Control Number : 38354
Item Number : 980
Addendum StartPage: 0
SOAH DOCKET NO. 4'^^,^^^'^
PUC DOCKET NO .'3934
I . ' . k'25 AM 9:04
APPLICATION OF LCRA
TRANSMISSION SERVICES
CORPORATION TO AMEND ITS
CERTIFICATE OF CONVENIENCE
AND NECESSITY FOR THE PROPOSED
MCCAMEY D TO KENDALL TO
GILLESPIE 345-KV CREZ
TRANSMISSION LINE IN
SCHLEICHER, SUTTON, MENARD,
KIMBLE, MASON, GILLESPIE, KERR
AND KENDALL COUNTIES, TEXAS
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^LyEi^^l^'`hOFFICE
OF
ADMINISTRATIVE HEARINGS
MOTION TO INTERVENE OF STONEHENGE STAR PROPERTIES, L.P.
Stonehenge Star Properties, L.P. ("SSP"), pursuant to P.U.C. PROC. R. §§22.103 and
22.104, files this Motion to Intervene in the above-referenced proceeding and in support thereof
would respectfully show:
1.
IDENTITY OF INTERVENOR
The name and address of SSP and its representative is as follows:
Stonehenge Star Properties, L.P.
c/o Geoffrey Perrin
4400 Post Oak Parkway, Suite 2550
Houston, Texas 77027
II.
LEGAL REPRESENTATIVE
The name and contact information of SSP's authorized legal representative is as
follows:
MOTION TO INTERVENE OF STONHENGE STAR PROPERTIES, L.P.
PAGE 1
L? rv
Robert G. Hargrove
Texas Bar No. 24032391
Hays & Owens, LLP
807 Brazos Street, Suite 500
Austin, Texas 78701
(512) 472-3993
(512) 472-3883 - Fax
rob.har rovea,haysowens.com
SSP requests that all pleadings, orders, correspondence, discovery and filings be served on its
legal representative in Austin.
III.
BASIS FOR INTERVENTION
Stonehenge Star Properties, L.P. has been identified by Applicant LCRA Transmission
Services Corporation as a directly affected landowner and therefore has a justiciable interest
which may be adversely affected by the outcome of this proceeding. Stonehenge Star
Properties, L.P. is therefore entitled to intervene in this proceeding.
This motion to intervene is timely filed within 30 days of the filing of the application, in
accordance with P.U.C. ROC. R. 22.104(b).
IV.
CONCLUSION AND PRAYER
THEREFORE, Stonehenge Star Properties, L.P. respectfully requests that this Motion to
Intervene be granted, that Stonehenge Star Properties, L.P. be allowed to participate as a party
to this proceeding, and for such further relief to which they may be entitled.
MOTION TO INTERVENE OF STONHENGE STAR PROPERTIES, L.P.
PAGE 2
Respectfully submitted,
HAYS & OWENS, LLP
Robert G. Hargrove
Texas Bar No. 24032391
807 Brazos Street, Suite 500
Austin, Texas 78701
(512) 472-3993
(512) 472-3883 - Fax
[email protected]
B Y:
-/1 ^ L
Robert G. Hargrove
ATTORNEYS FOR STONEHENGE STAR
PROPERTIES, L.P.
CERTIFICATE OF SERVICE
I hereby certify that on this the 25th day of August, 2010, a true and correct copy of the
foregoing document is being served pursuant to Orders Nos. 1 and 2 in this docket [Doc.565
and 563].
By:
n ^^obert G. Hargrove
MOTION TO INTERVENE OF STONHENGE STAR PROPERTIES, L.P.
PAGE 3