HomeMy WebLinkAbout20070612QWE to ATT 1-31.pdf, ,
Mary S. Hobson
Attorney & Counselor
999 Main, Suite 1103
Boise, ID 83702
208-385-8666
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June 12 , 2007
VIA HAND DELIVERY
Jean D. Jewell, Secretary
Idaho Public Utilities Commission
472 West Washington
Boise, ID 83702-5983
RE:Docket No. QWE-O6-
Dear Ms. Jewell:
Enclosed for filing with this Commission is a copy of QWEST'S RESPONSES TO
AT&T'S FIRST SET OF DATA REQUESTS in the above referenced matter. All
confidential information being provided in response to these requests is being with an
attorney s certificate under separate cover.
If you have any questions, please contact me. Thank you for your cooperation in this
matter.
Very truly yours
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Enclosurescc: Service List
Mary S. Hobson (ISB. No. 2142)
999 Main, Suite 1103
Boise, ID 83702
Tel: 208-385-8666
mary .ho bson(illqwest. com
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Douglas R. M. Nazarian
Hogan & Hartson
111 South Calvert Street
Baltimore, MD 21202
Tel: (410) 659-2700
drmnazarian~hhlaw .com
Attorneys for Qwest Corporation
BEFORE THE IDAHO PUBLIC UTILITIES COMMISSION
AT&T COMMUNICATIONS OF THE
MOUNTAIN STATES, INC.
Complainant,Case No. QWE-O6-
QWEST CORPORATION
Respondent.
QWEST'S RESPONSES TO AT&T'S FIRST SET OF DATA REQUESTS
Qwest Corporation ("Qwest") hereby attaches its responses to the First Set of Data
Requests (Requests to Admit, Interrogatories, and Production Requests) filed by AT&T
Communications ofthe Mountain States, Inc. ("AT&T"
).
Those responses that call for
information that Qwest considers confidential will be provided, under separate cover
once the parties enter an appropriate protective agreement. A proposed protective
agreement has been provided by Qwest to AT&T.
Qwest's Response to AT&T's First Data Requests page 1
Pursuant to this Commission s Order No. 30319, service of these responses is being
made through electronic mail except where attachments are voluminous. Such
attachments are being provided in the form of a compact disc. Confidential information
will also be provided on compact disc.
DATED this 12th day of June, 2007.
Attorney for Qwest Corporation
Qwest's Response to AT&T's First Data Requests page 2
CERTIFICATE OF SERVICE
I do hereby certify that a true and correct copy of the foregoing Responses to AT&T'
First Set of Data Requests was served on the 12th day of June, 2007 on the following:
Jean D. Jewell Hand DeliveryIdaho Public Utilities Commission U. S. Mail472 West Washington Street Overnight DeliveryO. Box 83720 Facsimile
Boise, ID 83702 Email
Telephone (208) 334-0300
i i ewell(2VPuc. state.id. us
Molly O'Leary
Richardson & O'Leary
515 North 27th Street
O. Box 7218
Boise, Idaho 83707
moll y(illri chardsonando leary. com
---1L
Theodore A. Livingston
Dennis G. Friedman
Mayer, Brown, Rowe & Maw LLP
71 South Wacker Drive
Chicago, IL 60606-4637
dfri edman(illma yerbro wn. com
---1L
Dan Foley
General Attorney & Assistant General Counsel AT&T West ---X
O. Box 11010
Reno, Nevada
df6929(illattcom
--X
Don Howell
Idaho Public Utilities Commission
472 West Washington Street
O. Box 83720
Boise, ID 83702
Don.H owell(illpuc. idaho. gov
Hand Delivery (attachments)
U. S. Mail
Overnight Delivery
Facsimile
Email
Hand Delivery
U. S. Mail
Overnight Delivery (attachments)
Facsimile
Email
Hand Delivery
U. S. Mail
Overnight Delivery( attachments)
Facsimile
Email
Hand Delivery
U. S. Mail
Overnight Delivery
Facsimile
Email
Mary S. Hobson
Attorney for Qwest Corporation
Qwest's Response to AT&T's First Data Requests page 3
Idaho
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Case No. QWE-06-11, ,,:; c
AT&T 01-001
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INTERVENOR:AT&T Communications of the Mountain States, Inc.
REQUEST NO:001
For each data request issued by AT&T in this case, identify the person or
persons responsible for the answer to the data request. Please include
each person s name and title.
RESPONSE:
The requested information is included on each Qwest response.
Respondent:Legal
Idaho
Case No. QWE-06-
AT&T 01-002A
INTERVENOR:AT&T Communications of the Mountain States, Inc.
REQUEST NO:002A
Referring to AT&T's data request number 24 , please admit that each
agreement produced by Qwest in response to that request was created and
kept by Qwest in the normal course of business. See, e.
g.,
Joint
Statement of Undisputed Facts, MPUC Unfiled Agreements Case, at ~ 48.
RESPONSE:
Qwest admits that each agreement produced in response to AT&T's data
request number 24 was created and kept by Qwest in the normal course ofbusiness. Qwest denies that ~the oral agreement between McLeod and Qwest
to provide discounts to McLeod on all purchases made from Qwest, entered
into on or about October 26, 2000 and found to exist by the Minnesota
Public Utilities Commission in its Docket No. P-421jC-02-197" was entered
by Qwest and McLeod and kept by Qwest.
Respondent: Larry Brotherson, Sr. Staff Witnessing Rep.
Idaho
Case No. QWE-06-
AT&T 01-003A
INTERVENOR:AT&T Communications of the Mountain States, Inc.
REQUEST NO:003A
Please admit or deny that the specific terms set forth in paragraph 2 of
the document referred to in paragraph 5 of the Definitions and
Instructions as Eschelon Agreement IV did not appear in any other Qwest
interconnection agreement approved by the Idaho Public Utilities
Commission from January 1 , 2000 through March 1 , 2002.
RESPONSE:
Admitted.
Respondent:Larry Brotherson, Sr. Staff Witnessing Rep.
Idaho
Case No. QWE-06-
AT&T 01-004A
INTERVENOR:AT&T Communications of the Mountain States, Inc.
REQUEST NO:004A
Please admit or deny that the specific terms set forth in paragraph 3 of
Eschelon Agreement IV did not appear in any other Qwest interconnection
agreement approved by the Idaho Public Utilities Commission from January
, 2000 through March 1, 2002.
RESPONSE:
Admitted.
Respondent:Larry Brotherson, Sr. Staff Witnessing Rep.
Idaho
Case No. QWE-06-
AT&T 01-005A
INTERVENOR:AT&T Communications of the Mountain States, Inc.
REQUEST NO:005A
Please admit or deny that the terms in paragraph 3 of Eschelon Agreement
IV, including the discount to Eschelon, applied to all purchases made by
Eschelon from Qwest, including but limited to switched access fees and
Eschelon s purchase of interconnection UNEs, tariffed services, and other
telecommunications services, while Eschelon Agreement IV was in effect.
RESPONSE:
Denied. Because Eschelon made no purchases from Qwest in or for Idaho
customers during the relevant time period, the terms and conditions of
Eschelon Agreement IV did not apply to any services purchased by Eschelon
from Qwest in or for customers in the State of Idaho.
Re sponden t :Larry Brotherson , Sr. Staff Witnessing Rep.
Idaho
Case No. QWE-06-AT&T 01-006A
INTERVENOR:AT&T Communications of the Mountain States, Inc.
REQUEST NO:006A
Please admit or deny that the agreement reflected in what is referred to
as McLeod Agreement III in paragraph 5 of the Definitions and Instructions
above applied to McLeod's purchase of unbundled network elements, switched
access, wholesale long distance, and tariffed retail services while McLeod
Agreement III was in effect.
RESPONSE:
Denied. Qwest denies that it entered into the agreement referred to as
McLeod Agreement III in paragraph 5 of the Definitions and Instructions.
Respondent:Larry Brotherson, Sr. Staff Witnessing Rep.
Idaho
Case No. QWE-06-
AT&T 01-007A
INTERVENOR:AT&T Communications of the Mountain States, Inc.
REQUEST NO:007A
Please admit or deny that, pursuant to Eschelon Agreement IV, Qwest agreed
to provide Eschelon with a discount of up to 10% on all of the aggregate
billed charges for all purchases made by Eschelon from Qwest from November
15, 2000 through December 31 , 2005.
RESPONSE:
Qwest denies that it agreed in Eschelon Agreement IV to provide Eschelon
with a discount of up to 10% on all of the aggregate billed charges for
all purchases made by Eschelon from Qwest from November 15, 2000 through
December 31 , 2005. Qwest states that Eschelon Agreement IV was part of a
series of agreements that Qwest and Eschelon entered on or about November
15, 2000 that collectively defined the terms and conditions of theparties' business relationship and that do not separately or individually
encompass the parties ' agreements. Qwest states further that the series
of agreements Qwest and Eschelon entered on or about November 15, 2000 was
terminated as of March 1, 2002 by a superseding agreement that Qwest
produces, and incorporates here by reference, as part of its response tothis Request. See Qwest I s response to AT&T 01-022, Attachment A.
Respondent: Larry Brotherson, Sr. Staff Witnessing Rep.
Idaho
Case No. QWE-06-
AT&T 01-008A
INTERVENOR:AT&T Communications of the Mountain States, Inc.
REQUEST NO:008A
Please admit or deny that Qwest did not make the discounts provided to
Eschelon under Eschelon Agreement IV available to AT&T.
RESPONSE:
Qwest denies that it entered into a "discount" agreement with Eschelon,
and therefore denies that there was any discount that could have or should
have been provided or made available to AT&T.
Respondent: Larry Brotherson, Sr. Staff Witnessing Rep.
Idaho
Case No. QWE-06-
AT&T 01-009A
INTERVENOR:AT&T Communications of the Mountain States, Inc.
REQUEST NO:009A
Please admit or deny that Qwest did not provide to AT&T the rates, terms,
and conditions included in Eschelon Agreement IV.
RESPONSE:
Qwest denies that Escehelon Agreement IV applied to the rates Qwest
charged to customers for products or services in the State of Idaho.
Qwest denies that it entered into a "discount" agreement with Eschelon,
and therefore denies that there was any discount that could have or should
have been provided or made available to AT&T.
Respondent:Larry Brotherson , Sr. Staff Witnessing Rep.
Idaho
Case No. QWE-06-
AT&T 01-010A
INTERVENOR:AT&T Communications of the Mountain States, Inc.
REQUEST NO:010A
Please admit or deny that, independent of any alleged disclosure made in
the MPUC Unfiled Agreements Case, Qwest never informed AT&T of the
discounts provided to Eschelon pursuant to Eschelon Agreement IV while
that agreement was in effect.
RESPONSE:
Qwest denies the characterization of the transactions with Eschelon in
this request for admission and therefore denies this statement.
Respondent: Larry Brotherson, Sr. Staff Witnessing Rep.
Idaho
Case No. QWE-06-
AT&T 01-011A
INTERVENOR:AT&T Communications of the Mountain States, Inc.
REQUEST NO:011A
Please admit or deny that McLeod Agreement III entitled McLeod to a
discount of from 6.5% to 10% on all purchases made from McLeod by Qwest,
including for intrastate access services, depending on the volume of
purchases made by McLeod from Qwest over the course of the year.
RESPONSE:
Qwest denies that McLeod Agreement III , as defined in Definition No.
was formed by Qwest and McLeod and that McLeod Agreement III entitled
McLeod to a discount of from 6.5% to 10% on all purchases made from McLeod
by Qwest in Idaho, including for intrastate access services, depending on
the volume of purchases made by McLeod from Qwest over the course of the
year. Qwest states further that it entered into a series of agreements
with McLeod on or about October 26, 2000 that collectively defined the
terms and conditions of the parties ' business relationship and that do not
separately or individually encompass the parties ' agreements.
Respondent:Larry Brotherson, Sr. Staff Witnessing Rep.
Idaho
Case No. QWE-06-
AT&T 01-012A
INTERVENOR:AT&T Communications of the Mountain States, Inc.
REQUEST NO:012A
Please admit or deny that the rates, terms, and conditions provided to
McLeod pursuant to McLeod Agreement III were not made available to AT&T.
RESPONSE:
Qwest denies that the agreement referred to as McLeod Agreement III in
paragraph 5 of the Definitions and Instructions, if it existed, would have
applied to the rates Qwest charged to customers for products or servicesin the State of Idaho. Qwest denies the remainder of Request 12 and
incorporates here by reference its response to Request
Respondent:Larry Brotherson , Sr. Staff Witnessing Rep.
Idaho
Case No. QWE-06-
AT&T 01-013A
INTERVENOR:AT&T Communications of the Mountain States, Inc.
REQUEST NO:O13A
Please admit or deny that the discounts provided to McLeod pursuant to
McLeod Agreement III were not provided to AT&T.
RESPONSE:
Qwest restates and incorporates here its response to Request 11, above.
Respondent: Larry Brotherson , Sr. Staff Witnessing Rep.
Idaho
Case No. QWE-06-AT&T 01-014A
INTERVENOR:AT&T Communications of the Mountain States, Inc.
REQUEST NO:014A
Please admit or deny that, independent of any alleged disclosure in the
MPUC Unfiled Agreement Case, during the time McLeod Agreement III was in
effect Qwest never informed AT&T of the discounts provided to McLeod
pursuant to that agreement.
RESPONSE:
Qwest restates and incorporates here its response to Request 11, above.
Respondent:Larry Brotherson, Sr. Staff Witnessing Rep.
Idaho
Case No. QWE-06-
AT&T 01-0151
INTERVENOR:AT&T Communications of the Mountain States, Inc.
REQUEST NO:0151
Please identify all services, products, and facilities purchased from
Qwest by Eschelon in Idaho during the period when Eschelon Agreement IV
was in effect, including but not limited to:
(a)
(b)
unbundled network elements
intrastate access services or facilities
(c)
(d)
special access services or facilities
other wholesale products, services, or facilities
(e)other retail services, products, or facilities
RESPONSE:
Not applicable.See Qwest I s response to Request No.5, above.
Idaho
Case No. QWE-06-
AT&T 01-0161
INTERVENOR:AT&T Communications of the Mountain States, Inc.
REQUEST NO:0161
For each service, product, and facility identified in response to data
request number 15, identify with specificity - by tariff number, page
number (s), and section number (s) - the rate or rates specified therefor at
the time of the purchase by Eschelon in Qwest' s relevant intrastate tariff
or tariffs or interconnection agreement with McLeod or Eschelon.
RESPONSE:
Not applicable.See Qwest' s response to Request No.5, above.
Idaho
Case No. QWE-06-
AT&T 01-0171
INTERVENOR:AT&T Communications of the Mountain States, Inc.
REQUEST NO:0171
For each service, product, and facility identified in response to data
request number 15, identify the rate or price paid by Eschelon, and
specify the application of any discount, rebate, or credit provided for
those services, products, or facilities pursuant to the Eschelon Agreement
IV.
RESPONSE:
Not applicable.See Qwest I s response to Request No.5, above.
Re sponden t :Larry Brotherson, Sr. Staff Witnessing Rep. and Legal
Idaho
Case No. QWE-06-
AT&T 01-0181
INTERVENOR:AT&T Communications of the Mountain States, Inc.
REQUEST NO:0181
Please identify all services, products, and facilities purchased from
Qwest by McLeod in Idaho during the period when McLeod Agreement III was
in effect, including but not limited to:
(a)
(b)
unbundled network elements
intrastate access services or facilities
(c)special access services or facilities
(d)
(e)
other wholesale products, services, or facilities
other retail services, products, or facilities
RESPONSE:
Qwest is in the process of gathering the requested data and will provide it
no later than June 15, 2007.
Respondent: Arturo Ibarra, Lead Finance/Business Analyst and Susan Hutchins,
Lead Process Analyst
Idaho
Case No. QWE-06-
AT&T 01-0191
INTERVENOR:AT&T Communications of the Mountain States, Inc.
REQUEST NO:0191
For each service, product, and facility identified in response to data
request number 18, identify with specificity - by tariff number, page
number(s), and section number(s) - the rate or rates specified therefor
at the time of the purchase by McLeod in Qwest' s relevant intrastate
tariff or tariffs or interconnection agreement with McLeod.
RESPONSE:
During the relevant period, all products and services, other than basic local
exchange service, were offered in southern Idaho by Qwest and its predecessor
in interest by catalog and price lists. See Attachments A, Band C for the
archived catalogs and price lists applicable to this request. Qwest tariffs
for all products and services offered in its northern Idaho service territory
and Qwest tariffs relating to basic local exchange service in southern Idaho
are available on file at the Idaho Public Utilities Commission.
Respondent:Legal
Idaho
Case No. QWE-06-
AT&T 01-0201
INTERVENOR:AT&T Communications of the Mountain States, Inc.
REQUEST NO:0201
For each service, product, and facility identified in response to data
request number 18, identify the rate or price charged to and paid by
McLeod, and specify the application of any discount, rebate, or credit
provided for those services, products, or facilities pursuant to McLeodAgreement III.
RESPONSE:
Qwest is in the process of gathering the requested data and will provide it
no later than June 15, 2007.
Respondent: Arturo Ibarra, Lead Finance/Business Analyst and Susan Hutchins,
Lead Process Analyst
Idaho
Case No. QWE-06-AT&T 01-0211
INTERVENOR:AT&T Communications of the Mountain States, Inc.
REQUEST NO:0211
If any McLeod/Eschelon Agreement was terminated prior to its originally
intended expiration date, fully explain the reason for terminating the
Agreement before that date.
RESPONSE:
Qwest objects that this request is vague, overly broad, and unduly
burdensome. Without waiving this objection , Qwest states as follows:
Many of the McLeod and Eschelon agreements themselves or provisions within
the agreements terminated early. The reasons for early termination
include that an agreement or separate provisions within the agreement were
superseded or terminated pursuant to agreements between the parties or
commission orders. Another reason may be that some obligations terminated
by virtue of the expiration of conditions underlying the obligation.
For example, a number of the Eschelon agreements were terminated as of
March 1 , 2002, pursuant to an agreement between the parties of that date.
As another example, a provision in the ATI (Eschelon) agreement relating
to reciprocal compensation was superseded by an interconnection agreement
amendment providing for bill and keep. Specific instances of early
termination can be provided upon specific request.
Respondent:Larry Brotherson , Sr. Staff Witnessing Rep.
Idaho
Case No. QWE-06-AT&T 01-0221
INTERVENOR:AT&T Communications of the Mountain States, Inc.
REQUEST NO:0221
Describe in detail any and all payments made by Qwest to Eschelon or
McLeod, or by Eschelon or McLeod to Qwest, in connection with or in
consideration for terminating any of the McLeod/Eschelon Agreements beforetheir originally intended expiration date. Identify each person with
knowledge of such termination or the reason therefor.
RESPONSE:
Qwest objects to this Request on the grounds that the terms " in connection
with" and "in consideration for" are vague. Subject to and without
waiving the foregoing or any other objection, Qwest states that the terms
of its agreements with Eschelon and McLeod to terminate any agreements
prior to their original expiration dates are set forth in documents that
speak for themselves and are attached as Attachments A, Band
The Qwest employees that participated in negotiations with Eschelon for
the referenced agreement are:
Dana Filip (Crandell)
Gordon Martin
Rich Corbetta
Jim Gallegos
The Qwest employees that participated in negotiations with McLeod for thereferenced agreement are:
Pat Engels
Audrey McKenney
Rich Corbetta
Roy Hoffinger
Respondent:Legal and Larry Brotherson, Sr. Staff Witnessing Rep.
Idaho
Case No. QWE-06-AT&T 01-0231
INTERVENOR:AT&T Communications of the Mountain States, Inc.
REQUEST NO:0231
Identify all persons with knowledge concerning (i) the purchase of
intrastate access services by Eschelon and McLeod during the period when
each McLeod/Eschelon Agreement was in effect; (ii) the rates or prices
paid by McLeod and Eschelon for such services and/or facilities; (iii) the
rates or prices for such services specified in the relevant intrastate
tariff or tariffs or interconnection agreement; and (iv) the rates or
prices charged other carriers for such services including the rates or
prices charged AT&T for such services and/or facilities.
RESPONSE:
Mary Dobesh - McLeod Service Manager
Nancy Batz - McLeod Access Manager
Rita Urevig - Eschelon Service Manager
Laura Stolper - Access Manager
The 2nd level service manager is Jodi Saldivar and the 2nd level access
manager is Linda Downey.
Respondent:Mark Holling, Product Manager
Idaho
Case No. QWE-06-
AT&T 01-024DR
INTERVENOR:AT&T Communications of the Mountain States, Inc.
REQUEST NO:024DR
Please produce true and accurate executed copies of each of the
McLeod/Eschelon Agreements identified in paragraph 5 of the Definitions
and Instructions above.
RESPONSE:
See Attachments A-H. Note that there is no corresponding document that
corresponds to the alleged oral agreement" herein refered to as "McLeod
Agreement III"
Re sponden t :Larry Brotherson, Sr. Staff Witnessing Rep.
Idaho
Case No. QWE-06-AT&T 01-025DR
INTERVENOR:AT&T Communications of the Mountain States, Inc.
REQUEST NO:025DR
Please produce true and accurate copies of the documents admitted as Trial
Exhibits Nos. 200,226,400 and 401J through 480J, inclusive in the MPUCUnfiled Agreements Case. Alternatively, please agree that AT&T can (i)
use the copies of such exhibits produced to it in the MPUC Unfiled
Agreements Case, to the extent they exist, and/or (ii) obtain copies of
said exhibits from the MPUC, and treat such documents as if they had beenproduced here.
RESPONSE:
Qwest responds that AT&T can (i) use the copies of such exhibits produced
to it in the MPUC Unfiled Agreements Case, to the extent they exist,
and/or (ii) obtain copies of said exhibits from the MPUC, and treat such
documents as if they had been produced here.
Respondent:Larry Brotherson , Sr. Staff Witnessing Rep.
Idaho
Case No. QWE-06-
AT&T 01-026DR
INTERVENOR:AT&T Communications of the Mountain States, Inc.
REQUEST NO:026DR
Referring to data requests 15 and 18 above, please produce copies of the
specific tariff pages or other document (s) or agreement (s) (if applicable)
that established the rates or prices that applied to the services,
circuits, or facilities purchased by Eschelon and McLeod from Qwest in
Idaho from January 1, 2000 through March 1, 2002. Alternatively, identify
the tariff pages with specificity or other documents or agreements (if
applicable), if they are publicly available, that established such rates.
RESPONSE:
See Attachment A (McLeod Interconnection Agreement, including Amendments) andAttachment B (Eschelon Interconnection Agreement, including Amendments)
During the relevant period, all products and services, other than basic local
exchange service, were offered in southern Idaho by Qwest and its predecessor
in interest by catalog and price lists. Qwest will supplement this response
with the archived catalogs and price lists applicable to this request, as
soon as they are available. Qwest tariffs for all products and services
offered in its northern Idaho service territory and Qwest tariffs relating to
basic local exchange service in southern Idaho are available on file at the
Idaho Public Utilities Commission.
Respondent:Legal and Larry Brotherson , Sr. Staff Witnessing Rep.
Idaho
Case No. QWE-06-
AT&T 01-027DR
INTERVENOR:AT&T Communications of the Mountain States, Inc.
REQUEST NO:027DR
Please produce copies of all files of the following persons regarding
Eschelon Agreement IV and/or McLeod Agreement III:
(a)Audrey McKenney
(b)Arturo Ibarra
(c)Greg Casey
(d)Judi th Rixe
(e)Kathleen Lucero
(f)Anthony Idaho
RESPONSE:
Qwest obj ects to the characterizations of Eschelon Agreement IV and McLeod
Agreement III and incorporates here by reference its responses to Requests8 and 13, above. Subj ect to and without waiving the foregoing, see
Confidential Attachments A, B , C and D , and Non-Confidential Attachment E
which are being provided on CD.
Respondent: Larry Brotherson, Sr. Staff Witnessing Rep.
Idaho
Case No. QWE-06-
AT&T 01-028DR
INTERVENOR:AT&T Communications of the Mountain States, Inc.
REQUEST NO:028DR
Please produce all documents (such as accounting records or records of
wire transfers) reflecting payments to Qwest by Eschelon for services
provided by Qwest in Idaho during the period when Eschelon Agreement IV
was in effect.
RESPONSE:
Qwest objects to the characterization of Eschelon Agreement IV and
incorporates here by reference its responses to Request 8, above. Qwest
further denies that Qwest provided any discounts to Eschelon in Idaho
pursuant to Eschelon Agreement IV. Subj ect to and without waiving the
foregoing, See Qwest's response to AT&T 01-027 in this docket.
Respondent: Larry Brotherson, Sr. Staff Witnessing Rep.
Idaho
Case No. QWE-06-AT&T 01-029DR
INTERVENOR:AT&T Communications of the Mountain States, Inc.
REQUEST NO:029DR
Please produce all documents (such as accounting records or records of
wire transfers) reflecting payments to Qwest by McLeod for services
provided by Qwest in Idaho during the period when McLeod Agreement III was
in effect.
RESPONSE:
Qwest objects to the characterization of McLeod Agreement III and
incorporates here by reference its responses to Request 6, above. Qwest
further denies that Qwest provided any discounts to McLeod in Idaho pursuant
to McLeod Agreement III. Subject to and without waiving the foregoing, See
Qwest's response to AT&T 01-027 in this docket.
Respondent: Larry Brotherson, Sr. Staff Witnessing Rep.
Idaho
Case No. QWE-06-
AT&T 01-030DR
INTERVENOR:AT&T Communications of the Mountain States, Inc.
REQUEST NO:030DR
Please produce all documents reflecting the discounts that Qwest provided
to Eschelon in Idaho pursuant to Eschelon Agreement IV during the period
when Eschelon Agreement IV was in effect.
RESPONSE:
Qwest objects to the characterization of Eschelon Agreement IV and
incorporates here by reference its responses to Request 8, above. Qwestfurther denies that Qwest provided any discounts to Eschelon in Idaho
pursuant to Eschelon Agreement IV. Subj ect to and without waiving the
foregoing, Qwest is producing copies of all such documents as produced in
the Minnesota PUC Unfiled Agreements Docket. See Qwest I s response to AT&T01-027S1 in this docket.
Respondent: Larry Brotherson, Sr. Staff Witnessing Rep.
Idaho
Case No. QWE-06-
AT&T 01-031DR
INTERVENOR:AT&T Communications of the Mountain States, Inc.
REQUEST NO:031DR
Please produce all documents reflecting the discounts that Qwest provided
to McLeod on services provided by Qwest in Idaho pursuant to McLeod
Agreement III (or any related "take or pay " agreements) during the period
when McLeod Agreement III was in effect.
RESPONSE:
Qwest objects to the characterization of McLeod Agreement III and
incorporates here by reference its responses to Requests 13, above. Qwest
further denies that Qwest provided any discounts to McLeod in Idaho
pursuant to McLeod Agreement III. Subject to and without waiving the
foregoing, Qwest is producing copies of all such documents as produced in
the Minnesota PUC Unfiled Agreements Docket. See Qwest I s response to AT&T
01-027S1 in this docket.
Respondent: Larry Brotherson, Sr. Staff Witnessing Rep.