20240401Response to Opposition to Legal Counsel.pdf

FEICHtED
Nbnday,April 1,2024 3:17.13 PM
IDAHOPUB IC
PARSONS UTILITIES C T\/MSRON
LATIMER
800 West Main Street,Suite 1300 Norman M.Semanko
Boise,Idaho 83702 A Professional Attorney at Law
Main 208.562.4900 Law Corporation Direct Dial 208.562.4909
Fax [phone] [e-mail]
April 1, 2024
Monica Barrio Sanchez, VIA EMAIL ONLY
Commission Secretary [e-mail]
IDAHO PUBLIC UTILITIES COMMISSION
11331 W. Chinden Boulevard,
Building 8, Suite 201-A
P. O. Box 83720
Boise, Idaho 83720-0074
Re: Response to Opposition to Legal Counsel for StoneRidge Property Owners
Association
Dear Commission Secretary:
I am writing in response to the recent request submitted by Chan Karupiah ("Mr.
Karupiah") on behalf of CDS StoneRidge Utilities, LLC ("StoneRidge Utilities")' to deny my
involvement in the General Rate Case SWS-W-24-01. I appreciate Stoneridge Utilities' diligence
in ensuring that all parties involved in this matter comply with ethical standards. I take my ethical
obligations very seriously. As I determined prior to agreeing to represent StoneRidge Property
Owners Association("SPOA")in this matter,there is no substantial relationship between the Rate
Case and my previous legal representation of Mr. Karupiah and his interests,pursuant to the Idaho
Rules of Professional Conduct("IRPC").Moreover,I have never represented StoneRidge Utilities.
IRPC Rule 1.9(a)provides the following regarding former clients:
(a) A lawyer who has formerly represented a client in a matter shall not thereafter
represent another person in the same or a substantially related matter in which that
person's interests are materially adverse to the interests of the former client unless
the former client gives informed consent, confirmed in writing.
Vega v. GEICO Choice Ins. Co., 645 F. Supp. 3d 987, 993 (D. Idaho 2022).
t CDS StoneRidge Utilities is duly recognized as an Idaho limited liability company. IPUC Rules of
Procedure 043(c) states "A municipal corporation; a state, federal, tribal, or local government agency; an
unincorporated association; a non-profit organization, or other entity shall be represented by a licensed
attorney."
PARSONSBEHLE.COM
4857-6325-1378.v2

Monica Barrio Sanchez,
IDAHO PUBLIC UTILITIES COMMISSION
April 1, 2024
Page 2
The nature of my previous representation of Mr. Karupiah and his interests is completely
unrelated to the matter at hand. The legal services previously provided have no bearing on the
General Rate Case. Conversely, my current representation of SPOA involves distinct and
substantially unrelated matters from those that I previously handled for Mr. Kurupiah. There is no
substantial relationship between the previous matter handled for Mr. Karupiah and the current
matter being handled for SPOA. The legal issues, parties involved, and desired outcomes are
disparate and independent of each other. Furthermore, these matters are not substantially related
as they do not pertain to the same transaction or legal dispute.
Therefore, the Idaho Rules of Professional Conduct do not prohibit my involvement in the
current case. My representation of SPOA in the General Rate Case does not present a conflict of
interest with my prior representation of Mr. Karupiah. In addition, as required by IRPC 1.9(c), I
will not use information relating to my previous representation of Mr. Karupiah to his
disadvantage, although I am free to use any generally known information under the rule.
Moreover, StoneRidge Utilities has not addressed the substantive issues beyond requesting
the Commission deny my involvement in this case. For the Petition to Intervene, SPOA has met
all of the necessary requirements to participate in General Rate Case SWS-W-24-01. Therefore,
SPOA's request to intervene in General Rate Case SWS-W-24-01 should be granted.
I respectfully request that StoneRidge Utilities' request, as submitted by Mr. Karupiah, be
denied. Should you require any further clarification regarding this matter,please do not hesitate to
contact me.
Respectfully submitted,
PARSONS BEHLE&LATIMER
N
1
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Norman M. Semanko
Attorney at Law
NMS:kea
4857-6325-1378.v2

Monica Barrio Sanchez,
IDAHO PUBLIC UTILITIES COMMISSION
April 1, 2024
Page 3
CERTIFICATE OF SERVICE
I HEREBY CERTIFY that on the 1 st day of April, 2024, I served a true and correct copy
of the foregoing upon each party in this matter by delivering the same to each of the following
individuals by the method indicated below, addressed as follows:
Michael Duval ® U.S. Mail
Deputy Attorney General ❑ Facsimile
IDAHO PUBLIC UTILITIES COMMISSION ❑ Hand Delivery
P.O. Box 83720 ❑ Overnight Delivery
Boise, ID 83720-0074 ® Email michael.duval(&,puc.idaho._og_v
CDS STONERIDGE UTILITIES,LLC ® U.S. Mail
P. O. Box 298 ❑ Facsimile
Blanchard, ID 83804 ❑ Hand Delivery
❑ Overnight Delivery
® Email chansan(&,comcast.net
utilitieskstoneridgeidaho.com
Rick Haruthunian ® U.S. Mail
RAMSDEN,MARFICE,EALY&DE SMET LLP ❑ Facsimile
700 Northwest Boulevard ❑ Hand Delivery
P. O. Box 1336 ❑ Overnight Delivery
Coeur d'Alene, ID 83816-1336 ® Email rharuthunian&medlaw.com
Randolph Lee Garrison ® U.S. Mail
76 Bellflower Court ❑ Facsimile
Blanchard, Idaho 83804 ❑ Hand Delivery
❑ Overnight Delivery
® Email garrison&rmgarrison.com
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Norman M. Semanko
4857-6325-1378.v2