20080627Cover Letter, Statement and Certificate.pdf

Mar S. Hobson
Attorney & Counselor
999 Main, Suite 1103
Boise, ID 83702
208-385-8666
10: 09
June 27,2008
VIA HAND DELIVRY "'.",~'
Ms. Jean Jewell, Secretary
Idaho Public Utilities Commission
472 West Washington Street
Boise,ID 83720-0074
Re: Qwest Corporation's Filg for Commission Approval of Non-Impaired Wire
Center Designations with Supporting Data; Affidavits of Robert Brigham and Rachel
Torrence, in support of Qwest Corporation's Petition in Case No. QWE- T -08-07
Dear Ms. Jewell:
Enclosed for filing with this Commission are Qwest Corporation's Filg for Commission
Approval of Non-Impaired Wire Center Designations with Supportig Data and the
Affidavits of Rachel Torrence and Robert Brigham in support of Qwest Corporation's
Petition for Commission Approval of Non-Impaired Wire Center Lists Pursuant to the
Triennial Review Remand Order ("Wire Center Petition"). The attachments to these
exhibits are termed "Highly Confidential" under the ters of the proposed Protective
Agreement, which was fied as Attachment B to the Wire Center Petition and which is based
on the language of an agreed model protective order that was adopted by several state
regulatory commissions in Qwest terrtory in recent years in similar actions. Qwest has
provided Highly Confidential redacted versions of cerain attachments, which presere the
confidentiality interests of competing CLECs while providing information to interenors to
evaluate Qwest s wire center listings herein..
The Highy Confidential attachments themselves are being provided separately and under seal
and are accompaned by an Attorney Certifcate. Qwest intends to sere these Highly
Confidential atta;chments on the Staff once its attorney has signed the proposed Protective
Agreement and the individual Staff members have executed the associated exhbits thereto.
Ms. Jean D. Jewell, Secretar
Idaho Public Utilities Commission
Page 2
Agreement and the individual Staff members have executed the associated exhibits thereto.
Intervening CLECs who sign the protective agreement and associated exhibits wil be provided
the redacted versions of the Highly Confidential documents together with the CLEC-specific
information pertaining to their own company.
Please let me know if you have any questions about this filing. Than you for your cooperation
in this matter.
Ver trly yours,~iJ~-i
Mar S. ¿¿bson
Enclosures
r
~'4)r
Mary S. Hobson
Attorney & Counselor
999 Main, Suite 1103
Boise, in 83702
208-385-8666
27 Áf'nO: 09
June 27, 2008
VIA HAND DELIVRY
PROPRIETARY AND HIGHLY CONFIDENTIAL
Ms. Jean Jewell, Secretary
Idaho Public Utilties Commission
472 West Washington Street
Boise,ID 83720-0074
Re: Confidential Attachments to the Affidavits of Robert Brigham and Rachel
Torrence, in support of Qwest Corporation's Petition in Case No. QWE- T -08-07
Dear Ms. Jewell:
Enclosed for filing with this Commission are three copies of the Highly Confidential
Attachments A, A (redacted) B, B (redacted), C, C (redacted) D and D (redacted) to the
Affidavit of Rachel Torrence and Highly Confidential Attachments A, A (redacted), B, B
(redacted) C, and D to the Affidavit of Robert Brigham. These affidavits are filed in support of
Qwest Corporation's Petition for Commission Approval of Non-Impaired Wire Center
Lists Pursuant to the Triennial Review Remand Order (Wire Center Petition) and Qwest
Corporation's Filg for Commission Approval on Non-Impaired Wire Center Designation
with Support Data, fied concurently with these affidavits and attachments. These documents
are termed "Highly Confidential" under the terms of the proposed Protective Agreement, which
was filed as Exhbit B to the Wire Center Petition and which is based on the language of an
agreed model protective order that was adopted by several state regulatory commissions in
similar actions in recent years.
Also enclosed is an Attorney Certifcate in support of this Highy Confidential filing.
Qwest is providing these Highy Confidential attachments with the understanding that they wil
be reviewed only by the Commissioners. All documents wil be disclosed to the Commission
Staff once its attorney has signed the proposed Protective Agreement and the individual Staff
members have executed the associated exhbits thereto. Interening CLECs who sign the
protective agreement and associated exhbits wil be provided the redacted versions of
Ms. Jean D. Jewell, Secretar
Idaho Public Utilties Commission
Page 2
the Highy Confidential documents together with the CLEC-specific information pertaining to
their own company.
Pursuant to the Commission's practice these attachments wil not be released for review by any
other person unless and until the Commission issues its order so directing the disclosure
following a hearng on the issue.
Than you for your cooperation in this matter.
Ver trly yours,
Enclosures
ATTORNEY'S CERTIFICATE E
QWEST CORPORATION 27 Á.M 10: 09
Docket No. QWE-T-08-07
This Cerificate is made pursuant to Rule 67 of the Idaho Public Utilities
Commission's Riles of Procedure I.D.A.P.A. 31.01.01000.
This Cerificate applies to the following:
Attachments marked "Highly Confidential" to the Affdavit of Rachel
Torrence:
Attachment A, Attachment A (redacted), Attachment B, Attachment B
(redacted), Attachment C, Attachment C (redacted), Attachment D,
Attachment D (redacted)
Attachments marked "Highly Confidential" to the Affdavit of Robert
Brigham:
Attachment A, Attachment A (redacted), Attachment B, Attachment B
(redacted), Attachment C and Attachment D
The information contained in these attachments is considered proprietary and
confidential due to the company-specific proprietary information peraining to
competitors in the Idaho telecommuncations market contained therein
The undersigned hereby asserts that she is familiar with the materal claimed not
to be available for public inspection, examination and copying, and that she, in good
faith, believes that there is a basis in law for that claim, namely that the information
contained therein constitutes a "trade secret" as defined in Idaho Code Section 48-801
and is by virte the Idaho Trade Secrets Act, Title 48, Chapter 8, Idaho Code subject to
protection.
DATED this 27th day of June, 2008.
~g~Mar S. llon
Attorney Representing
Qwest Corporation
Boise-169450.i 0029164-00012