20081106Pinardi Supplemental Affidavit.pdf

McDevitt & Miller LLP
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RECEIVED
420~. Bannock StreetZOO8 NOV -6 Pl112: 53
P.o. Box 2564-83701
Boise, Idaho 83702 IDAHO PUBLiC
UTILITIES COMMISSION
Chas. F. McDevitt
Dean J. (Joe) Miler
November 6, 2008
Via Hand Delivery
Jean Jewell, Secretary
Idaho Public Utilities Commission
472 W. Washington St.
Boise, Idaho 83720
Re: Teton Springs Water and Sewer LLC
Dear Ms. Jewell:
Enclosed for fiing in the above matter, please find an original and seven copies of the Supplemental
Affdavit of John Pinardi.
Kindly return a fie stamped copy to me.
Very Truly Yours,
McDevitt & Miler LLP~~
Dean J. Miler
DJM/hh
Enclosures
C: Teton Water and Sewer LLC
Dean 1. Miler ISH #1968
McDEVITT & MILLER LLP
420 West Bannock Street
P.O. Box 2564-83701
Boise, ID 83702
Tel: [phone]
Fax: [phone]
joeCimcdevitt -miler .com
Attorneysfor Teton Springs Water & Sewer Company
ORIGINAL
RECEIVED
200D HOV -6 PH 12: 53
IDAHO P~\31U~.I(' ~J
UTIUTIES COi'Mlik,S, Jj,
BEFORE THE IDAHO PUBLIC UTILITIES COMMISSION
IN THE MA ITER OF THE APPLICATION OF
TETON SPRIGS WATER AND SEWER
COMPANY LLC, INC, FOR THE ISSUANCE
OF A CERTIFICATE OF PUBLIC
CONVENIENCE AND NECESSITY, FOR
APPROVAL OF RATES AND CHARGES FOR
WATER SERVICE, FOR APPROVAL OF
RULES AND REGULA nONS GOVERNING
THE RENDERIG OF WATER SERVICE.
STATEOFIDAHO )
County of Ada )
) Case No. TTS-W-08-01
)
) SUPPLEMENTAL AFFIDAVIT OF
) JON PINARDI
)
)
)
)
)
Jon Pinardi being first duly sworn upon an oath deposes and says:
I. I am the general manager of Teton Springs Water and Sewer Company LLC ("Teton
Springs" or the "Company") and make this Affidavit to advise the Commission of events and
circumstances that have occurred subsequent to the fiing of the Company's Reply Comments on
October 10, 2008. I am over the age of 21 years and make this Affdavit of my own knowledge.
2. Allance Title and Escrow Corp., located in Driggs, Idaho, is the leading title insurance
company in Teton County, Idaho. I have recently received from Allance Title and Escrow
AFFIDAVIT OF JON PINARDI- 1
Corp., a report of pending foreclosure sales in Teton County. According to the report, there are
fort seven (47) foreclosure sales of lots located within the Teton Springs Resort scheduled for
foreclosure in the months of January and Februar 2009.
3. Subsequent to the filing of the Staff Comments on September 5, 2008, I approached three
lending institutions for the purpose of obtaining line of credit financing for Teton Springs. After
reviewing the rates and charges proposed in the Staff Comments, all three intuitions declined to
provide any financial support to Teton Springs.
4. Further your affant sayeth not.
Dated this (p day of November, 2008.
State of Idaho )
:ss
County of Teton )
On this t ç, day of November, 2008, before me, the undersigned, a NOfary Public in and said
State, personally appeared Jon Pinardi, known or identified to me to be the person ~hose name is
subscribed to the within instrument, and acknowledged to me that he executed the fame, and that the
statements therein contained are true to the best of his knowledge and belief. I
IN WITNESS WHEREOF, I have hereunto set my hand and affxed my 0 icial Seal the day and
year in this certificate first above written.
~
~"-~~ __ ¥. \\trl" \
Notar Public for IDAHO
Residing at: . I . '. ~
Commission Exp.:
..
SHANNON R. HERNDON
NOTARY PUBLIC
STATE OF IDAHO
AFFIDAVIT OF JON PINARDI- 2
~
.R
CERTIFICATE OF SERVICE
I hereby certify that on the ~ay of November, 2008, I caused to be served, via the
methodes) indicated below, true and correct copies of the foregoing document, upon:
Jean Jewell, Secretary Hand Delivered J(Idaho Public Utilties Commission U.S. Mail ..
472 West Washington Street Fax ...
P.O. Box 83720 Fed. Express ...
Boise, ID 83720-0074 Email ...
i jewellCipuc.state. id. us
Scott Woodbury Hand Delivered AIdaho Public Utilities Commission U.S. Mail ...
472 West Washington Street Fax ...
P.O. Box 83720 Fed. Express ...
Boise, ID 83720-0074 Email ...
jjeweii~puc.state. id.us
~lBy: McDEVITT & MILLER LLP
AFFIDAVIT OF JON PINARDI- 3