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BUR-L-000267-23 02/06/2023 12:27:19PM Pglof8 Trans ID: LCV2023463052
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HUDSON LAW OFFICES, PC
LAURI A. HUDSON*
ATTORNEYS AT LAW * Member ofNJ & PA Bar
1760 Market Street, Suite 400
Philadelphia, Pennsylvania 19103
WASHINGTON PROFESSIONAL CAMPUS
900 ROUTE 168, SUITE C-2 Reply To: *Tumersville Address
TURNERSVILLE, NEW JERSEY 08012
(856) 228-7600 FAX (856) 228-7621
lawyers@hudsoncollects.com | www.hudsoncollects.com
January 26, 2023
Clerk, Law Division
Burlington County Superior Court
49 Rancocas Road
Mount Holly, New Jersey 08060
Via eCourts Filing System
RE: Guttman Energy, Inc. vs. Philadelphia Truck Lines Inc.; and Sean Piscitelli
Our File No. 2200344
Dear Sir/Madam:
Attached is a Complaint with regard to the above captioned matter. Please file same and debit our
account number 140905 in the sum of $250.00 representing your fee for filing.
If you have any questions or require any further information, please do not hesitate to contact me.
Very truly yours,
HUDSON LAW OFFICES, P.C.
/s/ Lauri A. Hudson
Lauri A. Hudson, Esquire
For the Firm
LAH/ctl
Enclosure
BUR-L-000267-23 02/06/2023 12:27:19PM Pg2of8 Trans ID: LCV2023463052
Lauri A. Hudson, Esquire - Attorney ID 024211989
HUDSON LAW OFFICES, P.C.
Washington Professional Campus
900 Route 168, Suite C-2
Turnersville, New Jersey 08012
Phone: (856) 228-7600
Email: lawyers@hudsoncollects.com
Attorneys for Plaintiff
Guttman Energy, Inc. SUPERIOR COURT OF NEW JERSEY
200 Speers Street LAW DIVISION
Belle Vernon, Pennsylvania 15012 BURLINGTON COUNTY
Plaintiff CIVIL ACTION
vs. DOCKET NO.
Philadelphia Truck Lines Inc.; COMPLAINT
and Sean Piscitelli
106 Greenbrook Drive
Marlton, NJ 08053
Defendants
The Plaintiff, Guttman Energy, Inc., by way of Complaint against the Defendants,
Philadelphia Truck Lines Inc.; and Sean Piscitelli, alleges and says:
FIRST COUNT
1 Plaintiff has a principal place of business and/or resides at 200 Speers Street,
Belle Vernon, Pennsylvania 15012.
2. The Defendants, Philadelphia Truck Lines Inc.; and Sean Piscitelli, have a
principal place of business and/or reside at 106 Greenbrook Drive, Marlton, NJ 08053.
3 The Plaintiff sold and or delivered goods and/or services to the Defendants.
4 The Defendants failed to pay for all or a portion of the amount due for such
goods and/or services.
5 In accordance with the Agreement/Contract/Invoice, Defendants have
agreed to pay Plaintiff, in the event of default, interest at the rate of 18% from the day of
default, and reasonable collection and/or attomey’s fees. Plaintiff submits that 15% of the
unpaid principal is a reasonable collection and/or attorney's fee.
6 This outstanding amount is a book account that is still due and owing to the
Plaintiff from the Defendants.
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WHEREFORE, Plaintiff demands judgment against the Defendants in the amount of
$39,293.26, together with interest at the rate of 18% from April 20, 2022 through the filing of
the Complaint, January 26, 2023, in the amount of $5,442.97, with a per diem thereafter of
$19.37, attomey’s fees in the amount of 15% of the unpaid principal in accordance with the
Agreement/Contract/Invoice in the amount of $5,893.98, for a total due Plaintiff of
$50,630.21, together with attorney’s fees, interest and costs of suit.
SECOND COUNT
1 Plaintiff repeats and reiterates the allegations made in the First Count as if
more fully set forth herein at length.
2. Defendants have received certain goods and/or services from the Plaintiff
and have failed to pay for same.
3 Plaintiff is seeking to recover the reasonable value of the goods and/or
services delivered to the Defendants.
WHEREFORE, Plaintiff demands judgment against the Defendants in the amount of
$39,293.26, together with interest at the rate of 18% from April 20, 2022 through the filing of
the Complaint, January 26, 2023, in the amount of $5,442.97, with a per diem thereafter of
$19.37, attorney’s fees in the amount of 15% of the unpaid principal in accordance with the
Agreement/Contract/Invoice in the amount of $5,893.98, for a total due Plaintiff of
$50,630.21, together with attorney’s fees, interest and costs of suit.
THIRD COUNT
1 Plaintiff repeats and reiterates the allegations made in the First and Second
Counts as if more fully set forth herein at length.
3.2 The Defendants promised to pay for the goods and/or services delivered by
the Plaintiff.
3 The Defendants failed to pay for such goods and/or services delivered by the
Plaintiff thereby breaking the agreement or contract between the parties.
4. As a result of the Defendants’ breach the Plaintiff has been damaged.
WIIERIFORE, Plaintiff demands judgment against the Defendants in the amount of
$39,293.26, together with interest at the rate of 18% from April 20, 2022 through the filing of
the Complaint, January 26, 2023, in the amount of $5,442.97, with a per diem thereafter of
$19.37, attorney’s fees in the amount of 15% of the unpaid principal in accordance with the
Agreement/Contract/Invoice in the amount of $5,893.98, for a total due Plaintiff of
$50,630.21, together with attorney’s fees, interest and costs of suit.
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FOURTH COUNT
1 Plaintiff repeats and reiterates the allegations made in the First, Second and
Third Counts as if more fully set forth herein at length.
2. The Defendant, Sean Piscitelli, personally guaranteed the amount due to
Plaintiff from the co-Defendant.
WHEREFORE, Plaintiff demands judgment against the Defendants in the amount of
$39,293.26, together with interest at the rate of 18% from April 20, 2022 through the filing of
the Complaint, January 26, 2023, in the amount of $5,442.97, with a per diem thereafter of
$19.37, attorney’s fees in the amount of 15% of the unpaid principal in accordance with the
Agreement/Contrac/Invoice in the amount of $5,893.98, for a total due Plaintiff of
$50,630.21, together with attorney’s fees, interest and costs of suit.
DESIGNATION OF TRIAL COUNSEL
Lauri A. Hudson, Esquire of Hudson Law Offices, P.C. is hereby designated as
Trial counsel with regard to the above captioned matter.
HUDSON LAW OFFICES, P.C.
Attorneys for the Plaintiff
/s/ Lauri A. Hudson
Lauri A. Hudson, Esquire
For the Firm
Dated: January 26, 2023
Our File No.: 2200344
CERTIFICATION OF NO OTHER ACTIONS
Pursuant to Rule 4:5-1, it is hereby stated that the matter in controversy is not the
subject of any other action pending in any other court or arbitration proceeding to the best of
our knowledge or belief. Also, to the best of our knowledge or belief, no other action or
arbitration proceeding is contemplated. Further, other than the parties set forth in this
pleading, we know of no other parties that should be joined in the above captioned matter.
In addition, we recognize the continuing obligation of each party to file and serve on all
parties and the Court an amended certification if there is a change in the facts stated in this
original certification.
¢s/ Lauri_A. Hudson
Lauri A. Hudson, Esquire
BUR-L-000267-23 02/06/2023 12:27:19PM Pg5of8 Trans 0: LCV 2023463052
20034
& GUTTMAN ENERGY f
Page i 2
Guttman Enetgy/Fielman
Credit Application and Customer Agreement
Fol Name of Firse
Tee
ees led \evster “Veale Line, Dory
Sinte
big - pate Wey
Zip.
Sve isc Ox Se DP. SaleesG: QA Mn32 hi 822 S6%Y
‘Bteeet Address State Zip
= Sci vat ea. NNews\
— Flom Once Address St City State, Tip
Federal Tex ID: BIC Coda:
Ph nea
| CHECK APPROPRIATE BOX AND PROVIDE INTORMATION —
ErCorparciton Cy Subatiimy of [1] Division of ‘Naane wml Ads
RE QUESTED:
ent Company Parent Comping Pareit Company
C1 Préprictorship # Yrs in Duilness 30D
J 1 Partnership ‘Type of Busthess dian
9 aad eetehs: 0)
HeJe | Other (Explain), “Tale
PLEASE LIST NAME(S) OF CORPORATE OFFICERS:
* Ni 2 Oe Ad@ress
seeilt See =e cea ident
Nerve, dress,
Seve Piscyelti Se Abice Pees deny
PLEASE LIST NAME(S) AND ADDRESS(ES) OF PROPRIETOR OR PARTNE
RS:
MME eee T Bysiness All @ Bere WN, Telf 6 1 ~ 20S ORO SS
£ Sacdoo it Lif. Ne. Neary N02 Vos? 2-3
Ooen
Previous Reap
How ZC. Montbly Net income 25a, c1s (fin Business
less ehan 1 yr)
t Lang? ‘Omer Jnconie
Rank Narar and Braveh City
ae ‘State
‘Narae of Dank Officer
NS
Account # Tel Fax
z eure Becenedres Sty S~<0) 42s £7749
Refertnce Address WAWecteignia, PA Te
5
aye
Reference
Tees stdin Ss. Ws 9. Veeticlost. ys) 336- asa) SS 4887
Adldreet Sra
Ccerin Seredl 3 Sons PO Box WY eiskel OAS Fa) 52 na) 7a ine
Reference
one er Mae sit 4 Von As RIO She. aX On feaaste wantin) Seb Wed
Monthly Usige Estimate
faadenge- Rainher
af Vebleley: > Number ofDsiverss 10
Person to ¢oblact regarding arrungenuenis
for cards: Tt i
Freall
Boh Ceote (hyo). 8 32 -N&Y hobe Mh UnOS fe cor
xX
AGREEMENT AND GUARANTY ww
Liiawé made tie above stitemeats for ke pauposeof ob:etain genet. Lcertify thoy ate ruc andesiteyou tom cred e.
investiatio. Billings
or:
weekly and paynicitt will be duc in full within 10 days ofin ine date: Taree
ielinguent balances. This agwemcaticelodesthe tems and c ‘énditions to pay a inte chargeof U8 pes moll (18% px year) af 50s. uiiaiuuny shall befowell
on any Ww
company. Tpersona drthe reverse side heveot auntis estab ished
ja tic name of ye
puarantes payancat
liy ofthe account. All purthaieg made on thisaccount-wall bs for commercial
use.
SIGNED: TITLE: DATE:
eae frog the nel Constialler Va /\S
, BUR-L-000267-23 02/06/2023 12:27:19 PM Pg 6of8 Trans ID: LCV2023463052
. &) certian ERWERGY Page 2 of 2
Additional Terms
Supplier; Guttman Enerpy
rurcuasir: ? Wiladdlowic “Jeucle Lines “Und.
SIGNED: $4.24 Alte d. pate: \f 2.) AS
‘Timeis of the esseace ofthis agreemant.
Miniinum‘monthly purchases of400 gations Tequire
Furchaser shall be responsible for all purchases by d.Purchasér
or anyother
Tegardless of whether use‘by any ofher person Is wn: authorized or fraudulent. persons using cardlock cards issued to Purchaser,
If there is any change iri awncrsiiip.cf Purchaser or if substantially all of the asscts
Promptly notify Supplier of such sale and Siipplier shall Have a lien onall of Purchaser.sre-sold, Purchaser shalt
such sale the aasets of Purchaser-and a licw on the proceeds of
to secure payment of all outstandin; ig Sums OWingto Supplter.
a Purchaser vepretints that any. porson ising the.cardlock cards. delivered
of tlie cardlock system and shall nie safé Dracti¢es ini:compliance with thetoregulation
Purchaserare and shall be: aware of the proper usc
s of the local Fire Code ia the handling-of
the fuels dispensed from the cardlock 53 stein. Purchaser agrets’ to inderinify
, hold bacmless and defend Supplier Horn and
against any-and-all liabilit y damnge or expense for which Suppler may 'be held liable by reason of-injory Gocluding
far loss;,
dcath) to ay person (ncledingPui ehaser’ ‘s employe s) or damage to any props erty atising out of or in any maneer connected
With the: use of the cardicck system Guhether the. injury or damage occurs
at the édrdlock site.or wot), whether or not duc in
Whole of fn bart tO any act, omission; ‘or negligence of Supplieror any of their Tepresentatives, eniployees,-ather Purthasers:or
thi parties; whether known or-usikn nown to Supplier or Purchaser. It is expressly understood and agreed thar th ie indemnity
‘contained: in this paragraph.covers'¢) laims ‘by Purchater’s‘employees. It is further expressly agreed that Purchaser assumes thé
fullest extent of all obligations to i indemnify and defend Grtman Oil Comp any (whether oF riot such obligations may extend tn
items beyond those addressed in ‘this Agreement). Purchaser and Supplier further agree that the Laws of the Commonwealth of
Pennsylvania shall apply to the construction and opplication of the Indemuification and Hold Harmless
abave. Agreements set forth
Supplier shall use its best efforts te maintain the cardiock
system
hawever, Supplier shall-not be responsible for any damage or Iosin 6good working order and condition at its expense, Pptovided,
which mmy result from its failure to. provide fuel or the
failure of the ¢andiock system in'any. manner whatsoever, Pi urchaser agrces that it and any. pecson using
delivered to Purchaser shall promptly aotify Supplier of any malfunctioning of
the cardlock cards
the cardiléck system of which Purchaser or
such person.is.awaro.
Purchaser's right to purchase ‘fel thtough the cardlock system viey be terminated
immediate) ly upon any ‘breach of any of the,
terms hercof or of euy other agreement: with Sugplier-and may be terminated upon
termivation, Purchaser agrees to immediately surrender all cardiock cards issu
outstanding sums owing to Supplier.
30 days notice to citlier party. Upon
ed to Piichaser and ta immediately pay al)
NS
Tn the event of a breach of any of the terns of this agreoment
includirig but expressly not limited te the failure to pay-sums owiagor any other dgricment betwen Furchaser and Supptier,
to-Supplter when due, then in addition to cay other sums
dué-or payable to Supplier by Purchaser, Purchaser egrees to pay the, ccasonebile atom cy fees and costs incurred by Supplier
in the enforcement of Supplier's rights even: though no. suitor actionis Aled a SuitGt délio WW 4
if Hiled
n to enforce the rights of
Supplier, thea such farther gum as the courtmn: ay adjudge reasonable as‘attomt
in adgition‘to ali other suns provided by law.
ey fees at trial or dn appeal af such suit or action ef
Ni
Please: return to:
Guitman Energy
Card Access Division
200 Speers Street
Belle Vernon; PA 15012-1098
Phone: 1-800-245-5955
Fax: 724-483-5226
, BUR-L-000267-23 02/06/2023 12:27:19 PM Pg7of8 Trans ID: LCV2023463052
AUTOMATED COLLECTION/D
ISBURSE MENT DEPOSIT
AUTHORIZATION
ft hereby autho
fC rize Guttman Energy to ini itiate credits or
debits)to the ir istit ution indicated below. The i stitutio debits (and/or corrections te the Previous credits or
Account. The. authority Is to remai n is authorized to credit/debit and,
n in Full fo: ce and effe Hor correct the amounts to my
manner as.to afford the institution ct uriti I. revoke In writing
a reasonable: ‘Opportunity to act-on In such time (10 days) and such
it,
Be —_
PLEASE PLACE VOIDED CHECK
Financial Testtution @ank>Savings & Loa
Ceean
k Unio —=
, ns ‘Type of Account— Circle One
address VO Spilnedate Roonuel
1) Checking; 2) Savings
City: Cheeey SALA States tyS. Zip: OFoo03 3) Other bs as
— ||
Financial Tastitution Housing
Number
Financial Institution Account Number I
[ Company Name;
Prrradelphiarovdk Lanes rr
Street Address: Se ‘ocial Security Number of Tax
LD. Number:
Siq Kewtsce Oc- Svc ©.
City, State & Zip Code: ____]
LSelcco PA \Ge32
| lease indicate: ho: w you would like to receive draft
hotifications: alt [Fax 0] Both
Authorized Custonter Signature:
Email address(es):
Name: Sec v ‘serve?
S