20240313van Mastrigt Motion for Leave to File Amicus Curiae Brief.pdf

RECEIVED
MAR 13 2024 @ 21
SUPREME COURT
IN THE SUPRICMETCOURPHBESTHE STATE OF IDAHO
Supreme Court Docket No.51238-2023
Public Utilities Commission No.
Sam and Peggy Edwards
Complainants-Appellants,
PAC-E-23-05
VS.
MOTION FOR LEAVE TO FILE
AMICUS CURIAE BRIEF
PACIFICORP,dba ROCKY MOUNTAIN
POWER
Respondent.
ON APPEAL FROM THE DAHO PUBLIC UTILITIES COMMISSION
OF THE STATE OF DAHO
COMMISSION PRESIDENT,ERIC ANDERSON,PRESIDING
JOE DALLASSamandPeggyEdwards
825 NE Multnomah,Suite 2000333ShoshoneAve
Rexburg,Idaho 83440
Complainants-Appellants
MARK ADLER
1407 West North Temple,Suite 330
Salt Lake City,Utah 84116
Attorneyfor ROCKYMOUNTAIN POWER
Portland,OR 97232
Attorneyfor PACIFICORP
ADAM TRIPLETT,ISB #10221
11331 W.Chinden Blvd.,Bld.8,Ste.201-A
Boise,Idaho 83704
Attorneyfor IDAHO PUBLIC
UTILITIES COMMISSION
Comes now,Frits van Mastrigt,hereinafter Amicus,the son ofJacoba H.van Mastrigt who,
like Complainants-Appellants Sam and Peggy Edwards was one of the original six Complainants
who filed COMPLAINTS with the DAHO PUBLIC UTILITIES COMMISSION against
ROCKY MOUNTAIN POWER Company concerning the attempted installation of an AMI meter
(more commonly known as a smart meter)on their home(s).
Amicus motions this Court for leave to file an AMICUS CURIAE brief (see attached)in
support of Complainants-Appellants Sam and Peggy Edwards.
As this case concerns matters of broad public interest,Amicus wishes to add clarification
to the critical points of law and evidence previously brought up by Sam and Peggy Edwards in
their original COMPLAINT and NOTICE OF APPEAL to the IDAHO PUBLIC UTILITIES
COMMISSION,as well as introduce matters of great Constitutional concern and relevance to this
case which were not included and brought forth in said COMPLAINT and NOTICE OF APPEAL,
matters that should concern every electric power customer in Idaho,as well as throughout America.
Further,Amicus has a compelling interest to,1)not allow undue harm to come to himself,
2)not allow undue harm to come to his 100-year old mother,Jacoba H.van Mastrigt,who is also
facing threat of termination of electric power service,and 3)support and advance those principles
of law and justice which actively protects the Rights,health,and private property of not only Sam
and Peggy Edwards,but ofAmicus mother,Jacoba H.van Mastrigt,and those similarly situated,
and the people of Idaho as well.
MOTION FOR LEAVE TO FILE AMICUS BRIEF 2
Dated this //__day of March,2024.
Respectfully submitted,
Frits van Mastrigt,
c/o 3270 E.17™Street #128.
Idaho Falls,Idaho [83406]
650-759-3944 (telephone)
[e-mail]
Frits van Mastrigt,Sui Juris
MOTION FOR LEAVE TO FILE AMICUS BRIEF 3
CERTIFICATE OF SERVICE
I HEREBY CERTIFY that I,Frits van Mastrigt did personally insert the
following document into a United States Postal Service PRIORITY MAIL envelope with proper
mailed said document Certified Mail with Signature Required,through the United States Postal
SSO GSES FS 4O7/OL SO andpostage(Tracking No
Service:
1.Motion For Leave to File Amicus Curiae Brief,dated March 11,2024.
to the following address:
Idaho Supreme Court
Clerk's Office
P.O.Box 83720
Boise,Idaho 83720-0101
on this _//day of March 2024&
Frits van Mastrigt
c/o 3270 E.17"Street #128.
Idaho Falls,Idaho [83406]
650-759-3944 (telephone)
[e-mail]