Demanda Federal Ajuste Combustible AEE

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IN THE UNITED STATES DISTRICT COURT

FOR THE DISTRICT OF PUERTO RICO
DUAMEL SANTIAGO-RAMOS,
INDIVIDUALLY AND AS REPRESENTATIVE OF
THE CONJUGAL PARTNERSHIP OF SANTIAGO
MARINES RIVERA FIGUEROA,
INDIVIDUALLY AND AS CLASS
REPRESENTATIVE, and CARIBBEAN
ECONOMIC COUNCIL, INC.
PLAINTIFF
VS.
AUTORIDAD DE ENERGIA ELECTRICA
DE PUERTO RICO, AKA PUERTO RICO
POWER COMPANY [PREPA] and
MARIMAR PREZ-RIERA, CHAIR, BOARD
OF DIRECTORS INDIVIDUALLY, AND AS
PRESIDENT OF THE BOARD OF DIRECTOR.
DOES A-Z
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Case No.:
CLASS ACTION COMPLAINT
SEEKING DAMAGES
EQUITABLE AND INJUNTIVE
RELIEF
Demand for jury trial
CLASS ACTION COMPLAINT
Plaintiff[s] sues defendant in chancery of this court. In support the appearing party
state[s] and pray[s] as follows:
PRELIMINARY STATEMENT
1. This class action is brought on behalf of 1.8 million customers of defendant[s]
Autoridad de Energia Electrica (herein after PREPA) for damages suffered in
the capricious, arbitrary, and predatory assessment for a fuel adjustment charge
that violations the U.S. Constitution and the Robinson-Patman Act codified as 15
U.S.C. 13 for purchases involved which are , have been and continue to be in
commerce, that there has been discrimination in price between different
purchasers of products of like grade and quality [electric power commodity] , and
Case 3:11-cv-01987-JAF Document 1 Filed 10/06/11 Page 1 of 36
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that effect of discrimination is substantially to lessen compensation or tend to
create monopoly over the retail delivery of electric power to the consumer.
2. Counts 1-5 are constitution violation as against individual consumers, the
complaint seeks constitutional injury including damages for the differential
economic treatment between the religious, political and economic preferential
treatment, injunctive relief seeking affirmative treatment of equality in pricing
among all consumers; Count Six is the Robinson-Patman Act codified as 15
U.S.C. 13 for delivering -in commerce- the identical product at discriminatory
rates. The complaint seeks damages for the price differential with other classes of
rates charged for the same kilowatt hour commodity, injunctive relief, and
declaratory judgment that defendants have violated the Robinson-Patman Act 15
U.S.C. 13. Count Seven is a declaratory judgment brought by Plaintiff
Caribbean Economic Counsel declaring PREPA predatory pricing violative of the
Robinson-Patman Act 15 U.S.C. 13 and seeking injunctive relief to affirmative
require PREPA to formulate a tariff that complies with the congressional intent
Robinson-Patman Act 15 U.S.C. 13. Count Eight is a civil rights violation under
42 U.S.C. 1983 as against the individual capacity of defendant MARIMAR
PREZ-RIERA for violation of the Equal Protection clause of the Fourteenth
Amendment for applying disproportionately and benefitting certain religious
groups, by applying approving different tariffs which benefitted capriciously,
unilaterally, arbitrary, and unconstitutional formula and adjustment charges,
welfare recipients, religious groups, political associations, and municipal
subdivisions over the individual plaintiff and class of individual consumers.
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THE PARTIES
3. Plaintiff[s] is a conjugal partner of the conjugal partnership known as Duamel
Santiago-Ramos, Individually and as Representative of the Conjugal Partnership
of Santiago Marines Rivera Figueroa. Plaintiff demands and prays for relief in his
individual capacity and as member of the class of individual consumers which are
forced to pay for the fuel adjustments charge which contains capriciously,
arbitrarily, and unconstitutional charge that forces the individual consumer to pay
for religious and other governmental unwelcome associations. Plaintiff[s] is [a]re
at all times materials hereto are citizens of the Commonwealth of Puerto Rico
and, are sui juris. During the relatives period of time material hereto plaintiff has
maintain for (several years) an account with defendant with account number 032
0046137 0027. Plaintiff is a financial professional working at a major financial
institution in Puerto Rico.
4. Plaintiff Caribbean Economic Council is a non-profit organization to which
Plaintiff Duamel Santiago-Ramos is a member of the counsel. Plaintiff Caribbean
Economic Council brings this cause on its behalf and its entire association
members. Caribbean Economic Counsel association members are customers and
electric power consumer who have an interest to have a balance electric power
tariff so as to provide a balance economic development in the island of Puerto
Rico. Caribbean Economic Council members would otherwise have standing to
sue in their own right; (2) the interests it seeks to protect are germane to the
organization's purpose; and (3) neither the claims asserted, nor does the relief
requested, require the participation of the individual members in the lawsuit.
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5. Defendant PREPA is a political subdivision of the Commonwealth of PR created
by a legislative Act for the purpose of providing electric power to the
Commonwealth of PR with the most effective manner. Pursuant to 22 L.P.R.A.
193 the defendant is hereby created a body corporate and political subdivision
constituting a public corporation and governmental instrumentality of the
Commonwealth of Puerto Rico by the name of the Puerto Rico Electric Power
Authority [PREPA]. The Authority created is and shall be a governmental
instrumentality subject, as provided herein, to the control of its governing board,
but it is a corporation having legal existence and personality separate and apart
from that of the Commonwealth of Puerto Rico. The debts, obligations, contracts,
bonds, notes, debentures, receipts, expenditures, accounts, funds, undertakings,
and property of the Authority, its officers, agents or employees shall be deemed to
be those of said government-controlled corporation and not to be those of the
Commonwealth Government or any office, bureau, department, commission,
dependency, municipality, branch, agent, officer or employee thereof.
6. Marimar Prez-Riera, Chairperson, Board of Directors individually, and as
President of the Board of Director is a natural person that manages and controls
the Board of Director and is vested with the establishment of discriminatory price
of the commodity in commerce. Defendant Marimar Prez-Riera public policy is
to lower the cost of fuel based on the Governors policy
1
.
7. Does A/Z are fictional parties that are members of the governing board of
defendant PREPA that approved the discriminatory price practice and are liable
under the Robinson-Patman Act 15 U.S.C. 13.
1
http://www.aeepr.com/noticiasread.asp?r=DESQDSWMAC
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8. The primary purpose of the creation of the Public corporation is to purpose the
conserving, developing and utilizing, and aiding in the conservation, development
and utilization of water and energy resources of Puerto Rico, for the purpose of
making available to the inhabitants of the Commonwealth, in the widest economic
manner, the benefits thereof, and by this means to promote the general welfare
and increase commerce and prosperity, see 22 L.P.R.A. 196. Puerto Rico
Electric Power Authority (the Authority) is a public corporation and governmental
instrumentality of the Commonwealth of Puerto Rico (the Commonwealth)
created on May 2, 1941, pursuant to Act No. 83, as amended, re-enacted, and
supplemented, of the Legislature of Puerto Rico (the Act) for the purpose of
conserving, developing and utilizing the water, and power resources of Puerto
Rico in order to promote the general welfare of the Commonwealth. Under the
entity concept, the Authority is a component unit of the Commonwealth. The
Authority produces, transmits, and distributes, sells to consumers all of the
electric power consumed in Puerto Rico. The operating and financial goals of the
PREPA do not envision the payment of subsidies to promote religious groups,
welfare and political subdivisions subsidies, and state government finance of
electric power. As a government instrumentality PREPA maintains a tax
exemption from taxation of the state and is prohibited (by its creation) from
entertaining the notion or practice to finance the state government or pay taxes to
the state government, or its political subdivisions. When defendant PREPA was
created the goal was to provide the most efficient commodity in commerce to the
consumers of Puerto Rico and if through the efficient successful operation profits
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were generated only 11% would be paid to the Commonwealth of Puerto Rico. In
2010 the Commonwealth of Puerto force a payment $232,431.00 as a form of
contribution in lieu of taxes, when in fact the net income for PREPA was
$24,029,000.00 which would have required a payment of $2,643,190.00 to
conform to the organizational mandate.
9. Defendants A-Z are individual members of the board of directors appointed [in
part] by the political designation who are responsible for marinating the public
policy and price discrimination of the commodity in commerce delivered to
consumers in Puerto Rico.
GENERAL ALLEGATIONS
10. During the relative period of time the defendant PREPA has had an absolute
monopoly of the production, generation, sale, and distribution of electric power,
the defendant PREPA has become a political functionary of the party in
Government by inter alia establishing political views, borrowing moneys for
other sister agencies, lending other Governmental agencies and political
subdivisions monies, and requiring the payment of subsidies to pay for certain
political views and associations.
11. By some economists Puerto Rico's economy is considered somewhat fictitious.
Puerto Rico has very few natural resources of economic value and its economy
relies mainly on Federal Aid from the United States Government, which depends
on the industrialization programs and the tax incentives that U.S. offers. The main
government expenditures are on health, education and welfare. GDP per Capita
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Country Comparison establishes a reduction in per capita income in Puerto
Rico:
Country 2000 2008 2009 2010
Puerto Rico 10,000 18,100 17,400 16,300
United States 36,200 48,300 46,700 47,400
Jamaica 3,700 8,800 8,500 8,400
Cuba 1,700 9,700 9,800 9,900
12. The Puerto Rico per capita income has been declining to levels that prevent most
consumers from paying the highest electric power rated in the United States. The
available data suggests that Puerto Rico per capita income has decrease by -5.
8percent. See table
Country 1999 2000 2001 2002 2003 2004 2005 2006 2007 2008 2009 2010
Puerto Rico 4.2 2.8 2.2 0.5 1.6 2.7 2.5 0.5 -1.2 -2.5 -3.7 -5.8
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13. In 2008 the average electricity tariff in the U.S. was 9.82 Cents/kilowatt-hour
(kWh). In 2006-07 electricity tariffs in the U.S. were higher than in Australia,
Canada, France, Sweden and Finland, but lower than in Germany, Italy, Spain and
the UK. Residential tariffs vary significantly between states from 6.7 Cents/kWh
in West Virginia to 27.0 Cents/kWh in Puerto Rico. In Puerto Rico consumers are
forced to pay up to $0.27Cents/LWh, almost three times more than the average
American household.
14. Since approximately 1970s the public corporation has been utilizing a fuel
adjustment charge that is capriciously, unilaterally, arbitrary, unconstitutional, and
2
http://www.indexmundi.com/g/g.aspx?v=66&c=rq&l=en
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violative of the Robinson-Patman Act, codified as 15 U.S.C. 13. The practice has
inflicted unconstitutional, and commercial injury upon plaintiff because inter
alia- forces plaintiff to pay for subsidies, grants preferential treatment to religious
groups, provides for payment of governmental obligations of welfare subsidies to
indigent parties, finances political subdivisions (Municipalities) failure of
payments, debts services and obligations of the public corporation, and other
governmental agencies which do not pay the public corporation for the related
consumption of electric power. Provides for different prices to commercial
enterprises, over residential process, and sell the like kind product in commerce to
individuals and organizations based on social and economic basis unrelated to the
actual cost of producing the commodity. The sale of the same product to two or
more purchasers at different prices creates the violation of the Robinson-Patman
Act codified as 15 U.S.C. 13.
15. The capriciously, unilaterally, arbitrary, and unconstitutional formula and
adjustment charge, forces the individual plaintiff[s] and all individual consumer[s]
of the public corporation to unreasonably and unconstitutionally associate with
welfare recipients, religious groups, political associations, and municipal
subdivisions which the individual consumer[s] is [are] not forced to associate
because the U.S. Constitution under its First Amendment guarantees each citizen
and right of free association, a separation of church and state, and to choose what
political association to be a member or participate with.
16. Upon best information and belief, the capriciously, unilaterally, arbitrary, and
unconstitutional formula and adjustment charge forces the plaintiff and all
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individual class members to pay for the following: (1) Finance political
subdivisions in a sum of $190,400,000.00 (2) pay for subsidies in residential
services in an amount of $29,600,000.00; (3) Pay for churches and other nonprofit
associations the sum of $3,500,000.00; (4) pay for finance of tourisms subsidies
in the amount of $6,500,000.00; (5) residential subsidies to public housing and
public projects in amount of $18,100,000.00; (6) finance and pay for subsidies to
industries $9,800,000.00; (7) finance and pay for the development incentive laws
for Puerto Rico development $15,015,000.00
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; (8) finance and pay for agricultural
subsidies in the amount of $1,800,000.00 (other subsidies to the elderly, students
public projects of RH3, these include subsidies to persons who receive welfare or
nutritional assistance programs); (9) pay for and finance public education electric
power in a sum of $90,000,000.00.
17. The United States Congress created The Federal Power Act is a law appearing in
Chapter 12 of Title 16 of the United States Code, entitled "Federal Regulation and
Development of Power". The act created the Federal Power Commission (FPC)
(now the Federal Energy Regulatory Commission) as the electric power
regulatory commission. FERC Order No. 2000 at 332 establishes that
Competition and Consumer Protection Perspectives on Electric Power Regulatory
Reform are the public policy of the federal agency: Focus on Retail Competition
organizations to manage reliability, pricing, congestion management, planning,
expansion, and interregional coordination are critical to effective wholesale and
retail competition programs are essential to the United States. The public policy
of the Federal Agency is to promote competition in the generation of wholesale
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$140,000,000.00 in nine years.
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and retail sale electric power to consumers like plaintiff. Defendant PREPA
maintains and absolute monopoly over the production, distribution and sales of
electric power in Puerto Rico. PREPA denies plaintiff and all Puertorican
consumers of the public policy and opportunity to benefit from the federal public
policy. In recent PREPA financial publication defendant has admitted to have a
strong credit rating because it maintains a complete monopoly (exhibit A) in
Puerto Rico. In the same report defendants admits that is strong credit rating is
supported by Sole Provider of an essential service; Fuel rate setting
Authority; fuel and setting power passed through (exhibit A). It is this over
exercise of power that has led defendant to violate the consumers rights under the
United Sates Constitution and laws of the United States, by requiring forced
association with religious and political parties, and pay for welfare subsidies and
benefits to advance other political views of the Government in power through in
the fuel adjustment charge formula.
18. As a utility company defendant PREPA is capable of producing 5839 MW of
electricity, while most peak at 3404 MW. Established in 1941, a commonwealth
government public corporation, PREPA ranks fifth among the largest public
power-utility companies in the U.S. in terms of megawatt-hour (mWh) sales, just
behind the Los Angeles Department of Water & Power, and first in terms of
electric revenue.
19. With over 1.8 million customers residential clients accounted for 34.6% of
PREPAS electric-energy revenue, commercial $1.17 billion or 45.1%, industrial
17.1, for a total of over $4 billion in electric-energy revenue in fiscal 2009.
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20. The commonwealth government is PREPAS largest client. The public sector,
which is comprised of the central government and its public corporations and
municipalities (included primarily in the commercial category), accounted for
12.1% of kilowatt-hour (kwh) sales and 13.7% of revenue from electric-energy
sales for the 12-month period ended Dec. 31, 2004.
21. Public hearings are required before setting permanent rates, with final approval
vested solely within PREPA. Puerto Rico Law No. 21, approved May 31, 1985,
provides uniform procedures for public hearings and review of the actions of
certain public corporations in connection with rate changes set by such public
corporations. The law also authorizes the Legislature by resolution to review rates
of certain public corporations, including PREPA. At the request of another public
corporation under Law 21, the justice secretary has rendered an opinion to the
effect that it doesnt grant veto power to the Puerto Rico Legislature over rates
properly adopted by such public corporation. Since 2004 11% of PREPAS gross
electric-energy sales are being used by the utility to fund its government-subsidy
programs, to pay contributions in lieu of taxes to the municipalities, to finance the
utilitys capital-improvement programs, and for other purposes. In 2009 PREPA
gave in form of contribution (in lieu of taxes) the sum of $224,792,000.00 and
charged its customers the sum as part of the fuel adjustment charge which in 2009
account for 73% of the revenues of PREPA. This assessment of contribution is a
form of taxation upon electric consumers which PREPA is not authorize to asses
as part of the fuel adjustment formula.
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22. The increase in the purchased power adjustment revenue and expense of $24.9
million and $21.9 million, respectively, was due to an increase of 243,159 MWh
(or 3.6 percent) purchase power for fiscal 2010 when compared to fiscal 2009.
The increase in the purchased power adjustment revenue and expense of $6.9
million and $10.8 million, respectively, was mainly due to an increase of 1.0 cent
(9.9 percent) per kWh in the average price of purchased power for fiscal 2009
when compared to 2008. The increase in the purchased power adjustment revenue
and expense of $36.8 million and $36.4million, respectively, was mainly due to
an increase of 312,676 MWh (4.5 percent) purchased power for fiscal 2008, when
compared to fiscal 2007. See audited financial statement. In the audited financial
statements from PREPA it is clearly established that liabilities
($9,184,621,000,000) exceed assets ($9,081,005,000,000) and the fuel adjustment
charge is used to support government expending unrelated to the cost of fuel,
amounting to the consumer of electric power into unconstitutional taxation. In
2010 PREPA provided the central government with $224,792,000.00 in lieu of
taxation. This amount was assessed against the fuel adjustment charge as a form
of unauthorized taxation to support the political goals of the Commonwealth of
Puerto Rico, resulting in a financial bankruptcy of the public utility for on related
utility business
4
.
4
http://www.aeepr.com/INVESTORS/DOCS/Financial%20Information/Annual%20Reports/Final%202010%20F
S%20PREPA.pdf
For fiscal year ended June 30, 2010, as compared to June 30, 2009, Net Assets decreased by $142.8 million.
The reduction in Net Assets was mainly due to an increase in operating expenses of $171.9 million, mainly due
to increases of $38.9 and $37.8 in the Administrative and General and Depreciation Expenses, respectively, as
well as increases in Interest Expense and Contribution in Lieu of Taxes.
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23. In the month of August 2011, the individual Plaintiff was forced to pay a fuel
adjustment charge [for fuel purchased in interstate commerce there is no
production of oil of fossil fuels in Puerto Rico] in the amount of $0.208515, or
$0.21 per kilowatt hour, this rate was in addition to the standard rate of $.037693
per kilowatt hour. When comparing the fuel adjustment charge with other public
municipalities in the United States, defendant PRPA charges unreasonable
amounts of fuel adjustment charge. When compare with Public Utility Harrison
County Utility a cost of $0.09 is the published rate for that public utility
corporation, when comparing fuel adjustment rates with Anderson Municipal the
rate of the Municipal Corporation is $0.87 per kilowatt hour. Defendants fuel
adjustment rate exceeds more than double the rates of similar municipal utilities
which are forced to purchase the same fuel in the open market. When comparing
fuel adjustment charges with other jurisdictions we find that defendants have not
protected plaintiff equally under the law because through the United States fuel
adjustment charges charged by defendants are disparate with the reality of the fuel
market. The National Residential Consumer Bill for others Municipal Utility
Corporations established the capricious and unreasonably fuel adjustment charges
with culminates in unconstitutional taking, association and equal protection:
JURISDICTIONAL ELECTRIC UTILITY
RESIDENTIAL CUSTOMER BILL SUERVEY
[July 1, 2011 Billing] By Utility Name and Type
kWH Consumption
Overall
MUNICIPAL
UTILITIES
500 1000 1500 2000 Ranking*
Anderson Municipal $ 51.88 $ 93.92 $ 135.95 $ 175.78 13
14
Auburn Municipal 36.32 67.63 98.95 130.27 22
Columbia City Municipal 53.23 98.41 143.59 188.76 9
Crawfordsville Municipal 52.97 90.95 128.92 166.90 14
Frankfort Municipal 46.53 82.79 119.04 151.00 21
Kingsford Heights
Municipal
49.16 94.82 140.48 186.13 11
Knightstown Municipal 49.43 94.25 134.77 175.29 12
Lebanon Municipal 47.48 88.18 125.09 161.99 18
Logansport Municipal 59.69 110.57 159.03 206.49 6
Mishawaka Municipal 47.22 84.45 121.68 158.90 20
Peru Municipal 51.34 96.10 139.25 182.41 10
Richmond Municipal 52.35 89.16 125.97 161.04 15
Tipton Municipal 47.16 88.32 127.19 166.06 17
COOPERATIVE
UTILITIES
Harrison County REMC $ 69.51 $ 115.09 $ 156.75 $ 198.40 3
Jackson County REMC 65.51 113.02 160.53 208.04 5
Marshall County REMC 83.50 147.50 200.00 252.50 2
Northeastern REMC 66.25 114.06 161.86 204.16 4
INVESTOR OWNED
UTILITIES
Duke Energy Indiana $ 62.81 $ 104.61 $ 141.53 $ 178.49 8
Indiana Michigan Power
D/B/A AEP
45.72 84.65 123.57 162.50 19
Indianapolis Power &
Light Co.
55.68 88.86 122.03 155.20 16
Northern Indiana Public
Service Co.
58.56 110.37 162.17 213.98 7
So. Indiana Gas &
Electric Co. D/B/A
Vectren
83.05 155.10 227.15 299.20 1
*Overall Ranking based on
Total Rate at 1000 kWh
consumption.
SPECIFIC ALLEGATIONS
adjustment charge forces the plaintiff and all individual class members to
associate with municipalities that do not pay for the electric service. On the last
annual reportage of $190,400,000.00 is the amount believed to have been charged
the individual consumer who neither desires to associate with a municipal
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corporation[s] nor is required to finance the political subdivision or existence, or
even associate with public housing (residenciales publicos).
associate with political goals and views of providing subsidies to public housing
which has traditionally become zest pools of crime and violence, while good
citizens are sometimes force to live in such housing, the individual consumer is
guaranteed by the First Amendment a right not to associate with such subsidies. In
particular the published fuel adjustment factor:
FCC ($/kWh) $/BBL BBLS estimados Ajuste C
0.89
includes factors that contain further factors that included payments to the central
government payments and political subdivisions such as Municipalities. These
factors have an unconstitutional result which forces association with the payments
of subsidies to indigent and or welfare recipients, political association pay the
finance of political subdivisions, and agencies of the state, creates a de facto
taxing authority without legislature power to tax, and take property (individual
monies) without just compensation. The multitude of discriminatory tariff and aid
to welfare projects at the cost of the individual consumer create violation of the
Robinson-Patman Act 15 U.S.C. 13, by assessing different rates in commerce
for the same like commodity (electricity)
5
.
5
Electricity is a commodity for purposes of the Robinson-Patman Act, amending this section and adding
sections 13a, 13b and 21a of this title. Borough of Ellwood City, Pa. v. Pennsylvania Power Co., W.D.Pa.1983,
570 F.Supp. 553.
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26. The basic residential rate [GRS] as published by the defendants includes $ 35 for
the first 425KWH and $4.97 for additional kWh. When comparing this rate to the
special residential rate [LRS] (given to indigents and public housing recipients)
the rate is reduced for the same basic like kind commodity to a rate of $1.46 for
the first 425 kWh, an $18.00 maximum charge for cost of barrel of fuel, costing
today in excess of $80.00, and after consumption of 425 kWh there is a 100%
Negative adjustment, thus providing the cost of the commodity for all electricity
used or consumed in excess of 425 kWh to the paying consumers restricting trade,
price determination, quantity of output, terms of transactions and unreasonable
restrained of trade.
associate with churches which are separated by the First Amendment from go The
capriciously, unilaterally, arbitrary, and unconstitutional formula and adjustment
charge forces the plaintiff and all individual class members to associate with
religious groups which are not the religious belief of consumers who must
nonetheless pay and finance the fuel adjustment charge.
associate with the finance of industries such as tourism, finance income producing
entities such as hotels, governmental agencies, political groups and projects.
29. The Agricultural gross domestic product in Puerto Rico accounts for less than one
(1%) of the gross domestic product of the Island. Defendant in violation of the
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Robinson-Patman Act provide a subsidize rate to agricultural services (GAS)
these consumers pay less than $0.054 per Kwh, and others consumers must pay
for the cost of subsidy paying consumers restricting trade, price determination,
quantity of output, terms of transactions and unreasonable restrained of trade.
30. The rates charged for parks is [LP-13] $0.0900 cents per Kwh for the first kWh.
In cases where these parks are owned by a municipality the subsidize payment is
generally not collected and forced to be finance through the fuel adjustment
charge. Consumers must pay for the cost of subsidy restricting trade, price
determination, quantity of output, terms of transactions, enhancing the monopoly,
and unreasonable restrained of trade.
31. The street and highway [PLG] is charged at $0.07 cents per kWh to the
appropriate Government agency who in turn does not pay for the service and
places a financial burden upon the individual consumer who must pay the burden
of the highest rate charged by defendants, and the loss of electric power when
payment is not made. Consumers must pay for the cost of subsidy restricting
trade, price determination, quantity of output, terms of transactions, enhancing the
monopoly, and unreasonable restrained of trade.
adjustment charge forces the plaintiff and all individual class members to pay and
finance subsidies, political groups churches, because the fuel adjustment charge
requires each individual consumer, like plaintiff, to finance these governmental
projects, the same is a taking under the takings clause of the U.S. Constitutions,
which is not for public use, and does not provide for just compensation.
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33. The Low Income Home Energy Assistance Program (LIHEAP) received federal
funding of $5.1 billion in Fiscal Year 2009. It is funded mainly by the federal
government through the U.S. Department of Health and Human Services,
Administration for Children and Families, and is administered by states and
Puerto Rico. LIHEAP offers financial assistance to qualifying low-income
households who require support in paying their home heating or cooling bills. The
capricious fuel adjustment charge requires plaintiff to pay for these subsidies
when there are federal programs that already account for these subsidies and the
payment of subsidies is a form of taxation when the defendant public corporation
has no taxing authority. The public housing residential rate [RH3] the rate is
fixed at $2.00 per client with a 100% credit for consumption of electric service
over 425Kwh. There is also a maximum $0.033 charge for each Kwh in excess of
425Kwh. This rate results in an unequal, discriminatory, unconstitutional finance
and association with welfare, and with the nexus and assistance to certain drug
points which locate themselves in these privilege/subsidize locations throughout
Puerto Rico. Consumers must pay for the cost of subsidy restricting trade, price
determination, quantity of output, terms of transactions, enhancing the monopoly,
and unreasonable restrained of trade.
34. In the 2010 financial PREPA audited financial statements PREPA admits that
PREPA spent $ 2,006,000,000.00 purchasing of fuel. The fuel adjustment charge
generated 72% of revenues of $4,170,000,000.00 or $3,000,000,000.00 for
PREPA establishing an increase over one billion dollars in excess of the actual
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cost of fuel
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. It is the billion dollars in excess of costs that has gone to pay the
unconstitutional religious and welfare and government subsidies and association,
creating a de facto taxing authority to pay for theses political goals of the
Commonwealth of Puerto Rico. These excess charges and payments to the
Commonwealth in lieu of taxation violate the purpose and reason for which
PREPA was created, i.e. to provide the most efficient electric power to the
consumer have culmination in unconstitutional violations and restriction in trade
by enhancing the monopoly to sell electric power in Puerto Rico.
35. During the relative period of time from 2008 to 2011, the defendant PREPA had
an executive director (Angel Cordero). During the relative period of time in 2011
Mr. Angel Cordero after making payments to the Central Government of
$232,431,000.00 gave his closed associates and employees a 50% salary increase
resulting in millions of dollars in salary costs to chosen employees thereby
increasing the fuel adjustment charge to consumers. These excessive salary
increases were predatory non market related price increases that violated the
Robinson-Patman Act. The payments of $232,431,000.00 placed the defendant
PREPA in a bankrupt position because its liabilities exceeded the assets,
expecting only to increase the cost of the interstate purchase fuel to produce
electricity to its consumers when these financial transactions beard no free market
economic purpose. Upon political pressure the executive director resigned and
was replaced (within 24 hrs.) with Mr. Antonio Escudero, who had directed the
Puerto Rico Ports Authority. During the tenure of Mr. Antonio Escudero at the
6
http://www.aeepr.com/INVESTORS/DOCS/Financial%20Information/Annual%20Reports/Final%202010%20F
S%20PREPA.pdf
20
Puerto Rico Ports Authority had compiled over $50,000,000.00 dollars in unpaid
subsidized electric consumption and had not paid their share of consumed
electricity. Upon review of Mr. Alberto Escudero background, the public and the
board of directors learned that the now Executive Director had have an incident in
2006 where a devise to alter the measuring of expenditure of electricity had been
found at his domicile in Dorado, Puerto Rico. The board of directors terminated
the 36 hour tenure of the political appointment to lead the public utility.
SPECIFIC ALLEGATION VIOLATIONS OF THE
ROBINSON-PATMAN ACT CODIFIED AS 15 U.S.C. 13
36. The defendants purchases in interstate commerce barrels of fuel which in turn the
convert to the commodity of electricity. The electricity is delivered in commerce
to over 1.8 customers which the defendant maintains an absolute monopoly for
the sales and purchase of electricity. The defendant PREPA formulates
unilaterally the fuel adjustment price for the fuel purchase from outside of Puerto
Rico.
37. The defendants formulate several tariffs that is/are discriminatory because it
provides for different rates to social and economic groups not based on the cost
associated with the production cost but discriminatory based on political and
social goals of the central government. When congress, through enactment of the
Robinson-Patman Act 15 U.S.C. 13, sought generally to obviate price
discrimination practices threatening independent consumers, merchants and
businessmen, presumably, from whatever source, and intended to assure, to the
extent reasonably practicable, that businessmen at the same functional level
would start on equal competitive footing so far as price was concerned. The
21
section forbidding price discriminations where effect may be substantially to
lessen competition or tend to create a monopoly in any line of commerce was
originally enacted to curb use by financially powerful corporations like defendant
PREPA to localized price cutting tactics which impaired competitive position of
others like plaintiff and the class or consumers represented.
38. Pursuant to 15 U.S.C. 13(a) it shall be unlawful for any person engaged in
commerce, in the course of such commerce, either directly or indirectly, to
discriminate in price between different purchasers of commodities
[fuel/electricity] of like grade and quality, where either or any of the purchases
involved in such discrimination are in commerce, where such commodities are
sold for use, consumption, or resale within the United States or any Territory
thereof or the District of Columbia or any insular possession or other place under
the jurisdiction of the United States and where the effect of such discrimination
may be substantially to lessen competition or tend to create a monopoly in any
line of commerce, or to injure, destroy, or prevent competition with any person
who either grants or knowingly receives the benefit of such discrimination, or
with customers of either of them: 15 U.S.C.A. 13. The tariffs charge for deferent
types of customers receiving like kind electric service over those commercial
rates, and those subsidized rate are tantamount to violation of the Robinson-
Patman Act. Plaintiff in the instant case is charging, and has charged, higher
residential rates than those charges to public housing, customers receiving
financial aid or political subdivision which are prohibited from charging or
assessing a tax against another governmental agency. Similarly, defendant is
22
charge a rate that discriminates over commercial users of the same commodity
(electricity) and industrial users. Similarly, the Act prohibits (e) Furnishing
services or facilities for processing, handling, etc. It shall be unlawful for any
person to discriminate in favor of one purchaser against another purchaser or
purchasers of a commodity bought for resale, with or without processing, by
contracting to furnish or furnishing, or by contributing to the furnishing of, any
services or facilities connected with the processing, handling, sale, or offering for
sale of such commodity so purchased upon terms not accorded to all purchasers
on proportionally equal terms.
39. The advertised rates for defendant PREPA are as follows:
MONTH RESIDENTIAL COMERCIAL INDUSTRIAL
JUL 2011 27 /kWh 28 /kWh 24 /kWh
JUN 2011 28 /kWh 29 /kWh 24 /kWh
MAY 2011 26 /kWh 27 /kWh 23 /kWh
A review of the advertised rates establish -at a minimum- that the rate deferential
between tree different types of identical commodity purchasers. Providing
industrial rates, beneficial rate over residential rates, over commercial rates, for
the same like product delivery in commerce of kilowatt hour of electricity
7
in
commerce, that is, that either, that there has been discrimination in price between
different purchasers of products of like grade and quality electricity, and that
effect of discrimination has substantially lessen compensation and tend to create
monopoly over the sale of electricity.
7
http://www.prepa.com/spanish.asp?url=http://www.aeepr.com/CALENDARIO.ASP
23
40. The defendants provide beneficial rates to religious groups; socially economic
rates for public housing and government rates are not posted but are maintained
by the monopoly. The last rates for these tariff were made effective the year 2000.
41. The defendants violate the Robinson-Patman Act by -inter alia- stating that since
1989 the standard rate charge is a fixed rate from which the defendant pays their
entire fix operating costs adding only the cost of fuel as the differential cost. This
is false because the audited financial statements of Earnest & Young for 2010
establish that the majority of the revenues derives from fuel adjustment charge
and the fuel adjust charged to consumers exceed the cost of fuel by an amount in
excess of 1 Billion dollars.
42. Defendant falsely advertises to its consumers that the fuel adjustment rate is a
pass-through rate
8
. The fact is that the audited statements establish a gain of over
1 billion dollars over the cost of fuel in revenues (see audited statement June
2010).
43. One example of the unconstitutional predatory and capricious tariffs, restricting
trade is the special industrial tariffs given to new industry and expanding
industries. Pursuant to state law 111 of July 1986 PREPA is authorize to issue
exempt tariffs in lieu of taxes. The practice creates a restriction on trade and a
financial burden upon the plaintiff and all consumers of like commodities and
electricity who must bear the burden and costs of the fuel adjustment charge to
finance the exemptions and taxes for the new or expanding industries. The
establishment of exemptions in lieu of taxes is equally an unconstitutional
8
Ajuste por Compra de Combustible: A travs de este cargo la Autoridad recupera el gasto efectuado para la
compra y manejo del combustible consumido en las unidades generatrices de la Autoridad. Este es el rengln
de la factura que ms vara debido a las fluctuaciones del costo del petrleo en el mercado.
24
violation of the equal protection under the law and an unconstitutional delegation
of taxing authority by the state legislature to the public utility.
THE CLASS MEMBERS
44. The first class members are all individual members like plaintiff DUAMEL
SANTIAGO-RAMOS who have been charge a fuel adjustment charge that
includes subsides, finance, and other benefits to religious, welfare groups,
indigent or political subdivision provided economic benefits to these groups and
requiring association, and these groups in violation of the U.S. Constitution.
45. Second class members are all who have receive in commerce the commodity of
electric service at discriminatory rates over those with beneficial rates in violation
of Robinson-Patman Act codified as 15 U.S.C. 13. These include residential
consumers that pay over special residential consumers, commercial consumers
and industrial consumers that pay in excess of government, and public housing
rates.
46. Subclass members are those who were charge commercial rates in excess of the
best rate provided to residential consumers and those charged to public housing
and other governmental agencies.
JURISDICTION AND VENUE
47. The court has original jurisdiction based on Federal question 28 U.S.C. 1331;
that is the unconstitutional and discriminatory practices of PREPA in the
assessment of the fuel adjustment charge. The court has further jurisdiction
pursuant to 15 U.S.C. 13 and 28 U.S.C. 2201.
25
48. Venue lies in this district, as the facts and occurrences took place in the District of
Puerto Rico; All acts events occurred in the Commonwealth of Puerto Rico.
I. Numerosity and Definition of the Class
49. Plaintiff Duamel Santiago-Ramos Individually brings this class action in behalf of
himself and the following classes:
9
Class a: All individuals who have been
billed a fuel adjustment charge by defendant in the Commonwealth of Puerto Rico
The Class consists of over 1,000,000 individual consumers who have been forced
to pay a fuel adjustment charge that include charges for subsidies, and
associations with churches, and other charitable entities, political and municipal
subdivisions of the state. The exact number being unknown and unascertainable;
therefore, the Class is so numerous that joinder of all members is impracticable;
Class b all consumers of electricity who have purchased electricity in
commerce paying higher tariffs than those provided to agricultural consumers, or
a the best commercial rate as determined by the proof or the jury.
II. Commonality
50. This cause of action is predicated on violations of U.S. Constitution, equal
protection clauses, the takings clause, and the right of free association and the
rights protected under Robinson-Patman Act 15m U.S.C. 13. At all times
material hereto the plaintiff petitioners allege and reaffirm that they are members
of a class of persons that have been subject to violations of the U.S. Constitution
and violation of the Robinson-Patman Act 15 U.S.C 13, and have been injured
in business and property as a result of defendants discriminatory electric service
fuel adjustment charge and tariffs in Puerto Rico.
9
The class definition may be modified by the Court based on discovery or other factors that can surface
throughout the course of the litigation.
26
III. Typicality
51. The claims of the Plaintiffs are typical of the claims of the Class members they
represent as they seek essentially the same relief, namely damages in business and
property resulting from the defendants fuel adjustment charge and discriminatory
tariffs that include subsidies to political subdivisions, churches, charitable
institutions, and welfare subsidies to public housing, services and tourism in
Puerto Rico, and consumers who have been charge discriminatory tariff by
defendant in violation of the Robinson-Patman Act.
IV. Adequacy of Representation
52. Plaintiff Duamel Santiago-Ramos, Individually is a plaintiff representative of
citizen and consumers that have been injured in business and property as a result
of the violation capricious, arbitrarily, unconstitutional assessment of charges to
support political affiliations, subsidies to churches, other charitable entities,
political and municipal subdivisions of the defendants, who have been charge
discriminatory tariffs by defendant in violation of the Robinson-Patman Act.
V. Plaintiffs Meet the Requirements of Rule 23(b)(1)(A)
53. This action is maintainable under Rule 23(b)(1)(A), Fed.R.Civ.P., because the
prosecution of separate actions by individual members of the Class would create a
risk of inconsistent or varying adjudications with respect to individual members
of the Class which would establish incompatible standards of conduct for
Defendants.
VI. Plaintiffs Meet the Requirements of Rule 23(b)(3)
54. Certification is also appropriate under Rule 23(b)(3), Fed.R.Civ.P., because:
A. Common issues predominate where the exact same issues will apply
uniformly to each class member seeking injunctive relief; and
27
B. A class action is superior because individual class members have no
practical interest or ability to bring this action for damages.
In particular, there are numerous questions of law and/or fact that are
common to the claims of the Plaintiffs and the members of the Class.
Among these common questions of law and/or fact are the following:
A. whether the class members have no adequate remedy at law;
B. whether class members are subject to injury constitutional injury
by the fuel adjustment charge that includes subsidies to political
subdivisions, churches, charitable institutions, and welfare
subsidies to public housing, services and tourism in Puerto Rico,
and whether the members of the class have been injured by the
violations of the Robinson-Patman Act differential rate charges,.
C. whether injunctive relief is appropriate and in the public interest;
D. whether equity supports the relief requested in the instant issues.
The class action is the superior method of adjudication of this controversy
as joinder is impracticable and the case is manageable and can be tried
with class wide proof for all members of the Class.
Certification is also appropriate under Rule 23(b)(3), Fed.R.Civ.P., because:
C. Common issues predominate where the exact same issues will apply
uniformly to each class member seeking injunctive relief; and
D. A class action is superior because individual class members have no
practical interest or ability to bring this action for damages.
The class action is the superior method of adjudication of this controversy
FIRST CAUSE OF ACTION
Violation of the free association clause
55. Plaintiff avers and re-avers all preceding paragraphs, and further states:
56. Freedom of Association is defined as the right of people to meet together to
further their common goals. The fuel adjustment charge that inflicts a force
association with political and municipal subdivisions of the state, along with the
28
association of churches, welfare groups is unconstitutional because it forces the
plaintiff to associate by paying for a subsidy to political and municipal
subdivisions of the state, along with the association of churches, welfare groups.
57. The forced associations to finance groups which are opposed to the individual
consumer are a violation of the freedom of association of each individual
consumer. In particular forcing the payment of subsidies to groups would force
the individual consumer to repudiate its own belief system of free enterprise
system and that each citizen should pay for every service that the government
provides.
SECOND CAUSE OF ACTION
Establishment Clause
59. The Establishment Clause states that Congress shall make no law "respecting an
establishment of religion." The clause is generally interpreted to mean three
things. 1) That the government may not establish an official religion or
denomination and require people to support it or believe in it. 2) The government
may not favor in its laws one religion or denomination over another and 3)
Government may not favor or disfavor believers or unbelievers in any religion or
denomination over any other. By establishing a fuel adjustment charge the
includes subsidies to churches and other charitable organizations the Government
(PREPA) endorses and requires plaintiff to support a form of religion and to
finance and pay for cost to provide the benefit to these religious and charitable
organizations.
THIRD CAUSE OF ACTION
Takings clause
29
61. The Fifth Amendment prohibits "private property [from being] taken for public
use without just compensation." The application of the fuel adjustment charge by
the state own PREPA constitutes a taking from an individual consumer[s] who is
[are] not interested in supporting subsidies to political associations, government
agencies, or religious entities who receive a subsidy paid by the individual
consumers rate and fuel adjustment charge. The taking of the individual
consumers money is a taking of property without just compensation.
FOURTH CAUSE OF ACTION
Violation of due process of law
63. The fuel adjustments charge or rate is determined unilaterally by individual
government agents who are interested in remaining as government employees
while working for PREPA. These government agents formulate a rate based on
the need of the agency to provide for subsidies to churches, political subdivisions,
municipalities, welfare recipients, and other governmental needs. As a
Governmental political subdivision there is no public hearing, or input to evaluate
the fairness of constitutionality of the fuel adjustment charge. The public agency
is not vested with the taxing power of the state and by implication of the fuel
adjustment charge, the agency of the state is taxing the individual consumers with
payment of subsidies to political subdivisions of the state, predicated on the cost
of fuel adjustment when in fact and in truth the needs of taxing by the state are
open for public hearings and scrutiny. The subsidies which a government must
provide are not part of the organic law which created the public agency of the
state. These entities, churches, political subdivisions of the state, municipalities
30
already have stabled an assigned budget approved by legislature, and included in
the governmental budget of the state.
FIFTH CAUSE OF ACTION
Equal protection clause
65. The Equal Protection Clause of the 14th amendment of the U.S. Constitution
prohibits states from denying any person within its jurisdiction the equal
protection of the laws. See U.S. Const. amend. XIV. Defendant PREPA has failed
to protect Plaintiff[s] under the equal protection under the law by implemental a
fuel adjustment charge that is unconstitutional because it forces religious and
political associations, and takes property of plaintiff to finance and pay for
political associations and subdivision of the state that do not pay for electric
service. Similarly, the fuel adjustment charge is made by government workers that
implement the fuel adjustment charge without regard to rights of the plaintiff[s]
under the U.S Constitution and opportunity for a hearing and due process of law.
SIX CAUSE OF ACTION
Violation of the Robinson-Patman Act
66. Plaintiff avers and re-avers all preceding paragraphs and further states and prays:
67. Pursuant to 156 U.S.C. 3 (a) Price; selection of customers makes it unlawful for
any person entity engaged in commerce, in the course of such commerce, either
directly or indirectly, to discriminate in price between different purchasers of
commodities of like grade and quality [electricity], where either or any of the
purchases involved in such discrimination are in commerce, where such
commodities are sold for use, consumption, or resale within the United States or
31
any Territory thereof or the District of Columbia or any insular possession or
other place under the jurisdiction of the United States, and where the effect of
such discrimination may be substantially to lessen competition or tend to create a
monopoly in any line of commerce, or to injure, destroy, or prevent competition
with any person who either grants or knowingly receives the benefit of such
discrimination. The Robinson-Patman Act is concerned not with efficiency but
with the equitable dispersion of business power within a market like Puerto Rico.
Section 2(a) of the Robinson-Patman Act condemns price discrimination-two
sales of identical goods with equal marginal costs made at two different prices.
68. The Robinson-Patman Act makes it unlawful for any person engaged in
commerce to pay or contract for the payment of anything of value to or for the
benefit of a customer of such person in the course of such commerce as
compensation or in consideration for any services or facilities furnished by or
through such customer in connection with the processing, handling, sale, or
offering for sale of any products or commodities manufactured, sold, or offered
for sale by such person, unless such payment or consideration is available on
proportionally equal terms to all other customers competing in the distribution of
such products or commodities.
69. Defendants have violated, are violating, and continue to violate the Robinson-
Patman Act by their implementation of different rates for social, economic and
political groups setting different tariffs, rates based on social economic and
political views of the defendant[s]. It shall be unlawful for any person engaged in
commerce to pay or contract for the payment of anything of value to or for the
32
benefit of a customer of such person in the course of such commerce as
compensation or in consideration for any services or facilities furnished by or
through such customer in connection with the processing, handling, sale, or
offering for sale of any products or commodities manufactured, sold, or offered
for sale by such person, unless such payment or consideration is available on
proportionally equal terms to all other customers competing in the distribution of
such products or commodities.
70. One example of the unconstitutional predatory and capricious tariffs, restricting
trade is the special industrial tariffs given to new industry and expanding
industries. Pursuant to law 111 of July 1986 PREPA is authorize to issue exempt
tariffs in lieu of taxes. The practice creates a restriction on trade and a financial
burden upon the plaintiff and all consumers of like electricity who must bear the
burden and costs of the fuel adjustment charge to finance the exemptions and
taxes for the new or expanding industries. The establishment of exemptions in
lieu of taxes is equally an unconstitutional violation of the equal protection under
the law and an unconstitutional delegation of taxing authority by the state
legislature to the public utility.
SEVEN CAUSE OF ACTION
DECLARATORY JUDGMENT
71. Plaintiffs aver and re-aver all preceding paragraphs and further state:
72. Pursuant to 28 U.S.C. 2201 the court is empower to upon the filing of an
appropriate pleading, declare the rights and other legal relations of any interested
party seeking such declaration, whether or not further relief is or could be sought.
33
Any such declaration shall have the force and effect of a final judgment or decree
and shall be reviewable as such.
73. Plaintiff Caribbean Economic Council respectfully prays to this court to declare
the subsidies and predatory tariffs of defendant PREPA unconstitutional and
against the Public Policy of the United Sates under the Robinson-Patman Act 15
U.S.C. 15. Declaring that the payment of 11% of contributions in lieu of taxes
[as well as the payments in 2007 $ 192,591; 2008 $218,379; 2009 $224,792; and
2010 $232,431] from the operation revenues or profits of PREPA to the Central
Government an illegal act as a restriction in trade, free market process in
determining price, quantity output, quality, or other important terms of
transaction. The United States Supreme Court has articulated classic economic
price theory to be the touchtone, the standard for all antitrust analysis which
defendants have ignored and continue to ignore. The payments to the Central
Government are a further form of illegal unlegislated taxation which the
consumer of electric power must assume in the fuel adjustment charge which
bears no economic relation to economic price theory.
EIGHT CAUSE OF ACTION
Violation of the equal Protection Clause
Under 42 U.S.C. 1983
74. Plaintiff[s] aver and reaver all preceding paragraphs and further state:
75. This is an action against defendant Marimar Prez-Riera, Chairperson, Board of
Directors individually, defendant serves President of the Board of Directors, she
is a natural person that manages and controls the Board of Director and is vested
34
with the establishment and approval of discriminatory prices and tariffs for the
commodity in commerce of electricity and fuel adjustment charges.
76. Pursuant to 42 U.S.C. 1983 every person who, under color of any statute,
ordinance, regulation, custom, or usage, of any State or Territory or the District of
Columbia, subjects, or causes to be subjected, any citizen of the United States or
other person within the jurisdiction thereof to the deprivation of any rights,
privileges, or immunities secured by the Constitution and laws, shall be liable to
the party injured in an action at law, suit in equity, or other proper proceeding for
redress. Here, defendant has failed to protect plaintiff under the U.S. Constitution
as described under causes of action 1-6 and Eight, Robinson-Patman Act and has
failed to protect plaintiff and class members under the Equal Protection Clause of
the Federal Constitution to wit the 14th Amendment as against different type of
treatment for overcharges, beneficial tariff rates, to certain welfare recipients,
religious groups, public housing residents, political subdivisions of the State that
consume the same like commodity (electricity) as individual Plaintiff and are
receiving beneficial treatment over Plaintiff by -inter alias- receiving subsidies,
financing, and other benefits which are not offered to Plaintiff and the class of
individual consumer.
WHEREFORE, the Plaintiff[s], on behalf of himself [themselves] and the Class,
demand the following relief:
A. Recover the damages sustained by the individual plaintiffs by payment of fees
that support political, religious and other governmental association costs, and the
cost of suit, including a reasonable attorney's fee
B. After notice and hearing, an Order certifying the Class and any appropriate
Subclasses to administer the claims.
35
C. An Order appointing Lorenzo Palomares P.S.C., as Counsel for the Class and
awarding attorneys fees, pursuant to Federal Law and the rules governing class
actions, for the benefit of the Class for said representation;
D. Establishing a fund to provide relief for the injury to the class;
E. An Order requiring the Agency and its chief/director to cease and desist from
further discriminatory and unconstitutional practices.
F. An injunction requiring defendant PREPA to stop providing preferential treatment
to political subdivisions, agencies of the state, churches and welfare recipients and
otherwise providing price discounts and other forms of preferential treatment to
some buyers of like kind electricity and not to others.
G. Any and all further relief this Board/Court deems just and proper.
Respectfully submitted,
October 6, 2011

Ramon Rivera Iturbe, Esq.
Rivera Iturbe & Assoiates
USDC #120156
500 Ave Muoz Rivera,
Centro II
San Juan PR 00918
Tel. 787- 754-7248

Lorenzo J. Palomares, Esq.
U.S.D.C. #218017
Lorenzo Palomares, P.S.C.
Attorneys & Counselors at Law
421 Ave Munoz Rivera, Midtown Bld.
Penthouse Suite 1001,
San Juan, P.R. 00918
Tel (787) 753-7441
Fax (787) 622-2540
Palolaw@gmail.com
.
Ricardo Izurieta
USDC#124205
421 ave Muoz Rivera, suite 1002
San Juan PR 00918
Tel. 787-531-9418
izurieta.ricardo @gmail.com
36
NOTICE OF REPRESETATION
I hereby appoint the law offices of Lorenzo Palomares to represent the undersigned
plaintiff as class representative. I hereby agree to zealously represent the class of plaintiff that
has been injured by the defendants in the complaint at large.
S,/ Daumel Santiago Ramos
DUAMEL SANTIAGO-RAMOS

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