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Home My WebLink About200304181st Response of Carolyn Boyce.pdfJOHN GANNON (ISB #1975) Attorney at Law 1101 West River, Suite 110 Boise, Idaho 83702 Telephone No.(208) 433-0629 Attorney for Intervenors Meierotto et al RECEIVED illFiLED ZO03 APR 16 PM~:' IU.\LG FUbUC UTILITIES COt1HISSION 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- CAROLYN BOYCES ANSWERS TO INTERROGATORIES AND REQUEST FOR PRODUCTION COMES NOW CAROLYN BOYCE who answers QWESTS FIRST INTERROGATORIES AND REQUESTS FOR PRODUCTION as follows: INTERROGATORY NO.Please identify all of Ms. Boyce s credentials to offer opinion testimony on the wireless industry and on wireless technology. For purposes ofthis 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. Boyce) 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. Boyce. ANSWER: My creditionals to testify regarding the telecommunications requirements for a CPA or small business office and for CPA's in general are stated in my testimony. CAROLYN BOYCE'S ANSWERS TO INTERROGATORIES AND REQUEST TO PRODUCE - Page INTERROGA TORY NO.Your direct testimony if offered" on behalf of Intervenors Meierotto, et al". Please explain your relationship with the Intervenors and describe the whether you are testifying, "on behalf' of said individuals as an expert or in some other capacity. ANSWER: I am testifying as a person who has knowledge of the telecommunications requirements for my kind of business and in that capacity I am an expert. INTERROGA TORY 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 the third party. ANSWER: Mr. Gannon contacted me as a CPA and asked me questions about my telephone system and cell phone needs and then asked me to be a witness. Mr. Gannon briefly told me that Qwest wanted to deregulate local service rates because people can use cell phones and there is therefore competition. . He faxed me a copy of an Idaho Statesman article which I read. My initial response was that cell phones can t replace land lines. They are not interchangeable. INTERROGATORY NO.Are you aware that there are multiple competing telephone companies (known as competitive local exchange carriers or "CLECs CAROLYN BOYCE'S ANSWERS TO INTERROGATORIES AND REQUEST TO PRODUCE - Page 2 registered in Idaho that can provide residential and small business telephone service from a CLEC? If yes, please fully describe all such contacts and why your firm opted to obtain service from or remain with Qwest. If no, please fully explain why it did not. ANSWER: Carolyn Boyce objects to this interrogatory for the reason that it deals with issues outside the scope of this hearing. Without waiving this objection Carolyn Boyce states: No. INTERROGA TORY NO.Has your accounting firm researched or contacted any CLECs to determine if the firm could obtain its telephone service from a CLEC? If yes, please fully describe all such contacts and why your firm opted to obtain service from or remain with Qwest. If no, please fully explain why it did not. ANSWER: Carolyn Boyce objects to this interrogatory for the reason that it deals with issues outside the scope of this hearing. Without waiving this objection Carolyn Boyce states: No. INTERROGATORY NO.Has your accounting firm researched or contacted any wireless providers to determine if the firm could obtain all its telephone service from a wireless provider? If yes, please fully describe all such contacts and why your firm opted to obtain or continue obtaining wireline service from Qwest. If no, please fully explain why it did not. ANSWER: No, because we need land lines and I am not aware of anyone other than Qwest that provides them. CAROLYN BOYCE'S ANSWERS TO INTERROGATORIES AND REQUEST TO PRODUCE - Page 3 INTERROGATORY NO.What wireless company does your accounting firm use for the cell phones identified on page 1 of your testimony? Identify and describe the wireless plan your firm uses. ANSWER: We have AT&T and I can use it for a certain amount of minutes, I think 1000, at a flat rate and thereafter there is a minute charge. I pay $39.99 a month. INTERROGATORY NO.Do you use your cell phone to make long-distance calls rather than using your Qwest business phones? Please fully explain why or why not. ANSWER: No, because 75% oflong distance phone calls are made by my employes. I have only one cell phone and it usually sits in the car. I don t think it is practical to pass around a cell phone in an office for the employes to make long distance calls. I have made some long distance calls when I am away from the office. INTERROGA TORY NO.Do you receive cable television service at your home? If so, what cable company provides you service? ANSWER: Carolyn Boyce objects to this interrogatory because it deals with issues outside the scope of this hearing. Without waiving this objection Carolyn Boyce states: No INTERROGATORY NO. 10:Provide your home address. ANSWER: 982 E Riverpark Lane, Boise, Idaho 83706 REOUEST FOR PRODUCTION NO.Please produce all documents in your possession relevant to your responses to Interrogatory Nos. 1-10. RESPONSE: The Statesman article has been produced by Sharon Herrick. Carolyn Boyce CAROLYN BOYCE'S ANSWERS TO INTERR PRODUCE - Page 4 CERTIFICATE 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, POST AGE 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, lillNTER, ET AL 180E 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 T ALOR AVE NORTH SEATTLE, WA 98109 DEAN RANDALL VERIZON NORTHWEST INc. 17933 NW EVERGREEN PKWY BEAVER TON, OR 97006-7438