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