20091008Motion for Extension.pdf

Mar S. Hobson
Attorney & Counselor
999 Main, Suite 1103
Boise, ID 83702
208-385-8666
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28U9 OCT - ì PH~: 54
HO r.,u,Pl .1'"IDA i F 1;:;:-\" ,
UTILITIES COMMISS¡O~i
October 7, 2009
VIA HAND DELIVERY
Jean D. Jewell, Secretar
Idaho Public Utilities 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 MOTION FOR EXTENSION OF COMMENT DEADLINE
TO EXPLORE SETTLEMENT. If you have any questions, please contact me. Than
you for your cooperation in this matter.
Ver try yourlt
#
Enclosures
cc Service List
Mar S. Hobson (ISB. No. 2142)
999 Main, Suite 1103
Boise, ID 83702
Tel: [phone]
mary.hobson(igwest.com
RECEI
2009 OCT -7 PH 4: 54
UT1Lf¡DAHO PI,I,¡:i;I, Ir',T/r:s c""- --I',"'..' OMti!sn1o',. '.0, iN
Adam L. Sherr
Corporate Counsel, Qwest
1600 7th Avenue, Room 1506
Seattle, W A 98191
Tel: [phone]
adam.sherr(iqwest.com
Attorneys for Qwest Corporation
BEFORE THE IDAHO PUBLIC UTILITIES COMMISSION
In Re WITHDRAWAL of QWEST
COPORATION'S STATEMENT OF
GENERALY AVAILABLE TERMS AND
CONDITIONS
Case No. QWE-T-08- 04
Qwest Corporation's Motion for Extension
of Comment Deadline to Explore
Settlement
On August 5, 2009, the Commission entered Order No. 30873, which set a seres
of deadlines for Qwest, Staff, and Interenors to file comments concerning Qwests
Petition in this docket and the Report of Liberty Consulting, which had been placed in the
record by stipulation for purose of comment. The Comments of Qwest Corporation
were filed on August 14, 2009. Thereafter, and pursuant Order No. 30872, Staff and
Integra Telecom filed their respective responses on September 11, 2009. Qwests
comments in reply to those of the Staff ard Integra are to be filed, pursuant to the
Commission's Order, on October 9,2009.
However, on September 30, 2009, representatives of Qwest met with members of
Staff and a representative of Integra Telecom to discuss possible areas of common
Qwest Motion for Extension of
Comment Deadlie to ExploreSettlement - 1 -
understanding and areas of potential compromise concerning the provisions of Qwest s
Pedormance Assurance Plan (PAP). Legal counsel for Intervenor 360Networks
paricipated by telephone. Based on those discussions, which were preliminar but
encouraging, Qwest now moves this Commission for an Order extending Qwest's
October 9,2009 comment deadline to allow Staff and the paries to pursue settlement
discussions.
The undersigned counsel for Qwest reviewed this proposed extension of the
comment deadline with the representatives of the Intervenors and Staff at the meeting on
September 30; there was no objection
Based on the foregoing, Qwest requests that the Commission vacate the comment
deadline presently set for October 9,2009.
Respectfully submitted this 7th day of October, 2009.
~t::¡l:!¡fÑ:42)
999 Main. Suite 1103
Boise, ID 83702
Adam L. Sherr
Corporate Counsel, Qwest
1600 7th Avenue, Room 1506
Seattle, W A 98191
Attorneys for Qwest Corporation
Qwest Motion for Extension of
Comment Deadle to ExploreSettlement - 2 -
CERTIFICATE OF SERVICE
I do hereby certify that a tre and correct copy of the foregoing Qwest Motion for
Extension of Comment Deadle to Explore Settlement was served on the 7th day of
October, 2009 on the following individuals:
Jean D. Jewell
Weldon B. Stutzman
Idaho Public Utilties Commssion
472 West Washington Street
P.O. Box 83720
Boise, il 83702
j j ewell(fpuc.state.id. us
.. Hand Delivery
U. S. Mail
Overnght Delivery
Facsimle
Email
Douglas K, Denney
Integra Telecom
6160 Golden Hils Drive
Golden Valley, MN 55416
dkdenney(fintegratelecom.com
Hand Delivery
X U. S. Mail
Overnght Delivery
Facsimile
i Email
Michel Singer Nelson
Associate General Counsel
360networks (USA) Inc.
867 Coal Creek Circle, Suite 160
Louisvile, CO 80027
mnelson(f360 .net
Hand Delivery
U. S. Mail
Overnght Delivery
Facsimle
i Email
Gregory L. Rogers
Senior Corporate Counsel
Level 3 Communcations LLC
1025 Eldorado Boulevard
Broomfeld, CO 8002 1
greg.rogers(fleve13 .com
Hand Delivery
U. S. Mail
Overnght Delivery
Facsimle
~ Email
Ai ~M~S.~
Attorney r Qwest Corporation
Qwest Motion for Extension of
Comment Deadlie to ExploreSettlement - 3 -