USWS965v25.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 FURTHER   
REGULATED TITLE 61 SERVICES.)SUPPLEMENTAL 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 further 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 the following:
 Order No. 26198Case Nos.USW-S-94-4/PRJ-T-94-1 issued October 19, 1995
Order No. 26200Case Nos.USW-S-94-4/MID-T-94-1 issued October 19, 1995
Order No. 26280 Case Nos.USW-S-94-4/PRJ-T-94-1 issued December 22, 1995
Order No. 26353Case Nos.ALB-T-94-1, CAM-T-94-1, FRE-T-94-1,
MID-T-94-1, ROK-T-94-1, SIL-T-94-1,USW-S-94-4 issued March 5, 1996
Order No. 26728Case No.USW-S-96-4 issued December 13, 1996
As a party in the above referenced cases, U S WEST already possesses these orders.  Consequently, they are not included with this response.
DATED at Boise, Idaho, this               day of February 1997.
______________________________
Susan Hamlin
Deputy Attorney General
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