20260702Request for Extension of Time.pdf

RECEIVED
July 2, 2026
IDAHO PUBLIC
UTILITIES COMMISSION
Stephen R. Thomas, ISB No. 2326
Brandon Helgeson, ISB No. 11615
HAWLEY TROXELL ENNIS &HAWLEY LLP
877 W. Main Street, Suite 200
P.O. Box 1617
Boise, ID 83701-1617
Telephone: [phone]
Facsimile: 208.954.5921
Email: [e-mail]
[e-mail]
Attorneys for Respondent
BEFORE THE IDAHO PUBLIC UTILITIES COMMISSION
STABILITY NETWORKS, INC.,
Case No. QCC-T-26-01
COMPLAINANT,
REQUEST FOR EXTENSION OF TIME
V.
CENTURYLINK COMMUNICATIONS,
LLC d/b/a LUMEN TECHNOLOGIES
GROUP
RESPONDENT.
Pursuant to the Rules of Procedure of the Idaho Public Utilities Commission
("Commission"), IDAPA 31.01.01.256 (Rule 256), CenturyLink Communications, LLC d/b/a
Lumen Technologies Group ("Respondent"), respectfully requests an extension of time by the
Commission in which to respond to the Formal Complaint("Complaint") filed by Stability
Networks, Inc. ("Complainant") on or about May 11, 2026.
REQUEST FOR EXTENSION OF TIME-1
40619.0034.4897-8511-3018.1

I. REPRESENTATIVE DESIGNATION
Pursuant to Commission Rule 41, Respondent hereby designates it representatives for this
matter and requests all notices and communications with regard to this matter be served upon:
Stephen R. Thomas, ISB No. 2326 Joshua Trauner
Brandon Helgeson, ISB No. 11615 Assistant General Counsel
HAWLEY TROXELL ENNIS & Lumen Technologies
HAWLEY LLP 100 CenturyLink Drive
877 W. Main Street, Suite 200 Monroe, LA 71203
P.O. Box 1617 [e-mail]
Boise, ID 83701-1617
Telephone: [phone]
Facsimile: 208.954.5 921
[e-mail]
[e-mail]
II. FACTS
Complainant filed the Complaint on or about May 11, 2026, alleging issues with
Respondent's billing, disconnection and account-management procedures after Complainant's
allegedly unsuccessful efforts to resolve the issues through Respondent's customer service
representatives.
Respondent and its representatives take customer complaints seriously. After service of
of the Summons in this matter, Respondent and its representatives have been investigating the
allegations in the Complaint in order to fully understand the issues alleged therein and engaging
in discussions with Complainant's representative in an effort to resolve the dispute without the
need to resort to litigation. Respondent's efforts to resolve the dispute remain ongoing and, if
possible, it is Respondent's hope to resolve this dispute with the Complainant informally.
Additional time to respond to the Complaint affords the opportunity for the parties to fully
REQUEST FOR EXTENSION OF TIME-2

determine if informal resolution is possible before the parties, the Commission, and Commission
Staff must spend the time and expense of adjudicating this matter in formal proceedings.
III. REQUEST FOR RELIEF
Wherefore, in light of the above, Respondent hereby requests an extension of time to and
including July 17, 2026,1 in which to file a response to the Complaint.
IV. CONCLUSION
Respondent respectfully requests additional time through and including July 17, 2026, in
which to respond to the Complaint to allow for possible informal resolution of the dispute in this
matter.
HAWLEY TROXELL ENNIS &HAWLEY LLP
Dated: July 2, 2026.
By
Brandon Helgeson, ISB No. 11615
Attorneys for Respondent
1 According to IDAPA 31.01.01.017,in computing the time for a response to the Complaint"if the day the act must
be done is a Saturday, Sunday or legal holiday,the act may be done on the first day following that is not a
Saturday, Sunday or legal holiday."Service of the Summons was made via certified mail to Respondent on June
15,2026,meaning a response to the Complaint would normally be required to be filed on July 6,2026(21 days
from service of the Summons).On June 22,2026,Governor Little issued Executive Order No.2026-06 granting
paid leave to state employees on July 2 and July 6,2026,in addition to the state-observed Independence Day
holiday on July 3,2026.Therefore,Respondent interprets July 6,2026,as a legal holiday,meaning the current
deadline for filing a response is July 7,2026.
REQUEST FOR EXTENSION OF TIME—3

CERTIFICATE OF SERVICE
I HEREBY CERTIFY that I caused to be served a true copy of the foregoing REQUEST
FOR EXTENSION OF TIME by the method indicated below, and addressed to each of the
following:
Commission Staff ❑ U.S. Mail, Postage Prepaid
Commission Secretary ❑ Hand Delivered
Idaho Public Utilities Commission ❑ Overnight Mail
11331 W. Chinden Blvd., Bldg. 8, Suite 201-A 0 E-mail
Boise, ID 83714 ❑ Facsimile
secretgakpuc.idaho.gov ❑ iCourt
Miles L. Russon ❑ U.S. Mail,Postage Prepaid
Taylor Law Offices, PLLC ❑ Hand Delivered
1112 W. Main Street, Ste. 101 ❑ Overnight Mail
Boise, Idaho 83702 0 E-mail:
[e-mail] ❑ Facsimile
❑ iCourt
Joshua Trauner ❑ U.S. Mail, Postage Prepaid
Assistant General Counsel ❑ Hand Delivered
Lumen Technologies ❑ Overnight Mail
100 CenturyLink Drive 0 E-mail:
Monroe, LA 71203 ❑ Facsimile
joshua.trauner(a),lumen.com ❑ iCourt
Dated: July 2, 2026.
Brandon Helgeson, ISB No. 11615
REQUEST FOR EXTENSION OF TIME-4