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Home My WebLink About20070706Motion for Procedural Schedule Modification.pdfMolly O'Leary (ISB No. 4996) RICHARDSON & O'LEARY PLLC 515 North 2ih Street O. Box 7218 Boise, Idaho 83707 Telephone: 208.938.7900 Fax: 208.938.7904 Mail: moll richardsonandolear com Theodore A. Livingston Dennis G. Friedman MAYER, BROWN, ROWE & MAW LLP 71 South Wacker Drive Chicago, IL 60606-4637 Telephone: 312.782.0600 Fax: 312.706.8630 Mail: dfriedman erbrown.com Dan Foley General Attorney & Assistant General Counsel AT&T WEST P. O. Box 11010; 645 E. Plumb Lane, B132 Reno, Nevada 89520 Telephone: 775.333.4321 Fax: 775.333.2175 Mail: df6929 att.com '" L "~ I , .- " 'J ! , : i:?b , , , i :~., ; .. '".. , ':;; ':;,!" Attorneys for Complainant AT&T Communications of the Mountain States, Inc. vs. BEFORE THE IDAHO PUBLIC UTILITIES COMMISSION Complainant QWEST CORPORATION AT&T COMMUNICATIONS OF THE MOUNTAIN ) STATES , INC. Respondent. AT&T MOTION FOR PROCEDURAL SCHEDULE MODIFICATION Case No. QWE-06- AT&T'S MOTION FOR PROCEDURAL SCHEDULE MODIFICATION COMES NOW, AT&T ofthe Mountain States, Inc. (Plaintiff, hereafter AT&T) and by and through undersigned counsel hereby moves this Commission for a modification to the Procedural Schedule agreed to by the parties and ordered by the Commission on May 22, 2007 in Order No. 30319. AT&T requests this modification on the following grounds: One of its expert witnesses recently experienced a family death resulting in internal procedural delays; and AT&T has not received a finalized Protective Agreement from Qwest for execution and, consequently has not yet received the discovery documents that Qwest is retaining until execution of such an agreement. Settlement discussions between the parties are progressing and would benefit from additional time. AT&T has conferred with Peter Spivack, counsel for Qwest, and Mr. Spivack has stated that his client does not object to the following proposed modifications: PROCEDURAL TASK CURRENT DEADLINE PROPOSED DEADLINE AT&T's Direct Prefiled Testimony July 9 2007 July 30, 2007 Qwest's Reply Prefiled Testimony September 10 2007 October 1 2007 AT&T's Rebuttal Pre filed Testimony November 9, 2007 November 30, 2007 Summary Judgment Motions &November 30, 2007 December 21 , 2007 Discovery Cutoff Summary Judgment Oppositions December 21 , 2007 January 14 2008 Summary Judgment Replies January 11 2008 February 1 2008 Summary Judgment Hearing To be decided No change Evidentiary Hearing If necessary No change AT&T MOTION FOR PROCEDURAL SCHEDULE MODIFICATION - 2 For the foregoing reasons, AT&T respectfully requests this Commission to modify Order No. 30319 as set forth above. DATED this 6th day of July, 2007. RICHARDSON & O'LEARY, P.L.L.C. AT&T MOTION FOR PROCEDURAL SCHEDULE MODIFICATION - 3 CERTIFICATE OF SERVICE I HEREBY CERTIFY that on the 6th day of July, 2007 a true and correct copy ofthe within and foregoing AT&T'S MOTION FOR MODIFICATION OF PROCEDURAL SCHEDULE was filed with the Idaho Public Utilities Commission and parties as indicated below: Ms. Jean Jewell Commission Secretary Idaho Public Utilities Commission POBox 83720 Boise ID 83720-0074 K- Hand Delivery - U.S. Mail, postage pre-paid Facsimile Electronic Mail Mary S. Hobson 999 Main, Suite 1103 Boise, ID 83702 E-mail: mary .hobson~qwest.com - Hand Delivery S. Mail, postage pre-paid Facsimile 2L Electronic Mail Douglas R.M. Nazarian Hogan & Hartson 111 South Calvert St Baltimore MD 21202 E-mail: drmnazarian~hhlaw.com - Hand Delivery 2LU.S. Mail, postage pre-paid Facsimile 2L Electronic Mail Certificate of Service -