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1 PLLC Attorneys at Law 1411 Virginia Street, East wwwt.shumanlaw.com 1445 Stewartstown Road, Suite 200 Suite 200 Morgantown, West Virginia P.O. Box 3953 Telephone Charleston, West Virginia Christopher D. Negley, Esq. Facsimile Telephone manlaw.com Facsimile Ingrid Ferrell Executive Secretary Legal Division Public Service Commission of West Virginia 201 Brooks Street Charleston, West Virginia April 17, Re: Case No PSD-PC Petition for Consent and Approval to Uncouple from the City of St. Albans Municipal Utility Commission Dear Ms. Ferrell: Enclosed herein please find an original and twelve copies of the Greater St. Albans Public Service District s Objections to Staffs First Data Requests for filing in the above-referenced matter. Thank you for your attention to this matter. Should you have any questions, please do not hesitate to contact me. Christopher D. Negley CDN/lm Enclosures

2 PUBLIC SERVICE COMMISSION OF WEST VIRGINIA CHARLESTON In Re: CASE NO PSD-PC Petition for Consent and Approval to uncouple from the St. Albans Municipal Utility Commission GREATER ST. ALBANS PUBLIC SERVICE DISTRICT S OBJECTIONS TO STAFF S FIRST DATA REQUESTS COMES NOW the, by Counsel, who hereby files the following objections pursuant to 150 CSR 1, d. Question No. 11. Provide a plan for the District to perform billing and collecting services. The plan should identify the equipment, software program, personnel and training necessary to perform those services. REPONSE: Objection. This Request for Production seeks the PSD to provide a plan for the District to perform a billing and collecting service. The Request is improper under Rule 34 of the West Virginia Rules of Civil Procedure as the District does not have a plan at this time. Rather, as Staff is aware, it is seeking permission to prepare a plan as a part of its filing. The GSAPSD will supplement this Response when required by the Public Service Commission. Question No. 12. If MUC decides to terminate the Agreement in its entirety, include a detailed plan for the District to acquire the necessary tools, equipment and personnel with adequate training and knowledge to operate the sewer system. RESPONSE: Objection: Relevance. As GSAPSD set forth in its Petition the Agreement between MUC and GSAPSD, the GSAPSD Petition clearly states that no action is contemplated with regard to the Agreement which runs until Accordingly, this request is irrelevant under Rules of Civil Procedure 26. 1

3 Objection. Speculation. This Requests asks for the MUC to respond to a question based on a hypothetical involving a third-party. Accordingly, GSAPSD cannot respond in the format posed and thus is not required to Answer under Rule 26 of the West Virginia Rules of Civil Procedure. Objection. This Request for Production seeks the PSD to provide a plan should MUC decide to terminate the Agreement between MUC and GSAPSD. The Request is improper under Rule 34 of the West Virginia Rules of Civil Procedure as the District does not have a plan at this time. Question No. 14. Provide a detailed list of infrastructure, facilities, equipment, tolls and appurtenances that will need replaced in within five years. RESPONSE: Objection: Relevance. As GSAPSD set forth in its Petition the Agreement between MUC and GSAPSD which governs the type of information sought in the question, the GSAPSD Petition clearly states that no action is contemplated with regard to the Agreement which runs until Accordingly, this request is irrelevant under Rules of Civil Procedure 26. Objection. Respecthlly submitted, GREATER ST. ALBANS PUBLIC SERVICE DISTRICT By Counsel Christopher D. Negley, Esq. (WVSB ## 6086) SHUMAN, MCCUSKEY & SLICER, PLLC Virginia Street, East, Suite 200 (25301) Post Office Box 3953 Charleston, West Virginia (304)

4 PUBLIC SERVICE COMMISSION OF WEST VIRGINIA CHARLESTON In Re: CASE NO PSD-PC Petition for Consent and Approval to uncouple from the St. Albans Municipal Utility Commission CERTIFICATE OF SERVICE I, Christopher D. Negley, do hereby certify that a true copy of the foregoing Greater St. Albans Public Service District s Objections to Stafs First Data Requests was served upon counsel of record by U. S. mail, postage prepaid and addressed as follows: Dated: This 1 7'h day of April, Lisa L. Wansley, Esquire Public Service Commission of West Virginia Post Office Box 812 Charleston, West Virginia Counsel for Commission Staff Christopher D. Negley (WV SB #6086) 3

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