20070410Kastera to City of Eagle 1-5.pdf

Tom C, Morris, ISB No. 2974
Kastera LLC
372 S. Eagle Rd., Suite 375
Eagle, Idaho 83616
[phone]
tom morris~kastera.com
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BEFORE THE IDAHO PUBLIC UTILITIES COMMISSION
IN THE MATTER OF THE APPLICATION
OF UNITED WATER IDAHO INC. TO
AMEND AND REVISE CERTIFICATE OF
CONVENIENCE AND NECESSITY NO. 143
FIRST PRODUCTION
REQUEST OF KASTERA
LLC TO THE CITY OF
EAGLE, IDAHO
CASE NO. UWI-06-
Kastera LLC ("Kastera ) requests that the City of Eagle provide the following
documents and information on or before APRIL 20, 2007.
The City of Eagle 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
IDAPA 31.01.01.228.
This Production Request is to be considered as continuing, and the City of Eagle
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.
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,
For each item, please indicate the name ofthe persons(s) preparing the answers
along with the job title of such person(s) and the witness who can sponsor the answer at
hearing.
REQUEST NO.1: Please provide a copy of all documentation in your
possession, including all letters, memoranda and emails, that in any way deals with the
Kastera annexation request for the Trailhead Community.
REQUEST NO.2: Please provide a copy of all documentation in your
possession, including all letters, memoranda and emails, that in any way deals with the
City of Eagle s plan to provide water service to the Trailhead Community.
REQUEST NO.3: Please provide a copy of all written or electronic
communications with any outside or third party consultants (not including legal counsel)
concerning the City of Eagle s ability to provide water service to the Trailhead
Community.
REQUEST NO.4: If the City of Eagle has, as of this date, an enforceable
annexation path for the Trailhead Community, please identify in detail such path of
annexation, including all parties involved and the agreements in place to establish such
path. If an annexation path does not currently exist, please provide a copy of all letters
contracts, agreements, memoranda of understanding, development agreements or similar
documents that the City of Eagle has used in its attempt to establish an annexation path
for the Trailhead Community. Please include any map or maps that show the existing,
intended or anticipated path of annexation for the Trailhead Community.
REQUEST NO 5: As of this date, what capability does the City of Eagle have to
provide water service to the Trailhead Community? Based upon the facilities currently in
place or under construction, what is the earliest date that the City of Eagle could provide
water service to the Trailhead Community?
Dated this 6th day of April, 2007.
om C. Morris, Secretary/Attorney
Kastera LLC
CERTIFICATE OF SERVICE
I HEREBY CERTIFY THAT I HAVE THIS 6TH DAY OF APRIL, 2007, SERVED THE
FOREGOING FIRST PRODUCTION REQUEST IN CASE NO. UWI-06-, BY
THE METHOD INDICA TED BELOW, AND ADDRESSED TO THE FOLLOWING:
Dean J. Miller, Esq,
McDevitt & Miller LLP
420 West Bannock Street
PO Box 2564
Boise, ID 83701
(x) U.S. Mail, Postage Prepaid
( ) Hand Delivered
( ) Overnight Mail
( ) Facsimile
Gregory P. Wyatt
United Water Idaho, Inc.
PO box 190420
Boise, ID 83719
(x) U.S. Mail, Postage Prepaid
( ) Hand Delivered
( ) Overnight Mail
( ) Facsimile
Bruce M. Smith
Moore, Smith, Buxton
& Turcke, Chartered
950 W. Bannock St.
Suite 520
Boise, ID 83702
Jean Jewell, Secretary
Idaho Public Utilities Commission
472 West Washington Street
PO Box 83720
Boise, ID 83720-0074
Scott Woodbury
Idaho Public Utilities Commission
472 West Washington Street
PO Box 83720
Boise, ID 83720-0074
( ) U.S. Mail, Postage Prepaid
(x) Hand Delivered
( ) Overnight Mail
( ) Facsimile
(x) U.S. Mail, Postage Prepaid
( ) Hand Delivered
( ) Overnight Mail
( ) Facsimile
(x) U.S. Mail, Postage Prepaid
( ) Hand Delivered
( ) Overnight Mail
() Facsimile