Authority: IC 8-1-1-3

Affected: IC 8-1-2-58; IC 8-1-2-69

Sec. 4. (a) The complaint shall contain the following:

1. (1) A detailed statement of the facts supporting the complainant's position and demonstrating that despite good faith efforts, the complainant was unable to resolve its dispute with the respondent. The statement of facts must be:

   1. (A) supported by testimony or affidavits; and
   2. (B) made by persons with personal knowledge of the relevant facts.
2. (2) A statement of facts specifying each violation of the commission order or commission approved interconnection agreement committed by the respondent.
3. (3) A statement of applicable law, supported by appropriate citations.
4. (4) A statement indicating whether the remedy sought is consistent with the dispute resolution provisions of any interconnection agreement between the parties or other commission order, if applicable.
5. (5) An affirmation that the complainant provided the written notice required in section 3(a) of this rule.
6. (6) The name, address, and telephone number of the complainant's attorney, including local counsel.
7. (7) A copy of the interconnection agreement or the portion of the interconnection agreement that the complainant contends was or is being violated. If a copy of the entire interconnection agreement is provided, the complainant must specify the provisions at issue. If the interconnection agreement was adopted as a prior agreement or a portion of a prior agreement, the complaint must also indicate the provisions adopted in that agreement.

(b) The complainant may amend its complaint upon discovery of facts or circumstances unknown or unavailable to the complainant at the time the complaint was filed. Upon amendment of a complaint, the procedural schedule shall be adjusted at the discretion of the presiding officer.

(c) A complaint filed pursuant to this rule shall be assigned a cause number that corresponds to the interconnection agreement between the telecommunications carriers followed by the suffix "RD", and a sequential number to designate each dispute. For example, if the complaint involves the first dispute over an interconnection agreement that was approved by the commission in cause number 12345, the cause number for the dispute will be 12345-RD-01.

(Indiana Utility Regulatory Commission; 170 IAC 7-7-4; filed Nov 27, 2000, 9:36 a.m.: 24 IR 950; readopted filed Apr 6, 2006, 11:00 a.m.: 29 IR 2670; readopted filed Jul 12, 2012, 2:12 p.m.: 20120808-IR- 170120114RFA; readopted filed Jul 12, 2016, 10:01 a.m.: 20160810-IR-170160168RFA; readopted filed Jul 12, 2022, 12:18 p.m.: 20220810-IR-170220116RFA)