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Texas REP Files Response To Complaint Alleging Profit Sharing Dispute

January 31,2019



GBPower, LLC has filed a response at the Texas PUC to a self-styled "complaint" filed by Rico de los Reyes

In its response, GBPower summarized the complaint by stating, "The Complaint, while not clear, seems to allege that GBPower has wrongfully terminated Mr. de los Reyes employment with GB Power and breached one or more employment or compensation contracts with the Complainant."

GBPower in its response said that, "This is subject matter over which the Commission does not have jurisdiction."

GBPower in its response said that, "The Complainant has made three allegations against GBPower in his formal complaint: that he was removed from the GBPower REP certificate; that he was terminated from his position with the Company; and that the profit sharing agreement between he and the Company was unilaterally amended after his termination from the Company."

GBPower in its response said that, "The Complainant has failed to state how these actions have violated a statute over which the Commission has jurisdiction, a Commission rule, or a Commission order. Furthermore, these allegations, even if taken as true, do not entitle the Complainant to any relief from the Commission, and the entirety of the complaint should be dismissed for failure to state a claim for which relief can be granted..."

"In the event the Commission takes jurisdiction over this Complaint, GBPower, as the respondent in this Complaint, generally denies all the allegations in the Complainant's Formal Complaint filed with the Commission on January 4, 2019 and demands that the Complainant be required to prove each of his allegations with evidence to support his claims," GBPower said in its response

GBPower moved to dismiss the complaint

GBPower's response can be found here

The original complaint can be found here

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