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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 CE IV ED F t L ED llJ 2005 AUG t 7 Pti 2: 53 lDj\liD PUBtiC 1!TJ ' 1"f'Ij:"" ~'IVj\ !!j~- ::; " I II 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 U. S. Mail Overnight Delivery Facsimile Email 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