USWS965v24.docx

SUSAN HAMLIN
DEPUTY ATTORNEY GENERAL
IDAHO PUBLIC UTILITIES COMMISSION
472 WEST WASHINGTON STREET
PO BOX 83720
BOISE,  IDAHO  83720-0074
[phone]
Attorney for the Commission Staff
BEFORE  THE  IDAHO  PUBLIC  UTILITIES  COMMISSION

IN THE MATTER OF THE APPLICATION)
OF U S WEST COMMUNICATIONS, INC.)CASE  NO.  USW-S-96-5
FOR AUTHORITY TO INCREASE ITS)
RATES AND CHARGES FOR)STAFF'S SUPPLEMENTAL   
REGULATED TITLE 61 SERVICES.)RESPONSE TO THE SECOND
)PRODUCTION REQUEST OF
________________________________)U S WEST COMMUNICATIONS, INC.
The Staff of the Idaho Public Utilities Commission, by and through its attorney of record, Susan Hamlin, Deputy Attorney General, hereby supplements its response to U S WEST Communications, Inc.’s Second Production Request No. 127.
Request No. 127:Baldwin
Provide all correspondence, memos, notes of telephone conversations, E-Mail messages and files, and all other data of any kind pertaining to each and every contact and exchange between any member of the IPUC Staff (including persons who have subsequently left the Staff) and ETI, or any employee thereof including but not limited to Lee Selwyn and Susan Baldwin.
Response No. 127: Notwithstanding the Staff's continuing objection that this production request seeks information that is protected by the attorney-client privilege and constitutes attorney work product, the following information is provided in the response.  The Staff's consultant in this matter (ETI) has been furnished with copies of all pleadings, testimony, exhibits, workpapers, and other correspondence addressed to parties in this matter.  ETI has also received a copy of the three-way meeting documents for 1996 and the Staff booking letters from the 1991 and 1993 three-way meetings.  In addition, ETI has been supplied with the following orders and documents:
 Order No. 18188 Case No. U-1000-63 issued July 19, 1983
Order No. 18363Case No. U-1086-18 dated October 13, 1983
Order No. 20871 Case No. U-1002-59 issued November 17, 1986
Order No. 20981Case No. U-1000-87 issued January 9, 1987
Order No. 21049Case No. U-1500-166 issued February 12, 1987
Order No. 21074Case No. U-1000-87 dated February 23, 1987
Order No. 21848 Case No. U-1000-87 issued April 6, 1988
Order No. 21922Case No. MTB-T-88-3 dated May 16, 1988
Order No. 21949Case No. MTB-T-88-3 issued June 10, 1988
Order No. 22738Case No. MTB-T-88-13 issued September 21, 1989
Order No. 23441Case Nos. MTB-T-90-3/4 issued November 30, 1990
Order No. 23531Case No. MTB-T-90-3 issued January 22, 1991
Order No. 23951   Case No. USW-T-91-3 issued October 23, 1991
Order No. 24506Case No. USW-S-92-1 issued November 2, 1992
Order No. 25147Case No. USW-S-93-2 issued September 28, 1993
Order No. 25826Case No. USW-S-94-3 issued September 13, 1994 and its
Errata dated December 20, 1994
Order No. 25923Case No. USW-S-94-3 issued March 15, 1995
Order No. 26355 Case No. USW-T-95-1 issued March 7, 1996
Order No. 26434 Case No. USW-S-95-1 issued April 30, 1996
Order No. 26564 Case No. USW-S-96-3 issued August 15, 1996
Order No. 26672 Case No. USW-S-96-4 issued November , 1996
Stipulation and Settlement between Staff and U S WEST in Case
Nos. USW-S-95-4, -96-3, and -96-4
The Application, Orders/Notices, and Comments in Case No. GNR-T-97-1
Prefiled Testimony of Bill Eastlake in Case No. USW-S-95-1
Prefiled Testimony & Exhibit Nos. 5,6,8 of Mary Owen in Case No. USW-S-96-4
Final U S WEST Revenue Sharing Report for 1995 Sharing Year (USW-S-96-3)
Given the voluminous nature of this request these documents are not provided to the parties.  
DATED at Boise, Idaho, this               day of February 1997.
______________________________
Susan Hamlin
Deputy Attorney General
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