20101220PAC 6 (1-8) to Monsanto.pdf

Mark C. Moench
Daniel E. Solander
20 i South Main Street, Suite 2300
Salt Lake City, Utah 84111
Telephone No. (801) 220~4014
Facsimile No. [phone]
mark.moench (gpacificorp.com
daniel.solander(gpacificorp.com
Paul J. Hickey
Hickey & Evans, LLP
1800 Carey Avenue, Suite 700
P.O. Box 467
Cheyenne, WY 82003-0467
Ph. 307-634-1525
Fx.307-638-7335
phickey(l hickeyevans.com
Attorneys for Rocky Mountain Power
20m DEC 20 AM 9= 07
BEFORE THE IDAHO PUBLIC UTILITIES COMMSSION
IN THE MATTER OF THE
APPLICATION OF ROCKY
MOUNAI POWER FOR
APPROVAL OF CHAGES TO
ITS ELECTRIC SERVICE
SCHEDULES AN A PRICE
INCREASE OF $27.7 MILION,
OR APPROXITELY 13.7
PERCENT
)
)
)
)
)
)
CASE NO. PAC-E-I0-07
DISCOVERY REQUESTS
ROCKY MOUNTAIN POWER'S SIXTH SET OF DISCOVERY
REQUESTS TO MONSANTO COMPANY
COMES NOW, Rocky Mountain Power and hereby serves its sixth set of data requests
on Monsanto Company ("Monsanto") regarding the above docketed application of Rocky
Mountain Power, pursuant to Rule 225 of the Idaho Public Utilities Commssion's Rules of
Procedure, IDAPA 31.01.01, as follows:
DEFINITIONS AND INSTRUCTIONS
The following definitions and instructions apply to each of the requests for production set
forth herein and are deemed to be incorporated therein.
(1) "Document" and "documentation" should be interpreted as broadly as possible
to include, but not be limited to, the original or any copy, regardless of origin or location, of any
book, pamphlet, periodical publication, letter, scrapbook, diary, calendar, canceled check,
photograph, form, memorandum, schedule, tax return, telegram, telex, report, record, order or
notice of governmental action of any kind, study, minutes, logs, graph, index, tape, disc, internal
operating manual, data sheet or data processing card, or any other written, recorded, transcribed,
punched, taped, fimed, graphic or retrievable matter or data of any kind, however produced or
reproduced, to which you have or have had access. This definition is intended to include, but not
be limittt to, all documents which have been created and/or which reside in any type of
electronic format and is to be constred in its most comprehensive sense as contemplated by the
Idaho Rules of Civil Procedure.
(2) "Person or Entity" should be interpreted to denote, unless otherwise specified,
any natural person, firm, corporation, association, group, individual or organization of any typ
whatsoever.
(3) Any request to "identify" or "provide" should be interpreted to mean:
a) With respect to a natural person, that person's full name, title, job
description, and business and home address. Where the identification pertais to a past period,
as to each person identified who is still in your employ, or the employment of the group with
which such person is identified in response to any requests, provided, in addition, that person's
title and job description as of the time of such past period. Where the person is no longer in your
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employ or the employment of the group with which such person is identified in response to any
request, provide that person's affiliate, position, home and business address, if known, or if not
known, such person's last known affilation, position, home and business address, or portons
thereof as may be known.
b) With respect to an entity other than a natural person, that entity's name,
business, type of entity, present status and present or last known address.
c) With respect to a document, that document's title, date, author (and, if
different, the signer), addresses, recipients, or other persons who assisted in the preparation,
subject matter or general nature, and any amendments thereto, present location and custodian,
whether or not such document is in the respondent's possession, custody or control and whether
or not the document is claimed to be privileged. The final version and each draf of each
document should be identified and produced separately. Each original and each non-identical
copy (bearing marks or notations not found on the original) of each final version and draf of
each document should be identified and produced separately.
d) With respect to a physical facility, the location of the facilty, the intended
purpose of the faciliy, the actual use of such facility, the operating dates of the facility, the
installation date of the facility, the date utilization of the facilty termnated if applicable, and
whether the facilty is subject to the jurisdiction of the Federal Energy Regulatory Commssion,
the Idaho Public Utilties Commssion, or any other regulatory body.
(4) "Communication" should be interpreted to include, but not be limited to, all
forms of communication, whether written, printed, oral, pictorial, electronic or otherwise,
including testimony or sworn statement, or any means or type whatsoever.
(5) "Relating To" or "Related To" means pertaining to, presenting, discussing,
commenting on, analyzing, or mentioning in any way.
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(6) The term "and" and "or" should be construed either disjunctively or
conjunctively whenever appropriate in order to bring within the scope of each request any
information or document which might otherwise be considered to be beyond its scope.
(7) The singular form of a word should be interpreted as plural, and the plural form of
a word should be interpreted as singular, whenever appropriate in order to bring within the scope
of each request any information or document which might otherwise be considered to be beyond
its scope.
DATA REQUESTS
RM 1.1 Is Senator Bob Geddes curently an employee or a consultant of Monsanto?
RMP 1.2 Is Senator Bob Geddes a former employee or consultant of Monsanto?
RMP1.3 If the answer to either RM 1.1 or RM 1.2 is yes, please provide dates of past
and/or current employment or if a consultant please provide the terms of such engagement
including dates of service for past or current services.
RM 1.4 Has Senator Bob Geddes been asked by Monsanto to act as an external
spokesperson for Monsanto regarding issues pending before the Idaho Public Service
Commssion in Case No. PAC-E-10-07?
RM 1.5 Please provide any talng points, media communications plans, internal
documents or e-mails on directions and approved statements that were provided to him by
Monsanto or developed by Senator Geddes.
RMP 1.6 Does Senator Bob Geddes have any responsibilties or specific assignments as
either an employee or consultant to Monsanto related to the Rocky Mountain Power 2010
general rate case PAC-E-1O-07? If so, what are those responsibilties or assignments?
RM 1.7 If the answer to RMP 1.6 is yes, wil Senator Bob Geddes receive any additional
compensation depending upon the outcome in PAC-E-lO-07?
RMP 1.8 Please provide any and all internal communications, documents and
documentation related to Rocky Mountain Power's 2010 Idaho general rate case that were
provided to Senator Geddes or sent from Senator Geddes to Monsanto management or other
employees related to Case No. PAC-E-1O-07.
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DATED this~:ay of December 2010.
Respectfully submitted,
KY MOUNTAIN POWER
u J. Hicke
Hickey & Evans, LLP
1800 Carey Avenue, Sui
P.O. Box 467
Cheyenne, WY 82003-0467
Ph. 307-634-1525
FX.307-638-7335
phickey(l hickeyevans.com
Mark C. Moench
Danel E. Solander
201 South Main Street, Suite 2300
Salt Lake City, Utah 84111
Telephone No. [phone]
Facsimile No. [phone]
mark.moench (gpacificorp.com
danie1.solander(g pacificorp.com
Attorneys for Rocky Mountain Power
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CERTIFICATE OF SERVICE
I hereby certify that on this 15th day of December, 2010, I caused to be
served, via E-mail, and U.S. Mail a true and correct copy of Rocky Mountain
Power's Sixth Set of Discovery Requests to Monsanto in PAC-E-I0-07 to the
following:
Eric L. Olsen
Racine, Olson, Nye, Budge &
Bailey, Chartered
201 E. Center
P.O. Box 1391
Pocatello, ID 83204-1391
E-Mail: elo(acinelaw.net
Ronald L. Willams
Wiliams Bradbury, P.C.
1015 W. Hays St.
Boise ID, 83702
E-mail: ronCØlliamsbradbur.com
Tim Buller
Jason Hars
Agrum, Inc.
3010 Conda Road
Soda Springs, ID 83276
E-Mail: tbuller(agrum.com
JAHarst!agrum.com
Randall C. Budge
Racine, Olson, Nye, Budge &
Bailey, Chartered
201 E. Center
P.O. Box 1391
Pocatello, ID 83204-1391
E-Mail: rcb(acinelaw.net
Brad Purdy
CAPAI
2019 N. 17th St.
Boise, ID. 83702
E-mail: bmpurdythotmail.com
Benjamin J. Otto
Idaho Conservation League
710 N. 6th St.
P.O. Box 844
Boise, Idaho 83702
E-mail:
botto(dahoconservation.org
Anthony Yankel
29814 Lake Road
Bay Village, Ohio 44140
E-mail: tony(ankel.net
Katie Iverson (E-mail only)
Brubaker & Associates
17244 W. Cordova Court
Sunrise, Arzona 85387
E-Mail: kiversont!consultbaI.comJames R. Smith (E-mail only)
Monsanto Company
P.O. Box 816
Soda Springs, Idaho 83276
E-Mail: jim.r.smith(gonsanto.com
Melinda J. Davison
Davison Van Cleve, P.C.
333 S.W. Taylor, Suite 400
Portland, OR 97204
E-mail: mjdaMvclaw.com
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Scott Woodbur
Deputy Attorney General
Idaho Public Utilities Commission
472 W. Washington (83702)
PO Box 83720
Boise, ID 83720-0074
E-Mail:
scott. woodburyuc.idaho.gov
Dr. Don Reading (E-mail Only)
Idaho Conservation League
6070 Hil Road
Boise, ID 83703
E-mail: dreadingWindspring.com
Hi~'~
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