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Home My WebLink About20060426UWI 2nd interrogatories of BRACE.pdfMcDevitt & Miller LLP Lawyers (208) 343-7500 (208) 336-6912 (Fax) 420 W. Bannock Street O. Box 2564-83701 Boise, Idaho 83702 Chas. F. McDevitt Dean 1. (Joe) Miller April 26, 2006 Via Hand Delivery Jean Jewell, Secretary Idaho Public Utilities Commission 472 W. Washington St. Boise, Idaho 83720 Re: Case No. UWI-06- Dear Ms. Jewell: Enclosed for filing in the above matter please find three (3) copies of United Water Idaho s Second Interrogatories to Boise Residents Against Commercial Exploitation, Inc. Very Truly Yours ~~vitt 1iiller LLP 'dllnP~ DJM/hh ORIGINAL Dean J. Miller (ISB #1968) McDEVITT & MILLER LLP 420 West Bannock Street O. Box 2564-83701 Boise, ID 83702 Tel: 208.343.7500 Fax: 208.336.6912 i oe~mcdevi tt -miller. com .' ,r- - \: ;:) - 0 ' , " ' ", ", Attorneys for United Water Idaho Inc. BEFORE THE IDAHO PUBLIC UTILITIES COMMISSION Case No. UWI-O6- IN THE MATTER OF THE APPLICATION OF UNITED WATER IDAHO INe. FOR AUTHORITY TO INCREASE ITS RATES AND CHARGES FOR WATER SERVICE IN THE STATE OF IDAHO UNITED WATER'S SECOND INTERROGATORIES TO BOISE RESIDENTS AGAINST COMMERCIAL EXPLOIT A TION INc. TO:Boise Residents Against Commercial Exploitation, Inc. ("BRACE" NOTICE YOU WILL PLEASE TAKE NOTICE that you are hereby required to answer in writing the following interrogatories within fifteen (15) days from the date of service hereof. INSTRUCTIONS Procedure. You have a duty, pursuant to Rule 26(e) of the Idaho Rules of Civil Procedure, to reasonably supplement and amend your responses. Privilege. If, in responding or failing to respond to the discovery requested herein you invoke or rely upon any privilege of any kind, please state specifically the nature of the UNITED WATER'S SECOND INTERROGATORIES TO BOISE RESIDENTS AGAINST COMMERCIAL EXPLOITATION, INC. - 1 privilege and the basis upon which you invoke, rely upon, or claim it, and identify all documents or other information, including contracts and communications, which you believe to be embraced by the privilege invoked. INTERROGATORIES Interro2atorv No.. Please identify by name, occupation and address each and every person you intend to call as a witness at the hearing of this matter. Interro2atorv No.For each person identified in answer to Interrogatory No., please state the general nature of the facts to which each identified person will testify. Interro2atorv No.State the name and address of each Person(s) whom you expect to call as an expert witness at the hearing of this matter. For each such Identified Person(s), state: (a) The subject matter on which the expert is expected to testify; (b) The substance of the facts and opinions to which the expert is expected to testify; ( c) In capsule summary, the qualifications and background of such Identified expert (a produced exhibit curriculum vitae will be a satisfactory answer to this interrogatory); and (d) Pursuant to Rule 705 , I.R.E. set forth and disclose each and every underlying fact or data upon which the expert has or will rely in formulating and/or basing his or her opinion(s) or inference(s). UNITED WATER'S SECOND INTERROGATORIES TO BOISE RESIDENTS AGAINST COMMERCIAL EXPLOITATION, INC. - 2 Interro2atorv No.To the extent not previously disclosed in your answers to the preceding Interrogatories please in detail state each and every position or contention you intend to assert in this proceeding. DATED this day of April, 2006. ~VL Dean J. Miller Attorneys for United Water Idaho Inc. UNITED WATER'S SECOND INTERROGATORIES TO BOISE RESIDENTS AGAINST COMMERCIAL EXPLOITATION, INC. - 3 CERTIFICATE OF SERVICE I hereby certify that on the Jfli~y of April, 2006, I caused to be served, via the methodes) indicated below, true and correct copies of the foregoing document, upon: Jean Jewell, Secretary Idaho Public Utilities Commission 472 West Washington Street O. Box 83720 Boise, ID 83720-0074 iiewell~puc.state.id. Hand Delivered S. Mail Fax Fed. Express Email Scott L. Campbell, Esquire MOFF A TT, THOMAS, BARRETT ROCK & FIELDS, CHARTERED O. Box 829 Boise, ID 83701 Hand Delivered S. Mail Fax Fed. Express Email j;(,\- ~ ~ ~ ,lQ~fu" t UNITED WATER'S SECOND INTERROGATORIES TO BOISE RESIDENTS AGAINST COMMERCIAL EXPLOITATION, INC. - 4