Contract analysis

I. INTRODUCTION AND SUMMARY OF RELIEF REQUESTED Ridgeline Midstream Services LLC ("Ridgeline" or "Applicant"), by and through its undersigned counsel, Calderwood & Harkness LLP, respectfully moves the Presiding Administrative Law Judge, the Honorable Clara Whitfield, pursuant to 18 C.F.R. § 385.2008, for a 120-day extension of time — from the current deadline to August 28, 2023 — to complete its response to the remai

II. BACKGROUND A. The Applicant and the Ridgeline Pipeline System Ridgeline Midstream Services LLC is a Delaware limited liability company organized and existing under the laws of the State of Delaware. Ridgeline's sole member is Dunmore Energy Holdings Ltd., a Cayman Islands exempted limited company registered with the Cayman Islands Registry under Registration No. CR-381204. Ridgeline's Employer Identification Numb

III. THE REMAINING SIX DEFICIENCY ITEMS AND THE COMPLEXITY OF THE REQUIRED TARIFF REDESIGN Six deficiency items identified in the January 19, 2023 Deficiency Letter remain unaddressed and require substantial tariff redesign work. The complexity and interrelationship of these items are the principal basis for the requested 120-day extension. Each remaining item is described below, together with an explanation of the w

IV. ENGAGEMENT OF BRASWELL ENERGY CONSULTING GROUP LLC On April 15, 2023, Dunmore Energy Holdings Ltd., as Ridgeline's sole member, engaged Braswell Energy Consulting Group LLC ("Braswell") to provide comprehensive tariff redesign consulting services in connection with Ridgeline's response to the remaining deficiency items. Braswell is a Virginia limited liability company with offices at 8300 Greensboro Drive, Suite

V. PROPOSED TIMELINE Current Status. The procedural schedule in Docket Nos. RP22-847-000 and RP22-847-001 has been stayed since February 6, 2023, pursuant to the order of Administrative Law Judge Whitfield. No hearing dates, testimony deadlines, discovery cut-off dates, or other scheduling milestones are currently in effect. The stay was entered specifically to permit Ridgeline to complete its response to the Deficie

VI. GOOD CAUSE FOR THE EXTENSION The standard for extensions of time under Rule 2008 of the Commission's Rules of Practice and Procedure, 18 C.F.R. § 385.2008, requires a showing of good cause. Good cause exists in this case for several independent and mutually reinforcing reasons. First, the remaining deficiency items involve technically and legally complex tariff design issues. As described in Section III above, th

VII. NO PARTY HAS INDICATED OPPOSITION Consistent with its obligations of professional courtesy and its commitment to cooperative engagement with all parties in these proceedings, counsel for Ridgeline, Calderwood & Harkness LLP, has communicated with counsel for each intervenor and with FERC Trial Staff regarding this Motion. Specifically, Ridgeline's counsel has conferred with the following: • William Pratt, Senior

VIII. CONCLUSION AND PRAYER FOR RELIEF WHEREFORE, for the reasons set forth above, Ridgeline Midstream Services LLC respectfully requests that Administrative Law Judge Clara Whitfield grant this Motion and enter an order:

1. Extending the deadline for Ridgeline Midstream Services LLC to file a complete response to the remaining deficiency items (Items 5, 6, 11, 12, 13, and 14) identified in the January 19, 2023 Deficiency Letter issued by the Commission's Office of Energy Market Regulation to August 28, 2023 (120 days from the date of this Motion);

2. Continuing the stay of the procedural schedule in Docket Nos. RP22-847-000 and RP22-847-001 pending Ridgeline's filing of its complete response to the Deficiency Letter; and

3. Granting such other and further relief as the Presiding Judge deems just and appropriate. Respectfully submitted, CALDERWOOD & HARKNESS LLP By: ________ George Trujillo, Responsible Partner Brett Callahan, Lead Associate David Stanton, Working Associate 1601 K Street NW, Suite 900 Washington, DC 20006 Telephone: (202) 555-4200 Facsimile: (202) 555-4201 Counsel for Ridgeline Midstream Services LLC Dated: April 28,