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The firm represented Petitioner in a proceeding at the Public Service Commission seeking a declaratory ruling that the transfer of certain ownership interests should not be reviewed pursuant to PSL §70. The Commission issued a declaratory ruling finding the Petitioner’s argument persuasive and agreeing with Petitioner’s interpretation that the transaction should not be reviewed under Section 70 and even if it did, the Wallkill Presumption applied because there was no potential harm to New York ratepayers.