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 MOTION TO COMPEL DISCOVERY FROM INTERVENOR THE CITY OF CARMEL-BY-THE-SEA and DECLARATION OF MARIE L. FIALA IN SUPPORT OF PACIFIC GAS AND ELECTRIC COMPANY’S MOTION TO COMPEL DISCOVERY FROM CARMEL-BY-THE-SEA and [PROPOSED] RULING GRANTING PACIFIC GAS AND ELECTRIC COMPANY’S MOTION TO COMPEL DISCOVERY FROMINTERVENOR THE CITY OF CARMEL-BY-THE-SEA document copies are embedded.
ARGUMENT
A. The Information PG&E Requested Is Not Only Relevant, But Necessary to Clarify the Allegations Carmel Has Interjected into This ProceedingB. No Attorney-Client Privilege Exists Between Carmel and Ms. Banach
C. Facts Learned from Ms. Banach Are Not Protected as Work Product.
D. Carmel Has Not Shown That the Official-Information Privilege Applies.
E. Carmel’s Objection Based on the “Characterization” or “Purpose” of the Subpoena Does Not Provide a Basis for Refusing to Respond
CONCLUSION
For all these reasons, PG&E respectfully requests that ALJ Bushey adopt the proposed ruling filed with this Motion, which directs Carmel to provide responses and all responsive, non-privileged documents to Questions 13 through 23 in PG&E’s third sets of data requests not later than January 14, 2016.
Motion to Compel Discovery 12-31-15
PACIFIC GAS AND ELECTRIC COMPANY’S MOTION TO COMPEL DISCOVERY FROM INTERVENOR THE CITY OF CARMEL-BY-THE-SEA
DECLARATION OF MARIE L. FIALA IN SUPPORT OF PACIFIC GAS AND ELECTRIC COMPANY’S MOTION TO COMPEL DISCOVERY FROM CARMEL-BY-THE-SEA
[PROPOSED] RULING GRANTING PACIFIC GAS AND ELECTRIC COMPANY’S MOTION TO COMPEL DISCOVERY FROMINTERVENOR THE CITY OF CARMEL-BY-THE-SEA
For all these reasons, PG&E respectfully requests that ALJ Bushey adopt the proposed ruling filed with this Motion, which directs Carmel to provide responses and all responsive, non-privileged documents to Questions 13 through 23 in PG&E’s third sets of data requests not later than January 14, 2016.
Motion to Compel Discovery 12-31-15
PACIFIC GAS AND ELECTRIC COMPANY’S MOTION TO COMPEL DISCOVERY FROM INTERVENOR THE CITY OF CARMEL-BY-THE-SEA
DECLARATION OF MARIE L. FIALA IN SUPPORT OF PACIFIC GAS AND ELECTRIC COMPANY’S MOTION TO COMPEL DISCOVERY FROM CARMEL-BY-THE-SEA
[PROPOSED] RULING GRANTING PACIFIC GAS AND ELECTRIC COMPANY’S MOTION TO COMPEL DISCOVERY FROMINTERVENOR THE CITY OF CARMEL-BY-THE-SEA
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