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Enron Mail |
request_number: DS-BPA:375
firstname: Sarah lastname: Westenberg e-mail: sawestenberg@bpa.gov exhibit_wp-02-e-: JCG-01 and =01)02. page_numbers: request_text: Please disclose and/or produce copies of any and all=20 communications, from October 16, 2001 to the present, between any BPA=20 representative and any representative of any other party, concerning any of= =20 the following subjects: a. The general structure of the Cost Recovery Adjustment Clauses (CRACs)=20 described in the testimony of the Joint Customers; b. Any differences between the form of the CRACs described in the testimony= =20 of the Joint Customers and the CRACs contained in BPA's Amended Proposal, o= r=20 those contained in BPA's Supplemental Proposal; c. The detailed mechanics of implementing the CRACs described in the=20 testimony of the Joint Customers; d. Revenue effects of the CRACs described in the testimony of the Joint=20 Customers, any modifications; or e. Any aspect of the Partial Stipulation and Settlement Agreement and the= =20 Parties' Proposal attached thereto. For purposes of this Request, "disclose and/or produce" has the meanings=20 described below. With respect to oral communications, "disclose and/or=20 produce" means to describe the time, date, approximate duration, and=20 substantive content of the communication; the identity and organizational= =20 affiliation of the communicating individuals; whether the communication=20 occurred in person or by telephone; the location of the communication if in= =20 person; the identity of any witnesses to the communications, including all= =20 individuals in the room if the communication occurred by speakerphone; and= =20 whether the communication was made in the presence of or after coordination= =20 with BPA counsel (if so, identify such counsel). For purposes of this=20 Request, you need not "disclose and/or produce" oral communications that=20 occurred during meetings noticed in compliance with Rate Case Rule 1010.7(d= ). With respect to written communications, the Request includes communications= =20 in any recorded form, whether on paper, electronic (including, without=20 limitation, e-mails), or whatever form. For such communications, "disclose= =20 and/or produce" means to provide copies of all non-identical versions of an= y=20 written communications and to describe with particularity the location wher= e=20 such communications were found and/or stored, including the identity of the= =20 individual with possession or control of the written communications; to=20 describe with particularity the circumstances under which they were generat= ed=20 or referred to; and to fully "disclose and/or produce" any oral=20 communications made in connection with the written communications consisten= t=20 with the preceding paragraph. For purposes of this Request, you need not= =20 produce papers served on all parties to the rate case and made part of the= =20 official file in the rate case. response_text: There are no communications that fit the description since= =20 October 16, 2001 has not occurred. The following information is from the web server: 1. Logon: IUSR_GRANITE 2. Remote Host: 53.180.74.220 3. Remote IP Address: 53.180.74.220 4. Form URL: =20 http://www.bpa.gov/power/secure/psp/ratecase/discovery/wp_02_response.html 5. Browser Client: Mozilla/4.0 (compatible; MSIE 5.01; Windows NT; BPA 4.= 01=20 SP2; BPA 5.01 SP1)
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