20230519C15 17 to City of Burley.pdf

Peter J. Richardson
ISB No.3195
Richardson Adams PLLC
515 N.27th Street
Boise,Idaho 83702
Telephone: [phone] I
Fax: [phone]
peter@richardsonadams. com
Attomeys for United Electric Co-op, Inc.
BEFORE THE
IDAHO PUBLIC UTILITIES COMMISSION
CASE NO. Cl5-E-23-01
IN THE MATTER OF UNITED ELECTRIC
CO-OP INC.'S FORMAL COMPLAINT FOR
VIOLATION OF CONTRACT ENTERED
INTO PURSUANT TO THE IDAHO
ELECTzuC STABILIZATION ACT
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SECOND PRODUCTION REQUEST
OF UNITED ELECTRIC CO-OP, INC.
TO THE CITY OF BURLEY
Pursuant to Rule 225 of the Rules of Procedure of the Idaho Public Utilities
Commission (the'oCommission" or "IPUC"), United Electric Co-op, Inc, by and through
its attorney of record, Peter J. Richardson, hereby requests that the City of Burley
("City") provide its responses to the following Requests for Production of documents and
Requests for Admission.
These Production Requests and Requests for Admission are to be considered as
continuing, and the City 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/update the documents produced.
Page I
SECOND PRODUCTION REQUEST OF
UNITED ELECTRIC CO-OP TO TFIE CI'fY OF' BURLEY
RECEIVED
2023 May 19, 3:05PM
IDAHO PUBLIC
UTILITIES COMMISSION
Please provide one copy of the City's responses to Mr. Richardson at the address
noted above and one copy to Mr. Michael Darrington at 1330 21't Street Heyburn, Idaho
83336. In lieu of physical copies, electronic copies of your responses may be provided to
Mr. Richardson at the email noted above and to Mr. Darrington at:
mdarrin gton@uec. coop.
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
For purposes of the following, references to "Suntado" are references to Suntado,
LLC's proposed dairylmilk processing facility in Burley, Idaho and to Suntado, LLC and
its employees, agents, contractors and persons or entities operating under (or at) its
control or direction. References to the City includes references to the City of Burley, its
employees, agents, mayor, council members and contractors and persons or entities
operating under (or at) its control or direction.
c service to Suntado.
PRODI ICTI ON RF,OT Itr,ST NO 7
In response to Production Request No. l6 the City stated:
The City of Burley has applied for, and received, a grant from the ldaho Department of
Commerce for $450,000. Said grant is exclusively to be applied to electrical
infrastructure for the Suntado project.
Please provide a copy of all documents in the City's possession related to the referenced grant.
All documents necessarily includes a copy of the referenced application, a copy of the grant
documents and copies of allminutes of meetings (e.g.councilmeeting minutes, electric
committee minutes etc.) communications and internal memos and studies related to the same.
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SECOND PRODUCTION REQUEST OF
UNITED Ë,I,ECTRIC CO-OPTO THE CITY OF BURLEY
DATED this 19th day of May 2023.
Page 3
SECOND PRODUCTION REQUEST OF
UNI'TED ELEC'IRIC CO-OP TO THE CITY OF BTJRLEY
Richardson Adams, PLLC
By
Peter J. Richardson
CERTIFICATE OF SERVICE
I HEREBY CERTIFY that on the l9th day of May 2023, a true and correct copy
of the within and foregoing SECOND PRODUCTION REUEST of United Electric Co-
op, Inc. was served by electronic means only to:
David Shirley, City Attorney
City of Burley
[e-mail]
Jaxon Munns, Esq.
City of Burley, Special Counsel
[e-mail]
Chris Burdin, Deputy Attomey General
Idaho Public Utilities Commission
chris.burdin@f'uc. idaho. gov
Jan Noriyuki, Secretary
Idaho Public Utilities Commission
idaho.sov
(
Richardson,ISB # 3195
Page 4
SECOND PRODUCTION REQUEST OF
UNITED ELECTRIC CO-OP TO THE CITY OF BURLEY