Helical gear reducers H3 flender gear reducer H3CV-27-C

Flender/Flender Gear Units/Helical gear reducers H3

ding the scheduling of the ovember 2, 2, Capacity Test and its refus al to pay the costs of thi test. 1. Bicent has suffered damages as esult of Vernons frustration of the PPTA, including as result of damage and stress on the Facility, del ays in repairs to the Facility, costs associated with preparing for the November 1, 2 test, reduc ed or lost Energy Payments, and reduced or lost Capacity Payment . Bicent requests that the PPT be terminated and Vernon ordered to make the Terminati on Payment thereunder, equal to th net present valu of all amounts that would be due Bicent under the PPTA. Sixth Cause of Action: Negligent Misrepresentation or Omissions Regarding Dispatch Notices (By all Plaintiffs against all Defendants) 1. Plaintiffs reallege each paragraph of the Complaint as if fully set forth herein. 1. Defendants had duty to exercise care in the transmission of ispatch notices in accordance with the CAISO Tar iff and Good Utility Practice. 1. Defendants violated this dut by failing to properly monitor th Automated Dispatch System and report dispatch instr uctions from CAISO to Plaintiff . Plaintiffs are informed and believe that at least the fo llowing dispatch notices were not roperly reporte by Defendants: 1 2 3 4 5 6 7 8 9 1 1 1 1 1 1 1 1 1 1 2 2 2 2 2 2 2 2 2 3 Case No. ____________ VERIFIED COMPLAINT CAISO Automated Dispatch Sys tem request on January 3, 2 at or about 8:0 .. to ramp up from 7 megawatts to 9.7 mega watts. Upon information and beli ef, there are numerous other instances where Vernon has faile to notify Bicen of CAISO Aut omated Dispatch System requests. For example, Vernons recent production of informati on in response to Plaintiffs requests reveals that the City dispatch logs do not identify single requested load change for November 2. 1. As result of Vernons failure to provide noti ce of CAISO disp atch instruction to Plaintiffs in timely manner or at all, Bicent has been dam