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PAC generally denies the allegations and states that legal-conclusion allegations require no response. For most numbered paragraphs, PAC asserts lack of sufficient information or knowledge, admits limited corporate and operational facts, and denies remaining allegations. PAC also addresses specific events, including CBP actions and communications dated in December 2019 and January 2020.",{"@graph":69,"@context":122},[70,84,105],{"@type":71,"itemListElement":72},"BreadcrumbList",[73,77,79,82],{"item":74,"name":75,"@type":76,"position":8},"https://docshare.wps.com","Home","ListItem",{"item":78,"name":9,"@type":76,"position":14},"https://docshare.wps.com/document/",{"item":80,"name":40,"@type":76,"position":81},"https://docshare.wps.com/document/research-report/",3,{"item":83,"name":65,"@type":76,"position":19},"https://docshare.wps.com/document/answer-of-respondent-ports-america-chesapeake-llc-to-the-amended-complaint/503047/",{"url":83,"name":65,"@type":85,"image":86,"author":91,"headline":65,"publisher":94,"fileFormat":97,"inLanguage":63,"description":67,"dateModified":98,"datePublished":99,"encodingFormat":97,"isAccessibleForFree":100,"interactionStatistic":101},"DigitalDocument",{"url":87,"@type":88,"width":89,"height":90},"https://docshare.wps.com/thumbnails/answer-of-respondent-ports-america-chesapeake-llc-to-the-amended-complaint/503047.png","ImageObject",300,407,{"name":92,"@type":93},"Jiven","Person",{"url":74,"name":95,"@type":96},"DocShare","Organization","application/pdf","2026-10-16","2026-10-03",true,{"@type":102,"interactionType":103,"userInteractionCount":44},"InteractionCounter",{"@type":104},"ViewAction",{"@type":106,"mainEntity":107},"FAQPage",[108,114,118],{"name":109,"@type":110,"acceptedAnswer":111},"What is PAC’s general position in this filing?","Question",{"text":112,"@type":113},"PAC denies the allegations in the Complaint’s introductory paragraph and denies most numbered allegations either as legal conclusions requiring no response or due to lack of sufficient information or knowledge.","Answer",{"name":115,"@type":110,"acceptedAnswer":116},"What limited facts does PAC admit?",{"text":117,"@type":113},"PAC admits it is a Delaware limited liability company with a principal office in Wilmington, and that it is a marine terminal operator under the Shipping Act. PAC also makes limited admissions in specific numbered paragraphs, while denying the remainder.",{"name":119,"@type":110,"acceptedAnswer":120},"How does PAC address the CBP Emergency Action Notification (EAN)?",{"text":121,"@type":113},"PAC admits that CBP issued an Emergency Action Notification dated January 14, 2020 for two containers on the CCMA bill of lading, and that a CCMA representative sent a copy of the EAN to PAC on January 15, 2020, denying the remainder of those allegations.","https://schema.org",{"og:url":83,"og:type":124,"og:title":65,"og:site_name":95,"og:description":67},"article",{"robots":126,"canonical":83},"index,follow",{"doc_id":128,"site_id":62},503047,1791261187,{"code":4,"msg":5,"data":131},{"doc_id":128,"user_id":132,"nickname":92,"user_avatar":133,"doc_module":4,"category_id":39,"category_name":40,"doc_title":65,"doc_description":67,"doc_content":134,"file_id":135,"file_url":136,"file_type":137,"file_size":138,"view_count":44,"is_deleted":4,"is_public":8,"is_downloadable":8,"audit_status":8,"page_count":44,"language":139,"language_code":63,"site_id":62,"html_lang":63,"table_of_contents":140,"faqs":141,"seo_title":142,"seo_description":67,"update_tm":143,"read_time":144},1099513958607,"https://ap-avatar.wpscdn.com/avatar/100002390cf8733938c?x-image-process=image/resize,m_fixed,w_180,h_180&k=1778829742770036399","BEFORE THE FEDERAL MARITIME COMMISSION  \nCCMA, LLC )  \n)  \nComplainant, )  \n)  \nv. )  \n) FMC Docket No. 22-01  \nMAERSK A/S AND PORTS AMERICA )  \nCHESAPEAKE, LLC )  \n))  \nRespondent. )  \n________________________________________________)  \nANSWER OF RESPONDENT PORTS AMERICA CHESAPEAKE, LLC  \nTO THE AMENDED COMPLAINT  \nRespondent Ports America Chesapeake, LLC (“PAC”), by and through its undersigned counsel, hereby answers the Amended Complaint (“Complaint”) ofCCMA, LLC (“Complainant” or “CCMA”) as follows:  \nINTRODUCTORY STATEMENT AND GENERAL DENIAL  \nPAC denies the allegations in the introductory paragraph of the Complaint alleged against PAC, as they constitute legal conclusions to which no response is required, and to the extent a response is required, PAC denies the allegations. PAC lacks sufficient information or knowledge to enable it to respond to the allegations against the other Respondent, and therefore denies those allegations.  \n1. PAC lacks sufficient information or knowledge to enable it to respond to Paragraph 1 of the Complaint, and therefore denies the allegations.  \n2. PAC lacks sufficient information or knowledge to enable it to respond to the allegations of Paragraph 2 against the other Respondent and therefore denies the allegations.  \n3. PAC admits that it is a limited liability company organized and existing under the laws of the state of Delaware, registered with the Maryland Secretary of State as having a principal office address of 1209 Orange Street, Wilmington, DE 19801, and that PAC is a marine terminal operator within the meaning of the Shipping Act. The remainder of Paragraph 3 is denied.  \n4. Admitted.  \n5. The allegations in Paragraph 5 constitute legal conclusions to which no response is required. To the extent a response is required, PAC admits only that the Shipping Act speaks for itself, and denies the remainder.  \n6. PAC lacks sufficient information or knowledge to enable it to respond to the allegations of Paragraph 6 against the other Respondent and therefore denies the allegations.  \n7. Admitted.  \n8. Denied.  \n9. PAC lacks sufficient information or knowledge to enable it to respond to Paragraph 9 of the Complaint, and therefore denies the allegations.  \n10. PAC lacks sufficient information or knowledge to enable it to respond to Paragraph 10 of the Complaint, and therefore denies the allegations.  \n11. PAC admits only the second and third sentences of Paragraph 11. PAC lacks sufficient information or knowledge to enable it to respond to the first sentence of Paragraph 11 of the Complaint, and therefore denies the allegations.  \n12. Admitted as to PAC’s operation of Seagirt Marine Terminal, but lacks sufficient information or knowledge to enable it to respond to the allegations concerning the “designation”to “process.”  \n13. Admitted.  \n14. Admitted.  \n15. Admitted.  \n16. PAC admits that on December 27, 2019, PAC informed CCMA that CBP had found pests and seeds on two of the containers, but denies the remainder of Paragraph 16.  \n17. PAC admits that communications between CCMA and representatives of PAC occurred on January 2, 2020, denies the remainder of Paragraph 17 as to PAC, and lacks sufficient information or knowledge to enable it to respond to the allegations of Paragraph 17 against the other Respondent and therefore denies the allegations.  \n18. PAC admits that CBP issued an Emergency Action Notification (“EAN”) dated January  \n14, 2020 for two containers on the CCMA bill of lading. The EAN speaks for itself and the remainder of Paragraph 18 is denied.  \n19. PAC admits only that on January 15, 2020, a CCMA representative sent a copy of the EAN to PAC, and PAC denies the remainder of Paragraph 19.  \n20. The allegations in Paragraph 20 are vague and ambiguous, PAC lacks sufficient information or knowledge to enable it to respond to the allegations of Paragraph 20, and to the extent a response is required, PAC denies the allegations.  \n21. PAC admits the first and second sentences of ","cbCairUavrlupfeL","https://ap.wps.com/l/cbCairUavrlupfeL","pdf",462498,"English","# Introductory Statement and General Denial\n# Numbered Paragraph Responses (1-29)","[{\"question\":\"What is PAC’s general position in this filing?\",\"answer\":\"PAC denies the allegations in the Complaint’s introductory paragraph and denies most numbered allegations either as legal conclusions requiring no response or due to lack of sufficient information or knowledge.\"},{\"question\":\"What limited facts does PAC admit?\",\"answer\":\"PAC admits it is a Delaware limited liability company with a principal office in Wilmington, and that it is a marine terminal operator under the Shipping Act. PAC also makes limited admissions in specific numbered paragraphs, while denying the remainder.\"},{\"question\":\"How does PAC address the CBP Emergency Action Notification (EAN)?\",\"answer\":\"PAC admits that CBP issued an Emergency Action Notification dated January 14, 2020 for two containers on the CCMA bill of lading, and that a CCMA representative sent a copy of the EAN to PAC on January 15, 2020, denying the remainder of those allegations.\"}]","ANSWER OF RESPONDENT PORTS AMERICA CHESAPEAKE, LLC - TO THE AMENDED COMPLAINT | PDF",1791048712,23]