20160106Staff 1-3 to PKS.pdf

ldaho Public Utilities CommissionNEIL PRICE Office of the SecretarvDEPUTYATTORNEYGENERAL BECEIVED
IDAHO PUBLIC UTILITIES coMMISSIoN JAN 0 O 2016
PO BOX 83720
BOISE, IDAHO 83720-0074 Boise, ldaho
[phone]
IDAHO BAR NO. 6864
Street Address for Express Mail:
472W. WASHINGTON
BOISE, IDAHO 83102-5918
Attorney for the Commission Staff
BEFORE THE IDAHO PUBLIC UTILITIES COMMISSION
IN THE MATTER OF THE APPLICATION OF )
PACKSADDLE ESTATES WATER COMPANY ) CASE NO. PKS-W-15-01
TO TRANSFER ITS CERTIFICATE OF PUBLIC )
CONVENTENCE AND NECESSITY NO. 320 TO ) FIRST PRODUCTION
PACKSADDLE WATER SYSTEMS,INC. ) REQUEST OF THE
) COMMISSION STAFF TO
) PACKSADDLE WATER
) SYSTEMS
)
)
The Staff of the Idaho Public Utilities Commission, by and through its attorney of record,
Neil Price, Deputy Attorney General, requests that Packsaddle Water Systems (Company,
Packsaddle) provide the following documents and information as soon as possible, but no later
than WEDNESDAY, JANUARY 27,2016.
This Production Request is to be considered as continuing, and the Company is requested
to provide, by way of supplementary responses, additional documents that it or any person acting
on its behalf may later obtain that will augment the documents or information produced.
Please provide answers to each question, supporting workpapers that provide detail or are
the source of information used in calculations, and the name, job title and telephone number of
the person preparing the documents. Please identify the name, job title, location and telephone
number of the record holder.
FIRST PRODUCTION REQUEST
TO PACKSADDLE WATER SYSTEMS 1 JANUARY 6,2016
In addition to the written copies provided as response to the requests, please provide all
Excel and electronic files on CD with formulas activated.
REQUEST NO. 1: Have the water rights held by Pack Saddle Development
Corporation been transferred to Packsaddle Water System, Inc.? If so, please provide
documentation of ownership. If not, please explain what steps, if any, Packsaddle Water System
has taken to obtain water rights.
REQUEST NO. 2: Please provide documentation that Packsaddle Water System owns
or otherwise legally occupies the property upon which the pump house sits. Staff is aware of a
previous claim that the pump house encroaches onto property not owned by Packsaddle Estates
Water Corporation.
REQUEST NO.3: Did Packsaddle Estates Water Corporation have any customer
deposits on file at the time of sale? If so, were these deposits retained by Packsaddle, refunded
to customers, or transferred to Packsaddle Water System?
DATED at Boise, Idaho, this |b*of January 2016.
d^frq-
Neil Price
Deputy Attorney General
Technical Staff: Chris Hecht
i:umisc:prodreq/pksw15. lnpcwh prod req 1
FIRST PRODUCTION REQUEST
TO PACKSADDLE WATER SYSTEMS JANUARY 6,2016
CERTIFICATE OF SERVICE
I HEREBY CERTIFY THAT I HAVE THIS 6TH DAY OF JANUARY 2016,
SERVED THE FOREGOING FIRST PRODUCTION REQUEST OF THE
COMMISSION STAFF TO PACKSADDLE WATER SYSTEMS, IN CASE NO.
PKS-W-Is-OI, BY MAILING A COPY THEREOF, POSTAGE PREPAID, TO THE
FOLLOWING:
ROBERT A VOSTREJS
TREASURER
PACKSADDLE WATER SYSTEMS
PO BOX 71
DRIGGS TD 83422
CERTIFICATE OF SERVICE