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Home My WebLink About20210830CAIA 1-14 to Suez.pdfJames M. Piotrowski Marty Durand PIOTROWSKI DI.JRAND, PLLC P.O. Box 2864 1020 W. Main Sheet, Suite 400 Boise,Idaho 83701 Telephone: (208)33 1 -9200 Facsimile : (208)33 | -9201 j arnes@i dunionlu*."o* marty@idunionlaw.com Attorneys for Intervenor Citizens Allied for Integrity and Accountability IN TI{E MATTER OF THE JOINT APPLICATION OF SUEZ WATER IDAHO AND EAGLE WATER COMPAI\IY FOR THE ACQUISITION OF EAGLE WATER COMPANY BEF'ORE THE IDAHO PUBLIC UTILITIES COMMISSION cAsE NOS. SUZ-W-18-02 EAG-W-18-01 CITIZENS ALLIED FOR INTEGRITY AND ACCOTINTABILITY'S FIRST PRODUCTION REQUEST TO SUEZ Intervenor Citizens Allied for Integrity and Accountability ("CAIA")by and through their attorney of record Marty Durand submit to Suez Water ldaho, Inc. and its attorneys of record the Interrogatories and Request for Production described below pursuant to IDAPA $31.01.01.225. The Intervenors submit these Interrogatories to be answered separately and ftilly in writing within twenty-one (21) days fi'om the date of service. In responding to these Interrogatories, you are required to fumish such information as is available to you. These Interrogatories are continuing in nature and the Intervenor requests that any information coming into the possession of you, your agents, or your counsel that would change the answers in any way be promptly fumished to the undersigned counsel. Furthermore, the Intervenor requests that you produce the documents identified in the Request for Production within twenty-one (21) days after service of this document. The terms "documenf' and "documents" include but are not limited to all handwritten, typed, or printed or and drafu, duplicates or any other copies thereof, in the possession, custody or conhol of you or your counsel. Your response to these discovery requests shall be mailed or otherwise delivered to the undersigned Marty Durand, PIOTROWSKI DURAND, PLLC, P.O. Box 2864, Boise,Idaho 83701, REQIJEST NO. 1: Please state when the proposed merger of Suez and Veolia is anticipated to be completed for US operations. REQUEST NO.2: Please produce any and all documents describing the timeline for the proposed Sue/Veolia merger of US operations. REQUEST NO.3: Regarding the proposed Suez/Veolia merger, please state what regulatory approvals have been obtained and from what jurisdictions and/or agencies in the United States. REQUEST NO.4: Regarding the proposed Suez/Veolia merger, please state what regulatory approvals are still needed and from what jurisdictions and/or agencies in the United States. REQUEST NO. 5: Regarding the proposed Suez/ Veolia merger, please identiff unresolved issues or barriers to final approval in the agencies and jurisdictions identified in RequestNo.4. REQUEST NO. 6: Regarding the proposed Suez/Veolia merger, please describe how this merger will impact service to Suez customers in Idaho. REQUEST NO. 7: Please produce any documents describing or directing transition procedures for Suez operations in Idaho following the proposed merger with Veolia. REQUEST NO. 8: If the Sue/Veolia merger is approved, will any customer service call centers be located in ldaho? REQUEST NO. 9: If the proposed Suez/Veolia merger is approved, will any customer service call centers be located in the United States? REQUEST NO. l0: If the proposed Sue/ Veolia merger is approved, please describe how Eagle, Idaho and Ada County cnstomer requests for service will be dispatched and prioritized. REQUEST NO. 11: Please identify any anticipated changes to local management and personnel structures following final approval the Suez/Viole merger. REQIIEST NO. 12: Paragraphs IV through VII of your Application and Request for Modified Procedure indicate that H2O Eagle, managed by Mr. Bangle, will purchase the assets of Eagle water and then sell them to Suez. Please state Eagle H2O and/or Mr. Bangle's compensation for this tansaction and if it is to ultimately be paid by Suez customers. REQIJEST NO. t3: The Direct Testimony of Cathy Cooper speaks to a cost avoidance of $11.2 million dollars to develop and and transmit 12.5 million gallons of water daily. Please explain how and when Suez has planned to develop and transmit this water without acquiring Eagle Water assets. REQUEST NO. 14: Please produce any and all documents describing your planning for development and hansmittal of the water referenced in Request No. 13. Dated this 30ft day of August,2}2l I4nnh, b,,nnn r) utrtibrlnina CERTIFICATE OF SERVICE I HEREBY CERTIFY that on the 30th day of August,202l, a true and conect copy of the foregoing document was served on the following via electronic mail: JanNoriyuki Commission Secretary Idaho Public Utilities Commission secretary@puc.idaho. gov j an.noriyuki@puc. idaho. gov Erick Shaner Dayn Hardie Deputy Attorney General Dayn.hardie@puc.idaho. gov Erick. shaner@puc. idaho. gov Marshall Thompson Suez Water Idaho, Inc. Marshall.thompson@suez. com Molly O'Leary Eagle Water Company, Inc. molly@b izconseloratlaw. com Robert DeShazo, Jr. Eagle Water Company, Inc. Eaglewaterco@gmai l. com N.L. Bangle nbangle@h20-solutionsll c.net Jason Pierce Mayor, City of Eagle Jpierce@cityofeagle. org tosborn@cityofeagle. org B. Newall Squyres Murray D. Feldman Holland & Hart, LLP City of Eagle nsquyres@hollandhart. com mfeldman@rollandhart.com Norman Semanko Parsons Behle & Lattimer Eagle Water Customer Group NSemanko@parsonsbehle.com Mary Grant Scott B. Muir Boise City Attorney's Office boisecityattorney@cityofboise.org Brad Pudy Community Action Partrership Assn. of Idalro bmpurdy@hotmail.com Preston Carter Givens Rrslen LLP Suez Water Idaho, Inc. mcc@givenspursley. com prestoncarter@givenspursley. com