Representative Enforcement Experience:

• Lead counsel for energy company in related civil enforcement investigation, criminal investigation, market-related dispute, regulatory proceedings, petition for declaratory order, and civil litigation with regard to bilateral transactions for financially settled products in PJM power market.  
• Company representation related to CFTC and DOJ investigations of alleged conspiracy involved commodities traders and brokers who traded natural gas futures contracts using misappropriated material, non-public information.   
• Represented broker in CFTC investigation of alleged use of off-platform communications.  
• Represented trading company in exchange inquiry and CFTC investigation concerning alleged position limit violations.
• Counsel for broker in exchange inquiry related to alleged indirect wash trades.
• Represented trader in exchange inquiry related to alleged money pass in violation of exchange rules.  
• Advised client on market monitor inquiry related to "pseudo virtual transactions" in organized power market.  
• Represented natural gas production company in FERC and NERC investigation of reliability issues following winter storm.  
• Represented owner and trader in FERC Enforcement investigation and related civil enforcement action regarding up-to congestion (UTC) trading in PJM.
• Represented senior manager of generation owner in FERC Enforcement investigation of bidding practices. 
• Represented natural gas company in FERC Enforcement investigation of compliance with certificate and reporting requirements. 
• Represented senior trader in FERC Enforcement action regarding natural gas trading in West. 
• Represented trading company in FERC Enforcement investigation of natural gas trading in Eastern US markets.
• Represented generation company in FERC Enforcement investigation of qualification and sales in ISO-administered capacity auction.
• Represented trading company in FERC Enforcement investigation of affiliates' participation in virtual and transmission markets.
• Represented client in FERC Enforcement investigation of trading in financial product in day-ahead and real-time markets.
• Represented financial institution in FERC Enforcement investigation of third-party trading in CAISO.
• Represented energy trading company in FERC Enforcement investigation related to power imports and related transmission schedules in day-ahead and real-time markets.
• Represented trading company in FERC Enforcement investigation of natural gas sales to electric generator subject to mitigation in NYISO.
• Represented client in FERC Enforcement investigation of potential violations of hydro safety regulations and license.
• Represented financial institution in self-report of potential market manipulation involving trading in related positions.
• Represented client in self-report of potential violations related to obligations of market-based rate sellers.
• Lead counsel for client subject to FERC Enforcement investigation of generator interconnection and participation in ISO market.  
• Represented client in investigation of energy market offers in ISO market.  
• Represented energy company in CFTC investigation of trading in two energy commodity markets.  
• Represented client in FERC Enforcement investigation of electricity market transactions.  
• Lead counsel for client in FERC Enforcement investigation related to the operation of generation in ISO market.  
• Represented client in self-report to FERC Enforcement for activity in ISO markets.  
• Represented supplier in FERC Enforcement investigation of energy market activity.  
• Lead counsel for energy marketing company in non-public FERC Enforcement investigation regarding participation in ISO-administered markets.  
• Represented power marketer in a FERC Enforcement investigation about trading activity in ISO-administered energy markets.  
• Assisted multiple clients in responding to CFTC subpoenas in crude oil and natural gas markets.  
• Represented power marketer in an investigation by FERC Enforcement, which resulted in a favorable finding of no violation.  
• Conducted an internal investigation for a power marketer concerning market activity.

Representative Regulatory/Compliance Experience:

• Provided advice on formation of trading company affiliated with renewable asset portfolio with strategic .  
• Advised multilateral trading facility on CFTC regulatory requirements for exempt SEFs and FBOTs.
• Represented generator on dispute related to retention of surplus interconnection capacity for unexecuted interconnection agreement.
• Provided regulatory advice on Dodd-Frank swap definition related to price and volumetric optionality in physical commodity transactions. 
• Advised non-U.S. entity with regard to CFTC RED list (Registration Deficient) for allegedly acting in a capacity that required registration. 
• Represented generation company on application for fuel cost recovery in CAISO.  
• Provided advice to renewable generation company on CFTC swap data reporting requirements. 
• Represented trading company with expansion into power markets, including market access and related compliance issues. 
• Represented generation company in reactive power rate proceeding. 
• Represented transmission owner in petition for review of FERC orders on cost allocation issues.
• Counseled many clients on capacity market design issues and proposed changes, including the potential application and design of mitigation measures.  
• Successfully prosecuted a complaint against ISO-NE to qualify capacity.  
• Advised client on Standards of Conduct compliance for transmission providers.  
• Represented generators regarding proposed capacity market changes in NYC.  
• Represented a supplier in a complaint docket at FERC regarding the entry of new capacity in the NYC market.  
• Lead counsel in defending FPA Section 222 market manipulation claims in organized power market.  
• Lead counsel for shippers in a FERC natural gas pipeline rate case, which resulted in settlement prior to hearing.  
• Lead counsel for power generating company for waiver of ISO tariff provisions, which led to significant financial recovery.  
• Lead counsel for natural gas exploration and production company in a FERC rate case for a Gulf Coast offshore pipeline.  
• Advised client with compliance with ISO market power mitigation measures for participation in capacity and energy markets via DC transmission facility.  
• Handled cases at FERC related to the first ever buyer-side mitigation measures for the New York City ICAP market.  
• Represented market participants in a complaint regarding the lack of compensation for generators subject to a must-offer obligation.  
• Conducted compliance training for power marketer on FERC, CFTC, and DOE regulations.  
• Conducted compliance training on FERC Standards of Conduct and FERC/CFTC anti-manipulation regulations.  
• Prepared transactional documents regarding contractual obligations for participation in wholesale power market.  
• Advised on transaction for LNG terminal capacity.  
• Advised a cogeneration plant on FERC's requirements for status as a Qualifying Facility.  
• Advised clients with compliance with FERC's policy regarding Asset Management Agreements.