Control Number : 41158
Item Number : 5
Addendum StartPage : 0
P.U.C. DOCKET NO. 4t 158
COMPLAINT OF SOUTHWESTERN
BELL TELEPHONE COMPANY DBA
AT&T TEXAS AGAINST ZEUS
WIRELESS, LLC FOR RESOLUTION OF
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POST-INTERCONNECTION DISPUTE
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PUBLIC UTILITY COMMIS SWN
OF TEXAS
ZEUS' FIRST REQUEST FOR INFORMATION TO AT&T TEXAS
REQUEST NOS. i- 1 THROUGH 1-8
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ny
Zeus Wireless, LLC requests that AT&T Texas respond to the following requests for
information in accordance with the Commission's Procedural Rules. Your response should be
served on the attorneys listed below no later than 20 days after you receive this request or not
later than any deadline established by Commission arbitrations.
Respectfully Submitted,
Mark Foster, Attorney at Law
FosterLaw
707 West Tenth Street
Austin, TX 78701
(512) 708-8700
(512) 697-0058lfax
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By:
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Mark Foster
Texas Bar No. 07293850
niark'?mfosterlaw.coin
Counsel for Zeus Wireless, LLC
CERTIFICATE OF SERVICE
I certify that a copy of this document will be served on all parties of record on
in accordance with P.U.C. Procedural Rule 22.74.
Dated:
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Mark Foster
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ZEUS WIRELESS, LLC'S FIRST REQUEST FOR
INFORMATION TO AT&T TEXAS
REQUEST NOS. 1-1 THROUGH 1-8
DEFINITIONS AND INSTRUCTIONS
1.
"Commission" means the Public Utility Commission of Texas.
2.
"Communication" means any disclosure, transfer, or exchange of information,
whether oral or written.
3.
"Commissioners" means any or all of the Commissioners of the Public Utility
Commission of Texas.
4.
"AT&T Texas" means AT&T Texas and any person acting or purporting to act on
indicate AT&T
its behalf. The terms "you," "your" and "Company" may also be used to
Texas.
5.
"Concerning" means relating to, referring to, describing, concerning, evidencing,
or constituting.
6.
-Document" means any writing, email, dra^nqng, graph, chart, photograph, sound
recording, image, or data stored in any medium from which information can be obtained. A
draft or non-identical copy is a separate document. If responsive document has been
destroyed or transferred beyond the Company's control, please describe the circumstances
tinder which the document was destroyed or transferred and provide an exact citation to the
document.
7.
"Identify" has the following meanings depending on the context:
(a)
"Identify" when used with a natural person means to supply his or her
name, last known residential and business addresses, and last known residential and
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business telephone numbers. If the above information is unavailable, provide some other
means of identifying the person and his or her present location.
(b)
"Identify" when used with an entity means to provide its name, manner of
organization (e.g., corporation, partnership, joint venture, etc.), address, and telephone
number.
(c)
"Identify" when used with a document means to provide its date, author,
addressee, and the identity of the natural person known or believed by you to have
possession, custody, or control of the document. If this information is unavailable,
provide some other means of identifying the document and its present location with
sufficient particularity to allow a party to this action to request its production under
Procedural Rule 22.144.
(d)
"Identify" when used with any other thing or matter means to provide a
description with detail sufficient to allow a party to this action to identify it and
determine its present location.
8.
"Person" means any natural person, business, organization, legal entity, or
governmental entity.
9.
"Representative" means an officer, director, employee, agent, spokesperson, or
attorney of a person.
10.
"Staff" means the Staff of the Public Utility of Texas.
11.
The words "and" and "or" should be construed conjunctively or disjunctively as
necessary to give each request its broadest scope.
12.
The singular form of a word also refers to the plural, unless the context requires
otherwise.
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13.
"Interconnection" or "interconnection agreement" refers to the agreement
approved by the Texas PUC in Docket No. 37845.
REQUESTS FOR INFORMATION
1-I
Please provide all documents, communications, tangible things, reports, models and data
compilations that have been provided to, reviewed by or prepared by or for AT&T Texas
witnesses in anticipation of providing testimony in this matter.
1-2
Please separately provide the work-papers of each of AT&T Texas' witnesses in this
matter, and identify which witness is associated with each set of 'work-papers.
1-3
Provide all documents which AT&T Texas believes supports its claims or defenses
identified in its Complaint Against Zeus Wireless, LLC for Resolution of PostInterconnection Dispute and Conditional Request for Expedited Treatment.
1-4
Identify the name, address, and telephone number of persons having knowledge of
relevant facts, and a brief statement of each identified person's connection with the billing
disputes which are the subject of this proceeding.
1-5
Identify any expert to be called by AT&T Texas to testify in a hearing on the merits of
this proceeding and for any testifying expert provide:
(1) the expert's name, address, and telephone number;
(2) the subject matter on which the expert will testify;
(3) the general substance of the expert's mental impressions and opinions and a
brief summary of the basis for them, or if the expert is not retained by,
employed by, or otherwise subject to the control of AT&T Texas, documents
reflecting such information;
(4) if the expert is retained by, employed by, or otherwise subject to the control
of AT&T Texas:
(A) all documents, tangible things, reports, models, or data compilations
that have been provided to, reviewed by, or prepared by or for the
expert in anticipation of the expert's testimony; and
(B) the expert's current resume and bibliography.
1-6
Identify and produce any and all notices or documents that AT&T Texas sent to Zeus
regarding the issues involved in this proceeding.
1-7
State what AT&T Texas did to analyze Zeus' traffic to determine whether it is in
compliance with the ICA, as referred to in Exhibit B of AT&T Texas' Complaint,
Affidavit of Mark Neinast, page 5, lines 3-14. Your answer should include the identity of
the persons(s) who performed such evaluations. the procedures followed, and the date(s)
on which such evaluations were performed.
1-8
Produce all documents evidencing AT&T Texas' evaluations and conclusions regarding
the call studies discussed in Exhibit B of AT&T Texas' Complaint, Affidavit of Mark
Neinast, page 5, lines 3-14.
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