20161012INT Certficate of Attorney.pdf

Ronald L. Williams, ISB No. 3034
Williams Bradbury, P.C.
1015 W. Hays St.
Boise, ID 83 702
Telephone: [phone]
Email: [e-mail]
Attorneys for Intermountain Gas Company
r -CE IVED
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1' I •' :\)i i...,--j ' • -I ~ , .• , , : : • ', r: t.1 M I S l O 1 ~
BEFORE THE IDAHO PUBLIC UTILITES COMMISSION
IN THE MATTER OF INTERMOUNTAIN GAS)
COMPANY'S APPLICATION TO CHANGE)
ITS RATES AND CHARGES FOR NATURAL)
GAS SERVICE )
)
) _________________ )
Case No. INT-G-16-02
ATTORNEY'S CERTIFICATE
CLAIM OF CONF-IDENTIALITY
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 request and response regarding Amalgamated
Sugar Company LLC Request No. 2 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 12th day of October 2016.
Respectfully submitted,
By N~ V)l1r-
Ronald L. Williams
Attorney for Intermountain Gas Company
ATTORNEY'S CERTIFICATE CLAIM OF CONFIDENTIALITY RELATING TO DISCOVERY RESPONSES -2