BILL LOCKYER, Attorney General
of the State of California
PETER SIGGlNS
Chief Deputy Attorney General
RICHARD FRANK
Chief Assistant Attorney General
MORRIS BEATUS
Acting Assistant Attorney General
EN ALEX
Supervising Deputy Attorney General
PAMELA MERCHANT (SBN 2 13 169)
Special Deputy Attorney General
PAUL STEIN (SBN 184956)
Deputy Attorney General
LAURA ZUCKERMAN (SBN 161896)
Deputy Attorney General
455 Golden Gate Avenue, Suite 11000
San Francisco, CA 94102
.\ttorneys 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.:
BILL LOCKYER, ATTORNEY GENERAL OF THE
STATE OF CALIFORNIA,
Plaintiffs, COMPLAINT
v. PENALTIES,
AND OTHER
WILLIAMS ENERGY MARKETING & TRADING ANCILLARY
~ COMPANY; THE WILLIAMS COMPANIES, INC.;
~ andDOES l-100,
Code 5
J Defendants.
I The People of the State of California ex rel. Bill Lockyer, Attorney
of California, allege the following on information and belief:
1.
Complaint for Restitution, Civil Penalties, Injunction, and Other
SNIPPETS:
Attorney General of the State of California
PETER SIGGlNS Chief Deputy Attorney General
Acting Assistant Attorney General
PAMELA MERCHANT (SBN 2 13 169)
Complaint for Restitution, Civil Penalties, Injunction, and Other Equitable and Ancillary
Defendants have conspired to engage in, and have engaged in, a scheme to violate the rules of
IS0 market and to tortiously convert property to which the IS0 has an exclusive possessory
all to the detriment of the reliability of the California electricity market and California's
sold the same capacity into the lucrative "spot" market for wholesale power.
The loss and misuse of these ~ critically important reserves has posed, and continues to
Plaintiff seeks an injunction requiring defendants to cease 1 and desist from committing
predecessor and successor entities, "WILLIAMS ENERGY AURKETING & TRADING"),
formerly Williams Energy Services Company, is a corporation formed under the laws of the State
"WILLIAMS COMPANIES") is a corporation formed under the laws of the 10 State of Delaware.
The AES Corporation, Inc.: AES Alamitos, L.L.C., AES Huntington Beach, L.L.C., and AES
17 Redondo Beach, L.L.C..
21 capacity, energy, and Ancillary Services from the AES Plants.
California Edison Company an electricity generation facility located in Huntington Beach,
27 County of San Francisco.
17 AB 1890 established two new entities to administer the deregulated energy market:
18 California Power Exchange and the ISO.
16 Services on behalf of all load-serving entities.
25 convert the reserve capacity to actual energy and deliver it to the grid when it is called
Moreover, a SC providing 2c Ancillary Service capacity must, as a matter of law, follow IS0
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