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• required by the statute that would give Plaintiffs and other Non -Resident Customers an electoral • • voice in the governance of the City's municipal electric utility. 82. Plaintiffs dispute the City's erroneous interpretation of Section 366.04(7), and dispute the City's contention that it is not subject to that law. 83. Consistent with the method the City used for counting customers in its audited financial statements, its other filings with the PSC, and its filings with the various credit rating agencies, the City should be required to count customers by quantifying separate meter accounts, in which case the City is subject to the requirements of Section 366.04(7), Florida Statutes. 84. The Plaintiffs are being continually and irreparably harmed by the City's ongoing failure to comply with Section 366.04(7), because if the City complied with that statute, the Plaintiffs would have an opportunity to vote on the creation of a utility authority, which if approved, would give them a voice in electing the decision -makers who govern the City's electric utility and set the electric rates which Plaintiffs are being forced to pay. Thus, there exists a present, actual, and justifiable controversy between the Plaintiffs and the City, requiring a declaration of rights, not merely the giving of legal advice. 85. The Plaintiffs have a clear legal and ongoing right to vote in the referendum and otherwise be represented as provided by Section 366.04(7), Florida Statutes, and no adequate remedy at law to cure the ongoing denial of that right and the irreparable harm imposed on Plaintiffs. WHEREFORE, the Town and the Customer request this Court: (1) Declare that the City is subject to and must comply with Section 366.04(7)(a), Florida Statutes; (2) Enjoin the City from continuing to fail to comply with the requirements of Section 366.04(7); and 19 qq