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Home My WebLink About20110727Protective Agreement.pdfPROTECTIVE AGREEMENT RECEIVED BETWEEN IDAHO POWER COMPANY, STAFF, & INTEllN~òt0RS CASE NO. IPC-E-II-08 L 27 PH 1.: 22 IJ Ti L Î,' Li1A.jLJ 0¿ .ir'" This Protective Agreement is entered as of the i day of Junv .:ò 201 Idaho Power Company ("Idaho Power"), the IdaIo Public Utilities Commission Staff ("Staff), and the undersigned Interenors in Case No. IPC-E-ll-08 (hereinafter collectively refered to as the "Paries" or individually as a "Pary") in connection with Idaho Power's 2011 Idaho General Rate Case. RECITALS: 1. WHEREAS, Idaho Power desires to make available to the Parties cerain information respecting Idaho Power's Application for authority to increase its rates and charges for electric serice to its customer in the state of Idaho. 2. WHEREAS, the Paries desire to receive such information. 3. WHEREAS, Idaho Power and the Paries anticipate that Idaho Power may provide, or make available for review, certain information considered by Idaho Power to be of a trade secret, privileged, or confidential nature (as defined in Idaho Code § 9-340, et seq., and § 48-801, et seq.). 4. WHEREAS, Idaho Power and the Paries agree that enterng into a Protective Agreement wil expedite the production of documents; wil afford the necessar protection to Idaho Power's and the Paries' employees and/or representatives in this proceeding who might review the information and subsequently be requested to reveal its contents by setting forth clear cut parameters for use of Confidential Information, and will protect Confidential Information which might be provided hereafter. IT IS HEREBY STIPULATED AND AGREED AS FOLLOWS: 1. (a) Confidential Information. All documents, data, information, studies, and other materals furnished that are claimed to be of trade secret, proprietar, or confidential natue (herein refered to as "Confidential Information") shall be so marked by Idaho Power by stamping the same with a designation indicating its trade secret, proprietar, or confidential natue and printed on yellow paper. Any claim of confidentiality must be accompanied by an attorney's cerificate that the PROTECTIVE AGREEMENT BETWEEN IDAHO POWER COMPANY, STAFF, & INTERVENORS - 1 materal is protected by law from public disclosure and cite the specific legal authority to support the claim. IDAPA 31.01.01.067 and 31.01.01.233. Access to and review of Confidential Information shall be strctly controlled by the terms of this Agreement. (b) Use of Confidential Information. All perons who may be entitled to review or who are afforded access to any Confidential Information by reason of this Agreement shall neither use nor disclose the Confidential Information for purposes of business or competition or any purose other than the purose of preparation for and conduct of Case No. IPC-E-Il-08 and then solely as contemplated herein and shall keep the Confidential Information secure as trade secret, confidential, or proprietar information and in accordance with the purposes and intent of this Agreement. (c) Persons Entitled to Review. Individual access to Confidential Information shall be limited to counsel of the undersigned Paries, employees, expers, agents, or representatives of the undersigned Paries who have executed an Exhibit A to this Agreement. Such information wil be clearly marked and protected from unauthorized public disclosure. (d) Nondisclosure Agreement. Confidential Information shall not be disclosed to any peron who has not signed a nondisclosure agreement on this form, which is attached hereto as Exhibit A and incorporated herein. The nondisclosure agreement or Exhibit A shall require the person to whom disclosure is to be made to read a copy of this Protective Agreement and to cerify in writing that he or she has reviewed the same and has consented to be bound by its ters. The Agreement shall contain the signatory's full name, permanent address, and employer. (e) Challenge to Company Denial of Access. Any disputes arsing as a result of Idaho Power's denial of access to Confidential Information shall be resolved by the Idaho Public Utilties Commission ("Commission"). 2. (a) Copies. No copies or transcriptions of the Confidential Information shall be made by the Paries except as necessary to make the information available to individuals who have executed an Exhibit A to this Protective Agreement. PROTECTIVE AGREEMENT BETWEEN IDAHO POWER COMP AN, STAFF, & INTERVENORS - 2 (b) Return of Confidential Information. Upon request of Idaho Power, all original documents and copies of the Confidential Information shall be (l) returned to Idaho Power or (2) shredded by the holder of such documents. Unless otherwise ordered, Confidential Information, including transcripts of depositions containing information to which a claim of confidentiality is made, shall remain under seal, shall continue to be subject to the protective requirements of this Agreement, and shall likewise, be returned to counsel for Idaho Power within thirty (30) days after final settlement or conclusion of the proceedings before the Commission which Confidential Information is relevant, including administrative or judicial review thereof. After return of documents puruant to this paragraph, and upon request, a written receipt verfyng retu shall be provided by counseL. (c) Return of Notes. Any notes maintained by a recipient of Confidential Information which embody or reflect any of the Confidential Information provided under this Agreement shall, upon request of Idaho Power, be either returned to Idaho Power or, at the option of the recipient, destroyed. 3. Non-waiver of Objection to Admissibilty. The fuishing of any document, information, data, study, or other materals pursuat to this Protective Agreement shall in no way limit or waive the right of the providing Pary to object to its relevance or admissibilty in any proceedings before this Commission. 4. Challenge to Confidentiality. (a) Initial Challenge. This Protective Agreement establishes a procedure for the expeditious handling of information Idaho Power claims is confidentiaL. In any proceeding before the Commission, a Pary may challenge the characterzation of any information, document, data, or study claimed by Idaho Power to be a trade secret, proprietar, or confidential information. If seeking to challenge the confidentiality of any information, the Pary shall first contact counsel for Idaho Power and attempt to resolve any difference by stipulation. Resolution may include removing the confidential classifications, creating a non-confidential summar, reformatting the information, etc. PROTECTIVE AGREEMENT BETWEEN IDAHO POWER COMPAN, STAFF, & INERVENORS - 3 (b) Subsequent Challenge. . In the event that the Paries canot agree as to the charcter of the information challenged, the Paries may challenge the confidentiality of the information by petitioning in any proceeding in which the information is relevant the Commission to rule upon the disputed information. The petition shall be sered upon the Commission and all pares to the proceeding who have signed on Exhibit A as provided in this Protective Agreement. The petition shall designate with specificity the document or materal challenged and state the grounds upon which the subject materal are deemed to be non-confidential by the Pary. (c) Challenge Hearing. The Paries shall request that the Commission conduct an in camera proceeing where only those perons duly authorized to have access to such challenged materals under this Protective Agreement shall be present. This hearng shall be commenced no earlier than five (5) business days after sering the petition on Idaho Power and the Commission. The recrd of the in camera hearng shall be marked "CONFIDENTIAL - Subject to Protective Agreement." To the extent necessar, the transcript of such hearng shall be separately bound, segregated, sealed, and withheld from public inspection by any peron not bound by the ters of this Agreeent. (d) Determiation. The Paries wil ask the Commission to issue an Order deterining whether any challenged information or materal is not properly deemed to be exempt from public disclosure pursuant to the Idaho Public Recrds Act. (Idaho Code § 9-335, et seq.) If information is found to be not exempt from disclosure, the Paries shall not disclose such challenged materal or use it in the public record, or otherise outside the proceedings for at least five (5) business days unless Idaho Power consents to such conduct. This procedure enables the providing Pary to seek a stay or other relief from the Commission's Order removing the restrctions of this Agreement from materal claimed to be confidentiaL. Such relief may be sought from the Commission or a court of competent jursdiction. 5. (a) Receipt Into Evidence. Provision is hereby made for receipt into evidence in this proceeding of materals claimed to be confidential in the following maner: PROTECTIVE AGREEMENT BETWEEN IDAHO POWER COMPANY, STAFF, & INTERVENORS - 4 (1) If a Pary intends to use Confidential Information or to make substantive reference to Confidential Information supplied to it under this Agreement, it shall give reasonable prior notice of such intention to Idaho Power and shall provide copies of the used Confidential Information or substantive reference to Confidential Information only to the providing Pary, and such other Paries, if any, who have executed an Exhibit A to this Protective Agreement. (2) One (l) copy of the used Confidential Information or substantive reference to Confidential Information described in paragraph 5(a)(1) shall be placed in the sealed record. (3) Only one (l) copy of the documents designated to be placed in a sealed record shall be made. (4) The copy of the documents to be placed in the sealed record shall be tendered to the Commission and shall be maintained in accordance with the ters of this Protective Agreement. (b) Seal. While in the custody of the Commission, materals containing Confidential Information shall be marked "CONFIDENTIAL -- SUBJECT TO ATTORNEY'S CERTIFICATE OF CONFIDENTIALITY" and shall not be examined by any person except under the conditions set forth in this Agreement, if applicable. (c) In Camera Hearing and Transcripts. Any Confidential Information that must be orally disclosed at a hearng in the proceedings shall be offered at an in camera hearng, attended only by perons authorized to have access to the information under this Protective Agreement. Similarly, any transcrption of any examination or other reference to Confidential Information (or that portion of the record containing Confidential Information) shall be marked and treated as provided herein for Confidential Information. See IDAPA 31.01.01.287. (d) Access to Record. Access to sealed testimony, records, and information shall be limited to the Commission and persons who have signed an Exhibit A as provided in this Protective Agreement, unless such information is released from the restrctions of this Agreement either PROTECTIVE AGREEMENT BETWEEN IDAHO POWER COMPANY, STAFF, & INERVENORS - 5 through agreement of the paries or after notice to the paries and hearng, pursuant to the order of the Commission and/or the final order of a cour having final jurisdiction. (e) Appeal. Should an appeal from the proceeding be taken, sealed portions of the record may be forwarded to any court of competent jurisdiction for purposes of an appeal, but under seal as designated herein for the information and use of the cour. If a portion of the record is forwarded to a cour under seal for the purses of an appeal, the providing Pary shall be notified which portion of the sealed record has been designated by the appealing pary as necessary to the record on appeaL. 6. Destruction or Return. Unless otherise ordered, Confidential Information provided pursuat to a discover request and this Agreement, including trscripts of any discover depositions to which a claim of confidentiality is made, shall remain under seal, shall continue to be subject to the protective requirements of this Agreement, and shall be destroyed or shall be returned to counsel for the providing Pary within thirty (30) days after final settlement or conclusion of this matter, including administrative or judicial review thereof. 7. Use in Pleadigs. Where references to Confidential Information in the sealed record or with the custodian is required in pleadings, briefs, arguments, or motions (except as provided in paragraph 5), it shall be by citation to title or exhibit number or some other descrption that wil not disclose the substantive Confidential Information contained therein. Any use of or substantive references to Confidential Information shall be place in a separate section of the pleading or brief and submitted to the Commission pursuat to pargraph 5. This sealed section shall be sered only on counsel of record who have signed the non-disclosure agreeents set forth in Exhibit A attached to this Protective Agreement and may, in turn, be disclosed by them only to individuals who likewise signed Exhibit A. 8. Summary of Record. If deeed necessar by the Commission, Idaho Power shall prepare a wrtten sumar of the Confidential Information refered to in Orders to be issued to the public and the paries. PROTECTIVE AGREEMENT BETWEEN IDAHO POWER COMPANY, STAFF, & INERVENORS - 6 9. Counterparts. This Agreement may be executed in two or more counterars, each of which shall be deemed an original but all of which together shall constitute one and the same instrent. 10. This Protective Agreement shall become effective on the date first above wrtten. DATED this it- day of .:unv 2011. IDAHO POWER COMPANY By: ~:. .£ t!~ ¿ iS NordstrnL Idaho Power Company 1221 West Idaho Street Boise, Idaho 83702 Attorney Representing Idaho Power Company IDAHO PUBLIC UTILITIES COMMISSION STAFF iLi"By: 'D~nA\& L. \-.Ql\, TI Deputy Attorney General Idaho Public Utilties Commission 472 West Washington Street Boise, Idaho 83702 (NAME) Attorney Representing Idaho Public Utilties Commission Staff PROTECTIVE AGREEMENT BETWEEN IDAHO POWER COMPANY, STAFF, & INTERVENORS - 7 IDAHO IRRGATION PUMPERS ASSOCIATION, INC. fic L. Olsen Attorney Representing Idaho Irrgation Pumpers Association, Inc. PROTECTI AGREEMENT BETWEN IDAHO POWER COMPANY, STAF, & INTERVENORS - 9 INDUSTRIAL CUSTOMERS OF IDAHO POWER By:tJÆ~ Peter J. Richardson Attorney Representing Industrial Customers of Idaho Power PROTECTIVE AGREEMENT BETWEEN IDAHO POWER COMPANY, STAFF, & INTERVENORS - 8 MICRON TECHNOLOGY, INC. By:~/~ Thorvald A. Nelson Attorney Representing Micron Technology, Inc. PROTECTIVE AGREEMENT BETWEEN IDAHO POWER COMPANY, STAFF, & INTERVENORS - 11 KROGER CO. ~By:rt J. Bõ Attorney Representing Kroger Co. PROTECTIVE AGREEMENT BETWEEN IDAHO POWER COMPANY, STAFF. & lNTERVENORS . 10 UNITED STATES DEPARTMENT OF ENER(;Y By: Arthur Perry Bruder J Attorney Representing United States Department of Energy ..l,~ 1\, MIl PROTECTIVE AGREEMENT BETWEEN IDAHO POWER COMPANY, STAFF, & INTERVENORS. J 2 IDAHO CONSERVATION LEAGUE By: ~~ Benjii Oto Attorney Representing Idaho Conseration League PROTECTE AGREEMEN BETWEN IDAHO POWER COMPANY, STAFF, & INRVENORS - 14 COMM AcrON ASTION oJ'mAHO PARTNHI BrD~~Bra M. Puy Att Repti Communty Acton Parp Asiaon of Ida PROT AGR BET IDAH POWE COMPAN, STAF, & INVEORS - 13 SNAKE RIVER ALLIANCE --- By: ':",,,_..~_. /ø'i/7¿.-G~_A .", Ken Miler Representing Snake River Alliance PROTECTIVE AGREEMENT BETWEEN IDAHO POWER COMPANY, STAFF. & INTERVENORS .15 EXHIBIT "A" I have reviewed the foregoing Protective Agreement dated June 2,2011 in Case No. IPC-E-II-08 and agree to be bound by the terms and conditions of such Agreement. JJ.1ß/9 Karl T. Klein Deputy Attorney General Idaho Public Utilties Commission Employer or Firm 472 W. Washington Street. Boise, Idaho 83702 Business Address Commission Staff Pary -JUA~ \t 1ÐC\ Date EXHIBIT "A" I have reviewed the foregoing Protective Agreement dated June 2, 201 i in Case No. IPC-E-I i -08 and agree to be bound by the tenns and conditions of such Agreement. Idaho Public Utilties Commission Employer or Firm 472 W. Washington Street. Boise, Idaho 83702 Business Address Commission Staff Pary ¿/3/ÆOI/i iDate EXHIBIT "A" I have reviewed the foregoing Protective Agreement dated June 2, 20 i 1 in Case No. IPC-E-II-08 and agree to be bound by the terms and conditions of such Agreement. Idaho Public Utilties Commission Employer or Firm 472 W. Washington Street, Boise, Idaho 83702 Business Address Commission StaffPar \2P1 \\ Date EXHIBIT "A" I have reviewed the foregoing Protective Agreement dated June 2, 20 i i in Case No. IPC-E- i i -08 and agree to be bound by the terms and conditions of such Agreement. /'~-;:~~~,V~ MARIL YN PA ER Idaho Public Utilties Commission Employer or Firm 472 W. Washington Street, Boise, Idaho 83702 Business Address Commission Staff Pary :JUvN ? i d- 0 it Date EXHIBIT "A" I have reviewed the foregoing Protective Agreement dated June 2, 20 i i in Case No. IPC-E- i i -08 and agree to be bound by the terms and conditions of such Agreement. u CURTIS THADEN Idaho Public Utilties Commission Employer or Firm 472 W. Washington Street, Boise, Idaho 83702 Business Address Commission Staf Part ::UN Date Q ,2..1(i EXHIBIT "A" I have reviewed the foregoing Protective Agreement dated June 2, 20 i i in Case No. IPC-E- i 1-08 and agree to be bound by the terms and conditions of such Agreement. j C ~~ ßJLLoc1 TERR CARLOCK Idaho Public Utilties Commission Employer or Firm 472 W. Washington Street, Boise, Idaho 83702 Business Address Commission Staff Pary ~) &)aoi)iDate EXHIBIT" A" I have reviewed the foregoing Protective Agreement dated June 2, 2011 in Case No. IPC-E-II-08 and agree to be bound by the terms and conditions of such Agreement. 6i.5~RICK TERLING Idaho Public Utilties Commission Employer or Firm 472 W. Washington Street, Boise, Idaho 83702 Business Address Commission Staff Pary 0/'(11Date EXHIBIT "A" I have reviewed the foregoing Protective Agreement dated June 2, 20 i i in Case No. IPC-E- i i -08 and agree to be bound by the terms and conditions of such Agreement. í?~d,- RANDY LOBB Idaho Public Utilties Commission Employer or Firm 472 W. Washington Street. Boise, Idaho 83702 Business Address Commission Staff Pary 61:3/ZOI( Date EXHIBIT" A" I have reviewed the foregoing Protective Agreement dated June 2, 2011 in Case No. IPC-E-II-08 and agree to be bound by the terms and conditions of such Agreement. ~~. KA - Idaho Public Utilties Commission Employer or Firm 472 W. Washington Street, Boise, Idaho Business Address Commission Staff Pary ;j~ ~ J.D(l Date EXHIBIT "A" ¡ have reviewed the foregoing Protective Agreement dated June 2, 20 i i in Case No. ¡PC-E- i i -08 and agree to be bound by the terms and conditions of such Agreement. ~.çJ EPHTERRY Idaho Public Utilties Commission Employer or Firm 472 W. Washington Street, Boise, Idaho 83702 Business Address Commission Sta Pary 'i J/ Zol f Date EXHIBIT "A" I have reviewed the foregoing Protective Agreement dated June 2, 2011 in Case No. IPC-E-II-08 and agree to be bound by the terms and conditions of such Agreement. Idaho Public Utilities Commission Employer or Firm 472 W. Washington Street, Boise, Idaho 83702 Business Address Commission Staff Pary (L(ci( (( Date EXHIBIT" A" I have reviewed the foregoing Protective Agreement dated June 2, 20 i i in Case No. IPC-E- i i -08 and agree to be bound by the tenus and conditions of such Agreement. dL~~~MATIHEWEL~ Idaho Public Utilties Commission Employer or Firm 472 W. Washington Street, Boise, Idaho 83702 Business Address Commission StaffPar úÓ3/// Date ( 7 EXHIBIT" A" I have reviewed the foregoing Protective Agreement dated June 2, 2011 in Case No. IPC-E-II-08 and agree to be bound by the terms and conditions of such Agreement. L~ Idaho Public Utilties Commission Employer or Firm 472 W. Washington Street, Boise, Idaho 83702 Business Address Commission StaffPar c¡ßh Date EXHIBIT "A" I have reviewed the foregoing Protective Agreement dated June 2, 20 i i in Case No. IPC-E- i i -08 and agree to be bound by the terms and conditions of such Agreement. ~~& DOUG COX Idaho Public Utilties Commission Employer or Firm 472 W. Washington Street, Boise, Idaho 83702 Business Address Commission StaffPar D.fib):oii EXHIBIT "A" I have reviewed the foregoing Protective Agreement dated June 2, 20 i i in Case No. IPC-E- i i -08 and agree to be bound by the tenns and condition of such Agreement. Idaho Public Utilties Commission Employer or Firm 472 W. Washington Street, Boise, Idaho 83702 Business Address Commission StaffPar k29~1! Date EXIBIT "A" I have reviewed the foregoing Protective Agreement dated June 2, 20 i i in Case No. IPC-E- i i -08 and agree to be bound by the tenns and conditions of such Agreement. ~f)~ZU_ Shelby Baker Idaho Public Utilties Commission Employer or Firm 472 W. Washington Street, Boise, Idaho 83702 Business Address Commission Staff Pary 7/1~/\\ Date .. EXHIBIT "A" I have reviewed the foregoing Protective Agreement dated June 2, 20 i i in Case No. IPC-E- i i -08 and agree to be bound by the terms and conditions of such Agreement. !1~ Idaho Public Utilties Commission Employer or Firm 472 W. Washington Street, Boise, Idaho 83702 Business Address Commission StaffPar '7lu!1I Date EXHIBIT A I have reviewed the foregoing Protective Agreement dated June 2, 20 i i, in Case No. IPC-E-l i -08 and agree to be bound by the terms and conditions of such Agreement. ~~~Print N e ¡Çu l(:c.~ ~ c) \,-~Ø: fLLe Employer or Firm S l:S AI. 2- 7ti Sf ( 6;' k i 121) Business Address (f.? 1 cJ1. -: e-T- ? Part ~G-d-- (I Date EXHIBIT A EXIBIT A I have reviewed the foregoing Protecve Agrement dated June 2, 2011, in Case No. IPC-E-II-QS and agee to be bound by the te and coditions of such Agreeent. Lo"" C.Ç?Ac9 !i&"tPrinted Name \ · i:c QJ:Signate '\ ß£,. ~ 1.$.. rA~ho. Employer or F ¡; O?o ¿/J('f?¡(t 'B. o:~, Tb 85 ~ '5 Business Address w.,~=vd ~~ 2ì z:A ~~C=i:Par 7/~MO'(Date / EXIBIT A PROTECTIVE AGRf:EMENT BETWEEN lOAHO POWER COMPANY. STAn", AND INTERVENORS. IPIJC CASE NO. IPC-E-Il EXHIBIT A I have reviewed the foregoing Protective Agreement dated June 2, 201l, in Case No. IPC-E-l 1-08 and agree to be bound by the terms and conditions of such Agreement. ~ Steven A.Porter Assistant General Counsel for Electricity and Fossil Energy United States Department of Energy Offce of the General Counsel i 000 Independence Ave. SW Washington, DC 20585 July II ,201 i PROTECTIVE AGREEMl:NT BETWl:EN IDAHO POWER COMPANY, STAJ;'F, AND INTlRn:NORS . IPVC CASE NO. IPC-E-) 1 EXHIBIT A I have reviewed the foregoing Protective Agreement dated June 2, 2011, in Case No. IPC-E-l 1-08 and agree to be bound by the terms and conditions of such Agreement. ~~ Lot H. Cooke Attorney for United States Department of Energy Office of the General Counsel 1000 Independence Ave. SW Washington, DC 20585 July If, 2011 PROTECTIVE AGREEMENT BETWEEN IDAHO POWER COMPANY, STAFF, AND INTERVENORS IPUC CASE NO. IPC-E-ll EXHIBIT A I have reviewed the foregoing Protective Agrement dated June 2,2011, in Case No.IPC-E-Il-08 and agree to be bound by the terms and conditions of such Agreement. '10~d ¡(JJ Matthew i. Kahal Exeter Associates 10480 Little Patuxent Parkway Suite 300 Columbia, MD 21004 Pary: U.S. Deparment of Energy July i i. ,2011 PROTECTIVE AGREEMENT BETWEEN IDAHO POWER COMPANY, STAFF, AND INTERVENORS IPUC CASE NO. IPC-E-l1 EXHIBIT A I have reviewed the foregoing Protective Agreement dated June 2, 2011, in Case No.IPC-E- 11-08 and agree to be bound by the terms and conditions of such Agreement. 1) w t5)~ D £-r'-,,' i Jj ~ Dwight D. Etheridge b~ ty~ lc Exeter Associates 10480 Little Patuent Parkway Suite 300 Columbia. MD 21004 Pary: U.S. Departent of Energy July i '2.201 i PROTECTIVE AGREEMENT BETWEEN IOAHOPOWER COMPANY, STAFF, AND INTERVENORS IPUC CASE NO. IPC-E-II EXHIBIT A I have reviewed the foregoing Protective Agreement dated June 1, 20 i I, in Case No. IPC-E-II-08 and agree to be bound by the terms and conditions of such Agreement. tl ud-' Dr. Dennis Goins Potomac Management Group 580 I Westchester Street, Alexandria, Virginia 22310 Party: U. S. Department of Energy July _..L'Z ____, 20 II EXHIBIT A I have reviewed the foregoing Protective Agreement dated June 2, 2011, in Case No. IPC-E-II-08 and agree to be bound by the terms and conditions of such Agreement. MaryV. York Employer or Firm 101 S. Capitol Blvd., Suite 1400 Boise, ID 83702 Business Address Micron Technology, Inc. Part July 8, 2011 Date EXHIBIT A EXHIBIT A I have reviewed the foregoing Protective Agreement dated June 2, 2011, in Case No. IPC-E-l I -08 and agree to be bound by the terms and conditions of such Agreement. Fred Schmidt Printed Name.t~~ Signature Holland & Hart LLP Employer or Firm 777 E. William St., Suite 200 Carson City, NV 89701 Business Address Micron Technology Part 7/8/2011 Date EXHIBIT A 07/08/2011 10: 30 FAX 3032958261 HOLLA & HAT II 031 EXHIT A I have reviewed the foregoing Prtective Agreeent dated June 2, 2011, in Case No. IPC-E-ll-oS and agree to be bound by the terms and conditions of such Agrment. &M K d ¡J4//ØJ'ò;t Prnted Name~Siftue 1!LlA-~O d ~r ¿L~ Employer or Firm S 5J - / 7.J f rX~r; )7" 3,1 0 tJ/Cvt/M, CO ~:i2 Business Addess ¡f:ic~~ kC/jA/t/úJ£f, 7;1c.Part i Da ~ EXHIBIT A EXHIBIT A I have reviewed the foregoing Protective Agrement dated June 2. 2011, in Case No. IPC-E-II-08 and agre to be bound by the ters and conditions of such Agreement. t1J~fM Employer or Firm ~~~!.h~ ~I ~ t1êWi Party i-Zr-ZO¿( Date EXHIBIT A EXHIBIT A I have reviewed the foregoing Protective Agreement dated June 2, 20 i i, in Case No. IPC-E- i i -08 and agree to be bound by the terms and conditions of such Agreement. J).GS /lACl Jlrín~e_,dl~ ~ Signa re ~ jÇ1 ¿(St'et€, btEmployer or Fi /S( U~LAT' s r S& S;¿ 2~l) SA-M O¿ Business A~dress dcAAJPart EXHIBIT A EXHmITA I have reviewed the foregoing Protective Agreement dated June 2, 2011. in Case No. IPC-E- l l -08 and agree to be bound by the terms and conditions of such Agreement. lr ("0 fer E: Qlv-f,- Printed Name J x:/" e'" -- _ '"2.: /_.-/C? ~C Signatu ) (;t: (; t ( (" So (to" ..Employer or Fi /~-(Ì() L;fæyYySI Business Address ( '- l(C. s~.~ ó¿ c¡-Vd / ¡'I; c Va h Part -7 /(~ Ii iDate!. I l EXHIBIT A .- EXHIBIT A I have reviewed the foregoing Protective Agreement dated June 2, 2011, in Case No. IPC-E- i i -08 and agree to be bound by the terms and conditions of such Agreement. 'ÎéV-( O~V\~ Printed Name , LOtt£1'~:sSignature CA-PAJ Employer or Firm _bJQ bC2X Business Address SZz.C(ßO(.~ £03707 Party 7 //~ Ii (r ,Date EXHIBIT A EXHIBIT A I have reviewed the foregoing Protective Agreement dated June 2, 2011, in Case No. IPC-E-ll-08 and aaree to be bound bv the terms and conditions of such Agreement.'-,~, .. Â¡VT/IOA/VPnnted Name T. YfJl')(EL ~.t~~r?~t=~&. t1Employer or Firmc?7'5ï.l) ~ ~~(/~4 dlf B7i Addres ~9/Ýo .ziPl) Party ~/':fJO/D Oat EXHIBIT A EXHIBIT A I have reviewed the foregoing Protective Agreement dated June 2, 20 i i, in Case No. iPC- E-II-08 and agree to be bound by the terms and conditions of stich Agreement. l(£ \j 1.1 C.l- IGi61rJ 5Priiiiet _ /) .~ ~ --Signatl J. tNt((c...( f1l!(l1€G'EJ Employer or Firm 215" 5. 5'(l1t£ $T,i j Jl1 ~ 2.",: S Q i.1 Lt) iLr; C (11; J J ? Y It I Business Address 1fl i! IGOG-fR Co. Party '1" Z6 "q Date EXHIBIT A ExmBITA I have reviewed the foregoing Protective Agreement dated June 2, 2011, in Case No. IPC-E-ll-08 and agree to be bound by the terms and conditions of such Agreement. OL.I WI f' S)' 111 Printed Name l~N- Sig~atu E,N€.e.y" S~\G.-q'6S Employer or Firm "21~S ov11 ~íA:6 rft.bi;~ "r6 ~O $'A-L:r i.A-il eif) t vr II Business Address r(-~ ll12o~ç¡¿ (J. Part ~t2 I \ '1 II EXHmITA EXHIBIT A I have reviewed the foregoing Protective Agreement dated June 2, 2011, in Case No. IPC-E-ll-08 and agree to be bound by the terms and conditions of such Agreement. E f-l; iu 'f S-rA" t; i ~ l-L-. 1 Employer or Firn Zit; s. ~ .s~ ~TE Z,'C~ L~ C1-r ur cej ill Business Address I .:~ K(L "'~ Co , Party Jy\-'( Date i., "Zo " ) EXHIBIT A