20070619ICIP to IPC 4-5.pdf

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BIt(C!~'(i)1Nr &:: ~v.PLLCATTORNEYS AT LAW i 0 ;", 8:, Ii '
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Tel: [phone] I Fax: [phone]
perer!!!' richardson andol eary. com
O. Box 7218 Boise. ID 83707 - 515 N. 27rh Sr. Boise, ID 83702
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Peter Richardson
June 18 , 2007
Ms. Jean Jewell
Commission Secretary
Idaho Public Utilities Commission
POBox 83720
Boise ID 83720-0074
RE: Case No.lPC-07 -
Dear Ms. Jewell:
Enclosed please find three (3) copies of the SECOND PRODUCTION RE-
QUEST OF THE INDUSTRIAL CUSTOMERS OF IDAHO POWER TO IDAHO
POWER COMPANY in the above case. The original has been served on Idaho
Power Company.
I have also enclosed an extra copy to be service-dated and returned to us for
our files. Thank you.
Sincerely,~~S
Nina Curtis
Administrative Assistant
encl.
Peter 1. Richardson ISB # 3195
RICHARDSON & O'LEARY PLLC
515 N. 2ih Street
Boise, Idaho 83702
Telephone: [phone]
Fax: [phone]
peter~richardsonando leary. com
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Attorneys for the Industrial Customers of Idaho Power
BEFORE THE IDAHO PUBLIC UTILITIES COMMISSION
IN THE MATTER OF THE APPLICATION
OF IDAHO POWER COMPANY FOR
AUTHORITY TO INCREASE ITS RATES
AND CHARGES FOR ELECTRIC SERVICE
TO ELECTRIC CUSTOMERS IN THE STATE
OF IDAHO.
CASE NO. IPC-07-
SECOND PRODUCTION
REQUEST OF THE
INDUSTRIAL CUSTOMERS
OF IDAHO POWER TO IDAHO
POWER COMPANY
Pursuant to Rule 225 of the Rules of Procedure of the Idaho Public Utilities Commission
(the "Commission ), the Industrial Customers ofldaho Power (ICIP), by and through their
attorney of record, Peter J. Richardson, hereby requests that Idaho Power Company ("Idaho
Power ) provide the following documents.
This production request is to be considered as continuing, and Idaho Power 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 copy of your answer to Mr. Richardson at the address noted above and
one copy to Dr. Reading at 6070 Hill Road, Boise, Idaho 83703. Please provide Dr. Reading
copy in electronic fonnat, if available.
1 - SECOND PRODUCTION REQUEST OF ICIP TO IDAHO POWER - IPC-O7-
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.
REQUEST FOR PRODUCTION NO.
Please provide copies of Dr. Avera s workpapers that were used to prepare his testimony.
REQUEST FOR PRODUCTION NO.
If not otherwise provided in response to Request for Production No., please provide
copies of the rating agency reports referred to by Dr. Avera at Footnote Nos. 3 , 10, 11 , 12
, 14, 19 , 23 , 28 , and 71.
DATED this 18th day of June 2007.
RICHARDSON & O'LEARY PLLC
By: ~4L---
Peter J. Richardson, ISB #3195
Attorneys for the Industrial Customers
of Idaho Power
2 - SECOND PRODUCTION REQUEST OF ICIP TO IDAHO POWER - IPC-O7-
CERTIFICATE OF SERVICE
I HEREBY CERTIFY that on the 18th day of June, 2007, a true and correct copy of the
foregoing SECOND PRODUCTION REQUEST OF THE INDUSTRIAL CUSTOMERS OF
IDAHO POWER was served by u.S. Mail, postage prepaid to:
Barton Kline
Monica Moen
Idaho Power Company
PO Box 70
Boise, Idaho 83707-0070
Jean Jewell
Commission Secretary
Idaho Public Utilities Commission
472 West Washington Street
Boise, Idaho 83702
CUJ'1~
Nina Curtis
Administrative Assistant
3 - SECOND PRODUCTION REQUEST OF ICIP TO IDAHO POWER- IPC-O7-