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Home My WebLink About200304181st Response of Dennis McManamons.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 HECEIYED fiLED 2003 APR I 8 PH ~: , I T' ' " """ . "~:'-"V j'UbLlL U f/L/1 lES 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- DENNIS MCMANAMONS ANSWERS TO INTERROGATORIES AND RESPONSE TO REQUEST FOR PRODUCTION COMES NOW DENNIS MCMANAMON who answers QWESTS FIRST INTERROGATORIES AND REQUESTS FOR PRODUCTION as follows: INTERROGATORY NO.1: To the extent not already provided in his testimony, please identify all of Mr. Me Mana mons credentials to offer 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.e. not one produced by or on behalf of Mr. McManamon) identified and produced in this case. 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 McManamon. ANSWER: I have no further credentials to add to my testimony. INTERROGATORY NO.2: Your direct testimony is offered "on behalf ofIntervenors Meierotto, et al". Please explain your relationship with the Intervenors and describe whether you DENNIS MCMANAMONS ANSWERS TO INTERROGATORIES AND REQUEST TO PRODUCE - Page are testifying "on behalf' of said individuals as an expert or in some other capacity. ANSWER: I am testifying as a person with background in the wireline telephone system and wireless industry who is knowledgeable regarding the needs of small business telecommunications. INTERROGATORY NO.3: Please explain how you came to be involved in this case on behalf ofIntervenors 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. ANSWER: I was called by Mr.Gannon who asked questions regarding various aspects of communications devices and who asked me to be a witness. He did not state much regarding the case, just generally that Qwest maintains it should be allowed to deregulate local phone rates because cell phones offer similar features and competition. He did furnish me with a Statesman newspaper article which discussed the case. INTERROGATORY NO.4: Are you aware that there are multiple competing telephone companies (known as competitive local exchange carriers or "CLECS") registered in Idaho that can provide residential and small business telephone service to Awnings Unlimited? ANSWER: Dennis McManamon objects to this question on the basis that it deals with an issue that is not before the Commission. Without waiving this objection Dennis McManamon states: Yes there are competitors to Qwest for phone service, but they are not wireless DENNIS MCMANAMONS ANSWERS TO INTERROGATORIES AND REQUEST TO PRODUCE - Page 2 providers. Electric Lightwave is such a business. I don t think they offer residential service to small business. INTERROGATORY NO.5: Has Awnings Unlimited researched or contacted CLECs to determine ifthe firm could obtain its telephone service from a CLEC? If yes, please fully describe all such contacts and why Awnings Unlimited opted to obtain service from or remain with Qwest. If no, please fully explain why it did not. ANSWER: Dennis McManamon objects to this question on the basis that it deals with an issue that is not before the Commission. Without waiving this objection Dennis McManamon states: I have talked with Electric Lightwave from time to time because I know one of their sales representatives, John Fishback, but they are more interested in multiple line service. He isn really interested in our account because we only have three lines. Electric Lightwave use is too complicated and expensive for a small system. INTERROGATORY NO.6: Has Awnings Unlimited researched or contacted 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. If no, please fully explain why it did not. ANSWER: Yes and we can t use them because they don t offer 56K at a reasonable price and we can t have the features described in my testimony. INTERROGATORY NO.7: Identify and describe the Nextel wireless plan your company uses. ANSWER: There is only one Nextel system in the valley. It consists of cell phone service DENNIS MCMANAMONS ANSWERS TO INTERROGATORIES AND REQUEST TO PRODUCE - Page 3 and two way radio direct connect on the phone for use in the field. It is $49 a month for each unit with 300 minutes of cell phone service and unlimited radio. INTERROGATORY NO.8: Do employes of Awnings Unlimited use the cell phones provided by the company to make long distance calls rather than using your Qwest business phones? Please explain why or why not. ANSWER: No, because it is too expensive. INTERROGATORY NO.9: Do you receive cable television service at your home? If so what cable company provides you service? ANSWER: Dennis McManamon objects to this question on the basis that it deals with an issue that is not before the Commission. Without waiving this objection Dennis McManamon states: No INTERROGATORY NO. 10. Please provide your home address. ANSWER: 3741 Cayuga Place, Boise, 83709 REQUEST FOR PRODUCTION NO.1: 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. Dennis McManamon DENNIS MCMANAMONS ANSWERS TO INTERROGATORIES AND REQUEST TO PRODUCE - 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- T -02-25. BY MAILING A COpy THEREOF, POSTAGE PREPAID, (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 TALORAVENORTH SEATTLE, WA 98109 DEAN RANDALL VERIZON NORTHWEST INC. 17933 NW EVERGREEN PKWY BEAVERTON, OR 97006-7438