BEFORE THE PUBLIC UTILITIES COMMISSION OF THE STATE OF COLORADO
Ruby Ranch Internet Cooperative Association,
Petitioner,
DOCKET NO. 01B-493T
v.
Qwest Corporation,
Respondent.
REQUESTS FOR PRODUCTION OF DOCUMENTS
The Ruby Ranch Internet Cooperative Association (Coop), pursuant
to Colorado Commission Rule 77(b), requests that Qwest Corporation
(Qwest) produce the following documents within ten days. These
requests are made with respect to
definitions
provided herewith.
- The nondisclosure agreement referred to by Qwest at
page 5 of its November 19,
2001 Response herein.
- All cost and other documents, if any, substantiating Qwests $1707
Quote Preparation Fee, including but not limited to those identified in
Qwests response to interrogatory 10.
- All cost and other documents, if any, substantiating Qwests $126
non-recurring charge for installation of a Subloop, including but not limited
to those identified in Qwests response to interrogatory 12.
- Documents, if any, substantiating Qwests requirement that the Coop
purchase an Insurance Policy, including but not limited to those identified in
Qwests response to interrogatory 14.
- Documents, if any, identifying alleged risks to Qwests network
presented by the Coops Proposed Service.
____________________
Carl Oppedahl, Director
Ruby Ranch Internet Cooperative Association