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Home My WebLink About20221013Supplemental Declaration.pdfiIECIIVED illi 0{]T 13 P[l 2: I T i.l.'l iLl I'LiELlC I I ; tt iIIi-::i Ce Ml,4!SSl0N Paul B. Rippel, Esq. ISBN 2762 Austin O. Allen, Esq. ISBN 10076 HOPKINS RODEN CROCKETT HANSEN & HOOPES, PLLC 42SParkAvenue ldaho Falls, !D 83402 Telephone: (208) 5234445 Email: paulriopel@hookinsroden.com austi nal len@hopki nsroden.com Attorneys for Applicant Donald Sorrells IDAHO PUBLIC UTILITIES COMMISSION DONALD SORRELLS, an individual, Complainant, Case No. GNR-U-22-03 SU PPLEM ENTAL DECI.ARATION OF DONALD D. SORRELLS lN SUPPORT OF FORMAL COMPLAINT vs. SUNNYSIDE PARK UTILITIES, lNC., an ldaho Corporation, ndent. l, Donald D. Sorrells, having first been duly sworn under oath, declare and testify as follows: L. I am at over eighteen (18) years of age and am competent to testify in this matter; 2. I am the named Applicant in this matter, and my testimony is based upon my personal knowledge unless otherwise specified; 3. After filing my previous Declaration dated July 5, 2022,1 have received SUPPLEMENTAL DECI.ARATION OF DONALD D. SORRELS IN SUPPORT OF FORMAL COMPI.AINT_ 1 additional documentation and information to refute allegations made within the Respondent, Sunnyside Park Utilities, lnc.'s ("SPU") Amended Answer. These documents further demonstrate the ambiguous, inconsistent, and unestablished standards and policies exercised by SPU but not laid out within any written policies or water use agreement. 4. On or about August t5,2022,1 received an invoice for water and sewer service for the month of July. The total amount was the standard monthly rate of $46.00. I paid the invoice on August !5,2022 with a check, #7031,. 5. On or about August 3t,2022,1 received a second invoice for water and sewer service for the month of July. Again, the amount on the invoice was the standard monthly $46.00 rate. I understood this invoice to have been resent in error, as I had already paid the entirety of the July expenses on August 1-.5,2022, A true and correct copy of the August 31,,2022lnvoice is included with this declaration as Exhibit A. 6. On or about September 7 ,2022,1 received an accounting Statement from SPU identifying what it purported to be amounts owing on my account. A true and correct copy of the September 7 ,2022 Statement (the "Statement") is included with this declaration as Exhibit B. 7. There are numerous discrepancies, inaccuracies, and errors on the Statement, and the amounts alleged owing do not appear to be consistent with any published rates, policies, or written agreements with SPU. The following issues are present in the Statement that I believe to be improperly raised by SPU: a. October 3!,2O2t.1 received an invoice for water and sewer services SUPPLEMENTAL DECI.ARATION OF DONALD D. SORRELS IN SUPPORT OF FORMAL COMPI.AINT _2 with an excess water charge totaling $46.67. I paid the $46.67 with a check, Pmt. #60533. SPU subsequently and without explanation changed the fees from $46.67 to $48.48. b. October 31,,202L.1 received an invoice charging $653.49 for an alleged "Service Call". I received no explanation as to what this alleged charge was for or what the alleged "service call" was. Further, SPU has given no basis or explanation of rates to show how they value such "service calls". lt is my understanding that no service call was made by SPU on the property at issue during the month of October, or any other month since I have owned or occupied the property. This amount has not been paid as there is no basis for it being assessed against me under any policy, rule, or agreement with SPU. c. May 31, 2022.1 received two invoices, Nos. 3500 and 3517. lnvoice #3500 was for water and sewer services at the standard monthly rate of $46.00. lnvoice #35L7 charged $7,024.24. This exorbitant amount included $5,417.50 for an alleged one hundred and ninety- seven "water meter checks" without any explanation of when the alleged meter checks occurred, what the meter readings were, and the basis for charging meter checks. Additionally, the lnvoice sought $850.00 for 10 instances of non-descript "Account management" by Doyle Beck. There is no explanation for these charges and no water SUPPLEMENTAL DECLARATION OF DONALD D. SORRELS IN SUPPORT OF FORMAL COMPLAINT _ 3 use agreement has been signed which allows for the assessment of such charges. As of today's date, I have paid the $46.00 owing per invoice #3500 with a check, #7042.1 have not paid the unwarranted $7,O24.24 in miscellaneous attorneys fees and account management. d. August 31,,2022. The Statement included the amount charged under the re-sent invoice previously identified in paragraph 5 above. As explained, this amount had already been paid, and the remaining fee is in error. 8. On or about September 26,2022,1 received an invoice from SPU for $22,642.62. The invoice included $20,965.12 in alleged "Legal Fees" and $1,677.50 for 61 water meter checks. There is no explanation for these charges and no water use agreement has been sigined which allows for the assessment of such charges or identifies applicable rates. Further, there is no explanation of when the alleged water meter checks were performed. A true and correct copy of the September 26,2022 invoice is included with this declaration as Exhibit C. 9. The water meter at issue in this matter was installed on or about July 29,2021. According to the Statement and invoices I have received, SPU alleges that it has performed approximately two hundred and fifty-eight water meter checks on the subject water meter within a span of only 18 months. ln my opinion, it strains credulity to think that these water meter checks were necessary, reasonable, or, frankly, even occurred, at least at the rate and frequency indicated within the Statement and SUPPLEMENTAL DECI.ARATION OF DONALD D. SORRELS IN SUPPORT OF FORMAL COMPI.AINT _ 4 invoices. I have been consistently and continuously accosted with inexplicable and unfounded fees and charges, which I believe are designed purelyto frustrate or harass me. l, Donald D. Sorrells, hereby declare in accordance with ldaho Code section $ 1406 that the foregoing statements are true and conect to the best of my knowledge. DATED: October L3, 2022. ,/s/ Donald Sorrells Donald D. Sonells SUPPLEMENTAL DECIARATION OF DONALD D. SORRELS !N SUPPORT OF FORMAL COMPI.AINT_ 5 Sunnyside Utilities Inc P.O. Box 1768 Idaho Falls, ID 83403-1768 208-529-9891 BillTo Donald Sorrells 3341 N EmperorAve. Fresno, CA 93737 lnvoice Date lnvoice # 9t26D022 3576 P.O. No.Terms Project Quantity Description Rate Amount 6 LECAL FEES I I/3OI2I LEGAL FEES IZ3I2I LEGAL FEES OI/3II22 LEGAL FEES 04/0422 LEGAL FEES O4l30/22 LEGAL FEES O5AI/22 LEGAL FEES 06130/22 LEGAL FEES O7l3I/22 WATER METER CHECK $55.00 HR@.50 TOO9t23t22 2,433.74 1,496.25 3, r 50.00 6,243.?5 4,611.39 1,642.50 42s-O0 962.50 27.50 2,433.74 1,496.25 3,150.00 6243.75 4,611.39 r,642.50 425.00 962.50 1,677.50 Total 922,@2.63 Exhibit A I StatementSunnyside Utilities Inc P.O. Box 1768 Idaho Falls, [D 83403-1768 208-s29-989t To: Donald Sonclls 3341 N EmperorAvc. Fresno, CA 93737 Date 9nno22 Amount Due Amounl Enc. $7,070.24 Date Transaction Amount Balance nBtn020 0tBtDa2t 02fi1D02t 02n6D021 02n8D02r 03t30t2021 03t31t2021 un8t202t 04t30t202t 05ilgD02t 05t3v202t Balance foruard INV #3162. Due 01/3l/2021. -- H20 322.00 -- swR $24.00 {l -- Block 4 Lot 4 Sunnyside Indusrrial and Professional Park PMT#60438. PMTf,6o447. INV #3 I 82. Due 02D8D021. -- H20 $22.00.'- swR $24.00 fL -- BIock 4 Lol 4 Sunnysidc Industrial and Profcssional Park PM't'#60457. INV #3202. Due 03R 12021. -- H20 $22.00 --- swR s24.00 rq -- Block 4 Lot 4 Sunnyside Industrial and Professional Park PMT #6047t. INV #3224, Due MBOr202l. --- H20 $22.00 --- swR $24.00 I --- Block 4 Lot 4 Sunnyside Industrial and Profcssional Park PMT#60476. INV #3244. DwOSBIDO2I. - r{20 $22.00 -- swR $24.00 fl -- Block 4 Lot 4 Sunnyside Industrial and Professional Park ":l46.00/ .::1 ":::l ":l46.00 46.00 92.00 t'f:ffi 46.00 0.00 46.00 0.00 46.00 0.00 46.00 CURRENT 1.30 DAYS PAST DUE 31-60 DAYS PAST DUE 61.90 DAYS PAST DUE OVER 90 DAYS PAST DUE Amount Due 0.00 46.00 0.00 0.00 7,024.24 s7,070.24 Page I StatementSunnyside Utilities Inc P.O. Box 1768 Idaho Falls, ID 83403-1768 208-529-9891 To: Donald Sonells 3341 N EmperorAve. Fresno, CA 93737 Date 9i7n022 Amounl Due Amount Enc. s7,070.24 Date Transaction funounl Balance 06t30t202t 07t06t2021 07t23t202t 0113v202t 08t27t2021 08t31t2021 09DA202t 09t30/202t t0n4t202l t0t3v202l In9t2021 INV #3264. Due 06/302021 --- H20 $22.00 -- swR $24.00 Pl -- Block 4 Lot 4 Sunnyside Industrial and Professional Park PMT #60484. PMT #3337. INv #3284. Dw 07 t3t t2021. --- rr20 $22.00 --- swR $24.00 --- H2O Excess $0.00 --- Block 4 Lot 4 Sunnyside Industrial and Professional Park PMT #50504. INV #3304. Due 08/312021. --- H20 $22.00 --- swR $24.00 tl P11 -- Block 4 Lot 4 Sunnyside lndustrial and Professional Park PMT #605 r r. INV #3324. Due 0960/2021. --- H20 $22.00 --- swR $24.00 8J\ -- Block 4 Lot 4 Sunnyside lndustrial and Professional Park PM',t' #605 16. INV #3342. Due l0/31/2021 ---.---{8 and Profcssional Park ;;; "::l ":l ":l701.97 -f.gf j*.yf 46.67 n.o0 0.00 46.00 0.00 46.00 0,00 701.97 r? ' lilF/arn* #a a.61 6ogjs 6s5.30 CURRENT 1-30 DAYS PAST DUE 31-60 DAYS PAST DUE 61-90 DAYS PAST DUE OVER 90 DAYS PAST DUE Amount Due 0.00 45.00 0.00 0.00 7,024.24 $7,070.24 Page 2 ,StatementSunnyside Utilities Inc P.O. Box 1768 Idaho Falls, ID 83403-1768 208-529-989t To: Donald Sorrclls 3341 N Emperor Ave. Fresno, CA 93737 Date 9nnm2 Amount Due Amount Enc. tl,w0.24 Date Transaclion Amount Balance ltB0n02t tzRtn02t 01n7n022 0v26D022 0tRtn022 02t23n022 o2D8nO22 $D5n022 03Rlno22 04n6t2022 INV #3364. Due t 1802021. -- H20 $22.00-- swR $24.00 --- Il2O Excess, 0.66 @ $0.67 = 0.aa -- Block 4 tot 4 Sunnyside Industrial and Professional Park INV #3384. Due l2Bl DAZI. -.. u20 92.00-- swR $24.00 *- Block 4 Lot 4 Sunnpide Indusrrial and Professional Park PM',r'#60556. PMT#60574. INV #3405. Dnc 0l B I D022.-- H20 S22.00-- swR $24.m ff rl{ r( -- Block 4 l"ot 4 Sunnysidc Industrial and Professional Park PMT #60592. INV #3426. Duc Q2r2U2022. -- rr20 s22.00-- swR $24.00 f\ -- Block 4 Lot 4 Sunnyside lndusrial and Professional Park PMT #60610. INV #3444. Drrc 03R I 12022. -- il20 s22.00 -- swR $24.00:- ll20 Excess, 12.38 @ $0.67 = 8.29 -- Block 4 Lot 4 Sunnyside Indu*rial and Professional Park PMl #9009. il rot 46.44 "::] "::l :::t 701.74 747.74 70r.30 655.30 70t.30 655.30 70t.30 655.30 709.59 655.30 CURRENT 1.30 DAYS PAST DUE 31.60 DAYS PAST DUE 61-90 DAYS PAST DUE OVER90 DAYS PAST DUE Amount Due 0.00 46.00 0.00 0.00 7,W4.24 $7,070.24 Page 3 StatementSunnyside Utilities Inc P.O. Box 1768 Idaho Falls, ID 83403-l 768 208-529-9891 lol Donald Sonclls 3341 N EmperorAvc. Fresno, CA 93737 Date 9nna22 Amount Enc.Amount Due $7,070.24 Amount BalanceDateTransactbn cnrr 06R0n022 07il9t2022 07t3tn022 08D6n022 offih0zgr,'! 4 Lot 4 Sunnyside Indugrial and Professional Park -- Block 4 Lot 4 Sunnysidc Industrial and Professional Park -- Block 4 Lot 4 Sunnyside lndustrial and Profcssional Park ,l t/l lndusrial and Professional Park P p , .! r',t# { ry OJ .50s27In@ 0I $85.00 850.00 i-tN[isc.,@ l/2@2.arrar; -, --- t47771-152703 -- lI2O Excess $0.fi) 4 l-at 4 (i PMT#7025. lN\ #3540. Dua 07 Rl t2022. --- il20 s22.00-- swR $24.00 89 *tot'l ?ln$t INV #352 l. Due M13012022. -- il20 322.00 -- swR $24.00 t'swR$24.00 -- Block 4 l.ot 4 otlL *:l 46.00? t 46.00 rr * fti '1/051, 110.74 756.74 1,024.24 7,070.24 7,024.24 7,070.24 7,024.24 7,070.21 Amount DueCURRENT1-30 DAYS PAST DUE 31-60 DAYS PAST DUE 81.90 DAYS PAST DUE OVER 90 DAYS P-A$TrE[rlE-.frd0.00 46.00 0.00 0.m (I Page 4 ilhibit B Sunnyside Utilities Inc P.O. Box 1768 Idaho Falls, [D 83403-1768 208-529-989t BillTo Donald Sorrells 3341 N EmperorAve. Fresno, CA 93737 lnvoice Date lnvoice # 8Rtn022 P.O. No.Terms Projeci Quantity Description Rate Amount Watcr Scrvice Scwer Servicc Industrial and Profcssional Pa* {ilti /Nolr c q ?Ato 8(tsl""c,{K 'r 7o3l od ,Nu0r5eut'RL dzl cj 22.00 24.00 22.W 24.00 $46.00Total Exhibit C