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Home My WebLink About200304183rd Request of Qwest to Staff.pdf7?iJ ATTORNEYS AT lAW nECEIVED FILED :~~~ APR 18 AM II : iU.;\r;0 i UL,LiG UTILITIES COMMISSION 101 S. Capitol Boulevard. Suite i900 Boise. Idaho 83702 main 208.389.9000 STGEL ~~, fax 208.389.9040 www.stoel.com April 18, 2003 MARY S. HOBSON Direct (208) 387-4277 mshobson(iYstoel.com VIA HAND DELIVERY Jean D. Jewell, Secretary Idaho Public Utilities Commission 472 West Washington Boise, ID 83702-5983 RE:Docket No. QWE-O2- Dear Ms. Jewell: Enclosed for filing with this Commission is an original and three (3) copies of QWEST CORPORATION'S THIRD INTERROGATORIES AND REQUESTS FOR PRODUCTION OF DOCUMENTS TO STAFF. If you have any questions, please contact me. Thank you for your cooperation in this matter. Very truly yours ~ ~7lofs :blg Enclosurescc: Service List Oregon Washington California Boise-155816.10029164-00087 Utah Idaho Mary S. Hobson (ISB #2142) Stoel Rives LLP 101 South Capitol Boulevard - Suite 1900 Boise, ill 83702 Telephone: (208) 389-9000 Facsimile: (208) 389-9040 mshobson~stoel.com HECEIVED 111FILED ~~~~ APR I 8 AM II: IfJ!j i:D ?UbUC UTILITiES CO~it1ISSI0H Adam L. Sherr (WSBA #25291) Qwest 1600 7th Avenue - Room 3206 Seattle, WA 98191 Telephone: (206) 398-2507 Facsimile: (206) 343-4040 asherr~qwest.com Attorneys for Qwest Corporation BEFORE THE IDAHO PUBLIC UTILITIES COMMISSION IN THE MATTER OF THE APPLICATION OF QWEST CORPORATION FOR PRICE DEREGULATION OF BASIC LOCAL EXC Case. No. QWE- T -02- QWEST CORPORATION'S TIDRD PRODUCTION OF DOCUMENTS TO STAFF Qwest Corporation ("Qwest") pursuant to Rule 225 of the Rules of Procedure of the Idaho Public Utilities Commission and Idaho Rules of Civil Procedure 33 and 34 hereby submits the following Interrogatories and Requests for Production of Documents to the Staff of the Idaho Public Utilities Commission ("Staff'). Staff is requested to answer the following Interrogatories and Requests in writing and under oath by April 25, 2003. These Interrogatories and Requests shall be deemed continuing, and if Staff, its consultants or its attorneys discover additional information and facts related to the matters inquired of between the time answers are made and the time of the hearing in this matter QWEST CORPORATION'S THIRD INTERROGATORIES AND REQUESTS FOR PRODUCTION OF DOCUMENTS TO STAFF - Page Boise-155814.10029164-00087 supplemental answers shall be made informing Qwest and Qwest's attorneys as to said newly discovered information as far in advance of the hearing as possible. DEFINITIONS The term "Staff' , " you" or "your" refers to the Staff of the Idaho Public Utilities Commission, and its agents, consultants and representatives including its attorneys or any employee, agent, investigator or representative of its attorneys. The term "Qwest" refers to and shall mean Qwest Corporation. The terms "relating , " related", or "which relates to" means constitutes, refers to contains, embodies, evidences, reflects, contradicts, refutes, identifies, states, deals with, bears upon, or is in any way logically or factually connected with any matter described. The word "person" means any individual, corporation, joint venture, limited partnership, association, group or entity of any kind. The terms "document" or "statement" refer to and shall mean and include any written, typed, printed, recorded or computer-produced or graphic matter of every type and description, however and by whomever prepared, produced, reproduced, disseminated or made including, but not limited to, reports, letters, correspondence, memoranda, Tecords, summaries analyses, results or reports of investigations, recommendations, diaries, books, messages electronic mail (whether in hard copy form or as stored on disc or computer hard drive), notes tapes, drawings, graphs, photographs, microfilms, telegrams, periodical articles, computer printouts and any other writing, drawing, or records. Terms in the plural include the singular, and terms in the singular include the plural. QWEST CORPORATION'S THIRD INTERROGATORIES AND REQUESTS FOR PRODUCTION OF DOCUMENTS TO STAFF - Page 2 Boise-155814.10029164-00087 INSTRUCTIONS Whenever you are requested to identify or describe a document or statement, state with respect to such document or statement the following: The nature, date and substance of the document or statement with sufficient particularity to enable it to be identified, including its title, if any; The name, business affiliation and address of each person or persons who drafted, caused to be drafted and/or revised such document or statement; and The name, business affiliation and address of each person who presently has custody of the document or any copy of it and any other description necessary to enable its custodian to locate the document or stateIl).ent. Whenever you are requested to identify or describe a person, state with respect to each such person the following: his, her or its full name; his, her or its present or last known address; his, her or its present or last known telephone number; and his, her or its position, title and business affiliation. If you object to any Interrogatory or Request for Production, set forth all reasons for the objection. If you claim privilege as a basis for not complying with any Interrogatory or Request for Production, in full or in part, describe the factual basis for the claim of privilege in detail sufficient to permit the Commission to rule upon the validity of the claim. If you obj ect to any part of any Interrogatory or Request for Production, answer the remaining partes) completely. QWEST CORPORATION'S THIRD INTERROGATORIES AND REQUESTS FOR PRODUCTION OF DOCUMENTS TO STAFF - Page 3 Boise-155814.10029164-00087 If any information called for by an Interrogatory or Request for Production is unknown to you, so state and then state all remaining information that is known to you. INTERROGATORY NO.Following up on Staffs response to Qwest's Interrogatory 2-, does Dr. Johnson contend that Dr. Lincoln s value proposition theory - as defined in Dr. Lincoln s testimony starting at page 7, line 1 is incorrect? Please fully explain your answer and identify all facts and documents upon which you rely in formulating your answer. REQUEST FOR PRODUCTION NO.Please produce all documents identified in response to Interrogatory No. INTERROGATORY NO. 3-Following up on Staffs response to Qwest Interrogatory 2-, does Staff contend that a wireless customer subscribing to an unlimited usage plan will, or is more likely to, experience poorer service quality than a wireless customer of the same carrier who subscribes to a limited usage plan? INTERROGATORY NO. 3-In response to Qwest Interrogatory 2-, Staff states (b Jased upon Staff s understanding of the propogation of wireless signals, the basic theory of the design of cell systems and the locating of towers, as well as reports from other states of pockets within residential neighborhoods, where signals are not available, Staff has reason to believe additional such locations exist in these seven exchanges.Specifically identify each location in the seven exchanges Staff has reason to believe is a pocket wherein wireless service is not available. REQUEST FOR PRODUCTION NO. 3-Produce all studies, surveys, data, maps facts or documents supporting Staff s opinion that wireless service is not available in the pockets identified in Interrogatory No. 3- QWEST CORPORATION'S THIRD INTERROGATORIES AND REQUESTS FOR PRODUCTION OF DOCUMENTS TO STAFF - Page 4 Boise-155814.10029164-00087 INTERROGATORY NO. 3-As a matter of public policy, identify all reasons, aside from the possibility/likelihood that Qwest will increase basic local exchange service rates support Staffs position that approving Qwest's application in this case is not in the public interest. To be clear, Qwest is not asking for Staff to recite the reasons why Qwest does not satisfy the requirements of Section 62-622(3)(b) that functionally equivalent, competitively priced alternatives be reasonably available nor is Qwest seeking legal analysis.Qwest is focusing in this request solely on the public interest analysis. Respectfully submitted this 18th day of April, 2003. Qwest Corporation Mary S. son Stoel Rives LLP Adam L. Sherr Qwest Corporation Attorneys for Qwest Corporation QWEST CORPORATION'S THIRD INTERROGATORIES AND REQUESTS FOR PRODUCTION OF DOCUMENTS TO STAFF - Page 5 Boise-155814.1 0029164-00087 CERTIFICATE OF SERVICE I hereby certify that on this 18th day of April, 2003, I served the foregoing QWEST CORPORATION'THIRD INTERROGATORIES AND REQUEST FOR PRODUCTION OF DOCUMENTS TO STAFF upon all parties of record in this matter as follows: Jean Jewell, Secretary Idaho Public Utilities Commission 472 West Washington Street Boise, ID 83720-0074 Phone: (208) 334-0300 Fax: (208) 334-3762 ii ewell~puc.state.id. us Weldon Stutzman, Deputy Attorney General Idaho Public Utilities Commission 472 West Washington Street O. Box 83720 Boise, ill 83702 Telephone: (208) 334-0300 Facsimile: (208) 334-3762 W stutzm~puc.state.id. us Marlin D. Ard Willard L. Forsyth Hershner, Hunter, Andrews, Neill & Smith LLP 180 East 11 th Avenue O. Box 1475 Eugene, OR 97440-1475 Attorneys for Verizon Executed protective agreement John Gannon, Esq. 1101 West River - Suite 110 Boise, ill 83702 Telephone: (208) 433-0629 Attorney for Meierotto, Padget, Herrick Neal Hand Delivery U. S. Mail Overnight Delivery Facsimile Email Hand Delivery U. S. Mail Overnight Delivery Facsimile Email Hand Delivery U. S. Mail Overnight Delivery Facsimile Email Hand Delivery U. S. Mail Overnight Delivery Facsimile Email QWEST CORPORATION'S THIRD INTERROGATORIES AND REQUESTS FOR PRODUCTION OF DOCUMENTS TO STAFF - Page 6 Boise-155814.10029164-00087 Dean J. Miller McDevitt & Miller LLP 420 West Bannock Street O. Box 2565 Boise, ill 83701 Telephone: (208) 343-7500 Facsimile: (208) 336-6912 i oe~mcdevitt -miller .com Attorneys for Time Warner Telecom Executed protective agreement Hand Delivery-1L U. S. Mail Overnight Delivery Facsimile Email Dean Randall Verizon Northwest Inc. 17933 NW Evergreen Parkway Beaverton, OR 97006-7438 dean.randall ~verizon. co Executed protective agreement Hand Delivery U. S. Mail Overnight Delivery Facsimile Emai1 Mary Jane Rasher 10005 South Gwendelyn Lane Highlands Ranch, CO 80129-6217 Telephone: (303) 470-3412 mirasher~msn.com Hand Delivery U. S. Mail Overnight Delivery Facsimile Email Adam Sherr Qwest 1600 ih Avenue - Room 3206 Seattle, W A 98191 Telephone: (206) 398-2507 Facsimile: (206) 343-4040 asherr~qwest.com Hand Delivery-1L U. S. Mail Overnight Delivery Facsimile Email Clay R. Sturgis Moss Adams LLP 601 West Riverside - Suite 1800 Spokane, W A 99201-0663 Hand Delivery-1L U. S. Mail Overnight Delivery Facsimile Email Brian Thomas Time W aIDer Telecom 223 Taylor Avenue North Seattle, W A 98109 Brian. Thomas~twtelecom.com Hand Delivery U. S. Mail Overnight Delivery Facsimile Email QWEST CORPORATION'S THIRD INTERROGATORIES AND REQUESTS FOR PRODUCTION OF DOCUMENTS TO STAFF - Page 7 Boise-155814.10029164-00087 Susan Travis World Com, Inc. 707 1 ih Street - Suite 4200 Denver, CO 80202 Telephone: (303) 390-6333 Susan.a. Travis~worldcom.com Conley E. Ward, Jr. Givens Pursley LLP 277 North 6th Street - Suite 200 O. Box 2720 Boise, ill 83701-2720 Telephone: (208) 388-1200 Facsimile: (208) 388-1300 cew~givenspurs1ey.com Attorneys for Idaho Telephone Association Executed protective agreement Hand Delivery U. S. Mail Overnight Delivery Facsimile Email Hand Delivery U. S. Mail Overnight Delivery Facsimile Email Brandi L. Gearhart, PLS Legal Secretary to Mary S. Hobson Stoel Rives LLP QWEST CORPORATION'S THIRD INTERROGATORIES AND REQUESTS FOR PRODUCTION OF DOCUMENTS TO STAFF - Page 8 Boise-155814.10029164-00087