Estate of Richard R. Simplot - Page 36




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               In his expert witness report, Mr. Much stated that the                 
          valuation of decedent's holdings in J.R. Simplot Co. on a per-share         
          basis requires an initial determination of the enterprise and net           
          equity value of J.R. Simplot Co.  In this regard, he considered the         
          value of J.R. Simplot Co.'s business operations and the value of            
          its nonoperating assets (its 13.36-percent ownership in Micron              
          Technology), as well as whether any difference exists, on a per-            
          share basis, between the class A voting and class B nonvoting               
          shares.                                                                     
               In determining a value for J.R. Simplot Co., Mr. Much examined         
          the following factors:  The Company's history, economic growth,             
          financial condition, and earning capacity; the amount (if any) of           
          dividends paid; the value of the Company's tangible and intangible          
          assets; prior sales of the Company's stock to similar companies;            
          and restrictions placed on the stock of the Company.  He considered         
          both historical and projected earnings of J.R. Simplot Co.'s                
          operating divisions, using a market capitalization approach (which          
          applies market-related pricing ratios of comparable publicly traded         
          companies to the performance measures of each of the Company's              
          operating divisions) and by doing so arrived at an enterprise value         
          for J.R. Simplot Co. of $1,066,740,000.  He also used a discounted          
          cash-flow approach (DCF) (which estimates the present value of the          
          projected future operating cash-flows generated from the business           
          of the Company) and by doing so arrived at an $1,079,900,000                
          enterprise value. (In arriving at J.R. Simplot Co.'s enterprise             
          value through the use of both these approaches, Mr. Much gave no            

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