200302212nd Response of Qwest.pdf

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L.,101 S. Capitol Boulevard. Suite 1900
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ATTORNEYS AT lAW
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UTiL!TIES COj"'lf':fJ SION
February 21 2003
MARY S. HOBSON
Direct [phone]
mshobson(ij)stoel.com
VIA HAND DELIVERY
Ms. Jean Jewell, Secretary
Idaho Public Utilities Commission
472 West Washington Street
Boise, ill 83720-0074 .J~Re: Case No. QWE-O2;.95
Dear Ms. Jewell:
Enclosed for filing with this Commission is an original and three copies of Qwest
Corporation s Responses to Second Production Request of the Commission Staff in the
above-referenced matter. The confidential attachments, Attachments A, B, C, D and E to
Response to Request No. 012P, Attachment A, Band C to Response to Request No. 013P
Attachment A to Response to Request No. 015P, Attachment A and B to Response to Request
No. 016P, Attachment A and B to Response to Request No. 016P, Attachment A to Response to
Request No. 017P, Attachment A to Response to Request No. 018P are being filed under
separate cover.
Thank: you for your cooperation in this matter.
Very truly yours
/t/t/VUJ1t
Mary S. ~obson
:blg
Enclosures
Oregon
Washington
California
Boise-147264.10029164-00082
U I a h
Idaho
CONFIDENTIAL DOCUMENTS
WERE INCLUDED IN THIS FILING
Mary S. Hobson (ISB #2142)
Stoel Rives LLP
101 South Capitol Boulevard - Suite 1900
Boise, ill 83702
Telephone: [phone]
Facsimile: [phone]
Emai1: mshobsonCfYstoel.com
Adam L. Sherr (WSBA #25291)
Qwest
1600 7th Avenue - Room 3206
Seattle, WA 98191
Telephone: [phone]
Facsimile: [phone]
Email: asherrCfYqwestcom
Attorneys for Qwest Corporation
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UTiLITiES COhhlSSION
BEFORE THE IDAHO PUBLIC UTILITIES COMMISSION
.:J,l.
IN THE MATTER OF THE APPLICATION Case. No. QWE-O2~
OF QWEST CORPORATION FOR PRICE
DEREGULATION OF BASIC LOCAL
EXCHANGE SERVICES
QWEST CORPORATION'S RESPONSES TO
SECOND PRODUCTION REQUEST OF THE
COMMISSION STAFF
Qwest Corporation, through its undersigned attorneys, hereby files the attached responses
to the Second Production Request of the Commission Staff.
Respectfully submitted this 21st day of February, 2003.
Qwest Corporation
~~~
t/o-L-
Stoel Rives LLP
Adam L. Sherr
Qwest Corporation
Attorneys for Qwest Corporation
QWEST CORPORATION'S RESPONSES TO SECOND PRODUCTION REQUEST OF THE
COMMISSION STAFF - Page -
Boise-153453,10029164-00087
CERTIFICATE OF SERVICE
I hereby certify that on this 21st day of February, 2003, I served QWEST
CORPORATION'RESPONSES TO SECOND PRODUCTION REQUEST OF THE
COMMISSION STAFF as follows:
Weldon B. Stutzman
Deputy Attorney General
Idaho Public Utilities Commission
Box 83720
Boise, ill 83720-0074
LXJ Hand Delivery
L...J U. S. Mail
L...J Overnight Delivery
L...J Facsimile
L...J Email
Conley Ward
Givens Pursley, LLP
277 N. 6th St., Suite 200
O. Box 2720
Boise, ill 83701-2720
Hand DeliveryLkJ u. S. Mail
L...J Overnight Delivery
L...J Facsimile
L...J Email
Clay R. Sturgis
Moss Adams, LLP
601 W. Riverside, Suite 1800
Spokane, W A 99201-0663
J Hand DeliveryUU U. S. Mail
L...J Overnight Delivery
L...J Facsimile
L...J Email
Dean J. Miller
McDevitt & Miller LLP
420 W. Bannock St.
O. Box 2565
Boise, ill 83702
J Hand Delivery
U. S.Mail
L...J Overnight Delivery
L...J Facsimile
L...J Email
Brian Thomas
Time Warner Telecom
223 Taylor Ave North
Seattle, W A 98109
J Hand DeliverylLJ u. S. Mail
L...J Overnight Delivery
L...J Facsimile
L...J Email
Susan Travis
Worldcom, Inc.
707 17th Street, Suite 4200
Denver, CO 80202
Hand Delivery
U. S. Mail
L...J Overnight Delivery
L...J Facsimile
L...J Email
Mary Jane Rasher
AT&T Communications of the
Mountain States Inc.
10005 S. Gwendelyn Lane
Highlands Ranch, CO 80129-6217
J Hand DeliveryUU U. S. Mail
L...J Overnight Delivery
L...J Facsimile
L...J Email
QWEST CORPORATION'S RESPONSES TO SECOND PRODUCTION REQUEST OF THE
COMMISSION STAFF - Page - 2
Boise-153453.10029164-00087
Marlin D. Ard
Willard L. Forsyth
Hershner, Hunter, Andrews, Neill
& Smith, LLP
180 E 11th Ave
O. Box 1475
Eugene, OR 97440-1475
Hand Deliveryuu U. S. Mail
L...J Overnight Delivery
L...J Facsimile
L...J Email
John Gannon
Attorney at Law
1101 W. River, Suite 110
Boise, ill 83702
Hand Delivery
LKJ u. S. Mail
L...J Overnight Delivery
L...J Facsimile
L...J Email
Dean Randall
Verizon Northwest, Inc.
17933 NW Evergreen Pkwy
Beaverton, OR 97006-7438
Hand DeliverylLJ u. S. Mail
L...J Overnight Delivery
L...J Facsimile
L...J Email
~~\n
Assistant to Mary Hobson
QWEST CORPORATION'S RESPONSES TO SECOND PRODUCTION REQUEST OF THE
COMMISSION STAFF - Page - 3
Boise-153453.1 0029164-00087
Idaho
Case No. QWE-02-
STF 02-012P
INTERVENOR:Staff of the Idaho Public Utilities Commission
REQUEST NO:012P
Please provide electronic copies of all numerical exhibits filed by Qwest
in this proceeding. Provide numerical exhibits in standard spreadsheetformat (e., Excel) with functioning macros and formulas used to generate
any computed numbers.
RESPONSE:
Qwest objects to this request as being vague in terms of its use of the termnumerical exhibits.
Without waiving that objection , and specifically subject thereto , Qwest
responds as follows:
Electronic copies of the following documents are being provided in response
to this request:
Confidential
xls)
Conf idential
xls)
Confidential
Confidential
Confidential
Attachment F
Attachment G
Attachment H
Attachment I
Attachment J
Attachment A (STF 01-0021 Intrastate Confidential Attachment
Attachment B (STF 01-0021 Interstate Confidential Attachment
Attachment C (STF 01-004P
Attachment D (STF 01-0091
Attachment E (STF 01-0101
(Teitzel Exhibit 13.xls)
(Teitzel Exhibit 14.xls)
(Residential and Small Business
(Residential Data Set .xls)
(Small Business Data Set .xls)
Confidential Attachment A.xls)
Confidential Attachment A.xls)
Confidential Attachment A.xls)
Verbatims .xls)
**Attachment J are the data sets containing the information shown on pages
20 and 51-61 of the response to STF 01-003P. Please note that phone numbers
of respondents have been omitted to preserve respondent confidentiality. Both
data set files contain a second worksheet (labeled "Codes") that identifies
the information contained in each column in the spreadsheets.
Idaho
Case No. QWE-02-
STF 02-013P
INTERVENOR:Staff of the Idaho Public Utilities Commission
REQUEST NO:013P
To the extent not already provided , please provide all source documents and
workpapers supporting all exhibits filed by Qwest in this proceeding. To the
extent already provided , please identify all source documents and workpapers
supporting each Exhibit filed by Qwest in this proceeding. This request
includes source documents supporting workpapers and source documents
supporting other source documents. The intent of this request is to ensure
that we have received all available documentation which supports the
information provided in the Exhibits. If available, provide this information
in standard spreadsheet format (e. g., Excel) with functioning macros and
formulas used to generate any computed numbers.
RESPONSE:
Qwest obj ects to this request in so far as it is vague, overly broad and
unduly burdensome. Qwest further obj ects in so far as the request seeks
information protected by the attorney-client privilege or as attorney work
product.
Without waiving those objections, and specifically subject thereto , Qwest
responds as follows:
Exhibit As indicated in Qwest r s response to the Staff I s first set ofinterrogatories and requests for production (STF 01-004P), the values
depicting the number of wireless subscribers in Idaho were obtained via
telephone conversation with Alyson Anderson , Administrator of the Idaho
Telephone Service Assistance Plan. Ms. Anderson relied on reports provided
directly to her by the wireless carriers operating in Idaho. James Wozniak
formerly Idaho Director of Policy & Law and now a consultant for Qwest in
Idaho, contacted Ms. Anderson and wrote the values provided by her on notepaper. Several calls were made over a period of years to obtain the four
values and dates from Ms. Anderson and to track the growth of wireless
subscribers in Idaho. Once the values were transferred to electronic format
and verified as accurate against the original hand-written values, Mr.
Wozniak discarded the sheets of note paper.
Exhibit 2 . Please see Confidential Attachment A, which provides access line
counts for southern Idaho and the seven exchanges. This source document
provides the numbers which build the spreadsheet provided in response to STF
01-004P. The spreadsheet provided in response to STF 01-004P was the source
document used to produce Mr. Souba's Exhibit No.2, pages 1 - 8. In addition
please see Confidential Attachment B (Sept Reg 10 (10-28-02) .xls), which
provides source information for Mr. Souba s original Exhibit 2 , which has
since been replaced with a Revised Exhibit
Respondent:Jim Wozniak
Exhibit 12 The source documents for the competitive wireless coverage
areas shown on Exhibit 12 to Mr. Teitzel's direct testimony were the
official internet web sites for the respective wireless carriers. These
web addresses are as follows:
Cricket:
Clear Talk:
Mobile:
Nextel:
Sprint:
Verizon:
Edge Wireless:
AT&T
U S Cellular:
http: / /www.cricketcommunications.com
ht tp: / /www. cleartalk. net
http: / /www. t-mobile. com
ht tp: / /www. nextel . com
http: / /www. sprintpcs. com
http: / /www.verizonwireless.com
http: / /www. edgewireless . com
http: / /www.attws.com
http: / /www.uscellular.com
In each instance, the coverage area maps were obtained from these web
sites, then superimposed in Powerpoint on a map of Qwest' s Idaho wire
center boundaries. Those powerPoint documents comprise Exhibit 12.
Respondent:David Teitzel
Exhibit 13 Please see Confidential Attachment C, which is an electronic
copy of the material presented on pages 1-4 of the response to STF 01-003P.
Respondent:Doug Lincoln
Regarding Exhibit
At tachment
Attachment E
Attachment F
Attachment G
Attachment H
Attachment I
Attachment J
Attachment K
At tachment L
, the following documents are also attached:
(Wireless Comparison Oct 02 (10-17-02) .xls) **
(ID comparisons exhibit (11-25-02) .xls) **
(ID price comparisons (11-02) .xls) **
(ID price comparisons (11-02) .xls) **
(ID Wireless Comparison (11-4-02) .xls**
(ID Wireless Comparison Exc Compare Oct 02 .xls) **
(ID Wireless Comparison Oct 02 .xls) **
(ID Wireless Comparison Oct 02 (10-18-02) .xls) **
(ID Wireless Comparison Oct 02 (10-21-02) .xls) **
** Please note that Attachments D through L are prior , working versions of
the spreadsheet that was ultimately filed as Exhibit 13 to Mr. Teitzel'
testimony.
Respondent:David Teitzel
Exhibit 14 Please see Attachment M , which is the "South Idaho DCR
Analysis." Attachment M is the source document for Mr. Teitzel's Exhibit No.14. The acronym "DCR" means "disconnect reason This is a count of
residential disconnect service orders in Southern Idaho for which the
customer reported to Qwest that the wireline service is being disconnected in
lieu of wireless service.
Respondent:David Teitzel
Idaho
Case No. QWE-02-
STF 02-014P
INTERVENOR:Staff of the Idaho Public Utilities Commission
REQUEST NO:014P
Please refer to Qwest's response to Staff Request for Production 1-6. Please
provide copies of the "national statistics" referenced in this response.
RESPONSE:
See, e., Qwest's response to STF 01-010P , Attachment A , page 35 of 40
Yankee Group News Release.
Respondent:Jim Wozniak
Idaho
Case No. QWE-O2-
STF 02-015P
INTERVENOR:Staff of the Idaho Public Utilities Commission
REQUEST NO:015P
Please refer to Qwest's response to Staff Request for Production 1-6. Please
provide the requested information for all wireless service providers owned by
or affiliated with the Company or Qwest Communications International Inc.
RESPONSE:
Qwest objects in so far as this request seeks information that is not
relevant to the present case and is not reasonably calculated to lead to the
discovery of admissible evidence. Idaho Code ~ 62-622 (3) (b) defines the
scope of this proceeding as determining whether there are "functionally
equivalent, competi ti vely priced local services reasonably available to both
residential and small business customers from a telephone corporation
unaffiliated with the incumbent telephone corporation.Qwest Wireless datais thus outside the scope of this proceeding. Qwest further obj ects in so
far as this request is overly broad and unduly burdensome
Without waiving those objections, and specifically subject thereto, Qwest
responds as follows:
Please see Confidential Attachment A , a spreadsheet containing both
residential and business customers in the seven exchanges for which Qwest is
seeking economic deregulation. These are customers who either have Qwest
wireless service exclusively OR have Qwest wireline service billed on a
separate billed telephone number ("BTN"
Respondent:Rex Morse
Idaho
Case No. QWE-02-
STF 02-016P
INTERVENOR:Staff of the Idaho Public Utilities Commission
REQUEST NO:016P
For each of the 7 exchanges at issue in this proceeding, please provide the
following: number of residential customers; number of business customers;
number of residential access lines; and , number of business access lines.
RESPONSE:
Please see Confidential Attachment A , a spreadsheet depicting the number of
Qwest residential customers in access 'lines in the 7 exchanges. The "RES
Customers" column includes the quantity of residence primary lines. The "RES
Access Lines " column includes both residence primary and additional lines.
Also , see Confidential Attachment B , a spreadsheet depicting the number of
Qwest business lines (both T-61 and T-62) and Billed Telephone Numbers
BTNs") in the 7 exchanges.
Respondent:Rex Morse
Idaho
Case No. QWE-O2-
STF 02-017P
INTERVENOR:Staff of the Idaho Public Utilities Commission
REQUEST NO:017P
For each of the 7 exchanges at issue in this proceeding, please provide the
number of residential customers who also receive wireless service from a
wireless service provider own by or affiliated with the Company or Qwest
Communications International Inc.
RESPONSE:
Qwest objects in so far as this request seeks information that is not
relevant to the present case and is not reasonably calculated to lead to the
discovery of admissible evidence. Idaho Code ~ 62-622 (3) (b) defines the
scope of this proceeding as determining whether there are functionally
equivalent, competitively priced local services reasonably available to both
residential and small business customers from a telephone corporation
unaffiliated with the incumbent telephone corporation." Qwest Wireless datais thus outside the scope of this proceeding. Qwest further obj ects in so
far as this request is overly broad and unduly burdensome
Without waiving those objections, and specifically subject thereto, Qwest
responds as follows:
Please see Confidential Attachment A , which shows the total number of Qwest
residential wireline customers in the 7 exchanges who also use Qwest wireless
service.
Respondent:Rex Morse
Idaho
Case No. QWE-02-
STF 02-018P
INTERVENOR:Staff of the Idaho Public Utilities Commission
REQUEST NO:018P
Please refer to Qwest' s response to Staff Request for Production 1-7. Please
provide the requested information for consumers who are customers of both the
Company and any wireless service provider own by or affiliated with the
Company or Qwest Communications International Inc.
RESPONSE:
Qwest objects in so far as this request seeks information that is not
relevant to the present case and is not reasonably calculated to lead to the
discovery of admissible evidence. Idaho Code ~ 62-622 (3) (b) defines the
scope of this proceeding as determining whether there are "functionally
equivalent , competitively priced local services reasonably available to both
residential and small business customers from a telephone corporation
unaffiliated with the incumbent telephone corporation.Qwest Wireless datais thus outside the scope of this proceeding. Qwest further obj ects in so
far as this request is overly broad and unduly burdensome
Without waiving those objections , and specifically subject thereto , Qwest
responds as follows:
Please see Confidential Attachment A , which shows the total number of Qwest
business and residential customers in the 7 exchanges who also use Qwest
wireless service.
Customers whose billing address is in Idaho but whose wireless service has
been ordered for a different service territory (for example , their wireless
phone has a "303" area code) were excluded from the data because , although
their billing goes to Idaho , the Idaho service territory is not their primaryterri tory.
Respondent:Rex Morse
Idaho
Case No. QWE-O2-
STF 02-019P
INTERVENOR:Staff of the Idaho Public Utilities Commission
REQUEST NO:019P
Please provide copies of all data or other information reviewed by Qwest
(other than the information previously filed by Qwest in this proceeding)
which tends to prove that wireless services are "functionally equivalent" to
Qwest's basic local exchange service.
RESPONSE:
Qwest objects to this Request for Production on the grounds and for the
reasons that it seeks statements of opinion not previously written or
published, in violation of IPUC Rule of Procedure 225. Qwest further objects
on the grounds that the request appears to seek Qwest' s attorneys ' legal
opinions or attorney work product. Finally, Qwest obj ects that the request
is overly broad , unduly burdensome and vague.
Idaho
Case No. QWE-02-
STF 02-020P
INTERVENOR:Staff of the Idaho Public Utilities Commission
REQUEST NO:020P
Please provide copies of all data or other information reviewed by Qwest
(other than the information previously filed by Qwest in this proceeding)
which tends to prove that wireless services are not "functionally equivalent"
to Qwest' s basic local exchange service.
RESPONSE:
Qwest obj ects to this Request for Production on the grounds and for the
reasons that it seeks statements of opinion not previously written or
published , in violation of IPUC Rule of Procedure 225. Qwest further obj ects
on the grounds that the request appears to seek Qwest' s attorneys ' legal
opinions or attorney work product. Finally, Qwest objects that the request
is overly broad, unduly burdensome and vague.
Without waiving the foregoing objections
Qwest further responds to the request by
to respond to this request since it does
documents.
and specifically relying thereon
stating that it finds itself unable
not seek obj ecti vely discernible
Idaho
Case No. QWE-O2-
STF 02-021P
INTERVENOR:Staff of the Idaho Public Utilities Commission
REQUEST NO:021P
Please provide copies of all data or other information reviewed by Qwest
(other than the information previously filed by Qwest in this proceeding)
which tends to prove that wireless services are "competitively priced" with
Qwest's basic. local exchange service.
RESPONSE:
Qwest objects to this Request for Production on the grounds and for the
reasons that it seeks statements of opinion not previously written or
published , in violation of IPUC Rule of Procedure 225. Qwest further obj ects
on the grounds that the request appears to seek Qwest's attorneys ' legal
opinions or attorney work product. Finally, Qwest obj ects that the request
is overly broad, unduly burdensome and vague.
Idaho
Case No. QWE-02-
STF 02-022P
INTERVENOR:Staff of the Idaho Public Utilities Commission
REQUEST NO:022P
Please provide copies of all data or other information reviewed by Qwest
(other than the information previously filed by Qwest in this proceeding)
which tends to prove that wireless services are not competitively priced"
with Qwest's basic local exchange service.
RESPONSE:
Qwest objects to this Request for Production on the grounds and for the
reasons that it seeks statements of opinion not previously written or
published , in violation of IPUC Rule of Procedure 225. Qwest further objects
on the grounds that the request appears to seek Qwest' s attorneys ' legal
opinions or attorney work product. Finally, Qwest obj ects that the request
is overly broad, unduly burdensome and vague.
Without waiving the foregoing objections
Qwest further responds to the request by
to respond to this request since it does
documents.
and specifically relying thereon
stating that it finds itself unable
not seek objectively discernible
Idaho
Case No. QWE-O2-
STF 02-023P
INTERVENOR:Staff of the Idaho Public Utilities Commission
REQUEST NO:023P
Please provide copies of all data or other information reviewed by Qwest
(other than the information previously filed by Qwest in this proceeding)
which tends to prove that wireless services are "reasonably available to both
residential and small business customers" in the 7 exchanges at issue in this
proceeding.
RESPONSE:
Qwest objects to this Request for Production on the grounds and for the
reasons that it seeks statements of opinion not previously written or
published, in violation of IPUC Rule of Procedure 225. Qwest further obj ects
on the grounds that the request appears to seek Qwest's attorneys ' legal
opinions or attorney work product. Finally, Qwest obj ects that the request
is overly broad, unduly burdensome and vague.
Idaho
Case No. QWE-02-
STF 02-024P
INTERVENOR:Staff of the Idaho Public Utilities Commission
REQUEST NO:024P
Please provide copies of all data or other information reviewed by Qwest
(other than the information previously filed by Qwest in this proceeding)
which tends to prove that wireless services are not reasonably available to
both residential and small business customers" in the 7 exchanges at issue in
this proceeding.
RESPONSE:
Qwest objects to this Request for Production on the grounds and for the
reasons that it seeks statements of opinion not previously written or
published, in violation of IPUC Rule of Procedure 225. Qwest further objects
on the grounds that the request appears to seek Qwest' s attorneys ' legal
opinions or attorney work product. Finally, Qwest obj ects that the request
is overly broad , unduly burdensome and vague.
Without waiving the foregoing objections
Qwest further responds to the request by
to respond to this request since it does
documents.
and specifically relying thereon
stating that it finds itself unable
not seek obj ecti vely discernible
Idaho
Case No. QWE-O2-
STF 02-025P
INTERVENOR:Staff of the Idaho Public Utilities Commission
REQUEST NO:025P
Please refer to page 19 of the testimony of Douglas Lincoln, Please provide
copies of the 36 responses referenced on line
RESPONSE:
Please see Attachment A.
Respondent:Doug Lincoln
Idaho
Case No. QWE-02-
STF 02-026P
INTERVENOR:Staff of the Idaho Public Utilities Commission
REQUEST NO:026P
Please refer to page 20 of the testimony of Douglas Lincoln. Please provide
copies of the questionnaire referenced on line 17.
RESPONSE:
The questionnaire referred to on page 20 of Douglas Lincoln I s testimony was
reproduced (for both the residential and small business respondents) on pages
7 and 47-50 of Qwest I s response to STF 01-003P.
Respondent:Doug Lincoln
Idaho
Case No. QWE-T- 02 - 25
STF 02-027P
INTERVENOR:Staff of the Idaho Public Utilities Commission
REQUEST NO:027P
Please refer to page 27 of the testimony of Douglas Lincoln. Please provide a
complete narrative explanation of the "data editing " referenced on line 3.
RESPONSE:
Data editing refers to reviewing the (Excel) data sets forwarded by
FrederickPolls to ensure accuracy and precision. This included looking for
incomplete, inconsistent , and/or other possible response or data recoding
errors. For example, all completed records were reviewed to identify and omit
any duplicate entries , identify situations where recorded responses (e., a
6") fell outside of the set of possible responses (e.g., 1 through 5), or
where responses to one question would not be logical given a response to
another question. In cases where suspicious data were found , consultation
with FrederickPolls was undertaken for clarification and/or additional
information before deciding on how to treat the data. The purpose of data
editing was to ensure that all data analyzed and reported in Exhibits 8-
were valid measures of what they portrayed.
Respondent:Doug Lincoln
Idaho
Case No. QWE-O2-
STF 02-028P
INTERVENOR:Staff of the Idaho Public Utilities Commission
REQUEST NO:028P
Please refer to Exhibit B attached to the testimony of Douglas Lincoln.
Please provide the information included in this exhibit for each of the 7
exchanges at issue in this proceeding.
RESPONSE:
Qwest will supplement its response to this request.
Idaho
Case No. QWE-02-
STF 02-029P
INTERVENOR:Staff of the Idaho Public Utilities Commission
REQUEST NO:029P
Please refer to Exhibit 10 attached to the testimony of Douglas Lincoln.
Please provide the information included in this exhibit for each of the 7
exchanges at issue in this proceeding.
RESPONSE:
Qwest will supplement its response to this request.
Idaho
Case No. QWE-02-
STF 02-030P
INTERVENOR:Staff of the Idaho Public Utilities Commission
REQUEST NO:030P
Please refer to page 9 of the testimony of Harry Shooshan. Please provide a
copy of the presentation referenced in footnote 15.
RESPONSE:
See Qwest's response to STF 01-010P, Attachment A , pages 20 through 34
presentation of Robert Crandall.
Respondent:Jim Wozniak
Idaho
Case No. QWE-02-
STF 02-031P
INTERVENOR:Staff of the Idaho Public Utilities Commission
REQUEST NO:031P
Please refer to page 11 of the testimony of Douglas Lincoln. Please provide a
copy of the article referenced in footnote 21.
RESPONSE:
See the response to STF 01-010P , Attachment A, pages 37 & 38 , article by
Joelle Tessler.
Respondent:Jim Wozniak