20250116Staff 11 to Flying H Trailer Ranch Inc.pdf

RECEIVED
Thursday, January 16, 2025 1:33:59 PM
IDAHO PUBLIC
UTILITIES COMMISSION
ADAM TRIPLETT
DEPUTY ATTORNEY GENERAL
IDAHO PUBLIC UTILITIES COMMISSION
PO BOX 83720
BOISE, IDAHO 83720-0074
(208) 334- 0318
IDAHO BAR NO. 10221
Street Address for Express Mail:
11331 W CHINDEN BLVD, BLDG 8, SUITE 201-A
BOISE, ID 83714
Attorney for the Commission Staff
BEFORE THE IDAHO PUBLIC UTILITIES COMMISSION
IN THE MATTER OF CAPITOL WATER )
CORPORATION'S PETITION REQUESTING ) CASE NO. CAP-W-24-03
AN INVESTIGATION INTO FLYING H )
TRAILOR RANCH )
SECOND PRODUCTION
REQUEST OF THE
COMMISSION STAFF
TO FLYING H TRAILER
RANCH,INC.
Staff of the Idaho Public Utilities Commission,by and through its attorney of record,
Adam Triplett, Deputy Attorney General, requests that Flying H Trailer Ranch, Inc.
("Company")provide the following documents and information as soon as possible, but no later
than THURSDAY, FEBRUARY 6, 2025.
This Production Request is to be considered as continuing, and the Company 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 or information produced.
Please provide answers to each question, supporting workpapers that provide detail or are
the source of information used in calculations, and the name,job title, and telephone number of
the person preparing the documents. Please also identify the name,job title, location, and
telephone number of the record holder.
SECOND PRODUCTION REQUEST
TO FLYING H. TRAILER RANCH INC. 1 JANUARY 16, 2025

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.
REQUEST NO. 11: Regarding the Company's response to Staffs Production Request
Nos. 4 and 9, please clarify whether the proceeds from lot rentals are used to cover the expenses
associated with the installation, maintenance, or operation of the water system. If not, please
explain how water system expenses are paid.
DATED at Boise, Idaho, this 161h day of January 2025.
Adam Triplett
Deputy Attorney General
I:\Utility\UMISC\PRDREQ\CAP-W-24-03 PR#2.docx
SECOND PRODUCTION REQUEST
TO FLYING H. TRAILER RANCH INC. 2 JANUARY 16, 2025

CERTIFICATE OF SERVICE
I HEREBY CERTIFY THAT I HAVE THIS I0 DAY OF JANUARY 2025
SERVED THE FOREGOING SECOND PRODUCTION REQUEST OF THE
COMMISSION STAFF TO FLYING H TRAILER RANCH, INC. , IN CASE NO. CAP-
W-24-03, BY E-MAILING A COPY THEREOF, TO THE FOLLOWING:
ROBERT PRICE JOHN EVANS
PRESIDENT FLYING H TRAILER RANCH
CAPITOL WATER CORP E-MAIL: johnkjohnevanslaw.com
2626 ELDORADO
BOISE ID 83704
E-MAIL: infokcUitolwatercorp.com
MICHAEL P. LAWRENCE
GIVENS PURSLEY, LLP
601 WEST BANNOCK STREET
P.O. BOX 2720
BOISE, ID 83701
EMAIL: mMl�i�ursle
PAT ICIA JORDAN,AfCREARY
CERTIFICATE OF SERVICE