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Home My WebLink About20050622Qwest revised requests.pdf' PC0kJ w. .L:J L~... ,",.. Mary S. Hobson STOEL RIVES LLP 101 S Capitol Boulevard - Suite 1900 Boise, ill 83702-5958 Telephone: (208) 389-9000 Facsimile: (208) 389-9040 msho bson~stoel. com !LED c;. ') f')L! '). "vv Uh , f t'J. . . ."'"'. A " . "'."'"" HJfld'f' Ii tv iLIr. : ' I IlL . . 'nl iSSION Thomas M. Dethlefs Senior Attorney Qwest Services Corporation 1801 California Street - 10th Floor Denver, CO 80202 Telephone: (303) 383-6646 Facsimile: (303) 298-8197 Thomas .Dethlefs~qw est. com BEFORE THE IDAHO PUBLIC UTILITIES COMMISSION IN THE MATTER OF LEVEL 3 COMMUNICATIONS, LLC'S PETITION FOR ARBITRATION PURSUANT TO SECTION 252(B) OF THE COMMUNICA- TIONS ACT OF 1934, AS AMENDED BY THE TELECOMMUNICATIONS ACT OF 1996, AND THE APPLICABLE STATE LAWS FOR RATE, TERMS, AND CONDITIONS OF INTERCONNECTION WITH QWEST CORPORATION CASE NO. QWE-05- QWEST CORPORATION'S REVISED DISCOVERY REQUESTS TO LEVEL 3 CO MMUNI CA TI 0 NS, LLC Qwest Corporation ("Qwest"), through its undersigned attorneys of record, hereby serve Qwest's revised discovery requests upon Level 3 Communications, LLC ("Level 3" ). The revised requests are attached hereto and are intended to be substituted for the requests bearing the same numbers that were served and filed on June 21 , 2005. DATA REQUEST NO. 18 Assume the same scenario as the prior request, except that instead of the calls going to an ISP in Boise, the calls are routed to a VoIP customer whose VoIP Provider POP is located in Boise and the VoIP Provider receives service from Level 3 , whose Boise-185096.l 0029164-00012 POI is also located in Boise. Assume that the Idaho Falls customer makes 1 000 minutes of calls directed to the VoIP customer, but that the customer accesses the VoIP provider via a local number provided to the VoIP customer that has an NP A/NXX associated with the Idaho Falls LCA. (a)Under Level 3' s proposed interconnection agreement language, what amount would Qwest be required to pay Level 3 for terminating those minutes? (b)Assuming that Qwest's Idaho Falls customer pays for his or her local service on a flat rated basis, would Qwest receive any additional revenues for originating this traffic and delivering it to Level 3's POI in Boise? (c)Under Level 3' s proposed interconnection agreement language, would Level 3 have any financial responsibility for the transporting of the call from the end office serving Qwest's Idaho Falls customer to Level3's POI in Boise? DATA REQUEST NO. 62: Does Level 3 collect and remit state universal fund surcharges to the Idaho Universal Service Fund (USF) for any services that Level 3 provides to its customers in Idaho? If so, for what services? Dated this 22nd day of June, 2005 Mary S. son Stoel Rives LLP Attorneys for Qwest Corporation Boise-185096.l 0029164-00012 CERTIFICATE OF SERVICE I hereby certify that on this 21 st day of June, 2005 , I served the foregoing QWEST CORPORATION'S REVISED DISCOVERY REQUESTS TO LEVEL 3 COMMUNICATIONS, LLC upon all parties of record in this matter as follows: Jean Jewell, Secretary Idaho Public Utilities Commission 472 West Washington Street O. Box 83720 Boise, ill 83720-0074 11 ewell~puc.state.id. us Weldon Stutzman Idaho Public Utilities Commission 472 West Washington Street O. Box 83720 Boise, ill 83720-0074 Telephone: (208) 334-0318 weldon. stutzman~puc. Idaho. gov Dean J. Miller McDevitt & Miller LLP 420 West Bannock Street O. Box 2564 Boise, ill 83702 Erik Cecil Regulatory Counsel Level 3 Communications, LLC 1025 Eldorado Boulevard Broomfield, CO 80021 Boise-185096.l 0029164-00012 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 Drt24ttZ- Brandi L. Gearhart Legal Secretary Stoel Rives LLP