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Home My WebLink About200304177th Pro Request of the Commission.pdfWELDON B. STUTZMAN DEPUTY ATTORNEY GENERAL IDAHO PUBLIC UTILITIES COMMISSION PO BOX 83720 BOISE, IDAHO 83720-0074 (208) 334-0318 ISB NO. 3283 Street Address for Express Mail: 472 W. WASHINGTON BOISE, IDAHO 83702-5983 Attorney for the Commission Staff RECEIVED FILED lOa3 APR 17 PH 12: 40 liJ/\hJ PL8UC UTILITIES C0I1MiSSION BEFORE THE IDAHO PUBLIC UTILITIES COMMISSION IN THE MATTER OF THE APPLICATION OF QWEST CORPORATION FdR DEREGULATION OF BASIC LOCAL EXCaANGE RATES IN ITS BOISE, NAMPA, CALDWELL, MERIDIAN, TWIN FALLS, IDAHO FALLS, AND POCATELLO EXCHANGES. CASE NO. QWE-02- SEVENTH INTERROG~ TORIES AND REQUESTS FOR PRODUCTION OF DOCUMENTS OF THE . COMMISSION STAFF TO QWEST CORPORATION The Staff of the Idaho Public Utilities Commission by and through its attorney of record Weldon B. Stutzman, Deputy Attorney General, requests Qwest Corporation (Qwest) provide the following documents and information, pursuant to Commission Rule of Procedure 225, IDAP A J1.01.01.225, on or before Friday, April 25, 2003. This Production Request is to be considered as continuing, and Qwest is requested to provide, by way of supplementary responses, additional documents and information that it or any person acting on its behalf may later obtain that will augment the documents and information produced. For each request, please state the name of the person(s) preparing the answers, along with the job title of such person(s) and the witness who can sponsor the answer at hearing. SEVENTH INTERROGATORY / PRODUCTION REQUEST TO QWEST APRIL 17 2003 responses include workpapers or spreadsheets, please provide the responses on computer media (3.5" diskette or CD) using Lotus 123 (4.0) or Excel language. DEFINITIONS and INSTRUCTIONS The words "the Company" and "Qwest" refer to Qwest Corporation Document" includes any written or recorded or graphic matter, however produced or reproduced, including but not limited to correspondence, telegrams, contracts agreements, notes in any form memoranda, diaries, voice recording tapes, microfilms microfiche, pictures, data processing cards or discs, computer tapes and other computer- generated and stored information or data base, work papers, calendars, minutes of meetings or any other writings or graphic matter, including copies containing marginal notes or variations of any of the foregoing, now or previously in your possession. (1) (2) In the event that any document called for is to be withheld on the basis of a claim of privilege, identify the item being withheld as follows: addressor; addressee; indicated or b1ind\copies; and all persons to whom distributed, shown, or explained. Also identify the nature and legal basis of the privilege asserted. In the event that any document called for by this request has been destroyed or transferred beyond the control of the Company, (a) state the identity of the person by whom it was destroyed and person authorizing destruction and the time, place and method of, and reasons for its destruction, and if destroyed or disposed of by operation of a retention policy, state the retention policy; and, if transferred, the person authorizing transfer and the time, place, and method of, and reason for, its transfer, and (b) identify it as follows: addressor; addressee; indicated or blind copies; dates; subject matter; number of pages, attachments or appendices; and all persons to whom distributed, shown, or explained. Identify, " " Identity," or "Identification " when used in reference to an individual person means to state that person s full name and residence address, including zip code and phone number, if known, and present or last known business position and duties and business address, if known. Identify, " " Identity," or "Identification " when used in reference to a document, means to state the type of document (e., computer-stored information, microfilm, letter memorandum, policy circular, minute book, telegram, chart, etc.), or some other means of identifying it, and its present location and custodian. If any such document was, but is no longer, in your possession or subject to your control, state what disposition was made of it, and if destroyed or disposed of by operation of a retention policy, state the retention policy. SEVENTH INTERROGATORY / PRODUCTION REQUEST TO QWEST APRIL 17 2003 Identify, " " Identity," or "Identification " when us~d in reference to a number or other specific information, means to identify the document containing this information or some other means of identifying it, and to specify the approximate location of the requested information within that document. Identify, ;' " Identity," or "Identification " when used in reference to a business organization, means to state the corporate name or other names under which said organization does business, and location of its principal place ofbusiness. Note: to the extent the specific information requested herein is not available, but analogous or reasonably comparable information is available, please provide that information instead, and explain any differences between what was requested and what has been provided. To the extent the information requested herein is not available in the exact format requested, but the information can be more easily provided in a different format, please provide your response in the more readily available format, but explain any differences in format. Please provide an electronic copy of the requested information in Excel spreadsheet or compatible format. Interrogatory No. 24: The following is a list of all persons who provided written comments in Case No. QWE- T -02-25. From ~he list, please identify each person into the following categories: (1) Qwest employee; (2) Mountain Bell S WEST or Qwest retiree; (3) person who was solicited or encouraged by Qwest to comment, or (4) other or unknown. LAST NAME FIRST NAME Ashbaugh Baxter Bejsovec Boester Boester Burstedt Carr Couch Cox Crum Dailey Davidson Deyton Downey Dutton Edgar Fabbi Fitzryk Fleharty Richard Leonard Joe Robert Nicoline Raymond Marilyn Julia Kenneth Scott Clyde Susie Randy Martin Gail David Bruce Joel SEVENTH INTERROGATORY/ PRODUCTION REQUEST TO QWEST CITY EMPLOYEE RETIREE SOLICITED OTHER Pocatello Boise Boise Boise Boise Pocatello Lava Hot Springs Meridian Soda Springs Boise Meridian Boise Boise Boise Pocatello Boise Boise Boise New Plymouth APRIL 17 2003 Floyd Freudenthal Frost Frost Gerdes Hanson Holland House Jensen Johnson Jones Jones Lynch Martin McAlindin Mendiola I Panton. Quesnell Rinker Ryan Seibert Shinn Sornborger Sornborger Stewart Sullivan Sullivan Thompson Tidd Vannorsdel Vogt Walker Wieczorek Wocicki Barbara Denis Bob Julia John Sharon William Larry S. Dee Rock Kent Norris Daria Jean Dave Joe David Kim Kevin Michael Tom Richard Margaret Truman Michael Mrs. Michael Beverly Homer Nancy Ron William Tony Dale Caldwell Pocatello Pocatello Pocatello Boise Garden City Nampa Hailey Caldwell Ovid Boise Twin Falls Boise Star Twin Falls Boise Pocatello Twin Falls Boise Eagle Pocatello Boise Meridian Meridian Boise Boise Boise Meridian Nampa Boise Jerome New Plymouth Caldwell Meridian DATED at Boise, Idaho, this \.,4L Technical Staff: Joe Cusick Wayne Hart SEVENTH INTERROGATORY / PRODUCTION REQUEST TO QWEST day of April 2003. Weldon B. Stutzman Deputy Attorney General APRIL 17 2003 CERTIFICATE OF SERVICE I HEREBY CERTIFY THAT I HAVE THIS 17TH DAY OF APRIL 2003 SERVED THE FOREGOING SEVENTH INTERROGATORIES AND REQUESTS FOR PRODUCTION OF DOCUMENTS OF THE COMMISSION STAFF TO QWEST CORPORATION IN CASE NO. QWE-02-, BY MAILING A COpy THEREOF, POSTAGE PREPAID, TO THE FOLLOWING: MARY S. HOBSON STOEL RIVES LLP SUITE 1900 101 S CAPITOL BLVD BOISE, ill 83702 ADAM L SHERR QWEST 1600 7TH AVE, ROOM 3206 SEATTLE, WA 98191 CONLEY WARD GIVENS J?URSLEY LLP 277 N 6TH ST, SUITE 200 PO BOX 2720 BOISE, ID 83701-2720 CLAY R STURGIS MOSS ADAMS LLP 601 W RIVERSIDE, SUITE 1800 SPOKANE, WA 99201-0663 DEAN J MILLER McDEVITT & MILLER LLP 420 W BANNOCK ST. PO BOX 2564 (83701) BOISE, ID 83702 BRIAN THOMAS TIME WARNER TELECOM 223 TAYLOR AVE. NORTH SEATTLE, WA 98109 SUSAN TRAVIS WORLDCOM INc. 707 17TH STREET, SUITE 4200 DENVER, CO 80202 MARY JANE RASHER AT&T COMMUNICATIONS OF THE MOUNTAIN STATES INc. 10005 S GWENDELYNLANE HIGHLANDS RANCH, CO 80129-6217 MARLIN D ARD WILLARD,L FORSYTH HERSHNER, HUNTER, ET AL 80 Ell TH AVE, PO BOX 1475 EUGENE, OR 97440-1475 JOHN GANNON ATTORNEY AT LAW 1101 W. RIVER, SUITE 110 BOISE, ID .83702 DEAN RANDALL VERIZON NORTHWEST INC. 17933 NW EVERGREEN PKWY BEAVERTON, OR 97006-7438 BEN JOHNSON BEN JOHNSON ASSOCIATES INC. 2252 KILLEARN CENTER BLVD TALLAHASSEE, FL 32308 ~~ JD SE RET CERTIFICATE OF SERVICE