200504042nd IRU request to UWI.pdf

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Will~am M. Eddie (ISB# 5800)
ADVOCATES FOR THE WEST
O. Box 1612
Boise, ID 83701
[phone]
fax: [phone]
billeddie~rmci.net
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UTILITiES COr'H"'ISSION
Express Mail:
1320 W. Franklin St.
Boise, ID 83702
BEFORE THE IDAHO PUBLIC UTILITIES COMMISSION
IN THE MATTER OF THE APPLICATION
OF UNITED WATER IDAHO INC. FOR
AUTHORITY,TO INCREASE ITS RATES
AND CHARGES FOR WATER SERVICE IN
THE STATE OF IDAHO
CASE NO.UWI - W -04-
SECOND PRODUCTION REQUESTS OF IDAHO RIVERS UNITED
Intervenor Idaho Rivers United, by and through counsel, requests that United Water
Idaho, Inc. ("UWI" or "Company ) provide the following information. Idaho Rivers United
recognizes this request comes after the deadlines for completion of discovery set by
Commission. However, this request seeks data prepared by UWI in relation to the Stipulation
entered by UWI and the Community Action Partnership Association of Idaho. The Stipulation
, was signed and circulated to the parties via regular mail on March 23 2005 , two days prior to the
close of discovery. Idaho Rivers United requests UWI provide this information via fax or
delivery to counsel no later than close of business on April 4, 2005.
This Production Request is considered to by continuing, and the Company is requested to
provide, by way of supplementary responses, additional documents or information that it or any
SECOND PRODUCTION REQUESTS OF IDAHO RIVERS UNITED --
person acting on its behalf may later obtain that will augment the information or documents
produced.
In answering each request, please provide the name' of the person( s) preparing the
answers, along with the title and function such individual holds with the Company and the
witness who can sponsor the answer at the hearing.
REQUEST NO.6: Please provide the billing data analysis referenced in the
Stipulation between UWI and CAP AI dated March 23 2005 (at Attachment A, final
paragraph of page 1).
DATED this 1st day of April, 2005.
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William M. Eddie
On behalf of Idaho Rivers United
SECOND PRODUCTION REQUESTS OF IDAHO RIVERS UNITED -- 2
CERTIFICATE OF SERVICE
I hereby certify that on this 1 ST day of April 2005 , true and correct copies of the
foregoing SECOND PRODUCTION REQUESTS were delivered to the following
persons via the method of service noted:
Via U.S. Mail:
Dean J. Miller
McDevitt & Miller LLP
420 W. Bannock St
Boise, ID 83702
(also provided by fax)
Douglas Strickling
Boise City Attorney s Office
O. Box 500'
Boise, ID 83701
Mark Gennari
United Water
200 Old Hook Rd.
Harrington Park, NJ 07640-1738
Chuck Mickelson
City of Boise
O. Box 500
Boise, ID 83701
Brad M. Purdy
2019 N. 17th St.
Boise, ID 83702
Weldon Stutzman
Donovan E. Walker
Deputy Attorneys General
Idaho Public Utilities Commission
O. Box 83720
Boise, ID 83720
Scott L. Campbell
O. Box 829
Boise, ID 8370' 1
Sharon Ullman
9627 W. Desert Ave.
Boise, ID 8370'9
William M. Eddie
SECOND PRODUCTION REQUESTS OF IDAHO RIVERS UNITED -- 3