so ya wanna be a FERC lawyer, Part II

Part II: FERC Writing Handbook

1. "WHEREFORE, PREMISES CONSIDERED" adds a note of authority to your
pleadings. In fact, some administrative law judges will throw your pleading
into the special incinerator marked "Nonconforming Pleadings" (located on the
west side of the FERC building) unless such language is present.

2. Pronouns should be used sparingly, if at all. With few exceptions,
parties must always be named to avoid confusion, even if it means the name of
the party will appear several times in one sentence.

3. The verb "request" may not be used without the word "to." Example:
"Pipeline X respectfully requests the Commission to grant its motion."

4. "In regards to" or "vis-a-via" sound more intelligent than "about" or
"concerning."

5. If you are not sure you've conveyed an important point effectively,
repeat the statement verbatim at various other points in your pleading for
emphasis. Additionally, repeating a contractual provision several times in a
contract will give your client greater rights than if you only include the
provision once.

6. Always recite the entire history of the proceeding in your pleading
before stating the purpose of your pleading. No FERC staffer ever remembers
what happens, and the added pages will make your pleading really impressive.

7. When in doubt, insert more commas.