Thomas J . Keuler James A. Sigler David L. Kelly Theodore S . Hutchins * Stacey A. Blankensh ip Robert W. Goff ** Kristen N . Worak Le ley A. Owen * Judy K. Payne *** James P. Landry

• Also Licensed to Practice in Illinois •• Also Licensed to Practice in Illinois & Tennessee *** Also Licensed to Practice in Missouri

November 7, 20 I 8

VIA FEDEX

Ill

PUBLIC SERVICE COMMISSION 21 I SOWER BLVD FRANKFORT, KY 40602

Re: Paducah Water Works Rate Filing

Dear Commission:

Keuler, Kelly, Hutchins, Blankenship

& Sigler, LLP -ATTORNEYS-

100 South 4th Street, Suite 400 Paducah, KY 4200 I

p. (270) 448-8888 f . (270) 448-0998

www.kkhblaw.com

RECEIVED NOV 0 8 2018

PUBLIC SERVICE COMMISSION

Enclosed please find a Motion for Extension of Time to Commission Staffs Initial Request for Information to Joint Applicants, Joann Estates Utilities, lnc. and Paducah-McCracken County Joint Sewer Agency.

J have enclosed an original of the Application and I 1 copies. I wou ld ask that you file-stamp one copy and return it to me in the enc losed self-addressed, prepaid envelope. If you need any further information or have any questions, please do not hesitate to contact me.

Sincerely,

rgoff@kkhblaw.com 2220 10

222003

COMMONWEALTH OF KENTUCKY BEFORE THE PUBLIC SERVICE COMMISSION

RECEIVED NOV 0 8 2018

In the Matter of: PUBLIC SERVICE

COMMISSION

JOINT PETITION OF JOANN ESTATES UTILITIES, INC. AND PADUCAH-McCRACKEN COUNTY JOINT SEWER AGENCY TO APPROVE THE TRANSFER OF WASTEWATER COLLECTION SYSTEMS SERVING THE WILMINGTON CHILES AND JOANN ESTATES SUBDIVISIONS IN McCRACKEN COUNTY, KENTUCKY

} } } } } } } } }

CASE NO. 2018-00347

MOTION FOR EXTENSION OF TIME

Petitioners hereby move for an extension of time to provide responses to Commission

Staffs Initial Request for Information to Joint Applicants, Joann Estates Utilities, Inc. and

Paducah-McCracken County Joint Sewer Agency. As grounds therefore, Petitioners state that the

responses are complete and have been verified by John Hodges at Paducah-McCracken County

Joint Sewer Agency but have not yet been verified by Brian Waid on behalf of Joann Estates

Utilities, Inc. Petitioners also need to obtain from Brian Waid legible copies of an exhibit to the

responses. Petitioners diligently collected the information requested by Commission staff. Brian

Waid is. a Federal Express delivery driver with an inflexible seasonal work schedule who is only

off on Sundays and Mondays. Petitioners expect to have the responses verified by Iylonday,

November 12,2018 for filing with the Commission by Tuesday, November 13,2018.

Wherefore, the Petitioners respectfully request that the Commission modify its Order

setting the procedural schedule and allow them up to and including Tuesday, November 13, 2018

to file responses to the Commission Staffs Initial Request for Information to Joint Applicants,

Joann Estates Utilities, Inc. and Paducah-McCracken County Joint Sewer Agency.

l hereby certify that a true and correct copy ofthe foregoing has been served via Federal Express to:

GWEN R. PINSON EXECUTIVE DIRECTOR

Respectfully submitted ,

KEULER, KELLY, HUTCHINS. BLANKENSHIP & SIGLER, LLP 100 SOUTH 4TH STREET, SUITE 400 PADUCAH, KY 4200 1 Telephone: (270) 448-8888 Facsimi le: (270) 448-0998

By~~ ft~off rgoff@kkhblaw.com

ATTORNEYS FOR JSA AND JOANN ESTATES WITH RESPECT TO THEIR APPLICATION

KENTUCKY PUBLIC SERVICE COMMISSION 211 SOWER BLVD. FRANKFORT KY 40602

on thi s 7th day ofNovember, 2018.