20211201Staff 1 to ROC.pdf

JOHN R. HAMMOND, JR.
DEPUTY ATTORNEY GENERAL
IDAHO PUBLIC UTILITIES COMMISSION
PO BOX 83720
BOISE, IDAHO 83720-0074
(208) 334-03s7
IDAHO BAR NO. 5470
ROCKY MOUNTAIN UTILITY COMPANY,
INC.
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Street Address for Express Mail:
I I33I W CHINDEN BLVD, BLDG 8, SUITE 2OI-A
BOISE,ID 837I4
Attorney for the Commission Staff
BEFORE THE IDAHO PUBLIC UTILITIES COMMISSION
NICOLE BURBANK,
CASE NO. ROC-W-21-01
COMPLAINANT,
vs.
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FIRST PRODUCTION REQUEST
OF THE COMMISSION STAFF
TO ROCKY MOUNTAIN
UTILITY COMPANY,INC.
RESPONDENT.
The Staff of the Idaho Public Utilities Commission, by and through its attorney of record,
John R. Hammond, Jr., Deputy Attorney General, requests that Rocky Mountain Utility
Company, Inc. (Company; Rocky Mountain) provide the following documents and information
as soon as possible, but no later than WEDNESDAY, DECEMBER 15, 2021.r
This Production Request is to be considered as continuing, and Rocky Mountain is
requested to provide, by way of supplementary responses, additional documents that it, or any
I Stuff it requesting an expedited response. If responding by this date will be problematic, please call Stafls
attorney at [phone].
FIRST PRODUCTION REQUEST
TO ROCKY MOTINTAIN UTILITY
COMPANY
1 DECEMBER I,2O2I
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 also identifu the name, job title, location, and
telephone number of the record holder.
In addition to the written copies provided as response to the requests, please provide all
Excel spreadsheets and electronic files on CD with formulas intact and enabled.
REQUEST NO. 1: In Nicole Burbank's Declaration and Response to Respondent's
Answer she alleges that her water service was "temporarily shut off on August 16,2021,
September 1,2021, September 10,2021, September 24,2021and October 14,2021without
notice or cause." See Declaration at p.2,n 3. Please provide a response:
Providing whether Ms. Burbank's water service was temporarily shut-off on any
of the dates listed above in202l.
Describing the reason or reasons why Ms. Burbank's water service was
temporarily shut-off on any of the dates listed above in202l. For example, was
any temporary shutoff related specifically to Ms. Burbank's service or was it a
system outage or for some other reason?
c.Describing any notice given to Ms. Burbank or other customers for any temporary
cessation of water service on any of the dates listed above in202l. A copy of any
notice should be provided in response to this Production Request if it was
delivered by email, U.S. Mail or by posting a document on a customer's
residence.
a.
b.
^5L7 dayDated at Boise, Idaho, this
Technical Staff: Jolene Bossard
i:umisc:prodreq/rocw2l jhjb prod reql
FIRST PRODUCTION REQUEST
TO ROCKY MOUNTAIN UTILITY
COMPANY
of December 2021
J Jr
Attorney General
2 DECEMBER I,2O2I
CERTIFICATE OF SERVICE
I HEREBY CERTIFY THAT I HAVE THIS l't DAY OF DECEMBER 2021,
SERVED THE FOREGOING FIRST PRODUCTION REQUEST OF THE
COMMISSION STAFF TO ROCKY MOT]NTAIN UTILITY COMPAIYY, INC.,
IN CASE NO. ROC.W.2I.OI, BY E.MAILING A COPY THEREOF, TO THE
FOLLOWING:
NICOLE BURBANK
3890 EAST ASH LANE
RIGBY ID 83442
E-MAIL: nursenikkiO8 I 8@ gmail.com
JIM BERNARD
ROCKY MOUNTAIN UTILITY
2 N LANDMARK LANE STE 4
RIGBY ID 83442
E-MAIL : rockymountainutilitv@ gmail.com
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SECRETAR/-
CERTIFICATE OF SERVICE