20110107Email re lifting discovery freeze.pdf

Xan Allen
From:
Sent:
To:
Subject:
Kris Sasser
Friday, January 07,2011 6:58 AM
Xan Allen
FW: XRG v. PacifiCorp, IPUC Case No. PAC-E-10-08
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LUll JAll - 1 ~M 8: 04
Xan -
Please see below. Can you attach this to our intranet just below where you posted the
initial freeze notification? Thanks!
- Kris
-----Original Message-----
From: Jeff Lovinger (mailto:lovinger~lklaw.com)
Sent: Thursday, December 16, 2010 10: 59 AM
To: Greg Adams
Cc: Peter Richardson; Ken Kaufmann; Kris Sasser; Daniel Solander
Subject: XRG v. PacifiCorp, IPUC Case No. PAC-E-10-08
Thanks. I am forwarding your confirmation to Kris Sasser to let her know that the discovery
freeze will be lifted effective December 21, 2010.
Jeff
On Dec 16, 2010, at 9: 47 AM, Greg Adams wrote:
) Jeff, Receipt confirmed. We will get back to on any other issues we
) may need to discuss regarding discovery or the case.
)
) Greg Adams
) Richardson & O'Leary PLLC
) 515 N. 27th Street, 83702
) P.O. Box 7218, 83707
) Boise, Idaho
) Voice: 208.938.2236
) Facsimile: 208.938.7904
) Information contained in this electronic message and in any
) attachments hereto may contain information that is confidential,
) protected by the attorney/client privilege and/or attorney work
) product doctrine. This email is intended only for the use of the
) individual or entity named above. Inadvertent disclosure of the
) contents of this email or its attachments to unintended recipients is
) not intended to and does not constitute a waiver of the attorney/
) client privilege and/or attorney work product doctrine. This
) transmission is further covered by the Electronic Communication
) Privacy Act, 18 U.S.C. §§ 2510-2521.
)
) If you have received this email in error, immediately notify the
) sender of the erroneous receipt and destroy this email and any
) attachments of the same either electronic or printed. Any disclosure,
) dissemination, distribution, copying or use of the contents or
) information received in error is strictly prohibited.
) Thank you.
i
)
)
) -----Original Message-----
) From: Jeff Lovinger (mailto:lovinger~lklaw.com)
) Sent: Thursday, December 16, 2010 10: 31 AM
) To: Peter Richardson
) Cc: Greg Adamsj Ken Kaufmann
) Subject: Re: XRG
)
) Pete:
)
) Please let this e-mail serve as notice lifting the discovery freeze in
) XRG v. PacifiCorp, IPUCCase No. PAC-E-10-08, effective Tuesday,
) December 21, 2010. We expect to respond to XRG' s pending second set
) of discovery requests and serve Rocky Mountain Power' s second set of
) requests on Tuesday. Please confirm receipt of this notice and let me
) know if we need to discuss discovery or any other aspect of the case.
)
) Thanks,
)
) Jeff
)
) On Oct 18, 2010, at 10:23 AM, Peter Richardson wrote:
)
)) This will confirm a freeze on discovery pending the results of our
)) settlement discussions pursuant to the terms you have outlined below.
)) -Pete
))
)) Peter Richardson
)) Richardson & O'Leary
)) 515 N. 27th Street
)) Boise, Idaho 83702
)) [phone]
))
)) -----Original Message-----
)) From: Jeff Lovinger (mailto:lovinger~lklaw.com)
)) Sent: Monday, October 18, 2010 10: 09 AM
)) To: Peter Richardson
)) Cc: Greg Adamsj Ken Kaufmann
)) Subject: XRG
))
))
)) Pete:
))
)) We have begun to work with Paci fiCorp to process XRG i S settlement
)) proposal. I think it would be most efficient to freeze discovery as
)) we discussed briefly on Friday. I propose we begin a freeze of
)) indefinite duration and that either party can remove the freeze and
)) put us back on the current discovery schedule upon two business days
)) written notice (e-mail sufficient). Please confirm whether this is
)) acceptable.
))
)) Thanks,
))
)) Jeff
))
)) Jeffrey S. Lovinger
2
)) Lovinger Kaufmann LLP
)) 825 NE Mul tnomah, Suite 925
)) Portland, OR 97232-2150
)) [phone] (office)
)) [phone] (fax)
)) (503) 230- 7120 (di rect)
)) www.LKLaw.com
)) lovinger~LKLaw. com
))
))
)) THIS COMMUNICATION MAY CONTAIN CONFIDENTIAL INFORMATION AND MAY BE
)) SUBJECT TO ATTORNEY-CLIENT PRIVILEGE, THE ATTORNEY WORK PRODUCT
)) DOCTRINE, THE JOINT DEFENSE PRIVILEGE, AND/OR OTHER PRIVILEGES. If
)) you are not the intended recipient(s), or the employee or agent
)) responsible for delivery of this message to the intended
)) recipient(s), you are hereby notified that any dissemination,
)) distribution or copying of this e-mail message is strictly
)) prohibited. If you have received this message in error, please
)) immediately notify the sender and delete this e-mail message from
)) your computer.
))
))
))
))
)) ! SIG :4cbc710d44367545013629!
))
))
)
) Jeffrey S. Lovinger
) Lovinger Kaufmann LLP
) 825 NE Mul tnomah, Suite 925
) Portland, OR 97232-2150
) [phone] (office)
) [phone] (fax)
) [phone] (direct)
) www.LKLaw.com
) lovinger~LKLaw. com
)
)
) THIS COMMUNICATION MAY CONTAIN CONFIDENTIAL INFORMATION AND MAY BE
) SUBJECT TO ATTORNEY-CLIENT PRIVILEGE, THE ATTORNEY WORK PRODUCT
) DOCTRINE, THE JOINT DEFENSE PRIVILEGE, AND/OR OTHER PRIVILEGES. If you
) are not the intended recipient (s), or the employee or agent
) responsible for delivery of this message to the intended recipient(s),
) you are hereby notified that any dissemination, distribution or
) copying of this e-mail message is strictly prohibited. If you have
) received this message in error, please immediately notify the sender
) and delete this e-mail message from your computer.
)
)
)
)
)
)
Jeffrey S. Lovinger
Lovinger Kaufmann LLP
3
825 NE Mul tnomah, Suite 925
Portland, OR 97232-2150
[phone] (office)
[phone] (fax)
[phone] (direct)
www.LKLaw.com
lovinger~LKLaw. com
THIS COMMUNICATION MAY CONTAIN CONFIDENTIAL INFORMATION AND MAY BE SUBJECT TO ATTORNEY-CLIENT
PRIVILEGE, THE ATTORNEY WORK PRODUCT DOCTRINE, THE JOINT DEFENSE PRIVILEGE, AND/OR OTHER
PRIVILEGES. If you are not the intended recipient(s), or the employee or agent responsible
for delivery of this message to the intended recipient(s), you are hereby notified that any
dissemination, distribution or copying of this e-mail message is strictly prohibited. If you
have received this message in error, please immediately notify the sender and delete this e-
mail message from your computer.
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