20140331Motion to Extend Reply Time.pdf

i.-i' :,' il I ],,,, iij: l::J
Peter J. Richardson ISB # 3195
Gregory M. Adams ISB # 7454 ,
RICHARDSON ADAMS, PLLC
515 N.27ft Street
Boise, Idaho 83702
Telephone: [phone]
Fax: [phone]
[e-mail]
gr e g@richard s onad am s. c om
Attorneys for the J. R. Simplot Company
BEFORE THE IDAHO PUBLIC UTILITIES COMMISSION
rN THE MATTER OF IDAHO POWER ) CASE NO.IPC-E-13-23
COMPANY'S APPLICATION FOR )
APPROVAL OF SPECIAL CONTRACT ) J. R. SIMPLOT COMPANY'S
BETWEEN IDAHO POWER COMPANY ) MOTTON TO EXTEND TrME TO
AND J. R. SIMPLOT COMPANY ) REPLY
COMES NOW, counsel for the J. R. Simplot Company ("Simplot") and hereby requests
an additional seven days in which to file its reply comments in the above captioned docket.
Order No. 32984 issued in the above captioned docket by the Idaho Public Utilities
Commission ("Commission") on February 25,2014 provided that comments on the terms and
conditions of ldaho Power Company's ("ldaho Power") proffered special contract with Simplot
be filed on March 28,2014 and reply comments on April 4,2014.
Given the magnitude of the issues raised in ldaho Power's Comments and that counsel
for Simplot will be out of the office for much of the week on an unplanned business trip, Simplot
would be at a disadvantage in preparing a thorough and detailed reply in the short time available.
An additional week in which to file comments would accommodate counsel's schedule, not
prejudice the other parties or the Commission's ability to fully deliberate on the issues presented
and will not broaden the issues.
Pursuant to Rule 256.03 of the Commission's Rules of Procedure Simplot has
telephonically contacted counsel for both the Commission Staff and Idaho Power Company.
Neither Party objected to an extension of time of seven days.
WHEREFORE, the J. R. Simplot Company respectfully requests an additional seven days
in which to file its reply to comments filed on March 28,2014.
RESPECTFULLY SUBMITTED this 3l't day of March 2014.
zuCHARDSON ADAMS, PLLC
#e
Peter Richardson tSB# 3195
Greg Adams ISB# 7454
Attorneys for J. R. Simplot Company
J. R. STMPLOT COMPANY MOTION TO EXTEND TIME
IPC-E-13-23
PAGE 2
CERTIFICATE OF SERVICE
I hereby certify that on 3l$ day of March 2014, copies of the foregoing MOTION TO
EXTEND TIME of the J. R. Simplot Company in DocketNo. IPC-E-13-23 were hand delivered
to:
Jennifer M. Reinhardt-Tessmer Jean Jewel
Lisa Nordstrom Secretary
Idaho Power Company ldaho Public Utilities Commission
l22l West ldaho 472West Idaho
Boise, Idaho 83702 Boise,Idaho 83702
C^r^-\Vr,q,ttrr
Nina Curtis
Administrative Assistant
J. R. STMPLOT COMPANY MOTION TO EXTEND TIME
rPC-E-13-23
PAGE 3