200304181st Response of Carol Moyers.pdf

JOHN GANNON (ISB #1975)
Attorney at Law
1101 West River, Suite 110
Boise, Idaho 83702
Telephone No.[phone]
Attorney for Intervenors Meierotto et al
RECEIVED IT..!FILED
2003 APR \8 PH ~: II
IUjU-;;; eUGUC
UTILITIES COMMISSION
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-02-
CAROL MOYERS
ANSWERS TO
INTERROGATORIES AND
REQUEST FOR PRODUCTION
COMES NOW CAROL MOYER who answers QWESTS FIRST
INTERROGATORIES AND REQUESTS FOR PRODUCTION as follows:
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.
ANSWER: Carol Moyer has no additional credentials other than those stated in
CAROL MOYER'S ANSWERS TO INTERROGATORIES AND REQUEST TO PRODUCE-
Page 1
her testimony.
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? If yes, please fully explain the results of your inquiry.
ANSWER: No, there is no point in doing so.
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?
ANSWER: I am not certain, but I would estimate 3 months. It seems like I
recharge my card 2 or 3 times a year.
INTERROGATORY NO.Have you ever researched, or inquired of the
wireless carriers serving Boise, about the possibility of replacing your Qwest wireline local
telephone service with wireless service? If yes, please fully explain the results of your
mqUlry.
ANSWER: No.
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.
ANSWER: Your question is incorrect. I don t have a wireless bill. However, I
do think both wireline and wireless should be subject to the same taxes and fees so that my
wireline would cost less.
CAROL MOYER'S ANSWERS TO INTERROGATORIES AND REQUEST TO PRODUCE -
Page 2
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 home phone. Please identify, of those total minutes, how many minutes are
spent connected to the Internet. Please identify any documents which you would
corroborate your time estimates.
ANSWER: I probably spend on average a little more than 1 hour a day, so
around 40 hours a month., at least.I don t have the internet. I don t have any
documents that would verify my usage.
REOUEST FOR PRODUCTION OF DOCUMENTS NO.Produce all
documents identified in response to Interrogatory No.
ANSWER: None
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 be (you) would regularly exceed (wireless plan) minute limitations.
ANSWER: I think that 40 hours a month , or 2400 minutes, exceeds wireless
plans from all the advertisements and conversations I have had with those who use cell
phones.
REOUEST FOR PRODUCTION OF DOCUMENTS NO.Produce all
documents identified in response to Interrogatory No.
ANSWER: None
INTERROGATORY NO.Please explain how you came to be involved in this
CAROL MOYER'S ANSWERS TO INTERROGATORIES AND REQUEST TO PRODUCE -
Page 3
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.
ANSWER: I was at John Gannon s house on Christmas Day and we were
discussing cases he was working on and he mentioned Qwest wanted to be free from
regulation of its local telephone rates. I was interested in the case because I don t want
my rates to go up and I wanted to give my views and be part of the proceeding.
INTERROGATORY NO.Do you receive cable television service at your
home? If so, what cable company provides your service?
ANSWER: Carol Moyer objects to this interrogatory because it deals with issues
outside the scope of this proceeding. Without waiving this objection, Carol Moyer
answers: No.
INTERROGA TORY NO. 10:Please provide your home address
ANSWER: 2944 S Garden Boise, Idaho 83705
REOUEST 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 in Interrogatory Nos. 1-10.
Carol Moyer
ANSWER: None
CAROL MOYER'S ANSWERS TO INTERROGAT
Page 4
CERTIFICA TE OF SERVICE
I HEREBY CERTIFY THAT ON THE 18th DAY OF APRIL, 2003 , I
SERVED THE FOREGOING PLEADING IN CASE NO QWE-02-25. BY MAILING
A COpy THEREOF, POSTAGE PREP AID, (UNLESS OTHERWISE INDICATED) TO
THE FOLLOWING:
(HAND DELIVERED)
MARY S HOBSON
STOEL RIVES LLP
SUITE 1900
101 S CAPI8TOL BLVD
BOISE, ID 83702
CONLEY WARD
GIVENS PURSLEY LLP
277 N 6th ST, SUITE 200
PO BOX 2720
BOISE, ID 83702-2720
DEAN J MILLER
McDEVITT & MILLER LLP
PO BOX 2564
BOISE, ID 83701
(PERSONAL SERVICE)
WELDON STUTZMAN
DEPUTY ATTORNEY GENERAL
IPUC
PO BOX 83720
BOISE, ID 83720-0074
MARLIN D ARD
WILLARD L FORSYTH
HERSHNER, HUNTER, ET AL
180 E 11th AVE PO BOX 1475
EUGENE, OR 97440-1475
CERTIFICATE OF SERVICE
ADAM L SHERR
QWEST
1600 7th AVE, ROOM 3206
SEATTLE, WA 98191
CLAY R STURGIS
MOSS ADAMS LLP
601 W RIVERSIDE, SUITE 1800
SPOKANE, W A 99201-0663
BRIAN THOMAS
TIME WARNER TELECOM
223 TALOR AVE NORTH
SEATTLE, WA981O9
DEAN RANDALL
VERIZON NORTHWEST INc.
17933 NW EVERGREEN PKWY
BEAVERTON, OR 97006-7438