litigation and made a substantial response to Information contribution to each issue in the case. Requests, June 1, 2016. This was a data-driven proceeding. The Supplemental Testimony of Final Decision relies on carrier data Susan Baldwin, June 1, 2016. responses to Commission information Rebuttal Testimony of Susan requests and data requests issued to Baldwin, July 15, 2016. carriers by TURN and ORA, as well as Rebuttal Testimony of Trevor testimony, reports and federal data to Roycroft, July 15, 2016. support the Commission’s conclusions and findings. Despite the carriers’ best Numerous carrier motions efforts to prevent disclosure of their regarding procedural and most confidential subscription data, substantive issues, including TURN provided a comprehensive motions for reconsideration analysis on each issue in the Scoping ALJ Ruling Adopting Memo through its testimony, hearing Protective Order, participation, briefs, and comments. March 1, 2016. witnesses submitted extensive TURN’s ALJ Ruling Revising testimony on market definition, Protective Order, competition, wholesale markets and April 1, 2016. market analysis criteria. Ultimately, substantial contribution, along TURN’s TURN Motion to Compel, with other intervenors and ORA, April 19, 2016. presented the Commission with ACR/ALJ Ruling re: comprehensive analysis on just and Outstanding Motions, reasonable rates and competitive choice May 3, 2016. for California consumers. ALJ Ruling re: Carrier In addition to addressing substantive Motions for Reconsideration issues, the docket was marked by and to Stay, May 5, 2016 significant motion practice. TURN, in Federal collaboration with other intervenors, New Cingular v. PUC, Court complaint/TRO, issued, responded to, or opposed no May 5, 2016 fewer than 20 motions regarding all aspects of this proceeding including Scoping Memo, July 1, 2016. categorization, discovery and data TURN Opening Brief, production, scope and jurisdiction, and August 12, 2016. scheduling. TURN submits, as discussed below, that its work on these TURN Reply Brief, motions was critical to ensuring that the August 26, 2016. proceeding moved forward on a clear TURN Opening Comments on and productive path and shaping the Proposed Decision, November Final scope and conclusions. Decision’s 7, 2016. This proceeding was also unique in that TURN Reply Comments on several carrier respondents moved for
litigation and made a substantial contribution to each issue in the case. This was a data-driven proceeding. The Final Decision relies on carrier data responses to Commission information requests and data requests issued to carriers by TURN and ORA, as well as testimony, reports and federal data to support the Commission’s conclusions and findings. Despite the carriers’ best efforts to prevent disclosure of their most confidential subscription data, TURN provided a comprehensive analysis on each issue in the Scoping Memo through its testimony, hearing participation, briefs, and comments. TURN’s witnesses submitted extensive testimony on market definition, competition, wholesale markets and market analysis criteria. Ultimately, TURN’s substantial contribution, along with other intervenors and ORA, presented the Commission with comprehensive analysis on just and reasonable rates and competitive choice for California consumers. In addition to addressing substantive issues, the docket was marked by significant motion practice. TURN, in collaboration with other intervenors, issued, responded to, or opposed no fewer than 20 motions regarding all aspects of this proceeding including categorization, discovery and data production, scope and jurisdiction, and scheduling. TURN submits, as discussed below, that its work on these motions was critical to ensuring that the proceeding moved forward on a clear and productive path and shaping the Final Decision’s scope and conclusions. This proceeding was also unique in that several carrier respondents moved for response to Information Requests, June 1, 2016. Supplemental Testimony of Susan Baldwin, June 1, 2016. Rebuttal Testimony of Susan Baldwin, July 15, 2016. Rebuttal Testimony of Trevor Roycroft, July 15, 2016. Numerous carrier motions regarding procedural and substantive issues, including motions for reconsideration ALJ Ruling Adopting Protective Order, March 1, 2016. ALJ Ruling Revising Protective Order, April 1, 2016. TURN Motion to Compel, April 19, 2016. ACR/ALJ Ruling re: Outstanding Motions, May 3, 2016. ALJ Ruling re: Carrier Motions for Reconsideration and to Stay, May 5, 2016 New Cingular v. PUC, Federal Court complaint/TRO, May 5, 2016 Scoping Memo, July 1, 2016. TURN Opening Brief, August 12, 2016. TURN Reply Brief, August 26, 2016. TURN Opening Comments on Proposed Decision, November 7, 2016. TURN Reply Comments on
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