20240728Shery Cole Response to Hearing.pdf

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IDAHO SUPREME COURT 9 s Cif IDAHO COURT OF APPEALS
Clerk of the Courts Pa Box 83720
[phone] � x ���� Boise, Idaho 83720-t7f 01
Notice Date. 0712612024
SHERRY COLE, - Set for Hearing by Supreme Court
Petitioner-Appellant, Docket No. 51148- Q23
V.
IDAHO PUBLIC UTILITIES COMMISSION
and PACIFICORP, dba ROCKY
MOUNTAIN POWER COMPANY,
Respondents.
All attorneys of record must sign and return one copy of this notice within seven (7)days
indicating who will present oral argument. This notice may be submitted through File&Serve:
hfitps://idaho.tylerhost_neVofsw6b.
I will present argument.
❑ I will appear but not.argue.
Other counsel will present my argument. Larne of counsel:
You must review all recent opinions of this.Court issued since the briefs were filed. Any
additional citations, with: references to the issues or argument for which they are cited, should
be received by this office 24 hours prior to oral argument if you intend to cite this authority
during your argument.
Oral argument will be as set forth below.
Hearing Date: 1.010412024
Time: 11:10 AlU1
Location:Supreme Court
Address: 451 W. State Street
Boise, ID 83702
Counsel Si g �I nature: ante: o2a
C6 ft,
Printed Dame (Required). J h8 t r
Counsel for: �a-; t' (name of party)

CERTIFICATE OF SERVICE
I certify that on then day of , 20 %0 , I served true and
accurate copies of the foregoing document on the following persons, either by deposit in
the U.S. Mail, addressed as follows and with the correct first-class postage affixed
thereto,or be deposit in the designated courthouse mailbox, or by hand-delivery,as
indicated below.
Name: Michael Duval
Served by:
[ ] Hand-delivery
[ ] Deposit in the designated courthouse mailbox
[ ] By deposit in the U.S. Mail addressed as follows;
[ ^] Electronic submission via lcourt portal file and serve
[ ] email
Name: Joseph Dallas
Served by:
[ ] Hand-delivery
[ ] Deposit in the designated courthouse mailbox
[ ] By deposit in the U.S. Mail addressed as follows:
Electronic submission via Icourt portal file and serve
[ ] email
Name: Raul Labrador
Served by:
[ ] Hand-delivery
[ ] Deposit in the designated courthouse mailbox
[ ] By deposit in the U.S. Mail addressed as follows:
[ ] Electronic submission via Icourt portal file and serve
[X] email
Name: Idaho Supreme Court
Served by:
[ ] Hand-delivery
[ ] Deposit in the designated courthouse mailbox
[ ] By deposit in the U.S. Mail addressed as follows:
[ ] Electronic submission via Icourt portal file and serve
[ ] email
herry ole Pro Se Appelant

Pro Se 2(Rev. 12/16)Complaint and Request for Injunction
UNITED STATES DISTRICT COURT
for the
District of iE /ate
Division
Case No.
(to be filled in by the Clerk's Office)
Jherr� C te.,
..... _
Plaintiffs) l
(Write the full name of'edch plaintiff'who is filing this complaint. 1 IJ'the names of all the plaintiffs cannot f t in the space above ) m����� Aq 0 ko jA
please write "see attached"in the space and attach an additional ) /
page with the full list of names.) Q yt
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�,���. 1•�5..__Go�._-,..5�, gin:-- _ -- -�--- )'
Defendants)
(01rile the fill name of each defendant who is being sued. If the )
names of all the defendants cannot fit in the space above,please )
write "see attached"in the space and attach an additional page .
with the full list of names)
COMPLAINT AND REQUEST.FOR INJUNCTION
4. The Parties to This Complaint A. The Plaintiffs(.) C��deee
�S v f Ccr GC G�
Provide the information below for each plaintiff named in the complaint. Attach additional pages if
needed.
Name
Street Address
City and County
- ...- --- - — --... ___....._... ..__ ..... .. - .._. .
State and Zip Code
Telephone Number
E-mail Address
D. The Defendant(s)
Provide the information below for each defendant named in the complaint, whether the defendant is an
individual,a government agency,an organization,or a corporation. For an individual defendant,
include the person's job or title (ifknown). Attach additional pages if needed.
Page I of

Attorney for Defendant PacifiCorp d/b/a Sherry Cole
Rocky Mountain Power Company Plaintiff Pro Se
Joseph Dallas, senior Attorney Rocky Mountain Power,Pacific core, 350 S. 12th W.#14
825 NE Multnomah, STE 2000, Portland, OR 97232 Saint Anthony Idaho
83445
Attorney for Defendant IPUC
Raul Labrador,Idaho AG
Michael Duval ISB# 11714,
Idaho Public Utilities Commission
11331 W, Chinden Blvd.
Building 8, Suite 201-A, Boise Idaho 83704

To the honorable court on Amended Motion for Preliminary Injunction
Case is civil in nature with a guaranteed Constitutional outcome. under US rule 28 USC 1331
and US rule 65.
Back ground
I the plaintiff, Sherry Cole, Ask this court for Preliminary Injunction to prevent further
intimidation and threats of termination of Electric Service by Rocky Mountain I am currently
looking for help at the Federal level. Case does not qualify under 28 U.S.0 1332 due to the
amount though this does involve 3 states.
My apologies as I am not an attorney and doing my best to fight for my Constitutionally
protected God given rights and reading to the best of my ability,at state level I have been denied
access to an attorney through private practices and even the State bar association.
This cross connection was over the span of several years and was Rocky Mountain Power that
caused the cross connection, refused to cure the Constitutional violation where they gave credit
and then reversed it without due process guaranteed under the 5th and 14th amendment of due
process and block me from going after money legally owed me and get a state agency to run a
tribunal as this is how they work together against the private citizen
The only thing that prevented RMP terminating my electrical service on May 9th,2024, and
being unable to get electric service with another provider, was the emergency Preliminary
injunction was already filed. with this court.
Relief sought from this court
I the plaintiff ask for an injunction against Rocky Mountain Power for her families protection
until This issue is resolved. Idaho Supreme Court denied The Constitutional Challenges so far on
appeal , even though they were present in mediation with the Idaho Public Utilities Commission,
If this Court cannot give me this relief at this time, I will withdraw the motion without prejudice
until I can find an attorney to either take the case at the federal level or assist at least due to my
financial situation, to prevent aggravations to the court and myself.
Respectfully
Sherry ole

CERTIFICATE OF SERVICE
I certify that on the J day of , 20 , 1 served true and
accurate copies of the foregoing document on the following persons, either by deposit in
the U.S. Mail, addressed as follows and with the correct first-class postage affixed
thereto, or be deposit in the designated courthouse mailbox, or by hand-delivery, as
indicated below.
Name: Michael Duval
Served by:
] Hand-delivery
[ ] Deposit in the designated courthouse mailbox
[ ] By deposit in the U.S. Mail addressed as follows:
[Y] Electronic submission via Icourt portal file and serve
[ ] email
Name: Joseph Dallas
Served by:
[ ] Hand-delivery
[ ] Deposit in the designated courthouse mailbox
[ ] By deposit in the U.S. Mail addressed as follows:
[)l] Electronic submission via Icourt portal file and serve
[ ] email
Name: Raul Labrador
Served by:
[ ] Hand-delivery_
[ ] Deposit in the designated courthouse mailbox
[ ] By deposit in the U.S. Mail addressed as follows:
[ ] Electronic submission via Icourt portal file and serve
L4 email A& l a,Dr&)or @ • Ld tw • c 6 d
Name: Idaho Supreme Court
Served by:
[ ] Hand-delivery
[ ] Deposit in the designated courthouse mailbox
[ ] By deposit in the U.S. Mail addressed as follows:
[ ] Electronic submission via Icourt portal file and serve
[ ] email
Sherry ale Pro Se A pd t 4,