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Home My WebLink About200304071st Pro Request of Qwest to Carol Moyer.pdfMary S. Hobson (ISB #2142) Stoe1 Rives LLP 101 South Capitol Boulevard - Suite 1900 Boise, ill 83702 Telephone: (208) 389-9000 Facsimile: (208) 389-9040 mshobson(~Moel.com RECEIVED mF!LED 2003 APR -1+ PM 4: 51 JDt\HiJ PUbLIC UTILITIES COi'"1t1ISSION 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- T -02- QWEST CORPORATION'S FIRST INTERROGATORIES AND REQUESTS FOR PRODUCTION OF DOCUMENTS TO CAROL MOYER 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 Carol Moyer. Ms. Moyer is requested to answer the following Interrogatories and Requests in writing and under oath by April 14, 2003. These Interrogatories and Requests shall be deemed continuing, and if Ms. Moyer, or her attorneys discover additional information and facts related to the matters inquired of between the QWEST CORPORATION'S FIRST INTERROGATORIES AND REQUESTS FOR PRODUCTION OF DOCUMENTS TO CAROL MOYER - Page 1 Boise-155221.1 0029164-00004 time answers are made and the time of the hearing in this matter, 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 "you" or "your" refers to Carol Moyer and her representatives including her attorneys or any employees, agents, investigators 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 REQUESTS FOR PRODUCTION OF DOCUMENTS TO CAROL MOYER - Page 2 Boise-155221.1 0029164-00004 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 of the 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 REQUESTS FOR PRODUCTION OF DOCUMENTS TO CAROL MOYER - Page 3 Boise-155221.1 0029164-00004 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. INTERROGATORY NO.To the extent not already provided in her testimony, please identify all of Ms. Moyer s credentials to offer opinion testimony on the wireless industry and on wireless technology. For purposes of this Interrogatory, "opinion testimony" refers to any written or verbal testimony not specifically supported by a third party document (i., not one produced by or on behalf Ms. Moyer) identified and produced in this case. By "credentials Qwest seeks an identification of specific educational, vocational and first hand research experiences, as well as any studies, reports or publications authored by Ms. Moyer. - INTERROGATORY NO.Have you ever researched or inquired with any of the wireless carriers serving Boise whether such carriers offer extension phones or an equivalent? yes, please fully explain the results of your inquiry. INTERROGATORY NO.On average, how long does it take you to use the 420 long-distance minutes you are allotted on your Costco calling card? INTERROGATORY NO.Have you ever researched, or inquired of the wireless carriers serving Boise, the possibility of replacing your Qwest wireline local telephone service with wireless service? If yes, please fully explain the results of your inquiry. INTERROGATORY NO.On page 2 of your testimony, you discuss the disparity between the taxes and fees appearing on your wireline and wireless bills. Do you believe that such disparity causes wireless services to be priced artificially lower than wireline service by comparison? Please fully explain your answer. INTERROGATORY NO.On page 1 of your testimony, you state that you spend a lot of time on your phone. Please identify how many minutes per month you spend on your QWEST CORPORATION'S FIRST INTERROGATORIES AND REQUESTS FOR PRODUCTION OF DOCUMENTS TO CAROL MOYER - Page 4 Boise-155221.1 0029164-00004 Qwest home phone. Please identify, of those total minutes, how many minutes are spent connected to the Internet. Please also identify any documents which would corroborate your time estimates. REQUEST FOR PRODUCTION OF DOCUMENTS NO.Produce all documents identified in response to Interrogatory No. INTERROGATORY NO.Identify all studies, surveys, data, facts and documents you reviewed to reach the conclusion, as stated on page 1 of your testimony, that you "would bet (you) would regularly exceed (wireless plan) minute limitations. REQUEST FOR PRODUCTION OF DOCUMENTS NO.Produce all documents identified in response to Interrogatory No. INTERROGATORY NO.Please explain how you came to be involved in this case. Include in your description whether you or YOl,lr representative was contacted by Commission Staff, Mr. Gannon or any other party and asked to participate. Also, if you or your representative was contacted and invited to participate, include in your description, to your best recollection what was stated by that third party. INTERROGATORY NO.Do you receive cable television service at your home? , what cable company provides your service? INTERROGATORY NO. 10: Please provide your home address. REQUEST FOR PRODUCTION OF DOCUMENTS NO.To the extent not produced in response to Request for Production Nos. 1 or 2, please produce all documents in your possession relevant to your responses to Interrogatory Nos. 1-10. QWEST CORPORATION'S FIRST INTERROGATORIES AND REQUESTS FOR PRODUCTION OF DOCUMENTS TO CAROL MOYER - Page 5 Boise-155221.1 0029164-00004 Respectfully submitted this day of April, 2003. Qwest Corporation Adam L. Sherr Qwest Corporation Attorneys for Qwest Corporation QWEST CORPORATION'S FIRST INTERROGATORIES AND REQUESTS FOR PRODUCTION OF DOCUMENTS TO CAROL MOYER - Page 6 Boise-155221.1 0029164-00004 CERTIFICATE OF SERVICE I hereby certify that on this day of April, 2003, I served the foregoing QWEST CORPORATION'S FIRST INTERROGATORIES AND REQUESTS FOR PRODUCTION OF DOCUMENTS TO CAROL MOYER 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(Q),puc.state.id. us Weldon Stutzman, Deputy Attorney General Idaho Public Utilities Commission 472 West Washington Street O. Box 83720 Boise, ill 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, ill 83702 Telephone: (208) 433-0629 Attorney for Meierotto, Padget, Herrick Neal ---X- Hand Delivery U. S. Mail Overnight Delivery Facsimile Email ---X- Hand Delivery U. S. Mail Overnight Delivery Facsimile Email Hand Delivery ---X- u. S. Mail Overnight Delivery Facsimile Email ---X- Hand Delivery U. S. Mail Overnight Delivery Facsimile Email QWEST CORPORATION'S FIRST INTERROGATORIES AND REQUESTS FOR PRODUCTION OF DOCUMENTS TO CAROL MOYER - Page 7 Boise-15522L! 0029164-00004 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~mcdevitt -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 ~verizon. co 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, WA 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, W A 99201-0663 Hand Delivery ~ U.Mail Overnight Delivery Facsimile Email Brian Thomas Time Warner Telecom 223 Taylor Avenue North Seattle, W A 98109 Brian. Thomas~twtelecom.com Hand Delivery ~ U.Mail Overnight Delivery Facsimile Email QWEST CORPORATION'S FIRST INTERROGATORIES AND REQUESTS FOR PRODUCTION OF DOCUMENTS TO CAROL MOYER - Page 8 Boise-155221.10029164-00004 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, ill 83701-2720 Telephone: (208) 388-1200 Facsimile: (208) 388-1300 cew~givenspursley.com Attorneys for Idaho Telephone Association Executed protective agreement Hand Delivery U. S. Mail Overnight Delivery Facsimile Email Hand Delivery~ U.Mail Overnight Delivery Facsimile Email )k~ Brandi L. Gearhart, PLS Legal Secretary to Mary S. Hobson Stoel Rives LLP QWEST CORPORATION'S FIRST INTERROGATORIES AND REQUESTS FOR PRODUCTION OF DOCUMENTS TO CAROL MOYER - Page 9 Boise-15522Ll 0029164-00004