20230308Request to Testify Remotely - M. Kahn.pdf

REQUEST TO TESTIFY REMOTELY PAGE 1 OF 4
Preston N. Carter, ISB No. 8462
Blake W. Ringer, ISB No. 11223
GIVENS PURSLEY LLP
601 West Bannock Street
Boise, Idaho 83702
Telephone: [phone]
Facsimile: [phone]
[e-mail]
[e-mail]
16655839_1.docx[30.235]

Attorneys for Veolia Water Idaho, Inc.

BEFORE THE IDAHO PUBLIC UTILITIES COMMISSION
IN THE MATTER OF THE
APPLICATION OF VEOLIA WATER
IDAHO, INC. FOR AUTHORITY TO
INCREASE ITS RATES AND CHARGES
FOR WATER SERVICE IN THE STATE
OF IDAHO

CASE NO. VEO-W-22-02

REQUEST FOR PERMISSION FOR
COMPANY WITNESS MATT KAHN TO
TESTIFY REMOTELY

Veolia Water Idaho, Inc. (“Veolia” or “Company”) files this Request for Permission for
Company Witness Matt Kahn to Testify Remotely.
As the Commission knows, this rate-case proceeding is scheduled for hearing the first
week of April, 2023. The Company filed direct testimony of eleven witness. Commission Staff
and Micron Technology, Inc. (“Micron”), an intervenor in the case, filed rebuttal testimony of
eight additional witnesses, in total.
This Request applies to a single witness: Matthew Kahn. None of the rebuttal testimony
cited, addressed, or disputed any aspect of Mr. Kahn’s testimony. Accordingly, Veolia believes
that Mr. Kahn will not be the subject of any substantive cross-examination by the parties.
RECEIVED
2023 March, 8 5:00PM
IDAHO PUBLIC
UTILITIES COMMISSION
REQUEST TO TESTIFY REMOTELY PAGE 2 OF 4
Veolia understands and agrees that the Commission and the parties have the opportunity
to ask questions of Mr. Kahn. Veolia also understands and agrees that the Commission has
moved to fully in-person hearings, and understands and agrees with the benefits of in-person
hearings.
That said, because Mr. Kahn’s testimony was not addressed in rebuttal testimony, the
Company would like to avoid the expense and logistics associated with flying Mr. Kahn to Boise
to present his testimony in person. If allowed to do so, Veolia proposes that Mr. Kahn present his
testimony by telephone or videoconference. This will allow the Commission to ask questions if
they would like to do so, but preserve costs and allow the Commission and the parties to focus
their questions upon witnesses whose testimony is truly at issue in the case.
Veolia intends to present all of its other witnesses in person.
Veolia respectfully requests expedited consideration of this request to enable travel plans
before the hearing.
DATED: March 8, 2023.
VEOLIA WATER IDAHO, INC.
By
Preston N. Carter
Attorneys for Veolia Water Idaho, Inc.

REQUEST TO TESTIFY REMOTELY PAGE 3 OF 4
CERTIFICATE OF SERVICE
I certify that on March 8, 2023, a true and correct copy of the foregoing was served upon
all parties of record in this proceeding via electronic mail as indicated below:

Commission Staff Via Electronic Mail
Jan Noriyuki, Commission Secretary
Idaho Public Utilities Commission
11331 W. Chinden Blvd., Bldg. 8, Suite 201-A
Boise, ID 83714

[e-mail]
Dayn Hardie
Deputy Attorney General
Idaho Public Utilities Commission
11331 W. Chinden Blvd., Bldg. 8, Suite 201-A
Boise, ID 83714
[e-mail]

Lorna K. Jorgensen
Meg Waddel
Ada County Prosecuting Attorney’s Office
Civil Division
200 W. Front Street, Room 3191
Boise, ID 83702
[e-mail]

Sharon M. Ullman, pro se
5991 E. Black Gold St.
Boise, ID 83716
[e-mail]

Austin Rueschhoff
Thorvald A. Nelson
Austin W. Jensen
Holland & Hart, LLP
555 17th Street, Suite 3200
Denver, CO 80202
[e-mail]
[e-mail]
[e-mail]
[e-mail]
[e-mail]

Jim Swier
Micron Technology , Inc.
8000 South Federal Way
Boise, ID 83707
[e-mail]

REQUEST TO TESTIFY REMOTELY PAGE 4 OF 4

Mary Grant
Deputy City Attorney
Boise, City Attorney’s Office
150 N. Capitol Blvd.
PO Box 500
Boise, ID 83701-0500

[e-mail]
[e-mail]

Preston N. Carter