20130325Response Letter.pdf

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PLLC
ATTORNEYS AT LAW
Peter Richardson
Tel: [phone] Fax: [phone]
[e-mail]
P.O. Box 7218 Boise, ID 83707 - 515 N. 27th Sr. Boise, ID 83702
21113 MAR 25 API 8: 49
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March 22, 2013
Lisa Nordstrom
Idaho Power Company
1221 West Idaho Street
Boise, Idaho 83702
Re: Protective Agreement - Case No. IPC-E- 13-04
Dear Lisa:
Thank you for copying me with your letter to Ms. Jewell regarding the ICIP's access to
the entire files in the above captioned matter. I am not sure of Idaho Power's purpose in
lodging your objections with Ms. Jewell in a letter. As a signatory to the protective
agreement the ICIP is as entitled to the entire file as are the Staff members who have
signed the protective agreement.
Your concerns that ICIP members will have access to the confidential files is misplaced.
None of the ICIP members have signed the exhibit to the confidentiality agreement and
none contemplate doing so. Obviously as a signatory to the agreement I am barred from
disclosing confidential information disclosed pursuant to its terms to anyone other than
other signatories to the agreement.
I anticipate having full access to the file for purpose of protecting and promoting my
clients interests, without having to resort to a discovery dust up before the Commission.
Your cooperation will be appreciated.
Sincerely yours:
Peter Richardson, Member
RICHARDSON & O'LEARY, PLLC
Cc: Dr. Reading, Ben Johnson & Assoc.
Jean Jewell (via email)
Weldon Stutzman (via email)