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CALIFORNIA INDEPENDENT SYSTEM OPERATOR CORP v RELIANT ENERGY SERVICES INC Click to find out why . . .



Keywords & Phrases
CaseNo: CISOCVRESI380560, Plaintiff: CALIFORNIA INDEPENDENT SYSTEM OPERATOR CORP, State: CA California, UniqueCaseRef: LCD>CISOCVRESI380560, CourtName: IT IS ORDERED THAT THE PARTIES TO THIS ACTION SHALL APPEAR BEFORE THIS COURT ON, Reliant Energy, California, Is0, Iso, Is0 Tariff, Complaint, Llc, Scheduling Coordinator, Participating Generator, California Independent System, Agreement, Power, Generating Unit, Emergency, Electricity, Is0 Controlled Grid, Ancillary Services, Accordance, Provisions, Federal Power Act, Obligations, System Operator Corporation, Instructions, San Francisco, Reliant Energy Etiwanda, Energy Ellwood, Verified Complaint, Is0 Protocols, Parties, Osi, Ill, District, Operator Corporation , ContentID: 120249970

Case Documents
1   COMPLAINT
[ see first page and extracted highlights below  ] ItemID: 123702
102 pages
PDF
2 2000-05 PROPOSED ORDER
[ see first page and extracted highlights below  ] ItemID: 123706
3 pages
PDF
Total Documents: 2 documents , 105 pages
Price: $ 24.95


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1 . COMPLAINT

EXTRACTED KEY WORDS
CALIFORNIA
IS0
ISO
IS0 TARIFF
COMPLAINT
LLC
SCHEDULING COORDINATOR
PARTICIPATING GENERATOR
CALIFORNIA INDEPENDENT SYSTEM
AGREEMENT
POWER
GENERATING UNIT
EMERGENCY
ELECTRICITY
IS0 CONTROLLED GRID
COURT
ANCILLARY SERVICES
ACCORDANCE
DEFENDANTS
PROVISIONS
FEDERAL POWER ACT
OBLIGATIONS
SYSTEM OPERATOR CORPORATION
INSTRUCTIONS
SAN FRANCISCO
RELIANT ENERGY ETIWANDA
ENERGY ELLWOOD
VERIFIED COMPLAINT
IS0 PROTOCOLS
                                                                     -'
                           -

  1  Norma G. Formanek (CA Bar No. 111474)
       Laura C. Roche (CA Bar No.  174596)
 2     FARELLA  BRAUN  &  MARTEL  LLP
       Russ Building,  30th Floor
 3     235 Montgomery Street
       San Francisco, CA  94104
 4     Telephone: (415) 954-4400
       Facsimile:  (4 15) 9544480
 5
       Edward Berlin
 6  John R. Ferguson
       Timothy A. Ngau
 7     SWIDLER BERLIN  SHEREFF FRIEDMAN.  LLP
       3000 K  Street, N.W.
 8  Washington, DC 20007                                                     CLERK  U.S. DISTRICT 
                                                                      EASTERN'tMSDKT        CT 
       Telephone: (202) 424-7500                                      BY
 9     Facsimile:  (202) 424-7643                                                    OEWTY CLER!t

10  [Appearing Pro Hat  Vice]

11  Attorneys for Plaintiff
       CALIFORNIA  INDEPENDENT SYSTEM
12  OPERATOR CORPORATION

13
                                        UNITED  STATES DISTRICT  COURT
14
                                 FOR THE EASTERN DISTRICT  OF CALIFORNIA
15
                                            SACRAMENTO  DIVISION
16                                                              iiwo$-
                                                                               Q~l--Q238~~
                                                                                                   
17  CALIFORNIA  INDEPENDENT SYSTEM                            Civil  No.
18  OPERATOR CORPORATION,

19                       Plaintiff,
                                                              VERIFIED  COMPLAINT  FOR
20            vs.                                             INJUNCTIVE  RELIEF
21  RELIANT  ENERGY SERVICES, INC.;
       RELIANT  ENERGY ORMAND  BEACH LLC;
22  RELIANT  ENERGY MANDALAY,  LLC;
       RELIANT  ENERGY ETIWANDA,  LLC;
23  RELIANT  ENERGY COOLWATER, LLC;  and
       RELIANT  ENERGY ELLWOOD,  LLC
SNIPPETS:
  • CALIFORNIA INDEPENDENT SYSTEM
  • 21 RELIANT ENERGY SERVICES, INC.; RELIANT ENERGY ORMAND BEACH LLC;
  • RELIANT ENERGY ETIWANDA, LLC;
  • ISO"), for its verified complaint against Reliant Energy Services, inc.;
  • VERIFIED COMPLAINT FOR INJT_WCTIVE
  • Beach LLC; Reliant Energy Mandalay, LLC; Reliant Energy Etiwanda, LLC; ReIiant Energy
  • Coolwater, LLC, and Reliance Energy Ellwood, LLC,
  • under the laws of the United States, specifically, the Federal Power Act, 16 U.S.C. $3 824 et
  • 10 proceeding arising under or relating to the IS0 Tariff "shall be brought in any court of
  • Defendants reside, for purposes of determining venue, in this judicial district.
  • 26 Energy Regulatory Commission pursuant to Section 205 of the Federal Power Act,
  • by selling their electricity into the California ISO's markets and by availing themselves of
  • 10 as well as by entering into a Scheduling Coordinator Agreement or Participating Generator
  • 19 California, if Reliant refuses to respond to the ISO's instructions to deliver power, as
  • Reliant is a Scheduling Coordinator, pursuant to section 2.2.6 of the IS0 Tariff..
  • 23 ISO, including the quantity, duration, location of the generating unit and transmission
  • 25 Participating Generator Agreements and that it has a continuing obligation to be bound by
  • energy from the generating units owned by those Defendants to the IS0 controlled grid.
  • A Stage 3 Emergency occurs when electricity
  • 24 be requested by the California Independent System Operator".
  • Enjoining Defendants and each of them to comply with all provisions of the IS0
  • the Tariff have stated that they will default on their payment obligations to the TSO,
  • under Section 202of the Federal Power Act, Reliant Energy will provide electricity in
  • CALIFORNIA iNDEPENDENT SYSTEM OPERATOR CORPORATION
  • Providing Ancillary Services in accordance with Section 2.5;
  • IS0 Tariff and the IS0 Protocols, to direct the operations of the Generator as necessary
  • Bank City/State: San Francisco, California

  • 2 . PROPOSED ORDER

    EXTRACTED KEY WORDS
    LLC
    PARTIES
    COURT
    OSI
    ILL
    DISTRICT
    OPERATOR CORPORATION
    RELIANT ENERGY MANDALAY
    RELIANT ENERGY COOLWATER
    DEFENDANTS
    FILE RESPONSIVE PAPERS
    SUPPORTING EVIDENCE
    CIVIL PROCEDURE
    DISSOLUTION
    PERSONAL SERVICE
    
     2
    
     3
    
    
    
    
     6  FEB  -  6  %OSI
    ill.
    ml  (3 U.S.
                  DISTRICTC~U~T
             1 DISTRICT
                      OF CALI"OT:`
     8        -  -.__-_                          UNITED  STATES DISTRICT COURT
    
     9                                 FOR THE EASTERN DISTRICT  OF CALIFORNIA
    
    10                                               SACRAMENTO  DIVISION
    
    11
    
    12  CALIFORNIA  INDEPENDENT  SYSTEM                                 Civil  No.
             OPERATOR CORPORATION,
    13                                                                  [PROPOSED] ORDER RE HEARING
                                Plaintiff,                              ON PRELIMINARY  INJUNCTION
    14               vs.
    15  RELIANT ENERGY SERVICES, INC.;
    16  RELIANT  ENERGY ORMAND  BEACH LLC;
             RELIANT  ENERGY MANDALAY,  LLC;
    17  RELIANT  ENERGY ETIWANDA,  LLC;
             RELIANT  ENERGY COOLWATER, LLC;  and
    18  RELIANT  ENERGY ELLWOOD,  LLC
    
    19                          Defendants
    
    20
    
    21
    22               IT  IS ORDERED  that the parties to this action shall appear before this Court on
    23                                  at -       o'clock  to SHOW CAUSE why an order of preliminary
    
    24  should not issue. Defendants may file responsive papers and supporting evidence no later than
    25                            .  Plaintiffs  responsive brief and evidence shall be filed no later
    26                           .  Service of these papers shall be made personally upon counsel for
    
    27  parties or as arranged by the parties.
    
    
    
    
    SNIPPETS:
  • FEB - 6 %OSI
  • ill.
  • DISTRICT
  • OPERATOR CORPORATION,
  • RELIANT ENERGY MANDALAY, LLC;
  • Defendants may file responsive papers and supporting evidence no later than
  • 27 parties or as arranged by the parties.
  • Civil Procedure 65 is waived.
  • dissolution on two court days notice by personal service or such other notice as the Court may
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