20240610Garrison to SWS.pdf

RECEIVED
Monday, June 10, 2024
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