20240627Garrison 1 to Staff.pdf

RECEIVED
2024 June 27 AM 11:41
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 1st
AUTHORITY TO INCREASE ) REQUEST FOR PRODUCTION
ITS RATES AND CHARGES ) FROM IPUC STAFF
FOR WATER SERVICE IN THE )
STATE OF IDAHO )
REQUEST FOR DISCOVERY: Pursuant to the authority cited below,
Intervener, Randolph Lee Garrison, a party, as a 1st request for Production
of Documents from IPUC Staff, hereby requests production of the following
document(s).
CONTINUING REQUEST/FORMATS INTACT/IDENTITY OF PERSON ANSWERING:
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. This Production Request is continuing and IPUC Staff is
INTERVENER GARRISON'S 1st REQUEST FOR PRODUCTION
FROM IPUC STAFF — Page 1 of 4

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.
REQUEST NO. 1 : Any and all discovery:
(a) Received or obtained from CDS Stoneridge Utilities, LLC
(Stoneridge Utilities); and/or
(b) Received or obtained from any person or entity on behalf of
Stoneridge Utility; and/or
(c) Received or obtained from any person or entity related to
Stoneridge Utility.
As used herein, "discovery" means and includes (but is not limited to):
documents, summaries, spread sheets, admissions, answers to requests for
discovery, charts, notes, accounting records, quick-book records, electronic
records, balance sheets, business records, flow charts, water meter records,
INTERVENER GARRISON'S 1st REQUEST FOR PRODUCTION
FROM IPUC STAFF — Page 2 of 4

e-mails, proposed Tarriffs, marked up Tarriffs, water usage records; well
drilling records, invoices, checks, Checking accout records, bank records,
and/or any other item made in support or opposition to Stoneridge Utilities'
requests made in Case # SWS-W-24-01 (General Water Rate Increase) or
case # SWS-W-23-02 (Water Meter Installation Increase) or case #
SWS-W-23-03 (Debt/Capital Authorization Request).
DATED and Signed this 27th day of June 2024.
r\w.%Jl G
Randolph Lee Garrison
(541 ) 580-4446
[e-mail]
CERTIFICATE OF SERVICE
I HEREBY CERTIFY that on the 27th day of June, 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
Deputy Attorney General [e-mail]
IDAHO PUBLIC UTILITIES
COMMISSION
P.O. Box 83720
Boise, ID 83720-0074
INTERVENER GARRISON'S 1st REQUEST FOR PRODUCTION
FROM IPUC STAFF — Page 3 of 4

CDS STONERIDGE UTILITIES, By e-mail
LLC chansan(a_comcast.net
P.O. Box 298 utilities(a�_stoneridgeidaho.com
Blanchard, ID 83804 0eff(a_merkeley.com
Norman M. Semanko, By e-mail
ISB #4761 nsemanko(a_parsonsbehle.com
Patrick M. pngalamulume(c_parsonsbehle.c
Ngalamulume, ISB om
#11200 PARSONS
BEHLE & LATIMER
800 W. Main Street,
Suite 1300
Boise, Idaho 83702
Rick Haruthunian By e-mail:
CONDOMINIUM rharuthunian(a_rmedlaw.com
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 27th day of June 2024.
r\0:0-� G.y\, ,. . ` .1
Randolph Lee Garrison
(541 ) 580-4446
garrison(a_rmgarrison.com
INTERVENER GARRISON'S 1st REQUEST FOR PRODUCTION
FROM IPUC STAFF — Page 4 of 4