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Home My WebLink About20090504QWE 5 to Integra.pdf,-,""'-"1f) i-L,'" \ "~. -,¡ i_.i . .....~.; Mary S. Hobson Attorney & Counselor 999 Main, Suite 1103 Boise, ID 83702 208-385-8666 1U69 M~\~ - l PM~: 51 May 1, 2009 VIA HAND DELIVERY Jean D. Jewell, Secretary Idaho Public Utilities Commission 472 West Washington Boise, 10 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 Second 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,~~/I~ Enclosures Mary S. Hobson (ISB. No. 2142) 999 Main, Suite 1103 Boise, 10 83702 Tel: 208-385-8666 mary.hobson(q;gwest. com t"¡: .r: 'C-:: ~-,.~1\'- 'l" 20U9M:rf -I PN ~:52 Alex M. Duarte Corporate Counsel Qwest 421 SW Oak St, Room 810 Portland, OR 97204 Tel: (503) 242-5623 Alex.DuarteCigwest. com Attorneys for Qwest Corporation BEFORE THE IOAHO 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 Second 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 of Idaho, Inc. ("Integra") provide objections with in 14 days and written responses 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, 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 Qwest s Second Set Data Requests to Integra - 1 - 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 QwestCorporation. 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, 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. 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; Qwest s Second Set Data Requests to Integra -,2- (f) provide place of employment and job title. With respect to documents: (a) provide a brief description of the subject matter of the document; (b) provide the date of the document; (c) provide the name(s) of the author(s) ofthe document; and (d) provide the name(s) of the person in possession of the document. 7. If you cannot 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 ofthis 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. 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 claim.ed, tIre communication and/or answer as to which that claim is made, the topic discussed in the communication, and the basis for your claim. i O. 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 Qwest s Second Set Data Requests to Integra - 3 - or separation from possession or control, and, if applicable, identify the person who currently has possession or control of the document. DATA REQUESTS 5. Please confirm that the data provided in your Highly-Confidential response to Qwest data request NO.3 of Qwest s First Set of Data Requests lists those circuits that Integra has identified as in service on Oecember 31, 2007 . If you cannot confirm the identified circuits were in service on December 31, 2007, please provide the date on which you can confirm these .. circuits were in service. Dated thisl 5t day of May, 2009. ./ii/t t +6~ Mary S. / son (ISB. No. 2142) 999 Main. uite 1103 Boise, ID 83702 Alex M. Duarte Corporate Counsel Qwest 42LSW Oak St, Room 810 Portland, OR 97204 Attorneys for Qwest Corporation Qwest s Second Set Data Requests to Integra - 4 - CERTIFICATE OF SERVICE I do hereby certify that a true and correct copy of the foregoing QWEST CORPORATION'S SECOND SET OF DISCOVERY REQUESTS FOR INTEGRA TELECOM OF IDAHO, INC. was served on the 1st day of May 1,2009 on the following individuals: Jean D. Jewell Idaho Public Utilities Commission 472 West Washington Street P.O. Box 83720 Boise, il 83702 Telephone (208) 334-0300 Facsimile: (208) 334-3762 jj ewellCmpuc. state.id. us i Weldon Stutzman Deputy Attorney General Idaho Public Utilities Commission 472 W. Washington PO Box 83720 Boise, ID 83720-0074 Email: Weldon.StutzmanCdJpuc.idaho.gov -X Douglas K. Denney Director, Costs & Policy Suite 900 730 Second Avenue South Minneapolis, MN 55402 E-mail: dkdenneyCã)integratelecollcom .lL _x_ Michael Singer Nelson Associate General Counsel Suite 160 867 Coal Creek Circle Louisville, CO 80027 E-mail: mnelson(i360.net .x _x_ Qwest s Second Set Data Requests to Integra - 5 - Hand Delivery U. S. Mail Overnight Delivery Facsimile Email Hand Delivery U. S. Mail" Overnight Delivery Facsimile Email Hand Delivery U. S. Mail Overnght Delivery Eacsimile Email Hand Delivery U. S. Mail Overnight Delivery Facsimile Email L-