20160923INT Certificate of Attorney.pdf

Ronald L. Williams, ISB No. 3034
Williams Bradbury, P.C.
1015 W. Hays St.
Boise, ID 83702
Telephone: [phone]
Email: [e-mail]
Attorneys for Intermountain Gas Company
RE CEIVED
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BEFORE THE IDAHO PUBLIC UTILITES COMMISSION
IN THE MATTER OF INTERMOUNT AIN GAS )
COMPANY'S APPLICATION TO CHANGE)
ITS RA TES AND CHARGES FOR NATURAL )
GAS SERVICE )
)
) _________________ )
Case No. INT-G-16-02
ATTORNEY'S CERTIFICATE
CLAIM OF CONFIDENTIALITY
RELATING TO DISCOVERY
RESPONSES
I, Ronald L. Williams, am legal counsel for Intermountain Gas Company ("Intermountain"
or the in the above captioned matter. I make this certification and claim of confidentiality
regarding responses to the attached discovery requests and responses regarding Staffs Request
No. 2 and No. 16 because such information contained therein is Confidential and constitutes
Trade Secrets as defined by Idaho Code Sections 74-104, 74-106, 74-107 and 48-801 and
protected under IDAPA 31.01.01.067 and 31.01.01.233. Disclosing this information could give
entities access to competitive information Intermountain Gas Company believes could be used to
disadvantage it and its customers.
I am of the opinion that this information is "Confidential," as defined by Idaho Code
Sections 74-104, 74-106, 74-107 and 48-801, and should therefore be protected from public
inspection, examination and copying, and should be utilized only in accordance with the terms
of the Protective Agreement between Intermountain Gas Company and Idaho Public Utilities
Commission Staff.
ATTORNEY'S CERTIFICATE CLAIM OF CONFIDENTIALITY RELATING TO DISCOVERY RESPONSES -I
DATED this 23rd day of September, 2016.
Respectfully submitted,
By ~· ~~_,:__
Michelle E. Williams For
Ronald L. Williams
Attorney for Intermountain Gas Company
ATTORNEY'S CERTIFICATE CLAIM OF CONFIDENTIALITY RELATING TO DISCOVERY RESPONSES-2