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Enron Mail |
request_number: DS-WA:015
firstname: Terry lastname: Mundorf e-mail: terrym@millcreeklaw.com exhibit_wp-02-e-: JGC-01, 02 page_numbers: request_text: : Please disclose and/or produce copies of any and all communications, from October 16, 2000 to the present, between any BPA representative and any representative of any other party, concerning any of the following subjects: a. The general structure of the Cost Recovery Adjustment Clauses (CRACs) described in the testimony of the Joint Customers; b. Any differences between the form of the CRACs described in the testimony of the Joint Customers and the CRACs contained in BPA's Amended Proposal, or those contained in BPA's Supplemental Proposal; c. The detailed mechanics of implementing the CRACs described in the testimony of the Joint Customers; d. Revenue effects of the CRACs described in the testimony of the Joint Customers, any modifications; or e. Any aspect of the Partial Stipulation and Settlement Agreement and the Parties' Proposal attached thereto. For purposes of this Request, "disclose and/or produce" has the meanings described below. With respect to oral communications, "disclose and/or produce" means to describe the time, date, approximate duration, and substantive content of the communication; the identity and organizational affiliation of the communicating individuals; whether the communication occurred in person or by telephone; the location of the communication if in person; the identity of any witnesses to the communications, including all individuals in the room if the communication occurred by speakerphone; and whether the communication was made in the presence of or after coordination with BPA counsel (if so, identify such counsel). For purposes of this Request, you need not "disclose and/or produce" oral communications that occurred during meetings noticed in compliance with Rate Case Rule 1010.7(d). With respect to written communications, the Request includes communications in any recorded form, whether on paper, electronic (including, without limitation, e-mails), or whatever form. For such communications, "disclose and/or produce" means to provide copies of all non-identical versions of any written communications and to describe with particularity the location where such communications were found and/or stored, including the identity of the individual with possession or control of the written communications; to describe with particularity the circumstances under which they were generated or referred to; and to fully "disclose and/or produce" any oral communications made in connection with the written communications consistent with the preceding paragraph. For purposes of this Request, you need not produce papers served on all parties to the rate case and made part of the official file in the rate case. response_text: Exhibit 1 reflects e-mails currently on file. The computer of Terry Mundorf suffered a virus attack on or about 2/15/01, which corrupted the Outlook program. In order to repair the damage, all incoming e-mail was purged on or about 2/20/01, which eliminated records of incoming e-mail prior to that date. WPAG has no records of meetings or telephone calls that requested in DS-WA:015-017, so the information contained in Exhibit 2 is based on best recollection. For written communications, see Exhibit 1. For oral communications, see Exhibit 2. The exhibits and attachments are available in BPA's Data Response Room. The following information is from the web server: 1. Logon: IUSR_GRANITE 2. Remote Host: router.millcreeklaw.com 3. Remote IP Address: 204.57.181.3 4. Form URL: https://secure.bpa.gov/power/secure/psp/ratecase/discovery/wp_02_response.html 5. Browser Client: Mozilla/4.0 (compatible; MSIE 5.01; Windows 95)
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