Ohio AG Complaint

All the below are named as defendants

B. DEFENDANTS:

2. FIRSTENERGY CORP. is an Akron, Ohio-based public utility holding company. FirstEnergy Corp. is the parent company of FirstEnergy Service Company and former parent company of FirstEnergy Solutions Corp. FirstEnergy Corp. senior management, including its then-President and CEO Charles Jones, also served as senior officers of FirstEnergy Service Company. FirstEnergy Corp. directed and controlled the operation of FirstEnergy Service Company through this shared leadership. FirstEnergy Corp. also played an integral role in establishing and funding Partners for Progress, Inc., which is described below.

3. FIRSTENERGY SERVICE COMPANY (“FIRSTENERGY SERVICE”) is an Ohio corporation with its principal place of business in Akron, Ohio, and is a wholly-owned subsidiary of FirstEnergy Corp. At all times relevant to this Complaint, FirstEnergy Service provided administrative, management, financial, compliance, ethical, external affairs, and political and regulatory advocacy services to FirstEnergy Solutions Corp. In

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re: FIRSTENERGY SOLUTIONS CORP., et al., 18-50757(AMK), US District Court, NDOH ED, 18-50757amk Doc 2721-1 at 50-51. Because of this relationship, FirstEnergy Service is inextricably intertwined with FirstEnergy Solutions Corp. and the affairs of a corrupt enterprise, which is referred to herein as “The Unholy Alliance.” 4. FIRSTENERGY SOLUTIONS CORP. (“FIRSTENERGY SOLUTIONS”) was an Akron, Ohio-based operator of two financially troubled nuclear power generation stations located in the State of Ohio. FirstEnergy Solutions operated as a subsidiary of FirstEnergy Corp. On March 31, 2018, FirstEnergy Solutions filed a voluntary petition for relief under Chapter 11 of the United States Bankruptcy Code in the United States Bankruptcy Court for the Northern District of Ohio. FirstEnergy Solutions continued to operate the two Ohio nuclear plants throughout 2018 and 2019. On February 27, 2020, FirstEnergy Solutions emerged from these bankruptcy proceedings as Energy Harbor Corp.

5. ENERGY HARBOR CORP. (“ENERGY HARBOR”) is a Delaware corporation with its principal place of business in Akron, Ohio. Through bankruptcy proceedings, Energy Harbor is successor in interest to the former FirstEnergy Solutions and its nuclear power generation plants in Ohio. As successor in interest, Energy Harbor will be the direct beneficiary of House Bill 6 and the resulting subsidies. Energy Harbor stands to receive benefits in excess of $1.3 billion as the result of statutory changes contained in House Bill 6 of the 133rd Ohio General Assembly. Prior to FirstEnergy Solutions’ emergence from bankruptcy as Energy Harbor, a number of key executives now within Energy Harbor held similar positions within FirstEnergy Solutions.

HB6complaint92320.pdf