A. OVERVIEW OF THE CLAIM

1. This case is about unfairness, the abuse of power and process and undue political interference in the regulation of renewable energy in Ontario through the unannounced last~m.inute imposition of arbitrary measures and through opaque and secret administration and "buy local" contract requirements. The government changed the regulatory framework. without notice and without due process, so as directly to curtail and impair market access rights under the established scheme for renewable energy in Ontario.

2. The subject of this unlawful treatment is Mesa Power Group, LLC (Mesa Power), a United States Investor, which participated in Ontario's renewable energy production program through its ownership of four Ontario wind fann projects, and which has suffered substantial and direct injury,loss and hann as a result of those deliberately contrived governmental measures.

3. Mesa Power is a Delaware limited liability corporation. )t owns Mesa Wind, LLC (Mesa Wind), which in tum owns and controls Mesa AWA, LLC (Mesa AWA).

4. Mesa A WA owns and controls the following four wind fann locations in southwestern Ontario: