20190124CDS to Staff Nos. 1-12.pdf

EDITH PACILLO
DEPUTY ATTORNEY GENERAL
IDAHO PUBLIC UTILITIES COMMISSION
PO BOX 83720
BOISE, IDAHO 83720.0074
[phone]
IDAHO BARNO.5430
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Street Address for Express Mail:
472 W . WASHINGTON
BOISE, IDAHO 83702.5918
Attorneys for the Commission Staff
BEFORE THE IDAHO PUBLIC UTILITIES COMMISSION
IN THE MATTER OF THE APPLICATION OF
JD RESORT,INC. TO ACQUIRE CDS
STONERIDGE UTILITIES, LLC WATER
COMPANY AND TRANSFER CERTIFICATE
OF PUBLIC CONVENIENCE AND NECESSITY
NO.395
CASE NO. SWS-W-18-01
FIRST PRODUCTION
REQUEST OF THE
COMMISSION STAFF TO CDS
STONERIDGE UTILITIES, LLC
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The Staff of the Idaho Public Utilities Commission, by and through its attomey of record,
Edith Pacillo, Deputy Attorney General, requests that CDS Stoneridge Utilities, LLC (Company;
Stoneridge) provide the following documents and information as soon as possible, but no later
than FRIDAY, DECEMBER 21,2018.
This Production Request is to be considered as continuing, and Stoneridge 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, Iocation and telephone
number of the record holder.
FIRST PRODUCTION REQUEST
TO STONERIDGE UTILITIES NOVEMBER 30,2OI8
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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: The Purchase and Sale Agreement lists ESPRIT ENTERPzuSES,
LLC as the purchaser of CDS Stoneridge Partners, L.C.; CDS Stoneridge Associates - Golf,
L.C.; CDS Stoneridge - Land, L.C.; and CDS Stoneridge Utilities, LLC. However, the
Application indicates that the buyer of the properties is JD Resort, Inc.
a. Please describe the relationship between ESPRIT ENTERPRISES, LLC; JD Resort,
Inc., and Chan Karupiah.
Chan Karupiah is the Owner/President of JD Resort,Inc. and the Member of
Esprit Enterprises, LLC.
b. Please also provide an Organizational Chart.
There is no organizational chart per se as Chan Karupiah is the sole owner operator of
JD Resort,Inc. and Esprit Enterprises, LLC.
REQUEST NO. 2: If JD Resort, Inc. will assume ownership of CDS Stoneridge
Utilities, LLC, please describe how ESPRIT ENTERPzuSES, LLC will assign ownership to JD
Resort, Inc. and provide any agreements or other documentation of the assignment.
JD Resort,Inc. and Esprit Enterprises, LLC are both solely owned by Chan
Karupiah. JD Resort,Inc. will retain ownership in the Utility Company.
REQUEST NO.3: If JD Resort, Inc. willassume ownership of CDS Stoneridge
Utilities, LLC until a new corporate entity can be established, please provide the previous three
years' of financial statements for JD Resort, Inc. If ESPRIT ENTERPRISES, LLC will assume
ownership of CDS Stoneridge Utilities, LLC, please provide the previous three years' of
financial statements for ESPRIT ENTERPRISES, LLC.
Financials for JD Resort, Inc. are attached.
REQUEST NO. 4: The Application states that a new entity would be created for the
utility company. Has this been created? If so, please provide the charter documents, and state
the plan for transferring the utility to that entity.
FIRST PRODUCTION REQUEST
TO STONERIDGE UTILITIES 2 NOVEMBER 30,20I8
No new entity transfer at this time.
REQUEST NO. 5: Please provide a schedule showing all expected expenses relating to
the sale of CDS Stoneridge Utilities, LLC. Please include all expenses incurred and anticipated.
(Staff anticipates this may be confidential information. If so please provide on yellow paper or
mark it confidential.)
None
REQUEST NO. 6: Please provide a schedule showing all anticipated capital
expenditures relating to CDS Stoneridge Utilities, LLC or the subsequent water utility operation
for the next three years.
20192 Currently in the process of engineering analysis of critical needs anticipated
to be done this year if any. Estimated cost will be 10,000 to 20,000.
2020: Installation of municipal potable well (12") $50,000 - $60,000, or those
critical needs identified by the engineering analysis.
2021: Installation of 100,000 gallon reservoir and applicable appurtenances
150,000 - 200,000, or those critical needs identified by the engineering
analysis.
RLQUEST NO. 7: Please provide the status and documentation of the assignments and
resignations in 5.3(c) of the Purchase and Sale Agreement.
None as yet, per 5.3.(c) all are held until such a time as the State of Idaho issues it's
approval.
REQUBST NO. 8: If the Commission approves the sale of CDS Stoneridge Utilities,
LLC as requested in the Application, how will the new entity notify its customers of the purchase
of the water system? If a document has already been drafted, please provide a copy and explain
how it will be delivered.
Existing customers of the Utility Company shall be notified by e-mail, Certified Mail
or telephone call.
FIRST PRODUCTION REQUEST
TO STONERIDGE UTILITIES J NOVEMBER 30,2OI8
REQUEST NO. 9: Does the new entity plan on maintaining the same schedule for
monthly meter reading and billing?
Yes
REQUEST NO. 10: Please explain any anticipated personnel changes following the
sale.
None
REQUEST NO. 11: Does the new entity intend to retain CDS Stoneridge Utilities,
LLC's current tariff, which includes approved rates and charges, service classifications and other
requirements related to the provision of service? If not, please explain what changes the new
entity intends to propose.
None at this time. All items are currently being evaluated.
REQUEST NO. 12: Is the new entity aware that it will be required to comply with the
rules and regulations of the Idaho Public Utilities Commission, including but not limited to the
Utility Customer Relations Rules? UDAPA 3L2l.01. Utility Customer Relations Rules
(ucRR)l
Yes
FIRST PRODUCTION REQUEST
TO STONERIDGE UTILITIES 4 NOVEMBER 30,20I8
DATED at Boise, Idaho, this day of November 2018.
Edith Pacillo
Deputy Attomey General
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FIRST PRODUCTION REQUEST
TO STONERIDGE UTILITIES 5 NOVEMBER 30,2018