20031121Motion for Issuance of Subpoenas.pdf

Mary S. Hobson (ISB #2142)
Stoel Rives LLP
101 South Capitol Boulevard - Suite 1900
Boise, ID 83702
Telephone: [phone]
Facsimile: [phone]
mshobson~stoel.com
(EGEIVEQ LED
lOu3 NO\! 21 Aftll:
:ur\ i.; i'UbUCUTILITIES COi"If-'HSSION
Adam L. Sherr (WSBA #25291)
Qwest
1600 ih Avenue - Room 3206
Seattle, WA 98191
Telephone: [phone]
Facsimile: [phone]
adam.sherr~qwest.com
Attorneys for Qwest Corporation
BEFORE THE IDAHO PUBLIC UTILITIES COMMISSION
IN THE MATTER OF IPUC RESPONSE TO
FCC ORDER ON REVIEW OF SECTION 251
UNBUNDLING OBLIGATIONS OF
INCUMBENT LOCAL EXCHANGE
CARRIERS (CC DOCKET NO. 01-338)
Case No. GNR-03-
MOTION FOR ISSUANCE OF
COMMISSION SUBPOENAS
NINE-MONTH REVIEW OF ECONOMIC
AND OPERATIONAL IMPAIRMENT
REGARDING ACCESS TO SPECIFIC UNES
Qwest Corporation ("Qwest"), by and through its undersigned attorneys, and pursuant to
Commission Rules of Procedure 56, 222 and 226 IDAPA 31.01.01.056 31.01.01.222 and
31.01.01.226 moves the Commission for an order issuing the subpoenas that are attached as
Attachments 1-11 for the purpose of obtaining information relevant to the Commission s review
of Qwest's duty to provide certain network elements on an unbundled basis.
QWEST'S MOTION FOR ISSUANCE OF COMMISSION SUBPOENAS - Page
Boise-\64530.\ 0029164-00097
BACKGROUND
On August 21 2003 , the Federal Communications Commission (FCC) released its
Triennial Review Order (TRO),which adopts new rules concerning unbundled network
elements (UNEs). The TRO also imposes certain requirements on state commissions to make
determinations concerning whether incumbent local exchange carriers must continue to provide
certain UNEs to competitive local exchange carriers (CLECs) pursuant to 47 US.C. 9251(c)(3).
Among other findings, the TRO makes a national finding that competitors are impaired
without access to unbundled local circuit switching when serving mass-market customers.
However, the TRO did so with the clear reservation that the FCC lacked the specific facts
necessary for a more granular analysis of specific markets2 and delegated to state commissions
the authority to rebut the FCC's finding by conducting a market-by-market analysis concerning
impairment for mass-market switching.
The TRO repeatedly states that a state commission s task in a Triennial Review case is to
examine multiple factors to determine whether the national finding of impairment for mass
market switching is valid within specific markets. The Commission s ability to complete this
task is enhanced by its access to information that can only be obtained through discovery. The
FCC made it clear that, in order to fulfill its mandate, the Commission must not only examine
information in the possession of Qwest, but must also examine information in the possession of
CLECs and other providers:
State commissions possess the requisite expertise to apply (FCC)-
prescribed standards, and they routinely utilize processes and
In the M after of Review of the Section 251 Unbundling Obligations of Incumbent Local Exchange Carriers
Implementation of the Local Competition Provisions of the Telecommunications Act of 1996, Deployment of
Wireline Service Offering Advance Telecommunications Capability, CC Docket Nos. 01-338, 96-98 and 98-147
(August 21 2003) Triennial Review Order " or "TRO"
With regard to mass market switching, the FCC stated: "We also recognize that a more granular analysis
may reveal that a particular market is not subject to impairment in the absence of unbundled local circuit
switching.TRO, at ~ 461.
QWEST'S MOTION FOR ISSUANCE OF COMMISSION SUBPOENAS - Page 2
Boise-\64530.\0029\64-00097
procedures - including discovery, sworn testimony, and cross-
examination on the record - that are essential to reasoned fact
finding. 3
The TRO mandates that state commissions engage in a granular, fact-specific analysis
not only to analyze whether impairment exists within relevant geographic markets, but to define
the relevant geographic markets: "State commissions must first define the market in which they
will evaluate impairment.,,4 The Commission must analyze a vast amount of information much
of which is within the possession of CLECs and other providers to make this determination.
Likewise, Qwest's effort to definitively identify the unbundling relief it is requesting will
be materially assisted by review of the same information-that can only occur following
discovery.
DISCUSSION
The Commission has the legal authority to issue subpoenas to obtain discovery from
nonparties.
Idaho statute provides
, "
the commission shall have full power and authority to implement
the federal telecommunications act of 1996" and that "the commission may promulgate. . .
procedures necessary to carry out the duties. . . required" by the federal act. 5 The Triennial
Review Order implements provisions of the federal telecommunications act of 1996, and
delegates to the states the FCC's authority under section 251(d)(2) of the act concerning
incumbent local exchange companies' unbundling requirements for certain network elements
including mass-market switching.
The Commission s ability to conduct the granular, fact-finding analysis required by the
TRO and Idaho statute, will be materially enhanced by information from CLECs providing
Id. at ~ 488.
Id. at ~ 495.
Idaho Code!i 62-615(1);(3).
TRO at ~~ 187-90.
QWEST'S MOTION FOR ISSUANCE OF COMMISSION SUBPOENAS - Page 3
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telecommunications services in Idaho who have not chosen to intervene as parties. The
requested subpoenas are directed to those non-party CLECs that Qwest believes operate as
facilities-based providers in Idaho. The discovery requests attached to the requested subpoenas
have been strictly limited to obtain only such information as is material to the determinations the
Commission must make in this case with a minimum of burden to the subpoenaed companies.
Idaho Code 9 61-602 provides that "the commission and each commissioner shall have
power to issue writs of summons and subpoenas. . . in the like manner and to the same extent as
courts of record." Similarly, Commission Rule of Procedure 226 IDAPA 31.01.01.226 allows
the Commission
, "
upon motion in writing, or upon a Commissioner s own initiative" to issue
subpoenas for the attendance of witnesses, the production of documents, or "the production of
any books, accounts, papers or records of a utility or carrier kept within or without Idaho to any
designated place of deposition, hearing or investigation." These subpoena powers are in no way
limited to requiring attendance of or document production by utilities or companies regulated by
the Commission.
The information sought by the subpoenas will materially enhance the Commission
analysis in this case.
The requested subpoenas fall into two groups. The first group is directed to three
companies that were not served with discovery by Staff but which, according to Qwest's records
operate as facilities-based competitors in Idaho. Qwest submits that it is important to the
Commission s analysis in this case that all relevant information from all facilities-based carriers
be considered in determining whether CLECs will be impaired without the availability of mass
market switching provided by Qwest on an unbundled basis.
Although the subpoenas require attendance at deposition for the purpose of taking witness testimony, they
also provide the less-intrusive alternative ofresponding to the discovery questions in writing. Further, under Rule
222 the Commission is granted authority to "authorize or compel necessary discovery not listed in these rules.
IDAPA 31.01.01.222.
QWEST'S MOTION FOR ISSUANCE OF COMMISSION SUBPOENAS - Page 4
Boise-164530.10029164-00097
The second group of subpoenas is directed to facilities-based CLECs that were served
with discovery by Staff. These subpoenas merely seek to supplement the discovery propounded
by Staff to assure that the Commission has important information that is relevant to the
determinations it must make in this case particularly whether self-provisioning of mass market
switching is feasible in Idaho markets.
RELIEF REQUESTED
Qwest requests that the Commission issue the attached subpoenas without delay.9 The
Commission is required to complete its impairment analysis within nine months of the effective
date of the Triennial Review Order. Pursuant to Commission Rule 226.IDAPA
31.01.01.226.the Commission may, upon motion, quash a subpoena or "condition denial of
the motion to quash upon reasonable terms." Qwest submits that review of any CLEC motion
brought under this rule and exercise ofthis authority, if necessary, will provide the appropriate
level of protection to a subpoenaed CLEC with legitimate legal concerns about the
Commission s use of its subpoena powers in this case. Qwest states that it will tender to the
subpoenaed persons all fees required by statute and rule if the subpoenas are issued.
For the parties to this case and participants in the telecommunications industry in Idaho
prompt issuance of these subpoenas will facilitate the level of analysis required for this
proceeding and help ensure that factually sound determinations are made with regard to the
important issues that must be decided here.
TRO at ~ 463.
Commission Order No. 29375 requires that responses to initial discovery requests be completed by
December 19, 2003. Immediate issuance of these subpoenas will allow the CLECs sufficient time to respond within
that deadline.
QWEST'S MOTION FOR ISSUANCE OF COMMISSION SUBPOENAS - Page 5
Boise-I64530.10029164-00097
Respectfully submitted this 20th day of November, 2003.
Qwest Corporation~k---
Mary S. bson
Stoel Rives LLP
Adam L. Sherr
Qwest
Attorneys for Qwest Corporation
QWEST'S MOTION FOR ISSUANCE OF COMMISSION SUBPOENAS - Page 6
Boise-I64530.10029164-00097
CERTIFICATE OF SERVICE
,:JI I hereby certify that on this~ day of November, 2003 , I served the foregoing
MOTION FOR ISSUANCE OF COMMISSION SUBPOENAS as follows:
Jean Jewell, Secretary
Idaho Public Utilities Commission
472 West Washington Street
O. Box 83720
Boise, ill 83720-0074
Phone: [phone]
Fax: [phone]
iiewell~puc.state.id.
Hand Delivery
U. S. Mail
Overnight Delivery
Facsimile
Email
Wayne Hart
Idaho Public Utilities Commission
472 West Washington Street
O. Box 83720
Boise, ill 83720-0074
Phone: [phone]
Fax: [phone]
whart~puc.state.id.
Hand Delivery
U. S. Mail
Overnight Delivery
Facsimile
Email
Weldon Stutzman, Deputy Attorney General
Idaho Public Utilities Commission
472 West Washington Street
O. Box 83720
Boise, ID 83720-0074
Phone: [phone]
Fax: [phone]
wstutzm~puc. state.id.
Hand Delivery
U. S. Mail
Overnight Delivery
Facsimile
Email
Marlin D. Ard, Esq.
O. Box 2190
Sisters, OR 97759
Telephone: [phone]
Facsimile: [phone]
Maratty~qwest.net
Attorney for Verizon
Hand Delivery
U. S. Mail
Overnight Delivery
Facsimile
Email
QWEST'S MOTION FOR ISSUANCE OF COMMISSION SUBPOENAS - Page 7
Boise-164530.1 0029164-00097
Charles Carrathers
Verizon Northwest Inc.
1800 41 st Street
Everett, W A 98201
Telephone: [phone]
Facsimile: [phone]
chuck. carrathers~verizon. com
Hand Delivery
U. S. Mail
Overnight Delivery
Facsimile
Email
Dean J. Miller
McDevitt & Miller LLP
420 West Bannock Street
O. Box 2564 (83701)
Boise, ill 83702
Telephone: [phone]
Facsimile: [phone]
i oe~mcdevitt -miller .com
Attorney for MClmetro, Time Warner
Hand Delivery
U. S. Mail
Overnight Delivery
Facsimile
Email
Robert M. Pomeroy, Jr.
Holland & Hart
8390 East Crescent Parkway - Suite 400
Greenwood Village, CO 80111
Telephone: [phone]
Facsimile: [phone]
bpomero y~ho llandhart. com
Attorney for AT&T
Hand Delivery
--.-1L u. S. Mail
Overnight Delivery
Facsimile
Email
Adam L. Sherr
Qwest
1600 ih Avenue - Room 3206
Seattle, W A 98191
Telephone: [phone]
Facsimile: [phone]
adam.sherr~qwest.com
Hand Delivery
U. S. Mail
Overnight Delivery
Facsimile
Email
Clay R. Sturgis
Moss Adams LLP
601 West Riverside - Suite 1800
Spokane, WA 99201-0663
Telephone: [phone]
Facsimile: [phone]
clays~mossadams.com
Attorney for ITA
Hand Delivery
U. S. Mail
Overnight Delivery
Facsimile
Email
QWEST'S MOTION FOR ISSUANCE OF COMMISSION SUBPOENAS - Page 8
Boise-164530.10029164-00097
Brian Thomas
Time Warner Telecom
223 Taylor Avenue North
Seattle, W A 98109
Brian. Thomas~twtelecom.com
Hand Delivery
U. S. Mail
Overnight Delivery
Facsimile
Email
Mary B. Tribby
Letty S. D. Friesen
AT&T Communications of the Mountain States, Inc.
1875 Lawrence Street - Suite 1575
Denver, CO 80202
Telephone: [phone]
Facsimile: [phone]
lsfriesen~att.com
Hand Delivery
U. S. Mail
Overnight Delivery
Facsimile
Email
Conley E. Ward
Givens Pursley LLP
277 North 6th Street - Suite 200
O. Box 2720
Boise, ill 83701
Telephone: [phone]
Facsimile: [phone]
cew~givenspursley.com
Attorney for ITA
Hand Delivery
U. S. Mail
Overnight Delivery
Facsimile
Email
&and! A?
Brandi L. Gearhart, PLS
Legal Secretary to Mary S. Hobson
Stoel Rives LLP
QWEST'S MOTION FOR ISSUANCE OF COMMISSION SUBPOENAS - Page 9
Boise-164530.1 0029164-00097
ATTACHMENT
Mary S. Hobson (ISB #2142)
Stoel Rives LLP
101 South Capitol Boulevard - Suite 1900
Boise, ID 83702
Telephone: [phone]
Facsimile: [phone]
mshobson~stoel.com
Adam L. Shen (WSBA #25291)
Qwest
1600 ih Avenue - Room 3206
Seattle, W A 98191
Telephone: [phone]
Facsimile: [phone]
adam. shen~gwest. com
Attorneys for Qwest Corporation
BEFORE THE IDAHO PUBLIC UTILITIES COMMISSION
IN THE MATTER OF IPUC RESPONSE TO
FCC ORDER ON REVIEW OF SECTION 251
UNBUNDLING OBLIGATIONS OF
INCUMBENT LOCAL EXCHANGE
CARRIERS (CC DOCKET NO. 01-338)
Case No. GNR-03-
SUBPOENA DUCES TECUM TO 30(b)(6)
REPRESENTATIVE OF PROJECT
MUTUAL
NINE-MONTH REVIEW OF ECONOMIC
AND OPERATIONAL IMPAIRMENT
REGARDING ACCESS TO SPECIFIC UNES
To:Project Mutual Telephone Cooperative Association, Inc. ("PMT"
Charles H. Creason, Jr., 702 Fifth Street, Rupert, ill 83350
YOU ARE COMMANDED to designate and produce one or more officers, directors
employees, or other persons to appear and testify at the taking of a deposition at the office of
Stoel Rives LLP, 101 South Capitol Boulevard, Suite 1900, Boise, Idaho on December 18, 2003
at 9:00 a.m. in the above entitled matter pending before the Idaho Public Utilities Commission.
SUBPOENA DUCES TECUM TO 30(b)(6) REPRESENTATIVE OF PROJECT MUTUAL- Page 1
Boise-164645.10029164-00097
The deposition shall be taken before a licensed court reporter and will be conducted in
accordance with the IPUC Rules of Procedure IDAPA 31.01.01.000 et. seq.and the Idaho Rules
of Civil Procedure.
This deposition is being taken pursuant to IRCP 30(b )(6). PMT shall designate the
person or persons with sufficient knowledge to testify to all matters known or reasonably
available to PMT concerning the specific questions set forth in the document attached as
Attachment A and entitled "Discovery Requests." You are further commanded to produce all
documents listed on Attachment B to this subpoena. If the person or persons designated by PMT
cannot fully respond orally at the deposition, in addition to those documents listed on
Attachment B, you are further commanded to produce at the deposition the underlying
documentation and other data in your possession that will allow Qwest to compile the
information requested in Attachment A.
ALTERNATIVE PROCEDURE: In the alternative to producing a witness for the
deposition described above, you may comply with the subpoena by providing Qwest Corporation
a verified response to the discovery requests set forth in Attachment A and providing copies of
the documents listed on Attachment B. In the event you respond to this subpoena by providing
verified responses to the discovery requests, the responses shall be provided on or before
December 15, 2003 to counsel for Qwest as follows:
Mary S. Hobson (ISB #2142)
Stoel Rives LLP
101 South Capitol Boulevard - Suite 1900
Boise, ill 83702
Telephone: [phone]
Facsimile: [phone]
msho bson~stoel. com
Adam L. Sherr (WSBA #25291)
Qwest
1600 ih Avenue - Room 3206
Seattle, WA 98191
Telephone: [phone]
Facsimile: [phone]
adam.sherr~qwest.com
This subpoena is issued pursuant to Idaho Code 99 61-602; 61-605; 62-615 and IPUC
Rules of Procedure, 222, 224 and 226 IDAPA 31.01.01.222; 224; 226. Please note that Qwest
SUBPOENA DUCES TECUM TO 30(b)(6) REPRESENTATIVE OF PROJECT MUTUAL - Page 2
Boise-I64645.10029164-00097
has filed a motion with the Idaho Public Utilities Commission requesting that the Commission
enter a Protective Order in this matter governing the disclosure of proprietary and/or confidential
material or information. Thus, to the extent any of the responses, documents or underlying data
are claimed by you to be confidential, they can be provided to Qwest as confidential information
pursuant to the Protective Order, upon issuance.
DATED this 20th day of November, 2003.
IDAHO PUBLIC UTILITIES COMMISSION
By:
Its:
Jean D. Jewell
Secretary
SUBPOENA DUCES TECUM TO 30(b)(6) REPRESENT A TIVE OF PROJECT MUTUAL - Page 3
Boise-164645.10029164-00097
ATTACHMENT A
to Subpoena Duces Tecum (Project Mutual)
DISCOVERY REQUESTS
Please identify all switches owned or controlled by PMT that are being used in Idaho
to provide service to customers served by facilities at or above the DS-l level. For each switch
that you identify, please identify the type (e., 5ESS and 4ESS) and describe the "footprint" of
the switch, meaning the geographic area that the switch is capable of reaching. Separately,
please provide the same information for customers served by DS-O loop facilities.
For each switch that you identify in response to Request No.please provide the
capacity of the switch, with "capacity" defined as: (1) the number oflines installed; (2) the
number oflines currently in use; (3) the number of trunks installed; and (4) the number of trunks
currently in use. In addition, for each switch that you identify, please provide the generic
(feature package) loaded in the switch.
Please state whether the information in the LERG is current and accurate for the
switches that PMT owns, operates, controls, maintains in Idaho, or from which you lease dial
tone or trunking functionality/capacity. If any of the information is not accurate, please identify
the inaccurate information and provide corrected information, including any additions, deletions
or changes. As part of your review of the information in the LERG, please state whether the
CLLI code is accurate for each switch that PMT owns, operates, controls, maintains, or from
which you lease dial tone or trunking functionality/capacity. In addition, please state whether the
LERG definition of the function of each switch (i., tandem, end office, etc.) is accurate.
Please provide the average total revenue per line that PMT received from its
residential customers within Idaho in 2001 and 2002. The average revenue per line should
include revenues associated with the basic retail price charged to residential customers, vertical
ATTACHMENT A TO SUBPOENA DUCES TECUM (PROJECT MUTUAL)
Boise-I64645.1 0029164-00097
Page 1
features, universal service payments, interstate access charges, intrastate access charges
subscriber line charges, toll, long distance, local number portability, and line revenues derived
from any other sources. Please provide both the total average revenue per line and a breakdown
of the amount of revenue for each category of revenue that comprises the total. Please produce
all documents that reflect, refer or relate to the information provided in your response to this
request.
Please provide the average total revenue per line that PMT has received from its
business customers within Idaho in 2001 and 2002. The average revenue per line should
include revenues associated with the basic retail price charged to business customers, vertical
features, universal service payments, interstate access charges, intrastate access charges
subscriber line charges, toll, long distance, local number portability, and line revenues derived
from any other sources. Please provide both the total average revenue per line and a breakdown
of the amount of revenue for each category of revenue that comprises the total. If revenues differ
depending on the type of business customer (small vs. large), please provide the total revenues
and the breakdown of revenues by type of business customer. Please provide the information by
POTS, DSO, DSl , DS3, OC-, OC-, OC-, and any other relevant categories. Please produce
all documents that reflect, refer or relate to the information provided in your response to this
request.
Please explain how PMT defines its business customer segments and provide any
documents that reflect this definition or the criteria PMT uses to segment or classify business
customers into distinct customer groups. Please produce all documents that reflect, refer or
relate to the information provided in your response to this request.
Please provide the average total cost per line that PMT incurred in 2001 and 2002 for
lines used to serve residential customers within Idaho. These costs should include costs
ATTACHMENT A TO SUBPOENA DUCES TECUM (PROJECT MUTUAL)
Boise-I64645-1 0029164-00097
Page 2
associated with switching; loops; collocation; transport; hot cuts; operational support systems
OSS"); signaling; customer acquisitions; backhauling traffic to PMT's switches; maintenance
operations, and other administrative activities; and capital costs. If available, please provide a
breakdown of this information for the following categories: (1) service provided by UNE-, (2)
service provided by UNE-, and (3) service provided using PMT's own facilities. In addition
please provide any available breakdowns of each cost component that is part of the average total
cost per line, identifying the type and amount of each cost. Please produce all documents that
reflect, refer or relate to the information provided in your response to this request.
Please provide the average total cost per line that PMT incurred in 2001 and 2002 for
lines used to serve business customers within Idaho. These costs should include costs
associated with switching; loops; collocation; transport; hot cuts; OSS; signaling; customer
acquisitions; backhauling traffic to PMT's switches; maintenance, operations, and other
administrative activities; and capital costs. In addition to a total average cost, please provide
separate averages for service provided through UNE-, UNE-, and with PMT's own facilities.
Please provide a breakdown of each cost component that is part of the average total cost per line
identifying the type and amount of each cost. If costs differ depending on the type of business
customer (small vs. large), please provide the total cost and the breakdown of costs by type of
business customer. Please produce all documents that reflect, refer or relate to the information
provided in your response to this request.
To the extent not provided in response to Request Nos. 7 and 8, please identify the
types or categories of customer acquisition costs PMT incurred in Idaho in 2001 and 2002 to
attract new customers, set up their accounts, and establish service to them. In addition, to the
extent not provided in response to Request Nos. 7 and 8 , please provide the per line costs PMT
ATTACHMENT A TO SUBPOENA DUCES TECUM (PROJECT MUTUAL)
Boise-164645.1 0029164-00097
Page 3
incurred in 2001 and 2002 for both business and residential customers for each of the types or
categories of customer acquisition costs.
10. Please identify the monthly chum rate PMT has experienced for local exchange
customers in each month in which it has provided local exchange service in the Idaho market.
answering this request, you should calculate the churn rate based upon the number of lines lost
each year divided by the average number of lines in service that year. In calculating churn, do
not include customers who move but stay with the company. Please produce all documents that
refer or relate to the information you provide in response to this request.
11. In connection with PMT's churn rates in Idaho for the most recent 24 months that are
available for local exchange customers, of the total customers that have left PMT, please identify
the percentage that have left within one month of signing up for service, within two months of
signing up for service, within three months of signing up for service, and within six months of
signing up for service. Please produce all documents that refer or relate to the information you
provide in response to this request.
12. Please identify each rate plan that PMT offers to local exchange customers in Idaho.
In addition, please identify the percentage ofPMT's total local exchange customers in Idaho that
subscribe to each plan that you identify. Please produce all documents that reflect, refer or relate
to the information you provide in response to this request.
13. For rate plans identified in Response No. 12 that include a per minute of use
component, please provide the average long-distance per minute usage in Idaho ofPMT's local
exchange customers who subscribe to such plans for the most recent 24 months available. Please
produce all documents that reflect, refer, or relate to the information you provide in response to
this request.
ATTACHMENT A TO SUBPOENA DUCES TECUM (PROJECT MUTUAL)
Boise-164645.10029164-00097
Page 4
ATTACHMENT B
to Subpoena Duces Tecum (Project Mutual)
Please produce all documents that reflect, refer or relate to the average total revenue
per line that PMT received from its residential customers within Idaho in 2001 and 2002. For
purposes of this document request, the average revenue per line should include revenues
associated with the basic retail price charged to residential customers, vertical features, universal
service payments, interstate access charges, intrastate access charges, subscriber line charges
toll, long distance, local number portability, and line revenues derived from any other sources.
Please produce all documents that provide the total average revenue per line and a breakdown of
the amount of revenue for each category of revenue that comprises the total.
Please produce all documents that reflect, refer or relate to the average total revenue
per line that PMT has received from its business customers within Idaho in 2001 and 2002. For
purposes of this document request, the average revenue per line should include revenues
associated with the basic retail price charged to business customers, vertical features, universal
service payments, interstate access charges, intrastate access charges, subscriber line charges
toll, long distance, local number portability, and line revenues derived from any other sources.
Please provide all documents that provide the total average revenue per line and a breakdown of
the amount of revenue for each category of revenue that comprises the total. If revenues differ
depending on the type of business customer (small vs. large), please provide all documents that
provide the total revenues and the breakdown of revenues by type of business customer and by
POTS, DSO DSl DS3, OC-, OC-, OC-, and any other relevant categories.
Please produce all documents that reflect, refer or relate to how PMT defines its
business customer segments and provide any documents that reflect this definition or the
criteria PMT uses to segment or classify business customers into distinct customer groups.
ATTACHMENT B TO SUBPOENA DUCES TECUM (PROJECT MUTUAL)
Boise-l 64645. I 0029164-00097
Page 1
Please produce all documents that reflect, refer or relate to the average total cost per
line that PMT incurred in 2001 and 2002 for lines used to serve residential customers within
Idaho. For purposes of this document request, costs should include costs associated with
switching; loops; collocation; transport; hot cuts; operational support systems ("OSS"
signaling; customer acquisitions; bacldlauling traffic to PMT's switches; maintenance
operations, and other administrative activities; and capital costs. If available, please provide
documents showing a breakdown of this infol1nation for the following categories: (1) service
provided by UNE~P, (2) service provided by UNE-, and (3) service provided using PMT's own
facilities. In addition, please provide all documents containing any available breakdowns of each
cost component that is part of the average total cost per line.
Please produce all documents that reflect, refer or relate to the average total cost per
line that PMT incurred in 2001 and 2002 for lines used to serve business customers within
Idaho. For purposes of this document request, costs should include costs associated with
switching; loops; collocation; transport; hot cuts; OSS; signaling; customer acquisitions;
backhauling traffic to PMT's switches; maintenance , operations, and other administrative
activities; and capital costs. Please provide all documents that reflect, refer to relate to separate
averages for service provided through UNE-, UNE-, and with PMT's own facilities. If
available, please provide all documents showing a breakdown of each cost component that is part
of the average total cost per line, identifying the type and amount of each cost. If costs differ
depending on the type of business customer (small vs. large), please provide documents showing
the total cost and the breakdown of costs by type of business customer.
Please produce all documents that reflect, refer or relate to the monthly churn rate
PMT has experienced for local exchange customers in each month in which it has provided local
exchange service in the Idaho market.
ATTACHMENT B TO SUBPOENA DUCES TECUM (PROJECT MUTUAL)
Boise-l 64645.1 0029164-00097
Page 2
Please produce all documents that reflect, refer or relate to the percentage of local
exchange customers within the most recent 24 months that have left PMT within one month of
signing up for service, within two months of signing up for service, within three months of
signing up for service, and within six months of signing up for service.
Please produce all documents that reflect, refer or relate to each rate plan that PMT
offers to local exchange customers in Idaho. In addition, please provide all documents used to
identify the percentage ofPMT's total local exchange customers in Idaho that subscribe to each
plan.
Please produce all documents for the most recent 24 months available that reflect
refer or relate to rate plans the average long-distance per minute usage in Idaho ofPMT's local
exchange customers who subscribe to plans that include a per minute of use component.
A IT ACHMENT B TO SUBPOENA DUCES TECUM (PROJECT MUTUAL)
Boise-164645.10029164-00097
Page 3
ATTACHMENT 2
Mary S. Hobson (ISB #2142)
Stoel Rives LLP
101 South Capitol Boulevard - Suite 1900
Boise, ill 83702
Telephone: [phone]
Facsimile: [phone]
msho bsoncq)stoe I. com
Adam L. Sherr (WSBA #25291)
Qwest
1600 ih Avenue - Room 3206
Seattle, W A 98191
Telephone: [phone]
Facsimile: [phone]
adam.she1T~qwest.com
Attorneys for Qwest Corporation
BEFORE THE IDAHO PUBLIC UTILITIES COMMISSION
IN THE MATTER OF IPUC RESPONSE TO
FCC ORDER ON REVIEW OF SECTION 251
UNBUNDLING OBLIGATIONS OF
INCUMBENT LOCAL EXCHANGE
CARRIERS (CC DOCKET NO. 01-338)
Case No. GNR-03-
SUBPOENA DUCES TECUM TO 30(b)(6)
REPRESENTATIVE OF KMC DATA
NINE-MONTH REVIEW OF ECONOMIC
AND OPERATIONAL IMPAIRMENT
REGARDING ACCESS TO SPECIFIC UNES
To:KMC Data LLC ("KMC"
CT Corporation System, 300 North 6th Street, Boise, ill 83702
YOU ARE COMMANDED to designate and produce one or more officers, directors
employees, or other persons to appear and testify at the taking of a deposition at the office of
Stoel Rives LLP, 101 South Capitol Boulevard, Suite 1900, Boise, Idaho on December 18 , 2003
at 9:00 a.m. in the above entitled matter pending before the Idaho Public Utilities Commission.
SUBPOENA DUCES TECUM TO 30(b)(6) REPRESENTATIVE OF KMC DATA - Page 1
Boise-l 64646.1 0029164-00097
The deposition shall be taken before a licensed court reporter and will be conducted in
accordance with the IPUC Rules of Procedure IDAPA 31.01.01.000 et. seq.and the Idaho Rules
of Civil Procedure.
This deposition is being taken pursuant to IRCP 30(b )(6). KMC shall designate the
person or persons with sufficient knowledge to testify to all matters known or reasonably
available to KMC concerning the specific questions set forth in the document attached as
Attachment A and entitled "Discovery Requests." You are further commanded to produce all
documents listed on Attachment B to this subpoena. If the person or persons designated by
KMC cannot fully respond orally at the deposition, in addition to those documents listed on
Attachment B, you are further commanded to produce at the deposition the underlying
documentation and other data in your possession that will allow Qwest to compile the
information requested in Attachment A.
ALTERNATIVE PROCEDURE: In the alternative to producing a witness for the
deposition described above, you may comply with the subpoena by providing Qwest Corporation
a verified response to the discovery requests set forth in Attachment A and providing copies of
the documents listed on Attachment B. In the event you respond to this subpoena by providing
verified responses to the discovery requests, the responses shall be provided on or before
December 15 2003 to counsel for Qwest as follows:
Mary S. Hobson (ISB #2142)
Stoel Rives LLP
101 South Capitol Boulevard - Suite 1900
Boise, ID 83702
Telephone: [phone]
Facsimile: [phone]
mshobson~stoel.com
Adam L. Sherr (WSBA #25291)
Qwest
1600 7th Avenue - Room 3206
Seattle, WA 98191
Telephone: [phone]
Facsimile: [phone]
adam.sherr~qwest.com
This subpoena is issued pursuant to Idaho Code 99 61-602; 61-605; 62-615 and IPUC
Rules of Procedure, 222, 224 and 226 IDAPA 31.01.01.222; 224; 226. Please note that Qwest
SUBPOENA DUCES TECUM TO 30(b)(6) REPRESENTATIVE OF KMC DATA - Page 2
Boise-164646.1 0029164-00097
has filed a motion with the Idaho Public Utilities Commission requesting that the Commission
enter a Protective Order in this matter governing the disclosure of proprietary and/or confidential
material or infonnation. Thus, to the extent any of the responses, documents or underlying data
are claimed by you to be confidential, they can be provided to Qwest as confidential information
pursuant to the Protective Order, upon issuance.
DATED this 20th day of November, 2003.
IDAHO PUBLIC UTILITIES COMMISSION
By:
Its:
Jean D. Jewell
Secretary
SUBPOENA DUCES TECUM TO 30(b)(6) REPRESENTATIVE OF KMC DATA - Page 3
Boise-164646.1 0029164-00097
ATTACHMENT A
to Subpoena Duces Tecum (KMC Data)
DISCOVERY REQUESTS
Please identify all switches owned or controlled by KMC that are being used in Idaho
to provide service to customers served by facilities at or above the DS-l level. For each switch
that you identify, please identify the type (e., 5ESS and 4ESS) and describe the "footprint" of
the switch, meaning the geographic area that the switch is capable of reaching. Separately,
please provide the same information for customers served by DS-O loop facilities.
For each switch that you identify in response to Request No., please provide the
capacity of the switch, with "capacity" defined as: (1) the number of lines installed; (2) the
number oflines currently in use; (3) the number of trunks installed; and (4) the number of trunks
currently in use. In addition, for each switch that you identify, please provide the generic
(feature package) loaded in the switch.
Please state whether the information in the LERG is current and accurate for the
switches that KMC owns, operates, controls, maintains in Idaho, or from which you lease dial
tone or trunking functionality/capacity. If any ofthe information is not accurate, please identify
the inaccurate information and provide corrected information, including any additions, deletions
or changes. As part of your review of the information in the LERG, please state whether the
CLLI code is accurate for each switch that KMC owns, operates, controls, maintains, or from
which you lease dial tone or trunking functionality/capacity. In addition, please state whether the
LERG definition of the function of each switch (i., tandem, end office, etc.) is accurate.
Please provide the average total revenue per line that KMC received from its
residential customers within Idaho in 2001 and 2002. The average revenue per line should
include revenues associated with the basic retail price charged to residential customers, vertical
ATTACHMENT A TO SUBPOENA DUCES TECUM (KMC DATA)
Boise-I64646.10029164-00097
Page 1
features, universal service payments, interstate access charges, intrastate access charges
subscriber line charges, toll, long distance, local number portability, and line revenues derived
from any other sources. Please provide both the total average revenue per line and a breakdown
of the amount of revenue for each category of revenue that comprises the total. Please produce
all documents that reflect, refer or relate to the information provided in your response to this
request.
Please provide the average total revenue per line that KMC has received from its
business customers within Idaho in 2001 and 2002. The average revenue per line should
include revenues associated with the basic retail price charged to business customers, vertical
features, universal service payments, interstate access charges, intrastate access charges
subscriber line charges, toll, long distance, local number portability, and line revenues derived
from any other sources. Please provide both the total average revenue per line and a breakdown
of the amount of revenue for each category of revenue that comprises the total. If revenues differ
depending on the type of business customer (small vs. large), please provide the total revenues
and the breakdown of revenues by type of business customer. Please provide the information by
POTS, DSO, DSl , DS3, OC-, OC-, OC-, and any other relevant categories. Please produce
all documents that reflect, refer or relate to the information provided in your response to this
request.
Please explain how KMC defines its business customer segments and provide any
documents that reflect this definition or the criteria KMC uses to segment or classify business
customers into distinct customer groups. Please produce all documents that reflect, refer or
relate to the information provided in your response to this request.
Please provide the average total cost per line that KMC incurred in 2001 and 2002 for
lines used to serve residential customers within Idaho. These costs should include costs
ATTACHMENT A TO SUBPOENA DUCES TECUM (KMC DATA)
Boise-164646- J 0029164-00097
Page 2
associated with switching; loops; collocation; transport; hot cuts; operational support systems
OSS"); signaling; customer acquisitions; bacldlauling traffic to KMC's switches; maintenance
operations, and other administrative activities; and capital costs. If available, please provide a
breakdown of this information for the following categories: (1) service provided by UNE-, (2)
service provided by UNE-, and (3) service provided using KMC's own facilities. In addition
please provide any available breakdowns of each cost component that is part of the average total
cost per line, identifying the type and amount of each cost. Please produce all documents that
reflect, refer or relate to the information provided in your response to this request.
Please provide the average total cost per line that KMC incurred in 2001 and 2002 for
lines used to serve business customers within Idaho. These costs should include costs
associated with switching; loops; collocation; transport; hot cuts; OSS; signaling; customer
acquisitions; backhauling traffic to KMC's switches; maintenance, operations, and other
administrative activities; and capital costs. In addition to a total average cost, please provide
separate averages for service provided through UNE-, UNE-, and with KMC's own facilities.
Please provide a breakdown of each cost component that is part of the average total cost per line
identifying the type and amount of each cost. If costs differ depending on the type of business
customer (small vs. large), please provide the total cost and the breakdown of costs by type of
business customer. Please produce all documents that reflect, refer or relate to the information
provided in your response to this request.
To the extent not provided in response to Request Nos. 7 and 8, please identify the
types or categories of customer acquisition costs KMC incurred in Idaho in 2001 and 2002 to
attract new customers, set up their accounts, and establish service to them. In addition, to the
extent not provided in response to Request Nos. 7 and 8, please provide the per line costs KMC
ATTACHMENT A TO SUBPOENA DUCES TECUM (KMC DATA)
Boise-I64646.1 0029164-00097
Page 3
incurred in 2001 and 2002 for both business and residential customers for each of the types or
categories of customer acquisition costs.
10. Please identify the monthly churn rate KMC has experienced for local exchange
customers in each month in which it has provided local exchange service in the Idaho market.
answering this request, you should calculate the churn rate based upon the number oflines lost
each year divided by the average number of lines in service that year. In calculating churn, do
not include customers who move but stay with the company. Please produce all documents that
refer or relate to the information you provide in response to this request.
11. In connection with KMC's churn rates in Idaho for the most recent 24 months that are
available for local exchange customers, of the total customers that have left KMC, please
identify the percentage that have left within one month of signing up for service, within two
months of signing up for service, within three months of signing up for service, and within six
months of signing up for service. Please produce all documents that refer or relate to the
information you provide in response to this request.
12. Please identify each rate plan that KMC offers to local exchange customers in Idaho.
In addition, please identify the percentage ofKMC's total local exchange customers in Idaho that
subscribe to each plan that you identify. Please produce all documents that reflect, refer or relate
to the information you provide in response to this request.
13. For rate plans identified in Response No. 12 that include a per minute of use
component, please provide the average long-distance per minute usage in Idaho ofKMC's local
exchange customers who subscribe to such plans for the most recent 24 months available. Please
produce all documents that reflect, refer, or relate to the information you provide in response to
this request.
ATTACHMENT A TO SUBPOENA DUCES TECUM (KMC DATA)
Boise-164646.1 0029164-00097
Page 4
ATTACHMENT B
to Subpoena Duces Tecum (KMC Data)
Please produce all documents that reflect, refer or relate to the average total revenue
per line that KMC received from its residential customers within Idaho in 2001 and 2002. For
purposes of this document request, the average revenue per line should include revenues
associated with the basic retail price charged to residential customers, vertical features, universal
service payments , interstate access charges, intrastate access charges, subscriber line charges
toll, long distance, local number portability, and line revenues derived from any other sources.
Please produce all documents that provide the total average revenue per line and a breakdown of
the amount of revenue for each category of revenue that comprises the total.
Please produce all documents that reflect, refer or relate to the average total revenue
per line that KMC has received from its business customers within Idaho in 2001 and 2002. For
purposes of this document request, the average revenue per line should include revenues
associated with the basic retail price charged to business customers, vertical features, universal
service payments, interstate access charges, intrastate access charges, subscriber line charges
toll, long distance, local number portability, and line revenues derived from any other sources.
Please provide all documents that provide the total average revenue per line and a breakdown of
the amount of revenue for each category of revenue that comprises the total. If revenues differ
depending on the type of business customer (small vs. large), please provide all documents that
provide the total revenues and the breakdown of revenues by type of business customer and by
POTS , DSO, DSl , DS3 , OC-, OC-, OC-, and any other relevant categories.
Please produce all documents that reflect, refer or relate to how KMC defines its
business customer segments and provide any documents that reflect this definition or the
criteria KMC uses to segment or classify business customers into distinct customer groups.
ATTACHMENT B TO SUBPOENA DUCES TECUM (KMC DATA)
Boise-164646.1 0029164-00097
Page 1
Please produce all documents that reflect, refer or relate to the average total cost per
line that KMC incurred in 2001 and 2002 for lines used to serve residential customers within
Idaho. For purposes of this document request, costs should include costs associated with
switching; loops; collocation; transport; hot cuts; operational support systems ("OSS"
signaling; customer acquisitions; backhauling traffic to KMC's switches; maintenance
operations, and other administrative activities; and capital costs. If available, please provide
documents showing a breakdown of this information for the following categories: (1) service
provided by UNE-, (2) service provided by UNE-, and (3) service provided using KMC's own
facilities. In addition, please provide all documents containing any available breakdowns of each
cost component that is part of the average total cost per line.
Please produce all documents that reflect, refer or relate to the average total cost per
line that KMC incurred in 2001 and 2002 for lines used to serve business customers within
Idaho. For purposes of this document request, costs should include costs associated with
switching; loops; collocation; transport; hot cuts; OSS; signaling; customer acquisitions;
backhauling traffic to KMC's switches; maintenance, operations, and other administrative
activities; and capital costs. Please provide all documents that reflect, refer to relate to separate
averages for service provided through UNE-, UNE-, and with KMC's own facilities. If
available, please provide all documents showing a breakdown of each cost component that is part
of the average total cost per line, identifying the type and amount of each cost. If costs differ
depending on the type of business customer (small vs. large), please provide documents showing
the total cost and the breakdown of costs by type of business customer.
Please produce all documents that reflect, refer or relate to the monthly churn rate
KMC has experienced for local exchange customers in each month in which it has provided local
exchange service in the Idaho market.
A IT ACHMENT B TO SUBPOENA DUCES TECUM (KMC DATA)
Boise-164646.1 0029164-00097
Page 2
Please produce all documents that reflect, refer or relate to the percentage of local
exchange customers within the most recent 24 months that have left KMC within one month of
signing up for service, within two months of signing up for service, within tln-ee months of
signing up for service, and within six months of signing up for service.
Please produce all documents that reflect, refer or relate to each rate plan that KMC
offers to local exchange customers in Idaho. In addition, please provide all documents used to
identify the percentage ofKMC's total local exchange customers in Idaho that subscribe to each
plan.
Please produce all documents for the most recent 24 months available that reflect
refer or relate to rate plans the average long-distance per minute usage in Idaho ofKMC's local
exchange customers who subscribe to plans that include a per minute of use component.
ATTACHMENT B TO SUBPOENA DUCES TECUM (KMC DATA)
Boise-164646.1 0029164-00097
Page 3
TT A CHMENT 3
Mary S. Hobson (ISB #2142)
Stoel Rives LLP
101 South Capitol Boulevard - Suite 1900
Boise, ill 83702
Telephone: [phone]
Facsimile: [phone]
mshobson~stoel.com
Adam L. Sherr (WSBA #25291)
Qwest
1600 ih Avenue - Room 3206
Seattle, W A 98191
Telephone: [phone]
Facsimile: [phone]
adam.sherr~qwest.com
Attorneys for Qwest Corporation
BEFORE THE IDAHO PUBLIC UTILITIES COMMISSION
IN THE MATTER OF IPUC RESPONSE TO
FCC ORDER ON REVIEW OF SECTION 251
UNBUNDLING OBLIGATIONS OF
INCUMBENT LOCAL EXCHANGE
CARRIERS (CC DOCKET NO. 01-338)
Case No. GNR-O3-
SUBPOENA DUCES TECUM TO 30(b)(6)
REPRESENTATIVE OF SPRINT
COMMUNICATIONS
NINE-MONTH REVIEW OF ECONOMIC
AND OPERATIONAL IMPAIRMENT
REGARDING ACCESS TO SPECIFIC UNES
To:Sprint International Communications Corporation ("Sprint")
Prentice-Hall Corp. System, 1401 Shoreline Drive, Suite 2, Boise, ill 83702
YOU ARE COMMANDED to designate and produce one or more officers, directors
employees, or other persons to appear and testify at the taking of a deposition at the office of
Stoel Rives LLP, 101 South Capitol Boulevard, Suite 1900, Boise, Idaho on December 18, 2003
at 9:00 a.m. in the above entitled matter pending before the Idaho Public Utilities Commission.
SUBPOENA DUCES TECUM TO 30(b)(6) REPRESENTATIVE OF SPRINT COMMUNICA TIONS- Page 1
Boise-164647.10029164-00097
The deposition shall be taken before a licensed court reporter and will be conducted in
accordance with the IPUC Rules of Procedure IDAPA 31.01.01.000 et. seq.and the Idaho Rules
of Civil Procedure.
This deposition is being taken pursuant to IRCP 30(b)(6). Sprint shall designate the
person or persons with sufficient knowledge to testify to all matters known or reasonably
available to PMT concerning the specific questions set forth in the document attached as
Attachment A and entitled "Discovery Requests." You are further commanded to produce all
documents listed on Attachment B to this subpoena. If the person or persons designated by
Sprint cannot fully respond orally at the deposition, in addition to those documents listed on
Attachment B, you are further commanded to produce at the deposition the underlying
documentation and other data in your possession that will allow Qwest to compile the
information requested in Attachment A.
ALTERNATIVE PROCEDURE: In the alternative to producing a witness for the
deposition described above, you may comply with the subpoena by providing Qwest Corporation
a verified response to the discovery requests set forth in Attachment A and providing copies of
the documents listed on Attachment B. In the event you respond to this subpoena by providing
verified responses to the discovery requests, the responses shall be provided on or before
December 15 2003 to counsel for Qwest as follows:
Mary S. Hobson (ISB #2142)
Stoel Rives LLP
101 South Capitol Boulevard - Suite 1900
Boise, ill 83702
Telephone: [phone]
Facsimile: [phone]
mshobson~stoel.com
Adam L. Sherr (WSBA #25291)
Qwest
1600 ih Avenue - Room 3206
Seattle, WA 98191
Telephone: [phone]
Facsimile: [phone]
adam.she1T~qwest.com
This subpoena is issued pursuant to Idaho Code 99 61-602; 61-605; 62-615 and IPUC
Rules of Procedure, 222 224 and 226 IDAPA 31.01.01.222; 224; 226. Please note that Qwest
SUBPOENA DUCES TECUM TO 30(b)(6) REPRESENTATIVE OF SPRINT COMMUNICATIONS- Page 2
Boise-164647.10029164-00097
has filed a motion with the Idaho Public Utilities Commission requesting that the Commission
enter a Protective Order in this matter governing the disclosure of proprietary and/or confidential
material or information. Thus, to the extent any of the responses, documents or underlying data
are claimed by you to be confidential, they can be provided to Qwest as confidential infoDnation
pursuant to the Protective Order, upon issuance.
DATED this 20th day of November, 2003.
IDAHO PUBLIC UTILITIES COMMISSION
By:
Its:
Jean D. Jewell
Secretary
SUBPOENA DUCES TECUM TO 30(b)(6) REPRESENTATIVE OF SPRINT COMMUNICATIONS- Page 3
Boise-164647.J 0029164-00097
ATTACHMENT A
to Subpoena Duces Tecum (Sprint)
DISCOVERY REQUESTS
Please identify all switches owned or controlled by Sprint that are being used in Idaho
to provide service to customers served by facilities at or above the DS-llevel. For each switch
that you identify, please identify the type (e., 5ESS and 4ESS) and describe the "footprint" of
the switch, meaning the geographic area that the switch is capable of reaching. Separately,
please provide the same information for customers served by DS-O loop facilities.
For each switch that you identify in response to Request No.please provide the
capacity of the switch, with "capacity" defined as: (1) the number oflines installed; (2) the
number oflines currently in use; (3) the number of trunks installed; and (4) the number of trunks
currently in use. In addition, for each switch that you identify, please provide the generic
(feature package) loaded in the switch.
Please state whether the information in the LERG is current and accurate for the
switches that Sprint owns, operates, controls, maintains in Idaho, or from which you lease dial
tone or trunking functionality/capacity. If any of the information is not accurate, please identify
the inaccurate information and provide corrected information, including any additions, deletions
or changes. As part of your review of the information in the LERG, please state whether the
CLLI code is accurate for each switch that Sprint owns, operates, controls, maintains, or from
which you lease dial tone or trunking functionality/capacity. In addition, please state whether the
LERG definition of the function of each switch (i., tandem, end office, etc.) is accurate.
Please provide the average total revenue per line that Sprint received from its
residential customers within Idaho in 2001 and 2002. The average revenue per line should
include revenues associated with the basic retail price charged to residential customers, vertical
ATTACHMENT A TO SUBPOENA DUCES TECUM (SPRINT COMMUNICATIONS)
Boise-164647.10029164-00097
Page 1
features, universal service payments, interstate access charges, intrastate access charges
subscriber line charges, toll, long distance, local number portability, and line revenues derived
from any other sources. Please provide both the total average revenue per line and a breakdown
of the amount of revenue for each category of revenue that comprises the total. Please produce
all documents that reflect, refer or relate to the information provided in your response to this
request.
Please provide the average total revenue per line that Sprint has received from its
business customers within Idaho in 2001 and 2002. The average revenue per line should
include revenues associated with the basic retail price charged to business customers, vertical
features, universal service payments, interstate access charges, intrastate access charges
subscriber line charges, toll, long distance, local number portability, and line revenues derived
from any other sources. Please provide both the total average revenue per line and a breakdown
of the amount of revenue for each category of revenue that comprises the total. If revenues differ
depending on the type of business customer (small vs. large), please provide the total revenues
and the breakdown of revenues by type of business customer. Please provide the information by
POTS , DSO, DSl , DS3 , OC-, OC-, OC-, and any other relevant categories. Please produce
all documents that reflect, refer or relate to the information provided in your response to this
request.
Please explain how Sprint defines its business customer segments and provide any
documents that reflect this definition or the criteria Sprint uses to segment or classify business
customers into distinct customer groups. Please produce all documents that reflect, refer or
relate to the information provided in your response to this request.
Please provide the average total cost per line that Sprint incurred in 2001 and 2002
for lines used to serve residential customers within Idaho. These costs should include costs
ATTACHMENT A TO SUBPOENA DUCES TECUM (SPRINT COMMUNICATIONS)
Boise-I64647.) 0029164-00097
Page 2
associated with switching; loops; collocation; transport; hot cuts; operational support systems
OSS"); signaling; customer acquisitions; backhauling traffic to Sprint's switches; maintenance
operations, and other administrative activities; and capital costs. If available, please provide a
breakdown of this information for the following categories: (1) service provided by UNE-, (2)
service provided by UNE-, and (3) service provided using Sprint's own facilities. In addition
please provide any available breakdowns of each cost component that is part of the average total
cost per line, identifying the type and amount of each cost. Please produce all documents that
reflect, refer or relate to the information provided in your response to this request.
Please provide the average total cost per line that Sprint incurred in 2001 and 2002
for lines used to serve business customers within Idaho. These costs should include costs
associated with switching; loops; collocation; transport; hot cuts; OSS; signaling; customer
acquisitions; backhauling traffic to Sprint's switches; maintenance , operations, and other
administrative activities; and capital costs. In addition to a total average cost, please provide
separate averages for service provided through UNE-, UNE-, and with Sprint's own facilities.
Please provide a breakdown of each cost component that is part of the average total cost per line
identifying the type and amount of each cost. If costs differ depending on the type of business
customer (small vs. large), please provide the total cost and the breakdown of costs by type of
business customer. Please produce all documents that reflect, refer or relate to the information
provided in your response to this request.
To the extent not provided in response to Request Nos. 7 and 8, please identify the
types or categories of customer acquisition costs Sprint incurred in Idaho in 2001 and 2002 to
attract new customers, set up their accounts, and establish service to them. In addition, to the
extent not provided in response to Request Nos. 7 and 8, please provide the per line costs Sprint
ATTACHMENT A TO SUBPOENA DUCES TECUM (SPRINT COMMUNICATIONS)
Boise-164647.10029164-00097
Page 3
incurred in 2001 and 2002 for both business and residential customers for each of the types or
categories of customer acquisition costs.
10. Please identify the monthly churn rate Sprint has experienced for local exchange
customers in each month in which it has provided local exchange service in the Idaho market.
answering this request, you shou1d ca1culate the chum rate based upon the number ofJines lost
each year divided by the average number of lines in service that year. In calculating churn, do
not include customers who move but stay with the company. Please produce all documents that
refer or relate to the information you provide in response to this request.
11. In connection with Sprint's churn rates in Idaho for the most recent 24 months that
are available for local exchange customers, of the total customers that have left Sprint, please
identify the percentage that have left within one month of signing up for service, within two
months of signing up for service, within three months of signing up for service, and within six
months of signing up for service. Please produce all documents that refer or relate to the
information you provide in response to this request.
12. Please identify each rate plan that Sprint offers to local exchange customers in Idaho.
In addition, please identify the percentage of Sprint's total local exchange customers in Idaho
that subscribe to each plan that you identify. Please produce all documents that reflect, refer or
relate to the information you provide in response to this request.
13. For rate plans identified in Response No. 12 that include a per minute of use
component, please provide the average long-distance per minute usage in Idaho of Sprint's local
exchange customers who subscribe to such plans for the most recent 24 months available. Please
produce all documents that reflect, refer, or relate to the information you provide in response to
this request.
ATTACHMENT A TO SUBPOENA DUCES TECUM (SPRINT COMMUNICA TIaNS)
Boise-164647.10029164-00097
Page 4
ATTACHMENTB
to Subpoena Duces Tecum (Sprint)
Please produce all documents that reflect, refer or relate to the average total revenue
per line that Sprint received from its residential customers within Idaho in 2001 and 2002. For
purposes of this document request, the average revenue per line should inc1ude revenues
associated with the basic retail price charged to residential customers , vertical features, universal
service payments , interstate access charges , intrastate access charges, subscriber line charges
toll, long distance, local number portability, and line revenues derived from any other sources.
Please produce all documents that provide the total average revenue per line and a breakdown of
the amount of revenue for each category of revenue that comprises the total.
Please produce all documents that reflect, refer or relate to the average total revenue
per line that Sprint has received from its business customers within Idaho in 2001 and 2002.
For purposes of this document request, the average revenue per line should include revenues
associated with the basic retail price charged to business customers, vertical features, universal
service payments, interstate access charges, intrastate access charges, subscriber line charges
toll, long distance, local number portability, and line revenues derived from any other sources.
Please provide all documents that provide the total average revenue per line and a breakdown of
the amount of revenue for each category of revenue that comprises the total. If revenues differ
depending on the type of business customer (small vs. large), please provide all documents that
provide the total revenues and the breakdown of revenues by type of business customer and by
POTS, DSO, DSl , DS3, OC-, OC-, OC-, and any other relevant categories.
Please produce all documents that reflect, refer or relate to how Sprint defines its
business customer segments and provide any documents that reflect this definition or the
criteria Sprint uses to segment or classify business customers into distinct customer groups.
ATTACHMENT B TO SUBPOENA DUCES TECUM (SPRINT COMMUNICATIONS)
Boise-164647.\0029164-00097
Page 1
Please produce all documents that reflect, refer or relate to the average total cost per
line that Sprint incurred in 2001 and 2002 for lines used to serve residential customers within
Idaho. For purposes of this document request, costs should include costs associated with
switching; loops; collocation; transport; hot cuts; operational suppOli systems ("OSS"
signaling; customer acquisitions; backhauling traffic to Sprint's switches; maintenance
operations, and other administrative activities; and capital costs. If available, please provide
documents showing a breakdown of this information for the following categories: (1) service
provided by UNE-, (2) service provided by UNE-, and (3) service provided using Sprint's
own facilities. In addition, please provide all documents containing any available breakdowns of
each cost component that is part of the average total cost per line.
Please produce all documents that reflect, refer or relate to the average total cost per
line that Sprint incurred in 2001 and 2002 for lines used to serve business customers within
Idaho. For purposes ofthis document request, costs should include costs associated with
switching; loops; collocation; transport; hot cuts; OSS; signaling; customer acquisitions;
backhauling traffic to Sprint's switches; maintenance , operations, and other administrative
activities; and capital costs. Please provide all documents that reflect, refer to relate to separate
averages for service provided through UNE-, UNE-, and with Sprint's own facilities. If
available, please provide all documents showing a breakdown of each cost component that is part
of the average total cost per line, identifying the type and amount of each cost. If costs differ
depending on the type of business customer (small vs. large), please provide documents showing
the total cost and the breakdown of costs by type of business customer.
Please produce all documents that reflect, refer or relate to the monthly churn rate
Sprint has experienced for local exchange customers in each month in which it has provided
local exchange service in the Idaho market.
ATTACHMENT B TO SUBPOENA DUCES TECUM (SPRINT COMMUNICA TlONS)
Boise-I64647.10029164-00097
Page 2
Please produce all documents that reflect, refer or relate to the percentage of local
exchange customers within the most recent 24 months that have left Sprint within one month of
signing up for service, within two months of signing up for service, within three months of
signing up for service, and within six months of signing up for service.
Please produce all documents that reflect, refer or relate to each rate plan that Sprint
offers to local exchange customers in Idaho. In addition, please provide all documents used to
identify the percentage of Sprint's total local exchange customers in Idaho that subscribe to each
plan.
Please produce all documents for the most recent 24 months available that reflect
refer or relate to rate plans the average long-distance per minute usage in Idaho of Sprint's local
exchange customers who subscribe to plans that include a per minute of use component.
ATTACHMENT B TO SUBPOENA DUCES TECUM (SPRINT COMMUNICATIONS)
Boise-l 64647.1 0029164-00097
Page 3
TT CHMENT 4
Mary S. Hobson (ISB #2142)
Stoel Rives LLP
101 South Capitol Boulevard - Suite 1900
Boise, ill 83702
Telephone: [phone]
Facsimile: [phone]
mshobson~stoel.com
Adam L. Sherr (WSBA #25291)
Qwest
1600 ih Avenue - Room 3206
Seattle, W A 98191
Telephone: [phone]
Facsimile: [phone]
adam.sherr~qwest.com
Attorneys for Qwest Corporation
BEFORE THE IDAHO PUBLIC UTILITIES COMMISSION
IN THE MATTER OF IPUC RESPONSE TO
FCC ORDER ON REVIEW OF SECTION 251
UNBUNDLING OBLIGATIONS OF
INCUMBENT LOCAL EXCHANGE
CARRIERS (CC DOCKET NO. 01-338)
Case No. GNR-03-
SUBPOENA DUCES TECUM TO 30(b)(6)
REPRESENTATIVE OF CTC TELECOM
NINE-MONTH REVIEW OF ECONOMIC
AND OPERATIONAL IMPAIRMENT
REGARDING ACCESS TO SPECIFIC UNES
To:CTC Telecom, me. ("CTC"
Richard Wiggins, 130 Superior Street, Cambridge, ill 83610
YOU ARE COMMANDED to designate and produce one or more officers, directors
employees, or other persons to appear and testify at the taking of a deposition at the office of
Stoel Rives LLP, 101 South Capitol Boulevard, Suite 1900, Boise, Idaho on December 18 , 2003
at 9:00 a.m. in the above entitled matter pending before the Idaho Public Utilities Commission.
SUBPOENA DUCES TECUM TO 30(b)(6) REPRESENTATIVE OF CTC TELECOM - Page 1
Boise-l 64649. 1 0029164-00097
The deposition shall be taken before a licensed court reporter and will be conducted in
accordance with the IPUC Rules of Procedure IDAPA 31.01.01.000 et. seq.and the Idaho Rules
of Civil Procedure.
This deposition is being taken pursuant to IRCP 30(b )(6). CTC shall designate the
person or persons with sufficient knowledge to testify to all matters known or reasonably
available to CTC concerning the specific questions set forth in the document attached as
Attachment A and entitled "Discovery Requests." You are further commanded to produce all
documents listed on Attachment B to this subpoena. If the person or persons designated by CTC
cannot fully respond orally at the deposition, in addition to those documents listed on
Attachment B , you are further commanded to produce at the deposition the underlying
documentation and other data in your possession that will allow Qwest to compile the
information requested in Attachment A.
ALTERNATIVE PROCEDURE: In the alternative to producing a witness for the
deposition described above, you may comply with the subpoena by providing Qwest Corporation
a verified response to the discovery requests set forth in Attachment A and providing copies of
the documents listed on Attachment B. In the event you respond to this subpoena by providing
verified responses to the discovery requests, the responses shall be provided on or before
December 15 2003 to counsel for Qwest as follows:
Mary S. Hobson (ISB #2142)
Stoel Rives LLP
101 South Capitol Boulevard- Suite 1900
Boise, ill 83702
Telephone: [phone]
Facsimile: [phone]
rnshobson~stoel.com
Adam L. Sherr (WSBA #25291)
Qwest
1600 7th Avenue - Room 3206
Seattle, W A 98191
Telephone: [phone]
Facsimile: [phone]
adam.sherr0-J,qwest.com
This subpoena is issued pursuant to Idaho Code 99 61-602; 61-605; 62-615 and IPUC
Rules of Procedure, 222 , 224 and 226 IDAPA 31.01.01.222; 224; 226. Please note that Qwest
SUBPOENA DUCES TECUM TO 30(b)(6) REPRESENTATIVE OF CTC TELECOM - Page 2
Boise-164649.1 0029164-00097
has filed a motion with the Idaho Public Utilities Commission requesting that the Commission
enter a Protective Order in this matter governing the disclosure of proprietary and/or confidential
material or information. Thus, to the extent any of the responses, documents or underlying data
are claimed by you to be confidential, they can be provided to Qwest as confidential infonnation
pursuant to the Protective Order, upon issuance.
DATED this 20th day of November, 2003.
IDAHO PUBLIC UTILITIES COMMISSION
By:
Its:
Jean D. Jewell
Secretary
SUBPOENA DUCES TECUM TO 30(b)(6) REPRESENTATIVE OF CTC TELECOM - Page 3
Boise-164649.10029164-00097
ATTACHMENT A
to Subpoena Duces Tecum (CTC Telecom)
DISCOVERY REQUESTS
Please state whether the information in the LERG is current and accurate for the
switches that CTC owns, operates, controls , maintains in Idaho, or from which you lease dial
tone or trunking functionality/capacity. If any of the information is not accurate, please identify
the inaccurate information and provide corrected information, including any additions, deletions
or changes. As part of your review of the information in the LERG, please state whether the
CLLI code is accurate for each switch that CTC owns, operates, controls, maintains, or from
which you lease dial tone or trunking functionality/capacity. In addition, please state whether the
LERG definition of the function of each switch (i., tandem, end office, etc.) is accurate.
For each switch owned or controlled by CTC that is being used in Idaho to
provide service to customers, please provide the capacity of the switch, with "capacity" defined
as: (1) the number oflines installed; (2) the number oflines currently in use; (3) the number of
trunks currently installed; and (4) the number of trunks currently in use. In addition, for each
such switch that you identify, please provide the generic (feature package) loaded in the switch.
Please provide the average total revenue per line that CTC received from its
residential customers within Idaho in 2001 and 2002. The average revenue per line should
include revenues associated with the basic retail price charged to residential customers, vertical
features, universal service payments, interstate access charges, intrastate access charges
subscriber line charges, toll, long distance, local number portability, and line revenues derived
from any other sources. Please provide both the total average revenue per line and a breakdown
of the amount of revenue for each category of revenue that comprises the total. Please produce
ATTACHMENT A TO SUBPOENA DUCES TECUM (CTC TELECOM)
Boise-l 64649. 1 0029164-00097
Page 1
all documents that reflect, refer or relate to the information provided in your response to this
request.
Please provide the average total revenue per line that CTC has received from its
business customers within Idaho in 2001 and 2002. The average revenue per line should
include revenues associated with the basic retail price charged to business customers, vertical
features, universal service payments, interstate access charges, intrastate access charges
subscriber line charges, toll, long distance, local number portability, and line revenues derived
from any other sources. Please provide both the total average revenue per line and a breakdown
of the amount of revenue for each category of revenue that comprises the total. If revenues differ
depending on the type of business customer (small vs. large), please provide the total revenues
and the breakdown of revenues by type of business customer. Please provide the information by
POTS , DSO, DSl , DS3, OC-, OC-, OC-, and any other relevant categories. Please produce
all documents that reflect, refer or relate to the information provided in your response to this,
request.
Please explain how CTC defines its business customer segments and provide any
documents that reflect this definition or the criteria CTC uses to segment or classify business
customers into distinct customer groups. Please produce all documents that reflect, refer or
relate to the information provided in your response to this request.
Please provide the average total cost per line that CTC incurred in 2001 and 2002
for lines used to serve residential customers within Idaho. These costs should include costs
associated with switching; loops; collocation; transport; hot cuts; operational support systems
OSS"); signaling; customer acquisitions; backhauling traffic to CTC's switches; maintenance
operations, and other administrative activities; and capital costs. If available, please provide a
IT ACHMENT A TO SUBPOENA DUCES TECUM (CTC TELECOM)
Boise-164649.10029164-00097
Page 2
breakdown of this information for the following categories: (1) service provided by UNE-, (2)
service provided by UNE-, and (3) service provided using CTC's own facilities. In addition
please provide any available breakdowns of each cost component that is part of the average total
cost per line, identifying the type and amount of each cost. Please produce all documents that
reflect, refer or relate to the information provided in your response to this request.
Please provide the average total cost per line that CTC incurred in 2001 and 2002
for lines used to serve business customers within Idaho. These costs should include costs
associated with switching; loops; collocation; transport; hot cuts; OSS; signaling; customer
acquisitions; backhauling traffic to CTC's switches; maintenance, operations, and other
administrative activities; and capital costs. In addition to a total average cost, please provide
separate averages for service provided through UNE-, UNE-, and with CTC's own facilities.
Please provide a breakdown of each cost component that is part of the average total cost per line
identifying the type and amount of each cost. If costs differ depending on the type of business
customer (small vs. large), please provide the total cost and the breakdown of costs by type of
business customer. Please produce all documents that reflect, refer or relate to the information
provided in your response to this request.
To the extent not provided in response to Request Nos. 6 and 7, please identify
the types or categories of customer acquisition costs CTC incurred in Idaho in 2001 and 2002 to
attract new customers, set up their accounts, and establish service to them. In addition, to the
extent not provided in response to Request Nos. 5 and 6, please provide the per line costs CTC
incurred in 2001 and 2002 for both business and residential customers for each of the types or
categories of customer acquisition costs.
ATTACHMENT A TO SUBPOENA DUCES TECUM (CTC TELECOM)
Boise-164649-10029164-00097
Page 3
ATTACHMENT B
to Subpoena Duces Tecum (CTC Telecom)
Please produce all documents that reflect, refer or relate to the average total
revenue per line that CTC received from its residential customers within Idaho in 2001 and
2002. For purposes of this document request, the average revenue per line should include
revenues associated with the basic retail price charged to residential customers, vertical features
universal service payments, interstate access charges, intrastate access charges, subscriber line
charges, toll, long distance, local number portability, and line revenues derived from any other
sources. Please produce all documents that provide the total average revenue per line and a
breakdown of the amount of revenue for each category of revenue that comprises the total.
Please produce all documents that reflect, refer or relate to the average total
revenue per line that CTC has received from its business customers within Idaho in 2001 and
2002. For purposes of this document request, the average revenue per line should include
revenues associated with the basic retail price charged to business customers, vertical features
universal service payments, interstate access charges, intrastate access charges, subscriber line
charges, toll, long distance, local number portability, and line revenues derived from any other
sources. Please provide all documents that provide the total average revenue per line and a
breakdown of the amount of revenue for each category of revenue that comprises the total.
revenues differ depending on the type of business customer (small vs. large), please provide all
documents that provide the total revenues and the breakdown of revenues by type of business
customer and by POTS , DSO, DSl , DS3 , OC-, OC-, OC-, and any other relevant
categories.
IT ACHMENT B TO SUBPOENA DUCES TECUM (CTC TELECOM)
Boise-164649.10029164-00097
Page 1
Please produce all documents that reflect, refer or relate to how CTC defines its
business customer segments and provide any documents that reflect this definition or the
criteria CTC uses to segment or classify business customers into distinct customer groups.
Please produce all documents that reflect, refer or relate to the average total cost
per line that CTC incurred in 2001 and 2002 for lines used to serve residential customers within
Idaho. For purposes of this document request, costs should include costs associated with
switching; loops; collocation; transport; hot cuts; operational support systems ("OSS"
signaling; customer acquisitions; backhauling traffic to CTC's switches; maintenance
operations, and other administrative activities; and capital costs. If available, please provide
documents showing a breakdown of this information for the following categories: (1) service
provided by UNE-, (2) service provided by UNE-, and (3) service provided using CTC's own
facilities. In addition, please provide all documents containing any available breakdowns of each
cost component that is part of the average total cost per line.
Please produce all documents that reflect, refer or relate to the average total cost
per line that CTC incurred in 2001 and 2002 for lines used to serve business customers within
Idaho. For purposes of this document request, costs should include costs associated with
switching; loops; collocation; transport; hot cuts; OSS; signaling; customer acquisitions;
backhauling traffic to CTC switches; maintenance, operations, and other administrative
activities; and capital costs. Please provide all documents that reflect, refer to relate to separate
averages for service provided through UNE-, UNE-, and with CTC own facilities. If
available, please provide all documents showing a breakdown of each cost component that is part
of the average total cost per line, identifying the type and amount of each cost. If costs differ
ATTACHMENT B TO SUBPOENA DUCES TECUM (CTC TELECOM)
Boise-I64649.10029164-00097
Page 2
depending on the type of business customer (small vs. large), please provide documents showing
the total cost and the breakdown of costs by type of business customer.
A TT ACHMENT B TO SUBPOENA DUCES TECUM (CTC TELECOM)
Boise-l 64649. I 0029164-00097
Page 3
ATTACHMENT 5
Mary S. Hobson (ISB #2142)
Stoel Rives LLP
101 South Capitol Boulevard - Suite 1900
Boise, ID 83702
Telephone: [phone]
Facsimile: [phone]
mshobson~stoel.com
Adam L. Sherr (WSBA #25291)
Qwest
1600 ih Avenue - Room 3206
Seattle, WA 98191
Telephone: [phone]
Facsimile: [phone]
adam.sherr~qwest.com
Attorneys for Qwest Corporation
BEFORE THE IDAHO PUBLIC UTILITIES COMMISSION
IN THE MATTER OF IPUC RESPONSE TO
FCC ORDER ON REVIEW OF SECTION 251
UNBUNDLING OBLIGATIONS OF
INCUMBENT LOCAL EXCHANGE
CARRIERS (CC DOCKET NO. 01-338)
Case No. GNR-03-
SUBPOENA DUCES TECUM TO 30(b)(6)
REPRESENTATIVE OF ELECTRIC
LIGHTWAVE
NINE-MONTH REVIEW OF ECONOMIC
AND OPERATIONAL IMPAIRMENT
REGARDING ACCESS TO SPECIFIC UNES
To:Electric Lightwave, LLC ("ELI"
CT Corporation system, 300 North 6th Street, Boise, ID 83702
YOU ARE COMMANDED to designate and produce one or more officers, directors
employees, or other persons to appear and testify at the taking of a deposition at the office of
Stoel Rives LLP , 101 South Capitol Boulevard, Suite 1900, Boise, Idaho on December 18 2003
at 9:00 a.m. in the above entitled matter pending before the Idaho Public Utilities Commission.
SUBPOENA DUCES TECUM TO 30(b)(6) REPRESENTATIVE OF ELECTRIC LIGHTWAVE - Page 1
Boise-164650.10029164-00097
The deposition shall be taken before a licensed court reporter and will be conducted in
accordance with the IPUC Rules of Procedure IDAPA 31.01.01.000 et. seq.and the Idaho Rules
of Civil Procedure.
This deposition is being taken pursuant to IRCP 30(b)( 6). ELI shall designate the person
or persons with sufficient knowledge to testify to all matters known or reasonably available to
ELI concerning the specific questions set forth in the document attached as Attachment A and
entitled "Discovery Requests." You are further commanded to produce all documents listed on
Attachment B to this subpoena. If the person or persons designated by ELI cannot fully respond
orally at the deposition, in addition to those documents listed on Attachment B, you are further
commanded to produce at the deposition the underlying documentation and other data in your
possession that will allow Qwest to compile the information requested in Attachment A.
ALTERNATIVE PROCEDURE: In the alternative to producing a witness for the
deposition described above, you may comply with the subpoena by providing Qwest Corporation
a verified response to the discovery requests set forth in Attachment A and providing copies of
the documents listed on Attachment B. In the event you respond to this subpoena by providing
verified responses to the discovery requests, the responses shall be provided on or before
December 15, 2003 to counsel for Qwest as follows:
Mary S. Hobson (ISB #2142)
Stoel Rives LLP
101 South Capitol Boulevard - Suite 1900
Boise, ill 83702
Telephone: [phone]
Facsimile: [phone]
mshobson~stoel.com
Adam L. Sherr (WSBA #25291)
Qwest
1600 7th Avenue - Room 3206
Seattle, WA 98191
Telephone: [phone]
Facsimile: [phone]
adam. sherr(fU,qwest. com
This subpoena is issued pursuant to Idaho Code 99 61-602; 61-605; 62-615 and IPUC
Rules of Procedure, 222, 224 and 226 IDAPA 31.01.01.222; 224; 226. Please note that Qwest
has filed a motion with the Idaho Public Utilities Commission requesting that the Commission
SUBPOENA DUCES TECUM TO 30(b)(6) REPRESENTATIVE OF ELECTRIC LIGHTWAVE- Page 2
Boise-I64650.10029164-00097
enter a Protective Order in this matter governing the disclosure of proprietary and/or confidential
material or information. Thus, to the extent any of the responses, documents or underlying data
are claimed by you to be confidential, they can be provided to Qwest as confidential information
pursuant to the Protective Order, upon issuance.
DATED this 20th day of November, 2003.
IDAHO PUBLIC UTILITIES COMMISSION
By:
Its:
Jean D. Jewell
Secretary
SUBPOENA DUCES TECUM TO 30(b)(6) REPRESENTATIVE OF ELECTRIC LIGHTWAVE - Page 3
Boise-164650.10029164-00097
ATTACHMENT A
to Subpoena Duces Tecum (Electric Lightwave)
DISCOVERY REQUESTS
Please state whether the infonnation in the LERG is current and accurate for the
switches that ELI owns, operates, controls, maintains in Idaho, or from which you lease dial tone
or trunking functionality/capacity. If any of the information is not accurate, please identify the
inaccurate information and provide corrected information, including any additions, deletions or
changes. As part of your review of the information in the LERG, please state whether the CLLI
code is accurate for each switch that ELI owns, operates, controls, maintains, or from which you
lease dial tone or trunking functionality/capacity. In addition, please state whether the LERG
definition of the function of each switch (i., tandem, end office, etc.) is accurate.
For each switch owned or controlled by ELI that is being used in Idaho to provide
service to customers, please provide the capacity of the switch, with "capacity" defined as: (1)
the number of lines installed; (2) the number of lines currently in use; (3) the number of trunks
currently installed; and (4) the number of trunks currently in use. In addition, for each such
switch that you identify, please provide the generic (feature package) loaded in the switch.
Please provide the average total revenue per line that ELI received from its
residential customers within Idaho in 2001 and 2002. The average revenue per line should
include revenues associated with the basic retail price charged to residential customers, vertical
features, universal service payments, interstate access charges, intrastate access charges
subscriber line charges, toll, long distance, local number portability, and line revenues derived
from any other sources. Please provide both the total average revenue per line and a breakdown
of the amount of revenue for each category of revenue that comprises the total. Please produce
ATTACHMENT A TO SUBPOENA DUCES TECUM (ELECTRIC LIGHTWAVE)
Boise-164650.1 0029164-00097
Page 1
all documents that reflect, refer or relate to the information provided in your response to this
request.
Please provide the average total revenue per line that ELI has received from its
business customers within Idaho in 2001 and 2002. The average revenue per line should
include revenues associated with the basic retail price charged to business customers, vertical
features, universal service payments, interstate access charges, intrastate access charges
subscriber line charges, toll, long distance, local number portability, and line revenues derived
from any other sources. Please provide both the total average revenue per line and a breakdown
of the amount of revenue for each category of revenue that comprises the total. If revenues differ
depending on the type of business customer (small vs. large), please provide the total revenues
and the breakdown of revenues by type of business customer. Please provide the information by
POTS, DSO, DSl , DS3 , OC-, OC-, OC-, and any other relevant categories. Please produce
all documents that reflect, refer or relate to the information provided in your response to this
request.
Please explain how ELI defines its business customer segments and provide any
documents that reflect this definition or the criteria ELI uses to segment or classify business
customers into distinct customer groups. Please produce all documents that reflect, refer or
relate to the information provided in your response to this request.
Please provide the average total cost per line that ELI incurred in 2001 and 2002
for lines used to serve residential customers within Idaho. These costs should include costs
associated with switching; loops; collocation; transport; hot cuts; operational support systems
OSS"); signaling; customer acquisitions; backhauling traffic to ELI's switches; maintenance
operations, and other administrative activities; and capital costs. If available, please provide a
ATTACHMENT A TO SUBPOENA DUCES TECUM (ELECTRIC LIGHTWAVE)
Boise-l 64650.1 0029164-00097
Page 2
breakdown of this information for the following categories: (1) service provided by UNE-, (2)
service provided by UNE-, and (3) service provided using ELI's own facilities. In addition
please provide any available breakdowns of each cost component that is part of the average total
cost per line, identifying the type and amount of each cost. Please produce all documents that
reflect, refer or relate to the information provided in your response to this request.
Please provide the average total cost per line that ELI incurred in 2001 and 2002
for lines used to serve business customers within Idaho. These costs should include costs
associated with switching; loops; collocation; transport; hot cuts; OSS; signaling; customer
acquisitions; backhauling traffic to ELI's switches; maintenance , operations, and other
administrative activities; and capital costs. In addition to a total average cost, please provide
separate averages for service provided through UNE-, UNE- L, and with ELI's own facilities.
Please provide a breakdown of each cost component that is part of the average total cost per line
identifying the type and amount of each cost. If costs differ depending on the type of business
customer (small vs. large), please provide the total cost and the breakdown of costs by type of
business customer. Please produce all documents that reflect, refer or relate to the information
provided in your response to this request.
To the extent not provided in response to Request Nos. 6 and 7, please identify
the types or categories of customer acquisition costs ELI incurred in Idaho in 2001 and 2002 to
attract new customers, set up their accounts, and establish service to them. In addition, to the
extent not provided in response to Request Nos. 5 and 6, please provide the per line costs ELI
incurred in 2001 and 2002 for both business and residential customers for each of the types or
categories of customer acquisition costs.
A IT ACHMENT A TO SUBPOENA DUCES TECUM (ELECTRIC LIGHTW AVE)
Boise-I64650.\ 0029164-00097
Page 3
ATTACHMENT B
to Subpoena Duces Tecum (Electric Lightwave)
Please produce all documents that reflect, refer or relate to the average total
revenue per line that ELI received from its residential customers within Idaho in 2001 and
2002. FQf purposes of this document request, the average revenue per line should include
revenues associated with the basic retail price charged to residential customers, vertical features
universal service payments, interstate access charges, intrastate access charges, subscriber line
charges, toll, long distance, local number portability, and line revenues derived from any other
sources. Please produce all documents that provide the total average revenue per line and a
breakdown ofthe amount of revenue for each category of revenue that comprises the total.
Please produce all documents that reflect, refer or relate to the average total
revenue per line that ELI has received from its business customers within Idaho in 2001 and
2002. For purposes of this document request, the average revenue per line should include
revenues associated with the basic retail price charged to business customers, vertical features
universal service payments, interstate access charges, intrastate access charges, subscriber line
charges, toll, long distance, local number portability, and line revenues derived from any other
sources. Please provide all documents that provide the total average revenue per line and a
breakdown of the amount of revenue for each category of revenue that comprises the total.
revenues differ depending on the type of business customer (small vs. large), please provide all
documents that provide the total revenues and the breakdown of revenues by type of business
customer and by POTS, DSO, DSl , DS3 , OC-, OC-, OC-, and any other relevant
categories.
ATTACHMENT B TO SUBPOENA DUCES TECUM (ELECTRIC LIGHTWAVE)
Boise-164650.1 0029164-00097
Page 1
Please produce all documents that reflect, refer or relate to how ELI defines its
business customer segments and provide any documents that reflect this definition or the
criteria ELI uses to segment or classify business customers into distinct customer groups.
Please produce all documents that reflect, refer or relate to the average total cost
per line that ELI incuned in 2001 and 2002 for lines used to serve residential customers within
Idaho. For purposes of this document request, costs should include costs associated with
switching; loops; collocation; transport; hot cuts; operational support systems ("OSS"
signaling; customer acquisitions; backhauling traffic to ELI's switches; maintenance , operations
and other administrative activities; and capital costs. If available, please provide documents
showing a breakdown of this information for the following categories: (1) service provided by
UNE-, (2) service provided by UNE-, and (3) service provided using ELI's own facilities. In
addition, please provide all documents containing any available breakdowns of each cost
component that is part of the average total cost per line.
Please produce all documents that reflect, refer or relate to the average total cost
per line that ELI incurred in 2001 and 2002 for lines used to serve business customers within
Idaho. For purposes of this document request, costs should include costs associated with
switching; loops; collocation; transport; hot cuts; OSS; signaling; customer acquisitions;
backhauling traffic to ELI switches; maintenance, operations, and other administrative activities;
and capital costs. Please provide all documents that reflect, refer to relate to separate averages
for service provided through UNE-, UNE-, and with ELI own facilities. If available, please
provide all documents showing a breakdown of each cost component that is part of the average
total cost per line, identifying the type and amount of each cost. If costs differ depending on the
ATTACHMENT B TO SUBPOENA DUCES TECUM (ELECTRIC LIGHTWAVE)
Boise-l 64650.1 0029164-00097
Page 2
type of business customer (small vs. large), please provide documents showing the total cost and
the breakdown of costs by type of business customer.
ATTACHMENT B TO SUBPOENA DUCES TECUM (ELECTRIC LIGHTWAVE)
Boise-I64650.1 0029164-00097
Page 3
ATTACHMENT 6
Mary S. Hobson (ISB #2142)
Stoel Rives LLP
101 South Capitol Boulevard - Suite 1900
Boise, ill 83702
Telephone: [phone]
Facsimile: [phone]
mshobson~stoel.com
Adam L. Sherr (WSBA #25291)
Qwest
1600 ih Avenue - Room 3206
Seattle, W A 98191
Telephone: [phone]
Facsimile: [phone]
adam.sherr~qwest.com
Attorneys for Qwest Corporation
BEFORE THE IDAHO PUBLIC UTILITIES COMMISSION
IN THE MATTER OF IPUC RESPONSE TO
FCC ORDER ON REVIEW OF SECTION 251
UNBUNDLING OBLIGATIONS OF
INCUMBENT LOCAL EXCHANGE
CARRIERS (CC DOCKET NO. 01-338)
Case No. GNR-03-
SUBPOENA DUCES TECUM TO 30(b)(6)
REPRESENTATIVE OF FRETEL
COMMUNICATIONS
NINE-MONTH REVIEW OF ECONOMIC
AND OPERATIONAL IMPAIRMENT
REGARDING ACCESS TO SPECIFIC UNES
To:Fretel Communications, LLC ("Fretel"
CT Corporation System, 300 North 6th Street, Boise, ID 83702
YOU ARE COMMANDED to designate and produce one or more officers, directors
employees, or other persons to appear and testify at the taking of a deposition at the office of
Stoel Rives LLP, 101 South Capitol Boulevard, Suite 1900, Boise, Idaho on December 18 2003
at 9:00 a.m. in the above entitled matter pending before the Idaho Public Utilities Commission.
SUBPOENA DUCES TECUM TO 30(b)(6) REPRESENTATIVE OF FRETEL COMMUNICATIONS - Page 1
Boise-164651.10029164-00097
The deposition shall be taken before a licensed court reporter and will be conducted in
accordance with the IPUC Rules of Procedure IDAPA 31.01.01.000 et. seq.and the Idaho Rules
of Civil Procedure.
This deposition is being taken pursuant to IRCP 30(b)(6). Fretel shall designate the
person or persons with sufficient knowledge to testify to all matters known or reasonably
available to Fretel concerning the specific questions set forth in the document attached as
Attachment A and entitled "Discovery Requests." You are further commanded to produce all
documents listed on Attachment B to this subpoena. If the person or persons designated by
Fretel cannot fully respond orally at the deposition, in addition to those documents listed on
Attachment B, you are further commanded to produce at the deposition the underlying
documentation and other data in your possession that will allow Qwest to compile the
information requested in Attachment A.
ALTERNATIVE PROCEDURE: In the alternative to producing a witness for the
deposition described above, you may comply with the subpoena by providing Qwest Corporation
a verified response to the discovery requests set forth in Attachment A and providing copies of
the documents listed on Attachment B. In the event you respond to this subpoena by providing
verified responses to the discovery requests, the responses shall be provided on or before
December 15 2003 to counsel for Qwest as follows:
Mary S. Hobson (ISB #2142)
Stoel Rives LLP
101 South Capitol Boulevard - Suite 1900
Boise, ill 83702
Telephone: [phone]
Facsimile: [phone]
mshobson~stoel.com
Adam L. Sherr (WSBA #25291)
Qwest
1600 ih Avenue - Room 3206
Seattle, WA 98191
Telephone: [phone]
Facsimile: [phone]
adam.sherr~qwest.com
This subpoena is issued pursuant to Idaho Code 99 61-602; 61-605; 62-615 and IPUC
Rules of Procedure, 222, 224 and 226 IDAPA 31.01.01.222; 224; 226. Please note that Qwest
SUBPOENA DUCES TECUM TO 30(b)(6) REPRESENTATIVE OF FRETEL COMMUNICATIONS - Page 2
Boise-I64651.1 0029164-00097
has filed a motion with the Idaho Public Utilities Commission requesting that the Commission
enter a Protective Order in this matter governing the disclosure of proprietary and/or confidential
material or information. Thus, to the extent any of the responses, documents or underlying data
are claimed by you to be confidential, they can be provided to Qwest as confidential information
pursuant to the Protective Order, upon issuance.
DATED this 20th day of November, 2003.
IDAHO PUBLIC UTILITIES COMMISSION
By:
Its:
Jean D. Jewell
Secretary
SUBPOENA DUCES TECUM TO 30(b)(6) REPRESENTATIVE OF FRETEL COMMUNICATIONS - Page 3
Boise-164651.1 0029164-00097
ATTACHMENT A
to Subpoena Duces Tecum (Fretel Communications)
DISCOVERY REQUESTS
Please state whether the information in the LERG is cunent and accurate for the
switches that Fretel owns, operates, controls, maintains in Idaho, or from which you lease dial
tone or trunking functionality/capacity. If any of the information is not accurate, please identify
the inaccurate information and provide corrected information, including any additions, deletions
or changes. As part of your review of the information in the LERG, please state whether the
CLLI code is accurate for each switch that Fretel owns, operates, controls, maintains, or from
which you lease dial tone or trunking functionality/capacity. In addition, please state whether the
LERG definition of the function of each switch (i., tandem, end office, etc.) is accurate.
For each switch owned or controlled by Fretel that is being used in Idaho to
provide service to customers, please provide the capacity ofthe switch, with "capacity" defined
as: (1) the number oflines installed; (2) the number oflines currently in use; (3) the number of
trunks currently installed; and (4) the number of trunks currently in use. In addition, for each
such switch that you identify, please provide the generic (feature package) loaded in the switch.
Please provide the average total revenue per line that Fretel received from its
residential customers within Idaho in 2001 and 2002. The average revenue per line should
include revenues associated with the basic retail price charged to residential customers, vertical
features, universal service payments, interstate access charges, intrastate access charges
subscriber line charges, toll, long distance, local number portability, and line revenues derived
from any other sources. Please provide both the total average revenue per line and a breakdown
of the amount of revenue for each category of revenue that comprises the total. Please produce
ATTACHMENT A TO SUBPOENA DUCES TECUM (FRETEL COMMUNICATIONS)
Boise-l 64651. I 0029164-00097
Page 1
all documents that reflect, refer or relate to the information provided in your response to this
request.
Please provide the average total revenue per line that Fretel has received from its
business customers within Idaho in 2001 and 2002. The average revenue per line should
include revenues associated with the basic retail price charged to business customers, vertical
features, universal service payments, interstate access charges, intrastate access charges
subscriber line charges, toll, long distance, local number portability, and line revenues derived
from any other sources. Please provide both the total average revenue per line and a breakdown
of the amount of revenue for each category of revenue that comprises the total. If revenues differ
depending on the type of business customer (small vs. large), please provide the total revenues
and the breakdown of revenues by type of business customer. Please provide the information by
POTS , DSO, DSl , DS3, OC-, OC-, OC-, and any other relevant categories. Please produce
all documents that reflect, refer or relate to the information provided in your response to this
request.
Please explain how Fretel defines its business customer segments and provide
any documents that reflect this definition or the criteria Fretel uses to segment or classify
business customers into distinct customer groups. Please produce all documents that reflect
refer or relate to the information provided in your response to this request.
Please provide the average total cost per line that Fretel incurred in 2001 and 2002
for lines used to serve residential customers within Idaho. These costs should include costs
associated with switching; loops; collocation; transport; hot cuts; operational support systems
OSS"); signaling; customer acquisitions; backhauling traffic to Fretel's switches; maintenance
operations, and other administrative activities; and capital costs. If available, please provide a
ATTACHMENT A TO SUBPOENA DUCES TECUM (FRETEL COMMUNICATIONS)
Boise-l 64651.1 0029164-00097
Page 2
breakdown of this information for the following categories: (1) service provided by UNE-, (2)
service provided by UNE-, and (3) service provided using Fretel's own facilities. In addition
please provide any available breakdowns of each cost component that is part of the average total
cost per line, identifying the type and amount of each cost. Please produce all documents that
reflect, refer or relate to the information provided in your response to this request.
Please provide the average total cost per line that Fretel incurred in 2001 and 2002
for lines used to serve business customers within Idaho. These costs should include costs
associated with switching; loops; collocation; transport; hot cuts; OSS; signaling; customer
acquisitions; backhauling traffic to Fretel' s switches; maintenance, operations, and other
administrative activities; and capital costs. In addition to a total average cost, please provide
separate averages for service provided through UNE-, UNE-, and with Fretel's own facilities.
Please provide a breakdown of each cost component that is part of the average total cost per line
identifying the type and amount of each cost. If costs differ depending on the type of business
customer (small vs. large), please provide the total cost and the breakdown of costs by type of
business customer. Please produce all documents that reflect, refer or relate to the information
provided in your response to this request.
To the extent not provided in response to Request Nos. 6 and 7, please identify
the types or categories of customer acquisition costs Fretel incurred in Idaho in 2001 and 2002 to
attract new customers, set up their accounts, and establish service to them. In addition, to the
extent not provided in response to Request Nos. 5 and 6, please provide the per line costs Fretel
incurred in 2001 and 2002 for both business and residential customers for each of the types or
categories of customer acquisition costs.
ATTACHMENT A TO SUBPOENA DUCES TECUM (FRETEL COMMUNICATIONS)
Boise-I 64651.1 0029164-00097
Page 3
ATTACHMENTB
to Subpoena Duces Tecum (Fretel Communications)
Please produce all documents that reflect, refer or relate to the average total
revenue per line that Fretel received from its residential customers within Idaho in 2001 and
2002. For purposes ofthis document request, the average revenue per line should include
revenues associated with the basic retail price charged to residential customers, vertical features
universal service payments, interstate access charges, intrastate access charges, subscriber line
charges, toll, long distance, local number portability, and line revenues derived from any other
sources. Please produce all documents that provide the total average revenue per line and a
breakdown of the amount of revenue for each category of revenue that comprises the total.
Please produce all documents that reflect, refer or relate to the average total
revenue per line that Fretel has received from its business customers within Idaho in 2001 and
2002. For purposes of this document request, the average revenue per line should include
revenues associated with the basic retail price charged to business customers, vertical features
universal service payments, interstate access charges, intrastate access charges, subscriber line
charges, toll, long distance, local number portability, and line revenues derived from any other
sources. Please provide all documents that provide the total average revenue per line and a
breakdown of the amount of revenue for each category of revenue that comprises the total.
revenues differ depending on the type of business customer (small vs. large), please provide all
documents that provide the total revenues and the breakdown of revenues by type of business
customer and by POTS, DSO, DSl , DS3 , OC-, OC-, OC-, and any other relevant
categories.
ATTACHMENT B TO SUBPOENA DUCES TECUM (FRETEL COMMUNICATIONS)
Boise-164651.1 0029164-00097
Page 1
Please produce all documents that reflect, refer or relate to how Fretel defines its
business customer segments and provide any documents that reflect this definition or the
criteria Fretel uses to segment or classify business customers into distinct customer groups.
Please produce all documents that reflect, refer or relate to the average total cost
per line that Fretel incurred in 2001 and 2002 for lines used to serve residential customers
within Idaho. For purposes of this document request, costs should include costs associated with
switching; loops; collocation; transport; hot cuts; operational support systems ("OSS"
signaling; customer acquisitions; backhauling traffic to Fretel's switches; maintenance
operations, and other administrative activities; and capital costs. If available, please provide
documents showing a breakdown of this information for the following categories: (1) service
provided by UNE-, (2) service provided by UNE-, and (3) service provided using Fretel's own
facilities. In addition, please provide all documents containing any available breakdowns of each
cost component that is part of the average total cost per line.
Please produce all documents that reflect, refer or relate to the average total cost
per line that Fretel incurred in 2001 and 2002 for lines used to serve business customers within
Idaho. For purposes of this document request, costs should include costs associated with
switching; loops; collocation; transport; hot cuts; OSS; signaling; customer acquisitions;
backhauling traffic to Fretel switches; maintenance, operations, and other administrative
activities; and capital costs. Please provide all documents that reflect, refer to relate to separate
averages for service provided through UNE-, UNE-, and with Fretel own facilities.
available, please provide all documents showing a breakdown of each cost component that is part
of the average total cost per line, identifying the type and amount of each cost. If costs differ
A IT ACHMENT B TO SUBPOENA DUCES TECUM (FRETEL COMMUNICATIONS)
Boise-164651.1 0029164-00097
Page 2
depending on the type of business customer (small vs. large), please provide documents showing
the total cost and the breakdown of costs by type of business customer.
A TT ACHMENT B TO SUBPOENA DUCES TECUM (FRETEL COMMUNICA TIONS)
Boise-164651.1 0029164-00097
Page 3
TT A CHMENT 7
Mary S. Hobson (ISB #2142)
Stoel Rives LLP
101 South Capitol Boulevard - Suite 1900
Boise, ID 83702
Telephone: [phone]
Facsimile: [phone]
mshobson~stoel.com
Adam L. Sherr (WSBA #25291)
Qwest
1600 ih Avenue - Room 3206
Seattle, WA 98191
Telephone: [phone]
Facsimile: [phone]
adam.sherr~qwest.com
Attorneys for Qwest Corporation
BEFORE THE IDAHO PUBLIC UTILITIES COMMISSION
IN THE MATTER OF IPUC RESPONSE TO
FCC ORDER ON REVIEW OF SECTION 251
UNBUNDLING OBLIGATIONS OF
INCUMBENT LOCAL EXCHANGE
CARRIERS (CC DOCKET NO. 01-338)
Case No. GNR-03-
SUBPOENA DUCES TECUM TO 30(b)(6)
REPRESENTATIVE OF I CG TELECOM
NINE-MONTH REVIEW OF ECONOMIC
AND OPERATIONAL IMPAIRMENT
REGARDING ACCESS TO SPECIFIC UNES
To:lCG Telecom Group, Inc. ("lCG"
Corporation Service Company, 1401 Shoreline Drive, Suite 2, Boise, ill 83702
YOU ARE COMMANDED to designate and produce one or more officers, directors
employees, or other persons to appear and testify at the taking of a deposition at the office of
Stoel Rives LLP , 101 South Capitol Boulevard, Suite 1900, Boise, Idaho on December 18 2003
at 9:00 a.m. in the above entitled matter pending before the Idaho Public Utilities Commission.
SUBPOENA DUCES TECUM TO 30(b)(6) REPRESENTATIVE OF ICG TELECOM - Page 1
Boise-164653.1 0029164-00097
The deposition shall be taken before a licensed court reporter and will be conducted in
accordance with the IPUC Rules of Procedure IDAPA 31.01.01.000 et. seq.and the Idaho Rules
of Civil Procedure.
This deposition is being taken pursuant to IRCP 30(b)( 6). ICG shall designate the person
or persons with sufficient knowledge to testify to all matters known or reasonably available to
ICG concerning the specific questions set forth in the document attached as Attachment A and
entitled "Discovery Requests." You are further commanded to produce all documents listed on
Attachment B to this subpoena. If the person or persons designated by ICG cannot fully respond
orally at the deposition, in addition to those documents listed on Attachment B, you are further
commanded to produce at the deposition the underlying documentation and other data in your
possession that will allow Qwest to compile the information requested in Attachment A.
AL TERNATIVE PROCEDURE: In the alternative to producing a witness for the
deposition described above, you may comply with the subpoena by providing Qwest Corporation
a verified response to the discovery requests set forth in Attachment A and providing copies of
the documents listed on Attachment B. In the event you respond to this subpoena by providing
verified responses to the discovery requests, the responses shall be provided on or before
December 15, 2003 to counsel for Qwest as follows:
Mary S. Hobson (ISB #2142)
Stoel Rives LLP
101 South Capitol Boulevard - Suite 1900
Boise, ill 83702
Telephone: [phone]
Facsimile: [phone]
mshobson~stoel.com
Adam L. Sherr (WSBA #25291)
Qwest
1600 ih Avenue - Room 3206
Seattle, W A 98191
Telephone: [phone]
Facsimile: [phone]
adam.sherr~qwest.com
This subpoena is issued pursuant to Idaho Code 99 61-602; 61-605; 62-615 and IPUC
Rules of Procedure, 222, 224 and 226 IDAPA 31.01.01.222; 224; 226. Please note that Qwest
has filed a motion with the Idaho Public Utilities Commission requesting that the Commission
SUBPOENA DUCES TECUM TO 30(b)(6) REPRESENTATIVE OF ICG TELECOM - Page 2
Boise-164653.1 0029164-00097
enter a Protective Order in this matter governing the disclosure of proprietary and/or confidential
material or information. Thus, to the extent any of the responses, documents or underlying data
are claimed by you to be confidential, they can be provided to Qwest as confidential information
pursuant to the Protective Order, upon issuance.
DATED this 20th day of November, 2003.
IDAHO PUBLIC UTILITIES COMMISSION
By:
Its:
Jean D. Jewell
Secretary
SUBPOENA DUCES TECUM TO 30(b)(6) REPRESENTATIVE OF ICG TELECOM - Page 3
Boise-J64653.10029164-00097
ATTACHMENT A
to Subpoena Duces Tecum (ICG Telecom)
DISCOVERY REQUESTS
Please state whether the information in the LERG is current and accurate for the
switches that ICG owns, operates, controls, maintains in Idaho, or from which you lease dial tone
or trunking functionality/capacity. If any of the information is not accurate, please identify the
inaccurate information and provide corrected information, including any additions, deletions or
changes. As part of your review of the information in the LERG, please state whether the CLLI
code is accurate for each switch that ICG owns, operates, controls, maintains, or from which you
lease dial tone or trunking functionality/capacity. In addition, please state whether the LERG
definition of the function of each switch (i., tandem, end office, etc.) is accurate.
For each switch owned or controlled by ICG that is being used in Idaho to provide
service to customers, please provide the capacity of the switch, with "capacity" defined as: (1)
the number of lines installed; (2) the number of lines currently in use; (3) the number of trunks
currently installed; and (4) the number of trunks currently in use. In addition, for each such
switch that you identify, please provide the generic (feature package) loaded in the switch.
Please provide the average total revenue per line that ICG received from its
residential customers within Idaho in 2001 and 2002. The average revenue per line should
include revenues associated with the basic retail price charged to residential customers, vertical
features, universal service payments, interstate access charges, intrastate access charges
subscriber line charges, toll, long distance, local number portability, and line revenues derived
from any other sources. Please provide both the total average revenue per line and a breakdown
of the amount of revenue for each category of revenue that comprises the total. Please produce
ATTACHMENT A TO SUBPOENA DUCES TECUM (lCG TELECOM)
Boise-I64653.10029164-00097
Page 1
all documents that reflect, refer or relate to the information provided in your response to this
request.
Please provide the average total revenue per line that ICG has received from its
business customers within Idaho in 2001 and 2002. The average revenue per line should
include revenues associated with the basic retail price charged to business customers, vertical
features, universal service payments, interstate access charges, intrastate access charges
subscriber line charges, toll, long distance, local number portability, and line revenues derived
from any other sources. Please provide both the total average revenue per line and a breakdown
of the amount of revenue for each category of revenue that comprises the total. If revenues differ
depending on the type of business customer (small vs. large), please provide the total revenues
and the breakdown of revenues by type of business customer. Please provide the information by
POTS, DSO, DSl , DS3, OC-, OC-, OC-, and any other relevant categories. Please produce
all documents that reflect, refer or relate to the information provided in your response to this
request.
Please explain how ICG defines its business customer segments and provide any
documents that reflect this definition or the criteria ICG uses to segment or classify business
customers into distinct customer groups. Please produce all documents that reflect, refer or
relate to the information provided in your response to this request.
Please provide the average total cost per line that ICG incurred in 2001 and 2002
for lines used to serve residential customers within Idaho. These costs should include costs
associated with switching; loops; collocation; transport; hot cuts; operational support systems
OSS"); signaling; customer acquisitions; backhauling traffic to ICG's switches; maintenance
operations, and other administrative activities; and capital costs. If available, please provide a
ATTACHMENT A TO SUBPOENA DUCES TECUM (lCG TELECOM)
Boise-164653.10029164-00097
Page 2
breakdown of this information for the following categories: (1) service provided by UNE-, (2)
service provided by UNE-, and (3) service provided using ICG's own facilities. In addition
please provide any available breakdowns of each cost component that is part of the average total
cost per line, identifying the type and amount of each cost. Please produce all documents that
reflect, refer or relate to the information provided in your response to this request.
Please provide the average total cost per line that ICG incurred in 2001 and 2002
for lines used to serve business customers within Idaho. These costs should include costs
associated with switching; loops; collocation; transport; hot cuts; OSS; signaling; customer
acquisitions; backhauling traffic to ICG's switches; maintenance, operations, and other
administrative activities; and capital costs. In addition to a total average cost, please provide
separate averages for service provided through UNE-, UNE-, and with ICG's own facilities.
Please provide a breakdown of each cost component that is part of the average total cost per line
identifying the type and amount of each cost. If costs differ depending on the type of business
customer (small vs. large), please provide the total cost and the breakdown of costs by type of
business customer. Please produce all documents that reflect, refer or relate to the information
provided in your response to this request.
To the extent not provided in response to Request Nos. 6 and 7, please identify
the types or categories of customer acquisition costs ICG incurred in Idaho in 2001 and 2002 to
attract new customers, set up their accounts, and establish service to them. In addition, to the
extent not provided in response to Request Nos. 5 and 6, please provide the per line costs ICG
incurred in 2001 and 2002 for both business and residential customers for each of the types or
categories of customer acquisition costs.
ATTACHMENT A TO SUBPOENA DUCES TECUM (ICG TELECOM)
Boise-I64653.10029164-00097
Page 3
ATT ACHMENT B
to Subpoena Duces Tecum (ICG Telecom)
Please produce all documents that reflect, refer or relate to the average total
revenue per line that ICG received from its residential customers within Idaho in 2001 and
2002. For purposes of this document request, the average revenue per line should include
revenues associated with the basic retail price charged to residential customers, vertical features
universal service payments, interstate access charges, intrastate access charges, subscriber line
charges, toll, long distance, local number portability, and line revenues derived from any other
sources. Please produce all documents that provide the total average revenue per line and a
breakdown of the amount of revenue for each category of revenue that comprises the total.
Please produce all documents that reflect, refer or relate to the average total
revenue per line that ICG has received from its business customers within Idaho in 2001 and
2002. For purposes of this document request, the average revenue per line should include
revenues associated with the basic retail price charged to business customers, vertical features
universal service payments, interstate access charges, intrastate access charges, subscriber line
charges, toll, long distance, local number portability, and line revenues derived from any other
sources. Please provide all documents that provide the total average revenue per line and a
breakdown of the amount of revenue for each category of revenue that comprises the total.
revenues differ depending on the type of business customer (small vs. large), please provide all
documents that provide the total revenues and the breakdown of revenues by type of business
customer and by POTS, DSO, DSl , DS3 , OC-, OC-, OC-, and any other relevant
categories.
ATTACHMENT B TO SUBPOENA DUCES TECUM (lCG TELECOM)
Boise-164653.10029164-00097
Page 1
Please produce all documents that reflect, refer or relate to how ICG defines its
business customer segments and provide any documents that reflect this definition or the
criteria ICG uses to segment or classify business customers into distinct customer groups.
Please produce all documents that reflect, refer or relate to the average total cost
per line that ICG incurred in 2001 and 2002 for lines used to serve residential customers within
Idaho. For purposes of this document request, costs should include costs associated with
switching; loops; collocation; transport; hot cuts; operational support systems ("OSS"
signaling; customer acquisitions; backhauling traffic to ICG's switches; maintenance, operations
and other administrative activities; and capital costs. If available, please provide documents
showing a breakdown of this information for the following categories: (1) service provided by
UNE-, (2) service provided by UNE-, and (3) service provided using ICG's own facilities. In
addition, please provide all documents containing any available breakdowns of each cost
component that is part of the average total cost per line.
Please produce all documents that reflect, refer or relate to the average total cost
per line that ICG incurred in 2001 and 2002 for lines used to serve business customers within
Idaho. For purposes of this document request, costs should include costs associated with
switching; loops; collocation; transport; hot cuts; OSS; signaling; customer acquisitions;
backhauling traffic to ICG switches; maintenance, operations, and other administrative activities;
and capital costs. Please provide all documents that reflect, refer to relate to separate averages
for service provided through UNE-, UNE-, and with ICG own facilities. If available, please
provide all documents showing a breakdown of each cost component that is part of the average
total cost per line, identifying the type and amount of each cost. If costs differ depending on the
ATTACHMENT B TO SUBPOENA DUCES TECUM (lCG TELECOM)
Boise-164653.1 0029164-00097
Page 2
type of business customer (small vs. large), please provide documents showing the total cost and
the breakdown of costs by type of business customer.
A IT ACHMENT B TO SUBPOENA DUCES TECUM (lCG TELECOM)
Boise-164653.10029164-00097
Page 3
ATTACHMENT 8
Mary S. Hobson (ISB #2142)
Stoel Rives LLP
101 South Capitol Boulevard - Suite 1900
Boise, ill 83702
Telephone: [phone]
Facsimile: [phone]
mshobson~stoel.com
Adam L. Sherr (WSBA #25291)
Qwest
1600 ih Avenue - Room 3206
Seattle, W A 98191
Telephone: [phone]
Facsimile: [phone]
adam.sherr~qwest.com
Attorneys for Qwest Corporation
BEFORE THE IDAHO PUBLIC UTILITIES COMMISSION
IN THE MATTER OF IPUC RESPONSE TO
FCC ORDER ON REVIEW OF SECTION 251
UNBUNDLING OBLIGATIONS OF
INCUMBENT LOCAL EXCHANGE
CARRIERS (CC DOCKET NO. 01-338)
Case No. GNR-03-
SUBPOENA DUCES TECUM TO 30(b)(6)
REPRESENTATIVE OF LEVEL 3
COMMUNICATIONS
NINE-MONTH REVIEW OF ECONOMIC
AND OPERATIONAL IMPAIRMENT
REGARDING ACCESS TO SPECIFIC UNES
To:Level 3 Communications LLC ("Level 3"
CT Corporation System, 300 North 6th Street, Boise, ID 83701
YOU ARE COMMANDED to designate and produce one or more officers, directors
employees, or other persons to appear and testify at the taking of a deposition at the office of
Stoel Rives LLP, 101 South Capitol Boulevard, Suite 1900, Boise, Idaho on December 18 2003
at 9:00 a.m. in the above entitled matter pending before the Idaho Public Utilities Commission.
SUBPOENA DUCES TECUM TO 30(b)(6) REPRESENTATIVE OF LEVEL 3 COMMUNICATIONS - Page 1
Boise-164654.1 0029164-00097
The deposition shall be taken before a licensed court reporter and will be conducted in
accordance with the IPUC Rules of Procedure IDAPA 31.01.01.000 et. seq.and the Idaho Rules
of Civil Procedure.
This deposition is being taken pursuant to IRCP 30(b)( 6). Level 3 shall designate the
person or persons with sufficient knowledge to testify to all matters known or reasonably
available to Level 3 concerning the specific questions set forth in the document attached as
Attachment A and entitled "Discovery Requests." You are further commanded to produce all
documents listed on Attachment B to this subpoena. If the person or persons designated by
Level 3 cannot fully respond orally at the deposition, in addition to those documents listed on
Attachment B, you are further commanded to produce at the deposition the underlying
documentation and other data in your possession that will allow Qwest to compile the
information requested in Attachment A.
ALTERNATIVE PROCEDURE: In the alternative to producing a witness for the
deposition described above, you may comply with the subpoena by providing Qwest Corporation
a verified response to the discovery requests set forth in Attachment A and providing copies of
the documents listed on Attachment B. In the event you respond to this subpoena by providing
verified responses to the discovery requests, the responses shall be provided on or before
December 15 2003 to counsel for Qwest as follows:
Mary S. Hobson (ISB #2142)
Stoel Rives LLP
101 South Capitol Boulevard - Suite 1900
Boise, ID 83702
Telephone: [phone]
Facsimile: [phone]
mshobson~stoel.com
Adam L. Sherr (WSBA #25291)
Qwest
1600 ih Avenue - Room 3206
Seattle, W A 98191
Telephone: [phone]
Facsimile: [phone]
adam.sherr~qwest.com
This subpoena is issued pursuant to Idaho Code 99 61-602; 61-605; 62-615 and IPUC
Rules of Procedure, 222 224 and 226 IDAPA 31.01.01.222; 224; 226. Please note that Qwest
SUBPOENA DUCES TECUM TO 30(b)(6) REPRESENTATIVE OF LEVEL 3 COMMUNICATIONS - Page 2
Boise-164654.10029164-00097
has filed a motion with the Idaho Public Utilities Commission requesting that the Commission
enter a Protective Order in this matter governing the disclosure of proprietary and/or confidential
material or information. Thus, to the extent any of the responses, documents or underlying data
are claimed by you to be confidential, they can be provided to Qwest as confidential infon11ation
pursuant to the Protective Order, upon issuance.
DATED this 20th day of November, 2003.
IDAHO PUBLIC UTILITIES COMMISSION
By:
Its:
Jean D. Jewell
Secretary
SUBPOENA DUCES TECUM TO 30(b)(6) REPRESENTATIVE OF LEVEL 3 COMMUNICATIONS - Page 3
Boise-l 64654.1 0029164-00097
ATTACHMENT A
to Subpoena Duces Tecum (Level 3 Communications)
DISCOVERY REQUESTS
Please state whether the information in the LERG is current and accurate for the
switches that Level 3 owns, operates , controls, maintains in Idaho, or from which you lease dial
tone or trunking functionality/capacity. If any of the information is not accurate, please identify
the inaccurate information and provide corrected information, including any additions, deletions
or changes. As part of your review of the information in the LERG, please state whether the
CLLI code is accurate for each switch that Level 3 owns, operates, controls, maintains, or from
which you lease dial tone or trunking functionality/capacity. In addition, please state whether the
LERG definition of the function of each switch (i., tandem, end office, etc.) is accurate.
For each switch owned or controlled by Level 3 that is being used in Idaho to
provide service to customers, please provide the capacity of the switch, with "capacity" defined
as: (1) the number oflines installed; (2) the number oflines currently in use; (3) the number of
trunks currently installed; and (4) the number of trunks currently in use. In addition, for each
such switch that you identify, please provide the generic (feature package) loaded in the switch.
Please provide the average total revenue per line that Level 3 received from its
residential customers within Idaho in 2001 and 2002. The average revenue per line should
include revenues associated with the basic retail price charged to residential customers, vertical
features, universal service payments, interstate access charges, intrastate access charges
subscriber line charges, toll, long distance, local number portability, and line revenues derived
from any other sources. Please provide both the total average revenue per line and a breakdown
of the amount of revenue for each category of revenue that comprises the total. Please produce
A TT ACHMENT A TO SUBPOENA DUCES TECUM (LEVEL 3 COMMUNICATIONS)
Boise-164654.10029164-00097
Page 1
all documents that reflect, refer or relate to the information provided in your response to this
request.
Please provide the average total revenue per line that Level 3 has received from
its business customers within Idaho in 2001 and 2002. The average revenue per line should
include revenues associated with the basic retail price charged to business customers, vertical
features, universal service payments, interstate access charges, intrastate access charges
subscriber line charges, toll, long distance, local number portability, and line revenues derived
from any other sources. Please provide both the total average revenue per line and a breakdown
of the amount of revenue for each category of revenue that comprises the total. Ifrevenues differ
depending on the type of business customer (small vs. large), please provide the total revenues
and the breakdown of revenues by type of business customer. Please provide the information by
POTS, DSO, DSl , DS3, OC-, OC-, OC-, and any other relevant categories. Please produce
all documents that reflect, refer or relate to the information provided in your response to this
request.
Please explain how Level 3 defines its business customer segments and provide
any documents that reflect this definition or the criteria Level 3 uses to segment or classify
business customers into distinct customer groups. Please produce all documents that reflect
refer or relate to the information provided in your response to this request.
Please provide the average total cost per line that Level 3 incurred in 2001 and
2002 for lines used to serve residential customers within Idaho. These costs should include
costs associated with switching; loops; collocation; transport; hot cuts; operational support
systems (lfOSS If); signaling; customer acquisitions; backhauling traffic to Level 3' s switches;
maintenance, operations, and other administrative activities; and capital costs. If available
ATTACHMENT A TO SUBPOENA DUCES TECUM (LEVEL 3 COMMUNICATIONS)
Boise-164654.1 0029164-00097
Page 2
please provide a breakdown of this information for the following categories: (1) service provided
by UNE-, (2) service provided by UNE-, and (3) service provided using Level 3's own
facilities. In addition, please provide any available breakdowns of each cost component that is
part of the average total cost per line, identifying the type and amount of each cost. Please
produce all documents that reflect, refer or relate to the information provided in your response to
this request.
Please provide the average total cost per line that Level 3 incurred in 2001 and
2002 for lines used to serve business customers within Idaho. These costs should include costs
associated with switching; loops; collocation; transport; hot cuts; OSS; signaling; customer
acquisitions; backhauling traffic to Level 3' s switches; maintenance, operations, and other
administrative activities; and capital costs. In addition to a total average cost, please provide
separate averages for service provided through UNE-, UNE-, and with Leve13's own
facilities. Please provide a breakdown of each cost component that is part of the average total
cost per line, identifying the type and amount of each cost. If costs differ depending on the type
of business customer (small vs. large), please provide the total cost and the breakdown of costs
by type of business customer. Please produce all documents that reflect, refer or relate to the
information provided in your response to this request.
To the extent not provided in response to Request Nos. 6 and 7, please identify
the types or categories of customer acquisition costs Level 3 incurred in Idaho in 2001 and 2002
to attract new customers, set up their accounts, and establish service to them. In addition, to the
extent not provided in response to Request Nos. 5 and 6, please provide the per line costs Level 3
incurred in 2001 and 2002 for both business and residential customers for each of the types or
categories of customer acquisition costs.
ATTACHMENT A TO SUBPOENA DUCES TECUM (LEVEL 3 COMMUNICATIONS)
Boise-164654.! 0029164-00097
Page 3
ATTACHMENT B
to Subpoena Duces Tecum (Level 3 Communications)
Please produce all documents that reflect, refer or relate to the average total
revenue per line that Level 3 received from its residential customers within Idaho in 2001 and
2002. For purposes of this document request, the average revenue per line should include
revenues associated with the basic retail price charged to residential customers, vertical features
universal service payments, interstate access charges, intrastate access charges, subscriber line
charges, toll, long distance, local number portability, and line revenues derived from any other
sources. Please produce all documents that provide the total average revenue per line and a
breakdown of the amount of revenue for each category of revenue that comprises the total.
Please produce all documents that reflect, refer or relate to the average total
revenue per line that Level 3 has received from its business customers within Idaho in 2001 and
2002. For purposes of this document request, the average revenue per line should include
revenues associated with the basic retail price charged to business customers, vertical features
universal service payments, interstate access charges, intrastate access charges, subscriber line
charges, toll, long distance, local number portability, and line revenues derived from any other
sources. Please provide all documents that provide the total average revenue per line and a
breakdown of the amount of revenue for each category of revenue that comprises the total.
revenues differ depending on the type of business customer (small vs. large), please provide all
documents that provide the total revenues and the breakdown of revenues by type of business
customer and by POTS, DSO, DSl , DS3, OC-, OC-, OC-, and any other relevant
categories.
ATTACHMENT B TO SUBPOENA DUCES TECUM (LEVEL 3 COMMUNICATIONS)
Boise-164654.1 0029164-00097
Page 1
Please produce all documents that reflect, refer or relate to how Level 3 defines its
business customer segments and provide any documents that reflect this definition or the
criteria Level 3 uses to segment or classify business customers into distinct customer groups.
Please produce all documents that reflect, refer or relate to the average total cost
per line that Level 3 incurred in 2001 and 2002 for lines used to serve residential customers
within Idaho. For purposes of this document request, costs should include costs associated with
switching; loops; collocation; transport; hot cuts; operational support systems ("OSS"
signaling; customer acquisitions; backhauling traffic to Level 3' s switches; maintenance
operations, and other administrative activities; and capital costs. If available, please provide
documents showing a breakdown of this information for the following categories: (1) service
provided by UNE-, (2) service provided by UNE-, and (3) service provided using Leve13'
own facilities. In addition, please provide all documents containing any available breakdowns of
each cost component that is part of the average total cost per line.
Please produce all documents that reflect, refer or relate to the average total cost
per line that Level 3 incurred in 2001 and 2002 for lines used to serve business customers
within Idaho. For purposes of this document request, costs should include costs associated with
switching; loops; collocation; transport; hot cuts; OSS; signaling; customer acquisitions;
backhauling traffic to Level 3 switches; maintenance, operations, and other administrative
activities; and capital costs. Please provide all documents that reflect, refer to relate to separate
averages for service provided through UNE-, UNE-, and with Level 3 own facilities.
available, please provide all documents showing a breakdown of each cost component that is part
of the average total cost per line, identifying the type and amount of each cost. If costs differ
ATTACHMENT B TO SUBPOENA DUCES TECUM (LEVEL 3 COMMUNICATIONS)
Boise-I64654.1 0029164-00097
Page 2
depending on the type of business customer (small vs. large), please provide documents showing
the total cost and the breakdown of costs by type of business customer.
ATTACHMENT B TO SUBPOENA DUCES TECUM (LEVEL 3 COMMUNICATIONS)
Boise-164654.1 0029164-00097
Page 3
ATTACHMENT 9
Mary S. Hobson (ISB #2142)
Stoel Rives LLP
101 South Capitol Boulevard - Suite 1900
Boise, ill 83702
Telephone: [phone]
Facsimile: [phone]
mshobson~stoe1.com
Adam L. Sherr (WSBA #25291)
Qwest
1600 ih Avenue - Room 3206
Seattle, WA 98191
Telephone: [phone]
Facsimile: [phone]
adam.sherr~qwest.com
Attorneys for Qwest Corporation
BEFORE THE IDAHO PUBLIC UTILITIES COMMISSION
IN THE MATTER OF IPUC RESPONSE TO
FCC ORDER ON REVIEW OF SECTION 251
UNBUNDLING OBLIGATIONS OF
INCUMBENT LOCAL EXCHANGE
CARRIERS (CC DOCKET NO. 01-338)
Case No. GNR-03-
SUBPOENA DUCES TECUM TO 30(b)(6)
REPRESENTATIVE OF McLEOD
NINE-MONTH REVIEW OF ECONOMIC
AND OPERATIONAL IMPAIRMENT
REGARDING ACCESS TO SPECIFIC UNES
To:McLeodUSA Telecommunications Services, Inc. ("McLeod"
CT Corporation System, 300 North 6th Street, Boise, ID 83701
YOU ARE COMMANDED to designate and produce one or more officers, directors
employees, or other persons to appear and testify at the taking of a deposition at the office of
Stoel Rives LLP , 101 South Capitol Boulevard, Suite 1900, Boise, Idaho on December 18 2003
at 9:00 a.m. in the above entitled matter pending before the Idaho Public Utilities Commission.
SUBPOENA DUCES TECUM TO 30(b)(6) REPRESENTATIVE OF MCLEOD - Page 1
Boise-164656.10029164-00097
The deposition shall be taken before a licensed court reporter and will be conducted in
accordance with the IPUC Rules of Procedure IDAPA 31.01.01.000 et. seq.and the Idaho Rules
of Civil Procedure.
This deposition is being taken pursuant to IRCP 30(b)(6). McLeod shall designate the
person or persons with sufficient knowledge to testify to all matters known or reasonably
available to McLeod concerning the specific questions set forth in the document attached as
Attachment A and entitled "Discovery Requests." You are further commanded to produce all
documents listed on Attachment B to this subpoena. If the person or persons designated by
McLeod cannot fully respond orally at the deposition, in addition to those documents listed on
Attachment B, you are further commanded to produce at the deposition the underlying
documentation and other data in your possession that will allow Qwest to compile the
information requested in Attachment A.
ALTERNATIVE PROCEDURE: In the alternative to producing a witness for the
deposition described above, you may comply with the subpoena by providing Qwest Corporation
a verified response to the discovery requests set forth in Attachment A and providing copies of
the documents listed on Attachment B. In the event you respond to this subpoena by providing
verified responses to the discovery requests, the responses shall be provided on or before
December 15, 2003 to counsel for Qwest as follows:
Mary S. Hobson (ISB #2142)
Stoel Rives LLP
101 South Capitol Boulevard - Suite 1900
Boise, ill 83702
Telephone: [phone]
Facsimile: [phone]
mshobson~stoel.com
Adam L. Sherr (WSBA #25291)
Qwest
1600 ih Avenue - Room 3206
Seattle, W A 98191
Telephone: [phone]
Facsimile: [phone]
adam.sherr~qwest.com
This subpoena is issued pursuant to Idaho Code 99 61-602; 61-605; 62-615 and IPUC
Rules of Procedure, 222, 224 and 226 IDAPA 31.01.01.222; 224; 226. Please note that Qwest
SUBPOENA DUCES TECUM TO 30(b)(6) REPRESENTATIVE OF MCLEOD - Page 2
Boise-164656.1 0029164-00097
has filed a motion with the Idaho Public Utilities Commission requesting that the Commission
enter a Protective Order in this matter governing the disclosure of proprietary and/or confidential
material or infonnation. Thus, to the extent any of the responses, documents or underlying data
are claimed by you to be confidential, they can be provided to Qwest as confidential information
pursuant to the Protective Order, upon issuance.
DATED this 20th day of November, 2003.
IDAHO PUBLIC UTILITIES COMMISSION
By:
Its:
Jean D. Jewell
Secretary
SUBPOENA DUCES TECUM TO 30(b)(6) REPRESENTATIVE OF MCLEOD- Page 3
Boise-164656.! 0029164-00097
ATTACHMENT A
to Subpoena Duces Tecum (McLeod)
DISCOVERY REQUESTS
Please state whether the information in the LERG is current and accurate for the
switches that McLeod owns, operates, controls, maintains in Idaho, or from which you lease dial
tone or trunking functionality/capacity. If any of the information is not accurate, please identify
the inaccurate information and provide corrected information, including any additions, deletions
or changes. As part of your review of the information in the LERG, please state whether the
CLLI code is accurate for each switch that McLeod owns, operates, controls, maintains, or from
which you lease dial tone or trunking functionality/capacity. In addition, please state whether the
LERG definition of the function of each switch (i., tandem, end office, etc.) is accurate.
For each switch owned or controlled by McLeod that is being used in Idaho to
provide service to customers, please provide the capacity of the switch, with "capacity" defined
as: (1) the number oflines installed; (2) the number oflines currently in use; (3) the number of
trunks currently installed; and (4) the number of trunks currently in use. In addition, for each
such switch that you identify, please provide the generic (feature package) loaded in the switch.
Please provide the average total revenue per line that McLeod received from its
residential customers within Idaho in 2001 and 2002. The average revenue per line should
include revenues associated with the basic retail price charged to residential customers, vertical
features, universal service payments, interstate access charges, intrastate access charges
subscriber line charges, toll, long distance, local number portability, and line revenues derived
from any other sources. Please provide both the total average revenue per line and a breakdown
of the amount of revenue for each category of revenue that comprises the total. Please produce
ATTACHMENT A TO SUBPOENA DUCES TECUM (MCLEOD)
Boise-164656.1 0029164-00097
Page 1
all documents that reflect, refer or relate to the information provided in your response to this
request.
Please provide the average total revenue per line that McLeod has received from
its business customers within Idaho in 2001 and 2002. The average revenue per line should
include revenues associated with the basic retail price charged to business customers, vertical
features, universal service payments, interstate access charges, intrastate access charges
subscriber line charges, toll, long distance, local number portability, and line revenues derived
from any other sources. Please provide both the total average revenue per line and a breakdown
of the amount of revenue for each category of revenue that comprises the total. If revenues differ
depending on the type of business customer (small vs. large), please provide the total revenues
and the breakdown of revenues by type of business customer. Please provide the information by
POTS , DSO, DSl , DS3 , OC-, OC-, OC-, and any other relevant categories. Please produce
all documents that reflect, refer or relate to the information provided in your response to this
request.
Please explain how McLeod defines its business customer segments and provide
any documents that reflect this definition or the criteria McLeod uses to segment or classify
business customers into distinct customer groups. Please produce all documents that reflect
refer or relate to the information provided in your response to this request.
Please provide the average total cost per line that McLeod incurred in 2001 and
2002 for lines used to serve residential customers within Idaho. These costs should include
costs associated with switching; loops; collocation; transport; hot cuts; operational support
systems ("OSS"); signaling; customer acquisitions; backhauling traffic to McLeod's switches;
maintenance, operations, and other administrative activities; and capital costs. If available
ATTACHMENT A TO SUBPOENA DUCES TECUM (MCLEOD)
Boise-I64656 1 0029164-00097
Page 2
please provide a breakdown of this information for the following categories: (1) service provided
by UNE-, (2) service provided by UNE-, and (3) service provided using McLeod's own
facilities. In addition, please provide any available breakdowns of each cost component that is
part of the average total cost per line, identifying the type and amount of each cost. Please
produce all documents that reflect, refer or relate to the information provided in your response to
this request.
Please provide the average total cost per line that McLeod incurred in 2001 and
2002 for lines used to serve business customers within Idaho. These costs should include costs
associated with switching; loops; collocation; transport; hot cuts; OSS; signaling; customer
acquisitions; backhauling traffic to McLeod's switches; maintenance, operations, and other
administrative activities; and capital costs. In addition to a total average cost, please provide
separate averages for service provided through UNE-, UNE-, and with McLeod's own
facilities. Please provide a breakdown of each cost component that is part of the average total
cost per line, identifying the type and amount of each cost. If costs differ depending on the type
of business customer (small vs. large), please provide the total cost and the breakdown of costs
by type of business customer. Please produce all documents that reflect, refer or relate to the
information provided in your response to this request.
To the extent not provided in response to Request Nos. 6 and 7, please identify
the types or categories of customer acquisition costs McLeod incurred in Idaho in 2001 and 2002
to attract new customers, set up their accounts, and establish service to them. In addition, to the
extent not provided in response to Request Nos. 5 and 6, please provide the per line costs
McLeod incurred in 2001 and 2002 for both business and residential customers for each of the
types or categories of customer acquisition costs.
ATTACHMENT A TO SUBPOENA DUCES TECUM (MCLEOD)
Boise-I64656.1 0029164-00097
Page 3
TT ACHMENT B
to Subpoena Duces Tecum (McLeod)
Please produce all documents that reflect, refer or relate to the average total
revenue per line that McLeod received from its residential customers within Idaho in 2001 and
2002. For purposes of this document request, the average revenue per line should include
revenues associated with the basic retail price charged to residential customers, vertical features
universal service payments, interstate access charges, intrastate access charges, subscriber line
charges, toll, long distance, local number portability, and line revenues derived from any other
sources. Please produce all documents that provide the total average revenue per line and a
breakdown of the amount of revenue for each category of revenue that comprises the total.
Please produce all documents that reflect, refer or relate to the average total
revenue per line that McLeod has received from its business customers within Idaho in 2001
and 2002. For purposes of this document request, the average revenue per line should include
revenues associated with the basic retail price charged to business customers, vertical features
universal service payments, interstate access charges, intrastate access charges, subscriber line
charges, toll, long distance, local number portability, and line revenues derived from any other
sources. Please provide all documents that provide the total average revenue per line and a
breakdown of the amount of revenue for each category of revenue that comprises the total.
revenues differ depending on the type of business customer (small vs. large), please provide all
documents that provide the total revenues and the breakdown of revenues by type of business
customer and by POTS , DSO, DSl , DS3 , OC-, OC-, OC-, and any other relevant
categories.
ATTACHMENT B TO SUBPOENA DUCES TECUM (MCLEOD)
Boise-164656-1 0029164-00097
Page 1
Please produce all documents that reflect, refer or relate to how McLeod defines
its business customer segments and provide any documents that reflect this definition or the
criteria McLeod uses to segment or classify business customers into distinct customer groups.
Please produce all documents that reflect, refer or relate to the average total cost
per line that McLeod incurred in 2001 and 2002 for lines used to serve residential customers
within Idaho. For purposes ofthis document request, costs should include costs associated with
switching; loops; collocation; transport; hot cuts; operational support systems ("OSS"
signaling; customer acquisitions; backhauling traffic to McLeod's switches; maintenance
operations, and other administrative activities; and capital costs. If available, please provide
documents showing a breakdown of this information for the following categories: (1) service
provided by UNE-, (2) service provided by UNE-, and (3) service provided using McLeod'
own facilities. In addition, please provide all documents containing any available breakdowns of
each cost component that is part of the average total cost per line.
Please produce all documents that reflect, refer or relate to the average total cost
per line that McLeod incurred in 2001 and 2002 for lines used to serve business customers
within Idaho. For purposes of this document request, costs should include costs associated with
switching; loops; collocation; transport; hot cuts; OSS; signaling; customer acquisitions;
backhauling traffic to McLeod switches; maintenance, operations, and other administrative
activities; and capital costs. Please provide all documents that reflect, refer to relate to separate
averages for service provided through UNE-, UNE-, and with McLeod own facilities. If
available, please provide all documents showing a breakdown of each cost component that is part
of the average total cost per line, identifying the type and amount of each cost. If costs differ
ATTACHMENT B TO SUBPOENA DUCES TECUM (MCLEOD)
Boise-164656.1 0029164-00097
Page 2
depending on the type of business customer (small vs. large), please provide documents showing
the total cost and the breakdown of costs by type of business customer.
A TT ACHMENT B TO SUBPOENA DUCES TECUM (MCLEOD)
Boise-I 64656.1 0029164-00097
Page 3
ATTACHMENT
Mary S. Hobson (ISB #2142)
Stoel Rives LLP
101 South Capitol Boulevard - Suite 1900
Boise, ill 83702
Telephone: [phone]
Facsimile: [phone]
mshobson~stoel.com
Adam L. Sherr (WSBA #25291)
Qwest
1600 ih Avenue - Room 3206
Seattle, W A 98191
Telephone: [phone]
Facsimile: [phone]
adam. sh err(i!2q west. co m
Attorneys for Qwest Corporation
BEFORE THE IDAHO PUBLIC UTILITIES COMMISSION
IN THE MATTER OF IPUC RESPONSE TO
FCC ORDER ON REVIEW OF SECTION 251
UNBUNDLING OBLIGATIONS OF
INCUMBENT LOCAL EXCHANGE
CARRIERS (CC DOCKET NO. 01-338)
Case No. GNR- T -03-
SUBPOENA DUCES TECUM TO 30(b)(6)
REPRESENTATIVE OF RURAL
NETWORK SERVICES
NINE-MONTH REVIEW OF ECONOMIC
AND OPERATIONAL IMPAIRMENT
REGARDING ACCESS TO SPECIFIC UNES
To:Rural Network Services, Inc. ("Rural"
Lane Williams, 2203 Keithly Creek Road, Midvale, ill 83645
YOU ARE COMMANDED to designate and produce one or more officers. directors
employees, or other persons to appear and testify at the taking of a deposition at the office of
Stoel Rives LLP, 101 South Capitol Boulevard, Suite 1900, Boise, Idaho on December 18 , 2003
at 9:00 a.m. in the above entitled matter pending before the Idaho Public Utilities Commission.
SUBPOENA DUCES TECUM TO 30(b)(6) REPRESENTATIVE OF RURAL NETWORK SERVICES - Page 1
Boise-I 64658.\ 0029164-00097
The deposition shall be taken before a licensed court reporter and will be conducted in
accordance with the IPUC Rules of Procedure IDAPA 31.01.01.000 et. seq.and the Idaho Rules
of Civil Procedure.
This deposition is being taken pursuant to IRCP 30(b)(6). Rural shall designate the
person or persons with sufficient knowledge to testify to all matters known or reasonably
available to Rural concerning the specific questions set forth in the document attached as
Attachment A and entitled "Discovery Requests." You are further commanded to produce all
documents listed on Attachment B to this subpoena. If the person or persons designated by
Rural cannot fully respond orally at the deposition, in addition to those documents listed on
Attachment B , you are further commanded to produce at the deposition the underlying
documentation and other data in your possession that will allow Qwest to compile the
information requested in Attachment A.
ALTERNATIVE PROCEDURE: In the alternative to producing a witness for the
deposition described above, you may comply with the subpoena by providing Qwest Corporation
a verified response to the discovery requests set forth in Attachment A and providing copies of
the documents listed on Attachment B. In the event you respond to this subpoena by providing
verified responses to the discovery requests, the responses shall be provided on or before
December 15, 2003 to counsel for Qwest as follows:
Mary S. Hobson (ISB #2142)
Stoel Rives LLP
101 South Capitol Boulevard - Suite 1900
Boise, ill 83702
Telephone: [phone]
Facsimile: [phone]
mshobson~stoel.com
Adam L. Sherr (WSBA #25291)
Qwest
1600 7th Avenue - Room 3206
Seattle, WA 98191
Telephone: [phone]
Facsimile: [phone]
adam.sherr~qwest.com
This subpoena is issued pursuant to Idaho Code 99 61-602; 61-605; 62-615 and IPUC
Rules of Procedure, 222, 224 and 226 IDAPA 31.01.01.222; 224; 226. Please note that Qwest
SUBPOENA DUCES TECUM TO 30(b)(6) REPRESENTATIVE OF RURAL NETWORK SERVICES - Page 2
Boise-I 64658. \ 0029164-00097
has filed a motion with the Idaho Public Utilities Commission requesting that the Commission
enter a Protective Order in this matter governing the disclosure of proprietary and/or confidential
material or information. Thus, to the extent any of the responses, documents or underlying data
are claimed by you to be confidential, they can be provided to Qwest as confidential information
pursuant to the Protective Order, upon issuance.
DATED this 20th day of November, 2003.
IDAHO PUBLIC UTILITIES COMMISSION
By:
Its:
Jean D. Jewell
Secretary
SUBPOENA DUCES TECUM TO 30(b)(6) REPRESENTATIVE OF RURAL NETWORK SERVICES - Page 3
Boise-I 64658. I 0029164-00097
ATTACHMENT A
to Subpoena Duces Tecum (Rural).
DISCOVER~ REQUESTS
Please state whether the information in the LERG is current and accurate for the
switches that Rural owns, operates, controls, maintains in Idaho, or from which you lease dial
tone or trunking functionality/capacity. If any of the information is not accurate, please identify
the inaccurate information and provide corrected information, including any additions, deletions
or changes. As part of your review of the information in the LERG, please state whether the
CLLI code is accurate for each switch that Rural owns, operates, controls, maintains, or from
which you lease dial tone or trunking functionality/capacity. In addition, please state whether the
LERG definition of the function of each switch (i., tandem, end office, etc.) is accurate.
For each switch owned or controlled by Rural that is being used in Idaho to
provide service to customers, please provide the capacity of the switch, with "capacity" defined
as: (1) the number oflines installed; (2) the number oflines currently in use; (3) the number of
trunks currently installed; and (4) the number of trunks currently in use. In addition, for each
such switch that you identify, please provide the generic (feature package) loaded in the switch.
Please provide the average total revenue per line that Rural received from its
residential customers within Idaho in 2001 and 2002. The average revenue per line should
include revenues associated with the basic retail price charged to residential customers, vertical
features, universal service payments, interstate access charges, intrastate access charges
subscriber line charges, toll, long distance, local number portability, and line revenues derived
from any other sources. Please provide both the total average revenue per line and a breakdown
of the amount of revenue for each category of revenue that comprises the total. Please produce
ATIACHMENT A TO SUBPOENA DUCES TECUM (RURAL)
Boise-I 64658. 1 0029164-00097
Page 1
all documents that reflect, refer or relate to the information provided in your response to this
request.
Please provide the average total revenue per line that Rural has received from its
business customers within Idaho in 2001 and 2002. The average revenue per line should
include revenues associated with the basic retail price charged to business customers, vertical
features, universal service payments, interstate access charges, intrastate access charges
subscriber line charges, toll, long distance, local number portability, and line revenues derived
from any other sources. Please provide both the total average revenue per line and a breakdown
of the amount of revenue for each category of revenue that comprises the total. Ifrevenues differ
depending on the type of business customer (small vs. large), please provide the total revenues
and the breakdown of revenues by type of business customer. Please provide the information by
POTS, DSO, DSI, DS3, OC-, OC-, OC-, and any other relevant categories. Please produce
all documents that reflect, refer or relate to the information provided in your response to this
request.
Please explain how Rural defines its business customer segments and provide
any documents that reflect this definition or the criteria Rural uses to segment or classify
business customers into distinct customer groups. Please produce all documents that reflect
refer or relate to the information provided in your response to this request.
Please provide the average total cost per line that Rural incurred in 2001 and 2002
for lines used to serve residential customers within Idaho. These costs should include costs
associated with switching; loops; collocation; transport; hot cuts; operational support systems
OSS"); signaling; customer acquisitions; backhauling traffic to Rural's switches; maintenance
operations, and other administrative activities; and capital costs. If available, please provide a
ATTACHMENT A TO SUBPOENA DUCES TECUM (RURAL)
Boise-I64658-10029164-00097
Page 2
breakdown of this information for the following categories: (1) service provided by UNE-, (2)
service provided by UNE-, and (3) service provided using Rural's own facilities. In addition
please provide any available breakdowns of each cost component that is part of the average total
cost per line, identifying the type and amount of each cost. Please produce all documents that
reflect, refer or relate to the information provided in your response to this request.
Please provide the average total cost per line that Rural incurred in 2001 and 2002
for lines used to serve business customers within Idaho. These costs should include costs
associated with switching; loops; collocation; transport; hot cuts; OSS; signaling; customer
acquisitions; backhauling traffic to Rural's switches; maintenance, operations, and other
administrative activities; and capital costs. In addition to a total average cost, please provide
separate averages for service provided through UNE- P, UNE- L, and with Rural's own facilities.
Please provide a breakdown of each cost component that is part of the average total cost per line
identifying the type and amount of each cost. If costs differ depending on the type of business
customer (small vs. large), please provide the total cost and the breakdown of costs by type of
business customer. Please produce all documents that reflect, refer or relate to the information
provided in your response to this request.
To the extent not provided in response to Request Nos. 6 and 7, please identify
the types or categories of customer acquisition costs Rural incurred in Idaho in 2001 and 2002 to
attract new customers, set up their accounts, and establish service to them. In addition, to the
extent not provided in response to Request Nos. 5 and 6, please provide the per line costs Rural
incurred in 2001 and 2002 for both business and residential customers for each of the types or
categories of customer acquisition costs.
ATTACHMENT A TO SUBPOENA DUCES TECUM (RURAL)
Boise-\ 64658. \ 0029\64-00097
Page 3
ATTACHMENT B
to Subpoena Duces Tecum (Rural)
Please produce all documents that reflect, refer or relate to the average total
revenue per line that Rural received from its residential customers within Idaho in 2001 and
2002. For purposes of this document request, the average revenue per line should include
revenues associated with the basic retail price charged to residential customers, vertical features
universal service payments, interstate access charges, intrastate access charges, subscriber line
charges, toll, long distance, local number portability, and line revenues derived from any other
sources. Please produce all documents that provide the total average revenue per line and a
breakdown of the amount of revenue for each category of revenue that comprises the total.
Please produce all documents that reflect, refer or relate to the average total
revenue per line that Rural has received from its business customers within Idaho in 2001 and
2002. For purposes of this document request, the average revenue per line should include
revenues associated with the basic retail price charged to business customers, vertical features
universal service payments, interstate access charges, intrastate access charges, subscriber line
charges, toll, long distance, local number portability, and line revenues derived from any other
sources. Please provide all documents that provide the total average revenue per line and a
breakdown of the amount of revenue for each category of revenue that comprises the total.
revenues differ depending on the type of business customer (small vs. large), please provide all
documents that provide the total revenues and the breakdown of revenues by type of business
customer and by POTS, DSO, DS 1 , DS3, OC-, OC-, OC-, and any other relevant
categories.
AlTACHMENT B TO SUBPOENA DUCES TECUM (RURAL)
Boise-I 64658.1 0029164-00097
Page 1
Please produce all documents that reflect, refer or relate to how Rural defines its
business customer segments and provide any documents that reflect this definition or the
criteria Rural uses to segment or classify business customers into distinct customer groups.
Please produce all documents that reflect, refer or relate to the average total cost
per line that Rural incurred in 2001 and 2002 for lines used to serve residential customers
within Idaho. For purposes of this document request, costs should include costs associated with
switching; loops; collocation; transport; hot cuts; (')perational support systems ("OSS"
signaling; customer acquisitions; backhauling traffic to Rural's switches; maintenance
operations, and other administrative activities; and capital costs. If available, please provide
documents showing a breakdown of this information for the following categories: (1) service
provided by UNE-, (2) service provided by UNE-, and (3) service provided using Rural's own
facilities. In addition, please provide all documents containing any available breakdowns of each
cost component that is part of the average total cost per line.
Please produce all documents that reflect, refer or relate to the average total cost
per line that Rural incurred in 2001 and 2002 for lines used to serve business customers within
Idaho. For purposes of this document request, costs should include costs associated with
switching; loops; collocation; transport; hot cuts; OSS; signaling; customer acquisitions;
backhauling traffic to .Rural switches; maintenance, operations, and other administrative
activities; and capital costs. Please provide all documents that reflect, refer to relate to separate
averages for service provided through UNE-, UNE-, and with Rural own facilities. If
available, please provide all documents showing a breakdown of each cost component that is part
of the average total cost per line, identifying the type and amount of each cost. If costs differ
ATTACHMENT B TO SUBPOENA DUCES TECUM (RURAL)
Boise-I 64658.1 0029164-00097
Page 2
depending on the type of business customer (small vs. large), please provide documents showing
the total cost and the breakdown of costs by type of business customer.
ATfACHMENT B TO SUBPOENA DUCES TECUM (RURAL)
Boise-l 64658. I 0029164-00097
Page 3
ATTACHMENT
Mary S. Hobson (ISB #2142)
Stoel Rives LLP
101 South Capitol Boulevard - Suite 1900
Boise, ill 83702
Telephone: [phone]
Facsimile: [phone]
mshobson~stoel.com
Adam L. Sherr (WSBA #25291)
Qwest
1600 ih Avenue - Room 3206
Seattle, W A 98191
Telephone: [phone]
Facsimile: [phone]
adam.sherr~qwest.com
Attorneys for Qwest Corporation
BEFORE THE IDAHO PUBLIC UTILITIES COMMISSION
IN THE MATTER OF IPUC RESPONSE TO
FCC ORDER ON REVIEW OF SECTION 251
UNBUNDLING OBLIGATIONS OF
INCUMBENT LOCAL EXCHANGE
CARRIERS (CC DOCKET NO. 01-338)
Case No. GNR- T -03-
. .
SUBPOENA DUCES TECUM TO 30(b)(6)
REPRESENTATIVE OF XO IDAHO
NINE-MONTH REVIEW OF ECONOMIC
AND OPERATIONAL IMPAIRMENT
REGARDING ACCESS TO SPECIFIC UNES
To:XO Idaho, Inc. ("XO"
Corporation Service Company, 1401 Shoreline Drive, Suite 2, Boise, ill 83702
YOU ARE COMMANDED to designate and produce one or more officers, directors
employees, or other persons to appear and testify at the taking of a deposition at the office of
Stoel Rives LLP, 101 South Capitol Boulevard, Suite 1900, Boise, Idaho on December 18 2003
at 9:00 a.m. in the above entitled matter pending before the Idaho Public Utilities Commission.
SUBPOENA DUCES TECUM TO 30(b)(6) REPRESENTATIVE OF XO IDAHO - Page 1
Boise-I6466\.1 0029164-00097
The deposition shall be taken before a licensed court reporter and will be conducted in
accordance with the IPUC Rules of Procedure IDAPA 31.01.01.000 et. seq.and the Idaho Rules
of Civil Procedure.
This deposition is being taken pursuant to IRCP 30(b)(6). XO shall designate the person
or persons with sufficient knowledge to testify to all matters known or reasonably available to
XO concerning the specific questions set forth in the document attached as Attachment A and
entitled "Discovery Requests." You are further commanded to produce all documents listed on
Attachment B to this subpoena. If the person or persons designated by XO cannot fully respond
orally at the deposition, in addition to those documents listed on Attachment B, you are further
commanded to produce at the deposition the underlying documentation and other data in your
possession that will allow Qwest to compile the information requested in Attachment A.
ALTERNATIVE PROCEDURE: In the alternative to producing a witness for the
deposition described above, you may comply with the subpoena by providing Qwest Corporation
a verified response to the discovery requests set forth in Attachment A and providing copies of
the documents listed on Attachment B. In the event you respond to this subpoena by providing
verified responses to the discovery requests, the responses shall be provided on or before
December 15 2003 to counsel for Qwest as follows:
Mary S. Hobson (ISB #2142)
Stoel Rives LLP
101 South Capitol Boulevard - Suite 1900
Boise, ill 83702
Telephone: [phone]
Facsimile: [phone]
mshobson~stoe1.com
Adam L. Sherr (WSBA #25291)
Qwest
1600 7tl1 Avenue - Room 3206
Seattle, W A 98191
Telephone: [phone]
Facsimile: [phone]
adam.sherr~qwest.com
This subpoena is issued pursuant to Idaho Code ~~ 61-602; 61-605; 62-615 and IPUC
Rules of Procedure, 222, 224 and 226 IDAPA 31.01.01.222; 224; 226. Please note that Qwest
has filed a motion with the Idaho Public Utilities Commission requesting that the Commission
SUBPOENA DUCES TECUM TO 30(b)(6) REPRESENTATIVE OF XO IDAHO- Page 2
Boise-I 6466 \.I 0029164-00097
enter a Protective Order in this matter governing the disclosure of proprietary and/or confidential
material or information. Thus, to the extent any of the responses, documents or underlying data
are claimed by you to be confidential, they can be provided to Qwest as confidential information
pursuant to the Protective Order, upon issuance.
DATED this 20th day of November, 2003.
IDAHO PUBLIC UTILITIES COMMISSION
By:
Its:
Jean D. Jewell
Secretary
SUBPOENA DUCES TECUM TO 30(b)(6) REPRESENTATIVE OF XO IDAHO - Page 3
Boise-I64661.1 0029164-00097
ATTACHMENT A
to Subpoena Duces Tecum (XO Idaho)
DISCOVERY REQUESTS
Please state whether the information in the LERG is current and accurate for the
switches that XO owns, operates, controls, maintains in Idaho, or from which you lease dial tone
or trunking functionality/capacity. If any of the information is not accurate, please identify the
inaccurate information and provide corrected information, including any additions, deletions or
changes. As part of your review of the information in the LERG, please state whether the CLLI
code is accurate for each switch that XO owns, operates, controls, maintains, or from which you
lease dial tone or trunking functionality/capacity. In addition, please state whether the LERG
definition ofthe function of each switch (i., tandem, end office, etc.) is accurate.
For each switch owned or controlled by XOthat is being used in Idaho to provide
service to customers, please provide the capacity ofthe switch, with "capacity" defined as: (1)
the number oflines installed; (2) the number oflines currently in use; (3) the number of trunks
currently installed; and (4) the number of trunks currently in use. In addition, for each such
switch that you identify, please provide the generic (feature package) loaded in the switch.
Please provide the average total revenue per line that XO received from its
residential customers within Idaho in 2001 and 2002. The average revenue per line should
include revenues associated with the basic retail price charged to residential customers, vertical
features, universal service payments, interstate access charges, intrastate access charges,
subscriber line charges, toll, long distance, local number portability, and line revenues derived
from any other sources. Please provide both the total average revenue per line and a breakdown
of the amount of revenue for each category of revenue that comprises the total. Please produce
AlTACHMENT A TO SUBPOENA DUCES TECUM (XO IDAHO)
Boise-I6466\.1 0029164-00097
Page 1
all documents that reflect, refer or relate to the information provided in your response to this
request.
Please provide the average total revenue per line that XO has received from its
business customers within Idaho in 2001 and 2002. The average revenue per line should
include revenues associated with the basic retail price charged to business customers, vertical
features, universal service payments, interstate access charges, intrastate access charges
subscriber line charges, toll, long distance, local number portability, and line revenues derived
from any other sources. Please provide both the total average revenue per line and a breakdown
of the amount of revenue for each category of revenue that comprises the total. Ifrevenues differ
depending on the type of business customer (small vs. large), please provide the total revenues
and the breakdown of revenues by type of business customer. Please provide the information by
POTS, DSO, DSl , DS3, OC-, OC-, OC-, and any other relevant categories. Please produce
all documents that reflect, refer or relate to the information provided in your response to this
request.
Please explain how XO defines its business customer segments and provide any
documents that reflect this definition or the criteria XO uses to segment or classify business
customers into distinct customer groups. Please produce all documents that reflect, refer or
relate to the information provided in your response to this request.
Please provide the average total cost per line that XO incurred in 2001 and 2002
for lines used to serve residential customers within Idaho. These costs should include costs
associated with switching; loops; collocation; transport; hot cuts; operational support systems
OSS"); signaling; customer acquisitions; backhauling traffic to XO's switches; maintenance
operations, and other administrative activities; and capital costs. If available, please provide a
ATIACHMENT A TO SUBPOENA DUCES TECUM (XO IDAHO)
Boise-I64661.1 0029164-00097
Page 2
breakdown of this information for the following categories: (1) service provided by UNE-, (2)
service provided by UNE-, and (3) service provided using XO's own facilities. In addition
please provide any available breakdowns of each cost component that is part of the average total
cost per line, identifying the type and amount of each cost. Please produce all documents that
reflect, refer or relate to the information provided in your response to this request.
Please provide the average total cost per line that XO incurred in 2001 and 2002
for lines used to serve business customers within Idaho. These costs should include costs
associated with switching; loops; collocation; transport; hot cuts; OSS; signaling; customer
acquisitions; backhauling traffic to XO's switches; maintenance, operations, and other
administrative activities; and capital costs. In addition to a total average cost, please provide
separate averages for service provided through UNE-, UNE-, and with XO's own facilities.
Please provide a breakdown of each cost component that is part of the average total cost per line
identifying the type and amount of each cost. If costs differ depending on the type of business
customer (small vs. large), please provide the total cost and the breakdown of costs by type of
business customer. Please produce all documents that reflect, refer or relate to the information
provided in your response to this request.
To the extent not provided in response to Request Nos. 6 and 7, please identify
the types or categories of customer acquisition costs XO incurred in Idaho in 2001 and 2002 to
attract new customers, set up their accounts, and establish service to them. In addition, to the
extent not provided in response to Request Nos. 5 and 6, please provide the per line costs XO
incurred in 2001 and 2002 for both business and residential customers for each of the types or
categories of customer acquisition costs.
ATIACHMENT A TO SUBPOENA DUCES TECUM (XO IDAHO)
Boise-I64661.\ 0029164-00097
Page 3
ATTACHMENT B
to Subpoena Duces Tecum (XO Idaho)
Please produce all documents that reflect, refer or relate to the average total
revenue per line that XO received from its residential customers within Idaho in 2001 and
2002. For purposes of this document request, the average revenue per line should include
revenues associated with the basic retail price charged to residential customers, vertical features
universal service payments, interstate access charges, intrastate access charges, subscriber line
charges, toll, long distance, local number portability, and line revenues derived from any other
sources. Please produce all documents that provide the total average revenue per line and a
breakdown of the amount of revenue for each category of revenue that comprises the total.
Please produce all documents that reflect, refer or relate to the average total
revenue per line that XO has received from its business customers within Idaho in 2001 and
2002. For purposes ofthis document request, the average revenue per line should include
revenues associated with the basic retail price charged to business customers, vertical features
universal service payments, interstate access charges, intrastate access charges, subscriber line
charges, toll, long distance, local number portability, and line revenues derived from any other
sources. Please provide all documents that provide the total average revenue per line and a
breakdown of the amount of revenue for each category of revenue that comprises the total.
revenues differ depending on the type of business customer (small vs. large), please provide all
documents that provide the total revenues and the breakdown of revenues by type of business
customer and by POTS, DSO, DSl , DS3 , OC-3, OC-, dC-, and any other relevant
categories.
ATTACHMENT B TO SUBPOENA DUCES TECUM (XO IDAHO)
Boise-I 64661 . I 0029164-00097
Page 1
Please produce all documents that reflect, refer or relate to how XO defines its
business customer segments and provide any documents that reflect this definition or the
criteria XO uses to segment or classify business customers into distinct customer groups.
Please produce all documents that reflect, refer or relate to the average total cost
per line that XO incurred in 2001 and 2002 for lines used to serve residential customers within
Idaho. For purposes of this document request, costs should include costs associated with
switching; loops; collocation; transport; hot cuts; operational support systems ("OSS"
signaling; customer acquisitions; backhauling traffic to XO's switches; maintenance, operations
and other administrative activities; and capital costs. If available, please provide documents
showing a breakdown of this information for the following categories: (1) service provided by
UNE-, (2) service provided by UNE-, and (3) service provided using XO's own facilities. In
addition, please provide all documents containing any available breakdowns of each cost
component that is part ofthe average total cost per line.
Please produce all documents that reflect, refer or relate to the average total cost
per line that XO incurred in 2001 and 2002 for lines used to serve business customers within
Idaho. For purposes of this document request, costs should include costs associated with
switching; loops; collocation; transport; hot cuts; OSS; signaling; customer acquisitions;
backhauling traffic to XO switches; maintenance, operations, and other administrative activities;
and capital costs. Please provide all documents that reflect, refer to relate to separate averages
for service provided through UNE-, UNE-, and with XO own facilities. If available, please
provide all documents showing a breakdown of each cost component that is part of the average
total cost per line, identifying the type and amount of each cost. If costs differ depending on the
ATTACHMENT B TO SUBPOENA DUCES TECUM (XO IDAHO)
Boise-I6466 \.I 0029164-00097
Page 2
type of business customer (small vs. large), please provide documents showing the total cost and
the breakdown of costs by type of business customer.
ATTACHMENT B TO SUBPOENA DUCES TECUM (XO IDAHO)
Boise-\64661.\ 0029164-00097
Page 3