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Home My WebLink About20030529Motion for Hearing.pdft(ECEIVED ::- 1 r:- f' L" Robert C. Huntley ISB #894 HUNTLEY PARK LLP 250 So. Fifth Street, Suite 660 O. Box 2188 Boise, Idaho 83701 Telephone: 208-388-1230 Facsimile: 208-388-0234 2003 r'1.f\ Y 27 PM 4: 52 urIL iESJ CO /;11,isION Attorneys for Plaintiff ORIGINAL BEFORE THE IDAHO PUBLIC UTILITIES COMMISSION DEL RAY HOLM Case No. P AC-03- Petitioner MOTION FOR EXPEDITED HEARING vs. UTAH POWER & LIGHT COMPANY /P ACIFICORP Respondent. COMES NOW Del Ray Holm by and through his attorney, Robert C. Huntley, and requests an emergency telephonic hearing on Wednesday, May 28th, 2003 , to deal with the matter raised in the affidavit of Del Ray Holm attached hereto as Appendix A and made a part hereof as though fully set forth herein. DATED this 27th day of May, 2003.~il JI~ Robert C. Huntley Motion For Expedited Hearing - CERTIFICATE OF SERVICE I HEREBY CERTIFY that on the 27th day of May, 2003 , a true and correct copy of the foregoing document was served on the below listed individuals by the method indicated below: Mary S. Hobson STOEL RNES 101 South Capitol Blvd., Suite 1900 Boise, ill 83702 Fax: 389-9040 Hand Delivered US. Mail Overnight Mail-L Facsimile John M. Eriksson STOEL RNES One Utah Center 201 S. Main St. Suite 1100 Salt Lake City, UT 84111 Fax: 801-578-6999 Hand Delivered - U.S. Mail Overnight Mail-L Facsimile Scott Woodbury IPUC: 334-3762 ~~f1 Robert C. Huntley Motion For Expedited Hearing - 2 Robert C. Huntley ISB #894 HUNTLEY PARK LLP 250 So. Fifth Street, Suite 660 O. Box 2188 Boise, Idaho 83701 Telephone: 208-388-1230 Facsimile: 208-388-0234 Appendix Attorneys for Plaintiff BEFORE THE IDAHO PUBLIC UTILITIES COMMISSION DEL RAY HOLM Case No. P AC-03- Petitioner AFFIDAVIT OF DEL RAY HOLM RE REQUEST FOR EMERGENCY TELEPHONIC HEARINGvs. UTAH POWER & LIGHT COMPANY /P ACIFICORP Respondent. STATE OF IDAHO ss. County of DEL RAY HOLM being first duly sworn, deposes and says: Due to non-cooperation of Utah Power I am about to have crops of a value of approximately $52 000 go without water and be burned up and destroyed within the next week. I requested that Utah Power install the underground lines and transformers for the facilities in the matter under consideration in this case. I offered to take the existing lines down using a local contractor who will do it for $600 and the Power Company is refusing that effort to expedite the work. More importantly, the Company representative has advised me that it will be 6 to AFFIDAVIT OF DEL RAY HOLM RE REQUEST FOR EMERGENCY TELEPHONIC HEARING - 8 weeks before it will have transformers available. There are transformers available in the local market for installation tomorrow, but the Company refuses to use any transformers other than those which it procures exclusively from General Electric. I desire to have the system installed in the next 2 days with a competent and licensed electrical contracting company and request an order from the PUC that if! do so, that Utah Power will be required to energize the system. I have personal knowledge of the fact that Ricks College in Rexburg has recently completed the construction of an entire substation with outside contractors which Utah Power is agreeing to energize and place into service upon its completion. My installation is certainly much simpler than the construction of a substation. I request an emergency telephone hearing on Wednesday or Thursday, May 28th or 29th, to require Utah Power to energize my system after I get it constructed within this current week. Further sayeth affiant naught. DATED this _th day of May, 2003. Del Ray Holm SUBSCRIBED and sworn to before me this day of May, 2003. Notary Public for Idaho Residing at My Commission Expires AFFIDAVIT OF DEL RAY HOLM RE REQUEST FOR EMERGENCY TELEPHONIC HEARING - 2 CERTIFICATE OF SERVICE I HEREBY CERTIFY that on the _day of May, 2003 , a true and correct copy of the foregoing document was served on the below listed individuals by the method indicated below: Mary S. Hobson STOEL RNES 101 South Capitol Blvd., Suite 1900 Boise, ID 83702 Fax: 389-9040 Hand Delivered - U.S. Mail Overnight Mail-L Facsimile John M. Eriksson STOEL RNES One Utah Center 201 S. Main St. Suite 1100 Salt Lake City, UT 84111 Fax: 801-578-6999 Hand Delivered - U.S. Mail Overnight Mail-L Facsimile Scott Woodbury, IPUC 334-3762 Robert C. Huntley AFFIDAVIT OF DEL RAY HOLM RE REQUEST FOR EMERGENCY TELEPHONIC HEARING - 3