As this may hit the media:


This motion asks for relief from the bankruptcy stay to pursue dispute resolution at CPUC.   We ask that EES and EEMC be allowed to: 

"seek(ing) the restoration of the cumulative unpaid credit balances which previously were present on bills to EES and EEMC rendered by PG&E; and 2) to permit EES and EEMC to deposit monies representing the amount of disputed bills from PG&E with the CPUC pursuant to Rules 10 and 22 of PG&E's applicable tariff."

Our PX credits were removed from the bills late last year.   We have been billed by PG&E for the positive PX credit which is accruing now that we have put customers back on direct access and the "market price" has fallen below the generation portion of the tarriff.   We are asserting a recoupment argument.   The recoupment is ostensibly an offset against amounts which we are owed (negative PX credit).  Persuing this offset essentially liquidates the claim we are owed at 100 cents.






-----Original Message-----
From: CARL EKLUND [mailto:CEKLUND@LLGM.COM]
Sent: Thursday, September 06, 2001 6:06 PM
To: Steffes, James D.; Mellencamp, Lisa; Tribolet, Michael; Williams,
Robert C.; mday@gmssr.com
Cc: Charles Ferguson; John Klauberg; Sanford Kingsley
Subject: Motion for Relief from Stay


The Memorandum and Motion for Relief from Stay and other appropriate pleadings for relief from PG&E were filed in the Bankruptcy Court in the Northern District of California at 3:52 p.m., Thursday, September 6, 2001.  Stamped copies of the pleadigs will be circulated to Enron.  




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