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PENNSYLVANIA
ROBERT D. KODAK, ESQUIRE
KODAK LAW OFFICES, P.C.
407 N FRONT STREET, PO BOX 11848
HARRISBURG, PA 17108-1848
(717) 238-7159 Attorney for Plaintiff
OLD DOMINION FREIGHT LINES, IN THE COURT OF COMMON PLEAS OF
INC. CUMBERLAND COUNTY,
Plaintiff PENNSYLVANIA
v
NO. I_ y?(? ??.<! l c??
CHRISTOPHER T. GAMBILL
Defendant(s)
CIVIL ACTION - LAW
NOTICE
YOU HAVE BEEN SUED IN COURT. If you wish to defend against the claim set
forth in the following pages, you must take action within twenty (20) days after this
complaint and notice are served, by entering a written appearance personally or by an
attorney and filing in writing with the court your defenses or objections to the claims set
forth against you. You are warned that if you fail to do so the case may proceed without
you and a judgment may be entered against you by the court without further notice for any
money claimed in the complaint or for any other claim or relief requested by the plaintiff.
You may lose money or property or other rights important to you.
YOU SHOULD TAKE THIS PAPER TO YOUR LAWYER AT ONCE. IF YOU DO
NOT HAVE A LAWYER, GO TO OR TELEPHONE THE OFFICE SET FORTH BELOW.
THIS OFFICE CAN PROVIDE YOU WITH INFORMATION ABOUT HIRING A LAWYER.
IF YOU CANNOT AFFORD TO HIRE A LAWYER, THIS OFFICE MAY BE ABLE
TO PROVIDE YOU WITH INFORMATION ABOUT AGENCIES THAT MAY OFFER
LEGAL SERVICES TO ELIGIBLE PERSONS AT A REDUCED FEE OR NO FEE.
CUMBERLAND COUNTY BAR ASSOCIATION
TWO LIBERTY AVENUE
CARLISLE PA 17013
717-249-3166 gl'p3 7 S ?? ?l
S J ck,?t x-30
9 - c?7d-943
AVISO
USTED HA SIDO DEMANDADO/A EN CORTE. Si usted desea defenderse de las
demandas que se presentan mas adelante en las siguientes paginas, debe tomar accion
dentro de los proximos veinte (20) dias despues de la notificacion de esta Demanda y
Aviso radicando personalmente o por medio de un abogado una comparencencia escrita
y radicando en la Corte por escrito sus defensas de, y objecciones a, las demandas
presentadas aqui en contra suya. Se le advierte de que si usted falla de tomar accion
como se describe anteriormente, el caso puede proceder sin usted y un fallo por cualquier
suma de dinero reclamada en la demanda o cualquier otra reclamacion o remedio
solicitado por el demandante puede ser dictado en contra suya por la Corte sin mas aviso
adicional. Usted puede perder dinero o propiedad u otros derechos importantes para
usted.
USTED DEBE LLEVAR ESTE DOCUMENTO A SU ABOGADO
INMEDIATAMENTE. SI USTED NO TIENE UN ABOGADO, LLAME O VAYA A LA
SIGUIENTE OFICINA. ESTA OFICINA PUEDE PROVEERLE INFORMACION A CERCA
DE COMO CONSEGUIR UN ABOGADO.
SI USTED NO PUEDE PAGAR POR LOS SERVICIOS DE UN ABOGADO, ES
POSIBLE QUE ESTA OFICINA LE PUEDA PROVEER INFORMACION SOBRE
AGENCIAS QUE OFREZCAN SERVICIOS LEGALES SIN CARGO O BAJO COSTO A
PERSONAS QUE CUALIFICAN.
CUMBERLAND COUNTY BAR ASSOCIATION
TWO LIBERTY AVENUE
CARLISLE PA 17013
717-249-3166
OLD DOMINION FREIGHT LINES,
INC.
Plaintiff
v
CHRISTOPHER T. GAMBILL
Defendant(s)
IN THE COURT OF COMMON PLEAS OF
CUMBERLAND COUNTY,
PENNSYLVANIA
NO. )?_ lq.76
CIVIL ACTION - LAW
COMPLAINT
The Plaintiff, OLD DOMINION FREIGHT LINES, INC., by its attorneys, KODAK
LAW OFFICES, P.C., brings this action of Assumpsit against the Defendant(s) to recover
the sum of FOUR THOUSAND TWENTY FIVE DOLLARS AND ZERO CENTS
($4,025.00), along with interest thereon at the statutory rate from April 3, 2011, upon a
cause of action of which the following is a statement:
1. The Plaintiff, OLD DOMINION FREIGHT LINES, INC., is a corporation organized
and existing under the laws of the State of Virginia, having its principal office and
place of business at 500 Old Dominion Way, Thomasville, North Carolina 27360.
2. The Defendant, CHRISTOPHER T. GAMBILL, is an adult individual residing at 207
W MAPLEWOOD AVENUE, MECHANICSBURG, CUMBERLAND COUNTY
PENNSYLVANIA 17055.
F:\USER\Z-MASTER CMP FILES\COMPLAINTS\OLD DOMINION FREIGHT LINES\35511 DRV TRN AGR.wpd 2
3. On or about December 6, 2010, Defendant signed a Truck Driver Training Program
Agreement with Plaintiff which provided, in pertinent part, that should Defendant
leave Plaintiff's employ for any reason or voluntarily transfer to a non-driving
position with Plaintiff prior to 1 year after graduation from the driver training
program, Defendant would pay to Plaintiff the sum of $3,500.00 in consideration for
such Truck Driver Training Program. A true and correct copy of said Truck Driver
Training Program Agreement is attached hereto, marked Exhibit "A" and made a
part hereof.
4. Defendant completed the Old Dominion Truck DriverTraining Program and received
a Certificate of Achievement on or about February 1, 2011. A true and correct copy
of said Certificate of Achievement is attached hereto, marked Exhibit "B" and
made a part hereof.
5. Defendant's employment with Plaintiff ended on or about March 1, 2011, the last
date Defendant worked, and Defendant's employment with Plaintiff was terminated
on March 3, 2011, for cause, as set forth on Plaintiff's HR Change Request Form,
a true and correct copy of which is attached hereto, marked Exhibit "C" and made
a part hereof.
F:\USER\Z-MASTER CMP FILES\COMPLAINTS\OLD DOMINION FREIGHT LINES\35511 DRV TRN AGR.wpd
6. As the result of thereof Defendant failed, refused and/or neglected to comply with
the terms and conditions of Plaintiff's Truck Driver Training Program Agreement
attached hereto as Exhibit "A", hence, the sum of Three Thousand Five Hundred
Dollars ($3,500.00) as set forth in said Agreement is due and owing to Plaintiff by
Defendant.
7. The price charged for said training and services provided were just and reasonable,
were the legal and market prices therefor and were the prices which the Defendant
contractually promised and agreed to pay to Plaintiff.
8. The balance due and owing by Defendant to Plaintiff is the sum of Three Thousand
Five Hundred Dollars and Zero Cents ($3,500.00).
9. Due to the default of Defendant, and pursuant to the terms and conditions of the
Truck Driver Training Program Agreement executed by Defendant hereto attached
as Exhibit "A", attorney's fees in the total amount of Five Hundred Twenty Five
Dollars and Zero Cents ($525.00) have been added to said account.
10. Plaintiff frequently demanded payment from Defendant of said amount due and
owing as aforesaid, but Defendant refused and neglected and still refuses and
neglects to pay said amount of any part thereof.
F:\USER\Z-MASTER CMP FILES\COMPLAINTS\OLD DOMINION FREIGHT LINES\35511 DRV TRN AGR.wpd 4
WHEREFORE, Plaintiff brings this suit to recover from Defendant the sum of FOUR
THOUSAND TWENTY FIVE DOLLARS AND ZERO CENTS ($4,025.00), together with
interest as set forth herein.
Respectfully submitted,
KODAK LAW OFFICES, P.C.
?. J
R rt . Kodak, Esquire ID# 18041
Jeffrey L. Troutman, Esquire ID# 53984
407 North Front Street
Post Office Box #11848
Harrisburg, PA 17108-1848
(717) 238-7159
Attorney for Plaintiff
F:\USER\Z-MASTER CMP FILES\COMPLAINTS\OLD DOMINION FREIGHT LINES\35511 DRV TRN AGR.wpd
OLD DDMINIONEUIGHT LINE. INC.
TRUCK DRIVER TRAINING PROGRAMAGREEMENT
For and to consideration of Old Dominion Freight Line, Inc allowing me to participate in the Old Dominion Truck Driver
Training Program for the purpose of becoming trained as a professional truck driver, l agree as follows
I That I meet the qualifications of the program
? That I understand the requirements of the program, the type of training to be green and vrhat shall be required of
me should 1 remrvc my CDL
3 That I have read the attached information sheet and agree with its content. (Truck Driver Irtuning Information
Sheet - "Earn Wlule You Learn" )
4 That m the event 1 withdraw frotn the program, or deliberately delay my continued training/completion, after
having completed the classroom
I hereby agree to pay to Old Dominion any compensation I have received during the program including meat
reimbursement, lodgwg, classroom and on the fob trainigng
That to the event ttiat I Complete the training program and receive my CDL
If my employment with Old Domtnion Freight Lmc, Inc should terminate for any reason and/or I voluntarily
transfer ti, a non driving position with Old Domrntaa Freight Line, Inc prior to 1 year,(12; months) after
graduation from the Old Dominion Freight Gne, Inc Truck Driver Traming Program, I hereby agree to pay to
the order of Old Dominion Freight Lane. Inc the stun of 53500 00 as consideration for such training, carne to be
due and payable in full on the date of my tcrtrunation I agree that this sum represents a -fair-estimate of the cost
of the driver training to be provided by Old Dominion, and my agreement to pay this sum as prodded in this
Agreement constitutes liquidated damages and is not a penalty
I further agree that any wages or other momes not yet paid to me by Old Dominion Freight Lute, Inc may be withheld
and applied toward the stmt which I may owe Old Dominion Freight Line, Inc, under this Agreement or otherwise at the
time of termination and I authorize Old Dominion Freight Line, Inc to deduct said sums from wages or other mont"
due me at the time of said termination I comider this to be a voluntary' repayment of any amount which I owe as
provided by 595-25 10 of the General Statutes of North Cuohna.
In the event I default in the payment of such sutra, when due, then in such evenf interest'on ttie'unpaid balance at the
highest legal interest rate at the time of termination shall be due and payable and shall accrue until said is fully paid
In the event it becomes necessary for O1d,Domuuon Freight Line, Inc to employ an attorney to collect said sum then in
tiuch event, Old Dominion Freight Line, Inc shall be entitled to recover an addtuonal I S% of the balance due and interest
w attorney's fees
Nothing herein shall be considered to be a contract of employment with Old Dominion Freight Line, Inc and I understand
that either old Dominion Freight Line, Inc or 1 can t,etmutate my employment at wilL I further.agree that dwe, are no
promises or repmvntations concerning die training progaIIi except those set forth'in this Agieement and that, there,have
been no promises or representations concerning my compensation following completion of the t mning program
Executed this Qj? day of cf..ar6 , 20 0
tvttnes?.
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• HR CHANGE REQUEST
LOCATION HAR _ No. 0000010704 DEPARTMENT Harrisburg Platform
(1) Form Type End of Employment (2) Employee # 00059632
(3a) Old Employee Name Gambill Christopher T.
Last First Middle
(3b) Employee Name Gambill Christopher T.
Last First (4) Gender
(5) Address (House Number, Street, Apt.#) Middle
Male 0 Female
207 W. Maplewood Ave.
city Mechanicsbu
(6) Date of Birth
Y
00) Emergency Contact Phone No.
717-712-5092
(12) Current Empl. Status
O' Full Time O Part Time
(16) Existing Position#
40012946
08) New Position#
(20) Existing Empl Sub Group
W1
(24) Disability O yes ONO
(28) State Tax Subject to
(31) Drivers License Number
(34) DL Issue Date
- State PA Zip Code 17055 Phone No.
(7) Social Security No. (8) Marital Status
(9) Emergency Contact Name
O Married O Single _
(11) Date Employed (First Day Worked) (Important: In event date employed
5/20/2008 and/or first day worked changes, a
corrected PA01 must be submitted.)
(13) New Empl. Status (14) Full Time Date
OFull TimeOPart Time 5/20/2008
(17) Existing Position Name
S/C PLATFORM
(19) New Position Name
(21) New Empl Sub Group
(25) Ethnic
(29) City Tax Subject to
(32) Drivers License State
(35) DL Expiration Date
(22) New Service Center No.
(26) VeteranOYesONo
(30) Other Tax Subject to
(33) CDL Endorsements
(15) Effective Date of Change
(23) Department
0000010704
(27) EEO
OH ON OT OM OP OX
(36) Drivers License Type
(37) Last Date Worked (38) Termination Date (39) Eligible For Rehire If NO, Explain
3/1/2011 3/3/2011
OYes ONo Reason On Line (41).
(40) Reason Refused to perform job duty
(41) comments also stated he was unable b/c of 'sleeping disorder'
(42) Manager Comments
(43) Requested By Amanda S. Tuckey Title S/C ADMINISTRATIVE ASST S Date 3/3/2011
Approved By E011595 Date 3/3/2011
Approved By Bate
Approved By
Date Approved By
(44) Pay Status OHour•ly D Weekly Salary OMileage (45) Date Last Rate Change _
(46) Pay Rate Hourly (46a) Mileage
From Per_ To Per
To Per.
Date
(47) Amt. Last Change
VERIFICATION
I, Laura O. Williams Director of Payroll
of Old Dominion Freight Line, Inc., verify that the statements made in the aforegoing document are true
and correct. I understand that false statements herein are made subject to the penalties of 18 Pa. C.
S. §4904, relating to unworn falsification to authorities.
OLD DOMINION FRIEIGHT LINE, INC.
By:
Title: C7 .?€
Dated: 2-0 \2..--
38524111-482
GAMBILL
F:IUSER12-MASTER CMP FILESICOMPLAINTS%OLD DOMINION FREIGHT LINEW&524.wpd:IdMar12
SHERIFF'S OFFICE OF CUMBERLAND COUNTY
Ronny R Anderson
Sheriff
Jody S Smith 1
Chief Deputy ? ! P
Richard W Stewart
Solicitor
Old Dominion Freight Lines, Inc.
Case Number
vs.
Christopher T. Gambill 2012-1926
SHERIFF'S RETURN OF SERVICE
03/28/2012 06:50 PM - Robert Bitner, Deputy Sheriff, who being duly sworn according to law, states that on March 28,
2012 at 1850 hours, he served a true copy of the within Complaint and Notice, upon the within named
defendant, to wit: Christopher T. Gambill, by making known unto himself personally, at 207 W. Maplewood
Avenue, Mechanicsburg, Cumberland County, Pennsylvania 17044 its contents and at the same time
handing to him personally the said true and correct copy of the same.
RO RT BITNER, DEPUTY
SHERIFF COST: $38.45
March 30, 2012
SO ANSWERS,
RON R ANDERSON, SHERIFF
JOSEPH K. GOLDBERG, ESQUIRE
2080 LINGLESTOWN ROAD, SUITE 1 06
HARRISBURG, PA 171 10
(717) 703-3600
JGOLDBERG@SSBC-LAW.COM
PA ID #46782
OLD DOMINION FREIGHT LINES,
INC..
Plaintiff
V.
PILED-OFFICE
Or- TI;E PJR0TH0NOTrjj;2612 APR 27 AN 10: 33
CUMBERLAND COUNTY
PENNSYLVANIA
IN THE COURT OF COMMON PLEAS
OF CUMBERLAND COUNTY,
PENNSYLVANIA
NO. 12-1926 CIVIL TERM
CIVIL ACTION - LAW
CHRISTOPHER T. GAMBILL,
Defendant
JURY TRIAL DEMANDED
NOTICE
YOU HAVE BEEN SUED IN COURT. If you wish to defend against the claims set forth
in the following pages, you must take action within twenty (20) days after this Complaint and
Notice are served, by entering a written appearance personally or by attorney and filing in
writing with the Court your defenses or objections to the claims set forth against you. You are
warned that if you fail to do so the case may proceed without you and a judgment may be
entered against you by the Court without further notice for any money claimed in the Complaint
or for any other claim of relief requested by the Plaintiff. You may lose money or property or
other rights important to you.
YOU SHOULD TAKE THIS PAPER TO YOUR LAWYER AT ONCE. IF YOU DO NOT
HAVE A LAWYER OR CANNOT AFFORD ONE, GO TO OR TELEPHONE THE OFFICE SET
FORTH BELOW. THIS OFFICE CAN PROVIDE YOU WITH INFORMATION ABOUT HIRING
A LAWYER
IF YOU CANNOT AFFORD TO HIRE A LAWYER, THIS OFFICE MAY BE ABLE TO
PROVIDE YOU WITH THE INFORMATION ABOUT AGENCIES THAT MAY OFFER LEGAL
SERVICES TO ELIGIBLE PERSONS AT A REDUCED FEE OR NO FEE.
Cumberland County Bar Association
32 S. Bedford Street
Carlisle, PA 17013
(717) 249-3166
JOSEPH K. GOLDBERG, ESQUIRE
2080 LINGLESTOWN ROAD, SUITE 1 06
HARRISBURG, PA 171 10
(717) 703-3600
JGOLDBERG@SSBC-LAW.COM
PA ID #46782
OLD DOMINION FREIGHT LINES,
INC.,
Plaintiff
IN THE COURT OF COMMON PLEAS
OF CUMBERLAND COUNTY,
PENNSYLVANIA
NO. 12-1926 CIVIL TERM
V.
CHRISTOPHER T. GAMBILL,
CIVIL ACTION - LAW
Defendant JURY TRIAL DEMANDED
ANSWER WITH NEW MATTER AND COUNTERCLAIM
NOW COMES DEFENDANT, Christopher T. Gambill, by and through his
attorney, Joseph K. Goldberg, who answers Plaintiffs Complaint with New Matter, and
files a Counterclaim, as follows:
ANSWER
1. Admitted, except that the records of the Pennsylvania Department of
State and documents attached to Plaintiffs Complaint indicate the proper name of
Plaintiff is "Old Dominion Freight Line, Inc." and not "Lines."
2. Admitted.
3. It is admitted that Defendant signed the document attached as Exhibit A
to the Complaint herein. To the extent the averments interpret the provisions of the
document, those averments are conclusions of law to which no response is required.
4. Admitted.
5. Denied. To the contrary, Defendant was not terminated for cause. To the
contrary, Defendant was illegally terminated when he inquired about his rights under the
Family and Medical Leave Act, due to a persistent medical condition. The remaining
averments are admitted.
6. Denied. To the contrary, Defendant fully intended to comply with the
terms of the Agreement, but was prevented from doing so by Plaintiff's illegal
termination of his employment. Therefore, Defendant owes no money to Plaintiff.
7. Denied. To the contrary, Plaintiff paid no money for the training, which
consisted of Defendant riding along with Plaintiff's employee drivers on regular runs.
The averments as to what Defendant contractually promised and agreed are
conclusions of law to which no response is required. After reasonable investigation,
Defendant is without sufficient knowledge or information with which to admit or deny the
averments that the price charged for the training and services were just and reasonable
and were the legal and market prices therefor, and those averments are therefore
denied.
8. Denied. To the contrary, Defendant owes no money to Plaintiff for the
reasons set forth above.
9. The averments of paragraph 9 are conclusions of law to which no
response is required. To the extent a response is required, the averments are denied,
as Plaintiff is not entitled to recovery of any amount, including attorney's fees, for the
reasons set forth above.
10. Denied as stated. To the contrary, Defendant received only two written
requests from Defendant for payment. The averments that any amount is due or owing
to Plaintiff is a conclusion of law to which no response is required. To the extent a
response is required, the averments are denied, for the reasons set forth herein.
2
WHEREFORE, Defendant respectfully requests that Plaintiff's Complaint be
dismissed, with costs assessed against Plaintiff.
NEW MATTER
11. Plaintiff is estopped from asserting its claim against Defendant, as it arose
from Plaintiff's illegal termination of Defendant's employment.
12. Plaintiff's claim is barred by the illegality of its action.
13. Plaintiff's claim is barred by Plaintiff illegally acting to make impossible
Defendant's performance of the parties' agreement.
14. Plaintiff illegally terminated Defendant's employment in retaliation for his
inquiry about exercising his legal rights under federal law.
COUNTERCLAIM
15. For purposes of consistency, Counterclaim Plaintiff, Christopher T.
Gambill, is referred to in this Counterclaim as "Defendant," and Counterclaim
Defendant, Old Dominion Freight Lines, Inc., is referred to as "Plaintiff."
16. This is an action filed by Defendant against Plaintiff for the wrongful and
unjustified firing of Defendant when he attempted to exercise his rights as provided to
him under the Family and Medical Leave Act of 1993, 29 U.S.C. § 2601, et seq.
(hereafter "FMLA" ).
17. Defendant had been employed in a full time capacity by Plaintiff for more
than twelve months at the time the wrongful acts occurred.
3
18. At the time it committed the wrongful acts complained of herein, Plaintiff
was engaged in interstate commerce.
19. Plaintiff is a covered employer as defined by the FMLA.
20. At the time Plaintiff committed the wrongful acts, Defendant had a serious
health condition as defined by the FMLA.
21. In late 2010 or early 2011, Defendant developed a serious health
condition requiring continuing treatment by a health care provider, resulting in a period
of incapacity, which caused him to periodically miss work pursuant to instructions of his
treating physician.
22. In March, 2011, the condition worsened, and Defendant's doctor
recommended that Defendant not work for a period of time in order to treat the serious
health condition.
23. On or about March 1, 2011, Defendant met with a human resources
representative to discuss the procedure to apply for leave under the FMLA.
24. At that meeting, the human resources representative contacted Plaintiffs
home office about Defendant's request, after which Defendant was told that in light of
his request, he had two choices: he could resign or be fired.
25. On or about March 3, 3011, after Defendant refused to resign his position,
Plaintiff fired Defendant without legal justification and in retaliation for his attempt to
exercise his rights under federal law.
26. The termination of Defendant by Plaintiff was done in bad faith and
without reasonable grounds, in violation of the FMLA.
27. As a result of his wrongful termination, Defendant has suffered damages
4
in the form of loss of employment, lost wages and other benefits to which he was
entitled as an employee.
WHEREFORE, Defendant demands judgment against Plaintiff for reinstatement,
his actual damages, liquidated damages in an amount equal to his actual damages,
reasonable attorney's fees, costs of this action, and such other equitable relief the court
deems necessary and proper.
Respectfully submitted,
J . Goldberg, quire
ttornhamey ID No. 467
2080 Linglestown oad, Suite 106
Harrisburg, PA 110
(717)703-360
Date: Attorney for Defendant
5
VERIFICATION
I, Christopher Gambill, hereby state that I have reviewed the foregoing Answer
with New Matter and Counterclaim, and verify that the facts set forth in the document
are true and correct to the best of my knowledge, information and belief; and that this
statement is made subject to the penalties of 18 Pa. C.S. § 4904 relating to unsworn
falsification to authorities.
Dated: / Z6 /z 6??i;za CHRISTOPHER AM LL
CERTIFICATE OF SERVICE
I, the undersigned, hereby certify that on theolL day of krill-, 2012,
served a copy of the foregoing Answer with New Matter and Counterclaim, by first-class
mail, postage prepaid, upon the following:
Robert D. Kodak, Esquire
Jeffrey L. Troutman, Esquire
P.O. Box 11848
Harrisburg, PA 17108-1848
Attorneys for Plaintiff
ER LAND C0UNT ,
"THIISYUVANIA
OLD DOMINION FREIGHT LINE,
INC.
Plaintiff
v
CHRISTOPHER T. GAMBILL
Defendant(s)
IN THE COURT OF COMMON PLEAS
Cumberland COUNTY,
PENNSYLVANIA
NO. 12-1926 Civil Term
CIVIL ACTION - LAW
JOINT PRAECIPE TO DISCONTINUE
TO THE PROTHONOTARY:
Please mark the above-captioned matter settled and discontinued, with prejudice,
as to all claims by Plaintiff and all asserted Answers and/or New Matter and/or
Counterclaims by Defendant.
KODAK LAW OFFICES, P.C.
Wey t. Troutman, Esquire #53984
For Robert D. Kodak, Esquire
407 North Front Street
Post Office Box #11848
Harrisburg, PA 17108-1848
(717) 238152
ber , E uire #46782
2080 Linglestown ad, Suite 106
Harrisburg PA 1 10
71.7-703-3600
Dated: May 30, 2012