Contract analysis

1. Proposed Document Production Schedule 1.1 Ridgeline's Initial Document Production Ridgeline proposes to serve its initial document production on MGPC no later than December 19, 2022, which is approximately two weeks after the scheduled filing of Ridgeline's direct testimony on December 5, 2022. We believe this timeline will afford MGPC sufficient opportunity to review Ridgeline's testimony before evaluating the ac

2. Proposed Data Request Schedule 2.1 First Round of Data Requests Ridgeline proposes that the first round of data requests be served within ten (10) business days of receipt of answering testimony. Given that answering testimony is currently scheduled for filing on January 9, 2023, the deadline for service of first-round data requests would fall on approximately January 23, 2023. Responses to first-round data reques

3. Proposed Deposition Schedule 3.1 Ridgeline Witnesses Ridgeline is prepared to make the following witnesses available for deposition by MGPC following the filing of Ridgeline's direct testimony on December 5, 2022: (a) James K. Winfield, Chief Executive Officer and President, Ridgeline Midstream Services LLC. Mr. Winfield's testimony will address policy considerations, the need for the Ridgeline pipeline project, a

4. Protective Order and Confidentiality As referenced above, Ridgeline has been engaged in protective order negotiations with ATPC's counsel, Mr. William Pratt of Kellner, Royce & Dillard LLP, since approximately late September 2022. Those negotiations are progressing productively, and we anticipate reaching agreement on protective order terms in the near future. Ridgeline proposes that MGPC join a single omnibus pro

5. Coordination with Other Parties and the Proceeding Schedule As you are aware, this proceeding involves several parties in addition to Ridgeline and MGPC. The following parties have intervened and are represented by counsel of record: (a) Appalachian Trunk Pipeline Company, LLC ("ATPC"), which filed its protest and motion to intervene on August 15, 2022. ATPC is represented by William Pratt, Esq., Kellner, Royce &

6. Specific Ridgeline discovery Interests Regarding MGPC In addition to the general discovery categories discussed above, Ridgeline wishes to identify the following specific areas of interest that it intends to explore through the discovery process. Early identification of these areas is intended to allow MGPC to organize its document collection and review efforts efficiently and to minimize the likelihood of discove

7. Proposed Summary Timeline For ease of reference, Ridgeline presents the following consolidated proposed discovery timeline: The dates set forth above are proposed and are subject to the mutual agreement of the parties and any modifications that ALJ Whitfield may deem appropriate. Ridgeline is prepared to discuss adjustments to these dates as necessary to accommodate the schedules of witnesses, counsel, and the Com

8. Request for Response We respectfully request that you respond to this letter on behalf of MGPC no later than December 2, 2022, with the following information: (a) MGPC's comments on the proposed discovery schedule, including any suggested modifications to the document production, data request, or deposition timelines set forth herein; (b) Any counter-proposals MGPC may wish to advance regarding the format, scope,