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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" -.. ~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 ":;'" "~,", , . r: \ z:,u,iiJ"1j Iii '"..r, i "ri,;32;:,L3:(U I, , 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.