20181030Certificate of Attorney.pdf

KARI L. VANDER STOEP
PARTNER
K&L GATES LLP
925 FOURTH AVENUE
SUTTE 29OO
SEATTLE, WA 98I04
PHONE: [phone]
[e-mail]
RECEIVED
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BEFORE THE IDAHO PUBLIC UTILITIES COMMISSION
IN THE MATTER OF THE JOINT
APPLICATION OF HYDRO ONE LIMITED
AND AVISTA CORPORATION FOR
APPROVAL OF MERGER AGREEMENT
ATTORNEY' S CERTIFICATE
CLAIM OF
CONFIDENTIALITY
RELATING TO HYDRO ONE
LIMITED'S DISCOVERY
RESPONSES
FOR HYDRO ONE LIMITED
I, Kari L. Vander Stoep, represent Hydro One Limited. I am a partner at K&L Gates LLP,
and I am appearing on Hydro One's behalf in this proceeding. I make this certification and claim
of confidentiality pursuant to IDAPA 31.01.01 because Hydro One, through its response to Idaho
Sta[PR_043(HCXAVA), is disclosing certain information that is HIGHLY CONFIDENTIAL
and constitutes personal information as defined, and protected, by Idaho Code Section 74-106(8)
and IDAPA Rule 31.01.01.067(b).
The printed information Hydro One provides will be, as required under IDAPA Rule
31.01.01.067, marked as HIGHLY CONFIDENTIAL and will be reproduced on green paper.
ATTORNEY'S CERTIFICATE - 1
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CASE NO. AVU-E-I7 -09
CASE NO. AVU-G-I7-05
The highly confidential information that Hydro One is disclosing relates to compensation
packages for executives at Hydro One. Hydro One asserts that the aforementioned information is
highly confidential because: (l) the information is not publicly available, and (2) reveals
financial worth, which is exempt from disclosure under Idaho Code SectionT4-106(8).
I am of the opinion that this information is HIGHLY CONFIDENTIAL, as defined by
Idaho Code Section 74-106(8), and should therefore be protected from public inspection,
examination and copying, and should be utilized only in accordance with the terms of the
protective agreements between Hydro One Limited, Avista Corporation, the Idaho Public
Utilities Commission Staff, and the other parties to this proceeding.
RESPECTFULLY SUBMITTED this 29thday of October,2018.
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Kari L. Vander Stoep
On behalf of Hydro One Limited
ATTORNEY'S CERTIFICATE - 2