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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.