20101020Motion for Extension.pdf

Mary S. Hobson
Attorney & Counselor
999 Main, Suite 1103
Boise, ID 83702
208-385-8666
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IDAHO
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October 19,2010
VIA HAND DELIVRY
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 :fling with this Commission are an original and seven (7) copies of Qwest
Corporation's Motion for Extension of Time to Respond to Discovery.
If you have any questions, please contact me. Thank you for your cooperation in this
matter.
Very trly yours,
:!~¡rlz
Enclosures
cc Service List
Mary S. Hobson (ISB. No. 2142)
999 Main, Suite 1103
Boise, ID 83702
Tel: [phone]
mary.hob son(fg west. com
RECEIVED
20100£:T -19 PM 4: 51
IDAHO
UTILITIES
Adam L. Sherr
Corporate Counsel, Qwest
1600 7th Avenue, Room 1506
Seattle, W A 98191
Tel: [phone]
adam. sherr(fqwest.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
MOTION for EXTENSION of
TIME to RESPOND to DISCOVERY
Petitioner Qwest Corporation (Qwest) by and through its undersigned attorneys
moves this Commission for an order granting Qwest an additional seven (7) days in
which to respond to discovery propounded by Integra Telecom of Idaho, Inc.; Electric
Lightwave, LLC dba Integra Telecom; and Eschelon Telecom, Inc. dba Integra
(collectively referred to as "Integra"). Qwest requires this extension because some of
Qwests employees who are charged with responsibility of compiling the information
requested in the discovery, including Qwests witness Michael G. Wiliams, have been
required to attend to other regulatory dockets and have not had suffcient time to
complete the responses.
Motion for Extension of
Time to Respond to Discovery - 1 -
Procedural Order No. 32054 established October 20 as the deadline for Qwest to
respond to any discovery propounded by Intervenors or Staff. Qwest requests that that
date be extended to October 27. The undersigned has discussed this Motion with Staff,
Integra and 360networks (USA) Inc. and has been advised that no pary has an objection
to the extension. l!
Respectfully submitted this tL day of October, 2010.
~
Mar S. bson (ISB. No. 2142)
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
Motion for Extension of
Time to Respond to Discovery - 2 -
CERTIFICATE OF SERVICE
I do hereby cerify that a true and correct copy of the foregoing Motion for Extension of
Time to Respond to Discovery was served on the 19th day of October, 2010 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 ewellß!uc .state.id. us
Weldon. Stutzmnß!uc.daho.gov
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U. S. Mail
Overnght Delivery
Facsimle
Email
Douglas K, Denney
Integra Telecom, Inc.
1201 Lloyd Blvd., Suite 500
Portland, OR 97232
dkdenneyGyintegratelecom.com
Michel Singer Nelson
Associate General Counsel
360networks (USA) Inc.
370 Interlocken Blvd., Suite 600
Broomfield, CO 80021
mnelson(á360.net
Hand Delivery
U. S. Mail
Overnght Delivery
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.i Email
Hand Delivery
U. S. Mail
Overnight Delivery
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~ Email
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Mar S. bson
Attorney or Qwest Corporation