1}. DONALD N. TURNER ATTORNEY AT LAW THE BANK TOWER SUITE 510 307 FOURTH AVENUE PITTSBURGH, PA 15222 (412) 281-3823 (412) 281-3837 (Fax) October 14, 2015 Janitorial Resources, Inc. t/a North Shore Shuttles, LLC 1912 Brighton Road Pittsburgh, PA 15212 Respondent Ray F. Middleman, Esquire Paul S. Guarnieri, Esquire 11676 Perry Highway, #3100 117 VIP Drive, l s l Floor Wexford, PA 15090 Tricia L. Davis, Esquire 651 Holiday Drive Foster Plaza Building #5 Pittsburgh, PA 15220 Jeff A. Hollowood, Esquire Gaitens Tucceri & Nicholas 519 Court Place Pittsburgh, PA 15219 Eustace O. Uku, Esquire 214 Farmington Road Pittsburgh, PA 15215 RE: Harry Williams, Jr., Administrator of the Estate of Harry Williams, Sr. v. Janitorial Resources, Inc. t/a North Shore Shuttles, LLC PA Public Utility Commission No. A-8913963 and A-2014-2407338 To the above: Please be advised that the enclosed Petition to Recind Approval of License Issued to Janitorial Resources, Inc. t/a North Shore Shuttles, LLC, has been filed with the Public Utility Commission. If you have any questions, I can be reached at the above telephone number. My regards, DNT/pag Enclosure NOV 0 9 2015 SECRETARY'S BUREAU Donald N. Turner
ENNSYLVANIA PUBLIC UTILITY COMMISSION MARRY WILLIAMS, JR., Administrator of the Estate of Harry Williams, Sr., Petitioner, vs. No.: A-8913963 A-2014-2407338 NORTH SHORE SHUTTLES, LLC, Respondent. TYPE Ol 7 PLEADING: PETITION TO RECIND APPROVAL OP LICENSE ISSUED TO NORTH SHORE SHUTTLES, LLC PILE ON BEHALF OF: Harry Williams, Jr., Administrator of the Estate of Harry Williams, Sr.J'eiUioner COUNSEL OF RECORD: DONALD N. TURNER ATTORNEY AT LAW THE BANK TOWER, SUITE 510 307 FOURTH AVENUE PITTSBURGH, PA 15222 412-281-3823 FAX 412-2S1-3837 ATTORNEY STATE\Dli 18809
PENNSYLVANIA PUBLIC UTILITY COMMISSION HARRY WILLIAMS, JR Administrator of the Estate of Harry Williams, Sr., Petitioner, vs. NORTH SHORE SHUTTLES, LLC, NO. A-8913963 A-2014-2407338 Respondent. CERTIFICATE OF SERVICE certify that on. ~/A, 2015, my office mailed true and correct copies of the PETITION TO RECIND to the following: Janitorial Resources, Inc. t/a North Shore Shuttles, 1.912 Brighton road Pittsburgh, PA 15212 Respondant,LC Eustace O. Uku Attorney at Law 214 Farmington Road Pittsburgh, PA 15215 FAX (412) 772-10511 Malone Middleman, P.C. Wexford Professional Bldg. Ill 1.1676 Perry Highway, Suite 3100 Wesford, PA 15090 Phone: (724) 934-6888 Attorney Yellow Cab Co. Rosemary Chiavetta, Secretary Pennsylvania Public Utility Commission 400 North Street Harrisburg, PA 17120 % NOV 0 9 2315 SECRETARY'S 3JK AU Donald N. Turner Attorney for Petitioner. DNT/tma 11/9/1.5 2:52PM
PENNSYLVANIA PUBLIC UTILITY COMMISSION HARRY WILLIAMS, JR., Administrator of the ) Estate of Harry Williams, Sr. ) Petitioner, ) No. A-8913963 ) A-2014-2407338 vs. ) ) ) NORTH SHORE SHUTTLES. LLC, ) Respondent. ) PETITION TO RECIND APPROVAL OF LICENSE ISSUED TO JANITORIAL RESOURCES. INC. t/a NORTH SHORE SHUTTLES. LLC AND NOW comes Petitioner, Harry Williams. Jr., Administrator of the Estate of Harry Williams. Sr., by and through his attorney. Donald N. Turner, Esquire, and respectfully states: 1. That Petitioner, Harry Williams, Sr., was the owner of Eagle Taxicab Co. located in Pittsburgh, PA, operating under PUC ecrlificalc numbers A-00102568F0003 and A- 00102568F003AMB. 2. That on January 21, 2014. Janitorial Resources. Inc. t/a North Shore Shuttles. LLC (hereinafter "JR1 and NSS," respectively), entered into an Asset Purchase Agreement with Harry Williams, Sr., owner of Eagle Taxicab Co., for the purchase of assets of Eagle Taxicab Co, which would include certificates issued at A-00I02568F0003 and A-00I02568F003AMB. 3. That in order to complete the license transfer, the parties had to seek approval of the Public Utility Commission (hereinafter "PUC").. which was done prior to closing. 4. That on August 21, 2014, the PUC approved the license transfer subject to compliance with the PUC Order. NOV 0 9 2015 SECRETARY'S BUREAU
5. That after the approval of the transfer by the PUC, a closing was to take place, but was never scheduled. 6. That Respondent, JRI l/a NSS, failed to secure the funding and has been operating having never paid for the license as required by the Agreement. (Sales price $90,000.00.) 7. That Respondent had indicated prior to approval of license transfer funding was in place and approval by the PUC could be requested. 8. That Many Williams, Sr., died on July 13, 2014, and letters of administration were taken out on his estate on June 4, 2015, in the Court of Common Pleas of Allegheny County, Orphans' Court, at No. 021502793, designating Harry Williams, Jr., as Administrator of the Estate of Harry Williams, Sr. WHEREFORE, Petitioner, Harry Williams, Jr., as Administrator of the Estate of Harry Williams. Sr., requests that the license issued to Respondent, JRI t/a NSS, be recinded. Respectfully submitted. ate: iq^h-fi Donald N. Turned, Esquire Counsel for Petitioner, Harry Williams, Jr., Administrator of the Estate of Harry Williams, Sr. NOV 0 9 Z015 SECRETARY'S BUREAU
PENNSYLVANIA PUBLIC UTILITY COMMISSION HARRY WILLIAMS, JR., Administrator of the Estate of Harry Williams, Sr. Petitioner,, No.: A-8913963 A-2014-2407338 vs. NORTH SHORE SHUTTLES, LLC, Respondent. VERIFICATION I verify that the facts set forth in the petition are true and correct to the best of my knowledge, information, and belief. I understand that false statements herein are made subject to the penalties of 18 Pa. CS. 4904, relating to unsworn faslsification to authorities. DNT/tma NOV 0 9 2015 SECRETARY'S BUREAU
PENNSYLVANIA PUBLIC UTILITY COMMISSION HARRY WILLIAMS, JR., Administrator of the Estate of Harry Williams, Sr.. Petitioner, vs. No. A-8913963 A-2014-2407338 NORTH SHORE SHUTTLES, LLC,, Respondent. ORDER AND NOW, this day of 1, 2015, in consideration of the foregoing PETITION TO RECIND APPROVAL OF LICENSE ISSUED TO JANITORIAL RESOURCES, INC. t/a NORTH SHORE SHUTTLES, LLC, it is ORDERED that license transfer from Harry Williams. Jr. to Janitorial Resources. Inc. t/a North Shore Shuttles, LLC, is hereby recinded and PUC certificate numbers A-00102568F0003 and A-00102568F003AMB are restored to the Estate of Harry Williams, Sr. BY THE COMMISSION:
7015 OtiHO OQOb 7 c im 57=11 DONALD N Ti rrner ATTORNEY AT LAW BANK TOWER SUITE 510 307 FOURTH AVENUE PITTSBURGH, PA 15222 1000 // / 17120 HOSTAGE P, V 5 URGH, PA AMOUNT R2305M146483^2 ROSEMARY CHIAVETTA, SECRETARY Public Utility Commission 400 North Street Harrisburg, PA 17120