20200724IPC 1-2 to Mark Pecchenino.pdf

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LISA D. NORDSTROi'
Lead Gounsel
[e-mail]
July 24,2O2O
VIA ELECTRONIC FILING
Diane Hanian, Secretary
ldaho Public Utilities Commission
11331 W. Chinden Boulevard
Building 8, Suite 201-A
Boise, ldaho 83714
Case No. IPC-E-2O-29
In the Matter of the Rule 54 Formal Complaint of Mark Pecchenino
Dear Ms. Hanian
Attached for electronic filing is ldaho Power Company's First Production Request to Mark
Pecchenino. lf you have any questions about the attached document, please do not
hesitate to contact me.
Very truly yours,
Re
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Attachment
LISA D. NORDSTROM (!SB No. 5733)
ldaho Power Company
1221West ldaho Street (83702)
P.O. Box 70
Boise, ldaho 83707
Telephone: [phone]
Facsimile: [phone]
I no rd stro m @ ida h o power. co m
Attorney for ldaho Power Company
BEFORE THE IDAHO PUBLIC UTILITIES COMMISSION
IN THE MATTER OF THE RULE 54
FORMAL COMPLAINT OF MARK
PECCHENINO
CASE NO. rPC-E-20-29
IDAHO POWER COMPANY'S
FIRST PRODUCTION REQUEST
TO MARK PECCHENINO
COMES NOW, ldaho Power Company ("Company"), by and through its attorney,
and hereby requests that Mark Pecchenino answer the following production requests
and provide the following information and documents in accordance with the
Commission's Rules of Procedure and applicable scheduling orders and notices to be
issued by the Commission in this proceeding.
Please provide information that is responsive to this request as soon as possible
but no later than August 14,2020.
This production request is to be deemed continuing in nature and Mark
Pecchenino is requested to provide, through supplementation, additional documents or
IDAHO POWER COMPANY'S FIRST PRODUCTION
REQUEST TO MARK PECCHENINO- 1
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information that is responsive to this request that it, or any person acting on its behalf,
may later come into possession or become aware of.
REQUEST NO. 1:
Please provide a copy of any outdoor video surveillance of the Property for
Friday, March 27,2020,and Monday, March 30,2020.
REQUEST NO. 2:
Please provide a copy of recorded audio and/or any other supporting
documentation to substantiate the claims of statements made by ldaho Power Company
personnel or personnel of its contractor, Asplundh, to Complainant as explicitly quoted
in the formal complaint on page numbers 6-14,25-26, 29-31, 37, and 39.
DATED at Boise, ldaho, this 24s day of July 2020.
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LISA D. NORDSTROM
Attorney for ldaho Power Company
IDAHO POWER COMPANY'S FIRST PRODUCTION
REOUEST TO MARK PECCHENINO- 2
CERTIFICATE OF SERVICE
I HEREBY CERTIFY that on this 24th day of July 20201 served a true and conect
copy of IDAHO POWER COMPANY'S FIRST PRODUCTION REQUEST TO MARK
PECCHENINO, upon the following named parties by the method indicated below, and
addressed to the following:
Commission Staff
Deputy Attomey General
ldaho Public Utilities Commission
11331 W. Chinden Boulevard
Building 8, Suite 201-A
Boise, ldaho 83714
Complainant
Mark Pecchenino
2173 N Ten Mile Road
Kuna, ldaho 83634
IDAHO POWER COMPANY'S FIRST PRODUCTION
REQUEST TO MARK PECCHENINO- 3
Hand Delivered
_U.S. Mail
_Overnight Mail
_FAX
-L Email [e-mail]
Hand Delivered
_U.S. Mail
_Overnight Mail
FAXx Email mpecchen inotOmsn.com
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Sandra Holmes,
Legal Adm inistrative Assistant