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Contract analysis / motion-pro-hac-vice-trujillo.docx
motion-pro-hac-vice-trujillo.docx
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Standard · 2
I. INTRODUCTION AND NATURE OF MOTION
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⚑ Notice / time limit to track
I. INTRODUCTION AND NATURE OF MOTION Ridgeline Midstream Services LLC ("Ridgeline" or "Applicant"), by and through its counsel of record, Calderwood & Harkness LLP ("Calderwood & Harkness" or "C&H"), respectfully submits this Motion for the admission pro hac vice of George Trujillo, Esq., Responsible Partner in the Energy & Infrastructure practice of Calderwood & Harkness LLP, to appear and practice before the Federa
II. IDENTIFICATION OF THE APPLICANT FOR ADMISSION
II. IDENTIFICATION OF THE APPLICANT FOR ADMISSION The attorney for whom pro hac vice admission is sought is identified as follows: Full Name: George Trujillo Title: Responsible Partner, Energy & Infrastructure Group Firm: Calderwood & Harkness LLP Firm Address: 1601 K Street NW, Suite 900, Washington, DC 20006 Firm Type: Calderwood & Harkness LLP is a limited liability partnership organized and existing under the law
III. BAR ADMISSIONS AND PROFESSIONAL STANDING
III. BAR ADMISSIONS AND PROFESSIONAL STANDING George Trujillo is admitted to practice law and is a member in good standing of the bar of the following jurisdictions:
1. New York State Bar — Admitted on June 14, 2001; Registration No. 4187563. Mr. Trujillo
1. New York State Bar — Admitted on June 14, 2001; Registration No. 4187563. Mr. Trujillo is currently in good standing with the Appellate Division, First Department, of the Supreme Court of the State of New York, with no conditions, restrictions, or limitations on his license to practice.
2. Commonwealth of Pennsylvania — Admitted on October 22, 2001; Attorney ID No. 83291. Mr
2. Commonwealth of Pennsylvania — Admitted on October 22, 2001; Attorney ID No. 83291. Mr. Trujillo is currently in active status and in good standing with the Disciplinary Board of the Supreme Court of Pennsylvania, with no conditions, restrictions, or limitations on his license to practice.
3. District of Columbia Bar — Admitted on March 8, 2003; Bar No. 977214. Mr. Trujillo is
3. District of Columbia Bar — Admitted on March 8, 2003; Bar No. 977214. Mr. Trujillo is currently in active status and in good standing with the District of Columbia Bar, with no conditions, restrictions, or limitations on his license to practice.
4. United States Court of Appeals for the District of Columbia Circuit — Admitted on Nove
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⚑ Commercial term
4. United States Court of Appeals for the District of Columbia Circuit — Admitted on November 19, 2003; Bar No. 48-2761. Mr. Trujillo is currently in good standing, with no conditions, restrictions, or limitations on his admission. Mr. Trujillo confirms, and hereby represents to the Commission, that he is a member in good standing of each bar and court to which he is admitted, as identified above. His bar memberships
IV. QUALIFICATIONS AND EXPERIENCE
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⚑ Penalty / liquidated damages
IV. QUALIFICATIONS AND EXPERIENCE George Trujillo brings to these proceedings more than twenty years of experience in energy regulatory law, with a particular focus on the regulation of interstate natural gas pipelines under the Natural Gas Act and the Commission's implementing regulations. His qualifications to serve as lead counsel in the above-captioned proceedings are summarized as follows. Mr. Trujillo has serve
V. DESCRIPTION OF THE UNDERLYING PROCEEDINGS
V. DESCRIPTION OF THE UNDERLYING PROCEEDINGS The following information is provided to identify the client, describe the proceedings in which admission is sought, and furnish the Commission with sufficient detail to evaluate this Motion. A. The Client Ridgeline Midstream Services LLC ("Ridgeline") is a Delaware limited liability company, formed on March 14, 2019, and organized under the Delaware Limited Liability Comp
1. Docket No. RP22-847-000 (Rate Case): Approval of an initial tariff rate for interstate
1. Docket No. RP22-847-000 (Rate Case): Approval of an initial tariff rate for interstate natural gas transportation service on the Ridgeline Pipeline System, to be set forth in Ridgeline's FERC Gas Tariff, Original Volume No. 1, filed pursuant to Section 4 of the NGA, 15 U.S.C. § 717c, and the Commission's regulations at 18 C.F.R. Parts 154 and 284, Subpart G. The proposed initial recourse rate is $0.2265 per dekath
2. Docket No. RP22-847-001 (Interconnection): Authorization for physical interconnection
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⚑ Commercial term
2. Docket No. RP22-847-001 (Interconnection): Authorization for physical interconnection with the existing pipeline network of Appalachian Trunk Pipeline Company, LLC ("ATPC") at the Wetzel County Interconnect, located in Wetzel County, West Virginia, filed pursuant to Section 7 of the NGA, 15 U.S.C. § 717f, and the Commission's regulations at 18 C.F.R. Part 157. The requested interconnection would be located at ATPC
VI. IDENTIFICATION OF ADDITIONAL COUNSEL
VI. IDENTIFICATION OF ADDITIONAL COUNSEL George Trujillo will serve as lead counsel and Responsible Partner in these proceedings and will be assisted by the following attorneys of Calderwood & Harkness LLP, each of whom has separately entered or will promptly enter an appearance in these dockets:
1. Brett Callahan, Lead Associate, Energy & Infrastructure Group, Calderwood & Harkness L
1. Brett Callahan, Lead Associate, Energy & Infrastructure Group, Calderwood & Harkness LLP, 1601 K Street NW, Suite 900, Washington, DC 20006. Mr. Callahan is admitted to practice in the District of Columbia and the Commonwealth of Virginia, and is in good standing in each jurisdiction. Mr. Callahan will serve as day-to-day case manager and will be responsible for the coordination of discovery, the preparation of re
2. David Stanton, Working Associate, Energy & Infrastructure Group, Calderwood & Harkness
2. David Stanton, Working Associate, Energy & Infrastructure Group, Calderwood & Harkness LLP, 1601 K Street NW, Suite 900, Washington, DC 20006. Mr. Stanton is admitted to practice in the State of New York and the District of Columbia, and is in good standing in each jurisdiction. Mr. Stanton will assist with legal research, the drafting of pre-filed testimony, and the analysis of cost-of-service and rate design iss
VII. GROUNDS FOR ADMISSION
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⚑ Liability cap to check against exposure
VII. GROUNDS FOR ADMISSION The Commission's Rules of Practice and Procedure, codified at 18 C.F.R. § 385.2101, govern the admission and appearance of attorneys before the Commission. Under Section 385.2101(a), any person who is a member in good standing of the bar of the highest court of any state, the District of Columbia, or any territory or possession of the United States may be admitted to practice before the Com
VIII. CERTIFICATION AND REPRESENTATIONS
VIII. CERTIFICATION AND REPRESENTATIONS Pursuant to the Commission's Rules of Practice and Procedure and in support of this Motion, George Trujillo, Esq., hereby certifies and represents as follows:
1. He is a member in good standing of the bar of the State of New York (Registration No.
1. He is a member in good standing of the bar of the State of New York (Registration No. 4187563), the Commonwealth of Pennsylvania (Attorney ID No. 83291), the District of Columbia (Bar No. 977214), and the United States Court of Appeals for the District of Columbia Circuit (Bar No. 48-2761), as more fully described in Section III above.
2. He is not currently suspended, disbarred, or otherwise restricted from the practice of
2. He is not currently suspended, disbarred, or otherwise restricted from the practice of law in any jurisdiction, and no such proceeding is pending or, to his knowledge, contemplated.
3. He has not at any time been the subject of any public or private disciplinary sanction
3. He has not at any time been the subject of any public or private disciplinary sanction, censure, or reprimand by any court, bar association, or disciplinary authority, nor has he been denied admission to practice before any court or federal agency.
4. He has read and is familiar with the Commission's Rules of Practice and Procedure, 18
4. He has read and is familiar with the Commission's Rules of Practice and Procedure, 18 C.F.R. Part 385, including the provisions governing appearances, filings, service, ex parte communications, and the conduct of hearings.
5. He has read and is familiar with the Commission's Standards of Conduct for Transmissio
5. He has read and is familiar with the Commission's Standards of Conduct for Transmission Providers, 18 C.F.R. Part 358, to the extent applicable to these proceedings.
6. He will comply with all applicable rules of professional conduct, including the rules
6. He will comply with all applicable rules of professional conduct, including the rules of professional conduct of each jurisdiction in which he is admitted to practice and the rules and standards of conduct applicable to practitioners appearing before the Commission.
7. He designates Calderwood & Harkness LLP, 1601 K Street NW, Suite 900, Washington, DC 2
7. He designates Calderwood & Harkness LLP, 1601 K Street NW, Suite 900, Washington, DC 20006, as his address for service of all pleadings, orders, notices, and correspondence in these proceedings, and consents to electronic service at the email address set forth in Section IX below.
IX. SERVICE LIST INFORMATION
IX. SERVICE LIST INFORMATION All pleadings, orders, notices, and correspondence in these proceedings should be served on Mr. Trujillo at the following address: George Trujillo, Esq. Responsible Partner, Energy & Infrastructure Group Calderwood & Harkness LLP 1601 K Street NW, Suite 900 Washington, DC 20006 Telephone: (202) 654-7200 Facsimile: (202) 654-7201 Email: gtrujillo@calderwoodharkness.com Mr. Trujillo consent
X. PRAYER FOR RELIEF
X. PRAYER FOR RELIEF WHEREFORE, Ridgeline Midstream Services LLC respectfully requests that the Federal Energy Regulatory Commission:
1. Grant the admission pro hac vice of George Trujillo, Esq., to appear and practice befo
1. Grant the admission pro hac vice of George Trujillo, Esq., to appear and practice before the Commission as lead counsel for Ridgeline Midstream Services LLC in Docket Nos. RP22-847-000 and RP22-847-001;
2. Include Mr. Trujillo on the official service list for both dockets at the address, tel
2. Include Mr. Trujillo on the official service list for both dockets at the address, telephone number, and email address set forth in Section IX above; and
3. Grant such other and further relief as the Commission may deem just, appropriate, and
3. Grant such other and further relief as the Commission may deem just, appropriate, and in the public interest. Respectfully submitted, CALDERWOOD & HARKNESS LLP By: ________ George Trujillo, Esq. Responsible Partner, Energy & Infrastructure Group Calderwood & Harkness LLP 1601 K Street NW, Suite 900 Washington, DC 20006 Telephone: (202) 654-7200 Facsimile: (202) 654-7201 Email: gtrujillo@calderwoodharkness.com Coun
1. By electronic filing via the Commission's eFiling system:
1. By electronic filing via the Commission's eFiling system: The Honorable Kimberly D. Bose, Secretary Federal Energy Regulatory Commission 888 First Street NE Washington, DC 20426
2. By electronic mail and first-class United States mail, postage prepaid:
2. By electronic mail and first-class United States mail, postage prepaid: William R. Pratt, Esq. Kellner, Royce & Dillard LLP One PPG Place, Suite 2800 Pittsburgh, PA 15222 Telephone: (412) 391-4400 Email: wpratt@krdlaw.com Counsel for Appalachian Trunk Pipeline Company, LLC
3. By electronic mail and first-class United States mail, postage prepaid, upon all other
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⚑ Penalty / liquidated damages
3. By electronic mail and first-class United States mail, postage prepaid, upon all other parties whose names appear on the official service list for Docket Nos. RP22-847-000 and RP22-847-001 as of the date of this filing. Service was made in accordance with the Commission's Rules of Practice and Procedure, 18 C.F.R. § 385.2010, and the Commission's electronic filing and service requirements. ________________________
1. My full legal name is George Anthony Trujillo. I am over the age of eighteen years, am
1. My full legal name is George Anthony Trujillo. I am over the age of eighteen years, am of sound mind, and make this Declaration based upon my personal knowledge. I am competent to testify as to the matters stated herein.
2. My business address is Calderwood & Harkness LLP, 1601 K Street NW, Suite 900, Washing
2. My business address is Calderwood & Harkness LLP, 1601 K Street NW, Suite 900, Washington, DC 20006. I am employed as a Partner of Calderwood & Harkness LLP, where I hold the position of Responsible Partner in the firm's Energy & Infrastructure Group. I have been a partner of the firm since January 1, 2010, and have practiced in the firm's Washington, D.C. office since 2005.
3. I submit this Declaration in support of the Motion for Admission Pro Hac Vice filed by
3. I submit this Declaration in support of the Motion for Admission Pro Hac Vice filed by Ridgeline Midstream Services LLC ("Ridgeline") in the above-captioned proceedings, Docket Nos. RP22-847-000 and RP22-847-001, before the Federal Energy Regulatory Commission ("Commission" or "FERC").
4. Bar Admissions. I am admitted to practice law and am a member in good standing of the
4. Bar Admissions. I am admitted to practice law and am a member in good standing of the bar of each of the following jurisdictions: (a) New York State Bar — I was admitted to the bar of the State of New York on June 14, 2001. My registration number is 4187563. I am currently in good standing, and my registration is active and unrestricted. All continuing legal education requirements applicable to my admission have b
5. Disciplinary History. I have not at any time been the subject of any disciplinary proc
5. Disciplinary History. I have not at any time been the subject of any disciplinary proceeding, complaint, investigation, censure, reprimand, suspension, or disbarment by any court, bar association, or disciplinary authority in any jurisdiction. I am not currently the subject of any pending disciplinary proceeding or investigation. No complaint or grievance is pending against me before any disciplinary authority, to
6. Denial of Admission. I have not at any time been denied admission to practice before a
6. Denial of Admission. I have not at any time been denied admission to practice before any federal agency, federal court, or state court. No application for admission filed by me has been withdrawn under circumstances suggesting the likelihood of denial.
7. Familiarity with Commission Rules. I have read and am familiar with the Commission's R
7. Familiarity with Commission Rules. I have read and am familiar with the Commission's Rules of Practice and Procedure, 18 C.F.R. Part 385, including the rules governing appearances, filing requirements, service of pleadings and documents, ex parte communications, the conduct of evidentiary hearings, settlement procedures, and the standards of conduct applicable to practitioners before the Commission. I have also re
8. Role in These Proceedings. I serve as Responsible Partner for Calderwood & Harkness LL
8. Role in These Proceedings. I serve as Responsible Partner for Calderwood & Harkness LLP's engagement by Ridgeline Midstream Services LLC in connection with C&H Matter No. 1016-00005. In that capacity, I am responsible for the overall supervision and direction of the firm's representation of Ridgeline in the above-captioned proceedings, including the preparation and filing of the Application for Initial Tariff Rate
9. Commitment to Compliance. I hereby commit to abide by all rules, regulations, orders,
9. Commitment to Compliance. I hereby commit to abide by all rules, regulations, orders, and directives of the Federal Energy Regulatory Commission applicable to these proceedings, including all procedural orders and scheduling directives issued by the Commission or the presiding Administrative Law Judge. I further commit to comply with all applicable rules of professional conduct, including the rules of professional
10. Address for Service. I designate Calderwood & Harkness LLP, 1601 K Street NW, Suite 9
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⚑ Penalty / liquidated damages
10. Address for Service. I designate Calderwood & Harkness LLP, 1601 K Street NW, Suite 900, Washington, DC 20006, as my address for service of all pleadings, orders, notices, and correspondence in these proceedings. I consent to electronic service at the following email address: gtrujillo@calderwoodharkness.com. I declare under penalty of perjury, pursuant to 28 U.S.C. § 1746, that the foregoing is true and correct