200305279th Response of Qwest.pdf

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ATTORNEYS AT LAW
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UTILI TIES ' COr.'lt1t'SSION
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May 23 , 2003
MARYS. HOBSON
Direct [phone]
mshobsonl1YstoeLcom
VIA HAND DELIVERY
Jean D. Jewell, Secretary
Idaho Public Utilities Commission
472 West Washington
Boise, ill 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 RESPONSES TO NINTH INTERROGATORY / PRODUCTION REQUEST
OF THE COMMISSION STAFF TO QWEST CORPORATION. Copies of the confidential
attachments are provided under separate cover and have been provided to those parties who have
executed the Protective Agreement with the exception of certain confidential attachments to
Request for Production No. 38, whose authors requested that the information be disclosed only to
Staff.
If you have any questions, please contact me. Thank you for your cooperation in this matter.
Very truly yours4~(fr~
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Enclosurescc: Service List
Oregon
Washington
Caiifornia
U I a h
Boise-157409.10029164-00087 Idaho
Mary S. Hobson (ISB #2142)
Stoel Rives LLP
101 South Capitol Boulevard - Suite 1900
Boise, ill 83702
Telephone: [phone]
Facsimile: [phone]
mshobson~stoel.com
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UTILlT!ES COHt.1ISSION
Adam L. Sherr (WSBA #25291)
Qwest
1600 7th Avenue - Room 3206
Seattle, WA 98191
Telephone: [phone]
Facsimile: [phone]
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
EXCHANGE SERVICES
Case. No. QWE-O2-
QWEST CORPORATION'S RESPONSES TO
NINTH INTERROGATORY / PRODUCTION
REQUEST OF THE COMMISSION STAFF
TO QWEST CORPORATION
Qwest Corporation, through its undersigned attorneys, hereby files the attached responses
to the Ninth Interrogatory / Production Request of the Commission Staff.
Respectfully submitted this 23rd day of May, 2003.
Qwest Corporation
tt~
Mary S. H son
Stoel Rives LLP
Adam L. Sherr
Qwest Corporation
Attorneys for Qwest Corporation
QWEST CORPORATION'S RESPONSESTO NINTH INTERROGATORY /
PRODUCTION REQUEST OF THE COMMISSION STAFF TO QWEST CORPORATION - Page -
Boise-156283.10029164-00087
CERTIFICATE OF SERVICE
I hereby certify that on this 23rd day of May, 2003 , I served QWEST CORPORATION'
RESPONSES TO NINTH INTERROGATORY / PRODUCTION REQUEST OF THE
COMMISSION STAFF TO QWEST CORPORATION as follows:
Jean Jewell, Secretary
Idaho Public Utilities Commission
472 West Washington Street
Boise, ill 83720-0074
Phone: [phone]
Fax: [phone]
11 ewell~puc. state.id.
Weldon Stutzman, Deputy Attorney General
Idaho Public Utilities Commission
472 West Washington Street
O. Box 83720
Boise, ill 83702
Telephone: [phone]
Facsimile: [phone]
W stutzm~puc.state.id. us
Executed protective agreement
MarlinD. 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: [phone]
Attorney for Meierotto, Padget, Herrick Neal
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Email
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QWEST CORPORATION'S RESPONSES TO NINTH INTERROGATORY /
PRODUCTION REQUEST OF THE COMMISSION STAFF TO QWEST CORPORATION - Page - 2
Boise-156283.10029164-00087
Dean J. Miller
McDevitt & Miller LLP
420 West Bannock Street
O. Box 2565
Boise, ill 83701
Telephone: [phone]
Facsimile: [phone]
oe~mcdevitt -miller. com
Attorneys for WorldCom, Inc.
A ttorneys for AT&T
Attorneys for Time Warner Telecom
Executed protective agreement
Hand Delivery
---L u. S. Mail
Overnight Delivery
Facsimile
Email
Dean Randall
Verizon Northwest Inc.
17933 NW Evergreen Parkway
Beaverton, OR 97006-7438
dean.randall ((f2v erizon. com
Executed protective agreement
Hand Delivery
---L U. S. Mail
Overnight Delivery
Facsimile
Email
Mary Jane Rasher
10005 South Gwendelyn Lane
Highlands Ranch, CO 80129-6217
Telephone: [phone]
m1rasher~msn.com
Hand Delivery
U. S. Mail
Overnight Delivery
Facsimile
Email
Adam Sherr
Qwest
1600 7th Avenue - Room 3206
Seattle, WA 98191
Telephone: [phone]
Facsimile: [phone]
asherr((f2q west com
Hand Delivery
---L 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
---L U. S. Mail
Overnight Delivery
Facsimile
Email
Brian Thomas
TimeWarner Telecom
223 Taylor Avenue North
Seattle, W A 98109
Brian. Thomas((f2twtelecom.com
Hand Delivery
U. S. Mail
Overnight Delivery
Facsimile
Email
QWEST CORPORATION'S RESPONSES TO NINTH INTERROGATORY /
PRODUCTION REQUEST OF THE COMMISSION STAFF TO QWEST CORPORATION - Page - 3
Boise-156283.!0029164-00087
Susan Travis
WorldCom, Inc.
707 1 ih Street - Suite 4200
Denver, CO 80202
Telephone: [phone]
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: [phone]
Facsimile: [phone]
cew~givenspursley.com
Attorneys for Idaho Telephone Association
Executed protective agreement
Hand Delivery
~ D.Mail
Overnight Delivery
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Email
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~ U.Mail
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tJwuflU'
/~~
Brandi L. Gearhart, PLS
Legal Secretary to Mary S. Hobson
Stoel Rives LLP
QWEST CORPORATION'S RESPONSES TO NINTH INTERROGATORY /
PRODUCTION REQUEST OF THE COMMISSION STAFF TO QWEST CORPORATION - Page - 4
Boise-156283.1 0029164-00087
STOEL
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Boise. Idaho 83702
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ATTORNEYS AT LAW UTIl ESJ C
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www.stoel.com
May 23 2003
MARY S. HOBSON
Direct [phone]
mshobsonl1YstoeLcom
VIA HAND DELIVERY
PROPRIETARY AND CONFIDENTIAL
Jean Jewell
Deputy Attorney General
Idaho Public Utilities Commission
472 West Washington
Boise, ill 83702-5983
RE:Docket No. QWE-O2-
Dear Ms. Jewell:
Enclosed for filing with this Commission is an original and three (3) copies of the following
confidential attachments:
Attachments A-I for Response to Request #36P
Attachments A, B, C, E and F Response to Request #38P
Attachment A Response to Request #39P
Attachment A Response to Request #40P
to QWEST CORPORATION'S RESPONSES TO NINTH INTERROGATORY / PRODUCTION
REQUEST OF THE COMMISSION STAFF TO QWEST CORPORATION in the above-
referenced matter.
Also enclosed is an Attorney Certificate in support of this confidential filing.
Thank you for your cooperation in this matter.
Very truly yours
it /Vb!:
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Mary S. Ho~n
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Enclosures
Oregon
Washington
Caiifornia
Utah
Boise-157410.10029164-00087 Idaho
Idaho
Case No. QWE-02 -
STF 09-0271
INTERVENOR:Staff of the Idaho Public Utilities Commission
REQUEST NO:0271
On page 20, lines 12 through 15 of his rebuttal testimony, Mr. Shooshan
indicates Staff was unable to identify any studies showing wireless customers
in Idaho had problems in reaching 911. Please identify any studies, reports
or evidence Qwest is aware of showing that wireless customers in Idaho seldom
or never experience problems when dialing 911?
RESPONSE:
One would not expect there to be articles or studies indicating there is no
problem with wireless access to 911 , so consequently, Mr. Shoo shan is not
aware of any. It is his understanding that unused wireless phones have been
recycled by certain state and local police/public safety agencies (including
those in Idaho) for the express purpose of enabling eligible citizens to
access 911 services. The reliance by these authorities on wireless technology
with the specific objective of providing 911 access to those who otherwise may
not have such access (via wireline or wireless) supports Qwest's position
about the functional equivalency of wireless service in Idaho. See Attachment
A for an article in The Idaho Statesman regarding this public safety project.
It has been confirmed that the Boise Police Crime Prevention Unit still
accepts donations of cell phones that are less than three years old, have a
working battery, and a charger for purposes described in the Statesmanarticle. These wireless handsets can be delivered to the Public Safety
Building records counter located at 7200 Barrister. Deliveries are accepted
twenty four hours a day, seven days a week.
Respondent:Harry Shooshan
Idaho Statesman, The (Boise, ID)
March 12, 2001
Old cell phones can summon help
Author:
Stephanie EddyThe Idaho Statesman
Section: Communities
Page: 02
Estimated printed pages: 2
Article Text:
Donated phones get retooled to call in emergency cases
By Stephanie Eddy
Deactivated cell phones are being recycled to save lives in the Treasure
Valley through a Cellular Phone Campaign organized by the Idaho Crime
Prevention Association.
The ICP A, working with Boise Police Department, Ada County Sheriffs
Office and Nampa Police Department, is conducting a Cellular Phone Campaign
aimed at recycling unused cell phones and issuing them free of charge to
individuals for emergency use only. More than 200 have been issued.
The cellular phone is one of the best crime prevention tools available
said Charlene Miller, a crime prevention specialist with the Boise Police
Department and coordinator for the campaign. "Our criteria for giving these
cell phones to people is that the recipient does not already have a cell
phone, and they understand they can only call 911 and are unable to receive
any calls.
The Federal Communications Commission requires wireless telephone
companies to forward all 911 calls to public safety operators, even from
phones that are not in service but have been activated at some time.
Anyone upgrading their digital cell phone or changing from analog to
digital can donate a cellular phone for the campaign and receive a tax
donation receipt.
Phones must be in good condition and have a working battery and charger.
This has been one of the most enjoyable and rewarding programs to be
involved in " said Miller who cleans, charges and bags the phones. "Weare
benefitting donors with a tax deduction receipt and recipients with the
ability to access emergency help if they need it."
Several cell phones have been donated to Safe Place Ministries in Boise, a
IDAHO
Case No. QWE-02-
STF 09-0271
A TT A CHMENT A
non-profit corporation that provides safety, support and referral services
for victims of child abuse, domestic violence and sexual assault.
One client who is in the process of a divorce was issued a cell phone
because her husband has a history of mental illness and domestic battery.
It gives our clients a sense of security when they have a cell phone for
emergencies and puts them a little more at ease " said Nancy Edwards, SPM
executive director. "It promotes safety without the burden of charges they
cant afford.
Getting involved
Analog and digital cell phones can be donated at the public safety
buildIng, 7200 Barrister Drive, and Boise and Ada County police
substations. Sheriffs' offices in Nampa and Twin Falls also accept cell
phones. For more information, call Charlene Miller at 377-6676.
To request a free cellular phone for emergency use, call Miller at
377-6676 or Tuckie Shaver at 377-6575.
To offer story ideas or comments, contact reporter Stephanie Eddy at
377-6481 or seddycmboise.g:annett.com
Charlene Miller, Boise Police Crime Prevention Unit, works on cellular
phones that have been donated to the Idaho Crime Prevention Associations
Cellular Phone Campaign. The phones will be used by individuals who need a
cellular phone for emergency use only.
Copyright (c) The Idaho Statesman. All rights reserved. Reproduced with the
permission of Gannett Co., Inc. by NewsBank, inc.
Record Number: boi2001O3l2l651O77l
Idaho
Case No. QWE-02-
STF 09-0281
INTERVENOR:Staff of the Idaho Public Utilities Commission
REQUEST NO:0281
Starting on line 11 of his rebuttal testimony, Dr. Lincoln indicates that his
survey instrument was pre-tested with 40 individuals and that 96% of them
said they understood the terms used in the survey. Did Dr. Lincoln determine
whether each individuals understanding of the terms was the same as the other
individuals? If so , how was that done?
RESPONSE:
Qwest assumes Staff refers to page 7 not 11 of Dr. Lincoln s testimony. Yes.
The exact question used to ascertain the degree to which (pretest)
respondents understood the terms used in the survey was, "Did you find the
terms used in this survey to be understandable and clear?" If "no", they were
asked which ones they . found unclear. The total number of respondents (out of40), saying "no" was zero. The few that did not say "yes" were "unsure" and
asked to reveal what was unclear. The next pretest question was, "Could you
tell me what these terms in the survey refer to? A. Traditional phoneservice, B. Cell phone service, C. Local calls." The last pretest question
was , "The question which asked you to compare the monthly cost of cell phone
service compared to traditional phone service... did you think in terms of
local calls, local and long distance, or something else?"
Responses to all these questions told us that respondents appeared to have a
similar concept of the survey s terms. As an example of an area of some
differences, a few respondents thought of both local and long distance phone
bills when responding to the price comparison question. However , it was
decided not to try to change the wording on the pricing question in the final
questionnaire as many cell phone plans include long distance and a question
requiring them to split out long distance from local (cell phone) charges
would be exceeding the respondent's ability to do so.
Overall , the pretest activity gave us confidence that respondents had a
similar understanding of the survey instrument's terms. Given the fact that
13% of all adult Idahoans are illiterate, we felt that our survey stood very
clear in the minds of our anticipated adult respondents. Lastly, it should be
noted that all respondents in the final survey execution always had the
option of responding with a "Don't Know" or "Unsure" response to any of our
questions. This is common research practice where one does not want to force
a respondent to take a position when they feel that they lack enough
information to make a judgment.
Respondent:. Doug Lincoln
Idaho
Case No. QWE-02-
STF 09-0291
INTERVENOR:Staff of the Idaho Public Utilities Commission
REQUEST NO:0291
On page 10 of Dr. Lincoln s rebuttal testimony, he states that his survey was
to determine the degree to which the Idahoans who would be affected by price
deregulation believed that effective competition existed in their area"
you believe customers understood they were giving an opinion on whether
effective competition existed in their area?" If so, please explain.
RESPONSE:
If the question is whether customers knew they were rendering an opinion on a
legal standard , the answer is "No". Customers were giving an opinion on the
degree to which the three conditions exist in their area. While those
conditions are the conditions required by statute , customers were not told
these were statutory criteria and , as discussed in Dr. Lincoln s direct
testimony, customers were not given statutory language during the survey
process.
The methods undertaken by the survey to convert or translate statutory terms
into terms more commonly used and therefore better understood by Idahoans in
the seven exchange areas were scientifically valid. To ask customers if they
thought "effective competition" existed would assume that they have a common,
working definition of these two key words and not really provide the kind of
guidance needed for the Commission s decision setting. Instead , the survey
questions drew upon the three market conditions that the Idaho statute
requires for a finding of effective competition. Therefore , the survey design
process relied upon consumer input (our terminology phase with 36 respondents
and pretesting with another 40 respondents) to develop or operationalize
questions to assess the degree to which some 800 Idahoans believed these
three conditions to exist in their marketplace. Our development process led
to the creation of four basic questions to assess the consumer s perceptions
on them. One question addressed the functional equivalence criteria (i. e. ,
could they solely rely on cell phones for the purpose of making and receiving
local phone calls), another addressed perceived pricing similarities between
cell and traditional phone service , and two questions addressed how
reasonably available cell phone service was believed to be.
Respondent:Doug Lincoln
Idaho
Case No. QWE-02-
STF 09-0301
INTERVENOR:Staff of the Idaho Public Utilities Commission
REQUEST NO:0301
On page 13 of Dr. Lincoln s rebuttal testimony, he indicated that the 876
consumers tell us exactly what functional equivalence meant to them?"
you believe the survey respondents understood they were providing an opinion
on whether wireless and wireline services are functionally equivalent?
so, please explain.
RESPONSE:
If the question is whether customers knew that they were opining on a legal
terms , the answer is "No", and for good reasons. First, the term
"functionally equivalent" is a statutory term that needed to be converted
into a term or words that were more commonly understood by Idahoans living in
the seven exchange areas. The processes used to discover that asking
respondents if the two product choices could be used for the same purpose was
a better al ternati ve than using statutory language has already been discussed
in Dr. Lincoln s direct testimony as well as in Qwest's responses to
Interrogatories No.28 and No. 29. Using common research terminology, a
surrogate measure for functionally equivalent" was developed.
Second , to reveal the true purpose of a survey is not considered good
research practice when the researcher has reason to believe that knowing the
true purpose could bias respondents. For example , knowing that Qwest
sponsored the survey could have influenced responses in either direction.
Likewise, telling respondents that the results of the survey were going to be
used to determine if Qwest basic local exchange service should be deregulated
in their exchange area could have influenced responses in either direction.
Maintaining neutrality in the conduct of our survey was essential to insuring
that the Commission and the public would view it as credible.
Respondent:Doug Lincoln
Idaho
Case No. QWE-02-
STF 09-0311
INTERVENOR:Staff of the Idaho Public Utilities Commission
REQUEST NO:0311
On page 13 of Dr. Lincoln s rebuttal testimony, he states that "these
Idahoans told us that products are functionally equivalent when they can do
the same thing"Which question asked of the 800 survey respondents supports
Dr. Lincoln's conclusion that the survey respondents " (told) us exactly what
functional equivalence meant to them?"
RESPONSE:
Again, respondents' answers to the survey question , "Could you solely rely on
cell phone service for the purpose of making and receiving local phone calls?"
as a surrogate measure was developed via exploratory research with 36 adults.
Pretesting this question , along with others, was conducted with another set of
40 adults. These two steps confirmed that respondents, when responding to thequestion, would be telling us if they thought that cell phones could do the
same thing (as a traditional phone line) when it came to making and receiving
local phone calls. The eventual 800 survey participants "used" the "solely
rely on " question to tell us the degree to which they felt the two phone
services were functionally equivalent.
Respondent:Doug Lincoln
Idaho
Case No. QWE-02-
STF 09-0321
INTERVENOR:Staff of the Idaho Public Utilities Commission
REQUEST NO:0321
Please identify all features that are included in the total feature revenue
that was used in the calculation of the average cost of features used in
Exhibit 19.
RESPONSE:
The "average feature revenue per line" values were developed separately for
residential and business service in Idaho. The averages are displayed on
Exhibit 20 as a unique line item in the pricing comparisons. These values
were simply calculated by dividing all residential and business (for
customers with 5 lines and fewer) feature revenue by access lines in service.
For business, the following feature categories contributed to total feature
revenue in the state (only lines and features associated with business with 5
or fewer lines were included) :
Centron 1 Package , Centron 1 Features , Centron 1 Call Forwarding, Hunting,
Call Waiting, Call Forwarding, Three Way Calling, Speed Calling - 8 , Custom
Calling Packages, Speed Calling - 30 , Intracall , Custom Ringing, MessageWaiting Indication , Toll Restriction , Voice Messaging, Basic Mailbox , Call
Routing Mailbox , Optional Features , Priority Call , Caller ID , Continuous
Redial, Selective Call Forwarding, Last Call Return , Selective CallRejection, Call Trace , Caller ID with Privacy.
For residence, the following feature categories contributed to total feature
revenue in the state:
Centron 1 Package , Centron 1 Features , Centron 1 Call Forwarding, Hunting,
Call Waiting, Call Forwarding, Three Way Calling, Speed Calling - 8, Custom
Calling Packages , Speed Calling - 30 , Intracall , Custom Ringing, Custom
Ringing Plus, Easy Access Voice Messaging, Number Forwarding, Message WaitingIndication, Toll Restriction , Remote Access Forwarding, I-Called, PriorityCall, Caller I. D., Continuous Redial , Selective Call Forwarding, LAst Call
Return , Selective Call Rej ection , Caller ID Blocking, Call Trace , NoSolicitation, Do Not Disturb, Dial Lock , Call Curfew, Caller ID with Privacy,
Security Screen, Custom Choice Complete , Popular Choice , Custom Choice
Preferred Choice Package, Value Choice Package , Select Pak.
Respondent:David Teitzel
Idaho
Case No. QWE-02-
STF 09-0331
INTERVENOR:Staff of the Idaho Public Utilities Commission
REQUEST NO:0331
Was the impact of the expanded local calling areas implemented after 1996
factored in to the call holding times used in the preparation of Exhibit 21?
If so , what was the relative weight given to the impact of the expanded
calling areas?
RESPONSE:
It is not clear that EAS expansions in Idaho created a substantial impact on
call holding times in the state. For example, EAS expansions were
implemented in 1996 in Southern Idaho, and call hold times remained virtually
constant for flat business service through 1998 (1996 flat business call holdtime: 1., 1998 flat business call hold time: 1.76). For flat residence
service , there was a very slight increase in call hold time over the same
period (3.50 for 1996 to 3.83 for 1998)
Since the effect of EAS expansions on call holding times appears to not besignificant, no weighting was given to this effect in the preparation ofExhibit 21. Mr. Teitzel continues to maintain that the most significant
driver of increased call hold times has been the advent of dial-up internetaccess, as supported by the evidence introduced in the testimony of Staff
witness Mr. Wayne Hart that over 50% of Idahoans currently have internet
access.
Respondent:David Teitzel
Idaho
Case No. QWE-02-
STF 09-0341
INTERVENOR:Staff of the Idaho Public Utilities Commission
REQUEST NO:0341
Was the increased use of calling centers and their tendency to put callers
on hold factored in to your analysis of the call holding times used in the
preparation of Exhibit 21? If so, what was the relative weight given to the
increased use of calling centers?
RESPONSE:
The term "calling centers" is unclear. However , if the term is intended to
mean agencies that use automated systems to screen incoming calls, calls to
those types of entities were not (and cannot be) separately identified in the
Subscriber Line Usage (SLUS) data relied upon in this proceeding. It is also
unclear what the qualifier "increased use" in the question is intended to
convey, and does not concede to the premise of this question. Qwest has seen
no evidence that "call center " use has impacted call holding times in anymaterial way. In fact , it is noteworthy that SLUS data for measured
residential and measured business services shows an essentially constant hold
time over the past 10 years. If the existence of "call centers" had a
material impact on average hold times , that impact would be seen in both
measured and non-measured local calling patterns. That impact is simply not
evident in the SLUS call hold time data for Idaho.
Respondent:David Teitzel
Idaho
Case No. QWE-02-
STF 09-0351
INTERVENOR:Staff of the Idaho Public Utilities Commission
REQUEST NO:0351
On lines 6 and 7 of page 9 of Mr. Teitzel's rebuttal testimony, he quotes a
Mobile advertising claim that it's network provides service quality that is
near parity with wire lines"Is Qwest aware of any independent research
that indicates wireless quality as being at parity with wireline?
RESPONSE:
Qwest is not aware of any Idaho-specific independent research that discusses
this issue however T-Mobile I s claim is consistent with the strides made by
wireless carriers in the areas of service quality and is indicative of the
fact wireless carriers now market their service quality as comparable to thatprovided over land lines.
Respondent:Starla Rook
Idaho
Case No. QWE-02-
STF 09-035P
INTERVENOR:Staff of the Idaho Public Utilities Commission
REQUEST NO:035P
Please provide copies of the following references cited in Mr. Shooshan'
rebuttal testimony:
Michael L. Katz and Harvey S. Rosen Microeconomics , Second Edition (Boston:Richard Irwin Inc., 1994) at 32-33, 63.
Stephen Martin , Advanced Industrial Economics (Blackwell: 1993) at 261.
F. M. Scherer and David Ross The Welfare Economics of Competition and
Monopoly, Industrial Market Structure and Economic Performance (Houghton
Mifflin Company, Boston: 1990) at 52,
J. M. Clark
, "
Toward a Concept of Workable Competition The American Economic
Review Vol. XXX , No., June 1940.
The 2003 Telecom Industry Review: An Anthology of Market Facts and Forecasts,
The INSIGHT Research Corporation (January 2003)
Mobile Communications Report, Warren Publishing, Inc.(November 2002) .
RESPONSE:
Please see Attachment A for the requested information.
Respondent:Harry Shooshan
RE MAININ G P AGE S
ARE IN THE FILE
UNABLE TO SCAN
BECAUSE OF POOR QUALITY
CO NFID ENTIAL DOCUMENTS
WERE INCLUDED IN THIS FILING