The following is attached for paperless electronic filing: Affidavit in Support of Motion for Admission Pro Hac Vice of Jill M.

Transcription

1 December 12, 2017 Ms. Kavita Kale Michigan Public Service Commission 7109 W. Saginaw Hwy. P. O. Box Lansing, MI Via E-filing RE: MPSC Case No. U Dear Ms. Kale: The following is attached for paperless electronic filing: Motion for Pro Hac Vice of Jill M. Tauber Affidavit in Support of Motion for Admission Pro Hac Vice of Jill M. Tauber Letter of Good Standing for Jill M. Tauber Letter from State Bar of Michigan Receipt for Admissions from State Bar of Michigan Proof of Service Sincerely, Christopher M. Bzdok cc: Parties to Case No. U ALJ Suzanne D. Sonneborn

2 STATE OF MICHIGAN BEFORE THE MICHIGAN PUBLIC SERVICE COMMISSION In the matter of the Application of DTE ELECTRIC COMPANY for approval of Certificates of Necessity pursuant to MCL 460.6s, as amended, in connection with the addition of a natural gas combined cycle generating facility to it generation fleet and for related accounting and ratemaking authorizations U ALJ Suzanne D. Sonneborn MOTION FOR ADMISSION PRO HAC VICE OF JILL M. TAUBER AS CO-COUNSEL OF RECORD ON BEHALF OF THE SIERRA CLUB Christopher M. Bzdok of the law firm Olson, Bzdok & Howard, P.C., is counsel of record in MPSC Case No. U for the Michigan Environmental Council (MEC) and the Sierra Club and moves that Jill M. Tauber be granted permission to participate in this case as cocounsel of record for the Sierra Club. In support of this Motion, the movant states as follows: 1. Rule 309(2) of the rules of practice and procedure for the Michigan Public Service Commission ( MPSC or Commission ) states: An attorney who is duly licensed to practice law in another state or in the courts of the United States may be permitted to practice before the Commission on the same basis as in the circuit courts in this State. 2. Rule 15, Section 2 of the rules concerning the State Bar of Michigan states: Any person who is duly licensed to practice law in another state or territory, or in the District of Columbia, of the

3 United States of America, or in any foreign country, may be permitted to engage in the trial of a specific case in a court or before an administrative tribunal in this state when associated with and on motion of an active member of the State Bar of Michigan who appears of record in the case. Such temporary permission may be revoked by the court summarily at any time for misconduct. 3. The movant is an active member in good standing of the New York State Bar and the District of Columbia Bar, and an attorney of record in this matter. 4. Jill M. Tauber is the Managing Attorney for the Clean Energy Program with Earthjustice representing the Sierra Club in this matter. Earthjustice is a non- profit public interest law firm dedicated to protecting the natural resources, safeguarding public health, and promoting clean energy. Ms. Tauber s office is located at: 1625 Massachusetts Ave., NW, Suite 702 Washington, DC (202) Jill M. Tauber is duly licensed and admitted to practice law in the State of New York and the District of Columbia; is a member in good standing with the New York State Bar and the District of Columbia Bar; and has paid the required fee to the State Bar of Michigan for temporary admission. (See attached Affidavit, Certificate of Good Standing from the State of New York, and letter from the State Bar of Michigan.) 6. The undersigned states the following: a. I have read the affidavit of Jill M. Tauber and supporting documentation. b. I have made a reasonable inquiry concerning the averments made in the attached affidavit and believe the out-of-state attorney s representations to be true. c. I agree to ensure that the procedures of Michigan Court Rule are 2

4 followed. d. I agree to forward a copy of this Motion and the attachments to the Attorney Grievance Commission of the State of Michigan in compliance with Rule I respectfully request that Jill M. Tauber be admitted as co-counsel of record for the Sierra Club in Case Number U Date: December 5, 2017 OLSON, BZDOK & HOWARD, P.C. Counsel for MEC, NRDC & Sierra Club By: Christopher M. Bzdok (P53094) 420 E. Front St. Traverse City, MI Phone: 231/ ; Fax: 231/ chris@envlaw.com 3

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8 December 11, 2017 Michigan Public Service Commission 7109 West Saginaw Highway P.O. BOX Lansing, Michigan Re: In re Matter DTE Electric Co Case No. U NOTIFICATION PURSUANT TO MCR 8.126(A)(1)(b) Please be advised that Jill M. Tauber has been temporarily admitted zero (0) times within the past 365 days. In accordance with MCR 8.126(A), Jill M. Tauber is eligible for temporary admission. In accordance with MCR 8.126(A)(1)(c), by copy on this notice, the Michigan attorney moving for admission of the above-referenced out-of-state attorney is reminded to provide the State Bar of Michigan via at with a copy of the order granting or denying the motion upon entry. Pro Hac Vice Temporary Admission Department State Bar of Michigan Michael Franck Building 306 Townsend Street Lansing, MI prohacvice@mail.michbar.org cc: Jill M. Tauber, jtauber@earthjustice.org Christopher M. Bzdok, chris@envlaw.com

9 12/5/2017 State Bar of Michigan: member area Welcome Jill M. Tauber Pro Hac Vice New Case/Matter Court Judge Michigan Lawyer Upload Documents Process Fees Receipt Pro Hac Vice Admission Receipt Jill M. Tauber A copy of this receipt must be attached to the motion. The motion must be filed by the Michigan attorney in the court, administrative tribunal or agency, or in the arbitration in which you are seeking temporary admission. Member Area: Portal Home Edit Profile Change Password Change Change User Name Add/Edit Jurisdictions Add New Case/Matter Logout By submitting these documents, you are NOT temporarily admitted. The motion and documents required by MCR must be filed with the court, administrative tribunal or agency, or in the arbitration in which you are seeking temporary admission and the filing fee, if any, must be paid. Only the court, administrative tribunal or agency, or arbitrator may enter an order allowing temporary admission. Once the order is entered, the Michigan attorney must a copy of the order to ProHacVice@mail.michbar.org as soon as practicable. Your payment was charged to Credit Card: ************2828 Payment Date: 12/05/2017 Description Amount Pro Hac Vice $ CPF-Pro Hac Vice $15.00 Total: $ Next > 1/1

10 STATE OF MICHIGAN BEFORE THE MICHIGAN PUBLIC SERVICE COMMISSION In the matter of the Application of DTE ELECTRIC COMPANY for approval of Certificates of Necessity pursuant to MCL U s, as amended, in connection with the addition of a natural gas combined cycle ALJ Suzanne D. Sonneborn generating facility to it generation fleet and for related accounting and ratemaking authorizations PROOF OF SERVICE On the date below, an electronic copy of the Motion for Pro Hac Vice of Jill M. Tauber, Affidavit in Support of Motion for Admission, Letter of Good Standing, Letter from State Bar of Michigan and receipt for Admissions from State Bar of Michigan was served on the following: Name/Party Administrative Law Judge Suzanne D. Sonneborn Counsel for DTE Electric Co. David S. Maquera Michael J. Solo Counsel for MPSC Staff Heather M.S. Durian Amit T. Singh Counsel for Attorney General John A. Janiszewski Celeste R. Gill Counsel for Environmental Law & Policy Center Margrethe Kearney Counsel for ABATE Robert A. W. Strong Michael J. Pattwell Sean P. Gallagher Stephen A. Campbell Address sonneborns@michigan.gov mpscfilings@dteenergy.com david. maquera@dteenergy.com solom@dteenergy.com durianh@michigan.gov singha9@michigan.gov ag-enra-spec-lit@michigan.gov Janiszewskij2@michigan.gov Gillc1@michigan.gov mkearney@elpc.org rstrong@clarkhill.com mpattwell@clarkhill.com sgallagher@clarkhill.com scampbell@clarkhill.com

11 Counsel for Midland Cogeneration Venture Limited Partnership Kyle M. Asher Richard Aaron Jason Hanselman Counsel for Energy Michigan, Inc.; Michigan Energy Innovation Business Council; and the City of Ann Arbor Timothy J. Lundgren Laura A. Chappelle Toni L. Newell Counsel for International Transmission Company (ITC Transmission) Amy Monopoli Stephen J. Videto The statements above are true to the best of my knowledge, information and belief. OLSON, BZDOK & HOWARD, P.C. Counsel for MEC-SC Date: December 12, 2017 By: Karla Gerds, Legal Assistant Kimberly Flynn, Legal Assistant Marcia Randazzo, Legal Assistant 420 E. Front St. Traverse City, MI Phone: 231/ and and