcharges.”16 The Department’s per-call surcharge is the result of
its determination that ICS providers have “legitimate additional costs” due to “the unique
characteristics of inmate calling services.”17 These unique characteristics of inmate calling
services produce per-call costs that are higher than costs for traditional operator services.18 In
light of these “additional costs,” the Department determined it was necessary to modify the rate
cap mechanism for inmate calling services to provide for rate recovery of the legitimate
additional costs incurred in providing inmate calling services19 and adopted a maximum
surcharge of $3.00 per call in addition to the per-minute usage rates.20 As the Department
recently reiterated, the per-minute usage rates were intended only to reflect “traditional cost
recovery, not the unique additional costs associated with ICS.”21 There is nothing in the current
record that supports a prohibition on per-call surcharges if the FCC’s ban on such charges were
overturned on appeal. However, there is no reason for the Department to expend valuable
resources reviewing this issue while the appeal is pending.

This type of “administrative

inefficiency would not benefit the Department, the parties, or the public interest.”22

Petitioners’ Initial Brief at 3.

1998 Rate Cap Order at 9. The Department determined that inmate service providers’ “additional costs”
include “(1) costs associated with call processing systems, automated operators, call recording and monitoring
equipment, and fraud control programs that are required to ensure security and to deter abuses; (2) higher levels of
uncollectibles; and (3) higher personnel costs.” See id. at 9-10.
18

Id.

1998 Rate Cap Order at 10.

September 2013 Ruling at 19.

01-20 Interlocutory Order at 8.

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Whether the elimination of the per-call surcharges and the establishment of interim
and final rate caps for ICS service necessitates that the Department investigate
whether the $0.10 per-minute rate cap for all intrastate ICS in Massachusetts
remains just and reasonable.
As both GTL and Securus explain, matters concerning the per-minute usage rate cap are

not under review in this proceeding.23 This issue has not been “re-opened” in this proceeding by
GTL and Securus as Petitioners’ suggest.24 The Department has ruled on two separate occasions
that the per-minute usage rate is not part of this proceeding.25 While GTL agrees with Securus
and ICSolutions that there needs to be adjustments to Massachusetts’ per-minute usage cap in
light of the elimination of the per-call surcharge,26 any such adjustment should occur as part of a
generic rulemaking proceeding, through a waiver request, or during the tariff approval process.27
Even ICSolutions, which requests that the Department implement an interim adjustment in the
per-minute usage cap, admits that there is insufficient evidence in the record to establish a
permanent rate cap, and that it would be a waste of Department resources to undertake the
process in light of the Second ICS Order.28 Accordingly, there are no legal grounds to support
the review of the per-minute usage rate in this adjudicatory proceeding.29

GTL Initial Brief at 6-7; Securus Initial Brief at 6-7.

Petitioners’ Initial Brief at 2.

September 2013 Ruling at 19-20; D.T.C. 11-16, Petition of Recipients of Collect Calls from Prisoners at
Correctional Institutions in Massachusetts Seeking Relief from the Unjust and Unreasonable Cost of such Calls,
Order on Appeal of Hearing Officer’s Ruling (Feb. 26, 2014).
26

Securus Initial Brief at 6-7; ICSolutions Initial Brief at 7-8.

GTL Initial Brief at 7.

ICSolutions Initial Brief at 12.

See, e.g., Arthurs v. Bd. of Registration in Medicine, 418 N.E.2d 1236, 1246 (Mass. 1981) (quoting SEC v.
Chenery Corp., 332 U.S. 194, 203 (1947) and NLRB v. Bell Aerospace Co., 416 U.S. 267, 294 (1974)); Cambridge
Elec. Light Co. v. Dep’t of Pub. Utils., 295 N.E.2d 876, 883-84 (Mass. 1973) (internal quotation marks omitted). In
addition, “the application of new principles or standards announced in a decision may be so unfair as to amount to
an abuse of discretion.” Town of Brookline v. Comm’r of Dep’t of Environmental Quality Eng’g, 439 N.E.2d 792,
799 (Mass. 1982); accord Bell Aerospace Co., 416 U.S. at 294. Policy adoption via adjudication will not be upheld
in instances where it “suffers from any constitutional defect or statutory bar” or is not “rationally related to
furthering the [agency’s] purpose.” Anusavice v. Bd. of Registration in Dentistry, 889 N.E.2d 953, 961 (Mass.
2008); see also Attorney Gen. v. Dep’t of Pub. Utils., 900 N.E.2d 862, 864 (Mass. 2009) (“although the department

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Whether the FCC’s establishment of specific taxes and ancillary service charges
with price caps sufficiently resolved all concerns regarding the service and other
fees contained in ICS providers’ tariffs and warrants the Department closing that
portion of its Investigation.
All parties agree that the FCC’s Second ICS Order addresses the ancillary fees that may

be charged by ICS providers.30 The FCC’s determination of the permissible ancillary fees, taxes,
and regulatory surcharges that ICS providers may assess eliminates the need for the Department
to address Petitioners’ concerns regarding ICS provider fees. This portion of the Department’s
investigation should be closed.
There is no support for Petitioners’ request that the investigation on this issue remain
open due to the pending court appeal of the FCC’s ICS rules.31 As GTL explained in its Initial
Brief, Petitioners will continue to have recourse if the FCC’s ancillary fee rules are modified and
issues arise regarding ICS providers’ intrastate tariffed rates and fees.32 GTL and other ICS
providers are required to maintain and file schedules and tariffs with the Department for
intrastate telecommunications services, and those tariffs are subject to Department review and
approval to ensure they are just and reasonable,33 as required by Massachusetts law.34 Any rates
approved by the Department, “must be reasonable as determined by the [Department] in the first

may establish a policy in an adjudicatory proceeding, the application of that policy to other parties may, depending
on the nature of the policy at issue, require an additional process, as it does here”).
30

Petitioners’ Initial Brief at 4; Securus Initial Brief at 7-8; ICSolutions Initial Brief at 6-7; GTL Initial Brief

at 8-9.
31

Petitioners’ Initial Brief at 4.

GTL Initial Brief at 9.

Mass. Gen. Laws c.159, § 19 (“Unless the department otherwise orders, no change shall be made in any
rate, joint rate, fare, telephone rental, toll, classification or charge, or in any rule or regulation or form of contract or
agreement in any manner affecting the same as shown upon the schedules filed in accordance with this chapter,
except after thirty days from the date of filing a statement with the department setting forth the changes proposed to
be made in the schedule then in force and the time when such changes shall take effect.”).
34

Mass. Gen. Laws c.159, § 17.

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instance.”35 Once a provider’s rates are “examined and approved by the Department,” they are
“ipso facto just and reasonable.”36 There is no need for the Department to take any further action
in this proceeding with respect to ICS provider fees in light of the FCC’s Second ICS Order and
the Department’s ability to monitor rates and fees via the tariff review process.
4.

Whether the FCC’s Order resolves concerns about dropped calls and other service
quality issues and warrants the Department closing all or part of that portion of its
Investigation.
Petitioners recognize that the FCC’s prohibition on per-call surcharges “prevents

substantial overcharges from dropped calls,”37 which was Petitioners’ primary concern regarding
dropped calls - the requirement to “pay an additional connection surcharge of up to $3.00 when
the call is reconnected.”38 Yet, Petitioners claim this issue must remain open because Prisoners’
Legal Services has received “complaints” from “petitioners” regarding quality of service
issues.39 As both Securus and GTL point out, Petitioners have never provided the necessary
evidence to support their service quality allegations after numerous opportunities to do so.40
Petitioners’ new claim based on unnamed “petitioners” and unexplained “complaints” does not

See, e.g., Am. Tel. & Tel. Co. v. IMR Capital Corp., 888 F. Supp. 221, 246 (D. Mass. 1995) (“Any rate
approved by the DPU is considered to be prima facie lawful until it has been changed or modified by the DPU. . . . It
is thus clear that the requirement of Section 17 that rates be reasonable means that they must be reasonable as
determined by the DPU in the first instance.”) (citing Mass. Gen. Laws c.159, § 17).
36

Mass. Gen. Laws c.159, § 17; D.T.E. 04-33, Verizon New England, Inc. dba Verizon Massachusetts,
Arbitration Order (July 14, 2005) (“Because those rates were examined and approved by the Department in our last
TELRIC case, D.T.E. 01-20, which was not appealed, those rates are ipso facto just and reasonable and do not
provide double recovery; as such, Verizon may charge those rates when it begins performing the associated [routine
network modification] activities for CLECs.”) (citing Mass. Gen. Laws c.159, § 17).
37

Petitioners’ Initial Brief at 5.

D.T.C. 11-16, Petition of Recipients of Collect Calls from Prisoners at Correctional Institutions in
Massachusetts Seeking Relief from the Unjust and Unreasonable Cost of such Calls, Petition of Recipients of
Collect Calls from Prisoners at Correctional Institutions in Massachusetts Seeking Relief from the Unjust and
Unreasonable Cost of Such Calls, at 5 (filed Aug. 31, 2009).
39

Petitioners’ Initial Brief at 4-5, Kamanzi Affidavit.

Securus Initial Brief at 9-10; GTL Initial Brief at 12-13.

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provide a reasonable and sufficient basis for continuing with this portion of the investigation.41
To the extent Petitioners can identify any ICS service quality issues with specificity, those
concerns should be addressed through the normal complaint channels, not through this
adjudicatory proceeding. Petitioners consistently have ignored the Department’s long-favored
complaint policy, which is to first contact the telephone provider to resolve any problem,42 and
then file a complaint with the Department only if the telephone provider is unable to resolve the
problem in the first instance.43 Without sufficient and credible evidence,44 there is no reason for
the Department to take any further action in this proceeding with respect to service quality
issues.
5.

Whether the FCC’s Order resolves concerns about the adequacy of billing details
and warrants the Department closing that portion of its Investigation.
As explained by GTL in its Initial Brief, the FCC’s truth-in-billing rules, the

Department’s billing rules, and the FCC’s new disclosure requirements resolve Petitioners’
concerns about the adequacy of billing detail and warrant the Department closing this portion of
its investigation.45 Securus agrees, stating that the existence of these factors “warrant the closing
of this portion of the proceeding.”46 Petitioners’ attempt to keep this portion of the investigation
41

These instructions are found at: http://www.mass.gov/ocabr/government/oca-agencies/dtc-lp/consumerdtc/file-a-complaint.html.
43

See id.; see also D.P.U. 18448, Rules and Practices Relating to Telephone Service to Residential Customers
(for residential telephone complaints, requiring the customer to first notify the provider and then contact the
Department if the customer is not satisfied with the resolution).
44

D.T.E./D.P.U. 06-53, Investigation as to the propriety of the rates and charges set forth in M.D.T.E. No. 5
(Apr. 30, 2007 (“the Company would be expected to present to the Department credible evidence and explanation”);
D.P.U. 15576, Maynard Lender v. New England Telephone & Telegraph Company (Sept. 7, 1967) (finding there
was not “sufficient evidence” to make a finding).
45

GTL Initial Brief at 13-14.

Securus Initial Brief at 11.

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open based on new claims by unnamed “petitioners” regarding unexplained “complaints” 47 is
not a “reasonable” or “sufficient” basis for continuing with this portion of the investigation.48
Petitioners have never provided the necessary evidence to support their billing practice
allegations after numerous opportunities to do so.49

This portion of the Department’s

investigation should be closed.
6.

Whether any changes to the scope of the proceeding would moot any of the pending
discovery requests.
Review of the pending discovery motions is no longer necessary given that the four

issues identified for investigation have been resolved.50 As Securus notes, Petitioners’ pending
discovery requests relate to the per-call surcharge (now resolved), fees (now resolved), perminute usage charges (not part of this proceeding), quality of service (now resolved), and other
requests that are “totally outside the scope of this proceeding.”51 Therefore, review of the
pending discovery motions is no longer necessary.

Petitioners’ Initial Brief at 5, Kamanzi Affidavit.

Securus Initial Brief at 11-12.

GTL Initial Brief at 15; Securus Initial Brief at 12.

Securus Initial Brief at 13.

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CONCLUSION
For the foregoing reasons and those set forth in GTL’s Initial Brief, the Department
should close this proceeding. The issues identified for investigation in the September 2013
Ruling have been addressed by the FCC or are no longer ripe for review based on existing law
and record. In the alternative, the Department should stay this proceeding pending resolution of
the ongoing court review of the FCC’s ICS rules.
Respectfully submitted,
GLOBAL TEL*LINK CORPORATION

/s/ Chérie R. Kiser
David Silverman
Executive Vice President and
Chief Legal Officer
GLOBAL TEL*LINK CORPORATION
12021 Sunset Hills Road, Suite 100
Reston, VA 20190
(703) 955-3886
dsilverman@gtl.net

Chérie R. Kiser
Angela F. Collins
CAHILL GORDON & REINDEL LLP
1990 K Street, NW, Suite 950
Washington, DC 20006
(202) 862-8900
ckiser@cahill.com
acollins@cahill.com

Dated: May 23, 2016

Its Attorneys

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CERTIFICATE OF SERVICE
I, Angela F. Collins, certify that on this 23rd day of May 2016, I served a copy of the
foregoing Reply Brief of Global Tel*Link Corporation on the following via the method
indicated:
Sara Clark, Secretary
Department of Telecommunications and Cable
1000 Washington Street, 8th Floor, Suite 820
Boston MA 02118-6500
Email: sara.clark@MassMail.state.ma.us
Email: dtcefiling@state.ma.us
Via Federal Express and Electronic Mail
Michael Scott
Hearing Officer
Department of Telecommunications and Cable
1000 Washington Street, 8th Floor, Suite 820
Boston MA 02118-6500
Email: Michael.scott@state.ma.us
Via Federal Express and Electronic Mail
Sandra Merrick
General Counsel
Department of Telecommunications and Cable
1000 Washington Street, 8th Floor, Suite 820
Boston MA 02118-6500
Email: sandra.e.merrick@state.ma.us
Via Electronic Mail and U.S. Mail
Lindsay DeRoche
Director of Competition Division
Department of Telecommunications and Cable
1000 Washington Street, 8th Floor, Suite 820
Boston MA 02118-6500
Email: lindsay.deroche@state.ma.us
Via Electronic Mail and U.S. Mail

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Joseph Tiernan
Competition Division
Department of Telecommunications and Cable
1000 Washington Street, 8th Floor, Suite 820
Boston MA 02118-6500
Email: joseph.tiernan@state.ma.us
Via Electronic Mail and U.S. Mail
Joslyn Day
Director of Consumer Division
Department of Telecommunications and Cable
1000 Washington Street, 8th Floor, Suite 820
Boston MA 02118-6500
Email: joslyn.day@state.ma.us
Via Electronic Mail and U.S. Mail
Corey Pilz
Deputy Director of Consumer Division
Department of Telecommunications and Cable
1000 Washington Street, 8th Floor, Suite 820
Boston MA 02118-6500
Email: corey.r.pilz@state.ma.us
Via Electronic Mail and U.S. Mail
James Pingeon, Esq.
Leslie Walker, Esq.
Bonita Tenneriello, Esq.
Lizz Matos, Esq.
Alphonse Kamanzi
Prisoners’ Legal Services, Inc.
10 Winthrop Square, 3rd Floor
Boston, MA 02110
Email: jpingeon@plsma.org
Email: lwalker@plsma.org
Email: btenneriello@plsma.org
Email: lmatos@plsma.org
Email: akamanzi@plsma.org
Via Electronic Mail and U.S. Mail
Patricia Garin, Esq.
Stern, Shapiro, Weisberg & Garin
90 Canal St., 5th Floor
Boston, MA 02114
Email: pgarin@sswg.com
Via Electronic Mail and U.S. Mail

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Curtis Hopfinger
Director, Government and Regulatory Affairs
Securus Technologies, Inc.
14651 Dallas Parkway, 6th Floor
Dallas, Texas 75254
chopfinger@securustech.net
Via Electronic Mail and U.S. Mail
Ken Dawson
VP Contracts & Regulatory
Inmate Calling Solutions, LLC d/b/a ICSolutions
2200 Danbury Street
San Antonio, TX 78217
Email: kdawson@icsolutions.com
Via Electronic Mail and U.S. Mail
Paul C. Besozzi
Koyulyn K. Miller
Counsel for Securus Technologies, Inc.
Squire Patton Boggs LLP
2550 M Street NW
Washington D.C. 20037
Email: pbesozzi@squirepb.com
Email: koyulyn.miller@squirepb.com
Via Electronic Mail and U.S. Mail

/s/ Angela F. Collins
______________________________
Angela F. Collins

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