20150810Clearwater 1-3 to AVU.pdf

Peter J. Richardson (lSB No. 3195)
Greg Adams (lSB 7454)
Richardson Adams, PLLC
515 N.27ft Street
P.O. Box 7218
Boise,ldaho 83702
Telephone: [phone]
Fax: [phone]
peter@richardsonando I eary.com
Attomeys for Clearwater Paper Corporation
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CASENO. AVU.E-I5.07
FIRST PRODUCTION REQUEST OF
CLEARWATER PAPER
CORPORATTON TO AVISTA
CORPORATION
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BEFORE THE
IDAHO PUBLIC UTILITIES COMMTSSION
IN THE MATTER OF TIIE POWER COST
ADJUSTMENT (PCA) ANNUAL RATE
ADJUSTMENT FILING OF AVISTA
CORPORATION.
Pursuant to Rule 225 of the Rules of Procedure of the ldaho Public Utilities Commission
(the "Commission"), Clearwater Paper Corporation ("Clearwater") by and through their attomey
of record, Peter J. Richardson, hereby requests that Avista Corporation ("Avista") provide 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 documents produced.
Please provide one physicalcopy and one electronic copy, if available, of your answer to
Mr. Richardson at the address noted above. Please provide an additional electronic copy, or if
unavailable a physical copy, to Dr. Don Reading at: 6070 Hill Road, Boise, Idaho 83703, Tel:
Clearwater Paper First Productlon Request - AVU-E- I 5-07
[phone]; Fax: (208) 384- l5 I I ; [e-mail] and in electronic form to
marv. lewal [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 include disclosures deerned by Avista 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. I
Please provide, in electronic format with all formulae intact where possible, all workpapers and
other documents used in the development of Avista's Application.
REOUEST FOR PRODUCTION NO. 2
Please provide all discovery responses along with the workpapers and aftachments provided to
all other parties.
REOUEST FOR PRODUCTION NO. 3
Please provide copies of all communications with the Idaho Public Utilities Commission and its
Staff regarding Avista's Application in this matter.
DATED this 1Oft day of August 2015.
Richardson Adams, PLLC
Peter J. Richardson, SB #3195
RICHARDSON ADAMS, PLLC
Clearwater Paper First Production Request - AVU-E- I 5-07
CERTIFICATE OF SERVICE
I HEREBY CERTIFY that on the lOth day of August, 2015, a true and correct copy of
the within and foregoing FIRST PRODUCTION REQUEST of Clearwater Paper Corporation, in
Case No. AVU-E- l5-07 was served as indicated below to:
Ms. Jean Jewell
Commission Secretary
Idaho Public Utilities Commission
P O Box 83720
Boise [D 83720-0074
Kelly O. Norwood
Vice President
State and Federal Regulation
Avista Corporation
l4l I E. Mission Ave.
Spokane, W A 99220
Ke ll.norwood@.av istaco rp.com
David J. Meyer
Vice Presidentand Chief Counsel
For Regulatory and Governmental Affairs
Avista Corporation
l4l I E. Mission Ave.
Spokane, WA99220
Davi d. meyer@av istacorp.com
Electronic Copy
dockets@av istacorp.com
X_ Hand Delivery
_ U.S. Mail, postage pre-paid
Facsimile
Electronic Mail
_ Hand Deliver
X_U.S. Mail, postage pre-paid
_FacsimileX Electronic Mail
_ Hand Deliver
X_U.S. Mail, postage pre-paid
Facsimile
x_Electronic Mail
x
Administrative Assistant
Clearwater Paper First Production Request - AVU-E- I 5-07