February 8, 2005
Mimi Hull, President 
Board Members and General members
This update concerns the many securities lawsuits pending against Qwest.  As you know from reading my last report dated December 9, 2004, there are two primary groups of securities cases pending - federal court cases and state court cases.  All federal case have been consolidated into Denver Federal Court and are assigned to Federal Judge Robert E. Blackburn and Magistrate Judge Craig B. Shaffer.  The state court cases, namely lawsuits by CalSTRS, the State of Illinois, the State of New Jersey and Louisiana Teachers, are pending in different state courts.
On January 14, 2005, the defendants filed "Answers" to the 5th Consolidated Amended Complaint in the consolidated federal court cases.  None of the defendants filed cross-claims against each other.  Defendants denied all allegations of wrongdoing.
On January 27, 2005, Magistrate Judge Shaffer entered an order concerning coordinated discovery which order is attached hereto in Adobe PDF file format.  Written discovery must be completed by February 15, 2005.  Each side can take 80 depositions starting on February 21, 2005, and ending September 21, 2005.  The depositions must either take place in Denver, within 25 miles of the deponent's place of business or within 25 miles of the deponent's residence.  The deponent can decide where the deposition will take place.  All litigants in any of the coordinated cases can appear with their counsel and participate, unless the deponent can show grounds for a protective order.  No deposition can last more than 8 hours, absent some showing of good cause.  For example, former CEO Joseph Nacchio cannot be questioned more than 8 hours.  Therefore, the many attorneys are going to have to work together, carefully plan their questions and exhibits, and use the limited time wisely.
To date, none of the attorneys or litigants have filed anything in the court file saying anything about the progress of the ongoing settlement discussions.
Curtis L. Kennedy
8405 E. Princeton Ave.
Denver, CO  80237-1741
Tele: 303-770-0440
Attachment    (January 27, 2005 Order concerning coordinated discovery - 15 pages)