ÿWPCO ûÿ2 BVP Z¦ Courier 10cpiªÿÿ‰?xxx,Ûwôxþ6X@É“8Ç;X@þþþþþþþÿþÿÿÿþÿÿþÿÿÿÿÿÿÿÿÿÿÿÿÿÿÿÿÿÿÿÿHP LaserJet IIIHPLASIII.PRSÛx Œ @ɇÏ,\,ð=dX@ŠÐÐûÿ2=M#|x Ó@--@ÓÐ ÈÈ ÐÐÐÁàœ ìÁBEFORE THE FLORIDA PUBLIC SERVICE COMMISSIONƒ In re: Determination for FundingÁ-Á) for Universal Service and CarrierÁ-Á)Ápp2ÁDocket No. 950696©TP of Last Resort ResponsibilitiesÁ-Á) ___________________________________)Ápp2ÁFiled: September 29, 1995 Áà4ìÁBELLSOUTH TELECOMMUNICATIONS, INC.'S OBJECTIONS TOƒ Áà4ìÁAT&T COMMUNICATIONS OF THE SOUTHERN STATES, INC.'Sƒ Áà ìÁÃÃSECOND REQUEST FOR PRODUCTION OF DOCUMENTSÄă ÐÐÁÁCOMES NOW BellSouth Telecommunications, Inc. ("BellSouth" or "Company"), pursuant to Rules 25©22.034 and 25©22.035, Florida Administrative Code, and Rules 1.350 and 1.280(b), Florida Rules of Civil Procedure, hereby submits the following Objections to AT&T Communications of the Southern States, Inc. ("AT&T") Second Request for Production of Documents to BellSouth. ÁÁThe Objections stated herein are preliminary in nature and are made at this time for the purpose of complying with the tenªday requirement set forth in Order No. PSC©95©0888©PCO©TP issued by the Florida Public Service Commission (hereinafter the "Commission") in the above©referenced docket on July 19, 1995. Should additional grounds for objection be discovered as BellSouth prepares its Responses to the above©referenced set of requests, BellSouth reserves the right to supplement, revise, or modify its objections at the time that it serves its Responses on AT&T. Moreover, should BellSouth determine that a Protective Order is necessary with respect to any of the material requested by AT&T, BellSouth reserves the right to file a motion with the Commission seeking such an order at the time that it serves its Responses on AT&T. ÔØ'0*0*0*°°Ô Áà´ì!ÁÃÃGENERAL OBJECTIONSÄă ÁÁBellSouth makes the following General Objections to AT&T's Second Set of Requests for Production of Documents which will be incorporated by reference into BellSouth's specific responses when its Responses are served on AT&T. ÁÁØ‚1.ØÁ` ` ÁBellSouth has interpreted AT&T's requests to apply to BellSouth's regulated intrastate operations in Florida and will limit its Answers accordingly. To the extent that any request is intended to apply to matters other than Florida intrastate operations subject to the jurisdiction of the Commission, BellSouth objects to such request as irrelevant, overly broad, unduly burdensome, and oppressive. ÁÁØ‚2.ØÁ` ` ÁBellSouth objects to each and every request to the extent that such request calls for information which is exempt from discovery by virtue of the attorney©client privilege, work product privilege, or other applicable privilege. ÁÁØ‚3.ØÁ` ` ÁBellSouth objects to each and every request insofar as the request is vague, ambiguous, overly broad, imprecise, or utilizes terms that are subject to multiple interpretations but are not properly defined or explained for purposes of these requests. Any Responses provided by BellSouth in response to AT&T's requests will be provided subject to, and without waiver of, the foregoing objection. ÁÁØ‚4.ØÁ` ` ÁBellSouth objects to each and every request insofar as the request is not reasonably calculated to lead to the discovery of admissible evidence and is not relevant to the subject matterÔ'0* ( (°°Ô of this action. BellSouth will attempt to note each instance where this objection applies. ÁÁØ‚5.ØÁ` ` ÁBellSouth objects to AT&T's general instructions, definitions or specific discovery requests insofar as they seek to impose obligations on BellSouth which exceed the requirements of the Florida Rules of Civil Procedure or Florida law. ÁÁØ‚6.ØÁ` ` ÁBellSouth objects to providing information to the extent that such information is already in the public record before the Florida Public Service Commission. ÁÁØ‚7.ØÁ` ` ÁBellSouth objects to each and every request, general instruction, or definition insofar as it is unduly burdensome, expensive, oppressive, or excessively time consuming as written. ÁÁØ‚8.ØÁ` ` ÁBellSouth objects to each and every request to the extent that the information requested constitutes "trade secrets" which are privileged pursuant to Section 90.506, Florida Statutes. To the extent that AT&T's requests seek proprietary confidential business information which is not subject of the "trade secrets" privilege, BellSouth will make such information available to counsel for AT&T pursuant to an appropriate Protective Agreement, subject to any other general or specific objections contained herein. ÁÁØ‚9.ØÁ` ` ÁBellSouth is a large corporation with employees located in many different locations in Florida and in other states. In the course of its business, BellSouth creates countless documents that are not subject to Florida Public Service Commission or FCC retention of records requirements. These documents are kept inÔ'0* ( (°°Ô numerous locations are frequently moved from site to site as employees change jobs or as the business is reorganized. Therefore, it is possible that not every document has been provided in response to these discovery requests. Rather, these responses provide all of the information obtained by BellSouth after a reasonable and diligent search conducted in connection with this discovery request. BellSouth has complied with AT&T's request that a search be conducted of those files that are reasonably expected to contain the requested information. To the extent that the discovery request purports to require more, BellSouth objects on the grounds that compliance would impose an undue burden or expense. ÁਠìÁÃÃOBJECTIONS TO SPECIFIC REQUESTSÄă ÁÁSubject to, and without waiver of, the foregoing general objections, BellSouth enters the following specific objections with respect to AT&T's requests: ÂXÂÃÃREQUEST NOS. 5©6 and 8©13ÄÄ: BellSouth objects to this request on the grounds set forth in BellSouth's objection to AT&T's Third Set of Interrogatories contained in BellSouth's Objections to AT&T's Third Set of Interrogatories which is being served on AT&T contemporaneously with these objections. Such objection is incorporated herein by specific reference thereto.Æ(#Æ Ôð#0* ( (°°Ô ÁÁRespectfully submitted this 29th day of September, 1995. ÁÁÁ` ` ÁÁ¸ ¸ ÁÁÁÁhh#ÁÁÀÀ(ÁÐÐBELLSOUTH TELECOMMUNICATIONS, INC. ÁÁÁ` ` ÁÁ¸ ¸ ÁÁÁÁhh#ÁÁÀÀ(Á_________________________ ÁÁÁ` ` ÁÁ¸ ¸ ÁÁÁÁhh#ÁÁÀÀ(ÁROBERT G. BEATTY ÁÁÁ` ` ÁÁ¸ ¸ ÁÁÁÁhh#ÁÁÀÀ(ÁPHILLIP J. CARVER ÁÁÁ` ` ÁÁ¸ ¸ ÁÁÁÁhh#ÁÁÀÀ(Ác/o Nancy Sims ÁÁÁ` ` ÁÁ¸ ¸ ÁÁÁÁhh#ÁÁÀÀ(ÁSuite 400 ÁÁÁ` ` ÁÁ¸ ¸ ÁÁÁÁhh#ÁÁÀÀ(Á150 South Monroe Street ÁÁÁ` ` ÁÁ¸ ¸ ÁÁÁÁhh#ÁÁÀÀ(ÁTallahassee, Florida 32301 ÁÁÁ` ` ÁÁ¸ ¸ ÁÁÁÁhh#ÁÁÀÀ(Á(305) 530©5555 ÁÁÁ` ` ÁÁ¸ ¸ ÁÁÁÁhh#ÁÁÀÀ(Á___________________________ ÁÁÁ` ` ÁÁ¸ ¸ ÁÁÁÁhh#ÁÁÀÀ(ÁR. DOUGLAS LACKEY ÁÁÁ` ` ÁÁ¸ ¸ ÁÁÁÁhh#ÁÁÀÀ(ÁNANCY B. WHITE ÁÁÁ` ` ÁÁ¸ ¸ ÁÁÁÁhh#ÁÁÀÀ(Á4300 Southern Bell Center ÁÁÁ` ` ÁÁ¸ ¸ ÁÁÁÁhh#ÁÁÀÀ(Á675 West Peachtree St., N.E. ÁÁÁ` ` ÁÁ¸ ¸ ÁÁÁÁhh#ÁÁÀÀ(ÁAtlanta, Georgia 30375 ÁÁÁ` ` ÁÁ¸ ¸ ÁÁÁÁhh#ÁÁÀÀ(Á(404) 529©3862 ÁÁÁ` ` ÁÁ¸ ¸ ÁÁÁÁhh#ÁÁÀÀ(Á(404) 529©5387