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Home My WebLink About20090327QWE 1-4 to Integra.pdfL r: 1\/~_ Ii " Mary S.Hobson Attorney & Counselor 999 Main, Suite 1103 Boise,ID 83702 208~385-8666 2nU9 tU\R 21 M'\ a: 50 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 Integra Telecom of Idaho, Inc. If you have any questions, please contact me. Thank you for your cooperation in this matter. Very truly yours, '/ j ;". 11 '.. I(,llLc!ö!c-e-__-- Mary S. Hobson Enclosures (:;E' Mary S. Hobson (ISB. No. 2142) 999 Main, Suite 1103 Boise, ID 83702 Tel: 208-385-8666 mary.hobson(fqwest. com 2909 ~lAR 21 A.M 8: 50 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 APPROVAL OF NON-IMPAIRED 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 Integra Telecom of Idaho, Inc. Qwest Corporation (Qwest), pursuant to IPUC Rule of Procedure 225, respectfully requests that Integra Telecom ofIdaho, Inc. ("Integra") provide objections with in 14 days and written responses and responsive documents within 28 days to the following data requests. DEFINITIONS AND INSTRUCTIONS 1. "You," "your" and "Integra" refer to Integra Telecom of Idaho, Inc. to whom these data requests are directed and any entity or person affiliated with Integra, Qwest's 1 st Set Data Requests to Integra - 1 - including, without limitation, the parents, predecessors, or successors of Integra 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 Integra. 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 trarislation into written form, and all visible images including but not limited to, letters, memoranda, reports, studies, calendar or diary entries, maps, pamphlets, drafts, notes, chars, 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. 5. "Relating to" shall mean consist of, refer to, reflect or have any legal, logical or factual connection to the matter discussed. Qwest s 1 st Set Data Requests to Integra - 2 - 6. The term "identify" means: With respect to persons: (a) provide the full name; (b) provide business address; ( c) provide business telephone number; (d) provide occupation; (f) provide place of employment and job title. With respect to documents: (a) provide a brief description of the subject mátter ofthe document; (b) provide the date of the document; (c) provide the name(s) of the author(s) of the document; and (d) provide the name(s) of the person in possession of the document. 7. If you canot answer any portion of any of the following requests in full, after exercising diligence to secure the information, so state, and answer to the extent possible, specifying your inability to answer the remainder and stating whatever information or knowledge you have concerning the unanswered portions. 8. These requests shall be deemed to be continuing throughout the course of this action. If at any time after service of your responses hereto and prior to final decision in this action you obtain, generate or become aware of any additional information or document pertaining to these requests, you shall promptly supplement your answers. Qwests 1st Set Data Requests to Integra - 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, destruction, purge or separation from possession or control, and, if applicable, identify the person who currently has possession or control of the document. Qwest's 1st Set Data Requests to Integra - 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 from Qwest that were connected and in service on that date including but not limited to QPP, QLSP, Unbundled loops (DSO, DS 1, 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 each Unbundled Loop and each EEL identified in response to Request 2(a). 4. Please provide the telephone number for each QPP and eachQLSP identified iuresponse to Request 2(a). Dated this _ day of March, 2009. , ./ l ¿ L '\- htJ 2,,_ Mary S. Hpb'son (ISB. No. 2142) 999 Main. Suitell03 Boise, ID 83702 Alex Duarte Corporate Counsel, Qwest 421 Sw Oak St, 810 Portland, OR 97204 Attorneys for Qwest Corporation Qwestsl st Set Data Requests to Integra - 5 - . . ( CERTIFICATE OF SERVICE I do hereby certify that a true and correct copy of the foregoingQwest Corporation's First Set of Discovery Requests for Integra Telecom of Idaho, Inc. was served on the 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 ji ewell(ø,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(ipuc.daho.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 5.5402 E-mail: dkdenney(ãlintegratelecom.com Hand Delivery _~ U.S.Mail Overnight Delivery Facsimile ~ Email Michael Singer Nelson Associate General Counsel Suite 160 867 Coal Creek Circle Louisvile, CO 80027 E~mai1: mnelson(f1360.net Hand Delivery ~ U. S.Mail Overnight Delivery Facsimile _2L Email ¿ L h !. / ~ l/?r2_r.,r~ Mary S. li9bson Attorney for Qwest Corporation