Reed T. Warnick
Paul H. Proctor
Assistant Attorneys General
160 East 300 South, 5
th Floor
PO Box 140857
Salt Lake City, UT 84114-0857
Telephone: 801-366-0552
Facsimile: 801-
Attorneys for Utah Committee of Consumer Services

 

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BEFORE THE PUBLIC SERVICE COMMISSION OF UTAH

IN THE MATTER OF THE APPLICATION OF UINTAH BASIC TELECOMMUNICATIONS ASSOCIATIONI, INC. AND UBET TELECOM, INC.

DOCKET NO. 04-053-03

 

MOTION FOR EXTENSION OF TIME WITHIN WHICH TO FILE TESTIMONY AND MOTION FOR RESCHEDULING OF HEARING`

________________________________________________________________________

 

Under the provisions of the Utah Code Title 54, Chapter 7, and the provisions of the Public Service Commission Administrative Rules, Rule R746-100-10, the Utah Committee of Consumer Services (Committee) respectfully requests that if necessary as explained below, the Public Service Commission of Utah (Commission) extend to November 24, 2004, the time within which the Committee may file its responsive testimony, and extend to December 3, 2004, the time within which rebuttal testimony may be filed. Further, the Committee requests that the hearing upon this Application be rescheduled to December 10, 2004. The good cause for granting these requests follows.

1. In recent weeks, the applicants Uintah Basin Telecommunications Association and UBET Telecom, the Division of Public Utilities (Division) and the Committee have engaged in good-faith discussions and negotiations of a stipulation that could jointly be submitted to the Commission, recommending the terms and conditions for an order approving the combination of these telecommunication utilities. The Committee is hopeful that ongoing negotiations will be successful and that the stipulation can be presented at the November 22, 2004 hearing, as currently scheduled.

2. Discussions up to date have, however, revealed some differences that must be discussed internally in an effort to continue negotiations. If these issues prove to be barriers to a stipulation, then the Committee and possibly the Division will be unable to prepare testimony upon those issues that remain in dispute as well as delineate those issues that have been resolved.

3. In addition, the applicants responded to the Committee and Division’s most recent proposal only late this morning. The applicants’ response is also conditional as their counsel has not reviewed nor approved it.

4. Accordingly, in the event that the parties’ negotiations do not culminate in a stipulation that resolves all currently disputed issues, the Committee requests additional time as stated above, within which it can prepare testimony.

Dated this 3rd day of November 2004.

 

Paul H. Proctor Assistant Attorney General

/s/ Paul H. Proctor
Attorney for Utah Committee of Consumer Services

 

CERTIFICATE OF SERVICE

I hereby certify that a true and correct copy of the foregoing was served by email or US Mail, postage prepaid, this 3rd day of November 2004, on the following:

Michael Ginsberg
Patricia Schmid
ASSISTANT ATTORNEY GENERAL
Division of Public Utilities
500 Heber M. Wells Building
160 East 300 South
Salt Lake City, UT 84111

mginsberg@utah.gov

pschmid@utah.gov

Stanley K. Stoll
Blackburn & Stoll, LC
257 East 200 South, Suite 800
Salt Lake City, Utah 84111
sstoll@blackburn-stoll.com

Paul H. Proctor Assistant Attorney General

/s/ Paul H. Proctor
Attorney for Utah Committee of Consumer Services