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Home My WebLink About200302113rd Request.pdf- ;)...ws WELDON B. STUTZMAN DEPUTY ATTORNEY GENERAL IDAHO PUBLIC UTILITIES COMMISSION PO BOX 83720 BOISE, IDAHO 83720-0074 (208) 334-0318 ISB NO. 3283 ',C ("\fED , ~_ lJ CI1 t~; Il- 2mB FEB \ 2 PH 2: 20 ':L1 - \"\:'(' , u nu ( it:.:) CUf.\l~~\Oli Street Address for Express Mail: 472 W. WASHINGTON BOISE, IDAHO 83702-5983 Attorney for the Commission Staff BEFORE THE IDAHO PUBLIC UTILITIES COMMISSION IN THE MATTER OF THE APPLICATION OF QWEST CORPORATION FOR DEREGULATION OF BASIC LOCAL EXCHANGE RATES IN ITS BOISE, NAMPA CALDWELL, MERIDIAN, TWIN FALLS, IDAHO FALLS, AND POCATELLO EXCHANGES. CASE NO. QWE- T -02- THIRD PRODUCTION REQUEST OF THE COMMISSION STAFF TO QWEST CORPORATION The Staff of the Idaho Public Utilities Commission by and through its attorney of record Weldon B. Stutzman, Deputy Attorney General, requests Qwest Corporation (Qwest) provide the followi~g documents and information, pursuant to Commission Rule of Procedure 225 , IDAP A 31.01.01.225 , on or before February 28, 2003. This Production Request is to be considered as continuing, and Qwest is requested to provide, by way of supplementary responses, additional documents and information that it or any person acting on its behalf may later obtain that will augment the documents and information produced. For each request, please state the name of the person(s) preparing the answers, along with the job title of such person(s) and the witness who can sponsor the answer at hearing. responses include workpapers or spreadsheets, please provide the responses on computer media (3.5" diskette or CD) using Lotus 123 (4.0) or Excel 5.0 language. THIRD PRODUCTION REQUEST TO QWEST FEBRUARY 12, 2003 DEFINITIONS and INSTRUCTIONS The words "the Company" and "Qwest" refer to Qwest Corporation Document" includes any written or recorded or graphic matter, however produced or reproduced, including but not limited to correspondence, telegrams, contracts agreements, notes in any form, memoranda, diaries, voice recording tapes, microfilms microfiche, pictures, data processing cards or discs, computer tapes and other computer- generated and stored information or data base, work papers, calendars, minutes of meetings or any other writings or graphic matter, including copies containing marginal notes or variations of any of the foregoing, now or previously in your possession. (1) (2) In the event that any document called for is to be withheld on the basis of a claim of privilege, identify the item being withheld as follows: addressor; addressee; indicated or blind copies; and all persons to whom distributed, shown, or explained. Also identify the nature and legal basis of the privilege asserted. In the event that any document called for by this request has been destroyed or transferred beyond the control of the Company, (a) state the identity of the person by whom it was destroyed and person authorizing destruction and the time, place and method of, and reasons for its destruction, and if destroyed or disposed of by operation of a retention policy, state the retention policy; and, if transferred, the person authorizing transfer and the time, place, and method of, and reason for, its transfer, and (b) identify it as follows: addressor; addressee; indicated or blind copies; dates; subject matter; number of pages, attachments or appendices; and all persons to whom distributed, shown, or explained. Identify, " " Identity," or "Identification " when used in reference to an individual person means to state that person s full name and residence address, including zip code and phone number, if known, and present or last known business position and duties and business address, if known. Identify, " " Identity," or "Identification " when used in reference to a document, means to state the type of document (e., computer-stored information, microfilm, letter memorandum, policy circular, minute book, telegram, chart, etc.), or some other means of identifying it, and its present location and custodian. If any such document was, but is no longer, in your possession or subject to your control, state what disposition was made of it, and if destroyed or disposed of by operation of a retention policy, state the retention policy. Identify, " " Identity," or "Identification " when used in reference to a number or other specific information, means to identify the document containing this information or some other means of identifying it, and to specify the approximate location of the requested information within that document. THIRD PRODUCTION REQUEST TO QWEST FEBRUARY 12 2003 Identify, " " Identity," or "Identification " when used in reference to a business organization, means to state the corporate name or other names under which said organization does business, and location of its principal place of business. Note: to the extent the specific information requested herein is not available, but analogous or reasonably comparable information is available, please provide that information instead, and explain any differences between what was requested and what has been provided. To the extent the information requested herein is not available in the exact format requested, but the information can be more easily provided in a different format, please provide your response in the more readily available format, but explain any differences in format. Please provide an electronic copy of the requested information in Excel spreadsheet or compatible format. Interrogatory No. 13: Please identify any promotions or special offers that the Company has conducted for either primary lines, additional lines, or packages involving primary or additional lines, between January 1 , 1999 and December 31 , 2002. Please identify the timeframe of the promotion, as well as the applicable rates, terms and conditions of the promotion. Interrogatory No. 14: Please identify any promotions or special offers that the Company has conducted for custom calling features or caller identification services, either individually or in packages or combinations, between January 1 , 1999 and December 31 , 2002. Please identify the timeframe of the promotion, as well as the applicable rates, terms and conditions of the promotion. Interrogatory No. 15: Please provide the latest available data for subscriber line usage that would identify the average number of local minutes (both originating and terminating) used by Qwest subscribers. Please provide such data for weekdays and weekend days, and for peak and off peak periods. DATED at Boise, Idaho, this 12.. K--day of February 2003. Weldon B. Stutzman Deputy Attorney General Technical Staff: Joe Cusick Wayne Hart THIRD PRODUCTION REQUEST TO QWEST FEBRUARY 12 2003 CERTIFICATE OF SERVICE I HEREBY CERTIFY THAT I HAVE THIS 12TH DAY OF FEBRUARY 2003 SERVED THE FOREGOING THIRD PRODUCTION REQUEST OF THE COMMISSION STAFF TO QWEST CORPORATION IN CASE NO. QWE-02- BY MAILING A COpy THEREOF, POSTAGE PREPAID, TO THE FOLLOWING: MARY S HOBSON STOEL RIVES LLP SUITE 1900 101 S CAPITOL BLVD BOISE ID 83702 ADAM L SHERR QWEST 1600 7TH AVE, ROOM 3206 SEATTLE WA 98191 CONLEY WARD GIVENS PURSLEY LLP 277 N 6TH ST, SUITE 200 PO BOX 2720 BOISE ID 83701-2720 CLAY R STURGIS MOSS ADAMS LLP 601 W RIVERSIDE, SUITE 1800 SPOKANE WA 99201-0663 DEAN J MILLER McDEVITT & MILLER LLP 420 W BANNOCK ST PO BOX 2565 (83701) BOISE ID 83702 BRIAN THOMAS TIME WARNER TELECOM 223 TAYLOR AVE NORTH SEATTLE WA 98109 SUSAN TRAVIS WORLDCOM INC 707 17TH STREET, SUITE 4200 DENVER CO 80202 MARY JANE RASHER AT&T COMMUNICATIONS OF THE MOUNTAIN STATES INC 10005 S GWENDELYNLANE HIGHLANDS RANCH, CO 80129-6217 CERTIFICATE OF SERVICE MARLIN D ARD WILLARD L FORSYTH HERSHNER, HUNTER, ANDREWS, NEILL & SMITH, LLP 180 E 11TH AVE PO BOX 1475 EUGENE OR 97440-1475 JOHN GANNON ATTORNEY AT LAW 1101 W RIVER, SUITE 110 BOISE ID 83702 DEAN RANDALL VERIZON NORTHWEST INC 17933 NW EVERGREEN PKWY BEAVER TON OR 97006-7438 BEN JOHNSON ASSOCIATES INC 2252 KILLEARN CENTER BLVD ALLAHASSSEE FL 32308 "- k.. c::v SECRETARY CERTIFICATE OF SERVICE