HomeMy WebLinkAbout20050817Petition.pdfMary S. Hobson (ISB #2142)
Stoel Rives LLP
101 South Capitol Boulevard - Suite 1900
Boise, ill 83702
Telephone: (208) 389-9000
Facsimile: (208) 389-9040
mshobson~stoe1.com
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Attorneys for Qwest Corporation
BEFO RE THE IDAHO PUBLIC UTILITIES CO MMISSI 0 N
IN THE MATTER OF THE INVESTIGATION
TO DETERMINE WHETHER IT IS
REASONABLE FOR FRONTIER
COMMUNICATIONS OF IDAHO TO
PROVIDE TELECOMMUNICATIONS
SERVICE TO CUSTOMERS LOCATED IN
THE TAMARACK RESORT
CASE NO. CTC-O5-
Qwest Corporation ("Qwest"), by and through its attorneys of record, respectfully
petitions the Idaho Public Utilities Commission ("Commission ) for leave to intervene in the
above captioned proceeding pursuant to the Commission s Rules of Practice and Procedure for
the following reasons:
Qwest is a corporation authorized to do and doing business in the state of Idaho
with its principal Idaho business office located at 999 Main Street, Boise, Idaho, 83702. Qwest
is a corporation organized under the laws of the state of Colorado and is authorized to engage in
the furnishing of general telephone service in the north central and southern portions of Idaho
and elsewhere in the western United States.
Qwest has a direct and substantial interest in the above entitled proceedings
because this case potentially deals with issues that could impact the operations of Qwest in
Idaho.
QWEST CORPORATION'S PETITION TO INTERVENE - Page 1
Boise-186498.1 0029164-00012
Qwest does not expect that its intervention will broaden the issues in this case or
prejudice any party.
Qwest desires to intervene in order that it might receive documents and if its
interests require, comment, cross-examine witnesses and present evidence in this case. At this
point, Qwest cannot inform the Commission or other parties how involved its individual
participation in this proceeding will be because the positions of the other parties and the
Commission s Staff are not yet fully known. Therefore Qwest cannot presently inform the
Commission as to the type of evidence it will present if any, or the length of time necessary for
such presentation.
It is respectfully requested that all pleadings, testimony, exhibits, orders of the
Commission and any other documents relating to this proceeding be served upon the Qwest and
its attorney, to wit:
Mary S. Hobson
Stoel Rives LLP
101 South Capitol Boulevard- Suite 1900
Boise, ill 83702-5958
Respectfully submitted this 16th day of August, 2005.
Qwest Corporation
/~~
Mary S. bson
Stoel Rives LLP
...
Attorneys for Qwest Corporation
QWEST CORPORATION'S PETITION TO INTERVENE - Page 2
Boise-186498.1 0029164-00012
CERTIFICATE OF SERVICE
I??:hereby certify that on this day of August, 2005, I served QWEST
CORPORATION'S PETITION TO INTERVENE as follows:
Jean Jewell, Secretary
Idaho Public Utilities Commission
472 West Washington Street
O. Box 83720
Boise, ill 83720-0074
Phone: (208) 334-0300
Fax: (208) 334-3762
i i ewell~puc.state.id. us
Hand Delivery
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Brandi L. Gearhart, PLS
Legal Secretary to Mary S. Hobson
Stoel Rives LLP
QWEST CORPORATION'S PETITION TO INTERVENE - Page 3
Boise-186498.10029164-00012