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  • Guttman Energy Inc Vs Philadelphia Truck LinesBook Account (Debt Collection Matters Only) document preview
  • Guttman Energy Inc Vs Philadelphia Truck LinesBook Account (Debt Collection Matters Only) document preview
  • Guttman Energy Inc Vs Philadelphia Truck LinesBook Account (Debt Collection Matters Only) document preview
  • Guttman Energy Inc Vs Philadelphia Truck LinesBook Account (Debt Collection Matters Only) document preview
  • Guttman Energy Inc Vs Philadelphia Truck LinesBook Account (Debt Collection Matters Only) document preview
  • Guttman Energy Inc Vs Philadelphia Truck LinesBook Account (Debt Collection Matters Only) document preview
  • Guttman Energy Inc Vs Philadelphia Truck LinesBook Account (Debt Collection Matters Only) document preview
  • Guttman Energy Inc Vs Philadelphia Truck LinesBook Account (Debt Collection Matters Only) document preview
						
                                

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BUR-L-000267-23 02/06/2023 12:27:19PM Pglof8 Trans ID: LCV2023463052 ana 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. BUR-L-000267-23 02/06/2023 12:27:19PM Pg3o0f8 Trans ID: LCV2023463052 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. BUR-L-000267-23 02/06/2023 12:27:19PM Pg4of8 Trans ID: LCV2023463052 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