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Enron Mail |
request_number: DS-PP:011
firstname: Peter lastname: Richardson e-mail: peter@richardsonandoleary.com exhibit_wp-02-e-: JCG-01 and -02 page_numbers: request_text: Please disclose and/or produce any and all communications from October 16, 2001 to the present, between the BPA representatives listed below and any representative of any other party concerning BPA's rates to be in effect for Fiscal Years 2002-2006, the interactions of such rates and customer contracts, or procedural aspects of these rate proceedings. Bob Proctor Tim McCoy Byrne Lovell Byron Keep Valerie Lefler Jon Wright Peter Berger 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: The Public Power Council (PPC) objects to this Data Request on the grounds that it (i) seeks information that is not relevant; (ii) seeks information that is privileged; and (iii) seeks information that is unduly burdensome to produce. Rules of Procedure Governing Rate Hearings, Section 1010.8(b). PPC further objects to this Data Request on the grounds that it is in improper form as it does not cite to specific testimony or indicate the specific use to which the information sought will be put. Special Rules of Practice, WP-02-01. Without waiving the foregoing objections, PPC responds as follows: Please see attached. The e-mail dated 2/7/20 appears responsive to DS-PP:010 as well. The following information is from the web server: 1. Logon: IUSR_GRANITE 2. Remote Host: dsl226.usw-1-224.pacifier.com 3. Remote IP Address: 207.202.224.226 4. Form URL: https://secure.bpa.gov/power/secure/psp/ratecase/discovery/wp_02_response.html 5. Browser Client: Mozilla/4.76 [en] (Win95; U)
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