1st strike new target !
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PENNSYLVANIA PUBLIC COMMISSION
GARY FORD :
: Docket No. C-2008-2026482
PECO ENERGY COMPANY :
PLAINTIFF INTERROGATORIES TO DEFENDANT PECO ENERGY COMPANY
THE FOLLOWING INTERROGATORIES are to be answered by the Defendants separately and under oath within thirty (30) days after service pursuant to 52 Pa.Code § 5.341. Answers shall be inserted in the spaces immediately following the interrogatories. The requested information must be provided regardless of whether the Defendant possesses it personally or by others, or persons acting on behalf of the said Defendant. If you (Defendant) or anyone acting on your behalf should discover any new information or should change a position, you are obligated to supplement your answers within the time permitted by law.
1. State your full name(s), address, fax number, email address, direct phone number, and occupation(s), and the name, address, occupation and relationship to the parties of each individual who assisted the answering of these interrogatories.
2. Before answering these interrogatories, state whether or not you have:
A. Made a due and diligent search of all related documents, receipts, books, reports, memos, photos and writings within your possession or under your control, in order to obtain information with respect to this action.
B. Made a due and diligent inquiry of your friends, relatives and those persons available to assist you in order to obtain information with respect to this action.
3. Pursuant to your answer in paragraph four (4) please provide the factual bases to your answer “ These deposits were generated during periods when service was transferred out of an existing renter’s name …”. Please elaborate in full if you need additional space you can produce this on a separate sheet of paper.
4. In paragraph four why is the complaining party being subject to faulty billing practices as you said “… more easily”.
5. How many customers in a give month does this new computer system generate notices of security deposit requirements?
6. How many customers actually have to pay this security?
7. When the notice goes out do you provide a working telephone number, if so what is it?
A) how many attendant are available to answer that line ?
B) how many line are there ?
C) how many calls are received in a day ?
D) how many calls are received in a week ?
E) how many letter do you get in complaint of security deposit request ?
8. Explain on each account regarding this complainant why this customer was over billed?
9. Provide a detailed list of all account that being statements.
10. If a costumer is late on payment does PECO charge a late fee and or interest fee if so explain in details these events and amounts.
11. When PECO finds out that the system has over billed a customer does if refund the money with interest?
12. Please proved the number of over billing in any given month?
13. What is the total amount refunded in a given month?
14. What are the Standard operation procedure that PECO has in place regarding lateness and overpayments?
Respectfully submitted by:
Gary Ford, sui juris
Date: April 7, 2008
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