2. Procedural Background

On January 19, 2004, ORA and TURN filed a joint petition to modify D.02-10-020 to change the audit period to 1999 - 2004 or, alternatively, 2000 - 2004. Notice of the petition appeared in the Daily Calendar on January 21, 2005. Verizon and Pacific Bell Telephone Company d/b/a SBC California (referred to hereafter as "SBC") filed responses.

Verizon filed a petition to modify D.02-10-020 on February 8, 2005. Verizon's petition asks the Commission to (1) reduce the scope of the audit ordered by D.02-10-020, (2) revise the audit period to include only the most recent three years, and (3) implement these revisions in Phase 3 of this proceeding. Notice of Verizon's petition appeared in the Daily Calendar on February 10, 2005. Responses were filed by SBC and jointly by ORA and TURN. Verizon filed a reply after obtaining permission to do so from the assigned Administrative Law Judge.