20070302Motion to file reply comments.pdf

William J. Batt, ISB No. 2938
John R. Hammond, Jr., ISB No. 5~~Q ~ ," 1. r' - 'BATT & FISHER, LLP /.JJ I \"i,.yo '-
S. Bank Plaza, 5th Floor
101 S. Capitol Boulevard
Post Office Box 1308
Boise, ID 83701
Telephone: [phone]
Facsimile: [phone]
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jrh~battfisher. com
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Attorneys for A vimar, LLC
IN THE MATTER OF THE
APPLICATION OF IDAHO POWER
COMP ANY FOR APPROVAL OF
AGREEMENT BEWTEEN A VIMOR
LLC AND IDAHO POWER TO
PROVIDE ELECTRIC TRANSMISSION
AND SUBSTATION FACILITIES TO
THE A VIMOR MULTI-USE
DEVELOPMENT
BEFORE THE IDAHO PUBLIC UTILITIES COMMISSION
Case No. IPC-Q4-
MOTION REQUESTING LEAVE TO
FILE REPLY COMMENTS
COMES NOW Avimor, LLC ("Avimor" or the "Company ) and hereby makes
this motion respectfully requesting that the Commission grant the Company leave to file
to file reply comments in response to the Idaho Public Utilities Commission Staffs
Comments filed in this case and/or to file a revised Agreement to Provide Electric
Transmission and Substation Facilities (the "Agreement"
On November 1 , 2006 the Commission issued its Notice of Application and
Notice of Modified Procedure in this case. See Order No. 30165. In the Notice the Idaho
Public Utilities Commission (the "Commission ) allowed for the filing of comments in
regard to the Agreement. The Notice does not provide for the filing of reply comments.
MOTION FOR LEAVE TO FILE REPLY COMMENTS - ORtG1NAL
Due to the fact that A vimor is a party to the Agreement and the content of the
Commission Staffs Comments on it the Company respectfully requests that the
Commission grant it leave to file reply comments. Further, as Avimor has recently
retained counsel the Company requests an adequate amount of time by which to file reply
comments and/or a revised Agreement. Therefore, the Company requests that it be given
until April 2, 2007 to make its filing with the Commission.
No previous extensions of time have been granted in this matter.
Based on the foregoing, A vimor requests that it be given until Monday, April 2
2007 to file reply comments and/or a revised Agreement with the Commission.
PRAYER FOR RELIEF
That the Commission grant Avimor, LLC's Motion for Leave to File Reply
Comments and to give the Company until April 2, 2007 to file the same and/or revised
Agreement with the Commission in this case.
DATED THIS 2nd day of March, 2007.
A VIMOR, LLC
By:
. Hammond, Jr.
ey for A vimor, LLC
MOTION FOR LEAVE TO FILE REPLY COMMENTS - 2
CERTIFICATE OF SERVICE
I HEREBY CERTIFY that on this 2nd day of March, 2007, I served the foregoing
upon all parties of record in this proceeding as indicated below.
Jean Jewell
IDAHO PUBLIC UTILITIES COMMISSION
472 W. Washington Street
O. Box 83720
Boise, ID 83702-5983
ji ewell~puc.state.id. us
J Certified Mail
J First Class Mail
( x J Hand Delivery
J Facsimile
Monica B. Moen
IDAHO POWER COMPANY
O. Box 70
Boise, ID 83707-0070
mmoen~idahopower.com
J Certified Mail
( x J First Class Mail
J Hand Delivery
J Facsimile
Weldon Stutzman
IDAHO PUBLIC UTILITIES COMMISSION
472 W. Washington Street
O. Box 83720
Boise, ID 83702-5983
Weldon. S tutzman~puc.idaho. gov
J Certified Mail
J First Class Mail
( x J Hand Delivery
J Facsimile
R. Hammond, Jr.
orneys for Company
MOTION FOR LEAVE TO FILE REPLY COMMENTS - 3