20130805_4137.pdf

PeterJ.Richardson (ISB #3195)
Gregory M.Adams (ISB #7454)
Richardson Adams,PLLC
515 N.27th Street L i1 1!
P.O.Box 7218 ;;].
Boise,Idaho $3702 JTiC%1SSOi’
Telephone:(20$)938-7901
fax:(20$)938-7904
[e-mail]
gregrichardadams.com
Attorneys for Complainant
BEFORE THE
IDAHO PUBLIC UTILITIES COMMISSION
GRAND VIEW PV SOLAR TWO,LLC,)
Complainant,)Case No.IPC-E-11-15
)
vs.)MOTION TO EXTEND TIME TO FILE)RESPONSEIDAHOPOWERCOMPANY,)Respondent.)
)
1 INTRODUCTION
2 In Idaho Public Utilities Commission (“Commission”)Order No.32861,issued in the
3 above captioned matter on July 29,2013 and received in the U.S.Mail on August 1,Grand
4 View PV Solar Two,LLC (“Grand View”)is given seven days from July 29,2013,in which to
5 respond to the Commission’s directive,to wit:
6 [I]f Grand View has evidence that it created a legally enforceable obligation without
7 conditions,then it may present such evidence to the Commission within seven days of the
$date of this order.’
9
10 Grand View is simply unprepared to respond to the Commission’s request in the short time
11 period allowed due to other commitments its legal council has to meet,including a trip out of
‘Order No.32861 atp.22.
Page 1-MOTION TO EXTEND TIME
1 town.Grand View,however,is prepared to respond in fourteen days or later,at the
2 Commission’s discretion.
3 Grand View can see no prejudice to the Respondent,Idaho Power Company,in granting
4 it an additional seven days in which to respond.Grand View also can see no prejudice to the
5 Commission,or it’s Staff,in granting additional time in which to respond.In fact,with the
6 additional time,the response will be more complete and hopefully more helpful to the
7 Commission in arriving at a reasoned decision.Grand View has contacted Commission Staff
8 attorney Don Howell,who stated that the Staff has no objection to an extension.Grand View
9 has attempted to contact the Respondent,but as of this writing has not heard back.
10 WHEREFORE,Grand View respectfully requests this Commission grant it an additional
11 seven days in which to respond to Order No.32861.
12
13 Respectfully submitted this 2t1(day of August,2011
14 RICHARDSON AND O’LEARY,PLLC
17 Peter J.Richardson (ISB No.3195)
18 Gregory M.Adams (ISB No.7454)
19
20
Page 2-MOTION TO EXTEND TIME
2
3 CERTIFICATE Of SERVICE
4
5 I HEREBY CERTIFY that on this 2nd of August 2013,I served a true and correct copy of
6 GRAND VIEW PV SOLAR TWO,LLC’s MOTION TO EXTEND TIME TO FILE
7 RESPONSE upon the following named respondents by the method indicated below,and
8 addressed to the following;
9
10 COMMISSION STAFF Hand Delivery
11 Don Howell Electronic Mail
12 Deputy Attorney General
13 474 W.Washington Street
14 Boise,Idaho 83702
15 [e-mail]
16
17 IDAHO POWER COMPANY Hand Delivery
18 Lisa Nordstrom Electronic Mail
19 Donovan Walker
20 1221 West Idaho Street
21 Boise,Idaho 83702
22 [e-mail]
23 dwa1ker(idahopower.com
27 Peter Richardson ISB 3195
Page 3-MOTION TO EXTEND TIME