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    Inigntion Dkfiict: of To

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    Chapter 11 Dockets
    The document is a response letter from Modesto Irrigation District to the U.S. Bankruptcy Court regarding a claim. It disputes the debtor's objection to claim #670 for $114.76, providing copies of bills showing credits of $114.76 were made to the pre-petition account balance, leaving amounts due of $173.47 and $173.41 which were paid. It asks the court to deny reducing the claim as the district has provided evidence supporting the full $114.76 amount.

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    Inigntion Dkfiict: of To

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    Chapter 11 Dockets
    34 views5 pages
    The document is a response letter from Modesto Irrigation District to the U.S. Bankruptcy Court regarding a claim. It disputes the debtor's objection to claim #670 for $114.76, providing copies of bills showing credits of $114.76 were made to the pre-petition account balance, leaving amounts due of $173.47 and $173.41 which were paid. It asks the court to deny reducing the claim as the district has provided evidence supporting the full $114.76 amount.

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    10000010611

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    The document is a response letter from Modesto Irrigation District to the U.S. Bankruptcy Court regarding a claim. It disputes the debtor's objection to claim #670 for $114.76, providing copies of bills showing credits of $114.76 were made to the pre-petition account balance, leaving amounts due of $173.47 and $173.41 which were paid. It asks the court to deny reducing the claim as the district has provided evidence supporting the full $114.76 amount.

    Copyright:

    Attribution Non-Commercial (BY-NC)
    Download as PDF, TXT or read online from Scribd
    Download as pdf or txt
    34 views5 pages

    Inigntion Dkfiict: of To

    Uploaded by

    Chapter 11 Dockets
    The document is a response letter from Modesto Irrigation District to the U.S. Bankruptcy Court regarding a claim. It disputes the debtor's objection to claim #670 for $114.76, providing copies of bills showing credits of $114.76 were made to the pre-petition account balance, leaving amounts due of $173.47 and $173.41 which were paid. It asks the court to deny reducing the claim as the district has provided evidence supporting the full $114.76 amount.

    Copyright:

    Attribution Non-Commercial (BY-NC)
    Download as PDF, TXT or read online from Scribd
    Download as pdf or txt
    of 5

    ID

    February 25,2010

    Inigntion Dkfiict

    ,ilodgto

    Docket #4667 Date Filed: 3/5/2010


    1231 Eleventh St. P.O. Box 4060 Modesto, CA 95352 (?0e) 526-7373

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    ;;= U.S. Bankruptcy Court, District of Delaware 824 Market Street, 3'o Floor

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    Wilmington, DE 19801

    Re: Mervyn's Holdings,LLC., et al., Case #08-1 1587 (KG) Modesto Irrigation District, Claim #670
    RESPONSE TO DEBTOR'S TWENTY.SECOND OMNIBUS OBJECTION (SUBSTAI\TIVE) TO CERTAIN OVERSTATED CLAIMS AND MOTION TO REDUCE OR EXPUNGE CLAIMS

    In response to the Notice of Debtor's

    Twenty-Second Omnibus Objection (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 krigation District's Claim #670, in the amount of $114.76 to a reduced amount of $59.23 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 $168.99 for service period 07llll08 - 08/07108. You will also find a copy of their next bill dated 09/19/08 which shows credit adjustments totaling $114.76 that was made to their account for pre-petition services (07llll08 - 07 129108), leaving an ending balance of $173.47. This amount is the current post-petition charges of $114.24 for service period 08/08/08 - 09i08/08 plus the prorated amount of $54.23 from the previous bill for service period 07130108 - 08/07108 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 a copy of Debtor's bill dated 10/16/08 that shows a payment was received for $173.41, which is the amount due on the 09119/08 bill. Debtor did not object to the credit adjustments made to their account for pre-petition charges totaling $114.76; therefore, their objection to our claim is unwarranted as it is for the exact same amount.

    We ask that this court deny the Debtor's request to reduce the Modesto Irrigation District's Claim #670 in the amount of $114.76 as we have provided specific factual bases as well as documentation or other evidence of our claim.
    Sincerely,

    <:J\*+tVA
    Lien Campbell Modesto Irrigation District Sr. Customer Service Rep.

    0q/v*#% "b 0811586100305000000000002

    ONGANIIZED 1887. IRRIGATION WATER 1904' POWER 1923'DOMESTIC WATER

    LC:lc
    Attachments CC:

    Mark D. Collins Daniel J. DeFranceschi Christopher M. Samis Andrew C. hgens 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 l0l Park Avenue New York, NY 10178-0060

    l1=lllDrr*tr'
    STATEMENT DATE: CUSTOMER NAME: SERVICE LOCATION: SERVICE START DATE: LOCATION NUMBER: ACCOUNT NUMBER: ACCOUNT BALANCE: 08/16/2008 Mervyn's Of California 2801 MchenryAve, Modesto 't1t13t1973
    51842537
    1

    1231 ELEVENTH STREET P.O. BOX 5355 MODESTO. CA 95352-5355 (209) 526-7337

    CURRENT BILL DUE BY: 09/05/2008


    SERVICE PERIOD FROM: 07/1112008 09/08/2008 NEXT READ TO:08/0712008

    1246808108

    $ 168.99

    DATE: 05/01/2008 GSI Rate Active First 100.000 Per KWH $0.1216
    Effective for: 28 days

    MeterNumber:
    Prior Meter

    4'l1051'l

    Read: 59364

    Outage Block: 128 Current Meter Read: 60525

    Multiplier:

    Usage:

    1161

    Current Charges
    Fixed Monthly Amount Electric Usage Charge City Tax (67o) 18.00

    141.'t8 9.55 0.26

    AccountActivity From:
    Total Cunent Charges Previous Balance

    State Surcharge (0.00022 per kwh) 711612008

    To:

    8/1rU2008 168.99

    229.15
    229.15 CR

    Payment

    -*THANKYOU*

    AMOUNT

    DUE

    168.99

    Payments and Adjustments received aller 811412008 will appear on your next bill.

    Low lncome 22,2Yo Discount Sign-up available first Friday of every month - MID lobby. Bring last bill and proof of income.

    This

    Last

    Year:

    Year: 3260 kwh, 29 days, ,{vg kWh per day

    161 kwh, 28 days, Avg kWh per day 4 l .46


    112.41

    PLEASE KEEP THIS SECTION FOR YOUR RECORDS. FOR CUSTOMER INFORMATION SEE REVERSE SIDE

    Modesto

    I
    E

    lrrigation Bistrict

    ACCOUNT NUMBER
    1

    AMOUNT DUE
    PLEASE PAY

    1246808108

    $ 168.99
    IF DIFFERENT AMOUNT PAID PLEASE INOICATE

    PLEASE OETACH AND RETURN THIS PORTION WHEN PAYING BY MAIL

    #BWNGRTT
    I

    P.O. BOX 5355 MODESTO, CA 95352-5355


    #QQXDJTRTQ9RT3#

    l,l,,l,'ll,,,l,l,,,lll,,l,,,l,l,,,lll,,l,,,,lll,,l,,,,ll,,,lll
    Mervyn's Of California c/o Cass lnfo Systems Modesto MOOO9 PO Box 182181 Columbus. OH 43218-2181

    501 1 00000112468081 080000016899

    08/18/2008 07:56:52 ?Sequence?

    li=IvllDf,'iiili"l
    STATEMENT CUSTOMER SERVICE LOCATION: SERVfCE START DATE: LOCATION NUMBER:

    1231 ELEVENTH STREET P.O. BOX 5355 MODESTO. CA 95352-5355 (209) 526-7337

    DATE: NAME:

    09/19/2008 Mervyn's Of California 2801 Mchenry Ave, Modesto


    1111311973

    CURRENT BILL DUE BY: 10/09/2008


    SERVICE PERIOD FROM: 08/08/2008 'tot07t2008 NEXT READ DATE:

    TO: 09/08/2008

    ACCOUNTNUMBER:
    ACCOUNT

    BALANCE:

    51442537 11246808108 $ 173.47

    GSI Rate
    Effective

    First'100,000 Per

    Active 05/01/2008 KWH $0.1216

    for: 32 days

    Meter Number: 41'10511 Outage Block: 128 Current Meter Read: 61262 Prior Meter Read: 60525

    Multiplier:

    Usage: 737

    Current Charges
    Fixed Monthly Amount Electric Usage Charge City Tax (6%) State Surcharge (0.00022 per kWh)
    18.00 89.62

    6.46 0.16 9/15/2008 't14.24


    168.99 5.00

    AccountActivity From: 8/15/2008 To:


    Total Cunent Charges Previous Balance Late Fee GS-1 Fixed Month Charges GS-1 Total Elec. Usg Charges Modesto tax State Surcharge Adjustment

    12.22CR
    95.87 CR 6.49 CR 0.18 CR

    AMOUNT

    DUE

    173.47

    Payments and Adjustments received after 9/15/2008 will appear on your next bill.

    Low ncome 22.2o/o Discount Sign-up available first Friday of every month - MID lobby. Bring last bill and proof of income.
    f

    This

    Last

    Year:

    Year: 3326 kwh, 30 itays, Avg kWh pei day

    737 kwh, 32 days, Avg kWh per day 23.03

    110.87

    PLEASE KEEP THIS SECTION FOR YOUR RECORDS. FOR CUSTOMER INFORMATION SEE REVERSE SIDE

    li=lllDrilf,ff"
    E

    ACCOUNT NUMBER
    1

    AMOUNT DUE
    PLEASE PAY

    1246808108

    $ 173.47
    IF DIFFERENT AMOUNT PAID PLEASE INDICATE

    PLEASE OETACH AND RETURN THIS PORTION WHEN PAYING BY MAIL

    #BWNGRTT
    #QQXDJTRTQ9RT3#

    P.O. BOX 5355 MODESTO, CA 95352-53s5

    l,l,,l,,ll,,,l,l,,,lll,,l,,,l,l,,,lll,,l,',,lll,,l,,,,ll,,,lll
    Mervyn's Of California c/o Cass lnfo Systems Modesto MOOO9 PO Box 182181 Columbus. OH 4321 8-21 81

    401 1 00000112468081 080000017347

    09/1912008

    0E:02:43 ?Seauence?

    fLI'llDffi:i,?'ilx
    STATEMENT DATE: CUSTOMER NAME: SERVICE LOCATION: SERVICE START DATE: LOCATION NUMBER: ACCOUNT NUMBER: ACCOUNT BALANCE:
    10t1612008 Mervyn's Of California

    1231 ELEVENTH STREET P.O. BOX 5355 MODESTO. CA 95352-5355 (209) 526-7337 CURRENT BILL DUE

    BY:

    11/05/2008

    2801 MchenryAve, Modesto


    11t13t1973 '',t842537 1246808108
    1

    SERVICE PERIOD FROM: 09/09/2008 11t05t2008 NEXT READ DATE:

    TO: 10/07/2008

    $ 184.45

    GSI

    First 100,000 Per


    Effective

    RateActive 10/01/2008 GSI RateActive 05/01/2008 KWH $0.1044 First 100.000 Per KWH $0.1216
    for: 7 days
    Effectivefor: 22 days

    Meter

    Number:

    41 10511

    Prior Meter

    Read: 61262

    Outage Block: 128 Current Meter Read: 62588

    Multiplier:

    'l

    Usage: 1326

    KWH

    Current Charges
    Fixed Monthly Amount Electric Usage Charge City Tax (6%) State Surcharge (O.OO022 per kwh) 18.00 't55.74 10.42

    0.29
    10/1412008 184-45 173.47 173.47 CR

    AccountActivity From: 9/16/2008 To:


    Total Cunent Charges Previous Balance

    Payment

    *'THANK YOU**

    AMOUNT

    DUE

    184.45

    Payments and Adjustments received alter 1011N2008 will appear on your next bill. Low fncome
    22.2o/o

    Discount Sign-up available first Friday of every month - MID lobby. Bring last bill and proof of income'

    UiiV??i,JtASlY'A:1"'SXfu lX?JY'X,B"i!?'olil?'u,
    PLEASE KEEP THIS SECTION FOR YOUR RECORDS. FOR CUSTOMER INFORMATION SEE REVERSE SIDE

    ACCOUNT NUMBER
    1

    AMOUNT DUE
    PLEASE PAY

    1246808108

    $ 184.45
    IF OIFFERENT AMOUNT PAIO PLEASE INDICATE

    PLEASE DETACHANDRETURN

    THIS PORTIONWHEN PAYINGBYMAIL


    1

    #BWNGRTT
    #QQXDJTRTQ9RT3#

    P.O. BOX 5355 MODESTO, CA 9s352-5355

    l,l',l,,ll,,,l,l,,,lll,,l,,,l,l,,,lll,,l,,,,lll',1,,,,11,,,111
    Mervyn's Of California c/o Cass lnfo Systems Modesto MOOO9 PO Box 182181 Columbus. OH 43218-2181

    50

    11

    000001 "12468081 08000001 8445

    10/16/2008 08:06:11 ?Sequence?

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