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Home My WebLink About20020905Motion of AT&T for Extension of Time.pdfMark P.Trinchero idaho Public UMties Cornmisdat DAVIS WRIGHTTREMAINE LLP oince of the secre my Suite 2300 REGE VED 1300 S.W.Fifth Avenue Portland,Oregon 97201 Telephone:503-241-2300 Facsimile:503-778-5299 Boise,Idaho Rebecca DeCook AT&T Communications of the Mountain States,Inc. 1875 Lawrence Street,Room 1575 Denver,Colorado 80202 Telephone:303-298-6357 Facsimile:303-298-6301 BEFORE THE IDAHO PUBLIC UTILITIES COMMISSION IN THE MATTER OF THE APPLICATION ) OF CENTURYTEL OF THE GEM STATE,)INC.AND CENTURYTELOF IDAHO,)Case No.GNR-T-02-11 INC.FOR APPROVAL OF A TARIFF )ADVICE CONTAINING DEPOSIT )REQUIREMENTS BY INCUMBENT )MOTION OF AT&T FOR LOCAL EXCHANGE CARRIERS FOR )EXTENSIONOF TIME TO FILE INTEREXCHANGECARR1ERS )REPLY COMMENTS Pursuant to IDAPA 31.01.01.038 and 31.01.01.56,AT&T Communications of the Mountain States,Inc.("AT&T")submits this Motion for an Extension of Time to File Reply Comments ("Motion")in the above-captionedproceeding.AT&T respectfullyrequests that the Commission grant an extension of time to file ReplyComments until September 19,2002,a date that is twenty-one (21)days after Reply Comments were originally due pursuant to the Commission's Notice of Application and Notice of Modified Procedure in Order No.29089 ("Notice of Application"). Pursuant to the Commission's Notice of Application,issued on August 5,2002,AT&T submitted Comments regardingthe tariff advice letters filed by CenturyTelof the Gemstate,Inc. and CenturyTel of Idaho,Inc.(collectively "CenturyTel")proposing to change deposit regulations related to conditions under which CenturyTel may request security deposits from Interexchange Carriers ("IXCs").AT&T addressed the eleven questions raised by the Commission in the Notice of Application and raised numerous reasons why the Commission should reject CenturyTel'sproposed tariff revisions,or in the alternative,require CenturyTel to prove that the proposed revisions are needed to prevent significant financial harm. The Commission's Notice of Application anticipated that a modified procedure pursuant to Rules 201 through 204 of the Commission's Rules of Procedure (IDAPA 31.01.01.201 through .204)may be appropriatein this proceeding but requested that parties comment on why a modified procedure wouldbe inappropriate.Accordingly,due to the importance of issues raised by AT&T,AT&T's Comments also identified the need for the Commission to provide an opportunity either for additional comments or for cross-examination of CenturyTel's witnesses and the sponsorship of rebuttal evidence. Several other parties also submitted Comments on August 22,2002 that furtherraised important issues for consideration.The August 29,2002 due date for Reply Comments provided insufficient time for parties to effectively review and respond to all of the important issues raised.The insufficiencyof time is evidenced by the fact that the majority of parties that filed Comments on August 22,2002,includingCommission Staff,did not file Reply Comments by August 29,2002. To ensure that the Commission has the benefit of full discourse on the important issues raised in parties'August 22nd Comments,AT&T urges the Commission to grant an extension of 2 Portland time until September 19,2002 to file Reply Comments.AT&T recognizes that it may also be appropriate for the Commission to provide an opportunity for a response to Reply Comments submitted on September 19,2002 as such Reply Comments may address issues raised in Reply Comments submitted on August 29,2002. DATED this 4th day of September,2002. DAVIS WRIGHT TREMAINE LLP By Mark P.Trinchero V Of Attorneys for AT&T G:\home\trinm\ATT-Century Tel\Idaho Comments 3 Portland CERTIFICATE OF SERVICE I hereby certify that I served a copy of the foregoing "MOTION OF AT&T FOR EXTENSION OF TIME TO FILE REPLY COMMENTS"upon the parties named on the attachment. I further certify that said copies were placed in sealed envelopes addressed to said partys'/attorneys'last known addresses as shown and deposited in the United States Mail at Portland,Oregon,and that the postage thereon was prepaid. DATED this 4th day of September,2002. DAVIS WRIGHT TREMAINE LLP By:C Mark P.Trinchero (Attorneyfor AT&T G:\HOME\TRINM\UX28\COS.doc Portland SERVICE LIST CASE NO.GNR-T-02-11 Pamela Donovan Rebecca DeCook CenturyTel of the Gem State AT&T Comm.Of the Mountain States,Inc. P.O.Box 9901 1875 Lawrence Street,Room 1575 Vancouver,WA 98668-8701 Denver,CO 80202 Conley E.Ward Dean J.Miller Givens Pursley LLP McDevitt &Miller LLP 277 North Sixth Street,Suite 200 420 West Bannock Street P.O.Box 2720 P.O.Box 2564-83701 Boise,ID 83701-2720 Boise,ID 83702 Morgan W.Richards Mary S.Hobson Moffatt,Thomas,Barrett,Rock &Fields,Stoel Rives LLP Chartered 101 South Capitol Boulevard,Suite 1900 101 S.Capitol Boulevard,10"'Floor Boise,ID 83702 P.O.Box 829 Boise,ID 83701 Brian Thomas John R.Hammond Time Warner Telecom Deputy AttorneyGeneral 520 SW Sixth Avenue,Suite 300 Idaho Public Utilities Commission Portland,OR 97204 P.O.Box 83720 Boise,ID 83720-0074 Gregory Rogers Allan T.Thoms Level 3 Communications Inc.Vice President-Public Policy 1025 Eldorado Boulevard &External Affairs Broomfield,CO 80021 Verizon 17933 NW EvergreenParkway P.O.Box 1100 Beaverton,OR 97075 G:\HOME\TRINM\UX28\SERVICELIST.doc Portland