8. Discovery

The adopted schedule is aggressive. This Ruling adopts a balanced discovery process that is intended to reduce the potential for disputes or delays regarding discovery.

The parties should identify discovery needs and submit data requests as soon as possible. There is no predetermined limit on the number of questions that parties may submit, but parties are advised to be disciplined in making requests, keeping in mind the procedural schedule. Parties should make questions clear, focused, and relevant. Parties with similar interests should seek to coordinate their requests to avoid redundancy. Parties responding to data requests should provide clear and complete answers or promptly seek clarification for any questions that are ambiguous or unclear.

As a general rule, parties should respond to data requests within 14 calendar days. If a longer response time is required, the party preparing the response shall notify the requesting party and indicate when the response will be sent. Such notice should be provided as soon as possible, but no later than 14 days after receipt of the request. If a party's sole response to discovery is an objection (as opposed to an objection coupled with a substantive response), the party shall make objections to discovery requests within five working days.

Parties shall use web-based discovery protocols, to the extent practical, to obtain information from PG&E. These protocols are set forth in Appendix B.

The parties should follow the procedures set forth in Resolution ALJ-164 regarding any discovery disputes, with the following modifications. Parties shall respond to any discovery motion within three working days (instead of 10 calendar days) unless otherwise ruled by the ALJs. Parties are reminded to meet and confer before bringing any discovery dispute to the Commission.⁸

⁸ The web link to ALJ-164 is http://www.cpuc.ca.gov/WORD_PDF/FINAL_RESOLUTION/2538.DOC