MEMORANDUM OPINION
COLLYER, District Judge.
Littleton Gas Company ("Littleton") appeals a December 7, 2000, Decision and Order ("D & O") of the United States Department of Energy's ("DOE") Office of Hearings and Appeals ("OHA"). OHA denied Littleton's application for a full "volumetric" refund of overcharges paid to Vessels Gas Processing Company ("Vessels") during the period of price controls on petroleum products in the 1970s. Littleton and...
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