20211008Appellant Motion for Extension of Time.pdf

APPELLANT COLEMAN HYDROELECTRIC, LLC’S UNOPPOSED MOTION FOR
EXTENSION OF TIME TO FILE APPELLANT’S BRIEF - 1
Gregory M. Adams (ISB No. 7454)
Peter J. Richardson (ISB No. 3195)
Richardson Adams, PLLC
515 N. 27th Street
Boise, Idaho 83702
Telephone: [phone]
Fax: [phone]
[e-mail]
[e-mail]

Attorneys for Petitioner-Appellant Coleman Hydroelectric, LLC

IN THE SUPREME COURT OF THE STATE OF IDAHO

In the Matter of the Application of Idaho Power
Company for approval or rejection of an energy
sales agreement with Coleman
Hydroelectric LLC, for the sale and
purchase of electric energy from the
Coleman Hydro Project.

COLEMAN HYDROELECTRIC, LLC
Petitioner-Appellant,

v.

IDAHO PUBLIC UTILTIES COMMISSION
Respondent-Respondent on Appeal,
and
IDAHO POWER COMPANY,
Intervenor, Respondent.

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APPELLANT COLEMAN
HYDROELECTRIC, LLC’S UNOPPOSED
MOTION FOR EXTENSION OF TIME TO
FILE APPELLANT’S BRIEF

Supreme Court Docket No. 48812-2021

Public Utilities Commission No.
IPC-E-20-27

Pursuant to Idaho Appellate Rules 32 and 34(d), Appellant Coleman Hydroelectric, LLC
respectfully moves for an extension of time of 35 days for the due date to file Appellant’s Brief,
which would move the due from October 14, 2021, to November 18, 2021.
This Motion is supported by the concurrently filed Affidavit of Gregory M. Adams,
which addresses the eight factors set forth in Idaho Appellate Rule 34(d). As stated in the
Electronically Filed10/8/2021 2:05 PMIdaho Supreme CourtMelanie Gagnepain, Clerk of the CourtBy: Brad Thies, Deputy Clerk
APPELLANT COLEMAN HYDROELECTRIC, LLC’S UNOPPOSED MOTION FOR
EXTENSION OF TIME TO FILE APPELLANT’S BRIEF - 2
Affidavit, the requested extension is intended to preserve the status quo while the parties
complete settlement discussions that could ultimately obviate the need for the Court to address
the merits of this appeal. Additionally, because Appellant’s Brief is nearly complete, it will be
filed promptly should it ultimately be necessary for the appeal to move forward. Counsel for the
only other parties to this appeal, Respondent Idaho Public Utilities Commission and Intervenor-
Respondent Idaho Power Company, have each communicated to the undersigned via email that
those parties do not oppose this requested extension of time.
For the reasons set forth above and in the supporting Affidavit, Appellant Coleman
Hydroelectric, LLC respectfully moves the Court for an order granting an extension of time of 35
days to file Appellant’s Brief, from October 14, 2021 to November 18, 2021.
DATED: October 8, 2021.

/s/ Gregory M. Adams
Gregory M. Adams (ISB No. 7454)
Peter J. Richardson (ISB No. 3195)
Richardson Adams, PLLC
515 N. 27th Street
Boise, Idaho 83702
Telephone: [phone]
Fax: [phone]
[e-mail]
[e-mail]

Attorneys for Petitioner-Appellant
Coleman Hydroelectric, LLC

APPELLANT COLEMAN HYDROELECTRIC, LLC’S UNOPPOSED MOTION FOR
EXTENSION OF TIME TO FILE APPELLANT’S BRIEF - 3
CERTIFICATE OF UNCONTESTED MOTION

The undersigned does hereby certify that he has contacted opposing counsels and is
authorized to represent that opposing counsels have no objection to this motion.

Dated and Certified this 8th day of October, 2021.

/s/ Gregory M. Adams
Gregory M. Adams (ISB No. 7454)
Peter J. Richardson (ISB No. 3195)
Richardson Adams, PLLC
515 N. 27th Street
Boise, Idaho 83702
Telephone: [phone]
Fax: [phone]
[e-mail]
[e-mail]

Attorneys for Petitioner-Appellant
Coleman Hydroelectric, LLC

APPELLANT COLEMAN HYDROELECTRIC, LLC’S UNOPPOSED MOTION FOR
EXTENSION OF TIME TO FILE APPELLANT’S BRIEF - 4
CERTIFICATE OF SERVICE

The undersigned hereby certifies that on this 8th day of October, 2021, a true and correct copy of
the foregoing 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