HomeMy WebLinkAbout200304071st Pro Request of Qwest to Joel Sales.pdfMary S. Hobson (ISB #2142)
Stoel Rives LLP
101 South Capitol Boulevard - Suite 1900
Boise, ill 83702
Telephone: (208) 389-9000
Facsimile: (208) 389-9040
mshobson~stoel.com
RECEIVED mFILED
2003 APR -4 PM ~: 51
IDhHU PUf3LIC
UTILITIES COMMISSION
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 JOEL
SALES
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 Joel Sales. Mr. Sales
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 Mr. Sales, or his
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, supplemental answers shall be
QWEST CORPORATION'S FIRST INTERROGATORIES AND
REQUESTS FOR PRODUCTION OF DOCUMENTS TO JOEL SALES - Page
Boise-155229.10029164-00087
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 Joel Sales and his representatives including his
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 JOEL SALES - Page 2
Boise-155229.10029164-00087
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 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 partes)
completely.
QWEST CORPORATION'S FIRST INTERROGATORIES AND
REQUESTS FOR PRODUCTION OF DOCUMENTS TO JOEL SALES - Page 3
Boise-155229.10029164-00087
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.
INTERROGATORY NO.Please identify all ofMr. Sales ' credentials to offer expert
opinion testimony on the wireless industry and on wireless technology. For purposes of this
Interrogatory, "expert 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 Mr.
Sales) 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 Mr. Sales.
INTERROGATORY NO.Your direct testimony is offered "on behalf of Intervenors
Meierotto, et al". Please explain your relationship with the Intervenors and describe whether you
are testifying, "on behalf' of said individuals as an expert or in some other capacity.
INTERROGATORY NO.Describe how you came to be involved in this case on
behalf of the Intervenors Meierotto et al. Include in your description whether you or your
representative was contacted by one or more of the Intervenors, 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.Did Idaho Windows research or contact any competitive
local exchange carriers ("CLECs ) to determine if the company could obtain its telephone
service from a CLEC? If yes, please fully describe all such contacts and why it opted to obtain
service from or remain with Qwest. If no, please fully explain why it did not.
QWEST CORPORATION'S FIRST INTERROGATORIES AND
REQUESTS FOR PRODUCTION OF DOCUMENTS TO JOEL SALES - Page 4
Boise-155229.1 0029164-00087
INTERROGATORY NO.Did Idaho Windows research or contact any wireless
providers to determine if the company could obtain all its telephone service from a wireless
provider? If yes, please fully describe all such contacts and why your company opted to obtain
or continue obtaining wireline service from Qwest. Ifno, please fully explain why it did not.
INTERROGATORY NO.Identify the wireless carrier and describe all wireless
plans you use for your personal cell phone.
INTERROGATORY NO.Do you use your home cell phone to make long-distance
calls rather than using your Qwest residential phone? Please fully explain why or why not.
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.Have you ever researched or inquired with any 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. 10:Do you receive cable television service at your home?
, what cable company provides you service?
INTERROGATORY NO. 11:Please provide your home address.
REQUEST FOR PRODUCTION NO.Produce all documents in your possession
relevant to your responses to Interrogatory Nos. 1-11.
QWEST CORPORATION'S FIRST INTERROGATORIES AND
REQUESTS FOR PRODUCTION OF DOCUMENTS TO JOEL SALES - Page 5
Boise-155229.1 0029164-00087
Respectfully submitted this4 ~day of April, 2003.
Qwest Corporation
~ft.ff: hb~
Stoel Rives LLP
Adam L. Sherr
Qwest Corporation
Attorneys for Qwest Corporation
QWEST CORPORATION'S FIRST INTERROGATORIES AND
REQUESTS FOR PRODUCTION OF DOCUMENTS TO JOEL SALES - Page 6
Boise-155229.1 0029164-00087
CERTIFICATE OF SERVICE
I hereby certify that on this ay of April, 2003 , I served the foregoing QWEST
CORPORATION'S FIRST INTERROGATORIES AND REQUESTS FOR PRODUCTION OF
DOCUMENTS TO JOEL SALES 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
ii ewell~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, ID 83702
Telephone: (208) 433-0629
Attorney for Meierotto, Padget, Herrick Neal
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QWEST CORPORATION'S FIRST INTERROGATORIES AND
REQUESTS FOR PRODUCTION OF DOCUMENTS TO JOEL SALES - Page 7
Boise-155229.10029164-00087
Dean J. Miller
McDevitt & Miller LLP
420 West Bannock Street
O. Box 2565
Boise, ill 83701
Telephone: (208) 343-7500
Facsimile: (208) 336-6912
i oe~mcdevitt - miller.com
Attorneys for Time Warner Telecom
Executed protective agreement
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Dean Randall
Verizon Northwest Inc.
17933 NW Evergreen Parkway
Beaverton, OR 97006-7438
dean.randall~verizon. co
Executed protective agreement
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Mary Jane Rasher
10005 South Gwendelyn Lane
Highlands Ranch, CO 80129-6217
Telephone: (303) 470-3412
mirasher~msn.com
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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
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Clay R. Sturgis
Moss Adams LLP
601 West Riverside - Suite 1800
Spokane, WA 99201-0663
Hand Delivery
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Brian Thomas
TimeWarner Telecom
223 Taylor Avenue North
Seattle, W A 98109
Brian. Thomas~twtelecom. com
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Email
QWEST CORPORATION'S FIRST INTERROGATORIES AND
REQUESTS FOR PRODUCTION OF DOCUMENTS TO JOEL SALES - Page 8
Boise-I 55229.1 0029164-00087
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, ill 83701-2720
Telephone: (208) 388-1200
Facsimile: (208) 388-1300
cew~givenspursley.com
Attorneys for Idaho Telephone Association
Executed protective agreement
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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 JOEL SALES - Page 9
Boise-155229.10029164-00087