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Home My WebLink About20070402ITA to EDG 1-5.pdfConley E. Ward (ISB No. 1683) Michael C. Creamer (ISB No. 4030) GIVENS PURSLEY LLP 601 W. Bannock Street O. Box 2720 Boise, ID 83701-2720 Telephone No. (208) 388-1200 Fax No. (208) 388-1300 cew(fY gi venspursley. com mcc(fYgivenspursley.com :E:(; \~: , \- 2001 t.FR -2 PH lj: 0 I ;\.J A\SS!Cj, Attorneys for Idaho Telephone Association BEFORE THE IDAHO PUBLIC UTILITIES COMMISSION IN THE MATTER OF THE PETITION OF EDGE WIRELESS, LLC FOR DESIGNATION AS AN ELIGIBLE TELECOMMUNICATIONS CARRIER UNDER 47 U.C. ~ 214(e)(2) Case No. EDG-07- IDAHO TELEPHONE ASSOCIATION' FIRST SET OF DISCOVERY REQUESTS TO EDGE WIRELESS The Idaho Telephone Association ("ITA"), by and through its attorneys Givens Pursley LLP, and pursuant to the Commission s Rules of Procedure, propounds the following Interrogatories, Requests for Production, and Requests for Admission to Edge Wireless, LLC in connection with its Petition for Designation as an Eligible Telecommunications Carrier. PRELIMINARY STATEMENT In answering these interrogatories, requests for production and requests for admission furnish all information available to you, including information in the possession or your attorney (and experts, etc., retained by your and your attorneys) not merely information known of your own personal knowledge. IDAHO TELEPHONE ASSOCIATION'S FIRST SET OF DISCOVERY REQUESTS TO EDGE WIRELESS - Page 1 of 6 S:\CLIENTS\1233\198\ITA First Discovery RequestDOC If you cannot answer the following interrogatories, requests for production and requests for admission in full after exercising due diligence to secure the information to do so, so state and answer to the extent possible, specifying your inability to answer the remainder, and stating whatever information and knowledge you have concerning the unanswered portion. Because of the Petitioner s request for expedited treatment of this matter, it is requested that you produce the documents herein requested for inspection and copying as soon as possible but in no event later than within twenty-eight (28) days after receipt of this request. You may produce said documents at the office of Givens Pursley LLP, 601 West Bannock Street, P. Box 2720, Boise, Idaho 83701 , or by copying or mailing said documents to the attorney for IT via U.S. Mail, on or before said date. Unless you furnish copies of all of the following requested documents by delivering or mailing them to counsel, upon production you will be required to keep such documents available for a reasonable time thereafter to enable counsel to inspect and to photocopy said documents. DEFINITIONS Document" or "Documentary" means and includes any and all tangible things and papers, whether written, recorded, graphic, typewritten, printed, photographed or otherwise produced or reproduced, and whether produced manually or by mechanical, electrical , electronic or other artificial process or a combination of these methods, including but not limited to papers computer records and/or files, agreements , contracts, letters, cables, wires, notes, memoranda correspondence, telegrams, patents, books, reports, studies, minutes, records, accounting books maps , plans, blue prints, sketches, charts, drawings, diagrams, photographs , movies , films computer printouts, tape recordings, information stored on computers, assignments, notebooks ledgers, billings, statements, invoices, checks, receipts, analyses, surveys, transcriptions IDAHO TELEPHONE ASSOCIATION'S FIRST SET OF DISCOVERY REQUESTS TO EDGE WIRELESS - Page 2 of 6 S:\CLIENTS\1233\198\ITA First Discovery RequestDOC recordings, analyses, studies, of which you have any knowledge or information, referring, relating or pertaining in any way to the subject matters in connection with which the word is used. The term "Document" or "Documentary" includes, without limitation, originals, all file copies, and all the copies no matter how or by whom prepared and all drafts prepared in connection with such writings, whether used or not. Person" shall mean and include a natural person, partnership, corporation or other legal entity together with its principals, agents, employees, representatives and assigns. You" or "Your" means the Petitioner Edge Wireless, LLC, together with its counsel, consultants, experts, investigators, principals, agents, employees, representatives predecessors in interest and any other Person acting on their behalf. These requests include all Documents in Your possession or under Your control including Documents in the possession of Your attorneys, accountants, expert witnesses or other agents or Persons from whom You have a legal right to obtain such Document. All of the interrogatories and requests herein are deemed continuing. If, after responding to these interrogatories and requests for production You acquire any further information or any Documents requested herein, or any other information related to any Document herein, which is not reflected by any Documents produced or any response to these interrogatories and requests for production, You must file a supplemental response or indicate to counsel for the party propounding these interrogatories and requests for production of the existence of such Documents. If any Document or any portion of any Document or any other information which is requested herein is or will be withheld from Your answers to interrogatories, from production inspection or copying (whether because it is claimed to be work product, communication from IDAHO TELEPHONE ASSOCIATION'S FIRST SET OF DISCOVERY REQUESTS TO EDGE WIRELESS - Page 3 of 6 S:\CLIENTS\ 1233\198\IT A First Discovery RequestDOC attorney to client, or is claimed to be entitled to be withheld for any other reason), please fully identify each such Document or portion thereof in Your response and fully state in Your response the reason it is or will be withheld. In addition, if any Document is practically impossible of production, inspection or copying, please fully identify such Document and the reason for the practical impossibility. INTERROGATORIES INTERROGATORY NO.State the name, employer, and job title of each and every Person you intend to call as a witness in this matter. REQUESTS FOR PRODUCTION REQUEST FOR PRODUCTION NO.Please provide a color copy of all Exhibits attached to your Application in this matter. REQUEST FOR PRODUCTION NO.Please provide copies of all Documents You have furnished to the Idaho Public Utilities Commission or its Staff in any way related to this Petition or its subject matter. REQUEST FOR PRODUCTION NO.Please list all states where You have applied for Eligible Telecommunications Carrier status, together with a complete citation to the proceedings on such applications. If a final order has been issued in connection with such application(s), please provide a copy of such order. REQUEST FOR PRODUCTION NO.Please provide a detailed area coverage map of Your service area( s) within the Rural ILEC Wire Centers listed in Exhibit C to your Petition. At a minimum, the requested map should detail the location of Your cell towers, whether owned or provided by another party, together with a description of the equipment installed at each site and the signal strength for such equipment and its area coverage. IDAHO TELEPHONE ASSOCIATION'S FIRST SET OF DISCOVERY REQUESTS TO EDGE WIRELESS - Page 4 of 6 S:\CLlENTS\1233\198\ITA First Discovery RequestDOC REQUEST FOR PRODUCTION NO.Please list, by Idaho Rural ILEC Wire Center and date of application, the number of Your held orders or unfulfilled service requests, together with any Documents related to such held orders or service requests and state whether or not You intend to fulfill them, and, if so, the time and the manner in which You intend to fulfill them. You may omit the name ~'f the ~J cants from such Documents, DATED this -E day of 2007. &J~ Co eyE. W GIVENS PURSLEY LLP Attorneys for Idaho Telephone Association IDAHO TELEPHONE ASSOCIATION'S FIRST SET OF DISCOVERY REQUESTS TO EDGE WIRELESS - Page 5 of 6 S:\CLIENTS\ 1233\198\IT A First Discovery RequestDOC CERTIFICATE OF SERVICE t, ~ - I HEREBY CERTIFY that on this day of NY..... 2007, I caused to be served a true and correct copy of the foregoing document by t e method indicated below and addressed to the following: Commission Secretary Idaho Public Utilities Commission 472 W. Washington Street O. Box 83720 Boise, ID 83720-0074 S. Mail Hand Delivered Overnight Mail Facsimile Email Mark P. Trinchero Davis, Wright & Tremaine LLP 1300 S.W. 5th Ave., Suite 2300 Portland, OR 97201 Email: marktrinchero(fYdwt.com S. Mail Hand Delivered Overnight Mail Facsimile Email Molly O'Leary Richardson & O'Leary, PLLC O. Box 7218 Boise, ID 83707 Email: molly(fYrichardsonandoleary.com 'f-S. Mail Hand Delivered Overnight Mail Facsimile Email Dean J. Miller McDevitt & Miller LLP 420 W. Bannock Street O. Box 2564 Boise, ID 83701-2564 Email: joe(fYmcdevitt-miller.com S. Mail Hand Delivered Overnight Mail Facsimile Email Nathan Glazier Regional Manager, State Affairs All Tel Communications, Inc. 4805 Thistle Landing Dr. Phoenix, AZ 85044 Email: nathan.glazier(fYalltel.com u.S. Mail Hand Delivered Overnight Mail Facsimile Email IDAHO TELEPHONE ASSOCIATION'S FIRST SET OF DISCOVERY REQUESTS TO EDGE WIRELESS - Page 6 of 6 S:\CLIENTS\1 233\1 98\IT A First Discovery Request.DOC