The following are excerpts from AT&T's response to Keith Maydak's request for admissions. While the original document lists the requests and then lists the responses, it has been reformatted to alternate between requests and responses to make reading easier.
Numerous requests for admissions that AT&T responded to simply by citing responses to prior requests have been omitted.
Each request is a request that AT&T either admit or deny a specific allegation.
Pursuant to Rule 36 of the Federal Rules of Civil Procedure, Plaintiff, American Telephone and Telegraph Company (``AT&T''), by and through its attorneys, Thorp, Reed, & Armstrong, responds to Defendant's Revised Second Request for Admissions as follows:
Request: That each of the following documents, exhibited with this request, is genuine: (a) Exhibit ``B'' is a true and correct copy of a check issued by AT&T to Richard Fibb for over-billed 900-prefix calls which were billed to the telephone number (412)-829-1935.
Response: Denied as stated. Although AT&T has diligently searched its files, copies of the checks at issue in the Request could not be located. AT&T therefore has not been able to verify the authenticity of the checks. AT&T does admit, however, that AT&T does have authorizations for the check numbers cited by the Defendant. For purposes of the remaining responses, AT&T will presume that exhibit B is a true and correct copy of the check issued to Richard Fibb. However, as explained below, AT&T denies that Richard Fibb was, in fact, over-billed.
Request: Checks similar to Exhibit ``B'' were mailed to telephone subscribers who were over-billed by AT&T for 900-prefix calls.
Response: Denied as stated. AT&T admits that checks similar to Exhibit B were mailed to telephone subscribers whose numbers appeared to have been double-recorded.
The checks were issued when AT&T discovered that there had been some double-recording of Multi-Quest calls. To expedite resolution of this matter; and to promote customer satisfaction, AT&T issued checks to all subscribers whose numbers appeared to have been double-recorded, regardless of whether they were, in fact, double-billed.
Request: The over-billing occurred when AT&T sent local telephone companies electronic billing records for calls already included on previous bills.
Response: Denied as stated. AT&T admits that the double-recording occurred when AT&T sent local telephone companies electronic billing records for some calls already included on previous bills.
Request: AT&T did not advise any government employee that calls to 900-250-2555 may have been over-billed.
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