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Charleston Case No. 12-1333-Pwd-C Frank Dielon

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Charleston Case No. 12-1333-Pwd-C Frank Dielon PUBLIC SERVICE COMMISSION OF WEST VIRGINIA CHARLESTON CASE NO. 12-1333-PWD-C FRANK DIELON V. LOGAN COUNTY PUBLIC SERVICE DISTRICT COMPLAINANT, FRANK DILLON’S, RESPONSE TO FIRST SET OF INTERROGATORIES,DATA REQUEST OR REQUESTS FOR INFORMATION BY THE STAFF OF THE PUBLIC SERVICE COMMISSION OF WEST VIRGINIA NOW COMES the Complainant, Frank Dillon, by Counsel, Mark Hobbs, and for this his Response to First Set of Interrogatories, Data Request or Requests for Information by the Staff of the Public Service Commission of West Virginia and states as follows: Before answering, note that the Complaint’s family occupies three (3) residences on the property. The two (2) businesses we call buildings do not have water pipes laid to them. 1. Please submit all deeds and maps concerning the properties served with the existing 5/8” meter. RESPONSE: Please see the attached deed and map. 2. Are all properties owned by the Complainant? Are any of the buildingshomes rented? RESPONSE: All properties are owned by the Complainant, Frank Dillon. No Mark Hobbs Attow at Rofesslonal Bulldlng buildings or homes are rented. All buildings/homes are occupied by family (304) 855-4878 post OMce Box 974 members. Again, please note that there are no water lines laid to the two (2) ~pmamrille,WV 2550 businesses that are located on the Complainant’s property. 3. If the separate buildings are rented, how is the water usage for each building calculated and who is responsible for the water bill? Is the water usage included in the monthly rent? RESPONSE: Please note that there are two (2) buildings and three residences (homes) on the property. There are no water lines to the two (2) buildings. No buildings are rented and all homes are occupied by family. No water for any building is calculated for water usage. The Complainant, Frank Dillon, is responsible for paying the total amount of the monthly water bill and has been solely responsible for the water bill since 1986. There is no rent paid by any family members who occupy said buildings/homes. 4. Please indicate the type of service (commercial or residential) that will be required for each separate building. RESPONSE: It should be noted that the two (2) buildings on the property do not have water service as there are no water pipes ran to the two (2) buildings. The Complainant does not desire water service to the two (2) buildings. 5. Please indicate the purposes for which water will be used at each separate building and the approximate amount of water desired per month. RESPONSE: For the three (3) residences/homes using water, the water is used for cleaning, bathing, cooking and washing clothes. The water usage depends on if it is Mark Hobbs Attof~yat Law ~~fesslonalBulldlng summer or winter. Water usage can run between 20,000 and 60,000 gallon per (304) 855.4878 month. post Office Box 974 Owpmanvllle, WV 25508 6. Please provide a sketch or drawing showing the location of the service, line from the meter to each building. RESPONSE: Please see the attached colored sketch. 7. For each building, please indicate if a water shut-off valve has been installed immediately inside the foundation wall. RESPONSE: Yes, there is a shut-off valve to turn the water off for each building/home in case of a water leak. Frank Dillon By Counsel, Y" I Mark Hobbs, Esq. (WVSB#1744) Counsel for Complainant Post Office Box 974 Chapmanville, West Virginia 25508 (3 04) 855 -4878/( 3 04) 8 5 5 -4877 Hobbslaw82@,suddenliail.com Mark Hobbs Attorney at Imv ~ofers~ona~Building (304) 855-4878 post Office Box 974 Chapmanville,WV 25508 This made and entered into on this 22nd day of January, 1992, by and between 0. WARQ and CXWX- his wife, and parties of the first part and SpANTORS. and DILLON. and PXAN A L, M,U&&. hiR wife, for and during their joint lives and upon the death of either of them unto the survivor thereof forever, partles of the second part and GRmTEESt That for and in consideration of the sum of Thirty-five Thousand Dollars ($351000.00), cash in hand paid unto the parties of the first part by the parties of the second part, the receipt of which is hereby acknowledged, the parties of the first part have bargained and sold, and by these presents doth hereby bargain, sell, grant and convey, with covenants of Jf&RNWQ of title unto the parties of the second part, that certain lot, piece or parcel of real estate, together with improvements thereon, locate and situate on West Virginia State Route No. 10, in Logan District, Logan County, West Virginia, and situate between said Route No. 10 and the Guyandotte River, and which is more particularly described as follows, to-wit: I'Beginning at an iron pi e on the westerly right of way line of West VTrginia State Route No. 10, which beginning point stands at the southeast corner of Tract NO. 4 heretofore allotted to Lowell DOW Chambers and Sally Chambers Hole; thence from said beginning point and running u Guyandotte River with the westerly right of way lfne of said hi hway S 5' 06, W 207,50 feet to a point on said rqght of way line! thence leaving the road and running toward Guyand08h River N 85' 40' W 255.98 feet to a point at the ed e of the river! thence running down the river wyfh the low water mark and the meanders thereof N 0 22, E 99,42 feet to a point; thence N 27 27, E 132.62 feet to a point, which point: is at the southwcrrt carnal of Tract No. 4 heretofore allotted to Lowell now chambers and Sally Lou Chambers Hole; thence running with the South line of said Tract No. 4 and leaving the river S 82' 00, E. 214.0 feet to the place of beginning, and being #Tract No. 5' containing 1,22 acres, more or less, as said Tract io. 5 is shown on the map entitled 'Map Showing Land Owned yy L. D, Chambers, Jr. Heirs Situate at Rum Junction , etc., made b McCall Engineering Company, dated June, 1964 , whfch is of record in the Office of the Clerk of the County Commission of Logan County, to which map and deeds reference is here mdde for all pertinent purposes?' .. , .. .. .. .. si: J WZEi There is from the foregoing real estdte that certmor portion thereof heretofore conveyed unto West Vir inia Department of Highways for an saeement and rlght-of-way by Lonnie Ward and Marie Ward, his wife by deed dated September 8, 1975 whioh deed 1- of record in said Clerk's Office in De& Book tw;lat Page It55lft. Being in all respects the sane real estate conveyed unto Michael D. Ward from Lonnie E. Ward and Marie Ward, his wife, by virtue of that certain deed, bearing date the 29th day of Novembar, 1982, which said deed is of record in the Office of the Clerk of the County Commission of Logan County, West Virginia, in Deed Book t14251t, at Page 11236tt. The aforesaid Lonnie E. Watd and Harie Ward reserved unto themselves a life estate in the aforesaid deed and Marie Ward (now Vaughan) joins in this for purposes of relinquishing said life estate! the said Lonnie E. Ward being now deceased. This conveyance is expressly made 8uBJECT to all of the terms, provisions, conditions and restrictions set forth or referred to in that certain deed to Eleanor Chambers Vaughan and Ambers Vaughan, her husband, from Irene Spencer, widow, et al., dated September 11, 1964, a8 recorded in the aforesaid Clerk's Office in Deed Book tt3038t, at Page n158tt. BBpE AND To lrebp unto the parties of the second part for and during their joint lives and upon the death of either of them unto the survivor thereof EDRBVER. the parties of the first part have hereunto subscribed her signature and seal, all as of the day, month and year first within writtd.. (SEAL) LdoA (SEAL) (SEAL) GRANTOIJSL, -2- T- 1-1 J STATE OF WEST WRGINU, --, a Notary Public 11 -& L9. within and for the #AmCouney and State aforesaid, do hereby certify that WARD VAUGH?4N, whose name is subscribed to the foregoing writing of Deed of Conveyance, bearing &ate the 22nd day of January, 1992, has this day before me in my said County and State, duly acknowledged said writing to be her act and deed. GIVEN under my hand this 8 day of February, 1992. I further certify that my Commission as Notary Public will expire on the 29 day of .du,lY,19%. I hereby declare that the aoneideratfon paid for the property conveyed by the instrument to whioh this declaration This instrument prepared by: WARD h hssocuTBs Attorneye at Law P. 0. Box 628 Williamson, WV 25661 -4- 33 . - . 39 J STATE OF WSST VIRGINIA, , a Notary Public within and for the County and State aforesaid, do hereby certify that Mg,IhgL W. WARP, whose name is subscribed to the foregoing writing of Deed of Conveyance, bearing date the 22nd day of January, 1992, has this day before me in my said County and State, duly aoknowledged said writing to be his act and deed. QIVEN under my hand this 9 day of February, 5992. I further certify that my Commission as Notary Public will expire on the >? STATE OF WEST VIRGINIA, T0-w , a Notary Public within and* for the County and state aforesaid, do hereby certify that R. WARD. whose name is subscribed to the foregoing writing of Deed of Conveyance, bearing date the 22nd day of January, 1992, has this day before me in my said County and State, duly acknowledged said writing to be her act and deed.
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