20240913Supplement to Motion to Compel.pdf

RECEIVED
FRIDAY, SEPTEMBER 13, 2024
Randolph Lee Garrison IDAHO PUBLIC
p UTILITIES COMMISSION
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 AUTHORITY ) INTERVENOR GARRISON'S
TO INCREASE ITS RATES AND ) SUPPLEMENT TO MOTION TO
CHARGES FOR WATER SERVICE ) COMPEL INTERVENOR'S
IN THE STATE OF IDAHO ) FIFTH REQUEST FOR
DISCOVERY FROM APPLICANT
(Requests #s 69-96)
Request to place Matter on
Commission's Calendar
PURPOSE: This document is to supplement Intervenor Garrison's Motion to
Compel Intervenor's 5t" Request for Discovery, filed 3 July 2024. Request is also
made to place this matter before the IPUC Commission on its agenda. The specific
documents to be place before the IPUC Commission are:
(1 ) Garrison's Motion to Compel, filed 28 August 2024;
(2) This Supplement to Garrison's Motion to Compel; and
SUPPLEMENT TO MOTION TO COMPEL INTERVENOR'S FIFTH REQUEST FOR DISCOVERY
FROM APPLICANT(Requests#s 69-96)
Page 1 of 10

(3) Stoneridge Utilities' response, filed 11 September 2024.
(4) Garrison's 5th Discovery request, filed 5 August 2024.
(5) Stoneridge Utilities response to discovery, filed - 6 September 2024.
The issue before the Commission is whether the Motion to Compel should be
Granted.
SPECIFIC RELIEF REQUESTED: This document specifically requests the IPUC
Commission:
(1 ) Grant in entirety, Garrison's Motion to Compel (filed 28 August 2024)
Garrison's 51" request for Discovery; and,
(2) Without limiting the foregoing, Garrison's requests an order compelling
an answer to Requests No 75, 80, 81 and 91 , in Garrison's 51" request for
Discovery.
SUPPLEMENTAL ARGUMENT:
(1 ) There is no dispute that Stoneridge Utilities' answer to Garrison's Fifth
request for discovery was untimely and came only after Garrison's motion
to Compel. Garrison's 5th Discovery requestwas served upon Stoneridge
Utilities by e-mail on 2 August 2024. Objections to the request were due
16 August 2024. Rule: 31 .01 .01 .225.03 (objection must be made within
14 days). Stoneridge Utilities delivery of discovery was due 23 August
SUPPLEMENT TO MOTION TO COMPEL INTERVENOR'S FIFTH REQUEST FOR DISCOVERY
FROM APPLICANT(Requests#s 69-96)
Page 2 of 10

2024 (21 days). Garrison's Motion to Compel was filed 28 August 2024.
Discovery was not delivered by Stoneridge Utilities until 6 September
2024.
(2) Stoneridge Utilities has filed a response to Garrison's Motion to compel
on 11 September 2024. This response contends, inter alia, the matter
was now "moot": Specifically,
"On September 6, 2024, CDS Stoneridge
Utilities, LLC, responded with answers and
objections to Intervenor Garrison's Motion to
Compel. Accordingly, Intervenor's motion to
compel such responses is now moot."
Untimely and delinquent responses to requests for discovery never
render a Motion to Compel moot. Otherwise, there would never be timely
responses to discovery. Rule: 31 .01 .01 .225 requires timely responses to
discovery. Lack of a timely response simply admits that the response was
not made according to rule and entitles the requesting party to have an
order entered compelling a response. An untimely response does not
prevent nor is it a defense to an order to compel. An untimely response
may mitigate, prevent or make moot sanctions, if a motion for sanctions
SUPPLEMENT TO MOTION TO COMPEL INTERVENOR'S FIFTH REQUEST FOR DISCOVERY
FROM APPLICANT(Requests#s 69-96)
Page 3 of 10

is made for not complying with the order to compel. After an order to
compel is entered, a motion for sanctions may or may not be necessary,
depending on the merits of the untimely responses.
(3) Without limiting or waiving the above argument, Garrison specifically
notes that Stoneridge Utilities' response to requests # 75, 80, 81 and 91
for the first time, contained an objection:
"Objection: the information requested is irrelevant,
inadmissible, and not reasonably calculated to
lead to the legitimate discovery of admissible
evidence and exceeds the obligations of this
administrative process. Furthermore, the request
for an organization's contractual relations from
entities or other sources not related to this case is
not relevant or the issues of this rate case.
First, there is no dispute that Stoneridge Utilities "objection" is untimely.
If untimely, the objection is waived. Rule: 31 .01 .01 .225.03 (objection must
be made within 14 days). This motion should be granted on this basis
alone.
Second, the rule provides: " Relevant information need not be admissible
SUPPLEMENT TO MOTION TO COMPEL INTERVENOR'S FIFTH REQUEST FOR DISCOVERY
FROM APPLICANT(Requests#s 69-96)
Page 4 of 10

at the trial if the discovery appears reasonably calculated to lead to the
discovery of admissible evidence. [emphasis add] Idaho Rules of Civil
Procedure 26 (b) (1 ) (A) incorporated by Rule 221 .05.
Discovery is required when the document/information requested is
reasonably calculated to lead to discovery of admissible evidence.
Requests # 75, 80, 81 and 91 all ask for detailed contract and financial
information on the related entities' contracts and dealings with Stoneridge
Utilities and its related entities. The related entities are Chan or Teresa
Karupiah and Esprit, JD Resorts and Bayview. All of these
persons/entities are directly and solely owned by Chan and/or Teresa
Karupiah and are also engaged and involved in the utility business. They
are related entities by and through which the Stoneridge Utility has been
funded or paid expenses. Discovery will show whether or not there is a
doubling up of expenses. The Discovery is likely to show whether or not
these related entities are paying similar expense and whether there is any
justification for those expenses within the related company or Stoneridge
Utility. The discovery is reasonably calculated to lead to admissible
evidence. In this general rate case, the intervenors and the ratepayers
have a right to probe the finances and contracts of related entities and to
SUPPLEMENT TO MOTION TO COMPEL INTERVENOR'S FIFTH REQUEST FOR DISCOVERY
FROM APPLICANT(Requests#s 69-96)
Page 5 of 10

test the believability of Stoneridge Utilities claimed expenses. The Motion
to compel should be granted.
Third, during the parties' "conferring" process, counsel for Stoneridge
Utilities argued:
"The current rate case objective is to determine
the current revenue and expenses for The
Company so that an adequate rate of return can
be calculated for the Owner. " And,
"The requests "ha[ve] nothing to do with
determining the `reasonable and necessary
expenses' of The Company."'
No doubt, one focus of a general rate proceeding could be
"determining whether The Company's current expenses are
reasonable and necessary to provide water to its ratepayers".
But it is not the only focus.
For example, Idaho Code Sec. 61-622 (1 ) & (2) requires Stoneridge
Utilities to show a rate increase is `justified":
"(1 ) No public utility shall raise any existing rate,
. . . under any circumstances whatsoever, except
SUPPLEMENT TO MOTION TO COMPEL INTERVENOR'S FIFTH REQUEST FOR DISCOVERY
FROM APPLICANT(Requests#s 69-96)
Page 6 of 10

upon a showing before the commission and a
finding by the commission that such increase is
justified." [emphasis added]
And,
" . any tariff . . . shall not become effective
except upon a showing to and a finding by the
commission that such tariff or schedule is
justified." [emphasis added]
And, Idaho Code 61-502 provides that rates must be "just,
reasonable or sufficient".
The evidence sought by the Requests for discovery all are relevant to or
could lead to relevant evidence of a just, reasonable or sufficient rate.'
The expenses paid by related entities are factors that can be considered
' 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, equipment,
facilities, classifications, and customer relations of the utility are at issue,
" Idaho Admin. Code r. 31 .01 .01 .124. 02.c.
SUPPLEMENT TO MOTION TO COMPEL INTERVENOR'S FIFTH REQUEST FOR DISCOVERY
FROM APPLICANT(Requests#s 69-96)
Page 7 of 10

in determining whether Stoneridge Utilities expenses are "reasonable and
necessary", and whether they are "justified".
CONCLUSION: Stoneridge Utilities has not responded to any of Garrison's
request for discovery in a timely way. As a result, 3 previous motions to compel
discovery have been filed (10 June 2024; 20 June 2024; 27 June 2024). Once again,
Stoneridge Utilities has failed to timely respond to Garrison's 51" request for Discovery.
Garrison's motion to compel should be Granted. The requested documents are
reasonably calculated to lead to discovery of admissible evidence.
MEET AND CONFER: Pursuant to IRCivP 37(a), Intervenor has in good faith
conferred or attempted to confer with Applicant in an effort to obtain discovery without
IPUC Commission action. See attached exhibit.
DATED and Signed this 12th day of September 2024.
Za,V,AO -T� Lee 6a.,rr%S0V,
Randolph Lee Garrison
(541 ) 580-4446
garrison((_rmgarrison.com
SUPPLEMENT TO MOTION TO COMPEL INTERVENOR'S FIFTH REQUEST FOR DISCOVERY
FROM APPLICANT(Requests#s 69-96)
Page 8 of 10

CERTIFICATE OF SERVICE
I HEREBY CERTIFY that on the 12th day of September, 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
CDS STONERIDGE UTILITIES, LLC By e-mail chansan(@_comcast.net
P.O. Box 298 utilities(cD_stoneridgeidaho.com
Blanchard, ID 83804 jeff(D_merkeley.com
Jason T. Piskel, Attorney for By e-mail [e-mail]
CDS STONERIDGE UTILITIES, LLC
P.O. Box 298
Blanchard, ID 83804
SUPPLEMENT TO MOTION TO COMPEL INTERVENOR'S FIFTH REQUEST FOR DISCOVERY
FROM APPLICANT(Requests#s 69-96)
Page 9 of 10

Norman M. Semanko, ISB #4761 By e-mail nsemanko(a_parsonsbehle.com
Patrick M. Ngalamulume, ISB #11200 pngalamulume(a)_parsonsbehle.com
PARSONS BEHLE & LATIMER
800 W. Main Street, Suite 1300
Boise, Idaho 83702
Brady Espeland, Attorney for By e-mail: bespeland(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 12th day of September 2024.
Z,a,V,AOo T fee 6&,rr%S0I,
Randolph Lee Garrison
SUPPLEMENT TO MOTION TO COMPEL INTERVENOR'S FIFTH REQUEST FOR DISCOVERY
FROM APPLICANT(Requests#s 69-96)
Page 10 of 10

[e-mail]
From: Jason T. Piskel <[e-mail]>
Sent: Wednesday, September 11, 2024 10:52 AM
To: [e-mail]; 'Norman M. Semanko'; 'Brady Espeland'; 'Michael Duval'
Cc: 'Chan'; 'Stoneridge Utilities'; 'Patrick M. Ngalamulume'; 'Marcus Johnson'; 'Jeffrey
Merkeley'
Subject: Re: New 5th attempt to confer-- Intervenor Garrison's Motion to Compel 5th request
for Discovery
Mr. Garrison:
I agree you created confusion I was not speaking about discovery,just the deadline to file a response to your
motion to compel. Certainly,your objections (some of which are not formed) require time for the Company to
address and present,but that can't be done in one day's time especially since you are still formulating them and
thus, I think your initial motion to compel is moot and we are in territory requiring another motion. In the
meantime,here is a response that to address your objections noted below:
Objection #i: Request# 75 (requesting a copy of the contact with Integrity Water Management): The
answer give for the request is: "See Request . . . NO. 74." Request # 74 dealt with the Happy Valley
loan. Request# 74 did not ask for the Integrity Water contract. Likewise, Request # 74 resulted in no
information or contract about Integrity Water Management.
The response by provided by the Company actually was:
Answer: See Request PRR NO. 74 for a copy of the Integrity Water Management contract with StoneRidge
Water.
I believe you thought the Reference was to Question #74 in your Discovery Request. When in fact it is clear
that the Company's answer referenced Question PRR NO. 74 which was in The Staff s 71h Discovery Request
and you will find a copy of the Integrity Management Contract there for review.
Objection #2 (collapsed): This is a series of objections to the Company's objection on Your Requests #s:75,
8o,81,91.
Company's Response:
Objection: the information requested is irrelevant, inadmissible, and not reasonably calculated to lead to the
legitimate discovery of admissible evidence and exceeds the obligations of this administrative process.
Furthermore,the request for an organization's contractual relations from entities or other sources not related
to this case is not relevant or the issues of this rate case.
The reason for the Company's objection is summarized as follows:
The current rate case objective is to determine the current revenue and expenses for The Company so that an
adequate rate of return can be calculated for the Owner.
In Company's Response to Staffs PRR -The IPUC Staff s scope is determining whether The Company's
current expenses are reasonable and necessary to provide water to its ratepayers.
In Company's response to PRR NO. 34 in the IPUC Staff s 2nd Production Request the Company provided Staff
with copies of Company's current Contract Labor Agreement between The Company and Esprit Enterprises,
LLC. All parties have access to this information, and you should review those documents.
1

Your misdirected focus on"doubling up on expenses", etc., appears to illustrate the scope of this case and the
work being done by IPUC Staff to determine the expenses they will recommend.The Company recently
received IPUC Staffs loth. Through over ioo prior IPUC Staff questions, during this case, they have not
requested anywhere to your level of examination of related company records in requests 75, 8o, 81, go—most
likely showing IPUC Staff know that what happens with other related companies, such as, "doubling up on
expenses" and"whether or not these related entities are paying similar expense and whether there is any
justification for those expenses within the related company or Stoneridge Utility"has nothing to do with
determining the"reasonable and necessary expenses" of The Company.
-JTP
Jason T.Piskel
d: 509.505.ioi8
www.p,�wyers.com
This communication is intended to be private.If you believe this message has been sent to you in error,reply to the sender
and then delete this message.
From: [e-mail] <[e-mail]>
Date: Tuesday, September 10, 2024 at 3:55 PM
To: 'Norman M. Semanko' <[e-mail]>, 'Brady Espeland' <[e-mail]>,
'Michael Duval' <[e-mail]>, Jason T. Piskel <[e-mail]>
Cc: 'Chan' <[e-mail]>, 'Stoneridge Utilities' <[e-mail]>, 'Patrick M.
Ngalamulume' <[e-mail]>, 'Marcus Johnson' <[e-mail]>, 'Jeffrey
Merkeley' <[e-mail]>
Subject: New 5th attempt to confer-- Intervenor Garrison's Motion to Compel 5th request for Discovery
Mr. Piskel:
I'm sorry, I must have created some confusion.
My e-mail to you simply noted Mr. Duvall (e-mail dated 30 August 2024) offered to
place this matter on the Commission agenda if the discovery matter (Garrison's 5t"
request) was not worked out. I suggested we (you and 1) both agree to have Mr.
Duvall delay any action, until hearing further from either of us (i.e. you or 1).
In response, you suggest[d] ." . . we stay such deadlines so we have an opportunity to
work through the below objections to the Company's responses and if not worked out,
we reset the briefing calendar and allow the Commission to rule. Is this agreeable?"
In answer to your question, "No, not agreeable". Because,
1. The first step (which should take little time) is for you to decide whether the Utility
wants to continue refusing discovery as to Requests 74, 75, 80, 81 and 91 .
If you continue to refuse, then I will notify Mr. Duvall to put the dispute on the
Commissions calendar.
2. If you decide to provide discovery, the I need to know when discovery will be
forthcoming. If you and I cannot agree, then, again, I'll notify Mr. Duvall to put the
dispute on the IPUC calendar.
For the record, I have other objections to the Utility's Answer to the 5t" Request for
Discovery and they are under development.
Can I hear from you tomorrow whether you continue to refuse discovery?
Thanks,
2

Randy Garrison
[phone]
garrison rmgarrison.corn
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From: Norman M. Semanko<[e-mail]>
Sent:Tuesday, September 10, 2024 12:29 PM
To: Brady Espeland <[e-mail]>; Michael Duval <[e-mail]>;Jason T. Piskel
<[e-mail]>; [e-mail]
Cc: 'Chan' <[e-mail]>; 'Stoneridge Utilities' <[e-mail]>; Patrick M. Ngalamulume
<[e-mail]>; Marcus Johnson <[e-mail]>; 'Jeffrey Merkeley'
<[e-mail]>
Subject: Re: 4th attempt to confer-- Intervenor Garrison's Motion to Compel 5th request for Discovery
Agreed.Thank you.
Norm Semanko
Norman M.Semanko
PARSONS Attorney at Law
Parsons Behle&Latimer
LATIMER 800 West Main Street, Suite 1300 • Boise, Idaho 83702
Main+1 208.562.4900 • Direct+1 208.562.4909 • Fax[phone]
awCorpoatiProfessional parsonsbehle.com • [e-mail] • vCard
Law Corporation
CONFIDENTIALITY NOTICE: This electronic mail message and any attachment(s)are confidential and may also contain privileged attorney-client
information or work product. The message is intended only for the use of the addressee. If you are not the intended recipient,or the person responsible
to deliver it to the intended recipient,you may not use,distribute,or copy this communication. If you have received the message in error,please
immediately notify us by reply electronic mail or by telephone at+1 801.532.1234,and delete this original message.
From: Brady Espeland <[e-mail]>
Sent:Tuesday, September 10, 2024 1:13:20 PM
To: Michael Duval <[e-mail]>;Jason T. Piskel <[e-mail]>;
[e-mail] <[e-mail]>
Cc: 'Chan' <chansan @comcast.net>; 'Stoneridge Utilities' <[e-mail]>; Patrick M. Ngalamulume
<[e-mail]>; Norman M. Semanko<[e-mail]>; Marcus Johnson
<[e-mail]>; 'Jeffrey Merkeley' <[e-mail]>
Subject: RE:4th attempt to confer-- Intervenor Garrison's Motion to Compel 5th request for Discovery
On behalf of the SRCCOA,I have no objection to the moving of any discovery deadlines,provided that these adjustments
do not impact any of the other modified procedure deadlines already established.
Brady L. Espeland
Attorney at Law
Ramsden, Marfice, Ealy&De Smet, LLP
700 Northwest Blvd.
3

P.O. Box 1336
Coeur d'Alene,ID 83816-1336
Telephone: [phone]
Facsimile: [phone]
www.rmedlaw.com
This e-mail is for the sole use of the intended recipient(s). It contains information belonging to Ramsden, Marfice, Ealy& De Smet,
LLP, which is confidential and/or legally privileged. If you are not the intended recipient,you are hereby notified that any disclosure,
copying, distribution, or taking of any action in reliance on the contents of this e-mail information is strictly prohibited. If you have
received this e-mail in error,please immediately notify the sender by reply e-mail and destroy all copies of the original message.
From: Michael Duval <[e-mail]>
Sent:Tuesday, September 10, 2024 10:41 AM
To:Jason T. Piskel <[e-mail]>; [e-mail]
Cc: 'Chan' <[e-mail]>; 'Stoneridge Utilities' <[e-mail]>;
[e-mail]; 'Norman Semanko/Parsons Behle' <[e-mail]>; Marcus
Johnson <[e-mail]>; 'Jeffrey Merkeley' <[e-mail]>; Brady Espeland
<[e-mail]>
Subject: RE:4th attempt to confer-- Intervenor Garrison's Motion to Compel 5th request for Discovery
I am fine with this. Unless I hear otherwise, I will hold off on presenting a decision memo to the Commission
until an express request is made for me to do so.
Best,
MD
Michael Duval I Deputy Attorney General
State General Counsel Division
Office of the Attorney General I State of Idaho
208-334-0320 1 ag.idaho.gov
NOTICE: This message, including any attachments, is intended only for the individual(s) or entity(ies) named
above and may contain information that is confidential, privileged, attorney work product, or otherwise
exempt from disclosure under applicable law. If you are not the intended recipient, please reply to the sender
that you have received this transmission in error, and then please delete this email.
From:Jason T. Piskel <[e-mail]>
Sent:Tuesday, September 10, 2024 11:37 AM
To:[e-mail]
Cc: Michael Duval <[e-mail]>; 'Chan' <[e-mail]>; 'Stoneridge Utilities'
<[e-mail]>; [e-mail]; 'Norman Semanko/ Parsons Behle'
<[e-mail]>; 'Marcus Johnson' <[e-mail]>; 'Jeffrey Merkeley'
<[e-mail]>; 'Brady Espeland' <[e-mail]>
Subject: Re: 4th attempt to confer-- Intervenor Garrison's Motion to Compel 5th request for Discovery
CAUTION:This email originated outside the State of Idaho network.Verify links and attachments BEFORE you click or open,even
if you recognize and/or trust the sender.Contact your agency service desk with any concerns.
Mr. Garrison&Mr. Duval:
I have the below email in mind and will confer with my client. I recognize there is a pending motion by Mr.
Garrison and it requires a response. I'm writing to suggest as Mr. Garrishon does below we stay such deadlines
4

so we have an opportunity to work through the below objections to the Company's responses and if not worked
out,we reset the briefing calendar and allow the Commission to rule. Is this agreeable?
-JTP
Jason T. Piskel
d: 509.505.1o18
www.pyklawyers.com
This communication is intended to be private.If you believe this message has been sent to you in error,reply to the sender
and then delete this message.
From: garrison rmgarrison.com <garrison(aD_rmgarrison.com>
Date: Monday, September 9, 2024 at 11 :33 AM
To: Jason T. Piskel <ipiskel(cipyklawyers.com>
Cc: 'Michael Duval' <michael.duval(a-).puc.idaho.gov>, 'Chan' <chansan(a�comcast.net>, 'Stoneridge
Utilities' <utilities stoneridgeidaho.com>, pngalamulume(c)_parsonsbehle.com
<pngalamulume(a-).parsonsbehle.com>, 'Norman Semanko / Parsons Behle'
<nsemanko(c_parsonsbehle.com>, 'Marcus Johnson' <miohnson(a)-rmedlaw.com>, 'Jeffrey Merkeley'
<ieff merkeley.com>, 'Brady Espeland' <bespelandCa�,rmedlaw.com>
Subject: 4th attempt to confer -- Intervenor Garrison's Motion to Compel 5th request for Discovery
Mr. Piskel:
The Utility's response (via Mr. Merkeley) to the 51" request for Discovery has been
received.
have several objections to the response, the first set of which I share with you now.
REQUEST # 75 (requesting a copy of the contact with Integrity Water
Management): The answer give for the request is: "See Request . . . NO.
74." Request # 74 dealt with the Happy Valley loan. Request # 74 did not ask for the
Integrity Water contract. Likewise, Request # 74 resulted in no information or contract
about Integrity Water Management.
ALSO, REGARDING REQUEST # 75: In addition to the contract between Integrity
Water and Stoneridge Utilities, this request also asked for the contracts with Integrity
Water and the related entities of both water and sewer operations involving or related
to Chan or Teresa Karupiah and Esprit, JD Resorts and Bayview. All of these
persons/entities are directly and solely owned by Chan and/or Teresa Karupiah. They
are related entities by and through which the Stoneridge Utility has been funded or
paid expenses. Discovery will show whether or not there is a doubling up of
expenses. The Discovery is likely to show whether or not these related entities are
paying similar expense and whether there is any justification for those expenses within
the related company or Stoneridge Utility. The discovery is reasonably calculated to
lead to admissible evidence.
Importantly, the objection is untimely under Rule: 31 .01 .01 .225.03 (objection must be
made within 14 days).
REQUEST # 80 & 81 (requesting W-2s for Chan Karupiah from CDS Stoneridge,
Utilities, Esprit, and JD Resorts): Chan and/or Teresa Karupiah are the sole owners of
5

these entities. They are related entities by and through which the Stoneridge Utility
has been funded or paid expenses. Both Chan and Teresa Karupiah have claimed
expenses for themselves in this proceeding. Discovery will show whether or not there
is a doubling up of expenses. The Discovery is likely to show whether or not these
related entities are paying similar expense and whether there is any justification for
those expenses within the related company or Stoneridge Utility. The discovery is
reasonably calculated to lead to admissible evidence, namely the reasonableness of
Stoneridge Utility expenses.
Importantly, the objection is untimely under Rule: 31 .01 .01 .225.03 (objection must be
made within 14 days).
REQUEST # 91 (requesting compensation Randi Flaherty): The answer discloses that
Randi Flaherty worked on this rate case. Request # 91 requested not only
compensation paid to Randi Flaherty from Stoneridge Utility, but also the related
persons/companies of Chan or Teresa Karupiah, JD Resorts and Bayview. Chan
and/or Teresa Karupiah are the sole owners of these entities. They are related entities
by and through which the Stoneridge Utility has been funded or paid expenses. The
expense of Randi Flaherty has been a claimed expenses for in this
proceeding. Discovery will show whether or not there is a doubling up of
expenses. The Discovery is likely to show whether or not these related entities are
paying similar expense and whether there is any justification for those expenses within
the related company or Stoneridge Utility. The discovery is reasonably calculated to
lead to admissible evidence, namely the reasonableness of Stoneridge Utility
expenses.
Importantly, the objection is untimely under Rule: 31 .01 .01 .225.03 (objection must be
made within 14 days).
There will be other objections to the responses, but I wanted to get these out to you
now.
Mr. Duvall (e-mail dated 30 August 2024) offered to place this matter on the
Commission agenda if the matter was not worked out. I suggest we both agree to
have Mr. Duvall delay any action, until hearing further from either of us.
hope discovery will be forthcoming, as "It makes little sense to spend rate payer
money on discovery disputes".
Randy Garrison
(541 ) 580-4446
garrison(aD-rmgarrison.com
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From:Jeffrey Merkeley<[e-mail]>
Sent: Friday, September 6, 2024 2:47 PM
To: Monica Barrios-Sanchez<[e-mail]>
6

Cc:[e-mail]; Michael Duval <[e-mail]>;Jason T. Piskel
<[e-mail]>; Chan <[e-mail]>; Stoneridge Utilities<[e-mail]>;
[e-mail]; Norman Semanko/Parsons Behle<[e-mail]>; Marcus
Johnson <[e-mail]>
Subject: Re: CDS StoneRidge Utilities, LLC I IPUC Case No.: SWS-W-24-01-- Intervenor Garrison's Motion to Compel 5th
request for Discovery
Please find attached The Company's response to Garrison's 5th Request for Discovery.
Jeff
Jeffrey Merkeley
Technical Assistance Group
208-920-0442
ieff@ merkeley.com
On Wed,Aug 28, 2024 at 1:34 PM Monica Barrios-Sanchez<[e-mail]>wrote:
Received.
Thank you
Monica Barrios-Sanchez
Commission Secretary
Idaho Public Utilities Commission
11331 W. Chinden Blvd.
Bldg. 8, Ste. 201-A
Boise, ID 83714
From:[e-mail] <[e-mail]>
Sent:Wednesday,August 28, 2024 1:30 PM
To: Monica Barrios-Sanchez<[e-mail]>; secretary<[e-mail]>
Cc: Michael Duval <[e-mail]>; 'Jason T. Piskel' <[e-mail]>; 'Chan'
<chansan @comcast.net>; 'Stoneridge Utilities' <[e-mail]>; 'Jeffrey Merkeley'
<[e-mail]>; [e-mail]; 'Norman Semanko/Parsons Behle'
<[e-mail]>; 'Marcus Johnson' <[e-mail]>
Subject: CDS StoneRidge Utilities, LLC I IPUC Case No.: SWS-W-24-01-- Intervenor Garrison's Motion to Compel 5th
request for Discovery
CAUTION:This email originated outside the State of Idaho network.Verify links and attachments BEFORE you click or open,even
if you recognize and/or trust the sender.Contact your agency service desk with any concerns.
Monica Barrios-Sanchez
Secretary
Idaho Public Utilities Commission
Boise, Idaho 83720-0074
Via e-mail secretaU(a-)puc.kdaho.gov
7

RE: CDS STONERIDGE UTILITIES, LLC'S APPLICATION FOR AUTHORITY TO
INCREASE ITS RATES AND CHARGES FOR WATER SERVICE IN THE STATE OF
IDAHO, Case Number SWS-W-24-01 , Intervenor Garrison's Motion to Compel 5th
request for Discovery
Attached for filing with the IPUC is Intervenor Garrison's Motion to Compel 5th request
for Discovery.
Very Truly yours,
Randolph Lee Garrison
76 Bellflower Ct
Blanchard ID 83804
garrison(a�rmgarrison.com
(541 ) 672-4441
cc:
Michael Duval
Deputy Attorney General
michael.duval(a)-puc.idaho.gov
CDS STONERIDGE UTILITIES, LLC
chansan(a)-comcast.net
utilities(a-)_stoneridgeidaho.com
ieff(o-)-merkeley.com
Jason T. Piskel
0 pis kel _pyklawyers.com
Norman M. Semanko
Patrick M. Ngalamulume
nsemanko(c)-parsonsbehle.com
pngalamulume(a)_parsonsbehle.com
Marcus Johnson
mjohnson(o-)_rmedlaw.com
a