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 ADMISSION

The Ruby Ranch Internet Cooperative Association (“Coop”), pursuant to Colorado Commission Rule 77(b), as Qwest Corporation (“Qwest”) to respond to these requests for admission within ten days.

The following are to be answered with reference with definitions provided herewith.

  1. Admit that the Proposed Service poses less risk to Qwest’s network, in technical terms, than POTS service.
  2. Admit that the Proposed Service poses less risk to Qwest’s network, in technical terms, than LADS service.
  3. Admit that the Proposed Service poses less risk to Qwest’s network, in technical terms, than alarm line service.
  4. Admit that Qwest’s process of activating a Subloop for the Coop does not require Qwest personnel to do work at the Remote Terminal.
  5. Admit that Qwest’s process of activating a Subloop for the Coop does not require Qwest personnel to do work at any Qwest central office.
  6. Admit that Qwest’s process of activating a Subloop for the Coop does not require Qwest personnel to do work at the Highway 9 Pedestal.
  7. Admit that Qwest’s process of activating new POTS service in the Neighborhood has at times required Qwest personnel to do work at the Remote Terminal.
  8. Admit that Qwest’s process of activating new POTS service in the Neighborhood has at times required Qwest personnel to do work at the Qwest central office in Dillon.
  9. Admit that buried cable between the Crossbox and the Diamond Road Pedestal provides approximately two hundred copper pairs between those two points.
  10. Admit that buried cable between the Crossbox and the Diamond Road Pedestal provides at least one hundred fifty copper pairs between those two points.
  11. Admit that buried cable between the Diamond Road Pedestal and the Highway 9 Pedestal provides approximately two hundred copper pairs between those two points.
  12. Admit that buried cable between the Diamond Road Pedestal and the Highway 9 Pedestal provides at least one hundred fifty copper pairs between those two points.
  13. Admit that between the Crossbox and the Diamond Road Pedestal, fewer than one hundred thirty pairs are in use.
  14. Admit that between the Diamond Road Pedestal and the Highway 9 Pedestal, fewer than one hundred thirty pairs are in use.
  15. Admit that in the buried cable between the Crossbox and the Diamond Road Pedestal, there are presently at least twenty spare pairs.
  16. Admit that in the buried cable between the Crossbox and the Diamond Road Pedestal, there are presently at least fifty spare pairs.
  17. Admit that in the buried cable between the Diamond Road Pedestal and the Highway 9 Pedestal, there are presently at least twenty spare pairs.
  18. Admit that in the buried cable between the Diamond Road Pedestal and the Highway 9 Pedestal, there are presently at least fifty spare pairs.
  19. Admit that the buried cables from the Crossbox to homes within the Neighborhood provide approximately four hundred copper pairs.
  20. Admit that in the buried cables from the Crossbox to homes within the Neighborhood, fewer than two hundred pairs are in use.
  21. Admit that in the buried cables from the Crossbox to homes within the Neighborhood, there are presently at least two hundred spares.
  22. Admit that in the buried cables from the Crossbox to homes within the Neighborhood, there are presently at least one hundred fifty spares.
  23. Admit that in the buried cables from the Crossbox to homes within the Neighborhood, there are presently at least fifty spares.
  24. Admit that the Crossbox has eight positions capable of receiving screw terminal blocks each with one hundred pairs of screw terminals, six of which are filled with screw terminal blocks and two of which are presently spare positions.
  25. Admit that for carriers providing SDSL over copper pairs rented from Qwest, Qwest has never made a claim under an Insurance Policy arising out of the provision of SDSL service.
  26. Admit that as of October 23, 2001, Qwest had never executed any nondisclosure agreement with the Coop.
  27. Admit that as of September 23, 2001, Qwest had never executed any nondisclosure agreement with the Coop.
  28. Admit that as of August 23, 2001, Qwest had never executed any nondisclosure agreement with the Coop.
  29. Admit that as of July 23, 2001, Qwest had never executed any nondisclosure agreement with the Coop.
  30. Admit that as of June 23, 2001, Qwest had never executed any nondisclosure agreement with the Coop.
  31. Admit that as of December 6, 2001, Qwest has never provided any documents to the Coop marked “Confidential Information.”
  32. Admit that Qwest has sent billing inserts to Qwest customers in the Neighborhood, advertising Qwest’s DSL service.
  33. Admit that Qwest has never provided DSL service to anyone in the Neighborhood.
  34. Admit that Qwest is not presently taking orders for DSL service for anyone located in the Neighborhood.
  35. Admit that Qwest has never provided DSL service to anyone located in the area served by the Dillon Qwest central office.
  36. Admit that Qwest is not presently taking orders for DSL service for anyone located in the area served by the Dillon Qwest central office.
  37. Admit that Qwest has not said in writing that it will provide DSL service in the Neighborhood.
  38. Admit that Qwest has not said that it will provide DSL service in the Neighborhood.
  39. Admit that Qwest has not said in writing that it will provide DSL service in the area served by the Dillon Qwest central office.
  40. Admit that Qwest has not said that it will provide DSL service in the area served by the Dillon Qwest central office.
  41. Admit that Qwest has no evidence to establish that AT&T has ever offered cable modem Internet access in the Neighborhood.
  42. Admit that Qwest has no evidence to establish that AT&T has said that it will offer cable modem Internet access in the Neighborhood.
  43. Admit that as of December 10, 2001, Qwest has never provided cost data to substantiate its $1707 Quote Preparation Fee.
  44. Admit that as of December 10, 2001, Qwest has never provided cost data to substantiate its $126 nonrecurring charge for installation of a Subloop.
  45. Admit that the Coop asked Qwest for interconnection on or about June 1, 2001.
  46. Admit that the draft interconnect agreement sent by Qwest to the Coop on or about June 1, 2001, when printed, exceeds 250 pages in length and exceeds one hundred thousand words.
  47. Admit that on or about July 2, 2001, the Coop sent Qwest a proposed interconnect agreement which, when printed, is fewer than six pages in length.
  48. Admit that Coop Documents 100-104 are, but for matters of form, substantially a copy of a letter received by Qwest from the Coop on or about July 2, 2001.
  49. Admit that Coop Documents 105-110 are, but for matters of form, substantially a copy of an email received by Qwest from the Coop on or about July 29, 2001.
  50. Admit that Coop Documents 111-115 are, but for matters of form, substantially a copy of an email received by Qwest from the Coop on or about August 2, 2001.
  51. Admit that Coop Documents 116-118 are, but for matters of form, substantially a copy of a letter sent by Qwest to the Coop on or about August 14, 2001.
  52. Admit that Coop Documents 119-125 are, but for matters of form, substantially a copy of an email received by Qwest from the Coop on or about August 20, 2001.
  53. Admit that Coop Document 126 is, but for matters of form, substantially a copy of an email received by Qwest from the Coop on or about August 28, 2001.
  54. Admit that Coop Documents 127-128 are, but for matters of form, substantially a copy of an email received by Qwest from the Coop on or about August 31, 2001.
  55. Admit that Coop Document 129 is, but for matters of form, substantially a copy of a letter sent by Qwest to the Coop on or about October 12, 2001.
  56. Admit that Coop Documents 130-131 are, but for matters of form, substantially a copy of an email received by Qwest from the Coop on or about October 16, 2001.
  57. Admit that Coop Document 132 is, but for matters of form, substantially a copy of an email received by Qwest from the Coop on or about November 1, 2001.
  58. Admit that Coop Document 133 is, but for matters of form, substantially a copy of an email received by Qwest from the Coop on or about November 2, 2001.
  59. Admit that Coop Document 134 is, but for matters of form, substantially a copy of an email received by Qwest from the Coop on or about November 7, 2001.
  60. Admit that Coop Document 135 is, but for matters of form, substantially a copy of an email sent by Qwest to the Coop on or about November 9, 2001.
  61. Admit that Coop Document 136 is, but for matters of form, substantially a copy of an email received by Qwest from the Coop on or about November 9, 2001.
  62. Admit that during the July 26, 2001 conference call, Qwest took the position that the recurring cost for Subloops should be $21.32.
  63. Admit that during the July 26, 2001 conference call, Qwest took the position that the non-recurring cost for Subloops should be $126.
  64. Admit that during the July 26, 2001 conference call, Qwest took the position that a quote preparation fee of $1707 would have to be paid by the Coop prior to any field connection point being installed.
  65. Admit that during the July 26, 2001 conference call, Qwest took the position that the Coop would be required to have an eleven million dollar insurance policy.
  66. Admit that during the August 2, 2001 conference call, the Coop representatives were placed “on hold” by Qwest for intervals totaling more than one hour.
  67. Admit that during the August 2, 2001 conference call, the Coop representatives were placed “on hold” by Qwest for intervals totaling more than one-half hour.
  68. Admit that during the August 2, 2001 conference call, Qwest failed to identify the risks it wanted the Coop to insure against that were different from those presented by a POTS customer.
  69. Admit that as of August 3, 2001, Qwest had not identified the risks it wanted the Coop to insure against that were different from those presented by a POTS customer.
  70. Admit that during the August 2, 2001 conference call, Qwest took the position that the recurring cost for Subloops should be $21.32.
  71. Admit that during the August 2, 2001 conference call, Qwest failed to provide support for the $21.32 price.
  72. Admit that as of August 3, 2001, Qwest had not provided support for the $21.32 price.
  73. Admit that during the August 2, 2001 conference call, Qwest took the position that the non- recurring cost for Subloops should be $126.
  74. Admit that as of August 3, 2001, Qwest took the position that the non-recurring cost for Subloops should be $126.
  75. Admit that during the August 2, 2001 conference call, Qwest took the position that a quote preparation fee of $1707 would have to be paid by the Coop prior to any field connection point being installed.
  76. Admit that during the August 2, 2001 conference call, Qwest failed to provide support for the $1707 price.
  77. Admit that as of August 3, 2001, Qwest had not provided support for the $1707 price.
  78. Admit that on August 14, 2001, Qwest dropped the $21.32 monthly rate to $15.12.
  79. Admit that during the August 15, 2001 conference call, Qwest dropped the amount of required insurance to one million dollars.
  80. Admit that during the August 15, 2001 conference call, Qwest maintained its position as to the $126 and $1707 prices.
  81. Admit that as of August 16, 2001, Qwest had not explained how it decides whether to charge a “base rate area” or “zone 1” or “zone 2” or “zone 3” rate for Subloops.
  82. Admit that as of December 1, 2001, Qwest had never provided to the Coop any nondisclosure agreement with the Coop that had been executed by Qwest.
  83. Admit that during an August 1, 2001 telephone conference, the Coop asked Qwest for supporting data for Qwest’s $126 nonrecurring charge for Subloops.
  84. Admit that during an August 1, 2001 telephone conference, the Coop asked Qwest for supporting data for Qwest’s $1707 quote preparation fee.
  85. Admit that during an August 15, 2001 telephone conference, the Coop asked Qwest for supporting data for Qwest’s $126 nonrecurring charge for Subloops.
  86. Admit that during an August 15, 2001 telephone conference, the Coop asked Qwest for supporting data for Qwest’s $1707 quote preparation fee.
  87. Admit that during an August 27, 2001 telephone conference, the Coop asked Qwest for supporting data for Qwest’s $126 nonrecurring charge for Subloops.
  88. Admit that during an August 27, 2001 telephone conference, the Coop asked Qwest for supporting data for Qwest’s $1707 quote preparation fee.
  89. Admit that as of November 9, 2001, the Coop asked Qwest for supporting data for Qwest’s $126 nonrecurring charge for Subloops.
  90. Admit that as of November 9, 2001, the Coop asked Qwest for supporting data for Qwest’s $1707 quote preparation fee.
  91. Admit that on August 27, 2001, Qwest proposed to drop its insurance requirement if the Coop were to pay prices higher than those proposed by Qwest in its SGAT?
  92. Admit that between July 26, 2001 and December 10, 2001, Qwest’s position regarding an interconnection agreement with the Coop is that the $126 nonrecurring charge for Subloops is non-negotiable.
  93. Admit that between July 26, 2001 and December 10, 2001, Qwest’s position regarding an interconnection agreement with the Coop is that the $1707 quote preparation fee is non-negotiable.
  94. Admit that between July 26, 2001 and December 10, 2001, Qwest’s position regarding an interconnection agreement with the Coop is that the $126 nonrecurring charge for Subloops is available only on a take-it-or-leave-it basis.
  95. Admit that between July 26, 2001 and December 10, 2001, Qwest’s position regarding an interconnection agreement with the Coop is that the $1707 quote preparation fee is available only on a take-it-or-leave-it basis.

____________________

Carl Oppedahl, Director

Ruby Ranch Internet Cooperative Association