20020911First Request to Qwest.doc

JOHN R. HAMMOND
DEPUTY ATTORNEY GENERAL
IDAHO PUBLIC UTILITIES COMMISSION
PO BOX 83720
BOISE, IDAHO 83720-0074
[phone]
IDAHO BAR NO. 5470

Street Address for Express Mail:
472 W. WASHINGTON
BOISE, IDAHO 83702-5983

Attorney for the Commission Staff

BEFORE THE IDAHO PUBLIC UTILITIES COMMISSION

IN THE MATTER OF THE APPLICATION OF QWEST CORPORATION AND MCLEODUSA FOR APPROVAL OF AN AMENDMENT TO AN EXISTING INTERCONNECTION AGREEMENT PURSUANT TO 47 U.S.C. § 252(e).
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CASE NO. QWE-T-00-7

IN THE MATTER OF THE JOINT APPLICATION OF QWEST CORPORATION AND ESCHELON TELECOM, INC. FOR APPROVAL OF AN AMENDMENT TO AN INTERCONNECTION AGREEMENT PURSUANT TO 47 U.S.C. § 252(e).
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CASE NO. QWE-T-00-13
IN THE MATTER OF THE JOINT APPLICATION OF QWEST CORPORATION AND COVAD COMMUNICATIONS COMPANY FOR APPROVAL OF AN AMENDMENT TO AN EXISTING INTERCONNECTION AGREEMENT PURSUANT TO 47 U.S.C. § 252(e).
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CASE NO. USW-T-99-3

FIRST PRODUCTION REQUEST OF THE COMMISSION STAFF TO QWEST

The Staff of the Idaho Public Utilities Commission, by and through its attorney of record, John R. Hammond, Deputy Attorney General, requests that Qwest (Qwest; Company) provide the following documents and information, pursuant to Rule 225 of the Idaho Public Utilities Commission’s Rules of Procedure, IDAPA 31.01.01, on or before WEDNESDAY,
OCTOBER 9, 2002.
This Production Request is to be considered as continuing, and PacifiCorp is requested to provide, by way of supplementary responses, additional documents that it or any person acting on its behalf may later obtain that will augment the documents produced.
For each item, please indicate the name of the person(s) preparing the answers, along with the job title of such person(s) and the witness who can sponsor the answer at hearing. For all responses to the following requests, please provide all workpapers, diskettes (3.5 in.) and all underlying formulas in Excel (version 5) language.

Request No. 1: Please provide a copy of any agreements or contracts which these negotiated agreements in Case No. QWE-T-00-7, QWE-T-00-13 and USW-T-99-3 replace, supersede or terminate, such as each of the “terminated agreements” identified in section 3.(b) of the Eschelon agreement. (QWE-T-00-13).

Request No. 2: On page 5 of the W. Clay Deanhardt affidavit filed with the Minnesota Public Utilities Commission on June 12, 2002 in Docket No. P-421/CI-01-1371; OAH No. 7-2500-14486-2 is a reference to “11 non-public agreements that Qwest entered into with CLEC’s.” Please provide copies of each of these agreements.

Request No. 3: The affidavit of Deanhardt and an affidavit of Blake O. Fisher, filed on the same day in the same proceeding, refers to an oral agreement between Qwest and McLeodUSA that provided McLeodUSA with discounts of up to 10% on its purchases from Qwest. The Fisher affidavit describes the circumstances leading to the oral agreement and the terms of the agreement. Does Qwest dispute any of the items included in the Fisher affidavit, and if so, please identify which items are disputed and clarify Qwest’s position on the item. Why was the oral agreement with McCleodUSA agreement not reduced to writing?

Request No. 4: For all agreements, including those provided in response to Question 1 and 2, please identify the date the agreement became effective, and a date of termination, if applicable.

Request No. 5: Please provide non-redacted versions of all agreements. (Requests for confidential treatment of submitted materials will be handled in accordance with the Commission’s Rules of Procedure.)

Request No. 6: Please provide copies of any other agreement that has been identified or alleged to be an agreement that should have been filed with a state utility regulatory commission by the Commission, Commission Staff, or administrative law judge or other commission authority of any other state regulatory agency within Qwest’s 14 state region.

Dated at Boise, Idaho, this day of September 2002.

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John R. Hammond
Deputy Attorney General

Technical Staff: Wayne Hart

i:umisc/prdreg/Qwet00.7 Qwet00.13 Uswt99.3jhwh

FIRST PRODUCTION REQUEST 1 SEPTEMBER 11, 2002
TO QWEST