102 Service of notice of motor carrier formal complaints

PENNSYLVANIA PUBLIC UTILITY COMMISSION

Service of Notice of Motor Carrier Formal Complaints

[44 Pa.B. 301]
[Saturday, January 11, 2014]

 Formal complaints have been issued by the Pennsylvania Public Utility Commission. Answers must be filed in accordance with 52 Pa. Code (relating to public utilities). Answers are due January 27, 2014, and must be made with the Secretary, Pennsylvania Public Utility Commission, P. O. Box 3265, Harrisburg, PA 17105-3265, with a copy to the First Deputy Chief Prosecutor, Pennsylvania Public Utility Commission.

Pennsylvania Public Utility Commission, Bureau of Investigation and Enforcement v. G & T Cab Company;
Doc. No. C-2013-2381965

COMPLAINT

 The Pennsylvania Public Utility Commission (Commission) is a duly constituted agency of the Commonwealth of Pennsylvania empowered to regulate public utilities within the Commonwealth. The Commission has delegated its authority to initiate proceedings which are prosecutory in nature to the Bureau of Investigation and Enforcement. Pursuant to that delegated authority and Section 701 of the Public Utility Code, the Bureau of Investigation and Enforcement Prosecutory Staff hereby represents as follows:

 1. That G & T Cab Company, Respondent, maintains its principal place of business at 2079 Red Lion Road, Philadelphia, PA 19115.

 2. That Respondent was issued Certificates of Public Convenience by this Commission on October 4, 1994 at A-00111025 F. 3, and on September 21, 1994 at A-00111025 F. 4.

 3. That by Secretarial Letter issued on July 8, 2011 at C-2010-2133706, Respondent was directed to pay a civil penalty of two hundred fifty dollars ($250.00). To date, Respondent has not submitted any payment to this Commission.

 4. That Respondent failed to pay fines totaling two hundred fifty dollars ($250.00) and violated 66 Pa.C.S. § 501(c) for failing to observe, obey and comply with the Secretarial Letter issued on July 8, 2011 at C-2010-2133706.

 A Certificate holder has an obligation to comply with the Commission's rules and regulations. A Certificate of Public Convenience is neither a contract nor a property; it is a privilege. Where that privilege is violated, the Commission may, for due cause, exercise its power to revoke a carrier's privilege to operate. Paradise v. Pennsylvania Public Utility Commission, 132 A.2d 754, 184 Pa. Superior Court 8 (1957).

 Wherefore, the Bureau of Investigation and Enforcement Prosecutory Staff hereby requests that the Commission issue an Order which revokes the Certificates of Public Convenience held by Respondent at A-00111025, Fs. 3 and 4.

 Respectfully submitted,
 
 David W. Loucks, Chief
 Motor Carrier Enforcement
 Bureau of Investigation and Enforcement
 P. O. Box 3265
 Harrisburg, PA 17105-3265

VERIFICATION

 I, David W. Loucks, Chief, Motor Carrier Enforcement, Bureau of Investigation and Enforcement, hereby state that the facts above set forth are true and correct to the best of my knowledge, information and belief and that I expect that the Bureau will be able to prove same at any hearing held in this matter. I understand that the statements herein are made subject to the penalties of 18 Pa.C.S. § 4904 relating to unsworn falsification to authorities.

Date: 9/5/2013
David W. Loucks, Chief
Motor Carrier Enforcement
Bureau of Investigation and Enforcement

NOTICE

 A. You must file an Answer within 20 days of the date of service of this Complaint. The date of service is the mailing date as indicated at the top of the Secretarial Letter. See 52 Pa. Code § 1.56(a). The Answer must raise all factual and legal arguments that you wish to claim in your defense, include the docket number of this Complaint, and be verified. You may file your Answer by mailing an original to:

    Rosemary Chiavetta, Secretary
    Pennsylvania Public Utility Commission
    P. O. Box 3265
    Harrisburg, PA 17105-3265

 Or, you may eFile your Answer using the Commission's website at www.puc.pa.gov. The link to eFiling is located under the Filing & Resources tab on the homepage. If your Answer is 250 pages or less, you are not required to file a paper copy. If your Answer exceeds 250 pages, you must file a paper copy with the Secretary's Bureau.

 Additionally, a copy should either be mailed to:

    Wayne T. Scott, First Deputy Chief Prosecutor
    Pennsylvania Public Utility Commission
    Bureau of Investigation and Enforcement
    P. O. Box 3265
    Harrisburg, PA 17105-3265

 Or, emailed to Mr. Scott at: [e-mail]

 B. If you fail to answer this Complaint within 20 days, the Bureau of Investigation and Enforcement will request that the Commission issue an Order imposing the penalty.

 C. You may elect not to contest this Complaint by paying the civil penalty within 20 days. Your check or money order for the civil penalty should be payable to the Commonwealth of Pennsylvania and mailed to:

    Rosemary Chiavetta, Secretary
    Pennsylvania Public Utility Commission
    P. O. Box 3265
    Harrisburg, PA 17105-3265

 D. If you file an Answer which either admits or fails to deny the allegations of the Complaint, the Bureau of Investigation and Enforcement will request the Commission to issue an Order imposing the penalty set forth in this Complaint.

 E. If you file an Answer which contests the Complaint, the matter will be assigned to an Administrative Law Judge for hearing and decision. The Judge is not bound by the penalty set forth in the Complaint, and may impose additional and/or alternative penalties as appropriate.

 F. If you are a corporation, you must be represented by legal counsel. 52 Pa. Code § 1.21.

 G. Alternative formats of this material are available for persons with disabilities by contacting the Commission's ADA Coordinator at 717-787-8714.

____

Pennsylvania Public Utility Commission, Bureau of Investigation and Enforcement v. Dhillon Transportation, Inc.; Doc. No. C-2013-2381639

COMPLAINT

 The Pennsylvania Public Utility Commission (Commission) is a duly constituted agency of the Commonwealth of Pennsylvania empowered to regulate public utilities within the Commonwealth. The Commission has delegated its authority to initiate proceedings which are prosecutory in nature to the Bureau of Investigation and Enforcement. Pursuant to that delegated authority and Section 701 of the Public Utility Code, the Bureau of Investigation and Enforcement Prosecutory Staff hereby represents as follows:

 1. That Dhillon Transportation, Inc., Respondent, maintains its principal place of business at 146 Glencoe Road, Upper Darby, PA 19082.

 2. That Respondent was issued Certificates of Public Convenience by this Commission on December 20, 2001 at Application Docket No. A-00118334 F. 1, and on June 25, 2004 at A-00118334 F. 2.

 3. That by Secretarial Letter issued on March 24, 2011 at C-2010-2206200, Respondent was directed to pay a civil penalty of two hundred fifty dollars ($250.00). To date, Respondent has not submitted any payments to this Commission.

 4. That by Secretarial Letter issued on July 8, 2011 at C-2010-2129733, Respondent was directed to pay a civil penalty of two hundred fifty dollars ($250.00). To date, Respondent has not submitted any payments to this Commission.

 5. That by Secretarial Letter issued on December 6, 2012 at C-2011-2269753, Respondent was directed to pay a civil penalty of two hundred fifty dollars ($250.00). To date, Respondent has not submitted any payments to this Commission.

 6. That Respondent failed to pay fines totaling seven hundred fifty dollars ($750.00) and violated 66 Pa.C.S. § 501(c) for failing to observe, obey and comply with a Secretarial Letter issued on March 24, 2011 at C-2010-2206200, July 8, 2011 at C-2010-2129733, and December 6, 2012 at C-2011-2269753.

 A Certificate holder has an obligation to comply with the Commission's rules and regulations. A Certificate of Public Convenience is neither a contract nor a property; it is a privilege. Where that privilege is violated, the Commission may, for due cause, exercise its power to revoke a carrier's privilege to operate. Paradise v. Pennsylvania Public Utility Commission, 132 A.2d 754, 184 Pa. Superior Court 8 (1957).

 Wherefore, the Bureau of Investigation and Enforcement Prosecutory Staff hereby requests that the Commission issue an Order which revokes the Certificates of Public Convenience held by Respondent at A-00118334 Fs. 1 and 2.

 Respectfully submitted,
 David W. Loucks, Chief
 Motor Carrier Enforcement
 Bureau of Investigation and Enforcement
 P. O. Box 3265
 Harrisburg, PA 17105-3265

VERIFICATION

 I, David W. Loucks, Chief of Motor Carrier Enforcement, hereby state that the facts above set forth are true and correct to the best of my knowledge, information and belief and that I expect to be able to prove the same at any hearing held in this matter. I understand that the statements herein are made subject to the penalties of 18 Pa.C.S. § 4904 relating to unsworn falsification to authorities.

Date: 9/4/2013
David W. Loucks, Chief
Motor Carrier Enforcement
Bureau of Investigation and Enforcement

NOTICE

 You must file an Answer within 20 days of the date of service of this Complaint. The date of service is the mailing date as indicated at the top of the Secretarial Letter. See 52 Pa. Code § 1.56(a). The Answer must raise all factual and legal arguments that you wish to claim in your defense, include the docket number of this Complaint, and be verified. You may file your Answer by mailing an original to:

    Rosemary Chiavetta, Secretary
    Pennsylvania Public Utility Commission
    P. O. Box 3265
    Harrisburg, PA 17105-3265

 A. Or, you may eFile your Answer using the Commission's website at www.puc.pa.gov. The link to eFiling is located under the Filing & Resources tab on the homepage. If your Answer is 250 pages or less, you are not required to file a paper copy. If your Answer exceeds 250 pages, you must file a paper copy with the Secretary's Bureau.

 B. Additionally, a copy should either be mailed to:

    Wayne T. Scott, First Deputy Chief Prosecutor
    Pennsylvania Public Utility Commission
    Bureau of Investigation and Enforcement
    P. O. Box 3265
    Harrisburg, PA 17105-3265

 C. Or, emailed to Mr. Scott at: [e-mail]

 D. If you fail to answer this Complaint within 20 days, the Bureau of Investigation and Enforcement will request that the Commission issue an Order imposing the penalty.

 You may elect not to contest this Complaint by paying the civil penalty within 20 days. Your check or money order for the civil penalty should be payable to the Commonwealth of Pennsylvania and mailed to:

    Rosemary Chiavetta, Secretary
    Pennsylvania Public Utility Commission
    P. O. Box 3265
    Harrisburg, PA 17105-3265

 E. If you file an Answer which either admits or fails to deny the allegations of the Complaint, the Bureau of Investigation and Enforcement will request the Commission to issue an Order imposing the penalty set forth in this Complaint.

 F. If you file an Answer which contests the Complaint, the matter will be assigned to an Administrative Law Judge for hearing and decision. The Judge is not bound by the penalty set forth in the Complaint, and may impose additional and/or alternative penalties as appropriate.

 G. If you are a corporation, you must be represented by legal counsel. 52 Pa. Code § 1.21.

 H. Alternative formats of this material are available for persons with disabilities by contacting the Commission's ADA Coordinator at 717-787-8714.

____

Pennsylvania Public Utility Commission, Bureau of Investigation and Enforcement v. Ivy Taxi, Inc.;
Doc. No. C-2013-2382072

COMPLAINT

 The Pennsylvania Public Utility Commission (Commission) is a duly constituted agency of the Commonwealth of Pennsylvania empowered to regulate public utilities within the Commonwealth. The Commission has delegated its authority to initiate proceedings which are prosecutory in nature to the Bureau of Investigation and Enforcement. Pursuant to that delegated authority and Section 701 of the Public Utility Code, the Bureau of Investigation and Enforcement Prosecutory Staff hereby represents as follows:

 1. That Ivy Taxi, Inc., Respondent, maintains its principal place of business at 2041 Plum Street, Philadelphia, PA 19124.

 2. That Respondent was issued a Certificate of Public Convenience by this Commission on May 31, 2003, at A-00119639.

 3. That by Secretarial Letter issued on July 13, 2011 at C-2010-2137674, Respondent was directed to pay a civil penalty of two hundred fifty dollars ($250.00). To date, Respondent has not submitted any payment to this Commission.

 4. That Respondent failed to pay fines totaling two hundred fifty dollars ($250.00) and violated 66 Pa.C.S. § 501(c) for failing to observe, obey and comply with the Secretarial Letter issued on July 13, 2011 at C-2010-2137674.

 A Certificate holder has an obligation to comply with the Commission's rules and regulations. A Certificate of Public Convenience is neither a contract nor a property; it is a privilege. Where that privilege is violated, the Commission may, for due cause, exercise its power to revoke a carrier's privilege to operate. Paradise v. Pennsylvania Public Utility Commission, 132 A.2d 754, 184 Pa. Superior Court 8 (1957).

 Wherefore, the Bureau of Investigation and Enforcement Prosecutory Staff hereby requests that the Commission issue an Order which revokes the Certificate of Public Convenience held by Respondent at A-00119639.

 Respectfully submitted,
 
 David W. Loucks, Chief
 Motor Carrier Enforcement
 Bureau of Investigation and Enforcement
 P. O. Box 3265
 Harrisburg, PA 17105-3265

VERIFICATION

 I, David W. Loucks, Chief, Motor Carrier Enforcement, Bureau of Investigation and Enforcement, hereby state that the facts above set forth are true and correct to the best of my knowledge, information and belief and that I expect that the Bureau will be able to prove same at any hearing held in this matter. I understand that the statements herein are made subject to the penalties of 18 Pa.C.S. § 4904 relating to unsworn falsification to authorities.

Date: 9/10/2013
David W. Loucks, Chief
Motor Carrier Enforcement
Bureau of Investigation and Enforcement

NOTICE

 A. You must file an Answer within 20 days of the date of service of this Complaint. The date of service is the mailing date as indicated at the top of the Secretarial Letter. See 52 Pa. Code § 1.56(a). The Answer must raise all factual and legal arguments that you wish to claim in your defense, include the docket number of this Complaint, and be verified. You may file your Answer by mailing an original to:

    Rosemary Chiavetta, Secretary
    Pennsylvania Public Utility Commission
    P. O. Box 3265
    Harrisburg, PA 17105-3265

 B. Or, you may eFile your Answer using the Commission's website at www.puc.pa.gov. The link to eFiling is located under the Filing & Resources tab on the homepage. If your Answer is 250 pages or less, you are not required to file a paper copy. If your Answer exceeds 250 pages, you must file a paper copy with the Secretary's Bureau.

 C. Additionally, a copy should either be mailed to:

    Wayne T. Scott, First Deputy Chief Prosecutor
    Pennsylvania Public Utility Commission
    Bureau of Investigation and Enforcement
    P. O. Box 3265
    Harrisburg, PA 17105-3265

 D. Or, emailed to Mr. Scott at: [e-mail]

 E. If you fail to answer this Complaint within 20 days, the Bureau of Investigation and Enforcement will request that the Commission issue an Order imposing the penalty.

 F. You may elect not to contest this Complaint by paying the civil penalty within 20 days. Your check or money order for the civil penalty should be payable to the Commonwealth of Pennsylvania and mailed to:

    Rosemary Chiavetta, Secretary
    Pennsylvania Public Utility Commission
    P. O. Box 3265
    Harrisburg, PA 17105-3265

 G. If you file an Answer which either admits or fails to deny the allegations of the Complaint, the Bureau of Investigation and Enforcement will request the Commission to issue an Order imposing the penalty set forth in this Complaint.

 H. If you file an Answer which contests the Complaint, the matter will be assigned to an Administrative Law Judge for hearing and decision. The Judge is not bound by the penalty set forth in the Complaint, and may impose additional and/or alternative penalties as appropriate.

 I. If you are a corporation, you must be represented by legal counsel. 52 Pa. Code § 1.21.

 J. Alternative formats of this material are available for persons with disabilities by contacting the Commission's ADA Coordinator at 717-787-8714.

____

Pennsylvania Public Utility Commission, Bureau of Investigation and Enforcement v. Yannis Cab Co.;
Doc. No. C-2013-2382835

COMPLAINT

 The Pennsylvania Public Utility Commission (Commission) is a duly constituted agency of the Commonwealth of Pennsylvania empowered to regulate public utilities within the Commonwealth. The Commission has delegated its authority to initiate proceedings which are prosecutory in nature to the Bureau of Investigation and Enforcement. Pursuant to that delegated authority and Section 701 of the Public Utility Code, the Bureau of Investigation and Enforcement Prosecutory Staff hereby represents as follows:

 1. That Yannis Cab Co., Respondent, maintains its principal place of business at 1603 North Delaware Avenue, Philadelphia, PA 19125.

 2. That Respondent was issued Certificates of Public Convenience by this Commission on November 3, 2004 at Application Docket No. A-00120932 F. 3, on March 8, 2005 at A-00120932 F. 4, and on March 28, 2005 at A-00120932 F. 5.

 3. That by Secretarial Letter issued on April 5, 2011 at C-2010-2213368, Respondent was directed to pay a civil penalty of two hundred fifty dollars ($250.00). To date, Respondent has not submitted any payments to this Commission.

 4. That by Secretarial Letter issued on July 8, 2011 at C-2010-2135198, Respondent was directed to pay a civil penalty of two hundred fifty dollars ($250.00). To date, Respondent has not submitted any payments to this Commission.

 5. That by Secretarial Letter issued on May 24, 2012 at C-2011-2256026, Respondent was directed to pay a civil penalty of one thousand dollars ($1,000.00). To date, Respondent has not submitted any payments to this Commission.

 6. That Respondent failed to pay fines totaling one thousand five hundred dollars ($1,500.00) and violated 66 Pa.C.S. § 501(c) for failing to observe, obey and comply with Secretarial Letters issued on April 5, 2011 at C-2010-2213368, July 8, 2011 at C-2010-2135198, and May 24, 2012 at C-2011-2256026.

 A Certificate holder has an obligation to comply with the Commission's rules and regulations. A Certificate of Public Convenience is neither a contract nor a property; it is a privilege. Where that privilege is violated, the Commission may, for due cause, exercise its power to revoke a carrier's privilege to operate. Paradise v. Pennsylvania Public Utility Commission, 132 A.2d 754, 184 Pa. Superior Court 8 (1957).

 Wherefore, the Bureau of Investigation and Enforcement Prosecutory Staff hereby requests that the Commission issue an Order which revokes the Certificates of Public Convenience held by Respondent at A-00120932 Fs. 3, 4 and 5.

 Respectfully submitted,
 
 David W. Loucks, Chief
 Motor Carrier Enforcement
 Bureau of Investigation and Enforcement
 P. O. Box 3265
 Harrisburg, PA 17105-3265

VERIFICATION

 I, David W. Loucks, Chief of Motor Carrier Enforcement, hereby state that the facts above set forth are true and correct to the best of my knowledge, information and belief and that I expect to be able to prove the same at any hearing held in this matter. I understand that the statements herein are made subject to the penalties of 18 Pa.C.S. § 4904 relating to unsworn falsification to authorities.

Date: 9/11/2013
David W. Loucks, Chief
Motor Carrier Enforcement
Bureau of Investigation and Enforcement

NOTICE

 A. You must file an Answer within 20 days of the date of service of this Complaint. The date of service is the mailing date as indicated at the top of the Secretarial Letter. See 52 Pa. Code § 1.56(a). The Answer must raise all factual and legal arguments that you wish to claim in your defense, include the docket number of this Complaint, and be verified. You may file your Answer by mailing an original to:

    Rosemary Chiavetta, Secretary
    Pennsylvania Public Utility Commission
    P. O. Box 3265
    Harrisburg, PA 17105-3265

 B. Or, you may eFile your Answer using the Commission's website at www.puc.pa.gov. The link to eFiling is located under the Filing & Resources tab on the homepage. If your Answer is 250 pages or less, you are not required to file a paper copy. If your Answer exceeds 250 pages, you must file a paper copy with the Secretary's Bureau.

 C. Additionally, a copy should either be mailed to:

    Wayne T. Scott, First Deputy Chief Prosecutor
    Pennsylvania Public Utility Commission
    Bureau of Investigation and Enforcement
    P. O. Box 3265
    Harrisburg, PA 17105-3265

 D. Or, emailed to Mr. Scott at: [e-mail]

 E. If you fail to answer this Complaint within 20 days, the Bureau of Investigation and Enforcement will request that the Commission issue an Order imposing the penalty.

 F. You may elect not to contest this Complaint by paying the civil penalty within 20 days. Your check or money order for the civil penalty should be payable to the Commonwealth of Pennsylvania and mailed to:

    Rosemary Chiavetta, Secretary
    Pennsylvania Public Utility Commission
    P. O. Box 3265
    Harrisburg, PA 17105-3265

 G. If you file an Answer which either admits or fails to deny the allegations of the Complaint, the Bureau of Investigation and Enforcement will request the Commission to issue an Order imposing the penalty set forth in this Complaint.

 H. If you file an Answer which contests the Complaint, the matter will be assigned to an Administrative Law Judge for hearing and decision. The Judge is not bound by the penalty set forth in the Complaint, and may impose additional and/or alternative penalties as appropriate.

 I. If you are a corporation, you must be represented by legal counsel. 52 Pa. Code § 1.21.

 J. Alternative formats of this material are available for persons with disabilities by contacting the Commission's ADA Coordinator at 717-787-8714.

____

Pennsylvania Public Utility Commission, Bureau of Investigation and Enforcement v. Ambulance Corps of Portland Inc; Doc. No. C-2013-2384842

COMPLAINT

 The Pennsylvania Public Utility Commission (Commission) is a duly constituted agency of the Commonwealth of Pennsylvania empowered to regulate public utilities within the Commonwealth. The Commission has delegated its authority to initiate proceedings which are prosecutory in nature to the Bureau of Investigation and Enforcement. Pursuant to that delegated authority and Section 701 of the Public Utility Code, the Bureau of Investigation and Enforcement Prosecutory Staff hereby represents as follows:

 1. That Ambulance Corps of Portland, Inc., Respondent, maintains its principal place of business at 106 State Street, Portland, PA 18351.

 2. That Respondent was issued a Certificate of Public Convenience by this Commission on June 13, 1996 at A-00112592.

 3. That by Secretarial Letter issued on May 24, 2012 at C-2011-2256458, Respondent was directed to pay a civil penalty of one thousand dollars ($1,000.00). To date, Respondent has not submitted any payment to this Commission.

 4. That Respondent failed to pay fines totaling one thousand dollars ($1,000.00) and violated 66 Pa.C.S. § 501(c) for failing to observe, obey and comply with the Secretarial Letter issued on May 24, 2012 at C-2011-2256458.

 A Certificate holder has an obligation to comply with the Commission's rules and regulations. A Certificate of Public Convenience is neither a contract nor a property; it is a privilege. Where that privilege is violated, the Commission may, for due cause, exercise its power to revoke a carrier's privilege to operate. Paradise v. Pennsylvania Public Utility Commission, 132 A.2d 754, 184 Pa. Superior Court 8 (1957).

 Wherefore, the Bureau of Investigation and Enforcement Prosecutory Staff hereby requests that the Commission issue an Order which revokes the Certificate of Public Convenience held by Respondent at A-00112592.

 Respectfully submitted,
 
 David W. Loucks, Chief
 Motor Carrier Enforcement
 Bureau of Investigation and Enforcement
 P. O. Box 3265
 Harrisburg, PA 17105-3265

VERIFICATION

 I, David W. Loucks, Chief, Motor Carrier Enforcement, Bureau of Investigation and Enforcement, hereby state that the facts above set forth are true and correct to the best of my knowledge, information and belief and that I expect that the Bureau will be able to prove same at any hearing held in this matter. I understand that the statements herein are made subject to the penalties of 18 Pa.C.S. § 4904 relating to unsworn falsification to authorities.

Date: 9/25/2013
David W. Loucks, Chief
Motor Carrier Enforcement
Bureau of Investigation and Enforcement

NOTICE

 A. You must file an Answer within 20 days of the date of service of this Complaint. The date of service is the mailing date as indicated at the top of the Secretarial Letter. See 52 Pa. Code § 1.56(a). The Answer must raise all factual and legal arguments that you wish to claim in your defense, include the docket number of this Complaint, and be verified. You may file your Answer by mailing an original to:

    Rosemary Chiavetta, Secretary
    Pennsylvania Public Utility Commission
    P. O. Box 3265
    Harrisburg, PA 17105-3265

 B. Or, you may eFile your Answer using the Commission's website at www.puc.pa.gov. The link to eFiling is located under the Filing & Resources tab on the homepage. If your Answer is 250 pages or less, you are not required to file a paper copy. If your Answer exceeds 250 pages, you must file a paper copy with the Secretary's Bureau.

 C. Additionally, a copy should either be mailed to:

    Wayne T. Scott, First Deputy Chief Prosecutor
    Pennsylvania Public Utility Commission
    Bureau of Investigation and Enforcement
    P. O. Box 3265
    Harrisburg, PA 17105-3265

 D. Or, emailed to Mr. Scott at: [e-mail]

 E. If you fail to answer this Complaint within 20 days, the Bureau of Investigation and Enforcement will request that the Commission issue an Order imposing the penalty.

 You may elect not to contest this Complaint by paying the civil penalty within 20 days. Your check or money order for the civil penalty should be payable to the Commonwealth of Pennsylvania and mailed to:

    Rosemary Chiavetta, Secretary
    Pennsylvania Public Utility Commission
    P. O. Box 3265
    Harrisburg, PA 17105-3265

 F. If you file an Answer which either admits or fails to deny the allegations of the Complaint, the Bureau of Investigation and Enforcement will request the Commission to issue an Order imposing the penalty set forth in this Complaint.

 G. If you file an Answer which contests the Complaint, the matter will be assigned to an Administrative Law Judge for hearing and decision. The Judge is not bound by the penalty set forth in the Complaint, and may impose additional and/or alternative penalties as appropriate.

 H. If you are a corporation, you must be represented by legal counsel. 52 Pa. Code § 1.21.

 I. Alternative formats of this material are available for persons with disabilities by contacting the Commission's ADA Coordinator at 717-787-8714.

____

Pennsylvania Public Utility Commission, Bureau of Investigation and Enforcement v. Caring Hearts Ambulance & Medic; Doc. No. C-2013-2385269

COMPLAINT

 The Pennsylvania Public Utility Commission (Commission) is a duly constituted agency of the Commonwealth of Pennsylvania empowered to regulate public utilities within the Commonwealth. The Commission has delegated its authority to initiate proceedings which are prosecutory in nature to the Bureau of Investigation and Enforcement. Pursuant to that delegated authority and Section 701 of the Public Utility Code, the Bureau of Investigation and Enforcement Prosecutory Staff hereby represents as follows:

 1. That Caring Hearts Ambulance & Medic, Respondent, maintains its principal place of business at PO Box 596, New Oxford, PA 17350.

 2. That Respondent was issued a Certificate of Public Convenience by this Commission on March 26, 2006 at Application Docket No. A-00121912.

 3. That by Secretarial Letter issued on May 24, 2012 at C-2011-2259847, Respondent was directed to pay a civil penalty of one thousand dollars ($1,000.00). To date, Respondent has not submitted any payments to this Commission.

 4. That Respondent failed to pay fines totaling one thousand dollars ($1,000.00) and violated 66 Pa.C.S. § 501(c) for failing to observe, obey and comply with a Secretarial Letter issued on May 24, 2012 at C-2011-2259847.

 A Certificate holder has an obligation to comply with the Commission's rules and regulations. A Certificate of Public Convenience is neither a contract nor a property; it is a privilege. Where that privilege is violated, the Commission may, for due cause, exercise its power to revoke a carrier's privilege to operate. Paradise v. Pennsylvania Public Utility Commission, 132 A.2d 754, 184 Pa. Superior Court 8 (1957).

 Wherefore, the Bureau of Investigation and Enforcement Prosecutory Staff hereby requests that the Commission issue an Order which revokes the Certificates of Public Convenience held by Respondent at A-00121912.

 Respectfully submitted,
 
 David W. Loucks, Chief
 Motor Carrier Enforcement
 Bureau of Investigation and Enforcement
 P. O. Box 3265
 Harrisburg, PA 17105-3265

VERIFICATION

 I, David W. Loucks, Chief of Motor Carrier Enforcement, hereby state that the facts above set forth are true and correct to the best of my knowledge, information and belief and that I expect to be able to prove the same at any hearing held in this matter. I understand that the statements herein are made subject to the penalties of 18 Pa.C.S. § 4904 relating to unsworn falsification to authorities.

Date: 9/30/2013
David W. Loucks, Chief
Motor Carrier Enforcement
Bureau of Investigation and Enforcement

NOTICE

 A. You must file an Answer within 20 days of the date of service of this Complaint. The date of service is the mailing date as indicated at the top of the Secretarial Letter. See 52 Pa. Code § 1.56(a). The Answer must raise all factual and legal arguments that you wish to claim in your defense, include the docket number of this Complaint, and be verified. You may file your Answer by mailing an original to:

    Rosemary Chiavetta, Secretary
    Pennsylvania Public Utility Commission
    P. O. Box 3265
    Harrisburg, PA 17105-3265

 B. Or, you may eFile your Answer using the Commission's website at www.puc.pa.gov. The link to eFiling is located under the Filing & Resources tab on the homepage. If your Answer is 250 pages or less, you are not required to file a paper copy. If your Answer exceeds 250 pages, you must file a paper copy with the Secretary's Bureau.

 C. Additionally, a copy should either be mailed to:

    Wayne T. Scott, First Deputy Chief Prosecutor
    Pennsylvania Public Utility Commission
    Bureau of Investigation and Enforcement
    P. O. Box 3265
    Harrisburg, PA 17105-3265

 D. Or, emailed to Mr. Scott at: [e-mail]

 E. If you fail to answer this Complaint within 20 days, the Bureau of Investigation and Enforcement will request that the Commission issue an Order imposing the penalty.

 You may elect not to contest this Complaint by paying the civil penalty within 20 days. Your check or money order for the civil penalty should be payable to the Commonwealth of Pennsylvania and mailed to:

    Rosemary Chiavetta, Secretary
    Pennsylvania Public Utility Commission
    P. O. Box 3265
    Harrisburg, PA 17105-3265

 F. If you file an Answer which either admits or fails to deny the allegations of the Complaint, the Bureau of Investigation and Enforcement will request the Commission to issue an Order imposing the penalty set forth in this Complaint.

 G. If you file an Answer which contests the Complaint, the matter will be assigned to an Administrative Law Judge for hearing and decision. The Judge is not bound by the penalty set forth in the Complaint, and may impose additional and/or alternative penalties as appropriate.

 H. If you are a corporation, you must be represented by legal counsel. 52 Pa. Code § 1.21.

 I. Alternative formats of this material are available for persons with disabilities by contacting the Commission's ADA Coordinator at 717-787-8714.

ROSEMARY CHIAVETTA, 
Secretary

[Pa.B. Doc. No. 14-102. Filed for public inspection January 10, 2014, 9:00 a.m.]