Flint Hills Resources Alaska, LLC's Request for Issuance of a Subpoena Duces Tecum to Phillips 66 To Respond to Data Requests and Produce Documents under OR14-6.
12/17/2013UNITED STATES OF AMERICA BEFORE THE FEDERAL ENERGY REGULATORY COMMISSION ) BP Pipelines (Alaska) Inc. ) ConocoPhillips Transportation Alaska Inc. ) Docket No. OR14-6-000 ExxonMobil Pipeline Company ) FLINT HILLS RESOURCES ALASKA, LLCS REQUEST FOR ISSUANCE OF A SUBPOENA DUCES TECUM TO PHILLIPS 66 TO RESPOND TO DATA REQUESTS AND PRODUCE DOCUMENTS To: The Honorable H. Peter Young Presiding Administrative Law Judge Pursuant to Rule 409, 18 C.F.R. 285.409 (2013), of the Rules of Practice and Procedure of the Federal Energy Regulatory Commission (Commission), Flint Hills Resources Alaska, LLC (FHR) respectfully requests that the Presiding Administrative Law Judge issue the attached subpoena duces tecum compelling Phillips 66, who is not a party to this proceeding, to respond to data requests and produce documents regarding Phillips 66s refineries at which Alaska North Slope (ANS) crude oil has been processed. Responses to these data requests and the production of documents regarding those refineries are necessary for FHR to develop a full and complete record on the issue of the accurate value of ANS Resid.1 Under existing procedural rules, objections would be due five calendar days from the date of service and responses would be due ten calendar days from the date of service. 1 Flint Hills Resources Alaska, LLC v. BP Pipelines (Alaska) Inc., et al., 145 FERC 61,117 (2013) (order setting case for hearing). 1 III. CONCLUSION Phillips 66 has information that is highly relevant to the valuation of ANS Resid, which is the subject of the Commissions investigation in this proceeding. FHR respectfully requests that the Presiding Administrative Law Judge grant this request for the issuance of a subpoena that compels Phillips 66 to respond to data requests and produce documents. Respectfully submitted, /s/ David DAlessandro Travis A. Pearson David DAlessandro FLINT HILLS RESOURCES, LP Dennis Lane 4111 East 37th Street North M. Denyse Zosa Wichita, KS 67220 Stinson Morrison Hecker LLP Telephone: (316) 828-8594 1775 Pennsylvania Avenue, Suite 800 Travis.Pearson@fhr.com Washington, D.C. 20006 (202) 785-9100 ddalessandro@stinson.com dlane@stinson.com dzosa@stinson.com 3 CERTIFICATE OF SERVICE I hereby certify that I have this day served the foregoing document upon each person designated on the official service list compiled by the Secretary in this proceeding. Dated at Washington, D.C., 18th day of December, 2013 /s/ M. Denyse Zosa 5 person having custody or control of the material, (iv) the circumstances under which the material was destroyed, disposed of, lost, or otherwise rendered unavailable for production, (v) whether the material was stored under conditions of controlled access ...