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Home My WebLink About20090529Integra to QWE 5.pdfriegra' TELECOM May 28,2009 Via Overnight 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: -.- r~ \: \ ',\l ~r"~',Y-"-;i, (,.~, \,t , ~f' 9~ \ l\ lß~~ \-f\ ~ 2 S Integra Telecom 6160 Golden Hills Drive Golden Valley, MN 55416 ww.integratelecom.com Enclosed for filing are three copies of Integra's Second Set of Discovery Responses to Qwest. Please feel free to contact me should you have any questions. Enclosures Sincerely, ~KimWaf!~ Legal & Regulatory Administrator Integra Telecom 763-745-8468 (Direct) 763-745-8459 (Dept. Fax) Kim. WagnerCfintegratelecom.com cc: See Attched Certificate of Service REeF i\/r: r~: BEFORE TH IDAHO PUBLIC UTILITIES COMMSSION ZOû9 lli'r~.V,. ,2g .- AM 9: r 4 IN THE MATTER OF QWEST CORPORATION'S PETITION FOR APPROVAL OF NON-IMP AID WI CENTER LISTS PURSUANT TO THE TRINNIAL REVIEW REMA ORDER Case No. QWE- T-08-07 Integra's Second Set of Discovery Responses to Qwest GENERA 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 inormation subject to the attorney-client privilege, work product doctrine, or any other privilege recognzed by the State of Idaho and inormation that is trade secret, confdential, sensitive, competitive in natue or proprieta. 3. Integra objects to the Requests to the extent that they seek inormation 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. DATA REQUESTS 5. Please confir that the data provided in your Highly-Confdential 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 December 3 l, 2007. If you canot confrm the identified circuits were in service on December 3 l, 2007, please provide the date on which you can confrm these circuits were in service. Integra's Responses to Qwest's 2nd Set Data Requests - 1 - Response: The data provided in Integra's Highly-Confidential response to Qwest data request NO.3 was intended to reflect, as closely as possible, circuits in service on December 31, 2007. See also the Direct Testimony of Douglas Denney, pp. 33-35. Respondent: Douglas Denney Dated ths 28th day of May, 2009. C\o K.Denney D' ctor, 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 2nd Set Data Requests - 2- BEFORE TH IDAHO PUBLIC UTILITIES COMMSSION IN THE MATTER OF QWEST CORPORATION'S PETITION FOR APPROVAL OF NON-IMPAIRD WI CENTER LISTS PURSUANT TO THE TRINNIAL REVIEW REMAND ORDER Case No. QWE-T-08-07 CERTIICATE OF SERVICE I hereby certif that thee tre and correct copies of the foregoing Integra's Second Set of Discovery Responses to Qwest were fied on May 28,2009, with: VI OVERNGHT MA: Jean D. Jewell Idaho PUC 472 West Washington Street Boise, il 83702 and served on May 28,2009 upon the individuals listed below. VI EMA AN/ORU.S.MA: Mar S. Hobson 999 Main, Suite i 103 Boise, il 83702 Telephone: 208.385.8666 Mary.hobson§gwest.com Adam L. Sherr Corporate Counsel Qwest Corporation 1600 7th Avenue, Room 3206 Seattle, WA 98191 Adam.sherr(ggwest.com Michel Singer-Nelson Associate General Counsel 360networks 867 Coal Creek Circle, Suite 160 Louisville, CO 80027 mnelson(g3 60 .net Weldon Stutzan Deputy Attorney General Idaho Public Utilities Commission 472 West Washington P.O. Box 83720 Boise, il 83720-0074 Weldon. stutzantiuc.idaho. gov Alex Duare Alex. DuarteØlgwest.com ~~Lega andRe~~ Integra Telecom