A team moving & Storage Plano Richardson Rip off do not use them Richardson Texas

Here is a complaint I filed against A Team, if you are interested in joining a class action against them then contact me at (((ROR redacted))) there will be no charge to you.  IN THE UNITED STATES DISTRICT COURT FOR THE NORTHERN DISTRICT OF ILLINOIS EASTERN DIVISION THOMAS C. SOURAN Plaintiff, vs. ISRAEL ONE LLC, a Texas Corporation Mary Lee, and individual and employee Michael Grabley and individual Avraham Kadoch and individual Defendant Case No.: Judge: VERIFIED COMPLAINT THE PARTIES 1. The Plaintiff, Thomas C. Souran, is an individual and his primary residence is located at 14 Bright Oaks Circle, Cary, Illinois 60013. 2. On information and belief the Defendant, ISREAL ONE, LLC is the corporate entity that operates A Team Moving and Storage and is organized under the Laws of the State of Texas. The registered Agent is Avraham Kadoch, an officer of the corporation, who can be served at 1417 Exchange drive, Richardson, Texas 75081 Verified Complaint - 2 3. On belief and information defendant Michael Grabley, an officer of Israel One, LLC who’s address is 1417 Exchange Drive, Richardson Texas 75023. 4. On information and belief the defendant, Avraham Kadoch, an officer who operates A Team Moving and Storage who's address is 1417 Exchange Parkway, Richardson, Texas 75023 JURISDICTION AND VENUE 1.Jurisdiction and Venue are proper under United States Code 49 Subtitle IV> Part B> Chapter 147> 14706 which states: “Against carrier responsible for loss- A civil action under this section may be brought against the carrier for alleged to have caused loss or damage, in the in the judicial district in which such loss or damaged is alleged to occurred” 2. Venue is proper because all or substantially all of the facts or circumstances giving rise to Plaintiffs' causes of action occurred in northern Illinois. FACTUAL BACKGROUND 1. On May 19, 2011 Defendant sent Plaintiff a “Binding” quote for Defendants to move Plaintiffs' belongings the quote was for $787.50, EXHIBIT “A” 2. Plaintiff agreed to the move and arranged it for June 25, 2011. 3. On June 25, 2011 Defendants picked up all of Plaintiffs' belongings at a storage locker in Plano, Texas. Plaintiffs' belongings were in the Verified Complaint - 3 storage locker since in April 2011 the Plaintiff had back fusion surgery. 4. On June 25, 2011 Plaintiff arrived at the storage locker late the movers asked Plaintiff for a deposit, Plaintiff explained that the sales representative for Defendants never informed Plaintiff that he had to have a deposit. The employee called Defendants office and they notified the employee (driver) to proceed with the move. 5. Plaintiff explained to the employee's of the Defendant that he had back fusion surgery and could not stand long. Plaintiff told the employees of the Defendant that he was going home. The employees of the Defendant agreed that this was acceptable and they did not need Plaintiff on site. 6. On June 27, 2011 Plaintiff asked Defendants for all paperwork that should have been forwarded to Plaintiff, EXHIBIT “B” 7. On June 29, 2011 Defendants forwarded to Plaintiff a Bill of lading which the totals were left blank by Defendants, the Bill of Lading was dated June 25, 2011, EXHIBIT “C”, packaging materials and a Final Bill totaling $1,323.33 EXHIBIT “D” 8. On July 21, 2011 Defendants sent Plaintiff weight receipts for scales that a truck weighed on, this was 26 days after Defendants picked up all of Plaintiffs belongings. One receipt shows the scale at Anna, Texas on July 20, 2011 and the second receipt shows the weight taken in Plano, Texas, approximately 40 miles south of Anna, Texas. 9. On August 9, 2011 Plaintiff sent a fax to Defendants disagreeing with the amount owed for the move. Verified Complaint - 4 10. On August 15, 2011 Plaintiff sent an e-mail with an attached PDF file showing the Final Bill of $1,323.33 and informed Defendants that the Plaintiff felt the actions of Defendants were fraudulent. 11. On July 23, 2011 Plaintiff needed to drive to Prosper, Texas from Chicago, Illinois to pick his dogs up at a kennel. 12. On July 23, 2011 Plaintiff received a call from Defendants movers (employees) saying that they were ready to deliver his belongings, Plaintiff informed Defendants movers (employees) that Plaintiff had a blown tire in Southern Illinois and could not get the tire changed until Sunday and he was headed to Texas. 13. July 24, 2011 defendants called Plaintiff and said they were in Chicago, Illinois and were ready to deliver Plaintiffs' belongings. Plaintiff once again explained that he was on the way to Texas and could not be back until Wednesday July 27, 2011. 14. Defendants driver (employee) then called Plaintiff on Monday July 25, 2011 and told Plaintiff he needed to be there for delivery. Plaintiff explained that he was in Texas and that there was no agreed upon time for delivery. 15. Plaintiff spoke to Defendants dispatcher and Plaintiff informed him that he would be back Wednesday and wanted to weight everything as it came off the truck to verify weight before Plaintiff made payment. 16. Defendants refused Plaintiffs' request to weigh everything before payment, Defendant wanted payment before unloading then they would consider a refund. Verified Complaint - 5 17. The attempted delivery on July 24, 2011 is in contradiction to Defendants own stated policy in EXHIBIT “A” of fourteen (14) days. 18. Defendants stated in an e-mail and text that Defendant placed all Plaintiffs' belongings in a warehouse in Chicago, Illinois. 19. Plaintiff talked to Defendant and requested redelivery of his belongings, Defendants stated that they would do that with an additional fee, Plaintiff refused any additional fee. 20. On September 1, 2011 Defendant stated that they would not provide copies of logbooks to Plaintiff and that they will see Plaintiff in court. Defendant informed Plaintiff in an e mail to file an Arbitration with AMSA, which is an industry association. Defendant has no formal arbitration agreement with a neutral panel in place, per the US Department of Transportation and Texas Department of Transportation. 21. On September 7, 2011 after Plaintiff asked for the bill of the storage faculty that Defendants allegedly placed all of Plaintiffs' belongings at, Defendant sent Plaintiff a Defendant made storage bill from June 25, 2011 , the day Defendant picked up Plaintiffs' belongings to July 23, 2011 for storage in Plano Texas. 22. On September 16, 2011 Defendants sent Plaintiff a statement that storage charges were over due and needed to be paid or Plaintiffs' items will be auctioned. 23. Plaintiff filed complaints with the U. S. Department of Transportation and the Attorney General of the State of Texas. 24. To date the Defendants still have all of Plaintiffs' possessions. Verified Complaint - 6 VIOLATION OF DISPUTE SETTLEMENT PROGRAM FOR HOUSEHOLD GOODS CARRIERS 25. The Allegations set forth in Paragraphs 1 through 24 above are incorporated and herein by reference. 26. The U.S. Department of Transportation Code states: “Offering shippers Arbitration – As a condition of registration under section 13902 or 13903 a carrier providing transportation of household goods subject to jurisdiction under sub chapter I or iii of chapter 135 must agree to offer in accordance with this section to shippers of household goods arbitration as a means of settling disputes between such carriers and shippers of household goods concerning damage or loss to the household goods concerning damage or loss to the household goods transported and to determine whether carrier charges, in addition to those collected at delivery, must be paid by shippers for transportation and services related to transportation of household goods” 27. Defendants have failed to comply with this part of the code. VIOLATION OF BIDDING ESTIMATE 28. The allegations are set forth in Paragraphs 1 through 27 above are incorporated and herein by reference. 29. Defendants refused to be bound by there binding estimate. 30. US Code part 49 section 375.403 states: “ Once you load a shipment, failure to execute a new binding estimate or a non-binding estimate signifies you have reaffirmed the original binding estimate” Verified Complaint - 7 DEFENANTS FAILED TO PROPERLY DETERMINE THE WEIGHT OF SHIPMENT 31. The allegations are set forth in Paragraph 1 through 30 above are incorporated herein by reference. 32. The U. S. Department of Transportation states: “(a) You must weigh the shipment by using one of the following two methods: (1) First method—origin weigh. You determine the difference between the tare weight of the vehicle before loading at the origin of the shipment and the gross weight of the same vehicle after loading the shipment. (2) Second method—back weigh. You determine the difference between the gross weight of the vehicle with the shipment loaded and the tare weight of the same vehicle after you unload the shipment. (b) The following three conditions must exist for both the tare and gross weightings: (1) The vehicle must have installed or loaded all pads, dollies, hand trucks, ramps, and other equipment required in the transportation of the shipment. (2) The driver and other persons must be off the vehicle at the time of either weighing. (3) The fuel tanks on the vehicle must be full at the time of each weighing, or, in the alternative, when you use the first method—origin weigh, in paragraph (a)(1) of this section, where the tare weighing is the first weighing performed, you must refrain from adding fuel between the two weightings. Verified Complaint - 8 (c) You may detach the trailer of a tractor-trailer vehicle combination from the tractor and have the trailer weighed separately at each weighing provided the length of the scale platform is adequate to accommodate and support the entire trailer at one time. (d) You must use the net weight of shipments transported in containers. You must calculate the difference between the tare weight of the container (including all pads, blocking and bracing used in the transportation of the shipment) and the gross weight of the container with the shipment loaded in the container.” 33. The defendants failed to follow this section of the law. FAILURE TO DELIVER PLAINTIFFS' SHIPMENT IN A TIMELY MANNER 34. The allegations set forth in Paragraphs 1 through 33 above are incorporated by reference. 35. The U. S. Department of Transportation § 375.601 states: “Transportation in a timely manner is also known as “reasonable dispatch service.” You must provide reasonable dispatch service to all individual shippers, except for transportation on the basis of guaranteed pickup and delivery dates. “ 36. The defendants failed to comply with this section of the law. FRAUD 37. The allegations set forth in Paragraph 1 through 36 above are incorporated herein by reference. Verified Complaint - 9 38. All of the above constitutes fraud on part of the Defendants, thereby causing damages to the Plaintiff. CIVIL CONSPIRACY 39. The allegations set forth above in Paragraph 1 through 38 above are incorporated herein by reference. 40. All of the above constitutes civil conspiracy on the part of the Defendants, thereby causing damages to Plaintiff. PUNITIVE DAMAGES 41. The allegations set forth in Paragraphs 1 through 40 above are referenced herein by reference. 42. Because of the willful, wanton and reckless nature of the Defendants, Plaintiff seeks damages in an amount of not less than three (3) times and not more than five (5) times the damages not to exceed Five Million Dollars ($5,000,000). WHEREFORE, PLANTIFF prays that this Honorable Court enter judgment against the Defendants for the following relief; 1. That all items be returned to Plaintiff; 2. That Defendants list all parties they gave any of Plaintiffs papers or belongings to; 3. That Defendants turn over all inventory lists to Plaintiff that they took in compliance with United States Transportation Code § 375.503 Verified Complaint - 10 4. That if Defendants do not have Plaintiffs' belongings that the Defendants pay to Plaintiff the sum of One Million Dollars, ($1,000,000); 5. That Defendants pay to Plaintiff punitive damages of Five Million Dollars, ($5,000,000) for there actions and the fact that this is not the first time they have done this to someone they have moved; 6. Any and all other relief that this Honorable court feels if Just and Equitable. Respectfully Submitted, Thomas C Souran – Pro Se