20080725Kroger to IPC 1-1, 1-2.pdf

BOEHM, KURTZ & lOWRY
ATrORNS AT lAW
36 EAT SENT STET
SUI 1510
CICIATI. OIDO 45202
TEPHONE (513) 421-255
TELECOPIE [phone]
9: 44
VIA OVERNIGHT MAIL
July 23, 2008
Jean D. Jewell, Secreta
Idaho Public Utilities Commission
472 West Washington Street
Boise, Idaho 83720
In re: Case No. IPC-E-08-10
Dear Ms. Jewell:
Enclosed please find nine the original and (8) copies of the FIRST SET OF DATA REQUESTS OF THE
KROGER CO. dba FRED MEYER AN SMIH'S FOOD AN DRUG TO THE IDAHO POWER COMPANY
to be fied in the above referenced matter. I also attach an electronic version.
Copies have been served on all paries on the attched certificate of service. Please place this document
of fie.
Respectflly yours,lIMichael L. Kur, Esq.
Kurt J. Boehm, Esq.
BOEHM, KUTZ & LOWRY
MLew
Ene!.
G:\WORKIMOOIIAHO\IC-E-QS-IO (Rte Cas)\Commsson Itt (Idao ).doc
CERTIFICATE OF SERVICE
I hereby certify that tre copy of the foregoing was served by electronic mail, unless otherwise noted, this23RD day of July, 2008 to the following: ~
Michael L. Kurz, Esq.
Kur J. Boehm, Esq.
Radall C. Budge
Eric L. Olsen
Racine, Olson, Nye, Budge &
Bailey, Charered
P.O. Box 1391; 201 E. Center
Pocatello, Idaho 83204-1391
E-mail: rcb(fracinelaw.net
E-mail: elo(fracinelaw.net
Anthony Yanel
29814 Lake Road
Bay Vilage, Ohio 44140
Fax: [phone]
E-mail: yanel(fattbi.com
Jean D. Jewell, Secreta
Idao Public Utilities Commission
P.O. Box 83720
472 W. Washigton Street
Boise, Idaho 83720-0074
E-mail: jjewell(fpuc.state.id.us
Baron L. Kline
Lisa D. Nordstrom
Donovan E. Waler
Idao Power Company
P.O. Box 70
Boise, Idao 83707-0070
bldie~idaopower.com
lnordstrom~idaopower.com
dwalker(fidahopower .com
JohnR. Gale
Vice President, Reguatory Affairs
Idaho Power Company
P.O. Box 70
Boise, Idaho 83707-0070
rgale(fidahopower .com
G:\WORK\KOGEIIAHO\i.E-8-10 (Rte Cas)\Commsson Itt (Idao).doc
BEFORE THE
IDAHO PUBLIC UTILITIES COMMISSION 2~j 9: 44
In The Matter Of The Application Of Idaho Power Company
For Authority To Increase Its Rates And Charges For Electrc
Service To Electric Customers In The State Of Idaho
¡tii\'
Case No. iiiH~Hi?i~
FIRST SET OF INTERROGATORIES OF
THE KROGER CO.
TO IDAHO POWER COMPAN
July 23, 2008
DEFINIONS
1. "Document" means the original and all copies (regardless of ongin. and whether or not including
additional writing thereon or attched thereto) of memoranda, reports, books, manuals, instrctions,
directives, records, forms, notes, letters, notices, confirations, telegrams, pamphlets, notations of any
sort concerning conversations, telephone calls, meetings or other communications, bulletins, trscripts,
dianes, analyses, summaries, correspondence investigations, questionnaires, sureys, worksheets, and all
drafts, preliminar versions, alterations, modifications, revisions, changes, amendments and wrtten
comments concerning the foregoing, in whatever form, stored or contained in or on whatever medium,
including computerized memory or magnetic media.
2. "Study" means any written, recorded, transcribed, taped, fimed, or graphic matter, however produced or
reproduced, either formally or informally, a paricular issue or sitution, in whatever detail, whether or
not the consideration of the issue or sitution is in a preliminar stage, and whether or not the
consideration was discontinued prior to completion.
3. "Person" means any natual person, corporation, professional corporation, parership, association, joint
ventue, propnetorship, fir, or the other business enterpnse or legal entity.
4. A request to identify a natual person means to state his or her full name and residence address, his or her
present last known position and business afliation at the time in question.
5. A request to identify a document means to state the date or dates,author.or originator, subject matter, all
addressees and recipients, tye of document (e.g., letter, memorandum, telegram, char etc.), number of
code number thereof or other means of identifying it, and its present location and custodian. If any such
document was, but is no longer in the Company's possession or subject to its control, state what
disposition was made of it.
6. A request to identify a person other than a natual person means to state its full name, the address of its
principal office, and the tye of entity.
7. "And" and "or" should be considered to be both conjunctive and disjunctive, unless specifically stated
otherwise.
8. "Each" and "any" should be considered to be both singular and plural, unless specifically stated
otherwise.
9. Words in the past tense should be considered to include the present, ~d words in the present tense
include the past, unless specifically stated otherwise.
10. "You" or ''your'' means the person whose fied testimony is the subject of these interrogatories and, to the
extent relevant and necessar to provide full and complete answers to any request, ''you'' or ''your'' may
be deemed to include any person with information relevant to any interrogatory who is or was employed
by or otherwise associated with the witness or who assisted, in any way, in the preparation of the witness'
testimony.
11. Idao Power Co. ("Company") means any of their offcers, directors, employees, or agents who may have
knowledge of the parcular matter addressed.
INSTRUCTIONS
.
1. If any matter is evidenced by, referenced to, reflected by, represented by, or recorded in any document,
please identify and produce for discovery and inspection each such document.
2. These interrogatories are continuing in natue, and information which the responding par later becomes
aware of, or has access to, and which is responsive to any request is to be made available to Fred Meyer
Stores, studies, documents, or other subject matter not yet completed tha.t wil be relied upon durg the
course of this case should be so identified and provided as soon as they are completed. The Respondent is
obliged to change, supplement and correct all answers to interrogatories to conform to available
information, including such information as it first becomes available to the Respondent after the answers
hereto are served.
3. Unless otherwse expressly provided, each interrogatory should be constred independently and not with
reference to any other interrogatory herein for purose of limitation.
4. The answers provided should first restate the question asked and also identify the person(s) supplying the
information.
5. Please answer each designated par of each information request separately. If you do not have complete
information with respect to any interrogatory, so state and give as much information as you do have with
respect to the matter inquired about, and identify each person whom you believe may have additional
information with respect thereto.
6. In the case of multiple witnesses, each interrogatory should be considered to apply to each witness who
wil testify to the information requested. Where copies of testimony~ transcripts or depositions are
requested, each witness should respond individually to the information request.
7. The interrogatories are to be answered under oath by the witness(es) responsible for the answer.
FIRST SET OF INTERROGATORIS OF .
THE KROGER CO. TO
IDAHO POWER COMPAN
CASE NO. IPC-E-08-10
Q1.1. Please provide a copy of all past and futue data responses provided by' Idaho Power Company to data
requests submitted by other paries in this case. Please provide a copy of your response(s) to our
consultat at the address listed below.
Q 1.2. Please provide an electronic version of all workpapers with formulas in tact in excel format and forward
to our consultat at the address listed below.
Kevin Higgins
Energy Strategies, LLC
Parkside Towers
215 South State Street, Suite200
Salt Lake City, Uta 84111
khigginsiienergystrat.com
Respectfully submitted,
IlJtt
Michael L. Kurtz, Esq.
Kur J. Boehm, Esq.
BOEHM, KURTZ & LOWRY
36 East Seventh Street, Suite 1510
Cincinati, Ohio 45202'
Ph: [phone] Fax: [phone]
E-mail: mkurtiiBKLlawfirm.com
kboehmiiBKLlawfirm.com