20240424Motion for Extension.pdf

RECEIVED
Wednesday, April 24, 2024 5:46PM
IDAHO PUBLIC
UTILITIES COMMISSION
BEFORE THE IDAHO PUBLIC UTILITIES COMMISSION
IN THE MATTER OF THE APPLICATION ) CASE NOS.ATL-E-22-02
OF GREYLOCK ENERGY HOLDINGS,LLC )
FOR APPROVAL OF ITS STOCK AND ) MOTION TO EXTEND TIME
OWNERSHIP INTERESTS PURCHASE ) FOR COMPLIANCE FILING
AGREEMENT WITH ISRAEL RAY FOR )
THE ACQUISITION OF THE ATLANTA )
POWER COMPANY )
BACKGROUND
On December 2, 2022, Greylock Energy Holdings was ORDERED that no later than
August 1, 2023, the parties shall submit updated and complete legal descriptions of the land swap
described in Section 6.4 of the PSA, indicating clear ownership of the land in question, and clearly
delineating Greylock's access to all equipment and land necessary for the continued operation of
Atlanta Power. -Order No. 35649
On August 9, 2023, Greylock Energy Holdings was granted an extension up to May 1,
2024,to submit an updated and complete legal description of the land swap. Greylock Energy Holdings is
unable to meet the deadline of May 1, 2024, and would like to request an extension for the
following reasons:
• Current snow levels make it difficult to complete any type of surveying work.
• Greylock Energy Holdings and Israel Ray are renegotiating section 6.4 of the purchase
agreement.
REQUST FOR RELIEF
For the above reasons we request that the Commission extend the date for filing the
compliance filing ordered in Order No. 35649 to Augustlst, 2024
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Arnold Haught
Nick Jon s
MOTION TO EXTEND TIME FOR COMPLLANCE FILING I

MOTION TO EXTEND TIME FOR COMPLLANCE FILING 2