200506031st Level 3 request to Qwest.pdf

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Dean J. Miller, (ISB No. 1968)
McDevitt & Miller LLP
420 West Bannock Street
O. Box 2564, Boise-83701
Boise, Idaho 83702
Tel: [phone]
Fax: [phone]
oe~mcdevitt- miller .co m
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*****
In the Matter of Level 3 Communications
LLC's Petition for Arbitration Pursuant to
Section 252(b) of the Communications Act of
1934, as amended by the Telecommunications
Act of 1996, and the Applicable State Laws for
Rates, Terms, and Conditions of Interconnection)
with Qwest Corporation
Case No. G( LV E. ::t -05 -
LEVEL 3 COMMUNICATIONS,
LLC'S FIRST SET OF
INTERROGATORIES,
REQUESTS FOR PORDUCTION
0 F DOCUMENTS, AND
REQUESTS FOR ADMISSIONS
TO QWEST CORPORATION
DEFINITIONS AND INSTRUCTIONS
A. Each request pertains to documents, physical objects, and computer recorded
information in your knowledge, possession, custody, or control, or in the knowledge
possession, custody, or control of your agents or representatives. Each request is also a
continuing request for information and documents, which come into your control during
the time in which this proceeding is pending.
B. With respect to any document responsive hereto which has been destroyed, lost
or is no longer in your possession or subject to your control, you shall submit a statement
setting forth as to each, a description of the item, its disposition, the date of disposition
and the names of all those with knowledge thereof.
C. The words "document"
, "
memoranda
, "
work papers
, "
notes
, "
correspondence
item , and "record", include any physical object, written, printed, typed, recorded or
graphic, however produced or reproduced, whether sent, received or neither, including
originals, copies and drafts, and including but not limited to: correspondence, email
telecopier correspondence, messages, reports and recordings of telephone or other
conversations and of interviews and conferences, memoranda, notes, opinions, records
balance sheets, income statements, monthly statements, book entries, account letters
ledgers, journals, books or records of accounts, summaries of accounts, purchase or sales
orders, invoices, vouchers, bills, receipts, checks stubs, cancelled checks, drafts, leases
contracts, offers, desk calendars, appointment books, diaries, expense reports, summaries
transcripts, minutes, reports, affidavits, statements, questionnaires, answers to
questionnaires, plans, specifications, lab books and notations, data notations, workpapers
confirmations, formula, studies, forecasts, projections, analyses, evaluations, statistical
records, tabulations, calculations, charts, graphs, surveys, renderings, diagrams
photographs, recordings, films, video recordings, microfilms, papers, books, periodicals
pamphlets, newspaper articles or clippings, publications, schedules, lists, indexes, all
other records or information kept by electronic, photographic, mechanical or other means
and any item similar to the foregoing, however denominated, whether currently in
existence or already destroyed.
D. As used herein, the words "Qwest " or "Company" refer to Qwest Corporation-
Southern Idaho and Qwest Corporation-Northern Idaho and any predecessor, successor
or affiliated corporations, its present and former directors, officers, agents
representatives, employees, attorneys, and all other present or former persons
corporations, companies, partnerships, or organizations acting or purporting to act on
behalf of Qwest. The words "this state , or references to this "state , means Idaho.
E. These requests are directed to all documents and information in your possession
custody or control. A document is deemed to be in your possession, custody or control if
you have possession of the document, have the right to secure such document or
communication from another person having possession thereof, or the document or
communication is reasonably available to you (including those documents or
communications in the custody or control of your company s present employees
attorneys, agents, or other persons acting on its behalf and its affiliates. In response to
requests for production of documents contained in these discovery requests, you shall
produce the documents, including all appendices, exhibits, schedules, and attachments
that are most relevant to the request.
F. If you are unable to produce a document or information based on a claim that the
document is not in your possession, custody or control, state the whereabouts of such
document or information when it was last in your possession, custody or control, and
provide a detailed description of the reason the document is no longer in your possession
custody or control, and the manner in which it was removed from your possession
custody or control.
G. Qwest shall produce all responsive documents for inspection and copying
unaltered and/or unredacted as they are kept in the usual course of business and organize
and label them to correspond to the categories in this request. If the requested documents
are kept in an electronic format, you shall produce the requested document in such
format. If any part of a document is responsive to any request, the whole document is to
be produced. If there has been any alteration, modification or addition to a document
(whether in paper form or electronic), including any marginal notes, handwritten notes
underlining, date stamps, received stamps, attachments, distribution lists, drafts, revisions
or redlines, each such alteration, modification or addition is to be considered as a separate
document and it must be produced.
H. With respect to any responsive document to which Qwest asserts a claim of
privilege, you shall submit a list identifying each document. Identification shall include
LEVEL 3 COMMUNICATIONS, LLC'S FIRST SET OF INTERROGATORIES, REQUESTS
FOR PORDUCTION OF DOCUMENTS, AND REQUESTS FOR ADMISSIONS TO QWEST
CORPORA TION-
the (1) date of the document, (2) the names, addresses and capacity of those who have
signed the document, (3) the names, addresses and capacity of those who participated in
its preparation, (4) the addressee or addressees, (5) the person or persons by whom it was
received, (6) the general subject matter thereof, (7) the present or last known location and
custodian of the original (or, if that is unavailable, the most legible copy or duplicate
thereof), (8) the names and addresses of those who have received a copy of the document
and (9) the basis for your claim of privilege.I. Please answer each question separately and in the order that it is asked. Label
each response to correspond to the interrogatory, request for production of documents
and/ or request for admission. The numbers of the answers should correspond to the
numbers of the data requests being answered. In addition, copy each question
immediately before the answer. Following each answer, identify the person or persons
responsible for the answer and indicate what person or witness provided responsive
information or documents, and where applicable, what witness will sponsor each answer
in testimony.J. In response to Interrogatories requesting you to identify documents or other items
information or materials for disclosure, please identify the document(s) or other item(s),
information or material( s) in sufficient detail so that they can be produced in response to
a separate Request for Production. Such identification shall contain the number (and
subpart, if applicable) of the Interrogatory requesting the identification and the page
count or description of the document or item. Additionally, to the extent known, the
listing shall include the author, publisher, title, date, and any "Bates" or other sequential
production numbering for the document or item. When responding to the Request for
Production, please produce copies of all documents, other items, information or materials
that were identified in response to a request or directive to "identify for disclosure" in
these Interrogatories. For each document or other item, please identify by number
(including subpart, if any) the interrogatory which caused the "identification for
disclosure. "
K. These discovery requests impose a continuing obligation on the respondent to
supplement an initial response with additional responsive information if such information
becomes available. Should there be a change in circumstances which would modify or
change an answer you have supplied, you should change or modify such answer and
submit such changes, modifications, or additional information as a supplement to the
original answer. Further, should a subsequent version(s) of a document be created or
exist after the date of this discovery request, such version( s) must be produced. Where
prior versions or drafts of documents exist, please produce all such documents in your
possession, custody or control. In this regard, should additional responsive information
become available, advise Level 3 in writing, and provide a supplemental response as soon
as the material becomes available.
Questions or concerns regarding these discovery requests should be directed to:
Dean J. Miller (ISB No. 1968)
LEVEL 3 COMMUNICATIONS, LLC'S FIRST SET OF INTERROGATORIES, REQUESTS
FOR PORDUCTION OF DOCUMENTS, AND REQUESTS FOR ADMISSIONS TO QWEST
CORPORA TION-3
McDevitt & Miller LLP
420 West Bannock Street
O. Box 2564, Boise-83701
Boise, Idaho 83702
Tel: [phone]
Fax: [phone]
oe~mcdevitt -miller .com
Erik Cecil
Regulatory Counsel
Level 3 Communications, LLC
1025 Eldorado Boulevard
Broomfield, CO 80021
Tel.: [phone]Fax: [phone]
erik.cecil~leve13 .com
INTERROGATORIES AND REQUESTS FOR
THE PRODUCTION OF DOCUMENTS
1. F or each response provided to an interrogatory or Request for the Production of
documents, please provide the name, title and work address of any person that
assisted in the preparation of the response. Please include a list of each of the
interrogatories or data request responses in which the person assisted.
2. For each person that Qwest intends to call as a witness in this proceeding, provide the
following:
a. that witness' name , address and business affiliations;
b. copies of all documents relied upon by the witness in preparation of their
testimony;
c. copies of all documents prepared by the witness that reference, refer or relate to
the issues in this proceeding.
d. a statement describing the opinions held by the witness that are relevant to this
proceeding.
e. if the person has previously appeared as a witness in any regulatory proceeding,
under the 1996 Act, provide copies of all testimony that the person has submitted
in each such proceeding.
3. Please provide the following data:
LEVEL 3 COMMUNICATIONS, LLC'S FIRST SET OF INTERROGATORIES, REQUESTS
FOR PORDUCTION OF DOCUMENTS, AND REQUESTS FOR ADMISSIONS TO QWEST
CORPORA TION-4
a. By LATA, the number of Qwest local calling areas in each LATA in the state;
b. The number and locations of Qwest's end offices in state;
c. The number and locations of Qwest's tandem offices in state, as well as the
tandem type (access, local, access/local);
d. The number of access lines (loops) in the state, broken out by type such as analog,
DSO, DS 1, etc, by business and residence.
e. The number of local calls and local minutes of use per month and per year for
business and residential end user customers in the state. If Qwest does not
classify calls or minutes into a category denominated "local " please so state and
identify the categories into which Qwest classifies its traffic. If Qwest does
classify calls and/or minutes into a category denominated "local " please use that
definition to respond to this question, and also explain how Qwest determines
what traffic to classify as "local."
4. Does Qwest have an affiliated Internet Service Provider ("ISP") that offers Internet
access services in the state? If so, please identify the affiliates, and state the number
of end user and wholesale customers in the state for each Qwest ISP affiliate.
a. Please identify each telephone company end office in the state in which the Qwest
affiliate ISP has collocated equipment such as modem banks, DSL equipment
routers, A TM switches or other equipment. Please identify the telephone
company that owns/operates each such end office.
b. Please list each local calling area within the state in which the affiliate maintains a
physical presence.
5. Does Qwest or any affiliate of Qwest offer Voice over Internet Protocol ("VoIP") to
end users in this state? If so
a. Please identify the specific entity that offers the service and explain that entity
relationship to Qwest.
b. Please state how many end use customers and how many wholesale customers in
the state the Qwest VoIP provider has.
c. Please list each local calling area within the state in which the affiliate maintains a
physical presence.
d. Please identify each telephone company end office in the state in which the Qwest
affiliate VoIP provider has collocated equipment such as media gateways, DSL
equipment, routers, A TM switches or any other related equipment necessary for
providing VoIP service. Please identify the telephone company that
owns/operates each such end office.
LEVEL 3 COMMUNICATIONS, LLC'S FIRST SET OF INTERROGATORIES, REQUESTS
FOR PORDUCTION OF DOCUMENTS, AND REQUESTS FOR ADMISSIONS TO QWEST
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e. Does Qwest purchase any wholesale VoIP services from any other provider?
, please name the provider(s) and the state(s) in which such service(s) is/are
purchased.
6. Please describe any traffic exchange arrangements of any description applicable to
enhanced or Internet Enabled services such as Voice over Internet Protocol ("VoIP"
that Qwest or any Qwest affiliate operating in the state has with:
a. other ILECs;
b. CLECs; or
c. any other parties.
7. Please provide the total number of VoIP traffic minutes the Qwest network
transported in this State:
a. In 2003.
b. In 2004.
c. In 2005.
8. Of those VoIP traffic minutes provided in response to the question above, please
provide the total number ofVoIP traffic minutes that Qwest or Qwest's affiliates
carried to or from their own customers in this State in 2002 and 2003.
9. What are Qwest's plans for providing VoIP to its customers , either through Qwest
itself, by means of any affiliate or through a third party? Provide all documents
related to Qwest's plans.
10. What IP voice products do Qwest or Qwest's affiliates offer to customers in the state?
Please describe and provide all related relevant documentation regarding how Qwest
provides any V oIP, IP enabled, Voice embedded IP communications, or enhanced
services to its end user or enhanced service provider customers or affiliates such as
using PRis or some other architecture.
a. Please describe the architecture by which Qwest provides these services within
the state.
b. Please describe the architecture by which Qwest provides these services within
the state, but outside of Qwest's incumbent LEC operating territory.
11. Please provide the total number of VoIP customers Qwest has in the State as of May
2005. How many VoIP terminals does that number represent?
12. Please identify every state in which Qwest combines local and toll traffic (including
either interLA T A or intraLA T A toll traffic, or both, as the case may be) on the same
LEVEL 3 COMMUNICATIONS, LLC'S FIRST SET OF INTERROGATORIES, REQUESTS
FOR PORDUCTION OF DOCUMENTS, AND REQUESTS FOR ADMISSIONS TO QWEST
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trunk group at any point in Qwest's transmission of traffic. For each such state
please indicate which of the following situations apply:
a. Local and toll traffic combined on a direct trunk group between two end offices;
b. Local and toll traffic combined on a trunk group between a Qwest end office and
a Qwest tandem;
c. Local and toll traffic combined on a trunk group between a Qwest end office and
a third party carrier (CLEC, ILEC, IXC) switch;
d. Local and toll traffic combined on a trunk group between a Qwest tandem and a
third party (CLEC, ILEC, IXC) switch; and/or
e. Local and toll traffic combined on a trunk group between two Qwest tandems.
For purposes of this question, please use Qwest's own definitions of "local" and
toll" traffic, but provide a brief explanation of how Qwest classifies traffic into those
categories.
13. In which states, and in which local calling areas in those states, do Qwest's CLEC
affiliates combine their own local and toll (IntraLATA and InterLATA) traffic on a
single trunk?
14. In which states does Qwest combine CLEC local and toll (IntraLATA and
InterLATA) traffic on a single trunk?
a. Please provide a list of all CLECs for whom Qwest combines, or has combined
local and toll (IntraLA T A and InterLA T A) traffic on a single trunk.
b. Please provide the month and year when Qwest started to combine traffic in each
state where Qwest combines CLEC local and toll (IntraLA T A and InterLA T A)
traffic.
15. Does Qwest believe that it will receive materially more or less intercarrier
compensation from Level 3 if Qwest prevails in its proposal to require Level 3 to
establish multiple or separate trunking facilities for Transit Traffic, InterLA T A
traffic, and any non-local or non-intraLA T A traffic (see Petition, Tier Issues 2 and
4)? If your answer is anYthing other than an unqualified "" please explain in detail
the basis for your answer, including all workpapers underlying any calculations
involved in supporting that answer.
16. For each state in which Qwest operates as an ILEC, please identify each CLEC with
which Qwest (a) exchanges local and toll (IntraLATA and InterLATA) traffic on a
single trunk group and (b) uses a a Percent Local Use (PLU) or similar method of
establishing the apportionment of local vs. toll traffic on the combined trunk group.
LEVEL 3 COMMUNICATIONS, LLC'S FIRST SET OF INTERROGATORIES, REQUESTS
FOR PORDUCTION OF DOCUMENTS, AND REQUESTS FOR ADMISSIONS TO QWEST
CORPORA TION-
17. For each state in which a Qwest CLEC affiliate combines local and toll (IntraLATA
and InterLATA) traffic on a single trunk group, please state whether Qwest's CLEC
affiliate uses a Percent Local Use (PLU) or similar other method of establishing the
apportionment of local vs. toll traffic on the combined trunk group.
18. Please describe each system and/or method that Qwest uses to track or estimate the
amount of local and toll traffic exchanged with a CLEC. Please specifically state
whether each such system and/or method is capable of distinguishing between
IntraLATA and/or InterLATA calls on the one hand, and calls that are in-state versus
out-of-state on the other.
19. Please state whether Qwest is aware of any state commission that has required
separate trunk groups for transit traffic. If your answer is anYthing other than an
unqualified "" please identify each state that Qwest believes has required separate
trunk groups for transit traffic and provide a compete citation to such order.
20. Does Qwest contend that the costs it incurs in originating a call to a Level 3 customer
differ in any respect whatsoever based upon the physical location of the Level 3
customer? If Qwest responds to the above question with anYthing other than an
unequivocal "" please provide a detailed explanation of how the location of Level
s customer on Level3's side of the POI could affect Qwest's costs. Include in that
explanation all cost studies and any other documentation in your possession that you
believe provides support for your position.
21. Does Qwest offer any kind of foreign exchange ("FX") service in this state? If so
please provide a service description (including, but not limited to, tariff pages) for
each such service.
22. Unless your answer to Question #21 above was an unqualified "" please identify:
a. the number of customers in this state who subscribe to or purchase Qwest's FX
servIce;
b. the number of FX lines that Qwest provides in this state;
c. how long FX service has been available from Qwest; and
d. the number of ISPs to whom Qwest provides such service.
23. Please state whether Qwest offers any FX Like Service, other than service
specifically described as Foreign Exchange. If the answer is anYthing other than an
unqualified "" please state the name of each such FX-Like Service and provide
service descriptions (including, but not limited to, tariff pages) for each such FX-like
servIce.
24. Unless your answer to Question #23 above was an unqualified "" please identify:
LEVEL 3 COMMUNICATIONS, LLC'S FIRST SET OF INTERROGATORIES, REQUESTS
FOR PORDUCTION OF DOCUMENTS, AND REQUESTS FOR ADMISSIONS TO QWEST
CORPORA TION-8
a. the number of customers in this state who subscribe to or purchase each of the
FX - Like Services identified in response to the preceding questions;
b. the number of lines in this state over which Qwest provides each of the FX-Like
Services identified in response to the preceding questions;
c. how long each FX - Like Service has been available from Qwest; and
d. the number ofISPs who purchase each of the FX-Like Services identified in
response to the preceding questions.
25. With respect to Qwest's FX and FX-Like services:
a. Please explain the circumstances under which calls from a subscriber to Qwest
FX or FX-like service are rated as local versus toll, and provide all documentation
supporting your answer.
a. Please explain the circumstances under which calls to a subscriber to Qwest FX or
FX -like service are rated as local versus toll, and provide all documentation
supporting your answer.
26. Please state whether Qwest or any Qwest affiliate has ever billed or demanded
payment of access charges from an incumbent LEC for calls originated by Qwest'
end user to an incumbent LEC' s FX or FX - Like customer.
27. Please state whether Qwest has ever billed or received reciprocal compensation or
other terminating compensation for calls received from an incumbent LEC or any
CLECs for termination to Qwest's FX or FX-like customers? Please explain your
answer, including but not limited to (a) the dates upon which you first began billing
incumbent LECs or CLECs for such compensation; (b) the amount of compensation
received from incumbent LECs and CLECs; and (c) describe any changes you may
have made to your billing policies with respect to calls terminating to your FX or FX-
like customers.
28. Are there any circumstances in which Qwest has paid access charges to the
originating carrier for a call originated by another carrier and terminated to a Qwest
FX or FX-like customer? If your answer is anYthing other than an unequivocal "
please describe all circumstances under which Qwest has made such payments.
29. Please state whether Qwest knows, or has reason to believe, that any independent
LEC with whom Qwest has EAS arrangements provide FX or FX Like Service that
permits customers physically located in another rate center to be assigned a number
that is local to the rate center included in Qwest's EAS area.
30. Please provide Qwest's definition ofFX service and provide the source for that
definition. Is it true that Qwest's FX Service allows the customer to make calls to an
LEVEL 3 COMMUNICATIONS, LLC'S FIRST SET OF INTERROGATORIES, REQUESTS
FOR PORDUCTION OF DOCUMENTS, AND REQUESTS FOR ADMISSIONS TO QWEST
CORPORA TION-
exchange outside of the Qwest customer s home exchange without incurring a toll
charge? If not, please explain.
31. Does Qwest treat FX service associated with Broadband Data, and FX service
associated with voice service, differently? If yes, please explain why there are two
such differences.
32. Please provide Qwest's definition of "interexchange" service when assessing charges
to local exchange customers for such a call, and provide the source for such
definition.
33. Is it Qwest's position that access charges should apply to all interexchange services?
If not, please explain.
34. Please provide Qwest's definition of a "local" call when assessing charges (such as
message unit or similar charges) to local exchange customers for such a call, and
provide the source for this definition.
35. Please provide Qwest's definition of a "toll" call when assessing charges to local
exchange customers for such a call, and provide the source for this definition.
36. Please describe the facilities (switches, optical fiber, multiplexer, etc.) that Qwest
uses or expects to use in delivering traffic from its end users to Level 3. Assume for
purposes of this question that Level 3 and Qwest interconnect at a single POI in a
LATA and that Qwest is responsible for delivering its originated traffic to that POI.
37. Please state whether the facilities Qwest uses or expects to use in delivering traffic
from its end users to Level 3 as stated above differ in any way based on whether the
traffic is classified as "local" or "toll." If your answer is anYthing other than an
unqualified "" please explain in detail the basis for your answer.
38. Please describe the facilities (switches, optical fiber, multiplexer, etc.) that Qwest
uses or expects to use in delivering traffic from Level 3 to Qwest's end users.
Assume for purposes of this question that Level 3 and Qwest interconnect at a single
POI in a LATA and that Level 3 is responsible for delivering its originated traffic to
that PO I.
39. Please state whether the facilities Qwest uses or expects to use in delivering traffic
from Level 3 to Qwest's end users as stated above differ in any way based on whether
the traffic is classified as "local" or "toll." If your answer is anYthing other than an
unqualified "" please explain in detail the basis for your answer.
40. With how many CLECs in Idaho does Qwest exchange traffic (that is, CLECs with
their own switches, as opposed to resellers)?
41. How many physical POls exist in Idaho between Qwest and CLECs?
LEVEL 3 COMMUNICATIONS, LLC'S FIRST SET OF INTERROGATORIES, REQUESTS
FOR PORDUCTION OF DOCUMENTS, AND REQUESTS FOR ADMISSIONS TO QWEST
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,42. With how many CLECs in Idaho does Qwest assign traffic to different
jurisdictional/rating categories based on PIU/PLU or similar factors?
43. How many CLECs in Idaho connect to Qwest's network by means of (a) a Qwest-
supplied entrance facility running between Qwest's network and a CLEC switch; (b)
a CLEC-supplied facility delivered to Qwest's network at or near a Qwest central
office building; or (c) some other means?
REQUEST FOR ADMISSIONS
Please admit the following:
1. The location of the PO I between Qwest and Level 3 in Idaho does not determine
whether Qwest has an obligation to pay reciprocal compensation to Level 3 for Level
3' s transport of Qwest' s traffic.
2. The location of the Level3's switch in Idaho does not determine whether Qwest has
an obligation to pay reciprocal compensation to Level 3 for Level 3' s transport of
Qwest's traffic.
3. Qwest currently has interconnection agreements with one or more CLECs in Idaho
under which those CLECs are permitted to carry mixed intraLA T A interexchange
and inter LA T A interexchange traffic on the same trunk groups.
4. Qwest currently has interconnection agreements with one or more CLECs in Idaho
under which Qwest provides transit traffic connection for those CLECs to other
carrIers.
5. Qwest currently has agreements with one or more other incumbent local exchange
carriers in Idaho under which Qwest provides transit traffic connection for those
incumbent local exchange carriers to other carriers. Customers of Qwest's own Idaho
intrastate FX service do not pay toll charges on their FX interexchange calls
regardless of the distance of the call.
6. Qwest's position is that Voice over Internet Protocol traffic is subject to carrier access
charges, regardless of the origination and termination points of the call.
7. Qwest's position is that Voice over Internet Protocol traffic is subject to carrier access
charges only if the traffic originates in one LATA and terminates in another.
8. Qwest does not currently pay carrier access charges to other carriers for any of its
own Voice over Internet Protocol services.
9. Qwest currently offers QwestCID OneFlexTM Voice over Internet Protocol services
within Idaho which provides customers "the option of choosing up to five additional
phone numbers (virtual numbers) that will ring to your phone. Calls placed to a
LEVEL 3 COMMUNICATIONS, LLC'S FIRST SET OF INTERROGATORIES, REQUESTS
FOR PORDUCTION OF DOCUMENTS, AND REQUESTS FOR ADMISSIONS TO QWEST
CORPORATION-II
virtual phone number will ring the same phone as calls placed to your primary phone
number. A virtual phone number can be beneficial if you have colleagues, friends or
family living outside your local calling area. You could request a virtual number
within their area and the people who live in that local calling area can call you for a
price of a local phone call."
1 O. Qwest currently offers QwestCID OneFlexTM Voice over Internet Protocol services
within Idaho that provide "Virtual Numbers" which Qwest describes as follows:
Virtual Numbers are alias phone numbers that can be associated with your
OneFlexTM phone number. Your friends and family can dial your Virtual phone
number and avoid incurring long-distance charges. For example, if you live in
Denver and your primary # is 303.xxx.xxxx and your family lives in Omaha, your
family has to call long-distance. With OneFlex, you can get a virtual phone
number assigned to your account with an Omaha area code, so your family
doesn t have to pay long-distance charges.
You can have up to 5 Virtual Phone Numbers attached to one primary OneFlex
phone number.
11. Federal law currently does not permit the imposition of carrier access charges on
information services.
12. Interconnection contract language should be as consistent as possible with applicable
federal law and regulations.
13. Wireline local exchange services offered in Qwest's 14-state area are provided
through legal entities which operate within authorized regions subject to regulation by
each state in which they operate and by the Federal Communications Commission.
14. The Qwest regulated subsidiary which provides wire line local exchange services in
the State of Colorado is a different subsidiary of Qwest than the Qwest subsidiary
which provides wire line local exchange services in the State of Idaho.
15. Qwest has transported VoIP traffic over its network in the State of Idaho. Qwest or
Qwest's affiliates have carried VoIP traffic to or from their own customers in the
State of Idaho.
16. While the deployment of VoIP will result in increased competition for Qwest's core
wireline voice services, it also presents growth opportunities for Qwest to develop
new products for its customers.
17. Qwest favors federal and state legislative and regulatory policies which support the
development of facilities-based competition.
18. The FCC's rule defining the "telecommunications" subject to reciprocal
compensation is stated at 47 CFR ~ 51.701 (b).
LEVEL 3 COMMUNICATIONS, LLC'S FIRST SET OF INTERROGATORIES, REQUESTS
FOR PORDUCTION OF DOCUMENTS, AND REQUESTS FOR ADMISSIONS TO QWEST
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19. FCC Rule 47 CFR ~ 51.701 (b) makes no reference of any kind or in any way to a
category of traffic known as "local."
20. The Communications Act of 1934, as amended, contains no definition of "local"
telecommunications
, "
local" calling, or "local" exchange areas.
21. Qwest's end office and tandem switches do not store any information indicating the
address or location of any end user s premises.
22. Qwest's end office and tandem switches route traffic to other switches and/or to end
users on the basis of the dialed telephone number, without any reference to
information regarding the address or location of any end user s premises.
23. Qwest's end office switches determine whether to route a dialed call to an IXC on the
basis of the telephone number dialed, and not on the basis of any information
regarding the address or location of any end user s premises.
24. All calls to ISPs for purposes of Internet access are subject to the exclusive
jurisdiction of the FCC.
Erik Cecil
Regulatory Counsel
[phone] (voice)
E- Mail :erik.cecil~leve13 .com
Level 3 Communications, LLC
1025 Eldorado Boulevard
Broomfield CO 80021
[phone] (facsimile)
Date: June 3, 2005
Respectfully submitted
LEVEL 3 COMMUNICATIONS, LLC.
By:
DeanJ. Miller, (ISB No. 1968)
McDevitt & Miller LLP
420 West Bannock Street
O. Box 2564, Boise-83701
Boise, Idaho 83702
Tel: [phone]
Fax: [phone]
ioe~mcdevitt- miller .co m
Counsel to Level 3 Communications, LLC
LEVEL 3 COMMUNICATIONS, LLC'S FIRST SET OF INTERROGATORIES, REQUESTS
FOR PORDUCTION OF DOCUMENTS, AND REQUESTS FOR ADMISSIONS TO QWEST
CORPORA TION-I3
CERTIFICATE OF SERVICE
I hereby certify that on June 03, 2005, I caused to be served a true and correct copy of the
foregoing document, by the methode s) indicated, upon:
Mary S. Hobson
STOEL RIVES LLP
101 So. Capitol Blvd., Suite 1900
Boise, Idaho 83702
mshobson~stoel.com
Attorneys for Qwest Corporation
Hand Delivered
Federal Express
S. Mail
T elecopy
Yf 4 ~Sf?/f-~df/
LEVEL 3 COMMUNICATIONS, LLC'S FIRST SET OF INTERROGATORIES, REQUESTS
FOR PORDUCTION OF DOCUMENTS, AND REQUESTS FOR ADMISSIONS TO QWEST
CORPORA TION-I4