EXHIBIT No. 22

REPRODUCTION OF ANONYMOUS LETTER TO FLORIDA RAILROAD & PUBLIC UTILITIES COMMISSION FROM PARTY BEING HURT BY ILLEGAL TRUCKING OF LUMBER, RECEIVED JULY 7, 1955

Get some lumber company to lease your trucks letting you have a supply of their bills. Then you can haul for anyone and bill it on the letterhead of the broker or lumber company. This is being done by ABC of

Ga., who is

supposed to be leased to DEF of Jacksonville, Fla. XYZ Lumber Co. is working practically the same thing except they haul for BCD Lumber Co. of Ga., even though they are leased to XYZ Lumber Co. Whenever XYZ cannot keep them busy then they haul for of the BCD Lumber Co. who sells

lumber for XYZ and who finances same. JKL Lumber Co. of , Ga., has three trucks and would have to haul every load that he runs through his planer twice in order to keep three trucks moving. So he uses mill letterheads and hauls for anyone without fear of being caught.

Have some fake bills printed saying you are a lumber buyer. Go to Tallahassee and get a Florida sales tax exemption number and use these bills and haul away. This is the method used by MNO of Ga. Am attaching a bill from him showing this method. How many of the other bootleggers are using this method I cannot say. But it has been working for sometime.

Simply print the name of some lumber company on your truck doors. This works well also as no one checks them to see if the truck is even leased to the mill or if even the mill exists. They carry no lease papers or truck title with them. I know of only one mill that complies with the law. That mill is GHI of —. They have valid lease, pay the driver, pay social security on the driver and carry the insurance in the mill's name.

Just have the lumber billed to you from the planing mill. It clearly shows a conspiracy by the mill and the hauler. This is being done by QRS of on all the lumber that he hauls.

But by far the best is simply load the lumber and haul it into Florida. There is very little danger of being caught by this method. If you are caught the fine is small and you can overcome that by putting another truck to work. If business gets slow then cut the price another dollar. By not having to fork out tax or for-hire tags or brokerage you can always come out ahead of the boys that are struggling trying to stay with Watkins and haul it right. The number is increasing daily. Unless there is some positive action taken there is little for us to do. It has boiled down to just a matter of price. These mills in this area do not care about service, authorized legal carriers. Their interest is simply in the cheapest truck rate they can get. Trucking Co. hauls lumber Trucking Co.

out of Georgia with trucks clearly showing the name of on the doors. They will haul from Alabama, north Georgia to Miami for $12 per thousand. They do not charge tax and it makes it impossible for me to secure business. If something is not changed soon, we won't be in business very much longer.

NOTE.-Names in original letter have been disguised.

60470 0-60- 33

EXHIBIT NO. 23

Seasonal shipments of frozen citrus concentrates via rail, truck, and water from Florida to Eastern States as reported by plants producing 85 to 90 percent of total production

NOTE. No report from Sept. 1, 1957 to Aug. 31, 1958.

Source: Florida Canners Association through courtesy of Growers and Shippers League of Florida, Orlando, Fla.

EXHIBIT No. 24

Statement showing rail, truck, and water shipments of canned citrus products from Florida to Eastern States shown for seasons indicated, as reported by plants producing 85 to 90 percent of total canned citrus packed in Florida

NOTE.-No report from Sept. 1, 1957, to Aug. 31, 1958. Source: Florida Canners Association through courtesy of Growers and Shippers League of Florida, Orlando, Fla.

EXHIBIT No. 25

REPRODUCTION OF PAGES 936, 1031, 1032, 1035, 1036, AND 1044 TO 1047, INCLUSIVE, OF TRANSCRIPT OF JANUARY 7, 1960, TESTIMONY OF MR. EDMOND H. GAIENNIE, TRAFFIC VICE PRESIDENT, SEATRAIN LINES, INC., BEFORE INTERSTATE COMMERCE COMMISSION IN ITS DOCKET NO. 33257.

BEFORE THE INTERSTATE COMMERCE COMMISSION

Docket No. 33257

IN THE MATTERS OF GEORGIA PUBLIC SERVICE COMMISSION, ET AL. v. THE BUSH TERMINAL RAILROAD COMPANY, ET AL.

GOLD ROOM, HOTEL DESOTO,

Savannah, Georgia, Thursday, January 7, 1960.

Met, pursuant to adjournment, 9:30 a.m.

Before J. A. RUSSELL, Examiner.

Appearances (As heretofore noted).

Edmond H. Gaiennie was recalled and testified as follows:

DIRECT EXAMINATION

By Mr. EISEN :

Q. State your name, sir.-A. Edmond H. Gaiennie.

Q. Are you the same Mr. Gaiennie that previously testified in this proceeding as vice president of Seatrain Lines, Inc?—A. Yes.

Q. Mr. Gaiennie, Mr. Saunders in his cost studies in part has utilized a figure of 95 cars for the costing of New York-Savannah operations. Are you familiar with his use of that figure? A. Yes, I am.

Q. Did you have anything to do with the ascertainment of that 95-car figure?— A. I did.

Q. Were you part of the management team that determined upon the use of that figure?-A. Yes.

Q. Will you tell us upon what basis the management arrived at that figure?— A. On the basis of experience.

Q. Tell us what that experience consisted of.-A. Well, we took the experience in the year 1955 in our Texas City service.

Q. Why did you take the year 1955?-A. Because that was the last normal year of Seatrain operation, of complete normalcy.

Q. In the New York-Texas City operation?-A. That is correct.

Q. Will you explain what you mean by complete normalcy?—A. It is the only year in which we did not have one or more of the following things—a strike of one kind or another.

Q. You mean industrial strikes?-A. Industrial strikes, steel strikes, or strikes within our own industry, ship repair, major ship repairs that took ships out of service, where we had the number of voyages through the year in a normal operation.

Q. Now, what was your experience in the New York-Texas City service during incidentally, did you after that year have a disruption of your Texas City service by virtue of the injection of a new form of competition?—A. We certainly have. In 1956, Pan-Atlantic came into the operation with a new container operation, and as a result our rate structure was disrupted, and because of the reduction in rates we have not had a normal year as a result of that competition.

Q. Now, in 1955, which was your last normal year of operation in that trade, what was your actual carrying?

Q. With the attainment of joint rates into the southern area, and the cooperation of the railroads, do you have any doubt about your ability to regularly achieve a 95-car average in your New York-Savannah sailing?-A. No, I do not. Q. And in your New York-Texas City service, when you achieved the average that you did, did you run over 100 car carryings in any one voyage?-A. Oh, yes. Q. How high have you run?-A. I believe, as I recall, it was around 104. Mr. EISEN. Thank you, sir. The witness is available for cross-examination. The WITNESS. Not around-it was.

By Mr. REYNOLDS:

CROSS-EXAMINATION

Q. You say in the year 1955 you averaged 95 cars in your New York-Texas City service?-A. 94.7.

Q. How much did you average in your New York-New Orleans service?—A. I don't know whether I have those figures-I don't have those figures.

Q. How much did you average-how many cars did you average in 1955 in your New York-Savannah service?-A. I don't have those figures, because those weren't needed in what we were doing, for the use to which this was being put. Q. I understood you to say that you considered 1955 a normal year because you didn't have any strikes or no economic depression, or anything of that sort?-A. That is right.

Q. And also because you didn't have Pan-Atlantic competition?-A. That is correct.

Q. Pan-Atlantic is a factor-scratch that. Pan-Atlantic is in operation today, isn't it?-A. In 1956 they began operation.

Q. And they are in operation in 1960, aren't they?-A. Yes, sir; they are from Texas City.

Q. And they are quite a factor in the coastwise trade, are they not?-A. They certainly are.

Q. And they are trying to get authority to operate to and from Savannah, aren't they? A. Not that I know of.