Sample only. Names, dates, invoice numbers, dollar figures, and the law firm shown above are illustrative. The legal substance, statutory citations, case authority, evidentiary structure, damages framework, and time-limited acceptance mechanics shown here reflect how a competent commercial collections attorney drafts a real pre-suit demand letter on a defaulted receivable governed by New York law.
Holloway Commercial Law, P.C.
1185 Avenue of the Americas, Suite 3100
New York, NY 10036
Tel: (212) 555-0177 · mholloway@holloway-commercial.example
May 4, 2026
VIA CERTIFIED MAIL,
RETURN RECEIPT REQUESTED
AND ELECTRONIC TRANSMISSION
(accounts.payable@meridian-procurement.example)
Ms. Kara M. Donovan, Chief Financial Officer
Meridian Procurement Group, Inc.
88 Pine Street, 18th Floor
New York, NY 10005
Re: Final Demand for Payment — Master Services Agreement dated October 14, 2024 (the “Agreement”); Invoice Nos. AB-2025-1182, AB-2025-1241, and AB-2025-1289
Outstanding Balance: $284,612.00 in unpaid principal, plus accrued contract interest, late fees, and collection costs
Demand Open Through: 5:00 p.m. Eastern Time, May 18, 2026 (fourteen days)
Dear Ms. Donovan:
This firm represents Apex Bridge Logistics, Inc. (“Apex Bridge” or our “Client”) in connection with the unpaid balance owed by Meridian Procurement Group, Inc. (“Meridian”) under the Master Services Agreement dated October 14, 2024 between the parties (the “Agreement”). As of the date of this letter, three undisputed invoices remain unpaid in the aggregate principal amount of $284,612.00, the oldest of which is now ninety-six days past due. We write to make a final pre-suit demand for payment in full, with contract interest, late fees, and collection costs, on or before 5:00 p.m. Eastern Time on May 18, 2026. The deadline is set in good faith and is fully sufficient to authorize and execute a wire transfer through any commercially reasonable treasury function.
Failure to remit on the terms set out below will result in the immediate filing of a verified complaint in the Supreme Court of the State of New York, County of New York, for breach of contract, account stated, and unjust enrichment. The Agreement contains an exclusive New York forum-selection clause (§ 14.4) and a contractual attorney’s-fee shifting provision in favor of the prevailing party (§ 14.6). Both will be enforced.
I. The Agreement and the Unpaid Invoices
On October 14, 2024, Apex Bridge and Meridian entered into the Agreement, under which Apex Bridge furnishes contract logistics services on Meridian’s behalf, including dedicated cross-dock capacity at Apex Bridge’s Newark, New Jersey facility, line-haul scheduling, and chain-of-custody manifesting for Meridian’s electronics-grade freight. Meridian’s payment obligations are governed by Sections 4 and 5 of the Agreement and by the Statement of Work executed concurrently (Exhibit A). Standard payment terms are net thirty.
Apex Bridge issued, and Meridian received, the three invoices listed below. Each invoice was timely transmitted, conforms to the Agreement’s invoicing requirements, and identifies the related Statement of Work line items. None has been the subject of any written objection, counterclaim, or set-off notice within the fifteen-day dispute window prescribed by Section 5.3 of the Agreement.
| Invoice | Service period | Issued | Due | Days past due | Amount |
|---|---|---|---|---|---|
| AB-2025-1182 | Dec 16-31, 2025 | Jan 2, 2026 | Feb 1, 2026 | 96 | $118,940.00 |
| AB-2025-1241 | Jan 1-15, 2026 | Jan 17, 2026 | Feb 16, 2026 | 81 | $87,420.00 |
| AB-2025-1289 | Jan 16-31, 2026 | Feb 2, 2026 | Mar 4, 2026 | 65 | $78,252.00 |
| Unpaid principal | $284,612.00 | ||||
Apex Bridge has fully and faithfully performed all conditions, covenants, and obligations under the Agreement that, on its part, are required to be performed. Acceptance of the underlying services is documented by Meridian’s signed bills of lading, ASN confirmations, and absence of any rejection notice within the acceptance period defined at Section 6.2 of the Agreement.
II. Default and Causes of Action
Breach of contract. Meridian’s failure to remit payment on each of the invoices identified above is a material breach of Sections 4.1 and 5.1 of the Agreement. Under New York law, the elements of breach of contract are (1) a valid contract, (2) plaintiff’s performance, (3) defendant’s breach, and (4) damages. Harris v. Seward Park Hous. Corp., 79 A.D.3d 425, 426 (1st Dep’t 2010). All four elements are met on the face of the Agreement and the invoices.
Account stated. An account stated arises from the retention of invoices by a debtor who, having received them, fails to object within a reasonable time. Morrison Cohen Singer & Weinstein, LLP v. Waters, 13 A.D.3d 51, 52 (1st Dep’t 2004). Meridian’s receipt of each invoice is documented; Meridian raised no written objection within the contractual fifteen-day window or at any subsequent time. The unpaid balance is therefore an account stated and may be liquidated on summary judgment.
Unjust enrichment. In the alternative, Meridian has been enriched at Apex Bridge’s expense by accepting and consuming the contract logistics services and would be unjustly enriched if permitted to retain that benefit without payment. Mandarin Trading Ltd. v. Wildenstein, 16 N.Y.3d 173, 182 (2011).
III. Contract Interest, Late Fees, and Total Demand
Section 5.4 of the Agreement provides for contract interest on past-due amounts at the rate of one and one-half percent (1.5%) per month, or the maximum rate permitted by applicable law, whichever is less. That rate is enforceable as a matter of New York law and is below the criminal-usury threshold of N.Y. Penal Law § 190.40. Section 5.5 provides for a late fee of one percent of the invoice amount per calendar month, capped at five percent of the invoice. The accrued amounts as of the date of this letter are itemized below and are recalculated daily until paid.
| Component | Basis | Amount |
|---|---|---|
| Unpaid principal | Three invoices, supra | $284,612.00 |
| Contract interest at 1.5%/mo | § 5.4 (per-invoice accrual through May 4, 2026) | $10,488.42 |
| Late fees | § 5.5 (capped 5% per invoice) | $10,212.96 |
| Pre-suit collection costs | § 14.6 (Apex Bridge ledger, Exhibit B) | $3,820.00 |
| Total demand as of May 4, 2026 | $309,133.38 | |
Interest accrues each day at $140.32. Should suit be filed, prejudgment statutory interest at nine percent per annum from the earliest date the cause of action accrued is also recoverable as a matter of right under N.Y. C.P.L.R. §§ 5001 and 5004; the contract rate (1.5% per month, 18% per annum) controls between contracting parties and exceeds the statutory rate, so the contract rate will be sought in any verified complaint.
Goods component, if any. To the extent any portion of the underlying transactions is characterized as a sale of goods rather than services, the New York Uniform Commercial Code applies. Buyer’s acceptance under N.Y. U.C.C. § 2-606, and the seller’s right to recover the contract price under § 2-709, fully support the demand. The hybrid character of contract logistics services does not affect the result on the facts presented.
IV. Time-Limited Demand and Acceptance Terms
On the basis of the documented breach and the documented damages above, Apex Bridge hereby demands payment of $309,133.38, plus per-diem interest of $140.32 from May 5, 2026 until the date funds are received, by wire transfer to the Apex Bridge operating account at JPMorgan Chase Bank, N.A., wire instructions attached as Exhibit C.
Acceptance. This demand is open through 5:00 p.m. Eastern Time on May 18, 2026. Acceptance is effected by Meridian’s receipt by Apex Bridge’s bank of cleared funds in the demanded amount on or before the deadline. No partial tender, post-dated commitment, or course-of-dealing extension will satisfy this demand.
Reservation of rights. Apex Bridge reserves all rights, including the right to suspend further performance under Section 7.3 of the Agreement, the right to declare the Agreement terminated for cause under Section 12.2, the right to accelerate any future-billed minimum-volume obligations under Section 4.5, the right to assert claims for consequential and incidental damages where contractually recoverable, and the right to register the unpaid balance with credit-reporting agencies and trade associations within the meaning of the Fair Credit Reporting Act, 15 U.S.C. § 1681 et seq., once the demand window closes.
V. Litigation Hold and Statute of Limitations
Litigation hold. Meridian and each of its officers, agents, and contractors are hereby placed on notice of a pending dispute and are required to preserve, and to instruct each custodian to preserve, all documents and electronically stored information relating to the Agreement and the unpaid invoices, including but not limited to: signed bills of lading; ASN confirmations and EDI transaction logs; accounts-payable ledgers and aging reports; treasury-function communications; emails, Slack messages, and Teams chats discussing the Apex Bridge relationship; and any minutes or memoranda referencing the unpaid balance. Spoliation will be the subject of an adverse-inference application at trial.
Statute of limitations. The applicable limitations period is six years for contract claims under N.Y. C.P.L.R. § 213(2), and four years for any U.C.C. Article 2 claim under N.Y. U.C.C. § 2-725. Apex Bridge does not waive and will not extend the statute and intends to file suit promptly upon expiration of this demand if it is not paid in full on the terms set forth above.
VI. Exhibits Indexed to This Demand
- Exhibit A — Master Services Agreement and Statement of Work, fully executed
- Exhibit B — Pre-suit collection-cost ledger
- Exhibit C — Wire transfer instructions, Apex Bridge operating account
- Exhibit D — Invoices AB-2025-1182, AB-2025-1241, AB-2025-1289 with detail
- Exhibit E — Signed bills of lading and ASN confirmations
- Exhibit F — Aging report and contemporaneous accounts-payable correspondence
Apex Bridge values its commercial relationship with Meridian and would prefer to resolve this matter without litigation. The terms of the Agreement nonetheless require performance and provide for fee-shifting and interest at the rates set out above. Please direct your written response, and any settlement counterproposal, to the undersigned at the address above or by email to mholloway@holloway-commercial.example. We are willing to discuss a brief payment plan supported by a confessed-judgment instrument and personal guaranty if that is the only path to full satisfaction.
We are not willing to extend the deadline absent a confirmed and creditable proposal in writing. Govern yourself accordingly.
Very truly yours,
Holloway Commercial Law, P.C.
By: ____________________________
Marcus T. Holloway, Esq.
NY Bar #4582019 · NJ Bar #034712019
cc: Apex Bridge Logistics, Inc. (client); claim file
Enclosures: Exhibits A through F (indexed)
Sample only. Names, dates, invoice numbers, dollar figures, and the law firm shown above are illustrative. The legal substance, statutory citations, case authority, evidentiary structure, damages framework, and time-limited acceptance mechanics shown here reflect how a competent commercial collections attorney drafts a real pre-suit demand letter on a defaulted receivable governed by New York law.