1016-00005 · Dunmore Energy Holdings · Correspondence/Opposing Counsel

letter-to-whitmore-sable-discovery.docx DOCUMENT Finance & Banking

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CALDERWOOD & HARKNESS LLP Attorneys at Law

CALDERWOOD & HARKNESS LLP 1601 K Street NW, Suite 900 Washington, DC 20006 Telephone: (202) 555-7400 Facsimile: (202) 555-7401 www.calderwoodharkness.com

November 22, 2022

VIA EMAIL AND FIRST CLASS MAIL

Rebekah Montague, Esq. Partner Whitmore & Sable LLP 1200 New Hampshire Avenue NW, Suite 600 Washington, DC 20036

Re: FERC Docket Nos. RP22-847-000 and RP22-847-001 — Ridgeline Midstream Services LLC — Discovery Scheduling and Document Production Coordination C&H Matter No. 1016-00005

Dear Ms. Montague:

This firm represents Ridgeline Midstream Services LLC ("Ridgeline" or the "Company"), the applicant in the above-referenced proceeding before the Federal Energy Regulatory Commission ("FERC" or the "Commission"). We write to coordinate document production, data request procedures, and deposition scheduling between Ridgeline and your client, the Mountainside Gas Producers Coalition ("MGPC"), in light of the prehearing conference held before Administrative Law Judge Clara Whitfield on November 14, 2022, and the Track II procedural schedule established pursuant to the Commission's order issued September 22, 2022, in the captioned dockets.

As you know, the Commission's September 22 order granted MGPC's motion to intervene, filed July 28, 2022, along with all other timely and late-filed interventions in this proceeding. Consistent with the procedural schedule established by ALJ Whitfield, Ridgeline is preparing the direct testimony of seven witnesses for filing on December 5, 2022. We anticipate that the efficient coordination of discovery between the parties will be essential to meeting the remaining procedural milestones in the litigation track.

Ridgeline acknowledges and appreciates MGPC's general support for the proposed Ridgeline interconnection with Appalachian Trunk Pipeline Company, LLC ("ATPC") at the Wetzel County Interconnect, which will provide critical incremental transportation capacity serving natural gas producers in the Appalachian Basin. Ridgeline recognizes, however, that MGPC has expressed opposition to the proposed initial recourse rate of $0.2265 per dekatherm ("Dth") as set forth in Ridgeline's application and accompanying tariff filing. In its intervention filing, MGPC advocated that the Commission set a recourse rate no higher than $0.1740/Dth, a position that Ridgeline understands MGPC intends to support through the answering testimony of its rate expert. We believe that a well-structured discovery process will allow both parties to develop a complete record on the rate issues in dispute, while promoting efficiency and minimizing unnecessary burden.

Set forth below is Ridgeline's proposal for coordinating the discovery process between the parties. We have organized this letter into sections addressing: (1) document production scheduling; (2) data request procedures; (3) deposition scheduling; (4) protective order and confidentiality matters; (5) coordination with other parties; (6) specific areas of Ridgeline's discovery interest; (7) a consolidated proposed timeline; and (8) a request for your response.

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 accompanying document production, while also providing MGPC with the materials necessary to prepare its answering testimony, which is currently scheduled for filing on January 9, 2023.

Ridgeline's initial document production will be comprehensive and will include, at a minimum, the following categories of documents and supporting materials:

(a) Cost-of-service workpapers. Ridgeline will produce the workpapers and supporting schedules underlying its cost-of-service filing, including all calculations supporting the proposed initial recourse rate of $0.2265/Dth. These workpapers will reflect Ridgeline's filed cost of service in its entirety, including operation and maintenance expenses, administrative and general expenses, taxes, and all other components of the revenue requirement.

(b) Rate base supporting schedules. Ridgeline will produce the schedules and documentation supporting its total filed rate base of $612.40 million, including the original cost of plant-in-service, accumulated depreciation, working capital, and all other rate base components as reflected in the Company's application and supporting exhibits.

(c) Capital structure documentation. Ridgeline will produce documents supporting its proposed capital structure, which reflects a capitalization of 55% equity and 45% debt. This production will include documentation of the Company's actual capitalization, any hypothetical capital structure analysis, and supporting financial data.

(d) Depreciation schedules. Ridgeline will produce its depreciation schedules and supporting analysis, reflecting the proposed 2.5% annual straight-line depreciation rate applied to the pipeline construction cost of $587.2 million, as well as depreciation calculations for all other depreciable plant categories included in rate base.

(e) Return on equity supporting analyses. Ridgeline will produce all documents supporting the proposed 14.00% return on equity ("ROE"), including the discounted cash flow ("DCF") proxy group analysis prepared by Dr. Raymond Braswell, the selection criteria for proxy group companies, and all financial data and market information relied upon in the DCF analysis.

We note that certain categories of financial information included in the initial production may warrant confidential treatment. In particular, documents reflecting the details of the Pinnacle National Bank, N.A.-led Senior Secured Credit Facility — consisting of a $400 million term loan and a $75 million revolving credit facility — and the $150 million 7.875% Second Lien Senior Secured Notes contain commercially sensitive financial information that Ridgeline intends to designate as confidential. These designations will be made pursuant to any agreed-upon protective order or, alternatively, the protective order currently under negotiation with ATPC's counsel, Kellner, Royce & Dillard LLP ("KRD"), attention William Pratt, Esq. As discussed further in Section 4 below, we have separately corresponded with Mr. Pratt regarding proposed protective order provisions, most recently by letter dated September 28, 2022, and we believe those negotiations are progressing toward a resolution that can be extended to encompass all parties.

1.2 MGPC's Initial Document Production

Ridgeline respectfully requests that MGPC serve its initial document production on Ridgeline no later than January 23, 2023, which is approximately two weeks after the currently scheduled filing date for MGPC's answering testimony on January 9, 2023. This proposed timeline parallels the schedule Ridgeline has proposed for its own initial production and will afford Ridgeline adequate time to review the answering testimony before evaluating the supporting documentation.

Ridgeline is particularly interested in the supporting analyses and workpapers of Dr. Eleanor Vasquez, whom Ridgeline understands will serve as MGPC's rate expert. Ridgeline anticipates that Dr. Vasquez's testimony will address the proposed rate ceiling of $0.1740/Dth and will likely encompass topics including cost-of-service methodology, the appropriate ROE for Ridgeline, load factor assumptions, and billing determinant calculations. Accordingly, Ridgeline requests that MGPC's initial production include, without limitation:

(a) All workpapers, calculations, models, and supporting data underlying Dr. Vasquez's testimony, including any alternative cost-of-service analysis, rate design analysis, or revenue requirement calculation;

(b) All documents supporting MGPC's proposed ROE, to the extent MGPC advances a specific ROE recommendation through Dr. Vasquez's testimony or otherwise, including any independent DCF or comparable earnings analysis and all proxy group selection materials;

(c) Any independent cost-of-service or rate design analysis prepared by or on behalf of MGPC or any of its fourteen member companies in connection with this proceeding; and

(d) Communications between MGPC and its consultants, experts, or member companies to the extent such communications are relevant to the development of MGPC's rate position and are not protected by privilege.

1.3 Format and Manner of Production

To promote efficiency and reduce the burden on both parties, Ridgeline proposes that all document productions be made in electronic format. Specifically:

(a) Native files. Spreadsheets, financial models, and other electronically generated files should be produced in their native format (e.g., Microsoft Excel, including all formulas, linked worksheets, and embedded macros) to facilitate meaningful review and analysis.

(b) Image format. All other documents should be produced as single-page TIFF images with extracted text files, or alternatively as searchable PDF files, accompanied by appropriate metadata load files.

(c) Bates numbering. Ridgeline suggests the following Bates-numbering convention to ensure clarity and consistency throughout the proceeding: Ridgeline shall use the prefix "RMS-" followed by sequential numbering (e.g., RMS-000001), and MGPC shall use the prefix "MGPC-" followed by sequential numbering (e.g., MGPC-000001).

(d) Transmission. Productions shall be served via secure electronic transmission (e.g., secure FTP site or encrypted file transfer) to designated counsel of record. If the volume of production exceeds practical limits for electronic transmission, the producing party may deliver the production on encrypted external media. In either case, a cover letter or transmittal email identifying the production by Bates range and general subject matter shall accompany each production.

1.4 Ongoing and Supplemental Productions

Ridgeline proposes that each party bear an ongoing obligation to supplement its document production as additional responsive documents are identified after the initial production. Specifically, Ridgeline proposes the following protocol for supplemental productions:

(a) Each party shall serve any supplemental production of additional responsive documents within fifteen (15) business days of the identification of such documents.

(b) Each party shall provide notice to opposing counsel promptly upon identifying the existence of potentially responsive documents not included in its initial production, and shall endeavor to complete production as expeditiously as practicable.

(c) Both parties acknowledge their respective document preservation and litigation hold obligations in connection with this proceeding. Ridgeline has implemented a litigation hold covering all relevant custodians and document repositories, and we request confirmation that MGPC has likewise implemented appropriate preservation measures.

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 requests shall be due within fifteen (15) business days of service, or approximately February 7, 2023 (accounting for business days).

Ridgeline anticipates propounding data requests to MGPC focused on the following subject matter areas, among others:

(a) Dr. Vasquez's rate analysis methodology and proxy group composition. Ridgeline will seek to understand the inputs, assumptions, and methodological choices underlying Dr. Vasquez's rate analysis, including the composition and selection criteria of any DCF proxy group, the financial data relied upon, and the time periods over which dividend yields and growth rates were calculated.

(b) Billing determinants and load factor. Ridgeline will seek information regarding MGPC's position on appropriate billing determinants and load factor for rate design purposes. In this connection, Ridgeline notes that MGPC's fourteen member companies operate natural gas production facilities in the Marcellus and Utica shale formations across West Virginia, Ohio, and Pennsylvania. To the extent MGPC contends that a load factor other than the 100% load factor used in Ridgeline's filing is appropriate, Ridgeline will seek production of throughput data, production volume data, and transportation utilization data from MGPC member companies that may be relevant to the load factor dispute.

(c) Interconnection with ATPC. Ridgeline will seek information regarding MGPC's position, if any, on the proposed interconnection with ATPC at the Wetzel County Interconnect, including any views on the allocation of interconnection costs between Ridgeline and ATPC and the design and configuration of interconnection facilities.

2.2 Second Round of Data Requests

Ridgeline proposes that a second round of data requests be permitted on a limited basis, confined to follow-up questions arising from the responses to the first round. The proposed deadlines for the second round are as follows:

(a) Service of second-round data requests: Within ten (10) business days after receipt of first-round data request responses (approximately February 17, 2023).

(b) Responses to second-round data requests: Within ten (10) business days after service of second-round data requests (approximately February 27, 2023, accounting for business days and calendar).

Both parties should endeavor to respond to data requests fully and in a timely manner. To the extent either party objects to a particular data request, the objecting party should state its objection with specificity and, to the extent possible, provide a response subject to the stated objection. The parties should attempt to resolve any discovery disputes informally before seeking intervention by ALJ Whitfield.

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, and the public interest benefits of the proposed service. Mr. Winfield is available for deposition on matters within the scope of his direct testimony.

(b) Angela Moretti, Vice President, Finance and Treasurer, Ridgeline Midstream Services LLC. Ms. Moretti's testimony will address Ridgeline's cost of service, rate base (total filed rate base of $612.40 million), capital structure (55% equity / 45% debt), and financing arrangements. Ms. Moretti is available for deposition on matters within the scope of her direct testimony, subject to appropriate confidentiality protections for commercially sensitive financial information.

(c) Thomas Greaves, Vice President, Engineering and Operations, Ridgeline Midstream Services LLC. Mr. Greaves's testimony will address the engineering design, construction, and operational characteristics of the Ridgeline pipeline system, including the 187-mile, 24-inch diameter pipeline, the three compressor stations providing 45,000 horsepower of aggregate compression, the system's 1.2 billion cubic feet per day ("Bcf/d") design capacity, and current throughput of approximately 680 million cubic feet per day ("MMcf/d"). Mr. Greaves is available for deposition on matters within the scope of his direct testimony.

(d) Dr. Natasha Orlov, Director of Rates and Regulatory, Ridgeline Midstream Services LLC. Dr. Orlov's testimony will address rate design, tariff provisions, the use of a 100% load factor billing determinant, and the proposed reservation/usage rate split of $0.2223 (reservation) / $0.0042 (usage) per Dth. Dr. Orlov is available for deposition on matters within the scope of her direct testimony.

(e) Dr. Raymond Braswell (outside expert witness). Dr. Braswell's testimony will address ROE and capital structure, including the proposed 14.00% ROE and the supporting DCF proxy group analysis. Dr. Braswell is available for deposition on matters within the scope of his direct testimony.

As noted above, Ridgeline filed the testimony of seven witnesses in total. The remaining two witnesses, whose testimony relates to operational and environmental matters, are available for deposition upon request by MGPC. Ridgeline is happy to make these witnesses available at dates and times agreeable to both parties.

Ridgeline proposes that depositions of its witnesses be conducted during the period of January 30 through February 17, 2023. Depositions may be conducted at either (i) Ridgeline's principal office, located at 700 Kanawha Boulevard East, Suite 1400, Charleston, West Virginia 25301, or (ii) Calderwood & Harkness's office in Washington, DC, at MGPC's preference. We are flexible on location and will endeavor to accommodate MGPC's scheduling needs.

Each deposition shall be limited to one day, not to exceed seven (7) hours on the record, unless the parties agree to an extension. We trust this limitation is consistent with standard practice in Commission proceedings and will promote efficiency in the discovery process.

3.2 MGPC Witnesses

Ridgeline requests depositions of the following MGPC witnesses following the filing of MGPC's answering testimony, currently scheduled for January 9, 2023:

(a) Dr. Eleanor Vasquez, rate expert for MGPC. Ridgeline seeks to depose Dr. Vasquez on her proposed rate, her critique of Ridgeline's cost-of-service filing, her ROE analysis, and all other matters within the scope of her answering testimony.

(b) Calvin Dreyer, Executive Director, Mountainside Gas Producers Coalition. Ridgeline seeks to depose Mr. Dreyer on the coalition's positions in this proceeding, the interests of MGPC's shippers and member producers, and the operational perspectives of the fourteen member production companies as they relate to the issues in dispute.

Ridgeline proposes that depositions of MGPC witnesses be conducted during the period of February 20 through March 1, 2023. Depositions may be conducted at either (i) Whitmore & Sable's offices in Washington, DC, or (ii) MGPC's offices at 1100 Main Street, Suite 210, Morgantown, West Virginia 26505, at MGPC's preference. Ridgeline will accommodate either location and is prepared to travel as necessary.

3.3 Third-Party Depositions

Ridgeline wishes to advise MGPC that it may seek to depose one or more witnesses affiliated with other parties to this proceeding. In particular, Ridgeline is considering depositions of the following individuals:

(a) Sandra K. Fenton, Vice President, Regulatory Affairs, Appalachian Trunk Pipeline Company, LLC. Ms. Fenton is a likely witness for ATPC and may have testimony relevant to the proposed interconnection at the Wetzel County Interconnect, including interconnection cost allocation and design matters.

(b) Dennis Ott, General Manager, Clearwater Municipal Gas Authority ("CMGA"). Mr. Ott may have testimony relevant to CMGA's interests as an intervenor and municipal gas distribution customer.

Ridgeline intends to coordinate the scheduling of any third-party depositions separately with the respective counsel of record: Mr. William Pratt of Kellner, Royce & Dillard LLP for ATPC, and Mr. Stephen Greer of Fordham Municipal Law Group PC for CMGA. We will keep your office informed of any developments in that regard.

We also invite MGPC to advise us whether MGPC intends to seek depositions of any third-party witnesses in this proceeding. To the extent MGPC contemplates such depositions, Ridgeline proposes that the parties coordinate scheduling to avoid duplicative discovery of the same witnesses, thereby minimizing the burden on third parties and promoting overall efficiency.

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 protective order applicable to all parties to this proceeding. A unified protective order will streamline confidentiality protections, reduce the administrative burden associated with multiple overlapping confidentiality agreements, and ensure consistent treatment of sensitive information across all phases of discovery. We believe this approach is in the interest of all parties and is consistent with Commission practice.

Upon execution of a protective order, Ridgeline intends to designate certain categories of financial documents as "Confidential — Subject to Protective Order," including but not limited to:

(a) Details of the Pinnacle National Bank, N.A.-led Senior Secured Credit Facility, including the $400 million term loan agreement and $75 million revolving credit facility agreement, and all related term sheets, commitment letters, and financial covenants;

(b) Documentation related to the $150 million 7.875% Second Lien Senior Secured Notes, including the indenture, offering materials, and related financial information;

(c) Internal financial projections, budgets, and forecasts prepared by or for Ridgeline in connection with the pipeline project; and

(d) Certain rate-of-return supporting data, including proprietary financial models and sensitivity analyses.

We invite MGPC to identify any categories of documents that it would similarly wish to designate as confidential under the protective order. Early identification of confidentiality concerns will facilitate the drafting of protective order provisions that adequately address all parties' needs.

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 & Dillard LLP, One PPG Place, Suite 2800, Pittsburgh, Pennsylvania 15222.

(b) Clearwater Municipal Gas Authority ("CMGA"), which filed its motion to intervene on August 1, 2022. CMGA is represented by Stephen Greer, Esq., Fordham Municipal Law Group PC, 312 Adams Avenue, Suite 100, Scranton, Pennsylvania 18503.

Ridgeline proposes that Calderwood & Harkness and Whitmore & Sable coordinate discovery scheduling with counsel for ATPC and CMGA to avoid scheduling conflicts and promote efficiency. Where practicable, depositions and document production deadlines should be aligned across all parties to minimize disruption to the witnesses and the proceeding as a whole.

Ridgeline also wishes to note the parallel settlement track in this proceeding. Settlement Judge Howard Margolis was appointed on September 22, 2022, pursuant to the Commission's order establishing the procedural schedule. The first settlement conference is currently scheduled for November 30, 2022. Ridgeline believes that the discovery schedule proposed herein should account for the parallel settlement process and should be designed to proceed without impeding either the litigation track or the settlement discussions. At the same time, discovery scheduling should not be held hostage to the settlement process, and the parties should continue to pursue discovery diligently regardless of the status of settlement negotiations.

We request that MGPC advise Ridgeline whether MGPC intends to participate in the November 30, 2022 settlement conference before Settlement Judge Margolis, and whether MGPC anticipates that settlement discussions may affect the proposed discovery timeline in any material respect. Ridgeline intends to participate in the settlement conference and remains open to a negotiated resolution of the rate and other issues in dispute, but believes that vigorous prosecution of the litigation track is essential pending the outcome of any settlement discussions.

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 discovery disputes:

(a) Basis for the proposed $0.1740/Dth rate ceiling. Ridgeline seeks to understand the factual and analytical basis for MGPC's position that the recourse rate should not exceed $0.1740/Dth, including all assumptions, inputs, and methodological choices underlying this figure.

(b) Production volumes and transportation requirements. Ridgeline is interested in the current and projected natural gas production volumes and transportation requirements of MGPC's member companies in the Appalachian Basin, to the extent such information is relevant to the billing determinant and load factor analysis. As noted above, the fourteen MGPC member companies operate in the Marcellus and Utica shale formations across West Virginia, Ohio, and Pennsylvania, and their actual and projected throughput data may be material to the load factor dispute.

(c) Independent cost-of-service or rate design analyses. Ridgeline seeks production of any independent cost-of-service or rate design analysis prepared by or on behalf of MGPC, Dr. Vasquez, or any MGPC member company in connection with this proceeding or in connection with the evaluation of Ridgeline's proposed rates.

(d) Load factor position. Ridgeline is interested in MGPC's position regarding the appropriate load factor for billing determinant purposes. Ridgeline's filing employs a 100% load factor, and Ridgeline seeks to understand whether MGPC contends that a lower load factor is appropriate and, if so, the basis for that contention.

(e) Interconnection cost allocation. Ridgeline seeks information regarding MGPC's position, if any, on the proposed allocation of interconnection costs for the $22.3 million Wetzel County Interconnect facilities between Ridgeline ($7.6 million, or approximately 34.1%) and ATPC ($14.7 million, or approximately 65.9%). To the extent MGPC has views on the reasonableness of this allocation, Ridgeline wishes to understand the factual and analytical basis for those views.

Ridgeline reserves the right to pursue additional areas of discovery as warranted by the development of the record, including matters arising from MGPC's answering testimony once filed.

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 Commission's procedural requirements. Ridgeline notes that the proposed timeline has been designed to dovetail with the existing procedural schedule and to preserve all parties' ability to participate meaningfully in both the litigation and settlement tracks.

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, or timing of discovery;

(d) MGPC's position on the proposed omnibus protective order, including identification of any categories of documents MGPC anticipates designating as confidential;

(e) MGPC's intentions regarding participation in the November 30, 2022 settlement conference before Settlement Judge Margolis; and

(f) Confirmation of MGPC's availability for a scheduling call, should MGPC believe such a call would be productive.

We are happy to schedule a telephone conference at Ms. Montague's convenience to discuss the proposed schedule and to resolve any open issues. Please direct all scheduling inquiries to the undersigned at the contact information provided below.

In closing, Ridgeline is committed to conducting the discovery process in this proceeding efficiently, cooperatively, and in good faith. We believe that a coordinated and transparent approach to discovery will benefit all parties and will facilitate both the litigation before ALJ Whitfield and any parallel settlement discussions before Settlement Judge Margolis. We look forward to working with you and your colleagues at Whitmore & Sable to establish a discovery framework that serves the interests of all parties and advances the prompt resolution of the issues in this proceeding.

Thank you for your attention to this matter. Please do not hesitate to contact me with any questions or to discuss any aspect of this proposal.

Very truly yours,

CALDERWOOD & HARKNESS LLP

By: ________

David Stanton Partner

1601 K Street NW, Suite 900 Washington, DC 20006 Direct Telephone: (202) 555-7418

Email: dstanton@calderwoodharkness.com

cc: (via email)

Patricia Dunmore, Esq. — Calderwood & Harkness LLP George Trujillo, Esq. — Calderwood & Harkness LLP Brett Callahan, Esq. — Calderwood & Harkness LLP James K. Winfield — CEO & President, Ridgeline Midstream Services LLC Dr. Natasha Orlov — Director of Rates & Regulatory, Ridgeline Midstream Services LLC Calvin Dreyer — Executive Director, Mountainside Gas Producers Coalition (courtesy copy to client representative via counsel)

Date	Event
December 5, 2022	Ridgeline files direct testimony (7 witnesses)
December 19, 2022	Ridgeline serves initial document production on MGPC
January 9, 2023	MGPC (and ATPC, CMGA) files answering testimony
January 23, 2023	MGPC serves initial document production on Ridgeline
January 23, 2023	First-round data requests served
January 30 – February 17, 2023	Depositions of Ridgeline witnesses
February 7, 2023	First-round data request responses due
February 17, 2023	Second-round data requests served
February 20 – March 1, 2023	Depositions of MGPC witnesses
February 27, 2023	Second-round data request responses due

CALDERWOOD & HARKNESS LLP Attorneys at Law
CALDERWOOD & HARKNESS LLP 1601 K Street NW, Suite 900 Washington, DC 20006 Telephone: (202) 555-7400 Facsimile: (202) 555-7401 www.calderwoodharkness.com
November 22, 2022
VIA EMAIL AND FIRST CLASS MAIL
Rebekah Montague, Esq. Partner Whitmore & Sable LLP 1200 New Hampshire Avenue NW, Suite 600 Washington, DC 20036
Re: FERC Docket Nos. RP22-847-000 and RP22-847-001 — Ridgeline Midstream Services LLC — Discovery Scheduling and Document Production Coordination C&H Matter No. 1016-00005
Dear Ms. Montague:
This firm represents Ridgeline Midstream Services LLC ("Ridgeline" or the "Company"), the applicant in the above-referenced proceeding before the Federal Energy Regulatory Commission ("FERC" or the "Commission"). We write to coordinate document production, data request procedures, and deposition scheduling between Ridgeline and your client, the Mountainside Gas Producers Coalition ("MGPC"), in light of the prehearing conference held before Administrative Law Judge Clara Whitfield on November 14, 2022, and the Track II procedural schedule established pursuant to the Commission's order issued September 22, 2022, in the captioned dockets.
As you know, the Commission's September 22 order granted MGPC's motion to intervene, filed July 28, 2022, along with all other timely and late-filed interventions in this proceeding. Consistent with the procedural schedule established by ALJ Whitfield, Ridgeline is preparing the direct testimony of seven witnesses for filing on December 5, 2022. We anticipate that the efficient coordination of discovery between the parties will be essential to meeting the remaining procedural milestones in the litigation track.
Ridgeline acknowledges and appreciates MGPC's general support for the proposed Ridgeline interconnection with Appalachian Trunk Pipeline Company, LLC ("ATPC") at the Wetzel County Interconnect, which will provide critical incremental transportation capacity serving natural gas producers in the Appalachian Basin. Ridgeline recognizes, however, that MGPC has expressed opposition to the proposed initial recourse rate of $0.2265 per dekatherm ("Dth") as set forth in Ridgeline's application and accompanying tariff filing. In its intervention filing, MGPC advocated that the Commission set a recourse rate no higher than $0.1740/Dth, a position that Ridgeline understands MGPC intends to support through the answering testimony of its rate expert. We believe that a well-structured discovery process will allow both parties to develop a complete record on the rate issues in dispute, while promoting efficiency and minimizing unnecessary burden.
Set forth below is Ridgeline's proposal for coordinating the discovery process between the parties. We have organized this letter into sections addressing: (1) document production scheduling; (2) data request procedures; (3) deposition scheduling; (4) protective order and confidentiality matters; (5) coordination with other parties; (6) specific areas of Ridgeline's discovery interest; (7) a consolidated proposed timeline; and (8) a request for your response.
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 accompanying document production, while also providing MGPC with the materials necessary to prepare its answering testimony, which is currently scheduled for filing on January 9, 2023.
Ridgeline's initial document production will be comprehensive and will include, at a minimum, the following categories of documents and supporting materials:
(a) Cost-of-service workpapers. Ridgeline will produce the workpapers and supporting schedules underlying its cost-of-service filing, including all calculations supporting the proposed initial recourse rate of $0.2265/Dth. These workpapers will reflect Ridgeline's filed cost of service in its entirety, including operation and maintenance expenses, administrative and general expenses, taxes, and all other components of the revenue requirement.
(b) Rate base supporting schedules. Ridgeline will produce the schedules and documentation supporting its total filed rate base of $612.40 million, including the original cost of plant-in-service, accumulated depreciation, working capital, and all other rate base components as reflected in the Company's application and supporting exhibits.
(c) Capital structure documentation. Ridgeline will produce documents supporting its proposed capital structure, which reflects a capitalization of 55% equity and 45% debt. This production will include documentation of the Company's actual capitalization, any hypothetical capital structure analysis, and supporting financial data.
(d) Depreciation schedules. Ridgeline will produce its depreciation schedules and supporting analysis, reflecting the proposed 2.5% annual straight-line depreciation rate applied to the pipeline construction cost of $587.2 million, as well as depreciation calculations for all other depreciable plant categories included in rate base.
(e) Return on equity supporting analyses. Ridgeline will produce all documents supporting the proposed 14.00% return on equity ("ROE"), including the discounted cash flow ("DCF") proxy group analysis prepared by Dr. Raymond Braswell, the selection criteria for proxy group companies, and all financial data and market information relied upon in the DCF analysis.
We note that certain categories of financial information included in the initial production may warrant confidential treatment. In particular, documents reflecting the details of the Pinnacle National Bank, N.A.-led Senior Secured Credit Facility — consisting of a $400 million term loan and a $75 million revolving credit facility — and the $150 million 7.875% Second Lien Senior Secured Notes contain commercially sensitive financial information that Ridgeline intends to designate as confidential. These designations will be made pursuant to any agreed-upon protective order or, alternatively, the protective order currently under negotiation with ATPC's counsel, Kellner, Royce & Dillard LLP ("KRD"), attention William Pratt, Esq. As discussed further in Section 4 below, we have separately corresponded with Mr. Pratt regarding proposed protective order provisions, most recently by letter dated September 28, 2022, and we believe those negotiations are progressing toward a resolution that can be extended to encompass all parties.
1.2 MGPC's Initial Document Production
Ridgeline respectfully requests that MGPC serve its initial document production on Ridgeline no later than January 23, 2023, which is approximately two weeks after the currently scheduled filing date for MGPC's answering testimony on January 9, 2023. This proposed timeline parallels the schedule Ridgeline has proposed for its own initial production and will afford Ridgeline adequate time to review the answering testimony before evaluating the supporting documentation.
Ridgeline is particularly interested in the supporting analyses and workpapers of Dr. Eleanor Vasquez, whom Ridgeline understands will serve as MGPC's rate expert. Ridgeline anticipates that Dr. Vasquez's testimony will address the proposed rate ceiling of $0.1740/Dth and will likely encompass topics including cost-of-service methodology, the appropriate ROE for Ridgeline, load factor assumptions, and billing determinant calculations. Accordingly, Ridgeline requests that MGPC's initial production include, without limitation:
(a) All workpapers, calculations, models, and supporting data underlying Dr. Vasquez's testimony, including any alternative cost-of-service analysis, rate design analysis, or revenue requirement calculation;
(b) All documents supporting MGPC's proposed ROE, to the extent MGPC advances a specific ROE recommendation through Dr. Vasquez's testimony or otherwise, including any independent DCF or comparable earnings analysis and all proxy group selection materials;
(c) Any independent cost-of-service or rate design analysis prepared by or on behalf of MGPC or any of its fourteen member companies in connection with this proceeding; and
(d) Communications between MGPC and its consultants, experts, or member companies to the extent such communications are relevant to the development of MGPC's rate position and are not protected by privilege.
1.3 Format and Manner of Production
To promote efficiency and reduce the burden on both parties, Ridgeline proposes that all document productions be made in electronic format. Specifically:
(a) Native files. Spreadsheets, financial models, and other electronically generated files should be produced in their native format (e.g., Microsoft Excel, including all formulas, linked worksheets, and embedded macros) to facilitate meaningful review and analysis.
(b) Image format. All other documents should be produced as single-page TIFF images with extracted text files, or alternatively as searchable PDF files, accompanied by appropriate metadata load files.
(c) Bates numbering. Ridgeline suggests the following Bates-numbering convention to ensure clarity and consistency throughout the proceeding: Ridgeline shall use the prefix "RMS-" followed by sequential numbering (e.g., RMS-000001), and MGPC shall use the prefix "MGPC-" followed by sequential numbering (e.g., MGPC-000001).
(d) Transmission. Productions shall be served via secure electronic transmission (e.g., secure FTP site or encrypted file transfer) to designated counsel of record. If the volume of production exceeds practical limits for electronic transmission, the producing party may deliver the production on encrypted external media. In either case, a cover letter or transmittal email identifying the production by Bates range and general subject matter shall accompany each production.
1.4 Ongoing and Supplemental Productions
Ridgeline proposes that each party bear an ongoing obligation to supplement its document production as additional responsive documents are identified after the initial production. Specifically, Ridgeline proposes the following protocol for supplemental productions:
(a) Each party shall serve any supplemental production of additional responsive documents within fifteen (15) business days of the identification of such documents.
(b) Each party shall provide notice to opposing counsel promptly upon identifying the existence of potentially responsive documents not included in its initial production, and shall endeavor to complete production as expeditiously as practicable.
(c) Both parties acknowledge their respective document preservation and litigation hold obligations in connection with this proceeding. Ridgeline has implemented a litigation hold covering all relevant custodians and document repositories, and we request confirmation that MGPC has likewise implemented appropriate preservation measures.
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 requests shall be due within fifteen (15) business days of service, or approximately February 7, 2023 (accounting for business days).
Ridgeline anticipates propounding data requests to MGPC focused on the following subject matter areas, among others:
(a) Dr. Vasquez's rate analysis methodology and proxy group composition. Ridgeline will seek to understand the inputs, assumptions, and methodological choices underlying Dr. Vasquez's rate analysis, including the composition and selection criteria of any DCF proxy group, the financial data relied upon, and the time periods over which dividend yields and growth rates were calculated.
(b) Billing determinants and load factor. Ridgeline will seek information regarding MGPC's position on appropriate billing determinants and load factor for rate design purposes. In this connection, Ridgeline notes that MGPC's fourteen member companies operate natural gas production facilities in the Marcellus and Utica shale formations across West Virginia, Ohio, and Pennsylvania. To the extent MGPC contends that a load factor other than the 100% load factor used in Ridgeline's filing is appropriate, Ridgeline will seek production of throughput data, production volume data, and transportation utilization data from MGPC member companies that may be relevant to the load factor dispute.
(c) Interconnection with ATPC. Ridgeline will seek information regarding MGPC's position, if any, on the proposed interconnection with ATPC at the Wetzel County Interconnect, including any views on the allocation of interconnection costs between Ridgeline and ATPC and the design and configuration of interconnection facilities.
2.2 Second Round of Data Requests
Ridgeline proposes that a second round of data requests be permitted on a limited basis, confined to follow-up questions arising from the responses to the first round. The proposed deadlines for the second round are as follows:
(a) Service of second-round data requests: Within ten (10) business days after receipt of first-round data request responses (approximately February 17, 2023).
(b) Responses to second-round data requests: Within ten (10) business days after service of second-round data requests (approximately February 27, 2023, accounting for business days and calendar).
Both parties should endeavor to respond to data requests fully and in a timely manner. To the extent either party objects to a particular data request, the objecting party should state its objection with specificity and, to the extent possible, provide a response subject to the stated objection. The parties should attempt to resolve any discovery disputes informally before seeking intervention by ALJ Whitfield.
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, and the public interest benefits of the proposed service. Mr. Winfield is available for deposition on matters within the scope of his direct testimony.
(b) Angela Moretti, Vice President, Finance and Treasurer, Ridgeline Midstream Services LLC. Ms. Moretti's testimony will address Ridgeline's cost of service, rate base (total filed rate base of $612.40 million), capital structure (55% equity / 45% debt), and financing arrangements. Ms. Moretti is available for deposition on matters within the scope of her direct testimony, subject to appropriate confidentiality protections for commercially sensitive financial information.
(c) Thomas Greaves, Vice President, Engineering and Operations, Ridgeline Midstream Services LLC. Mr. Greaves's testimony will address the engineering design, construction, and operational characteristics of the Ridgeline pipeline system, including the 187-mile, 24-inch diameter pipeline, the three compressor stations providing 45,000 horsepower of aggregate compression, the system's 1.2 billion cubic feet per day ("Bcf/d") design capacity, and current throughput of approximately 680 million cubic feet per day ("MMcf/d"). Mr. Greaves is available for deposition on matters within the scope of his direct testimony.
(d) Dr. Natasha Orlov, Director of Rates and Regulatory, Ridgeline Midstream Services LLC. Dr. Orlov's testimony will address rate design, tariff provisions, the use of a 100% load factor billing determinant, and the proposed reservation/usage rate split of $0.2223 (reservation) / $0.0042 (usage) per Dth. Dr. Orlov is available for deposition on matters within the scope of her direct testimony.
(e) Dr. Raymond Braswell (outside expert witness). Dr. Braswell's testimony will address ROE and capital structure, including the proposed 14.00% ROE and the supporting DCF proxy group analysis. Dr. Braswell is available for deposition on matters within the scope of his direct testimony.
As noted above, Ridgeline filed the testimony of seven witnesses in total. The remaining two witnesses, whose testimony relates to operational and environmental matters, are available for deposition upon request by MGPC. Ridgeline is happy to make these witnesses available at dates and times agreeable to both parties.
Ridgeline proposes that depositions of its witnesses be conducted during the period of January 30 through February 17, 2023. Depositions may be conducted at either (i) Ridgeline's principal office, located at 700 Kanawha Boulevard East, Suite 1400, Charleston, West Virginia 25301, or (ii) Calderwood & Harkness's office in Washington, DC, at MGPC's preference. We are flexible on location and will endeavor to accommodate MGPC's scheduling needs.
Each deposition shall be limited to one day, not to exceed seven (7) hours on the record, unless the parties agree to an extension. We trust this limitation is consistent with standard practice in Commission proceedings and will promote efficiency in the discovery process.
3.2 MGPC Witnesses
Ridgeline requests depositions of the following MGPC witnesses following the filing of MGPC's answering testimony, currently scheduled for January 9, 2023:
(a) Dr. Eleanor Vasquez, rate expert for MGPC. Ridgeline seeks to depose Dr. Vasquez on her proposed rate, her critique of Ridgeline's cost-of-service filing, her ROE analysis, and all other matters within the scope of her answering testimony.
(b) Calvin Dreyer, Executive Director, Mountainside Gas Producers Coalition. Ridgeline seeks to depose Mr. Dreyer on the coalition's positions in this proceeding, the interests of MGPC's shippers and member producers, and the operational perspectives of the fourteen member production companies as they relate to the issues in dispute.
Ridgeline proposes that depositions of MGPC witnesses be conducted during the period of February 20 through March 1, 2023. Depositions may be conducted at either (i) Whitmore & Sable's offices in Washington, DC, or (ii) MGPC's offices at 1100 Main Street, Suite 210, Morgantown, West Virginia 26505, at MGPC's preference. Ridgeline will accommodate either location and is prepared to travel as necessary.
3.3 Third-Party Depositions
Ridgeline wishes to advise MGPC that it may seek to depose one or more witnesses affiliated with other parties to this proceeding. In particular, Ridgeline is considering depositions of the following individuals:
(a) Sandra K. Fenton, Vice President, Regulatory Affairs, Appalachian Trunk Pipeline Company, LLC. Ms. Fenton is a likely witness for ATPC and may have testimony relevant to the proposed interconnection at the Wetzel County Interconnect, including interconnection cost allocation and design matters.
(b) Dennis Ott, General Manager, Clearwater Municipal Gas Authority ("CMGA"). Mr. Ott may have testimony relevant to CMGA's interests as an intervenor and municipal gas distribution customer.
Ridgeline intends to coordinate the scheduling of any third-party depositions separately with the respective counsel of record: Mr. William Pratt of Kellner, Royce & Dillard LLP for ATPC, and Mr. Stephen Greer of Fordham Municipal Law Group PC for CMGA. We will keep your office informed of any developments in that regard.
We also invite MGPC to advise us whether MGPC intends to seek depositions of any third-party witnesses in this proceeding. To the extent MGPC contemplates such depositions, Ridgeline proposes that the parties coordinate scheduling to avoid duplicative discovery of the same witnesses, thereby minimizing the burden on third parties and promoting overall efficiency.
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 protective order applicable to all parties to this proceeding. A unified protective order will streamline confidentiality protections, reduce the administrative burden associated with multiple overlapping confidentiality agreements, and ensure consistent treatment of sensitive information across all phases of discovery. We believe this approach is in the interest of all parties and is consistent with Commission practice.
Upon execution of a protective order, Ridgeline intends to designate certain categories of financial documents as "Confidential — Subject to Protective Order," including but not limited to:
(a) Details of the Pinnacle National Bank, N.A.-led Senior Secured Credit Facility, including the $400 million term loan agreement and $75 million revolving credit facility agreement, and all related term sheets, commitment letters, and financial covenants;
(b) Documentation related to the $150 million 7.875% Second Lien Senior Secured Notes, including the indenture, offering materials, and related financial information;
(c) Internal financial projections, budgets, and forecasts prepared by or for Ridgeline in connection with the pipeline project; and
(d) Certain rate-of-return supporting data, including proprietary financial models and sensitivity analyses.
We invite MGPC to identify any categories of documents that it would similarly wish to designate as confidential under the protective order. Early identification of confidentiality concerns will facilitate the drafting of protective order provisions that adequately address all parties' needs.
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 & Dillard LLP, One PPG Place, Suite 2800, Pittsburgh, Pennsylvania 15222.
(b) Clearwater Municipal Gas Authority ("CMGA"), which filed its motion to intervene on August 1, 2022. CMGA is represented by Stephen Greer, Esq., Fordham Municipal Law Group PC, 312 Adams Avenue, Suite 100, Scranton, Pennsylvania 18503.
Ridgeline proposes that Calderwood & Harkness and Whitmore & Sable coordinate discovery scheduling with counsel for ATPC and CMGA to avoid scheduling conflicts and promote efficiency. Where practicable, depositions and document production deadlines should be aligned across all parties to minimize disruption to the witnesses and the proceeding as a whole.
Ridgeline also wishes to note the parallel settlement track in this proceeding. Settlement Judge Howard Margolis was appointed on September 22, 2022, pursuant to the Commission's order establishing the procedural schedule. The first settlement conference is currently scheduled for November 30, 2022. Ridgeline believes that the discovery schedule proposed herein should account for the parallel settlement process and should be designed to proceed without impeding either the litigation track or the settlement discussions. At the same time, discovery scheduling should not be held hostage to the settlement process, and the parties should continue to pursue discovery diligently regardless of the status of settlement negotiations.
We request that MGPC advise Ridgeline whether MGPC intends to participate in the November 30, 2022 settlement conference before Settlement Judge Margolis, and whether MGPC anticipates that settlement discussions may affect the proposed discovery timeline in any material respect. Ridgeline intends to participate in the settlement conference and remains open to a negotiated resolution of the rate and other issues in dispute, but believes that vigorous prosecution of the litigation track is essential pending the outcome of any settlement discussions.
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 discovery disputes:
(a) Basis for the proposed $0.1740/Dth rate ceiling. Ridgeline seeks to understand the factual and analytical basis for MGPC's position that the recourse rate should not exceed $0.1740/Dth, including all assumptions, inputs, and methodological choices underlying this figure.
(b) Production volumes and transportation requirements. Ridgeline is interested in the current and projected natural gas production volumes and transportation requirements of MGPC's member companies in the Appalachian Basin, to the extent such information is relevant to the billing determinant and load factor analysis. As noted above, the fourteen MGPC member companies operate in the Marcellus and Utica shale formations across West Virginia, Ohio, and Pennsylvania, and their actual and projected throughput data may be material to the load factor dispute.
(c) Independent cost-of-service or rate design analyses. Ridgeline seeks production of any independent cost-of-service or rate design analysis prepared by or on behalf of MGPC, Dr. Vasquez, or any MGPC member company in connection with this proceeding or in connection with the evaluation of Ridgeline's proposed rates.
(d) Load factor position. Ridgeline is interested in MGPC's position regarding the appropriate load factor for billing determinant purposes. Ridgeline's filing employs a 100% load factor, and Ridgeline seeks to understand whether MGPC contends that a lower load factor is appropriate and, if so, the basis for that contention.
(e) Interconnection cost allocation. Ridgeline seeks information regarding MGPC's position, if any, on the proposed allocation of interconnection costs for the $22.3 million Wetzel County Interconnect facilities between Ridgeline ($7.6 million, or approximately 34.1%) and ATPC ($14.7 million, or approximately 65.9%). To the extent MGPC has views on the reasonableness of this allocation, Ridgeline wishes to understand the factual and analytical basis for those views.
Ridgeline reserves the right to pursue additional areas of discovery as warranted by the development of the record, including matters arising from MGPC's answering testimony once filed.
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 Commission's procedural requirements. Ridgeline notes that the proposed timeline has been designed to dovetail with the existing procedural schedule and to preserve all parties' ability to participate meaningfully in both the litigation and settlement tracks.
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, or timing of discovery;
(c) Confirmation of MGPC's agreement to coordinate discovery scheduling with counsel for ATPC and CMGA;
(d) MGPC's position on the proposed omnibus protective order, including identification of any categories of documents MGPC anticipates designating as confidential;
(e) MGPC's intentions regarding participation in the November 30, 2022 settlement conference before Settlement Judge Margolis; and
(f) Confirmation of MGPC's availability for a scheduling call, should MGPC believe such a call would be productive.
We are happy to schedule a telephone conference at Ms. Montague's convenience to discuss the proposed schedule and to resolve any open issues. Please direct all scheduling inquiries to the undersigned at the contact information provided below.
In closing, Ridgeline is committed to conducting the discovery process in this proceeding efficiently, cooperatively, and in good faith. We believe that a coordinated and transparent approach to discovery will benefit all parties and will facilitate both the litigation before ALJ Whitfield and any parallel settlement discussions before Settlement Judge Margolis. We look forward to working with you and your colleagues at Whitmore & Sable to establish a discovery framework that serves the interests of all parties and advances the prompt resolution of the issues in this proceeding.
Thank you for your attention to this matter. Please do not hesitate to contact me with any questions or to discuss any aspect of this proposal.
Very truly yours,
CALDERWOOD & HARKNESS LLP
By: ________
David Stanton Partner
1601 K Street NW, Suite 900 Washington, DC 20006 Direct Telephone: (202) 555-7418
Email: dstanton@calderwoodharkness.com
cc: (via email)
Patricia Dunmore, Esq. — Calderwood & Harkness LLP George Trujillo, Esq. — Calderwood & Harkness LLP Brett Callahan, Esq. — Calderwood & Harkness LLP James K. Winfield — CEO & President, Ridgeline Midstream Services LLC Dr. Natasha Orlov — Director of Rates & Regulatory, Ridgeline Midstream Services LLC Calvin Dreyer — Executive Director, Mountainside Gas Producers Coalition (courtesy copy to client representative via counsel)
Date | Event
December 5, 2022 | Ridgeline files direct testimony (7 witnesses)
December 19, 2022 | Ridgeline serves initial document production on MGPC
January 9, 2023 | MGPC (and ATPC, CMGA) files answering testimony
January 23, 2023 | MGPC serves initial document production on Ridgeline
January 23, 2023 | First-round data requests served
January 30 – February 17, 2023 | Depositions of Ridgeline witnesses
February 7, 2023 | First-round data request responses due
February 17, 2023 | Second-round data requests served
February 20 – March 1, 2023 | Depositions of MGPC witnesses
February 27, 2023 | Second-round data request responses due

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