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Home My WebLink About20060426Motion for order shortening discovery time.pdfMcDevitt & Miller LLP Lawyers (208) 343-7500 (208) 336-6912 (Fax) 420 W. Bannock Street O. Box 2564-83701 Boise, Idaho 83702 Chas. F. McDevitt Dean J. (Joe) Miller April 26, 2006 Via Hand Delivery Jean Jewell, Secretary Idaho Public Utilities Commission 472 W. Washington St. Boise, Idaho 83720 Re: Case No. UWI-06- Dear Ms. Jewell: Enclosed for filing in the above matter please find the original and seven (7) copies of a Motion For Order Shortening Time For Discovery. An additional copy of the document and this letter is included for return to me with your file stamp thereon. ~:~: ~i11er DJM/hh ORIGINAL Dean J. Miller (ISB # 1968) McDEVITT & MILLER LLP 420 West Bannock Street O. Box 2564-83701 Boise, ID 83702 Tel: 208.343.7500 Fax: 208.336.6912 i oeClV,mcdevi tt -miller. com " . J , '. ~ : . I , ' . ,-) '"" " ". Attorneys for United Water Idaho Inc. BEFORE THE IDAHO PUBLIC UTILITIES COMMISSION Case No. UWI-06- IN THE MATTER OF THE APPLICATION OF UNITED WATER IDAHO INC. FOR AUTHORITY TO INCREASE ITS RATES AND CHARGES FOR WATER SERVICE IN THE STATE OF IDAHO MOTION FOR ORDER SHORTENING TIME FOR DISCOVERY COMES NOW United Water Inc. , (" United Water ) and moves the Commission pursuant to IPUCRP 225., for an Order Shortening Time for Discovery, and in support thereof respectfully shows as follows: On April 26, 2006, United Water propounded to the Intervenor BRACE the attached Second Interrogatories. II. The information sought by the Second Interrogatories is not voluminous and the preparation of answers to the Second Interrogatories would not reasonably require twenty-eight (28) days as otherwise permitted by IPUCRP 225.03. MOTION FOR ORDER SHORTENING TIME FOR DISCOVERY - 1 IlL It would not be unduly burdensome to require submission of Answers to the Second Interrogatories within fifteen (15) days, as required by the Idaho Rules of Civil Procedure. IV. Oral Argument is not requested. Pursuant to IPUCRP 256, BRACE has received actual notice of this Motion and United Water respectfully requests that the Commission act upon the Motion with less than fourteen (14) days notice. DATED this L. day of April 2006. ~~~ Attorneys for United Water Idaho Inc. MOTION FOR ORDER SHORTENING TIME FOR DISCOVERY - 2 CERTIFICATE OF SERVICE I hereby certify that on the 21.e!'day of April , 2006, I caused to be served, via the methodes) indicated below, true and correct copies ofthe foregoing document, upon: Jean Jewell, Secretary Idaho Public Utilities Commission 472 West Washington Street O. Box 83720 Boise, ID 83720-0074 i i ewellClV,puc.state.id. us Hand Delivered S. Mail Fax Fed. Express Email Scott L. Campbell, Esquire MOFFATT, THOMAS, BARRETT ROCK & FIELDS, CHARTERED O. Box 829 Boise, ID 83701 Hand Delivered u.s. Mail Fax Fed. Express Email ~v.~1 ~, MOTION FOR ORDER SHORTENING TIME FOR DISCOVERY - 3 Dean J. Miller (ISB #1968) McD EVITT & MILLER LLP 420 West Bannock Street O. Box 2564-83701 Boise, ID 83702 Tel: 208.343.7500 Fax: 208.336.6912 ioe((i)mcdevi it -mi 11 er. com Attorneys for United Water Idaho Inc. BEFORE THE IDAHO PUBLIC UTILITIES COMMISSION Case No. U\VI-O6- IN THE MATTER OF THE APPLICATION OF UNITED WATER IDAHO me. FOR AUTHORITY TO INCREASE ITS RATES AND CHARGES FOR WATER SERVICE IN THE STATE OF IDAHO UNITED WATER'S SECOND INTERROGATORIES TO BOISE RESIDENTS AGAINST COMMERCIAL EXPLOITATION INc. TO:Boise Residents Against Commercial Exploitation, Inc. ("BRACE" NOTICE YOU WILL PLEASE TAKE NOTICE that you are hereby required to answer in writing the following interrogatories within fifteen (15) days from the date of service hereof. INSTRUCTIONS Procedure. You have a duty, pursuant to Rule 26(e) of the Idaho Rules of Civil Procedure, to reasonably supplement and amend your responses. Privilege. If, in responding or failing to respond to the discovery requested herein you invoke or rely upon any privilege of any kind, please state specifically the nature of the UNITED WATER'S SECOND INTERROGATORIES TO BOISE RESIDENTS AGAINST COMMERCIAL EXPLOITATION, INC. privilege and the basis upon which you invoke, rely upon, or claim it, and identify all documents or other information, including contracts and communications, which you believe to be embraced by the privilege invoked. INTERROGATORIES Interro2atorv No.. Please identify by name, occupation and address each and every person you intend to call as a witness at the hearing of this matter. Interro2atorv No.For each person identified in answer to Interrogatory No., please state the general nature of the facts to which each identified person will testify. Interro2atorv No.State the name and address of each Person(s) whom you expect to call as an expert witness at the hearing of this matter. For each such Identified Person(s), state: (a) The subject matter on which the expert is expected to testify; (b) The substance of the facts and opinions to which the expert is expected to testify; (c) In capsule summary, the qualifications and background of such Identified expert (a produced exhibit curriculum vitae will be a satisfactory answer to this interrogatory); and (d) Pursuant to Rule 705, LR.E. set forth and disclose each and every underlying fact or data upon which the expert has or will rely in formulating and/or basing his or her opinion(s) or inference(s). UNITED WATER'S SECOND INTERROGATORIES TO BOISE RESIDENTS AGAINST COMMERCIAL EXPLOITATION, INC. - 2 Interrogatory No.To the extent not previously disclosed in your answers to the preceding Interrogatories please in detail state each and every position or contention you intend to assert in this proceeding. DATED this day of April, 2006. ~\~QL ean J. Miller Attorneys for United Water Idaho Inc. UNITED WATER'S SECOND INTERROGATORIES TO BOISE RESIDENTS AGAINST COMMERCIAL EXPLOITATION, INC. - 3 CERTIFICATE OF SERVICE \1.-- I hereby certify that on the Jffi. day of April, 2006 , I caused to be served, via the methodes) indicated below, true and correct copies of the foregoing document, upon: Jean Jewell, Secretary Idaho Public Utilities Commission 472 West Washington Street O. Box 83720 Boise, ID 83720-0074 iiewell(Q)puc.state.id. us Hand Delivered S. Mail Fax Fed. Express Email Scott L. Campbell, Esquire MOFF A TT, THOMAS, BARRETT ROCK & FIELDS , CHARTERED O. Box 829 Boise, ID 83701 Hand Delivered S. Mail Fax Fed. Express Email 't:i.... ~C\~\\~, ~\Ll~tQ~-fR",t- UNITED WATER'S SECOND INTERROGATORIES TO BOISE RESIDENTS AGAINST COMMERCIAL EXPLOITATION, INC. - 4