20200804Mark Pecchenino to IPC 1-2.pdf

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Response to IPC First Production Request
Both Requests I and 2
The Complainant and Mr. Thaden have both asked the Respondent to provide name(s),
date and time ofthe alleged notice. No response was provided to the Complainant. The
Complainant was told by the Respondent's staffthat notice was provided by a contractor
and they had proof. This story has since changed, according to vague responses from the
Respondent to Mr. Thaden as addressed in Addendum l. To date, no proof, name(s), date
or time as been provided by the Respondent. They have refused, despite multiple
requests. Therefore, the Complainaflt does not feel compelled to comply with this
production request or any future requests.
2. This requests are not reasonably calculated to lead to the discovery of relevant evidence.
The information requested will not produce evidence to the matters at hand, addressing
the core of the Complaint, trespass and arbitrary and cupreous policies.
3. The Complaint has not been approved by the PUC and therefore the requests are not ripe
at this time and would be unduly burdensome to the Complainant. Ifnot approved by the
tlis matter will likely result in some qpe of civil action and the Complaint does nol want
to provide any other information to the Respondent.
4. Granting the request, may interfere or influence other ongoing complaints or
investigations.
5. The Complainant views the requests as continued bulling by Idaho Power for the reasons
stated herein. It is an attempt to intimidate the Complainant, an average rate payer who
doesn't have a vast legal staff at their beckon call.
Request I
1 . The request is arbitrary. The Complainant cannot provide video tape of something that
did not occur.
2. This request is overly broad and unduly burdensome. It is the Respondent's duty to prove
notice and not the Complainant.
Request 2
L This request has little relevance to the matter at hand, trespass and the Respondent's
arbitrary and cupreous policies. No written documentation was provided to the
Complainant ofany decisions rendered by staff. Now the Respondent seeks the diligent
work ofthe Complainant. The request looks to provide the Respondent with
documentation when no documentation was provided to the Complainant by the
Respondent or their staff.
2. This request has no direct bearing on the Complaint. Failure to respond would not inhibit
the PUC form rendering their analysis of the issues stated in the complaint. If the staff
quoits were removed, what the Respondent is fishing for, the Complaint would still stand
on its own merit.
3. This request is overly broad and unduly burdensome and does not address any specific
issues or quote.