1. 124. See Wolf, , supra note 95 for a fuller discussion of our legal analyses regarding Certificates.
2. 83. People v. Still, 369 N.Y.S.2d at 761 (App. Div. 1975).
3. 65. PremPro Order, supra note note 61, at 1; Transcript of Hearing on Motion to Quash/Motion for Protective Order at 3, Dummit v. CSX Transportation, Inc., 01-C-145 (Cir. Ct. W. Va. Dec. 7, 2006) (on file with author).
4. 132. United States v. Mead Corp., 533 U.S. 218, 241 (2001). The Court has ruled that “interpretive rules…enjoy no Chevron status as a class.” Id., at 232. However, guidance documents are entitled to Skidmore deference. Christensen v. Harris County, 529 U.S. 576, 585–87 (2000) (relying on cases in which Skidmore deference was used for guidance documents).
5. 33. People v. Newman, 298 N.E.2d 651 (N.Y. 1973).