20050714Motion to shorten discovery time.pdf

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Dean J. Miller ISB #1968
McDEVITT & MILLER LLP
420 West Bannock Street
o. Box 2564-83701
Boise, ill 83702
Tel: [phone]
Fax: [phone]
oe mcdevitt-miller.com
1uns JUL \ It PM 4: 28
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T\L\'tiES COMMtSSlOf'i
Attorneys for Magic Wind LLC
Cassia Wind Farm LLC (Magic and Cassia)ORIGINAL
BEFORE THE IDAHO PUBLIC UTILITIES COMMISSION
IN THE MATTER OF THE PETITION OF
IDAHO POWER COMPANY FOR AN
ORDER TEMPORARILY SUSPENDING
IDAHO POWER'S PURPA OBLIGATION TO
ENTER INTO CONTRACTS TO PURCHASE
ENERGY GENERATED BY WIND-
POWERED SMALL POWER PRODUCTION
FACILITIES.
Case No. IPC-O5-
MOTION TO SHORTEN TIME
FOR DISCOVERY
COMES NOW Magic Wind LLC and Cassia Wind Farm LLC (Magic and
Cassia), pursuant to IPUCRP 56 and moves the Commission for an order shortening the
time for response to discovery and in support thereof respectfully shows as follows:
1. Magic and Cassia have filed petitions for intervention herein, which demonstrates
its substantial interest in these proceedings.
2. The Commission, pursuant to its Order of Procedural Schedule, adopted July 1
2005 adopted a compressed time schedule to consider Idaho Power Company
request to suspend its PURA obligation with respect to wind generation small
power producers.
3. Magic and Cassia have propounded to Idaho Power Company certain Requests
for Admissions and Interrogatories which are attached hereto. To adequately
prepare for the scheduled hearing on July 22, it is necessary for Magic and Cassia
to receive answers to the requested discovery requests by July 20, 2005.
MOTION TO SHORTEN TIME FOR DISCOVERY -
4. The information requested in the attached discovery requests is all within the
possession of Idaho Power Company and the production thereof would not by
unduly burdensome.
WHEREFORE Magic and Cassia Respectfully requests that the Commission
enter its Order shortening the time for response to discovery as requested above.
Date this day of July, 2005
Respectfully submitted
McDEVITT & MILLER LLP
J. Ml ler
McDevitt & Miller LLP
420 W. Bannock
Boise, ID 83702
Phone: [phone]Fax: [phone]
Counsel for Magic Wind LLC Cassia
Wind Farm LLC (Magic and Cassia)
MOTION TO SHORTEN TIME FOR DISCOVERY -
~~~~ICA TE OF SERVICE
I hereby certify that on the --W"ay of July, 2005, I caused to be served, via the
methodes) indicated below, true and correct copies of the foregoing document, upon:
Jean Jewell, Secretary
Idaho Public Utilities Commission
472 West Washington Street
O. Box 83720
Boise, ID 83720-0074
iiewell~puc.state.id. us
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Barton L. Kline
Monica B. Moen
Idaho Power Company
1221 West Idaho Street
O. Box 70
Boise, ID 83707
BKline~idahopower .com
MMoen~idahopower. com
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Peter J. Richardson
Richardson & O'Leary PLLC
99 East State Street
O. Box 1849
Eagle, ID 83616
peter~richardsonanqoleary .com
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Fax
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iiI
MOTION TO SHORTEN TIME FOR DISCOVERY - 3