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Home My WebLink About20070817Motion for Extension of Time.pdfn ,~ '""t !" I r= . .. ~ v ,-. v MC~nS(l)N' &0 ()!~'):(; PLLC ATTORNEYS AT LAW 71'-:11 "I" 'O.1i\1 i (i, r, ., j 1~ ! ,. '" .vu ,'-to Molly 0' Leary ;:';2':.; r'- I ,,- VTel: 208-938-7900 Fax: 208-938-7904 mollyliP richardson and oleary. com P.O. Box 7218 Boise, ID 83707 - 515 N. 27th St. Boise, ID 83702 17 August 2007 Ms. Jean Jewell Commission Secretary Idaho Public Utilities Commission POBox 83720 Boise ID 83720-0074 Via HAND DELIVERY RE: Case No. QWE-06- Dear Ms. Jewell: Enclosed please find an original and seven (7) copIes of AT&T'S MOTION FOR EXTENSION OF TIME. I have also enclosed an extra copy of the foregoing pleading to be date-stamped and returned to us for our files. Thank you. encl. Molly O'Leary (ISB No. 4996) RICHARDSON &O'LEARYPLLC 515 North 27th Street O. Box 7218 Boise, Idaho 83707 Telephone: 208.938.7900 Fax: 208.938.7904 Mail: molly~richardsonandoleary.com Theodore A. Livingston Dennis G. Friedman MAYER, BROWN, ROWE & MAW LLP 71 South Wacker Drive Chicago IL 60606-4637 Telephone: 312.782.0600 Fax: 312.706.8630 Mail: dfriedman~mayerbrown.com Dan Foley General Attorney & Assistant General Counsel AT&T WEST P. O. Box 11010; 645 E. Plumb Lane, B132 Reno, Nevada 89520 Telephone: 775.333.4321 Fax: 775.333.2175 Mail: df6929~att.com RECE\VED lUill f\UG \ 1 1.\: 33 UTI L:tH~g~"d~5~";~I ~' \~ 81 ON Attorneys for Complainant AT&T Communications of the Mountain States, Inc. BEFORE THE IDAHO PUBLIC UTILITIES COMMISSION AT&T COMMUNICATIONS OF THE MOUNTAIN ) STATES, INC. Complainant vs. QWEST CORPORATION Respondent. CASE NO. QWE-06- AT &T COMMUNICATIONS OF THE MOUNTAIN STATES, INC.S MOTION FOR EXTENSION OF TIME COMES NOW, AT&T of the Mountain States , Inc. and files this MOTION FOR EXTENSION OF TIME, pursuant to Idaho Public Utility Commission Rule 057.03. On August 10, 2007, Qwest filed a Motion to Stay the present Commission proceeding pending the outcome of its Removal of AT&T's companion Complaint in Idaho s Fourth Judicial Court ("State Court") to the US. District Court for the District of Idaho ("Federal Court ), and its subsequently filed Motion to Dismiss the same. Pursuant to Rule .057, AT&T's Response to Qwest's Motion to Stay the present matter is due no later than August 24 2007. Unfortunately, the primary attorney responsible fro drafting AT&T's responsive pleading is scheduled to be gone on previously planned vacation and will not return until August 27 , 2007. AT&T has conferred with opposing counsel, Peter Spivak, and Mr. Spivak has stated that Qwest does not oppose AT&T's request. See Attachment 1. Based on the foregoing, AT&T respectfully requests that it be given until August th to file its Response to Qwest's Motion to Stay. Dated this 17th day of August, 2007 AT&T COMMUNICATIONS OF THE MOUNTAIN STATES, INc. Richardso ' eary, PLLC Attorne s for AT&T COMMUNICATIONS OF THE OUNTAIN STATES , INc. AT&T MOTION FOR EXTENSION OF TIME - 2 II RE: o.west (South Dakota) appeal: Motion for Extension, Message (HTML) 1~11'6'l l~'i~~~;;;~C:;~t~tI~ ~cIiono helP il~~;jii~~~~L~I'M.!ar~l;3 ~J~L!J~b'J)(I.. l~, From:Spivack, Peter S. (pSSpivack!!HHLAW.com)Sent: Thu 8/16/2007 12:40 PMTo: Covey, J. Tyson; living,ron, Theodore A.; Friedman, Dennis G.Cc: Stetson, Catherine E.; RoI1rbach, Peter A.; "Mor, Thomas J.; Mitchell, Cynthia; Hobson, Mary Subject: RE: Qwest (South Dakoto) appeal: Motion for Exton.on Best. Peter Thanks. Ty. I have not heard from your local counsel. but maybe Mary Hobson has In any event. we do not have an objection. and would appreciate the same accommodation from you. From: Spivack, Peter 5, (mallto:PSSpivack~HHLAW,comJ Sent: Thursday, August 16, 2007 11:23 AM To: Livingston, Theodore A.; Covey, J. Tyson; Friedman, Dennis G, Cc: Stetson, catherine E.; Rohrbach, Peter A.; Widor, Thomas J.; Mitchell, Cynthia Subject: FW: Qwest (South Dakota) appeal: Motion for Extension Ted, Ty. and Dennis - I hope you are ha~ng an enjoyable summer. I'Ve would like to get en extension on the South Dakota appeal. so that it is on the same briefing schedule w~h the Minnesota and to accommodate some vacations (including my own) I am attaching a dra1\ consent motion for your re,;ew. Gould you let me know your position? 1.. Thanks peter . .. .. .. .. ". ,, , From: Covey, J. Tyson (mailto:JCovey&mayerbrownrowe.comJ Sent: Thursday, August 16, 2007 2:32 PM To: Spivack, Peter 5.; livingston, Theodore A.; Friedman, Dennis G. Cc: Stetson, catherine E,; Rohrbach, Peter A.; Wid or, Thomas J.; M~chell, Cynthia Subject: RE: Qwest (South Dakota) appeal: Motion for Extension I'll check and get back to you. I don't know d our local counsel has contacted you. but in Idaho we were seeking an extension on the response to Owes!'s motion to stay the Idaho PUG case from August 24 to August 30 (since I am on vacation next week) Do you know Owes!'s position on thai? " i AT& T MOTION FOR EXTENSION OF TIME ATTACHMENT CERTIFICA TE OF SERVICE I HEREBY CERTIFY that on the 17th day of August, 2007 a true and correct copy of the within and foregoing AT&T'S MOTION FOR EXTENSION OF TIME was filed with the Idaho Public Utilities Commission and parties as indicated below: Ms. Jean Jewell Commission Secretary Idaho Public Utilities Commission POBox 83720 Boise ID 83720-0074 X- Hand Delivery - US. Mail, postage pre-paid Facsimile Electronic Mail Mary S. Hobson 999 Main, Suite 1103 Boise, ill 83702 E-mail: mary.hobson(g)qwest.com - Hand Deli very US. Mail, postage pre-paid Facsimile X- Electronic Mail AT&T MOTION FOR EXTENSION OF TIME - 3