BEFORE THE PUBLIC SERVICE COMMISSION
OF THE STATE OF MISSOURI

DELTA PHONES, INC.,					)
								)
		Complainant,					)
								)
v.								)  Case No. TC-2004-0064
								)
SOUTHWESTERN BELL 					) 
TELEPHONE COMPANY, L.P., D/B/A			)
SOUTHWESTERN BELL TELEPHONE COMPANY, 	)
)
		Respondent.					)

COMPLAINANT’S STATEMENT OF DISPUTED 
AND UNDISPUTED CHARGES 
	Comes now Complainant, Delta Phones, Inc. (“DPI”), by its attorneys Newman, Comley & Ruth P.C., and pursuant to the Commission’s Order Regarding Complaint submits the following statement of the charges that are disputed and undisputed for purposes of the complaint: 
1.	The Commission’s order directed that DPI file with the Commission a statement, with supporting calculations, showing the disputed and undisputed amounts that have not been paid by DPI to Southwestern Bell Telephone Company (SWBT).  The figures set forth below do not account for amounts disputed or undisputed for the months of April, May, June and July, 2003.  Regarding the months of April and May, 2003, DPI received billings from SWBT in paper form, and these billings must be sorted and evaluated manually.  The process is highly labor intensive. DPI is still processing these billings.  DPI has not received billings from SWBT for the months of June and July, 2003, and cannot determine without them the extent to which disputes may exist about the charges.   DPI will supplement its response to the Commission’s order as the additional data becomes available. 
2.	Based upon bill dates from 4/9/2000 through 7/15/2003, excepting therefrom certain required updates for January 2003 data, and the lack of completed billing documentation for the months of April, May, June and July (as set out above): 

Current Charges 	$ 3,811,861.41
Credits Issued	$ -----
Payments	$(3,200,495.33)
Disputed Resale Amts	$(338,617.01) 	
Lost CABS revenue	  $(201,525.00)	
Late Charges	       $(406.00)	
--------------------------------------------------------------------------
Total Undisputed	$70,818.07

The attached spreadsheet was used for purposes of this summary. 

3.	The analysis in paragraph 2 does not include other matters in dispute between DPI and SWBT.  DPI contends that because of the failures, errors and omissions committed by SWB, as alleged in the complaint, DPI has also suffered other losses.  Those other losses are incorporated into the calculation as follows:
Current Charges 	$ 3,811,861.41
Credits Issued	$ -----
Payments	$(3,200,495.33)
Disputed Resale Amts	$(338,617.01) 	
UNE-P Overcharges	$(108,999.73)  	
Lost CABS revenue	  $(201,525.00)	
Lost Fed Access Revenue	   $(80,610.00)	
Late Charges	       $(406.00)	
--------------------------------------------------------------------------
Total	$(118,791.66)

						Respectfully submitted,

						Newman, Comley & Ruth P.C.

					By:	  /s/ Mark W. Comley   
						Mark W. Comley		#28847
						Cathleen A. Martin		#45682
						601 Monroe Street, Suite 301
						P.O. Box 537
						Jefferson City, MO 65102-0537
						(573) 634-2266
						(573) 636-3306 FAX

						Attorneys for Delta Phones, Inc.

Certificate of Service

	I hereby certify that a true and correct copy of the above and foregoing document was sent via e-mail on this 29th day of August, 2003, to General Counsel’s Office at gencounsel@psc.state.mo.us; Office of Public Counsel at opcservice@ded.state.mo.us; and Anthony K. Conroy, Southwestern Bell Telephone Company, at anthony.conroy@sbc.com.

						   /s/ Mark W. Comley