20170417IPC to Tidwell Supplemental 44.pdf

3Effi*.
An IDACORP Company
DONOVAN E. WALKER
Lead Counsel
[e-mail]
April 17, 2017
VIA HAND DELIVERY
Diane M. Hanian, Secretary
ldaho Public Utilities Commission
472 West Washington Street
Boise, ldaho 83702
Re Case No. IPC-E-16-28
Certificate of Public Convenience and Necessity for Wood River Valley
ldaho Power Company's Supplemental Response to Kiki Leslie A. Tidwell's
Request for Production No. 44
Dear Ms. Hanian
Enclosed forfiling in the above matter please find an original and three (3) copies of
ldaho Power Company's Supplemental Response to Kiki Leslie A. Tidwell's Request for
Production No.44.
Also enclosed are four (4) copies of a non-confidential disk containing information
responsive to Ms. Tidwell's production request.
Very ly yours,
Donovan E. Walker
DEW:csb
Enclosures
1221 W. ldaho St. (83702)
PO, Box 70
Boise, lD 83707
DONOVAN E. WALKER (lSB No. 5921)
ldaho Power Company
1221\Nest Idaho Street (83702)
P.O. Box 70
Boise, ldaho 83707
Telephone: [phone]
Facsimile: [phone]
dwalker@ idahopower. com
Attorney for ldaho Power Company
;-,'i
":I;.
.,.'
.; .".J:"t;:r ;l-i
.* ,:ie=: rn
crt
BEFORE THE IDAHO PUBLIC UTILITIES COMMISSION
IN THE MATTER OF THE APPLICATION
OF IDAHO POWER COMPANY FOR A
CERTIFICATE OF PUBLIC CONVENIENCE
AND NECESSITY FOR THE WOOD RIVER
VALLEY
CASE NO. !PC-E-16-28
IDAHO POWER COMPANY'S
SUPPLEMENTAL RESPONSE
TO KIKI LESLIE A. TIDWELL'S
REQUEST FOR PRODUCTION
NO. 44
COMES NOW, ldaho Power Company ("ldaho Powe/' or "Company") and
supplements its response to Kiki Leslie A. Tidwell's Request for Production No. 44 to
Idaho Power Company dated March 10,2017, as follows:
IDAHO POWER COMPANY'S SUPPLEi'ENTAL RESPONSE TO
KIKI LESLIE A. TIDWELL'S REQUEST FOR PRODUCTION NO.44 - 1
)
)
)
)
)
)
)
)
)
REQUEST FOR PRODUCTION NO. 44: Please provide all information in your
possession that relates to or mentions Ms. Tidwell, please include all information that
relates to her role as a holder of lda Corp/ldaho Power securities.
RESPONSE TO REQUEST FOR PRODUCTION NO. 44: Please see
Attachments 1-15 provided on the enclosed CD for the requested information that
relates to the mention of Ms. Tidwell that is not attorney-client privileged or attorney-
work product.
IDACORP, lnc. ("IDACORP") does not show Ms. Tidwell as a current registered
holder of IDACORP common stock. lf Ms. Tidwell owns shares of IDACORP common
stock through a broker or other nominee, those shares would be registered under the
broker or nominee name and not under Ms. Tidwell's name. IDACORP's Annual
Meeting attendance records indicate that Ms. Tidwell signed in for attendance at the
May 20,2009, IDACORP Annual Meeting.
ldaho Power needs additional time to identify and review communications
relevant to this Request for Production. ldaho Power will file a supplemental response
to this Request for Production within an additional 10 days, by April 12,2017 .
The response to this Request is sponsored by Pat Harrington, Corporate
Secretary, ldaho Power Company, and David Angell, Transmission and Distribution
Planning Manager, ldaho Power Company.
SUPPLEMENTAL RESPONSE TO REQUEST FOR PRODUCTION NO. 44:
ldaho Power objects to this Request for Production as being overly broad, not bounded
by time, requesting information that is neither relevant nor designed to lead to relevant
information, and is unduly burdensome. Notwithstanding, and without waiving, said
objections, ldaho Power provides the following response.
IDAHO POWER COMPANY'S SUPPLEMENTAL RESPONSE TO
KIKI LESLIE A. TIDWELL'S REQUEST FOR PRODUCTION NO. 44 - 2
Rather than search all 2000+ ldaho Power employees, eighteen (18) individuals
who have been involved with the Wood River Valley transmission line and/or Ms.
Tidwell were queried and an electronic search conducted. This produced 2,091
documents and e-mails that relate to or mention Ms. Tidwell. As you will notice in the
453 e-mails and documents provided on the enclosed CD with this supplemental
response, the search resulted in multiple identical copies of many items, particularly e-
mail items that may reside with several different employees.
Of the 2,091tota!, 1,301 e-mails and documents are related solely to drafting and
producing responses to Ms. Tidwell's requests for production in this case. They are a!!
internal communications circulating the requests, templates, drafts, and other
information required to respond to the production requests, as well as circulation of the
actual requests, templates, and drafts themselves. The process involved with
responding to requests for production in a pending case is done at and under the
direction, control, and supervision of the Company's attorney, in this case, Donovan E.
Walker, who advises and assists in the responses and ultimately reviews and signs the
final responses, which are then filed with the ldaho Public Utilities Commission
("Commission") and circulated to the parties. These items are attorney-work product
and are not provided herewith.
Two hundred forty-one (241) of the 2,091 documents and e-mails are simply
circulated copies of the filed pleadings from this case to ldaho Power employees and
legal staff, as well as the filed pleadings themselves. Because Ms. Tidwel! is a party to
the proceeding, her name is contained in all of these documents. All of these
documents are publicly available from the Commission, and these 241 e-mails and
documents are not provided herewith.
IDAHO POWER COMPANY'S SUPPLEMENTAL RESPONSE TO
KIKI LESLIE A. TIDWELL'S REQUEST FOR PRODUCTION NO. 44 - 3
Seventy-five (75) of the 2,09'l e-mails and documents are customer database
lists that happen to contain Ms. Tidwell's name, address, and other account related
information because she is a customer of ldaho Power. These database Iists also
contain thousands of other ldaho Power customer names and information. This
information is not provided herewith because it has no relevance to the pending
proceeding. Further, it is of no purpose or design to potentially lead to relevant
evidence, as well as the fact that it contains the confidential customer information of
thousands of other ldaho Power customers, as well as Ms. Tidwell.
Thirteen (13) of the 2,091 e-mails and documents contain some reference to
other individuals with the name Tidwell, not referring to Kiki Leslie A. Tidwell. These
items are not provided herewith.
Eight (8) of the 2,091 e-mails and documents contain aftorney-client privileged
communications. Seven (7) of the eight (8) are e-mails, five (5) of which are in the
same string, discuss development of information utilized in the drafting of testimony for
this case. The other item is Blaine County Commission hearing notes drafted at the
request and under the direction of legal counsel from an audio recording of said
hearing. These items are not provided herewith.
Finally, provided herewith on the enclosed CD are the remaining 453 e-mails and
documents that relate to or mention Ms. Tidwell.
The response to this Request is sponsored by Donovan E. Walker, Lead
Counsel, ldaho Power Company.
DATED at Boise, ldaho, this 17th day 2017.
NOVAN E. WALKER
Attorney for ldaho Power Company
IDAHO POWER COMPANY'S SUPPLEMENTAL RESPONSE TO
KIKI LESLIE A. TIDWELL'S REQUEST FOR PRODUCTION NO. 44 .4
CERTIFICATE OF SERVICE
t HEREBY CERTIFY that on the 17th day of Apri! 2017 t served a true and correct
copy of IDAHO POWER COMPANY'S SUPPLEMENTAL RESPONSE TO KlKl
LESLIE A. TIDWELL'S REQUEST FOR PRODUCTION NO. 44 upon the following
named parties by the method indicated below, and addressed to the following:
Commission Staff
Daphne Huang
Camille Christen
Deputy Attorneys General
ldaho Public Utilities Commission
472 West Washington (83702)
P.O. Box 83720
Boise, ldaho 83720-007 4
X Hand Delivered
_U.S. Mail
_Overnight Mail
_FAX
X Email daphne.huang@puc. idaho.qov
cam il le. ch risten@ puc. idaho. qov
ldaho Conservation League
Benjamin J. Otto
ldaho Conservation League
710 North 6th Street
Boise, ldaho 83702
_Hand DeliveredX U.S. Mail
_Overnight Mail
_FAXxEmail botto@idahoconservation.o rq
Sierra Club
Kelsey Jae Nunez
KELSEY JAE NUNEZLLC
920 North Clover Drive
Boise, ldaho 83703
_Hand DeliveredX U.S. Mail
_Overnight Mai!
_FAXX Email [e-mail]
Zach Waterman
Director, ldaho Sierra Club
503 West Franklin Street
Boise, ldaho 83702
_Hand DeliveredX U.S. Mail
_Overnight Mail
_FAXX Email [e-mail]
Michael Heckler
3606 North Prospect Way
Garden City, ldaho 83714
_Hand DeliveredX U.S. Mai!
_Overnight Mail
_FAXX Email [e-mail]
Kiki Leslie A. Tidwell
Peter J. Richardson
RICHARDSON ADAMS, PLLC
515 North 27th Street (83702)
P.O. Box 7218
Boise, ldaho 83707
_Hand DeliveredX U.S. Mail
_Overnight Mail
_FAXX Email [e-mail]
IDAHO POWER COMPANY'S SUPPLEMENTAL RESPONSE TO
KIKI LESLIE A. TIDWELL'S REQUEST FOR PRODUCTION NO. 44.5
Kiki Leslie A. Tidwell
300 Let'er Buck Road
Hailey, ldaho 83333
_Hand DeliveredX U.S. Mail
_Overnight Mail
_FAXX Email [e-mail]
City of Ketchum
Matthew A. Johnson
Wm. F. Gigray, lll
WHITE PETERSON GIGRAY
& NICHOLS, P.A.
5700 East Franklin Road, Suite 200
Nampa, ldaho 83687
_Hand DeliveredX U.S. Mail
_Overnight Mail
_FAXX Email [e-mail]
lndividual
Laura Midgley
231 Valley Club Drive
Hailey, ldaho 83333
_Hand DeliveredX U.S. Mail
_Overnight Mail
_FAXX Email [e-mail]
ComGox, LLC
C. Tom Arkoosh
ARKOOSH LAW OFFICES
802 West Bannock Street, Suite 900
P.O. Box 2900
Boise, ldaho 83701
_Hand DeliveredX U.S. Mai!
_Overnight Mail_FA)(X Emai! [e-mail]
IDAHO POWER COMPANY'S SUPPLEMENTAL RESPONSE TO
KIKI LESLIE A. TIDWELL'S REQUEST FOR PRODUCTION NO. 44 -6