20240429Garrison 1 to SWS.pdf

RECEIVED
Monday, April 29, 2024 4:26PM
IDAHO PUBLIC
UTILITIES COMMISSION
Randolph Lee Garrison
Pro per
76 Bellflower Ct
Blanchard Idaho 83804
(541 ) 580-4446
garrison(a-)_rmgarrison.corn
BEFORE THE IDAHO PUBLIC UTILITIES COMMISSION
IN THE MATTER OF CDS ) Case No: SWS-W-24-01
STONERIDGE UTILITIES, LLC'S )
APPLICATION FOR AUTHORITY ) INTERVENER GARRISON'S
TO INCREASE ITS RATES AND ) FIRST REQUEST FOR
CHARGES FOR WATER SERVICE ) DISCOVERY FROM APPLICANT
IN THE STATE OF IDAHO )
REQUEST FOR DISCOVERY: Pursuant to the authority cited below, Intervener,
Randolph Lee Garrison, a party, hereby requests discovery from the applicant, CDS
Stoneridge Utilities, LLC, of the following document(s):
(1 ) StoneRidge Utilities "USB Memory stick" described as and including a
"copy of our (StoneRidge Utilities') Quickbooks Files for 2022-2024",
which is one and the same filed with the IPUC (on 8 March 2024),
together with a letter marked "Confidential".
Please also identify a time and place the items can be picked up
from the StoneRidge Utilities' Office, which is described in the Application
Request for Production — Page 1 of 4

as located a 364 StoneRidge Road, Blanchard, Id. If you would prefer,
the documents can be picked up at the StoneRidge Utility office, 105
Chatwold Rd, Blanchard, ID 83804.
CONTINUING REQUEST/IDENTITYOF PERSON ANSWERING: This Production Request
is continuing and StoneRidge Utilities is requested to provide, by way of
supplementary responses, additional documents that it or any person acting on its
behalf may later obtain that will augment the documents produced. Please provide
answers to each question, supporting work papers that provide detail or are the
source of information used in calculations. Responses must include the name and
phone number of the person preparing the document, and the name, location and
phone number of the record holder and if different the witness who can sponsor the
answer at hearing if need be. See IDAPA 31 .01 .01 .228.
AUTHORITY:
(a) This is a general rate case. In a general rate case, "The utility's Idaho
intrastate revenue requirement, and every component of it, both rate base
and expense, are at issue." Idaho Admin. Code r. 31 .01 .01 .124. 01 . "The
rates and charges of all Idaho retail customers, both recurring and
non-recurring, including those of special contract customers, are at issue,
and every component of every existing and proposed rate and charge is
Request for Production — Page 2 of 4

at issue." Idaho Admin. Code r. 31 .01 .01 .124 02. And "The tariffs,
practices, rules and regulations, service, instrumentalities, equipment,
facilities, classifications, and customer relations of the utility are at issue,
Idaho Admin. Code r. 31 .01 .01 .124. 02.c.
(b) Idaho Admin. Code r. 31 .01 .01 .222 [Parties are entitled to Discovery;
IPUC has authority to compel necessary discovery not listed in the rules].
(c) Idaho Admin. Code r. 31 .01 .01 .221 .05 [Scope and procedure of discovery
is governed by IRCivP]
(d) IRCivP 34 provides for the Production of Documents. All relevant
evidence is subject to Discovery. IRCivP 26 (b).
(e) StoneRidge Utilities is a public utility governed by the IPUC. There is
nothing "confidential" about public utility's books and records in a general
rate case. The information requested is not legally "privileged".
DATED and Signed this 291" day of April, 2024.
r Gv\,^ ,`,
Randolph Lee Garrison
(541 ) 580-4446
garrison(D_rmgarrison.com
Request for Production — Page 3 of 4

CERTIFICATE OF SERVICE
I HEREBY CERTIFY that on the 29th day of April, 2024, 1 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 By e-mail [e-mail]
Deputy Attorney General
IDAHO PUBLIC UTILITIES COMMISSION
P.O. Box 83720
Boise, ID 83720-0074
CDS STONERIDGE UTILITIES, LLC By e-mail chansan(@_comcast.net
P.O. Box 298 [e-mail]
Blanchard, ID 83804
Norman M. Semanko, ISB #4761 By e-mail nsemanko(@parsonsbehle.com
Patrick M. Ngalamulume, ISB #11200 pngalamulume(@ parsonsbehle.com
PARSONS BEHLE & LATIMER
800 W. Main Street, Suite 1300
Boise, Idaho 83702
DATED this 29th day of April 2024.
Randolph Lee Garrison
Request for Production — Page 4 of 4

From: garrison(armgarri son.corn
To: secretary
Cc: Michael Duval;cha nsan(a)comcast.net; utilities(a)stoneridgeidaho.com; nsemanko(s�parsonsbehle.com;
pngalamulume(aparsonsbehle.com
Subject: IPUC Case#SWS-W-24-01,Garrison Request for Discovery
Date: Monday,April 29,2024 4:27:27 PM
Attachments: Garrison IPUC Request for discovery general water rate increase.pdf
CAUTION:This email originated outside the State of Idaho network.Verify links and attachments BEFORE you
click or open,even if you recognize and/or trust the sender.Contact your agency service desk with any
concerns.
Monica Barrios-Sanchez
Secretary
Idaho Public Utilities Commission
Boise, Idaho 83720-0074
Via e-mail ,ecretary&puc.kdaho.gov
RE: CDS STONERIDGE UTILITIES, LLC'S APPLICATION FOR
AUTHORITY TO INCREASE ITS RATES AND CHARGES FOR
WATER SERVICE IN THE STATE OF IDAHO, Case Number
SWS-W-24-01 , Garrison Request for Discovery
As required by Rules of Procedure 31 .01 .01 .229, attached for filing with
the IPUC is Intervener Garrison's Request for Production from the
Applicant (Stoneridge Utilities).
Very Truly yours,
Randolph Lee Garrison
76 Bellflower Ct
Blanchard ID 83804
garrison&rmgarrison.com
(541 ) 672-4441
cc:
Michael Duval
Deputy Attorney General
michael.duval&cuc.idaho.gov
CDS STONERIDGE UTILITIES, LLC
chansan&comcast.net

[e-mail]
Norman M. Semanko
Patrick M. Ngalamulume
[e-mail]
[e-mail]