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Home My WebLink About200303311st Pro Request of Qwest.pdf:- ;, "- om, , :::. ~. . ..... Mary S. Hobson (ISB #2142) Stoe1 Rives LLP 101 South Capitol Boulevard - Suite 1900 Boise, ID 83702 Telephone: (208) 389-9000 Facsimile: (208) 389-9040 mshobson~stoel.com , ::. r. ' U i , ' 0 " viii..... " ,;; .(\ ~ JI. Adam L. Sherr (WSBA #25291) Qwest 1600 7th Avenue - Room 3206 Seattle, WA 98191 Telephone: (206) 398-2507 Facsimile: (206) 343-4040 asherr~qwest.com Attorneys for Qwest Corporation BEFORE THE IDAHO PUBLIC UTILITIES COMMISSION IN THE MATTER OF THE APPLICATION OF QWEST CORPORATION FOR PRICE DEREGULATION OF BASIC LOCAL EXCHANGE SERVICES Case. No. QWE-O2- QWEST CORPORATION'S FIRST INTERROGATORIES AND REQUESTS FOR PRODUCTION OF DOCUMENTS TO STAFF Qwest Corporation ("Qwest") pursuant to Rule 225 of the Rules of Procedure of the Idaho Public Utilities Commission and Idaho Rules of Civil Procedure 33 and 34 hereby submits the following Interrogatories and Requests for Production of Documents to the Staff of the Idaho Public Utilities Commission ("Staff'). Staff is requested to answer the following Interrogatories and Requests in writing and under oath by AprilS, 2003. These Interrogatories and Requests shall be deemed continuing, and if Staff, its consultants or its attorneys discover additional information and facts related to the matters inquired of between the time answers are made and the time of the hearing in this matter QWEST CORPORATION'S FIRST INTERROGATORIES AND REQUEST FOR PRODUCTION OF DOCUMENTS TO STAFF - Page Boise-154917.2 0029164-00087 supplemental answers shall be made informing Qwest and Qwest's attorneys as to said newly discovered information as far in advance of the hearing as possible. DEFINITIONS The term "Staff' , " you" or "your" refers to the Staff of the Idaho Public Utilities Commission, and its agents, consultants and representatives including its attorneys or any employee, agent, investigator or representative of its attorneys. The term "Qwest" refers to and shall mean Qwest Corporation. The terms "relating , " related", or "which relates to" means constitutes, refers to contains, embodies, evidences, reflects, contradicts, refutes, identifies, states, deals with, bears upon, or is in any way logically or factually connected with any matter described. The word "person" means any individual, corporation, joint venture, limited partnership, association, group or entity of any kind. The terms "document" or "statement" refer to and shall mean and include any written, typed, printed, recorded or computer-produced or graphic matter of every type and description, however and by whomever prepared, produced, reproduced, disseminated or made including, but not limited to, reports, letters, correspondence, memoranda, records, summaries analyses, results or reports of investigations, recommendations, diaries, books, messages electronic mail (whether in hard copy form or as stored on disc or computer hard drive), notes tapes, drawings, graphs, photographs, microfilms, telegrams, periodical articles, computer printouts and any other writing, drawing, or records. Terms in the plural include the singular, and terms in the singular include the plural. QWEST CORPORATION'S FIRST INTERROGATORIES AND REQUEST FOR PRODUCTION OF DOCUMENTS TO STAFF - Page 2 Boise-154917,20029164-00087 INSTRUCTIONS Whenever you are requested to identify or describe a document or statement, state with respect to such document or statement the following: The nature, date and substance ofthe document or statement with sufficient particularity to enable it to be identified, including its title, if any; The name, business affiliation and address of each person or persons who drafted, caused to be drafted and/or revised such document or statement; and The name, business affiliation and address of each person who presently has custody of the document or any copy of it and any other description necessary to enable its custodian to locate the document or statement. Whenever you are requested to identify or describe a person, state with respect to each such person the following: his, her or its full name; his, her or its present or last known address; his, her or its present or last known telephone number; and his, her or its position, title and business affiliation. If you object to any Interrogatory or Request for Production, set forth all reasons for the objection. If you claim privilege as a basis for not complying with any Interrogatory or Request for Production, in full or in part, describe the factual basis for the claim of privilege in detail sufficient to permit the Commission to rule upon the validity of the claim. If you object to any part of any Interrogatory or Request for Production, answer the remaining part(s) completely. QWEST CORPORATION'S FIRST INTERROGATORIES AND REQUEST FOR PRODUCTION OF DOCUMENTS TO STAFF - Page 3 Boise-154917.2 0029164-00087 If any information called for by an Interrogatory or Request for Production is unknown to you, so state and then state all remaining information that is known to you. REQUEST FOR PRODUCTION NO.Please produce copies of all comments from groups, organizations, or members of the public received formally or informally by the Commission or its Staff related in any way to this case. INTERROGATORY NO.On pages 8-9 of his Direct Testimony, Mr. Hart states Based on confidential information provided by Qwest, I calculated an amount of peak usage minutes that would correspond to a low, median and high usage customer for both residential and business classes of service, and for both measured and flat rated service." Please provide a table showing the "amount of peak usage minutes" you calculated for each type of customer (low median and high usage), for each type of service (business and residential), and for each type of billing structure (measured and flat-rated). Please use the following table to supply your entries which should be stated to the nearest minute. 1FR 1FB 1MR 1MB Low Usage Median Usage High Usage INTERROGATORY NO.In calculating the number of minutes as described in response to Interrogatory No., what steps, if any, did you take to back out non-voice wireline usage from originating or terminating minutes of use? INTERROGATORY NO.For each wireless company and each page of Exhibit 101 identify the particular wireless plan used for each comparison and all pricing terms related to each such plan, including but not limited to , peak time frames, included minutes of use and rates QWEST CORPORATION'S FIRST INTERROGATORIES AND REQUEST FOR PRODUCTION OF DOCUMENTS TO STAFF - Page 4 Boise-154917.20029164-00087 for additional minutes. Please also identify all documents within Staff s possession setting out such terms. To the extent Staff relied upon a document provided by Qwest in connection with this case, it would be sufficient for Staff to refer to such document by exhibit or data request response number and page. REQUEST FOR PRODUCTION NO.Produce all documents identified in response to Interrogatory No. REQUEST FOR PRODUCTION NO.Produce all work papers, drafts or other documents prepared or utilized in any way in connection with the preparation of Exhibit 101 or any drafts thereof. Also produce any spreadsheets or other documentation you used (with calculation formulas unmasked) to prepare Exhibit 101. INTERROGATORY NO.For each wireless company and each page of Exhibit 102 identify the particular wireless plan used for each comparison and all pricing terms related to each such plan, including but not limited to, peak time frames, included minutes of use for local and long distance minutes and rates for additional minutes for both local and long distance minutes. Please also identify all documents within Staffs possession setting out such terms. REQUEST FOR PRODUCTION NO.Produce all documents identified in response to Interrogatory No. INTERROGATORY NO.Please provide the "peak local minutes" used for each line on each page of Exhibit 102. To the extent that the "peak local minutes" used to develop Exhibit 102 are different from those provided in response to Interrogatory No., provide an explanation of each difference. REQUEST FOR PRODUCTION NO.Produce all work papers, drafts or other documents prepared or utilized in any way in connection with the preparation of Exhibit 102 or QWEST CORPORATION'S FIRST INTERROGATORIES AND REQUEST FOR PRODUCTION OF DOCUMENTS TO STAFF - Page 5 Boise-154917.20029164-00087 any drafts thereof. Also produce any spreadsheets or other documentation you used (with calculation formulas unmasked) to prepare Exhibit 102. INTERROGATORY NO.6: Does Mr. Hart contend that two services must be identically priced in order to be competitively priced? If not, fully describe how Mr. Hart determines whether two services are competitively priced. Please also identify whether there is a real dollar or percentage price differential threshold above which two services can not be competitively priced. Ifthere is such a threshold, please identify the threshold and identify all facts and documents supporting the conclusion that it is the appropriate threshold. REQUEST FOR PRODUCTION NO.Please produce all documents identified in your Response to Interrogatory No.6 or which were consulted in preparation of your response. REQUEST FOR PRODUCTION NO.Please produce all documents that record reflect, summarize or corroborate the "( c )onversations with students and young adults, including (Mr. Hart's) stepson" referred to at page 18, lines 10-18 ofMr. Hart's Direct Testimony. REQUEST FOR PRODUCTION NO.Please produce all documents that record reflect, summarize or corroborate each of the service quality problems experienced by the students and young adults being referred to at page 18, lines 10-18 ofMr. Hart's Direct Testimony. INTERROGATORY NO.Identify by name and street address each student and young adult being referred to at page 18, lines 10-18 ofMr. Hart's Direct Testimony. REQUEST FOR PRODUCTION NO.Produce all documents relating in any way to the activities of March 17, 2003 referred to at page 18, line 21 to page 19, line 12 of Mr. Hart' Direct Testimony. QWEST CORPORATION'S FIRST INTERROGATORIES AND REQUEST FOR PRODUCTION OF DOCUMENTS TO STAFF - Page 6 Boise-154917.20029164-00087 INTERROGATORY NO.8: To the extent that this information is not contained in the documents produced in response to Request for Production No., for each call placed, identify: network, and the location from which the call was placed whether the calling party was stationary or moving, the telephone number and location of the called party, whether a wireline or wireless number was called why the called number was selected whether the call completed whether the call was interrupted due to a problem with the wireless whether the call was interrupted due to a problem with the wireless handset, such as a low battery INTERROGATORY NO.Please explain what Mr. Hart means by his statement on page 18 of his Direct Testimony that "(fJorty of the calls were completed only far enough to verify the ringing of the called wireline phone. INTERROGATORY NO. 10:Is a fair reading ofMr. Hart's testimony concerning the wireless calls placed by Staff on March 17, 2003 that they experienced disconnection or an inability to complete the call on only one of the fifty attempted calls from the Cricket phone? not, please fully explain why this is not a fair reading ofMr. Hart's testimony. INTERROGATORY NO. 11:Did Staff use the same Cricket phone for each call made on March 17 2003 as referred to in Mr. Hart's Direct Testimony? INTERROGATORY NO. 12: Were the activities of March 17 2003 described at pages 18 through 20 ofMr. Hart's Direct Testimony the only empirical test or study attempted or QWEST CORPORATION'S FIRST INTERROGATORIES AND REQUEST FOR PRODUCTION OF DOCUMENTS TO STAFF - Page 7 Boise-J54917.20029164-00087 conducted by or on behalf of Staff in connection with this case? If not, please describe all other such tests or studies and identify all facts and all documents concerning such tests or studies. REQUEST FOR PRODUCTION NO.1 0 : Produce all documents identified in response to Interrogatory No. 12. REQUEST FOR PRODUCTION NO. 11:Please provide any empirical evidence available to Staff or its consultant ofIdaho consumers having difficulty reaching E911 PSAPs via wireless telephones during the past 12 months. REQUEST FOR PRODUCTION NO. 12 : Please provide all reports, studies, price lists and other empirical evidence to support the statement on page 13 ofMr. Hart's testimony that wireless carriers typically charge twenty cents or more per minute for all long distance calls in excess of included minutes. REQUEST FOR PRODUCTION NO. 13:Please provide all reports, studies, price lists and other empirical evidence to support the statement on page 14 ofMr. Hart's testimony that wireless carriers typically charge 45 cents per minute for excess minute charges. REQUEST FOR PRODUCTION NO. 14:Please provide copies of all expert opinion testimony on the wireless industry and/or wireless technology authored by Dr. Johnson and filed in any regulatory proceeding other than the present docket. REQUEST FOR PRODUCTION NO. 15: Please produce all documents that embody, reflect, record, or relate to any analyses or research oftechnical or other aspects of wireless and wireline services undertaken by Dr. Johnson to determine whether wireline and wireless services are functionally equivalent. INTERROGATORY NO. 13 : Please identify specific carrier plans, by name of carrier and name of plan, which require consumers to pay "substantial additional monthly fees for each QWEST CORPORATION'S FIRST INTERROGATORIES AND REQUEST FOR PRODUCTION OF DOCUMENTS TO STAFF - Page 8 Boise-154917.20029164-00087 additional phone" as described on Dr. Johnson s testimony at Page 28. Please describe each plan in detail, including all terms and conditions of such plans, and the pricing of such plans. REQUEST FOR PRODUCTION NO. 16 Please produce all documents identified in your response to Interrogatory No. 13. REQUEST FOR PRODUCTION NO. 17:Please provide all Idaho-specific wireless usage studies Dr. Johnson relied upon to prepare his testimony. REQUEST FOR PRODUCTION NO. 18 Please produce copies of all discovery requests served upon and responses received from other parties to this case. Respectfully submitted this 28th day of March, 2003. Qwest Corporation t!!h~Mary S.obson Stoel Rives LLP ... Adam L. Sherr Qwest Corporation Attorneys for Qwest Corporation QWEST CORPORATION'S FIRST INTERROGATORIES AND REQUEST FOR PRODUCTION OF DOCUMENTS TO STAFF - Page 9 Boise-154917.20029164-00087 CERTIFICATE OF SERVICE I hereby certify that on this 28th day of March, 2003 , I served the foregoing QWEST CORPORATION'S FIRST INTERROGATORIES AND REQUEST FOR PRODUCTION OF DOCUMENTS TO STAFF upon all parties of record in this matter as follows: Jean Jewell, Secretary Idaho Public Utilities Commission 472 West Washington Street Boise, ill 83720-0074 Phone: (208) 334-0300 Fax: (208) 334-3762 i i ewell~puc. state.id. Weldon Stutzman, Deputy Attorney General Idaho Public Utilities Commission 472 West Washington Street O. Box 83720 Boise, ID 83702 Telephone: (208) 334-0300 Facsimile: (208) 334-3762 W stutzm~puc.state.id. us Marlin D. Ard Willard L. Forsyth Hershner, Hunter, Andrews, Neill & Smith LLP 180 East 11 th Avenue O. Box 1475 Eugene, OR 97440-1475 Attorneys for Verizon Executed protective agreement John Gannon, Esq. 1101 West River - Suite 110 Boise, ID 83702 Telephone: (208) 433-0629 Attorney for Meier,otto, Padget, Herrick Neal Hand Delivery U. S. Mail Overnight Delivery Facsimile Email Hand Delivery U. S. Mail Overnight Delivery Facsimile Email Hand Delivery U. S. Mail Overnight Delivery Facsimile Email Hand Delivery U. S.Mail Overnight Delivery Facsimile Email QWEST CORPORATION'S FIRST INTERROGATORIES AND REQUEST FOR PRODUCTION OF DOCUMENTS TO STAFF - Page 10 Boise-154917.20029164-00087 Dean J. Miller McDevitt & Miller LLP 420 West Bannock Street O. Box 2565 Boise, ID 83701 Telephone: (208) 343-7500 Facsimile: (208) 336-6912 i oe((1),mcdevi tt - miller.com Attorneys for Time Warner Telecom Executed protective agreement Hand Delivery U. S. Mail Overnight Delivery Facsimile Email Dean Randall Verizon Northwest Inc. 17933 NW Evergreen Parkway Beaverton, OR 97006-7438 dean. ran dall ((1),v erizo n. co m Executed protective agreement Hand Delivery U. S. Mail Overnight Delivery Facsimile Email Mary Jane Rasher 10005 South Gwendelyn Lane Highlands Ranch, CO 80129-6217 Telephone: (303) 470-3412 mirasher~msn.com Hand Delivery U. S. Mail Overnight Delivery Facsimile Email Adam Sherr Qwest 1600 ih Avenue - Room 3206 Seattle, W A 98191 Telephone: (206) 398-2507 Facsimile: (206) 343-4040 asherr~qwest.com Hand Delivery U. S. Mail Overnight Delivery Facsimile Email Clay R. Sturgis Moss Adams LLP 601 West Riverside - Suite 1800 Spokane, WA 99201-0663 Hand Delivery U. S. Mail Overnight Delivery Facsimile Email Brian Thomas TimeWarner Telecom 223 Taylor Avenue North Seattle, W A 98109 Brian. Thomas((1),twtelecom .com Hand Delivery U. S. Mail Overnight Delivery Facsimile Email QWEST CORPORATION'S FIRST INTERROGATORIES AND REQUEST FOR PRODUCTION OF DOCUMENTS TO STAFF - Page Boise-154917.20029164-00087 Susan Travis WorldCom, Inc. 707 1 ih Street - Suite 4200 Denver, CO 80202 Telephone: (303) 390-6333 Susan. a. Travis~worldcom.com Conley E. Ward, Jr. Givens Pursley LLP 277 North 6th Street - Suite 200 O. Box 2720 Boise, ID 83701-2720 Telephone: (208) 388-1200 Facsimile: (208) 388-1300 cew~gjvenspursley.com Attorneys for Idaho Telephone Association Executed protective agreement Hand Delivery U. S. Mail Overnight Delivery Facsimile Email Hand Delivery U. S. Mail Overnight Delivery Facsimile Email ~#.~ Brandi L. Gearhart, PLS Legal Secretary to Mary S. Hobson Stoel Rives LLP QWEST CORPORATION'S FIRST INTERROGATORIES AND REQUEST FOR PRODUCTION OF DOCUMENTS TO STAFF - Page 12 Boise-154917,20029164-00087