Update: On March 23, 2015, Ohio Edison Company, The Cleveland Electric Illuminating Company, and The Toledo Edison Company filed an answer to the complaint, denying the pertinent allegations of the complaint and asserting that complainants have failed to allege reasonable grounds for the complaint.

AEP Ohio likewise filed an answer, as well as a motion to dismiss the complaint, on March 23, 2015, denying the pertinent allegations of the complaint, asserting that complainants have failed to allege reasonable grounds for the complaint, and alleging that FirstEnergy Solutions (FES) is wholly responsible for all disputed billing charges at issue in the complaint.

FES filed an answer to the complaint on March 24, 2015, denying the pertinent allegations of the complaint and asserting, among other things, that complainants have failed to allege reasonable grounds for the complaint, that the Commission lacks subject matter jurisdiction over the claims alleged in the complaint, and that Complainants’ claims are barred by the terms of their contracts with FES.

On March 24, 2015, complainants filed a reply to the various memoranda contra complainants’ motion for assistance to prevent termination of service, alleging that they remain in need of protection against disconnection of service unless Ohio Edison Company, The Cleveland Electric Illuminating Company, The Toledo Edison Company, and AEP Ohio admit that the complainants have filed a formal complaint with the Commission which reasonably asserts a bona fide dispute, and that the complainants have paid the undisputed portions of their electric bills and have agreed to continue doing so during the pendency of the complaint.

On March 26, 2015, FES filed a motion to dismiss the complaint, alleging in greater detail the items it alleged as affirmative defenses in its answer earlier in the week.