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HomeMy WebLinkAbout20080702Second Clarification to Reply Comments.pdfJohn R. Hamond, Jr., ISB No. 5470 Fisher Pusch & Alderman LLP U.S. Ban Plaza, 5th Floor 101 S. Capitol Boulevard, Suite 500 Post Office Box 1308 Boise, ID 83701 Telephone: (208) 331-1000 Facsimile: (208) 331-2400 t¡: 53 Attorneys for Applicant BEFORE THE IDAHO PUBLIC UTILITIES COMMISSION IN THE MATTER OF THE APPLICATION OF MAYFIELD SPRIGS WATER COMPAN, INC., FOR A CERTIFICATE OF PUBLIC CONVENIENCE AND NECESSITY CASE NO. MSW-W-08-01 MAYFIELD SPRINGS WATER COMPANY, INC.'S SECOND CLARFICATION TO REPLY COMMENTS COMES NOW Mayfield Springs Water Company, Inc., an Idaho corporation (the "Company" or "Mayfield"), by and through its counsel, Fisher Pusch & Alderman LLP, and fies this Second Clarification to Reply Comments. The Company wishes to provide clarification on an additional matter on which it filed reply comments. This matter involves the number of customers with unpaid balances who are also involved in the homeowner's suit against the Company. On page 14 and 15 in the Reply Comments, the Company makes the following statement. There is no dispute that the Company has continuously provided water service to its customers and that it began billng for service in Januar of 2007. As admitted by Mr. Corvino in his Intervenor Testimony, at least two customers have only paid for one month of service and four have never paid for water service. In addition, the Company's biling records indicate that the majority of the 14 homeowners suing the Company have never paid for any water service despite in many cases being provided with service for more than two years. MAYFIELD SPRIGS WATER COMPANY INC.'S SECOND CLARICATION TO REPLY COMMENTS-l Reply Comments at pp. 14-15. The Company has rereviewed all of its biling data and is submitting the following documents for Exhibit 34 which should replace the existing Exhibit 34. This biling data shows the full history for each of these 14 customer accounts to insure that customers are properly credited for any amounts they have paid toward water service provided by the Company in the pas. Based on the data included in new Exhibit 34 it stil is apparent that the Company is owed significant balances on certain customer accounts for water service. Curently, the Company is reviewing all of the remaining customer accounts and can submit additional history on these if requested to do so. DATED THIS -I day of July, 2008. MAYFIELD SPRIGS WATER COMPAN, INC. By: JohnR. Atto y MAYFIELD SPRIGS WATER COMPANY INCo'S SECOND CLARICATION TO REPLY COMMENTS-2 . . . CERTIFICATE OF SERVICE I HEREBY CERTIFY that on this í day of July, 2008, a tre and correct copy of the foregoing document was served on the following individuals by the method indicated below: Jean Jewell IDAHO PUBLIC UTILITIES COMMISSION 472 W. Washington St. POBox 83720 Boise ID 83720-5983 Don Howell Krstine A. Sasser Deputy Attorney General IDAHO PUBLIC UTILITIES COMMISSION POBox 83720 Boise ID 83720-0074 Gerald J. Corvino 11865 W. Tustin Lake Kuna ID 83634-5032 ( l U.S. Mail ( L Facsimile (208) 342-3829 H Overnight Delivery Messenger Delivery L Email ( l U.S. Mail ( L Facsimile (208) 342-3829 ( L Overnight Delivery LA Messenger Delivery 1 l Email l U.S. Mail L Facsimile Overnight Delivery Messenger Delive mail ~/ MA YFIELD SPRIGS WATER COMPANY INC.'S SECOND CLARICATION TO REPLY COMMENTS-3