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Petition Model

The letter presents a request for reconsideration in substitution of an appeal before the Superintendent of Residential Public Services against a decision by Electricaribe. The petitioner argues that Electricaribe did not adequately respond to several of her requests related to charges on her electricity bill and financing associated with the debt of a previous tenant. She requests that only the first two months of arrears be billed and that the break of solidarity be recognized. She states that the resp
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0% found this document useful (0 votes)
7 views12 pages

Petition Model

The letter presents a request for reconsideration in substitution of an appeal before the Superintendent of Residential Public Services against a decision by Electricaribe. The petitioner argues that Electricaribe did not adequately respond to several of her requests related to charges on her electricity bill and financing associated with the debt of a previous tenant. She requests that only the first two months of arrears be billed and that the break of solidarity be recognized. She states that the resp
Copyright
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We take content rights seriously. If you suspect this is your content, claim it here.
Available Formats
Download as PDF, TXT or read online on Scribd
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Bucaramanga, April 4, 2019

Gentlemen
ELECTRICARIBE S.A. ESP
16th Street No. 8 - 37
Valledupar

Subject: RECOURSE FOR RECONSIDERATION IN SUBSIDY APPEAL BEFORE THE


SUPERINTENDENCE OF DOMESTIC PUBLIC SERVICES
AGAINST THE DECISION FILED WITH THE SEQUENTIAL NO.
6250998 DEL APRIL 1, 2019 ISSUED BY ELECTRICARIBE
IN RESPONSE TO THE PETITION RIGHT FILED WITH No.
RE3110201910288. NIC 5305328.

MARY BUITRAGO SOLANO, an adult identified with citizenship ID No.


28,294,803 from Piedecuesta, owner of the property identified by the address Calle 22
A No. 18 E - 35 located in the Primero de Mayo neighborhood of the city of Valledupar, presented
REAPPLICATION FOR SUBSIDY APPEAL BEFORE THE
SUPERINTENDENCE OF PUBLIC SERVICES, AGAINST THE
DECISION RENDERED WITH CONSECUTIVE NO. 6250998 OF APRIL 1
FROM 2019 ISSUED BY ELECTRICARIBE IN RESPONSE TO THE RIGHT OF
REQUEST FILED WITH No. RE3110201910288.

I base the appeal for reconsideration as a subsidiary of the appeal on the following considerations:

CONSIDERATIONS

I disagree with the decision made by the company ELECTRICARIBE.


April 1, 2019, filed with the consecutive number 6250998, in response to
it states that the certificate of Freedom and Tradition provided in the petition is more than 90
days of issuance, without taking into account that on March 20, 2019, via email
electronicservicioalcliente@electricaribe.coI provided the Certificate of Freedom and Tradition of
property subject to the present claim, issued on March 20, 2019,
this in response to the request made to me by ELECTRICARIBE through the official communication
filed with consecutive No. 6238231 on March 13, 2019 via email
electronicservicioalcliente@electricaribe.coCertificate that I also sent by email
certificate (Servientrega) on March 30, 2019; with this evidence presented
It proves that I am indeed the owner of the property and therefore it is demonstrated.
the existence of the joint obligors and how this requirement is met as well as the
from the lack of service suspension to the second overdue payment period and the inefficiency
action by Electricaribe for not carrying out the effective suspension, which allowed the
unauthorized reconnection of the user and the consequent increase in debt, due to such
Reasons for meeting the requirements, the breakdown of solidarity was configured from the
second period of payment default for invoice NIC 5305328 of the tenant of the property
Consequently, I have the right to be charged only for the first two invoices.
payment default of the tenant and that Electricaribe acknowledges the breaking of solidarity.

I also disagree with the decision made by the company.


ELECTRICARIBE on April 1, 2019, filed with consecutive number 6250998,
Given that the response is not clear, consistent or substantive with what was requested in my
request, thus allowing this action by Electricaribe to establish silence
positive administrative and as a consequence of this, they should be granted in my favor the
legally valid claims, and since the breaking of solidarity
alleged meets the factual and legal requirements, for this reason Electricaribe must
immediately access my claims.

The positive administrative silence was generated in 14 responses given to my 21 requests.


I will now proceed to explain the reasons for its occurrence.

In the second request, I asked for the charges being made to be removed.
concept of pending financing and debts that the tenant has incurred in the
time I spent in the property, and not being charged again. Receiving as
Electricaribe's response that "this is how we indicate to you that you can approach a "}
from our commercial offices or contact our call center (line 115) and request
either the cancellation of the existing agreements or the refinancing of the payment agreement,
provide a substantial answer to what was requested, avoiding informing whether the values that are being withdrawn.
charging for financing and other debts.

In the third request, I ask to be informed how many financings have been made in the
electric power service identified with NIC No. 5305328, who requested each one
of them, the concepts they correspond to, the date and the values, receiving as a response
from the Company that 'the property has two balances for pending payment financed invoices'
The company does not specify or respond to who requested each of the financings,
concepts to which they correspond, dates or values.

In the fifth request, I asked you to inform me how many power service suspensions there are.
Electrical work has been carried out in the property identified by the address Calle 22 A No. 18 E -
35 located in the Primero de Mayo neighborhood of the city of Valledupar, the date on which it
they carried out, and the reason for its execution, receiving incomplete feedback since the company
Electricaribe states that "it has made the respective service suspensions leaving
recorded in the suspension minutes; it is necessary to inform you that at the moment of the
execution of service orders, our technicians provide a copy of them in
the moment of the visit, which is why they must rest in the user's possession, and also
these are sent to an inactive company file. Therefore, it is not appropriate to
delivery of the minutes", the company with this response evades the request, the fact that the
The tenant received a copy of the suspension minutes is not an excuse for this moment.
As the owner of the property, that information is not provided to me, considering others.
it is logical that at that moment it was the tenant who received a copy of the minutes, and for
for this reason I am unaware of its existence.

In the sixth claim, I requested a report in a detailed, thorough manner with its
respective generation date of each of the concepts that are part of the amount of $
3,297,048 identified in invoice No. 5305328 corresponding to the energy service
electricity of the property identified by the address Calle 22 A No. 18 E – 35 located in the
First of May neighborhood of the city of Valledupar as 'AMOUNT OF'
PENDING FINANCINGS," receiving a response from the Company that "in the
The considerations of this document detailed the outstanding balance of financings.
corresponding to energy invoices. We attach the account statement for greater clarity
the company does not provide the information in the way I requested, as the account statement
attached does not detail the concepts that are part of said financing amount
pending. And the consideration part does not detail the information as requested.

In the seventh request, I requested a report in a detailed manner, with its


respective generation date of each of the concepts that are part of the amount of $
263.670 identified in invoice No. 5305328 corresponding to the energy service
electricity of the property identified with the address Calle 22 A No. 18 E – 35 located in the
First of May neighborhood of the city of Valledupar as 'BILL AMOUNT'
OVERDUE,” receiving in response from the Company that “we indicate that the balance for
The value of $263,670 corresponds to the invoices from July 2018 to December 2018.
We attach the account statement for greater clarity. The company attaches an account statement.
but there it is not answered in detail with its respective generation date for each one
of the concepts that are part of the amount. In addition, the information presented in the statement
the account statement is not clear enough, and the total amount owed according to the account statement
the amount that the company attaches in response to my right of petition does not match the amount of
overdue invoices $263,670.

In the eighth request, I asked them to inform me what concepts the current debt corresponds to.
and total of the property identified with the address Calle 22 A No. 18 E - 35 located in the
First of May neighborhood of the city of Valledupar, identified with the NIC 5305328
indicating in a detailed manner, with their respective generation date each
one of the concepts, receiving as a response from the Company that 'in the part
we provided clarity on the financed balance in this document. We indicate that the
The balance of $263,670 corresponds to the invoices from July 2018 to December.
from 2018. We attach the account statement for greater clarity" This response does not address my
claim because I was not informed of each of the concepts to which the debt corresponds
current and total, the information presented by the company is evasive, ambiguous, the annex does not provide
the requested information.

In the ninth request, I asked that in accordance with Law 142 of 1994, an invoice be generated.
for the concepts that are not subject to claim, that is to say for the consumptions generated in
the first two months in default, and therefore withdrawing the financed amounts such as the
other concepts billed after the first two months in arrears, receiving
as a response from the Company to cancel the first solidarity invoice
corresponding to the month of July 2018 for the amount of $9.990 I can approach our
commercial office and request the information and the flyer to accredit the respective
payments. The company evades my request with this response as it did not generate the invoice for the
the first two months in payment arrears (Concepts that are not subject to claim), all
since the invoice to which the Company refers in its response to my first request
(the solidarity invoice corresponding to the month of July 2018 for the amount of $9,990)
corresponds to the first installment of one of the financing options (value that is the subject of
complaint) which does not address my request as I am asking for the
generation of the invoice for the first two months in arrears of payment (since this value
It is not subject to claim) and I am not requesting the first invoice of the fee that
it is part of the debt financing, since this amount is part of the total
(s) that is the subject of the claim and consequently I do not agree with this
decision since it does not correspond to what was requested in my initial petition. The company has
the obligation to generate the invoice for the amounts that are not subject to claim,
as stated in law 142 of 1994, I hereby reiterate the request and REQUEST that
that invoice with the concepts that are truly not subject to claim, is
issued and attached to the response of this resource, to proceed with the payment
respective. Additionally, considering that I reside in the city of Bucaramanga, I do not have
with the resources to move to the company's commercial offices
Electricaribe in the city of Valledupar, for this reason I base this request on the
principle of procedural economy.

In the tenth request, I asked to be informed why the company ELECTRICARIBE S.A.
ESP being obligated to suspend the service at the second billing period in
he didn't, and because he continued providing the service, receiving in response that
As previously indicated, the company did suspend the service as evidenced.
in the graphs of the consideration part,” response in which no date is evidenced in the
that each suspension was carried out, an effective suspension of the service is not carried out either because
the user continues to consume electricity, thus increasing the debt month by month. No
Evidence of the suspension of the service is provided, and how the user continued consuming.
monthly energy, this allowed the debt to rise without the company doing the
suspension of service.

In the eleventh request, I ask you to inform me why the company ELECTRICARIBE S.A.
Even being obligated to suspend the service at the second billing period in
Mora continued to provide the service without taking the actions established in Law 142 of 1994.
and the contract of uniform conditions to avoid new consumption and the increase of
the debt, receiving the response that 'as previously indicated to you, the company yes
suspended the service as evidenced in the graphs of the considerative part," without
Respond to my request thoroughly and clearly, as the company Electricaribe does not present.
tests of the suspensions in which the date of them is evident, does not respond because
if there was a suspension, the user remained with electricity consumption, increasing
increasingly more debt.
In the twelfth claim, I requested information on why the company ELECTRICARIBE
S.A. ESP being obliged not to finance the debt to the
tenants, without my consent as the owner, granted to the tenant
debt financing which allowed it to increase every month, receiving as
Electricaribe made the financing to benefit you in the payment of the
invoices taking into account the debt that the property had,” without providing a clear response and
in support of my request.

In the fourteenth request, I requested a copy of the history of suspensions, receiving as


In response to the request for copies of the suspension minutes, it is appropriate to inform you
that at the time of executing the service orders, our technicians provide
copies of them at the time of the visit, which is why these must rest in
user power, and they are also sent to an inactive file of the company. Therefore
the delivery of minutes is not appropriate,” leaving my request unresolved as I do not possess the
copies of such minutes since the property was leased as mentioned
previously.

In the fifteenth request, I requested a copy of the payment history, receiving as


response that "due to the property having an incorporation date of December 31
from 2000, you should indicate which months it refers to in relation to the payment history.
leaving my request unanswered.

In the seventeenth request, I asked to be informed which person(s) made the request. the
debt financing, for what concepts it was made and on what date it was done, and what
documents were requested and which documents were actually presented,
receiving as a response that 'the balance was financed directly by the Company, for
"which makes the request made inappropriate," so my request is not answered either.
effectively resolved. The company does not prove the existence of the contract(s), does not respond to
each of the requirements of the request.

In the nineteenth request, I asked the Company to inform me if the facts


mentioned in the petition filed were true or not and why, receiving as
response that "there is indeed an outstanding balance due and nevertheless the company yes
proceeded with the service suspension as previously indicated,
The company does not respond clearly and substantively to the request.

Reasons for disagreement with the response

Regarding the claims made, I disagree with the response.


given by Electricaribe in response to the following.

In the first request, I asked that ELECTRICARIBE S.A. ESP recognize the breach.
of solidarity between landlord and tenant of the property identified by the address
22A Street No. 18 E – 35 located in the Primero de Mayo neighborhood of the city of Valledupar
since the second period of default on the payment of the service and consequently withdraw from the
invoice the charges generated after the second month in arrears and do not return to
charge. Receiving a response that 'The Company does not proceed to declare the breach of
solidarity due to debt generated by the non-payment of the service provision
energy in the property, for all the details mentioned above. To cancel the first
solidarity invoice for the month of July 2018 for the amount of $9,990 can
approach our commercial offices and request the information and the payment slip
to credit the respective payments. I express my dissatisfaction as...
As mentioned earlier, the necessary evidence was presented for ELECTRICARIBE.
declare the breaking of solidarity between the property owner and the tenant
of the property meeting my demands. However, ELECTRICARIBE did not have in
counts the evidence presented in the process by making an incorrect assessment of them;
I have also proven that the Company must accept the breaking of solidarity as long as
The evidence is overwhelming and leaves no doubt about the existence of a breakdown in solidarity.

Furthermore, the company, with its actions, violates the fundamental right to due process since
that makes a factual default error by making an incorrect assessment of the evidence and
Despite having the right as indicated by the law, I did not remove the values from the invoice.
generated after the second month in default. The error indicates the payment of the
first invoice of July 2018 for the amount of $9,990 corresponding to a balance
financed. This is unacceptable as this value is part of the amounts that are subject to
of claim and therefore I cannot be charged. The company does not generate the invoice for the
concepts that are not subject to claim.

In the fourth request I asked for a copy of the documents in which they were recorded.
each of the financings that have been made in the service identified with No. NIC
53053328 corresponding to the property identified with the address Calle 22 A No. 18 E -
35 located in the Primero de Mayo neighborhood of the city of Valledupar. The company responds
We clarify that we do not have a copy of the document; considering that they were
financings carried out internally by the Company to benefit you with the payment of the
invoices.” Response which I express my dissatisfaction as it does not address my request, not
attached are proofs of the documents in which each of the
financing, does not inform who requested such financing (is) nor who, which person(s)
the actor(s) participated in it.

In the ninth request, I asked that in accordance with law 142 of 1994, an invoice be generated.
for the concepts that are not subject to claim, that is, for the consumption generated in
the first two months in default, and therefore withdrawing the financed amounts as the
other concepts billed after the first two months in default, receiving
as a response that 'to cancel the first solidarity invoice corresponding to the month of
July 2018 for the amount of $9,990 I can go to the commercial office and request the
information and the flyer to verify the respective payments.” I declare my
dissatisfaction with this response as the company evades my request, since it did not generate the
invoice for the first two months in payment arrears (Concepts that are not subject to
complaint), since the invoice to which the Company refers in its response to
my first request (the solidarity invoice corresponding to July 2018 for the amount
The $9,990 corresponds to the first installment of one of the financing options (value that is
object of complaint) which does not respond to my request as I am asking for
the generation of the invoice for the first two months in payment default (since this value
is not subject to complaint) and I am not requesting the first invoice of the fee that
it is part of the debt financing, since this value is part of the amount
(s) that is the subject of the claim and consequently I do not agree with this
decision since it does not correspond to what was requested in my initial petition. The company has
the obligation to generate the invoice for the values that are not subject to claim,
as stated in law 142 of 1994, therefore I reiterate the request and REQUEST that
the invoice with the concepts that are truly not the subject of the claim, is
issued and attached to the response of this resource, to proceed with the payment
respective. Furthermore, in consideration of the fact that I reside in the city of Bucaramanga, and I do not have
with the resources to move to the company's commercial offices
Electricaribe in the city of Valledupar, for this reason I base this request on the
principle of procedural economy.

In the tenth request, I asked to be informed why the company ELECTRICARIBE S.A.
E.S.P being obliged to suspend the service at the second billing period in
he didn’t do it and because he continued providing the service, receiving as a response that
As previously indicated, the Company did suspend the service as evidenced.
in the graphs of the considered part. Response with which I express my
discontent as the date on which each suspension was made is not evident, nor is it
they provide clear and effective evidence of the suspension, as the user continued
consuming electrical energy, which allowed the company to accumulate debt.
increasingly without the service suspension being carried out.

In the thirteenth request, I asked for a copy of the billing history, to which the
The company responds that 'a copy of the invoices for the contractual period is attached.
between January 15, 2017 (contract start date) and February 26, 2019 (date
that the property was vacated)”. Response with which I express my dissatisfaction already
that the attached invoices do not match the indicated contractual period in
the response, the attached invoices from the company correspond to the months of November and
December of the year 2018 and the months of January and February of the year 2019. Thus my request does not
it was effectively resolved.

In the sixteenth request, I requested a copy of the contract or contracts through which
the debt was financed, Electricaribe responds that 'we confirm that the balance was financed'
directly by the Company, and therefore the request is not applicable
with which I am dissatisfied because the company responds with evasions, it is not proven.
the existence of the contract(s) is not indicated that actors are involved in the
debt financing, for which I request that this financing be approved by the Company

In the twentieth request, I asked for each of the claims to be answered in detail.
clear, broad and without evasions or unjustified delays, to which the company responds
that a response is given to your requests as requested clarifying that it is necessary
that informs us which months you request copies of the payments made to provide you with the
information considering that it is not specific in your request and the property has 18
years of issuing invoices," which I disagree with because the
The company does not respond clearly, comprehensively, without evasions or in depth as it should.
demonstrated in all that has been said above.

EVIDENCE PROVIDED IN THE PROCESS

The evidence presented in the process is because on July 8, 2010, I acquired


by sale the property identified with the address Calle 22 A carrera 18 E - 35
located in the Primero de Mayo neighborhood of the city of Valledupar, which was recorded
in the public deed No. 1,792 issued at the First Notary of the Valledupar Circle and
registered in annotation No. 17 of the real estate registration folio No. 190-44805,
presenting as EVIDENCE: the public deed, the photocopy of the citizenship ID
from the owner, and the Certificate of Freedom and Tradition within the established terms,
that is to say, with less than 90 days of seniority.

On January 15, 2017, I leased the property identified in the previous point to the lady
LORENA ACOSTA DAZA identified with citizenship ID No. 1129566648 of
Barranquilla, for which I attached as proof: the lease contract.

ORIGIN OF THE SOLIDARITY BREAK

The company Electricaribe did not analyze the evidence presented in the process and responded to the
claim without taking them into account. The owner demonstrates by presenting each of the
The mentioned tests show that the property owner and the tenant are two different people.
different, which demonstrates the contractual link with the tenant and consequently
the existence of joint obligors is tested, giving rise to the figure of breach of
solidarity for not suspending the service despite the overdue payment of the bill and for not doing so
the effective suspension preventing unauthorized reconnection.

The company Electricaribe did not suspend the service after two months of overdue payment.
the bill, since the tenant continued using the electricity service,
allowing the Company for the debt to rise more and more.

By virtue of the above and in accordance with Law 142 of 1994, the Electricaribe Company
It must acknowledge the breaking of solidarity.

FUNDAMENTALS OF LAW

Law 142 of 1994

ARTICLE 130. PARTS OF THE CONTRACT. <Article modified by article 18 of


Law 689 of 2001. The new text is as follows: The parties to the contract are the company
public services, the subscriber and/or user. The owner or holder of the property, the
subscriber and the service users are jointly responsible for their obligations and rights in the
public services contract.

The debts arising from the provision of public services may be collected.
executively before the ordinary jurisdiction or exercising the coercive jurisdiction by
the industrial and commercial state-owned companies that provide public services.
invoice issued by the company and duly signed by the legal representative of the
entity will grant executive merit in accordance with the norms of Civil Law and
Commercial. What is prescribed in this section applies to electricity service invoices.
for public lighting. Failure to pay for the mentioned service results in
responsible for the application of the article that addresses the 'special duties of users'
from the official sector.

PARAGRAPH. If the user or subscriber fails to fulfill their obligation to pay on time
the services billed within the term established in the contract, which shall not exceed two
in consecutive billing periods, the utility company will be obligated
to suspend the service. If the company fails to comply with the obligation of the suspension of
the service will break the solidarity provided for in this regulation.

ARTICLE 152. RIGHT OF PETITION AND APPEAL. It is essential to the


public services contract that the subscriber or user may present to the company
requests, complaints and resources related to the public service contract.

The rules on the presentation, procedure, and decision of appeals will be interpreted and applied
taking into account the customs of commercial companies in dealing with their clientele,
so that, insofar as the law does not provide otherwise, action will be taken in accordance with such
customs.

ARTICLE 154. OF THE RESOURCES. The resource is an act of the subscriber or user to
force the company to review certain decisions that affect the provision of the service or the
execution of the contract. Against the acts of denial of the contract, suspension, termination,
The cuts and billing carried out by the company are subject to the appeal for reconsideration and the appeal.
in cases where the law expressly provides for it.

The resources against acts of suspension, termination, and cutoff are not admissible if with
They intend to discuss a billing act that was not subject to timely appeal.

The appeal for reconsideration against acts that resolve claims regarding billing
must be filed within five (5) days following the date of knowledge of the
decision. In no case are claims against invoices that are more than five allowed.
(5) months after having been issued by public service companies.

From the resources for replacement and appeal against the other acts of the company that it enumerates
The first paragraph of this article must be used within five days following that.
in which the company brings the act to the attention of the subscriber or user, in the manner provided
under the uniform conditions of the contract.

These resources do not require personal appearance or lawyer intervention although they
employ a representative. Companies must have forms available to facilitate the
presentation of the resources to subscribers or users who wish to use them. The
The appeal will be presented to the superintendent.

PRETENSIONS

In light of the fact that the company Electricaribe remained silent on some claims, on others
responded with evasions and without getting to the heart of the request and with a lack of clarity, I allow myself
to reiterate them again so that I am answered clearly, without evasions or delays
the silences.

1. I request that ELECTRICARIBE S.A. ESP recognize the breaking of solidarity between
landlord and tenant of the property identified with the address Calle 22 A carrera 18 E
– 35 located in the Primero de Mayo neighborhood of the city of Valledupar since the second
period of default in the payment of the service and consequently remove the charges from the bill
generated after the second month of default and are not to be collected again.
I request that the amounts being charged for financing be removed.
accounts payable and debts that the tenant has incurred during the time they were in the
property, and not be charged again.
3. I request information on how many financing operations have been carried out in the energy service.
electric identified with NIC No. 5305328, who requested each of them, the concepts
what the date and the values correspond to.
4. I request a copy of the documents in which each of the
financing that has been carried out in the service identified by No. NIC 53053328
corresponding to the property identified with the address Calle 22 A No. 18 E – 35 located
in the Primero de Mayo neighborhood of the city of Valledupar.
5. I request to be informed how many power service suspensions have been carried out.
in the property identified with the address Calle 22 A carrera 18 E – 35 located in the neighborhood
May First in the city of Valledupar, the date on which it took place, and the reason
of its realization.
6. I request detailed information from you, specifying the respective date of
generation of each of the concepts that are part of the amount of $3,297,048 identified
in invoice No. 5305328 corresponding to the electricity service of the property
identified with the address Calle 22 A carrera 18 E – 35 located in the neighborhood Primero de
May of the city of Valledupar as 'AMOUNT OF PENDING FINANCINGS'.
7. I request that you provide me with detailed information along with the respective date of
generation of each of the concepts that are part of the amount of $263,670 identified
in invoice No. 5305328 corresponding to the electricity service of the property
identified with the address Calle 22 A No. 18 E - 35 located in the Primero de Mayo neighborhood
from the city of Valledupar as 'AMOUNT OF OVERDUE INVOICES'.
8. I request that you inform me about the concepts corresponding to the current and total debt of the property.
identified with the address Calle 22 A carrera 18 E - 35 located in the Primero neighborhood
May of the city of Valledupar, identified with NIC 5305328 indicating in a way
detailed, with its respective generation date for each of the concepts.
9. I request that in accordance with Law 142 of 1994, an invoice be generated for the concepts that
they are not subject to complaint, meaning for the consumption generated in the first two months.
in default, and therefore withdrawing the financed values as well as the other concepts
invoiced after the first two months in arrears. I REQUEST that said invoice
The invoice has been sent and attached to the response of this resource, to proceed with the payment.
respective. Furthermore, considering that I reside in the city of Bucaramanga, and I do not have
the resources to get to the commercial offices of the Electricaribe company in the
city of Valledupar, for this reason I base this petition on the principle of economy
procedural.
10. I request to be informed why the company ELECTRICARIBE S.A. ESP is in the
obligation to suspend the service at the second billing period in arrears, did not do so and
because it continued to provide the service.
11. I request information on why the company ELECTRICARIBE S.A. ESP is in the
obligation to suspend the service at the second billing period in arrears, continued
providing the service without taking the actions established in law 142 of 1994 and the contract
of uniform conditions to avoid new consumption and the increase of debt.
12. I request that you inform me why the company ELECTRICARIBE S.A. ESP is in the ...
obligation not to finance the debt to the tenants, without my consent
as the owner, granted the tenant financing for the debt
which allowed it to rise more each month.
I request a copy of the billing history.
I request a copy of the suspension history.
I request a copy of the payment history.
16. I request a copy of the contract or contracts through which the debt was financed.
17. I request you to inform me which person(s) required the debt financing, and why.
concepts were made and on what date it was done, and what documents were requested and what
documents were effectively submitted.
18. I request a copy of the Uniform Conditions Contract.
19. I request that you inform me whether the facts mentioned in this petition are true or not and
why.
20. I request that each of the claims be answered clearly, comprehensively and
fundamental without evasions or unjustified delays.
21. I request that this petition be answered in accordance with the law.
ANNEXES

Copy of the citizenship ID of MARY BUITRAGO SOLANO


2. Photocopy of the public deed No. 1,792 issued at the First Notary
Valledupar Circle.
3. Current certificate of freedom and tradition.
4. Copy of the lease agreement signed by Mrs. MARY BUITRAGO
SOLANO and Mrs. LORENA ACOSTA DAZA of the property identified
identified with the address Calle 22 A carrera 18 E – 35 located in the Primero neighborhood
May of the city of Valledupar.

NOTIFICATIONS

The undersigned receives notifications at street 108 B No. 15 A Bis - 30 house 21 of the complex
residential La Riviera located in the city of Bucaramanga (Santander) email
maryluzpovedabuitrago@gmail.comphones 311 846 6191.

Sincerely,

MARY BUITRAGO SOLANO


C.C. No. 28.294.803 of Piedecuesta

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