Prison Phone Justice

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BEFORE THE FLORIDA PUBLIC SERVICE COMMISSION
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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 reknding overcharges
For collect calls made from inmate pay telephones

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Docket No. 0606 I&Tf2 i
Filed: December 13, 2006
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EVERCOM SYSTEMS, INC. D/B/A CORRECTIONAL BILLING SERVICES
SUPPLEMENTAL RESPONSE TO
SUBPOENA DUCES TECUM WITHOUT DEPOSITION
mercom aystems, inc. a m a Correctional m i i n g services pvercom), hereby
provides its supplemental response' to the Commission Staff subpoena served on
Evercom on or about November 3, 2006.2 Evercom incorporates herein its Objections to
and Motion to Quash in Part or Limit the Subpoena filed on December 4,2006. As noted

in its original response, Evercom is not a party to this docket. Neither the filing of this
Supplemental Response nor the provision of any documents or responses in regard to this
Supplemental Response should be construed as an intervention or appearance either as a
party or interested person in connection with this proceeding, or as Evercom's agreement
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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, served by TCG in the state of Florida.
LOCAL - Number of calls
(a)
Intrastate - Number of calls and minutes
(b)

RCA

Supplemental
Response:

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SEC
OTH

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Responsive documents attached, which separates calls on a local
and intrastate basis. This document should replace the document
originally provided in response to this request. It should also be

' Evercom's original response was provided on December 4,2006.
Staf€first attempted to serve a subpoena on Evercom on September 22,2006, but it w s apparently sent to
a
the wrong pla

FPSC - C 0MPiiS S i 0kd C LER K

noted that in the original response to this request, filed on December 4,
2006, interstate call information was inadvertently included. Such data is
included here so that the numbers in this Supplemental Response are
consistent with those originally provided; however, the provision of
interstate information is not an admission that the Commission has
jurisdiction over interstate calls or an agreement that Evercom will file
such information in the future.

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Vicki Gordon Kaufman
Moyle Flanigan Katz Raymoxd White &
masker, PA
118 North Gadsden Street
Tallahassee, Florida 32301
Telephone: 850.681.3828
Fax: 850.681.8788
vkaufman@,moylelaw .com
Attorneys for Evercom Systems, Inc.
d/b/a Correctional Billing Services

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CERTIFICATE OF SERVICE
I HEREBY CERTIFY that a true and correct copy of the foregoing Response to
Subpoena Duces Tecum Without Deposition was furnished by (*) hand delivery and U.S.
Mail this 13* day of December, 2006 to:
(*)Adam Teitzman
(*)Lee Eng Tan
Staff Counsel
Florida Public Service Commission
Division of Legal Services
2540 Shumard Oak Boulevard
Tallahassee, FL 32399-0850
ateitzma@,psc.state.fl .us
ltan@,psc.state.fl.us
FloydR. Self
Messer Law Firm
Post Office Box 15579
Tallahassee, FL 323 17
fself@,lawfla.com
Tracy Hatch
AT&T Communications of the Southern States, Znc.
101 North Monroe Street, Ste 700
Tallahassee, FL 3230 1
thatch@att.com

Vicki Gordon Kaufman

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Docket No. 060614-TC
Evercom Supplemental Response to Staff Subpoena
#4

CONFIDENTIAL

Supplemental response to Staff Subpoena #4 is confidential and has
been redacted in its entirety.