20211008Appellant Affidavit ISO Motion for Extension of Time.pdf

Gregory M. Adams (ISB No. 7454)
Peter Richardson (ISB No. 3195)
Richardson Adams, PLLC
515 N. Street
Boise, Idaho 702
Telephone: [phone]
Fax: [phone]
[e-mail]
[e-mail]
Attorneys for Petitioner-Appellant Coleman Hydroelectric, LLC
IN THE SUPREME COURT OF THE STA TE OF IDAHO
In the Matter the Application Idaho Power) AFFIDAVIT OF GREGORY ADAMS IN
Company for approval rejection an energy) SUPPORT OF APPELLANT COLEMAN
sales agreement with Coleman
Hydroelectric LLC, for the sale and
purchase electric energy from the
Coleman Hydro Project.
HYDROELECTRIC, LLC
Petitioner-Appellant,
v.
IDAHO PUBLIC UTIL TIES COMMISSION
Respondent-Respondent on Appeal,
and
IDAHO COMPANY,
Intervenor, Respondent.
) HYDROELECTRIC, LLC'S UNOPPOSED
) MOTION FOR EXTENSION OF TIME TO
) FILE APPELLANT'S BRIEF
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Supreme Court Docket No. 48812-2021
Public Utilities Commission No.
IPC-E-20-27
~~~~~~~~~~~~~~~~)
ST A OF IDAHO, )
) SS.
County Ada )
Gregory Adams, being first duly sworn on oath, depose and say:
AFFIDAVIT ADAMS IN
FILE
BRIEF -1
Electronically Filed10/8/2021 2:05 PMIdaho Supreme CourtMelanie Gagnepain, Clerk of the CourtBy: Brad Thies, Deputy Clerk
l. I am the attorney of record for Appellant Coleman Hydroelectric, LLC. I have personal
knowledge of the matters set forth herein, and I make this Affidavit in support of the
contemporaneously filed Appellant's Motion for Extension of Time to File Appellant's Brief.
2. In accordance with Idaho Appellate Rule 34( d), I state the following:
l) Appellant's Brief is due October 14, 202 l.
2) No previous requests for extension of the due date for Appellant's Brief have
been requested or granted.
3) No previous requests for extension of the due date for Appellant's Brief have
been requested or denied.
4) An extension of time to file Appellant's Brief is requested with the intent of
preserving the status quo while the parties complete settlement discussions which
could ultimately obviate the need for the Court to address the merits of this
appeal. In addition to preserving the status quo, the requested extension would
allow Appellant to avoid expending additional time and resources on completion
of Appellant's Brief while the parties engage in such discussions.
5) Appellant requests an extension of 35 days, which would make Appellant's Brief
due by November 18, 2021.
6) The parties have not executed a formal stipulation with respect to Appellant's
Motion for Extension of Time to File Appellant's Brief.
7) Attorney for Respondent Idaho Public Utilities Commission, John R. Hammond,
Jr., and attorney for Intervenor-Respondent Idaho Power Company, Donovan E.
Walker, have each communicated via email to the undersigned attorney that those
parties do not oppose this requested extension of time.
AFFIDAVIT OF GREGORY M. ADAMS IN SUPPORT OF APPELLANT COLEMAN
HYDROELECTRIC, LLC'S UNOPPOSED MOTION FOR EXTENSION OF TIME TO FILE
APPELLANT'S BRIEF -2
8) Appellant's Brief is nearly complete and will be filed promptly should it
ultimately be necessary for the appeal to move forward.
FURTHER YOUR AFFIANT SA YETH .
y M. Adams (ISB No. 7454)
SUBSRIBED AND SWOR me is 1i~ay of October 2021 .
Julie · st ·
Nota y Public fort .e State of Idaho
Residing at ~ \.A t'\..c-. I>/
My Commission expires \t;\ri-lf \&2:->
AFFIDAVIT OF GREGORY M. ADAMS IN SUPPORT OF APPELLANT COLEMAN
HYDROELECTRIC, LLC'S UNOPPOSED MOTION FOR EXTENSION OF TIME TO FILE
APPELLANT'S BRIEF -3

CERTIFICATE OF SERVICE

The undersigned hereby certifies that on this 8th day of October, 2021, a true and correct copy of
the foregoing AFFIDAVIT OF GREGORY M. ADAMS IN SUPPORT OF APPELLANT
COLEMAN HYDROELECTRIC, LLC’S UNOPPOSED MOTION FOR EXTENSION OF
TIME TO FILE APPELLANT’S BRIEF were served upon opposing counsel as follows:

JOHN R. HAMMOND, JR. (ISB No. 5470 )
Deputy Attorney General
Idaho Public Utilities Commission
P.O. Box 83720
Boise, Idaho 83720-0074
Telephone: [phone]
Fax: [phone]
Email: [e-mail]

DONOVAN E. WALKER (ISB No. 5921)
Idaho Power Company
1221 West Idaho Street (83702)
P.O. Box 70
Boise, Idaho 83707
Telephone: [phone]
Fax: [phone]
Email: [e-mail]

_____ US Mail
_____ Personal Delivery
X Email/I-Court

_____ US Mail
_____ Personal Delivery
X Email/I-Court

By: /s/ Gregory M. Adams
Gregory M. Adams (ISB No. 7454)
Attorney for Petitioner-Appellant