ADDITIONAL EXHIBIT: SISTER COMPANY SYSTEMATIC VIOLATIONS

Re: Theodore Rubin v. 1-800-PACK-RAT, LLC
Order No.: 2919163
Date: July 28, 2025

PURPOSE

This exhibit documents systematic violations identical to those experienced by Plaintiff extending to 1-800-PACK-RAT’s sister company Zippy Shell, demonstrating corporate-wide policies of unfair and deceptive trade practices under shared ownership and management.

CORPORATE CONNECTION

Shared Ownership & Operations:

• Parent Company: Virgo Investment Group owns both 1-800-PACK-RAT and Zippy Shell
• Merged Operations: Customer reviews confirm shared “1-800-Pack-Rat Zippy Shell claims process”
• Identical Business Practices: Same billing policies, claims procedures, and customer service structure

Customer Confirmation of Shared Operations: > “I filed a claim for my items, I waited 6 months for them to get back to me to tell me ‘The 1-800-Pack-Rat Zippy Shell claims process has concluded, and we appreciate your patience regarding the matter.’”
Source: MoveAdvisor.com Review (January 18, 2024)

IDENTICAL SYSTEMATIC BILLING VIOLATIONS

1. OVERCHARGING & HIDDEN FEES

Trustpilot Review (April 22, 2024): > “Never will I use zippy shell… they told me one price and over charged me 821 dollars do not use them”
Source: https://www.trustpilot.com/review/zippyshell.com

Yelp Review: > “They also charged me $83 for gas excise tax, which also was not in my contract. I had to fight with them to get those charges removed.”
Source: https://www.yelp.com/brands/zippy-shell

2. DECEPTIVE BILLING TIMING

Customer Review: > “SO, they say we have to pay a $477 fee to cover storage since our 30 days is up by one day… Basically, they’ll charge you any way they can, and they absolutely REFUSE to work with you via phone.”

3. BILLING MODEL DECEPTION

Yelp Review: > “The sales person we spoke with quoted an all-inclusive price but their terms indicate we are billed for fuel if it exceeds an internal estimate for the distance.”
Source: https://www.yelp.com/brands/zippy-shell

IDENTICAL CLAIMS DENIAL PRACTICES

Systematic Claims Rejections:

MoveAdvisor Review (January 18, 2024): > “I filed a claim for my items, I waited 6 months for them to get back to me to tell me ‘The 1-800-Pack-Rat Zippy Shell claims process has concluded… it has been determined that the damage incurred to your property were not caused as a result of the unit being improperly loaded, mishandled or dropped by a member of the 1-800-Pack-Rat Zippy Shell staff.’”

Pattern of Blame Shifting: > “They basically said they don’t care when moving stuff. Sure enough they were right, broken furniture, broken box, and missing pieces… Based on the terms of the Addendum, this is not a covered loss.”

CUSTOMER SERVICE FAILURES

Identical Communication Issues:

Trustpilot Review (April 22, 2024): > “I’m on day 3 of calling to cancel the booking we made and have been repeatedly hung up on and lied to. The standout was when Zippy Shell support transferred me to UPack’s main customer service line when I asked to cancel.”

ConsumerAffairs Review: > “When I tried to call customer service to get a refund, I was transferred to another department where the automated message said the wait time was over 30 minutes. I stayed on hold for nearly an hour, only for the call to hang up automatically without ever speaking to anyone.”

EXISTING LITIGATION

Weinstein v. Zippy Shell, Incorporated et al

• Case Number: 6:22-cv-00042
• Court: U.S. District Court, Middle District of Florida
• Filed: 2022
• Status: Ongoing litigation against Zippy Shell
• Significance: Demonstrates other customers pursuing legal remedies

Law360 Case Reference: Source: https://www.law360.com/cases/61dc701f732ad960cf384c54

CUSTOMER CALLS FOR CLASS ACTION

Widespread Sentiment for Legal Action:

Trustpilot Review (April 22, 2024): > “We should sue them in a class action civil suit. Let’s put them out of business!”

MoveAdvisor Review: > “It got to the point where we almost got a lawyer involved to help us get our stuff… if it doesn’t we will be contacting the police for stolen property.”

Review Platform Comment: > “I’m considering a lawsuit if they don’t handle this properly - we’re paying rent on a house we can’t move into!”

REGULATORY PATTERNS

BBB Complaints:

• Multiple BBB profiles across different states
• Consistent pattern of unresolved disputes
• Same response templates as 1-800-PACK-RAT

Review Platform Ratings:

• Trustpilot: 259 reviews with widespread billing complaints
• Yelp: 776 reviews documenting systematic issues
• ConsumerAffairs: Verified reviews confirming billing violations

CORPORATE-WIDE POLICY EVIDENCE

Shared Management & Procedures:

1. Same Claims Department: “1-800-Pack-Rat Zippy Shell claims process”
2. Identical Contract Language: Same exclusions and blame-shifting terms
3. Corporate Training: Same customer service scripts and denial procedures
4. Billing Systems: Shared overcharging and hidden fee practices

Pattern Demonstrates:

• Systematic Corporate Policy rather than isolated incidents
• Willful Implementation across multiple brand names
• Intent to Deceive consumers through brand separation while maintaining same practices
• Enhanced NCUDTPA Violations affecting broader customer base

LEGAL IMPLICATIONS

Corporate Liability:

The systematic nature of identical violations across both 1-800-PACK-RAT and Zippy Shell demonstrates:

1. Corporate-Wide Policy of unfair and deceptive trade practices
2. Willful Implementation of systematic overcharging schemes
3. Pattern of Consumer Harm extending beyond single brand
4. Enhanced Damages Justification under consumer protection statutes

Class Action Potential:

• Existing Litigation: Weinstein case establishes legal precedent
• Customer Sentiment: Multiple calls for class action remedy
• Systematic Impact: Violations affect customers across multiple states and brands
• Corporate Structure: Shared ownership creates unified liability exposure

CONCLUSION

The evidence demonstrates that Plaintiff’s experience with 1-800-PACK-RAT represents part of a systematic corporate-wide policy of unfair and deceptive trade practices extending to sister company Zippy Shell under the same ownership and management. This pattern includes:

• Identical billing violations and hidden fees
• Same claims denial procedures and blame-shifting
• Shared customer service failures and communication breakdowns
  
• Corporate-wide training in deceptive practices

The existing litigation against Zippy Shell and widespread customer calls for class action legal remedy demonstrate mounting legal pressure against these systematic corporate violations.

This evidence strongly supports enhanced damages under consumer protection statutes and establishes the willful, systematic nature of Defendant’s unfair and deceptive trade practices.

Respectfully submitted,

Theodore Rubin (Pro Se)
504 Geneva Crest Drive
Fuquay Varina, NC 27526
(914) 318-5610
ted@theorubin.com

Date: July 28, 2025