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Home My WebLink About20090327QWE 1-4 to 360Networks.pdfRE(~Et Mary S. Hobson Attorney & Counselor 999 Main, Suite 1103 Boise, ID 83702 208-385-8666 2nU9 tiAR 27 AM 8: 5 , February 27,2009 VIA HAND DELIVERY Jean D. Jewell, Secretary Idaho Public Utilities Commission 472 West Washington Boise, ID 83702-5983 RE: Docket No. QWE-T-08-07 Dear Ms. Jewell: Enclosed for filing with this Commission are three (3) copies of Qwest Corporation's First Set of Discovery Requests for 360Networks (USA), Inc. If you have any questions, please contact me. Than you for your cooperation in this matter. Very trl y yours, /;¡ \'\,__ L i,- v; ,~_) Mary S. Hobson Enclosures i-h Mary S. Hobson (ISB. No. 2142) 999 Main, Suite 1103 Boise, ID 83702 Tel: 208-385-8666 mary.hobson(fqwest.com 2UU9 M~R 27 AM 8: 5 , Alex Duarte Corporate Counsel, Qwest 421 Sw Oak St, 810 Portland, OR 97204 Tel: (503) 242-5623 Alex .Duarte(fqwest. com Attorneys for Qwest Corporation BEFORE THE IDAHO PUBLIC UTILITIES COMMISSION IN THE MATTER OF QWEST CORPORATION'S PETITION FOR APPROV AL OF NON-IMP AIRED WIRE CENTER LISTS PURSUANT TO THE TRIENNIAL REVIEW REMAND ORDER Case No. QWE-T-08-07 Qwest Corporation's First Set of Discovery Requests for 360Networks (USA), Inc. Qwest Corporation (Qwest), pursuant to IPUC Rule of Procedure 225, respectfully requests that 360Networks (USA), Inc. provide objections with in 14 days and written responses and responsive documents within 28 days to the following data requests. Qwest's 1 st Set Data Requests to 360Networks - 1 - DEFINITIONS AND INSTRUCTIONS 1. "You," "your" and "360Networks" refer to 360Networks (USA), Inc., ("360Networks") to whom these data requests are directed and any entity or person affiliated with 360Networks, including, without limitation, the parents, predecessors, or successors of360Networks and its past and present employees, officers, directors, shareholders, agents, attorneys, accountants and other personnel and any entity or person acting at the direction of or on behalf of 360Netwroks. Items and information sought in these requests shall include items and information within your possession, control or access or within that of your agents and employees, attorneys, investigators, . and any other person or entity directly or indirectly subject to your control in any way. 2. "Qwest" refers to Qwest Corporation. 3. The term "document" includes all writings of any kind, whether in final or draft form; all records stored by any electronic or mechanical means and capable or translation into written form, and all visible images including but not limited to, letters, memoranda, reports, studies, calendar or diary entries, maps, pamphlets, drafts, notes, charts, tabulations, analyses, statistical or informational accumulations, accounting records of any kind, videotape, magnetic tape, sound or mechanical reproductions. 4. "Communication" shall mean any inquiry, discussion, conversation, meeting, negotiation, agreement, understanding, telephone conversation, letter, note, telegram, facsimile message, electronic mail message, advertisement, or other oral or written exchange of information of any kind whatsoever. Qwest's 1 st Set Data Requests to 360Networks - 2- your answers. Qwest's 1 st Set Data Requests to 360Networks - 3 - 9. If you claim privilege as to any communication as to which information is requested by these requests, or as to any answer requested by these requests, specify the privilege claimed, the communication and/or answer as to which that claim is made, the topic discussed in the communication, and the basis for your claim. 10. If you at any time had possession or control of a document called for under these requests and if such document has been lost, destroyed, purged, or is not presently in your possession or control, describe the document, the date of its loss, destruction, purge, or separation from possession or control, the circumstances surrounding its loss, destructiön, purge or separation from possession or control, and, if applicable, identify the person who currently has possession or control of the document. Qwest's 1 st Set Data Requests to 360Networks - 4 - DATA REQUESTS 1. For each data request issued by Qwest in this case, identify (as defined above) the person or persons responsible for the answer/response to the request. . 2. As of December 31, 2007, please provide the following pertaining to your any of your business operations in Idaho: (a) a detailed list of all services obtained frorr Qwest that were connected and in service on that date including but not limited to QPP, QLSP, Unbundled loops (DSO, DSl, DS3), and EELs; and (b) the Qwest wire center in which the services identified in Request 2(a), were located. 3. Please provide the circuit id for ea.ch Unbundled Loop and each EEL identified in response to Request 2(a). 4. Please provide the telephone number for each QPP and each QLSP identified in response to Request 2(a). Dated this ~ day of March, 2009. (L j( l( . i/ il.-!." t ~_:-.-i r lJ - Mary S. li9bson (ISB. No. 2142) 999 Main. Suite 1103 Boise, ID 83702 Alex Duarte Corporate Counsel, Qwest 421 Sw Oak St, 810 Portland, OR 97204 Attorneys for Qwest Corporation Qwests 1 st Set Data Requests to 360Networks - 5 - .. _I l . CERTIFICATE OF SERVICE I do hereby certify that a true and correct copy ofthe foregoing Qwest Corporation's First Set of Discovery Requests for 360Networks (USA), Inc. was served onthe 27th day of March, 2009 on the following individuals: . Jean D. Jewell Idaho Public Utilities Commssion 472 West Washington Street P.O. Box 83720 Boise, il 83702 Telephone (208) 334-0300 Facsimile: (208) 334-3762 j jewell(ä)puc.state. id. us i Hand Delivery U. S. Mail Overnight Delivery Facsimile Email Weldon Stutzman Deputy Attorney General Idaho Public Utilities Commission 472 W. Washington PO Box 83720 Boise, ID 83720-0074 Email: Weldon.Stutzman(ä)puc.idaho.gov X_Hand Delivery U. S. Mail Overnight Delivery Facsimile Email Douglas K. Denney Director, Costs & Policy Suite 900 730 Second Avenue South Minneapolis, MN 55402 E-mail: dkdenney(0integratelecom.com Hand Delivery ~ U. S.Mail Overnght Delivery Facsimile X_ Email Michael Singer Nelson Associate General Counsel Suite 160 867 Coal Creek Circle Louisvile, CO 80027 E-mail: mnelson(f360.net Hand Delivery _X_ U. S. Mail Overnight Delivery Facsimile -. Email _..(~ l MaryS. Hobson Attorney for Qwest Corporation