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HomeMy WebLinkAbout20110309Griswold Affidavit Supporting Motion.pdfRE 1'\1¡ "c- Mark C. Moench Daniel E. Solander Rocky Mounta Power 201 South Main Street, Suite 2300 Salt Lake City, Utah 84111 Telephone: (801) 220-4014 Fax: (801) 220-3299 mark.moench~pacificorp.com danel.solander~pacificorp.com 2011 t1ÂR -8 Pi'1 4= 44 Jeffrey S. Lovinger Kenneth E. Kaufian Lovinger Kaufan LLP 825 NE Multnomah, Suite 925 Portland, Oregon 97232 Telephone: (503) 230-7715 Fax: (503) 972-2921 lovinger~lklaw.com kaufian~lklaw.com Attorneys for Defendat Rocky Mounta Power BEFORE THE IDAHO PUBLIC UTILITIES COMMISSION XRG-DP-7, XRG-DP-8, XRG-DP-9, XRG-DP- 10, LLCs, Case No. PAC-E-1O-08 Complainant,AFFIDAVIT OF BRUCE GRISWOLD IN SUPPORT OF ROCKY MOUNTAIN POWER'S MOTION FOR SUMMARY JUDGMENT v. PACIFICORP, DBA ROCKY MOUNTAIN POWER, Defendant. I, Bruce Grswold, having been duly sworn to testify trthlly, say that: 1. I am an employee of PacifiCorp, dba Rocky Mountain Power, defendant in the above-captioned matter. I am employed by PacifiCorp in the Commercial & Trading ("C&T") deparent as Director of Short-Term Origination and Qualifying Facilty ("QF") Contracts. AFFIDAVIT OF BRUCE GRISWOLD IN SUPPORT OF ROCKY MOUNTAIN 1 POWER'S MOTION FOR SuMMARY JUDGMENT 2. I have personal knowledge of the proceedìgs in the above captioned matter. I have personal knowledge of all the documents submitted as Exhibits A and B in support of Rocky Mountain Power's Motion for Sumar Judgment, filed with the Commission on Februar 4, 2011. 3. With one exception, the documents attached as Exhibit A to Rocky Mountan Power's Motion for Sumar Judgment are tre copies of all written communications between XRG and PacifiCorp, from Janua 21, 2009 through July 29, 2010. The exception is Exhibit A-O, which is a tre copy of XRG's response to Rocky Mountai Power's Production Request No.2, acknowledging that it either sent or received the each of Exhibits A-I though A-25 and that it is aware of no other written correspondences between the paries durng that period. 4. The documents attached as Exhbit B to Rocky Mounta Power's Motion for Sumar Judgment ar tre copies of excerpts from XRG's Responses to Rocky Mountan Power's Production Requests. FURTHER YOUR AFFIANT SA YETH NAUGHT DATED: March3 ,2011.~ _OFfiCIAL SEAL WHITNEY MARIE KING NOTARY PUBLIC. OREGON . COMMISSION NO. 453854 "Y (O""ISSION EXPIRES NO'EKIER 14, ZI14 fiD~~vL~ Be' wold Director of Origination PacifiCorp Energy PacifiCorp State of Oregon ) County o~£~~-: ~ ss. i~lirtl', ~\~tary public, do hereby certify that on this ~ day of OOt£CmQ, 2011, personally appeared before me Bruce Griswold, who, being by me first duly sworn, declard that he made his mark on the foregoing instrment, and that the statements therein contained are tre. AFFIDAVIT OF BRUCE GRISWOLD IN SUPPORT OF ROCKY MOUNTAIN 2 POWER'S MOTION FOR SUMMARY JUDGMENT CERTmCATE OF SERVICE I HEREBY CERTIFY that, on the 8th day of March, 2011, a tre and correct copy of the foregoing Rocky Mountain Power's Reply to XRG's Anser in Opposition to Rocky Mountain Power's Motion for Protective Order to Stay Discovery and Motion for Summary Judgment and Affdavit oj Bruce Griswold in Support of Rocky Mountain Power's Motion for Summary Judgment was served in the maner shown to: Jean Jewell Peter J. Richardson Commission Secretar Richardson & O'Lear, PLLC Idaho Public Utilties Commssion 515 N. 27th Street 472 W Washington POBox 7218 Boise, ID 83702 Boise, ID 83702 jean.jewell(ßuc.idaho.gov peterCIchardsonandolear.com (Hand Delivery and Electronic Mail)(U.S. Mail, postage pre-paid, and Electronic Mail) Mark C. Moench Rocky Mounta Power Gregory M. Adams 201 South Main Street, Suite 2300 Richardson & O'Lear, PLLC Salt Lake City, UT 84111 515 N. 2th Street mark.moench~acificorp.com POBox 7218 (U.S. Mail, postage pre-paid, and Boise, ID 83702 Electronic Mail)gregCßchardsonandolear.com (U.S. Mail, postage pre-paid, and Electrnic Mail) Danel E. Solander Rocky Mountain Power 201 South Main Street, Suite 2300 Salt Lae City, UT 84111 dael.solander~acificorp.com (U.S. Mail, postage pre-paid, and Electronic Mail) DATED ths 8th day of March, 2011. LOVINGER KAUFMA LLP . Lovinger ey for Rocky Mounta Power