20181206Stipulation 44.pdf

Stipulation and Request Extending the Deadline for Plaintiff’s Responses/Replies to Various
Motions and Response of the Defendant and the Defendant-Intervenor.

1.

Peter J. Richardson, ISB# 3195 Robert C. Huntley, ISB# 2188
515 N. 27th Street R. HUNTLEY LAW, PLLC
Boise, Idaho 83702 815 West Washington Street
Telephone [phone] Boise, ID 8701
Facsimile: [phone] Telephone [phone]
[e-mail] Facsimile [phone]
[e-mail]

Attorney for Plaintiffs Attorney for Plaintiffs

UNITED STATES DISTRICT COURT
FOR THE DISTRICT OF IDAHO
FRANKLIN ENERGY STORAGE ONE, LLC,
FRANKLIN ENERGY STORAGE TWO, LLC
FRANKLIN ENERGY STORAGE THREE,
LLC, FRANKLIN ENERGY STORAGE
FOUR, LLC

Plaintiffs,
vs.

PAUL KJELLANDER, KRISTINE RAPER and
ERIC ANDERSON, in their official capacity as
Commissioners of the IDAHO PUBLIC
UTILITIES COMMISSION,

Defendants.
Case No.: 1:18-cv-00236-REB
STIPULATION AND REQUEST TO
EXTEND THE DEADLINE TO RESPOND
TO DEFENDANT’S AND DEFENDANT-
INTERVENOR’S RESPONSES TO MOTION
FOR SUMMARY JUDGMENT, MOTIONS
TO DISMISS, AND REPLY TO RESPONSES
TO PLAINTIFF’S MOTION FOR
SUMMARY JUDGMENT

The parties, by and through their respective counsel of record, hereby stipulate and
request that the time for Plaintiffs’ to file its respective replies to Defendants and Defendant-
Intervenor’s Responses to Motion for Summary Judgment, and Responses to Defendant’s and
Defendant-Intervenor’s Motion for Summary Judgment and Motions to Dismiss (Docket Nos.
38, 39, 40, 41 and 42) shall be extended up to an including November 30, 2018. The parties
hereby stipulate to the subject extensions to accommodate a request by Counsel for Plaintiffs
Case 1:18-cv-00236-REB Document 44 Filed 11/09/18 Page 1 of 3

Stipulation and Request Extending the Deadline for Plaintiff’s Responses/Replies to Various
Motions and Response of the Defendant and the Defendant-Intervenor.

2.

(Mr. Richardson) due to an unexpected family health issue that has required his personal
attention over the past several weeks.
Respectfully submitted this 9th day of November 2018.
____/s/ Robert C. Huntley, Esq_________________________________
Robert C. Huntley, Esq.

____/s/ Peter J. Richardson, Esq._ _____________________________
Peter R. Richardson, Esq.

Attorneys for Plaintiffs

____/s/ Brandon Karpen ____________________________

Attorney for Defendant, Idaho Public Utilities Commission

___/s/ Donovan Walker_______________________________________

Attorney for Defendant-Intervenor, Idaho Power Company

Case 1:18-cv-00236-REB Document 44 Filed 11/09/18 Page 2 of 3

Stipulation and Request Extending the Deadline for Plaintiff’s Responses/Replies to Various
Motions and Response of the Defendant and the Defendant-Intervenor.

3.

CERTIFICATE OF SERVICE

I HEREBY CERTIFY that on the 9th day of November, 2018, I filed the foregoing electronically
through the CM/ECF system, which caused the following parties and counsel to be served by
electronic means, as more fully reflected on the Notice of Electronic Filing:

Brandon Karpen
[e-mail]
Edith Pacillo
[e-mail]
Scot Zanzig
[e-mail]
Attorneys for Defendants
Steven B. Anderson
[e-mail]
Wade L. Woodard
[e-mail]
Donovan Walker
[e-mail]
Attorneys for Defendant-Intervenor Idaho Power Company

/s/ Peter J. Richardson, Esq.
Peter R. Richardson, Esq.

Case 1:18-cv-00236-REB Document 44 Filed 11/09/18 Page 3 of 3