Control Number : Item Number : 33. Addendum StartPage: 0

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1 Control Number : Item Number : 33 Addendum StartPage: 0

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3 DOCKET NO. PUC LAURANCE KRIEGEL * PRO SE APPELLANT * * V. * MARIAH NORTHWEST, LLC * SCANDIA WIND SOUTHWEST, LLC * SCANDIA JIM SWAFFORD PARMER COUNTY COMMISSIONERS* PARMER COUNTY JUDGE * TREY ELLIS APPELLEE'S PUBLIC UTILITY COMMISSION OF TEXAS 2 To The Texas Public Utility Clerk; CLERK's ENTRY FOR DEFAULT JUDGMENT NOW COMES APPELLANT, filing this ENTRY of Default Judgment for the Public Utility Clerk to enter this Order for the following reasons; Appellant finds from the record that Appellee's have not answered or defended this proceeding. Appellant finds from the record the Public Utility Commissioners have not entered a Opinion or Order is this proceeding for Appellee's to stop the construction of the Alternate Electric Windmill projects or program's with their flawed electrical design. Appellant has just recently been granted his Constitutional and Statutory Right to intervene in these PUC cases by SOAH after Appellant appealed this error to The Supreme Court of Texas. A Order by the PUC on a Complaint before caused a Appeal to the Supreme Court of Texas, This case is still open. Texas Civil Practice and Procedure Rules state that the Appellant will close a case. Upon examination of the record Appellee's have had notice since of this proceeding. PUC has accepted and filed additional Intervention documents with additional facts and additional construction areas in this proceeding. 1 3,-)

4 Appellee's had notice again on and this recent notice on Each involved a different area with different legal descriptions. Each involved a different group of parties in the heading of the Complaint. Appellee's have had notice of the proceeding for more than 20 days. The PUC has had notice of the Default Judgment for more than 30 days. Texas Rules of Civil Procedure, Rule 239a allow The Public Utility Commission Clerk of Texas to enter this Default Judgment. Appellant is allowed to receive this Default Judgment since Appellee has not placed any of Appellant's facts at issue, Rule 419. There are no disputed facts. Appellee's have failed to plead since Appellant has filed addition documents of record in this proceeding since the PUC's Order No. 2, dated This order caused another Appeal the Supreme Court of Texas case, Additional new complaints by Appellant with new information and new Alternate Electric Windmill Company's involved were filed by The Public Utility Commission of Texas under the same number Rule 21a, Rule 101 and require a answer within 20 days plus mail delivery. Appellee, received the complaints on , , and with the filing in The Public Utility Commission of Texas. Appellee did not answer the filing in this proceeding with in prescribed time required by Texas Civil Practice and Procedure, therefore the Court is lawfully allowed to enter a Default Judgment, Rule 239. Now the clerk of the PUC has the lawfully authority to enter the Default Judgment into the record, Rule 239a. Appellant has filed addition documents of record in this proceeding since the case was filed that Appellee's have not responded to. Appellee's, has received and not responded with a answer to the Motion for Replevin, dated Appellee's, has received and not responded with a answer to the Motion for Injunctive Relief, dated Appellee's, the Partner County Commissioners and The Parmer County Judge do not have authority to designate my property as a reinvestment zone, the fee simple clear title landowner on most of the designated lands, if not all. See the Original Petition That pleading clearly explains the errors in Law. Appellee, Mariah North West LLC does not have all of the necessary documents in the State Comptrollers office of Texas for legal standing to conduct business in Texas. Mariah does not have a Electric Provider number or Electric Billing number or all of the documents with THE STATE OFFICE of COMPTROLLER. 2

5 Appellee, Scandia does not have all of the necessary documents in the State Comptrollers office of Texas for legal standing to conduct business in Texas, or the PUC for the Electric Provider number or Electric Billing numbers. Appellee's have used Quit Claim deeds recorded in the Parmer County Clerk's office, the 1836 and/or the 1845 Republic of Texas Constitution does not allow the use of Quit Claim deeds. Appellee's do not have a valid wind lease recorded in the Parmer County Clerk office. This memorandum does not contain the necessary information required by Texas Property Code or The Texas Natural Resource Code for a Wind Lease. Appellee's, do not have any authority to construct any type of Alternate Electric Windmill project using comments about the Competitive Renewable Energy Zone (CREZ). [The Alternate Electric Windmill Energy is not competitive]. The CREZ was for only 3 Windmills. This project was built a number of years ago. All Alternate Electric Windmill Energy is unaffordable and unreasonable and unsafe. The Texas PUC has approved excessive Electric Windmill rates in other proceeding in excessive of $1.35 per KWH. Conventional Electricity can be produced for $.0001 per KWH. Appellee's do not have a Electric Energy Provider number on record in the Public Utility Commission of Texas office. Texas Public Utility Code. Appellee's do not have a Electric Energy Billing number on record in the Public Utility Commission of Texas office. Texas Public Utility Code Appellants Land records are recorded in The General Land office of Texas. Land of Appellants has been sold without permission of Laurance Kriegel or his father (now deceased). Land of Appellant is being built on by Alternate Windmill Energy company's without permission of Appellant. Appellee's and other Company's [SPS and XCEL] and other Alternate Electric Windmill Company's have been notified of the Lands of Laurance Kriegel for several years. Appellee's has not been given permission to be on these lands. Appellee's Alternate Electric Windmill design is flawed and this documentation is recorded in the Public Utility Commission of Texas by Southwestern Public Service. Flawed electric should never be constructed; it is dangerous to the Citizens of Texas, and all types of electric motors. One danger is from the sparks the Electric Windmill will emit. The sparks can be large or small. Appellee's should stop construction of all of there projects over all of Texas. Appellee's are demising the land they are on without permission of the fee simple land owner. Rule 799. Appellee's do not have permission to be on Appellants land. Appellee's have continued to dig holes in this illegal Parmer County Reinvestment Zone for what Appellant construes to be for a large concrete base, since they were notified again during Jan., Appellee's, Parmer County Commissioners

6 are not allowed to be involved in this type of business. See the internet cite for Parmer County Reinvestment zone. Appellee's have failed to plead. Appellee's have not challenged any fact in the proceeding, Rule 419. Appellee's were notified again in Jan., 2014 of there wrongs, over 20 days have elapsed since the notice was received by Appellee's. Appellee's have failed to answer or otherwise serve a copy of a answer in the proceeding. The legal time for pleading or otherwise defending has expired and the default against Appellee's can be entered according to Law. The grounds for the default have been clearly established by LAW and presented to Appellee's. AFFIDAVIT This affidavit is executed by affiant in accordance with Rule 239 of THE TEXAS RULES OF CIVIL PROCEDURE for the purpose of Appellant to obtain an entry of default against Appellee's for their failure to answer or otherwise defend as to Appellant's complaint. Laurance Kriegel REQUESTED RELIEF WHEREFORE, APPELLANT moves this Court make and enter a Default Judgment that instructs Appellee's to; 1] shall stop construction and remove there equipment from the land after the land is restored to the Original condition at their expense. 2] shall take down all Alternate Electric Windmill Towers and Transformers systems and Electric Transmission Lines. Appellee's shall pickup up and remove all bolts, nuts, steel, pieces of steel, wire, small pieces of wire, and all concrete and small chips of concrete from the land. 3] shall plow all roads they created with a chisel plow to the depth of the hard pan created by Appellee's. Appelleee's shall protect a112 inch Natural Gas Lines and larger Mainline natural gas lines. Appellee shall place all Natural Gas Lines back in service at their expense. Appellee shall replace all Natural Gas Meters with meters that read Natural Gas in MCF. ORDERED AND ADJUDGED, that Appellant receive this Default Judgment written if favor of Appellant and all fee simple land owners were Appellee's have entered the land to build the unsafe and flawed Alternate Windmill Electricity without correct legal documentation. Signed this day of, 2014, Clerk 4

7 Entered this _ day of, 2014 Clerk of the Public Utility Commission Respectfully Submitted; v Dated July 21, 2014 p. Q Laurance Kriegel, Pro Se 1202 Hwy 86 Bovina, Texas Copies: The Texas Rules of Civil Procedure for District Court rules require the clerk to send a copy to all involved. This administrative proceeding follows the same rules. Appellant request the clerk send a copy of this document to all involved. CERTIFICATE OF SERVICE I, Appellant, Laurance Kriegel, certify that a true and correct copy of the Motion for Default Judgment and this request for Entry of the Default Judgment has been sent to all of record by U. S. Mail to: SPS 600 Tyler St., Suite 27B01 Amarillo, Texas Public Utility Commission of Texas 1701 N. Congress Avenue P.O. Box Austin, Tx Paul M. Guinn Xcel Energy Services, Inc. 816 Congress Austin, Texas Federal Energy Regulatory Commission Washington, D. C Reference Docket # EL # EL Public Utility Commission of New Mexico The CT Corporation Company P.O. Box North S. Paul Santa Fe, N.M Dallas, Tx FAX Spinning Spur Ranch Wildorado Wind Ranch, LP Wildorado Wind LP 5

8 % Cielo Wind Services, LLC %Edison Mission Group 6798 CO RD Congress Avenue, Suite Von Karman Ave, P.O. Box 55 Austin, Texas Suite 1700 Vega, Tx Irvine, CA Fax Mariah North West, LLC Prinsens Gate Oslo, Norway Fax Attention: Ketil Reed Aasgaard, CEO Scandia Wind Southwest, LLC 201 North Street P.O. Box 783 Bovina, Texas Attention: Jim Swafford Parmer County Commissioners %Trey Ellis P.O. Box 506 Farwell, Texas Respectfully Submitted; Dated Laurance Kriegel, Pro e 6

9 LAURANCE KRIEGEL PRO SE APPELLANT DOCKET NO. PUC V. * PUBLIC UTILITY MARIAH NORTHWEST, LLC * COMMISSION OF TEXAS SCANDIA WIND SOUTHWEST, LLC * SCANDIA JIM SWAFFORD PARMER COUNTY COMMISSIONERS* PARMER COUNTY JUDGE TREY ELLIS * APPELLEE'S DEFAULT JUDGMENT The PUBLIC UTILITY COMMISSION of TEXAS finds that Appellants claims against Appellee's are proven in Appellant's Original Petition, Motion for Replevin, and Motion for Injunctive relief. The Public Utility Commission of Texas finds that Appellee's shall stop construction and remove all there equipment and Alternate Electric Windmills and Alternate Electric Transmission lines. The PUC finds that Appellee's are to remove every piece and crumb of concrete, electric wire, bolt and nut from the property of Appellant. The PUC finds that Appellee's shall close all the holes in the ground to the same condition as the soil was in before the soil was disturbed. All roads created by Appellee in the fields shall be plowed with a chisel plow to the depth of the hard pan created by Appellee's equipment. All natural gas pipelines, mainline and 2 inch, and irrigation pipelines, and gas meters shall be placed back in service where they were disconnected. THEREFORE, IT IS, ORDERED and ADJUDGED that Appellee's carry out these instructions at there expense. Public Utility Clerk Dated

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