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PLEASE DESCRIBE YOUR PROFESSIONAL EXPERIENCE.
Prior to my current position with asl Consulting, I was a Senior Executive Staff
Member in MCI WorldCom s ("MCIW") National Public Policy Group. In this
position I was responsible for providing public policy expertise in key cases
across the country and for managing external consultants for MCIW's state public
policy organization. In certain situations , I also provided testimony in regulatory
and legislative proceedings.
Prior to my position with MCIW in Denver, I was an Executive Staff Member II at
MCI Telecommunications ("MCI") World Headquarters in Washington D.C..
that position I managed economists, external consultants, and provided training
and policy support for regional regulatory staffs. Prior to that position I was a
Senior Manager in MCI'Regulatory Analysis Department, which providedsupport in state regulatory and legislative matters to the various operating
regions of MC!. In that position I was given responsibility for assigning resources
from our group for state regulatory proceedings throughout the United States. At
the same time, prepared and presented testimony on various
telecommunications issues before state regulatory and legislative bodies. I was
also responsible for managing federal tariff reviews and presenting MCI's position
on regulatory matters to the Federal Communications Commission. Prior to my
assignment in the Regulatory Analysis Department, I was the Senior Manager of
Economic Analysis and Regulatory Policy in the Legal , Regulatory and
Legislative Affairs Department for the Midwest Division of MC!. In that position
developed and promoted regulatory policy within what was then a five-state
operating division of MC!. I promoted MCI policy positions through negotiations,
testimony and participation in industry forums.
Prior to my positions in the Midwest, I was employed as Manager of Tariffs and
Economic Analysis with MCI's West Division in Denver, Colorado. In that
position I was responsible for managing the development and application of
MCI's tariffs in the fifteen MCI West states. I was also responsible for managing
regulatory dockets and for providing economic and financial expertise in the
areas of discovery and issue analysis. Prior to joining the West Division , I was a
Financial Analyst III and then a Senior Staff Specialist with MCI's Southwest
Division in Austin, Texas. In those positions, was responsible for the
management of regulatory dockets and liaison with outside counsel. I was also
responsible for discovery, issue analysis, and for the development of working
relationships with consumer and business groups. Just prior to joining MCI
was employed by the Texas Public Utility Commission as a Telephone RateAnalyst in the Engineering Division responsible for examining
Exhibit 101
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telecommunications cost studies and rate structures.
I was employed as an Economic Analyst with the Public Utility Commissioner of
Oregon from July, 1983 to December, 1984. In that position , I examined and
analyzed cost studies and rate structures in telecommunications rate cases and
investigations. I also testified in rate cases and in private and public hearingsregarding telecommunications services. Before joining the Oregon
Commissioner s Staff I was employed by the Bonneville Power Administration
(United States Department of Energy) as a Financial Analyst, where I made total
regional electric use forecasts and automated the Average System Cost Review
Methodology. Prior to joining the Bonneville Power Administration I held
numerous positions of increasing responsibility in areas of forest management for
both public and private forestry concerns.
PLEASE DESCRIBE YOUR EDUCATIONAL CREDENTIALS.
I received a Bachelor of Science degree from Oregon State University and a
Master of Management degree in Finance and Quantitative Methods from
Willamette University s Atkinson Graduate School of Management. I have also
attended numerous courses and seminars specific to the telecommunications
industry, including the NARUC Annual and Advanced Regulatory Studies
Program.
WHAT ARE YOUR CURRENT RESPONSIBILITIES?
Effective April 1 , 2000 I joined QSI Consulting as Senior Vice President and
Partner. In this position I provide analysis and testimony for QSl's many clients.The deliverables include written and oral testimony, analysis of rates, cost
studies and policy positions, position papers, presentations on industry issues
and training.
PLEASE IDENTIFY THE JURISDICTIONS IN WHICH YOU HAVE TESTIFIED.
I have filed testimony or comments on telecommunications issues in the following
44 states: Alabama , Arizona, Arkansas, California, Colorado, Connecticut,
Delaware, Georgia, Florida , Idaho , Illinois, Indiana, Iowa, Kansas , Kentucky,
Louisiana Maryland, Massachusetts , Michigan, Minnesota , Mississippi
Montana, Nebraska, Nevada, New Hampshire, New Jersey, New Mexico, New
York, North Carolina, North Dakota , Ohio Oklahoma, Oregon, Pennsylvania,
Rhode Island , South Carolina , South Dakota, Tennessee, Texas, Utah
Washington, West Virginia , Wisconsin and Wyoming. I have also filed comments
with the FCC and made presentations to the Department of Justice.
Exhibit 101
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I have testified or presented formal comments in the following proceedings
and forums:
Alabama:
October 18, 2000; Docket No. 27867; Adelphia Business Solutions Arbitration
with BeliSouth Telecommunications; Direct Testimony on Behalf of Adelphia.
January 31 , 2001; Docket No. 27867; Adelphia Business Solutions Arbitration
with BeliSouth Telecommunications; Rebuttal Testimony on Behalf of Adelphia.
Arkansas:
September 7, 2004; Docket No. 04-0999-U; In the Matter of Level 3 Petition for
Arbitration with Southwestern Bell Telephone, L.P. D/B/A SBC Arkansas; Direct
Testimony on Behalf of Level 3.
Arizona:
September 23, 1987; Arizona Corporation Commission Workshop on Special
Access Services; Comments on Behalf of MCI.
August 21 1996; Affidavit in Opposition to USWC Motion for Partial SummaryJudgment; No. CV 95-14284 No. CV-96-03355, No. CV-96-03356
(consolidated); On Behalf of MCI.
October 24, 1997; Comments to the Universal Service Fund Working Group;
Docket No. R-0000-97-137; On Behalf of MC!.
May 8, 1998; Comments to the Universal Service Fund Working Group; Docket
No.0000-97-137; On Behalf of MC!.
November 9, 1998; Docket No. T-03175A-97-0251; Application of MClmetro
Access Transmission Services, Inc. to Expand It's CCN to Provide IntraLA T A
Services and to Determine that Its IntraLA T A Services are Competitive; Direct
Testimony on Behalf of MCI WorldCom, Inc.
September 20, 1999; Docket No. T-00000B-97-238; USWC OSS Workshop;
Comments on Behalf of MCI WorldCom , Inc.
January 8,2001; Docket Nos. T-03654A-00-0882 , T-01051 B-00-0882; Petition of
Level 3 Communications, LLC, for Arbitration with Qwest Corporation; Direct
Testimony on Behalf of Level 3.
Exhibit 101
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February 20 2001; Superior Court of Arizona; Count of Maricopa; ESI Ergonomic
Solutions, LLC, Plaintiff, vs. United Artists Theatre Circuit; No. CV 99-20649;
Affidavit on Behalf of United Artists Theatre Circuit.
September 2, 2001; Docket No. T-00000A-00-0194 Phase II - A; Investigation
into Qwest's Compliance with Wholesale Pricing Requirements for Unbundled
Network Elements and Resale Discounts; Rebuttal Testimony on Behalf of
WorldCom, Inc.
January 9, 2004; Docket No. T-00000A-03-0369; In the Matter of ILEC
Unbundling Obligations as a Result of the Federal Triennial Review Order; Direct
Testimony on Behalf of WorldCom, Inc. (MCI).
November 18, 2004; Docket No. T-01051 B-0454; In the Matter of Qwest
Corporation Amended Renewed Price Regulation Plan; Direct Testimony on
Behalf of Time Warner Telecom , Inc.
July 15 , 2005; Docket No. T -03654-05-0350, T -01051 B-05-0350; I n the Matter of
Level 3 Communications, LLC Petition for Arbitration with Qwest Corporation
Direct Testimony on Behalf of Level 3.
Arkansas:
September 7 , 2004; Docket No. 04-099-U; In the Matter of Level 3 Petition for
Arbitration Pursuant to Section 252(b) with Southwestern Bell Telephone, L.
D/B/A SBC Arkansas; Direct Testimony on Behalf of Level 3 Communications
LLC.
California:
August 30 , 1996; Application No. 96-08-068; MCI Petition for Arbitration with
Pacific Bell; Direct Testimony on Behalf of MC!.
September 10 , 1996; Application No. 96-09-012; MCI Petition for Arbitration with
GTE California, Inc.; Direct Testimony on Behalf of MC!.
June 5, 2000; Docket No. AOO04037; Petition of Level 3 Communications for
Arbitration of an Interconnection Agreement with Pacific Bell Telephone
Company; Direct Testimony on Behalf of Level 3 Communications, LLC.
Exhibit 101
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June 1 , 2004; Docket No. A.04-06-004; Petition of Level 3 Communications for
Arbitration with SBC; Direct Testimony on Behalf of Level 3 Communications
LLC.
Colorado:
December 1 , 1986; Investigation and Suspension Docket No. 1720; Rate Case of
Mountain States Telephone and Telegraph Company; Direct Testimony on
Behalf of MCI.
October 26, 1988; Investigation and Suspension Docket No. 1766; Mountain
States Telephone and Telegraph Company s Local Calling Access Plan; Direct
Testimony of Behalf of MC!.
September 6, 1996; MClmetro Petition for Arbitration with U S WEST
Communications, Inc.; Docket No. 96A-366T (consolidated); Direct Testimony on
Behalf of MCI.
September 17, 1996; MClmetro Petition for Arbitration with U S WEST
Communications, Inc.; Docket No. 96A-366T (consolidated); Rebuttal Testimony
on Behalf of MCI.
September 26, 1996; Application of U S WEST Communications , Inc. To ModifyIts Rate and Service Regulation Plan; Docket No. Docket No. 90A-665T
(consolidated); Direct Testimony on Behalf of MC!.
October 7 , 1996; Application of U S WEST Communications, Inc. To Modify ItsRate and Service Regulation Plan; Docket No. Docket No. 90A-665T
(consolidated); Rebuttal Testimony on Behalf of MCI.
July 18, 1997; Complaint of MCI to Reduce USWC Access Charges to EconomicCost; Docket Nos. 97K-237T, 97F-175T (consolidated) and 97F-212T
(consolidated); Direct Testimony on Behalf of MC!.
August 15, 1997; Complaint of MCI to Reduce USWC Access Charges to
Economic Cost; Docket Nos. 97K-237T, 97F-175T (consolidated) and 97F-212T
(consolidated); Rebuttal Testimony on Behalf of MC!.
March 10, 1998; Application of WorldCom , Inc. for Approval to Transfer Control
of MCI to WorldCom, Inc.; Docket No. 97A-494T; Supplemental Direct Testimony
on Behalf of MC!.
Exhibit 101
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March 26, 1998; Application of World Com , Inc. for Approval to Transfer Control
of MCI to WorldCom , Inc.; Docket No. 97A-494T; Rebuttal Testimony on Behalf
of MC!.
May 8, 1998; Application of WorldCom , Inc. for Approval to Transfer Control of
MCI to WorldCom , Inc.; Docket No. 97 A-494T; Affidavit in Response to GTE.
November 4, 1998; Proposed Amendments to the Rules Prescribing IntraLA T A
Equal Access; Docket No. 98R-426T; Comments to the Commission on Behalf of
MCI WorldCom and AT&T Communications of the Mountain States, Inc.
May 13, 1999; Proposed Amendments to the Rules on Local Calling Area
Standards; Docket No. 99R-128T; Oral Comments before the Commissioners on
Behalf of MCIW.
January 4, 2001; Petition of Level 3 Communications, LLC for Arbitration with
Qwest Corporation; Docket No. 00B-601T; Direct Testimony on Behalf of Level 3.
January 16, 2001; Petition of Level 3 Communications , LLC for Arbitration with
Qwest Corporation; Docket No. 00B-601 T; Rebuttal Testimony on Behalf of Level
January 29, 2001; Qwest Corporation , Inc., Plaintiff, v. IP Telephony, Inc.Defendant. District Court, City and County of Denver, State of Colorado; Case
No. 99CV8252; Direct Testimony on Behalf of IP Telephony.
June 27 , 2001; US WEST Statement of Generally Available Terms and
Conditions; Docket No. 991-577T; Direct Testimony on Behalf of Covad
Communications Company, Rhythms Links, Inc., and New Edge Networks, Inc.
January 26, 2004; Regarding the Unbundling Obligations of ILECs Pursuant to
the Triennial Review Order; Docket No. 031-478T; Direct Testimony on Behalf of
WorldCom, Inc. (MCI).
February 18 , 2005; Regarding Application of Qwest for Reclassification and
Deregulation of Certain Products and Services; Docket No. 04A-411 T; Direct
Testimony on Behalf of Time Warner Telecom.
July 11 , 2005; Petition of Level 3 Communications, LLC for Arbitration with
Qwest Corporation; Docket No. 05B-210T; Direct Testimony on Behalf of Level 3.
Exhibit 101
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Connecticut:
November 2, 2004; Petition of Level 3 Communications, LLC for Arbitration
Pursuant to Section 252(b) with Southern New England Telephone Company
d/b/a/ SBC Connecticut; Level 3/SNET Arbitration; Direct Testimony on Behalf of
Level 3 Communications , LLC.
Delaware:
February 12 , 1993; Diamond State Telephone Company s Application for a Rate
Increase; Docket No. 92-47; Direct Testimony on Behalf of MC!.
Florida:
July 1 1994; Investigation into IntraLATA Presubscription; Docket No. 930330-
TP; Direct Testimony on Behalf of MC!.
October 5 , 2000; Petition of Level 3 for Arbitration with BeliSouth; Docket No.
000907-TP; Direct Testimony On Behalf of Level
October 13 , 2000; Petition of BeliSouth for Arbitration with US LEC of Florida
Inc.; Docket No. 000084-TP; Direct Testimony On Behalf of US LEC.
October 27 , 2000; Petition of BeliSouth for Arbitration with US LEC of Florida
Inc.; Docket No. 000084-TP; Rebuttal Testimony On Behalf of US LEC.
November 1 , 2000; Petition of Level 3 for Arbitration with BeliSouth; Docket No.
000907-TP; Rebuttal Testimony On Behalf of Level 3.
June 11 , 2004; Petition of KMC Telecom for Arbitration with Sprint
Communications; Docket No. 031047-TP; Direct Testimony on Behalf of KMC
Telecom III, L., KMC Telecom V , Inc., and KMC Data, L.
July 9 2004; Petition of KMC Telecom for Arbitration with Sprint
Communications; Docket No. 031047-TP; Rebuttal Testimony on Behalf of KMC
Telecom III, L., KMC Telecom V, Inc., and KMC Data, L.
Georgia:
December 6, 2000; Docket No. 12645-U; Petition of Level 3 for Arbitration with
BeliSouth; Direct Testimony on Behalf of Level 3.
Exhibit 101
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December 20, 2000; Docket No. 12645-U; Petition of Level 3 for Arbitration with
BeliSouth; Rebuttal Testimony on Behalf of Level 3.
Idaho:
November 20, 1987; Case No. U 1150 1; Petition of MCI for a Certificate of
Public Convenience and Necessity; Direct Testimony on Behalf of MC!.
March 17 , 1988; Case No. U 1500 177; Investigation of the Universal Local
Access Service Tariff; Direct Testimony on Behalf of MC!.
April 26, 1988; Case No. U 1500 177; Investigation of the Universal Local
Access Service Tariff; Rebuttal Testimony on Behalf of MCI.
November 25, 2002; Case No. GNR-02-16; Petition of Potlatch , CenturyTel
the Idaho Telephone Association for Declaratory Order Prohibiting the Use of
Virtual" NXX Calling; Comments/Presentation on Behalf of Level 3, AT&T
WorldCom , and Time Warner Telecom.
Illinois:
January 16, 1989; Docket No. 83-0142; Appropriate Methodology for Intrastate
Access Charges; Rebuttal Testimony Regarding Toll Access Denial on Behalf of
MC!.
February 16, 1989; Docket No. 83-0142; Appropriate Methodology for Intrastate
Access Charges; Testimony Regarding ICTC's Access Charge Proposal on
Behalf of MCI.
May 3, 1989; Docket No. 89-0033; Illinois Bell Telephone Company s Rate
Restructuring; Direct Testimony on Behalf of MC!.
July 14, 1989; Docket No. 89-0033; Illinois Bell Telephone Company s Rate
Restructuring; Rebuttal Testimony on Behalf of MCI.
November 22, 1989; Docket No. 88-0091; IntraMSA Dialing Arrangements;
Direct Testimony on Behalf of MC!.
February 9, 1990; Docket No. 88-0091; IntraMSA Dialing Arrangements; Rebuttal
Testimony on Behalf of MC!.
Exhibit 101
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November 19, 1990; Docket No. 83-0142; Industry presentation to the
Commission re Docket No. 83-0142 and issues for next generic access docket;
Comments re the Imputation Trial and Unitary Pricing/Building Blocks on Behalf
of MC!.
July 29 , 1991; Case No. 90-0425; Presentation to the Industry Regarding MCI'
Position on Imputation.
November 18, 1993; Docket No. 93-0044; Complaint of MCI and LDDS re Illinois
Bell Additional Aggregated Discount and Growth Incentive Discount Services;
Direct Testimony on Behalf of MCI and LDDS.
January 10 , 1994; Docket No. 93-0044; Complaint of MCI and LDDS re Illinois
Bell Additional Aggregated Discount and Growth Incentive Discount Services;
Rebuttal Testimony on Behalf of MCI and LDDS.
May 30, 2000; Docket No. 00-0332; Level 3 Petition for Arbitration to Establishand Interconnection Agreement with Illinois Bell Telephone Company; Direct
Testimony on Behalf of Level (3) Communications, LLC.
July 11 , 2000: Docket No. 00-0332; Level 3 Petition for Arbitration to Establishand Interconnection Agreement with Illinois Bell Telephone Company;
Supplemental Verified Statement on Behalf of Level (3) Communications, LLC.
June 22, 2004; Docket No. 04-0428; Level 3 Petition for Arbitration to Establishan Interconnection Agreement with Illinois Bell Telephone Company; Direct
Testimony on Behalf of Level (3) Communications, LLC.
September 3, 2004; Docket No. 04-0428; Level 3 Petition for Arbitration to
Establish an Interconnection Agreement with Illinois Bell Telephone Company;
Direct Testimony on Behalf of Level (3) Communications, LLC.
Indiana:
October 28, 1988; Cause No. 38561; Deregulation of Customer Specific
Offerings of Indiana Telephone Companies; Direct Testimony on Behalf of MC!.
December 16, 1988; Cause No. 38561; Deregulation of Customer Specific
Offerings of Indiana Telephone Companies; Direct Testimony on Behalf of MCI
Regarding GTE.
April 14 , 1989; Cause No. 38561; Deregulation of Customer Specific Offerings of
Indiana Telephone Companies; Direct Testimony on Behalf of MCI Regarding
Staff Reports.
Exhibit 101
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June 21 , 1989; Cause No. 37905; Intrastate Access Tariffs -- Parity with Federal
Rates; Direct Testimony on Behalf of MC!.
June 29, 1989; Cause No. 38560; Reseller Complaint Regarding 1 + IntraLATA
Calling; Direct Testimony on Behalf of MC!.
October 25, 1990; Cause No. 39032; MCI Request for IntraLA T A Authority;
Direct Testimony on Behalf of MCI.
April 4, 1991; Rebuttal Testimony in Cause No. 39032 re MCI's Request for
IntraLATA Authority on Behalf of MC!.
September 2 , 2004; Cause No. 42663-INT -01; In the Matter of Level 3
Communications, LLC Petition for Arbitration with SBC Indiana; Direct Testimony
on Behalf of Level 3 Communications, LLC.
October 5, 2004; Cause No. 42663-INT-01; In the Matter of Level 3
Communications, LLC Petition for Arbitration with SBC Indiana; Rebuttal
Testimony on Behalf of Level 3 Communications, LLC.
Iowa:
September 1 , 1988; Docket No. RPU 88 6; IntraLATA Competition in Iowa;
Direct Testimony on Behalf of MCI.
September 20, 1988; Docket No. RPU 1; Regarding the Access Charges of
Northwestern Bell Telephone Company; Direct Testimony on Behalf of MC!.
September 25, 1991; Docket No. RPU-91-4; Investigation of the Earnings of U S
WEST Communications , Inc.; Direct Testimony on Behalf of MC!.
October 3, 1991; Docket No. NOI-90-1; Presentation on Imputation of Access
Charges and the Other Costs of Providing Toll Services; On Behalf of MC!.
November 5 , 1991; Docket No. RPU-91-4; Investigation of the Earnings of U S
WEST Communications, Inc.; Rebuttal Testimony on Behalf of MC!.
December 23, 1991; Docket No. RPU-91-4; Investigation of the Earnings of
WEST Communications; Inc.; Supplemental Testimony on Behalf of MC!.
January 10 1992; Docket No. RPU-91-4; Investigation of the Earnings of U S
WEST Communications, Inc.; Rebuttal Testimony on Behalf of MC!.
Exhibit 101
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January 20, 1992; Docket No. RPU-91-4; Investigation of the Earnings of U S
WEST Communications, Inc.; Surrebuttal Testimony on Behalf of MC!.
June 8, 1999; Docket NOI-99-1; Universal Service Workshop; Participated on
numerous panels during two day workshop; Comments on Behalf of MCIW.
October 27, 1999: Docket NOI-99-1; Universal Service Workshop; Responded to
questions posed by the Staff of the Board during one day workshop; Comments
on Behalf of MCIW and AT&T.
November 14, 2003; Docket Nos. INU-03-, WRU-03-61; In Re:
Corporation; Sworn Statement of Position on Behalf of MC!.
Qwest
December 15, 2003; Docket Nos. INU-03-, WRU-03-61; In Re:
Corporation; Sworn Counter Statement of Position on Behalf of MCI.
Qwest
July 20, 2005; Docket No. ARB-05-4; In the Matter of Level 3 Communications,
LLC Petition for Arbitration with Qwest; Direct Testimony on Behalf of Level 3.
Kansas:
June 10, 1992; Docket No. 181 097-U; General Investigation into IntraLATA
Competition within the State of Kansas; Direct Testimony on Behalf of MC!.
September 16 1992; Docket No. 181 097-U; General Investigation into
IntraLA T A Competition within the State of Kansas; Rebuttal Testimony on Behalfof MC!.
August 31 , 2004; Docket No. 04-L3CT-1046-ARB; In the Matter of Arbitration
Between Level 3 Communications LLC and SBC Communications; Direct
Testimony on Behalf of Level 3 Communications, LLC.
Kentucky:
May 20, 1993; Administrative Case No. 323, Phase I; An Inquiry into IntraLATA
Toll Competition, an Appropriate Compensation Scheme for Completion of
IntraLATA Calls by Interexchange Carriers, and WATS Jurisdictionality; Direct
Testimony on Behalf of MCI.
December 21 , 2000; Case No. 2000-404; Petition of Level 3 Communications,
LLC for Arbitration with BeliSouth; Direct Testimony on Behalf of Level 3.
Exhibit 101
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January 12 , 2001; Case No. 2000-477; Petition of Adelphia Business Solutions
for Arbitration with BeliSouth; Direct Testimony on Behalf of Adelphia.
Louisiana:
December 28, 2000; Docket No. U-25301; Petition of Adelphia Business
Solutions for Arbitration with BeliSouth; Direct Testimony on Behalf of Adelphia.
January 5 , 2001; Docket No. U-25301; Petition of Adelphia Business Solutions
for Arbitration with BeliSouth; Rebuttal Testimony on Behalf of Adelphia.
Maryland:
November 12 , 1993; Case No. 8585; Competitive Safeguards Required re C&P'
Centrex Extend Service; Direct Testimony on Behalf of MCI.
January 14 1994; Case No. 8585; Competitive Safeguards Required re C&P'
Centrex Extend Service; Rebuttal Testimony on Behalf of MCI.
May 19 , 1994; Case No. 8585; Re Bell Atlantic Maryland, Inc.'s Transmittal No.
878; Testimony on Behalf of MCI.
June 2, 1994; Case No. 8585; Competitive Safeguards Required re C&P'
Centrex Extend Service; Rebuttal Testimony on Behalf of MCI.
September 5 2001; Case No. 8879; Rates for Unbundled Network Elements
Pursuant to the Telecommunications Act of 1996; Rebuttal Testimony on behalf
of the Staff of the Public Service Commission of Maryland.
October 15 , 2001; Case No. 8879; Rates for Unbundled Network Elements
Pursuant to the Telecommunications Act of 1996; Surrebuttal Testimony on
behalf of the Staff of the Public Service Commission of Maryland.
Massachusetts:
April 22, 1993; D.U. 93-45; New England Telephone Implementation of
Interchangeable NPAs; Direct Testimony on Behalf of MCI.
May 10, 1993; D.U. 93-45; New England Telephone Implementation of
Interchangeable NPAs; Rebuttal Testimony on Behalf of MCI.
Exhibit 101
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Michigan:
September 29, 1988; Case Nos. U 9004, U 9006, U 9007 (Consolidated);
Industry Framework for IntraLATA Toll Competition; Direct Testimony on Behalf
of MCI.
November 30, 1988; Case Nos. U 9004, U 9006, U 9007 (Consolidated);
Industry Framework for IntraLATA Toll Competition; Rebuttal Testimony on
Behalf of MCI.
June 30, 1989; Case No. U-8987; Michigan Bell Telephone Company Incentive
Regulation Plan; Direct Testimony on Behalf of MCI.
July 31 , 1992; Case No. U-10138; MCI v Michigan Bell and GTE re IntraLATA
Equal Access; Direct Testimony on Behalf of MCI.
November 17, 1992; Case No. U-10138; MCI v Michigan Bell and GTE re
IntraLATA Equal Access; Rebuttal Testimony on Behalf of MCI.
July 22, 1993; Case No. U-10138 (Reopener); MCI v Michigan Bell and GTE re
IntraLATA Equal Access; Direct Testimony on Behalf of MCI.
February 16 , 2000; Case No. U-12321; AT&T Communications of Michigan , Inc.
Complainant v. GTE North Inc. and Contel of the South, Inc., d/b/a GTE Systems
of Michigan; Direct Testimony on Behalf of AT&T. (Adopted Testimony of
Michael Starkey)
May 11 , 2000; Case No. U-12321; AT&T Communications of Michigan, Inc.
Complainant v. GTE North Inc. and Contel of the South , Inc., d/b/a GTE Systems
of Michigan; Rebuttal Testimony on Behalf of AT&T.
June 8, 2000; Case No. U-12460; Petition of Level 3 Communications for
Arbitration to Establish an Interconnection Agreement with Ameritech Michigan;
Direct Testimony on Behalf of Level (3) Communications, LLC.
September 27 , 2000; Case No. U-12528; In the Matter of the Implementation of
the Local Calling Area Provisions of the MT A; Rebuttal Testimony on Behalf of
Focal Communications, Inc.
June 1 , 2004; Case No. U-14152; Petition of Level 3 Communications LLC for
Arbitration with SBC Michigan; Direct Testimony on Behalf of Level 3
Communications, LLC.
Exhibit 101
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Minnesota:
January 30 , 1987; Docket No. - 421/CI 88; Summary Investigation into
Alternative Methods for Recovery of Non-traffic Sensitive Costs; Comments to
the Commission on Behalf of MCI.
September 7 , 1993; Docket No. P-999/CI-85-582, P-999/CI-87-697 and
999/CI-87-695 , In the Matter of an Investigation into IntraLATA Equal Access and
Presubscription; Comments of MCI on the Report of the Equal Access and
Presubscription Study Committee on Behalf of MCI.
September 20 1996; Petition for Arbitration with U S WEST Communications
Inc.; Docket No. P-442, 421/M-96-855; P-5321 , 421/M-96-909; and P-3167
421/M-96-729 (consolidated); Direct Testimony on Behalf of MCI.
September 30 1996; Petition for Arbitration with U S WEST Communications,
Inc.; Docket No. P-442, 421/M-96-855; P-5321 , 421/M-96-909; and P-3167
421/M-96-729 (consolidated); Rebuttal Testimony on Behalf of MCI.
September 14-, 1999; USWC OSS Workshop; Comments on Behalf of MCI
World Com, Inc. re OSS Issues.
September 28 , 1999; Docket No. P-999/R-97-609; Universal Service Group;
Comments on Behalf of MCI World Com , Inc. and AT&T Communications.
April 18, 2002; Commission Investigation of Qwest's Pricing of Certain
Unbundled Network Elements; Docket Nos. P-442 , 421 , 3012/M-01-1916; P-
421/C1-01-1375; OAH Docket No. 12-2500-14490; Rebuttal Testimony on Behalf
of McLeod USA Telecommunications Services , Inc., Eschelon Telecom
Minnesota, Inc., US Link, Inc., Northstar Access, LLC, Otter Tail Telecomm LLC
VAL-Ed Joint Venture, LLP , dba 702 Communications.
January 23, 2004; In the Matter of the Commission Investigation into ILEC
Unbundling Obligations as a Result of the Federal Triennial Review Order;
Docket No.: P-999/CI-O3-961; Direct Testimony on Behalf of World Com, Inc. (MCI).
Mississippi:
February 2 , 2001; Docket No. 2000-AD-846; Petition of Adelphia Business
Solutions for Arbitration with BeliSouth Telecommunications; Direct Testimony on
Behalf of Adelphia.
Exhibit 101
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February 16, 2001; Docket No. 2000-AD-846; Petition of Adelphia Business
Solutions for Arbitration with BeliSouth Telecommunications; Rebuttal Testimony
on Behalf of Adelphia.
Montana:
May 1 , 1987; Docket No. 86.12.67; Rate Case of AT&T Communications of the
Mountain States, Inc.; Direct Testimony on Behalf of MCI.
September 12 , 1988; Docket No. 88.2; Rate Case of Mountain States
Telephone and Telegraph Company; Direct Testimony on Behalf of MCI.
May 12 , 1998; Docket No. D97.1 0.191; Application of WorldCom Inc. for
Approval to Transfer Control of MCI Communications Corporation to WorldCom
Inc.; Rebuttal Testimony on Behalf of MCI.
June 1 , 1998; Docket No. D97.1 0.191; Application of WorldCom, Inc. for
Approval to Transfer Control of MCI Communications Corporation to WorldCom
Inc.; Amended Rebuttal Testimony on Behalf of MCI.
Nebraska:
November 6, 1986; Application No. C 627; Nebraska Telephone Association
Access Charge Proceeding; Direct Testimony on Behalf of MCI.
March 31 , 1988; Application No. C 749; Application of United Telephone Long
Distance Company of the Midwest for a Certificate of Public Convenience and
Necessity; Direct Testimony on Behalf of MCI.
New Hampshire:
April 30, 1993; Docket DE 93-003; Investigation into New England Telephone
Proposal to Implement Seven Digit Dialing for Intrastate Toll Calls; Direct
Testimony on Behalf of MCI.
January 12, 2001; Docket No. DT 00-223; Investigation Into Whether Certain
Calls are Local; Direct Testimony on Behalf of BayRing Communications.
April 5, 2002; Docket No. DT 00-223; Investigation Into Whether Certain Calls
are Local; Rebuttal Testimony on Behalf of BayRing Communications.
Exhibit 101
Page 15 of 27
-~CQSI
-1" consulting, inc.
New Jersey:
September 15, 1993; Docket No. TX93060259; Notice of Pre-Proposal re
IntraLATA Competition; Comments in Response to the Board of Regulatory
Commissioners on Behalf of MCI.
October 1 , 1993; Docket No. TX93060259; Notice of Pre-Proposal re IntraLATA
Competition; Reply Comments in Response to the Board of Regulatory
Commissioners on Behalf of MCI.
April 7 , 1994; Docket Nos. TX90050349, TE92111047, and TE93060211;
Petitions of MCI, Sprint and AT&T for Authorization of IntraLATA Competition
and Elimination of Compensation; Direct Testimony on Behalf of MCI.
April 25 , 1994; Docket Nos. TX90050349, TE92111047, and TE93060211;
Petitions of MCI, Sprint and AT&T for Authorization of IntraLATA Competition
and Elimination of Compensation; Rebuttal Testimony on Behalf of MCI.
New Mexico:
September 28 , 1987; Docket No. 87 _TC; Application of MCI for a Certificate
of Public Convenience and Necessity; Direct Testimony on Behalf of MCI.
August 30, 1996: Docket No. 95-572-TC; Petition of AT&T for IntraLATA Equal
Access; Rebuttal Testimony on Behalf of MCI.
September 16, 2002; Utility Case No. 3495 , Phase B; Consideration of Costingand Pricing Rules for OSS, Collocation, Shared Transport, Nonrecurring
Charges, Spot Frames, Combination of Network Elements and Switching; Direct
Testimony on Behalf of the Staff of the New Mexico Public Regulation
Commission.
February 9, 2004; Case Nos. 03-00403-UT and 03-00404-UT; Triennial Review
Proceedings (Batch Hot Cut and Local Circuit Switching); Testimony on Behalf of
World Com , Inc. (MCI).
May 11 2004; Case No. 00108-UT; Regarding Unfiled Agreements between
Qwest Corporation and Competitive Local Exchange Carriers; Testimony on
Behalf of Time Warner Telecom
New York:
April 30, 1992; Case 28425; Comments of MCI Telecommunications Corporation
on IntraLA T A Presubscription.
Exhibit 101
Page 16 of 2'
.~CQSI
-t' consulting, inc.
June 8, 1992; Case 28425; Reply Comments of MCI Telecommunications
Corporation on IntraLATA Presubscription.
North Carolina:
August 4, 2000; Docket No. P779 SUB4; Petition of Level (3) Communications
LLC for Arbitration with Bell South; Direct Testimony on Behalf of Level (3)
Communications, LLC.
September 18, 2000; Docket No. P779 SUB4; Petition of Level (3)
Communications LLC for Arbitration with Bell South; Rebuttal Testimony on
Behalf of Level (3) Communications, LLC.
October 18, 2000; Docket No. P-886, SUB 1; Petition of Adelphia Business
Solutions of North Carolina, LP for Arbitration with BeliSouth; Direct Testimony
on Behalf of Adelphia.
December 8, 2000; Docket No. P-886 SUB 1; Petition of Adelphia Business
Solutions of North Carolina, LP for Arbitration with BeliSouth; Rebuttal Testimony
on Behalf of Adelphia.
North Dakota:
June 24, 1991; Case No. PU-2320-90-183 (Implementation of SB 2320 --
Subsidy Investigation); Direct Testimony on Behalf of MCI.
October 24 , 1991; Case No. PU-2320-90-183 (Implementation of SB 2320
Subsidy Investigation); Rebuttal Testimony on Behalf of MCI.
December 4 , 2002; Case No. PU-2065-02-465; Petition of Level 3 for Arbitration
with SRT Communications Cooperative; Direct Testimony on Behalf of Level (3)
Communications, LLC.
May 2, 2003; Case No. PU-2342-01-296; Qwest Corporation Price Investigation;
Direct Testimony on Behalf of the CLEC Coalition (US Link, Inc., VAL-ED Joint
Venture LLP d/b/a 702 Communications, McLeod USA Telecommunications, Inc.
and IdeaOne Telecom Group, LLC).
Ohio:
February 26 2004; Case No. 04-35-TP-COI; In the Matter of the Implementation
of the FCC's Triennial Review Regarding Local Circuit Switching in the Cincinnati
Bell Telephone Company s Mass Market; Direct Testimony on Behalf of AT&T.
Exhibit 101
Page 17 of 27
'~CQSI
-1" consulting, inc.
Oklahoma:
April 2 , 1992; Cause No. 28713; Application of MCI for Additional CCN Authority
to Provide IntraLATA Services; Direct Testimony on Behalf of MCI.
June 22, 1992; Cause No. 28713; Application of MCI for Additional CCNAuthority to Provide ntraLA T A Services; Rebuttal Testimony on Behalf of MCI.
Oregon:
October 27, 1983; Docket No. UT 9; Pacific Northwest Bell Telephone Company
Business Measured Service; Direct Testimony on Behalf of the Public Utility
Commissioner of Oregon.
April 23, 1984; Docket No. UT 17; Pacific Northwest Bell Telephone Company
Business Measured Service; Direct Testimony on Behalf of the Public UtilityCommissioner of Oregon.
May 7, 1984; Docket No. UT 17; Pacific Northwest Bell Telephone Company
Business Measured Service; Rebuttal Testimony on Behalf of the Public Utility
Commissioner of Oregon.
October 31 , 1986; Docket No. AR 154; Administrative Rules Relating to the
Universal Service Protection Plan; Rebuttal Testimony on Behalf of MCI.
September 6, 1996; Docket ARB3/ARB6; Petition of MCI for Arbitration with U S
WEST Communications, Inc.; Direct Testimony on Behalf of MCI.
October 11 , 1996; Docket No. ARB 9; Interconnection Contract Negotiations
Between MClmetro and GTE; Direct Testimony on Behalf of MCI.
November 5 , 1996; Docket No. ARB 9; Interconnection Contract Negotiations
Between MClmetro and GTE; Rebuttal Testimony on Behalf of MCI.
November 6, 2002; Docket No. UM 1058; Investigation into the Use of VirtualNPAlNXX Calling Patterns; Comments/Presentation on Behalf of Level (3)
Communications, LLC.
Pennsylvania:
December 9 , 1994; Docket No. 1-00940034; Investigation Into IntraLATAInterconnection Arrangements (Presubscription); Direct Testimony on Behalf of
MCI.
Exhibit 101
Page 18 of 27
-~CQSI
-'1' consulting, inc.
September 5, 2002; Docket No. C-20028114; Level 3 Communications, LLC v.
Marianna & Scenery Hill Telephone Company; Direct Testimony on Behalf of
Level (3) Communications, LLC.
Rhode Island:
April 30, 1993; Docket No. 2089; Dialing Pattern Proposal Made by the New
England Telephone Company; Direct Testimony on Behalf of MCI.
South Carolina:
October 2000; Docket No. 2000-0446-C; US LEC of South Carolina Inc.
Arbitration with BeliSouth Telecommunications; Direct Testimony on Behalf of US
LEC.
November 22 , 2000; Docket No. 2000-516-C; Adelphia Business Solutions of
South Carolina Inc. Arbitration with BeliSouth Telecommunications; Direct
Testimony on Behalf of Adelphia.
December 14, 2000; Docket No. 2000-516-C; Adelphia Business Solutions of
South Carolina, Inc. Arbitration with BeliSouth Telecommunications; Rebuttal
Testimony on Behalf of Adelphia.
South Dakota:
November 11 , 1987; Docket No. F _3652 12; Application of Northwestern Bell
Telephone Company to Introduce Its Contract Toll Plan; Direct Testimony on
Behalf of MCI.
May 27, 2003; Docket No. TC03-057; Application of Qwest to Reclassify Local
Exchange Services as Fully Competitive; Direct Testimony on Behalf of
WorldCom, Inc., Black Hills FiberCom and Midcontinent Communications.
Tennessee:
January 31 , 2001; Petition of Adelphia Business Solutions for Arbitration with
BeliSouth Telecommunications; Direct Testimony on Behalf of Adelphia.
February 7 2001; Petition of Adelphia Business Solutions for Arbitration with
BeliSouth Telecommunications; Rebuttal Testimony on Behalf of Adelphia.
Exhibit 101
Page 19 of 27
-~CQSI
-t' consulting, inc.
Texas:
June 5, 2000; PUC Docket No. 22441; Petition of Level 3 for Arbitration with
Southwestern Bell Telephone Company; Direct Testimony on Behalf of Level (3)
Communications, LLC.
June 12 , 2000; PUC Docket No. 22441; Petition of Level 3 for Arbitration with
Southwestern Bell Telephone Company; Rebuttal Testimony on Behalf of Level
(3) Communications, LLC.
October 10 , 2002; PUC Docket No. 26431; Petition of Level 3 for Arbitration with
CenturyTel of Lake Dallas , Inc. and CenturyTel of San Marcos , Inc.; Direct
Testimony on Behalf of Level (3) Communications, LLC.
October 16, 2002; PUC Docket No. 26431; Petition of Level 3 for Arbitration with
CenturyTel of Lake Dallas, Inc. and CenturyTel of San Marcos , Inc.; Reply
Testimony on Behalf of Level (3) Communications, LLC.
July 19 2004; PUC Docket No. 28821; Arbitration of Non-costing Issues for
Successor Interconnection Agreement to the Texas 271 Agreement; Direct
Testimony on Behalf of KMC Telecom III , L.C, KMC Telecom V, Inc. (d/b/a
KMC Network Services, Inc.), and KMC Data, L.
August 23, 2004; PUC Docket No. 28821; Arbitration of Non-costing Issues for
Successor Interconnection Agreement to the Texas 271 Agreement; Rebuttal
Testimony on Behalf of KMC Telecom III , L.C, KMC Telecom V, Inc. (d/b/a
KMC Network Services, Inc.), and KMC Data , L.L.C.
Utah:
November 16, 1987; Case No. 87 049 05; Petition of the Mountain State
Telephone and Telegraph Company for Exemption from Regulation of Various
Transport Services; Direct Testimony on Behalf of MCI.
July 7, 1988; Case No. 83 999 11; Investigation of Access Charges for
Intrastate InterLATA and IntraLATA Telephone Services; Direct Testimony on
Behalf of MCI.
November 8, 1996; Docket No. 96-095-01; MClmetro Petition for Arbitration with
USWC Pursuant to 47 U.C. Section 252; Direct Testimony on Behalf of MCI.
November 22, 1996; Docket No. 96-095-01; MClmetro Petition for Arbitration
with USWC Pursuant to 47 U.C. Section 252; Rebuttal Testimony on Behalf of
MCI.
Exhibit 101
Page 20 of 27
.~CQSI
.t' consulting, inc.
September 3, 1997; Docket No. 97-049-08; USWC Rate Case; Surrebuttal
Testimony on Behalf of MCI.
September 29, 1997; Docket No. 97-049-08; USWC Rate Case; Revised Direct
Testimony on Behalf of MCI.
February 2, 2001; Docket No. 00-999-05; In the Matter of the Investigation of
Inter-Carrier Compensation for Exchanged ESP Traffic; Direct Testimony on
Behalf of Level 3 Communications, LLP.
January 13, 2004; Docket No. 03-999-04; In the Matter of a Proceeding to
Address Actions Necessary to Respond to the FCC's Triennial Review Order;
Direct Testimony on Behalf of WorldCom, Inc. (MCI).
Washington:
September 27 , 1988; Docket No. U-88-2052-P; Petition of Pacific Northwest Bell
Telephone Company for Classification of Services as Competitive; Direct
Testimony on Behalf of MCI.
October 11 , 1996; Docket No. UT -96-0338; Petition of MClmetro for Arbitration
with GTE Northwest, Inc., Pursuant to 47 U.252; Direct Testimony on Behalf
of MCI.
November 20, 1996; Docket No. UT-96-0338; Petition of MClmetro for Arbitration
with GTE Northwest, Inc.Pursuant to 47 U.252; Rebuttal Testimony on
Behalf of MCI.
January 13, 1998; Docket No. UT-97-0325; Rulemaking Workshop re Access
Charge Reform and the Cost of Universal Service; Comments and Presentation
on Behalf of MCI.
December 21 2001; Docket No. UT-003013, Part D; Continued Costing and
Pricing of Unbundled Network Elements, Transport, and Termination; Direct
Testimony on Behalf of WorldCom , Inc.
October 18, 2002; Docket No. UT -023043; Petition of Level 3 for Arbitration with
CenturyTel of Washington , Inc.; Direct Testimony on Behalf of Level (3)
Communications, LLC.
November 1 2002; Docket No. UT-023043; Petition of Level 3 for Arbitration with
CenturyTel of Washington , Inc.; Rebuttal Testimony on Behalf of Level (3)
Communications, LLC.
Exhibit 101
Page 21 of 27
.~CQSI
-t' consulting, inc.
January 31 , 2003; Docket No. UT-021569; Developing an Interpretive or Policy
Statement relating to the Use of Virtual NPAlNXX Calling Patterns; Comments on
Behalf of World Com , Inc. and KMC Telecom.
May 1 , 2003; Docket No. UT-021569; Developing an Interpretive or Policy
Statement relating to the Use of Virtual NPAlNXX Calling Patterns; Workshop
Participation on Behalf of MCI , KMC Telecom , and Level (3) Communications
LLC.
August 13, 2003; Docket No. UT-030614; In the Matter of the Petition of Qwest
Corporation for Competitive Classification of Basic Exchange
Telecommunications Services; Direct Testimony on Behalf of MCI , Inc.
August 29, 2003; UT-030614; In the Matter of the Petition of Qwest Corporation
for Competitive Classification of Basic Exchange Telecommunications Services;
Rebuttal Testimony on Behalf of MCI , Inc.
September 13, 2004; Docket No. UT-033011; In the Matter of Washington
Utilities and Transportation Commission , Petitioners, v. Advanced Telecom
Group, Inc., et ai Respondents; Direct Testimony on Behalf of Time Warner
Telecom of Washington , LLC.
West Virginia:
October 11 , 1994; Case No. 94-0725- T -PC; Bell Atlantic - West Virginia Incentive
Regulation Plan; Direct Testimony on Behalf of MCI.
June 18, 1998; Case No. 97-1338-PC; Petition of WorldCom, Inc. for Approval
to Transfer Control of MCI Communications Corporation to WorldCom, Inc.
Rebuttal Testimony on Behalf of MCI.
Wisconsin:
October 31 , 1988; Docket No. 05- TR 02; Investigation of Intrastate Access
Costs, Settlements, and IntraLATA Access Charges; Direct Testimony on Behalf
of MCI.
November 14 , 1988; Docket No. 05- TR 02; Investigation of Intrastate Access
Costs, Settlements, and IntraLATA Access Charges; Rebuttal Testimony on
Behalf of MCI.
December 12 , 1988; Docket No. 05- TI 116; In the Matter of Provision of
Operator Services; Rebuttal Testimony on Behalf of MCI.
Exhibit 101
Page 22 of 27
.~CQSI
-t' consulting, inc.
March 6, 1989; Docket No. 6720 102; Review of Financial Data Filed by
Wisconsin Bell , Inc.; Direct Testimony on Behalf of MCI.
May 1 , 1989; Docket No. 05 100; Amendment of MCI's CCN for Authority to
Provide IntraLATA Dedicated Access Services; Direct Testimony on Behalf of
MCI.
May 11 , 1989; Docket No. 6720- TR 03; Investigation Into the Financial Data
and Regulation of Wisconsin Bell , Inc.; Rebuttal Testimony on Behalf of MCI.
July 5, 1989; Docket No. 05- TI-112; Disconnection of Local and Toll Services for
Nonpayment -- Part A; Direct Testimony on Behalf of MCI.
July 5, 1989; Docket No. 05-TI-112; Examination of Industry Wide Billing and
Collection Practices -- Part B; Direct Testimony on Behalf of MCI.
July 12, 1989; Docket No. 05-TI-112; Rebuttal Testimony in Parts A and B on
Behalf of MCI.
October 9, 1989; Docket No. 6720- TI-1 02; Review of the WBI Rate Moratorium;
Direct Testimony on Behalf of MCI.
November 17, 1989; Docket No. 6720-TI-102; Review of the WBI Rate
Moratorium; Rebuttal Testimony on Behalf of MCI.
December 1 , 1989; Docket No. 05-TR-102; Investigation of Intrastate Access
Costs , Settlements, and IntraLATA Access Charges; Direct Testimony on Behalf
of MCI.
April 16 , 1990; Docket No. 6720- TR-04; Wisconsin Bell Rate Case; Direct
Testimony of Behalf of MCI.
October 1 , 1990; Docket No. 2180- TR-02; GTE Rate Case and Request for
Alternative Regulatory Plan; Direct Testimony on Behalf of MCI.
October 15 1990; Docket No. 2180-TR-102; GTE Rate Case and Request for
Alternative Regulatory Plan; Rebuttal Testimony on Behalf of MCI.
November 15 1990; Docket No. 05- TR-03; Investigation of Intrastate Access
Costs and Intrastate Access Charges; Direct Testimony on Behalf of MCI.
April 3, 1992; Docket No. 05-NC-102; Petition of MCI for IntraLA T A 10XXX 1 +
Authority; Direct Testimony on Behalf of MCI.
Exhibit 101
Page 23 of 27
.~CQSI
-1" consulting, inc.
September 30, 2002; Docket No. 05-MA-130; Petition of Level 3 for Arbitration
with Century Tel; Direct Testimony on Behalf of Level (3) Communications, LLC.
October 9, 2002; Docket No. 05-MA-130; Petition of Level 3 for Arbitration with
CenturyTel; Reply Testimony on Behalf of Level (3) Communications, LLC.
September 1 , 2004; Docket No. 05-MA-135; Petition of Level 3 for Arbitration
with Wisconsin Bell , Inc. d/b/a/ SBC Wisconsin; Direct Testimony on Behalf of
Level (3) Communications, LLC.
Wyoming:
June 17 1987; Docket No. 9746 Sub 1; Application of MCI for a Certificate of
Public Convenience and Necessity; Direct Testimony on Behalf of MCI.
May 19 , 1997; Docket No. 72000-TC-97-99; In the Matter of Compliance with
Federal Regulations of Payphones; Oral Testimony on Behalf of MCI.
Comments Submitted to the Federal Communications Commission and/or
the Department of Justice
March 6, 1991; Ameritech Transmittal No. 518; Petition to Suspend and
Investigate on Behalf of MCI re Proposed Rates for OPTINET 64 Kbps Service.
April 17, 1991; Ameritech Transmittal No. 526; Petition to Suspend and
Investigate on Behalf of MCI re Proposed Flexible ANI Service.
August 30, 1991; Ameritech Transmittal No. 555; Petition to Suspend and
Investigate on Behalf of MCI re Ameritech Directory Search Service.
September 30 1991; Ameritech Transmittal No. 562; Petition to Suspend and
Investigate on Behalf of MCI re Proposed Rates and Possible MFJ Violations
Associated with Ameritech's OPTINET Reconfiguration Service (AORS).
October 15, 1991; CC Docket No. 91-215; Opposition to Direct Cases of
Ameritech and United (Ameritech Transmittal No. 518; United Transmittal No.
273) on Behalf of MCI re the introduction of 64 Kbps Special Access Service.
November 27, 1991; Ameritech Transmittal No. 578; Petition to Suspend and
nvestigate on Behalf of MCI re Ameritech Directory Search Service.
September 4, 1992; Ameritech Transmittal No. 650; Petition to Suspend and
Investigate on Behalf of MCI re Ameritech 64 Clear Channel Capability Service.
Exhibit 101
Page 24 of 27
-~CQSI
.t' consulting, inc.
February 16, 1995; Presentation to FCC Staff on the Status of Intrastate
Competition on Behalf of MCI.
November 9, 1999; Comments to FCC Staff of Common Carrier Bureau on the
Status of OSS Testing in Arizona on Behalf of MCI WorldCom, Inc.
November 9 , 1999; Comments to the Department of Justice (Task Force on
Telecommunications) on the Status of OSS Testing in Arizona and the USWC
Collaborative on Behalf of MCI WorldCom, Inc.
Presentations Before Legislative Bodies:
April 8 , 1987; Minnesota; Senate File 677; Proposed Deregulation Legislation;
Comments before the House Committee on Telecommunications.
October 30, 1989; Michigan; Presentation Before the Michigan House and
Senate Staff Working Group on Telecommunications; "A First Look at Nebraska
Incentive Rates and Price Caps " Comments on Behalf of MCI.
May 16, 1990; Wisconsin; Comments Before the Wisconsin Assembly Utilities
Committee Regarding the Wisconsin Bell Plan for Flexible Regulation, on Behalf
of MCI.
March 20, 1991; Michigan; Presentation to the Michigan Senate Technology and
Energy Committee re SB 124 on behalf of MCI.
May 15 1991; Michigan; Presentation to the Michigan Senate Technology and
Energy Commission and the House Public Utilities Committee re MCI's Building
Blocks Proposal and SB 124/HB 4343.
March 8, 2000; Illinois; Presentation to the Environment & Energy Senate
Committee re Emerging Technologies and Their Impact on Public Policy, on
Behalf of MCI WorldCom , Inc.
February 19, 2004; Presentation to the Iowa Senate Committee Regarding
House Study Bill 622/Senate Study Bill 3035; Comments on Behalf of MCI.
Presentations Before Industry Groups -- Seminars:
May 17 , 1989; Wisconsin Public Utility Institute -- Telecommunications Utilities
and Regulation; May 15-18, 1989; Panel Presentation -- Interexchange Service
Pricing Practices Under Price Cap Regulation; Comments on Behalf of MCI.
Exhibit 101
Page 25 of27
-~CQSI
-1" consulting, inc.
July 24, 1989; National Association of Regulatory Utility Commissioners --
Summer Committee Meeting, San Francisco, California. Panel Presentation --
Specific IntraLA T A Market Concerns of Interexchange Carriers; Comments on
Behalf of MCI.
May 16, 1990; Wisconsin Public Utility Institute -- Telecommunications Utilities
and Regulation; May 14-18, 1990; Presentation on Alternative Forms of
Regulation.
October 29, 1990; Illinois Telecommunications Sunset Review Forum; Two Panel
Presentations: Discussion of the Illinois Commerce Commission s Decision
Docket No. 88-0091 for the Technology Working Group; and, Discussion of the
Treatment of Competitive Services for the Rate of Return Regulation Working
Group; Comments on Behalf of MCI.
May 16, 1991; Wisconsin Public Utility Institute -- Telecommunications Utilitiesand Regulation Course; May 13-16, 1991; Participated in IntraLATA Toll
Competition Debate on Behalf of MCI.
November 19, 1991; TeleStrategies Conference -- "Local Exchange Competition:
The $70 Billion Opportunity." Presentation as part of a panel on "lntraLA T A 1 +
Presubscription" on Behalf of MCI.
July 9, 1992; North Dakota Association of Telephone Cooperatives Summer
Conference, July 8-10, 1992. Panel presentations on "Equal Access in North
Dakota: Implementation of PSC Mandate" and "Open Network Access in North
Dakota" on Behalf of MCI.
December 2-3, 1992; TeleStrategies Conference -- "lntraLATA Toll Competition -
- A Multi-Billion Dollar Market Opportunity." Presentations on the interexchange
carriers' position on intraLA T A dialing parity and presubscription and on technical
considerations on behalf of MCI.
March 14-, 1993; NARUC Introductory Regulatory Training Program; Panel
Presentation on Competition in Telecommunications on Behalf of MCI.
May 13-1993; TeleStrategies Conference -- "lntraLATA Toll Competition --
Gaining the Competitive Edge ; Presentation on Carriers and IntraLA T A Toll
Competition on Behalf of MCI.
May 23-, 1994; The 12th Annual National Telecommunications Forecasting
Conference; Represented IXCs in Special Town Meeting Segment Regarding the
Convergence of CATV and Telecommunications and other Local Competition
Issues.
Exhibit 101
Page 26 of 27
~~CQSI
.'1' consulting, inc.
March 14-15, 1995; "The LEC-IXC Conference Sponsored
Telecommunications Reports and Telco Competition Report; Panel
Redefining the IntraLATA Service Market -- Toll Competition Extended Area
Calling and Local Resale.
August 28-30, 1995; "Phone+ Supershow '95"; Playing Fair: An Update on
IntraLATA Equal Access; Panel Presentation.
August 29, 1995; "TDS Annual Regulatory Meeting ; Panel Presentation on Local
Competition Issues.
December 13-1995; "NECAlCentury
Presentation on Local Exchange Competition.
Access Conference Panel
October 23, 1997; "Interpreting the FCC Rules of 1997"; The Annenberg School
for Communication at the University of Southern California; Panel Presentation
on Universal Service and Access Reform.
February 5-, 2002; "Litigating Telecommunications Cost Cases and Other
Sources of Enlightenment"; Educational Seminar for State Commission and
Attorney General Employees on Litigating TELRIC Cases; Denver, Colorado.
February 19-20, 2003; Seminar for the New York State Department of Public
Service entitled "Emerging Technologies and Convergence in the
Telecommunications Network"Presented with Ken Wilson of Boulder
Telecommunications Consultants, LLC.
July 25, 2003; National Association of Regulatory Utility Commissioners Summer
Committee Meetings; Participated in Panel regarding "Wireless Substitution of
Wireline - Policy Implications.
Exhibit 101
Page 27 of 27
Idaho
Case No. QWE-T-OS-
L3C 01-021I
INTERVENOR:Level 3 Communications, LLC
REQUEST NO:021I
Does Qwest offer any kind of foreign exchange ("FX") service
state? If so, please provide a service description (including,
limited to, tariff pages) for each such service.
in this
but not
RES PONSE :
Qwest obj ects to this request on the basis that its tariffs/catalogs are on
file with the Idaho Commission and are, therefore, readily available to Level
3 without resorting to burdensome discovery.
Without waiving its objection Qwest responds:
Yes. Qwest offers Foreign Exchange (FX) service in northern Idaho. Qwest
does not actively promote or advertise FX service, therefore there is no
additional material available for FX, other than the tariff. Please refer to
the Northern Idaho Exc~ange and Network Services Tariff, which is provided as
Attachment A, for the service description of foreign exchange service. Please
note that the northern Idaho tariff will be converted to catalog on or
about
August 1, 23005. Foreign Exchange service in Southern Idaho was discontinued
as of April 13, 1979.
Respondent: Larry Brotherson
Exhibit 102
Page 1 of 7
Qwest CorporationExchange and Network
Services Tariff
IDAHO
; Case No. QWE-O5-
: L3C 01-0211SECTION 5 Attachment A
Page
Release 1
Effective: 5-31-02 I
5. EXCHANGE SERVICES
Replaces Page 5
NORTHERN IDAHO
Issued: 5-
EXCHANGE AREAS (Cont'
FOREIGN EXCHANGE SERVICE
A. Description
Foreign Exchange Service is a service furnished within a LATA (Local Area andTransport Area) from an exchange other than the exchange from which the
customer would nonnally be served.
B. Defmitions
geographic area established by the Company for the provision and
administration of communications service. It encompasses designated exchanges,
which are grouped to serve common social, economic and other purposes.
Local Exchange
As used in this Tariff means the exchange in which the main access line is located.
Foreign Exchange
As used in this Tariff means the exchange from which the service is rendered.
C. Terms And Conditions
1. Rates for local service includes service without additional charge to all accesslines receiving service from the exchange from which the foreign exchange
service is furnished.
2. The interexchange rates applicable in connection with toll service over foreignexchange lines will be as shown in the interexchange tariff provisions of theforeign exchange.
ADVICE No. 02-IO-N
Exhibit 102
Page 2 of 7
Replaces Page 6
NORTHERN IDAHO
Issued: 5-
Qwest CorporationExchange ana Network
Services Tariff SECTION 5
Page 6
Release 1
Effective: 5-31-02,
S. EXCHANGE SERVICES
EXCHANGE AREAS
FOREIGN EXCHANGE SERVICE
C. Terms and Conditions (Cont'
3. Additional listings and lines of information will be furnished to foreign exchange
customers in local or foreign directories and the rates in effect for the directory
containing the additional listing or line of infonnation will apply.
4. Except as provided, services furnished in the local exchange will be available in
connection with foreign exchange service at rates shown in the tariff provisionsof the local exchange.
5. Except as provided, foreign exchange service will be furnished subject to thesame conditions as those applicable in connection with local residence serviceregarding the use of the service by anyone other than the customer or members ofthe customer s household.
6. Foreign exchange service win not be provided for Smart PAL use.
7. Foreign exchange mileage rates for service furnished in a contiguous exchange as
shown under D.I., following, are applicable to the air-line distance between thecustomers main access line and the nearest point on the common boundary of the
foreign and local exchange areas.
8. Foreign exchange mileage rates for. business service furnished in non-contiguousexchanges as shown under D.I., following, are applicable to the interexchangcmileage measured between the rate centers of the foreign and local exchanges.
9. A suburban exchange access line shall not be located within the base rate area.
ADVICE No. 02-10-
Exhibit 102
Page 3 of 7
Qwest CorporationExchange and Network
Services Tariff SECTION 5
Page 7
Release 1
Effective: 5-31-
Replaces Page 7
NORTHERN IDAHO
Issued: 5-
S. EXCHANGE SERVICES
EXCHANGE AREAS
FOREIGN EXCHANGE SERVICE
C. Terms and Conditions (C6nt'
10. Four-party residence foreign exchange service is available from the followingexchanges only to a customer having such service either ordered or in service at a
premises on the date shown below.
Customers to suburban residence service may elect to subscribe to four-partyresidence service after the date shown below, at the time that the Companychanges a base rate area to include these suburban customers' premises.
EXCHANGE DATE
Grangeville Febmary 1, 1971
11. A Foreign Exchange line may be utilized with customer-provided tenninal
equipment, protective circuitry, PBX and key telephone systems which areconnected to the exchange telephone service associated with such lines. Also, seeSection 8 of this Tariff.
12. Where foreign exchange service furnished under Do, following, is provided bymeans of a circuit crossing the exchange area boWldary, the following applies:
a. Where extensions of plant are. required in the foreign or local exchange they willbe made at the charges and under the conditions of 4., Line ExtensionCharges.
13. Foreign exchange service over any route is available under the conditions, ratesand charges specified in this section, when facilities and operating conditionspennit.
14. When the Company establishes a new central office or revises a central office or
exchange area boundary, additions or increases in mileage increments are not
applicable to existing customers as long as these services are retained withoutchange by the same customer at the same premises.
ADVICE No. 02-10-
,c,
Exhibit 102
Page 4 of 7
Qwest CorporationExchange and Network
Services Tariff SECTION 5
Page 8
Release 1
Effective: 5-31-
Replaces Page 8
NORTHERN IDAHO
Issued: 5-
S. EXCHANGE SERVICES
EXCHANGE AREAS
FOREIGN EXCHANGE SERVICE (Cont'
D. Rates and Charges
1. Business Foreign Exchange
a. The' following charge applies to each one-half mile or fraction thereof for
business service furnished in contiguous exchanges.
NON-
RECURRING FIRST SECOND OVER
CHARGE MILE MILE Two MILES
. Each premium flat
rate or PBX exchange
access line(1)$25.$3.$6.$9.
b. The following charge applies to each mile or fraction thereof for businessservice furnished in non-contiguous exchanges.
NONRECURRING
CHARGE
EACH MILE OR
FRACTION THEREOF
. Each premium flat
rate or PBX exchange
access line(!)$25.$6.
r 1 J In addition, rates and charges for the associated access line also apply.
ADVICE No. 02-10..
Exhibit 102
Page 5 of 7
Replaces Page 9
NORTHERN IDAHO
Issued: 5-
Qwest CorporationExchange and Network
Services Tariff SECTION 5
Page 9
Release 1
Effective: 5-31-
5. EXCHANGE SERVICES
EXCHANGE AREAS
FOREIGN EXCHANGE SERVICED. Rates and Charges (Cont'
2. Residence Foreign Exchange
The fonowing rates and charges apply to residence seIVice furnished in
contiguous exchanges for each one-quarter mile or fraction thereof.
, NONRECURRING
CHARGE
MONTHLY RATEFIRST BEYOND
ONE-HALF FIRST ONE-MILE HALF MILE.
. Each Exchange Access
Line( 1
- Individualline
- Two-party line
- Four-party line
- Suburban line
$25.
25.
25.
25.
$1.
1.00
$1.50
1.25
1.00
( 1) In addition, the rates and charges for the associated access line also apply.
ADVICE No. 02-10-
Exhibit 102
Page 6 of 7
Qwest CorporationExchange and Network
Services Tariff SECTION 5
Page 10!
Release 1
Effective: 5-31-02.
Replaces Page 10
NORTHERN IDAHO
Issued: 5-
5. EXCHANGE SERVICES
EXCHANGE AREAS1.4 FOREIGN EXCHANGE SERVICED. Rates and Charges (Cont'
3. Off-Premises Extension Station Lines and PBX Station Lines Foreign Exchange
Service
Where foreign exchange service is offered in D.I. and D., preceding, an off-premises extension line or private branch exchange station line from a mainstation line in the exchange from which foreign exchange service is offered, may
be furnished in the contiguous exchange at the following rates:
MONTHLY
RATE
a. Each one-quarter mile or fraction thereof, air-line
measurement, from the extension station line or
private branch exchange station line or private
branch exchange station line to the nearest
point on the common exchange boundary.
b. Each one-quarter mile or fraction thereof,
air-line measurement, from the nearest point
on the common exchange boundary to the
main station line.
$1.
1.25
c. The total mileage charge is the sum of the charges determined above.
ADVICE No. 02-10-
Exhibit 102
Page 7 of 7
Idaho
Case No. QWE-T-OS-11L3C 01-020I
INTERVENOR:Level 3 Communications, LLC
REQUEST NO:020I
Does Qwest contend that the costs it incurs in originating a call to a Level
3 customer differ in any respect whatsoever based upon the physical location
of the Level 3 customer? ~f Qwest responds to the above question with
anything other than an unequivocal II No , II please provide a detailedexplanation of how the location of Level 3 I s customer on Level 3 I s side of
the POI could affect Qwest I s costs. Include in that explanation all cost
studies and any other documentation in your possession that you believeprovides support for your position.
RESPONSE:
Qwest objects to this request on the basis that it 'is overly broad, unduly
burdensome, ambiguous and not reasonably calculated to lead to the discovery
of admissible evidence.
Without waiving its objection, Qwest responds:
No. . The costs Qwest incurs do not vary based upon the physical location of
the Level 3 customer. Qwest's overall costs incurred to complete a call,
however, vary depending on the originating voice caller's location and the
location of the Level 3 POI.
Respondent:Larry ~rotherson
Exhibit 103
Page 1 of 1
Idaho
Case No. QWE-T-OS-l1
L3C 01-021A
INTERVENOR:Level 3 Communications, LLC
REQUEST NO:021A
Qwest's end office and tandem switches do not store any information
indicating the address or location of any end user I s premises.
RESPONSE:
Qwest can neither admit nor deny this request.
The telephone numbers that Qwest uses for call routing purposes are assigned
to its end users based on NPA-NXXs associated with specific LCAs in thestate. Thus, Qwest's end office and tandem switches process calls based on
information that that in most, but- not all, cases identifies the general
geographic area within which the end users are located. Thus, while switches
do not route calls based on specific addresses stored within the switches,
the routing and connecting function of switches are based on information
concerning a customer's address and location located in other companydatabases. Furthermore, installation facts, repair facts, billing. information and other related information related to specific customers are
contained in company databases that are based on customer address and
location information.
Exhibit 104
Page 1 of
Idaho
Case No. QWE-T-OS-11
L3C 01-00SA
INTERVENOR:Level 3 Communications, LLC
REQUEST NO:OOSA
Qwest currently has agreements with one or more other incumbent local
exchange carriers in Idaho under which Qwest provides transit traffic
connection for those incumbent local exchange carriers to other carriers.Customers of Qwest' s own Idaho intrastate FX service do not pay toll charges
on their FX interexchange calls, regardless of the distance of the call.
RESPONSE:
Qwest objects to the form of this request on the basis that it contains two
distinct statements that are not appropriately combined in a single request
for admission.
Without waiving its objects, Qwest provides the following response:
Admitted. Qwest currently has agreements with one or more other incumbent
local exchange carriers in Idaho under which Qwest provides transit traffic
connection for those incumbent IQcal exchange carriers to other carriers.
See response to Request No. 4A.
Denied. Customers of Qwest I s own Idaho intrastate FX service do not pay toll
charges on their FX interexchange calls, regardless of the distance of thecall. Qwest customers of FX service do pay toll charges for interexchangecalls. Calls to and from end users in the local calling area where the FX
customer purchases an FX connection are treated as local. All calls to other
exchanges are treated as interexchange calls and toll charges would apply.
In addition, the FX customer pays for the transport from the LCA where the
number is obtained by purchasing special access/private line products
contained in the Idaho private line tariffs.
Exhibit 105
Page 1 of 1
Idaho
Case No. QWE-T-OS-11
L3C 01-009A
INTERVENOR:Level 3 Communications, LLC
REQUEST NO:0O9A
Qwest currently offers Qwest~ OneFlexTM Voice over Internet Protocol services
within Idaho which provides customers "the option of choosing up to fiveaddi tional phone numbers (virtual numbers) that will ring to your phone.
Calls placed to a virtual phone number will ring the same phone as calls
placed to your primary phone number. A virtual phone number can be benef icialif you have colleagues, friends or family living outside your local calling
area. You could request a virtual number within their area and the people who
live in that local calling area can call you for a price of a local phone
call. "
RESPONSE:
Qwest obj ects to these requests on the grounds that they are ambiguous and
compound requests and as such are inappropriate requests to admit.
Without waiving the foregoing objections, Qwest admits this request as to QCC
but denies it as to Qwest Corporation.
Exhibit 106
Page 1 of 1