Simplot Petition to Intervene.pdf

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J R. SIMPLOT COMPANY / ONE CAPITAL CENTER / 999 MAIN STREET / SUITE 1300
P.O BOX 27 / BOISE, IDAHO 83707 / [phone] / TELEX 368432
CORPORATE HEADOUARTERS
May 30, 1980
Myrna Walters, Secretary
Idaho Public Utili ties CommissionStatehouse
Boise, Idaho 83720
Re: Case No.: U-l034-88
Dear Myrna:
Enclosed please find for filing with the Commission
an original and seven (7) copies of a Petition to Intervene.
Please conform the copy and return to us at your convenience.
Thank you for your assistance in this matter.
Dreiy,
~C:andYAssistan Counsel
NRS:rm
Encs.
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OFFICE OF SEC\'~1
e .DAHO PUBLIC UT!UT ii_,; CO¡v¡¡/nSSION
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BEFORE THE IDAHO PUBLIC UTILITIES COMMissi~lje h - d -/lQ
IN THE MATTER OF THE APPLICATION )
OF INTERMOUNTAIN GAS COMPANY FOR ) CASE NO. U-l034-88
APPROVAL OF ITS PROPOSED RATE )
SCHEDULES . . . . . . . . . . . . .) PETITION TO INTERVENE
)
COMES NOW, J. R. SIMPLOT CO~~lNY, a corporation doing
business in the State of Idaho, and more particularly doing
business within the certificated servic~ area of Intermountain
Gas Company, and respectfully petitions i the Idaho Public utili ties
Commission as follows:
1. J. R. Simplot Company (heteafter called "Petitioner")
is a corporation authorized to do business in the State of Idaho,
with its principal office therein located at Boise, Ada County,
Idaho, and having operational divisions located throughout
southern Idaho.
2. Petitioner's operating divisions in southern Idaho
are located within the certificated seryice area of Intermountain
Gas Company and, as such, the Petitionet is a customer of said
Intermountain Gas Company and, as a result, purchases natural gas
from said utility company.
3. If the Application of Intermountain Gas Company,
filed in the above matter asking for changes in rates, is
approved by the Idaho Public utilities çommission, Petitioner
will be directly and substantially affected.
4. Peti tioner requests leave! to intervene in the
above-enti tIed matter so it might cross!-examine witnesses of
Intermountain Gas Company and any other! parties intervening in
this proceeding, present evidence in sa!id proceeding and
generally participate therein.
5. If Petitioner is allowed ito intervene , it is
respectfully requested that all pleadings, exhibits, orders
and other filings of Intermountain Gas Company, the Idaho
PETITON TO INTERVENE - 1
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Public utilities Commission and all other intervening parties
relating to the Application filed in the above matter be served
upon the Petitioner and the attorneys for the Petitioner as
follows:
N. Randy Smith
Assistant General Counsel
J. R. Simplot Company
P. O. Box 27
Boise, Idaho 83707
Melvin D. Alsager
J. R. Simplot Company
P. O. Box 27Boise, "'~83707
DATED This~ay of May, 1980.
J. R. S IMPLOT COMPANY
By
PETITION TO INTERVENE - 2
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CERTIFICATE OF MAILIBQ ~
I HEREBY CERTIFY that on the ~ay of May, 1980,
I served the foregoing PETITION TO INTERVENE upon:
Eugene C. Thomas and
Tom Amrose
Moffatt, Thomas, Barrett &
Blanton, Chartered
P. O. Box 829
Boise, Idaho 83701
R. D. Grim, President
Intermountain Gas Company
P. O. Box 7608
Boise, Idaho 83707
R. Michael Southcombe
Clemons, Cosho & Humphrey. . .1110 Bank of Idaho Building
Boise, Idaho 83702
Dan Poole
Elam, Burke, Jeppesen, Evans
& Boyd
P. O. Box 1559
Boise, Idaho 83701
Walter H. Smith, Acting President
Intermountain Gas Company
555 South Cole Road
Boise, Idaho 83705
by depositing true copies thereof in the United States Mail,
postage prepaid, in envelopes addressed to each of said attorneys
at their addresses listed above.
PETITION TO INTERVENE - 3