BILL LOCKYER, Attornev General
' of the State of California -
PETER SIGGINS
~ Chief Deputy Attorney General
i RICHARDFRANK
! Chief Assistant Attorney General
MORRIS BEATUS
~ Acting Assistant Attorney General
i KEN ALEX
~ Supervising Deputy Attorney General
I PAMELA MERCHANT (SBN 2 13 169)
~ Special Deputy Attorney General
PAUL STEIN (SBN 184956)
i Deputy Attorney General
LAURA ZUCKERMAN (SBN 16 1896)
Deputy Attorney General
455 Golden Gate Avenue, Suite 11000
San Francisco, CA 94102
Attorneys for People of the State of California
ex rd. Bill Lockyer, Attorney General of the State of California
IN THE SUPERIOR COURT OF THE STATE OF CALIFORNIA
FOR THE COUNTY OF SAN FRANCISCO
PEOPLE OF THE STATE OF CALIFORNIA ex rel. Case No.: CGC
BILL LOCKYER, ATTORNEY GENERAL OF THE
STATE OF CALIFORNIA,
Plaintiffs, COMPLAINT
RESTITUTION,
V. PENALTIES,
AND OTRER
RELIANT ENERGY, INC.; RELIANT ENERGY ANCILLARY
SERVICES, INC.; RELIANT ENERGY POWER
GENERATION, INC.; RELIANT RESOURCES, (California
INC.; RELIANT ENERGY COOLWATER, L.L.C.; Code 8 17200)
RELIANT ENERGY ELLWOOD, L.L.C.; RELIANT
ENERGY ETIWANDA, L.L.C.; RELIANT ENERGY
MANDALAY, L.L.C.; RELIANT ENERGY
ORMOND BEACH, L.L.C.; and DOES l-100,
Defendants.
The People of the State of California ex rel. Bill Lockyer, Attorney General
of California, allege the following on information and belief:
SNIPPETS:
I PAMELA MERCHANT (SBN 2 13 169)
Attorneys for People of the State of California ex rd.
Bill Lockyer, Attorney General of the State of California
SERVICES, INC.; RELIANT ENERGY POWER
RELIANT ENERGY ELLWOOD, L.L.C.; RELIANT ENERGY ETIWANDA, L.L.C.; RELIANT ENERGY MANDALAY,
ORMOND BEACH, L.L.C.; and DOES l-100,
Complaint for Restitution, Civil Penalties, Injunction, and Other Equitable and Ancillary
defendants have unlawfully collected millions of dollars.
jje use or employment by any person of any unlawful, unfair, or fraudulent business act or
The facility consists of four separate 1 electricity generating units with a combined
RELIANT COOLWATER is a wholly-owned, indirect subsidiary of defendant Reliant Energy
Power Generation, Inc.
the IS0 on or about February 12,
This Participating Generator Agreement, as amended,
successor entities, "RELIANT ELLWOOD"), formerly Oeste Power Generation, L.L.C., is a 10
RELIANT ELLWOOD acquired from Southern California Edison Company an electricity
20 successor entities, &RELIANT ETIWANDA"), formerly Mountain Vista Power Generation,
18 all to the detriment of the reliability of the California electricity market, the ISO, the
County of San Francisco.
The IS0 uses the imbalance 10 energy and Ancillary Services bought and sold in these markets
Invert the reserve capacity to actual energy and deliver it to the grid when it is called on
jroviding Ancillary Service capacity must, as a matter of law, follow IS0 dispatch
Instead of producing energy out of obligated Ancillary Services capacity as directed by
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