200304218th Request of the Commission to Qwest.pdf

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WELDON B. STUTZMAN
DEPUTY ATTORNEY GENERAL
IDAHO PUBLIC UTILITIES COMMISSION
PO BOX 83720
BOISE, IDAHO 83720-0074
[phone]
ISB NO. 3283
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UTILITIES CQt1MISSIOH
Street Address for Express Mail:
472 W. WASHINGTON
BOISE, IDAHO 83702-5983
Attorney for the Commission Staff
BEFORE THE IDAHO PUBLIC UTILITIES COMMISSION
IN THE MATTER OF THE APPLICATION OF
QWEST CORPORATION FOR DEREGULATION OF BASIC LOCAL
EXCHANGE RATES IN ITS BOISE, NAMPA,
CALDWELL, MERIDIAN, TWIN FALLS,
IDAHO FALLS, AND POCATELLO EXCHANGES.
CASE NO. QWE- T -02-
EIGHTH INTERROGATORY/
PRODUCTION REQUEST OF
THE COMMISSION STAFF TO
QWEST CORPORATION
The Staff of the Idaho Public Utilities Commission by and through its attorney of record
Weldon B. Stutzman, Deputy Attorney General, requests Qwest Corporation (Qwest) provide the
following documents and information, pursuant to Commission Rule of Procedure 225, IDAP A
31.01.01.225 on or before Friday, April 25 2003.
This Production Request is to be considered as continuing, and Qwest is requested to
provide, by way of supplementary responses, additional documents and information that it or any
person acting on its behalf may later obtain that will augment the documents and information
produced. For each request, please state the name of the person(s) preparing the answers, along
with the job title of such person(s) and the witness who can sponsor the answer at hearing.
responses include workpapers or spreadsheets, please provide the responses on computer media
(3.5" diskette or CD) using Lotus 123 (4.0) or Excel 5.0 language.
EIGHTH INTERROGATORY/
PRODUCTION REQUEST
TO QWEST APRIL 21 , 2003
DEFINITIONS and INSTRUCTIONS
The words "the Company" and "Qwest" refer to Qwest Corporation
Document" includes any written or recorded or graphic matter, however produced or
reproduced, including but not limited to correspondence, telegrams, contracts
agreements, notes in any form, memoranda, diaries, voice recording tapes, microfilms
microfiche, pictures, data processing cards or discs , computer tapes and other computer-
generated and stored information or data base, work papers, calendars, minutes of
meetings or any other writings or graphic matter, including copies containing marginal
notes or variations of any of the foregoing, now or previously in your possession.
(1)
(2)
In the event that any document called for is to be withheld on the basis of a claim
of privilege, identify the item being withheld as follows: addressor; addressee;
indicated or blind copies; and all persons to whom distributed, shown, or
explained. Also identify the nature and legal basis of the privilege asserted.
In the event that any document called for by this request has been destroyed or
transferred beyond the control of the Company, (a) state the identity of the person
by whom it was destroyed and person authorizing destruction and the time, place
and method of, and reasons for its destruction, and if destroyed or disposed of by
operation of a retention policy, state the retention policy; and, if transferred, the
person authorizing transfer and the time, place, and method of, and reason for, its
transfer, and (b) identify it as follows: addressor; addressee; indicated or blind
copies; dates; subject matter; number of pages, attachments or appendices; and all
persons to whom distributed, shown, or explained.
Identify,
" "
Identity," or "Identification " when used in reference to an individual person
means to state that person s full name and residence address, including zip code and
phone number, if known, and present or last known business position and duties and
business address, if known.
Identify,
" "
Identity," or "Identification " when used in reference to a document, means
to state the type of document (e., computer-stored information, microfilm, letter
memorandum, policy circular, minute book, telegram, chart, etc.), or some other means
of identifying it, and its present location and custodian. If any such document was, but is
no longer, in your possession or subject to your control, state what disposition was made
of it, and if destroyed or disposed of by operation of a retention policy, state the retention
policy.
Identify,
" "
Identity," or "Identification " when used in reference to a number or other
specific information, means to identify the document containing this information or some
other means of identifying it, and to specify the approximate location of the requested
information within that document.
EIGHTH INTERROGATORY/
PRODUCTION REQUEST
TO QWEST APRIL 21, 2003
Identify,
" "
Identity," or "Identification " when used in reference to a business
organization, means to state the corporate name or other names under which said
organization does business, and location of its principal place of business.
Note: to the extent the specific information requested herein is not available, but analogous or
reasonably comparable information is available, please provide that information instead, and
explain any differences between what was requested and what has been provided. To the extent
the information requested herein is not available in the exact format requested, but the
information can be more easily provided in a different format, please provide your response in
the more readily available format, but explain any differences in format. Please provide an
electronic copy of the requested information in Excel spreadsheet or compatible format.
Interrogatory No. 25: In Production Request No., Request No. 22, from the Staff to
Qwest, the Company was asked "Assuming, arguendo that Qwest was granted deregulation, if
Qwest decided to change rates for residence or business customers in the seven exchanges in
which they have asked for deregulation, how long would it take to process this change through
the Qwest billing system? Less than 10 days, 11 - 30 days, 31-60 days, greater than 60 days.
For clarification in its response please make the following assumptions: The IFR or IFB rate is
being changed in all of the seven exchanges for which Qwest is requesting deregulation, this is
the only change being requested, and Idaho is the only state requesting these billing changes.
Please provide the timeframes in accordance with the original request, that is: less than 10 days
11 - 30 days, 30 - 60 days, greater than 60 days.
Interrogatory No. 26: In Production Request No., Request No. 23 , from the Staff to
Qwest, the Company was asked "Assuming, arguendo that Qwest was granted deregulation, if
Qwest decided to change product packages for residence or business customers in the seven
exchanges in which they have asked for deregulation, how long would it take to process this
change through the Qwest billing system? Less than 10 days, 11 - 30 days, 31-60 days, greater
than 60 days." For clarification in its response please make the following assumptions: That 3-
way calling is being deleted from a package in all of the seven exchanges for which Qwest is
requesting deregulation, this is the only change being requested, and Idaho is the only state
requesting these billing changes. Please provide the timeframes in accordance with the original
request, that is: less than 10 days, 11 - 30 days, 30 - 60 days, greater than 60 days.
EIGHTH INTERROGATORY/
PRODUCTION REQUEST
TO QWEST APRIL 21 , 2003
DATED at Boise, Idaho, this 7~' 4i-day of April 2003.
0l )------C
Weldon B. Stutzman
Deputy Attorney General
Technical Staff: Joe Cusick
Wayne Hart
i :umisc:prodreq/qwetO225 - 8thProductionRequest
EIGHTH INTERROGATORY/
PRODUCTION REQUEST
TO QWEST APRIL 21 2003
CERTIFICATE OF SERVICE
HEREBY CERTIFY THAT I HAVE THIS 21ST DAY OF APRIL 2003
SERVED THE FOREGOING COMMISSION STAFF'S EIGHTH INTERROGARY/
PRODUCTION REQUEST TO QWEST, IN CASE NO. QWE-02-, BY MAILING
A COpy THEREOF, POSTAGE PREPAID, TO THE FOLLOWING:
MARY S HOBSON
STOEL RIVES LLP
SUITE 1900
101 S CAPITOL BLVD
BOISE, ID 83702
ADAM L SHERR
QWEST
1600 7TH AVE, ROOM 3206
SEATTLE, WA 98191
CONLEY WARD
GIVENS PURSLEY LLP
277 N 6TH ST, SUITE 200
PO BOX 2720
BOISE, ID 83701-2720
CLAY R STURGIS
MOSS ADAMS LLP
601 W RIVERSIDE, SUITE 1800
SPOKANE, WA 99201-0663
DEAN J MILLER
McDEVITT & MILLER LLP
PO BOX 2564
BOISE, ID 83701
BRIAN THOMAS
TIME WARNER TELECOM
223 TAYLOR AVE NORTH
SEATTLE, WA 98109
SUSAN TRAVIS
WORLDCOM INC.
707 17TH STREET, SUITE 4200
DENVER, CO 80202
MARY JANE RASHER
AT&T COMMUNICATIONS OF THE
MOUNTAIN STATES INC.
10005 S GWENDEL YN LANE
HIGHLANDS RANCH, CO 80129-6217
MARLIN D ARD
WILLARD L FORSYTH
HERSHNER, HUNTER, ET AL
180 E 11 TH AVE PO BOX 1475
EUGENE, OR 97440-1475
DEAN RANDALL
VERIZON NORTHWEST INC.
17933 NW EVERGREEN PKWY
BEAVER TON, OR 97006-7438
JOHN GANNON
ATTORNEY AT LAW
1101 W RIVER, SUITE 110
BOISE, ID 83702
BEN JOHNSON
BEN JOHNSON ASSOCIATES INC.
2252 KILLEARN CENTER BLVD
TALLAHASSEE, FL 32308
. l;(j
CERTIFICATE OF SERVICE