20080828Response to Staff Motion.pdf

Mar S. Hobson
Attorney & Counselor
999 Main, Suite 1103
Boise, ID 83702
208-385-8666
RECEiVEO
2008 AUG 21 PM i.: 53
tOAHO PUBLIC
UTlLlTteS COMM1SSION
August 27, 2008
VIA HAND DELIVERY
Jean D. Jewell, Secreta
Idaho Public Utilties Commission
472 West Washington
Boise,ID 83702-5983
RE: Docket No. QWE-T-08-04
Dear Ms. Jewell:
Enclosed for filing with this Commission are an original and seven (7) copies of QWEST
CORPORATION'S RESPONSE TO STAFF'S MOTION RE RESPONSIVE
COMMENTS. If you have any questions, please contact me. Than you for your
cooperation in this matter.
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Enclosures
cc Service List
Mar S. Hobson (ISB. No. 2142)
999 Main, Suite 1103
Boise, ID 83702
Tel: [phone]
mary.hobsonlfgwest.com
RECEIVED
200 AUG 21 PH i.: 5i.
IDAHO PUBLIC
UTILITiES COMMISSiON
Adam L. Sherr
Corporate Counsel, Qwest
1600 7th Avenue, Room 3206
Seattle, WA 98191
Tel: [phone]
adam.sherrlfqwest.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 RESPONSE
TO STAFF'S MOTION RE RESPONSIVE
COMMENTS
Qwest Corporation ("Qwest") by and through its attorneys of record, responds to
Staffs Motion in Response to Qwest's Motion for Permission to File Responsive
Comments filed in the above-referenced docket on August 12, 2008.
Staffs motion requests that the Commission allow Staff and interenors the
opportty to file a pleading in response to Qwests filing, which was the subject of
Qwests motion fied on August 4,2008 and is to be submitted September 15,2008.
Staff states that it makes no objection to Qwests motion but requests that the responsive
filing by Staff and intervenors be due "on or before October 17, 2008."
Qwest Corporation's Response to Staffs Motion re Responsive Comments - 1 -
In recent informal discussions with Staff, Qwest now understads that Staffwould
prefer to extend the deadline for the purposed Staff and interenor responses to October
31, 2008. Qwest has no objection to permitting Staff and intervenors the opportnity to
fie responsive pleadings on or before October 31, however Qwest asks that the
Commission schedule oral arguent on the issues addressed in Qwest's comments and
the responses fied by Staff and intervenors. Based upon the above-mentioned informal
discussions with Staff, Qwest undertands that Staff supports Qwests request for oral
arguent.
Dated this 27th day of August, 2008.
Mar S. bson (ISB. No. 2142)
999 Mai . Suite 1103
Boise, ID 83702
Adam L. Sher
Corporate Counsel, Qwest
1600 7th Avenue, Room 3206
Seattle, W A 98191
Attorneys for Qwest Corporation
Qwest Corporation's Response to Staffs Motion re Responsive Comments - 2-
CERTIFICATE OF SERVICE
I do hereby certify that a true and correct copy of the foregoing Response to Staff's
Motion re Responsive Comments was served on the 27th day of August, 2008 on the
following individuals:
Jean D. Jewell
Weldon B. Stutzmn
Idaho Public Utilities Commssion
472 West Washington Street
P.O. Box 83720 .
Boise, il 83702
j j ewell(ßuc.state.id. us
i Hand Delivery
U. S. Mail
Overnght Delivery
Facsimile
Email
Douglas K, Denney
Integra Telecom
730 Second Avenue S., Suite 900
Minneapolis, MN 55402
dkdenneyßlintegratelecom.com
Michel Singer Nelson
Associate General Counsel
360networks (USA) Inc.
867 Coal Creek Circle, Suite 160
Louisvile, CO 80027
mnelsonßl360.net
Hand DeliveryiU. S. Mail
Overnght Delivery
FacsimleiEmail
Hand DeliveryiU. S. Mail
Overnght Delivery
FacsimileiEmail
Hand DeliveryiU. S. Mail
Overnght Delivery
Facsimle--Email
Gregory L. Rogers
Senor Corporate Counsel
Level 3 Communcations LLC
1025 Eldorado Boulevard
Broomfeld, CO 80021
greg.rogersßlleve13 .com
~Attorney for Qwest Corporation
Qwest Corporation's Response to.Staffs Motion re Responsive Comments - 3 -