20040517Answer 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
BOB LEWANDOWSKI and MARK
SCHROEDER
IDAHO POWER COMPANY, an Idaho
corporation
Complainants CASE NO. I PC-04-1 0
vs.
ANSW E R
Respondent.
COMES NOW, Idaho Power Company (hereinafter referred to as "Idaho
Power" or "Respondent"), by and through its attorneys of record, and hereby answers
the Complaint of Bob Lewandowski and Mark Schroeder (hereinafter referred to as
Complainants ). Idaho Power responds to the allegations contained in the Complaint
as follows:
ANSWER, Page
Idaho Power admits the allegations contained in Paragraphs 1 8 and
9 of the Complaint.
II.
Idaho Power is without knowledge or information sufficient to form a belief
as to the truth of the allegations contained in Paragraphs 2 6 and 7 of the Complaint.
III.
Idaho Power admits that it has undertaken discussions with Complainants
and provided drafts of Firm Energy Sales Agreements to Complainants. Idaho Power
denies the balance of the allegations contained in Paragraphs 10, 11 , 12 , 13 and 14 of
the Complaint.
PRAYER FOR RELIEF
Complainants have 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, I D 83707
bkline ~ idahopower.com
mmoen ~ idahopower.com
John P. Prescott
Vice President, Power Supply
Idaho Power Company
O. Box 70
Boise, I D 83707
Iprescott ~ idahopower.com
ANSWER, Page 2
DATED at Boise, Idaho, this 14th day of May, 2004.
tL-
BARTON L. KLINE
Attorney for Idaho Power Company
CERTIFICATE OF SERVICE
I HEREBY CERTIFY that on the 14th day of May, 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:
Peter J. Richardson
Richardson & O'Leary PLLC
99 East State Street
Eagle , Idaho 83616
Hand Delivered
S. Mail
Overnight Mail
FAX
BARTON L. KLI N E
ANSWER , Page 3