20180326Williams Affidavit.pdf

Ronald L.Williams,ISB No.3034 RECENED
Williams Bradbury,P.C.y (():()O
P.O.Box 388
Boise ID,83701
Telephone:[phone]
Fax:[phone]
[e-mail]
Attorneys for PIIC
BEFORE THE IDAHO PUBLIC UTILITES COMMISSION
IN THE MATTER OF THE APPLICATION )Case No.PAC-E-17-07
OF ROCKY MOUNTAIN POWER FOR )
CERTIFICATES OF PUBLIC )AFFIDAVIT OF RONALD L.
CONVENIENCE AND NECESSITY AND )WILLIAMS IN SUPPORT OF
BINDING RATEMAKING TREATMENT )MOTION TO COMPEL DISCOVERY
FOR WIND AND TRANSMISSION )RESPONSES
FACILITIES
Affiant being first duly sworn upon oath hereby deposes and states as follows:
1.I am legal counsel of record for the PacifiCorp Idaho Industrial Costumers ("PIIC")and
as such possesses sufficient information and knowledge to attest to the statements set
forth herein.
2.Attached as Exhibit A to PIIC's Memorandum in Support of its Motion to Compel
("Memorandum")is a true and correct copy of PacifiCorp's responses to PIIC's 5th Data
Requests 21 -42.
3.Attached as Exhibit B to PIIC's Memorandum is a true and correct copy of my email to
PacifiCorp legal counsel asking that the Company only respond to Requests 30,31,34(d)
and 34(h),and that PIIC would "let go"of the other discovery requests.This email also
AFFIDAVIT OF RONALD L WILLIAMS,Page 1
asked that PacifiCorp respond "at your earliest convenience"and that I would "appreciate
knowing ASAP if [the Company]will not amend [its]answer."
4.In compliance with IRCP Rule 37,I have acted in good faith in attempting to confer and
resolve this discovery dispute,but PacifiCorp has failed to respond.
DATED thisË day of March,2018.
Ronald L.Williams
SUBSCRIBED AND SWORN TO before me this¾day of March,2018.
i '.:Notary Public for IdahoUBLN,.'O,?Residing at Boise,Ada County,Idaho
../*My Commission expires:Ÿek.4
AFFIDAVIT OF RONALD L WILLIAMS,Page 2