20080812Motion in Response.pdf

WELDON B. STUTZMAN
DEPUTY ATTORNEY GENERALL
IDAHO PUBLIC UTILITIES COMMISSION
472 WEST WASHINGTON STREET
PO BOX 83720
BOISE, ID 83720-0074
Idaho Bar No. 3283
Tele: [phone]
Fax: [phone]
E-mail: weldon.stutzmanaYpuc.daho.gov
ll: 36
Attorney for Commission Staff
BEFORE THE IDAHO PUBLIC UTILITIES COMMISSION
IN THE MATTER OF THE PETITION OF
QWEST CORPORATION REQUESTING
AUTHORIZATION TO WITHDRAW ITS
STATEMENT OF GENERALLY
AVAILABLE TERMS AND CONDITIONS
)
) CASE NO. QWE- T -08-04
)
) STAFF'S MOTION IN
) RESPONSE TO QWEST'S
) MOTION FOR PERMISSION TO
) FILE RESPONSIVE COMMENTS
On August 4, 2008, Qwest Corporation filed a response to Staffs Motion to Extend
the Comment Period, and also fied a Motion for Permission to File Responsive Comments in
this case. In its Motion, Qwest contends that initial comments by Staff and intervenors raise
intermingled questions of law and regulatory policy which have not been clearly delineated.
Qwest asked the Commission grant it leave to fie responsive comments on or before September
15,2008.
Staff has no objection to Qwests Motion for Permission to File Responsive
Comments, but moves the Commission for permission for Staff and intervenors to fie responsive
briefs to Qwests brief to be filed on September 15, 2008. In its initial comments, Staff did not
address the legal issues Qwest now plans to address in responsive comments, nor were the issues
fully addressed by the intervenors. Accordingly, Staff requests that the Commission allow Staff
and intervenors to fie a brief in response to Qwests filing on September 15, 2008. Staff
requests that the responsive filing by Staff and intervenors be due on or before October 17, 2008.
STAFF'S MOTION IN REPONSE TO QWEST MOTION
FOR PERMISSION TO FILE RESPONSIVE COMMENTS 1
Staff respectfully requests that the Commission issue a procedural order establishing
a deadline for Qwest to fie its brief on September 15, 2008, and for Staff and intervenors to fie
responsive briefs on or before October 17,2008.
Respectfully submitted this / i. f' day of August 2008.
J1~r-ì
Weldon B. Stutzman
Deputy Attorney General
blslN :QWE- T -08-04_ Staff Response
STAFF'S MOTION IN REPONSE TO QWEST MOTION
FOR PERMISSION TO FILE RESPONSIVE COMMENTS 2
CERTIFICATE OF SERVICE
I HEREBY CERTIFY THAT I HAVE THIS 12th DA Y OF JULY 2008,
SERVED THE FOREGOING STAFF'S MOTION IN RESPONSE TO QWEST'S
MOTION FOR PERMISSION TO FILE RESPONSIVE COMMENTS, IN CASE
NO. QWE-T-08-4, BY MAILING A COPY THEREOF, POSTAGE PREPAID, TO THE
FOLLOWING:
MARY S HOBSON
QWEST CORPORATION
999 MAIN ST, SUITE 1103
BOISE ID 83702
E-MAIL: mar.hobson!!qwest.com
ADAMLSHERR
CORPORATE COUNSEL
QWEST CORPORATION
1600 7TH AVE, ROOM 3206
SEATTLE WA 98191
E-MAIL: adam.sherr!!gwest.com
MICHEL SINGER-NELSON
ASSOCIATE GENERAL COUNSEL
360NETWORKS (USA) INC
867 COAL CREEK CIRCLE, SUITE 160
LOUISVILLE CO 80027
E-MAIL: mnelson!!360.net
DOUGLAS K DENNEY
DIRECTOR COSTS & POLICY
INTEGRA TELECOM
730 SECOND AVE SOUTH, SUITE 900
MINEAPOLIS MN 55402
E-MAIL: dkdenney!!integratelecom.com
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SECRETARY
CERTIFICATE OF SERVICE