HomeMy WebLinkAbout20070409City of Eagle to Kastera 1-13.pdfMOORE SMITH BUXTON & TURCKE, CHARTERED
ATIORNEYS AND COUNSELORS AT LAW
950 W. BANNOCK STREET, SUITE 520; BorSE, ID 83702
TELEPHONE: (208) 331-1800 FAX: (208) 331-1202 www.msbtlaw.com
STEPHANIEJ. BONNEY
SUSAN E. BUXTON"
PAuLl. FITZER
MICHAEL c. MOORE*
BRUCE M. SMITH
PAUL A. TURCKE'
CARLl. WITHROE,,
TAMMY A. ZOKAN
JOHN J. McFADDEN"*
o/Counsel
)) Also admitted in California
+ Also admitted in New Mexico
" Also admitted in Oregon
, Also admitted in South Dakota
*Also admitted in Washington
April 6, 2007 (.J"
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~r. Scott VVoodbury
Idaho Public Utilities Commission
472 VV. VVashington
Boise, ID 83720
~ '" .(.-
RE: UVVI-VV-06-
Our File No. 1019.42
Dear ~r. VV oodbury:
Enclosed for filing in the above matter please find the original and 3 copies of the following:
City of Eagle s Requests for Production to Kastera LLC
City of Eagle s Requests for Production to United VVater Idaho
An additional copy of the document and this letter are included for return to our office.
Thank you for your assistance.
Sincerely yours
~OORE S~ITH BUXTON & TURCKE, CHTD.
Bruce ~. Smith
B~S/dls
Enclosures
Bruce ~. Smith, ISB # 3425
Susan E. Buxton, ISB # 4041
~OORE S~ITH BUXTON & TURCKE, CHARTERED
Attorneys at Law
950 VVest Bannock Street, Suite 520
Boise, Idaho 83702
Telephone: (208) 331-l800
Facsimile: (208) 331-1202
bms(?j),msbtlaw.com
Attorney for City of Eagle, Idaho
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BEFORE THE IDAHO PUBLIC UTILIES COMMISSION
IN THE ~ATTER OF THE APPLICATION OF )
UNITED VV ATER IDAHO INC., TO A~END
AND REVISE CERTIFICATE OF
CONVENIENCE AND NECESSITY NO 143
Case No. UVVI-VV-06-
CITY OF EAGLE'S FIRST
PRODUCTION REQUEST TO
KASTERA, LLC
The City of Eagle, Idaho, by and through its attorney of record, Bruce ~. Smith, and
requests that Kastera, LLC provide the following documents and information on or before
FRIDAY, APRIL 20, 2007.
Kastera, LLC is reminded that responses pursuant to Commission Rules of Procedure
must include the name and phone number of the person preparing the document, and the name
location and phone number of the record holder. Reference IDAP A 31.01.01.228.
This Production Request is to be considered as continuing, and Capital Development 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 produced.
CITY OF EAGLE'S FIRST PRODUCTION REQUEST TO KASTERA, LLC - 1
1019.42
Please provide answers to each question; supporting work papers that provide detail or
are the source of information used in calculations; the name and telephone number of the person
preparing the documents; and the name, location, and telephone number of the record holder.
REQUEST NO.Please provide a copy of the Comprehensive Plan applicable to your
proposed Trailhead Community development.
REQUEST NO.Please provide a copy of your complete application to Ada County
for rezone and subdivision approval.
REQUEST NO.Please provide a copy of all correspondence, including emails and
facsimiles, and any attachments thereto, between you and Ada County regarding the Trailhead
Community development.
REQUEST NO.Please provide a copy of any schedule(s) for public hearing for the
Trailhead Community development.
REQUEST NO.Please provide a copy of all correspondence and contracts or other
agreements, including emails and facsimiles and any attachments thereto, between you and
United VV ater regarding the Trailhead Community development.
REQUEST NO.Please provide a copy of all engineering design drawings for the
water distribution system for the Trailhead Community development.
REQUEST NO.Please provide a copy of all water rights appurtenant to the property
included within the Trailhead Community development.
REQUEST NO.: Please provide a copy of all engineering designs and drawings for
any irrigation facilities for the Trailhead Community development.
CITY OF EAGLE'S FIRST PRODUCTION REQUEST TO KASTERA, LLC - 2
1019.
REQUEST NO. 10: Please provide a copy of any letter, memoranda, email, assessment
or analysis between or among your employees, staff, or consultants regarding annexation of the
development into the City of Eagle or application to Ada County for rezone and subdivision
approvals,
REQUEST NO. : Please provide a copy of any proposed or final schedule(s) for
development, including any phases, of the Lanewood development.
REQUEST NO. 12 : Please provide a copy of any purchase and sale agreement(s) for
land for the Lanewood development as referenced in the ~arch 14, 2007 Affidavit of 1. Ramon
Yorgason.
REQUEST NO. Please provide a copy of all water needs assessments for the
Lanewood development.
DATED this day of April, 2007.
~OORE S~ITH BUXTON & TURCKE
RTERED
Bruce ~. Smith
Attorney for City of Eagle, Idaho
CITY OF EAGLE'S FIRST PRODUCTION REQUEST TO CAPITAL DEVELOPMENT, INC. - 3
1019.49
CERTIFICATE OF SERVICE
I hereby certify that on this day of April, 2007, the foregoing document was served
to the following parties by the method indicated below:
Dean 1. ~iller
~cDevitt & ~iller, LLP
420 VV, Bannock Street (83702)
PO Box 2564
Boise, ID 83701
i oe(?j),mcdevitt - miller .com
--+ ) U.S. ~ail, Postage Prepaid
( )
Hand Delivered
( )
Overnight ~ail
( )
Facsimile
( )
Other
Scott VV oodbury
Deputy Attorney General
Idaho Public Utilities Commission
472 VVest VVashington Street (83702)
O. Box 83720
Boise, ID 83720-0074
scott. woodbury(?j),puc. idaho. gov
( ) US. ~ail, Postage Prepaid
( ) Hand Delivered
( )
Overnight ~ail
( )
Facsimile
( )
Other
Tom ~orris
372 S. Eagle Road, Suite 375
Eagle, ID 83616
tom. m orri s (?j),kas tera. co m
-r) US. ~ail, Postage Prepaid
( )
Hand Delivered
( )
Overnight ~ail
( ) Facsimile
( )
Other
Attorney for City of Eagle, Idaho
CITY OF EAGLE'S FIRST PRODUCTION REQUEST TO KASTERA, LLC - 5
1019.