Florida Utilities Commission v Evercom Fl Def Response to Data Request Jail Phone Overcharge 4-6-07.pdf

Type: Phone Litigation, Administrative Agency • Topics: Telephones

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MOYLE,

FLANIGAN,
KATZ, BRETON,
WHITE & KRASKER, P.A.
ATTORNEYS AT LAW

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Telephone: (850) 681-3828
Facsimile: (850) 681-8788

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The Perkins House
118 North Gadsden Street
Tallahassee, Florida 32301

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CLERK
Wellington Office
(561) 227-1560
West Palm Beach Office
(561) 659-7500

Vicki Gordon Kaufman
E-mail: vkaufman@moylelaw.com

April 6, 2007
VIA HAND DELIVERY

Blanca S. Bayo, Director
Commission Clerk and Administrative Services
Florida Public Service Commission
2540 Shumard Oak Boulevard
Tallahassee, FL 32399
Re :

This claim of confidentiality was filed b or on behalf of a
"telco" for Confidential D
Y
The
document is in locked storage pending advice on handling.
To access the material, your name must be on the CASR.
If undocketed, lour division director must provide written
permission before you can access it.

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Docket No. 0606 14-TC - T-NETIX Telecommunications Systems, Inc.'s Amended
Response to Staff Data Request

Dear Ms. Bayo:
Attached is T-NETIX Telecommunications Systems, Inc. 's
Amended
Response to Staffs February 6, 2007 Data Request, as limited by the objections and conditions
set forth in the response. This amended response is identical to the original response with the
exception of the Bates numbers. Bates numbers 00256-00268 were stamped on the confidential
documents attached to the original response. Bates numbers 00256-00261 of that filing were
inadvertently duplicated from Evercom's (T-Netix's) Supplemental Response to Staffs
Subpoena, Request #4 filed in this matter on December 13, 2006. The Bates numbers on the
enclosed confidential documents are 00262-00274; these confidential documents should be
L e p l a c e d for the confidential documents provided with the original response of December 13,
2006.

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The enclosed amended response constitutes proprietary confidential business information
of T-NETIX within the meaning of Section 364.183( l), Florida Statutes, and rule 25-22.06(5),
Florida Administrative Code. This amended response contains sensitive business information
I-----relating to competitive interests, and the public disclosure of this information would impair the
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competitive business of T-NETIX. Thus, this infomation should be held exempt from the public
disclosure requirements of section 119.07, Florida Statutes.
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One copy is enclosed which highlights the information for which T-NETIX claims
confidentiality. Two redacted copies of the confidential information are also enclosed.

Ms. Bay0
April 6, 2007
Page 2 of 2

Thank you for your assistance. Please contact me if you have any questions.
Sincerely,
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Enclosure
cc:

Lee Eng Tan
Adam Teitzman
Floyd Self
Tracy Hatch
Curtis Hopfinger

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BEFORE THE FLORIDA PUBLIC SERVICE COMMISSION
In re: Compliance investigation of TCG Public
Communications, Inc. for apparent violation of
Section 364.183(1), F.S., Access to Company
Records, and determination of amount and
Appropriate method for refunding overcharges
For collect calls made from inmate pay telephones

Docket No. 0606 14-TC

Filed: April 6, 2007

T-NETIX TELECOMMUNICATION SYSTEMS, INC.'S
AMENDED RESPONSE TO
STAFF'S INFORMAL DATA REQUEST
T-NETIX Telecommunication Systems, Inc. (T-Netix),' hereby provides its
amended responses to the Commission Staffs informal data request which, by
agreement, was sent to counsel for T-NETIX on February 6,2007.
General Obiections to Requests and Limitations on Responses
T-NETIX is not a party to this docket. The regulated company that is the subject
of this investigation is TCG Public Communications, Inc. (TCG). Neither T-NETIX's
filing of this response nor its provision of any documents or responses should be
construed as an intervention or appearance either as a party or interested person in
connection with this proceeding, or as T-NETIX's agreement or consent to respond
further in connection with this matter.

T-NETIX provides this response so as to

cooperate with the Commission Staff in this docket.
Staff has not delineated any time frame goveming the information it seeks. An
unspecified time frame for the information sought is unreasonable. Therefore, T-NETIX
has provided information for the last three (3) years, with the exception of Request No.
3, where calling data is provided for the last six (6) years.

In addition, T-NETIX is a

While Staffs request for information is addressed to Evercom Systems, Inc., Evercom Systems, Inc. does
not provide service in the Dade County facilities at issue in this docket. T-NETIX Telecommunications
Systems, Inc. is the entity that provides service. Therefore, the requests have been answered on that basis.

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corporation with employees located in many different locations in Florida and in other
states. T-NETIX has made its best efforts to diligently search its files for the requested
information (as limited by the objections and limitations set out herein). To the extent the
Staff informal requests purport to require more, such requests would impose an undue
burden and expense on T-NETIX.
Requests and Responses
Request No. 1:

For each of the Miami-Dade facilities, please identify if ThreeWay Detection software was installed.

Provide the date that the software was installed at each facility.

Provide the date that the software was activated at each facility.
Response is confidential and has been redacted.

Response:
Request No. 2:

Please identify the technicians responsible for maintaining and
monitoring the Three-way Detection software at each facility.

For each facility, provide the period for each technician that has been or
presently assigned to monitor and maintain the Three-way Detection
software.

For each facility, provide the period for each supervisor that has been or
presently assigned to monitor and maintain the Three-way Detection
software.

Response: