USWS965v26.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 responds to U S WEST Communications, Inc.’s Second Request for Production to the Idaho Public Utilities
Commission Staff dated December 11, 1996.
Request No. 128:Baldwin
Provide a copy of the agreement under which ETI was retained and all amendments, extensions and appendices which accompany, modify or update such agreement.
Response No. 128:Baldwin
Staff partially objects to this request on the grounds that it seeks information that is protected by attorney/client privilege and is work product.  Further, Staff partially objects to this request on the grounds that it asks for information that is not relevant and not likely to lead to discovery of admissible evidence in this proceeding.  Notwithstanding these objections, attached is a redacted contract.
DATED at Boise, Idaho, this               day of March 1997
______________________________
Susan Hamlin
Deputy Attorney General
Attachments
i:wpfiles\umisc\prodreq\response\usws965.rs4