Tilodcto: Lnigntion Urtrict
Tilodcto: Lnigntion Urtrict
Tilodcto: Lnigntion Urtrict
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Water and Power
February 25,2010
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U.S. Bankruptcy Court, District of Delaware 824 Market Street, 3'd Floor
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Wilmington, DE 19801
Re: Mervyn's Holdings,LLC., et al., Case #08-l1587 (KG) Modesto lrigation District, Claim #668
RESPONSE TO DEBTOR'S TWENTY-SECOND OMNIBUS OBJECTION (SUBSTAIITIVE) TO CERTAIN OVERSTATED CLAIMS AND MOTION TO REDUCE OR EXPUNGE CLAIMS (Substantive) to Certain Overstated Claims and Motion to Reduce or Expunge Such Claims in which the Debtor is seeking to modify the amount of Modesto Irrigation birtri"t'r Claim #66g, in the amount of $250-23 to a reduced amount of $123.50 based on their assertion that the original claim was overstated, Modesto Irrigation District disputes Debtor's objection and motion. Enclosed you will find a copy of Debtor's bill dated 08/16/08 in the amount of $36g.73 for service period 07/lll08 - 08/07108. You will also find a copy of their next bill dated 0gll7l0g which shows credit adjustments totaling $250.23 that was made to their account for pre-petition services (07llI/08 -07/29/08), leaving an ending balance of $588.16. This amount is the current post-petition charges of $464.66 for service period 08/08/08 09/08i0g plus the prorated amount of $118'50 from the previous bill for serice period 07130108 08ll7l0g that Debtor is responsible for as it too is post-petition, along with a $5.00 late fee because payment was not received by the due date. Also enclosed, is u of Debtor's bill dated 10/16/0g that shows a "opy payment was received for $588.16, which is the amount due on the 09/19/08 bill. Debtor did not object to the credit adjustments made to their account for pre-petition charges totaling $250.23; therefore, their objection to our claim is unwarranted as it is roittre exact sarie amount.
We ask that this court deny the Debtor's request to reduce the Modesto Irigation District,s Claim #668 in the amount of $250'23 as we have provided specific factual bases as well as
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Lien Campbell Modesto Irrigation District Sr. Customer Service Rep.
0q/v*#% #p 0811586100305000000000003
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Attachments CC:
Mark D. Collins Daniel J. DeFranceschi Christopher M. Samis Andrew C. Irgens RICHARDS, LAYTON & FINGER, P.A. One Rodney Square 920 North King Street Wilmington, DE 19801
and
Howard S. Beltzer Wendy S. Walker MORGAN, LEWIS & BOCKruS LLP 101 Park Avenue New York, NY 10178-0060
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STATEMENT GUSTOMER SERVICE LOGATION: SERVfCE START DATE: LOCATION NUMBER: ACCOUNT NUMBER: ACCOUNT BALANCE:
1231 ETEVENTH STREET P.O. BOX 5355 MODESTO, CA 95352-5355 (209\ 526-7337 CURRENT BILL DUE
DATE: NAME:
BY:
51842il1
25000632445
$ 368.73
GSi Rate
Effective
Actlve
05/01/2008 $0.1216
KWH
for: 28 days
Meter Number: 4110585 Outage Block: 128 Prior Meter Read: 24841 Current Meter Read: 27549
Multiplier:
'l
Usage: 2708
't8.00
329.29 20.84
AccountActivity From:
State Surcharge (0.00022 per kWh) 711612008 otal Current Charges Previous Balance **THANK yOU**
To:
0.60
8/1rU200g
Paynent
315.39 315.39 CR
AMOUNT
DUE
368.73
Payments and Adjustments received atter gtl4l2}ogwiil appear on your next biil.
Low fncome 22.2o/o Discount sign'up availabte first Friday of every month MID lobby. Bring last bill and proof of income.
2.20_8
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Modesto
lrrigation District
AMOUNT DUE
PLEASE PAY $ 368.73
IF DIFFERENT AMOUNT
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Mervyn's Of California c/o Cass Info Systems Modesto MOOO PO Box 182181 Columbus, OH 43218-2181
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STATEMENT CUSTOMER SERVICE LOCATION: SERVICE START DATE: LOCATION NUMBER: ACCOUNT NUMBER: ACCOUNT BALANCE:
1231 ELEVENTH STREET P.O. BOX 5355 MODESTO, CA 95352-5355 (20e) 526-7337
DATE: NAME:
0911712008
51842541
25000632445 $ 588.16
DATE: GS1 Rate Active 05/01/2008 First 100,000 Per KWH $0.1216
Effeclive for: 32 days
TO: 09/08/2008
Meter
Number:
Prior Meter
Read: 27549
Multiplier:
Usage: 3451
Current Charges
Fixed Monthly Amount Electric Usage Charge City Tax (6%) 18.00
419.64 zo.zo
Account
Activity
From: 8/15/2008
To:
0.76
9/15/2008
464.66
368.73 5.00
12.22CR
223.46 CR 14.14 CR 0.41 CR
AMOUNT
DUE
588.16
Payments and Adjustments received after 9/15/200g wiil appear on your next biil.
Low lncome 22'2o/o Discount Sign-up available first Friday of every month MID lobby. Bring last blll and proof of income.
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AMOUNT DUE
PLEASE PAY $ 588.16
IF DIFFERENT AMOUNT PAID PLEASE INDICATE
PLEASE KEEP THIS SECTION FOR YOUR RECORDS. FOR CUSTOMER TNFORMATION SEE REVERSE SIDE
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P.O. BOX 5355 MODESTO, CA 9s352-53s5
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Mervyn's Of California c;/o Cass Info Systems Modesto MOOO PO Box 182181 Columbus, OH 4321 B-21 81
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STATEMENT DATE: GUSTOMER NAME: SERVICE LOCATION: SERVICE START DATE: LOCATION NUMBER: ACCOUNT NUMBER: ACCOUNT BALANCE: 10t16t2008 Mervyn's Of California 2801 Mchenry Ave Unit D, Modesto
1231 ELEVENTH STREET P.O. BOX 5355 MODESTO. CA 95352-5355 (209) 526-7337 CURRENT BILL DUE
BY:
11/05/2008
't217t2002
51842541 25000632445
$ 137.18
DATE: GSI Rate Active 10/01/2008 GS1 Rate Active 05/01/2008 First 100,000 Per KWH $0.1044 First 100.000 Per KWH $0.1216
Effective
TO: 10/07/2008
for: 7 days
Effective ior'.
22 days
Meter Number: 4110585 Outage Block: 'l2B Prior Meter Read: 31000 Current Meter Read: 31947
Multiplier:
'l
Usage: 947
Current Charges
Fixed Monthly Amount Electric Usage Charge City Tax (6%) 18.00 1l',t.22
7.75
0.21
To:'1011412008
137.18 588.16
588.16 CR
AMOUNT
DUE
137.18
Payments and Adjustments received alter i0t1412009 will appear on your next bill.
Low lncome 22.2vo Discount sign'up available first Friday of every month - MID lobby, Bring last bill and proof of income.
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AMOUNT DUE
PLEASE PAY
PLEASE KEEP THIS SECTION FOR YOUR RECOROS. FOR CUSTOMER INFORMATION SEE REVERSE SIDE
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$ 137.18
IF DIFFERENT AMOUNT PAID PLEASE INDICATE
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Mervyn's Of Califomia c/o Cass Info Systems Modesto MOOO PO Box 182181 Columbus, OH 43218-21 81
10/1612008
08:06:11 ?Sequence?
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