9. Allegations of Document Irregularities

Karrison alleges that A&P failed to record on the moving agreement the destination of the shipment as required by Item 460. However, A&P wrote on the moving agreement the destination, "same...reg. stg." under its letterhead, which indicated the full address of its storage facility. We cannot agree that such a notation violates Item 460 or Item 4.¹⁰ It reasonably informs a shipper of the destination of the shipment.

Karrison alleges A&P caused other state agencies to rely on its falsified insurance and valuation. Karrison argues that by inducing such unfounded reliance, A&P violated Pub. Util. Code § 5259. This section basically empowers the Commission's Executive Director to seek an injunction against a household goods' carrier for action (or inaction) in violation of law. The record does not prove that A&P falsified its insurance or valuation. Therefore, Karrison's argument is without merit.

Karrison contends she did not receive a bill within seven days after the move, as required by Item 104.4 of MAX4. Karrison makes this allegation in her closing brief, rather than providing notice and opportunity for A&P to directly address this allegation. This is improper and we decline to find a violation without due process. Moreover, the record on this issue is inconclusive. The record has a copy of the bill, entitled "Shipping Order and Freight Bill," totalling $620.41 dated June 4, 1994, the date of the move. Aman testified that she reminded Karrison to pay the bill in their telephone conversation in September 1994. A&P sent a statement in October 1994 which references a bill dated June 14, 1994. Given this conflicting evidence, we cannot conclude whether this requirement is violated or sanctions warranted.

Karrison alleges that A&P failed to prepare a change order to indicate that the goods were being moved in order to complete an inspection for damage as required by Item 120. Item 120 requires a change order to be prepared for "additional services or additional articles to the shipment, not covered in the ... agreement." There were no additional services or articles shipped; therefore, a change order was not required.