5. Even if BudSco's Complaint Allegations Were
Accepted as True, Alco's Motion to Dismiss
Must Be Granted

Initially, we note the absence of any well-pleaded allegations to accept as true as BudSco's complaint does not appear to set forth any causes of action in the manner required by Pub. Util. Code § 1702 and Rule 4.2(a). Specifically BudSco does not allege that Alco violated any law or Commission order or rule, nor does it allege an injury. Instead, BudSco raises a series of questions regarding well ownership and wonders if the ownership is in contravention of "Commission restrictions" of "commercial family transactions."¹⁷ BudSco further claims that it does not "want to issue checks for their water use to anyone other than the owners of this well lot/equipment."¹⁸ BudSco then wonders if there will be fire suppression concerns if its water supply is discontinued. Finally, BudSco wants an explanation about "a $14.24 non-disclosed charge."¹⁹ Taken collectively as true, these allegations are nothing more than a series of questions and speculations. BudSco has failed to allege that Alco engaged in an act or failed to perform an act in violation of any California law or Commission order or rule as required by Pub. Util. Code § 1702.

¹⁷ BudSco's Complaint at 2.

¹⁸ Id.

¹⁹ Id.