20140804Clearwater 1-3 to Avista.pdf

Peter J. Richardson ISB # 3195
Gregory M. Adams ISB # 7454
RICHARDSON ADAMS, PLLC
515 N. 27e Sreet
Boise,Idatro 83702
Telephone: [phone]
Fax: [phone]
Peter@richardsonandolear,. com
8re g@richardsonandoleary. com
Attorneys for Clearwater Paper Corporation
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BEFORE THE IDAIIO PUBLIC UTILITIES COMMISSION
IN THE MATTER OF THE POWER COST ) CASE NO. AW-E-14-06
ADJUSTMENT (PCA) ANNUAL RATE )
ADJUSTMENT FILING OF AVISTA ) FIRST PRODUCTION REQUEST OF
CORPORATION ) CLEARWATER PAPER
) CORPORATTON
)
)
)
Pursuant to Rule 225 of the Rules of Procedure of the Idatro Public Utilities Commission
(the "Commission"), Clearwater Paper Corporation ("Clearwater") by and through its attomey of
record, Peter J. Richardson, hereby requests that Avista Corporation ("Avista") provide
responses to the following with supporting documents, where applicable.
This production request is to be considered as continuing, and Avista 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 responses or documents produced.
FIRST PRODUCTION REQUEST OF CLEARWATER PAPER CORPORATION
TN CASE NO. AVU-E-I4-06 _ PAGE I
Please provide an additional electronic copy, or if unavailable, a physical copy, to Dr.
Don Readingat:6070 Hill Road, Boise, Idatro 83703, Tel: [phone]; Fan: (208) 384-151l;
[e-mail] and in electronic form to [e-mail].
For each item, please indicate the name of the person(s) preparing the answers, along
with the job title of such person(s) and the witness at hearing who can sponsor the answer.
Some of the following requests may include disclosures deemed by to be confidential.
Counsel for Clearwater and Clearwater's expert witness, Don Reading, will execute a
confidentiality agreement as necessary to facilitate complete responses.
REOUEST FOR PRODUCTION NO.l
Please provide, in electronic format with all formulae intact where possible, all workpapers and
other documents used in the development of Avista's Application in this matter.
REOUEST FOR PRODUCTION NO.2
Please provide copies of all communications with the Idaho Public Utilities Commission and its
Staffregarding Avista's Application in this matter.
REOUEST FOR PRODUCTION NO. 3
Please provide copies of all responses to production requests provided to any other party to this
proceeding.
FTRST PRODUCTION REQUEST OF CLEARWATER PAPER CORPORATION
TN CASE NO. AVU-E.14-06 - PAGE 2
Datedthil4th day of Augurt 2q14.
RICHARDSON ADAMS, PLLC
I HEREBY CERTIFY that on the 4th day of August,2}l4, a true and correct copy of the within
and foregoing FIRST PRODUCTION REQUEST of Clearwater Paper Corporation in Case No.
AVU-E-14-06 was served by HAND DELIVERY, to:
Jean Jewell
Commission Secretary
Idatro Public Utilities Commission
472West Washington
Boise,Idaho 83702
and via electronic mail and U.S. Mail, postage prepaid to:
Kelly O. Norwood
Vice President
State and Federal Regulation
Avista Corporation
1411 E. Mission Ave.
Spokane, WA 99220
Kelly.norwood@ avistacorp. com
David J. Meyer
Vice President and Chief Counsel
for Regulatory and Governmental
Affairs
Avista Corporation
1411 E. Mission Ave.
Spokane, WA99220
David.meyer@ avistacorp. com
Nina Curtis
FTRST PRODUCTION REQUEST OF CLEARWATER PAPER CORPORATION
IN CASE NO. AVU-8.I4.06 _ PAGE 3