BEFORE THE PUBLIC SERVICE COMMISSION
OF THE 
STATE OF MISSOURI

COCHRAN DEVELOPMENT INC.	)
d/b/a EXPRESSWAYS FOOD SHOPS	)
						)
	Complainant, 			)
						)	Case No.:  EC-2005-0004
vs.						)
						)
AQUILA, INC.				)
						)
	Respondent.				)

MOTION FOR ADDITIONAL TIME 
TO RESPOND TO SHOW CAUSE ORDER

	COMES NOW Cochran Development Inc., b/d/a Expressways Food Shops and hereby requests an additional three (3) business days with which to respond to the “Order Directing Filing” entered on the 31st day of August, 2004 by the Public Service Commission.  In support thereof, Cochran Developement Inc., states as follows:
	1.  The Commission’s “Order Directing Filing” was entered August 31, 2004.  Such order directed Cochran Development Inc. to show cause why the Motion to Dismiss filed by Aquila should not be granted.  The Commission gave Cochran Development Inc. until September 14, 2004, at 4:00 p.m. to file such pleading.  
	2.  The Commission’s Order directed Cochran to “set out in it’s pleading an explanation of just how Aquila’s calculation of underpayment, if any, is erroneous.”  Cochran was further directed to “include it’s own calculation of the underpayment, or otherwise explain it’s justification of the underpayment amount that it believes is reasonable under the circumstances.”
	3.  The aforementioned order was not received by counsel for Cochran until Tuesday, September 7, 2004.  Due to counsel’s court schedule during the week of September 7, 2004, as well as other business obligations of counsel that same week, a response to the Commission’s order was prepared until Monday, September 13, 2004.  
	4.  Counsel is now awaiting verification from his client as to the correctness of the calculations regarding underpayment.  Counsel believes that such verification can and will be obtained by Friday, September 17, 2004, at 4:00 p.m.
	WHEREFORE, Cochran Development Inc. prays that the Public Service Commission extend the time set forth in it’s prior Order Directing Filing such as to allow to Cochran Development Inc. until Friday, September 17, 2004, at 4:00 p.m. to file it’s response. 

							COCHRAN DEVELOPMENT INC. 

							_________________________________
							BY: 	John  H. Edmiston    (31205)
                                 					118 Hout Street, Suite A
                                 					Warrensburg, MO 64093
                                 					Tel: (660) 747-9141
                                 					Fax: (660) 747-7177
                                 					ATTORNEY FOR COCHRAN
								DEVELOPMENT INC.

STATE OF MISSOURI 	)	
                  			)SS.
COUNTY OF JOHNSON 	)
	
JOHN H. EDMISTON being duly sworn upon his oath states he executed the above and foregoing Motion for Additional Time and that the matters therein stated are true according to his best information and belief.

							_____________________________
							JOHN H. EDMISTON

	Subscribed and sworn to before me this ______ day of September, 2004.

                                 				____________________________
                                 				NOTARY PUBLIC

My Commission Expires:

CERTIFICATE OF SERVICE

The undersigned certifies
that on the ____ day of
September, 2004, a copy of the
above was faxed to: 

Mr. Dean L. Cooper
BRYDON, SWEARENGEN & ENGLAND P.C.
312 E. Capitol Avenue
Jefferson City, MO 65102      
(573) 635-3847