B4FV-14-C with mounted auxiliary drive Not recommended fo Bevel-helical gearboxes B4

Flender/Flender Gear Units/Bevel-helical gearboxes B4

y Practice and the ITSA, compelling production of the records Plaintiffs have requested under those agreements, and permitting Plaintiffs to conduct thorough physical inspection of Vernons systems; . For declaration that Vernon is in breach of the PPTA and the ITSA and that Bicent is entitled to the PPTA Termination Payment in an amount to be determined at trial; . For compensatory damages from all Defendants in an amount to be determined at trial; . For pre- and post-judgment in terest from all Defendants; . For declaratory relief against Vernon; . For punitive damages against all Defendants; . For all attorneys fees , expenses, and costs; . For such other and further relief as the Court deems just and roper. DEMAND FOR JURY TRIAL Plaintiffs demand jury trial for all claims so triable. Dated: March 1, 2 Respectfully Submitted, BRAUNHAGEY & BORDEN LLP : Andrew Levine Attorneys for Plaintiffs VERIFICATION am the Plant Manager of the Malburg Generating Station, owned by PlaintiffBicent (California) Malburg LLC ("Bicent") and operated by Plaintiff Colorado Energy Management, LLC ("Colorado Energy''). am an employee of Heorot Power Management LLC, the sole member of Colorado Energy. am authorized to make this verification on Bi cent and Colorado Energy' behalf. have read the foregoing Complaint for breach of contract, frustration of purpose, breach of the covenant of good faith and fair dealing, negligent misrepresentation, and declaratory and injunctive relief (the "Complaint') and know its contents. have personal knowledge of the facts alleged in paragraphs 1-1 and 3-9, except as to those matters which are alleged on information and belief, and believe the facts alleged in these paragraphs to be true. declare under penalty of perjury under the laws of the State of California that the foregoing is true and correct. Executed on March ., 2, at Vernon, California. ~~ Matt Richards 1