200304071st Pro Request of Qwest to Sharon Herrick.pdf

Mary S. Hobson (ISB #2142)
Stoel Rives LLP
101 South Capitol Boulevard - Suite 1900
Boise, ill 83702
Telephone: [phone]
Facsimile: [phone]
mshobson~stoel.com
RECEIVED mFILED
2003 APR -4 PH 4: 58
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UTILITIES COr1f'tISSION
Adam L. Sherr (WSBA #25291)
Qwest
1600 7th Avenue - Room 3206
Seattle, W A 98191
Telephone: [phone]
Facsimile: [phone]
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
SHARON HERRICK
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 Sharon Herrick. Ms.
Herrick 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. Herrick, or
her 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
QWEST CORPORATION'S FIRST INTERROGATORIES AND
REQUESTS FOR PRODUCTION OF DOCUMENTS TO SHARON HERRICK - Page
Boise-155194.10029164-00087
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 Sharon Herrick 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 SHARON HERRICK - Page 2
Boise-155194.10029164-00087
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 SHARON HERRICK - Page 3
Boise-155194.10029164-00087
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 of Ms. Herrick'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. Herrick)
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. Herrick.
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.Please explain what you mean by "the internet is operated
by Cable One." Do you receive cable-based Internet service? Have you inquired whether Cable
One would be willing to provide you local telephone service? If 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.Please identify all time periods you have been a Mountain
Bell, U S WEST or Qwest customer for local telephone service.
QWEST CORPORATION'S FIRST INTERROGATORIES AND
REQUESTS FOR PRODUCTION OF DOCUMENTS TO SHARON HERRICK - Page 4
Boise-155194.!0029164-00087
INTERROGATORY NO.Aside from the billing dispute described on page 2 of
your testimony, please describe in as much detail as possible (identifying all relevant facts and
documents) any other billing disputes you have had with Mountain, Bell, U S WEST or Qwest.
INTERROGATORY NO.For either the billing dispute described in your testimony
or any of the other disputes identified in response to Interrogatory No., did you contact the
Public Utilities Commission for assistance or to lodge a complaint? If so, please describe in as
much detail as possible (identifying all relevant facts and documents) the result of such contact
with the Public Utilities Commission.
REQUEST FOR PRODUCTION NO.Produce all documents identified in response
to Interrogatory Nos. 6 and 7.
INTERROGATORY NO.On page 3 of your testimony, you discuss the disparity
between the taxes and fees appearing on your wire line 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.Please explain how you came to be involved in this case.
Include in your description whether you or your 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. 10: Please provide your home address.
REQUEST FOR PRODUCTION NO.To the extent not produced with regard to
Request for Production No., 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 SHARON HERRICK - Page 5
Boise-155194.10029164-00087
Respectfully submitted this ~day of April, 2003.
Qwest Corporation
.Auv~
Mary S. bson
Stoel Rives LLP
Adam L. Sherr
Qwest Corporation
Attorneys for Qwest Corporation
QWEST CORPORATION'S FIRST INTERROGATORIES AND
REQUESTS FOR PRODUCTION OF DOCUMENTS TO SHARON HERRICK - Page 6
Boise-155194.10029164-00087
CERTIFICATE OF SERVICE
I hereby certify that on this !/!:. day of April, 2003, I served the foregoing QWEST
CORPORATION'FIRST INTERROGATORIES AND REQUESTS FOR
PRODUCTION OF DOCUMENTS TO SHARON HERRICK 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: [phone]
Fax: [phone]
i i ewell~puc. state.id.
Weldon Stutzman, Deputy Attorney General
Idaho Public Utilities Commission
472 West Washington Street
O. Box 83720
Boise, ill 83702
Telephone: [phone]
Facsimile: [phone]
W stutzm~puc.state.id.
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: [phone]
Attorney for Meierotto, Padget, Herrick Neal
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Email
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Email
QWEST CORPORATION'S FIRST INTERROGATORIES AND
REQUESTS FOR PRODUCTION OF DOCUMENTS TO SHARON HERRICK - Page 7
Boise-155194.10029164-00087
Dean J. Miller
McDevitt & Miller LLP
420 West Bannock Street
O. Box 2565
Boise, ill 83701
Telephone: [phone]
Facsimile: [phone]
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. com
Executed protective agreement
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Mary Jane Rasher
10005 South Gwendelyn Lane
Highlands Ranch, CO 80129-6217
Telephone: [phone]
mirasher~msn.com
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~ U.Mail
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Adam Sherr
Qwest
1600 7th Avenue - Room 3206
Seattle, W A 98191
Telephone: [phone]
Facsimile: [phone]
asherr~qwest.com
Hand Delivery
U. S. Mail
Overnight Delivery
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Email
Clay R. Sturgis
Moss Adams LLP
601 West Riverside - Suite 1800
Spokane, W A 99201-0663
Hand Delivery
U. S. Mail
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Email
Brian Thomas
TimeWarner Telecom
223 Taylor Avenue North
Seattle, W A 98109
Brian. Thomas~twtelecom.com
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U. S. Mail
Overnight Delivery
Facsimile
Email
QWEST CORPORATION'S FIRST INTERROGATORIES AND
REQUESTS FOR PRODUCTION OF DOCUMENTS TO SHARON HERRICK - Page 8
Boise-155194.10029164-00087
Susan Travis
World Com, Inc.
707 17th Street - Suite 4200
Denver, CO 80202
Telephone: [phone]
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: [phone]
Facsimile: [phone]
cew (if) gi venspursley. com
Attorneys for Idaho Telephone Association
Executed protective agreement
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~tft. 'RrJt~
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 SHARON HERRICK - Page 9
Boise-155194.10029164-00087