20090413Integra to QWE 1-4.pdf

tiegra
TELECOM ~l t: Gi: t\ \f t
Integra Telecom
6160 Golden Hills Drive
Golden Valley, MN 55416
ww.integratelecom.com
iû09 ~lR \:3 M' 9~ \ 9
April 10, 2009
Via Overnight Delivery
Jean D. Jewell, Secretar
Idaho Public Utilties Commission
472 West Washington
Boise, ID 83702-5983
RE: Docket No. QWE-T-08-07
Dear Ms. Jewell:
Enclosed for fiing are three copies of Integra's First Set of Discovery Responses to
Qwest.
Please feel free to contact me should you have any questions.
Sincerely,
¥Kim Wagner ~
Legal & Regulatory Administrator
Integra Telecom
763-745-8468 (Direct)
763-745-8459 (Dept. Fax)
kkwagner(fintegratelecom.com
Enclosures
cc: See Attached Certificate of Service
CERTIFICATE OF SERVICE
I hereby certify that three tre and correct copies of the foregoing Integra's First Set of
Discovery Responses to Qwest were filed on April 10,2009, with:
VIA OVERNGHT MA:
Jean D. Jewell
Idaho PUC
472 West Washington Street
Boise,ID 83702
Telephone: [phone]
Fax: [phone]
:;e:...0."-0'::-c.:-r¡
and served on April 10, 2009 upon the following:~~..
VI EMAIL AND/OR U.S. MAIL: \.
Mary S. Hobson
999 Main, Suite 1103
Boise, ID 83702
Telephone: [phone]
Mary.hobsontßqwest.com
Adam L. Sherr
Corporate Counsel
Qwest Corporation
1600 7th Avenue, Room 3206
Seattle, W A 98191
Adam.sherrtßqwest.com
Michel Singer-Nelson
Associate General Counsel
360networks
867 Coal Creek Circle, Suite 160
Louisvile, CO 80027
mnelsontß360.net
Weldon Stutzan
Deputy Attorney General
Idaho Public Utilities Commission
472 West Washington
P.O. Box 83720
Boise, ID 83720-0074
Weldon. stutzantßpuc.idaho. gov
n-.Cr:1\1l\ t:.,i 'J".~ l';
BEFORE THE IDAHO PUBLIC UTILITIES COMMISSION
2Û09 ~PR 13 AM 9: \ 9
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
Integra's First Set of Discovery Responses
to Qwest
GENERAL OBJECTIONS TO ALL DATA REQUESTS
1. Integra objects to the Requests to the extent they are vague, over-broad
and/or unduly burdensome.
2. Integra objects to the Requests to the extent they seek information subject
to the attorney-client privilege, work product doctrine, or any other privilege recognzed
by the State of Idaho and information that is trade secret, confidential, sensitive,
competitive in nature or proprietary.
3. Integra objects to the Requests to the extent that they seek information that
is not relevant or reasonably calculated to lead to the discovery of admissible evidence.
4. Integra objects to the Requests to the extent that they seek a legal
conclusion.
ADDITIONAL OBJECTIONS
Subject to, and without waiving, the foregoing objections, Integra provides the
following additional question specific objections.
Integra's Responses to Qwest's 1 st Set Data Requests - 1 -
DATA REQUESTS
I . 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.
Response:
Douglas Denney is the respondent to all data requests below.
Integra's Responses to Qwest's 1 st Set Data Requests - 2 -
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,
DS1, DS3), and EELs; and
(b) the Qwest wire center in which the services identified in Request 2(a) were
located.
Objection:
(a) Integra objects to this request as it is unduly burdensome, seeks information
that should already be in Qwest's possession (Qwest should know what it sells
to Integra), and requests an analysis that has not been performed at this time.
(b) Integra objects to this request as it is unduly burdensome, seeks information
that should already be in Qwest's possession (Qwest should know where it
sells to Integra), requests a work product that does not exist at this time, and
requests information that is irrelevant to this proceeding.
Integra's Responses to Qwest's 1 st Set Data Requests - 3 -
3. Please provide the circuit id for each Unbundled Loop and each EEL identified in
response to Request 2(a).
Objection:
Integra objects to this request as it is unduly burdensome, seeks information that
should already be in Qwests possession (Qwest should know the circuit ID ofthe
elements it sells to Integra), requests an analysis that has not been performed at
this time, and requests information that is neither relevant nor likely to lead to the
discovery of admissible evidence (e.g. there are only two wire centers at issue in
this proceeding).
Integra's Responses to Qwest's 1 st Set Data Requests - 4 -
4. Please provide the telephone number for each QPP and each QLSP identified in
response to Request 2(a).
Objection:
Integra objects to this request as it is unduly burdensome, seeks information that should
already be in Qwest's possession (Qwest should know the circuit ID of the elements it
sells to Integra), requests an analysis that has not been performed at this time, and
requests information that is neither relevant nor likely to lead to the discovery of
admissible evidence (e.g. there are only two wire centers at issue in this proceeding).
Without waiving the objection, should Integra perform this analysis during the course of
this case, it wil provide the information.
Integra's Responses to Qwest's 1 st Set Data Requests - 5 -
RESPONSE
To all of the above requests and based on the above objections, Integra responds that it
has no responsive information to provide at this time. Without waiving the objection, if
Integra should pedorm analysis relevant to the above questions during the course of this
case, it wil provide or supplement its response.
Dated this 10th day of April, 2009
Douglas K. Denney
Director, Costs & Policy
6160 Golden Hils Drive
Golden Valley, MN 55416
763-745-8462 (Direct)
763-745-8459 (fax)
Company Representative, Integra
Integra's Responses to Qwest's 1 st Set Data Requests - 6-