May 15, 2006

Re: Docket No. 2006-274

MAINE PUBLIC UTILITIES COMMISSION
Request for Commission Investigation into
Whether Verizon is cooperating in Maine
With the National Security Agency’s
Warrantless domestic wiretapping program

Complainants's 2nd Data Request [to Verizon]

The questions below refer to information in the May 12, 2006 USA Today article,
entitled "NSA has massive database of Americans' phone calls," which the
Complainants filed that day in this proceeding, the text of which is attached. The
article reports that "[t]he National Security Agency has been secretly collecting
the phone call records of tens of millions of Americans, using data provided by
AT&T, Verizon and BellSouth," and that "[t]he three telecommunications
companies are working under contract with the NSA, which launched the
program in 2001 shortly after the Sept. 11 terrorist attacks." In regard to its
cooperation with NSA in this program, the article quotes Verizon as stating: "We
do not comment on national security matters, we act in full compliance with the
law and we are committed to safeguarding our customers' privacy." Accordingly,
these questions are based on the assumption that the USA Today article is
substantially accurate with regard to Verizon being under contract to the NSA to
provide it with "phone call records."

1. Under its contract with NSA, how much money has Verizon received from
providing its customers' call records to NSA for each of the years 2001, 2002,
2003, 2004, 2005, and 2006 year-to-date? [Please include in reponse to this and
all relevant questions that follow, counts of MCI call records provided to NSA and
the associated revenues from NSA, from the date MCI became part of Verizon.]

2. How has Verizon been booking the revenues it receives from NSA for providing
it Verizon's customers' call records?

3. What percent of Verizon's revenues from NSA is attributable to Verizon

providing NSA its Maine customers' records?

4. Under its contract with NSA: [a] how many call records in total has Verizon
provided to NSA; and [b] how many are its Maine customers' records, and how
many of those are records of those customers' intrastate calls?

5. Under its contract with NSA, what price does NSA pay Verizon for its
customers' call records, and what is the price based on? If it is a per-call record
price, please provide how that price was arrived at. Also please include Verizon's
costs to provide the records and any cost study that supports Verizon's costs.
6. Since, under its contract with NSA, Verizon is essentially selling NSA its
customers' records, have Verizon's customers, in any way, received any share of
the revenues from those sales, such as any reductions in Verizon's service rates,
or any customer rebates?

7. What percentage of its Maine customers' call records Verizon has provided to
NSA are records of those customers' intrastate calls?

8. Did Verizon's board of directors, or did a committee of the board, approve the
contract with NSA to provide it with Verizon's customers' phone call records? If
so, please provide the minutes of the board or committee meeting when that
approval was voted? If no such approval was obtained, please provide the
company by-laws that authorized the Verizon CEO or other Verizon employees to
enter into that contract with NSA.

9. By what processes does Verizon provide NSA its customers’ call records? Is
NSA provided access to Verizon switches, such as to its tandem switches? Or does
Verizon first transcribe the call records and then ship them via a computer link to
NSA? What parts of the call records, if any, does Verizon not provide to NSA
under its contract?

10. Under its contract with NSA, has Verizon provided NSA the call records of
customers of any other local exchange or long distance carrier that does business
in Maine? If so, please provide the names of the companies, the number of call
records Verizon provided from the customers of each company, and whether
Verizon obtained the companies’ prior permission.

11. Please provide a copy of Verizon's contract with NSA to provide it with
Verizon's customers' phone call records.

12. Please provide all lawsuits filed against Verizon related to allegations that it
has provided its customers’ phone call records to NSA without the customers’
permission or without the NSA providing Verizon warrants for those records.

Respectfully submitted, on behalf of the Complainants

James D. Cowie
Lead Complainant
32 North Street
Portland Maine 04101