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Home My WebLink About20070409City of Eagle to CDI 1-13.pdfMOORE SMITH BUXTON & TURCKE, CHARTERED ATTORNEYS AND COUNSELORS AT LAW 950 W. BANNOCK STREET, SUITE 520; BOISE, ID 83702 TELEPHONE: (208) 331-1800 FAX: (208) 331-1202 www.msbtlaw.com STEPHANIEJ. BONNEY SUSAN E. BUXTON' PAUL J. FITZER MICHAEL C. MOORE' BRUCE M. SMITH PAUL A. 'TURCKE' CARLJ. WITHROE,, TAMMY A. ZOKAN JOHN J. McFADDEN" Of Counsel )) Also admitted in California + Also admitted in New Mexico . Also admitted in Oregon , Also admitted in South Dakota 'Also admitted in Washington . - ,~3 April 6 , 2007 r- :::; c, --= ~-'-:::::," .' - Mr. Scott Woodbury Idaho Public Utilities Commission 472 W. Washington Boise, ill 83720 , ' enC' OJ'? (5"; RE: UWI- W -07 - Our File No. 1019.49 Dear Mr. Woodbury: Enclosed for filing in the above matter please find the original and 3 copies of the City of Eagle Requests for Production to United Water Idaho and Capital Development, Inc, along with the original and 7 copies of the City of Eagle s Reply to Capital Development, Inc.' s Motion to File Brief on Legal Issues. An additional copy of each document and this letter are included for return to our office. Thank you for your assistance. Sincerely yours MOORE SMITH BUXTON & TURCKE, CHTD. Bruce M. Smith BMS/d1s Enclosures Bruce M. Smith, ISB # 3425 Susan E. Buxton, ISB # 4041 MOORE SMITH BUXTON & TURCKE , CHARTERED Attorneys at Law 950 West Bannock Street, Suite 520 Boise, Idaho 83702 Telephone: (208) 331-1800 Facsimile: (208) 331-1202 bms~msbt1aw.com Attorney for City of Eagle, Idaho '" , ~Cj7 .-G F,i ll: SS i."::~i;,_, ",. 1 ".. ""' -"';;""":;'::';/( BEFORE THE IDAHO PUBLIC UTILIES COMMISSION IN THE MATTER OF THE APPLICATION OF ) UNITED WATER IDAHO INC., TO AMEND AND REVISE CERTIFICATE OF CONVENIENCE AND NECESSITY NO 143 Case No. UWI-07- CITY OF EAGLE'S FIRST PRODUCTION REQUEST TO CAPITAL DEVELOPMENT, INC. The City of Eagle, Idaho, by and through its attorney of record, Bruce M. Smith, requests that Capital Development, Inc. provide the following documents and information on or before FRIDAY, APRIL 20, 2007. Capital Development 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 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 CAPITAL DEVELOPMENT, INc. - 1 1019. 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 Lanewood 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 emai1s and facsimiles, and any attachments thereto , between you and Ada County regarding the Lanewood development. REQUEST NO.Please provide a copy of any schedu1e(s) for public hearing for the Lanewood development. REQUEST NO.Please provide a copy of all correspondence and contracts or other agreements , including emai1s and facsimiles and any attachments thereto, between you and United Water regarding the Lanewood development. REQUEST NO.Please provide a copy of all engineering design drawings for the water distribution system for the Lanewood development. REQUEST NO.Please provide a copy of all water rights appurtenant to the property included within the Lanewood development. REQUEST NO.Please provide a copy of all engineering designs and drawings for any irrigation facilities for the Lanewood development. REQUEST NO.Please provide a copy of any CCR's for the Lanewood development. CITY OF EAGLE'S FIRST PRODUCTION REQUEST TO CAPITAL DEVELOPMENT, INc. - 2 1019. REQUEST NO. 10 : Please provide a copy of any letter, memoranda, emai1, 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 schedu1e(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 March 14, 2007 Affidavit of J. Ramon Yorgason. REQUEST NO. Please provide a copy of all water needs assessments for the Lanewood development. DATED this day of April, 2007. MOORE SMIT CHARTERED TON & TURCKE ce M. Smith Attorney for City of Eagle, Idaho CITY OF EAGLE'S FIRST PRODUCTION REQUEST TO CAPITAL DEVELOPMENT, INc. - 3 1019. 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: Scott Woodbury Deputy Attorney General Idaho Public Utilities Commission 472 West Washington Street (83702) O. Box 83720 Boise, ID 83720-0074 scott.woodbury~puc.idaho.ov \ Robert B. Burns ' "f) u.S. Mail, Postage Prepaid Moffatt, Thomas , Barrett, Rock & Fields, Chtd ( ) Hand Delivered 101 S. Capitol Blvd., 10th Floor ( ) Overnight MailPO Box 829 ( ) Facsimile Boise, ID 83701 ( ) Other rbb~moffatt.com ) U.S. Mail, Postage Prepaid ( ) Hand Delivered ( ) Overnight Mail ( ) Facsimile ( ) Other ~) US, Mail, Postage Prepaid ( ) Hand Delivered ( ) Overnight Mail ( ) Facsimile ( ) Other Dean J. Miller McDevitt & Miller, LLP 420 W. Bannock Street (83702) PO Box 2564 Boise, ID 8370 i oe~mcdevitt - miller. com rUce..-.M. Smith Attorney for City of Eagle, Idaho CITY OF EAGLE'S FIRST PRODUCTION REQUEST TO CAPITAL DEVELOPMENT, INC. - 4 1019.