20240802Garrison to SWS 69-96.pdf

RECEIVED
Friday, August 2, 2024
IDAHO PUBLIC
UTILITIES COMMISSION
Randolph Lee Garrison
Pro per
76 Bellflower Ct
Blanchard Idaho 83804
(541 ) 580-4446
garrison(a_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 5th
AUTHORITY TO INCREASE ) REQUEST FOR
ITS RATES AND CHARGES ) PRODUCTION/DISCOVERY
FOR WATER SERVICE IN THE ) FROM CDS STONERIDGE
STATE OF IDAHO ) UTILITIES
(#s 69 - 96)
REQUEST FOR DISCOVERY: Pursuant to the authority cited below,
Intervener, Randolph Lee Garrison, a party, as a 5th request for production
of documents and discovery from CDS Stoneridge Utilities, LLC, hereby
requests production of the following document(s) and discovery.
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 StoneRidge Utilities
5th Request for Production/Discovery — page 1 of 15

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 restate in full each
question asked, then state in full the party's response to the question and the
persons who will be able to answer questions about or sponsor the answer
at hearing. The restatement of the question and its accompanying answer
must begin on a new page whenever the preceding answer refers to other
documents or whenever the preceding question in the particular production
request or written interrogatory is not answered in full in that document. See
DAPA 31 .01 .01 .228.02
Delivery: Discovery is generally required to be provided electronically.
If Discovery is to be delivered by or through someone other than the partes
listed on the Commison Secretary's Second Amended Notice of Parties (filed
on 30 July 2024), please notify me in advance.
REQUEST NO. 69: Bob Kuchenski, Integrity Water Management, send out
a notice/letter dated 24 July 2024. The notice stated that well number 3 was
5th Request for Production/Discovery — page 2 of 15

not operational and that well number 1 was providing 100% of the water
demand.
(a) Is any part of the golf course served by well number 1?
(i) If so, what area of the golf course is served by well number 1?
(ii) If so, what is the yearly by month (for 2023) number of gallons
used by the golf course from well number 1?
(iii) If so, what is the year to date by month for 2024 number of
gallons used by the golf course from well number 1?
(b) Is any part of the golf course served by well number 3?
(1) If so, what area of the golf course is served by well number 3?
(ii) If so, what is the yearly (for 2023) number of gallons used by
the golf course from well number 3?
(iii) If so, what is the year to date by month for 2024 number of
gallons used by the golf course from well number 3?
(c) What wells/sources (other than wells # 1 and 3) provide water to
non-golf course areas, for example Stoneridge generally and Happy Valley?
(ii) If so, what is the annual number of gallons for 2023?
(iii) If so, what is the annual number of gallons by month to date
for 2024?
5th Request for Production/Discovery — page 3 of 15

(d) Is any part of the golf course served by other water wells/sources
(other than the well on fairway 16 and wells 1 & 3)?
(i) If so, what areas of the golf course are served?
(ii) If so, what is the annual number of gallons by month for 2023?
(iii) If so, what is the annual number of gallons by month to date
for 2024?
(e) The notice stated: "We are requesting an expedited review/approval
from IPUC for this pump replacement request, please contact IPUC staff and
encourage Staff's expediting this approval."
(i) Why did think any approval from IPUC is needed for a pump
replacement?
(ii) For what reason did you encourage "contact with IPUC staff
. . . [to] encourage Staff's expediting this approval"?
(iii) Do you agree IPUC approval was not necessary to replace
pump # 3?
(iv) What experience does Bob Kuchenski have working with the
IPUC?
REQUEST NO. 70: Regarding well/pump # 2:
(a) When was this well last in service?
5th Request for Production/Discovery — page 4 of 15

(b) Why was it not repaired or replace?
REQUEST NO. 65: In case number SWS-W-23-23, Commission staff noted:
The Company has already recorded a note payable to Esprit of$787,782 and
advances from associated companies of $196,422, totaling $984,204.
(a) Did any of this money pay for any repairs, improvements, or pumps
involving well number 1 or well number 3?
(i) If so, exactly what amount of money was spent on repair,
improvements or pumps for well number 1 or well number 3?
(ii) If so, exactly what repair, improvement, or pumps was done/to
well number 1 or well number 3?
(ii) If not, why did you not allocate the some of this money to a "30
year old pump"?
(b) Was this sum ($984,204) actually transferred into the accounts of
the water utility, CDS Stoneridge Utilities, LLC?
(1) If so, please provide the deposit receipts.
(ii) If not, please provide the company/entity/place the money was
deposited in the deposit receipts.
REQUEST NO. 71 : Are you aware of a water pressure problem in any area
you serve.
5th Request for Production/Discovery — page 5 of 15

(a) If so, what areas have a water pressure problem?
(b) If so, what steps are being taken to remediate the water pressure
problem?
REQUEST NO. 72: Regarding the new well for the Golf Course put on line at
or near October 2023:
(a) Is the new well located at, near and on the 16th Fairway?
(b) Discovery disclosed on 1 August 2024 contained a file "Gofl (sic)
Irrigation Meer (sic) Daily Readings 2024 - 2025". Only one reading was
recorded and that was for July 9, 2024. These was no indication when the
last reading was taken.
(i) What is the number of gallons pumped by the new golf course well
on a monthly basis from and including October 2023 to present?
(ii) What is the number of gallons pumped by the new golf course well
on a monthly basis 2024 to present?
(iii) Please include a date for each entry from which the meter reading
is taken.
(c) Please identify the source of all funds, by date and amount, for the
construction and installation of the new well.
(d) Please provide all cancelled checks for the funds used for the
5th Request for Production/Discovery — page 6 of 15

construction and installation of the new well.
(e) Please provide invoices (on a monthly basis) for all electricity paid
by for the pump and well from it's inception to present.
REQUEST NO. 73: Did the Golf Course reduce its water usage consistent
with Bob Kuchenski, Integrity Water Management, notice/letter dated 24 July
2024?
(i) If so, what amount of gallons were reduced?
(ii) What amount of water was reduced from pump # 1?
(iii) What amount of water was reduced from pump # 3?
(iv) If not, why not, in light of water to the golf course was to be
"interruptible" and therefore paid at a lesser rate?
(v) Does the CDS Stoneridge Utility presently receive any benefit
from the golf course water being "interruptible"?
(vi) If so, was is the benefit?
(vii) In the event the golf course water is interrupted, how and in
water manner is that specifically done and accomplished?
REQUEST NO. 74: Regarding Happy Valley loan:
(a) The Happy Valley loan was taken out in 2003, correct?
(b) The loan was for 20 years, correct?
5th Request for Production/Discovery — page 7 of 15

(c) Why has the loan not been paid off?
(d) The balance of the loan was reported to be $104,005.43 as of
January 2024. After 20 years, why is there still a balance?
(e) The contract provided in response to Request # 32 does not have
a copy of the promissory note referred to in Section VIII A. (page 8). Please
provide the promissory note.
(f) The response to Request # 32 provided a loan payment schedule
from 2019 to March 2024. Please provide a schedule for all other payments.
REQUEST NO. 75: Please provide all contract documents, directions or
instruction to/with Integrity Water Management. This request includes, but is
not limited to, both water and sewer operations involving or related to Chan
or Teresa Karupiah and/or for CDS Stoneridge Utilities, Esprit, JD Resorts
and Bayview.
REQUEST NO. 76: Please list all employees of the CDS Stoneridge Utilities.
REQUEST NO. 77: Please list all contracted persons with CDS Stoneridge
Utilities (except for Water Systems Management, Sandpoint, identified in
Request 36 and Integrity Water Management).
REQUEST NO. 78: Please provide the contract, directions and/or instructions
to all contracted persons/entities with CDS Stoneridge Utilities.
5th Request for Production/Discovery — page 8 of 15

REQUEST NO. 79: Please provide all 2023 W-2s for all employees of the
Utility.
REQUEST NO. 80: Provide all W-2s for Chan Karupiah from CDS Stoneridge
Utilities, Esprit, and JD Resorts.
REQUEST NO. 81 : Provide all 2023 W-2s for Teresa Karupiah from CDS
Stoneridge Utilities, Esprit, and JD Resorts.
REQUEST NO. 82: The Annual report filed with IPUC shows a 2019 expense
for Rentals- Property & Equipment in the amount of $85,200.00, correct?
(a) Please provide a breakdown of this expense for each month,
allocated to each person or entity.
REQUEST NO. 83: The Annual report filed with IPUC shows a 2020 expense
for Rentals- Property & Equipment in the amount of $63,735.00, correct?
(a) Please provide a breakdown of this expense for each month,
allocated to each person or entity.
REQUEST NO. 84: The Annual report filed with IPUC shows a 2021 expense
for Rentals- Property & Equipment in the amount of $68,704.00, correct?
(a) Please provide a breakdown of this expense for each month,
allocated to each person or entity.
REQUEST NO. 85: The Annual report filed with IPUC shows a 2022 expense
5th Request for Production/Discovery — page 9 of 15

for Rentals- Property & Equipment in the amount of $61 ,371 .00, correct?
(a) Please provide a breakdown of this expense for each month,
allocated to each person or entity.
REQUEST NO. 86: The Annual report filed with IPUC shows a 2023 expense
for Rentals- Property & Equipment in the amount of $79,465.00, correct?
(a) Please provide a breakdown of this expense for each month,
allocated to each person or entity.
REQUEST NO. 87: What is the 2024 year to present date for Rentals-
Property & Equipment Expenses?
(a) Please provide a breakdown of this expense for each month,
allocated to each person or entity.
REQUEST NO. 88: Esprit leases to the Water Utility water rights and use of
Rights of Way. Why are the water rights and use of Rights of Way not
already a part of and owned the Utility?
(a) What are the annual actual cash costs to Esprit of the water rights
and use of the Rights of Way?
REQUEST NO. 89: The Annual report filed with IPUC shows a 2023 expense
for Labor - Amin & General in the amount $67,863.00, correct?
(a) Please provide a breakdown of this expense for each month,
5th Request for Production/Discovery — page 10 of 15

allocated to each person or entity.
REQUEST NO. 90: The Annual report filed with IPUC shows a 2023 expense
for Salaries— Off. & Directors in the amount $39,303.00, correct?
(a) Are the only persons in this expense item Chan Karupiah and
Teresa Karupiah?
(b) Please provide a breakdown of this expense for each month,
allocated to each person or entity.
REQUEST NO. 91 : Regarding Randi Flaherty,
(a) Please provide any employment contracts, agreements, directions
or instructions involving her employment.
(b) Please provide her 2024 compensation by month from all entities
associated with or involving Chan or Teresa Karupiah, and/or for CDS
Stoneridge Utilities, JD Resorts and Bayview
REQUEST NO. 92: The Annual report filed with IPUC shows a 2023 expense
for Labor - Amin & General in the amount $67,863.00, correct?
(a) Please provide a breakdown of this expense for each month,
allocated to each person or entity.
REQUEST NO. 93: Please provide a year to date (2024) detail for Labor -
Amin & General.
5th Request for Production/Discovery — page 11 of 15

(a) Please provide a breakdown of this expense for each month (2024),
allocated to each person or entity.
REQUEST NO. 94: Regarding the schedule provided in response to Request
# 1 , please provide the time cards, logs or details of each employee for the
days claimed to have been working (on the rate case).
REQUEST NO. 95: Regarding the IDEQ Report dated 10 October 2019 and
attached to response # 16:
(a) The report states (at pages 2/3) the pump house buildings contain
chlorination components for both wells 1 and 2. The water feeds from both
wells 1 and 2 into 2 lines for distribution and "a separate line for the golf
course. A fourth line is abandoned . . . The golf course (irrigation) line is not
chlorinated".
(i) Is this still true today?
(ii) Was this true in October 2023?
(iii) If either of the above are not true, when was the change
made not to have a "golf curse (irrigation) line".
(iii) If a change was made not to have a "golf curse (irrigation)
line" why was the change made?
(iv) Explain why is there no current DEQ report (IDEA Sanitary
5th Request for Production/Discovery — page 12 of 15

Survey)?
REQUEST NO. 96: Regarding all of the sub-questions in this Request # 91 ,
if any of the requests are not answered and/or are objected to, please provide
the name of the person best suited to answer the question; several dates and
times his/her deposition may be taken; and a proposed place of deposition.
(a) Do you agree that CDS Stoneridge Utilities owes its customers a
duty of good faith and fair dealing as describe in Burns Concrete, Inc. v.
Teton County, 168 Idaho 442, 483 P.3d 985 (2020) ["The district court did not
err in its determination that the County violated the covenant of good faith and
fair dealing. A party violates this covenant when it "violates, nullifies or
significantly impairs any benefit of the contract."]?
(b) Do you agree CDS Stoneridge Utilities violated its duty of good faith
and fair dealing, by significantly impairing a benefit of its contract when
removing most of the golf course water service from CDS Stoneridge
Utilities?
(c) Do you agree that the golf course was a significant benefit to CDS
Stoneridge Utilities by providing to the Utility net review (after electricity and
chlorine expense) of $12,648.59.
5th Request for Production/Discovery — page 13 of 15

(d) Do you agree that the golf course was a significant benefit to the
customers of CDS Stoneridge Utilities by providing a broader base and a high
end user to cover and pay for costs of the Utility?
DATED and Signed this 2nd day of August 2024.
GV\,A `.4
Randolph Lee Garrsion
CERTIFICATE OF SERVICE
I HEREBY CERTIFY that on the 2nd day of August, 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
Chan Karupiah By e-mail chansanacomcast.net
CDS STONERIDGE UTILITIES, LLC utilities�stoneridgeidaho.com
P.O. Box 298 Jeff [e-mail]
Blanchard, ID 83804
Jason T. Piskel By e-mail: jpiskel(�D_pyklawyers.com
Piskel Yahne Kovarik, PLLC
612 W. Main Ave., Suite 207
Spokane, WA 99201
5th Request for Production/Discovery — page 14 of 15

Norman M. Semanko, ISB #4761 By e-mail nsemanko(oparsonsbehle.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(a_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 2nd day of August 2024.
Gv\,^ `4
Randolph Lee Garrison
5th Request for Production/Discovery — page 15 of 15