request_number:  DS-AC:001
firstname:  Thomas
lastname:  DeBoer
e-mail:  tdeboer@painehamblen.com
exhibit_wp-02-e-:  JCG-01 and JCG-02
page_numbers:
request_text:  Please disclose and/or produce copies of any and all
communications, from October 16, 2001 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 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:  There have been no communications from October 16, 2001
forward.  We have received your amendment to this data
request via e-mail but have not yet received a hard copy.
Once we receive the hard copy, we will respond within seven
(7) days as  set forth in WP-02-O-05.

The following information is from the web server:
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2.  Remote Host:  border.paine-hamblen.com
3.  Remote IP Address:  207.53.155.98
4.  Form URL:  
https://secure.bpa.gov/power/secure/psp/ratecase/discovery/wp_02_response.html
5.  Browser Client:  Mozilla/4.7 [en] (Win98; I)