request_number:  DS-WA:016
firstname:  Terry Mundorf
lastname:  Mundorf
e-mail:  terrym@millcreeklaw.com
exhibit_wp-02-e-:  JGC-01, 02
page_numbers:
request_text:
request_text:  Please disclose and/or produce any and all communications from 
October 16, 2000 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:
  WPAG objects to this Data Request on the grounds that it (1) seeks 
information that is not relevant and (2) seeks information that is unduly 
burdensome to produce.  (Rules of Procedure Governing Rate Hearings, Section 
1010.8(b).)  WPAG 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 to information sought will be put,  (Special Rules 
of Practice, WP-02-O-01.)and was received after the deadline for submission 
of data requests.  Without waiving the foregoing objections, we respond as 
follows:

See response and exhibits to DS-WA:015.


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