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Home My WebLink About20043435.tiff BEFORE THE PUBLIC UTILITIES COMMISSION OF THE STATE OF COLORADO Docket No. 03A-496T IN THE MATTER OF THE JOINT APPLICATION TO EXPAND THE LOCAL CALLING AREA IN NORTHERN COLORADO JOINT UNOPPOSED MOTION TO MODIFY PROCEDURAL SCHEDULE AND REQUEST FOR WAIVER OF RESPONSE TIME Pursuant to Rule 22 of the Commission's Rules of Practice and Procedure, Qwest Corporation ("Qwest"), Nunn Telephone Company ("Nunn"), the Office of Consumer Counsel ("OCC") and that the Staff of the Public Utilities Commission of the State of Colorado ("Staff') respectfully request that the Commission modify the procedural schedule in this docket, as described more fully below. As grounds therefor, the parties state as follows: 1. On August 18, 2004, the Commission conducted a prehearing conference in this docket. Based upon the unanimous consent of all parties, the Commission ordered the procedural deadlines set out in Decision R04-1000 and set this matter to be heard on December 9, 2004. 2. With the Commission's accommodation, through prior modifications to the procedural schedule, Qwest and the OCC have reached a settlement in principle allowing full resolution of the remaining disputed issues in this docket and have begun to exchange draft language memorializing the agreement. 3. Based upon the short time remaining until the scheduled hearing date, the parties propose vacating the remaining procedural schedule, yet retaining the current hearing date in the event the Administrative Law Judge wishes to have a hearing on the impending motion to approve the settlement agreement of the parties. Rather than focusing efforts on further �0�mu/ 2004-3435 ni��horvS Cl4- litigation, the parties wish to focus upon reducing the settlement agreement to writing for the Commission's consideration. 4. The undersigned conferred with all parties regarding the relief sought herein and is authorized to represent that the City of Loveland does not oppose the relief sought herein. Further, the undersigned Counsel has been authorized to execute this motion on behalf of Nunn, Qwest and Staff. Therefore, the parties request, and believe it appropriate, that response time to this motion be waived. WHEREFORE, for good cause shown, Qwest Corporation, Nunn Telephone Company, the Office of Consumer Counsel and the Staff of the Public Utilities Commission of the State of Colorado respectfully request that the presiding administrative law judge vacate the remaining procedural schedule up to the scheduled hearing date and waive response time to this motion. Respectfully submitted this 23rd day of November 2004. Respectfully Submitted, KEN SALAZAR Attorney General BY: G. Harris Adams,No. 19668 Assistant Attorney General Office of the Attorney General 1525 Sherman Street, 5th Floor Denver, Colorado 80203 (303) 866-5441 (303) 866-5342 (Fax) ATTORNEYS FOR THE COLORADO OFFICE OF CONSUMER COUNSEL 7 CERTIFICATE OF SERVICE I hereby certify that on this 23rd day of November, 2004,the original and 5 copies of the foregoing JOINT UNOPPOSED MOTION TO MODIFY PROCEDURAL SCHEDULE AND REQUEST FOR WAIVER OF RESPONSE TIME were hand-delivered to: Bruce Smith,Director Colorado Public Utilities Commission 1580 Logan, OL2 Denver, CO 80203 and a copy was placed in the United States mail,postage prepaid, and addressed to: Renee Wheeler Pat Parker Assistant to the City Manager Rate/Financial Analyst City of Loveland Office of Consumer Counsel 500 E. 3`d St. 1580 Logan Street, Suite 740 Loveland, CO 80537 Denver, CO 80203 David P. Ayraud, Esq. Andrew B. Clauss, Esq. Assistant County Attorney Winslow B. Waxter, Esq. Larimer County Board of County David W. McGann, Esq. Commissioners Qwest Corporation P.O. Box 1606 1005 17th St., Suite 200 Fort Collins, CO 80522 Denver, CO 80202 P.B. Schechter Anne K. Botterud,Esq. Rate/Financial Analyst Assistant Attorney General Office of Consumer Counsel Business & Licensing Section 1580 Logan Street, Suite740 Office of the Attorney General Denver, CO 80203 1525 Sherman St. 5th Floor Denver, CO 80203 Sharon Podein Gary Klug Testimonial Staff Testimonial Staff Public Utilities Commission Public Utilities Commission 1580 Logan St., OL2 1580 Logan St., OL2 Denver, CO 80203 Denver, CO 80203 Becky Quintana Michael Zimmerman Advisory Staff Advisory Staff Public Utilities Commission Public Utilities Commission 1580 Logan St., OL2 1580 Logan St., OL2 Denver, CO 80203 Denver, CO 80203 Anthony Marquez, Esq. Barry L. Hjort Assistant Attorney General Hjort Law Firm State Services Section P.O. Box 461288 Office of the Attorney General Glendale, CO 80246 1525 Sherman St., 5th Floor Denver, CO 80203 City of Evans City of Fort Collins 1100 37`h Street 300 Laporte Ave., Floor 2 Evans, CO 80620 Fort Collins, CO 80522 City of Greeley Larimer County 1000 10th St. Tom Bender, Commission Chair Greeley, CO 80631 P.O. Box 1190 Fort Collins, CO 80522 Weld County Nunn Telephone Company David E. Long, Commission Chair P.O. Box 249 915 10`h St. Nunn, CO 80648 Greeley, CO 80632 Town of Ault Town of Berthoud Sharon Sullivan, Town Clerk/Treasurer P.O. Box 1229 201 First Street Berthoud,CO 80513-2229 Ault, CO 80610 Town of Eaton Town of Estes Park Gary Carsten, Town Administrator John Baudek, Mayor 223 First Street P.O. Box 1200 Eaton, CO 80615 Estes Park, CO 80517 Town of Gilcrist Town of Johnstown Paul Chacon,Mayor Troy Mellon, Mayor 204 8`h St.,Box 128 Box 609 Gilcrest, CO 80623 Johnstown, CO 80534 Town of Kersey Town of LaSalle Timothy J. Phippard,Mayor Tim Evans,Mayor 332 Third St. 128 No. Second St. Kersey, CO 80644 LaSalle, CO 80645 Town of Mead Town of Milliken Richard E.Kraemer,Mayor P.O. Box 290 441 Third St. Milliken, CO 80543 Mead, CO 80542 Town of Nunn Town of Platteville Duane Bayne, Mayor Nicholas J.Meier, Town Administrator 185 Lincoln Ave. 400 Grand Avenue Nunn, CO 80648 Platteville,CO 80651 Town of Timnath Town of Windsor Annalee Foster, Mayor Board of Trustees 4100 Main Street 301 Walnut Street Timnath, CO 80547 Windsor, CO 80550 Don F. Williams Sharon Citino City Manager Assistant City Attorney City of Loveland 500 East Third St. 500 East Third St. Loveland, CO 80537 Loveland, CO 80537 Greg White Town Attorney 1423 W. 29th St. Loveland, CO 80538 Cam . S Hello