20240517Garrison 1-4 to SWS.pdf

RECEIVED
Friday, May 17, 2024 8:OOAM
IDAHO PUBLIC
UTILITIES COMMISSION
Randolph Lee Garrison
Pro per
76 Bellflower Ct
Blanchard Idaho 83804
(541 ) 580-4446
garrison(.@_rmgarrison.com
BEFORE THE IDAHO PUBLIC UTILITIES COMMISSION
IN THE MATTER OF CDS ) Case No: SWS-W-24-01
STONERIDGE UTILITIES, )
LLC'S APPLICATION FOR ) INTERVENER GARRISON'S 2nd
AUTHORITY TO INCREASE ) REQUEST FOR PRODUCTION
ITS RATES AND CHARGES ) FROM CDS STONERIDGE
FOR WATER SERVICE IN THE ) UTILITIES
STATE OF IDAHO )
REQUEST FOR DISCOVERY: Pursuant to the authority cited below,
Intervener, Randolph Lee Garrison, a party, as a second request for
production of documents from CDS Stoneridge Utilities, LLC, hereby requests
production of the following document(s):
(1 ) For a copy of any/all Requests for Production (Discovery) from the
Assistant Attorney General (Mr. Duval) ("Commission Staff"), including (but
not limited to):
(a) The First, Second and Third Production Requests made to CDS
Stoneridge.
(2) For a copy of any other discovery/document/production requests
which have been made upon you by any party.
(3) For a copy of any Answers or Responses to production requests
which have been made by CDS Stoneridge (including, but not limited to
Answers or Responses made by CDS Stoneridge to the First, Second and
Third and Fourth Production Requests made by the Assistant Attorney
General (Mr. Duval) ("Commission Staff") to CDS Stoneridge)
(4) For a copy of in and all items which have been sent by CDS
Second Request for Production — Page 1 of 4

Stoneridge in response to requests for production, including, but not limited
to:
(a) Any and all items disclosed by CDS Stoneridge in response or
answer to the First, Second and Third and Fourth Production Requests
made by the Assistant Attorney General (Mr. Duval) ("Commission
Staff") to CDS Stoneridge.
A copy of Assistant Attorney General's (Mr. Duval's) ("Commission
Staff") Fourth Production Request accompanies this document as a separate
file. It is provided as if recited verbatim herein.
Please also identify a time and place the items can be picked up from
the StoneRidge Utilities' Office, which is described in the Application as
located at 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/IDENTITY Of 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:
(1 ) 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 at issue." Idaho Admin. Code r. 31 .01 .01 .124 02. And "The
tariffs, practices, rules and regulations, service, instrumentalities,
Second Request for Production — Page 2 of 4

equipment, facilities, classifications, and customer relations of the utility
are at issue, . . ." Idaho Admin. Code r. 31 .01 .01 .124. 02.c.
(2) 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]. Idaho Admin. Code r. 31 .01 .01 .221 .05 [Scope and procedure of
discovery is governed by IRCivP]
(3) IRCivP 34 provides for the Production of Documents. All relevant
evidence is subject to Discovery. IRCivP 26 (b).
(4) 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 16th day of May,
2024.
Randolph Lee Garrison
(541 ) 580-4446
garrison(c_rmgarrison.com
CERTIFICATE OF SERVICE
I HEREBY CERTIFY that on the 16th day of May, 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:
Second Request for Production — Page 3 of 4

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 utilities(a�_stoneridgeidaho.com
Blanchard, ID 83804
Norman M. Semanko, ISB #4761 By e-mail nsemanko(D_parsonsbehle.com
Patrick M. Ngalamulume, ISB #11200 pngalamulume(a�_parsonsbehle.com
PARSONS BEHLE & LATIMER
800 W. Main Street, Suite 1300
Boise, Idaho 83702
Rick Haruthunian By e-mail: rharuthunian(c rmedlaw.com
CONDOMINIUM OWNERS ASSOC.
INC: Ramsden, Marfice, Ealy & De Smet,
LLP
(Exhibit Nos. 201-300) 700 Northwest
Blvd.
P.O. Box 1336
Coeur d'Alene, ID 83816-1336
DATED this 16th day of May 2024.
R� G V\,^ `.4
Randolph Lee Garrison
Second Request for Production — Page 4 of 4

MICHAEL DUVAL
DEPUTY ATTORNEY GENERAL
IDAHO PUBLIC UTILITIES COMMISSION
PO BOX 83720
BOISE, IDAHO 83720-0074
[phone]
IDAHO BAR NO. 11714
Street Address for Express Mail:
11331 W CHINDEN BLVD, BLDG 8, SUITE 201-A
BOISE, ID 83714
Attorney for the Commission Staff
BEFORE THE IDAHO PUBLIC UTILITIES COMMISSION
IN THE MATTER OF CDS STONERIDGE )
UTILITIES,LLC'S APPLICATION FOR ) CASE NO. SWS-W-24-01
AUTHORITY TO INCREASE ITS RATES )
AND CHARGES FOR WATER SERVICE IN )
THE STATE OF IDAHO ) FOURTH PRODUCTION
REQUEST OF THE
COMMISSION STAFF
TO CDS STONERIDGE
UTILITIES,LLC
Staff of the Idaho Public Utilities Commission("Commission"), by and through its
attorney of record, Michael Duval, Deputy Attorney General, requests that CDS Stoneridge
Utilities, LLC ("Company")provide the following documents and information as soon as
possible, but no later than THURSDAY,MAY 30, 2024.
This Production Request is to be considered as continuing, and the Company 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 or information produced.
Please provide answers to each question, supporting workpapers that provide detail or are
the source of information used in calculations, and the name,job title, and telephone number of
the person preparing the documents. Please also identify the name,job title, location, and
telephone number of the record holder.
FOURTH PRODUCTION REQUEST
TO CDS STONERIDGE UTILITIES, LLC 1 MAY 9, 2024

In addition to the written copies provided as response to the requests,please provide all
Excel spreadsheets and electronic files with formulas intact and enabled.
REQUEST NO. 56: Please provide a copy of the 2023 annual report. If not available,
please provide a date when it will be filed with the Commission.
REQUEST NO. 57: Please provide all documents, including invoices, receipts, time
sheets/weekly worked reports, etc., that support the Company's response to Staff s Production
Request No. 1, Rate Case Labor Cost Details to date schedule.
a. 2020-2023 Mailing Costs of$1,250;
b. 2020-2023 Publication Costs $225;
c. 2020-2023 Labor Costs $50,200;
d. Jan-Mar 2024 labor Costs $12,300; and
e. April 1-15, 2024, labor Costs $33,441.50.
REQUEST NO. 58: Staff is unable to open the following spreadsheets provided in
responses to Production Requests. Please provide the Excel and hardcopy printouts of the
following:
a. Response to Production Request No. 2 "2020_2023 Annual Depreciation Worksheet
SRU Water Known Schedule;"
b. Response to Production Request No. 5 "2023 Annual Depreciation Known changes"
and"2020_2024 Annual depreciation Known Changes;"
c. Response to Production Request No. 11 "Inland Power Master Meter List;"
d. Response to Production Request No. 12 "well pump record 2019,"well pump record
2020 2023" and"well volumes 20-24;"
e. Response to Production Request No. 15 "chlorine report 2019_2024;"
f. Response to Production Request No. 19 "Backup Power System;"
g. Response to Production Request No. 20 "Wireless meter changeout Cap Ex;"
h. Response to Production Request No. 30 "IPUC Excel General Rate Case 2_29_24
final;" and
i. Response to Production Request No. 32 "2020_2023 annual Depreciation Worksheet
SRU Water Known Schedule."
FOURTH PRODUCTION REQUEST
TO CDS STONERIDGE UTILITIES, LLC 2 MAY 9, 2024

REQUEST NO. 59: Please provide copies of the Company's 2022 and 2023 tax
returns.
REQUEST NO. 60: As a supplement to Production Request No. 31, please provide
identical reports for all months of 2022 and 2023 in Excel format.
REQUEST NO. 61: Please explain the Company's billing policies and practices used
to read customer meters. Pease answer the following:
a. Please explain if the Company charges seasonal rates. If so, please provide the month
and dates of the first and last meter reading of a calendar year.
b. Please explain how a customer is billed if the meter is not read every month.
c. If multiple months pass between meter readings, what is the monthly customer
charge?
d. If multiple months pass between meter readings, how is a customer's monthly
consumption determined?
DATED at Boise, Idaho, this 9 h day of May 2024.
i
Michael Duval
Deputy Attorney General
[:\Utility\UMISC\PRDREQ\SWS-W-24-01 PR#4.docx
FOURTH PRODUCTION REQUEST
TO CDS STONERIDGE UTILITIES, LLC 3 MAY 9, 2024

CERTIFICATE OF SERVICE
I HAVE THIS `��DAY OF MAY 2024
I HEREBY CERTIFY THAT ,
SERVED THE FOREGOING FOURTH PRODUCTION REQUEST OF THE
COMMISSION STAFF TO CDS STONERIDGE UTILITIES, LLC, IN CASE NO.
SWS-W-24-01, BY E-MAILING A COPY THEREOF, TO THE FOLLOWING:
CHAN KARUPIAH RICK HARUTHUNIAN
MANAGING PARTNER RAMSDEN, MARFICE, EALY& DE SMET,
CDS STONERIDGE UTILITIES, LLC LLP
P.O. BOX 298 700 NORTHWEST BLVD.
364 STONERIDGE ROAD P.O. BOX 1336
BLANCHARD, ID 83804 COEUR D'ALENE, ID 83816-1336
E-MAIL: chansan ,comcast.net E-MAIL: rharuthunianAnnedlaw.com
utilities(istoneridgeidaho.com
RANDOLPH LEE GARRISON,PRO SE
76 BELLFLOWER CT.
BLANCHARD, ID 83804
E-MAIL: izarrison(@,nngarrison.com
PATRICIA JORDAN, SECRETARY
CERTIFICATE OF SERVICE