20020911Staff to Qwest First Prod Req.pdf

JOHN R.HAMMOND
DEPUTY ATTORNEY GENERAL
IDAHO PUBLIC UTILITIES COMMISSION I I P 3:PO BOX 83720
BOISE,IDAHO 83720-0074
[phone]
IDAHO BAR NO.5470
Street Address for Express Mail:
472 W.WASHINGTON
BOISE,IDAHO 83702-5983
Attorneyfor the Commission Staff
BEFORE THE IDAHO PUBLIC UTILITIES COMMISSION
IN THE MATTER OF THE APPLICATION OF )QWEST CORPORATION AND MCLEODUSA FOR )CASE NO.QWE-T-00-7
APPROVAL OF AN AMENDMENT TO AN )EXISTING INTERCONNECTION AGREEMENT )PURSUANT TO 47 U.S.C.§252(e).)
IN THE MATTER OF THE JOINT APPLICATION )OF QWEST CORPORATION AND ESCHELON )CASE NO.QWE-T-00-13TELECOM,INC.FOR APPROVAL OF AN )AMENDMENT TO AN INTERCONNECTION )AGREEMENT PURSUANT TO 47 U.S.C.§252(e).)
IN THE MATTER OF THE JOINT APPLICATION )OF QWEST CORPORATION AND COVAD )CASE NO.USW-T-99-3
COMMUNICATIONS COMPANY FOR )APPROVAL OF AN AMENDMENT TO AN )EXISTING INTERCONNECTION AGREEMENT )FIRST PRODUCTIONPURSUANTTO47U.S.C.§252(e).)REQUESTOF THE
)COMMISSION STAFF TO
)QWEST
The Staff of the Idaho Public Utilities Commission,by and through its attorney of record,
John R.Hammond,Deputy AttorneyGeneral,requests that Qwest (Qwest;Company)provide
FIRST PRODUCTION REQUEST 1 SEPTEMBER 11,2002
TO QWEST
the followingdocuments and information,pursuant to Rule 225 of the Idaho Public Utilities
Commission's Rules of Procedure,IDAPA 31.01.01,on or before WEDNESDAY,
OCTOBER 9,2002.
This Production Request is to be considered as continuing,and PacifiCorp is requested to
provide,by way of supplementaryresponses,additional documents that it or any person acting
on its behalf may later obtain that will augment the documents produced.
For each item,please indicate 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.For
all responses to the followingrequests,please provide all workpapers,diskettes (3.5 in.)and all
underlyingformulas in Excel (version 5)language.
Request No.1:Please provide a copy of any agreements or contracts which these
negotiatedagreements in Case No.QWE-T-00-7,QWE-T-00-13 and USW-T-99-3 replace,
supersede or terminate,such as each of the "terminated agreements"identified in section 3.(b)of
the Eschelon agreement.(QWE-T-00-13).
Request No.2:On page 5 of the W.Clay Deanhardt affidavit filed with the Minnesota
Public Utilities Commission on June 12,2002 in Docket No.P-421/CI-01-1371;OAH No.7-
2500-14486-2 is a reference to "ll non-public agreements that Qwest entered into with
CLEC's."Please provide copies of each of these agreements.
Request No.3:The affidavit of Deanhardt and an affidavit of Blake O.Fisher,filed on
the same day in the same proceeding,refers to an oral agreement between Qwest and
McLeodUSA that provided McLeodUSA with discounts of up to 10%on its purchases from
Qwest.The Fisher affidavit describes the circumstances leading to the oral agreement and the
terms of the agreement.Does Qwest dispute any of the items included in the Fisher affidavit,
and if so,please identify which items are disputed and clarify Qwest's position on the item.
Why was the oral agreement with McCleodUSA agreement not reduced to writing?
FIRST PRODUCTION REQUEST 2 SEPTEMBER 11,2002
TO QWEST
Request No.4:For all agreements,includingthose provided in response to Question 1
and 2,please identify the date the agreement became effective,and a date of termination,if
applicable.
Request No.5:Please provide non-redacted versions of all agreements.(Requests for
confidential treatment of submitted materials will be handled in accordance with the
Commission's Rules of Procedure.)
Request No.6:Please provide copies of any other agreement that has been identified or
alleged to be an agreement that should have been filed with a state utilityregulatorycommission
by the Commission,Commission Staff,or administrative law judge or other commission
authority of any other state regulatory agency within Qwest's 14 state region.
Dated at Boise,Idaho,this I day of September 2002.
olm .Hammond
ep ty AttorneyGeneral
Technical Staff:Wayne Hart
i:umisc/prdreg/Qwet00.7 Qwet00.13 Uswt99.3jhwh
FIRST PRODUCTION REQUEST 3 SEPTEMBER 11,2002
TO QWEST
CERTIFICATE OF SERVICE
I HEREBY CERTIFY THAT I HAVE THIS 11TH DAY OF SEPTEMBER 2002,
SERVED THE FOREGOING FIRST PRODUCTION REQUEST OF THE
COMMISSION STAFF TO QWEST,IN CASE NOS.QWE-T-00-7,QWE-T-00-13
AND USW-T-99-3,BY MAILING A COPY THEREOF,POSTAGE PREPAID,TO THE
FOLLOWING:
MARY S HOBSON LAURAINE A HARDING
STOEL RIVES LLP SR MGR -INTERCONNECTION
STE 1900 McLEODUSA TELECOMMUNICATIONS
101 S CAPITAL BLVD 6400 C STREET SW -BOX 3177
BOISE ID 83702-5958 CEDAR RAPIDS IA 52406-3177
DENNIS AHLERS DHRUV KHANNA
SENIOR ATTORNEY COVAD COMMUNICATIONS COMPANY
ESCHELON TELECOM INC 3560 BASSETT STREET
730 2ND AVE SOUTH STE 1200 SANTA CLARA CA 95054
MINNEAPOLIS MN 55402
SECRETARY
CERTIFICATE OF SERVICE