20151217Certificate of Attorney .pdf

Daniel E. Solander(ISB #8931)
Rocky Mountain Power
1407 WestNorth Temple
Suite 320
Telephone No. [phone]
Email: [e-mail]
Attorneysfor Rocky Mountain Power
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UTILITIES CCMMlSSION
BEFORD TIIE IDAIIO PUBLIC UTILITIES COMMISSION
IN THE MATTER OF TIIE APPLICATIONOF PACIFICORP DIBIA ROCKY
MOI]NTAIN POWER FOR AUTHORITYTO CANCEL ELECTRIC SERYICE
SCHEDT]L3 NO. 71 ENIRGY EXCHA}IGE
PROGRAM
CASE NO. P4C.8.15.14
ATTORNEY'S CERTITICATE
CLAIM OF CONHDENTIALITY
RELATING TO DISCOYERY
RESPONSES
I, Daniel E. Solander, represent Rocky Mountain Power in the above captioned matter. I
am a Senior Attomey for Rocky Mountain Power.
I make this certification and claim of confidentiality regarding the responses to the
attached discovery requests and responses to IPUC Requests pursuant to IDAPA 31.01.01
because Rocky Mountain Power, through its responses, is disclosing certain information that is
Confidential andlor constitutes Trade Secrets as defined by Idaho Code SectionT4-101, et seq.
and 48-801 and protected under IDAPA 31.01.01.067 and 31.01.01.233. Specifically, Rocky
Mountain Power asserts that the attachment to the response to IPUC Requests 1.11 contains
confidential customer information.
Rocky Mountain Power herein asserts that the aforementioned response is confidential in
that the information contains confidential customer information.
I arn of the opinion that this information is "Confidential,' as defined by ldatro Code
Section 74-101, et seq. and 48-801, and should therefore be protected from public inspection,
examination and copying and should be utilized only in accordance with the terms of the
Protective Agreement between Rocky Mountain Power and Idalro Public Utilities Commission
Statr
DATED this 17th day of December, 2015.
Attorneys for Rocky Motrntain Power
Reqpectfirlly submitted,
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