20031126Limited Response.pdf

RECEIVED mnLED
2003 NOV 26 P~1 I: 2S
William J. Batt
Marshall Batt & Fisher, LLP
U S Bank Plaza, 5th Floor
101 South Capital Blvd.
Boise, Idaho 83702
[phone]
it) ;,j F
"""
UTILiT ItS COf~H'iISSIOH
Adam Sherr
Qwest
1600 7th Avenue - Room 3206
Seattle, WA 98191
[phone]
Attorneys for
Respondent Qwest Corporation
BEFORE THE IDAHO PUBLIC UTILITIES COMMISSION
JOSEPH B. MCNEAL, d/b/a P AGEDA T A
, )
Case No. QWE- T -03-
Complainant
QWEST COMMUNICA nONS , INC.
QWEST CORPORATION'
LIMITED RESPONSE TO
JOSEPH B. MCNEAL, d/b/a
PAGEDATA'S COMPLAINT
vs.
Respondent.
Introduction and Summary
On October 31 , 2003, Joseph McNeal d/b/a PageData ("PageData ) filed a document
captioned as a "Complaint" with the Idaho Public Utilities Commission ("Commission ). That
ORIGINAL
QWEST CORPORA nON'S LIMITED RESPONSE TO JOSEPH B. MCNEAL d/b/a P AGEDA T A'
COMPLAINT, P. 1
document (hereinafter "PageData s Filing ) names Qwest Communications, Inc. as Respondent
PageData seeks to invoke the Commission s jurisdiction to interpret an interconnection
agreement2 - the "Arch Agreement" - recently adopted by PageData 3 and to order Qwest to do
certain things in connection with the Arch Agreement.
Qwest hereby provides a limited response to PageData s Filing. Qwest does not address
PageData s allegations and contentions, but raises only a single point that the Commission
should consider before determining whether to open a complaint docket. For the reasons stated
below, the Commission should decline to open a complaint docket, and should dismiss
PageData s Filing.
First, the Arch Agreement itself sets out detailed procedures for resolving disputes such
as this one, but PageData has entirely ignored that contractual obligation.
Second, the resolution of this billing dispute depends on determining one narrow factual
issue - the intent of the contracting parties. PageData raises no legal issues whatsoever, much
less important questions of telecommunications law. Likewise, resolution of this private contract
language dispute will not affect other Idaho telecommunications carriers, nor is there any
potential ramification for telecommunications industry.
I Qwest Corporation ("Qwest") notes that the Respondent named by the Complainant is inaccurate, as there is no
entity named Qwest Communications, Inc. Qwest Corporation is the incumbent local exchange company in Idaho
and is the party with whom PageData has an interconnection agreement. See Order No. 29198.
2 Type 1 and Type 2 Paging Interconnection Agreement between U S WEST Communications, Inc., and Arch
Paging, Ine.! Mobile Communications Corporation of America, filed with the IPUC on July 13 2000 (hereinafter as
Arch Agreement ). See In the Matter of the Joint Application ofQwest Corporation FKA US WEST
Communications, Inc. Arch Paging, Inc. and Mobile Communications Corporation of America for Approval of a
Type and Type Interconnection Agreement Pursuant to 47 USe. 252(e), Case No. USW- T-00-20. The
Commission approved the Arch Agreement on September 1 2000. Id.Order No. 28499.
3 The Commission approved PageData s adoption of the Arch Agreement on February 25, 2003. See In the Matter
of the Joint Application ofQwest Corporation and Joseph B. McNeal dba PageDatafor Approval of a Paging
Connection Agreement Pursuant to 47 USe. 252(i), Case No. QWE-03-, Order No. 29198.
QWEST CORPORATION'S LIMITED RESPONSE TO JOSEPH B. MCNEAL d/b/a PAGEDATA'
COMPLAINT, P. 2
Finally, the Commission has no legal obligation to entertain this purely private contract
dispute, and it would be a waste of the Commission s scarce resources for it to do so. The
Commission should refer PageData back to the dispute resolution provisions ofthe Arch
Agreement.
Qwest's Limited Response Is ~ot an Answer und.!!.1he IPUC Rules of Procedure
Qwest understands the Commission has not opened a complaint case under Rule 54 of the
IPUC Rules of Procedure or otherwise acted on PageData s Filing and that this matter is
currently governed by the Commission s informal procedures 4 as follows:
After review, the Commission will determine whether to treat PageData
Filing as a complaint under the IPUC Rules of Procedure. In the meantime, the
Commission has assigned a case number for administrative purposes only.
If the Commission decides to treat PageData s Filing as a complaint, the
Commission will issue a summons and serve Qwest S after which
Qwest would be
required to file an answer.
Under the Commission s Rules, Qwest is not obligated to answer or
otherwise respond to PageData s Filing at this time. However, it is proper for
Qwest to respond to PageData s Filing before the Commission decides whether to
open a complaint docket.
4 IPUC Rules of Procedure, Rules 21-30.
5 IPUC Rules of Procedure, Rule 16.
6 IPUC Rules of Procedure, Rule 57.
QWEST CORPORATION'S LIMITED RESPONSE TO JOSEPH B. MCNEAL d/b/a P AGEDA T A'
COMPLAINT, P. 3
Accordingly, Qwest submits this Limited Response , but does not hereby file an "answer
under Rule 57, and reserves the right to answer and defend against the allegations in PageData
Filing, should the Commission determine that a complaint docket should be opened.
The Dispute
Money Owed to Owest by PageData
As the Commission is well aware, PageData has pursued litigation against Qwest on a
variety of theories since 1999. In P ageData v. Qwest 7 the Commission determined the amount
of billing credit due PageData under the FCC's TSR Wireless decision and its progeny.8 Qwest
applied the credit to PageData s account per the Commission s Orders. PageData has appealed
the Commission s decision to the Idaho Supreme Court, but PageData did not seek a stay of the
Commission s final order. Accordingly, the Commission established the amount of wholesale
credit due PageData for the period of November 1996 through September 1999. PageData still
has paid nothing for any interconnection or other wholesale services since at least October 1998
including services provided under PageData s interconnection agreement. PageData currently
owes Qwest approximately $300 000 for wholesale/interconnection services after the
Commission-determined credit is applied. PageData refuses to pay one cent of this balance.
See, PageData et.al v. us WEST Communications, Inc., USW-99-(appeal pending before the Idaho Supreme
Court) Docket No. 29175 (hereinafter PageData v. Qwest
TSR Wireless, LLC, et al. v. US West Communications, Inc.Memorandum Opinion and Order, 15 FCC Rcd.
11166 (2000); Metrocall, Inc. v. Southwestern Bell Tel. Co.Memorandum Opinion and Order on Supplemental
Complaint for Damages, 16 FCC Rcd 18123 (2001); Metrocall v. Concord, Memorandum Opinion and Order, Case
No. EB-OI-MD-008, (February 8, 2002); Mountain Communications, Inc. v. Qwest Communications InternationalInc.Memorandum Opinion and Order, 17 FCC Rcd 2091 (2002) Mountain Order
QWEST CORPORATION'S LIMITED RESPONSE TO JOSEPH B. MCNEAL d/b/a PAGEDATA'
COMPLAINT, P. 4
Charges and Payments Under the Arch Agreement
The Arch Agreement is a post-Metzger paging connection agreement under which Qwest
provides local interconnection facilities to the paging company without charge, except to the
extent the facilities carry transit traffic. The paging company must compensate Qwest for the
facilities to the extent they carry transit traffic.
Under the Arch Agreement, Qwest compensates the paging company for the termination
of the land-to-pager calls originated by Qwest customers. The paging company s charge for
termination ofland-to-pager calls is set at rates "symmetrical" to Qwest's reciprocal
compensation (i., transport and termination) charges.
The crux of the parties' dispute is as follows. PageData claims that Qwest must write a
check to PageData every month for the termination charges. Qwest, on the other hand, believes
that it can offset PageData s charges against other amounts owed Qwest for wholesale services.
Resolution of this dispute depends on the language of the Arch Agreement and the intent
of the parties under that Agreement. 9 The contract itself is silent.
The Dispute Resolution Provisions
PageData s Filing acknowledges that Dispute Resolution provisions ofthe Arch
Agreement govern. PageData states in its first paragraph:
This Complaint is a formal complaint, filed in accordance with (federal and state
law) and section 13.14. of PageD at a s interconnection agreement with Qwest
approved by the Idaho PUC on February 25 2003.
9 PageData s intent is irrelevant because it simply adopted an already existing agreement.
QWEST CORPORATION'S LIMITED RESPONSE TO JOSEPH B. MCNEAL d/b/a PAGEDATA'
COMPLAINT, P. 5
PageData correctly cites the Arch Agreement's dispute resolution section , which provides:
13.14. Dispute Resolution
If any claim. controversy or dispute between the Parties. their agents. employees.
officers. directors or affiliated agents ("Dispute ) cannot be settled through
negotiation. it shall be resolved by arbitration under the then current rules of the
American Arbitration Association ("AAA"The arbitration shall be conducted by
a single neutral arbitrator familiar with the telecommunications industry and
engaged in the practice of law. Such arbitrator shall not be a current or former
employee, agent, contractor, officer or director of either Party or its affiliates or
subsidiaries or related in any way to a current or former employee, agent
contractor, officer, or director of either Party or its affiliates. The Federal
Arbitration Act, 9 U.C. Secs. 1-, not state law, shall govern the arbitrability of
all Disputes. The arbitrator shall not have authority to award punitive damages.
All expedited procedures prescribed by the AAA rules shall apply and the rules
used shall be those for the telecommunications industry. The arbitrator s award
shall be final and binding and may be entered in any court having jurisdiction
thereof. The prevailing Party, as determined by the arbitrator, shall be entitled to
an award of reasonable attorneys' fees and costs. The arbitration shall occur at a
mutually agreed upon location. Nothing in this Section shall be construed to
waive or limit either Party s right to seek relief from the Commission or the FCC
as provided by state or federal law.
If Qwest (as PageData alleges) is misinterpreting the Arch Agreement when it offsets
PageData s debts to Qwest against the reciprocal compensation charges of PageData, the
contract provides a very clear path by which PageData can resolve that dispute. PageData is
contractually bound to follow that approach to resolve its dispute.
The Commission Should Decline to Exercise Jurisdiction over this Private Contract
Dispute. and Has No Lel!3l Oblie:ation To Entertain Pae:eData s Filine: as a Formal
Complaint
Over a period of years following the Act's passage , the Federal Communications
Commission created confusion and disorder in the law over paging interconnection, particularly
by retroactively preempting state tariffs under which paging companies ordered interconnection
10 PageData Filing, p. 1.
QWEST CORPORATION'S LIMITED RESPONSE TO JOSEPH B. MCNEAL d/b/a PAGEDATA'
COMPLAINT, P. 6
services from local exchange companies.12 The long-standing confusion over the extent of FCC
preemption led to considerable difficulty in interconnection negotiations and ultimately litigation
in interconnection arbitrations, in the courts, and at the FCC. The extent of the preemption was
very uncertain until approximately one year ago.
To Qwest's knowledge , the Idaho Commission has been alone among state commissions
in being faced with the enormously difficult, expensive, and unrewarding task of attempting to
determine retroactive credits due to paging companies under the FCC's murky preemption.
This Commission s Orders in PageData v. Qwest present the most definitive and best reasoned
statements available on paging interconnection law. Yet even now those rulings are challenged
by PageData and the other appellants at the Idaho Supreme Court, and PageData seeks to
II Arch Agreement, ~ 13.14. See Exhibit A. (Emphasis added.
Letter ftom A. Richard Metzger, Jr., Chief, Common Carrier Bureau to Keith Davis, Southwestern Bell Telephone
DA 97-2726 (Dec. 30, 1997) (Metzger Letter); TSR Wireless, LLC, et al. v. US West Communications, Inc.
Memorandum Opinion and Order, 15 FCC Rcd. 11166 (2000).
\3 The principal issues concerning preemption were: (i) the extent to which FCC rules, as interpreted by the FCC
preempted state tariffs and state commission decisions; (ii) whether paging carriers may obtain LEC facilities ftom
the LECs without paying and if so, within what geographic area; (iii) whether paging carriers are entitled to
compensation or ftee facilities even if they purchased the facilities under state tariffs and have not entered into
section 251/252 interconnection agreements: (iv) transit traffic. The issues were primarily resolved in a series of
decisions ftom the FCC beginning in June 2000. See TSR Wireless LLC v. US West Communications Inc.
Memorandum Opinion and Order, issued June 21, 2000 aff'd sub. nom.Qwest v. FCC, 252 F.3d 462 (D.c. Cir.
2001); Metrocall, Inc. v. Southwestern Bell Tel. Co.Memorandum Opinion and Order on Supplemental Complaint
for Damages, 16 FCC Rcd 18123 (2001); Texcom, Inc, d/b/a Answer Indiana v. Bell Atlantic Corp. d/b/a Verizon
Communications Memorandum Opinion and Order, FCC No. 01-347 (reI. Nov. 29, 2001); Metrocall v. Concord
Telephone Company, Memorandum Opinion and Order, 17 FCC Rcd 2252 (Feb. 8, 2002); Texcom, Inc., d/b/a
Answer Indiana v. Bell Atlantic Corp., d/b/a Verizon Communications Order on Reconsideration, FCC 02-96 (reI.
Mar. 27, 2002) Texcom Reconsideration Order ); Mountain Communications, Inc. v. Qwest CommunicationsInternational, Inc.Memorandum Opinion and Order, 17 FCC Rcd 2091 (2002); Mountain Communications, Inc.
Qwest Communications International, Inc.Order on Review, July 25 2002.
14 Besides the Commission s decisions in PageData v. Qwest we are aware of only one other reported decision
attempting to sort through the myriad accounting and billing issues where a paging company claimed retroactive
credit: Metrocall, Inc. v. Southwestern Bell Tel. Co.Memorandum Opinion and Order on Supplemental Complaint
for Damages, 16 FCC Rcd 18123 (2001), in which the FCC expresses great ITustration at the difficulty of the
computations and lack of evidence; the FCC determined no credit was due Metrocall. 1d at ~~ 8-, 15.
QWEST CORPORATION'S LIMITED RESPONSE TO JOSEPH B. MCNEAL d/b/a PAGEDATA'
COMPLAINT, P. 7
relitigate all those issues in a new lawsuit in federal court. IS Against that backdrop, the
Commission should decline this new opportunity. In PageData v. Qwest the case presented
issues of industry importance, and complex questions peculiarly within the Commission
expertise. The billing dispute described in PageData s Filing, on the other hand, presents no
such important issues or technical complexities.
1. The Commission May Exercise Discretion Whether to Entertain a Private
Contract Dispute.
The Commission should decline to exercise its jurisdiction, and should hold that
PageData follow the contract's dispute resolution process. This result is supported by a long line
of decisions from the Idaho Supreme Court and the Commission regarding when the
Commission should assert jurisdiction over a private contract dispute.
The Commission has stated that where there is concurrent jurisdiction over a private
contract dispute with another court or commission, the Commission will exercise restraint and
determine whether assertion of Commission jurisdiction is in the public interest:
The authority and jurisdiction of this Commission is restricted to that expressly
and by necessary implication conferred upon it by the Legislature. . .. . Mindful of
our duty, we recognize that in some instances Commission power, authority and
jurisdiction is coincident or concurrent with that of Idaho courts, specifically in
the area of contracts. Determining when to exercise our jurisdiction is often
predicated on an attitude of self-restraint and a determination of the most
appropriate forum. Idaho Code gg 61-307
, -
502
, -
503
, -
622
, -
623; Idaho
Constitution Article I, g 16; Lemhi Telephone Company v. Mountain States Tel
15 Joseph B. McNeal, d/b/a PageData, et al v. Qwest Corporation, et ai filed October 31, 2003 , (United States
District Court, District ofIdaho) Case No. CIV 03-473-MHW.
16 Bunker Hill v. Washington Water Power 98 Idaho 249 (1977); Lemhi Telephone Company v. Mountain States Tel
Tel 98 Idaho 692, 571 P.2d 753 (1977); Agricultural Products v. Utah Power Light 98 Idaho 23, 557 P.2d 617
(1976).Forest Fuel Power v. Washington Water Power Case No. U-IO08-246, Order No. 20486 (1986)(" We have
repeatedly said that the Idaho Public Utilities Commission is not the proper forum for arbitration or mediation of
disputed contracts.
);
Idaho Power Company, vs. Cogeneration, Inc.Case No. IPC-94-24; Order No. 25918
(1995).
QWEST CORPORATION'S LIMITED RESPONSE TO JOSEPH B. MCNEAL d/b/a PAGEDA T A'
COMPLAINT, P. 8
Tel 98 Idaho 692 571 P.2d 753 (1977); Agricultural Products v. Utah Power
Light 98 Idaho 23, 557 P.2d 617 (1976).
The Commission has further stated that this was true, even whether the parties had
expressly agreed in the contract that contract disputes were to be decided by the Commission:
The Commission reminds the parties that jurisdiction may not be conferred on the
Commission by contractual stipulation. The authority and jurisdiction of the
Commission is restricted to that expressly and by necessary implication conferred
upon it by enabling statutes. The nature and extent of Commission jurisdiction to
resolve actual disputes will be determined by the Commission on an individual
case-by-case basis, not withstanding P21.1 of the Agreement.
In this case, the Commission s assertion of jurisdiction over PageData s billing dispute
does not impact the public interest; it is a purely private matter affecting no one other than the
parties to the interconnection agreement, especially since the parties have obligated themselves
to use a different forum.
The Commission s Jurisdiction Over This Contract Dispute Is Uncertain.
There is no federal or state law clearly granting the Commission jurisdiction over
disputes in an interconnection agreement between an incumbent local exchange company and a
paging carrier, and the Commission does not appear to have a statutory obligation to entertain the
PageData Filing as a formal complaint.
17 Idaho Power Company, vs. Cogeneration, Inc.Case No. IPC-94-24 (1995), Order No. 25918 at p. 5.
18 Id. at pp.
19 Although Idaho statutes may be read to empower the Commission to deal with interconnection disputes generally,
the extent to which Idaho has asserted jurisdiction over wireless interconnection is completely unclear. The
boundary of state commissions' jurisdiction over wireless interconnection is uncertain; the FCC and courts have
found supreme law jurisdiction outside the 1996 Act. See, e.Iowa Utilities Bd. v. FCC, 120 F.3d 753 (8th Cir.
1997), affd in part and remanded AT&T Corp. v. Iowa Utils. Bd.119 S Ct 721 (1999120 F.3d at 800 n21, 820
39 (finding FCC authority to issue local competition rules of special concern to CMRS providers under sections
2(b) and 332( c) of the Act and granting motion to lift stay of section 51.703 as it applied to CMRS providers); TSR
Wireless, supra n14, at ~ 13 42 ("An additional basis for authority for the action we take here exists under
section 332 of the Act"
);
Developing a Unified Intercarrier Compensation Regime CC Docket No. 01-, Notice of
Proposed Rulemaking, FCC 01-132 (reI. Apr. 27, 2001) (seeking comment on the relationship between the CMRS
interconnection authority assigned to FCC under sections 201 and 332, and that granted to the states under sections
QWEST CORPORATION'S LIMITED RESPONSE TO JOSEPH B. MCNEAL d/b/a PAGEDATA'
COMPLAINT, P. 9
3. The FCC Has Recognized That a State Commission Has No Responsibility to
Decide an Interconnection Dispute If the Parties Have Provided A Dispute Resolution
Mechanism.
Even if there were a clear grant of jurisdiction to the Commission, the FCC has
recognized that a state commission may not have responsibility to decide a dispute under an
interconnection agreement if the parties have contractually agreed to a dispute resolution
mechanism:
We note that, in other circumstances, parties may be bound by dispute resolution
clauses in their interconnection agreement to seek relief in a particular fashion
and, therefore, the state commission would have no responsibility under section
252 to interpret and enforce an existing agreement. In this case, however, the
relevant interconnection agreements do not expressly specify how the disputes
shall be resolved.
4. Dismissal of the PageData Filing Is Supported By the Strong Public Policy
Favoring Arbitration and Alternative Dispute Resolution.
Idaho law strongly favors the enforcement of contractual arbitration clauses. Idaho has
enacted the Uniform Arbitration ACt.21 In a recent case, the Idaho Supreme Court stated:
(W)e recognize that arbitration is a favored remedy. AT&T Technologies, Inc.
Communications Workers of America 475 U.S. 643, 650, 89 L. Ed. 2d 648, 106
S. Ct. 1415 (1986). See Bingham County Comm 'v. Interstate Elec. Co.105
Idaho 36, 665 P.2d 1046 (1983) (Arbitration allows parties to settle their disputes
without expending time and unnecessary expense on needless litigation.). A court
reviewing an arbitration clause will order arbitration unless "it may be said with
positive assurance that the arbitration clause is not susceptible of an interpretation
that covers the asserted dispute.AT T Technologies, Inc., supra. Doubts are to
be "resolved in favor of coverage.Id; Local Union No.3 70 of Internt '1 Union of
Operating Engineers v. Morrison-Knudsen Co., Inc.786 F.2d 1356 (9th Cir.
251 and 252; noting FCC's authority for preemption of state entry and rate regulation under section 332(c)(3);
seeking comment on extent to which section 332 preempts state regulation of intrastate LEC-CMRS interconnection
and gives such authority to FCC). Id. ~~ 86-87.
20 In the Matter of Star power Communications, LLC, Petition for Preemption of Jurisdiction of the Virginia State
Corporation Commission Pursuant to Section 252(e)(5) of the Telecommunications Act of 1996, CC Docket No. 00-
, Memorandum Opinion and Order, FCC 00-216 (reI. June 14 2000).
21 Idaho Code ~~ 7-901 -- 7-922.
QWEST CORPORATION'S LIMITED RESPONSE TO JOSEPH B. MCNEAL d/b/a P AGEDA T A'
COMPLAINT, P. 10
1986), citing United Steelworkers of America v. Warrior and Gulf Navigation
Co.363 u.S. 574 582-4 L. Ed. 2d 1409, 80 S. Ct. 1347 (1960). See Iowa City
Community School Dist. v. Iowa City Educ. Ass '343 N.2d 139, 141 (Iowa
1983); Mayor v. Baltimore Fire Fighters, Local 734, 93 Md. App. 604, 613 A.2d
1023, 1026 (Md.App. 1992); Howard Co. Bd of Educ. v. Howard Co. Educ.
Ass 61 Md. App. 631 487 A.2d 1220 (Md.App. 1985); Mayor City Council
of Baltimore v. Baltimore City Fire Fighters, 49 Md. App. 60, 430 A.2d 99 (Md.
App. 1981), cert. denied, 291 Md. 771 (1981); West Fargo Pub. School Dist.
West Fargo Educ. Ass '259 N.W.2d 612, 620 (N.D. 1977); Corvallis School
Dist. v. Corvallis Educ. Ass 35 Ore. App. 531 , 581 P.2d 972 974 (Or. App.
1978). In further support of a strong policy in favor of arbitration, this Court has
expressly stated that public bodies in Idaho are bound by their agreements to
arbitrate disputes. Bingham County Comm 'v. Interstate Elec. Co.105 Idaho 36
665 P.2d 1046 (1983); Bear Lake Educ. Ass v. School Dist. , 116 Idaho 443
447, 776 P.2d 452, 456 (1989).22
This strong Idaho policy requires that the PageData be required to adhere to the
contractually provided dispute resolution clause. The Commission should there decline
jurisdiction and dismiss PageData s Filing.
Conclusion
For the foregoing reasons, Qwest respectfully requests that the Commission deny the
relief sought by PageData, as well as dismiss PageData s Complaint.
22 International Assoc. of Firefighters, Local No 672 v. City of Boise 136 Idaho 162; 30 P.3d 940; 2001 Ida. LEXIS
36 (2001).
QWEST CORPORATION'S LIMITED RESPONSE TO JOSEPH B. MCNEAL d/b/a PAGEDATA'
COMPLAINT, P. 11
DATED this 26th day of November, 2003.
Respectfully SubmittedVI~
William J. Batt
Marshall Batt & Fisher, LLP
U S Bank Plaza, 5th Floor
101 South Capital Blvd.
Boise, Idaho 83702
Adam L. Sherr
Qwest
1600 7th Avenue, Room 3206
Seattle, WA 98191
Attorneys for Qwest Corporation
QWEST CORPORATION'S LIMITED RESPONSE TO JOSEPH B. MCNEAL d/b/a PAGEDATA'
COMPLAINT, P. 12
CERTIFICATE OF SERVICE
I HEREBY CERTIFY that on this 26th day of November, 2003 , I served the foregoing
upon all parties of record in this proceeding as indicated below.
Jean Jewell
Idaho Public Utilities Commission
472 W. Washington Street
Boise, ID 83702-5983
) Certified Mail
) First Class Mail
[phone] (4Hand Delivery
) Facsimile
Joseph McNeal, d/b/a PageData
O. Box 15509
Boise, ID 83715
) Certified Mail
~First Class Mail
[phone] ) Hand Delivery
) Facsimile
QWEST CORPORATION'S LIMITED RESPONSE TO JOSEPH B. MCNEAL d/b/a PAGEDATA'
COMPLAINT, P. 13