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Florida Utilities Commission v Evercom Fl Def Response to Subpoena Jail Phone Overcharge 2006.pdf

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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( l), F.S., Access to Company
Records, and Determination of amount and
Appropriate method for refunding overcharges
for collect calls made from inmate pay
telephones

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Docket

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STATE OF FLORIDA
AT&T’S COMMUNICATIONS OF THE SOUTHERN STATES, LLC/d/b/a AT&T
RESPONSE TO SUBPOENA DUCES TECUM WITHOUT DEPOSITION

Request No. I :

Any and all requests and correspondence regarding telephone
equipment sensitivity settings for the correctional facilities served
by TCG in the state of Florida

Response:

Responsive Documents Attached.

Request No .2:

Any records of modifications and changes to sensitivity levels for
the telephone equipment for the correctional facilities served by
TCG in the state of Florida.

Response:

No documents responsive to this request are within AT&T’s
posssession or control.

Request No.3:

Complete copies of any and all contracts between TCG and
Evercom d/b/a Correctional Billing Services governing work
performed for TCG by Evercom d/b/a Correctional Billing
Services,
See Attached “unsigned” copy of agreement between AT&T and
Evercom.

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Response:

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Request No.4:

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Please provide the information below for calls that terminated and
another call was completed to the same telephone number within
10 minutes for correctional facilities, identified by month and
location, serviced by TCG in the state of Florida.

(a) LOCAL - Number of calls
(b) Intrastate - Number of calls
Response:

AT&T has no information, and no access to information
responsive to this request.

Request No.5:

How many complains have been received by the company from
consumers conaerning prematurely disconnected calls (for all
correctional facilities served by TCG) for the time AT&T
controlled TCG?
Based on AT&T’s records 14 complaints were received from
consumers complaining of prematurely disconnected or
“dropped” calls.
Of the 14 consumer complaints, 8 received refunds which totaled
$1339.81 plus applicable taxes.

Response:

SUBMITTED this 23‘d day of October, 2006.

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Daniels,Sonia C EXTAF
Subject:

FW: 3-way at PTDC

EXHIBIT - A

---0
riginaI Message----From: Brown, Kim (MDCR) (305) 229-7574 [mailto:KBROWND@miamidade.gov]
Sent: Monday, December 22,2003 11:04 AM
To: Teruel, Adelaida (Ada), CSSVC; Larry Batts (E-mail 2)
Cc: Brophy, Frank (MDCR) (305) 229-7548; Mike Delucia (E-mail); Edwards,
Ronald J (Ron), CSSVC; Walsh, JoAnn, CSSVC
Subject: RE: 3-way at PTDC
Good morning Ada,
43% is exactly what is needed at this time for PTDC and we will evaluate all
the facilities again for the New Year, once we are provide updated
comparison stats.
Thank you.
Kim Brown
Miami-Dade Corrections & Rehabilitation Dept.
-----0riginal Message----From: Teruel, Adelaida (Ada), CSSVC [mailto:teruel@att.com]
Sent: Monday, December 22,2003 10:47 AM
To: Brown, Kim (MDCR) (305) 229-7574; Larry Batts (E-mail 2)
Cc: Brophy, Frank (MDCR) (305) 229-7548; Mike Delucia (E-mail); Edwards,
Ronald J (Ron), CSSVC; Walsh, JoAnn, CSSVC
Subject: RE: 3-way at PTDC
Good morning Kim,
We have your letter stating at 35%, my understanding at the present time
Pre-Trial is at 43% any tighter it will cause many calls to be dropped just
by breathing this will cause complaints to the Florida PSC.
Please advise what percentage is Miami-Dade County requesting 3-way to be
set at.
Thank you and Happy Holidays!
Ada Teruel
AT&T Public Markets
Office: 305-828-9605

FAX: 281-664-4910
CelI: 305-205-3679
€-MaiI: te rue I@att.co m
-----0riginal Message----From: Brown, Kim (MDCR) (305) 229-7574 [mailto:KBROWND@miamidade.gov]
Sent: Monday, December 22,2003 10:14 AM
To: Larry Batts (E-mail 2)
Cc: Brophy, Frank (MDCR) (305) 229-7548; Teruel, Adelaida (Ada), CSSVC;
Mike Delucia (E-mail)
Subject: 3-way at PTDC
Good morning Larry,
Sorry for the delay in confirm the need for further adjustment at PTDC, I
have been out sick.
Per our conversation over a week ago, I am confirming that we still need
PTDC 3-way tighten a little more, as that facility is the most prevalent
offender of the system.
Thank you
Kim Brown
Miami-Dade Corrections & Rehabilitation Dept.

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EXHIBIT - B

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Daniels,Sonia C EXTAF
Subject:

FW: Re:

Importance:

High

Richard Breeder - Florida PSC Case No 123388

-----Original Message----From:
Teruel, Adeiaida (Ada), CMO
Wednesday, January 19, 2005 6:29 PM
Sent:
To:
Kim Brown (E-mail)
Ron Edwards (E-mail); Frank Brophy (E-mail)
cc:
Subject:
RE: Re: Richard Breeder Ronda PSC Case No. 123388
Importance:
High

-

Good evening Kim,
I am following up on our discussion and your request on January 18th for an extension until January 19th to respond to our
letter, at this time I still do not have a response from Miami Dade Corrections. AT&T will proceed with the steps mentioned
on our letter dated January 7, 2005.

Thank you,
Ada Teruel
AT&T
National Public Markets
Project Manager
Office: 305- 828- 9605
Wireless: 305-205-3679
Fax: 281-664-4910
e-mail: teruel@att.com
-----Original Message----From:
Teruel, Adelaida (Ada), CMO
Tuesday, January 18, 2005 1153 AM
Sent:
Frank Brophy (E-mail); Klm Brown (E-mail)
To:
cc:
Ron Edwards (E-mail)
RE: Re:
Richard Breeder Florida PSC Case No. 123388
Subject:

-

Good morning Mr. Brophy and Ms. Brown,
As of today I have no response from Miami Dade Corrections on the e-mail below, AT&T will proceed with the steps

mentioned below.
Thank you,
Ada Teruel
AT&T
National Public Markets
Project Manager
Office: 305-828-9605
Wireless: 305-205-3679
Fax: 281-664-4910
e-mail: teruel@att.com

-----Original Message----From:
Teruel, Adelaida (Ada), CMO
Friday, January 07, 2005 3:OO PM
Sent:
Frank Brophy (E-mail); Kim Brown (E-mail)
To:

cc:
Subject:

Ron Edwards (E-mail)
Re:
Richard Breeder - Florida PSC Case No. 123388

Good afternoon Mr. Brophy and Ms. Brown:
We have received the attached letter from the staff of the State of Florida Public Service
Commission. AT&T must respond by January 21, 2005. The Commission’s letter is in response to the
attached email from Ms. Brown to Mr. Lewis of the Commission staff dated December 20, 2004. While
AT&T does not fully agree with the Department’s December 20themail, we do not wish to discuss that
at this time, and instead AT&T wishes to focus on what to tell the Commission on the 2Ist and what
sensitivity settings should be used in the future,
The Commission has asked that AT&T lower the sensitivity levels of the Miami-Dade
Corrections & Rehabilitation Department facilities, based on the information in the Department‘s email.
Unless the Department directs AT&T otherwise, in accordance with the Public Service
Commission’s request AT&T intends to drop the sensitivity levels at all of the Department’s facilities to
30% on February 1, 2005, and will advise the Commission of this plan in its January 21, 2005
response.
Should the Department desire that the sensitivity levels at the facilities be kept at their current
settings, or be set at some different level than 30%’ we will need to receive a clear instruction in writing
or email from the Department no later than January 18, 2005, specifying the exact sensitivity levels that
you want used at the Department‘s locations. If AT&T receives such an instruction from the
Department, we will provide that to the Commission on the 2Istand advise them that it is our intent to
comply with the Department’s request. Othetwise, AT&T will comply with the Commission’s request to
lower the sensitivity levels, as stated above. Thank you.
Sincerely,
Ada Teruel
AT&T
National Public Markets
Project Manager
Office: 305- 828- 9605
Wire/ess: 305-205-3679
Fax: 287 -664-4970
e-mail: teruelgatt. com

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Attachment:

From: Brown, Kim (MDCR) (786) 263-5853 [mailto:kbrown@miamidade.qov]
Sent: Monday, December 20, 2004 3:07 PM
To: Clayton Lewis
Cc: Brophy, Frank (MDCR) (786) 263-5859; Don McDonald
Subject: RE: CATS # 589024T - Richard Breeder

Good afternoon Clayton Lewis,
Miami-Dade Corrections and AT&T do not have a contractual agreement regarding the 3-way sensitivity
level, so there is no agreement we can supply.
We have requested that the level of the sensitivity be increased and decreased to protect our facility
security and to address issues AT&T has brought to our attention. The current level has stopped the
majority of the 3-way calls. AT&T was the initiator of this request dating back to 10/2003.
Thank you

Kim Brown
Miami-Dade Corrections & Rehabilitation Dept.
<< File: F0541EB.tif >>

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EXHIBIT - C

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