20080805Motion to File Responsive Comments.pdf

Mar S. Hobson (ISB. No. 2142)
999 Main, Suite 1103
Boise, ID 83702
Tel: [phone]
mar.hobsonCiqwest.com
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Adam L. Sher
Corporate Counsel, Qwest
1600 7th Avenue, Room 3206
Seattle, WA 98191
Tel: [phone]
adam.sherCiqwest.com
Attorneys for Qwest Corporation
BEFORE THE IDAHO PUBLIC UTILITIES COMMISSION
In Re WITHDRAWAL of QWEST
COPORATION'S STATEMENT OF
GENERAL y AVAILABLE TERMS AND
CONDITIONS
Case No. QWE-T-08-04
QWEST CORPORATION'S MOTION FOR
PERMISSION TO FILE RESPONSIV
COMMENTS
Qwest Corporation ("Qwest") by and through its attorneys of record, moves this
Commission for permission to respond to the comments filed in the above-referenced
docket by interenors and the Commission Staff. Qwest proposes to submit its
responsive comments on or before September 15, 2008.
This Motion is made on the ground and for the reasons that the comments of Staff
and intervenors raise intermingled questions of law and regulatory policy, which have not
Qwest s Motion to File
Responsive Comments - 1 -
been clearly delineated. Qwest believes that its response wil assist the Commission in
identifyng the key issues and in using its modified procedure to resolve those issues.
Dated this 4th day of August, 2008.
Respectfully submitted,
/ti/lt/i¡ ..t lk/-_:/ 1Mar S. Ho~son (ISB. No. 2142)
999 Main. Suite 1103
Boise, ID 83702
Adam L. Sher
Corporate Counsel, Qwest
1600 7th Avenue, Room 3206
Seattle, W A 98191
Attorneys for Qwest Corporation
Qwests Motion to File
Responsive Comments - 2 -
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CERTIFICATE OF SERVICE
I do hereby certify that a tre and correct copy of the foregoing Motion for Permission
to File Responsive Comments was served on the 4th day of August, 2008 on the following
individuals:
Jean D. Jewell
Weldon B. Stutzman
Idaho Public Utilities Commssion
472 West Washington Street
P.O. Box 83720
Boise, il 83702
j j ewellt!uc. state.id. us
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Douglas K, Denney
Integra Telecom
730 Second Avenue S., Suite 900
Minneapolis, MN 55402
dkdenney(fintegratelecom.com
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Michel Singer Nelson
Associate General Counsel
360networks (USA) Inc.
867 Coal Creek Circle, Suite 160
Louisville, CO 80027
mnelson(q),60.net
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Gregory L. Rogers
Senior Corporate Counsel
Level 3 Communcations LLC
1025 Eldorado Boulevard
Broomfeld, CO 80021
greg.rogers(flevel3.com
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At1:81-6~
MarS. H son
Attorney; or Qwest Corporation
Qwest s Motion to File
Responsive Comments - 3 -