20130802Motion to Extend Filing Time.pdf

Peter J. Richardson (ISB # 3195)
Gregory M. Adams (ISB # 7454)
Richardson Adams, PLLC
515 N. 27th Street
P.O. Box 7218
Boise, Idaho 83702
Telephone: [phone]
Fax: [phone]
peter@richardadams. com
gre [e-mail]
Attorneys for Complainant
GRAND VIEW PV SOLAR TWO, LLC,
Complainant,
vs.
IDAHO POWER COMPANY,
Respondent.
BEFORE THE
IDAHO PUBLIC UTILITIES COMMISSION
Case No. IPC-E-I1-15
MOTION TO EXTEND TTME TO FILE
RESPONSE
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INTRODUCTION
In tdaho Public Utilities Commission ("Commission") Order No. 32861, issued in the
above captioned matter on July 29,2013 and received in the U. S. Mail on August l, Grand
View PV Solar Two, LLC ("Grand View") is given seven days from JuJy 29,2013, in which to
respond to the Commission's directive, to wit:
[I]f Grand View has evidence that it created a legally enforceable obligation without
conditions, then it may present such evidence to the Commission within seven days of the
date of this order.l
Grand View is simply unprepared to respond to the Commission's request in the short time
period allowed due to other commitments its legal council has to meet, including a trip out of
' Order No. 32861 atp.22.
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I town. Grand View, however, is prepared to respond in fourteen days or later, at the
2 Commission'sdiscretion.
3 Grand View can see no prejudice to the Respondent, Idaho Power Company, in granting
4 it an additional seven days in which to respond. Grand View also can see no prejudice to the
5 Commission, or it's Staff, in granting additional time in which to respond. [n fact, with the
6 additional time, the response will be more complete and hopefully more helpful to the
7 Commission in arriving at a reasoned decision. Grand View has contacted Commission Staff
8 attorney Don Howell, who stated that the Staff has no objection to an extension. Grand View
t has attempted to contact the Respondent, but as of this writing has not heard back.
10 WHEREFORE, Grand View respectfully requests this Commission grant it an additional
I 1 seven days in which to respond to Order No. 32861.
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13 Respectfully submitted this 2"d day of August, 2011
14 RICHARDSON AND O'LEARY, PLLC
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Priter J. Richardson (ISB No. 3195)
Gregory M. Adams (ISB No. 7454)
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CERTIFICATE OF SERVTCE
I HEREBY CERTIFY that on this 2nd of August 2013, I served a true and correct copy of
GRAND VIEW PV SOLAR TWO, LLC's MOTION TO EXTEND TIME TO FILE
RESPONSE upon the following named respondents by the method indicated below, and
addressed to the following;
COMMISSION STAFF
Don Howell
Deputy Attorney General
47 4 W . Washington Street
Boise,Idaho 83702
[e-mail]. gov
IDAHO POWER COMPANY
Lisa Nordstrom
Donovan Walker
1221 West Idaho Street
Boise,Idaho 83702
Peter Richardson ISB 3195
Hand Delivery
Electronic Mail
Hand Delivery
Electronic Mail
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