20181130Staff 1-12 to CDS.pdf

EDITH PACILLO
DEPUTY ATTORNEY GENERAL
IDAHO PUBLIC UTILITIES COMMISSION
PO BOX 83720
BOISE, IDAHO 83720-0074
[phone]
IDAHO BAR NO. 5430
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Street Address for Express Mail
472 W, WASHINGTON
BOISE, IDAHO 83702-5918
Attorneys for the Commission Staff
BEFORB 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
The Staff of the Idaho Public Utilities Commission, by and through its attorney 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, location and telephone
number of the record holder.
FIRST PRODUCTION REQUEST
TO STONERIDGE UTILITIES
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1 NOVEMBER 30,2018
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. l: The Purchase and Sale Agreement lists ESPRIT ENTERPRISES,
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.
b. Please also provide an Organizational Chart.
REQUEST NO.2: If JD Resort, Inc. will assume ownership of CDS Stoneridge
Utilities, LLC, please describe how ESPRIT ENTERPRISES, LLC will assign ownership to JD
Resort, Inc. and provide any agreements or other documentation of the assignment.
REQUEST NO.3: If JD Resort, Inc. will assume 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 ENTERPzuSES, LLC will assume
ownership of CDS Stoneridge Utilities, LLC, please provide the previous three years' of
financial statements for ESPRIT ENTERPRISES, LLC.
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.
R-EQUEST 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.)
FIRST PRODUCTION REQUEST
TO STONERIDGE UTILITIES 2 NOVEMBER 30,2018
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.
REQUEST NO. 7: Please provide the status and documentation of the assignments and
resignations in 5.3(c) of the Purchase and Sale Agreement.
REQUEST 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.
REQUEST NO. 9: Does the new entity plan on maintaining the same schedule for
monthly meter reading and billing?
REQUEST NO. 10: Please explain any anticipated personnel changes following the
sale
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.
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 31.21.01. Utility Customer Relations Rules
(ucRR)l
FIRST PRODUCTION REQUEST
TO STONERIDGE UTILITIES aJ NOVEMBER 30, 2018
DATED at Boise, Idaho, ttis SA&aay of November 2018
fr U //,Lfi EdithPacillo
Deputy Attorney General
i:umisc:prodreq/swsw1 8. I epjtjb prod req I
FIRST PRODUCTION REQUEST
TO STONERIDGE UTILITIES 4 NOVEMBER 30, 2018
CERTIFICATE OF SERVICE
I HEREBY CERTIFY THAT I HAVE THIS 3OTH DAY OF NOVEMBER 2018,
SERVED THE FOREGOING FIRST PRODUCTION RE,QUEST OF THE
COMMISSION STAFF TO CDS STONERIDGE UTILITIES, LLC, IN CASE NO.
SWS-W.I8.01, BY MAILING A COPY THEREOF, POSTAGE PREPAID, TO THE
FOLLOWNG:
CHAN KARUPIAH
JD RESORT INC
PO BOX 770
BAYVIEW ID 83803
E-MAIL : chansan(?.conrcast.com
DEAN ALLARA MGR
CDS STONERIDGE UTILITIES
364 STONERIDGE ROAD
BLANCHARD ID 83804
NANCY E NICK
HIGH TRAIL CONSULTING
E-MAIL: nanc),@hightrailconsulting.com
CERTIFICATE OF SERVICE