20090428360 to QWE 1-4.pdf

BEFORE THE IDAHO PUBLIC UTILITIES COMMISSION
2009 APR 28 AM 9: 36
IN THE MATTER OF QWEST
CORPORATION'S PETITION FOR
APPROVAL OF NON-IMPAIRD WIRE
CENTER LISTS PURSUANT TO THE
TRIENNIAL REVIEW REMAND ORDER
Case No. QWE-T-08-07
360's First Set of Discovery Responses to
Qwest,
GENERAL OBJECTIONS TO ALL DATA REQUESTS
1. 360networks (USA) inc. ("360") objects to the Requests to the extent they
are vague, over-broad and/or unduly burdensome.
2. 360 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 proprieta.
3. 360 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. 360 objects to the Requests to the extent that they seek a legal conclusion.
ADDITIONAL OBJECTIONS
Subject to, and without waiving, the foregoing objections, 360 provides the
following additional question specific objections.
360's Responses to Qwest's 1st Set Data Requests - 1 -
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.
Response:
Michel Singer Nelson is the respondent to all data requests below.
360's Responses to Qwest's 1 st Set Data Requests - 2 -
2. As of December 31, 2007, please provide the following pertning to any of your
business operations in Idaho:
(a) a detailed list of all services obtaned 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 (4/13/09):
(a) 360 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
360), and requests an analysis that has not been performed at this time.
(b) 360 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
360), requests a work product that does not exist at this time, and requests
information that is irrelevant to this proceeding.
Response (4/27/09)
Subject to and without waiver of the objections, 360 responds as follows, upon
information and belief:
(a) With regard to the two wire centers at issue in this case, Boise Main and Boise
West, 360 only purchased local interconnection trs (LIS) from Qwest as of December
31,2007. 360 purchased no QPP, QLSP, Unbundled loops or EELs in these wire centers
durng the relevant time period.
360's Responses to Qwest's 1 st Set Data Requests - 3 -
(b) With regard to the two wire centers at issue in this case, Boise Main is the
only wire center where 360 purchased LIS.
360's Responses to Qwest's 1st Set Data Requests - 4-
..
3. Please provide the circuit id for each Unbundled Loop and each EEL identified in
response to Request 2(a).
Objection (4/13/09):
360 objects to ths request as it is unduly burdensome, seeks information that
should already be in Qwest's possession (Qwest should know the circuit ID ofthe
elements it sells to 360), requests an analysis that has not been performed at ths
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).
Response (4/27/09):
Subject to and without waiver ofthe objections, see Response to Request No.2,
no responsive information exists.
360's Responses to Qwest's 1 st Set Data Requests - 5 -
4. Please provide the telephone number for each QPP and each QLSP identified in
response to Request 2(a).
Objection (4/13/09):
360 objects to ths request as it is unduly burdensome, seeks information that should
aleady be in Qwest's possession (Qwest should know the circuit ID of the elements it
sells to 360), 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 360 perform this analysis during the course of this case, it
wil provide the information.
Response (4/27/09):
Subject to and without waiver of the objections, see Response to Request No.2, no
responsive information exists.
Dated this 27th day of April, 2009.
360networks (USA) inc.
fs/Michel Singer Nelsonl
Michel Singer Nelson
Associate General Counsel
303 8545513 (voice)
mnelson(£360.net
360's Responses to Qwest's 1 st Set Data Requests - 6 -
.' . 'r -
QWE-T-08-07
Certificate of Service
I hereby certify that a tre and correct copy of the forgoing set of Discovery
Responses was served on ths :J7:i day of April, 2009 on the following individuals:
Jean D. Jewell
Idaho Public Utilties Commission
472 West Washington Street
P.O. Box 83720
Boise, ID 83702
Weldon Stutzan
Deputy Attorney General
Idaho Public Utilties Commission
472 W. Washington
P.O. Box 83720
Boise,ID 83720-0074
Alex Duae
Corporate Counsel, Qwest
421 Sw Oak St. 810
Portland, OR 97204
Douglas K. Denney
Director, Costs & Policy
Integra Telecom
730 Second Avenue S., Suite 900
Minneapolis, MN 55402
Adam L. Sherr
Corporate Counsel, Qwest
1600 7th Avenue, Room 3206
Seattle, W A 98191
Mar S. Hobson (lSB No. 2412)
Attorney for Qwest
999 Main Suite 1103
Boise, ID 83702
By:!!i?L~
Document Specialist