20181212PAC to IIPA Attach 1a CUB 1.pdf

UM 1968 / PacifiCorp
November 29, 2018
CUB Data Request 1

Despite PacifiCorp's diligent efforts, certain information protected from disclosure by the attorney-client privilege or other applicable privileges
or law may have been included in its responses to these data requests. PacifiCorp did not intend to waive any applicable privileges or rights by
the inadvertent disclosure of protected information, and PacifiCorp reserves its right to request the return or destruction of any privileged or
protected materials that may have been inadvertently disclosed. Please inform PacifiCorp immediately if you become aware of any inadvertently
disclosed information.
CUB Data Request 1

Email Communication between Gannet Fleming and PacifiCorp
Please provide all email communication between Gannet Fleming and PacifiCorp. In
addition to the email communication, please provide the electronic email attachments
between Gannet Fleming and PacifiCorp employees. Please provide the electronic files in
a zip file format.

Response to CUB Data Request 1

PacifiCorp objects to this request as overly broad, unduly burdensome, and outside the
scope of this proceeding. PacifiCorp also objects to this request to the extent it seeks
information that is protected under the attorney/client privilege or is attorney work
product or is related to the company’s expert witness work draft product. Without
waiving these objections, the company responds as follows:

Please refer to the response to Monsanto Data Request 6 in Idaho case PAC-E-18-08
provided as part of the 1st Supplemental Response to AWEC Data Request 001.