upr000280 111

1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 26 27 28 29 30 31 32 set forth, or suffer a nit loss In the amount set forth, or thut the rate ©f return should be 6-1/4$ a® alleged beginning with the word »and*» in 3ine 7 and ending with the figures #57,319.00 in line 16 of pa&e 7. Further, defendant denies the allegation beginning with the word ’’Since* in line 19 of page 7 and ending with the word ’’Nevada” in line 6 of page 6. VI. Answering paragraph VI of plaintiff’s complaint, defend­ant denies that the opinion and order of defendant commission of August 24, 1951 is unreasonable, unlawful or in violation of the Fourteenth Amendment of the United States Constitution and Section 6, Article I of the Constitution of the State of Nevada in that said opinion and order denied the plaintiff hearing and decision in ac­cordance with due process of law. VII. Answering paragraph VII of plaintiff’s complaint, defendant ,denies the allegations therein contained* VIII. Answering paragraph VIII of plaintiff’s complaint, de­fendant denies, each and every all and singular, the allegations therein contained; save and except, defendant while admitting that the cost of defense plant facilities were excluded, denies that said cost should be included in the rate base as alleged in sub-paragraph 4 of paragraph VIII A, II. Answering paragraph II of plaintiff’s complaint, defendant denies that the order of the defendant commision of August 24, 1951 should be set aside and/or vacated, and further states that the pro­posed schedule of rates filed with the commission on January 22, 1951 should not be granted or approved. -3-