Prepared Direct Testimony and Exhibits of HWRT Oil Company, LLC under OR13-25, et. al.

Exhibit No. HWR-36 Page 25 of 27 Exhibit No. HWR-36 Page 26 of 27 20130624-5121 FERC PDF (Unofficial) 6/24/2013 3:24:22 PM Document Content(s) Exhibit No. HWR-36 Seymour Lateral PDO Reply Comments (Final).PDF........................1-26 Page 27 of 27 Exhibit No. HWR-37 EXHIBIT NO. HWR-37 HIGHLY CONFIDENTIAL 15(13) PROTECTED MATERIALS REMOVED Exhibit No. HWR-38 EXHIBIT NO. HWR-38 HIGHLY CONFIDENTIAL 15(13) PROTECTED MATERIALS REMOVED Exhibit No. HWR-39 EXHIBIT NO. HWR-39 HIGHLY CONFIDENTIAL 15(13) PROTECTED MATERIALS REMOVED Exhibit No. HWR-40 Page 1 of 7 UNITED STATES OF AMERICA BEFORE THE FEDERAL ENERGY REGULATORY COMMISSION CHS Inc., Docket No. OR13-25-002 Federal Express Corporation GROWMARK, Inc. HWRT Oil Company LLC MFA Oil Company Southwest Airlines Co. United Airlines, Inc. UPS Fuel Services, Inc. v. Enterprise TE Products Pipeline Company, LLC Chevron Products Company Docket No. OR13-26-002 v. Enterprise TE Products Pipeline Company, LLC (consolidated) Objections of Enterprise TE Products Pipeline Company LLC To the First Set of Discovery Requests of Complainants Pursuant to the Rules of Practice and Procedure of the Federal Energy Regulatory Commission (FERC), 18 C.F.R. 385.401, et. seq., and the Order Establishing Procedural Schedule issued by the Presiding Administrative Law Judge on April 24, 2014, Enterprise TE Products Pipeline Company LLC (Enterprise TE) submits these objections to the First Set of Discovery Requests of Complainants (CHS Inc., Federal Express Corporation, GROWMARK, Inc., HWRT Oil Company LLC, MFA Oil Company, Southwest Airlines Co., United Airlines, Inc., and UPS Fuel Services, Inc.) in the above-captioned proceeding. Exhibit No. HWR-40 Page 2 of 7 I. GENERAL OBJECTIONS In addition to the objections to the specific requests, Enterprise TE objects generally to the data requests set forth below. The following general objections are applicable to and are hereby incorporated by reference into all of Enterprise TEs objections and responses to specific data requests. No specific objection set forth below constitutes a waiver, in whole or in part, of any of the foregoing general objections. 1. Enterprise TE objects to any discovery request to the extent it seeks information or documents that are not relevant to the subject matter of the above-captioned FERC proceeding and are not reasonably calculated to lead to the discovery of admissible evidence in that proceeding. 2. Enterprise TE objects to any discovery request to the extent it seeks information or documents protected from disclosure by the attorney-client privilege, other statutory or judicially recognized privileges, or the attorney work product doctrine. 3. Enterprise TE objects to any discovery request that calls for proprietary and confidential information and/or ...