20040526Reply to Opposition.pdf

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Peter J. Richardson
RICHARDSON & O'LEARY PLLC
99 East State Street
Eagle, Idaho 83616
Telephone: [phone]
Fax: [phone]
peter~ri chardsonando leary. com
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UTiLiTiES COr'lf"lIS~tOH
Attorneys for the Industrial Customer of Idaho Power
BEFORE THE IDAHO PUBLIC UTILITIES COMMISSION
BOB LEWANDOWSKI AND MARK
SCHROEDER
Complainants
IDAHO POWER COMPANY, an Idaho
Corporation
Respondent
CASE NO. IPC-04-
CASE NO. IPC-04-
REPLY TO U.GEOTHERMAL'
OPPOSITION TO MOTION TO
CONSOLIDATE
COMES NOW, Bob Lewandowski and Mark Schroeder ("Complainants ), through their
attorneys, Richardson and O'Leary, and hereby lodges its reply to u.S. Geothermal's opposition
to their Motion to Consolidate.
The only reason u.S. Geothermal offers in opposition to the Complainant's motion to
consolidate is that it would delay the proceeding thereby prejudicing U.S. Geothermal. Although
no formal notice of a procedural schedule has been issued, and no pre-hearing conference has
been held in the -08 docket, the parties to that proceeding have apparently set the following
informal schedule for filing testimony:
REPLY TO OPPOSITION TO MOTION TO CONSOLIDATE
June 2 U.S. Geothermal
July 15 Idaho Power
August 5 Staff
August 19 Rebuttal
Your Complainants will be ready to prefile their testimony on June 9, should the
Commission grant them status as a party. This would only require the schedule to be moved
back one week. It is difficult to see how moving the schedule back one week would have any
material affect on U. S geothermal - let alone rise to the level of prejudice.
Your complainants respectfully renew their motion to consolidate
Respectfully submitted this 26th day of May, 2004.
RICHARDSON & 0 'LEARY PLLC
4J By. \ I
Pet J. Richardson, ISB #3195
Attorneys for the Industrial Customers
of Idaho Power
REPLY TO OPPOSITION TO MOTION TO CONSOLIDATE
CERTIFICATE OF SERVICE
I HEREBY CERTIFY that on this 26th day of May, 2004, I caused a true and
correct copy of the foregoing REPLY TO U .GEOTHERMAL'S 0 PPOSITI 0 N TO
MOTION TO CONSOLIDATE to be served by the method indicated below, and addressed to
the following:
Jean Jewell
Idaho Public Utilities Commission
472 West Washington Street
Post Office Box 83720
Boise, Idaho 83720-0074
( ) U.S. Mail, Postage Prepaid
(X) Hand Delivered
( )
Overnight Mail
( )
Facsimile
( )
Electronic Mail
Monica B. Moen, Attorney II
Barton L. Kline, Seniior Attorney
Idaho Power Company
PO Box 70
Boise, ID 83707-0070
bkline~idahopower. com
mmoen~idahopower.com
(X) U.S. Mail, Postage Prepaid
( )
Hand Delivered
( )
Overnight Mail
( )
Facsimile
(X) Electronic Mail
Randy C. Allphin, Contract Admin.
Power Supply Planning
Idaho Power Company
Post Office Box 70
Boise, Idaho 83707-0070
rall phin~idahopower. com
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Hand Delivered
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John Prescott
Vice-President - Power Supply
Idaho Power Company
Post Office Box 70
Boise, Idaho 83707-0070
prescott(alidahopower. com
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Conley E. Ward
Givens Pursley LLP
601 West Bannock
Po Box 2720
Boise, Idaho 83701-2720
cew~gi venspursl ey. com
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Hand Delivered
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REPLY TO OPPOSITION TO MOTION TO CONSOLIDATE
Doug Glaspey
S. Geothermal
1509 Tyrell Lane
Boise, Idaho 83706
glaspey~us geothermal. com
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Hand Delivered
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Signed CuJ\~(.,
Nina Curtis
REPLY TO OPPOSITION TO MOTION TO CONSOLIDATE