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Enron Mail |
request_number: BPA-JCG:012
firstname: Pamela lastname: Jacklin e-mail: pljacklin@stoel.com exhibit_wp-02-e-: JCG-02 page_numbers: page 11, line 13 - page 18, line 10 request_text: The JCG proposes to eliminate WP-02-E-BPA-65 and=20 WP-02-E-BPA-74, except for page 1, lines 1-22 and page 8, line 4 to page 9,= =20 line 17. The JCG, however, has filed testimony on the same central issue f= or=20 which it finds BPA=01,s testimony objectionable. Why is it necessary to=20 eliminate either BPA=01,s or the JCG=01,s testimony when Section C.1. of th= e=20 Partial Stipulation and Settlement Agreement provides that =01&no Party sha= ll be=20 deemed to have approved, admitted or consented to the facts, principles,=20 methods or theories employed in arriving at the terms of this Partial=20 Settlement Agreement or the Parties=01, Proposal, nor shall any party be de= emed=20 to have agreed that any provision of this Partial Settlement or Parties=01,= =20 Proposal is appropriate for resolving issues in any other proceeding=20 regardless of whether the Parties=01, Proposal or Partial Settlement is ado= pted=20 by the Administrator, except as expressly provided in this Partial=20 Settlement=018? Please provide a complete explan! at! ion why it is absolutely necessary to eliminate any currently filed testimo= ny=20 and please provide any alternatives to eliminating such testimony considere= d=20 by the JCG. response_text: OBJECTION Data Request BPA-JCG:012 was not properly served and is otherwise=20 objectionable. The Joint Customer Group objects to the above Data Request,= =20 as it seeks information about why the Joint Customers contend that the=20 testimony is inconsistent with the Partial Settlement. Whether BPA's=20 testimony is consistent or not with the Partial Settlement is not the prope= r=20 subject of a data request. The following information is from the web server: 1. Logon: IUSR_GRANITE 2. Remote Host: 198.36.178.141 3. Remote IP Address: 198.36.178.141 4. Form URL: =20 https://secure.bpa.gov/power/secure/psp/ratecase/discovery/wp_02_response.h= tml 5. Browser Client: Mozilla/4.0 (compatible; MSIE 5.01; Windows NT)
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