20230222Veolia to Micron No. 1-3.pdf

VEOLIA WATER IDAHO, INC.’S FIRST PRODUCTION REQUEST TO
MICRON TECHNOLOGY, INC. PAGE 1 OF 4
16629634_2.DOCX (30-235)
Preston N. Carter, ISB No. 8462
Blake W. Ringer, ISB No. 11223
Givens Pursley LLP
601 W. Bannock St.
Boise, ID 83702
Telephone: [phone]
Facsimile: [phone]
[e-mail]
[e-mail]

Attorneys for Veolia Water Idaho, Inc.

BEFORE THE IDAHO PUBLIC UTILITIES COMMISSION

IN THE MATTER OF THE APPLICATION
OF VEOLIA WATER IDAHO, INC. FOR A
GENERAL RATE CASE
Case No. VEO-W-22-02

VEOLIA WATER IDAHO, INC.’S FIRST
PRODUCTION REQUEST TO MICRON
TECHNOLOGY, INC.
Veolia Water Idaho, Inc. (“Veolia” or “Company”), by and through its attorneys of
record, Givens Pursley LLP, requests that Micron Technology, Inc. (“Micron”) provide the
following documents and information as soon as possible, but no later than March 14, 2023.
This Production Request is to be considered continuing, and Micron 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 or information produced.
Please provide answers to each question; supporting workpapers that provide detail or are
the source of information used in calculations; the name, job title, and telephone number of the
person preparing the documents. Please also identify the name, job title, location, and telephone
number of the record holder.
In addition to the written copies provided as responses to the requests, please provide all
Excel spread sheets and electronic files with formulas intact and enabled.
RECEIVED
2023 February 21, 4:18PM
IDAHO PUBLIC
UTILITIES COMMISSION
VEOLIA WATER IDAHO, INC.’S FIRST PRODUCTION REQUEST TO
MICRON TECHNOLOGY, INC. PAGE 2 OF 4
16629634_2.DOCX (30-235)
DEFINITIONS
“Micron’s Witnesses” means the witnesses that have filed, or that may file in the future,
testimony on behalf of Micron in this proceeding.
REQUEST NO. 1: Please provide all Exhibits filed in support of the testimony of
Micron’s Witnesses in native format, with formulas intact.
REQUEST NO. 2: Please provide all workpapers that were created, referenced, or
otherwise used to support the testimony of Micron’s Witnesses. This request includes any
workpaper that includes or references calculations created, referenced, or otherwise used by the
witness in creating or drafting his or her testimony.
REQUEST NO. 3: Please provide all documents that were used to create, or that are
referenced within, any exhibit of the testimony of Micron’s Witnesses. If such documents were
provided by Veolia in response to production requests, there is no need to provide a second copy
of these documents, but please identify the document by production response number, file name,
and other identifying characteristic such as file name.
DATED: February 21, 2023.

By:_____________________________
Preston N. Carter
Givens Pursley LLP
Attorneys for Veolia Water Idaho, Inc.

VEOLIA WATER IDAHO, INC.’S FIRST PRODUCTION REQUEST TO
MICRON TECHNOLOGY, INC. PAGE 3 OF 4
16629634_2.DOCX (30-235)
CERTIFICATE OF SERVICE

I certify that on February 21, 2023, a true and correct copy of the foregoing was served
upon all parties of record in this proceeding via electronic mail as indicated below:

Commission Staff Via Electronic Mail
Jan Noriyuki, Commission Secretary
Idaho Public Utilities Commission
11331 W. Chinden Blvd., Bldg. 8, Suite 201-A
Boise, ID 83714

[e-mail]
Dayn Hardie
Deputy Attorney General
Idaho Public Utilities Commission
11331 W. Chinden Blvd., Bldg. 8, Suite 201-A
Boise, ID 83714
[e-mail]

Lorna K. Jorgensen
Meg Waddel
Ada County Prosecuting Attorney’s Office
Civil Division
200 W. Front Street, Room 3191
Boise, ID 83702
[e-mail]

Sharon M. Ullman, pro se
5991 E. Black Gold St.
Boise, ID 83716
[e-mail]

Austin Rueschhoff
Thorvald A. Nelson
Austin W. Jensen
Holland & Hart, LLP
555 17th Street, Suite 3200
Denver, CO 80202
[e-mail]
[e-mail]
[e-mail]
[e-mail]
[e-mail]

Jim Swier
Micron Technology, Inc.
8000 South Federal Way
Boise, ID 83707
[e-mail]

VEOLIA WATER IDAHO, INC.’S FIRST PRODUCTION REQUEST TO
MICRON TECHNOLOGY, INC. PAGE 4 OF 4
16629634_2.DOCX (30-235)

Mary Grant
Deputy City Attorney
Boise, City Attorney’s Office
150 N. Capitol Blvd.
PO Box 500
Boise, ID 83701-0500

[e-mail]
[e-mail]

Preston N. Carter