HomeMy Public PortalAboutExhibit BJH 84 BJH 4th Discovery Request to MSD 090911BEFORE 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
Fourth Discovery Request of Barnes Jewish Hospital to MSI)
1. Please provide the date that Ms. Vanda reviewed the Black & Veatch electronic rate
model with all formulas intact, including: (a) the approximate amount of time she
spent reviewing the full model; (b) the portions of the model that she reviewed with
the approximate amount of time spent on each portion; (c) the location at which she
reviewed the model.
2. Please provide any updates to any prior responses to the First, Second, and Third
Discovery Requests of Bill to MSD.
3. As an ongoing request, please provide any additional updates to the First, Second, and
Third Discovery Requests of BM to MSD Staff, should MSD Staff responses change,
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through the close of the discovery period in this matter.
DATED: SEPTEMBER 9, 2011
SANDBERG PHOENIX & VON GONTARD, P.C.
/S/ Lisa C. Langeneckert
Lisa C. Langeneckert #49781
600 Washington Avenue — 15T11 Floor
St. Louis, MO 63101-1313
314 446-4238 (Direct Dial)
314 241-7604 (FAX)
Langeneckert@sandbergphoenix.com
Attorneys for Barnes -Jewish Hospital
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 81h day of September, 2011.
/S/ Lisa C. Langeneckert
Lisa C. Langeneckert
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