HomeMy Public PortalAboutExhibit BJH 70 BJH 3rd Discovery Request to MSDBEFORE THE RATE COMMISSION
OF THE METROPOLITAN ST. LOUIS SEWER DISTRICT
For Consideration of a Wastewater Rate
Change Proposal by the Rate
Commission of the Metropolitan
St. Louis Sewer District
Third Discovery Request of Barnes Jewish Hospital to MSD
1. Please provide the names and positions of anyone on MSD's staff (or under MSD's
direction) who has reviewed Black & Veatch's electronic rate model with all formulas
intact, as described in MIEC's First Data Request to MSD, Question 1-1 and designated
as both Exhibit MSD 15 and Exhibit MIEC 15.
2. Please provide a copy of any executed Confidentiality Agreement (by that name or any
similar name for such purpose) between Black & Veatch and MSD relating to this rate
case and the confidential and/or proprietary information provided or to be provided in
this rate case.
DATED: AUGUST 26, 2011
SANDBERG PHOENIX & VON GONTARD, P.C.
Lisa C. Lang€i'ieckert #49781
600 Washington Avenue — 15T Floor
St. Louis, MO 63101-1313
314 446-4238 (Direct Dial)
314 241-7604 (FAX)
llangeneckert@sandbergphoenix.com
Attorneys for Barnes -Jewish Hospital
3109560\1
CERTIFICATE OF SERVICE
I hereby certify that I have this day caused a copy of the foregoing to be served on the
Secretary of the Rate Commission and all persons on the official service list of record in this
matter on this 26th day of August, 2011.
Lisa C. Langeneckert
3109560\1