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HomeMy WebLinkAbout20171102Protective Agreement.pdfPROTECTIVE AGREEMENT RECEIVED BETWEEN rDAHo powER coMpANy AND l0lt t{0Y -2 [t'f l0: 35 TDAHO PUBLIC UTILITIES COMMISSION STANR, (AND orHER pARrr ES AS Ad;iiilffi ;1?l fPCollf'h i8 *,0 * CASE NO. IPC-E-17-13 This Protective Agreement is entered into this 21'r day of September, 2017,by Idaho Power Company ("Idaho Power") and the Idaho Public Utilities Commission (Staff), and other parties as applicable. Recitals: l. WHEREAS,Idaho Power and the ldaho Public Utilities Commission Staff (hereinafter "Staff') anticipate that parties to this proceeding may make requests to provide, or make available for review, certain information, considered by its custodian to be of a trade secret, privileged or confidential nature (as defined in ldaho Code $ $ 7 4-107 through 7 4-109 and 48-80 I ). 2. WHEREAS, Idaho Power and the undersigned parties agree that entering into a Protective Agreement will expedite the production of documents; will afford the necessary protection to Idaho Power's and the undersigned parties' employees and/or representatives in Case No. IPC-E- 1 7- 1 3 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 during the course of the proceedings, now therefore, IT IS HEREBY STIPULATED AND AGREED AS FOLLOWS: 1. (a) Confidential Informstion All documents, data, information, studies and other materials furnished pursuant to any requests for information, subpoenas or other modes of discovery (formal or informal), and including depositions, that are claimed to be of trade secret, proprietary or confidential nature (herein referred to as "Confidential Information") shall be so marked by the party or entity providing the information by stamping the same with a designation indicating its trade secret, proprietary orconfidential nature and printed on "yellow" paper. TDAPA 31.01.01.067. Any claim of confidentiality must be accompanied by an attorney's certificate that the material is protected by law from public disclosure and cite the specific legal authority to support the claim. IDAPA 31.01.01.233. PROTECTIVE AGREEMENT - I (b) Protection of Confidential Information Access to and review of Confidential [nformation shall be strictly controlled by the terms of this Agreement. Unless otherwise ordered, Conhdential 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 not be disclosed to individuals who have not executed the nondisclosure agreement set forth in Exhibit "A." (c) Uss of Confidential Information All persons 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 purpose other than the purpose ofpreparation for and conduct of the proceedings, and then solely as contemplated herein, and shall keep the Confidential Information secure as trade secret, confidential or proprietary information and in accordance with the purposes and intent of this Agreement. (d) Persons Bntitlcd to Rcview Access to Confidential Information shall be limited to counsel of the undersigned parties, employees, experts, agents or representatives of the undersigned parties who have executed an Exhibit "A" to this Agreement. Such information will be clearly marked and protected from unauthorized public disclosure. (e) Non-tlisclosure Agreement Confidential Information shall not be disclosed to any person who has not signed a non- disclosure agreement on this form, which is attached hereto as Exhibit o'A" and incorporated herein. The non-disclosure 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 certifr in writing that he or she has reviewed the same and has consented to be bound by its terms. The Agreement shall contain the signatory's full name, permanent address and employer. Such agreement shall be delivered to counsel for the providing pa(ry, before disclosure is made. 2, Copies No copies or transcriptions of the Confidential lnformation shall be made by the recipient except as necessary to make the information available to individuals who have executed an Exhibit "A" to this Protcctive Agreement. PRO'| I,]CI'I V E AGREEMENT . 2 3. Non-waiver of Obicction to Admissibilitv The furnishing of any document, information, data, study or other materials pursuant to this Protective Agreement shall in no way limit or waive the right of the providing party to object to its relevance or admissibility in any proceedings before this Commission. 4, Challenee to Confidcntiality (a) Initial Challenee This Protective Agreement establishes a procedure for the expeditious handling of information that a parly claims is confidential. Any party may challenge the characterization of any information, document, data or study claimed by the providing party to be a trade secret, proprietary or confidential information. A party seeking to challenge the confidentiality of any information shall first contact counsel for the providing party and attempt to resolve any difference by stipulation. Resolution may include removing the confidential classifications, creating a non-confidential summary, reformatting the information, etc. (b) Subsequent Challenee In the event that the parties cannot agree as to the character of the information challenged, any party challenging the confidentiality may petition the Commission to rule upon the disputed information. The Petition shall be served upon the Commission and all parties to the case who have signed an Exhibit "A" as provided in this Protective Agreement. The Petition shalldesignate with specificity the document or material challenged and state the grounds upon which the subject material are deemed to be non-confidential by the challenging party. (c) Challenee Hearine The challenging party shall request that the Commission conduct an in camera proceeding where only those persons duly authorized to have access to such challenged materials under this Protective Agreement shall be present. This hearing shall be commenced no earlier than hve (5) business days after serving the Petition on the providing party and the Commission. The record of the in camera hearing shall be maTked "CONFIDENTIAL - Subject to Protective Agreement." To the extent necessary, the transcript of such hearing shall be separately bound, segregated, sealed, and withheld from public inspection by ary person not bound by the terms of this Agreement. PROTECTIVE AGREI]MENT - 3 (d) Determination The parties will ask the Commission to issue an Order determining whether any challenged information or material is not properly deemed to be exempt from public disclosure pursuant to the ldaho Public Records Act(ldaho Code $$ 74-l0l through 74-126). tf information is found to be not exernpt from disclosure, no party shall disclose such challenged material or use it in the public record, or otherwise outside the proceedings for at least five (5) business days unless the providing party consents to such conduct. This procedure enables the restrictions of this Agreement from material claimed to be confidential. Such relief may be sought from the Commission or a court of competent j urisdiction. 5. (a) Rcccirrt Into Evidence Provision is hereby made for receipt into evidence in this proceeding of materials claimed to be confidential in the following manner: (l) If the requesting party 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 the providing party and shall provide copies of the used Confidential Information or substantive reference to Confidential Information onlyto the providing pafty, and such other parties, 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 lnformation or substantive reference to Confidential Information described in paragraph 5(aXl) shall be placed in the sealed record. (3) The copy of the documents to be placed in the sealed record shall be tendered by counsel for the providing party to the Commission, and shall be maintained in accordance with the terms of this Protective Agreement. (b) Seal While in the custody of the Commission, materials 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. PROTECTIVE AGREEMENT - 4 (c) .fir Carrera Hearing and Transcriots Any Confidential Information that must be orally disclosed at a hearing in the proceedings shall be offered at an in camera hearing, attended only by persons authorized to have access to the information under this Protective Agreement. Similarly, any transcription of any examination or other reference to Conhdential Information (or that portion of the record containing Confidential Information) shall be marked and treated as provided herein for Confidential Information. (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 restrictions of this Agreement either through agreement of the parties or after notice to the parties and hearing, pursuant to the order of the Commission and/or the final order of a court 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 court. If a portion of the record is forwarded to a court under seal for the purposes of an appeal, the providing party shall be notified which portion of the sealed record has been designated by the appealing party as necessary to the record on appeal. 6. Use in Pleadines 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 description that will not disclose the substantive Confidential Information contained therein. Any use of or substantive references to Confidential Information shall be placed in a separate section of the pleading or brief and submitted to the Commission pursuant to Paragraph 5. This sealed section shall be served only on counsel of record who have signed the nondisclosure agreements set forth in Exhibit "A" attached to this Protective Agreement, and may, in turn, be disclosed by them only to individuals who likcwise signed Exhibit ,.Arr. PROTECTIVE AGREEMEN . 5 7. $urrolqsry aflRecord If deemed necessary by the Commission, the providing parties shall prepare a written summary of the Confidential Information referred to in Orders to be issued to the public and the parties. 8. Return or Destruction of Confidential Information (a) Upon request of the providing party, all original documents and copies of the Confidential lnformation shall be: (l) returned to the providing party; or (2) or at the option of the recipient destroyed within thirty (30) days after the final settlement or conclusion of the proceedings, including administrative or judicial review thereof. After return or destruction of documents pursuant to this paragraph, and upon request, a written receipt veriffing return or destruction shall be provided by counsel. (b) On a case-by-case basis and upon notification to the utility, the Commission Staff may retain one copy of the Confidential Information under seal. Notwithstanding any other provision in this Agreement, any member of Staff may review and use that copy of the Confidential Information outside this proceeding while performing his or her duties as a Staff member. Staff s use and disclosure of the Confidential Information in a later Commission proceeding shall be subject to any protective agreement signed in the proceeding. (c) Any notes maintained by a recipient of Confidential Information which embody or rcflect any of the Confidential Information provided under this Agreement shall, upon request ofthe providing party, be either returned to the providing party or, at the option of the recipient, destroyed. 9, Effective Date This Protective Agreement shall become effective on the date hereof. PROTECTIVE AGREEMENT - 6 \DATED this 2l't day of September 2017 IDAHO POWER COMPANY By Q . /) <---tz?rAuu il . / / o,</zlr.-,--lffi Idaho Power Company 1221 West Idaho Street Boise,ldaho 83702 Attorney Representing Idaho Power Company IDAHO PUBLIC UTILITIES COMMISSION STAFF By:J* ( ') Sean Costello Deputy Attorney General Idaho Public Utilities Commission 472 W est Washington Street Boise,ldaho 83702 Attorney Representing the Idaho Public Utilities Commission Staff 'I PROTECTIVE AGREEMENT - 7 11* ^t- | DATED this C5 day of September 2017. IDAHYDRO IDAHO CLEAN ENBRGY ASSOCIATION C. Tom Arkoosh Attorney Representing Idahydro and Idaho Clean Energy Association By PROTECTIVE AGREEMENT. 8 DATED this of September 2017 IDAHO CLEAN ENERGY ASSOCIATION David H. Arkoosh Attorney Representing Idaho Clean Energy Association By: PROI'ECTIVE AGREEM ENT . 9 o**t"- \/DATED this j*aayof Septemb er2017. SNAKE RIVER ALLIANCE NW ENERGY COALITION By: Hammond, Jr. Representing Snake River Alliance and NW Coalition I PROTECTIVE AGR-EEMENT - IO I DATED this X 7 day of September 2017 AURIC LLC -F,rV i-By / Preston N. Carter Attorney Representing Auric Solar PROTECTIVE AGREEMENT. I I I DATED thir2?\ay of Seprem ber2orT AURIC LLC De Nelson Attomey Representing Auric Solar ) PROTECTIVE AGREEMENT . I2 I \ ,!, DArED tn" 2u4 day of September 2017. IDAHO CONSERVATION LEAGUE By: Benjamin J. Attorney Representing Idaho Conservation League b PROTECTIVE AGREEMENT. 13 n_$ DAI'ED this L5 day of September 2017. SIERRA CLUB By: Kelsey Jae N Attorney Sierra Club PRO]-EC'I'IVF] ACREEMEN'T . I4 DATED this l(tb'auy or@zon. Attorney INTERMOUNTAIN WIND AND SOLAR, LLC By: Wind and Solar, LLC PROTECTIVE AGREEMENT - I5 ' ' +L Oc*$'t DATED this lto day of S,qpffier 2017. By: INTERMOUNTAIN WIND AND SOLAR, LLC Q Brian W. Burnett Attorney Representing Intermountain Wind and Solar, LLC PROTECTIVE AGREEMENT . I6 P. J(' 0 DArED this 3 ou, offinrorr. CTTY OF BOTSE CITY By: Boise Germaine Attomey Representing the City of Boise t\ -\ l PROTECTIVE AGREE]VIENT . I7 3 DATED thiS -ZZ*hu,of September20lT. IDAIIO By: PUMPERS ASSOCIATION, INC. Olsen Attorney Representing the Idaho Irrigation Pumpers Association, Inc. PROTECTIVE AGREEMENT. I 8 I I I I )^,.I{DATED this dl day of September 2017. VOTE SOLAR By: David Bender Attorney Representing Vote Solar ( 1 PROTECTIVE AGREEMENT - 19 3 EXHIBIT ..A'' I have reviewed the foregoing Protective Agreement dated this Zl"t day of September 2017 in Case No. IPC-E- 17- l3 and agree to be bound by the terms and conditions of such Agreement. El"nnbAL\L) Stacey Public Utilities Commission Employer or Firm 472 \4r. \uashiumou StreELBliseJL837Qz ) Business Address Commission Staff Party Date lo /7 ) )EXHIBIT *A' I have reviewed the foregoing Protective Agreement dated this 2lu_day of September 2017 in Case No. IPC-E-17-13 and agree to be bound by the terms conditions of such Agreement. Public Utilities Commission Employer or Firm 472W. Washineton Street. Boise" ID 83702 Business Address Party Date F 0 \ J Commission Staff II EXHIBIT "A'' I have reviewed the foregoing Protective Agreement dated this 2l't day of September20lT in Case No. IPC-E- 17- 13 and agree to be bound by the terms and conditions of such Agreement. Public Utilities Commission Employer or Firm 472 W. Washinston Street.se ID 81702 Business Address Commission Staff Party Zr' Date ) i ) EXHIBIT 6'A'' I have reviewed the foregoing Protective Agreement dated this 21't day of September 2017 in Case No. IPC-E-17-13 and agree to be bound by the terms and conditions of such Agreement. Public Utilities Commission Employer or Firm 472 W . Washineton Street.rD 83702 Business Address Commission Staff 2S :>eP Zort Date arley Party \ J"EXHIBIT "A" I have reviewed the foregoing Protective Agreement dated this 2l't day of September 2017 in Case No. IPC-E-17-13 and agree to be bound by the terms and conditions of such Agreement. Mike Public Utilities Commission Employer or Firm 472 W . Washineton Street. Boise. ID 83702 Business Address Commission Staff Party /o t{ Date \ "fl J EXHIBIT "A" I have reviewed the foregoing Protective Agreement dated this 2_[" day of September 2017 in Case No. IPC-E-17-13 and agree to be bound by the terms and conditions of such Agreement. Public Utilities Commission Employer or Firm 472W. Washington Street, Boise. lD 83702 Business Address Commission Staff Party Date B \t EXHIBIT ..A'' I have reviewed the foregoing Protective Agreement dated this 2l't day of September20lT in Case No. IPC-E-17-13 and agree to be bound by the terms and conditions of such Agreement. Randy Lobb Public Utilities Commission Employer or Firm 472W. Washington Street. Boise,ID 83702 Business Address Commission Staff Party ?/ u /ro77 Date EXHIBIT "A' I have reviewed the tbregoing Protective Agreement dated September 21, 2077 ,inCase No IPC-E-17-13 and agree to be bound by the terms and conditions of such Agreement. Name City of Boise Employer or Firm PO Box 500 Business Address Party 0912912017 Date i EXHIBIT "A'' EXHIBIT "A" I have reviewed the foregoing Protective Agreement dated September 2l , 2017 ,inCase No. IPC-E-17-13 and agree to be bound by the terms and conditions of such Agreement. Name Mic-lretle Employer or Business Address Party --1 Date EXHIBIT "A'' fu k,' 5c,C; hik- fD 33'acl EXHIBIT "A" I have reviewed the foregoing Protective Agreement dated September 21,2017, in Case No IPC-E-17-13 and agree to be bound by the terms and conditions of such Agreement. DAVID M. COOPER, Trustee Name ldaho Hydroelectric Producer's Trust Employer or Firm 802 West Bannock, 9th Floor Business Address Party 1012612017 Date EXHIBIT "A" EXHIBIT "A" I have reviewed the foregoing Protective Agreement dated September 21, 2017,inCase No. IPC-E- l 7- I 3 and agree to be bound by the terms and conditions of such Agreement. Loutts M. Zanu rZrX Name -l-w,inl F*ltx Cqilrl L CbI4PA^]L/ Employer or Firm P,a, e Y 326 / rtl |-,q1/,<. tr\ A s<.,3 Business Address ]DAH YDI?D Party 0 Date EXHIBIT *A'' EXHIBIT *A" I have reviewed the foregoing Protective Agreement dated September 27,2017 , in Case No IPC-E-I7-13 and agree to be bound by the terms and conditions of such Agreernent. J6r.u T Srneq t<uAt- Name 5uo rlocr. 11yora., . Txs. Employer or Firm lll SHosH0^,6 S'-t,<ee T il, Sqtzc zoo 7r,,.r r *t FaLts. TDAuo 33?o Business Address i D*ttYDRo Party O.trtlr*- 6, zot 7 Date EXHIBIT*A" I EXHIBIT "A" I have reviewed the foregoing Protective Agreement dated September 2 I , 2017 , inCase No. IPC-E-17-13 and agree to be bound by the terms and conditions of such Agreement, ^l L flB.raNt- L*,,u Drr,,rE< Employer or Firm Business Address Par$ -t Date EXHIBIT "A'' ( I.:\ I il Bt'r ..."\" I ltar c rcr icrr cd tltc lirrcgt, iltg [)rt rk'r'1i1 c .\grcclllclll r.lirtc{ Scptcrtt[cr ] I - l() I 7. itt Casc N.r. ll'(-1.-l7-l.llrrdrtgrucl()lrchountibr tltctcrrttsurrclc()rlrlilirulsol'sr^rch..\grccrnr:rrt. /:ltPtrth L{ltcf \:rrrrc I :ttt1rl,'r cP pr l;irltt ') lltrsi ncss .'\rltlress I'lr rt r S,,iea ilSrryp fit \,\e llltfig LT ?fi46 I \ilil111 ",\" CI EXHIBIT'A" I have reviewed the foregoing Protective Agreement dated Septernber 2 1 ,2017 , in Case No. IPC-E-I7-13 and agree to be bound by the terms and conditions of such Agreement. Name L-o *oc-\<-\ Employer or Firm ttt SL.oS\^-or^.e. :t. N Business Address 6,.^-. te_ 2.O c> f t^r. .-- tr€-\\S , T d ' Part, ir,r^, t1 c-- lo Date EXMBIT'A" l i I I I t i I I ! I I I I I ,p EXHIBTT "A', I have reviewed the tbregoing Protective Agreement dated Septemlxr 21,2077 ,in Case No. IPC-E- l7- 13 and agree to be bound by the terms and conditions of such Agreement. A^/Til oMY fAtl)<fL Name /buJ<6L +fiSSac. rMc Ernployer or Firm t /.Vocs L k<e L AKeWuoOt Business Address -T"TFfr Party 97 2 Dt Date PVE 0 t+ '-t4 r ory j i EXHBTT *A" EXHIBIT "A" I have reviewed the foregoing Protective Agreement dated September 21,2017 , in Case No. IPC-E-I7-13 and agree to be bound by the terms and conditions of such Agreement. NIq tbAt+" Gxll*(Aflor cgA1uz Employer or Firm (-J rb8 Business Address ti;fttlo Cirxsi.P-VffircyJ LVAlt tL Party Z}t1 Date q EXHIBIT*A" EXI{IBIT ftA'' I have reviewed the foregoing Protective Agreement dated September2l,2077,in Case No. IPC-E-I7-13 and agree to be bound by the terms and conditions of such Agreement. lut& 1,.O),'ltrr1* Name S a",1, l]-irtn d//''ooou ' Employer or Firm P- O . B x 17 7 /, 77ais"*I-D eszct 1 Business Address Party 0crt 7 '/7 Date \l EXHIBIT'A" EXHIBIT "A" I have reviewed the foregoing Protective Agreement dated September 21, 2017 ,in Case No. IPC-E-17-13 and agree to be bound by the terms and conditions of such Agreement. ,Uc"s Name r1 ,'fu^av.,-- Employer or Firm d{ /e,*./'0- f/Oo I Business Address /uoe c / tg,4-- Party ?> -( Date EXHIBIT "A'' UT rrL)s EXHIBIT'A'' I have reviewed the foregoing Protective Agreement dated September 21, 2017 , in Case No. IPC-E-I7-13 and agree to be bound by the terms and conditions of such Agreement. Name Employer or Firm Business Address *lol, Lb^ f^ ^u Atsni,l^ Party "___at7__ loAtlt2 Date EXHIBIT *A" EXI{IBIT 3A'' I have reviewed the foregoing Protectivc Agreernent datcd September 21,2017,in Case No. IPC-E-17-13 and agree to be bound by the terms and conditions of such Agreement. %*U; Name c.otth€L LaarnnD. A, rtuR,+ Do-.,< 4,v> \otorl I^- Employer or Finn \'/tz /. 3(r* Sr. Booo -Do fs7o3 Business Address TceA Parly o1/uz / tt Date EXHIBIT "A" EXIIIBIT *A'' I have reviewed the foregoing Protective Agreement dated Septerrber 21,2017 ,in Case No. IPC-E-17-13 and agree to be bound by the terms and conditions of such Agreement. \-zL Nanre beeiFJ,r.a,szv Aoi\orz* Po-ea Ar(D N"""0, Ttu Employer or Firrr \4tL M \re 5 ttc TL {3zo\t Business Address t ceA Party s1/>z /t7 Date EXHIBIT "A" EXHIBIT "A' I have reviewed the foregoing Protective Agreement dated September2l,20lT,inCase No. IPC-E-I7-13 and agree to be bound by the terms and conditions of such Agreement. Lul Name &ta,6ht S,[* { L;Al-' Employer or Firm V {,,{ Business Address t{7, t@4 Parly 7/"/z,n Date EXHIBIT'4" EXHIBIT *A'' I have reviewed the foregoing Protective Agreement dated September 2l ,2017 , in Case No. IPC-E-I7-13 and agree to be bound by the terms and conditions of such Agreement. Beau Husfloen Name Bluebird Solar and Light, LLC Employer or Firm POBox4714 Ketctum, lD 83340 Business Address ldaho Clean Energy Association Party September 9,2017 Date B* /L)^g,gna:ttr';--7 EXHIBIT *A'' EXHIBIT ..A" I have reviewed the foregoing Protective Agreement dated September 21, 2017 , in Case No IPC-E-17-13 and agree to be bound by the terms and conditions of such Agreement. l*l* Name t^t R . u,,,r^:leCo u,'/ s. l+ Employer or Firm I t I 8 K*q[{5 }r. 8., rr. e37 tL Business Address \l I L.A Party Z(/.ot7 Date EXHIBIT'A" EXHIBIT "A" I have reviewed the foregoing Protective Agreement dated September 21 , 2017 ,inCase No. IPC-E-17-13 and agree to be bound by the terms and conditions of such Agreement. (c,;n /(; n o Name ecr folor Employer or Firm {o t /U /?ldn el, flr.i/;on XD r56lL Business Address 7c EA Party 1-zz- t7 Date EXHIBIT "A" EXHIBIT ftA" I have reviewed the foregoing Protective Agreement dated September 21, 2017,inCase No. IPC-E-17-13 and agree to be bound by the terms and conditions of such Agreement. Name Employer or Firm Business Address (Uikr, d+"L IJ*f..-.\,.^ Party Date 2 v t EXHIBTT "A" EXHIBIT *A' I have reviewed the foregoing Protective Agreement dated September 21, 2017 ,in Case No. IPC-E-I7-13 and agree to be bound by the terms and conditions of such Agreement. Name Vote Solar Employer or Firm 360 22nd Street,Suite 730 CA94612 Business Address Vote Solar Party September 28,20L7 Date 1 EXHIBIT "A'' \J EXHIBIT (nA', I have reviewed the forcgoing Protective Agreement dated September 2 | ,2017 , in Case No. IPC-E- 1 7- I 3 and agree to be bound by the terms and conditions of such Agreement. '(,-k G, / /,j-,,,4/ .t ;.L-- Name V'ole S'rl^- Employer or Firm S'i o Er/"Lr, {),,,'* It,at.*,{,rtr/co toa>O Business Address V rl, S,i^n Party ?A - Snp' 7ot1 Date EXHIBIT*4" li't ;,/EXHIBIT'A'' I have reviewed the foregoing Protective Agreement dated September 21, 2017 , in Case No. IPC-E-17-13 and agree to be bound by the terms and conditions of such Agreernent. Name Employer or Firm {ol h t^"tt; ,8,;, Z) Business Address Srrr^ (lrl Party 2t+?tttt Date EXHIBIT*A" t{ .\ )., EXHIBIT'A'' I have reviewed the foregoing Protective Agreement dated September2l,Z}l7,in Case No. IPC-E-I7-13 and agree to be bound by the terms and conditions of zuch Agreement. Slecro Clrh Employer or Firm 5o) W fr^k1," 5f , borse lD t]oX Business Address 5rec.a. Cl"b Party 2.4 Date I EXHIBIT "A'' /lr*l LJ"f*^"*, -Name / 1 EXHIBIT'A' I have reviewed the foregoing Protective Agreement dated September2l,20l7,in Case No. IPC-E-17-13 and agree to be bormd by the terms and conditions of such Agreement. Aw-tu S"\ar, LLC- Employer or Firm zTto S. lloD r^I . s^l/ L "L-L,try,W Brltll Business Address Au.i. S.,l^t, LLU Par$ lo z i1 Date ) EXHIBIT"A" 1tA7-> Elias $islr-oP lf/v ' ,q ,lffme -/ 3 tr'.)KITrR11..4tt I have reviewedthe foregoingProtectiveAgrccme,ntdated Septernbo2I,20\7,inCaseNo IPC-E-17-13 and agree to be bound by the tErms and conditions of such Agree,meut. f,)c'tr-ta[a..s SYri=\e-rNamt J Employer or Firm Business Address .-'i-'n+Pf tvr h Lrn{dr'rN J',r..A ,-J 6*\o-r- Pafty \l )EXHIBIT'A" fn+ecrtrn, nta.io t)\r.A nA fr.\a.f t({3 rJast }{}S s^^rt tJmAr., (rco: L( &(cK1 tclual r-) Date ' I