200304181st Response of Sharon Herrick.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
nECEIVED IT)FILED
2003 APR 18 PH 4= 12
IL))~;-:J PUi~lIC
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-
SHARON HERRICKS ANSWERS TO
INTERROGATORIES AND RESPONSE
TO REQUEST FOR PRODUCTION
COMES NOW SHARON HERRICK who answers QWESTS FIRST INTERROGATORIES
AND REQUESTS FOR PRODUCTION as follows:
INTERROGATORY NO.1: Please identify all ofMs Herricks 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.e. not one produced by or on behalf ofMs Herrick) 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
Herrick.
ANSWER: I have have been a wireless cell phone user since 1997 and a land line user for
many years so I know the differences between the products and how they can serve a large family
SHARON HERRICK ANSWERS TO INTERROGATORIES AND REQUEST TO PRODUCE
- Page 1
or household.
INTERROGATORY NO.2: Have you ever researched or inquired with any of the
wireless carriers serving Boise whether such carriers offer extension phones or an equivalent?
yes, please fully explain the results of your inquiry.
ANSWER:: Yes I have inquired with several of the wireless carriers regarding extension
phones. I found no wireless carriers that provide extensions in this area.
INTERROGATORY NO.3: Please explain what you mean by "the internet is operated
by Cable One." Do you receive cable based Internet service? Have you inquired whether Cable
One would be willing to provide you local telephone service? If yes, please fully explain the
results of your inquiry.
ANSWER: Ms Herrick objects to this question as these questions address issues outside
the scope of this hearing. Without waiving this objection, I state that I currently have internet
service from Cable One in my residence. I have not inquired into local telephone service from
them.
INTERROGATORY NO.4: Have you ever researched or inquired with any of the
wireless carriers serving Boise about the possibility of replacing your Qwest local telephone
service with wireless. If yes, please fully explain the results of your inquiry.
ANSWER: I have contacted Sprint and talked to a representative. They said I would need
two phones to replace the current land line with extension. It would cost around $80.
INTERROGATORY NO.5: Please identify all time periods you have been a Mountain
Bell, US WEST or Qwest customer for local telephone service..
SHARON HERRICK ANSWERS TO INTERROGATORIES AND REQUEST TO PRODUCE
- Page 2
ANSWER:: I have been a customer of Mountain Bell, US. West or Quest since 1967 or
1968 when I established my own residence.
INTERROGATORY NO.6: Aside from the billing dispute described on page 2 of your
testimony, please describe in as much detail as possible (identifying all relevant facts and
documents) any other billing disputes you have had with Mountain Bell, US WEST, or Qwest.
ANSWER: I have had service so long I cannot remember if! have ever had any other
billing dispute with any of the above mentioned companies.
INTERROGATORY NO.7: For either the billing dispute described in your testimony or
any of the other disputes identified in response to Interrogatory No., did you contact the Idaho
Public Utilities Commission for assistance or to lodge a complaint? If so, please describe in as
much detail as possible (identifying all relevant facts and documents) the result of such contact
with the Idaho Public Utilities Commission.
ANSWER: I contacted the Public Utilities Commission in regard to the fact that in August
or September, 2001 , our phone was disconnected. I had contacted Qwest and they said they did
not know why it was disconnected and it must have been an error. They said there would be no
charges for this inconvenience. On the next bill we were charged twice for that month. Both bills
were around $60. I contacted Qwest and they said I had to pay the bill or they would disconnect
our service. I contacted the Public Utilities Commission and they said they would check into it.
They contacted me and said that Qwest said that a Mr. someone had called and told them to cancel
the phone and I was 10 days behind paying my bills and so that is why I had two charges for the
same month. The Public Utilities Commission said that it probably was just an error that my
SHARON HERRICK ANSWERS TO INTERROGATORIES AND REQUEST TO PRODUCE
- Page 3
phone was disconnected. Someone just entered the wrong number. Also, my long distance
service with AT&T was discontinued and they charged me a rate of 3 5 cents a minute for my long
distance calls. AT&T did go back and credit my account for part of the charges. But I had to get
a new plan with a higher rate than I had because the earlier rate was no longer offered.
INTERROGATORY NO.8: On page 3 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: I believe the lower tax on my cell phone allows the wireless company to
provide a cheaper service. I feel they should have to charge the same taxes for wirelines so that
the field is level, and wireline taxes could be reduced.
INTERROGATORY NO.9: Please explain how you came to be involved in this 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 saw the article in the newspaper on December 19, 2002. Some of the
employees at Neal and Uhl, where I work, were discussing the situation. I think Gary talked
about the case he was going to be involved regarding deregulation of Qwest. He told me to
discuss it with John Gannon and I discussed participating with him.
INTERROGATORY NO 10: Please provide your home address.
SHARON HERRICK ANSWERS TO INTERROGATORIES AND REQUEST TO PRODUCE
- Page 4
ANSWER: My home address is 11330 Hanks Street Boise, Idaho 83709
REQUEST FOR PRODUCTION NO.1: Produce all documents identified in response to
Interrogatory No.6 and 7.
RESPONSE: I no longer have them.
REQUEST FOR PRODUCTION NO.2: To the extent not produced with regard to
Request for Production No., please produce all documents in your possession relevant to
Interrogatories No.10:
RESPONSE: The Idaho Statesman article is produced.
SHARON HERRICK ANSWERS TO INTERROGATORIES AND REQUEST TO PRODUCE
- Page 5
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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 TALORAVENORTH
SEATTLE, W A 98109
DEAN RANDALL
VERIZON NORTHWEST INc.
17933 NW EVERGREEN PKWY
BEAVERTON, OR 97006-7438