Prison Phone Justice

.
; .z
I

r-9

'I-.',..

-.

: :1
:1
.

*

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. 060614-TC

~ \ ; i + ~ ; ] j~ ' ~

/-LE$(
Filed: March 7, 2007
I

T-NETIX TELECOMMUNICATION SYSTEMS, INC.'S RESPONSE TO
STAFF'S INFORMAL DATA REOUEST
T-NETIX Telecommunication Systems, Inc. (T-Netix),' hereby provides its
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

I

I

CMP

-

CTR

E
x

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 governing the information it seeks. An

-_u___7

1

GCt
CPfZ

unspecified time frame for the information sought is unreasonable. Therefore, T-NETIX
-__-__

a3
c4

has provided information for the last three (3) years, with the exception of Request No.

cB\
.lkd

__n_rr_z

5
3
%

_=--

SEX

-

*IH

3, where calling data is provided for the last six (6) years.

In addition, T-NETIX is a

z T - pI
- IL .'

1

While Staff's 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

f@(.3dTSystems, Inc. is the entity that provides service. Therefore, the requests have been answered on that

1

I '

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.

A.

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

B.

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

Response:

Response is confidential and has been redacted.

Request No. 2 :

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

A.

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

B.

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:
Request No. 3: For each facility, where the Three-way Detection software was installed,
provide the following:

A.

The number of calls made from the inmate payphone system since the
Three-way detection software installation. (By month)

B.

The number of calls interrupted due to Three-way call attempts detected
by the system since the date of the software installation. (By month)

C.

The number of calls interrupted due to DTMF detection by the system
since the date of the Three-way Detection software installation. (By
month)

2

Response:

Response is confidential and has been redacted.

Request No. 4: What are the criteria for setting the sensitivity level on the Three-way
Detection software?
Response:

Response is confidential and has been redacted.

Request No. 5: Please explain how the software differentiates between a Three-way
attempt and DTMF attempt?
Response:

Response is confidential and has been redacted.

Request No. 6: Who is the primary person to have the ability to modify settings on the
Three-W ay Detection software?
Response:

Response is confidential and has been redacted.

Request No. 7 : What is the self adjustment component to the Three-way detection
software? Please answer the following:

A. How often is the software set to self adjust?

B. Are records kept of each self adjustment?
C. Is there a max percentage set for the sensitivity level?
Response:

Response is confidential and has been redacted.

Request No. 8: For each facility, please provide the names of the personnel responsible
forproviding reports on the status and performance of the sensitivity
levels during the time the software has been activated.
Response:

Response is confidential and has been redacted.

Request No. 9:Are there records used to record the sensitivity settings for each facility?
Response:

Response is confidential and has been redacted.

Request No. 10:

Response:

If the response to Interrogatory No. 9 is affirmative, please provide
copies of the log books that were used to record the sensitivity
settings at each facility.

Response is confidential and has been redacted.

3

Request No. 11:

Please identify all other facilities where your company has
installed the Three-way Detection software within the state of
Florida.

Response:

Response is confidential and has been redacted.

Request No. 12:

If other facilities within the state of Florida are identified, then
please provide answers to questions 1 through 10 above.

Response:

Response is confidential and has been redacted.

Request No. 13:

Is there a refund policy in place for customers when it has been
determined that a call was incorrectly dropped by the Three-way
detection software? If so, what does the customer need to provide
to be eligible?

Response:

Response is confidential and has been redacted.

Request No. 14:

In June 2006, Evercom provided to the Commission a report
detailing that the number of calls repeated within 10 minutes of
drop was over 5 19,000 for the Miami- Dade Pretrial detention
center. However, the number reported to the Commission in
December of 2006, for all Miami-Dade facilities was significantly
lower. Please explain the discrepancy.

Response:

Response is confidential and has been redacted.

.ti

Vicki Gordon Kaufman
Moyle Flanigan Katz W e & Krasker,
PA
118 North Gadsden Street
Tallahassee, Florida 32301
Telephone: 850.681.3828
Fax: 850.681.8788
vkaufinankdino ylclaw .coin
Attorneys for T-NETIX
Telecommunications Systems, Inc.

4

CERTIFICATE OF SERVICE

I HEREBY CERTIFY that a true and correct copy of the foregoing Response to
Staffs Informal Data Request was furnished by (*) hand delivery and U.S. Mail this 7th
day of March, 2007, to:
(*)Adam Teitzman
(*)Lee Eng Tan
Staff Counsel
Florida Public Service Commission
Division of Legal Services
2540 Shumard Oak Boulevard
Tallahassee, FL 32399-0850
ateitznia@psc.state. fl.us
ItanjLi:r>sc.st fl. us
ate.
Floyd R. Self
Messer Law Firm
Post Office Box 15579
Tallahassee, FL 323 17
fself(&lacv fl ii.coin
Tracy Hatch
AT&T Communications of the Southern States, Inc.
3 15 South Calhoun Street
Suite 750
Tallahassee, FL 32301
thatclihhtt .coin

Vicki Gordon K a u h a n

5