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Home My WebLink About200304181st Response of Joel Sales.pdfRECEIVED FILED JOHN 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 2003APRI8 PM~:fZ U:JJ,,;J0 UGLlG UTILITIES CO~1HISSION 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- JOEL SALES ANSWERS TO INTERROGATORIES AND REQUEST FOR PRODUCTION COMES NOW JOEL SALES who answers QWESTS FIRST INTERROGATORIES AND REQUESTS FOR PRODUCTION as follows: INTERROGATORY NO.1: Please identify all of Mr. Sales' credentials to offer expert 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., not one produced by or on behalf Mr. Sales) identified and produced in this case. By "credentials " Qwest seeks an identification of specific education, vocational and first hand research experiences, as well as any studies reports or publications authored by Mr. Sales. ANSWER: I have worked in the construction industry since 1978 and this extensive experience is the basis for my testimony as to the uses of cell phones and land line phones in the industry. I have described my experience in my testimony and I feel I have better JOEL SALES ANSWERS TO INTERROGATORIES AND REQUEST FOR PRODUCTION Page - knowledge of the day to day needs and uses of communications equipment than persons not part of my industry. INTERROGATORY NO.2: Your direct testimony is offered" on behalf of Intervenors Meierotto, et al". Please explain your relationship with the Intervenors and describe whether you are testifying, "on behalf' of said individuals as an expert or in some other capacity. ANSWER: I was asked by counsel for the intervenors to offer testimony in this case and I am testifying as stated in response to Interrogatory No. I. INTERROGA TORY NO.3: 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 that third party. ANSWER: No.3: I think I was told by counsel for intervenors that Qwest wanted to deregulate phone line charges for small business and residential and Mr. Gannon gave me a copy of the newspaper article and asked if I would like to testify regarding the uses of cell phones and land line phones in my industry. I read the newspaper article on a fishing trip and said I would like to testify. Mr.Gannon didn t tell me anything else, and actually he just asked me a lot of questions and my information on the case came ITom the newspaper article. JOEL SALES ANSWERS TO INTERROGATORIES AND REQUEST FOR PRODUCTION Page - 2 INTERROGATORY NO.4: Did Idaho Windows research or contact any competitive local exchange carriers ("CLECS") to determine ifthe company could obtain its telephone service ITom a CLEC? If yes, please fully describe all such contacts and why it opted to obtain service ITom or remain with Qwest. If no, please fully explain why it did not. ANSWER: Joel Sales objects to this interrogatory as it addresses issues outside the scope of this proceeding. Without waiving said objection Joel Sales states: No. I don t know that any CLEC would provide such service. I also don t know what a CLEC is. INTERROGATORY NO.5: Did Idaho Windows research or contact any wireless providers to determine if the company could obtain all its telephone service ITom a wireless provider? If yes, please fully describe all such contacts and why your company opted to obtain or continue obtaining wireline service ITom Qwest. If no, please fully explain why it did not. ANSWER: I am not aware of any wireless provider offering a land line for my fax line or computer modem. I have talked in the past with AT&T, Verizon and Nextel and no one had a cell phone that could fulfill all of my needs. INTERROGATORY NO.6: Identify the wireless carrier and describe all wireless plans you use for your personal cell phone. ANSWER: AT&T is my wireless carrier and I use an unlimited air time, voice mail and call forwarding package. INTERROGATORY NO.7: Do you use your home cell phone to make long- distance calls rather than using your Qwest residential phone? Please fully explain why or why not. JOEL SALES ANSWERS TO INTERROGATORIES AND REQUEST FOR PRODUCTION Page - 3 ANSWER: We use both, but when I can I use the cell phone because they offer tree long distance. The cell phone long distance is less expensive. INTERROGATORY NO.8: Have you ever researched or inquired with any of the wireless carriers serving Boise whether such carriers offer extension phone or an equivalent? If yes, please fully explain the results of your inquiry. ANSWER: I am not sure what you mean. My Nextel service has a cell phone and a radio phone and the radio phone is kind of an extension phone. I have never seen an extension cell phone such as a land line would have. INTERROGATORY NO.9: Have you ever researched or inquired with any 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 inquiry. ANSWER: No because of the reasons stated in my testimony. INTERROGATORY NO. 10: Do you receive cable television service at your home? If so, what cable company provides you service? ANSWER: Joel Sales objects to this interrogatory as it addresses issues outside the scope of this proceeding. Without waiving this objection, Joel Sales states: We use Cable One. INTERROGATORY NO. 11: Please provide your home address ANSWER: 4154 Ticonderoga Boise, Idaho 83704 REQUEST FOR PRODUCTION NO.1: Produce all documents in your possession relevant to your responses to Interrogatory Nos. 1-11. RESPONSE: See Idaho Statesman article produced by Sharo Joel Sales JOEL SALES ANSWERS TO INTERROGA PRODUCTION 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 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 180E Ilth AVE PO BOX 1475 EUGENE, OR 97440-1475 CERTIFICATE OF SERVICE ADAM L SHERR QWEST 1600 7th AVE, ROOM 3206 SEATTLE, WA98191 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, WA 98109 DEAN RANDALL VERIZON NORTHWEST INC. 17933 NW EVERGREEN PKWY BEAVERTON, OR 97006-7438