IN THE OFFICE OF ADMINISTRATIVE HEARINGS
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1 Squire Patton Boggs (US) LLP Lawrence J. Rosenfeld (State Bar # 00) lawrence.rosenfeld@squirepb.com Laura Lawless Robertson (State Bar # 1) laura.robertson@squirepb.com 1 E. Washington St., Suite 00 Phoenix, Arizona 00 Telephone: Facsimile: Attorneys for Rural/Metro Intervenors In the Matter of: IN THE OFFICE OF ADMINISTRATIVE HEARINGS Sun City Fire District dba Sun City Fire and Medical Department, Applicant. Case No. 01A-EMS-00-DHS RURAL/METRO INTERVENORS INITIAL WITNESS AND EXHIBIT LIST (Assigned to the Hon. Thomas Shedden) In accordance with Case Management Order No., the Rural/Metro Intervenors submit herewith their Initial Witness and Exhibit List. In listing these witnesses and exhibits, the Rural/Metro Intervenors are not necessarily committing to call every witness on the list, or to seek the admission of each listed exhibit. Moreover, nothing contained herein is to be construed as a representation that any item of evidence listed herein (whether testimonial or documentary) is relevant to any issue in this case. A. WITNESSES 1. Orlando M. Alcordo, Jr. Mr. Alcordo is Rural/Metro s Training Program Director/Director of Clinical Services and a certified paramedic. Mr. Alcordo may testify regarding his background and expertise, as set forth in his resume, and regarding 0-1-/1/AMERICAS
2 Rural/Metro s education and training programs and quality assurance processes and policies.. James Cunningham, V. Mr. Cunningham is Rural/Metro s Clinical Coordinator and Educator. Mr. Cunningham may testify regarding his background and expertise, as set forth in his resume, and may testify with respect to quality assurance and quality improvement matters, including Rural/Metro s quality assurance processes and policies.. Greg James. Mr. James is Rural/Metro s West Division President. Mr. James may testify regarding his background and expertise, as set forth in his resume. He may offer testimony regarding business strategies and plans of the Rural/Metro operating division of which its Sun City operations are a component. He also may offer testimony regarding the overall operational performance of Rural/Metro. He may also testify regarding other operational matters, as further described in Kevin Stock s areas of testimony.. Sven K. Johnson. Mr. Johnson is Rural/Metro s Chief Strategy Officer. Mr. Johnson may testify regarding his background and expertise, as set forth in his resume. He may testify regarding financial and operational matters, as further described in Mr. Stock s areas of testimony.. Michael Kalember. Mr. Kalember is a Field Service Engineer at Rural/Metro. He may testify regarding his background and expertise, as set forth in his resume. He may testify regarding Rural/Metro s response times, call volumes, and dispatch and scheduling matters.. Charles Jason L Odense. Mr. L Odense is Rural/Metro s Chief Information Officer, Fire Operations. He may testify regarding his background and expertise, as set forth in his resume. He may also testify regarding technological matters, including, for example, matters relating to Rural/Metro s ambulance fleet and the electronic patient care records systems. 0-1-/1/AMERICAS
3 Rakesh Mopidevi. Mr. Mopidevi is Rural/Metro s Director of Operations Strategy and Analytics. He may testify regarding his background and expertise, as set forth in his resume. Mr. Mopidevi may testify regarding Rural/Metro s system status plan, deployment efficiencies and response times, as well as Rural/Metro s business operations generally.. Marco Antonio Rivera, Jr. Mr. Rivera is Rural/Metro s Business Analysis Manager/Operational Analyst. He may testify regarding his background and expertise, as set forth in his resume. Mr. Rivera may lay foundation for the processes used and the data sources queried by Rural/Metro with respect to the collection of data and the analyses based thereon presented by other witnesses.. Jim Roeder. Mr. Roeder is Rural/Metro s Regulatory Manager. Mr. Roeder may testify regarding his background and expertise, as set forth in his resume. He may lay foundation for the processes used and the data sources queried with respect to the collection of data and the analyses presented by other witnesses.. Kevin Stock. Mr. Stock is Rural/Metro s Vice President of Operations Mountain Zone. He may testify regarding his background and expertise, as set forth in his resume. He may testify regarding operational matters, including, for example, response times, call volumes, unit hour utilization, system status management, ambulance dispatch, staffing and posting, catastrophic and mass casualty responses, mutual aid, ADHS matters, and any unmet need/public necessity assertions that may be made by the Applicant. Mr. Stock may also testify as to Rural/Metro s corporate citizenship activities and recognition therefor. He may also testify regarding Rural/Metro s business strategy and planning and investment in the local community. Mr. Stock may also offer testimony regarding Applicant s proposal and concerns with respect thereto.. Witnesses, as necessary, to lay foundation. 0-1-/1/AMERICAS
4 All witnesses listed by Applicant and/or by ADHS in their respective original and supplemental witness lists, irrespective of whether those parties call any such witness. B. EXHIBITS Curriculum Vitae 1. Orlando M. Alcordo, Jr. [RM0001-RM000]. James Cunningham, V [RM000-RM000]. Greg James [RM000-RM000]. Sven K. Johnson [RM000-RM00]. Michael Kalember [RM00]. Charles Jason L Odense [RM001-RM001]. Rakesh Mopidevi [RM001-RM001]. Marco Antonio Rivera, Jr. [RM001-RM001]. Jim Roeder [RM001-RM001]. Kevin Stock [RM00-RM00] Articles and press releases re: Rural/Metro. Sun Devil Swimming Association and Rural/Metro Corporation Are Partnering to Host The Water Safety Splash this Saturday, Press Release, April, 01 [RM00-RM00] 1. Rural/Metro Corporation Hosts Summer Blood Drive and Donor Education Event, July 1, 01 [RM00] 1. Notice re: Rural/Metro Arizona Job Fair July th and July 1th [RM00- RM00] 1. Rural/Metro to hire 1,000 nationwide, 0 in Arizona, Phoenix Business Journal, July, 01 [RM000] 1. List of Community Events Sponsored and/or Participated In By Rural/Metro, 01 [RM001-RM00] 0-1-/1/AMERICAS
5 List of Community Events Sponsored and/or Participated In By Rural/Metro, January-July 01 [RM00-RM00] 1. Cub Scout Pack Will Assist Rural/Metro Fire Fighters in / Ceremonies, September, 0 [RM00] 1. Rural/Metro Fire Crews Respond for Fire in Recycling Plant, February, 01 [RM000] 1. Mountain Vista Fire District Crews Respond for Pediatric Non-Fatal Drowning, February, 01 [RM001] 0. Ground Breaking on Fire Station in the Town of Sahuarita, April 0, 01 [RM00] 1. The Mountain Vista Fire District to Celebrate the Opening of New Fire Station, April, 01 [RM00]. June is Home Safety Month, June 1, 01 [RM00-RM00]. Rural/Metro Announces Multi-County Arizona Epic-Traumatic Brain Injury Agency Certification, August, 01 [RM00-RM00]. Rural/Metro Fire Crews Have Quick Knockdown on Mobile Home Fire, August, 01 [RM00]. Rural/Metro Southern Arizona Operations Recognized as Premier Provider in EMS, September, 01 [RM00]. Rural/Metro Fire Crews Stop Fire From Spreading, June, 01 [RM000]. Quick Attack Saves Foothills Residence, July, 01 [RM001]. EMT s Quick Action Saves Life, August, 01 [RM00]. Rural/Metro Increases Skills in Mass Casualty Emergencies, September 1, 01 [RM00] 0. Rural/Metro EMT One of Three Heroes Being Honored, October 1, 01 [RM00-RM00] 0-1-/1/AMERICAS
6 Rural/Metro Participates in Ronald McDonald Walk for Kids, December, 01 [RM00]. Rural/Metro Visits Sick Children in Hospice, December, 01 [RM00]. Rural/Metro Paramedic Graduation Ceremonies, January 1, 01 [RM00]. Rural/Metro Rewards Employees of the Year, January 1, 01 [RM00]. Rural/Metro Awards EMS Person of the Year, January, 01 [RM000]. Rural/Metro Hosts Pancake Breakfast, February, 01 [RM001- RM00]. Rural/Metro Partners for Stuff the Kidzulance with Love, February 1, 01 [RM00]. Local Battalion Chief Receives International Professional Designation, March, 01 [RM00-RM00]. Rural/Metro Station Saved Puppies in Desert, March 1, 01 [RM00] 0. Rural/Metro Participates in Chili Cook Off, March 0, 01 [RM00] 1. Rural/Metro Teaches ABC s of Water Safety, March, 01 [RM00]. Missing Teen Found With the Help of a News Tucson Viewer, April 1, 01 [RM00]. Rural/Metro Rescues Kittens, April 1, 01 [RM000]. Rural/Metro Provides Automatic Aid to Helmet Peak Fire, April 1, 01 [RM001-RM00]. Rural/Metro Responds to South Side Residential Fire, April, 01 [RM00]. PulsePoint App Established for Tucson Rural/Metro, April, 01 [RM00-RM00]. Rural/Metro Participates in Career Day, May 1, 01 [RM00]. Rural/Metro Celebrates EMS Week, May 0, 01 [RM00] 0-1-/1/AMERICAS
7 Rural/Metro Responds to Near-Drowning Call, June, 01 [RM00] 0. Rural/Metro Crews at Mobile Home Fire on South Palo Verde, June 1, 01 [RM00-RM000] 1. Rural/Metro Storm Coverage, July 1, 01 [RM001]. Driver Rescued From South Side Intersection, July 1, 01 [RM00]. Verizon Backpack Giveaway, August, 01 [RM00]. Station Opening, August, 01 [RM00]. Rural/Metro Provides EMS Care Season Opener, August, 01 [RM00]. Rural/Metro Personnel to Observe Moment of Silence for /, September, 01 [RM00]. Rural/Metro Offers Its Tips for Storm Safety, September 1, 01 [RM00-RM00]. Rural/Metro Participates in BBQ Challenge, September, 01 [RM00]. Rural/Metro Station 0 Neighbor Assist, September, 01 [RM000- RM001] 0. Rural/Metro Assists Couple Deliver Baby at Fire Station, September, 01 [RM00] 1. Station Project Winner, September 0, 01 [RM00]. Rural/Metro Participates in Heroes Day 01, October, 01 [RM00]. Rural/Metro Participates in Halloween Safehouse, October, 01 [RM00-RM00]. Rural/Metro Responds to Electrical Injury, October, 01 [RM00]. Rural/Metro Halloween Safety Tips, October 1, 01 [RM00]. Rural/Metro First Responders Rescue Trapped Deer, November 0, 01 [RM00]. Rural/Metro Thanksgiving Safety Release, November, 01 [RM00] 0-1-/1/AMERICAS
8 Day 1 of Rural/Metro Fire Department Transition Academy, January, 01 [RM01-RM0]. Rural/Metro Gains Firefighters, February, 01 [RM0] 0. PCSD Rescues Woman from Tanque Verde Falls Area, February, 01 [RM0] 1. Fire Crews Responding to House Fire Near Swan, Valencia, March 1, 01 [RM0]. Paramedic of the Year Recognized, March, 01 [RM0]. Northwest Fire and Rural/Metro Form Partnership For Ambulance Transportation, March, 01 [RM0]. Rural/Metro Corporation Announces Enhanced Public/Private Partnership With the Superstition Fire and Medical District, March, 01 [RM0]. Rural/Metro Makes Donation to Mexico, April 1, 01 [RM0]. Fire Crews Respond to Eastside Garage Fire, April, 01 [RM01]. Rural/Metro Participates in American Heart and Stroke Walk, May, 01 [RM01]. Rural/Metro Participates in Special Olympics Torch Run, May, 01 [RM0-RM0]. Ride to School Auction Winners Announced, May 1, 01 [RM0- RM0] 0. Rural/Metro Responds to Report of Brush Fire, June 1, 01, and Update, June, 01 [RM0-RM0] 1. Rural/Metro Participates in Never Leave a Child In the Car Event, June, 01 [RM0-RM010]. San Diego City Council Unanimously Approves -Year Contract Extension with Rural/Metro, June, 01 [RM011] 0-1-/1/AMERICAS
9 Rural/Metro Fire Captain Among Fire Officers To Participate in National Fire Academy s Inaugural Managing Officer Program, June, 01 [RM01]. Rural/Metro Responds to Overturned Mobile Home, June 0, 01 [RM01-RM01] Response time statistics. Sun City Response Times, July 01 - September 01 [RM01]. CON (ComTrans) Response Times [TO COME]. CON (Southwest Ambulance Maricopa) Response Times [RM01]. CON (Rural/Metro Maricopa) Response Times [RM01] Rural/Metro Training Materials. Summary of Rural/Metro Central Arizona Operations training programs [RM01] 0. New Employee Orientation Program SWA Operations 01 Schedule [RM01-RM011] 1. Rural/Metro Corporation NHO Core Contents [RM01-RM01]. Rural/Metro Online Education Requirements Checklist 01 [RM01- RM01] Quality assurance policies. Rural Metro Clinical Services Continuous Quality Improvement Administrative Guide [RM01-RM01]. R/M Clinical Services Central Arizona [RM01-RM01] Service area maps. Maricopa County [RM01]. Southwest Ambulance CON service area [RM010]. Rural/Metro (Maricopa) CON service area [RM011]. ComTrans Ambulance CON service area [RM01] 0-1-/1/AMERICAS
10 Applicant s proposed service area [RM01; TO COME] 0. System status plans [RM01-RM01] 1. Emergency Management Plan [RM01-RM]. ComTrans Ambulance Service, Inc., CON No., Ambulance Revenue and Cost Report, January 1, 01 to December 1, 01 [RM0-RM0]. SW General, Inc., CON No., Ambulance Revenue and Cost Report, January 1, 01 to December 1, 01 [RM0-RM0]. Rural/Metro Corporation (Maricopa), CON No., Ambulance Revenue and Cost Report, January 1, 01 to December 1, 01 [RM0-RM01]. Applicant s Proforma ARCR [RM01-RM01]. All exhibits listed by Applicant and/or ADHS in their respective original and supplemental exhibit lists, to the extent relevant and admissible. RESPECTFULLY SUBMITTED this th day of November, 01. Squire Patton Boggs (US) LLP By: /s/ Lawrence J. Rosenfeld Lawrence J. Rosenfeld Laura Lawless Robertson Attorneys for Rural/Metro Intervenors 0-1-/1/AMERICAS
11 CERTIFICATE OF SERVICE Original filed using the OAH electronic document filing system this th day of November, 01, with copies provided to all parties on the approved mailing list this th day of November, 01, by posting through the designated OAH website at 0-DHS/index.html. Furthermore, a CD of the Bates-numbered exhibits listed herein, each in.pdf format, has been delivered via courier this th day of November, 01 to: /s/ Lisa Danczewski Lisa Danczewski The Honorable Thomas Shedden Administrative Law Judge The Office of Administrative Hearings 100 West Washington, Suite 1 Phoenix, Arizona /1/AMERICAS
IN THE OFFICE OF ADMINISTRATIVE HEARINGS
1 1 1 1 1 1 1 0 1 Squire Patton Boggs (US) LLP Lawrence J. Rosenfeld (State Bar # 00) lawrence.rosenfeld@squirepb.com Laura Lawless Robertson (State Bar # 1) laura.robertson@squirepb.com 1 E. Washington
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