20040420Answer to Summons.pdf

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BARTON L. KLINE ISB #1526
MONICA B. MOEN ISB #5734
Idaho Power Company
O. Box 70
Boise, Idaho 83707
Telephone: [phone]
FAX Telephone: [phone]
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Attorney for Idaho Power Company
Street Address for Express Mail
1221 West Idaho Street
Boise, Idaho 83702
BEFORE THE IDAHO PUBLIC UTILITIES COMMISSION
S. GEOTHERMAL , INC.
Respondent.
CASE NO. IPC-04-Complainant
vs.
ANSWER
IDAHO POWER COMPANY
COMES NOW, Idaho Power Company (hereinafter referred to as "Idaho
Power" or "Respondent"), by and through its attorneys of record , and hereby files its
answer to the Complaint of U.S. Geothermal, Inc. (hereinafter referred to as
Geothermal" or "Complainant"). Idaho Power herewith admits and denies the
allegations contained in the Complaint as follows:
ANSWER, Page
Idaho Power admits the allegations contained in Paragraphs 1 , 2, 3, and 4
of the Complaint.
II.
Idaho Power admits it has held discussions with Geothermal. Idaho
Power is without knowledge or information sufficient to form a belief as to the truth of
the balance of the allegations contained in Paragraphs 5 and 6 of the Complaint.
III.
Idaho Power admits it has exchanged drafts of Agreements with
Geothermal. Idaho Power denies the balance of the allegations contained in
Paragraphs 7, 8, 9 and 10 of Geothermal's Complaint.
PRAYER FOR RELIEF
Geothermal has not stated a claim for relief which can be granted and the
Complaint should be denied by the Commission.
SERVICE
Communications with reference to this case should be sent to the
following:
Barton L. Kline
Monica B. Moen
Idaho Power Company
O. Box 70
Boise , ID 83707
bkline (Q) idahopower.com
mmoen (Q) idahopower.com
John P. Prescott
Vice President, Power Supply
Idaho Power Company
O. Box 70
Boise , ID 83707
jprescott (Q) idahopower.com
ANSWER, Page 2
DATED at Boise , Idaho, this 19th day of April, 2004.
BARTON L. KLINE
Attorney for Idaho Power Company
CERTIFICATE OF SERVICE
I HEREBY CERTIFY that on the 19th day of April , 2004 , I served a true
and correct copy of the within and foregoing ANSWER upon the following named
parties by the method indicated below, and addressed to the following:
Conley E. Ward
Givens Pursley LLP
601 W. Bannock Street
O. Box 2720
Boise , ID 83701-2720
Hand Delivered
~ U.S. Mail
Overnight Mail
FAX
Daniel Kunz, President
S. Geothermal, Inc.
1509 Tyrell Lane, Suite B
Boise , ID 83706
Hand Delivered
X. U.S. Mail
Overnight Mail
FAX
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BARTON L. KLINE
ANSWER , Page 3