20240614Attempt to Confer Exhibit - Intervenor Motion to Compel Discovery.pdf

I
RECEIVED
Friday, June 14, 2024
IDAHO PUBLIC
[e-mail] UTILITIES COMMISSION
1r-M.- [e-mail]
Sent: Wednesday,June 12, 2024 8:47 AM
T©: 'Jeffrey Merkeley'; '[e-mail]; '[e-mail]';
'Chan'; 'Teresa Karupiah'; '[e-mail]'; 'Michael Duval'
Subject: Supplemental Objections to Stoneridge Utilities PRR Responses
Jeff:
In addition to the obTeotions below, please also not the following objections (the
numbering below Vfith the next number following 'the first objections):
(6) Stoneridge Utilities response mUlSt Comply With Rule 22 . Your response does not
comply With Rule 228, because:
(a) There has been no agreement to use your "Google Documents"
approach. Agr eernent is required by Rule 228.01,.
(b) Answers must "'must restate in full each question asked, then state In fell the
party's response to the question and the persons who will be able to answer questions
about or sponsor the anmver at hearing , as required by Rolle 229.
(7) As stated in objection # 5, Rule 221.05 requires complianace with l RC P 34 (b)
(2) Subsection E (i) requires electronically stored information to be produced "as they
are kept In the USUQ� I course of business".
(c) The responses Iruave not been filed with the Commission. Filing with the
Commission is required by Rule 228.02.
Randy Garrison
(541) 580-444
garrison@ri-�ngarr,i,gon.com
From:[e-mail]<[e-mail]>
Sent:Tuesday,June 11, 2024 9:09 PM
To: 'Jeffrey Merkeley'<[e-mail]>; '[e-mail]'<rharunthunian@medlaw,com>;
'[e-mail]'<[e-mail]>; 'Chan'<[e-mail]>; 'Teresa
Ka rupiah'<tka rupia [e-mail]>; 'nsemanko@pa rsonsbeh le.com'<nsemanko@pa rsonsbehle.com>; 'Michael Duval'
<[e-mail]>
Subject:Objection to Stoneridge Utilities PRR Responses
Jeff:
(1)l understand that the documents provided are not subject to the Non-Disclosure
Agreement.
(2)AH the responses given by you are dead ends, evasive or not responsive to my
request for production of documents.
(3)Please respond by listing my request, immediately followed by your ansvv�er.
(4)Don't send us down Alice in Wonderland journey by clicking on files which are
dead ends or have no context or meaning.
(5)Please comply with lRCP 34 (b) (2). Rile 221 M.
1

For Example:
When I tried to access the first item, "Known Changes", I received these responses.,
Type People Modified
Name Last mo...
-$Backup Power System.xlsx Zft*%, Feb 14, 2C
E3 -$Wireless meter changeout Cap Ex.xlsx Feb 14, 2C
CM 2023 usage water.pdf Feb 6, 20,'
Backup Power System.xlsx dMell, Feb 26, 2(
Wireless meter changeout Cap Ex.xlsx dftV. Feb 21, 2C
T h e,n.-

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See shortcuts UPC
Name Last rev...
13 PR2 Quest. 31 - Comp 5:55 Pal
M PR2 Guest. 32 - Comp 5:55 PM
R3 PR2-Quest. 33 - Comp 5:53 PIS
In PR2 Quest. 34 -- Camp 5:55 PM
PR2 Quest. 35 - Camp 5:55 PM
R3 PR2 Quest. 36 - Camp Apr 24, 202t
Which returned this:
4

See shortcuts U
Name Last mo...
Chan Review Files 5:85 PM
-$See Exhibit 8 General Rate Case 2_15_2... Apr 8, 20'
© Silo #31 Title Page.docx :.: Apr 23, 2C
X onthly Revenue by Customer WITHOU... .: Apr 23, 2C
Which returned this:
Name t Last m{
C Original file with names Monthly Revenue ... �: Jun 8,
13 Original file with names Monthly Revenue ... .:.: Jun 5,
5

Which returned this:
STONERIDGE UTILITIES, LLC
Billing Register for 9/29/2023
(creatpd W29i2023 by T ER SA
Customerld Water Misc other Previous C
01-00030-00 35.06 0.00 0.00 0.00
BROWN,JOHN&DONNA Wtr Use 14,000
i 01-00220-00 35.85 0.00 0.00 0.00
MACKLIN,MIKE&LIBBY Wtr Use 15,000
01-00280-01 24.79 0.00 0.00 0.00
MOE.MARK&MARTHA Wtr Use 1,000
01-0031MO 42.17 0.00 0.00 0.00
COOK.CHARLES&KATHLEEN Wtr Use 23,000
01-01650-00 36.64 0.00 0.00 0.00
BECK,DELIA M. Wtr Use 16,000
01-02350-00 30.32 0.00 0.00 35.85
GURLEY.SCOTT&BARBARA Wtr Use 8,000
01-02880-00 25.58 0,00 0.00 0.00
MCKAMEY,JAMES B. Wtr Use 2,000
01.03710-00 27.95 0.00 0.O0 0.00
JMBCA Wtr Use 5,000
01-03720-00 61 A2 0.00 0.00 76.93
JMBCA Wtr Use 48,000
01-04270-00 29.53 0.00 0.00 0.00
RAPALLI,CATHRYN&BOB Wtr Use 7,000
01-04400-01 29.53 0.00 0.00 0.00
CAMPER,BRANDON&ABBEY Wtr Use 7,000
01-04520-00 44.am
0.00
COLES,MIKE&TERESA
01-04790-00 27. 0.00
A note at the end of your e-mail states:
6

"PRR 1,2,3,5., along with the primary Excel Exhibit with the application and a
couple of the individual excel files for known changes, volumes pumped and rate
case cost amortization. We are copying both other Intervenors."
This statement is without context, unintelligible and does not contain any documents
which are referred to.
Randy Garrison
[phone]
garrison@rm,qarrison.com
From:Jeffrey Merkeley<[e-mail]>
Sent:Tuesday,June 11,2024 6:13 PM
To: Randy Garrison<[e-mail]>; [e-mail]; [e-mail];
Chan<[e-mail]>;Teresa Karupiah<[e-mail]>; [e-mail]
Subject: PRR Responses
Randy,we've been struggling getting these files to send.We sending them from a google drive link.if you are prompted
to request access please reply and we will approve the access
when we get the email request.
Known Changes
2nd Production Request Submittal 4-24-24 1PUC
3rd Production Request Submittal 4-24-24
First Prod. Request Final Submittal-4-16-2024 Working File
PRR 1,2,3,5.,along with the primary Excel Exhibit with the application
and a couple of the individual excel tiles for known changes,volumes pumped and rate case cost amortization.
we are copying both other Intervenors.
Jeffrey Merkeley
Technical Assistance Group
208-920-0442
[e-mail]
7