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MOTION FOR LEAVE TO INTERVENE AND PROTEST OF THE ELECTRIC POWER SUPPLY ASSOCIATION re: PUBLIC UTILITY DISTRICT NO. 1 OF SNOHOMISH COUNTY V. MORGAN STANLEY CAPITAL GROUP, INC.

INTRODUCTION

Public Utility District No. 1

Of Snohomish County, Washington,

Complainant

v.

Morgan Stanley Capital Group, Inc.,

Respondent.

Docket No. EL02-56-000

Pursuant to Rules 211 of the Rules of Practice and Procedure of the Federal Energy Regulatory Commission (FERC or Commission), 18 C.F.R. § 385.211, the Electric Power Supply Association (EPSA) hereby requests leave to intervene and protest the complaint filed in the above-captioned proceeding.