20210726SWS to Staff 14-18-Redacted.pdf

Case NO SWS-W-20-02
Second production request of the commission staff to CDS StoneRidge utilities, LLC
CDS StoneRidge Utilities response:
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Request NO 14:
See attached documents, enclosed are all of the cancelled checks that were written to customers for a
refund for water connections. There are 2 checks that were written but not cashed.
Check #tL87 to Michael Rafferty for the amount of 52856.00 and #1193 to Katherine Bauman for $ZgZe.
Request NO L5
StoneRidge utilities refunded everybody on the list you provided for us marked "Attachment A" Order
No. 34974 page 1 of 1. The order stated to refund those who paid over the 51,200. Which is what we
did.
Request NO 16:
The correct dates for said applications are L0/UAOZA and 6/3012020. I also have an application for
1213O/2O2O. lt is unknown as to which application you are referring to. Could you please send a
response so we can make this correction?
Request No 17:
The customers whom turned their applications in with the $aOOO payments after the 9th of September
with order 34770 more than likely had their applications before that order was in effect. However, we
did refund those owners any amount above the S1,200. This was not intentionally done by StoneRidge
Utilities.
Request NO 18:
StoneRidge Utilities has never received any application for either 37 Bellflower, nor 51 Bellflower. Those
lots were owned by Blueplank at the time they were connected to water. The water was connected by
private developers' unknown to StoneRidge Utilities. During closing on those lots, StoneRidge contacted
the new owners of said lots to inform them the water connection and the sewer connection for both of
these lots had not been paid. While the lots were in escrow, BluePlank and the owner of StoneRidge
Utilities LLC made an agreement (l have attached) that for both of these lots, plus another in lronwood
Development StoneRidge Utilities would accept S28,q)0 in total for all 3 properties. 3 properties at
51,200 for water connection and a discounted sewer price for each lot at 58,133 for each lot.
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December 9,2019
ldaho Public Utilities Commtsston
P.O. Box 83720
Boise, Idaho 83720'007 4
Department of Environmental Quality
it io tron*ood ParkwaY, Suite 100
Coeur d'Alene, Idaho 83814
Re: IPUC CASE NO' SWS-W-I8-01
Ms. Pacillo and Messrs. Terry and Plaisted:
VIA: E-Mail
As you know our office represents Blueplank, LLC. In our-letter to you of Novembet 20,2019
we outlined several items that *"r".or..rning to us as well as other homeowner's in the
StoneRidge CommunitY.
In our negotiations with Esprit, the resolttion of our existing three constructed homes at
StoneRidge is demonstrated on the three recently received utility invoices from StoneRidge
utilities.
All statements or accusation made on the original letter were false, wrong or ignorant on our
client's part including no licensed operators nor staffavailable during business houls and
soliciting John Lamb to write a letter which he was ignorant of the facts.
This letter is being sent to notifu you that Blueplank and CDS StoneRidge Utilities LLC have
reached an agreement that we believe to be fair and beneficial to all parties concerned.
Therefore, we rescind our formal complaint in the November 20,2019 conespondence to you
and apologize for all inconvenience caused.
Sincerely,
HOLT LAW OFFICES, PLLC
Kevin P. Holt, Attorney:KPH
Attachments
o
("Subject Property")
DATED this _ day of February,20?O
By
SIATE OF IDAHO
County of Kootenai
UTILTTIES, LLC,
that cxecutcd the
behalf.
)
):
)
SS
NOTICE OF' SATISF'ACTION
OF
UTILITY INSTALLATION CHARGES.
This is to confirm satisfaction, in full, of all obligations of installation of waterand
hook ups for the property known as 37 Belleflower Ct., Blanchard, Idatro and legally
,ls:
Lot 9 Block I of the Greenside Place Townhomes at Stoneridge, a Replat of
Block 10, The Fairways at Stoneridge - Phase 2, according to the plat thereof,
recorded in Book 9 of Plats, Page 52, records of Bonner Counly,ldatro.
CDS STONERIDGE UTILITIES, LLC, d/b/a STONERIDGE UTILITIES, Esprit
Enterprises, LLC ("Company") is the official utility company authorized to supply water to
Subject Property. Company is also the recognized and official provider of sewer services to
Subject Property and surrourding properties.
There was recently a dispute as to whether or not the owners of the Subject Properly
paid a mutraally agreed amount for water and sewer hookup.
'lhis notice shall confirm that all initial hook-up charges for water and sewer
the Subject Property are now fully satisfied and no firrther payment or other obligation is
foom the owners of the Subject Pnrperty relating to initial installation of water and/or sewer.
"Company'
CDS STONERIDGE UTILITIES, LLC, d/b/a STONERIDGE
UTILITIES, Esprit Enterprises, LLC ("Company')
On this
-
day ol'February ,2020, before me, the undensigned, a Notary in and for said state, personally
appeared Chan Karupiah, known or identified to me to be the Manager/Member for CDS STONERIDGE
d/b/a S'I'ONERIDGE UTILITIES, Esprit Enterprises, LLC, Idaho limited liability
instrument on behalf of said company, and acknowledged to me that he executed the same ttreir
to
IN WITNESS WHEREOF, I havc hereunto set my hand and affixed my official seal the day andthis certificate first above written.
Notary forthe State of ldaho
Commission Expires__
Attachment "A"
tn
("Subject Properfy")
DAI'EDthis _ day of l'ebruary,2020.
By:
STATEOF IDAI{O
County ofKootenai
On this -,* day of February,
appeared Chan Karupiah, known or
UTILITI ES, LLC, dlbla STONERIDGE
that executed the inslrument on behalf of
behalf.
NOTICE OF SATISFACTION
OF
UTILITY INSTALLATION CHARGES.
This is to confirm satisfaction, in full, of all obligations of installation of water and
hook ups for the property known as 51 Belleflower Ct., Blanchard, Idatro and legally
zts:
Lot L0 Block I of the Greenside Place Townhomes at Stoneridge, a Replat of
Block 10, The Fairways at Stoneridge - Phase 2, according to the plat thereof,
recorded in Book 9 of Plats, Page SZ,records of Bonner County, Idaho.
CDS STONERIDGE UTILITIES, LLC, d/b/a STONEzuDGE L.ITILITIES, Esprit
Enteqprises,LLC (Company") is the official utility company authorized to supply water to
Subject Properly. Company is also the recognized and official provider of sewer services to
Subject Property and surrounding properties.
There was recently a dispute as to whether or not the owners of the Subject Property
paid a rnutually agreed amount for water and sewer hookup.
This notice shall confirm that all initial hook-up charges tbr water and sewer
the Subject Properly are now fully satisfied and no further payment or other obligation is
from the owners of the Subject Properly relating to initial installation of water and/or sewer.
"Company'
CDS STONERI
UTILITIES, Esprit Enterprises, LLC ("Company")
)
):ss
)
2020, before me, the undersigned, a Notary in and for said slatq personally
identified to me to be the Manager/Member for CDS STONERIDGE
UTILITIES, Esprit Enterprises, LLC, Idaho limited liability
said company, and acknowledgcd b me that he executed the same
IN WITNESS WI.IEREOF, I have hereunto set my hand and affixed my official seal the day and year
this certificate first above written'
Notary for 0re State of ldaho
Commission Expires---
Attachment "B'
to
their
("Subject Properly")
DATED this _ day of February,20?0.
By
STATE OF IDAHO
County of Kootenai
)
):ss
)
NOTTCE OF SATISFACTION
OF
UTILITY INSTALLATION CHARGIS.
This is to confirm satisfaction, in full, of all obligations of installation of water and
hook ups for the property known as226 lronwood Drive, Blanchard, Idaho and legally
as:
Lot 23 Block I Ironwood at Stoneridge, according to the plat thereof recorded in
Book "l l" of Plats at Page 78, offrcial records of Bonner County,Idaho.
CDS STONERIDGE UTILITIES, LLC, d/b/a STONERIDGE UTILITIES, Esprit
Enterprises, LLC ('Company") is the official utility company authorized to supply water to
Subject Property. Cornpany is also the recognized and official provider of sewer services to
Subject Properly and surrounding properties.
There was recently a dispute as to whether or not the owners of the Subject Property
paid a mutually agreed amount for water and sewer hookup.
This notice shall confirn that all initial hook-up charges for water and sewer
the Subject Properly are now fully satisfied and no further payment or olher obligation is
from the owners of the Subject Property relating to initial installation of water and/or sewer.
"Company"
CDS STONERIDGE UTILITIES, LLC, d/b/A
UTILITIES, Esprit Enterprises, LLC ("Company")
On this _ day of February,2020, before me, the undersigned, a Notary in and for said state, personally
appeared Chan Karupiah, known or identified to me to be the Manager/Member for CDS STONERIDGE
UTILITIES, LLC, d/b/a STONERIDGE UTILITIES, Esprit Enterprises, LLC,Idaho limited liability
that executcd tlre instument on behalf of said company, and acknowledged to me that he executed the same on
behalf.
lN WITNESS WHEREOF, I have hercunto set my hand and affixed my official seal the day and year
this certificate first above writen.
Notary forthe State of Idaho
Commission Expires_
Attachment "C"
to
[Type here]
February 7,2020
ldaho Public Utilities Commission
P.O. Box 83720
Boise, Idaho 83720-007 4
Department of Environmental Quality
2110 lronwood Parkway, Suite 100
Coeur d'Alene, Idaho 83814
Re: IPUC CASE NO. SWS-W-18-01
Ms. Pacillo and Messrs.'terry and Plaisted:
As you knowo our offtc,e represents Blueplank, LLC ('Blueplank"). In our letter to you of
November 20,2019 we outlined several items that were of concern to our client.
Since sending that letter, oru client and the principal member of StoneRidge Utilities
("StoneRidge") have been in regular discussions and negotiations
Blueplank and StoneRidge have reached an agreement that we believe to be fair and
all parties concerned. Therefure, we rescind our formal complaint in its entirety, including
eighteen (18) attachments, contained in the November 20, 2019 correspondence to you.
Att chment ',o'
VIA: E-Mail
Ed ith. Paci I lo@.P U C.. idaho. qov
.loseph. l'eny@P LIC. ldaho. qov
Sincerely,
I-IOLT LAW OFFICES, PLLC
Kevin P. Holt, Attorney
to
NOW, TI{EREFORE, IT IS I.IEREBY AGREI]D AS IT0I,LOWS:
2. Recitals.
The Recitals of this Agreement are incorporated herein.
2. Identitication of Subject Dispute.
'l'he parties acknowledge that this Mutual Release and Settlement Agrcement relates
claims or counterclaims that could or might be asserted in a lawsuit that arise or relate in
way to the events, transactions, occurrences. or series oltransactions or occun'cnccs which
alleged or might have been alleged in or form the basis of a lawsuit between. The parlies
each acknowledge that this Mutual Release and Settlement Agreement relates to all claims
counterclaims that could have been, or could now be asscrted by them against any other
hereto relating to any previous business transactions between and/or among the parties.
3. Agreernent of the Parties.
'l'he parties hereby agree as lbllows
3.I . Blueplank agrees to instruct North ldaho 'fitle, of Coeur d'Alene,
release $18,000 to llsprit.
3.2. Esprit agrees to instruct Norlh Idalro'l'itle, of Coetr d'Alene, to lran
$10,000.00 into an Escrow Account as Earnest Money at North Idaho'l"itle Conr
ol'Coeur d'Alene. as described in Section 3.5. below.
3.3. Esprit agrees to provide oflicial notice to the owners ol 37151 and
Ironwood f)rive ("226") in the tbmr of a will serve lettcr ltrr each pnrpcrty. corrfirnr
writirrg that all initial utility arrd watcr/scrver hookup flees luve been paid in lirll lbr 3
226:lltc letters shall be in tlrc lirrrn sct lortlr on Attachnrent *A." "1J" and "(1" withirr th
business days ol'thc executiott of this Agrectncnt.
3.4. Blueplank agrees that upon completion ol'paragraphs 3.3 by Esprit.
then irnnrediately prepare and send a letter to the ldaho Public Utilities
and [daho Department of Environmental Quality in the fonn set fbrtlr on
"D" to this agrecment, within three (3) business days from the execution of this
Agrcemenl.
3.5. '[he partics lurthsr agree that Esprit shall purchase two lots in
as sct fbrth herein and as sct fbrth in a Purchase & Sale C'P&S") agreement in
form set forth in Attachrnent "E." The terms of the P&S nrust include a term
Esprit (or its agents or designee) shall upon signing ol'the P&S, tender $5,000
($10,000 total) to lllueplank as an absolutely non-refundable earnest nloney
The two Stoneridge lots arc described as:
MUTUAL REI-EASE, AND SETTI,IJMT1NT AGI{EEMENT - 2
all
to
ilr
I and
(3)
lot
MUTUAL RELEASE AND SETTLEMENT AGITEEMENT
'l'HlS AGIttjr.'IMENT is madc and entered into this -- day o1'F.ebruary,2020,
between:
and
Chan Karupiah, CIDS Stoneridge Utilities, LLCI d/b/a Stoneridgc Utilities, Esprit
Enterprises, LLC (hereinafter "Esprit").
ard
Blueplank. LI-C, (hereinafter "Blueplank")
Each party enters into this Mutual Release and Settlement Agreement (hereinaf'ter relbrredo'Agteement") lbr themselves and their employees. agents, heirs, executors, administrators,
assigns, servants, rcpresentatives. attonreys, insurers, reinsurers, indemnitors, subrogees.
al'l'iliates, paftners, predecessors and successors in intercst, and any and all persons or entiti
whose behall'it nray havc actcd or who nright bc al'fcctcd, iointly and scvcrally. Esprit and
Blueplank are also hercinaller sonretimes colleclively rel'emed to as thc'oparties."
R Ii C I'I'A I- S
A. A dispute has arisen between and among the parties relating to providing ol'
and sewer utilities and collateral issues bctween Esprit and Blucplank (hereinatler "Subject
Dispute").
B. Subsequent to the Subject Dispute arising. thc parties agreed that $28.000
be held in escrow by North ldaho'litle Co., in Coeur d'Alene. Idaho, pending negotiations the
Sub.ject Disputc. Thc $28,000 was related to closings on two parcels of real estate in
Idaho generally described as 37 Bellf'lower Courl, Blanchard, ID and 51 Bellflower Court,
Blanchard, ID (hercinaller collectively ret'erred to as *37151")
C. Subsequently, Esprit sent corespondence to the new owners o{ 37/51, inlbrm
thcm that they each owed $14,000 in utility l'ees and that if they did not pay the i'ees their uti
would bc cut ofl'.
D. Blueplank. in response, scnl corrcspondcnoc to thc ldaho I'}ublic Utililies
Conrnrission and ldaho Departnrcnt o1'Environmental Quality tlrat was critical of many ol'
Iisprit's activities.
E. 'l'he parties wish to settle. release and forever extinguish, on thc temrs sst u1
this Agreernent, all clainrs and counterclainrs which are or could be the subject of a lawsuit
rclated to the Subject Dispute, or which otherwise arise or may arise from the Subject Di
AS
on
iine
ilities
MUI'UAI., RELEASE AND SET'I'I,EMEN'I AGREEMENT - I
Lots 24 and 25 Block I lronwood at Stoneridge, according to the plat of
thereof recorded in Book " l I " of Plats at Page 78, otlcial records of Bonner
County.ldaho
(hereinalter "Lots 24 and 25 Ironwood at Stoneridge")
4. Release bv Esprit.
For good and valuable consideration, including, but not limited to, thc Agreement ol'
parties set lbrth herein, the legal sulIiciency of said consideration being hereby
Esprit does hereby fully, finally and forever discharge, release and acquit Blucplank liom
and all claims. counterclaims, actions, causes of action, judgments, demands, liabilities,
liens. darnages (including general, special, compensatory, and punitive damages),
indentnitication and subrogations claims, costs, fees, exp€nses and compensation ol'any
nature, whether based on contract, tort or other theory of recovery, whether known or
which Esprit may havc that are related to the Subject Dispute.
5. Release bv Blueolank
For good and valuable consideration, including, but not limited to, the Agreement
parties set forth herein, the legal sufliciency of said consideration being hereby
Blueplank does hereby fully, finally and fbrever discharge, release and acquit Esprit fronr
and all claims, counterclaims, actions, causes of action, judgments, demands, liabilities,
liens, damages (including geneml, special, compensatory, and punitive damages),
indemnification and subrogations claims, costs, fees, expenses and compensation of any
nature, whether based on contracl, tort or other theory of recovery, whether known or
which Blueplank nray have that are related to the Subject Disputc.
6. Liabilitv Contested and Denied.
This settlement between and among the parties as documented in this Agreement is
settlement of disputed clainrs between the parties to this Agreemcnt. Except as otherwise
provided herein, nothing contained in this Agreement shall constitute an admission of fauttliability by any party to it on any claim asserted or alleged. The parties to this Agreement
by this Agreement to fully, finally and forever resolve all claims, and the parties intendbuy their pcace and avoid l'urther Iitigal,ion.'Ihis Agreement and the consideration
made and accepted in good lhith with the understanding by the parties of the risksfurther Iitigation.
7. Authority as to Settlement of All Claims.
Thc parties hereto represent and warrant that no other person or entity has or hasinterest in or lien against the claims, counterclaims,demands,causes of action or suits byparties rel'erred to in this Agreement; that the parties hereto have the sole right andauthority to execute this Agreement and recei ve the benefits specificd herein as
MUTUAI. RELEASE AND SETTLEMENTAGREEMENT - 3
any
or
or
to
provided
attendant
and neither party has sold, assigned, transfbrred, conveyed or otherwise disposed of any of
claints. counterclaims, demands, obligations or causes of action relbrred to in this
8. Entire Aqreement.
All oral and written rcpresentations, covenants, agreements and contracts discusscd
entered into by the parties heretcl or their representatives prior to this Agreement relating
or indirectly to the transactions set forth in this Agreement are merged into and superseded
this Agreement, and this Agreement, and alldocuments executed in connection therewith,
constitute the sole and the entire agreement between the parties relating to the transactions
lbrth herein.
9. Advice and Aporoval of Counsel.
1'he parties hereby acknowledge and agree that they are, and have been, represented
counsel ol'their own choosing during any and all negotiations which have led to this
and that they have been fully advised concerning the effect of this Agreement, the ternts of
settlemcnt, and thcir obligations contained in this Agreenrent. The parties have asked all
questions deemed necessary or desirable by them or their legal counsel in order to evaluate
terms hereof to their complete satisfaction. '[he parties have read this Agreement, fully
understand its contents, and voluntarily acoept the terms of this Agreement. In executing t
Agreement, each party has relied entirely upon their owniudgment and knowledge, and the
knowledge, judgment and advice of its attorneys. Neither party has relied upon any promise
inducement by the other. And, both parties understand that by executing this Agreement
have given the other a general release ofany and all claims arising from the dispute(s) and
lawsuit, whether known or unknown ot whether
rnay hereafter arise.
they have heretofore arisen, presently exist,
10. CovenantNotto Sue.
'the parties herebY agrec and covenant that they will not sue or comnrence any
law, equity or otherwise against each other for anY claim,counterclaim, cause of action' or
demand, whatsoever and of whatsoever nature, arising out o1'or in any way related to the
Dispute, tlr the claims released by the Parties herein. The parties mutually agree and
however, that theY maY initiate an action against the other lbr breach of this Agreement or
the obligations, Promises,representations and covenants under this Agreement'
I l. Enfbrcernent Expense of the Parties'
'fhe party hereto who is the prevailing party il *y court action brought to ettforce
the provisiotls ot'this Agreement shall recovJr'from the non-prevailing party or parties its
and attorneys, fees, inciifing uf I expert witness costs, incurred in all trial and appellate
proceedings in said court action'
MU'TUAL REI.,EASE AND SETTI,EMENT AGREEMEN'T - 4
ly
at
ol'
ol'
12. All Modifications to be Written.
'l'lre parties nray modily the terms, conditions, rights and obligations of this
I-lowever, no nrodilications ol'any kind or nature, ol'any term, condition, right or obligation
herein, and no waiver of any term, condition, right or obligation herein shall be of any force
ellbct unless the same is in writing and signed by the parties hereto.
13. Coverning LaW.
'Ihis Agrecmsnt is entered into in the State of Idaho and shall be construed ard
interpreted in accordance with its laws.
14. Survival of Itcprcsentations and Warrants.
The parties agrec and undcrstand that all promises, representations, and covenants
herein slrall survive and remain f'ully operative afler all consideration to be paid or rcceived
urder this Agreenrent has been paid or received.
15. Binding EfTect.
This Agreement shall be binding upon the present and luturc shareholders, directors,
olfi cers, enrployees, agents, heirs, executors, administrators, assigns, servants,
attomeys, insurcrs, rcinsurers, indemnitors, subrogees, affiliates, partners, predecessors and
successors in interest, and any and all persons or entities on whose behalfthey have acted
might claim rights through it, iointly and severally, and any and all successors-in-interest of
party.
16. Cooperation.
'Ihe pa(ies and thcir attomeys agree to cooperate fully and execute any and all
supplemental documents and to take any and all additional actions which may be necessary
appropriate to give full tbrce and ellect to the terms and intent of this Agreement.
17. Duplicate Originals.
'Ihe parties hereto shall execute duplicale originals of this Agreement, with each
retain one ol'the duplicate originals. Ihc duplicate originals shall be considered as a single,
executed original document. Faxed or emailed signatures are acceptable and enforceable as
originals.
MUTUAL ITI]LEASE AND SE'T'I'LEMENT AGRI]I]MEN'T - 5
who
to
llv
lN WITNESS WHEREOF, the patties hereto have hereby set thcir hands and seals
day and year first above-written.
CDS STONERIDGE UTILITTES, LLC
rt/b/a STONERIDGE UTILITIES, Esprit
Enterprises, LLC, Chan Karupiah,
individually
Chan Karupiah, individually and as
Memberof CDS ST ONERIDGE
UTILITIES,LLC dIbIA
S'l ONERIDGE UTILITIES, Esprit
Enterprises, LLC
By:
"Esprit"
Jon Jae Enos, Member
Nicholas Andrew Boone, Member
*BLUEPLANK"
Blueplank, LLC
By:
By
MUTUAI. RELEASIi: AND SET'I'I,tsMENT AGREEMENT . 6