20220426Staff 47-51 to Teton Water.pdf

RILEY NEWTON
DEPUTY ATTORNEY GENERAL
IDAHO PUBLIC UTILITIES COMMISSION
PO BOX 83720
BOISE, IDAHO 83720-007 4
[phone]
IDAHO BAR NO. II2O2
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Street Address for Express Mail:
1I331 W CHINDEN BLVD, BLDG 8, SUITE 2OI-A
BOISE, ID 83714
Attomey for the Commission Staff
BEFORE THE IDAHO PUBLIC UTILITIES COMMISSION
IN THE MATTER OF THE APPLICATION OF
TETON WATER & SEWER COMPAI\Y FOR
AUTHORITY TO INCREASE ITS RATES AI\D
CHARGES FOR WATER SERYICE IN THE
STATE OF IDAIIO.
CASE NO. TTS.W.22-02
THIRD PRODUCTION
REQUEST OF THE
COMMISSION STAFF
TO TETON WATER AI\D
SEWER COMPANY
The Staff of the Idaho Public Utilities Commission, by and through its attorney of record,
Riley Newton, Deputy Attorney General, requests that Teton Water and Sewer Company
("Company") provide the following documents and information as soon as possible, but no later
than TUESDAY, MAY 17,2022.
This Production Request is to be considered as continuing, and the Company 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 also identiff the name, job title, location, and
telephone number of the record holder.
THIRD PRODUCTION REQUEST
TO TETON WATER AND SEWER
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1 APRIL 26,2022
In addition to the written copies provided as response to the requests, please provide all
Excel spreadsheets and electronic files on CD with formulas intact and enabled.
REQUEST NO. 47: Regarding the Company's response to Production Request Nos. I I
and 12, please explain the services AT&T, Silverstar Communications, and Go To My PC
provide to the Company, and explain how the service each company offers is diflerent from each
other as they are all classified as intemet expenses.
REQUEST NO. 48: Please explain why there are eight lines on the cellphone bills, five
for Jon Pinardi, and three for Teton Management Services. Please include the purpose for each
line.
REQUEST NO. 49: Regarding the Company's response to Production Request No. 7,
please provide a list of supplies and tools Teton Management Services has required Teton Water
& Sewer Company to purchase, as specified in their contract.
REQUEST NO. 50: Please provide a list of any Extraordinary Expenses that occurred
during the year 2021.
REQUEST NO. 51: Please provide a copy of the most recent Federal Income Tax return
and the State Income Tax return for the Teton Water & Sewer Company.
DATED at Boise,Idaho, this/S l^
day of April2022
Riley ewton
i :umisc:prodreq/ttstw22.2rnlc prod req 3
THIRD PRODUCTTON REQUEST
TO TETON WATER AND SEWER 2
Deputy Attorney General
APRIL 26,2022
CERTTFICATE OF SERVICE
I HEREBY CERTIFY THAT I HAVE THIS 26TH DAY OF APRIL 2022,
SERVED THE FOREGOING THIRD PRODUCTION REQUEST OF TIIE
COMMISSION STAFF TO TETON WATER AND SEWER COMPAI\IY, IN
CASE NO. TTS-W-22-02, BY E. MAILING A COPY THEREOF, TO THE
FOLLOWING:
JON PINARDI
TETON WATER & SEWER CO
PO BOX 786
DRIGGS ID 83422
E-MAIL : [e-mail]
Tetonws@ silverstar. com
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CERTIFICATE OF SERVICE