Coop Exhibit K2
From: "Tymkovich, Timothy M." <TTymkovich@halehackstaff.com>
To: 'Carl Oppedahl' <carl@rric.net>
Subject: RE: Qwest's production
Date: Sat, 19 Jan 2002 13:51:03 -0700
The photograph shows spare locations in the cross connect box. Qwest has not had a visual confirmation. Our response will be subject to that qualification.
Please do not access Qwest's network equipment without permission of the company. Your prefiled testimony was highly misleading in representing to the Commission that you had been authorized by Qwest's counsel to access the company's telecommunications equipment. You represented to me that you had existing photographs of the cross connect box. There was never any suggestion that you or any other Ruby Ranch employee was entitled to access equipment in your neighborhood or elsewhere. We appreciate your cooperation in this regard.
-----Original Message-----
From: Carl Oppedahl [mailtocarl@rric.net]
Sent: Saturday, January 19, 2002 119 PM
To: Tymkovich, Timothy M.
Subject: RE: Qwest's production
At 01:10 PM 1/19/2002, Tymkovich, Timothy M. wrote:
Pursuant to Judge Kirkpatrick's Order, and as we told you in my email message on January 7, 2002, and in Qwest's Response to Petitioner's Second Motion to Compel, we will provide the requested information when Ruby Ranch complies with Commission Rule 3 (723-16, CCR). The requested documents have been submitted to the Commission under seal in Docket No. 99A-577T.
It is good to hear from you today. Maybe you can help with some other outstanding matters.
Admission 24, that there are spare locations in the cross-connect box for 100-pair screw terminal blocks. With the photographs we have provided, your client should have no difficulty responding properly to the request. I am still waiting for you to get back to me as you said you would.
Production request 6. We asked Qwest to produce a 100-pair screw terminal block of the type used in the cross-connect box at the corner of Ruby and Emerald Roads on Ruby Ranch. Your objection says our request "6 seeks to have Qwest produce an actual switch box for Ruby Ranch's inspection. This request is irrelevant because what one switch box looks like and how it functions has no bearing on the issues in this Arbitration." We did not ask for a "switch box." We asked for a screw terminal block. Perhaps there is some confusion on your client's part as to what is being requested. If that is the explanation for your objection, then I suggest we spend whatever time is required for your client to understand clearly what is being requested.