20060925Motion for expeditious procedural.pdf

Peter Richardson
ISB 3195
Richardson & O'Leary
515 N. 27th Street
O. Box 7218
Boise, Idaho 83702
Telephone: [phone] Tel
Fax: [phone] Fax
peter~richardsonando leary. com
Attorneys for the Industrial Customers of Idaho Power
RECEIVED
2006 SEP 25 PM 2:
IDAHO PUP' Ie
UTILITIES COFl~AiSSION
BEFORE THE
IDAHO PUBLIC UTILITIES COMMISSION
IN THE MATTER OF IDAHO POWER
COMPANY'S APPLICATION FOR A
CERTIFICATE OF PUBLIC CONVENIENCE
AND NECESSITY FOR THE EV ANDER ANDREWS POWER PLANT
CASE NO. IPC-06-
INDUSTRIAL CUSTOMERS OF
IDAHO POWER MOTION FOR
EXPEDITIOUS PROCEDURAL
RELIEF TO COMPEL RESPONSE
REQUESTS FOR PRODUCTION
COMES NOW, The Industrial Customers ofIdaho Power, hereinafter referred to
as the "ICIP " and pursuant to Rule 256.03 and hereby moves this Commission for
expeditious procedural relief to compel Idaho Power Company ("Idaho Power ) to fully
and completely respond to the Confidential Third Production Request of the Industrial
Customers, Nos. 49, 50, 51 , 52, and 53.
Idaho Power filed answers to the above referenced production requests on
September 12 2006 taking the full 28 days allowed under Commission Rule 225.03.
However its answer is actually an objection based on the alleged confidential nature of
the requested information. Because the production requests that Idaho Power has refused
to answer are confidential and were filed on yellow paper pursuant to a confidentially
agreement executed between the Commission Staff, Idaho Power and the ICIP, this
motion will not address the specific information requested because doing so will violate
that confidentiality agreement. Idaho Power and the ICIP have agreed to waive briefing
this issue and request an in camera oral argument be scheduled as soon as possible.
DATED this 22nd day of September 2006.
Richardson & O'Leary, LLP
Jl~~Pe er J. Richardson
Industrial Customers of Idaho
Power
CERTIFICATE OF SERVICE
I HEREBY CERTIFY that on the 22nd day of September 2006, a true and correct
copy of the within and foregoing PETITION TO INTERVENE BY THE INDUSTRIAL
CUSTOMERS OF IDAHO POWER, was served by tele-fax to:
Barton Kline
Monica Moen
Idaho Power Company
PO Box 70
Boise, Idaho 80707-0070
Via telefax [phone]
Jean Jewell
Commission Secretary
Idaho Public Utilities Commission
472 West Washington
Boise, Idaho 83702
Via telefax [phone]~Jt
Peter 'd's