20031210Qwest Objections to AT&T Requests.pdf

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Mary S. Hobson (ISB #2142)
Stoe1 Rives LLP
101 South Capitol Boulevard - Suite 1900
Boise, ID 83702
Telephone: [phone]
Facsimile: [phone]
mshobson~stoel.com
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Adam L. Shell' (WSBA #25291)
Qwest
1600 ih Avenue - Room 3206
Seattle, W A 98191
Telephone: [phone]
Facsimile: [phone]
adam.shell'~qwest.com
Attorneys for Qwest Corporation
BEFORE THE IDAHO PUBLIC UTILITIES COMMISSION
IN THE MATTER OF IPUC RESPONSE TO
FCC ORDER ON REVIEW OF SECTION 251
UNBUNDLING OBLIGATIONS OF
INCUMBENT LOCAL EXCHANGE
CARRIERS (CC DOCKET NO. 01-338)
Case No. GNR-03-
NINE-MONTH REVIEW OF ECONOMIC
AND OPERATIONAL IMPAIRMENT
REGARDING ACCESS TO SPECIFIC UNES
QWEST CORPORATION'S OBJECTIONS
TO AT&T COMMUNICATIONS OF THE
MOUNTAIN STATES, INc.'S FIRST SET OF
DISCOVERY REQUESTS
Qwest Corporation ("Qwest") pursuant to Rule 225 of the Rules of Procedure of the
Idaho Public Utilities Commission hereby submits the following objections to the First Set of
Discovery Requests filed by AT&T Communications of the Mountain States, Inc. (AT&T).
INTRODUCTION
Qwest lodges numerous objections to the discovery propounded by AT&T. It is
important to understand the context for these objections. First, it is critical to be clear about the
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issues that are part of the case and the issues that are not because discovery must bear a
reasonable relationship to the issues in the proceeding. The Federal Communications
Commissions
' ("
FCC") Triennial Review Order ("TRO") 1 is a lengthy and complicated order
that addresses a wide all'ay of unbundling and other issues under the Federal Act. However , this
docket does not purport to address all of those issues. Indeed, while the issues in this case are
not simple, this case is nan-owly focused on one general issue: whether Qwest is entitled to relief
from its obligation to provide unbundled switching for mass market customers in certain portions
ofIdaho. The focus of the mass market switching docket is on what individual competitors
(including CLECs) are actually doing or what an efficient CLEC would be able to do.
AT &T ignores this focus and seeks information from Qwest related to mass market or
high-capacity loop unbundling, enterprise switching unbundling, dedicated transport unbundling,
next-generation loops, line sharing, line splitting, or any other high-capacity or next generation
services, none of which is related to this case.
Despite the fact that the inquiry in this case is primarily focused on the actual and
potential activities ofCLECs and other competitors in Idaho, AT&T propounded 128 separate
data requests. Many of them have as many as 5 subparts. Further, even though Qwest has stated
that it did not intend to pursue either a high-capacity loop case or a dedicated transport case in
Idaho, many of AT&T's questions appear to be focused on loop and transport issues. Given the
fact that Qwest is not pursuing a loop case or a dedicated transport case, Qwest does not intend
to respond to those questions.
Report and Order and Order on Remand and Further Notice of Proposed Rulemaking, In the Matter of
Review of the Section 251 Unbundling Obligations of Incumbent Local Exchange Carriers, Implementation of the
Local Competition Provisions of the Telecommunications Act of 1996 Deployment of Wireline Service Offering
Advance Telecommunications Capability, CC Docket Nos. 01-338, 96-98 and 98-147 (August 21 2003) ("TRO"
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GENERAL OBJECTIONS
Qwest objects to providing answers to data requests that require production of
CLEC/Carrier specific data. The information requested pursuant to these data requests seeks
CLEC/Carrier-specific information that may be protected under paragraph (a) Section 222
Privacy of Customer Information ) of the Communications Act of 1934, 47 US. c. Ii 151 et.
seq, and/or other state and federal privacy laws. Qwest will provide the requested CLEC
information upon receiving either: (1) a Commission order requiring production of the
information; or (2) permission by the CLEC to release the requested information.
Qwest objects to AT&T's data requests to the extent they seek to impose an
obligation on Qwest to respond on behalf of subsidiaries, affiliates, or other persons that are not
parties to this case on the grounds that such discovery is overly broad, unduly burdensome
oppressive and not permitted by the applicable discovery rules. Qwest will not be responding to
discovery that seeks information from parent, subsidiary and/or affiliate companies.
Qwest objects to each and every AT&T data request that seeks information on a
region-wide basis insofar as these requests are overly broad, unduly burdensome and seek
information that is ill'e1evant to Qwest's mass-market switching case in Idaho.
Qwest objects to each and every data request to the extent that such request may
call for information that is exempt from discovery by virtue of the attorney-client privilege, or
other applicable privilege.
Qwest objects to these data requests to the extent they seek third party vendor
proprietary information that Qwest is under contractual obligation to maintain as confidential.
Subject to this objection and all other objections, Qwest is in the process of obtaining vendor
authorization in order to provide responsive information, if applicable.
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Qwest objects to these data requests insofar as they are vague, ambiguous, overly
broad, unduly burdensome, or utilize terms that are subject to multiple interpretations but are not
properly defined or explained for purposes of these data requests. Any and all answers of Qwest
in response to these data requests will be provided subject to, and without waiving, this
objection.
Qwest objects to each and every data request insofar as it is not reasonably
calculated to lead to the discovery of admissible evidence and is not relevant to the subject
matter of this action. While CLEC and Carrier data is relevant to the analysis the Commission
must perform in Qwest's mass market switching case concerning the ability of a CLEC/Carrier
to deploy switches to serve mass market customers, Qwest's data is not relevant to this analysis.
Qwest objects to providing information to the extent such information is already a
matter of public record before this or any other state commission or federal agency, or is
otherwise available as a matter of public record. Particularly in light of the voluminous nature of
AT &T' s requests , AT&T is not entitled to require other parties to gather information that is
equally available and accessible to them.
Qwest objects to these data requests, instructions and definitions insofar as they
are vague, ambiguous, overly broad, unduly burdensome and/or seek to impose obligations on
Qwest that exceed the requirements of the Commission s Rules of Procedure and the Idaho Rules
of Civil Procedure.
10.Qwest objects to the manner in which certain data is requested. Qwest may not
maintain information in the ordinary course of its business in the particular format requested by
AT&T. Qwest objects to providing responsive information in the format requested by AT&T on
the grounds that doing so would be overly broad, unduly burdensome, and oppressive.
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11.Qwest obj ects to AT&T's data requests to the extent that they seek to have Qwest
create documents not in existence at the time of the request and would require a special study.
12.Further, in light ofthe short time frames in this proceeding and due to the
voluminous data requests served by AT&T, Qwest has attempted to provide specific objections
to data requests. However, due to the compressed schedule in this and other proceedings, Qwest
reserves the right to lodge additional objections in its responses.
13.Finally, Qwest has a general objection with respect to all data requests concerning
the batch hot-cut process. Pursuant to the agreement reached between Qwest, AT&T and MCI
outlined in a joint filing made with this Commission on October 31 , 2003 , Qwest submitted its
batch hot cut proposal. The proposal includes a detailed description of the process, including but
not limited to capacity, Pre-ordering, Ordering and Provisioning, and the intervals. Qwest
believes that many of the batch hot cut process data requests AT&T has proffered will be
addressed in the Qwest proposal. To the extent a data request is not addressed in the Qwest
proposal and is not otherwise objectionable, Qwest will respond to that data request.
AT&T 001 Re:Switch Triggers - Competitive Wholesale Facilities
Please identify any telecommunications carriers (including Independent Local Exchange
Companies ("ILECs ) or Competitive Local Exchange Companies ("CLECs )) that you have
identified as being willing to provide, intending to provide, or cull'ently making available
wholesale unbundled local switching used in combination with unbundled analog loops obtained
from the ILEC to CLECs. Additionally, please:
Produce any documents substantiating any assertion that an unaffiliated
competitive switch provider qualifies as a wholesale provider and identifying the
product, customer and geographic market served by such wholesale provider.
Identify by wire center each wholesale alternative to ILEC circuit switching and
provide the basis upon which you believe such entity qualifies as a wholesale
provider.
Produce any documents substantiating any assertion that a non- ILEC wholesale
circuit switching provider is operationally ready to provide wholesale switching
and that such provider and the ILEC have procedures in place to enable a carrier
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purchasing an ILEC analog loop to provide service of equivalent quality using
another non- ILEC carrier s switch.
Produce any documents, information, notes, work papers, or communications
from the identified company in your possession or control relating to the
identified company s ability, intent, desire, or willingness to provide or to make
available wholesale unbundled local switching to CLECs.
Identify any other companies, other than telecommunications carriers, that are
willing to offer wholesale unbundled switching to CLECs. Please provide the
name, address, and telephone number of each identified companies.
OBJECTION: Qwest objects to this request to the extent it seeks information protected by
the attorney client and/or attorney work product privileges. Without waiving this
objection Qwest will provide any and all general information it has relating to carriers that
have been identified as being willing to provide, intending to provide, or currently making
available, wholesale unbundled local switching used in combination with unbundled analog
loops obtained from the ILEC to CLECs, in its written testimony on January 19 , 2004.
Qwest objects to the extent this request seeks CLEC/carrier specific information which
protected by Section 222 of the Communications Act of 1934 47 U.c. ~ 222, or other
privacy laws. Qwest will produce such information upon receipt of a Commission order
compelling Qwest to do so. Qwest also objects on the grounds that this request seeks
information that is neither relevant to these proceedings nor reasonably calculated to lead
to the discovery of admissible evidence. Qwest is unable at this point to specifically define
the markets in which it will seek relief from unbundling obligations for switching for mass
market customers. Qwest intends to specifically define those market areas in its testimony
to be filed on Januaryl9, 2004. Once those market areas are defined, all requested
information for CLLI codes and/or wire centers outside of those areas will be irrelevant in
this docket. Without waiving these objections, within a reasonable time after Qwest makes
its proposed market definitions, Qwest will respond to relevant requests with relevant
information.
AT&T 002 Re:Switch Triggers - Competitive Wholesale Facilities
For each carrier listed in AT&T 001 , please provide for each switch you claim provides a
wholesale alternative:
The 11-digit CLLI code of the switch as it appears in the LERG, the V
coordinates ofthe switch from the LERG, and claimed function of the switch
(e.stand-alone, host, or remote);
For each applicable CLLI code: the associated LATA number; MSA number (if
applicable); the V &H coordinates; the latitude and longitude (L&L) coordinates;
the UNE loop rate zone; the special access density zone and whether interstate
special access pricing flexibility is applicable for that end office;
The location of each collocation all'angement that you claim is interconnected to
the switch;
The number ofloops, by type (i.analog UNE, DS-1 UNE, analog special
access, DS-1 Special Access, etc.) provisioned to each collocation:(i) Within the last 3 months;
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(ii)
(iii)
(iv)
Within the last 6 months; and
Within the past year; and
The number of loops, by type (i.analog UNE, DS-1 UNE
analog special access, DS-1 Special Access, etc.) in-service at each
collocation as of September 30 2003.
OBJECTION: Qwest objects to this request to the extent it seeks information protected by
the attorney client and/or attorney work product privileges. Without waiving this
objection Qwest will provide any and all general information it has relating to carriers that
have been identified as being willing to provide, intending to provide, or currently making
available, wholesale unbundled local switching used in combination with unbundled analog
loops obtained from the ILEC to CLECs, in its written testimony on Januaryl9, 2004.
Qwest objects to the extent this request seeks CLEC/carrier specific information which is
protected by Section 222 of the Communications Act of 1934 47 U.c. ~ 222, or other
privacy laws. Qwest will produce such information upon receipt of a Commission order
compelling Qwest to do so. Qwest also objects on the grounds that this request seeks
information that is neither relevant to these proceedings nor reasonably calculated to lead
to the discovery of admissible evidence. Qwest is unable at this point to specifically define
the markets in which it will seek relief from unbundling obligations for switching for mass
market customers. Qwest intends to specifically define those market areas in its testimony
to be filed on January 19, 2004. Once those market areas are defined, all requested
information for CLLI codes and/or wire centers outside of those areas will be irrelevant in
this docket. Without waiving these objections, within a reasonable time after Qwest makes
its proposed market definitions, Qwest will respond to relevant requests with relevant
information.
AT&T 003 Re:Switch Triggers - Self Provisioning
Identify by wire center each unaffiliated competitive switch provider that you assert qualifies as
a retail self provider and detail the basis upon which you believe such entity qualifies as a self
provider, including the geographic markets within which each unaffiliated competitive switch
provider is providing service and the product and customer markets reached by each unaffiliated
competitive switch provider.
Produce any documents substantiating any assertion that an unaffiliated
competitive switch provider qualifies as a self provider and include the
product, customer and geographic market served by such self provider;
Identify by wire center each wholesale alternative to ILEC circuit
switching and provide the basis upon which you believe such entity
qualifies as a self-provider; and
Produce any documents, information, notes, work papers, or
communications from the identified company in your possession or
control relating to the identified company s ability, intent, desire, or
willingness to provide or to make available wholesale unbundled local
switching to CLECs.
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OBJECTION: Qwest objects to this request to the extent it seeks information protected by
the attorney client and/or attorney work product privileges. Without waiving this
objection Qwest will provide any and all general information it has relating to carriers that
have been identified as being willing to provide, intending to provide, or currently making
available, wholesale unbundled local switching used in combination with unbundled analog
loops obtained from the ILEC to CLECs, in its written testimony on January 19, 2004.
Qwest objects to the extent this request seeks CLEC/carrier specific information which is
protected by Section 222 of the Communications Act of 1934 47 U.c. ~ 222, or other
privacy laws. Qwest will produce such information upon receipt of a Commission order
compelling Qwest to do so. Qwest also objects on the grounds that this request seeks
information that is neither relevant to these proceedings nor reasonably calculated to lead
to the discovery of admissible evidence. Qwest is unable at this point to specifically define
the markets in which it will seek relief from unbundling obligations for switching for mass
market customers. Qwest intends to specifically define those market areas in its testimony
to be filed on January 19,2004. Once those market areas are defined, all requested
information for CLLI codes and/or wire centers outside of those areas will be irrelevant in
this docket. Without waiving these objections, within a reasonable time after Qwest makes
its proposed market definitions, Qwest will respond to relevant requests with relevant
information.
AT&T 004 Re:Switch Triggers - Self Provisioning
For each carrier listed in the previous question, please provide for each switch you claim is used
for self provisioning:
The 11-digit CLLI code of the switch as it appears in the LERG, the V &H
coordinates of the switch from the LERG, and claimed function of the switch
(e., stand-alone, host, or remote);
For each applicable CLLI code: the associated LATA number; MSA number (if
applicable); the V &H coordinates; the L&L coordinates; the UNE loop rate zone;
the special access density zone and whether interstate special access pricing
flexibility is applicable for that end office;
The location of each collocation all'angement that you claim is interconnected to
the switch;
The number ofloops, by type (i.analog UNE, DS-1 UNE, analog special
access, DS-1 Special Access, etc.) provisioned to each collocation:(i) Within the last 3 months(ii) Within the last 6 months
(iii) Within the past year; and
(iv) The number of loops, by type (i.analog UNE, DS-1 UNE, analog
special access, DS-1 Special Access, etc.) in-service at each collocation as
of September 30, 2003.
OBJECTION: Qwest objects to this request to the extent it seeks information protected by
the attorney client and/or attorney work product privileges. Without waiving this
objection Qwest will provide any and all general information it has relating to carriers that
have been identified as being willing to provide, intending to provide, or currently making
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available, wholesale unbundled local switching used in combination with unbundled analog
loops obtained from the ILEC to CLECs, in its written testimony on January 19,2004.
Qwest objects to the extent this request seeks CLEC/carrier specific information which is
protected by Section 222 of the Communications Act of 1934,47 U.c. ~ 222, or other
privacy laws. Qwest will produce such information upon receipt of a Commission order
compelling Qwest to do so. Qwest also objects on the grounds that this request seeks
information that is neither relevant to these proceedings nor reasonably calculated to lead
to the discovery of admissible evidence. Qwest is unable at this point to specifically define
the markets in which it will seek relief from unbundling obligations for switching for mass
market customers. Qwest intends to specifically define those market areas in its testimony
to be filed on January 19, 2004. Once those market areas are defined, all requested
information for CLLI codes and/or wire centers outside of those areas will be irrelevant in
this docket. Without waiving these objections, within a reasonable time after Qwest makes
its proposed market definitions, Qwest will respond to relevant requests with relevant
information.
AT&T 005 Re:Network and Market Demand - Switch Information
For each switch (e.
g.
circuit, packet, soft switch, etc.) that you have used or could use to provide
local service in Idaho (this would include switches located in other states that provide or have the
ability to provide local exchange service in Idaho) please provide the following information for
the switch and/or the switch location:
the physical location of each switch (i.the street address);
the area the switch serves (by wire center);
the services provided by the switch;
the utilized trunk line, trunk and processor capacity;
the potential line, trunk and processor capacity;
OBJECTION: Qwest objects to this data request on the grounds that it is overly broad
and unduly burdensome. Qwest further objects on the grounds that this request seeks
information that is neither relevant to these proceedings nor reasonably calculated to lead
to the discovery of admissible evidence. Qwest is unable at this point to specifically define
the markets in which it will seek relief from unbundling obligations for switching for mass
market customers. Qwest intends to specifically define those market areas in its testimony
to be filed on January 19, 2004. Once those market areas are defined, all requested
information for CLLI codes and/or wire centers outside of those areas will be irrelevant in
this docket. Within a reasonable time after Qwest makes its proposed market definitions,
Qwest will respond to relevant requests with relevant information.
AT&T 006 Re:Network and Market Demand - Switch Information
For each switch identified in AT&T 005, provide the following information:
the total number of voice-grade equivalent lines served by the switch (by wire
center)
the number of voice-grade equivalent lines being provided to business customers
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the number of DSO voice-grade equivalent lines being provided to business
customers
the number of voice-grade equivalent lines being provided to residential
customers
the switch type (e.Lucent 5ESS);
OBJECTION: Qwest objects to this data request on the grounds that it is overly broad
and unduly burdensome. Qwest further objects on the grounds that this request seeks
information that is neither relevant to these proceedings nor reasonably calculated to lead
to the discovery of admissible evidence. Qwest is unable at this point to specifically define
the markets in which it will seek relief from unbundling obligations for switching for mass
market customers. Qwest intends to specifically define those market areas in its testimony
to be filed on January 19, 2004. Once those market areas are defined, all requested
information for CLLI codes and/or wire centers outside of those areas will be irrelevant in
this docket. Within a reasonable time after Qwest makes its proposed market definitions
Qwest will respond to relevant requests with relevant information.
AT&T 007 Re:Network and Market Demand- Switch Information
For each switch identified in AT&T 005 , provide the following information:
the 11-digit Common Language Location ("CLLI") code of the switch;
the vertical and horizontal ("V &H") coordinates of the switch;
function of the switch (e.stand-alone, host, or remote); and
whether each CLLI offers International Direct Distant Dialing ("IDDD"
OBJECTION: Qwest objects to this data request on the grounds that it is overly broad
and unduly burdensome. Qwest further objects on the grounds that this request seeks
information that is neither relevant to these proceedings nor reasonably calculated to lead
to the discovery of admissible evidence. Qwest is unable at this point to specifically define
the markets in which it will seek relief from unbundling obligations for switching for mass
market customers. Qwest intends to specifically define those market areas in its testimony
to be filed on January 19,2004. Once those market areas are defined, all requested
information for CLLI codes and/or wire centers outside of those areas will be irrelevant in
this docket. Within a reasonable time after Qwest makes its proposed market definitions,
Qwest will respond to relevant requests with relevant information.
AT&T 008 Re:Network and Market Demand - Switch Information; Out of Region
For each switch (e.
g.,
circuit, packet, soft switch, etc.) that you have used or could use to provide
local service outside of the territory for which you are an incumbent please provide the following
information for the switch and/or the switch location:
the physical location of each switch (i.the street address);
the area the switch serves (by wire center);
the services provided by the switch;
the utilized trunk line, trunk and processor capacity; and
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the potential line, trunk and processor capacity;
OBJECTION: Qwest objects to this request on the grounds that the information sought in
the data request is neither relevant nor reasonably calculated to lead to the discovery of
admissible evidence. Qwest also objects to this data request in that it does not seek
information concerning Qwest Corporation but seeks information concerning Qwest
Corporation s Section 272 affiliates. Qwest further objects to this data request on the
grounds that it is overly broad and unduly burdensome. Without waiving these objections
Qwest affirmatively states that neither it nor its affiliates provide local service out of
region.
AT&T 009 Re:Network and Market Demand - Switch Information; Out of Region
For each switch identified in AT&T 008, provide the following information:
the total number of voice-grade equivalent lines served by the switch (by wire center);
the number of voice-grade equivalent lines being provided to business customers;
the number ofDSO voice-grade equivalent lines being provided to business customers;
the number of voice-grade equivalent lines being provided to residential customers; and
the switch type (e.Lucent 5ESS);
OBJECTION: Qwest objects to this request on the grounds that the information sought in
the data request is neither relevant nor reasonably calculated to lead to the discovery of
admissible evidence. Qwest also objects to this data request in that it does not seek
information concerning Qwest Corporation but seeks information concerning Qwest
Corporation s Section 272 affiliates. Qwest further objects to this data request on the
grounds that it is overly broad and unduly burdensome. Without waiving these objections
Qwest affirmatively states that neither it nor its affiliates provide local service out of
region.
AT&T 010 Re:Network and Market Demand - Switch Information; Out of Region
For each switch identified in AT&T 008 , provide the following information:
the 11-digit CLLI code of the switch;
the vertical and horizontal V &H coordinates of the switch;
function of the switch (e.stand-alone, host, or remote); and
whether each CLLI offers IDDD.
OBJECTION: Qwest objects to this request on the grounds that the information sought in
the data request is neither relevant nor reasonably calculated to lead to the discovery of
admissible evidence. Qwest also objects to this data request in that it does not seek
information concerning Qwest Corporation but seeks information concerning Qwest
Corporation s Section 272 affiliates. Qwest further objects to this data request on the
grounds that it is overly broad and unduly burdensome. Without waiving these objections
Qwest affirmatively states that neither it nor its affiliates provide local service out of
region.
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AT&T 015 Re:Network and Market Demand - Loops
Provide the number ofloops, by Central Office (by applicable CLLI code), in Idaho that are
cull'ently served by each of the following:
IDLC an-angements;
NGDLC an-angements;
UDLC all'angements; and
Of the IDLC loops, please state how many loops are transferable to
universal digital loop carrier (UDLC) without additional construction.
OBJECTION: Qwest objects on the grounds that this request seeks information that is
neither relevant to these proceedings nor reasonably calculated to lead to the discovery of
admissible evidence. Qwest is unable at this point to specifically define the markets in
which it will seek relief from unbundling obligations for switching for mass market
customers. Qwest intends to specifically define those market areas in its testimony to be
filed on January 19, 2004. Once those market areas are defined, all requested information
for CLLI codes and/or wire centers outside of those areas will be irrelevant in this docket.
Without waiving these objections, within a reasonable time after Qwest makes its proposed
market definitions, Qwest will respond to relevant requests with relevant information.
AT&T 016 Re:Network and Market Demand - Loops
Provide a forecast for the next five years, or the longest available forecast if a five-year forecast
is not available, identifying the number of loops in Idaho that you intend to serve via:
IDLC loop an-angements; and
NGDLC loop an-angements.
OBJECTION: Qwest objects to this request on the grounds that this data request seeks
information that is not relevant or reasonably calculated to lead to the discovery of relevant
evidence. Qwest also objects to this data request on the grounds that it is overly broad and
unduly burdensome.
AT&T 018 Re:Network and Market Demand - NGDLC
Have you considered deploying NGDLC all'angements that packetize both the voice and data
services? If so, please describe any such alternatives considered and produce any documents that
refer, relate to or discuss your deployment ofNGDLC all'angements that packetize both the
voice and data services.
OBJECTION: Qwest objects to this request on the grounds that the information sought in
the data request is not relevant or reasonably calculated to lead to the discovery of
admissible evidence.
AT&T 019 Re:Network and Market Demand - DSL Capable Loops
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By wire center, please provide the percentage of copper loops that are located within 18 000 feet
of Qwest' s Central Offices.
OBJECTION: Qwest objects to this request on the grounds that this data request seeks
information concerning DSL service that is not relevant or reasonably calculated to lead to
the discovery of relevant evidence.
AT&T 020 Re:Network and Market Demand - Loops, Line Splitting
Identify the overall number and percentage of loops in Qwest territory in Idaho that are cull'ently
provisioned on:
All-copper loop facilities without pair-gain devices of any type (e.
analog pair gain, DAMLs, etc.
All-copper loop facilities with pair gain devices.
All-copper loop facilities less than 18K feet in length.
All-copper loop facilities greater than 18K feet in length.
OBJECTION: Qwest objects to this request on the grounds that this data request seeks
information concerning DSL capable loops and line splitting that is not relevant or
reasonably calculated to lead to the discovery of admissible evidence.
AT&T 021 Re:Network and Market Demand - Loops, Line Splitting
Identify the overall number and percentage of loops in Qwest territory in Idaho that are cull'ently
provisioned on:
Fiber-fed DLC facilities that do not support DSL.
Fiber-fed DLC facilities that do or will support DSL.
OBJECTION: Qwest objects to this request on the grounds that this data request seeks
information concerning DSL capable loops and line splitting that is not relevant or
reasonably calculated to lead to the discovery of admissible evidence.
AT&T 022 Re:Network and Market Demand - Copper Loops, DLC
Please provide the number oflines served by DLC for which alternative copper loop facilities are
cull'ently not available.
OBJECTION: Qwest objects to this request on the grounds that the information sought in
the data request is not relevant or reasonably calculated to lead to the discovery of
admissible evidence.
AT&T 023 Re:Network and Market Demand - Copper Loops, Retirement
Describe with specificity your plans to retire any copper loop plant in Idaho.
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OBJECTION: Qwest objects to this request on the grounds that the information sought in
the data request is not relevant or reasonably calculated to lead to the discovery of
admissible evidence.
AT&T 024 Re:Network and Market Demand - Copper Loops, Retirement
Please provide a copy of any studies, reports, memorandum, email or documents describing your
plans to retire any copper loop plant in Idaho.
OBJECTION: Qwest objects to this request on the grounds that the information sought in
the data request is not relevant or reasonably calculated to lead to the discovery of
admissible evidence.
AT&T 025 Re:Network and Market Demand - Copper Loops, Retirement
Please describe with specificity the process you use in retiring a copper loop plant. Please
specifically include in your answer the notice you provide to CLECs who have customers that
provide service using the plant and what options will be available to CLECs providing voice
and/or DSL service to customers served by the copper loop plant you plan to retire.
OBJECTION: Qwest objects to this request on the grounds that the information sought in
the data request is not relevant or reasonably calculated to lead to the discovery of
admissible evidence.
AT&T 026 Re:Network and Market Demand - Availability, TIs
For each month beginning in January 2000 and extending to the most recent month for which
data is available, provide the following information:
a. The total number of orders for T -1 exchange access lines/trunks that were rejected
due to a determination by you that facilities were not available;
b. The total number of orders for T -1 intraLA T A Special Access lines that were
rejected due to a determination by you that facilities were not available; and
c. The total number of orders for T -1 UNEs that were rejected due to a
determination by you that facilities were not available.
OBJECTION: Qwest objects to this request on the grounds that the information sought in
the data request is not relevant or reasonably calculated to lead to the discovery of
admissible evidence. Qwest objects to this data request on the grounds that the request is
overly broad and unduly burdensome.
AT&T 027 Re:Network and Market Demand - Availability, Tis
Please provide any written practice(s) or, ifno such practice exists, provide a nall'ative
explaining your practices and policies relative to the reall'angement and reuse of existing
facilities when facilities are initially unavailable at a particular customer location to fulfill an
order for a service requiring a T -1 facility. Indicate whether the same or different practices apply
in the case of retail service orders placed by end users, orders for special access placed by
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carriers, or orders for T-1 UNEs placed by carriers, including IntraLATA Special Access T-
and UNE T -1. In your response, please address the following circumstances:
The T-1 common equipment has no spare ports/slots, but one or more of the
ports/slots is assigned to a circuit that is no longer in use because service has been
discontinued. Under your applicable policies and procedures, could the
technician reuse such a port/slot in order to fulfill the new order? Describe any
differences that might occur as between orders for IntraLA T A Special Access T-
, and UNE T-
There is no unassigned T -1 copper or fiber distribution facility available to fulfill
the order, but one or more T -1 distribution facilities along the route passing the
customer location is assigned to a circuit that formerly served a customer at a
nearby location, but is no longer in use because that service had been
discontinued. Under your applicable policies and procedures, could the
technician reuse such a distribution facility in order to fulfill the new order?
Describe any differences that might occur as between orders for IntraLA T A
Special Access T -, and UNE T -
OBJECTION: Qwest objects to this request on the grounds that the information sought in
the data request is not relevant or reasonably calculated to lead to the discovery of
admissible evidence. Qwest objects to this data request on the grounds that the request is
overly broad and unduly burdensome.
AT&T 030 Re:Network and Market Demand - CLEC Resale Lines
For each of the serving methods listed below, provide the total number ofDS-O (or voice grade
analog) lines in each wire center being served by CLECs:
Resale Residential; and
Resale Business;
OBJECTION: Qwest objects on the grounds that this request seeks information that is
neither relevant to these proceedings nor reasonably calculated to lead to the discovery of
admissible evidence. Qwest is unable at this point to specifically define the markets in
which it will seek relief from unbundling obligations for switching for mass market
customers. Qwest intends to specifically define those market areas in its testimony to be
filed on January 19,2004. Once those market areas are defined, all requested information
for CLLI codes and/or wire centers outside of those areas will be irrelevant in this docket.
Without waiving these objections, within a reasonable time after Qwest makes its proposed
market definitions, Qwest will respond to relevant requests with relevant information.
AT&T 031 Re:Network and Market Demand - CLEC UNE-L Lines
For each of the serving methods listed below, provide the total number ofDS-O (or voice grade
analog) lines in each wire center being served by CLECs:
UNE- L Residential; and
UNE-L Business;
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OBJECTION: Qwest objects on the grounds that this request seeks information that is
neither relevant to these proceedings nor reasonably calculated to lead to the discovery of
admissible evidence. Qwest is unable at this point to specifically define the markets in
which it will seek relief from unbundling obligations for switching for mass market
customers. Qwest intends to specifically define those market areas in its testimony to be
filed on January 19,2004. Once those market areas are defined, all requested information
for CLLI codes and/or wire centers outside of those areas will be irrelevant in this docket.
Without waiving these objections, within a reasonable time after Qwest makes its proposed
market definitions, Qwest will respond to relevant requests with relevant information.
AT&T 032 Re:Network and Market Demand - CLEC UNE-P Lines
For each of the serving methods listed below, provide the total number ofDS-O (or voice grade
analog) lines in each wire center being served by CLECs:
UNE- P Residential; and
UNE-P Business
OBJECTION: Qwest objects on the grounds that this request seeks information that is
neither relevant to these proceedings nor reasonably calculated to lead to the discovery of
admissible evidence. Qwest noted in its Notice of Scope that it is unable at this point to
specifically define the markets in which it will seek relief from unbundling obligations. for
switching for mass market customers. Qwest intends to specifically define those market
areas in its testimony to be filed on January 19,2004. Once those market areas are defined
all requested information for CLLI codes and/or wire centers outside of those areas will be
irrelevant in this docket. Without waiving these objections, within a reasonable time after
Qwest makes its proposed market definitions, Qwest will respond to relevant requests with
relevant information.
AT&T 033 Re:Network and Market Demand - Request for Interconnection
Identify any instances where you initiated a request for interconnection with a CLEc. For each
such instance, provide the identity of the CLEC, the date at which such request was first made to
the CLEC, the date at which the CLEC responded with a draft or template interconnection
agreement, the date at which you provided your responsive comments/red-lines to the draft or
template agreement, whether and the date at which an interconnection agreement was
successfully negotiated between you and the CLEC. In the event that no such successful
negotiation took place, indicate what subsequent actions or initiatives were taken by you (e.
mediation, arbitration) to secure an agreement, and the CUll'ent status of the agreement or lack
thereof.
OBJECTION: Qwest objects to this data request on the grounds that it is overly broad
and unduly burdensome. Qwest objects to this request on the grounds that the information
sought in the data request is not relevant or reasonably calculated to lead to the discovery
of admissible evidence.
AT&T 034 Re:Network and Market Demand - Business Customers
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With regard to business customer locations that you serve using 24 or fewer analog lines, for the
most recent quarter available, delineate, by wire center, the business customers by the number of
such analog lines, through and including those business premises with 24 analog lines (i.
identify those with a single line, two analog lines, three analog lines, etc. through 24 analog
lines). Also, with regard to business customer locations using more than 24 analog lines, for the
most recent quarter available, delineate, by wire center, the number of business customer
locations and the average total lines in those locations.
OBJECTION: Qwest objects to this data request on the grounds that it is overly broad
and unduly burdensome. Qwest further objects that the number and location of business
customers using 24 or fewer analog lines or 24 or more analog lines is not relevant to
Qwest's mass market switching case. Qwest does not retain information in the form
requested and it would require a special study to produce the information in the form
requested. Qwest also objects to this data request on the grounds that it is overly broad
and unduly burdensome. Qwest further objects on the grounds that this request seeks
information that is neither relevant to these proceedings nor reasonably calculated to lead
to the discovery of admissible evidence. Qwest is unable at this point to specifically define
the markets in which it will seek relief from unbundling obligations for switching for mass
market customers. Qwest intends to specifically define those market areas in its testimony
to be filed on January 19,2004. Once those market areas are defined, all requested
information for CLLI codes and/or wire centers outside of those areas will be irrelevant in
this docket. Without waiving these objections, within a reasonable time after Qwest makes
its proposed market definitions, Qwest will respond to relevant requests with relevantinformation.
AT&T 035 Re:Network and Market Demand - Number of Residential and Business
Lines
Provide separately the number of primary and secondary residential and DSO-equivalent business
switched exchange access lines for end of year 1996 through 2002 and for year 2003 through
September 30, 2003.
OBJECTION: Qwest objects to this data request on the grounds that the request is unduly
broad and it would be unduly burdensome to produce such information. Without waiving
this objection, Qwest will supplement this answer with relevant information from the time
period January 1,2003 through September 30,2003, to the extent such information exists.
AT&T 036 Re:Network and Market Demand - Number of Access Lines
Specify by wire center and, within each wire center, by UNE and retail rate zone, if applicable
the number of primary, secondary and total switched exchange access lines, disaggregated by
month from January 1999 to present.
OBJECTION: Qwest objects to this data request on the grounds that it is overly broad
and unduly burdensome. Qwest believes that the time period identified in this request is
overly broad, and, therefore, producing responsive information would be unduly
burdensome. Qwest further objects on the grounds that this request seeks information that
is neither relevant to these proceedings nor reasonably calculated to lead to the discovery of
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admissible evidence. Qwest is unable at this point to specifically define the markets in
which it will seek relief from unbundling obligations for switching for mass market
customers. Qwest intends to specifically define those market areas in its testimony to be
filed on January 19, 2004. Once those market areas are defined, all requested information
for CLLI codes and/or wire centers outside of those areas will be irrelevant in this docket.
Within a reasonable time after Qwest makes its proposed market definitions, Qwest will
respond to relevant requests with relevant information.
AT&T 037 Re:Network and Market Demand - Residential Access Lines
Provide, by wire center and by exchange:
the total residential access lines subscribed to each category of local
exchange service (i.message rate, flat rate, etc.), by Rate Group;
the total access lines subscribed to Lifeline service;
The average monthly minutes for use of subscribers to Flat Rate service
by Rate Group;
OBJECTION: Qwest objects on the grounds that this request seeks information that is
neither relevant to these proceedings nor reasonably calculated to lead to the discovery of
admissible evidence. Qwest is unable at this point to specifically define the markets in
which it will seek relief from unbundling obligations for switching for mass market
customers. Qwest intends to specifically define those market areas in its testimony to be
filed on January 19 2004. Once those market areas are defined, all requested information
for CLLI codes and/or wire centers outside of those areas will be irrelevant in this docket.
Without waiving these objections, within a reasonable time after Qwest makes its proposed
market definitions, Qwest will respond to relevant requests with relevant information.
AT&T 038 Re:Network and Market Demand - Residential Access Lines
Provide, by wire center and by exchange:
The average monthly number of message units for subscribers to Message Rate service
by Rate Group;
The total residential access lines by wire center not subscribed to an optional local calling
package plan; and
The average monthly billed amount to those residential access lines not subscribed to an
optional calling plan.
OBJECTION: Qwest objects on the grounds that this request seeks information that is
neither relevant to these proceedings nor reasonably calculated to lead to the discovery of
admissible evidence. Qwest is unable at this point to specifically define the markets in
which it will seek relief from unbundling obligations for switching for mass market
customers. Qwest intends to specifically define those market areas in its testimony to be
filed on January 19, 2004. Once those market areas are defined, all requested information
for CLLI codes and/or wire centers outside of those areas will be irrelevant in this docket.
Without waiving these objections, within a reasonable time after Qwest makes its proposed
market definitions, Qwest will respond to relevant requests with relevant information.
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AT&T 039 Re:Network and Market Demand - Minutes of use per Line
Please provide the CUll'ent average total monthly minutes of use separately for business and
residential lines by wire center and provide a complete breakdown of each category of usage by
type (e.local, intraLATA intrastate, intraLATA interstate, interLATA intrastate, interLATA
interstate, international, 800 service, etc.
OBJECTION: To the extent that Qwest does not retain information in the form requested
it objects to this request. Further, Qwest objects to the extent that a special study may be
required to produce the information in the form requested. Qwest also objects to this data
request in that it does not seek information concerning Qwest Corporation but seeks
information concerning Qwest Corporation s Section 272 affiliates. Qwest further objects
on the grounds that this request seeks information that is neither relevant to these
proceedings nor reasonably calculated to lead to the discovery of admissible evidence.
Qwest is unable at this point to specifically define the markets in which it will seek relief
from unbundling obligations for switching for mass market customers. Qwest intends to
specifically define those market areas in its testimony to be filed on January 19, 2004. Once
those market areas are defined, all requested information for CLLI codes and/or wire
centers outside of those areas will be irrelevant in this docket. Without waiving these
objections, within a reasonable time after Qwest makes its proposed market definitions,
Qwest will respond to relevant requests with relevant information.
AT&T 040 Re:Network and Market Demand - Number of Residential and Business
Lines
Please provide the cuaent average number of voice grade equivalent lines you provide per
residential and business customer in Idaho.
OBJECTION: Qwest objects on the grounds that this request seeks information that is
neither relevant to these proceedings nor reasonably calculated to lead to the discovery of
admissible evidence. Qwest is unable at this point to specifically define the markets in
which it will seek relief from unbundling obligations for switching for mass market
customers. Qwest intends to specifically define those market areas in its testimony to be
filed on January 19, 2004. Once those market areas are defined, all requested information
for CLLI codes and/or wire centers outside of those areas will be irrelevant in this docket.
Without waiving these objections, within a reasonable time after Qwest makes its proposed
market definitions, Qwest will respond to relevant requests with relevant information.
AT&T 041 Re:Network and Market Demand
Please provide a copy ofthe completed Part II (Wire line and Fixed Wireless Local Telephone) to
the FCC's Form 477 (Local Competition and Broadband Reporting Data Request) with data as of
June 2003 for Idaho.
OBJECTION: Qwest objects to this request on the grounds that the information sought in
the data request is not relevant or reasonably calculated to lead to the discovery of
admissible evidence.
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AT&T 042 Re:Network and Market Demand
Please provide a copy of the completed Part II (Wire line and Fixed Wireless Local Telephone) to
the FCC's Form 477 (Local Competition and Broadband Reporting Data Request) with data as of
June 2003 for Idaho.
OBJECTION: Qwest objects to this data request because it is a duplicate of request
number 041.
AT&T 043 Re:Customer and Economic Market Forces - Average Residential
Revenue
For each year 1996 inclusive through 2002 , and for 2003 through September 30 2003 , please
provide the following average revenue, per residential customer and per residential line
identified in response to AT&T 035, received by you and/or your corporate predecessor, by wire
center separately for:
a. Local exchange service;
b. Discretionary services, including vertical services;
c. IntraLA T A toll revenues;
d. Intrastate switched access revenues, identifying separately intraLA T A access revenues
from interLA T A access revenues; and
e. Interstate switched access revenues, identifying separately intraLA T A access revenues
from interLA T A access revenues.
f. Nomegulated services furnished in connection with, and billed to, the subscriber access
line (e.voice mail, inside wire maintenance, OS/DA).
g. Reciprocal compensation;
h. Data services, and
i. DSL
OBJECTION: Qwest objects to this data request on the grounds that it is overly broad
and unduly burdensome. Qwest believes that the time period identified in this request is
overly broad, and, therefore, producing responsive information would be unduly
burdensome. Qwest also objects that it does not track the information requested and that
response would require a special study. Qwest further objects on the grounds that this
request seeks information that is neither relevant to these proceedings nor reasonably
calculated to lead to the discovery of admissible evidence. Qwest is unable at this point to
specifically define the markets in which it will seek relief from unbundling obligations for
switching for mass market customers. Qwest intends to specifically define those market
areas in its testimony to be filed on January 19,2004. Once those market areas are defined,
all requested information for CLLI codes and/or wire centers outside of those areas will be
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irrelevant in this docket. Within a reasonable time after Qwest makes its proposed market
definitions, Qwest will respond to relevant requests with relevant information.
AT&T 044 Re:Customer and Economic Market Forces - Average Business Revenue
For each year 1996 inclusive through 2002, and for 2003 through September 30, 2003 , please
provide the following average revenue, per business customer and per business line identified in
response to AT&T 035, received by you and/or your corporate predecessor, by wire center
separately for:
a. Local exchange service;
b. Discretionary services, including vertical services;
c. IntraLA T A toll revenues;
d. Intrastate switched access revenues, identifying separately intraLA T A access revenues
from interLA T A access revenues; and
e. Interstate switched access revenues, identifying separately intraLATA access revenues
from interLA T A access revenues.
f. Nonregulated services furnished in connection with, and billed to, the subscriber access
line (e.
g.,
voice mail, inside wire maintenance, OS/DA).
g. Reciprocal compensation;
h. Data services, and
i. DSL
OBJECTION: Qwest objects to this data request on the grounds that it is overly broad
and unduly burdensome. Qwest believes that the time period identified in this request is
overly broad, and, therefore, producing responsive information would be unduly
burdensome. Qwest also objects that it does not track the information requested and that
response would require a special study. Qwest further objects on the grounds that this
request seeks information that is neither relevant to these proceedings nor reasonably
calculated to lead to the discovery of admissible evidence. Qwest is unable at this point to
specifically define the markets in which it will seek relief from unbundling obligations for
switching for mass market customers. Qwest intends to specifically define those market
areas in its testimony to be filed on January 19,2004. Once those market areas are defined
all requested information for CLLI codes and/or wire centers outside of those areas will be
irrelevant in this docket. Within a reasonable time after Qwest makes its proposed market
definitions, Qwest will respond to relevant requests with relevant information.
AT&T 045 Re:Customer and Economic Market Forces - "Take Rates
Please provide the average "take rate " by wire center, for intraLATA toll, interLATA toll
vertical features (by feature), inside wire maintenance, voice mail and DSL service
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OBJECTION: Qwest objects to this request on the grounds that it seeks information
concerning DSL that is neither relevant nor reasonably calculated to lead to the discovery
of admissible evidence. Qwest also objects to this data request to the extent that it seeks
information concerning Qwest Corporation s Section 272 affiliates. Qwest further objects
on the grounds that this request seeks information that is neither relevant to these
proceedings nor reasonably calculated to lead to the discovery of admissible evidence.
Qwest also objects that it does not track the information requested and that response would
require a special study. Qwest is unable at this point to specifically define the markets in
which it will seek relief from unbundling obligations for switching for mass market
customers. Qwest intends to specifically define those market areas in its testimony to be
filed on January 19, 2004. Once those market areas are defined, all requested information
for CLLI codes and/or wire centers outside of those areas will be irrelevant in this docket.
Within a reasonable time after Qwest makes its proposed market definitions, Qwest will
respond to relevant requests with relevant information.
AT&T 046 Re:Customer and Economic Market Forces - IntraLATA toll usage,
Residential
By wire center, provide the total number of your intraLA T A toll residential customers with
average intraLA T A toll usage of:
Less than 30 minutes per month;
30 to 60 minutes per month;
60 to 120 minutes per month;
120 to 180 minutes per month; and
More than 180 minutes per month.
OBJECTION: Qwest objects to this data request on the grounds that it is overly broad
and unduly burdensome. Qwest also objects to this data request to the extent that it seeks
information concerning Qwest Corporation s Section 272 affiliates. Qwest further objects
that it does not track the information requested and that response would require a special
study. Qwest also objects on the grounds that this request seeks information that is neither
relevant to these proceedings nor reasonably calculated to lead to the discovery of
admissible evidence. Qwest is unable at this point to specifically define the markets in
which it will seek relief from unbundling obligations for switching for mass market
customers. Qwest intends to specifically define those market areas in its testimony to be
filed on January 19,2004. Once those market areas are defined, all requested information
for CLLI codes and/or wire centers outside of those areas will be irrelevant in this docket.
Within a reasonable time after Qwest makes its proposed market definitions, Qwest will
respond to relevant requests with relevant information.
AT&T 047 Re:Customer and Economic Market Forces - IntraLA T A toll usage,
Business
By wire center, provide the total number of your intraLA T A toll business DSO loop customers
with average intraLATA toll usage of:
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Less than 30 minutes per month;
30 to 60 minutes per month;
60 to 120 minutes per month;
120 to 180 minutes per month; and
More than 180 minutes per month.
OBJECTION: Qwest objects to this data request on the grounds that it is overly broad
and unduly burdensome. Qwest also objects on the grounds that the term "intraLATA toll
business DSO loop customers" is vague and undefined. Qwest objects on the grounds that
this request seeks information that is neither relevant to these proceedings nor reasonably
calculated to lead to the discovery of admissible evidence. Qwest is unable at this point to
specifically define the markets in which it will seek relief from unbundling obligations for
switching for mass market customers. Qwest intends to specifically define those market
areas in its testimony to be filed on January 19,2004. Once those market areas are defined
all requested information for CLLI codes and/or wire centers outside of those areas will be
irrelevant in this docket. Within a reasonable time after Qwest makes its proposed market
definitions, Qwest will respond to relevant requests with relevant information.
AT&T 048 Re:Customer and Economic Market Forces - InterLATA toll usage
Residential
By wire center (or other disaggregated geographic breakout) provide the total number of your
long distance affiliates ' interLATA residential customers with average interLATA usage of:
Less than 30 minutes per month;
30 to 60 minutes per month;
60 to 120 minutes per month;
120 to 180 minutes per month; and
More than 180 minutes per month.
OBJECTION: Qwest objects to this data request in that it does not seek information
concerning Qwest Corporation but seeks information concerning Qwest Corporation
Section 272 affiliates.
AT&T 049 Re:Customer and Economic Market Forces - InterLATA toll usage,
Business
By wire center (or other disaggregated geographic breakout) provide the total number of your
long distance affiliates ' interLATA business DSO loop customers with average interLATA usage
of:
Less than 30 minutes per month;
30 to 60 minutes per month;
60 to 120 minutes per month;
120 to 180 minutes per month; and
More than 180 minutes per month.
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OBJECTION: Qwest objects to this data request in that it does not seek information
concerning Qwest Corporation but seeks information concerning Qwest Corporation
Section 272 affiliates.
AT&T 050 Re:Customer and Economic Market Forces - InterLATA toll revenues
Provide the average interLATA and intraLATA revenue per subscriber for your long distance
affiliates, by wire center.
for residential customers;
for business DSO loop customers.
OBJECTION: Qwest objects to this data request in that it does not seek information
concerning QwestCorporation but seeks information concerning Qwest Corporation
Section 272 affiliates.
AT&T 051 Re:Customer and Economic Market Forces - Switched Access
Identify any local exchange carriers in Idaho other than you from which any of your long
distance affiliates intend to or already have agreed to purchase switched carrier access services
and specify precisely what types of switched access services will be purchased from each such
carner.
OBJECTION: Qwest objects to this request on the grounds that the information sought in
the data request is not relevant or reasonably calculated to lead to the discovery of
admissible evidence. Qwest also objects to this data request to the extent that it seeks
information concerning Qwest Corporation s Section 272 affiliates.
AT&T 052 Re:Customer and Economic Market Forces - Qwest Toll Services
Does Qwest or any of its long distance affiliates provide interLATA and intraLATA services in
Idaho to customers served by other local exchange carriers? If so, indicate which other LEC
customers will be able to obtain intraLATA and interLATA long distance services from Qwest
or its long distance affiliates.
OBJECTION: Qwest objects to this request on the grounds that the information sought in
the data request is not relevant or reasonably calculated to lead to the discovery of
admissible evidence. Qwest also objects to this data request in that it does not seek
information concerning Qwest Corporation but seeks information concerning Qwest
Corporation s Section 272 affiliates.
AT&T 054 Re:Competitive and Economic Market Forces- Substitutable Services
For each mass market service you offer, identify every provider that actively offers services that
you consider substitutes, excluding wireless providers and services. For each competitive
service identified, provide your exchanges and/or wire centers where the substitute is cull'ently
being offered.
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OBJECTION: Qwest objects to this request to the extent it seeks information protected by
the attorney client and/or attorney work product privileges. Without waiving this
objection Qwest will provide any and all general information it has in its written testimony
on January 19, 2004.
AT&T 055 Re:Competitive and Economic Market Forces - Substitutable Services
For each business service you offer, identify every provider that actively offers services that you
consider substitutes, excluding wireless providers and services. For each service identified
provide your exchanges and/or wire centers where the substitute is cull'ently being offered.
OBJECTION: Qwest objects to this request to the extent it seeks information protected by
the attorney client and/or attorney work product privileges. Without waiving this
objection Qwest will provide any and all general information it has in its written testimony
on January 19, 2004.
AT&T 056 Re:Competitive and Economic Market Forces - Fixed Wireless
Do you contend that all of the business services you now provide can be provided over fixed
wireless in Idaho? If so, do you contend that fixed wireless facilities are available to provide
commercial volumes of business services in Idaho?
OBJECTION: Qwest objects to this request to the extent it seeks information protected by
the attorney client and/or attorney work product privileges. Without waiving this
objection Qwest will provide any and all general information it has in its written testimony
on January 19,2004.
AT&T 059 Re:Competitive and Economic Market Forces - Costs
Please provide your variable costs and marginal costs for local, long distance and broadband
services individually and as part of a bundled offering.
OBJECTION: Qwest objects to this data request on the grounds that it is overly broad
and unduly burdensome. Qwest objects on the grounds that this request seeks information
concerning broadband service that is neither relevant to these proceedings nor reasonably
calculated to lead to the discovery of admissible evidence. Qwest further objects that it does
not track the information requested and that response would require a special study.
Qwest objects on the grounds that this request seeks information that is neither relevant to
these proceedings nor reasonably calculated to lead to the discovery of admissible evidence.
Qwest is unable at this point to specifically define the markets in which it will seek relief
from unbundling obligations for switching for mass market customers. Qwest intends to
specifically define those market areas in its testimony to be filed on January 19, 2004. Once
those market areas are defined, all requested information for CLLI codes and/or wire
centers outside of those areas will be irrelevant in this docket.
AT&T 061 Re:Network and Market Demand - Average Cost Per Line
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Provide the average total cost per line for each of the past two years that Qwest has incull'ed to
install and maintain lines used to serve mass market customers (residential customers and
business customers that are served by 1-3 voice-grade equivalent lines at one location, or are
otherwise included in the definition of mass market customer as determined by the Idaho
Commission. Provide a breakdown of each cost component (e.
g.,
investment -related costs
network operations, maintenance, and SG&L) that is part of the average total cost per line
identifying the type and amount of each cost. Produce all documents that reflect, refer or relate to
the information provided in your response to this request.
OBJECTION: Qwest objects to this request on the grounds that the information sought in
the data request is not relevant or reasonably calculated to lead to the discovery of
admissible evidence. Also, Qwest objects to this data request on the grounds that it is
overly broad and unduly burdensome.
AT&T 062 Re:Competitive and Economic Market Forces - Costs, Transport
For each of the last 10 new interoffice fiber facilities that you have constructed in Idaho, please
provide:
The initial project business case;
Any requests for bids and all responsive documents;
A complete description of the project including routes and materials requirements; and
Final "actual" booked costs for the project.
OBJECTION: Qwest objects to this request on the grounds that the information sought in
the data request is not relevant or reasonably calculated to lead to the discovery of
admissible evidence.
AT&T 063 Re:Competitive and Economic Market Forces - Price Reductions
Identify and describe any constraints (if any) on your ability to:
Reduce prices in relation to some measure of cost (e.price floor based on
TELRIC);
Target price reductions to geographic areas; and
Target price reductions to types of customers (including individual customers).
OBJECTION: Qwest objects to this request on the grounds that the information sought in
the data request is not relevant or reasonably calculated to lead to the discovery of relevant
evidence. Qwest also objects to this data requests on the grounds that it improperly seeks
legal analysis or legal conclusions.
AT&T 064 Re:Competitive and Economic Market Forces - Competitive Responses
Produce any documents referring or relating to any pricing offers, advertising campaigns
packaged offerings, waiver of fees, term contract offerings, marketing strategies you have
evaluated or implemented in consideration of one or more CLEC's planned or actual entry into a
local service market.
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OBJECTION: Qwest objects to this request on the grounds that the information sought in
the data request is not relevant or reasonably calculated to lead to the discovery of
admissible evidence.
AT&T 065 Re:Competitive and Economic Market Forces - Line Growth
On an individual Central Office, end office, and serving wire center basis, please provide the
recent history of line growth/line loss for:
Primary voice lines;
Additional voice lines; and
Broadband/data lines.
OBJECTION: Qwest objects on the grounds that this request seeks information
concerning broadband service that is neither relevant to these proceedings nor reasonably
calculated to lead to the discovery of admissible evidence. Qwest objects on the grounds
that this request seeks information that is neither relevant to these proceedings nor
reasonably calculated to lead to the discovery of admissible evidence. Qwest is unable at
this point to specifically define the markets in which it will seek relief from unbundling
obligations for switching for mass market customers. Qwest intends to specifically define
those market areas in its testimony to be filed on January 19,2004. Once those market
areas are defined, all requested information for CLLI codes and/or wire centers outside of
those areas will be irrelevant in this docket. Within a reasonable time after Qwest makes
its proposed market definitions, Qwest will respond to relevant requests with relevant
information.
AT&T 066 Re:Competitive and Economic Market Forces - Financial Information by
Services
For each year 1996 through 2002 inclusive, and for this year through September 30, 2003, please
provide the following financial information: (i) total operating revenues; (ii) total operating
expenses; (iii) average Telephone Plant in Service (TPIS); (iv) average net investment/net
telephone plant; (v) realized return on investment as well as return on equity for you and/or for
your corporate predecessor, separately, for total company all services (regulated and
nonregulated).
OBJECTION: Qwest objects to this request on the grounds that the information sought in
the data request is neither relevant nor reasonably calculated to lead to the discovery of
admissible evidence. Qwest objects to this data request on the grounds that it is overly
broad and unduly burdensome. Qwest believes that the time period identified in this
request is overly broad, and, therefore, producing responsive information would be unduly
burdensome. Without waiving these objections, Qwest will produce its Idaho annual
reports for the years 1999,2000,2001 and 2002 (when available). The Idaho annual
reports for the years 2000 and 2001 are subject to amendment as a result of Qwest
Corporation s financial restatements. The Idaho annual report for 2002 has not yet been
filed because of Qwest Corporation s financial restatements.
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AT&T 067 Re:Competitive and Economic Market Forces - Financial Information by
Services
For each year 1996 through 2002 inclusive, and for this year through September 30, 2003 , please
provide the following financial information: (i) total operating revenues; (ii) total operating
expenses; (iii) average Telephone Plant in Service (TPIS); (iv) average net investment/net
telephone plant; (v) realized return on investment as well as return on equity for you and/or for
your corporate predecessor, separately, for jurisdictionally intrastate regulated services.
OBJECTION: Qwest objects to this request on the grounds that the information sought in
the data request is neither relevant nor reasonably calculated to lead to the discovery of
admissible evidence. Qwest objects to this data request on the grounds that it is overly
broad and unduly burdensome. Qwest believes that the time period identified in this
request is overly broad, and, therefore, producing responsive information would be unduly
burdensome. Without waiving these objections, Qwest will produce its Idaho annual
reports for the years 1999,2000,2001 and 2002 (when available). The Idaho annual
reports for the years 2000 and 2001 are subject to amendment as a result of Qwest
Corporation s financial restatements. The Idaho annual report for 2002 has not yet been
filed because of Qwest Corporation s financial restatements.
AT&T 068 Re:Competitive and Economic Market Forces - Financial Information by
Services
For each year 1996 through 2002 inclusive, and for this year through September 30, 2003, please
provide the following financial information: (i) total operating revenues; (ii) total operating
expenses; (iii) average Telephone Plant in Service (TPIS); (iv) average net investment/net
telephone plant; (v) realized return on investment as well as return on equity for you and/or for
your corporate predecessor, separately, for jurisdictionally interstate regulated services.
OBJECTION: Qwest objects to this request on the grounds that the information sought in
the data request is neither relevant nor reasonably calculated to lead to the discovery of
admissible evidence. Qwest objects to this data request on the grounds that it is overly
broad and unduly burdensome. Qwest believes that the time period identified in this
request is overly broad, and, therefore, producing responsive information would be unduly
burdensome. Without waiving these objections, Qwest will produce its Idaho annual
reports for the years 1999,2000 2001 and 2002 (when available). The Idaho annual
reports for the years 2000 and 2001 are subject to amendment as a result of Qwest
Corporation s financial restatements. The Idaho annual report for 2002 has not yet been
filed because of Qwest Corporation s financial restatements.
AT&T 069 Re:Competitive and Economic Market Forces - Financial Information by
Services
For each year 1996 through 2002 inclusive, and for this year through September 30, 2003 , please
provide the following financial information: (i) total operating revenues; (ii) total operating
expenses; (iii) average Telephone Plant in Service (TPIS); (iv) average net investment/net
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telephone plant; (v) realized return on investment as well as return on equity for you and/or for
your corporate predecessor, separately, for total company regulated services.
OBJECTION: Qwest objects to this request on the grounds that the information sought in
the data request is neither relevant nor reasonably calculated to lead to the discovery of
admissible evidence. Qwest objects to this data request on the grounds that it is overly
broad and unduly burdensome. Qwest believes that the time period identified in this
request is overly broad, and, therefore, producing responsive information would be unduly
burdensome. Without waiving these objections, Qwest will produce its Idaho annual
reports for the years 1999,2000,2001 and 2002 (when available). The Idaho annual
reports for the years 2000 and 2001 are subject to amendment as a result of Qwest
Corporation s financial restatements. The Idaho annual report for 2002 has not yet been
filed because of Qwest Corporation s financial restatements.
AT&T 070 Re:Competitive and Economic Market Forces - Financial Information by
Services
For each year 1996 through 2002 inclusive, and for this year through September 30 2003, please
provide the following financial information: (i) total operating revenues; (ii) total operating
expenses; (iii) average Telephone Plant in Service (TPIS); (iv) average net investment/net
telephone plant; (v) realized return on investment as well as return on equity for you and/or for
your corporate predecessor, separately, for services classified as Non-Regulated per 47 C.
64.901.
OBJECTION: Qwest objects to this request on the grounds that the information sought in
the data request is neither relevant nor reasonably calculated to lead to the discovery of
admissible evidence. Qwest objects to this data request on the grounds that it is overly
broad and unduly burdensome. Qwest believes that the time period identified in this
request is overly broad, and, therefore, producing responsive information would be unduly
burdensome. Without waiving these objections, Qwest will supplement this response with
its Idaho annual reports for the years 1999,2000,2001 and 2002 (when available). The
Idaho annual reports for the years 2000 and 2001 are subject to amendment as a result of
Qwest Corporation s financial restatements. The Idaho annual report for 2002 has not yet
been filed because of Qwest Corporation s financial restatements.
AT&T 071 Re:Competitive and Economic Market Forces - Financial Information by
Services
For each year 1996 through 2002 inclusive, and for this year through September 30, 2003 , please
provide the following financial information: (i) total operating revenues; (ii) total operating
expenses; (iii) average Telephone Plant in Service (TPIS); (iv) average net investment/net
telephone plant; (v) realized return on investment as well as return on equity for you and/or for
your corporate predecessor, separately, for services classified as Non-Regulated by the Idaho
commISSIOn.
OBJECTION: Qwest objects to this request on the grounds that the information sought in
the data request is neither relevant nor reasonably calculated to lead to the discovery of
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admissible evidence. Qwest objects to this data request on the grounds that it is overly
broad and unduly burdensome. Qwest believes that the time period identified in this
request is overly broad, and, therefore, producing responsive information would be unduly
burdensome. Without waiving these objections, Qwest will supplement this response with
its Idaho annual reports for the years 1999,2000 2001 and 2002 (when available). The
Idaho annual reports for the years 2000 and 2001 are subject to amendment as a result
Qwest Corporation s financial restatements. The Idaho annual report for 2002 has not yet
been filed because of Qwest Corporation s financial restatements.
AT&T 072 Re:Competitive and Economic Market Factors - Out-of-Region,
Wholesale Switching
Provide any documents that refer, relate to, or discuss the examination or consideration by you of
offering wholesale switching in any out-of-region local market.
OBJECTION: Qwest objects to this request on the grounds that the information sought in
the data request is not relevant or reasonably calculated to lead to the discovery of
admissible evidence. Operational and economic factors Qwest believes are appropriate to
consider in making a determination whether to implement, continue, expand or curtail any
out-of-region local market entry strategy are not relevant to Qwest's in-region mass
market switching case.
AT&T 075 Re:Mass Market - Identification
Indicate whether local or state governmental agencies, such as Idaho state offices, universities
and/or university housing are considered residential customers or mass market business
customers.
OBJECTION: Qwest objects to this data request on the grounds that the phrase "mass
market business customers" is vague and ambiguous. Without waiving this objection
Qwest will answer the request to the extent it can.
AT&T 078 Re:Mass Market - Switching, Delisted UNEs
What is the "market rate" that you propose to charge other carriers for access to de-listed local
switching functionality?
Explain the basis for determining the "market rate " including a description of the market
and any competitors to your switching functionality.
Explain the source of each difference between the proposed just and reasonable rate for
de-listed local switching and the approved TELRIC rate.
Provide the new return-on-equity achieved by the proposed just and reasonable rate for
de-listed local switching.
OBJECTION: Qwest objects to this request on the grounds that the information sought in
the data request is not relevant or reasonably calculated to lead to the discovery of
admissible evidence.
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AT&T 079 Re:Mass Market - DSL, UNE - L
Please describe with specificity the process by which CLECs offering voice service to a mass-
market customer utilizing unbundled local switching could provide xDSL service using UNE-
Please also provide the following information regarding the process:
Please state whether the process is mechanized or manual. If the process is
mechanized, please state whether the service orders flow through. If orders do
flow through, please state the percentage of the service orders that flow through to
completion;
Please list the recurring and nonrecurring charges the CLEC would incur;
Please provide the average service outage experienced by the end user customer;
Please state whether the loop and switch port would be reused or whether new
facilities would be provisioned; and
Please state whether information in downstream databases, including 911 , LIDB
and directory listings would be impacted. If your answer is yes, please explain
any such effects in detail.
OBJECTION: Qwest objects to this request on the grounds that this data request seeks
information concerning DSL service that is not relevant or reasonably calculated to lead to
the discovery of admissible evidence.
AT&T 080 Re:Mass Market - DSL, EELs
Please describe with specificity the process by which CLECs offering voice service to a mass-
market customer utilizing unbundled local switching could provide xDSL service using EELs.
Please also provide the following information regarding the process:
a. Please state whether the process is mechanized or manual. If the process is mechanized
please state whether the service orders flow through. If orders do flow through, please
state the percentage of the service orders that flow through to completion;
b. Please list the recurring and nonrecurring charges the CLEC would incur;
c. Please provide the average service outage experienced by the end user customer;
d. Please state whether the loop and switch port would be reused or whether new facilities
would be provisioned; and
e. Please state whether information in downstream databases, including 911 , LIDB and
directory listings would be impacted. If your answer is yes, please explain any such
effects in detail.
OBJECTION: Qwest objects to this request on the grounds that this data request seeks
information concerning DSL service that is not relevant or reasonably calculated to lead to
the discovery of admissible evidence.
AT&T 081 Re:Mass Market - DSL, UNE-
Please describe with specificity the process by which CLECs offering voice service to a mass
market customer utilizing its own switches could provide xDSL service using UNE-L. Please
also provide the following information regarding the process:
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Please state whether the process is mechanized or manual. If the process is
mechanized, please state whether the service orders flow through. If orders do
flow through, please state the percentage of the service orders that flow through to
completion;
Please list the recurring and nonrecurring charges the CLEC would incur;
Please provide the average service outage experienced by the end user customer;
Please state whether the loop would be reused or whether new facilities would be
provisioned; and
Please state whether information in downstream databases, including 911 , LIDB
and directory listings would be impacted. If your answer is yes, please explain
any such effects in detail.
OBJECTION: Qwest objects to this request on the grounds that this data request seeks
information concerning DSL service that is not relevant or reasonably calculated to lead to
the discovery of admissible evidence.
AT&T 082 Re:Mass Market - DSL, EELs
Please describe with specificity the process by which CLECs offering voice service to a mass
market customer utilizing its own switches could provide xDSL service using EELs. Please also
provide the following information regarding the process:
a. Please state whether the process is mechanized or manual. If the process is mechanized
please state whether the service orders flow through. If orders do flow through, please
state the percentage of the service orders that flow through to completion;
b. Please list the recurring and nonrecurring charges the CLEC would incur;
c. Please provide the average service outage experienced by the end user customer;
d. Please state whether the loop would be reused or whether new facilities would be
provisioned; and
e. Please state whether information in downstream databases, including 911 , LIDB and
directory listings would be impacted. If your answer is yes, please explain any such
effects in detail.
OBJECTION: Qwest objects to this request on the grounds that this data request seeks
information concerning DSL service that is not relevant or reasonably calculated to lead to
the discovery of admissible evidence.
AT&T 083 Re:Mass Market - DSL
Please describe with specificity the process by which CLECs providing voice and xDSL service
to a mass-market customer utilizing unbundled local switching for the voice service could
perform the following activities:
Disconnect the data service, but retain the voice service;
Migrate the data service to another provider, but retain the voice service;
Migrate the voice service to another provider, but retain the data service; and
Disconnect the voice service, but retain the data service.
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OBJECTION: Qwest objects to this request on the grounds that this data request seeks
information concerning DSL service that is not relevant or reasonably calculated to lead to
the discovery of admissible evidence.
AT&T 084 Re:Mass Market - DSL
For each scenario described in AT&T 083, please also provide the following information:
Please state whether the process is mechanized or manual. If the process is
mechanized, please state whether the service orders flow through. If orders do
flow through, please state the percentage of the service orders that flow through to
completion;
Please list the recurring and nonrecurring charges the CLEC would incur;
Please provide the average service outage experienced by the end user customer;
Please state whether the loop and switch port would be reused or whether new
facilities would be provisioned; and
Please state whether information in downstream databases, including 911, LIDB
and directory listings would be impacted. If your answer is yes, please explain
any such effects in detail.
OBJECTION: Qwest objects to this request on the grounds that this data request seeks
information concerning DSL service that is not relevant or reasonably calculated to lead to
the discovery of admissible evidence.
AT&T 085 Re:Mass Market - DSL
Please describe with specificity the process by which CLECs providing voice and xDSL service
to a mass-market customer utilizing their own switches and a UNE loop could perform the
following activities:
Disconnect the data service, but retain the voice service;
Migrate the data service to another provider, but retain the voice service;
Migrate the voice service to another provider, but retain the data service; and
Disconnect the voice service, but retain the data service.
OBJECTION: Qwest objects to this request on the grounds that this data request seeks
information concerning DSL service that is not relevant or reasonably calculated to lead to
the discovery of admissible evidence.
AT&T 086 Re:Mass Market - DSL
For each scenario described in AT&T 085, please also provide the following information:
Please state whether the process is mechanized or manual. If the process is mechanized
please state whether the service orders flow through. If orders do flow through, please
state the percentage of the service orders that flow through to completion;
Please list the recurring and nonrecurring charges the CLEC would incur;
Please provide the average service outage experienced by the end user customer;
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Please state whether the loop would be reused or whether new facilities would be
provisioned; and
Please state whether information in downstream databases, including 911 , LIDB and
directory listings would be impacted. If your answer is yes, please explain any such
effects in detail.
OBJECTION: Qwest objects to this request on the grounds that this data request seeks
information concerning DSL service that is not relevant or reasonably calculated to lead to
the discovery of admissible evidence.
AT&T 087 Re:Collocation - Experience and History
Provide the following data for each of your Central Offices and Remote Terminals in which one
or more CLECs maintains a collocation presence:
Identification of the wire center (CLLI code);
The area served by the Central Office or Remote Terminal;
The total number of switched exchange access lines cull'ently being served at
retail by you;
The total amount of space cull'ently being used by collocators; and
The total amount of space available for use by collocators (which does not include
space reserved for you or your affiliates).
OBJECTION: Qwest objects to the extent this request seeks CLEC/carrier specific
information which is protected by Section 222 of the Communications Act of 1934
C. ~ 222, or other privacy laws. Qwest will produce such information upon receipt of a
Commission order compelling Qwest to do so. Qwest further objects on the grounds that
this request seeks information that is neither relevantto these proceedings nor reasonably
calculated to lead to the discovery of admissible evidence. Qwest is unable at this point to
specifically define the markets in which it will seek relief from unbundling obligations for
switching for mass market customers. Qwest intends to specifically define those market
areas in its testimony to be filed on January 19,2004. Once those market areas are defined,
all requested information for CLLI codes and/or wire centers outside of those areas will be
irrelevant in this docket. Within a reasonable time after Qwest makes its proposed market
definitions, Qwest will respond to relevant requests with relevant information.
AT&T 088 Re:Collocation - Experience and History
Provide the following data for each of your Central Offices and Remote Terminals in which one
or more CLECs maintains a collocation presence:
The number of CLECs collocated in the wire center;
The name(s) of any CLECs collocated in the wire center and the date of
occupancy;
The types ofservice(s) being offered by each of the collocated CLECs to their
customers (retail local residential, retail local mass market (small) business, retail
data services, retail enterprise services, or wholesale services (specify nature));
and
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The number of residential and business lines that each CLEC serves out of its
collocation space, via UNE-
Specify your policy with respect to disconnecting collocation all'angements for
non-payment.
OBJECTION: Qwest objects to the extent this request seeks CLEC/carrier specific
information which is protected by Section 222 of the Communications Act of 1934,
c. ~ 222, or other privacy laws. Qwest will produce such information upon receipt of a
Commission order compelling Qwest to do so. Qwest further objects on the grounds that
this request seeks information that is neither relevant to these proceedings nor reasonably
calculated to lead to the discovery of admissible evidence. Qwest noted in its Notice of
Scope that it is unable at this point to specifically define the markets in which it will seek
relief from unbundling obligations for switching for mass market customers. Qwest
intends to specifically define those market areas in its testimony to be filed on January 19,
2004. Once those market areas are defined, all requested information for CLLI codes
and/or wire centers outside of those areas will be irrelevant in this docket. Within a
reasonable time after Qwest makes its proposed market definitions, Qwest will respond to
relevant requests with relevant information.
AT&T 090 Re:Collocation - Experience and History
Identify the number of your Central Offices in Idaho in which there are no CUll'ent collocation
all'angements provided to CLECs. For each identified Central Office, please identify the name
and location of the Central Office, and state whether each such Central Office is manned or
unmanned.
OBJECTION: Qwest objects to this data request on the grounds that the request is unduly
broad and it would be unduly burdensome to produce such information. Without waiving
this objection, to the extent it is available Qwest will produce information responsive to this
request from the time period January 1 2003 through September 30,2003.
AT&T 091 Re:Collocation - Experience and History
Identify the number of your Central Offices in which more than one CLEC was collocated in
Idaho as of:
December 31 , 1996;
December 31 , 2000; and
March 31 , 2003.
OBJECTION: Qwest objects to this data request on the grounds that the request is unduly
broad and it would be unduly burdensome to produce such information. Without waiving
this objection, to the extent it is available Qwest will produce information responsive to this
request from the time period January 1 , 2003 through September 30, 2003.
AT&T 094 Re:Collocation - Experience and History
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Identify any cases where you have refused collocation requests since January 1 2001. Indicate
the ultimate resolution of the dispute.
OBJECTION: Qwest objects on the grounds that this request seeks information that is
neither relevant to these proceedings nor reasonably calculated to lead to the discovery of
admissible evidence. Qwest is unable at this point to specifically define the markets in
which it will seek relief from unbundling obligations for switching for mass market
customers. Qwest intends to specifically define those market areas in its testimony to be
filed on January 19, 2004. Once those market areas are defined, all requested information
for CLLI codes and/or wire centers outside of those areas will be irrelevant in this docket.
Within a reasonable time after Qwest makes its proposed market definitions, Qwest will
respond to relevant requests with relevant information.
AT&T 096 Re:Hot Cuts - Historical Quantities
Please provide UNE Loop quantities provisioned for each quarter from January 2001 to the
present, stating for each quarter and each wire center the:
Average number of lines provisioned on a daily basis;
Fewest number of lines provisioned in a work day; and
Maximum number of lines provisioned in a work day.
OBJECTION: Qwest objects to this data request on the grounds that it is overly broad
and unduly burdensome. Qwest also objects to this request on the grounds that it seeks
irrelevant information and is not reasonably calculated to lead to the discovery of
admissible evidence. Without waiving these objections, Qwest refers AT&T to the batch
hot cut proposal filed by Qwest on October 31,2003, and Qwest notes that the general
subject matter concerning hot cuts and OSS capabilities will be addressed by the parties in
the batch hot cut forum that will take place during these proceedings.
AT&T 097 Re:Hot Cuts - Quantities and Charges
For UNE Loop lines provisioned for CLECs, identify separately the quantities of business and
residential lines, and the hot cut charges (average per line and total) on a monthly basis from
January 2001 to present, distinguishing between provisioning done on a project or negotiated
basis and those lines not provisioned on a project or negotiated basis and between those
processed as coordinated installation with cooperative testing versus coordinated installation
without cooperative testing.
OBJECTION: Qwest objects to this data request on the grounds that it is overly broad
and unduly burdensome. Qwest also objects to this request on the grounds that it seeks
irrelevant information and is not reasonably calculated to lead to the discovery of
admissible evidence. Without waiving these objections, Qwest refers AT&T to the batch
hot cut proposal filed by Qwest on October 31, 2003, and Qwest notes that the general
subject matter concerning hot cuts and OSS capabilities will be addressed by the parties in
the batch hot cut forum that will take place during these proceedings.
AT&T 098 Re:Hot Cuts - Capacity
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On an individual wire center basis, identify the CUll'ent total number ofUNE loops per day that
can be provisioned by you, where "provisioned" includes migration of customers from ILEC-to-
CLEC, from CLEC-to-CLEC, and from CLEC-to- ILEc. Identify how the maximum quantities
of lines that may be provisioned mayor may not be dependent on: (i) how many different
CLECs
' "
hot cut" requests are being provisioned on a given day, (ii) whether requests are being
handled on a coordinated installation with cooperative testing, coordinated installation without
cooperative testing, or project/negotiated basis, (iii) how many Central Offices in Idaho have
scheduled cutovers on the same day, (iii) whether you also are processing "winbacks" of
customers cull'ently served by CLECs using UNE-, (iv) whether any of the "hot cuts" are
CLEC-to-CLEC migrations, and (v) any other relevant factors (describe).
OBJECTION: Qwest objects to this data request on the grounds that it is overly broad
and unduly burdensome. Qwest also objects to this request on the grounds that it seeks
irrelevant information and is not reasonably calculated to lead to the discovery of
admissible evidence. Without waiving these objections, Qwest refers AT&T to the batch
hot cut proposal filed by Qwest on October 31, 2003, and Qwest notes that the general
subject matter concerning hot cuts and OSS capabilities will be addressed by the parties in
the batch hot cut forum that will take place during these proceedings.
AT&T 099 Re:Hot Cuts - Plans to Increase Capacity
Detail any plans to increase CUll'ent capacity to provision UNE loops. Provide any testing
performed or planned and any studies done or planned (including their underlying assumptions
and supporting data) to determine work force, process and system scalability to meet an
increasing demand for UNE- L provisioning.
OBJECTION: Qwest objects to this data request on the grounds that it is overly broad
and unduly burdensome. Qwest also objects to this request on the grounds that it seeks
irrelevant information and is not reasonably calculated to lead to the discovery of
admissible evidence. Without waiving these objections, Qwest refers AT&T to the batch
hot cut proposal filed by Qwest on October 31, 2003, and Qwest notes that the general
subject matter concerning hot cuts and OSS capabilities will be addressed by the parties in
the batch hot cut forum that will take place during these proceedings.
AT&T 100 Re:Hot Cuts - Capability
Has Qwest ever communicated to any CLEC the total number of unbundled loop cutovers Qwest
is capable of performing per central office per day? Or in any specific geographic area per day?
If yes, provide the substance of those communications, including all documents relating to
limitations on the number of hot cuts that can be performed. If there are differences in the
maximum number of cutovers that can be performed in a Central Office or geographic area
explain the reasons for the differences.
OBJECTION: Qwest objects to this data request on the grounds that it is overly broad
and unduly burdensome. Qwest also objects to this request on the grounds that it seeks
irrelevant information and is not reasonably calculated to lead to the discovery of
admissible evidence. Without waiving these objections, Qwest refers AT&T to the batch
QWEST CORPORATION'S OBJECTIONS TO AT&T COMMUNICATIONS OF THE MOUNTAIN
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hot cut proposal filed by Qwest on October 31 , 2003, and Qwest notes that the general
subject matter concerning hot cuts and OSS capabilities will be addressed by the parties in
the batch hot cut forum that will take place during these proceedings. Without waiving
said objections, Qwest states that it is not aware of every communicating the requested
information.
AT&T 101 Re:Hot Cuts - OSS
Describe CUll'ent process flows supporting "hot cuts" on a coordinated installation with
cooperative testing, coordinated installation without cooperative testing, and project/negotiated
basis. The description should include any variations that exist when the customer is served over
all-copper facilities, hybrid fiber-copper facilities using IDLC, and hybrid fiber-copper facilities
using UDLC or NGDLC. The description should include any variations in the process flows
depending on whether the provisioning is a transition of a CLEC customer cull'ently served on
UNE- P (same CLEC, a migration of a UNE- L served customer to another CLEC' s switch
(CLEC to CLEC), a transition of an ILEC customer to CLEC's UNE-L based service (ILEC to
CLEC), or a "winback" of a cull'ently served CLEC UNE-L customer to the ILEC (CLEC to
ILEC)).
OBJECTION: Qwest objects to this data request on the grounds that it is overly broad
and unduly burdensome. Qwest also objects to this request on the grounds that it seeks
irrelevant information and is not reasonably calculated to lead to the discovery of
admissible evidence. Without waiving these objections, Qwest refers AT&T to the batch
hot cut proposal filed by Qwest on October 31,2003, and Qwest notes that the general
subject matter concerning hot cuts and OSS capabilities will be addressed by the parties in
the batch hot cut forum that will take place during these proceedings.
AT&T 102 Re:Hot Cuts - OSS, Process Improvements
Describe any proposed improvements to your CUll'ent process flows for "hot cut" provisioning,
including any proposed plans for a batch hot cut process, and the dates by which such
improvements are planned to be proposed and implemented. Described improvements should
cover the scenarios identified in AT&T 113 , and specifically include the TELRIC rate for the
process as revised, and a description ofthe applicable performance measurement standards.
OBJECTION: Qwest objects to this data request on the grounds that it is overly broad
and unduly burdensome. Qwest also objects to this request on the grounds that it seeks
irrelevant information and is not reasonably calculated to lead to the discovery of
admissible evidence. Without waiving these objections, Qwest refers AT&T to the batch
hot cut proposal filed by Qwest on October 31,2003, and Qwest notes that the general
subject matter concerning hot cuts and OSS capabilities will be addressed by the parties in
the batch hot cut forum that will take place during these proceedings.
AT&T 103 Re:Hot Cuts - OSS
Describe and document CUll'ent and planned OSS functionality and requirements to support Pre-
ordering, Ordering, Provisioning/Status Inquiry and Communication, Maintenance/Repair and
Billing for voice-grade, DSL capable, and line-split UNE loops on all-copper facilities, hybrid
QWEST CORPORATION'S OBJECTIONS TO AT&T COMMUNICATIONS OF THE MOUNTAIN
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fiber-copper facilities using IDLC, and hybrid fiber-copper facilities using UDLC or NGDLC.
Your response should include process flows, requirements, and business rules (identifying data
characteristics associated with each combination ofreq type/activity code) for:
transitioning an existing customer s service to UNE- L (ILEC to CLEC),
transitioning a customer served on UNE-L by one CLEC to another CLEC
serving a customer using UNE-L (CLEC to CLEC), and
transitioning your existing UNE-P customer to service as a UNE-L customer
(same CLEC).
OBJECTION: Qwest objects to this data request on the grounds that it is overly broad
and unduly burdensome. Qwest also objects to this request on the grounds that it seeks
irrelevant information and is not reasonably calculated to lead to the discovery of
admissible evidence. Without waiving these objections, Qwest refers AT&T to the batch
hot cut proposal filed by Qwest on October 31, 2003, and Qwest notes that the general
subject matter concerning hot cuts and OSS capabilities will be addressed by the parties in
the batch hot cut forum that will take place during these proceedings.
AT&T 104 Re:Hot Cuts - OSS, LSR
For your responses to AT&T 115 , detail which Local Service Requests ("LSRs ) associated with
each scenario will be handled on a fully automated, flow-through basis. Identify any limitations
on the number of lines that can be included on a single UNE- L LSR, and your anticipated
proposals for changing such limitations.
OBJECTION: Qwest objects to this data request on the grounds that it is overly broad
and unduly burdensome. Qwest also objects to this request on the grounds that it seeks
irrelevant information and is not reasonably calculated to lead to the discovery of
admissible evidence. Without waiving these objections, Qwest refers AT&T to the batch
hot cut proposal filed by Qwest on October 31, 2003, and Qwest notes that the general
subject matter concerning hot cuts and OSS capabilities will be addressed by the parties in
the batch hot cut forum that will take place during these proceedings.
AT&T 105 Re:Hot Cuts - OSS, LSR
Does ILEC have in place a single LSR process to migrate UNE loops from ILEC to CLEC
CLEC to ILEC and CLEC to CLEC for each of the following?
Voice service;
Data service; and
Voice and data service.
OBJECTION: Qwest objects to this data request on the grounds that it is overly broad
and unduly burdensome. Without waiving this objection, Qwest refers AT&T to the batch
hot cut proposal filed by Qwest on October 31,2003, and Qwest notes that the general
subject matter concerning hot cuts and OSS capabilities will be addressed by the parties in
the batch hot cut forum that will take place during these proceedings.
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AT&T 106 Re:Hot Cuts - OSS, LSR
If Qwest has a single LSR process to migrate UNE loops, state whether the process provides
flow through capability, and provide:
The capacity of each process in terms of number of UNE loops per day that can
be migrated; and
State the percentage ofthe service orders that flow through to completion.
OBJECTION: Qwest objects to this data request on the grounds that it is overly broad
and unduly burdensome. Without waiving this objection, Qwest refers AT&T to the batch
hot cut proposal filed by Qwest on October 31 , 2003, and Qwest notes that the general
subject matter concerning hot cuts and OSS capabilities will be addressed by the parties in
the batch hot cut forum that will take place during these proceedings.
AT&T 107 Re:Hot Cuts - OSS, LSR
Does Qwest have plans to increase its capacity to perform single LSR migrations? If so, provide
the planned capacity for each type of migration and service.
OBJECTION: Qwest objects to this data request on the grounds that it is overly broad
and unduly burdensome. Without waiving this objection, Qwest refers AT&T to the batch
hot cut proposal filed by Qwest on October 31 , 2003 , and Qwest notes that the general"
subject matter concerning hot cuts and OSS capabilities will be addressed by the parties in
the batch hot cut forum that will take place during these proceedings.
AT&T 108 Re:Hot Cuts - OSS, LSR
To the extent that you do not today offer CLECs the ability to submit one Local Services
Request (LSR) to support any of the CLEC-initiated scenarios described in AT&T 115, on a one-
service order, fully-electronic basis, describe any plarmed improvements and identify when you
project delivering the new functionality. Include any requirement changes that may be required
but for which OBF or other standards bodies have not yet released ~uidelines, and which may be
subject to change management plan requirements.
OBJECTION: Qwest objects to this data request on the grounds that it does not
understand the reference to AT&T 115. Further Qwest objects as the request is overly
broad and unduly burdensome. Qwest also objects to this request on the grounds that it
seeks irrelevant information and is not reasonably calculated to lead to the discovery of
admissible evidence. Without waiving these objections, Qwest refers AT&T to the batch
hot cut proposal filed by Qwest on October 31, 2003, and Qwest notes that the general
subject matter concerning hot cuts and OSS capabilities will be addressed by the parties in
the batch hot cut forum that will take place during these proceedings.
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AT&T 109 Re:Hot Cuts - OSS, LSR
Provide any testing and studies of the scalability of end-to-end electronic systems and manual
OSS processes to migrate customers from one CLEC to another CLEC or to migrate customers
from UNE-P loops to UNE Loops.
OBJECTION: Qwest objects to this data request on the grounds that it is overly broad
and unduly burdensome. Qwest also objects to this request on the grounds that it seeks
irrelevant information and is not reasonably calculated to lead to the discovery of
admissible evidence. Without waiving these objections, Qwest refers AT&T to the batch
hot cut proposal filed by Qwest on October 31, 2003, and Qwest notes that the general
subject matter concerning hot cuts and OSS capabilities will be addressed by the parties in
the batch hot cut forum that will take place during these proceedings.
AT&T 110 Re:Hot Cuts - OSS
IfUNE-P is unavailable, which ILEC and CLEC systems and processes need to be established
altered or enhanced to accommodate facilities-based local telecommunications competition
including but not limited to, updates/upgrades to PSAP/E911, NP AC/number portability,
directory assistance, directory listings, white pages, and electronic access to both ILEC and
CLEC customer service records?
OBJECTION: Qwest objects to this data request on the grounds that it is overly broad
and unduly burdensome. Qwest also objects to this request on the grounds that it seeks
irrelevant information and is not reasonably calculated to lead to the discovery of
admissible evidence. Without waiving these objections, Qwest refers AT&T to the batch
hot cut proposal filed by Qwest on October 31, 2003, and Qwest notes that the general
subject matter concerning hot cuts and OSS capabilities will be addressed by the parties in
the batch hot cut forum that will take place during these proceedings.
AT&T 111 Re:Hot Cuts - OSS
Please describe the impact on any of your systems and databases associated with migrating a
UNE Loop used in conjunction with unbundled switching to a UNE Loop used in conjunction
with CLEC provided switching. Please specifically state whether circuits inventoried as UNE-
loops must be migrated to a different inventory system.
OBJECTION: Qwest objects to this data request on the grounds that it is overly broad
and unduly burdensome. Qwest also objects to this request on the grounds that it seeks
irrelevant information and is not reasonably calculated to lead to the discovery of
admissible evidence. Without waiving these objections, Qwest refers AT&T to the batch
hot cut proposal filed by Qwest on October 31, 2003, and Qwest notes that the general
subject matter concerning hot cuts and OSS capabilities will be addressed by the parties in
the batch hot cut forum that will take place during these proceedings.
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AT&T 112 Re:Hot Cuts - OSS
Is UNE-P treated as a designed or non-designed circuit in your inventory systems? Is UNE-
treated as a designed or non-designed circuit in your inventory systems? Please describe the
impact of migrating a non-designed circuit to a designed circuit.
OBJECTION: Qwest objects to this data request on the grounds that it is overly broad
and unduly burdensome. Qwest also objects to this request on the grounds that it seeks
irrelevant information and is not reasonably calculated to lead to the discovery of
admissible evidence. Without waiving these objections, Qwest refers AT&T to the batch
hot cut proposal filed by Qwest on October 31 , 2003, and Qwest notes that the general
subject matter concerning hot cuts and OSS capabilities will be addressed by the parties in
the batch hot cut forum that will take place during these proceedings.
AT&T 113 Re:Hot Cuts - Loop Testing
Is MLT testing available with UNE-Loops? If not, what type oftesting is available to a CLEC
utilizing UNE- Loops? Must you install test access points for manual testing? Must the CLEC
install terminal equipment? Is there a capacity constraint on the test access points that can be
installed? If so, is the capacity constraint associated with the manual testing?
OBJECTION: Qwest objects to this data request on the grounds that it is overly broad
and unduly burdensome. Qwest also objects to this request on the grounds that it seeks
irrelevant information and is not reasonably calculated to lead to the discovery of
admissible evidence. Without waiving these objections, Qwest refers AT&T to the batch
hot cut proposal filed by Qwest on October 31, 2003, and Qwest notes that the general
subject matter concerning hot cuts and OSS capabilities will be addressed by the parties in
the batch hot cut forum that will take place during these proceedings.
AT&T 114 Re:Hot Cuts - OSS
For each month since January 1 , 2001 , provide the number of and the total charges assessed for
unbundled loop cutovers when the "CHC" field on the LSR form is populated with a ", for
existing customers by wire center, separated between each type or classification of cutover
provided by ILEC, including, but not limited to
, "
coordinated installation with cooperative
testing,
" "
coordinated installation without cooperative testing,
" "
frame due time" or "project
coordinated installation" cutovers.
OBJECTION: Qwest objects to this data request on the grounds that it is overly broad
and unduly burdensome. Qwest also objects to this request on the grounds that it seeks
irrelevant information and is not reasonably calculated to lead to the discovery of
admissible evidence. Without waiving these objections, Qwest refers AT&T to the batch
hot cut proposal filed by Qwest on October 31 , 2003, and Qwest notes that the general
subject matter concerning hot cuts and OSS capabilities will be addressed by the parties in
the batch hot cut forum that will take place during these proceedings.
QWEST CORPORATION'S OBJECTIONS TO AT&T COMMUNICATIONS OF THE MOUNTAIN
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AT&T 115 Re:Hot Cuts - Capability
State the highest number of unbundled loop cutovers, when the "CHC" field on the LSR form is
populated with a "" Qwest has ever performed in a single day for each Central Office.
OBJECTION: Qwest objects to this data request on the grounds that it is overly broad
and unduly burdensome. Without waiving this objection, Qwest refers AT&T to the batch
hot cut proposal filed by Qwest on October 31 , 2003, and Qwest notes that the general
subject matter concerning hot cuts will be addressed by the parties in the batch hot cut
forum that will take place during these proceedings.
AT&T 116 Re:Hot Cuts - Capability
State, for the most recent 30, 60 and 90-day periods for which data are available, the average
number of lines Qwest processes on an order when the "CHC" field on the LSR form is
populated with a ". State the time period used to develop the averages provided and the
number of observations used to develop the average.
OBJECTION: Qwest objects to this data request on the grounds that it is overly broad
and unduly burdensome. Without waiving this objection, Qwest refers AT&T to the batch
hot cut proposal filed by Qwest on October 31 2003, and Qwest notes that the general
subject matter concerning hot cuts will be addressed by the parties in the batch hot cut
forum that will take place during these proceedings.
AT&T 117 Re:Hot Cuts - Personnel Time
Provide the average Qwest personnel time attributable to a single cutover on a single unbundled
loop order, separated between each type or classification of cutover provided by ILEC,
including, but not limited to
, "
coordinated installation with cooperative testing,
" "
coordinated
testing without cooperative testing,
" "
frame due time" or "project coordinated installation
cutovers.
OBJECTION: Qwest objects to this data request on the grounds that it is overly broad
and unduly burdensome. Without waiving this objection, Qwest refers AT&T to the batch
hot cut proposal filed by Qwest on October 31 , 2003, and Qwest notes that the general
subject matter concerning hot cuts will be addressed by the parties in the batch hot cut
forum that will take place during these proceedings.
AT&T 118 Re:Hot Cuts - Personnel Time
Provide the average Qwest personnel time attributable to multiple cutovers contained on a single
unbundled loop order, separated between each type or classification of cutover provided by
ILEC, including, but not limited to
, "
coordinated installation with cooperative testing,
coordinated installation without cooperative testing,
" "
frame due time" or "project coordinated
installation" cutovers.
OBJECTION: Qwest objects to this data request on the grounds that it is overly broad
and unduly burdensome. Without waiving this objection, Qwest refers AT&T to the batch
QWEST CORPORATION'S OBJECTIONS TO AT&T COMMUNICATIONS OF THE MOUNTAIN
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hot cut proposal filed by Qwest on October 31 , 2003, and Qwest notes that the general
subject matter concerning hot cuts will be addressed by the parties in the batch hot cut
forum that will take place during these proceedings.
AT&T 119 Re:Hot Cuts - OSS
What processes do you have in place with regard to directory listings, E911 and LIDB when a
UNE-P loop is migrated to UNE-Loop? Are there capacity constraints? What is the process for
ensuring the accuracy of the records?
OBJECTION: Qwest objects to this data request on the grounds that it is overly broad
and unduly burdensome. Qwest also objects to this request on the grounds that it seeks
irrelevant information and is not reasonably calculated to lead to the discovery of
admissible evidence. Without waiving these objections, Qwest refers AT&T to the batch
hot cut proposal filed by Qwest on October 31, 2003, and Qwest notes that the general
subject matter concerning hot cuts and OSS capabilities will be addressed by the parties in
the batch hot cut forum that will take place during these proceedings.
AT&T 120 Re:Hot Cuts - Restoration
Describe in detail any process Qwest has to restore service if an end-user experiences problems
resulting in loss of service during a hot cut.
OBJECTION: Qwest objects to this data request on the grounds that it is overly broad
and unduly burdensome. Without waiving this objection, Qwest refers AT&T to the batch
hot cut proposal filed by Qwest on October 31, 2003, and Qwest notes that the general
subject matter concerning hot cuts will be addressed by the parties in the batch hot cut
forum that will take place during these proceedings.
AT&T 121 Re:Hot Cuts - OSS, Winback
Describe process flows supporting, and record and database changes associated with, your
winback" of a customer which had been served by a CLEC using UNE- L. For any descriptions
and documentation relating to "planned" as opposed to presently available OSS, provide the
plarmed or projected release date.
OBJECTION: Qwest objects to this data request on the grounds that it is overly broad
and unduly burdensome. Qwest also objects to this request on the grounds that it seeks
irrelevant information and is not reasonably calculated to lead to the discovery of
admissible evidence. Without waiving these objections, Qwest refers AT&T to the batch
hot cut proposal filed by Qwest on October 31, 2003, and Qwest notes that the general
subject matter concerning hot cuts and OSS capabilities will be addressed by the parties in
the batch hot cut forum that will take place during these proceedings.
AT&T 122 Re:Hot Cuts - Winbacks
For each month since January 1999, please provide the number ofloop cutovers by wire center
that resulted in the loop being swung back to your switch, separated by those that met the
QWEST CORPORATION'S OBJECTIONS TO AT&T COMMUNICATIONS OF THE MOUNTAIN
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provisioning due date, the number within 10 days of the provisioning due date and the number
beyond 10 days of the provisioning due date.
OBJECTION: Qwest objects to this data request on the grounds that it is overly broad
and unduly burdensome. Qwest also objects to this request on the grounds that it seeks
irrelevant information and is not reasonably calculated to lead to the discovery of
admissible evidence. Without waiving these objections, Qwest refers AT&T to the batch
hot cut proposal filed by Qwest on October 31, 2003, and Qwest notes that the general
subject matter concerning hot cuts and OSS capabilities will be addressed by the parties in
the batch hot cut forum that will take place during these proceedings.
AT&T 123 Re:Hot Cuts - CLEC Complaints
Provide documentation of any process or performance complaints from CLECs regarding your
hot cut procedures and any internal analysis of potential improvements to the hot cut process you
cull'ently use , including any description of planned improvements to the process.
OBJECTION: Qwest objects to this data request on the grounds that it is overly broad
and unduly burdensome. Qwest also objects to this request on the grounds that it seeks
irrelevant information and is not reasonably calculated to lead to the discovery of
admissible evidence. Without waiving these objections, Qwest refers AT&T to the batch
hot cut proposal filed by Qwest on October 31, 2003, and Qwest notes that the general
subject matter concerning hot cuts and OSS capabilities will be addressed by the parties in
the batch hot cut forum that will take place during these proceedings.
AT&T 124 Re:Transport - Availability
Identify each instance in the last three years in which Qwest has denied a CLEC request for UNE
interoffice transport in Idaho on the basis of "no facilities available.
OBJECTION: Qwest objects to this request on the grounds that the information sought in
the data request is not relevant or reasonably calculated to lead to the discovery of
admissible evidence.
AT&T 125 Re:Transport - Availability
Specify the CLLI code for each pair of end offices (if any) between which the CLEC requested
UNE interoffice transport was denied due to "no facilities available." Provide all documents
information or communications on which Qwest relies for its response to this request.
OBJECTION: Qwest objects to this request on the grounds that the information sought in
the data request is not relevant or reasonably calculated to lead to the discovery of
admissible evidence.
AT&T 126 Re:Transport - Availability
Identify each instance in the last three years in which Qwest has delayed provisioning a CLEC
request for UNE interoffice transport on the basis of "no facilities available.
QWEST CORPORA nON'S OBJECTIONS TO AT&T COMMUNICATIONS OF THE MOUNTAIN
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OBJECTION: Qwest objects to this request on the grounds that the information sought in
the data request is not relevant or reasonably calculated to lead to the discovery of
admissible evidence.
AT&T 127 Re:Transport - Availability
In each instance where provisioning of a CLEC's UNE interoffice transport was delayed due to
no facilities available" at the time of the request, describe in detail why there were no facilities
available at the time of the request. "How long was each such request delayed before facilities
became available? Provide all documents, information or communications on which Qwest
relies for its response to this request.
OBJECTION: Qwest objects to this request on the grounds that the information sought in
the data request is not relevant or reasonably calculated to lead to the discovery of
admissible evidence.
Respectfully submitted this 8th day of December, 2003.
Qwest Corporation
!:hJ
Mary S. obson
Stoel Rives LLP
Adam L. Shell'
Qwest
Attorneys for Qwest Corporation
QWEST CORPORATION'S OBJECTIONS TO AT&T COMMUNICATIONS OF THE MOUNTAIN
STATES INC.'S FIRST SET OF DISCOVERY REQUESTS- Page 46
Boise-165139.10029164-00097
CERTIFICATE OF SERVICE
I hereby certify that on this 8th day of December, 2003 , I served QWEST
CORPORATION'S OBJECTIONS TO AT&T COMMUNICATIONS OF THE
MOUNTAIN STATES, INc.'S FIRST SET OF DISCOVERY REQUESTS as follows:
Jean Jewell, Secretary
Idaho Public Utilities Commission
472 West Washington Street
O. Box 83720
Boise, ill 83720-0074
Phone: [phone]
Fax: [phone]
ij ewell~puc.state.id. us
--.lL. HandDelivery
U. S. Mail
Overnight Delivery
Facsimile
Email
Wayne Hart
Idaho Public Utilities Commission
472 West Washington Street
O. Box 83720
Boise, ill 83720-0074
Phon~: [phone]
Fax: [phone]
whart~puc.state.id. us
Hand Delivery
U. S. Mail
Overnight Delivery
Facsimile
Email
Weldon Stutzman, Deputy Attorney General
Idaho Public Utilities Commission
472 West Washington Street
O. Box 83720
Boise, ill 83720-0074
Phone: [phone]
Fax: [phone]
wstutzm~puc. state. id. us
Hand Delivery
U. S. Mail
Overnight Delivery
Facsimile
Email
Marlin D. Ard, Esq.
O. Box 2190
Sisters, OR 97759
Telephone: [phone]
Facsimile: [phone]
Maratty~qwest.net
Attorney for Verizon
Hand Delivery
U. S. Mail
Overnight Delivery
Facsimile
Email
QWEST CORPORATION'S OBJECTIONS TO AT&T COMMUNICATIONS OF THE MOUNTAIN
STATES INC.'S FIRST SET OF DISCOVERY REQUESTS- Page 47
Boise-l 65139.1 0029164-00097
Charles Call'athers
Verizon Northwest Inc.
1800 41 sl Street
Everett, W A 98201
Telephone: [phone]
Facsimile: [phone]
chuck. call'athers~verizon. com
Hand Delivery
U. S. Mail
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Email
Dean J. Miller
McDevitt & Miller LLP
420 West Bannock Street
O. Box 2564 (83701)
Boise, ID 83702
Telephone: [phone]
Facsimile: [phone]
oe~mcdevitt -miller. com
Attorney for MCImetro, Time Warner
Hand Delivery
U. S. Mail
Overnight Delivery
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Email
Robert M. Pomeroy, Jr.
Holland & Hart
8390 East Crescent Parkway - Suite 400
Greenwood Village, CO 80111
Telephone: [phone]
Facsimile: [phone]
bpomero vC(i),ho llandhart. com
Attorney for AT&T
Hand Delivery
-1L u. S. Mail
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Facsimile
Em ail
Adam L. Shell'
Qwest
1600 ih Avenue - Room 3206
Seattle, WA 98191
Telephone: [phone]
Facsimile: [phone]
adam.shell'~qwest.com
Hand Delivery-1L U. S. Mail
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Email
Clay R. Sturgis
Moss Adams LLP
601 West Riverside - Suite 1800
Spokane, W A 99201-0663
Telephone: [phone]
Facsimile: [phone]
cla vsC(i),mossadams. com
Attorney for ITA
Hand Delivery
U. S. Mail
Overnight Delivery
Facsimile
Email
QWEST CORPORATION'S OBJECTIONS TO AT&T COMMUNICATIONS OF THE MOUNTAIN
STATES INC.'S FIRST SET OF DISCOVERY REQUESTS- Page 48
Boise-165139.10029164-00097
Brian Thomas
Time Wamer Telecom
223 Taylor Avenue North
Seattle, W A 98109
Brian. Thomas~twtelecom.com
Hand Delivery
U. S. Mail
Overnight Delivery
Facsimile
Email
Mary B. Tribby
Letty S. D. Friesen
AT&T Communications of the Mountain States, Inc.
1875 Lawrence Street- Suite 1575
Denver, CO 80202
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lsfriesen~att.com
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Conley E. Ward
Givens Pursley LLP
277 North 6th Street - Suite 200
O. Box 2720
Boise, ill 83701
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cew(Q),gi venspursley. com
Attorney for ITA
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Brandi L. Gearhart, PLS
Legal Assistant to Mary S. Hobson
Stoel Rives LLP
QWEST CORPORATION'S OBJECTIONS TO AT&T COMMUNICATIONS OF THE MOUNTAIN
STATES INC.'S FIRST SET OF DISCOVERY REQUESTS- Page 49
Boise-165139.10029164-00097