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Home My WebLink About20070618QWE to ATT 18, 20.pdfMary S. Hobson Attorney & Counselor 999 Main, Suite 1103 Boise, ID 83702 208-385-8666 ! " \:, " , :' ,\~) ' I i I c .' ", ": ,~ '' '" ,,! !" ",, -,' '; 'J June 15 2007 VIA HAND DELIVERY Jean D. Jewell, Secretary Idaho Public Utilities Commission 472 West Washington Boise, ill 83702-5983 RE:Docket No. QWE- T -06- Dear Ms. Jewell: Enclosed for ,filing with this Commission is a copy ofQWEST'S SUPPLEMENTAL 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 Enclosurescc: Service List Mary S. Hobson (ISB. No. 2142) 999 Main, Suite 1103 Boise, ill 83702 Tel: 208-385-8666 mary .ho bson(fYqwestcom Douglas R. M. Nazarian Hogan & Hartson 111 South Calvert Street Baltimore, MD 21202 Tel: (410) 659-2700 drmnazarian~hhlaw.com Idaho Public Utilities Office of the ommlsS/on R E C E , /i~tary JUN 1 5 2007 Boise Idaho Attorneys for Qwest Corporation BEFORE THE IDAHO PUBLIC UTILITIES COMMISSION AT&T COMMUNICATIONS OF THE MOUNTAIN STATES, INC., Complainant,Case No. QWE-06- QWEST CORPORATION, Respondent. QWEST'S RESPONSES TO AT&T'S FIRST SET OF DATA REQUESTS Qwest Corporation ("Qwest") hereby attaches its supplemental responses to interrogatories nos. 18 and 20 of the First Set of Data Requests filed by AT&T Communications of the Mountain States, Inc. ("AT&T"). These responses call for information that Qwest considers confidential will be provided, under separate cover once the parties enter an appropriate protective agreement. Qwest's Supplemental 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 or confidential. DATED this 15th day of June, 2007. Respectfully submitted Mary S. obson (ISB. No. 2142) 999 Main. Suite 1103 Boise, ill 83702 Attorney for Qwest Corporation Qwest's Supplemental 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 15th day of June, 2007 on the following: Jean D. Jewell Hand DeliveryIdaho Public Utilities Commission U. S. Mail 472 West Washington Street Overnight DeliveryO. Box 83720 Facsimile Boise, ill 83702 Email Telephone (208) 334-0300 i iewell~puc.state.id. Molly O'Leary Richardson & O'Leary 515 North 2ih Street O. Box 7218 Boise, Idaho 83707 mo 11 y(fYrichardsonando leary. com Theodore A. Livingston Dennis G. Friedman Mayer, Brown, Rowe & Maw LLP 71 South Wacker Drive Chicago, IL 60606-4637 dfu edman(fYma yerbro wn. com Dan Foley General Attorney & Assistant General Counsel AT&T West O. Box 11010 Reno , Nevada df6929(fYatt.com Don Howell Idaho Public Utilities Commission 472 West Washington Street O. Box 83720 Boise, ill 83702 Don.Howell(fYpuc. idaho. gov 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 bson or Qwest Corporation Qwest's Supplemental Response to AT&T's First Data Requests page 3 Idaho Case No. QWE-06- AT&T 01-018I- INTERVENOR:AT&T Communications of the Mountain States, Inc. REQUEST NO:018I- 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)unbundled network elements (b)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 RES PONSE : 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 SUPPLEMENTAL RESPONSE DATED 06/15/07 Qwest interprets this question as requesting information as to all servcies without regard to which services are the subject of this case or the subject of the purported agreements, and Qwest reserves all such rights and defenses. See Confidential Attachment A. Respondent: Larry Brotherson, Sr. Staff Witnessing Rep., Arturo Ibarra, Lead Finance/Business Analyst and Susan Hutchins, Lead Process Analyst Idaho Case No. QWE-06- AT&T 01-020I- INTERVENOR:AT&T Communications of the Mountain States, Inc. REQUEST NO:020I-S1 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 McLeod Agreement I I I . 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 SUPPLEMENTAL RESPONSE DATED 06/15/07 See Confidential Attachment A. Respondent: Arturo Ibarra, Lead Finance/Business Analyst and Susan Hutchins, Lead Process Analyst Mary S. Hobson Attorney & Counselor 999 Main, Suite 1103 Boise ID 83702 208-385-8666 , i Ii, .:: ;~:; ~, " O,l::U i '" :~; "i;3;:i June 15 2007 VIA HAND DELIVERY PROPRIETARY AND CONFIDENTIAL Ms. Jean Jewell, Secretary Idaho Public Utilities Commission 472 West Washington Street Boise, ill 83720-0074 Re:Confidential Attachments to Qwest Corporation s Responses to AT&T First Set of Data Requests, Case No. QWE-06- Dear Ms. Jewell: Enclosed for filing with this Commission are the confidential attachments (both labeled Confidential Attachment A") to Qwest Corporation s Supplemental Response to AT&T' Data Requests 18 and 20. Also enclosed is an Attorney Certificate in support of this confidential filing. Qwest is providing these attachments with the understanding that they will be reviewed only by members of the Commission Staff and the Commissioners and that it will not be released for review by any other person unless and until the Commission issues its order so directing the disclosure following a hearing on the issue. Qwest intends to serve these confidential attachments on the parties to the above-referenced docket once a suitable protective agreement has been executed. Thank you for your cooperation in this matter. Very truly yours Dc ~~ Mary S. t4son Enclosures Cc Service List ATTORNEY'S CERTIFICATE ;' " QWEST CORPORATION '; ij; l:~) i;i L;:::~~tj , I !(: Docket #QWE-06-.J i i , " '..I :;i This Certificate is made pursuant to Rule 67 of the Idaho Public Utilities Commission Rules of Procedure I.D.A. 31.01.01000. The following attachments to Qwest's Supplemental Responses to AT&T First Set of Data Requests in the above-reference docket are confidential and proprietary: Attachment A to Qwest's Response to AT&T's Interrogatory 10 Attachment A to Qwest's Response to AT&T's Interrogatory 20 These attachments are considered proprietary and confidential due to their sensitive nature as customer records relating to the services, volumes, uses and charges of said customer(s). The undersigned hereby asserts that she is familiar with the material claimed not to be available for public inspection, examination and copying, and that she, in good faith, believes that there is a basis in law for that claim, namely that the information contained therein constitutes a "trade secret" as defined in Idaho Code Section 48-801 and is by virtue the Idaho Trade Secrets Act, Title 48 , Chapter 8, Idaho Code subject to protection. DATED this 15th day of June 2007. Mary S. obson Attorney Representing Qwest Corporation Boise-169450.10029164-00012