ABSTRACT: Re: BEFORE THE PUBLIC UTILITIES COMMISSION OF THE STATE OF CALIFORNIA Order Instituting Investigation And Order to Show Cause on the Commission’s Own Motion into the Operations and Practices of Pacific Gas and Electric Company with Respect to Facilities Records for its Natural Gas Distribution System Pipelines, the PACIFIC GAS AND ELECTRIC COMPANY’S SUPPLEMENTAL REPLY IN SUPPORT OF ITS MOTION TO COMPEL DISCOVERY FROM INTERVENOR THE CITY OF CARMEL-BY-THE-SEA and SUPPLEMENTAL DECLARATION OF MARIE L. FIALA IN SUPPORT
OF PACIFIC GAS AND ELECTRIC COMPANY’S MOTION TO COMPEL document copy is embedded. CONCLUSION Accordingly, even if Carmel’s invocation of the attorney work product doctrine or official information privilege had any merit before, Carmel has waived them now. For this additional reason, PG&E respectfully requests that Your Honor either direct Carmel to immediately provide the requested discovery5 or preclude Carmel from seeking to introduce evidence going to any of the related allegations in this proceeding.
Filing Date 01-19-16PACIFIC GAS AND ELECTRIC COMPANY’S SUPPLEMENTAL REPLY IN SUPPORT OF ITS MOTION TO COMPEL DISCOVERY FROM INTERVENOR THE CITY OF CARMEL-BY-THE-SEA