Motion for Preliminary Injunction in ONCOR ELECTRIC DELIVERY COMPANY LLC vs KEVIN LEWIS

On February 22, 2022 a PLTF'S ORIG PET & APPL/TRO & INJ RELIEF was filed involving a dispute between and for OTHER CIVIL, OTHER in the District Court of Tarrant County.

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FILED
TARRANT COUNTY
2/22/2022 4:03 PM
348-332099-22 THOMAS A. WILDER
CAUSE NO. _______________________ DISTRICT CLERK

ONCOR ELECTRIC DELIVERY § IN THE DISTRICT COURT
COMPANY LLC §
§
Plaintiff, §
§
vs. § TARRANT COUNTY, TEXAS
§
KEVIN LEWIS §
§
§
Defendant. § _____ JUDICIAL DISTRICT

PLAINTIFF’S ORIGINAL PETITION AND APPLICATION
FOR TEMPORARY RESTRAINING ORDER AND INJUNCTIVE RELIEF

TO THE HONORABLE COURT:

Plaintiff Oncor Electric Delivery Company LLC files this Original Petition complaining

of Defendant Kevin Lewis as follows:

DISCOVERY LEVEL
1. This is an action for a mandatory injunction to enjoin interference with a utility,

pursuant to Section 186.005 of the Texas Utility Code, and Plaintiff requests that discovery be

conducted under Level 2 pursuant to Rule 190 of the Texas Rules of Civil Procedure.

PARTIES
2. Plaintiff Oncor Electric Delivery Company LLC (“Oncor”) is a Delaware limited

liability company engaged in the transmission and distribution of electrical service to individuals

and the public generally, public bodies and instrumentalities of state, local and federal

government, for light, heat, power and other purposes, and in the conduct of said business has

constructed, maintained and operates a system of transmission and distribution lines for electric

service throughout the State of Texas, including Tarrant County. Oncor maintains its corporate

offices in Dallas County, Texas, with legal and transmission operations based in Tarrant County.

Oncor v. Lewis: Plaintiff’s Original Petition and Application for TRO– Page 1
3. Defendant Kevin Lewis (“Mr. Lewis”) is an individual resident of the State of

Texas. Mr. Lewis is the owner and/or care-taker of real property located 400 Lynda Lane

Arlington, TX 76010 (the “Lynda Lane Property”). Defendant may be served with citation at his

residence located at 400 Lynda Lane Arlington, TX 76010 and contacted by phone at 303-250-

1146.

VENUE AND JURISDICTION

4. Venue is proper under 15.002(a)(1) and (2) of the Texas Civil Practices &

Remedies Code in that the events complained of occurred in Tarrant County and that Lewis

resides in Tarrant County, Texas. Additionally, venue is mandatory in Tarrant County, Texas as

that is the domicile of Lewis. See TEX. CIV. PRAC. & REM CODE § 65.023. Finally, venue is also

proper pursuant to Section 186.005(d) of the Texas Utilities Code, as Tarrant County is the

location of the violation or threatened violation of the Texas Utilities Code.

5. This court has jurisdiction over the subject matter of this case as it seeks damages

and injunctive relief within the jurisdictional limits of the court.

6. All parties are residents of the State of Texas and this action seeks recovery solely

under the laws of the State of Texas; therefore, this case is not removable to federal court.

FACTUAL BACKGROUND

7. Oncor owns and maintains electrical transmission lines throughout the State of

Texas, including Tarrant County. One such distribution line, known as the Arlington (ARLNG)

1213 Feeder (The Feeder) passes through the Lynda Lane Property and transmits high voltage

current. This feeder directly provides power to 1,338 homes and businesses in Tarrant County

and serves as an integral part of the ERCOT grid that provides electrical delivery to millions of

Texans. Oncor’s customers served by the Feeder include three critical care customers (generally

individuals dependent on life support equipment) and four essential business customers.

Oncor v. Lewis: Plaintiff’s Original Petition and Application for TRO– Page 2
8. At this time, there is a post-oak

tree with a trunk and tree branches within six

feet of the high voltage primary, as shown in the

photograph to the left. In Oncor’s judgment this

vegetation constitutes a possible interference or

hazard to the operation of Oncor’s power lines,

which in turn hampers Oncor’s ability to

maintain continuous and adequate electric

service which in turn endangers the safety and

health of the public should an interruption of

electric service occur. For instance, the trees

could cause damage to the power lines, possibly causing a power outage which could affect

many customers. In the event of a line failure, the tree could prevent the line from obtaining an

adequate ground to operate fault protection equipment, resulting in a fire or serious injury or

death due to a 7.2 kV line remaining energized. Moreover, the trees are particularly hazardous in

this instance due to the fact that the power lines carry 7.2 kV (kilovolts) of current and are not

insulated. The trees’ interference with the open wire power lines could jeopardize the safety of

the public and surrounding property through the danger of exposure to live wires, including the

risk of electric shock or fire.

9. Accordingly, the trees interfere with Oncor’s existing rights and create a danger to

the public and the power lines. Some of these dangers are outlined in Allen L. Clapp's Practical

Utility Safety, which is one of the leading treatises on the electric utility industry and is relied

Oncor v. Lewis: Plaintiff’s Original Petition and Application for TRO– Page 3
upon by Oncor in certain regards in formulating its vegetation management programs. Clapp

details three basic safety issues related to tree trimming requirements:

(1) keeping trees far enough away from energized conductors so that the
conductors will not be burned down by an arcing contact (NESC Rule
218);

(2) keeping trees far enough away from energized conductors that children
climbing in trees cannot reach the conductors or swing the tree into the
conductors (NESC Rule 012 and Good Industry Practice); and

(3) trimming the trees far enough back that, after the plant growth between
trimming cycles, the trees will still be far enough away to allow safe
trimming and removal of the sucker growth (ANSI Z133.1). Id.

Practical Utility Safety, at p. 230. The author continues on to concisely express the safety issues

that arise with trees that contact power lines, stating:

[W]hen trees contact energized power conductors, current flows from the line
through the tree to the ground, energizing the ground around the tree. Because this
contact is not solid, an arc occurs between the line and the tree. The heat from the
arc can, if sustained long enough, damage the conductor enough that it will break
under its own tension, either at that time or later when the wind forces or weight
of ice increases the tension beyond its damaged structural capacity. During the
time of the current flow, persons in contact with the tree may be shocked, burned
or killed if a good contact with the tree limb is made.

Id. at p. 230. Clapp’s book explains that trees contacting power lines can result in adverse

reactions ranging from momentary flickering of the power voltage level to power outages. Id. at

232. Trees may cause the line to be severed, making it possible that a person may contact an

energized conductor when it is lying on the ground. Id. at 232. Trees in close proximity to power

lines additionally allow squirrels to jump to the poles or conductors. Id. This becomes a problem

when the squirrel’s tail comes in contact with something else, resulting in a short out of the line,

thus increasing the outage rate. Id. Further, “several people have been hit by flaming squirrels

that contacted energized power facilities and fell into an area where people were underneath the

line.” Id. In sum, Clapp concludes, improperly trimmed trees around power lines can cause a

Oncor v. Lewis: Plaintiff’s Original Petition and Application for TRO– Page 4
wide range of problems. Significant damage or injury can result both directly or indirectly from

power lines. Id. at 232. For example, power lines can be dropped on cars, or an accident may

occur at an intersection where lights failed to work due to power outages. Id. As explained in

Practical Utility Safety, trimming trees around power lines is essential to the protection of

individuals and property, and the maintenance of electrical service. True and correct copies of

the relevant excerpts from Clapp’s treatise are attached hereto as Exhibit A.

10. Additionally, when faced with a customer’s refusal to allow pruning of trees or

other vegetation, such as that done by Lewis in this case, Oncor’s representatives will generally

provide a package of material to inform the customer of the respective rights of the parties. A

true and correct copy of that document in attached hereto as Exhibit B. Mr. Lewis refused to

accept the package when it was presented to him. That package includes the entire text of

Section 186 of the Texas Utility Code, so that customers will be aware that Oncor is entitled to a

mandatory injunction against those that interfere with the maintenance of power lines. See . TEX.

UTIL. CODE 186.005.

11. Over the last several years, there have been a number of outages on the Feeder.

Over the last five years, there have been 221 tree-related outages. In order to limit such outages

as part of its ongoing maintenance program, Oncor began the pruning of vegetation and trees

along the entire Feeder in response to these outages back in 2019, which constitutes the normal

course of business and the proper status quo that the court should maintain in this action. During

the work in 2019, itwas discovered that a rotten pole in a creek behind that property, which

required replacement. That remedial work was completed and vegetation management was

rescheduled.

Oncor v. Lewis: Plaintiff’s Original Petition and Application for TRO– Page 5
12. On February 16, 2022, Oncor arborist Lynette Dunn (“Dunn”) and Wright Tree

Service foreman Jorge Huerta (“Huerta”) and his crews arrived at 400 Lynda Lane to trim the

post-oak at the back of the property. Dunn knocked on the door this morning and no one

answered. The crews and Dunn made their way to the back of the property, which was open as

there was no gate or fence. Lewis then came outside before anyone could climb up the oak and

begin work. He asked the Oncor personnel what they were planning to do. Dunn and Huerta

explained to him the work needing to be done and why. Lewis refused, claiming the oak had

been there for years, and he did not want Oncor to trim anything. He claimed that Oncor already

cut down too many trees over the years and there were stumps less than four feet from the closest

conductor. Lewis then pulled out his phone and started recording everyone saying, “for the

video, I am formally protesting this tree being cut down and I want everyone off my property.”

Dunn explained that once the trimming was completed, the Oncor crews would leave his

property. He kept recording and repeating himself about wanting everyone to leave. When a

crew member started to put his tree climbing gear on, Lewis went into the garage and came back

out with a rake. He hastily walked between the crew members and stood between them and the

tree and said he wouldn’t allow any trimming, blocking the work area.

13. Dunn called 9-1-1 and four Arlington Police Officers arrived shortly thereafter.

The officers spoke with Dunn and Huerta, who explained why Oncor was there, the work that

needed to be done and that it was a safety concern. The officers then spoke to Lewis and his

sister, who had recently arrived. The officers then came back over to talk to Huerta and Dunn,

informing them that the dispute was a civil matter. Dunn explained the safety concern and asked

to speak to a supervisor. Sgt. Mike Skarbek arrived on scene, and in the end, told Dunn the same

thing his officers did; that this is a civil matter and that Oncor would need to leave and go the

Oncor v. Lewis: Plaintiff’s Original Petition and Application for TRO– Page 6
legal route to return with a court order. Before everyone left, Sgt. Skarbek talked to Dunn, Lewis

and his sister and explained to them that this matter was not over; that we would be back at a

later date and that Oncor was going to go the legal route with this case.

14. On February 17, 2022, Oncor Customer Representative Holly Raeder reached out

to Lewis to discuss a resolution, but Lewis said he was very upset about losing another tree. He

said if no legal order was filed or presented to him, he would do everything in his power to stand

between the tree and our chainsaws.

15. In order to prevent Lewis’ efforts to thwart the reliable delivery of electrical

service in accordance with the express terms of the easement and applicable law, Oncor now

seeks this injunctive relief. Lewis’ conduct constitutes an unlawful interference with Oncor’s

maintenance of its utility lines and places others at great risk for serious property damages,

bodily injury or even death. Lewis’ conduct is inexcusable and unlawful.

CAUSES OF ACTION

16. Unlawful Interference with Public Utility. It is the policy of the State of Texas

that continuous service by a public utility is essential to the life, health, and safety of the public.

TEX. UTIL. CODE § 186.002(a). The primary duty of a public utility is to maintain continuous and

adequate service at all times to protect the safety and health of the public against the danger

inherent in the interruption of service. TEX. UTIL. CODE. § 186.002(b). The Texas Utilities Code

mandates that every court of this state shall recognize this policy. TEX. UTIL. CODE § 186.002(c).

Oncor is a public utility, and the Texas Utilities code prohibits any person from engaging in the

following acts:

(1) intimidate, threaten, or harass an employee of a public utility with intent to
disrupt the service of the utility or prevent the maintenance of that service;
or

Oncor v. Lewis: Plaintiff’s Original Petition and Application for TRO– Page 7
(2) intimate, threaten, or harass an employee of a public utility if that conduct
has the effect of disrupting the service of the utility or preventing the
maintenance of that service.

TEX. UTIL. CODE § 186.004(b). Lewis violated the Texas Utilities Code and other laws protecting

the reliability and integrity of electrical service 1 because his actions prevent Oncor from

maintaining its power lines and because his actions have the effect of disrupting electrical

service. The Utilities Code further provides that “[i]f it appears that there is a violation or

threatened violation of § 186.004 the Court shall immediately issue an order restraining the

person, the person’s agent, and any other person acting with them from committing an act

prohibited by that section.” TEX. UTIL. CODE § 186.005 (emphasis added). The Utilities Code

mandates that Lewis’s conduct be enjoined. Thus, the requested temporary restraining order in

mandatory and bond must be set at only such an amount as to cover anticipated court costs,

which should be some amount less than $500. 2 Oncor is willing and able to post bond in the

amount set by the court.

17. Violation of Texas Utility Code. Electric corporations are given the authority to

construct, maintain, and operate power plants and substations and any machinery, apparatus,

1
The law recognizes that high voltage lines present an open and obvious danger when objects are brought into contact
with them Nance Exploration Co. v. Texas Employers Ins. Ass'n, 305 S.W.2d 621, 626 (Tex.Civ.App. – El Paso 1957, writ ref’d
n.r.e.). Thus bringing object in contact with lines or interfering with their maintenance can give rise to criminal penalties. TEX.
CIV. STAT. § 1446(a) (stating in relevant part “[a]ny person
who shall willfully . . . .interferes
with . . . . any machinery,
equipment, or facilities of any such utility . . . for the purpose of preventing the maintenance of such service, shall be guilty of a
felony. . .”).
Additionally, the law prohibits persons from conducting any activity that may bring material within six (6) feet of
high voltage power lines. TEX. HEALTH & SAF. CODE § 752.004. Vegetation, such as tree branches, is a material that one may not
bring or attempt to bring into contact with high voltage wires. See Chavez v. City of San Antonio ex rel. City Public Service Bd. of
San Antonio, 21 S.W.3d 435, 439-440 (Tex.App.-San Antonio 2000, pet. denied). Violation of Section 752 is a crime punishable
by a fine of $100 to $1000 and confinement of up to one year in jail. TEX. HEALTH & SAF. CODE § 752.007.

2
Bond amounts set for similar cases involving Oncor’s distribution lines at residences have been in these amounts. See
Oncor Electric Delivery Company LLC v. Donald Tidwell and Janet Tidwell, Cause No. 017-237166-09, Tarrant County (April
17, 2009, J. Wilkinson) (setting bond at $500.00); Oncor Electric Delivery Company LLC v. Mark A. Sweazey, Cause No. 067-
239733-09, Tarrant County (August 27, 2009, J. Cosby) (setting bond at $500.00); Oncor Electric Delivery Company LLC v.
Dickie and Michelle Musselman, Cause No. 09-10766, Dallas County (August 29, 2009, J. Snelson) (setting bond at $100.00);
Oncor Electric Delivery Company LLC v. Leslie “Les” Martin, Cause No. CV-10-0458, Grayson County (March 16, 2010, J.
Fallon) (setting bond at $100.00); Oncor Electric Delivery Company LLC v. John Bieber and Jes Jomell LLC, Cause No. 94097-
422, Kaufmann County (November 4, 2015, J. Chitty) (setting bond at $500.00), Oncor Electric Delivery Company LLC v. James
and LaDorthy Webb, Cause No. 16-01598, Dallas County (February 15, 2016, J. Hoffman) (setting bond at $500.00),

Oncor v. Lewis: Plaintiff’s Original Petition and Application for TRO– Page 8
pipe, pole, wire, device, or arrangements as necessary to operate its lines in this state. TEX. UTIL.

CODE § 181.008(b)(2). The Texas Utilities Code provides that a municipal electric utility (or,

with regard to clearances, an electric utility that is not a municipal electric utility) shall construct,

operate, and maintain its lines for the transmission and distribution of electric energy along

highways and other places in accordance with the National Electric Safety Code (“NESC”). TEX.

UTIL. CODE § 181.045(a). The NESC provision addressing tree trimming states, “trees that may

interfere with ungrounded supply conductors should be trimmed or removed.” NESC § 218A. A

note follows, stating “normal tree growth, the combined movement of trees and conductors under

adverse weather conditions, voltage, and sagging of conductors at elevated temperatures are

among the factors to be considered in determining the extent of trimming required.” In

accordance with the Texas Utility Code and the NESC, Oncor seeks to maintain a safe clearance

distance of at least ten feet (10’) when pruning trees. 3 Lewis’ interference with Oncor’s lawful

trimming along its conductors is in contravention of the Texas Utility Code.

18. Breach of Tariff for Retail Delivery: The Public Utility Regulatory Act (“PURA”)

requires each utility to file a tariff with the Public Utility Commission. TEX. UTIL. CODE

§32.101; Houston Lighting & Power v. Auchan, U.S.A., 995 S.W.2d 668, 671 (Tex. 1998). A

filed tariff governs a utility’s relationship with its customers and has the force and effect of law.

Southwest Electric Power Co. v. Grant, 73 S.W.3d 211, 222 (Tex. 2002); Auchan, 995 S.W.2d at

671. “[A] customer is ‘conclusively presumed’ to know the contents and the effect of the tariff,

3 Oncor’s general rule of ten foot minimum clearance addresses several key concerns for reliability and worker safety.

First, federal regulations such as OSHA require that utility workers maintain a minimum distance of two feet, four inches (or
more) from high voltage lines. See 29 C.F.R. 1910.269. In addition, adequate clearance is required for utility workers to safely
operate and maintain our high voltage lines and equipment without the encumbrances of vegetation. Second, the National Electric
Safety Code and other experts suggest that an allowance of no less than two feet for sway in the lines and trees during storms. See
NESC Rule 233 Finally, in order to provide cost effective service and avoid frequent entries on customers’ properties for regular
pruning, Oncor attempts to prune trees no more than every several years. Based on average tree growth, Oncor plans for a foot
and a half of growth per year. These combined considerations are the basis for the minimum clearance sought herein. This also
ensures thatunqualifiedpersons are not working on materialswithin ten feetof high voltage linesin violationof federal
standards, see 29 C.F.R. 1910.333(c)(3)(i)(A) or potentially in violation of Texas law. TEX. HEALTH & SAF. CODE § 752.004.

Oncor v. Lewis: Plaintiff’s Original Petition and Application for TRO– Page 9
and neither the customer’s ignorance nor the carrier’s misquotation of the applicable tariff alters

the tariff’s terms.” Kanuco Technology Corp. v. Worldcom Network Services, Inc., 979 S.W.2d

368, 374 (Tex.App. – Houston [14 Dist.] 1998, no pet.). Oncor’s Tariff for Retail Delivery

Service (“Tariff”) gives Oncor the right of ingress and egress and to trim and remove trees on

Oncor’s property. Specifically, section 5.4.8 of Oncor’s Tariff, entitled “Access to Retail

Customer’s Premises,” gives Oncor or its duly authorized representatives the right of access to a

Retail Customer’s Premises at all reasonable hours, to perform activities necessary to provide

electrical services, including tree trimming and tree removal where such trees in the Oncor’s

opinion constitute a hazard to personnel, facilities, or to the provision of continuous electrical

service. Accordingly, Oncor has the right to enter Lewis’ property to trim and remove trees.

Lewis’ attempt to thwart Oncor’s lawful access to remove hazardous trees and/or vegetation

contravenes his own obligations under the Tariff, which he has, as a matter of law, contractually

agreed to accept in return for being provided electrical service. Having accepted the benefits of

the Tariff, in receiving regulated and controlled rates, Lewis cannot now disregard the Tariff and

seek to selectively opt out from its provision. Oncor requests that the Court issue a declaratory

judgment pursuant to 37.001 et seq. of the Texas Civil Practices & Remedies Code, declaring

that Oncor has the right to trim the vegetation in proximity to the power lines on the property in

question. Oncor further seeks the award of reasonable and necessary expenses and attorneys’

fees as are equitable and just as provided by Section 37.009 of the Texas Civil Practices &

Remedies Code. Oncor also requests all recoverable consequential and incidental damages

arising from Lewis’ breach of the Tariff.

Oncor v. Lewis: Plaintiff’s Original Petition and Application for TRO– Page 10
REQUEST FOR TEMPORARY AND PERMANENT INJUNCTIVE RELIEF

19. Oncor has no adequate remedy at law or otherwise for the harm or damage done

or threatened to be done by Lewis because the potential damages to Oncor or third parties

attributable to Lewis’ conduct cannot be calculated and because absent injunctive relief, Lewis

will continue to deny Oncor access to its power lines, and continue to threaten the safety of

individuals, and real and personal property. Oncor will suffer irreparable harm, damage, and

injury unless the acts and conduct of Lewis is enjoined because such acts deny Oncor access to

its conductors, and Lewis’ conduct jeopardizes the safety and welfare of all individuals who live

in Tarrant County, including himself and his neighbors, and threatens damage to surrounding

personal and real property. As such, the harm, damage and injury with which Oncor and the

public are threatened are of a nature that cannot be adequately compensated in damages.

20. For the foregoing reasons, Oncor requests that the Court grant ex parte relief

including a temporary restraining order and, after final trial, permanently enjoin Lewis, his

spouse, family, agents, servants, and employees, from directly or indirectly:

a. Prohibiting Oncor, Oncor’s agents, employees, and/or contractors from accessing

its high voltage lines, conductors and equipment over the Lynda Lane Property.

b. From prohibiting Oncor, Oncor’s agents, employees, and/or contractors from

removing trees and other vegetation, on or upon Oncor’s easement for

transmission lines over the Lynda Lane Property.

c. From threatening Oncor’s agents, employees, and/or contractors by any means,

d. Causing bodily injury to any Oncor agent, employee, and/or contractor.

e. Going into the work area incident to trimming the trees, which shall be no greater

than within fifteen (15) yards of Oncor’s agents, employees, and/or contractors,

Oncor v. Lewis: Plaintiff’s Original Petition and Application for TRO– Page 11
while they are on the Lynda Lane Property in order to remove trees and other

vegetation from the right-of-way.

f. Displaying, handling or otherwise having on his person firearms or other weapons

while Oncor’s agents, employees and/or contractors are present trimming

vegetation or otherwise maintaining the power lines at the Lynda Lane Property.

g. Attempting to trim the trees himself until after such time as Oncor has achieved a

clearance of ten feet or greater to make it safe for him to perform such work.

PRAYER

WHEREFORE, Oncor respectfully prays that Lewis be cited to appear and answer

herein, and that upon hearing or final trial hereon:

1. The Court issues a temporary restraining order, temporary injunction and
permanent injunction, enjoining Lewis from:

a. Prohibiting Oncor, Oncor’s agents, employees, and/or contractors from
accessing its high voltage lines, conductors and equipment over the Lynda
Lane Property.

b. From prohibiting Oncor, Oncor’s agents, employees, and/or contractors
from removing trees and other vegetation, on or upon Oncor’s easement
for transmission lines over the Lynda Lane Property.

c. From threatening Oncor’s agents, employees, and/or contractors by any
means,

d. Causing bodily injury to any Oncor agent, employee, and/or contractor.

e. Going into the work area incident to trimming the trees, which shall be no
greater than within fifteen (15) yards of Oncor’s agents, employees, and/or
contractors, while they are on the Lynda Lane Property in order to remove
trees and other vegetation from the right-of-way.

f. Displaying, handling or otherwise having on his person firearms or other
weapons while Oncor’s agents, employees and/or contractors are present
trimming vegetation or otherwise maintaining the power lines at the Lynda
Lane Property.

Oncor v. Lewis: Plaintiff’s Original Petition and Application for TRO– Page 12
g. Attempting to trim the trees himself until after such time as Oncor has
achieved a clearance of ten feet or greater to make it safe for him to
perform such work.

2. Alternatively, the Court enter a declaratory judgment declaring that Oncor has the
right to trim the trees and vegetation at least ten feet (10’) from the power lines at
issue;

3. Oncor has and recovers from Lewis its recoverable consequential and incidental
damages arising from Lewis’ breach of the Tariff;

4. Oncor has and recovers from Lewis its attorneys’ fees, costs and expenses;

5. Oncor have and recover from Lewis pre- and post-judgment interest; and

6. Oncor has such other and further relief to which it may be justly entitled.

Respectfully submitted,

By: __/s/ Daniel G. Altman_______________
Daniel G. Altman
Texas Bar No. 00793255

Oncor Electric Delivery Company LLC
777 Main Street, Suite 747
P.O. Box 970
Fort Worth, Texas 76101-0970
(817) 215-5534 (telephone)
(817) 215-6360 (facsimile)
daniel.altman@oncor.com

ATTORNEY FOR PLAINTIFF ONCOR
ELECTRIC DELIVERY COMPANY LLC

Oncor v. Lewis: Plaintiff’s Original Petition and Application for TRO– Page 13
Certificate of Compliance with Local Rules

Pursuant to Tarrant County Local Rule 3.30, I certify that to the best of my knowledge the party,
to wit Matthew Lewis, against whom relief is sought ex parte is not represented by counsel in the
matter made the basis of the relief sought. Furthermore, two hours prior to filing this action, I
reached out to Mr. Lewis at 303-250-1146 and informed him of Oncor’s intent to file same and
offered to email a copy of the Petition and inform him of the court to which the case was
assigned upon filing, if he wished to be heard.

/s/ Daniel G. Altman
Daniel. G. Altman

Oncor v. Lewis: Plaintiff’s Original Petition and Application for TRO– Page 14

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