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Home My WebLink About20210201IFHC to Suez 1-2.pdf| :* r-l- i- i r i ill"1:.- -,,! -- i Y i-ts/ Iii; I{* * t EH lS: L? --''lr . .: r tii:. i-:= i1/' -'"r.;i:lt;Ilffit a.\_riiLfitr KEN NAGY (I.S.B. No. 6176) ATTORNEY AT LAW P.O. Box 164 Lewiston, Idaho 83501 Telephone: (208) 301 -0126 Facsimile: (888) 291 -3832 E-mail: knagy@lewiston.com ATTORNEY FOR INTERVENOR INTERMOUNTAIN FAIR HOUSING COUNCIL, NC. BEFORE THE IDAHO PUBLIC UTILITIES COMMISSION IN THE MATTER OF SUEZ WATER IDAHO INC.'S APPLICATION FOR AUTHORITY TO INCREASE ITS RATES AND CHARGES FOR WATER SERVICE IN IDAHO ) ) ) ) ) ) ) CASE NO. SUZ-W-20-02 INTERVENOR INTERMOUNTAIN FAIR HOUSING COUNCIL, INC.'S FIRST INTERROGATORIES AND REQUEST FOR PRODUCTION TO SUEZ WATER IDAHO,INC. PROPOUNDED TO:Suez Water Idaho, Inc. and its attomeys of record, Michael C. Creamer and Preston N. Carter Intervenor lntermountain Fair Housing Council, lnc. February 1,2021 One (No.s 1-2) One (No.s 1-2) PROPO{.'NDED BY: DATE: Interrogatories Set No. : Request for Production Set No: I INTERVENOR INTERMOUNTAIN FAIR HOUSING COLINCIL, INC.'S FIRST INTERROGATORIES AND REQUEST FOR PRODUCTION TO SUEZ WATER IDAHO,INC. KEN NAGY Attorney at Law Lewiston, Idaho COMES NOW the Intervenor Intermountain Fair Housing Council, Inc. ("Intervenor"), by and through its attorney of record Ken Nagy, Attorney at Law, and hereby submits to Suez Water Idaho, Inc. and its attorneys of record the lnterrogatories and Request for Production described below pursuant to IDAPA $31.01.01.225. The lntervenor submits these lnterrogatories to be answered separately and fully in writing under oath within twenty-one (21) days from the date of service of said Interrogatories upon you. In responding to these lnterrogatories, you are required to furnish such information as is available to you and not merely information which you know of your own personal knowledge, including information in the possession of your agent, or attorney, or any investigator for the answering party. These Interrogatories are continuing in nature and the Intervenor demands that any information coming into the possession of you, your agents, or your counsel that would change the answers in any way be promptly furnished to the undersigned counsel. Furthermore, the lntervenor requests that you produce the documents identified in the Request for Production within twenty-one (21) days after service of this document. This request is continuing in nature and it is expressly requested that any relevant correspondence, information, documents or writing coming into the possession of you, your agents, or your counsel be promptly fumished to the undersigned attomey of record. The terms "document" and "documents" include but are not limited to all handwritten, typed, printed or photostatic material and drafts, duplicates, carbon copies or any other copies thereof, in the possession, custody or INTERVENOR INTERMOUNTAIN FAIR HOUSING COUNCIL, INC.'S FIRST INTERROGATORIES AND REQUEST FOR PRODUCTION TO SUEZ WATER IDAHO,INC. 2 KEN NAGY Attorney rt Law Lewiston, Idaho control of you or your counsel. If any portion of the documents requested to be produced was, but no longer is, in your possession or control or is no longer in existence, state whether it is: l. Missing or lost; 2. Destroyed; 3. Transferred voluntarily or involuntarily to other, and if so, to whom; 4. Otherwise disposed of. In each instance, explain the circumstances surrounding the authorization for such disposition and state the approximate date thereof. Your response to these discovery requests shall be mailed or otherwise delivered to the undersigned KenNagy, Attorney atLaw, P.O. Box 164, Lewiston, Idaho 83501. INTERROGATORY NO. 1: Describe each and every study, investigation or inquiry that you conducted regarding the impact that the rate increases that you have proposed in this proceeding will impact low-income housing consumers in the relevant service area. REOUEST FOR PRODUCTION NO. 1: Produce a copy of each and every item pertaining to any study, investigation or inquiry that you conducted regarding the impact that the rate increases that you have proposed in this proceeding will impact low-income housing consumers in the relevant service area described or discussed in your response to Interrogatory No. 1 above. INTERVENOR INTERMOUNTAIN FAIR HOUSING COUNCIL, INC.'S FIRST INTERROGATORIES AND REQUEST FORPRODUCTION TO SUEZ WATER IDAHO,INC. 3 KEN NAGY Attorney rt Law Lewiston, Idaho INTERROGATORY NO. 2: Describe each and every action in which you engaged to give notice to housing consumers in the relevant service area regarding the rate increases that you have proposed in this proceeding. REOLJEST FOR PRODUCTION NO. 2: Produce a copy of each and every item pertaining to any action in which you engaged to give notice to housing consumers in the relevant service area regarding the rate increases that you have proposed in this proceeding described or discussed in your response to Interrogatory No. I above. DATED x1, l-st day of February 2021 Ken Nagy t gibly5l9mdbyf6N.gy DN: o=lcn t{.gy, o=AMy.t Lil, d, rmil*E9),Ohtitton.M, cdrshh: m21 .O2Ol m2:35 4'0d KEN NAGY Attorney for Intervenor Intermountain Fair Housing Council,Inc. CERTIFICATE OF SERVICE I hereby certify that on,1" Lst day of February 2021,1 caused to be served a full, true, and accurate copy of the foregoing by the method/s indicated below, and addressed to the following: JanNoriyuki Commission Secretary Idaho Public Utilities Commission ll331W. ChindenBlvd. Building 8, Suite 201-A P.O. Box 83720 Boise, D 83720 INTERVENOR INTERMOUNTAIN FAIR HOUSING COUNCIL, INC.'S FIRST INTERROGATORIES AND REQUEST FOR PRODUCTION TO SI.]EZ WATER IDAHO,INC. [ ] Bv U.S. Mail I x] By Email to: jan.noriyuki@puc.idaho.sov 4 KEN NAGY Attorney atLew kwiston" Idaho Michael C. Creamer Preston N. Carter Givens Pursley LLP Afforneys at Law 601 W. Bannock St. Boise, lD 83702 David Njuguna Suez Water Management & Services 461 From Rd., Suite 400 Paramus, N.J. 07052 Dayn Hardie Deputy Attomey General Idaho Public Utilities Commission 11331 W. ChindenBlvd. Building 8, Suite 201-A P.O. Box 83720 Boise, ID 83720 Lorna Jorgensen John Cortabitarte Ada County Prosecuting Attorney's Office Civil Division 200 W. Front St., Room 3191 Boise, lD 83702 Scott Muir Deputy City Attomey City of Boise 150 N. Capitol Blvd. P.O. Box 500 Boise,ID 83701-0500 Norman M. Semanko Parsons, Behle & Latimer 800 W. Main St., Suite 1300 Boise, lD 83702 INTERVENOR INTERMOUNTAIN FAIR HOUSING COUNCIL, INC.'S FIRST INTERROGATORIES AND REQUEST FOR PRODUCTION TO SI]EZ WATER IDAHO,INC. [ ] By U.S. Mail Ix] By Email to: mcc(@.givenspursley.com and prestoncarter(E givenspursley. com [ ] Bv U.S. Mail Ix] By Email to: David.njuquna(@suez.com [ ] Bv U.S. Mail Ix] By Email to: dayn.hardie(@puc.idaho.eov [ ] Bv U.S. Mail Ix] Bv Email to: civilpafiles(@,adaweb.net [ ] Bv U.S. Mail I x] By Email to: boisecityattorney(dcityofboise.org [ ] Bv U.S. Mail Ix] By Email to: NSemanko(@parsonsbehle.com Boisedocket@oarsonsbehle. com 5 KEN NAGY Attorney at Law Lewiston, Idaho Marty Durand Piotrowski Durand, PLLC 1020 Main St., Suite 440 P.O. Box 2864 Boise,ID 83701 [ ] Bv U.S. Mail I x] By Email to: marty@idunionlaw.com Bard M. Purdy 2019 N. 17ft St. Boise, lD 83702 [ ] Bv U.S. Mail [x] gV Email to: bmpurdy@hotmail.com Austin Rueschhoff Thorvald A. Nelson 555 176 St., Suite 3200 Denver, CO 80202 [ ] Bv U.S. Mail I x ] By Email to: darueschhoff@hollandhaft .com tnelson@hollandhart. com aclee@hollandhart. com el eareonomari@hollandhart. com Jim Swier Greg Harwood Micron Technology, Inc 8000 S. Federal Way Boise,ID 83707 [ ] Bv U.S. Mail I x] By Email to: j.swigl@gicrog.com gbharwood@micron.com Ken Nagy Dlghly rlEmd by Kcn tLry DN: o=&n hry, dndry .t hw ou amll=tnrqyelewlrton.com, eus o.te 202r.0201 @02:57 48'0 Ken Nagy 6 INTERVENOR INTERMOUNTAIN FAIR HOUSING COUNCIL, INC.'S FIRST INTERROGATORIES AND REQL]EST FOR PRODUCTION TO SUEZ WATER IDAHO,INC. KEN NAGY Attorney rt Lrw kwiston, Idaho