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Home My WebLink About20040127Affidavit of Mary Hobson.pdfF~ECEIVED !LED Mary S. Hobson (ISB #2142) Stoel Rives LLP 101 South Capitol Boulevard - Suite 1900 Boise, ID 83702 Telephone: (208) 387-4277 Facsimile: (208)389-9040 mshobson~stoel.com lilO4 JMJ 27 PM 3: 36 : . J F'UijLlC UTILITIES COt1r'iJSSIClN Charles W. Steese Steese & Evans, P. 6400 S. Fiddlers Green Circle, Suite 1820 Denver, CO 80111 Telephone: (720) 200-0677 Facsimile: (720) 200-0679 csteese(ro,s-elaw.com IN THE SUPREME COURT OF THE STATE OF IDAHO IDAHO TELEPHONE ASSOCIATION CITIZENS TELECOMMUNICATIONS COMPANY OF IDAHO, CENTURYTEL OF IDAHO, CENTURYTEL OF THE GEM STATE, POTLATCH TELEPHONE COMP ANY and ILLUMINET, INe. Docket No. 30107 DC Docket No. QW-O3- Respondents AFFIDAVIT OF MARY S. HOBSON IN SUPPORT OF QWEST CORPORATION'S MOTION FOR EXTENSION OF TIME TO FILE APPELLANT'S BRIEF vs. QWEST CORPORATION Appellant. STATE OF IDAHO ) ss.County of Ada I am co-counsel for Appellant in the above-referenced matter, and provide this Affidavit fTom my personal knowledge. AFFIDAVIT OF MARY S. HOBSON IN SUPPORT OF QWEST CORPORATION'S JYI ~ F~ \\ r;'EXTENSION OF TIME TO FILE APPELLANT'S BRIEF - Page 1 (( .... I?" . ! '~:) Boise-166S 1 \.1 0029164-00082 , ~~-::/ '~:::::~, / U I have spoken with Mr. Steese, and he has confinned to me the contents of the attached Affidavit; however, due to the fact that he is traveling and away from his office he was unable to provide to me a signed and notarized copy today. Appellant will substitute Mr. Steese s notarized Affidavit as soon as it is received. .A~ ;#h- Mary S. obson STATE OF IDAHO )ss. COUNTY OF ADA On this 26th day..Qf.liU\v,ary, 2004, before me, Brandi L. Gearhart, a Notary Public personally appeare~~~.sGH;'f~~, known or identified to me, to be the person whose name is subscribed to the#~li"'1';'stru1nek ~d acknowledged to me that she executed the same. ~ ~ ::"" J\ ::,..,.. .. .... 0 T AI? t~ ... ~ ~ -~o " ~-.- :*: . G . P"J . '-' "* iP . . Q ~ "*~.. ....... ~.. "'I)" ...... ~ '\.7 ~ 11 0 F \\) ~"""'I"" /M? d- :,F! dcuA Notary Public for Idaho Printed Name: Brandi L. Gearhart Commission Expires: 09/04/07 AFFIDAVIT OF MARY S. HOBSON IN SUPPORT OF QWEST CORPORATION'S MOTION FOR EXTENSION OF TIME TO FILE APPELLANT'S BRIEF - Page 2 Boise-166811.10029164-00082 CERTIFICATE OF SERVICE I hereby certify that on this 26th day of January, 2004, I served AFFIDAVIT OF MARY HOBSON IN SUPPORT OF QWEST CORPORATION'S MOTION FOR EXTENSION OF TIME TO FILE APPELLANT'S BRIEF as follows: Weldon Stutzman Deputy Attorney General Idaho Public Utilities Commission 472 West Washington Street Boise, ill 83702 (.--J Hand Delivery LXJ U. S. Mail Overnight Delivery Facsimile Email F. Wayne Lafferty LKAM Services, Inc. 2940 Cedar Ridge Drive McKinney, TX 75070 Facsimile: (972) 548-5030 Hand Delivery LXJ U. S. Mail Overnight Delivery Facsimile Email Todd Lundy Qwest Services Corporation 1801 California Street - 47th Floor Denver, CO 80202 Telephone: (303) 896-1446 Facsimile: (303) 896-8120 tlundy(ti),qwestcom Hand Delivery LXJ u. S. Mail Overnight Delivery Facsimile Email Thomas J. Moorman Kraskin, Lesse & Cosson LLP 2120 L Street NW - Suite 520 Washington DC 20037 Phone: (202) 296-8890 Fax: (202) 296-8893 tmoorman(ti),klctele.com Hand Delivery (.--J U. S. Mail LXJ Overnight Delivery Facsimile Email Morgan W. Richards Moffatt Thomas 101 South Capitol Boulevard - 10th Floor Boise, ill 83701 mwr~moffatt.com LXJ Hand Delivery U. S.Mail Overnight Delivery Facsimile Email Charles W. Steese Steese & Evans, P. 6400 S. Fiddlers Green Circle, Suite l820 Denver, CO 80111 Telephone: (720) 200-0677 Facsimile: (720) 200-0679 csteese~s-elaw .com Hand Delivery LXJ U. S. Mail Overnight Delivery Facsimile Email AFFIDAVIT OF MARY S. HOBSON IN SUPPORT OF QWEST CORPORATION'S MOTION FOR EXTENSION OF TIME TO FILE APPELLANT'S BRIEF - Page 3 Boise-166811.10029164-00082 Clay Sturgis Moss Adams LLP 601 West Riverside - Suite 1800 Spokane, W A 99201-0663 Hand Delivery LXJ U. S. Mail Overnight Delivery Facsimile Email Lance Tade Citizens Telecommunications 4 Triad Center - Suite 200 Salt Lake City, UT 84180 Facsimile: (801) 924-6363 Hand Delivery LXJ U. S. Mail Overnight Delivery FacsimileL-J Email Conley Ward Givens Pursley 277 North 6th Street - Suite 200 O. Box 2720 Boise, ill 83701 cew~givenspursley.com (lJ Hand Delivery~ U.MailL-J Overnight Delivery Facsimile Email Richard Wolf Illuminet, Inc. 4501 Intelco Loop SE O. Box 2909 Olympia, W A 98507 Hand Delivery(lJ U. S. Mail Overnight DeliveryL-J FacsimileL-J Email !f:Jl/j~ Stoel Rives LLP AFFIDAVIT OF MARY S. HOBSON IN SUPPORT OF QWEST CORPORATION'S MOTION FOR EXTENSION OF TIME TO FILE APPELLANT'S BRIEF - Page 4 Boise-166811.1 0029164-00082 Mary S. Hobson (ISB #2142) Stoel Rives LLP 101 South Capitol Boulevard - Suite 1900 Boise, ID 83702 Telephone: (208) 387-4277 Facsimile: (208) 389-9040 msho bson((!),stoel. com Charles W. Steese Steese & Evans, P. 6400 S. Fiddlers Green Circle, Suite 1820 Denver, CO 80111 Telephone: (720) 200-0677 Facsimile: (720) 200-0679 csteese((!),s-elaw.com IN THE SUPREME COURT OF THE STATE OF IDAHO IDAHO TELEPHONE ASSOCIATION CITIZENS TELECOMMUNICATIONS COMP ANY OF IDAHO, CENTURYTEL OF IDAHO , CENTURYTEL OF THE GEM STATE, POTLATCH TELEPHONE COMP ANY and ILLUMINET, INe. Docket No. 301Q7 DC Docket No. QW-03- Respondents vs. QWEST CORPORATION Appellant. AFFIDAVIT OF CHARLES W. STEESE IN SUPPORT OF QWEST CORPORATION'S MOTION FOR EXTENSION OF TIME TO FILE APPELLANT' BRIEF , Charles W. Steese, being over 18 years old and having personal knowledge of each fact asserted in this Affidavit, hereby attest as follows. Qwest's Appellant's Brief is presently due on February 18 2004. No extensions of time have previously been granted on this brief. No previous requests for extensions of time have been denied or denied in part. The reason that the extension is necessary is that I am involved in representing Qwest Corporation in a series of proceedings emanating fTom the Federal Communications Commission triennial review decision.In Re Review of the Section 251 Unbundling Obligations of Incumbent Local Exchange Carriers FCC 03-36Al , (released Aug. 21 , 2003). These proceedings require several filings in each of ten states (Arizona, Colorado, Iowa Minnesota, Nebraska, New Mexico, North Dakota, Oregon, Utah, and Washington) between now and the currently scheduled deadline for the Appellant's Brief in this case. These filings are expected to be several hundred pages long. In particular, I have such a filing due in each of ten states on February 17, 2004 , the day before the Appellant's Brief is due in this case. These proceedings also require me to participate in hearings for the entire first and third weeks of March 2004: March 1-5 and March 15-2004. Because the FCC specifically requires each of the state commissions to issue decisions fTom these proceedings on or before July 2, 2004 (see Triennial Review Order, at ~ 417), I am not able to reset those deadlines. At the same time Qwest's appeal in this case requires briefing the Court on complex telecommunications facts and will require substantial time on my part in preparing the Appellant's Brief. The schedule imposed by the Triennial Review related proceedings will not allow adequate time for the preparation of Qwest's Appellant's Brief in this case. Accordingly, an extension of 42 calendar days is necessary, and the Appellant's Brief would become due on April 1 , 2004. I spoke with counsel for the Respondents regarding Qwest's request for an extension.Opposing counsel did not decide whether Respondents would oppose Qwest's Motion for Extension.Opposing counsel does not object to Qwest's Motion to Expedite Decision on the Motion for Extension. Qwest will file its Appellant's Brief within the extended time , as I assure the Court I will devote the time necessary for preparing the Appellant's Brief between February 17 2004 and April 1 , 2004. I attest under penalty of perjury the truth and accuracy of the foregoing facts, and respectfully request that Qwest's Motion be granted. Charles W. Steese STATE OF ARIZONA SS: COUNTY OF PIMA On this day of January, 2004, before me personally appeared Charles W. Steese, to me known to be the person described in and who executed the foregoing instrument, and acknowledged that he executed the same as his :tree act and deed. IN TESTIMONY WHEREOF, I have hereunto set my hand and affixed my official seal in the County and State aforesaid, the day and year first above written. Notary Public My commission expires: