20040601Qwest Motion for Extension of Time.pdf

William J. Batt
James B. Alderman
Batt & Fisher, LLP
US Bank Plaza, 5th Floor
101 South Capital Blvd.
Boise, Idaho 83702
[phone]
Adam Sherr
Qwest Communications, Inc.
1600 7th Avenue - Room 3206
Seattle, W A 98191
[phone]
Attorneys for
Respondent Qwest Corporation
HECEIVEO mFILED
2nn~tilY 2 8 PM 3: 3m
iO ;10 PUBLIC
UTILITIES COMr1JSSlON
BEFORE THE IDAHO PUBLIC UTILITIES COMMISSION
IN THE MATTER OF PAGEDATA'
PETITION FOR ARBITRATION OF
INTERCONNECTION RATES, TERMS AND
CONDITIONS AND RELATED
ARRAN G EMENTS WITH Q WEST
CORPORATION PURSUANT TO SECTION
252(B) OF THE FEDERAL
TELECOMMUNICATIONS ACT.
IN THE MATTER OF WAVESENT'
PETITION FOR ARBITRATION OF
INTERCONNECTION RATES, TERMS AND
CONDITIONS AND RELATED
ARRANGEMENTS WITH QWEST
CORPORATION PURSUANT TO SECTION
252(B) OF THE FEDERAL
TELECOMMUNICATIONS ACT.
Case No. GNR-O4-
STIPULATED MOTION TO
EXTEND TIME FOR
QWEST CORPORATION'
RESPONSE
Case No. GNR-O4-
COME NOW the Petitioners, Wave Sent and PageData (the "Pagers) and the
Respondent Qwest Corporation ("Qwest") and move the Commission for an Order
extending the time for Qwest to file its response to the Petition for Arbitration filed by
PageData on March 23, 2004 and the Petition for Arbitration filed by WaveSent on
ORIGINAL
STIPULATED MOTION TO EXTEND TIME FOR QWEST CORPORATION'S RESPONSE, P. 1
March 25, 2004 ("Petitions for Arbitration ), and the Amendment to Petitions filed by the
Pagers on April 12, 2004 ("Amendment"). The Pagers and Qwest (collectively referred to
herein as the "Parties ) represent the following to the Commission:
Qwest has prepared a Response to the Petitions and Amendment.
Qwest has, however, not yet filed these pleadings with the Commission.
On May 13 2004, the Parties met in person at the Commission
offices for negotiations. Wayne Hart of the Commission s Staff, and Don
Howell, Counsel for the Commission, attended the negotiations. The
Parties made significant progress and reached an agreement in principle on
many of the terms of new interconnection agreements between the two
Pagers and Qwest.
The Parties are optimistic that negotiations will be successful, in
which case these arbitration cases can be dismissed.
The Parties would like to avoid unnecessary effort and expense to
themselves and the Commission, and wish to provide a period of time in
which the Parties direct their entire efforts to negotiations rather than
litigation.
The Parties respectfully move the Commission for an order extending the time for
Qwest to file its response to the Petitions until the earlier of (i) June 11 , 2004 or (ii)
business day after the Pagers provide written notice Qwest's counsel that they have
elected to proceed with the arbitrations.
STIPULATED MOTION TO EXTEND TIME FOR QWEST CORPORATION'S RESPONSE, P. 2
Respectfully submitted on behalf of all Parties this 27th of May, 2004.
Adam Sherr
Qwest Communications, Inc.
1600 7th Avenue - Room 3206
Seattle, WA 98191
and
eM 'l--
William J. Batt
Batt & Fisher, LLP
U S Bank Plaza, 5th Floor
101 South Capital Blvd.
Boise, Idaho 83702
[phone]
STIPULA TED MOTION TO EXTEND TIME FOR QWEST CORPORATION'S RESPONSE, P. 3
CERTIFICA TE OF SERVICE
I HEREBY CERTIFY that on this 2ih day of May, 2004, I served the foregoing
upon all parties of record in this proceeding as indicated below.
Jean Jewell J Certified Mail
Idaho Public Utilities Commission
472 W. Washington Street First Class Mail
Boise, ID 83702-5983
J Hand Delivery
[phone]
J Facsimile
Joseph McNeal, d/b/a PageData J Certified Mail
O. Box 15509
Boise, ID 83715 p(l First Class Mail
[phone] J Hand Delivery
J Facsimile
ll'v
William J. Batt
STIPULATED MOTION TO EXTEND TIME FOR QWEST CORPORATION'S RESPONSE, P. 4