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Answer of EPSA in Opposition of the Motion to Intervene Out-Of-Time, and Answer to Motion to File Out-Of-Time Brief of the Missouri Public Service Commission

Conclusion

Wherefore, for the reasons set forth above, EPSA respectfully requests that the Commission deny the MOPSC’s motion to intervene out-of-time, and treat the MOPSC’s brief as that of an amicus curiae.

Dated: April 9, 2004

Respectfully submitted,


/s/ Larry F. Eisenstat [E-Filed]
_______________________________
Larry F. Eisenstat
Michael J. Wentworth
Dickstein Shapiro Morin & Oshinsky LLP
2101 L Street, N.W.
Washington, D.C. 20037-1526
(202) 785-9700

Attorneys for the Electric Power Supply Association

CERTIFICATE OF SERVICE

I hereby certify that I have caused to be served a copy of the foregoing document by first-class mail upon each person designated on the official service list compiled by the Secretary in this proceeding.
Dated at Washington, D.C. this 9th day of April 2004.

/s/ Michael J. Wentworth [E-Filed]
_______________________________
Michael J. Wentworth
Dickstein Shapiro Morin & Oshinsky LLP
2101 L Street NW
Washington, DC 20037-1526