20070321Motion requesting leave to file.pdf

William J. Batt, ISB No. 2938
John R. Hammond, Jr., ISB No. 5470
BATT & FISHER, LLP
u.S. Bank: Plaza, 5th Floor
101 S. Capitol Boulevard
Post Office Box 1308
Boise, ID 83701
Telephone: [phone]
Facsimile: [phone]
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Attorneys for Avimor, LLC
BEFORE THE IDAHO PUBLIC UTILITIES COMMISSION
IN THE MATTER OF THE
APPLICATION OF UNITED WATER
IDAHO, INc., FOR AUTHORITY TO
AMEND AND REVISE CER TIFI CA TE
OF PUBLIC CONVENIENCE AND
NECESSITY NO. 143 AND FOR
APPRO V AL OF A SPECIAL
FACILITIES AGREEMENT WITH
A VIMOR LLc.
Case No. UWI-O7-
MOTION REQUESTING LEAVE TO
FILE REPLY COMMENTS AND FOR
AN EXTENSION OF TIME TO FILE
REPLY COMMENTS
COMES NOW Avimor, LLC ("Avimor" or the "Company ) and hereby makes
this motion respectfully requesting that the Commission grant the Company leave to file
reply comments in response to the Idaho Public Utilities Commission Staff s Comments
filed in this case and for extending the reply comment deadline in this case to April 13
2007. This pleading is filed contemporaneously with the Company s Petition to
Intervene in this proceeding.
On February 14 2007, the Commission issued its Notice of Application and
Notice of Modified Procedure in this case. See Order No. 30242. In the Notice, the
Idaho Public Utilities Commission (the "Commission ) allowed for the filing of
MOTION FOR LEAVE TO FILE REPLY COMMENTS AND FOR AN EXTENSION OF TIME - 1
comments on the Application and associated Special Facilities Agreement (the
Agreement"). The Notice also provides a time period for United Water Idaho, Inc. to
file reply comments. Due to the fact that Avimor is a party to the Agreement and directly
impacted by United Water Idaho, Inc.s request to amend and revise its Certificate of
Public Convenience and Necessity, the Company respectfully requests that the
Commission grant it leave to file reply comments. In addition, Avimor, like United
Water Idaho, Inc., requests the opportunity to present oral argument to the Commission in
support of its reply comments.
Further, as A vimor has recently retained counsel for this matter, the Company
requests an adequate amount of time by which to file reply comments. Therefore, the
Company requests that the reply comment deadline for United Water Idaho, Inc. and
Avimor be extended to April 13, 2007. United Water Idaho, Inc. has no objection to this
request.
No previous extensions of time have been granted in this matter.
PRAYER FOR RELIEF
That the Commission grant Avimor, LLC's Motion for Leave to File Reply
Comments.
That the Commission grant Avimor, LLC's Motion to extend the reply comment
deadline until April 13 , 2007.
DATED THIS 2151 day of March, 2007.
A VIMOR, LLC
R. Hammond, Jr.
orney for Avimor, LLC
By:
MOTION FOR LEAVE TO FILE REPLY COMMENTS AND FOR AN EXTENSION OF TIME - 2
CERTIFICATE OF SERVICE
I HEREBY CERTIFY that on this 21 5t day of March, 2007, I served the foregoing
upon all parties of record in this proceeding as indicated below.
Jean Jewell
IDAHO PUBLIC UTILITIES COMMISSION
472 W. Washington Street
O. Box 83720
Boise, ID 83702-5983
iiewell~puc.state.id.
Dean J. Miller, Esq.
McDEVITT & MILLER LLP
O. Box 2564
Boise, Idaho 83701
208-343- 7500
208-336-6912 (fax)
Gregory P. Wyatt
UNITED WATER IDAHO, INc.
O. Box 190420
Boise, Idaho 83719-0420
208-362- 7327
208-362- 7069 (fax)
Weldon Stutzman
IDAHO PUBLIC UTILITIES COMMISSION
472 W. Washington Street
O. Box 83720
Boise, ID 83702-5983
W eldon. Stutzman~puc.idaho. gov
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MOTION FOR LEAVE TO FILE REPLY COMMENTS AND FOR AN EXTENSION OF TIME - 3