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Home My WebLink About200304181st Response of Steve Chattin.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 FilED ZO03 APR 18 PH ~: 12 iLJf\Hd PUBLIC 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- STEVE CHATTINS ANSWERS TO INTERROGATORIES AND REQUEST fOR PRODUCTION COMES NOW STEVE CHATTIN who answers QWESTS FIRST INTERROGATORIES AND REQUESTS FOR PRODUCTION as follows: INTERROGATORY NO.To the extent not already provided in his testimony, please identify all of Mr. Chattin 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 Mr. Chattin) identified and produced in this case. By "credentials " Qwest seeks an identification of specific educational, vocational and first hand research experiences. ANSWER: I don t have anything to add to my testimony. STEVE CHATTINS ANSWERS TO INTERROGATORIES AND REQUEST FOR PRODUCTION Page - INTERROGATORY NO.Your direct testimony is offered" on behalf of Intervenors Meierotto, et al". Please explain your relationship with the Intervenors and describe the capacity in which you are testifying, "on behalf' of said individuals. ANSWER: I was asked to testify regarding uses of cell phones and land lines in business. . INTERROGATORY 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 that third party. ANSWER: Mr. Gannon called me and asked me questions regarding cell phone and land line usages by realtors. He sent me a Statesman article which I read and he asked me if! was willing to share my knowledge and testify. I said yes. I don t recall any statements made by Mr. Gannon. INTERROGATORY NO.Are you aware that there are multiple competing telephone companies (known as competitive local exchange carries or "CLECs registered in Idaho that can provide residential and small business telephone service to Vantage Real Estate. STEVE CHATTINS ANSWERS TO INTERROGATORIES AND REQUEST FOR PRODUCTION Page - 2 ANSWER:: Steve Chattin objects to this Interrogatory on the basis that it is outside the scope of the issues in this proceeding. Without waiving this objection Steve Chattin answers: No. INTERROGATORY NO.Has Vantage Real Estate researched or contacted any CLECs to determine if the firm could obtain its telephone service from CLEC? If yes please fully describe all such contacts and why Vantage Real Estate opted to obtain service from or remain with Qwest. If no, please fully explain why it did not. ANSWER: Steve Chattin objects to this Interrogatory on the basis that it is outside the scope of the issues in this proceeding. Without waiving this objection Steve Chattin answers: No, I don t know they are even available. INTERROGATORY NO.Has Vantage Real Estate researched or contacted any wireless providers to determine ifthe 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: No. I have talked to wireless providers from time to time and I am not aware they provide landline service. INTERROGATORY NO.Identify and describe the wireless plan your company uses. STEVE CHATTINS ANSWERS TO INTERROGATORIES AND REQUEST FOR PRODUCTION Page - 3 ANSWER: I use the AT&T wireless shared plan. There are two phones, one for me and one for my wife. They have different phone numbers. They cost $60 a month and there is a minute limitation. INTERROGA TORY NO.Do you use the cell phones to make long-distance calls rather than using your Qwest business phone? Please fully explain why or why not. ANSWER: No, because of the cost, unless I am away from the premises and need to make the call. I make a couple on the cell phone each month. INTERROGATORY NO.Do you receive cable television service at your home? If so, what cable company provides your service? ANSWER: Steve Chattin objects to this Interrogatory on the basis that it is outside the scope of the issues in this proceeding. Without waiving this objection Steve Chattin answers: I use Cable One. INTERROGATORY NO. 10:Please provide your home address. ANSWER: 2711 Teton Boise, Idaho 83705 REOUEST FOR PRODUCTION NO.Please produce all documents in your possession relevant to your responses to Interrogatory Nos. 1-10. RESPONSE: The Statesman article - See Herrick Answers. Steve Chattin 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, 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 BEA VERT ON, OR 97006-7438