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Home My WebLink About94-06519 \I) ~I ~I Qj (jJ I . -; :>0- J ~ ~ ..> P3 tJS J Jj ~J ~I , I dtl . . IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY. PENNSYLVANIA CIVIL DIVI~ION ST. JOHNS BURY TRUCKING COMPANY, INC. Plaintiff q 1,-- &5/1 NO. vs. COMPLAINT EXEL LOGISTICS, INC. Defendant FILED ON BEHALF OF Plaintiff COUNSEL OF RECORD OF THIS P1UlTY: NICHOLAS D. KRAWEC, ESQ. PA 1. D. #38527 HOLLIE A. BERNSTEIN, ESQ. PA 1.0. #52664 CHRISTIAN S. DAGHIR PA 1.0. #47741 Bernstein and Bernstein,P,c. Firm Un8 1133 Penn Avenue Pittsburgh. PA 15222 412-456-8113 BBRNSTBIN FILB NO. H6299 (I.uk-~Jl.~ 9. Defendant has made partial payment leaving an unpaid balance including penalties of $12,619.75. 10. Plaintiff claims legal interest as damages on the liquidated debt. 11. Plaintiff avers that interest amounts to $2,429.35 to November 29, 1994, 12. Although repeatedly requested to do so by Plaintiff, Defendant has willfully failed and refused to pay the aforesaid balance, legal interest, penalties or any part thereof to Plaintiff. WHEREFORE Plaintiff demands Judgment against Defendant in the amount of $15,049.10 with continuing legal interest thereon at the rate of 1/2\ per month and costs. aERNSTEIN AND BERNSTEIN, P.C. By:" ,t,J...!1 ."f!;: Hol A. Be stein, Esquire Attorney far Plaintiff 1133 Penn Avenue pittsburgh, PA 15222 BBRNSTBIN rILB NO. H6299 DIRECT DIAL: (412) 456-S113 62991101. h riLl: CD" TRUCKING COMPANY, INC. 31 nftlN ITREET, lOX lDO, IT. JDIlMDlUAY, VERnONT 011111 -766-27~7 T[ltP~ONE 102-741-8131 EXEL LOGISTICS ATTN BEllY ~tALL POBOX <127 CAMP HILL ['A STATEMENT OATE PRO NUMBER W-U73674 12/11/69 W-lJ259~B 11/16/90 W-Ul0772 01/07/91 37-022556 07/09/91 37-5<107<16 07/12/91 <I~-705230 OB/01/91 ~7-07337t 08/01/91 37-07337B- 06/0 \191.___31-5<10752 08112191 23-1<11670 08/12/91 23-141672 0~/19/91 37-036613 09,03/91 T 60-427320 10/03/91 37-096753 \0/21/91 ~7-0B7250 0<1/02/92 ~7-E082B86 05/01/92 ~B-22606B 0511B/92 13-110663 Ob/l~/92 --3-1-297~Gl 07/15/92 37-315B65 07/20/92 17-092235 07/~0/92 37-E293961 08/10/92 37-323743M 08/12/92 37-3268~~ 09/30/92 14<:8787B 09/~0/92 17-09435& 09/30/92 41-104B16 ACCT. NO. 031<15<1L AUGUST 16. 1993 PAGE 17001 A 37 PRO DATE CURRENT BILLING 09/'17/92 O;::/.!6/90 );UO~!90 01/03/91 05/30/91 07/01/91 05/31/91 05/2B/91. 06/07/91 OB/07/91 OB/07/91 08/12/91 08/22/91 10/0\/91 10/10/9\ 04/01/92 04/~7/92 04/21/92 OG/09/S2 07/07/92 07/1<1/92 07/;;9/f'l2 OB/O<l/92 OB/04/92 09/17/92 09/11/92 09/~~/9~ PAST OUE <11.66 676.63 98. 16 <12.75 2,255.78 106.10 -2~~: ~~- (l/0i-1tf-'ir 119. BO -276.63 227.33 51.74 128.09 266.52 . \ 8 4.83 81.50 427.68 27.95 839.33 50.89 156.<17 52. 16 fJl 71, 90-/'.,{ -:H'/'7j/ 4~.OO 279.B<I 90.42 89.00 ...-- r"'t"''''''n~r.~ I " '. I L...;.;.~t.,~i.i..~Ji: ~ 1- D II . . \, . . .. " . . .', - " . .., riLl CD_Y Sfim_ 9 !lY TRUCKING COMPANY, INC. 31 nfllN ITAUT, lOX 100, IT. JOHH.IUAV. UEAnOHT DID II , , - 766- 2727 U!EPHOHE 102-711-8131 EXEL LOGISTICS S TATE ME NT DATE PRO NUMBER 11/02/92 01/~5/93 OV01/93 0~/01/93 O~/15/93 W-U58015 02-378~23 W-U~2~15 37-49~606 37-E503367 0~/30/93 37-49424~ 05/10/93 10-296590 05/10/93 16-150331 05/19/93-~7-503993 06/Q4/93 3~-513856 - 06/09/93 37-52605~ ACCT. NO. 031454L AUGUST 16, 1993 CONTINUED PAGE 2 PRO DATE CURRENT BILLING 01/11/93 01119/93 04/06/93 03/23/93 04/1~/93 PAST DUE 975.82 49.10 ~65.65 ,:~:~~ tJ. ~-7r' I, 04/23/93 04/29/93 04/28/93 05(14/93 05/28/93 ..- ...- 06/01/93 47.95 33.92 188.78 51.77 -If:f6 . 80 40. 80-fJ~.f'I-'lf 9 'le-f?tp:; / 8'/0 ~I Y .00 GRAND TOTAL /..:.?/..?tJ.':< ~ f:P 1- r7Sf D. 5'"0 E;-d.t1 I 'd 10 Iq. 7 $" ~ ?m~ Y T D AMOUN T: 56.533.69 \, < .:'...: ( " Nov 15 2 30 fH '911 ~ q " OfllQ! 'Jf '.,,: ,.\'1tIOIlOTUY (,.Uf';jr;lL~~p CI.'~HTY "f ~HS1,.yp,'4 . (2 4d.JV V~ fsSL C;!. ~(04-f ~.~ /51J"7 Q) d- 1 jj ~. < .'~'- ....._~'~i'.,.,,'~.,,;,t.~"',::;.:,i~i'l'4 ~;~,}._cJ~.;f..u,'*"'..;:o.~-..ii.~"'.,..--",......-" . "'~-.....-.' . ~ ,.. . . I .. , ' , \ .. .......-- . r ... ~ lR - iE ~ "" ~ ~-.. ..,'- t.1 ~.:~~ "I t.,... r k.:o'.'~" ,'- Co:. ('"P l' -.... . , . ." J ~'l " , ," ~ 'ldl..l;" . , " ~ 1.1 ;".X;;" ~ . ~., '..1 -:r I. ~ U S '" ... :~ ~ 0.: .... e ... u.::d; .... ~ +' U'<! U . ~ '" t1 < lJ. :5 II: ;r: i:l0l~ ::> .. H., :z: - .. ~ ",... ~Uol .... .J ~ 1Il ~ .I~ ~o-l ~~ i:l U < !i >< '" H '" C ~ ;r: ;r: gl . . fj; ii~~~ i .~ 1Jl~ > ~ H ~~ g ~ i~"'.; r - II: ..:I ~ C <::l il ...,u ~ - .. . ~ ! fj; ~ ~ .- , , . ,. . v. EXEL LOGISTICS, INC., Defendant IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA No. 94-6519 CIVIL TERM ST. JOHNSBURY TRUCKING COMPANY, INC., Plaintiff ANSWER WITH NEW MATTER 1. Denied. After reasonable investigation Defendant is without knowledge or information sufficient to form a belief as to the truth of the averment and proof thereof is demanded. 2. Admitted. 3. Denied in that Defendant did not order, request or agree to the services, amounts and prices referred to on the Statement of Account attached to the Complaint as Exhibit 1. Further denied in that after reasonable investigation Defendant is without knowledge or information sufficient to form a belief as to the truth of the averment and proof thereof is demanded. 4. Denied. After reasonable investigation Defendant is without knowledge or information sufficient to form a belief as to the truth of the averment and proof thereof is demanded. 5. Denied. After reasonable investigation Defendant is without knowledge or information sufficient to form a belief as to the truth of the averment and proof thereof is demanded. 6. Denied. After reasonable investigation Defendant ia without knowledge or information sufficient to form a belief as to the truth of the averment and proof thereof is demanded. 7. Denied. After reasonable investigation Defendant is without knowledge or information sufficient to form a belief as to the truth of the averment and proof thereof is demanded. B. Denied. After reasonable investigation Defendant ia without knowledge or information sufficient to form a belief as to the truth of the averment and proof thereof is demanded. 9. Admitted that Defendant, as agent for various principals, paid St. Johnsbury Trucking Company, Inc., for transportation services rendered to Defendant's principals. Denied that Defendant paid any amounts on its own account and also denied that there is an unpaid balance due to Plaintiff. Further denied that after reasonable investigation Defendant is without knowledge or information sufficient to form a belief as to the truth of the averment and proof thereof is demanded. 10. Denied. After reasonable investigation Defendant is without knowledge or information sufficient to form a belief as to the truth of the averment and proof thereof is demanded. 11. Denied in that plaintiff had no agreement with Defendant to pay interest. Also denied that any interest is due in that after reasonable investigation Defendant is without knowledge or information sufficient to form a belief as to the truth of the averment and proof thereof is demanded. 12. Denied that any balance, interest or penalties are due and therefore also denied that Defendant willfully refused to pay amounts due. NEW MATTER 13. Exel LogistiCS, Inc., is an agent for various shippers of freight. 14. On all bills of lading, Defendant discloses its agency status. 15. Any freight services provided by plaintiff were for the principals of Defendant as disclosed on the documentation provided to Plaintiff. 16. Claims asserted under pro numbers 37-036813, 37-315865, 37-494606, and 37-494242 are duplicate billings on items previously paid to Plaintiff. 17. The claim averred is beyond the applicable statute of limitations with regard to pro number W-U25928 dated December 11, 1989. 18. Any items not on Dauphin Distribution Service Co. or Exel Logistics, Inc., bill of lading were shipped at the request of an entity other than Defendant and are the responsibility of that third party. 19. The claims are time barred for failure of the Plaintiff to comply with the credit regulations of the Interstate Commerce Commission, duly adopted and published as 49 CFR Part 1320. 20. invalid, referral The rates alleged by Plaintiff are unreasonable and and Defendant will file a separate Petition seeking to the Interstate Commerce Commission. 21. The Defendant is a public warehouseman. 22. The provisions of the Negotiated Rates Act of 1993, adopted as Pub. L. 103-180, December 3, 1993 (107 Stat. 2044), apply and as a public warehouseman, Defendant's liability is limited to five (5%) percent. 62/13/1995 15:52 DAVID H RADCLIFF PC PAGE 65 71 723&9354 . . . , .' ,~ . ~ I, ~ VBRIPICA~I~ 2)~~~ , verify that the .tatem.nt. made in the foregoing MIl_r are true and correct to tho beet of my know1edqe, information and belief. I under.tand that falee .tatement. herein are made .ubj.ot to the p.nalt!.. of 18 Pa. c.S. 54904 rolating to unllworn fallllfication to author it!.. . Date. ~!:i:L. Q~Ih/~ . ---- . truth of the averments contained in Paragraph 16 of Defendant's New Matter. Proof of the same is demanded at trial. 17. The averments contained in Paragraph 17 of Defendant's New Matter are conclusions of law to which no responsive pleading is required. If a response is deemed necessary, the same are denied. 18. Denied. After reasonable investigation, Plaintiff lacks knowledge or information sufficient to form a belief as to the truth of the averments contained in paragraph 18 of Defendant I s New Matter. Proof of the same is demanded at trial. The remaining averments contained in Paragraph 18 of Defendant's New Matter are conclusions of law to which no responsive pleading is required. If a response is deemed necessary, the same are denied. 19. The averments contained in Paragraph 19 of Defendant's New Matter are conclusions of law to which no responsive pleading is required. I f a response is deemed necessary, the same are denied. 20. The averments contained in Paragraph 20 of Defendant's New Matter are conclusions of law to which no responsive pleading is required. If a response is deemed necessary, the same are denied. 21. Denied. After reasonable investigation, Plaintiff lacks knowledge or information sufficient to form a belief as to the truth of the averments contained in Paragraph 21 of Defendant's New Matter. Proof of the same is demanded at trial. 22. The averments contained in Paragraph 22 of Defendant's New Matter are conclusions of law to which no responsive pleading is required. denied. If a response is deemed necessary, the same are 23. Denied. After reasonable investigation, Plaintiff lacks knowledge or information sufficient to form a belief as to the truth of the averments contained in paragraph 23 of Defendant's New Matter. Proof of the same is demanded at trial. 24. The averments contained in Paragraph 24 of Defendant's New Matter are conclusions of law to which no responsive pleading is required. denied. If a response is deemed necessary, the same are WHEREFORE, Plaintiff respectfully requests this Honorable Court to enter judgment in favor of plaintiff and against Defendant for the amount prayed for in Plaintiff I s Complaint, with costs assigned to Defendant. Respectfully submitted, BERNSTEIN AND BERNSTEIn, By I an s. Dagh Attorney 10 #47741 204 State Street Harrisburg, PA 17101 (717) 233-1000 DATE: ~/~"'f/qS -~,~-, "'$;w~.,+...-'i.'" ';.-.."..'...., "...;....". ''''',)". ;;,;:"...." ,,,. HAil 1 12 01 PH '95 :~ "t'flC~ ur ftli 1\~,ltj\j"~r.1f1r GtH{;[r;, .~!1{) ('C..l rr riu.1;'i'rI"',.HII~ . ,.. . . ~ .. , ~ ,",' ._~,- . ( ~ ~~ ~I ~ ~ a, g U . H r.. >< U O~ ~ 1-<0 In 8u i i~ 0 ~ ~ .. . , =: - 5 '", N' 0::> =- m ..... .... ..., " .. H fo-t bd fo-t U .... ::> ... IS .~ . al >< . o-i glua, gj~ ~~ ~~ .~ fn8 ~>- ~~ . .- ", ::.~ ~; ~.: :.~ , .' , . ..~ ~., .r ., , ". .~ .' . 01 > . .... U :a ~1l . .. U1fo-t U.. H~ H UI H 8 .:l . a, U1U .. . 0<>: H H< ua, ~O'I U1~ <>:51 o r..r.1 ..5 0<>: H f::el :O:~ .. ::> U ::l It " LL~8~ !!: 5 ~ ~ .J .. VI ~ U <( ~ Iii ~ ~d z lr z ~ is 0: ~ .. :i 0 III ci I: - a: C <( l:I il - on > ii c( a: o :i! ~ ;. . 1 , ''!l~'~;f:,\!. . \ ST. JOHNS BURY TRUCKING COMPANY, INC., Plaintiff IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA NO. 94-6519 CIVIL TERM va. I I I I I I I I I EXEL LOGISTICS, INC., Defendant ORDBR And now thia day of , 1995, upon preaentation and coneideration of the within Motion it is hereby ordered and decreed undar Rule 4019(0)(2) Pa. R.C.P. that Plaintiff may not introduce into evidenoe ahipping orders or other doouments regarding the goods alleged to have been shipped or the rates charged for the alleged shipmenta, the tariff authorities or other documents believed by Plaintiff to substantiate its claim (exoept for 14 freight bille provided to Defendant under date of September 8, 1995). BY TilE COURT I J. ST. JOHNS BURY TRUCKING COMPANY, INC., Plaintiff I I I IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA NO. 94-6519 : CIVIL TERM vs. . . I EXEL LOGISTICS, INC., Defendant RULE TO SHOW CAUSE AND NOW, this day of , 1995, upon presentation and consideration of the within Motion for Sanctions Under Rule 4019 Pa, R.C.P. does hereby order and direct that Plaintiff, st. Johnsbury Trucking Co., Inc. appear and show cause why sanctions should not be imposed under Rule 4019 PA R.C.P. for Plaintiff's failure to respond to a request for production or inspection made under Rule 4009 PA R.C.P. This rule returnable in daya. BY THE COURT: J. ST. JOHNS BURY TRUCKING COMPANY, INC., Plaintiff IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA NO. 94-6519 CIVIL TERM vs. EXEL LOGISTICS, INC., Defendant REOUEST FOR PRODUCTION OF DOCUMENTS To: St. Johnsbury Trucking Co., Inc. % Christian S. Daghir, Esquire Bernstein & Bernstein, P.C. 204 State Street Harrisburg, PA 17101 Exel Logistics, Inc. requests through its attorney, David H. Radcliff that you produce the documents herein specified at the offices of the undersigned attorney on or before July 12, 1995, in accordance with Pa, R.C.P. No. 4009: A. CONSTRUCTION These requests shall be construed in accordance with the Pennsylvania Rules of Civil Procedure. Other terms used herein shall have the same meaning as they have when used in the pleadings. In addition, the following words shall have the meanings stated herein: 1. "Communication" or similar words shall mean all statements, admissions, denials, inquiries, discussions, conversations, negotiations, agreements, contracts, understandings, meetings, telephone conversations, letters, correspondence, notes, telegrams, telexes, advertisements, facsimile transmissions or receipts, or any other form of written or verbal intercourse. 2. "Describe, description" or similar words shall mean to give a detailed narrative description, giving all particulars known by you. 3. "Document" shall mean the original or a copy of any written, printed, typed, or other graphic matter of any kind or nature, including those items that are stored in a non-graphic form, but which can be retrieved and transferred to a graphic form, and any other similar tangible thing in your custody or control. When used with reference to an occurrence or event, it shall Exhi bit 1 B. INSTRUCTIONS 1. If you claim any privilege not to answer or respond as requested, identify each matter to which you claim the privilege, the nature of the privilege, and the legal and factual basis for the claim of privilege. If any documents sought by this request for production is withheld from production based upon a privilege not to answer or for any other reason, you are to identify said document in your response to this request by stating its nature (letter, memorandum, etc.), date, author, and each recipient. 2. If you cannot answer or respond as requested in full, answer or respond to the extend possible, and specify the reasons for your inability to answe~ or respond fully. C. SPECIFIC REQUESTS please produce copies of the following and verify the copies to be true and correct copies of the originals: 1. The original shipping order. Any document containing a description shipped for each shipment alleged in the not fully and accurately presented on order) . 3. Any document stating the quantity of goods shipped for each shipment alleged in the Complaint (if not accurately presented on the shipping order). of the goods Complaint (if the shipping 2 . 4. Any document stating the point of origin and the point of destination for each shipment alleged in the Complaint (and points of stop-off for pickup and delivery, if pertinent) . Any document stating the classification or exception rating assigned the goods, in the case of class rates, for each shipment alleged in the Complaint. 6. Any document stating the mileage from origin to destination (via stop-off points, if pertinent) in the case of mileage rates, for each shipment alleged in the Complaint. 5. 7. Any document stating the discount factor, if any, applied in the original billing compared with the discount factor, if any, applied in re-billing, for each shipment alleged in the Complaint. 8. Any document stating the per-unit line-haul rate as originally billed compared with the per-unit line-haul rate as re-billed, for each shipment alleged in the Complaint. 9. Any document stating the rate or charge for accessorial services, if any, originally billed compared with the rate or charge for accessorial services as re-billed, for each shipment alleged in the Complaint. 10. Any document stating total shipment charges as originally billed compared with total shipment charges as re-billed, for each shipment alleged in the Complaint. 11. Complete tariff authority (e.g., item number, page number, rule number, etc.) or specifically cited tariffs (all) used in the calculation of applicable rates and charges as originally billed and as re-billed. '" '" '" 0 '" '" '" .. '" N '" N CD ~ ~ .. 0\ III III III 0 '" CD .. N III III .. 5- '" ~ 0\ N ~ CD '" N '" N CD ~ III CD '" 0 '" ~ '" M ... ~ CD ... '" 0 N III ~ .. 0 CD 0\ .. 0\ 0\ '" 0\ N ... N '" U 0 III III 0 0 III ... N '" ... '" III 0 N I I I I I I I I I I I I I I ~ ~ ~ ~ ~ ~ ~ ~ ~ ~ ~ ~ ~ ~ M M '" M M M M M M M M M M M n .. '" '" .. M N M N .. .. .. 0\ ..... '" M '" N '" '" '" 0\ .. '" 0\ .... ~ ..... 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H H H H 11 ... <I 0 " . . .<1 11 u . ll\ ~ <I <l <l <l . .<I . ll\ "" 0 t: 0 0 0 0 " U <l ... .... .... . ... ... ... ... ... Gl ... ... Gl Ql 'il e <l ~ ... ... ... .. .... ~ .... k il 0 ... <I <I " <I III k .... .<I " ~ ,Q ~ ~ :J: 0 Gl .... . u 0 ~ ... iZl III ... :a . fi lJ tJ lJ tJ . u l> " f< l>l . . Ql ~ '" ... <l . H .. " " " " " ~ c:l Ql ., . ... ... ... '.. . ... ... . l> Gl , " l:l l:l c:l l:l 9 Jl III 0 ., ~ .'J '.. k .... u ... U Gl Ql Gl Ql Gl ... ~ III <l I Gl III <l <l ] l> l> l> l> k ... .>: Gl R '.. ... ... ... i . ~ <I .. ll\ " " " " l.l k III 0< '" " " " " ~ 0 k Ql 0 Ql Gl Gl Ql .<I .... III U ... .~ 0 ~ ~ ~ ~ 0 110 ~ tl k ., k ll\ ... III .... III ~ ~ u 0 0 e 0 e u " .... Ql ... 'il k k k ... 0 ... :J: '" III W '" '" '" '" l:l l> ., III . IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL DIVISION ST. JOHNS BURY TRUCKING COMPANY, INC. plaintiff vs. Civil Action No. 94-6519CIVILTER~ EXEL LOGISTICS, INC. Defendant PRAECIPE TO SETTLE DISCONTINUE AND ~ TO THE PROTHONOTARY OF CUMBERLAND COUNTY: Settle, Discontinue and End the above-captioned matter upon the records of the Court and mark the costs paid. ay: At rneys for Pl 1133 Penn Avenue pittsburgh, PA 15222 (412) 456-8100 Sworn to and subscribed before me this ~ i//.tc. day of .t:1!c.{~C ,1996 "iLl. (_fl. V-3u~~. No NOl3 a s.,~'" Public Ch.",l A. Bauer. Nolo CouolV P\"'bUr~, "'~~t.:. ~lI\Y 22. 2000 My comml's 00 ,1100 01 Nol3118S AnOsyl-vanl3 M~O\,I om er, V" ~............_..-..............,..._.__. . -_..~ '. ~";'.:.'~C:.:....~" AlEO-Ol-'F1CE OF TjJf: rrr1n1nNOTtRY 96 NOV"6 PH 3: "'0 CUMbi:HU';;CI CGUN1Y PENNSYLW.t-l1A " ~--......"",.....-...~~ '-Wlft1 ~ '" ~ ~ . ., ~ , .' , " , ' , . , " " j ",'''",': ..~~ .'.--, :. . r