20200827IPC Reissued 1-2 to Mark Pecchenino.pdf

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LISA D. NORDSTROM
Lead Counsel
[e-mail]
August 27,2020
VIA ELECTRONIC FILING
Jan Noriyuki, Secretary
ldaho Public Utilities Commission
11331 W. Chinden Boulevard
Building 8, Suite 201-A
Boise, ldaho 83714
Re: Case No. IPC-E-20-29
Mark Pecchenino vs. ldaho Power Company
Dear Ms. Noriyuki:
Attached for electronic filing, pursuant to Order No. 34602, is ldaho Power Company's
Reissued First Production Request to Mark Pecchenino. This is substantively the same
documentfiled on July 24,2020: the Company is reissuing it after receiving the Summons
dated August 21,2020, to address possible procedural argument in Complainant's letter
dated August 2,2020, that the Complainant is not required to respond.
Because the Complainant and Respondent are parties named in the Summons, it should
beclearthattheCommission's Rulesof Procedure..including RP225and228 pertaining
to discovery requests and answers - apply equally to both.
lf you have any questions about the attached document, please do not hesitate to contact
me.
Very truly yours,
X*!.ff'^l-t".*,
LDN:sdh
Attachment
P.O.8or 70 O370D
t22t W. ld.ho 5t.
Bois., lD 8370:l
Lisa D. Nordstrom
LISA D. NORDSTROM (lSB No. 5733)
ldaho Power Company
1221West ldaho Street (83702)
P.O. Box 70
Boise, ldaho 83707
Telephone: [phone]
Facsimile: [phone]
I nord strom @ ida hopower. com
Attorney for ldaho Power Company
BEFORE THE IDAHO PUBLIC UTILITIES COMMISSION
MARK PECCHENINO,
COMPLAINANT,
IDAHO POWER COMPANY,
IDAHO POWER COMPANY'S
REISSUED FIRST PRODUCTION
REQUEST TO MARK
PECCHENINO
RESPONDENT.
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 September 17,2020.
This production request is to be deemed continuing in nature and Mark Pecchenino
is requested to provide, through supplementation, additiona! documents or information
IDAHO POWER COMPANY'S REISSUED FIRST PRODUCTION
REQUEST TO MARK PECCHENINO. 1
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CASE NO. rPC-E-20-29
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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 27th day of August 2020.
X*!,(r,*t"-*,
LISA D. NORDSTROM
Attorney for ldaho Power Company
IDAHO POWER COMPANY'S REISSUED FIRST PRODUCTION
REQUEST TO MARK PECCHENINO- 2
CERTIFICATE OF SERVICE
I HEREBY CERTIFY that on this 27th day of August 2020, I served a true and
correct copy of IDAHO POWER COMPANY'S REISSUED FIRST PRODUCTION
REQUEST TO MARK PECCHENINO, upon the following named parties by the method
indicated below, and addressed to the following:
Commission Staff
Dayn Hardie
Deputy Attomey General
ldaho Public Utilities Commission
1 1331 W. Chinden Boulevard
Building 8, Suite 201-A
Boise, ldaho 83714
Hand Delivered
_U.S. Mail
_Overnight Mail
_FAX
X Email davn.hardie puc.idaho.qov
Gomplainant
Mark Pecchenino
2173 N Ten Mile Road
Kuna, ldaho 83634
Hand Delivered
_U.S. Mail
_Overnight Mail
_FAXx Email [e-mail]
/**)-aM*._
Sandra Holmes,
Legal Administrative Assistant
IDAHO POWER COMPANY'S REISSUED FIRST PRODUCTION
REQUEST TO MARK PECCHENINO- 3