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-17- <br />EXHIBIT NO. P -2 <br />PAGE 3 OF 11 <br />3. Formal discovery requests related to the application and the Company's <br />prefiled direct testimony shall be served on the Company by hand delivery, facsimile, or <br />electronic delivery (with the Company's agreement), no later than 14 calendar days prior <br />to the filing of Public Staff and other intervenor testimony. The Company shall have up <br />to ten calendar days to file with the Commission objections to the discovery requests on <br />an item -by -item basis, but in no event shall objections be filed later than ten calendar <br />days prior to the deadline for the filing of Public Staff and other intervenor testimony. <br />4. Formal discovery requests of the Public Staff or other intervenors shall be <br />served by hand delivery, facsimile, or electronic delivery (with the agreement.of the <br />receiving party), no later than five calendar days after the filing of that party's testimony. <br />The party served shall have up to three business days to file with the Commission <br />objections to the discovery requests on an item -by -item basis, but in no event shall <br />objections be filed later than nine calendar days after the filing of that party's testimony. <br />5. Formal discovery requests related to pre -filed rebuttal testimony shall be <br />served by hand delivery or facsimile no later than two business days after the filing of <br />such testimony. The party served shall have up to two calendar days to file with the <br />Commission objections to the discovery requests on an item -by -item basis, but in no <br />event shall objections be filed later than three business days after the filing of such <br />rebuttal testimony. Discovery related to rebuttal testimony shall be limited to new <br />material introduced in such rebuttal testimony and will be carefully scrutinized upon <br />objection that such discovery should have been sought during the initial period of <br />discovery. <br />6. Discovery requests need not be filed with the Commission when served; <br />however, any party filing objections shall attach a copy of the relevant discovery request <br />to the objections. Each discovery request, or part thereof, to which no objection is filed <br />shall be answered by the time objections are due, subject to other agreement of the <br />affected parties or other order of the Commission. Upon the filing of objections, the <br />party seeking discovery shall have two business days to file with the Commission a <br />motion to compel, and the party objecting to discovery shall have one day thereafter to <br />file a response. All objections, motions to compel, and responses shall be served on <br />the other affected party by hand delivery, facsimile, or electronic delivery (with the <br />agreement of the receiving party), at or before the time of filing with the Commission. <br />7. A party shall not be granted an extension of time to pursue discovery due <br />to that party's late intervention or other delay in initiating discovery. <br />