20190124Staff 1-3 to City of Eagle.pdf

SEAN COSTELLO
DEPUTY ATTORNEY GENERAL
IDAHO PUBLIC UTILITIES COMMISSION
PO BOX 83720
BOISE, IDAHO 83720-0074
(208) 334-03t2
IDAHO BAR NO. 8743
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CASE NO. SUZ.W.18.O2I
EAG-W-18-01
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Street Address for Express Mail:
472 W. WASHINGTON
BOISE, IDAHO 83702-5983
Attorneys for the Commission Staff
BEFORE THE IDAHO PUBLIC UTILITIES COMMISSION
IN THE MATTER OF THE JOINT
APPLICATION OF SUEZ WATER IDAHO AND
EAGLE WATER COMPANY FOR THE
ACQUISITION OF EAGLE WATER COMPANY FIRST PRODUCTION
REQUEST OF THE
COMMISSION STAFF TO
THE CITY OF EAGLE
The Staff of the Idaho Public Utilities Commission requests that the City of Eagle provide
the following documents and information as soon as possible, but no later than THURSDAY,
FEBRUARY I4,20I9.
This Production Request is continuing, and the City of Eagle 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 produced.
Please provide answers to each question, supporting workpapers that provide detail or are
the source of information used in calculations. The City of Eagle is reminded that responses
pursuant to Commission Rules of Procedure must include the name and phone number of the
person preparing the document, and the name, location and phone number of the record holder and
if different the witness who can sponsor the answer at hearing if need be. Reference IDAPA
31.01.01.228.
FIRST PRODUCTION REQUEST
TO THE CITY OF EAGLE 1 JANUARY 24,2019
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In addition to the written copies provided as response to the questions, please provide all
Excel and electronic files on CD with formulas activated.
REQUEST NO. 1: Has the City of Eagle been aware of any other agreements for the
purchase and sale of Eagle Water Company and their water system, prior to SUEZ Water Idaho
Asset Purchase Agreement?
REQUEST NO.2: Please provide a detailed service map of the City of Eagle water
system and where it is connected, or would become connected, to Eagle Water Company water
system.
REQUEST NO. 3: Please explain how the City of Eagle purchasing Eagle Water
Company and its water system would benefit Eagle Water Company customers.
DATED at Boise, Idaho, this //frauvof January 2019
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Sean Costello
Deputy Attorney General
i:umisc:prodreq/suzwl8.2_eagwl8.lsctnc prod req I to City of Eagle
FIRST PRODUCTION REQUEST
TO THE CITY OF EAGLE 2 JANUARY 24,2019
CERTIFICATE OF SERVICB
I HEREBY CERTIFY THAT I HAVE THIS 24Th DAY OF JANUARY 2019, SERVED
THE FOREGOING FIRST PRODUCTION REQUEST OF THE COMMISSION STAFF
TO THE CITY OF EAGLE, N CASE NOS. SUZ-W-18-02/EAG-W-18-01, BY MAILING A
COPY THEREOF, POSTAGE PREPAID, TO THE FOLLOWING:
MICHAEL C CREAMER
PRESTON N CARTER
GIVENS PURSLEY LLP
601 W. BANNOCK ST.
BOISE, ID 83702
E-MAIL:con-l
prestoncarter(.? gi venspu.rsley. com
ROBERT DESHAZO
EAGLE WATER COMPANY, INC.
188 W. STATE ST.
EAGLE,IDAHO 83616
E-MAIL : [e-mail]
MOLLY O'LEARY
BIZCOUNSELOR AT LAW PLLC
1775 W STATE STREET, #150
BOISE ID 83702
E-MAIL : rnol l)r@bizcounselelatlar.l'.cont
MAYOR STAN RIDGWAY
CITY OF EAGLE
660 E CIVIC LANE
EAGLE ID 83616
E-MAIL : sri d gewayr, 0,cityot'eagle. org
sber: gm ann (,lc i tyo fb a gl e. or g
BRAD M PURDY
ATTORNEY AT LAW
2019 N 17TH STREET
BOISE ID 83702
E-MAIL:
MARSHALL THOMPSON
SUEZ WATER IDAHO, INC.
8248 W. VICTORY RD,
BOISE, IDAHO 83709
E-MAIL : rnarshal L thorn rrsonG)suez.com
N.L. BANGLE
H2O EAGLE ACQUISTION, LLC
188 W. STATE ST.
EAGLE, IDAHO 83716
E-MAIL: nban [e-mail]
NORMAN M SEMANKO
PARSON BEHLE & LATIMER
8OO W MAIN STREET, SUITE I3OO
BOISE ID 83709
E-MAIL: nsernanko(*)parsonsbehle.com
ec 1'(g)parsclns b ehle. corn
com
CERTIFICATE OF SERVICE
CHERESE D. McLAIN
MSBT LAW, CHTD.
7699 W RIVERSIDE DR
BOISE ID 837I4
E-MAIL: @
JAMES M PIOTROWSKI
PIOTROWSKI DURAND PLLC
I O2O W. MAIN STREET, SUITE 440
PO BOX 2864
BOISE ID 83701
E-MAIL:,[e-mail]
ABIGAIL R GERMAINE
DEPUTY CITY ATTORNEY
BOISE CITY ATTORNEY'S OFFICE
150 N. CAPITOL BLVD.
PO BOX s00
BOISE rD 83701-0500
E-MAIL : a gennaine@)cityofboise. org
CERTIFICATE OF SERVICE