20200428Motion to Extend Time.pdf

Peter J. Richardson (tSB No. 3195)
Gregory M. Adams (ISB No. 7454)
Richardson Adams, PLLC
515 N. 27tr' Street
Boise, Idaho 83102
Telephone: [phone]
Fax: [phone]
peter@richardsonadams. com
[e-mail]
Attorneys for Complainant Black Mesa Energy, LLC
BEFORE THE
IDAHO PUBLIC UTILITIES COMMISSION
BLACK MESA ENERGY, LLC,
Complainant,Case No. IPC-E-20-17
)
)
)
)
)
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)
VS
IDAHO POWER COMPANY,
Defendant.
MOTION TO EXTEND TIME
1 INTRODUCTION
2 On March 17 ,2020, Black Mesa Energy, LLC ("Black Mesa") filed a formal complaint
3 against the ldaho Power Company ("ldaho Power" or the "Company") with the Idaho Public
4 Utilities Commission (the "Commission" or "IPUC") pursuant to ldaho Administrative Rule
5 31.01.01.054. On Ãpnl2,2020, the Commission issued a summons to Idaho Power. On April
6 23,2020, ldaho Power filed its Answer and Motion to Dismiss.
7 Pursuant to ldaho Administrative Rule 21.01.01.057.03, answers (or motions for additional
8 time) to motions must be filed within fourteen days after the original motion is filed.
9 Given the complexity of the issues involved and the disruption to normal business operations
l0 due to the Govemor's quarantine orders, Black Mesa respectfully requests additional time in
Page I - Motion of Black Mesa Energy, LLC to Extend Time
RECEIVED
2020 April 28,PM5:03
IDAHO PUBLIC
UTILITIES COMMISSION
I which to lodge its answer to ldaho Power's Motion. Currently an answer is due on May ],2020.
2 Black Mesa seeks just an additional eight days, until May 15,2020, in which to lodge its answer.
3 Black Mesa has contacted counsel for Idaho Power and the ldaho PUC regarding its
4 requested extension of time. Counsel for Idaho Power responded via telephone that the Power
5 Company has no objection to an extension of time until May 15,2020. Counsel for the ldaho
6 PUC represented by email that "staff would look at the reasons stated therein and the applicable
7 Rules and determine whether it supports the motion."
8 Black Mesa represents that no party will be prejudiced by granting its motion for
9 additional time and believes the Commission's interest in complete and thorough responses will
l0 be furthered by the same. In order to provide it with adequate time in which to reply to ldaho
I I Power's Motion to Dismiss, Black Mesa therefore respectfully requests the Commission issue an
12 order approving an extension of time for said reply not to be due until May 15.2020.
Respectfully submitted this 28th day of April2020,
Peter J. Richardson (ISB No. 3195)
Richardson Adams, PLLC
CERTIFICATE OF SERVICE
I HEREBY certify that I have on this 28th day of April, 2020,I served the foregoing
MOTION TO EXTEND TIME OF BLACK MESA LLC, in Case IPC-E-20-ll, by electronic
mail to the following:
Diane Hanian
Idaho PUC Secretary
Di ane. hani an@,puc.idaho. so v
Edward Jewell, Deputy Attorney General
Donovan Walker
Senior Counsel, ldaho Power Company
dwalker@idahopower. com
dockets@idahopower. com
Page 2 - Motion of Black Mesa Energy, LLC to Extend Time