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HomeMy WebLinkAbout02-5469JTH TAX SERVICES LLC, JAMES S. HARRIS AND TERRI HARRIS, Husband and Wife, VS. Applicants, G.H. HARRIS ASSOCIATES, INC., Respondent. : IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA .' CIVIL ACTION - LAW PETITION IN THE FORM OF AN APPLICATION TO STAY ARBITRATION Applicants JTH Tax Services LLC, James S. Harris and Terri Harris, husband and wife, make application to this Court pursuant to 42 Pa. C.S. § 7304(b) (Court proceedings to compel or stay arbitration; stay of arbitration), 42 Pa. C.S. § 7317, and 42 Pa. C.S. § 7342 (Procedure) for an order staying arbitration, and in support of their application aver the following: PARTIES 1. Applicant JTH Tax Services LLC ("JTH") is a corporation organized under the laws of the Commonwealth of Pennsylvania with its office located at 70 Marfield Circle, Hanover, Pennsylvania 17331, and conducting business in Cumberland County. 2. Applicants James S. Harris and Terri Harris, husband and wife, are adult individuals residing at 70 Marfield Cimle, Hanover, Pennsylvania 17331. 3. Respondent G.H. Harris Associates, Inc. ("G.H. Harris") is a corporation organized and existing under the laws of the Commonwealth of Pennsylvania, having its principal place of business at R.R. 4, P.O. Box 216, Dallas, Pennsylvania 18612, and conducting business in Cumberland County. 4. G.H. Harris is in the business of collecting delinquent taxes and also serving as deputy tax collector for various nmnicipal taxing authorities in Pennsylvania, including a portion of the Cumberland Valley School District. (See Demand for Arbitration, attached to this Application as Exhibit A, ~ 6). VENUE 5. This Court has jurisdiction over this application pursuant to 42 Pa. C.S. § 7319 (venue of court proceedings) and Pa. R.C.P. 2179 because: (1) Cumberland County is a county where G.H. Harris regularly conducts its business; (2) is a county where a transaction or occurrence took place out of which the demand for arbitration arose; and (3) because the Purchase Agreement between G.H. Harris and James P. Harris does not prescribe where the arbitration hearing shall be held. FACTS 6. On or about October 31, 2002, G.H. Harris served upon JTH, James S. Harris and Terri Harris a copy of its Demand for Arbitration,~ in which G.H. Harris requests, inter alia, an injunction against JTH by a three member arbitration panel for an alleged violation of a "non-compete" provision in a contract to which JTH, James S. Harris and Terri Harris are not a party. A copy of the Demand for Arbitration is attached to this Application as Exhibit A. 7. This Court has authority to stay the arbitration of G.H. Harris's demand for arbitration against JTH, James S. Harris, and Terri Harris, pursuant to 42 Pa. C.S. §§ 7304(b), (d) and 42 Pa. C.S. § 7342. 8. This Court's inquiry in determining whether to stay the arbitration involves determining: (I) whether a valid arbitration agreement was entered into, and, if so, (2) whether the dispute in question is within the scope of the arbitration provision. See PBS Coal, ~ On November 7, 2002, the American Arbitration Association ( AA ) acknowledged receipt of G.H. Harris's Demand for Arbitration that includes as parties: G.H. Harris, JTH, James S. Harris, Terri Harris, James P. Harris, Kathy Harris, and J.P. Harris Associates, LLC. The AAA case number 14-199-02058-02. -2- Inc. v. Hardhat Min., Inc., 429 Pa. Super. 372, 632 A.2d 903 (1993) (citing Flightways Corp. v. Keystone Helicopter Co., 459 Pa. 660, 663,331 A.2d 184, 185 (1975)). 9. JTH, James S. Harris and Terri Harris did not enter into an arbitration agreement with G.H. Harris. 10. On August 25, 2000, G.H. Harris allegedly entered into a "Market Region Purchase Agreement" ("Pumhase Agreement") with Mr. and Mrs. James P. Harris, individuals,2 in which G.H. Harris sold a portion of its tax collection business to Mr. and Mrs. James P. Harris. A true and correct copy of the Purchase Agreement is attached to this Application as Exhibit B, and made a part hereof as if incorporated in full herein. 11. The Purchase Agreement is between G.H. Harris and Mr. and Mrs. James P. Harris, individuals; it is signed by G.H. Harris, individually and as President of G.H. Harris Associates, Inc., and James P. Harris, individually and for his associated business entities. Exhibit B, p. 7. 12. The Purchase Agreement has attached to it a "Consent of Spouses & Affected Family Members," to which are affixed the signatures of Kathy Harris, Viola Harris, Paul Adamshick, and Patricia Adamshick. The attachment also is initialed by G.H. Harris. Exhibit B, p. 8. 13. The Purchase Agreement contains a provision requiring that disputes "between the Parties''3 be submitted to "final and binding arbitration with exclusive venue, 2 James P. Harris is the son of G.H. Harris and the father of James S. Harris. 3 The term "Parties" is never defined in the Purchase Agreement but a thorough reading of the Purchase Agreement appears to indicate that the term meant G.H. Harris and James P. Harris. -3- personal jurisdiction, and hearing authority vested in AAA, Philadelphia, Pennsylvania, under its Commemial Rules using a panel of three arbitrators." Exhibit B, § 4.6.2, p. 5. 14. The Pumhase Agreement arbitration provision is initialed by James P. Harris, as buyer, G.H. Harris, as seller, G.H. Harris, individually, Viola Harris, individually, Paul Adamshick, individually, Patricia Adamshick, individually, and Kathy Harris, individually. Exhibit B, p. 6. 15. JTH, James P. Harris and Terri Harris are not parties to the Purchase Agreement. 16. JTH, James P. Harris and Terri Harris are not signatories to the Purchase Agreement. 17. JTH, James P. Harris and Terri Harris have not entered into an arbitration agreement with G.H. Harris. 18. A contract cannot legally bind persons not a party thereto. Cumberland- Perry Area Vocational-Technical Sch. Auth. v. Bogar & Bink, 396 A.2d 433, 435 (Pa. Super. 1978). 19. The arbitration clause in a contract can be enforced only by signatories to a contract. See, e.g., Dayhofflnc. v. H.J. Heinz Co., 86 F. 3d 1287, 1296 (3d Cir. 1996). 20. Counsel for Applicants JTH Tax Services LLC, James S. Harris and Terri Harris, husband and wife, contacted counsel for G.H. Harris Associates, Inc., and he does not concur. -4- WHEREFORE, Applicants JTH Tax Services LLC and James S. Harris and Terri Harris, husband and wife, request that this Court issue an order staying the commenced arbitration proceeding against them, with all proceedings to be stayed pending a determination of this Application. Date: November 12, 2002 Respectfully submitted, NNAL. FISHER (39410) pAe~ eXrAHNaD~iAo nM~AL pK O S K Y (80267) 200 One Keystone Plaza North Front and Market Streets P.O. Box 1181 Harrisburg, PA 17108-1181 (717) 255-1155 (717) 238-0575 (Fax) Attorneys for Applicants JTH Tax Services LLC, James S. Harris and Terri Harris, Husband and Wife -5- Exhibit A AMERICAN ARBITRATION ASSOCIATION COIHMERCLA l: ARBITRATION RULES DEMA=.ND FOR ARBITRATION ~ON 1.~ ct nonblndlng proc~$, the mediator c$~M~t~ the parHr~ tn workl, mit a ~o/ution th wish/or the ~ to contact the otfier -artl~ to .......... L .... . · . n~. . at is acceptable to th~m Z 'v ~ addltl°ncd admi~istratlvzrf;, or th'~;~:;"' ='='n'r mcy wt$~ to madlate tlti~ matter, plea~, ol~ck this box o~ Name Sac Attached List of Partial Address City State Phone No. · Fax No. Zip Code Namo of Firm (if applicablo) City State Phone No Fax No. Zip Code The aaraed cia/mast, a party to an ' ' · 08/28/00 a~bitrauon agreemant contained i~ a written contract, dated · . _ and providing for arb/Ixa~ion under the Commercial Arbitration Rul~ of ~ dema~d~ arbi/ration there,ruder. 15 THIS A DisPl/n~ BETWl~L=N A BUS.ESS AND A CONSUMER? ~ Yes ~ No TI~E NATURE OF THE DISPUTE See Attached Demaud for Arbitration THE CLAIM OR Rg_r:n~F SOUGHT {~o Preliminary and P~rmananC I~Juncr.~on., plus liquidated d~ges in excess of $5,000, comPenaatory da~ge8 of approxi~tely $38,000, punitive d~$es, and all DOES ~ DISP~ ~SE OUT OF AN ~LOM~ ~LATION$~ ~ Y~ ~ No T~ES OF BUS.SS Cl~t~elinquen~ tax co~ l~c~ors Re~on~nt Delinquent ~ collectors You aro h~rcby no~fi~d ~t copies ~f o~ ~b~fion ~ ~ ~ ~8 ~ ~i~ filed wi~ ~ ~eric~ ~bi~afion. Under the roles, y~u may file ~ ~efing ' office, w~.a request ~t ~t co~enco a~s~on of~e ~e of Cla~nt ~' 9,~. ~arrip 6~sociate$, Inc.I Steven E, Gruhh · .~at~u~u$~lnC~n~gonw hThisCa~) ~ ....... , i .. ~r , - ..... a~W'"'~'L~- · p.O. Box 216 ]320 Market $treet ~i~la~, ] pi , ] 18612 ~Harrtsburg ~Pl ,'-, O~G~AL DE.ND ........ f~ ~o r~uv~m rU~ ~N T~ RULES, TO ~E A~ S~D THE Au i~ ~sFO~E~T. ' Po~ FC2.02/0 J.P, Harris Associates, LLC P.O. Box 226 . 101 Rich. Valley Road Mechanicsburg, Pennsylvania 17,055 James P. Harris and Kathy Harris, husband and Wife 1'01 Rich Valley Road Meehanicsburg, PA 17055. JTH Tax.ServiCes, LLC ' Mailing address: P.O. Box 327 Mechanicsburg, Pennsylvania 17055' Street address: . 70 Marfield Circle Hanover, Pennsylvania 1733 I. · lames $. Harris and Terri Harris. husband and wife 70 Mantle, id Circle Hanover, Pennsylvania 17331 Representative: Anna. Marie Sossong, Esq. Skarlatos and Zonarich 204 State Street Harrisburg, PA 17101 DEMAND FOP. ARBITRATION Plaintiff, G.H. Harris AssOciates, Inc., demands arbitration and judgment in its favor based on the following facts: 1. . Plaintiff, G.H. Harris Associates, Inc. ('~G.H. Harris"), is a Pennsylvania Corporation with a principal place of business in Dallas, Pennsylvania. 2. Defendant, LP, Harria:A~sociates, LLC CJPH"), is a Pennsylvania limited liability company with a mailing address of P.O; Box 226, Mechanicsburg, Pennsylvania 17055 and a street address of 101 Rich Valley Road', Mechanicsburg' Pennsylvania 17055. Defondants, James P. Harris and Kathy Harris, husband and wife, are adult 'individuals with a mailing address of I01 Rich Valley Road, Mechanicsburg, PA 17055. · 4. Defendant, JT[-[ Tax Services, LLC (!'JTH'), is a Pennsylvania limited liability company With a mailing address of P.O. Box 327, M~chaniosburg, Pennsylvania 17055 and a street addr*ss of 70 Marfield Circle, Hanover, Permsylvania 17331. 5. Defendants, Jam~s S. Harris and Terri Harris, husband and wife, are adult individUals residing at 70 Marfiold Circle, Hanover, P~nmylvania 17331. 6. O.H. Harris collects delinquent taxes, and also serves as deputy tax collector for various municipal taxing authorities. 7. James P. and Kathy Harris previously were employed by G.H. Harris. 8. On or about August'28, 2000, G.H. Harris entered into ,~ Market Region Purchase Agreement (the "Agreement") with James P. Harris, a copy of which is attached hereto as Exhibit "A". 9. The Agreement was intended to formalize James P. and Kathy ltarris' tbrmation ora new bminess which would effectuate a split from G.H. Harris. 10. The parties wished !~o define the parameters of the business split and memorialize which customers would remain wi~:each business. 1 l. Exhibits 1 and 2 to the Agreement detail who would service which account. 12. Each party agreed not to solicit, or in any way compete, for the accounts divided by the parties, per ttie Agreement. ~ Soction 1.1 oft.he Agreement. 13. The division of accounts, and. covenant not-to-compete was of the "essence" and perhaps the most important component of.the overall Agreement. See Section 3.4 of the Agreement. 14. The Agreement is binding and inures to the benefit 0fthe signatories, their representatives, administrators, assigns md/or successors-in-interest. It is also binding upon James P~ 'and Kathy Harris~ childrer~ and all business.entities in which they have a direct or indirect ovmemlaip interest. ~1~ Section 4:7 0fthe Agreement. Gee_ also the signature line for James P. Harris where he signs for his "wife, children and ~ssoeiated business entities.") 15. James ?. Harris warranted that he had full authority to bind his children. (~ Section 4.7' o£the AgreemenL) 16. On or ~bout October 25, 2001, JTH was organized, purportedly by James S. and Terd' L, Harris. 17.. James S. Harris is the only son of James P. and Kathy Harris, and Terri Harris is the daughter-in-law of James P. and Kathy Harris, t 8, James S. Harris is a civil engineer by trade and maintains a flail time job with an engineering firm in Maryland. ~9. JTH's registered address and office is in Hanover, Pennsylvania, as indicated above. 20. Despito their registered office being in Hanover, Pennsylvania, JTH maintains a post office box at the same post office as JPH. 21. ' James p. Harris regularly picks up mail for JTH at the Mechanicsburg Post Office. 22, JTH is using the exact same delinquent tax forms used by JPH and G.H. Harris. 23. JPH designed and l~roduced the delinquent tax forms for JTH. 24. JTH and JPH use the same deputy tax collector employees - Christopher Freitas and William Nievus. 25. Mssrs. Freitas and Nievus are the only deputy tax collector employees employed by both. JTH and JPH. 26. Kathy. Harris trained Terri Harris in administrative matters pertaining to how JTH should be rtm~ including the use ofcomputex, sofiware that JPH provided or copied over to JTH. 27, Kathy Harris prepared proposals for potential customers of JTH's 28. James P. H&rris trained and assisted James S, Harris in how to effectively give a sales presentation to potential clients, 29. James P, Harris attended Sales presentations given by James $. Harris, on behalf of JTH. 30. James P. and Kathy Harris have been actively marketing JTH and introducing JTH to various municipalities and tax colleCtors throughout Central Pennsylvania, all of which are municipalities JPH is prohibited from doing business with under the Agreement. 31. Silver Spring and Middlesex Townships, within the Cui>aberland Valley School District, no longer use G.H. Harris for tax collection services. 32. Silver Spring and Middlesex Townships now use JTH for tax collection services. 33. Silver Spring and Middlesex Townships had been cliems of G.H. Harris for over forty (40)years 34. On or about June 18, 2002, Tuscarora School District informed G.H. Harris that it was not renewing its agreement for tax collection services. 35. Tuscarora had been a client of G.H, Harris for ten (l 0) years. 36. Tuscarora School Disu'ict now utilizes JTH.for tax collection services. 37. Farmett Township and Metal Township, within the Fannett-Metal School District, now use JTH'for tax collection services. 38. Farmett and Metal Townships had been clients of G.H. Harris for over forty (40) years, 39. Tuscarora, Silver Spring, Middlesex; Fannett and Metal Townships were all G.H. H~ris customers under the Agreement. 40. It is believed, and ~herefore averred, that Cumberland Valley School District will assign Hampden and Monroe Townshlp accounts to JTH in the coming year. 41. JTH is a front set up by ~H, James ?. Harris and Kathy Harris to attempt to avoid the restrictive covenants of the Agreement and injure the business interests of his father. 42. James P. and Kathy Harris' actions through JTH. are deliberate and intentional and done with the intent of ir0uring the business, of G.H. Harris, and take G.H. Harris' business, through tl~ ~ontrived JTH business entity. 43. JTH has not solicited or competed for any account ' ' of JPH s. 44. It is believed that JTH, aided and abetted by James P. and Kathy I-tan'is, continues to solicit.O.H. Harris' clients in an,effort to harm the business interests of James P. Harris' father and James S. Harris' grandfather. 45. James P. and Kathy Harris, jointly and severally, have guaranteed compliance with the terms of the Agreement on behalf of any person or business entity through which he or she may xvork, consult, manage or have any ownership interest..See Section 3.4 of the Agreement. 46. Arbitration of this dispute by a panel of 3 is mandated by Section 4.6.2 of the aaached Agreement. 47. $TH, James S. and Ten4 Harris, as. the agent.and alter ego of JPH, organized to avoid the terms of the Restrictive Covenant, is bound by the terms of the Arbitration Clause, 48. Inmaediate heating on the equitable portion of this claim is demanded within ten ~10) daya of submission per Section 4,6.4 of the Agreement, 49, Final hearing on the merits is demanded w/th thirty (30) days of submission per Section 4.6.3 of the Agreement. 50. COUNT I. BREACH OF RESTRICTIVE COVENANT~; The allegations of 1-49 are incorporated by references as if set out in full. ~.~1. The actions of James P. and Kathy Harris, their children, and associated business entitie~ a~e in-violation of the Agreement, in' that they have solicited and taken business, namely Silver Spring, Middlesen, Metal and Farmett Townships and the Tuscarora School District, in violation of the restrictive covenants contained in the Agreement 52. G.H. Harris has abided by the Agreement in all respects. 53. The. continued solicitation of G.H. Harris' clients by JPH and JTH constitutes irreparable harm for which there is no adequate remedy at law. 54. An in. junction is demanded to prohibit this future conduct, which is reasonably tailored to abate Defendants' conduct. 55. An immediate preliminary iqjunction is demanded since G.H. Harris has a strong likelihood of success on the merits. 56. An immediate preliminary iqjuncfion will maintain the status quo and prohibit Defendants' conduc~ which is contrary to the Agreement. 57. Greater harm will result fi.om denial of an injunction, than the granting of the injunction in that without granting the injunction, JPH and JTI-I will continue to solicit and rake G.H. Harris' clients~ contrary to the terms of the Agreement. It is believed that Hampden and Monroe Township accounts will soon be turned over to JTH through the efforts of~H and James P. and Kathy Harris. 58. The parties have vested the arbitration panel with the ability to accord these remedies. (See Section 4.6.2 of the Agreement) WHEREFORE, the following relief is requested: {A) The Arbitration Panel enter an order which preliminarily aad permaneatly ~.njOins all defendants from soliciting those accounts, which are properly G.H. Harris', as identified in the Agreement, for the duration of the Agreement. (B) JTH and James S, and Terri Harris terminate their agreements to collect delinqtmnt taxes with the Tuscarora School District and Fannett, Metal, Silver Spring and Middlesex Townships. (C) Pursuant to the terms of the Agreement, at Section 4.6.8, all costs, including reasonable attorneys fees necessary to enfor~ this Agreement, be awarded in thvor of O.H. Harris, (D) All Defendants be required to pay, as damages to G.H. Harris, all lost reveaues O.H. Harris sustained as a ~;esult of Defendants' violation of the contract. (E) The Arbitrator award liquidated damages in excess of $1,000.00 per incident of solicitation, which presently is known to be five incidents, and which shall not be deemed compensatory Or punitive, pursuant to' Section 3.4 of the Agreement. (F) Whatever other remedy the Arbitrators deem proper under the circumstances, COUNT II- TORTIOUS INTERFERENCE WITH CONTRACTUAL RELATIONS 59. The allegations of 1-58 are incorporated by references as if set out in full. 60. Tuscarora School District and Silver Spring, Middlesex, Farmeu and Metal Townships had contractual relations with G.H. Harris for the collection of delinquent taxes. 61. By breazhing the Agreement, all defendants, acting as one, have inlerfered with rite Prel;ent and gu'rare contractual relationships G.H. Hatxis had with these school districts and municipalities. 62. Such interfirence was done with the intent of injuring the business of G.H. Harris. 63. Such interference is contrary to the Agreement and unjustified. 64; Collectively; Tuscal;ora School District and Silver Spring, Middlesex, Fannett and Metal Townships r~sulted in approximately $38,000.00 in profits per year to G.H. Harris. WHEREFORE, the following relief is requested: (A) The Arbitration Panel enter an order which preliminarily and permanently enjoins ail defendants from soliciting those accounts, which are properly G.H. Harris',' as · identified in the Agreement, for the duration of the Agreement. (B) .~TI-I and james S. and Terri Harris terminate their agreements to collect delinquent taxes with the Tuscarora School District and Fannett, Metal, Silvtn' Spring and Middlesex To.wnships. (C). Pursuant to' the terms of the Agrcement, at Section 4.6.8, all cost~, including r~.u_sonable attorneys re% necessary to enforce this Agreement, be awarded in favor of G.H. Harris, (D) Ail Defen~ont~ be required to pay, as damages to G.H. Harris, all lost revenue.~ O,H. Harris suatained a~ a resuit of Defendanta' violation of the contract. (E) The Arbilrat0r award liquidated damages in excess of $1,000.00 per incident of ~olicitation, which presently is known to be five incidents, and which shall not be deemed compensatory or punitive, pursuant to Section 3.4 of the Agreement. (F) Due to the outrageous, intentional and improper conduct, punitive damages are demanded. (0) Whatever other remedy the Arbitrators deem proper under the circumstances. COUNT III - BREACH OF REP ~I~ESENTATION AND WARRANTI~?; 65. The allegations of 1-64 are incorporated by references as if set out in full. 66. Alternatively, ifJTH is held not to be r~lated to `IPH, ,lames P. and Kathy Harris represented and warranted in Section 4.7 of the Agreement that they had full authority to bind their ohildren to the terms of the Agreement, especially the restrictive covenants. 2ames P. and Kathy Harris guaranteed, personally, compliance with the 67, Agreement. · 68, JTH, James S. and Terri Harris' obvious competition with G.H. Harris manifests that JTH is not abiding by the Agreement and doesnot believe it is bound by the Agreement. 69. James P. and Kathy Harris, thus, have breached the representation and warranty of Section 4.7 of the Agreement. WHIgREFORJg, G.H. Harris demands: (A) That the Arbitration Panel order James P. and Kathy Harris, jointly and severally, to pay G.H. Harris all amounts it has lost as a result of James P. and Kathy Harris' children breaching the Agreement, including all revenues and profits t3.H. Harris has lost as a result of losing customers to/TH. (B) The mount remain open, and periodically adjusted, based on the further busines~ that JTH procures, 'to the detriment of G.H. Harris. (C) All COSTS, including attorneys fees, associated with this action per Section 4,6.8 of the Agreement. (D) Any other romedy the Arbitration Panel deems proper under the c~'cumst~noe$.' Exhibit B This bo~ (~a ~ ~e bU~s ~ o~ ~e ~s op~cd fr~ his b ' Se~e~ ~ "M~h~lo~ NOW T~O~, goo~ ~s ~t ~uld ~ u~g ~ ~S~rs, t~ye~, ~ Per~p~ ~e P~es Mo~o~ O~ce ~ bo ~ ba~ ~e P~ as ~c~ B~o To~. Mor~ R~on ~hue A~cem~t 2,4. ~c~ ~ ~th ~ o~ ~ ~d~a~on for ~ls ~m~ B~ a~ees to ~y ~ell~ a~ follo~: 2.1. No dom pa~m~t m,b as warn. ole~ici~, e~. for ~e ~I1 m~ of A~. 2.2. 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TCR FROM m. H, ~:tRi~I~ I:I~S~C. INC. 'FO 5, H. ~l~IS R~. [NC. 17~72~6740 P. 97 Sg"EOOZ, + ,S'CBOO£ ~. J~ROr..IG~ EC'EOOL ~CHOOL .~ TOWNSHIP C~AlerO~, zowNm~zp 8~-25-~ ~3~ 21PM FE~3~I ~, H. N~{~; R$SOC. INC. ; P, 14 I: l, I I TnT~L p, ~.g VERIFICATION I, Donna L. Fisher, state that I am an attorney for JTH Services LLC, and James S. Harris and Terri Harris, that I am authorized to make this verification on their behalf, that they were unavailable to provide a verification within the time allowed for filing this pleading, and that this verification is made upon information and belief. This verification is made subject to the pen al ties of 18 Pa. C.S. § 4904. Dated: November 12, 2002 DONNA L. FiSHeR" - CERTIFICATE OF SERVICE I hereby certify that on November 12, 2002, a copy of the foregoing document was served by first class mail, postage prepaid, addressed as follows: Steven E. Grubb, Esquire Goldberg Katzman & Shipman, P.C. 320 Market Street, Strawberry Square P.O. Box 1268 Harrisburg, PA 17108-1268 John R. Zonarich, Esquire Skarlatos and Zonarich 204 State Street Harrisburg, PA 17101 Katharine LeGeros, Case Manager American Arbitration Association 950 Warren Avenue East Providence, RI 02914 MAKOSKY (80267~ GOLDBERG, KATZMAN & SHIPMAN, P,C. Steven E. Grubb, Esq. I.D.# 75897 320 Market Street, Strawberry Square P. O. Box 1268 Harrisburg, PA 17108-1268 (717) 234-4161 Attorneys for Movants JTH TAX SERVICES, LLC, JAMES S. AND TERRI HARRIS, HUSBAND AND WIFE, Applicants Vo G.H. HARRIS ASSOCIATES, INC., Respondent IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA 02-5469 CIVIL TERM MOTION FOR CLARIFICATION AND TO LIFT STAY Movant, G.H. Harris Associates, Inc., by and through their counsel, Goldberg, Katzman & Shipman, P.C., allege the following in support of this Motion for Clarification and to Lift Stay: 1. Movant is G.H. Harris Associates, Inc. (G.H. Harris). 2. Respondents are JTH Tax Services, LLC and James and Terri Harris, husband and wife (hereinafter collectively referred to as "JTH"). 3. On October 31, 2002, G.H. Harris filed a ,demand for arbitration with the American Arbitration Association (AAA), which is attached hereto as Exhibit A. 4. The demand named JTH as a party, but also named James P. and Kathy Harris, as well as James P: Harris Associates, LLC as parties (hereinafter collectively referred to as "JPH."). 5. It is beyond conjecture that section 4.6 et seq. of the Market Region Purchase Agreement (the "Agreement") requires G.H. Harris and JPH to submit all disputes between them to arbitration. The Agreement is attached hereto as Exhibit B. 6. While the demand speaks for itself, one of the major issues in the demand was the enforcement of a covenant not-to-compete. 7. As alleged in the demand for arbitration, G.H. Harris believes that JTH is nothing more than a front for JPH and a means by which JPH could harm G.H. Harris by taking its clients. What JPH could not do directly, it did through a company set up by James P. and Kathy Harris, using their only child, James S. Harris, as a front. (See paragraphs 16-30 of Exhibit A). 8. JTH was named in the arbitration on the basis that it is nothing more than the alter ego and agent of JPH and because James P. and Kathy Harris represented they were binding their "children" to the non-competition agreement. See Section 4.7 of the Agreement. (See also the signature line for James P. Harris where he signs fbr his "wife, children and associated business entities.") 9. Considering the nature of the claim, G.H Harris exercised its right to an immediate hearing to obtain a preliminary injunction per Section 4.6.4 of the Agreement. 10. Obviously, time is of the essence in matters such as this since the consequences of JPH and JTH's actions could be destructive to G.H. Harris' business. 11. AAA scheduled an administrative conference call for November 13 at 2 p.m. to set a schedule for the preliminary injunction hearing. 2 12. JTH filed its "Petition in the Form of an Application to Stay Arbitration" late on the afternoon of November 12, 2002. The next morning, the court issued an Order of Court attached hereto as 13. Exhibit C. 14. Paragraph 1 of the order directs G.H. Harris to show cause why "American Arbitration Association, Case Number 14-199-02058-02 should, not be stayed for JTH Tax Services LLC and James S. Harris and Terri Harris, husband and wife." 15. The court, in paragraph six, at the request of JTH, made an ex parte order enjoining the JTH's involvement in the arbitration as follows: "All proceedings in this matter are stayed pending further order of this court." 16. An issue has arisen as to whether the reference to "all proceedings in this matter" refers to the entirety of Case Number 14-199-02058-02, including G.H. Harris' claims against JPH, or just those matters between G.H. Harris and JTH. 17. The AAA arbitrators have interpreted the court's order to stay only those arbitration proceedings between G.H. Harris and JTH and have proceeded to schedule a preliminary injunction arbitration hearing on November 18, 2002. AAA's decision is attached hereto as Exhibit D. 18. The words of the order, considered in the full context of the order, and the fact that the "proceedings" referenced therein could only refer to "proceedings" involving the only parties to the order, JTH, are clear that the order can, and only, applies to proceedings between G.H. Harris and JTH. 19. The court also ordered that discovery, briefs and argument on JTH's motion be completed by February 20, 2003. 20. Attached hereto as Exhibit E is §7304 of Pennsylvania's Arbitration Act. 21. As is clear in the act, stays of arbitration are governed by subsection b and stays of judicial proceedings are governed by subsection d. 22. §7304(b) provides that the issue of arbitrability is to be "forthwith and summarily tried and determined and a stay of the arbitration proceedings shall be ordered if the court finds for the moving party_." 23. §7304(b) does not permit an interim stay of an arbitration absent the court "find[lng] for the moving party." 24. §7304(d) requires that this issue be tried :summarily, as opposed to the process the court has ordered which will take four months. 25. The court, by granting JTH's ex parte request to enjoin the arbitration between JTH and G.H. Harris, without giving G.H. Harris the opportunity to be heard, has ordered a special injunction under Pa. R.C.P. 1531 (a), which must be dissolved in five (5) days, absent a heating on JTH's request. Pa. R.C.P. 1531(d). 26. JTH relies on §7304(d) in its petition as the grounds for the automatic, ex parte stay the court has ordered. 27. JTH's reliance is misplaced since §7304(d) only pertains to a stay of a judicial proceeding. §7304(d) would only be applicable if a party were seeking to stay a court 4 action involving an "issue subject to arbitration." The filing of an application to stay the court action is the only circumstance where the ex parte stay might be,' effectuated by the filing of a petition as JTH has done in this case. 28. Concurrence in this motion was sought ~rnd not granted by counsel for JTH and JPH. 29. Based on the above, the following relief is requested: The court clarify that the intent of its order was to only stay the proceedings between G.H. Harris and JTH, leaving G.H. Harris the ability to proceed in this time sensitive case with the preliminary injunction arbitration heating on November 18, as now scheduled. Pursuant to the clear words of §7304(b) which does not permit a stay absent a holding by the court in favor of the moving party after a summary trial on the issues, the court strike paragraph six of its November 13, 2002 order as having been improvidently granted due to the misleading arguments of JTH, Altematively, pursuant to §7304(b) the court "forthwith and summarily" try the arbitrability issues in this highly time sensitive case, well in advance of the February 20, 2003 date now stated in the court's order. It is suggested that the issue of arbitrability be tried no later than the end of November. Respectfully submitted, By: GOLDBERG, KATZMAN & SHIPMAN, P.C. Attorney I.D. No. 75897 320 Market Street, Strawberry Square P.O. Box 1268 Harrisburg, PA 17108-1268 Telephone: (717) :!34-4161 Attorney for Movant CERTIFICATE OF SERVICE I HEREBY CERTIFY that I served a true and correct copy of the foregoing document upon all parties or counsel of record via facsimile and by depositing a copy of same in the United States Mail at Harrisburg, Pennsylvania, with first-class postage prepaid, addressed to the following: John R. Zonarich, Esq. Skarlatos & Zonarich 204 State Street Harrisburg, PA 17101 Date: Alexandra Makosky, Esq. Pepper Hamilton LLP P.O. Box 1181 Harrisburg, PA 17108-1181 st~¢-en K Grubb t,/ .... AMERICAN ARBITRATION ASSOCIATION COMMERCIAL ARBITRATION RULES DEMAND FOR ARBITRATION MEDI/i TION is a nonbinding process. The mediator assists the parties in working out a solution that is acceptable to them. wish for the .4MA to contact the other parties to ascertain whether they wish to mediate this mailer, please check this box (there is no additional administrative fee for this service) TO: Name ~ Name of Representative (if known) I Name of Firm (if applicable) See Attached List of Partie Address City State [ Zip Code Phone No. [ Fax No. Representative's Address City I State I Zip Code Phone No Fax No. The named claimant, a party to an arbitration agreement contained in a written contract, dated 08/28/00 and providing for arbitration under the Commercial Arbitration Rules of the American Arbitration Association, hereby demands arbitration thereunder. IS THIS A DISPUTE BETWEEN A BUSINESS AND A CONSUMER? [~ Yes ~ No THE NATURE OF THE DISPUTE See Attached Demand for Arbitration THE CLAIM ORRELIEFSOUGHT(m~^mou,[if^ny} Preliminary and Permanent Injunction, plus liquidated damages in excess of $5,000, compensatory damages of approximately $38,000, punitive damages, and all o~e~ mhd F~m~: JncludSn~ attornevs fees, associated herewith. DOEST HIS DISPUTE ARISE OUT OFAN EMPLOYMENTRELATIONSHIP? [2YesUNo TYPES OF BUSINESS Claimant Delinquent tax collectors Respondent Delinquent tax collectors HEARING LOCALE REQUESI'~zo Harrisburg You arc hereby notified that copies of our arbitration agreement and this demand arc being filed with the American Arbitration Association at its Philadelphia office, with a request that it commence administration of the arbitration. Under the rules, you may file an answering statement within fif~ean days after notice from the AAA. Signa.~.~si~~?~' si a ntative) [ Title/~.r. Name of Claimant Inc. Name of Representative G.H. Harris Associates~ Steven E. Grubb, Address (to ae Used in Connection with This Case} P.O. Box 216 City State I Zip Code Dallas PA I 18612 Phone No. (570) 639-5005 Fax No. (570) 639-2964 Date Esquire Represenmtive'sAddress 320 Market Street NameofFirm(ifAppli~ble) Goldberg, Kat~m~n & Shipman, City I State [ Zip Code Harrisburg PA 17108 Phone No. Fax No. (717) 234-4161 (717) 234-6808 TO INS I'litJTE PROCEEDINGS, PLEASE SEND TW( COPIES OF THIS DEMAND AND THE ARBITRATION AGREEMENT, WITH THE FILING FEE AS PROVIDED FOR IN THE RULES, TO THE AAA. SEND THE ORIGINAL DEMAND TO THE RESPONDENT. Form FC2-02/02 Parties J.P. Harris Associates, LLC P.O. Box 226 101 Rich Valley Road Mechanicsburg, Pennsylvania 17055 James P. Harris and Kathy Harris, husband and wife 101 Rich Valley Road Mechanicsburg, PA 17055. JTH Tax Services, LLC Mailing address: P.O. Box 327 Mechanicsburg, Pennsylvania 17055 Street address: 70 Marfield Circle Hanover, Pennsylvania 17331. James S. Harris and Terri Harris, husband and wife 70 Marfield Circle Hanover, Pennsylvania 17331 Representative: Anna Marie Sossong, Esq. Skarlatos and Zonarich 204 State Street Harrisburg, PA 17101 DEMAND FOR ARBITRATION Plaintiff, G.H. Harris Associates, Inc., demands arbitration and judgment in its favor based on the following facts: 1. Plaintiff, G.H. Harris Associates, Inc. ("G.H. Harris"), is a Pennsylvania corporation with a principal place of business in Dallas, Pennsylvania. 2. Defendant, J.P. Harris Associates, LLC ("JPH"), is a Pennsylvania limited liability company with a mailing address of P.O. Box 226, Mechanicsburg, Pennsylvania 17055 and a street address of 101 Rich Valley Road, Mechanicsburg, Pennsylvania 17055. 3. Defendants, James P. Harris and Kathy Harris, husband and wife, are adult individuals with a mailing address of 101 Rich Valley Road, Mechanicsburg, PA 17055. 4. Defendant, JTH Tax Services, LLC ("JTH"), is a Pennsylvania limited liability company with a mailing address of P.O. Box 327, Mechanicsburg, Pennsylvania 17055 and a street address of 70 Marfield Circle, Hanover, Pennsylvania 17!331. 5. Defendants, James S. Harris and Terri Harris, husband and wife, are adult individuals residing at 70 Marfield Circle, Hanover, Pennsylvania 17331. 6. G.H. Harris collects delinquent taxes and also serves as deputy tax collector for various municipal taxing authorities. 7. James P. and Kathy Harris previously were employed by G.H. Harris. 8. On or about August 28, 2000, G.H. Harris entered into a Market Region Purchase Agreement (the "Agreement") with James P. Harris, a copy of which is attached hereto as Exhibit "A". 9. The Agreement was intended to formalize James P. and Kathy Harris' formation of a new business which would effectuate a split from G.H. Harris. 10. The parties wished to define the parameters of the business split and memorialize which customers would remain with each business. 11. Exhibits 1 and 2 to the Agreement detail who would service which account. 12. Each party agreed not to solicit, or in any way compete, for the accounts divided by the parties, per the Agreement. See Section 1.1 of the Agreement. 13. The division of accounts and covenant not-to-compete was of the "essence" and perhaps the most important component of the overall Agreement. See Section 3.4 of the Agreement. 14. The Agreement is binding and inures to the benefit of the signatories, their representatives, administrators, assigns and/or successors-in-interest. It is also binding upon James P. and Kathy Harris' children, and all business entities in which they have a direct or indirect ownership interest. See Section 4.7 of the Agreement. (See also the signature line for James P. Harris where he signs for his "wife, children and associated business entities.") 15. James P. Harris warranted that he had full authority to bind his children. (See Section 4.7 of the Agreement.) 16. On or about October 25, 2001, JTH was organized, purportedly by James S. and Terri L. Harris. 17. James S. Harris is the only son of James P. and Kathy Harris, and Terri Harris is the daughter-in-law of James P. and Kathy Harris. 18. James S. Harris is a civil engineer by trade and maintains a full time job with an engineering finn in Maryland. 19. JTH's registered address and office is in Hanover, Pennsylvania, as indicated above. 20. Despite their registered office being in Hanover, Pennsylvania, JTH maintains a post office box at the same post office as JPH. 21. James P. Harris regularly picks up mail for JTH at the Mechanicsburg Post Office. 22. JTH is using the exact same delinquent tax forms used by JPH and G.H. Harris. 23. JPH designed and produced the delinquent tax fi>rms for JTH. 24. JTH and JPH use the same deputy tax collector employees - Christopher Freitas and William Nievus. 25. Mssrs. Freitas and Nievus are the only deputy t~[x collector employees employed by both JTH and JPH. 26. Kathy Harris trained Terri Harris in administrative matters pertaining to how JTH should be run, including the use of computer software that JPH provided or copied over to JTH. 27. Kathy Harris prepared proposals for potential customers of JTH's 28. James P. Harris trained and assisted James S. Harris in how to effectively give a sales presentation to potential clients. 29. James P. Harris attended sales presentations given by James S. Harris, on behalf of JTH. 30. James P. and Kathy Harris have been actively marketing JTH and introducing JTH to various municipalities and tax collectors throughout Central Pennsylvania, all of which are municipalities JPH is prohibited from doing business with under the Agreement. 31. Silver Spring and Middlesex Townships, within the Cumberland Valley School District, no longer use G.H. Harris for tax collection services. 32. Silver Spring and Middlesex Townships now use JTH for tax collection services. 33. Silver Spring and Middlesex Townships had beem clients of G.H. Harris for over forty (40) years. 34. On or about June 18, 2002, Tuscarora School District informed G.H. Harris that it was not renewing its agreement for tax collection services. 35. Tuscarora had been a client of G.H. Harris for ten (10) years. 36. Tuscarora School District now utilizes JTH for tax collection services. 37. Fannett Township and Metal Township, within the Farmett-Metal School District, now use JTH for tax collection services. 38. Fannett and Metal Townships had been clients o:f G.H. Harris for over forty (40) years. 39. Tuscarora, Silver Spring, Middlesex, Fannett and Metal Townships were all G.H. Harris customers under the Agreement. 40. It is believed, and therefore averred, that Cumberland Valley School District will assign Hampden and Monroe Township accounts to JTH in the coming year. 41. JTH is a front set up by JPH, James P. Harris and Kathy Harris to attempt to avoid the restrictive covenants of the Agreement and injure the business interests of his father. 42. James P. and Kathy Harris' actions through JTH are deliberate and intentional and done with the intent of injuring the business of G.H. Harris, and take G.H. Harris' business, through the contrived JTH business entity. 43. JTH has not solicited or competed for any account of JPH's. 44. It is believed that JTH, aided and abetted by James P. and Kathy Harris, continues to solicit G.H. Harris' clients in an effort to harm the business interests of James P. Harris' father and James S. Harris' grandfather. 45. James P. and Kathy Harris, jointly and severally:, have guaranteed compliance with the terms of the Agreement on behalf of any person or business entity through which he or she may work, consult, manage or have any ownership interest. See Section 3.4 of the Agreement. 46. Arbitration of this dispute by a panel of 3 is mandated by Section 4.6.2 of the attached Agreement. 47. JTH, James S. and Tend Harris, as the agent and alter ego o£JPH, organized to avoid the terms of the Restrictive Covenant, is bound by the terms of the Arbitration Clause. 48. Immediate hearing on the equitable portion of this claim is demanded within ten (10) days of submission per Section 4.6.4 of the Agreement. 49. Final hearing on the merits is demanded with thirty (30) days of submission per Section 4.6.3 of the Agreement. COUNT I - BREACH OF RESTRICTIVE COVENANTS 50. The allegations of 1-49 are incorporated by references as if set out in full. 51. The actions of James P. and Kathy Harris, their children, and associated business entities are in violation of the Agreement, in that they have solicited and taken business, namely Silver Spring, Middlesex, Metal and Farmett Townships and the Tuscarora School District, in violation of the restrictive covenants contained in the Agreement 52. G.H. Harris has abided by the Agreement in all respects. 53. The continued solicitation of G.H. Harris' clients by JPH and JTH constitutes irreparable harm for which there is no adequate remedy at law. 54. An injunction is demanded to prohibit this future conduct, which is reasonably tailored to abate Defendants' conduct. 55. An immediate preliminary injunction is demanded since G.H. Harris has a strong likelihood of success on the merits. 56. An immediate preliminary injunction will maintain the status quo and prohibit Defendants' conduct which is contrary to the Agreement. 57. Greater harm will result from denial of an injunction, than the granting of the injunction in that without granting the injunction, JPH and JTH will continue to solicit and take G.H. Harris' clients, contrary to the terms of the Agreement. It is believed that Hampden and Monroe Township accounts will soon be turned over to JTH tlu'ough the efforts of JPH and James P. and Kathy Harris. 58. The parties have vested the arbitration panel with the ability to accord these remedies. (See Section 4.6.2 of the Agreement) WHEREFORE, the following relief is requested: (A) The Arbitration Panel enter an order which preliminarily and permanently enjoins all defendants from soliciting those accounts, which are properly G.H. Harris', as identified in the Agreement, for the duration of the Agreement. (B) JTH and James S. and Terri Harris terminate their agreements to collect delinquent taxes with the Tuscarora School District and Fannett, Metal, Silver Spring and Middlesex Townships. (C) Pursuant to the terms of the Agreement, at Section 4.6.8, all costs, including reasonable attorneys fees necessary to enforce this Agreement, be awarded in favor of G.H. Harris. (D) All Defendants be required to pay, as dmnages to G.H. Harris, all lost revenues G.H. Harris sustained as a result of Defendants' violation of the contract. (E) The Arbitrator award liquidated damages in excess of $1,000.00 per incident of solicitation, which presently is known to be five incidents, and which shall not be deemed compensatory or punitive, pursuant to Section 3.4 of the Agreement. (F) Whatever other remedy the Arbitrators deem proper under the circumstances. COUNT II - TORTIOUS INTERFERENCE WITH CONTRACTUAL RELATIONS 59. The allegations of 1-58 are incorporated by references as if set out in full. 60. Tuscarora School District and Silver Spring, Middlesex, Fannett and Metal Townships had contractual relations with G.H. Harris for the collection of delinquent taxes. 61. By breaching the Agreement, all defendants, acting as one, have interfered with the present and future contractual relationships G.H. Harris had. with these school districts and municipalities. 62. Such interference was done with the intent of in.'iuring the business of G.H. Harris. 63. Such interference is contrary to the Agreement and unjustified. 64. Collectively, Tuscarora School District and Silver Spring, Middlesex, Fannett and Metal Townships resulted in approximately $38,000.00 in profits per year to G.H. Harris. WItEREFORE, the following relief is requested: (A) The Arbitration Panel enter an order which preliminarily and permanently enjoins all defendants from soliciting those accounts, which are properly G.H. Harris', as identified in the Agreement, for the duration of the Agreement. (B) JTH and James S. and Terri Harris terminate their agreements to collect delinquent taxes with the Tuscarora School District and Fannet~:, Metal, Silver Spring and Middlesex Townships. (C) Pursuant to the terms of the Agreement, at Section 4.6.8, all costs, including reasonable attorneys fees necessary to enforce this Agreement, be awarded in favor of G.H. Harris. (D) All Defendants be required to pay, as damages to G.H. Harris, all lost revenues G.H. Harris sustained as a result of Defendants' violation of the contract. (E) The Arbitrator award liquidated damages in excess of $1,000.00 per incident of solicitation, which presently is known to be five incidents, and which shall not be deemed compensatory or punitive, pursuant to Section 3.4 of the Agreement. (F) Due to the outrageous, intentional and improper conduct, punitive damages are demanded. (G) Whatever other remedy the Arbitrators deem proper under the circumstances. COUNT HI - BREACH OF REPRESENTATION AND WARRANTIES 65. The allegations of 1-64 are incorporated by references as if set out in full. 66. Alternatively, ifJTH is held not to be related to JPH, James P. and Kathy Harris represented and warranted in Section 4.7 of the Agreement that they had full authority to bind their children to the tenus of the Agreement, especially the restrictive covenants. James P. and Kathy Harris guaranteed, personally, compliance w/th the 67. Agreement. 68. JTH, James S. and Terri Harris' obvious competition with G.H. Harris manifests that JTH is not abiding by the Agreement and does not believe :it is bound by the Agreement. 69. James P. and Kathy Harris, thus, have breached the representation and warranty of Section 4.7 of the Agreement. WHEREFORE, G.H. Harris demands: (A) That the Arbitration Panel order James P. and Kathy Harris, jointly and severally, to pay G.H. Harris all amounts it has lost as a result of James P. and Kathy Harris' children breaching the Agreement, including all revenues and profits G.H. Harris has lost as a result of losing customers to JTH. (B) The amount remain open, and periodically adjusted, based on the further business that JTH procures,'to the detriment of G.H. Harris. (C) All costs, including attorneys fees, associated with this action per Section 4.6.8 of the Agreement. (D) Any other remedy the Arbitration Panel deems proper under the circumstances. 82334.1 10 MA~W~.T RKGION PURCHASE This Ag~e~ is m~de effe~ti~ ~st ~2000 (thc "E~= Dat~"), by ~twc~ G, H, Harm ~iatc~ ~,, a P~yl~co~mti~ ("Scllc~ ~ ~ p~clp~ pl~ce of ~a/ness ~ D~las. P~eyl~a, ~d Mr. & Mrs, J~es P, H~ ("B~'), ~ER~ 8~11~ h~s bu~ess ~oiNties Ioc~ed ~ ~e homes of bo~ Buyer ~d ~ERE~ B~ez h~s ~gN ~ bus.ss ~oh of ~e ~sN~a op~ai~d from his home (&o "Mech~io~u~ ~ge") ~ now desks ~o ~roh~ ~t ~ of ~e ~ss Se~eG ~d WH~E~ ~e m~mi~d P~s ~o~e the m~ long-term ~ofim of sale ~ tho ~s ~d ~fi~ set f~ ~ ~[s NOW T~ORE, ~ ~demti~ of ~ pmm~ gt fo~ ~[ow, ~ of whlah is hereby ae~ledg~, ~o P~ ~ ag~ ~ ~ows: [. L A~ ~ bt Tr*n~ferr~ tubj~ ~o ~is ~m~g 8ell~ ~B ~d~ all i~ obligafims ~d~ its ~a~m~ ~ ~ on E~i~t i m Burr, m~g ~ [tse~ ~stom~s [~ed on Exhibi~ 2. Buyer ag~es to sssume fully ~ ~mpl~e~ all ~on~ a~oo~ed ~ E~ibit 1 ~ers, ~d 8~er s~ to ~t ~ B~ ~clu~ve o~o~p For ~c ~ of cl~ ~d ~ ~e ia~s of ~v~ng ~ omafion of overh~ng geo~hi~ ~ss that would ~ co~g to cnstamers, ~yem, ~ perhaps ~e · em~elv~, ~e ougomo~ ~ on ~o ~ve E~ibRs shall be ~e~ ~clusively ~vemm~ ~fios ~ ~at dis~i~ ~, ~' c~stomer ~sted ~ ~e ~MM~ ~ is ~ ciW, bomu~, to~ to~sMp, or school dis~ sh~l ~olude dl ~te~ ~soo~ oil. bomu~, Mec~ics~rg O~ce s~ be ~v~ be~ ~e ]?~es ~ ~clu~g ~u~o To~ip, How~ T~p, ~1~ To. ship, N~ Bomu8~ Ju~ ~ Oliv~ To--hip, To~hlp, La~y, the 0elision of ~ ~ of ~ for ~ ~ ~omer i~hi~s dl ~e~ of mxc~ for ~c l~ed c~mm, F~ ~mpl~, ~= coll~ of B=lld~ Bo~ ~xcs that te~phi~ ~a ~clu~g ~d h~ ~cs, pm~ ~, ~in~s ~e8= ~oupafio~ privilege ~, ~o. The o~d~ ~d hc~ is m ~ni~ ~ mu~ as ~s~ibte ~y possible ~s~t ~d ~re po~ of ~o~on or ~flict ~e~ ~e ~s. 1,2. T~f~ ~ Le~: The P~es ~ ~ the Iea~c ~I ~ d~mcd ~;-~ted elos~g, ~d Buyer agrees ~ ~ the p~ises ~ee oFcla~s against Sager or i~ 1,3. Wa~6es ~ Rep~s~don~: ~e Me&a~o~ O~ is ~ mid "a.~ is" o~s~g lmbifi~:g, ~o~ ~d u-k-own, ~ t~t Bt~ h~ worked ~ g~ m~g~ Mar~t R~on ~h~e A~ement ~P~I~ 1 pr~smnecI lmowledg~ab[e abou~ any ~xistiug liabili~i~s associated therewith. T~e Parties agr~ to coop~mt~ promptly wi~ m~y accoanting r~que~s associated with t~x and r~gulatory r~po~ting no~s and,Mth any oth~r reasonab]~ ~qne~ ~o fa~ilitat~ and to implement this Agreement. Article 2 - Co=~dera~ In consideration for this Agreement, Buyer agrees m pay 8etler as follows: 2,1. No down pa)meat is sought or reqttirod by Seller except non-s~u-y operations experls0s tach as water, elecU'icity, etc, for tho fall month of Aunt, 2.2, The purctucs, price shall be ~100,000 payable in sixty (60) monlhly paymet~ cf $1,666.67 beginning September I, 2000, and ending with a b~loon payment for the 2.3. Monthly payments shall b: mai[cd ~o Seller's address o~' record and m~st he r~eelved within the first five (5) days of each calendar month until paid fit full. lin the eve.~t that any payment i-~ late, a late fee equal to tea peroent (10%) of the late payment shall apply and be payable within ten (10) days of Seller's writ~.en demand, the Pm'tie; agreeing that this is a reasonable ass~arment of the admlnis~tive cosls of dealing wilh the delinquency. A check dishonored for any reason :ghall autoraatically be deemed lat~ and subject to the late fee, la the ev~t that any paymem becomes more than thirty (30) days ~ due. tho emire balauc~ shall immed_~mly become due iud payabl0 withou~ demand or other pi-esentmcn~ and without waiver of any other Seller right~. Simple annual interest of' ten pcr~cnt (10%), instead of thc IRS in~pu~ed rat~, shall at, mc m ~c unpaid balance thereafter un'-til paid in full. Buyer gra~ts geller fa-st prioHB, llen on its accounts receivable and bank aceount~ a~ securiw for prompt payment. 2.4, As of the affect/ye date. Buyer wamms that it 'trill pay all post F-ff~ve Date staff ~sal~ and ~'neflts incladi~ instance, all suppliers, all taxes, and ev,rff other aspect of its ow-he~d previously paid by Sdlcr, Article 3 - Tramsttton~l mad lhrim-e Bn.l~m,s llelsttons 3,1 ~; The Pmle~ a~ree In ke~p ~e t~rms and oono~pt~ of thi~ ~ranasotlon s~tly confidential md revealed ordy t~ Itlo .~tvisory prof~ssiol~s needed l~ uonsummaIe this tnmsa~on until aft,e lhe effective date. Befor~ that d~t¢, the Parties shall a~e upc~ the wording md d~rilmtlon channels for a joint press rel~s;, aftor svhid~ the Psrfl,s are fr~e to disolose the terr~ of this a~r,emont s~ approl~r~, wilh third Ps.rti~s. ~onsistently ill a light rhat portrays thn Parfi~, their family m~abers, th, business prs~fiee~, in ~ thvomble light. E~? Party agre~ not tn d/~rage, doraean, or oth~'wi~ lmrtray any ~ta~ psr~ ~o thi~ Asr=nmer~t m urdlattcrlng terms with any third party except as may Im compelled by legal pmee~. 3.2, ,Pm~t~' R~tlnn,~p: Buyer and his mmpany shall be ma independent business entity entirely respomibl, for it~ own taxes, insurance, m~d expms,$, Exc0pt as otherarise Irrovided herein, this is a non-exclusive relationship. <d nothing ¢ontain,d in this As~em~ sh~ll oons~tnte the Partiea ~ partner% joint vea~rers, emplo)~r .~,,~1 employee, frmaohiser md lYm-~hisee, or otherwise ~ s~gent~ of the other after the effeofi,ic date. 3,3 Lo~tztiqs or Customer Tr,,~fe~: The P~des agm~ to advise ali oustomers transfeived under this Agr~mcnt of this change in-operstions and agvls¢ th~m in a joint commur~qu~ that t~ sh?l ha¥¢ the option of continuing th,ir businesa rela~ionthip with Sell~r. but only if notice Fins] P~g. ~ :of ~ueh a request ia made in writing to both Seller and Buyer wil~hin fifteen (15) days £olIowing the date of the notice. Buyer agrees go dragt and present his proposed notice immediately to Seller for approval and ~he final version will bc in mutually m:ccptablc language sent at the curliest possible date af~ez the sigakLR of this Ailrccmeflt. Tn the event that the Parties are urmble to agree upon m~alally aceeptabie language, Seller shall have fatal discretion regarding the wording of said joint notioe with duo rcspe~.t for the Buyer's preferences and the intent that the Exhibit I custoiiier~ dire~t their business to Buyer. Seller agrees to mail said notice to all customers ti~ted on Exhibit 1 within fly: (5) business ,days of the date of ~r~ment th= lett,r wording and ia any :vent not later than fi¥c days after receipt of BayeFa dra_,~, geller agrees not to initiate ccatacts with customers for the purpose of preventing the transfer of their busincas to Buyer darius thc fiftc~-a (15) day transition period following th~ mailing af the letter, stipttlating that sanctions a~alnst thc non-oompete olausc below shall apply to any such contacL Scllcr vdli advi~ Buyer of such amen~knents to Exhibi,; 1 as may result from r~spon~s tn this notice, fn thc croat that Bu'y~r que~ons any amcndmmats to Exhibit 1 based upo~ customer initiated responses to th~ ~rensition notice, Buyer end ;~cller shell an'huge for joint oonK're~e calls to the affected customer(s) and confer jointly only w/th such customer(s) until the allocation qucslion i~ msolved. With regard to accounting, flnar~iaI obllga~ons, mad lo~istleal iss~,~s, thc Partita agree to cooperate reasonably as n~dcd and to £~l[~:w thc gcr~:ral pro~-durea dcscrlb~d in Exl~it 3 tn inaludc provision for compensation to 8~II¢r ami Buyer e. amcd to 3.4 Culstonmr ltelatio~ During fred After the Ti:~?,lti, : Thc controlling rule is that Parties agre~ not to do any business with any customer li~ed on tho customer list of the other, except as provided he, in, cyan if a customer Sl~Cifically deaL-cs to shi~ M~incss relations directly or indirectly to th: othcr party tn this Agre~n~cnt, the only exception being during thc transition phase when customers on F, xh/bit 1 shall have the option to continue business relations with Seller. After the lifteen (153 day I~-ansiiion period wha: customers will be responding to the reorganization notice, thc Parties agree that changes in the Customer lists may be made in writing by mutual eonseng but neither party nor its agents, directly or indir,-Cdy, shall appmanh, solicit, have any oontaot w/th. or o~er end/or perform any services for customers listed on other party's list. even if thc change is requestcxl end/or e~ively sought ~ the customer. In such a situation, a. tho Parties eg~e simply to advise, th~ prospective customer politely that the non-compete prov/sions ~ oontraotual relations bcmve~ the c~npanies prevent thc acceptance of the new business; or b. under exceptional oircumatanccs, the Part/es may agree upon an equitable exchange of customers with thc affected customers' consent. These non-compote provisions are of the essenoe, and the Parties agree that an5, violation of this provision may do irreparable and serious damag~ wa:Tanting immcdlate £njunctlve rclin£ under the arbitration provisic&g of this Agreement. ~ · ,-¢~ke-lt~' , the Part/es · agree ~ rain/mum liquidated dan~ag~s 0£ $I,000: whioh shall not he deemed compea.~atnry or ptm/t/ve damages that may also he awarded. Any sanctions shall apply on ~ per hacldent basis related to solicitation or other conduct violative of this provision and includc prompt res;oration m thc other party, nf any ~ua~om~ ht thc event of oba~d relations. Thc goaJ here is simply to ~er// M'rk¢' Re,ton Pttrcha.c A~r~mcn, "discourage any imp~flse to violate and actively to encourage compliance wi~ the reruns of ~is ~ieable w~-Mn ~fi~ b~ f~y m~bers. G. ~. H~s ~d Viola H~fis, Paul ~s~ek md Pa~eia ~s~e~ ~d Ka~y H~s each ~r~ to be jo~fly ~d ~eve~Hy as c~ples ~to~ or' ~mp~ce by each ~s~cfi~ ~plc ~ ~e ~s o~ ~s ~m~t ~ ~y pc~on ~ bus'ss t~ough which he or she my wo~ cons~ m~a~, or hsve my o~ership ~re~. ' 3.5 O~er Bas,ess .Rflafi0~: Be~ cf ~e P~' f~li~W ~ fl~e o~'s business ~d thc ~t~fial ~ies of eon~d eoo~mtion ~ ~e ~o offmes, ~e P~es may a~ee from time to time ~ ~ ~ hoe ~i~ ~ w~gs ~ng ~tb Panics' si~a~r~, but ~ way oblig~ to ~end ~er the a~ched ~i~, to ~chmge or p~ehase ~en4~s, ~ se~ces, or ~er ~ofi~ ~si~, ~ each c~e ~xdd~g for eompe~afim ~n t~ s~cifi~ ~ ~ ~ advice ~d ~ ail cases i~oiced ~ pai~ wi~ ten ~VOI~. 3.6 .~ Par~ ~z~s~ei: This ~t is f~ ~z b~fit of ~e ~d~ed ~d, exee~ lbr ~e ~ni~cafi~ ob~gati~, not for the ~efi~ of nor may ~y 3,7 ~: ~yer ag~s ~ ~ndu~ its bus~; ~re~ u~er a n~ ~ame of ~ devis~g (pms~ e~mplaed to M J, p, Hajji Ass~ia~s hm.) fl~at is ~se &c pub~, suppli~, ~s~em, or deblum, ~d S~ ~ to o~ate recently ~sis~g Burr ~ ideai~ ~ secu~g such a ~e ~ ~11 ~ly m~e Buy~'s m~ p~. Burr a~es ~t ~ usc thc nas of G, H. ~r/s ~ ~y of SeWer's prior ~es for ~y purest ~t ~t ~ ~ ~e~c ~ ~at ~ each ~fl eve~ use, 3,g Tern: E~ for ~ pa~ obNga~ons ~ ~nh ~ove, ~e obli~ms agmm~t sMll ccn~e ~ ~ rome ~ ~ f~ ~t l~s ~ ~W (20) ~ ~iRen a~omem ~ ~e con~ b~ ~e P~s, No ~ my aelI or assi~ ~sfe~fl ~er ~is ~m~t ~thout tho ~R~ ~s~t of~e o~er p~, 3.9 Res~aflon & ~1~ Buyer ~ membe~ of Ms f~fly h~e~ ~ ~m employment, posts, or pos~ w~ Seller ~ a ~H ~le~o of ~1 o~, ~. or ~nte~ e~ for ~mpi~ wi~ ~e ~s ~ ~is ~m~t ~ ~ym~ f~ w~k eomplet~ before ~e effe~w da~ of ~i.~ ~de 4- ~neom 4.1, ~ ~s ~eem~t eoic~as ~e ~[ ~d ~mplete ~er~d~g rcp~s~fi~, wfiu~cr ~, ~ ~ ~, ~s ~m~ may ~ m~fi~ or ~d ~e~ret~ f~ or aS~a ei~ P~, ~oh of ~e ~Me~i~ ha~ ~ep~d~ co. el. 4.2, Severa~, of P~s. If ~y oro~si~ of ~ Agreem~ s~ be held to ~v~id or unenf~le for ~, ~, ~e ~g pro~s s~l co~e ~ be e~o~eable. M a ce~ or ~h~or fmd~ tat ~ ~slm m' fils Ag~e~ is inv~id or un~orceab]e, hot ~t ~ ~g ~ch p~on i~ would, b~me v~d ~fl ~force~le. such pro.ion shall ho d~mefl to be ~en, c~[u~ed, ~fl ~or~ aa so li~, The b~ of ~is Ag~m~ ~ pa~s the~of sh~l not bc ~ff~icd ~cmby, ~c pro~sio~ eonstmcd ~ serial ~d ~~~ M~ke' Re.on Purchase A..m.t ~ Page 4 Buyar: 4.6,2 4.3.' Apl~lieable Law. This Agreement shall be construed ~nd enforced in accordance with the laws of the Comn~onweallh of ?eal~ylvania appliceble to contrasts ~o be wMIly performed with/n said ,qtate. 4.4. ~, This Agreem~t may be executed in counterpa~ and all eoua~e~pm-ts shall consiltu~- e~c a~eement binding c~a all Parties hereto, n~ithaanding ~a~: all of the Parties have not ~igaed the same eouaterpar~ $igr~ture Page. A deemed a~ original for al/purposes. 4.5. N..oilc,s, Ail notices purmant to this Agreemm~ .4~all be i~ writing a~cI shall be sent hy certified mail, postage £ully prepaid, adclre,sed as follow~: Seller, Mr. ~. H. HarrY, ?r~sident G, H. I-Isrris/t~oel,~s lac. P. O. Box 216, Dallas, PA Telephone: Faeslmfle; Mr, & Mrs. J. P. Harrls 101 ~ct Valley p~, Me~hani~sburg, PA 170!0 Telepl~one: 717-76fi-~77 · ~i~h ia each ease to: Facsimile: 717-766-8039 Bernard Waiter~ Esq, 20 North Memorial l~ighway Shavertown, PA 18708.1422 Teleph~e: 570-696-9090 Facsimile: ~00-~30-6~6 Ama Marie 8os~ong, Esq, Sks~t~ & Zon~ieh, 204 Harrisburg, PA 17101 Telephone: 717-233-1000 Faosimil¢; 717-233-6740 4.6,3 i~terrosatofies, and single request for prod~tion of documents, trod the arbitrator panel Buyer/~ t All not/cos shall be deemed delivered ~ personal del/very or sevmty-tw~ (72) hours ~fier ma/ling, postage pretafich whichever shell first occur. Addresses for purposes of notice may be ch~-ged from time m time by notice in writing sent ~ provided alm~e. [h~til nofie, is received by the other Partios, the ~ove ~dresses hereto shall be dee~efl corm,[ The undersigned each ~peeifically agree that servi~ under rids provis/on slmll be effe~ve to personal ~ufisflictio~ for mediation and/or arbitration. 4,6, Disgn~ R~solufion & M--,'l,s~ry 4,6.1 In the ex,ant at' a dispute between the Parti.m, each Party agrees to attempt msoluilcm through mediation with a m~diator provided by the American Arbitration .4~oeiation ("AAA") in Philadelphia, Pennsylvania, in aceordanoe with the the~ exi~ag .4.AA CommerrJaI Rules, Absent favorable remits, aflitration aatice may b~ ~ within thirty (30) days of the request for mediali-,a, Claims for equitable n: ' llef nmnt not be medla~ad, In the int.-rests at' e.o~omy, pr/vaay, and expedifiour, resolu~on, ia the evenI of a breaoh, defaulL or dispute based on oontmet, tort. or stalut~ between the Partios arising out of or r*lated to th/s Agreement including without limitation cia/ms for equitable relief svhethcr an issue is ~bit,~b!~ ea~h Party eonsen~ I~ f;--! ~d binding ar~trafion exclusive '~enue, p~rsc~ jurisdi~on, and he~h~g authorily ve~ in AAA, Philadelphia, Penasylvatfia, ander its Cammerelal Rules us/ng a panel of three arbitrators. Each Paxty may serve a single act of requests f~r admissiam, a aingle set Market Region Purchase Agreement Final Page 5 ~eller ................. ~u-.:.~u-ecr. li~ Te~ &'Inl Mmfl~ 2~oNon~ Dill: I],~5/0D T',,,.~: :DS i~M Page~nf~ shall h~ve sole and complete discr~on to determine any discovery disputes, Each Party agrees actively to expedite the dispute resolution w/th ~11 re~somble effo~ to secure a hem4_ng within Ihirty (30) c~ys ~r servi~e of ~e Arbitration dcmmzd, or ~s ;con their as possible, w~ivi~g jury trial and appeal rights. 4.6.4 In thc e~t of an applioafio~ for a teml~rary restralni~E order, e~h P~m'y egrees tn any and all me. urea neo~ssery to mm a hearing with/n t~n (10) lmsine~ days of thc Notice which may proceed even without the responding Par~y. 's presence. 4.6.5 Thc arbitrator panel shaft deliver a written oplnlon'.setfi, v forth factual ftadlngs and the decision rationale thug m~y be reduced witen final to ~ ~flgmenI and filed in any court having jurladicfioa. At thc expenso of thc moving party, the arbitrator panel shall reeonmider the opinion o~e upon a written motion submitted and ~rved busineg.~ days of th~ opinlon'g mailing, 4.6,6 Any complaint, adversarial claim, or snti~n l~lat~d to this Agrecmct~ prosecuted in any other jurisdictlnn or i'orum than as provided herein shall be null and void. 4.6.7 In the event of litig~on betva~n a Party to tiffs Agreement and a third tmrty for which indemni~cafion or eonl~ibution is d~sired, ~oh iadenmifioafion or con~n'buiion shall sought alter that liti§~tion through ~ separate mediation/arbitration rather than by cro.~s complaint or ~olnder. 4.5,8 In ~ddition to any olfler form of re~ovez3; the preys/ling Party shall be entitled to re~over reasonable attorneys' fc~s and co~ ne~e~s~3, to enfi~rce this Agreement, wen/n thc ~.~.~e of arbitration. 4.?. i~tiilLF.,ff~: This Agreement supersedes alt prior agreements, written or oral, betwem the ?arti~s concerning thc sub~.t matter o£ this Agreement. It shall be binding upon and inure tn the bene~it of the undersigned mad their s ' ' ' and/or successors-in-interest. This Agreement and the non-compete provisions in particular shall be binding upon l!]uycr, Buyer's wife and children, and gpm any and all buldncss e~titics in which Buyer has any ownership ire'crest, ~ or indirect Th~ person signing for ea~h party warraaiz that h~ has the full a~thor[ty to bind thc Party 4,8. Waivers; Nc waiver of ~ay ~ov~aat, condition, or limitation hc~4n oontalned shall be valid unless the same is made in v~iiiing and duly executed by the Party making the waiver, No waiver oi' any pmvislon of this Agreement shall be deemed or shall continue a w~.vicr other pmvlsicm, whether or sot similar, The fifilum or neglect of ~ Party ~ any oceaslon enforce any provision of this Agreement shah not restrain or limit such Party from enforcing such provisions upon any other occa,i~n or occasions, if such ?arty elects to do s~, and written waiver of' any breach of this Agreerncrit shall bo deemed to be a conilrming waiver of such breach urlless so expressly stated. Ali remedies, rights, underaldngs, and obligations hereunder shall bc cumulatiw and nor~ shall opgratc a~ a limit~llon or my other rernedy~ right~ undermklng, or obllgstLnn hereunder. The Parties further agree to waive any oonflint of ~ntcr,-st or any other olaia~ against any attorney involved in the negotiation ~d/or Ix~paration of this r n ent. 4.9. . ~illl~lilli~l: Given that B,u. 3~r will be operating a completel F/.-~P.~5~ ct' the eff, ctive d~e with ,ts own payroll, creditnr r~l,tlons, ~k separate business ~'~ Market Region Purchase Agreement a~oounts, and tax ' ¥in l Page 6 obligatio.~ but working with long tern clients of S~]ler, clie~ se~oed ~Iy ~ Buyer, P~es ague to ~e follm~g ~d~f~fi~: 4.9.1 B~er a~es ~ defmd, ~dem~;~, ~ hold hamless ~er, meeesmrs, ~d a~i~s ("P~i~s") ag~ ~ action, pmcee~gs, ~its, ~d clams ~'C~s") ~at may fr~ (1) Buy~'s b~ of ~ ~ment, (2) B~'s failure at ~ time ~ oomp~ wi~ ~te or red,al t~fion m~mm~ts ~clud~ ~t cf c~ t~cs on ~e eomp~sa~on described hem~ it ~ agreed ~a~ said oompliamo ~ paymeg are of ~* essm~, ~d (3) ~1 Clams of ~he Mcch~es~ ~cc'a c~mers, uppers, ~ate~ic ~ers. le~s, ~ ~ o~ ~tor ~ght s~in~ Sefl~ caus~ ~ or gfrom opemfio~ ~ c~m~ tlst~ ~ [~ibit 1 ~clnd~g ~ose ~isin 'or e eff~ve date of ~i~ A~at..omsid~flm that j~fies p~ ~ the ~n~d 'pumhdse Pfi~ of ~s 4.9.2 Solar ~es m d~md, ~de~, ~ hoS h~es~ Buy~, hs a~, ~o~ssora, md m~y ~se ~m (I) Sell,r's ~ach of ~s ~m~ (2) Seller'~ ~um to comply s~ ~d f~ ~xafim m~imm~ ~ehd~g ~yment of ~divid~l i~me taxes on · e eomp~a~on d~sefi~d h~n, it b~ a~ ~at said eomp~ ~ parrot · e obI~afim of ~e Seller, ~d 0) ~ Ct~ of ~e Seller's m~omem, l~lo~s, s~a~ic pamers, ~fl~, ~8 my ~er om~r bmght ~a~ Burr cm~sed ~ ~ ~g ~ operafi~ ~g ~e effective ~ f~s Ag~emmt. 4.9.3 ~eh ~emnffieafion ~ded ~ ~is seo~m s~l ~lude ~1 defoe ms*s md m~o~lc x~m~s' ~es ~is~ ~ eo~c,fim wi~ tim el~ for wM~ ha~ ~ pm~s~ ~ong w~ ind~nit~'s inrle~. Each demmfiea~ ~o~ded ~ ~s seefi~ s~l ~ehde ~l r~s~le ~ . . m~mble eons of ~fore~ ~e a~h~le eo~ ~ masonic e~me~' f~ ~slng ~ oomcofim wi~ the ~l~m for w~eh · d*~eaflm ~s b~ ~msed ~d ~ the ~de~tee's ~ble ~s~ of ~ore~g the ~p~eable ide~. Each ~i~du~ P~eip~ m be ~cd ~ ~5' ~e~ under ~fs ~t~t is a ~ird p~ b~efioi~ of such ~ndem~. 4.10, W~ver 0f Conffiet of Inter~t, Each P~, und~m~ ~ v~ of ~e~ ~h has pla~ ~ a~t~g the P~es ~ ~s yompl~ ~d m~fifac~d ~sitiom pmfessi~l a~ee~ m ~y ~di~du~s or comply inmms~ ~eeted ~ ~a c~enc~g upoa ~c d~ of his ~ ~ ~ ~ ~ ~[s A~em~L 4.ll. ~e & S~ Title~. ~eM ~ ~m titles ~ for ~sofipfi~ ~se~ ~y ~ sh~ not ~1 or al~r ~c me~ of IM~ A~mmt a~ set ~ ~ ~e ~, ~, 2000. Seller ~3. H. Harris, indhddually and a~ Pre~ide~ G. H. Harris Associates, Final Page ~$ENT 0F ~POUSEs & AFFECTED FAMILY ME~E~S As a f~ly m~ber of ~e fo~g ~divid~ls sing a~, ! ~owl~e that I have read ~c f~go~ sev~ page A~e~ent ~ ~at I ~ow i,~ ~. I am aw~e flint, by its pmvislm~, ~e fo~o~g ~d~d~ ha~ ~ ~ a m~f~ of c~ assc~ or ~ym~s in oxvh~g~ for ~, sp~ifi~ oonsido~fion ~th ~e li~,d tonns ~d con,flora ~at my ~f~t my mplm;mmk m~dffi pm~dy: ~ pcm~ bus~ ~, Wi~ ~wlcdg~ ~at I m~ ~e~ r,la~ md ~ ~at I shall ~e no ~tlon ~ my time ~ h~d~, ~, or viol~ · c t~z of ~ A~cmmt. PALrL ADAMSHICK PATItlCIA ~SHICK - Market R*gton Purchase Agreement Buyer Final _l~ge 8 Seller MECEAJ~IC~UBG FOLLOWING ~R~ COUN:"~' W~rD;~ T~I~RITCLm. rF.~ M~CH&N~O~BUR~ OFFIOE COUNTy ............ --, . .,. :~ '1 ~-~um G. H. HC~RR~ A~E~C, [NC, TO 171~740 p,pJ~ MEC~IANIC$BURG OF~'ICE ~ELLEPONTE BOEOUGE ]PORT MATILD;} BOROUGH CARROLL TOWNSHIP DI£LSBURG BOROUGH TO ~.07 ......... ~,.-',.,,:~Jr~'l r~ur, G. H. HF4P. RIS R5~OC, INC, TO ~?:L?23"36'Tala p.la8 TH~ FOLLOWII~G AR~ COUNTYi WIDE COUNTY ti', ~ ?J SCHOOL SCHOOL ~i. H. PIRRR[S R-SS~C. [~C, TO BU~KS CO~r~' P, ~-0 SCHUOL SCHOOL + TOWN~I~ SCHOOL ~ BOROU~ SC"~3£ + TOWNBBiI~ SCHOOL + SCHOOL + BOROUG~ PHILIP~BU~OROUGH $CA~QOL -~ TOWNSHIP c~ ~ TOWNSHIP' FRANKLIN ~ BCHOOL & TOWNSHIP mOROUC47 TDWN~!P TOWNShIp SCI;COL ~ ~OWN~!~ SCHOOL tOWNship BOROUGH TOWNSHI~ TOWNSEIp BOROU~B ~s ~' ' p ON ~.WE ~FF~Tt~E D~ OF T~ ~G~, T~ ~C~ICSBU~ OFFIC~ WILL ~ A COS~ ~R~, WITHIN ~IV~ DAYS ~IS R~PORT SH~ 9~ ~ ~ T~ MAIN OFFICE IBT~RZST. ~IRTY D~YS LATER TB~ ~CH~NICSBURG OFFICE WI~.n RUN ~ FINAL COST AR~ TBS ~NICSBU~ OFFiCE'~ ~/OR THE DEPLOY' LONGER MaK~ DE~BITg ~ ~IS ~OU~ ~R ~LL T~E M~H~NICBBU~ OFPICE ~IT~ ~ OUTE~I~ ~K ~BB. ~FT~ THE FIN~ CO~ ~$~ HA~ BE~ S~. ANY U~ ~ ~ ~CL~ZNG TS~ F~AA ~ RE~, A~ CO~S <.,,_............ .-~.~ ~:.:~x.. ]NC, TO ~,?~.723'3G?~!~ p.~? P~S~ O~ C~S ~Y'T~ ~C~NICS~ OFF~OE [J P ~ARRIS~ ON ~ ~ER ~ SI~G OF ~FIS ~.D C~CKS'RECEIV~D F~ D~Q~ T~XABLE~ OFFICE ~ FOR ~ P~Y~D OF S~l'~ DRY~, ~ MECH~NIC~B~G OFFICE t~R~' a6~SOC!A~S INC ST~, ~ORS~ ~ ~/OB G ~ N~IS ASSOCIATE ~C I~ED ~ ~ ~CHA~csBu~ OFFICE= ~CK ~Dff OUF ~ T~ M~N~CS~ OFFICE E~R T~T ~ I~ FOR G N ~S A~I~ES i?17233~740 P.18 G. H. ~R~ ~0~. ]NC, T~ i?I?2~'~674G P,l-q NOV-13-2002 12:18 PEPPER,HAMILTON P.0~/04 JTH TAX SERVICES LLC. JAMES S. : IN THE COURT OF COMMON PLF. AS OF HARRIS AND TERRI HARRIS. Husband: CUMBERLAND COUNTY, PENNSYLVANIA and Wife, APPLICANTS : G.H. HARRIS ASSOCIATES. INC., RESPONDENT AND NOW, this the petition in the I~orm of an application to stay arbitration, I1' I$ ORDERED: 1. A rule is issued upon Responc~ent G.H. Harris Associates, Inc., to show cause why the arbitration Pending before the American Arbitration Association, Case Number 14-199-02058-02, should not be stayed for JTH Tax Services LLC, and. James S. Harris and Terri Harris. husband and wife. 2. Plaintiff shall file an answer to the petition within twenty (20) days of service. · 02-546g CIVIL TERM _ORDER OF COURT · / ~'~. _ _day of November, 2002, upon consideration of 4. sen~fce. The petition shall be decided pursuant to Pa.R.C.P. 206.7. Deposition, il~ any, shall be completed within sixty (60) days of the date of 5. Briefs shall be filed in chambers not later than Tuesday, February 18, 2003. Oral argument shall be conducted in Courtroom Number 2. Cumberland County Courthouse, Carlisle, Pennsylvania at 8:4S a.m.. Thursday, Februan/20, 2003. 6. All proceedings in this maffer are stayed pending further order of this court. NOU-13-2002 12:18 PEPPER, HAMILTON P.04~04 petitioner. :sal Notice of the entry of this order shall be provided to all parties by the Edgar B. Bayley, J.~ TOTAL P.04 NOV, lq-. 20U2 ll:~/AM November 14, 2002 AMEkICAN ARBITRATION AMERICAN ARBITRATION ASSOCIATION Notice of Hearing N0.2439 P, 4/7 Steven Grubb, Esq. Goldbcrg, Kai~an & Shipman, P.C. 320 Market Strcct Harri-~burg, PA 17108 John R. Zonarich, Esq. Skarlatos & Zonarich 2(~ State Street Harrisburg, PA 17101 Pepper Hamilton 200 One Keystone pl.?. North Front and Market Struts Harrisburg, PA 17101 Re: 14 199 02058 02 G.H. Hams Associa~s, Inc. and James P. Hams & Kathy Hams and J.P. Harris Associates, LLC and ITH Tax Services, I. LC and James S. Harris & Terri Hams PLEASE TAKE NOTICE that hearings in the above-entitled arbilxation will be held as follows: Place: Schurnack~r and Lunkenheimer 1400 Liberty Ridge Drive Suite 103 Wayne, PA 19087 Date: November 18, 2002 Time: 10:00 AM Date: November 25, 2002 Time: 10:00 AM Bcforc: Robert A. Ahton Harry T. Mondoil James J. Zaydon, Jr. NO]E: Please attend promptly with your wimesses and be prepared to present your proofs. Katharine M. Legeros Case Manager 401 431 4714 NOTICE: The arbitrator(s) have arranged their schedule and reserved the above date(s). Therefore, every effot~ should be made to appear on the date(s) scheduled. In the event that unforeseen circumstances make it ;mposs,]~le to a~cnd the hearing as schcduled, a party requesting a pos~poncmen~ should obtain the a~reer~nt of thc other par~s). If there is no n'mtual agreement, the arbi~s) will make a detcrmmafion~ All requests for postponements mu~t be comw--icated to the Case Manager, not thc arbiWator. Therc should be no commumcalion bem, een the parties and the neuual arbitrator(s) other than as outlined in the parties' agreemen! to the Accelerated Exchange procedures. In some instances, postponements ar~ subject to NUV, I~,ZUU2 II:J/AM AM~KICAN AKBiIKAIION NO, 2439 P. 5/7 ~n~cllation ~ees by the arbitra~c~(s). Any psny wishinl~ a s~ndllrapbi¢ record must make ana~eme~ direly wi~h ~ s~eno~rapher ~d notify ~h~ oliler party(s) of the srran~ement~ i~ advance or,he hearings. cc; R. obcx*~ .A. ls~n Hnn*~ T. ~ondoil Sames Zaydon, Jr. 42 Pa.C.S.A. § 7303 CML ACTIONS & PROCEEDIN~ Note 21 indicated that arbitration should be had by performance, breach or other'wi only during Performance of the contract, Bangev. Harrisburg West Motor Inn, and not after the contract was terminated York 155 (1967). § 7304. Court proceedings to compel or stay arbitration (a) Compelling arbitration.--On application to a court to comp. arbitration made by a party showing an agreement described i section 7303 (relating to validity of agreement to arbitrate) and showing that an opposing party refused to arbitrate, the court sba order the parties to proceed with arbitration~ If the opposing par~ denies the existence of an agreement to arbitrate, the court shal proceed summarily to determine the issue so raised and shall orde the parties to proceed with arbitration if it finds'for the moving party Otherwise, the application shall be denied. (b) Stay of arbitration.--On application of a party to a court tc stay an arbitration proceeding threatened or commenced the cour~ may stay an arbitration on a showing that there is no agreement to arbitrate. When in substantial and bona fide dispute, such an issue shall be forthwith and summarily tried and determined and a stay of the arbitration proceedings shall be ordered if the court finds for the moving party. If the court finds for the opposing party, the court shall order the parties to proceed with arbitration. (c) Venue.--If a controversy alleged to be or not to be referable to arbitration under the agreement is also involved in an action or proceeding pending in a court having jurisdiction to hear applica- tions to compel or stay arbitration, the application shall be made to that court. Otherwise, subject to section 7319 (relating to venue of court proceedings), the application may be made in any court of competent jurisdiction. (d) Stay of Judicial proceedings.--An action or proceeding, alleg- edly involving an issue subject to arbitration, shall be stayed if a court order to proceed with arbitration has been made or an applica- tion for such an order has been made under this section. If the issue allegedly subject to arbitration is severable, the stay of the court action or proceeding may be made with respect to the severable issue only. If the application for an order to proceed with arbitration is made in such action or proceeding and is granted, the court order to proceed with arbitration, shall include a stay of the action or proceed- ing. (e) No examination of merlts.~An application for a court order to proceed with arbitration shall not be refused, nor shall an application to stay arbitration be granted, by the court on the grc~und that the 52 JTH TAX SERVICES LLC, JAMES S. HARRIS AND TERRI HARRIS, Husband and Wife, VS. Applicants, G.H. HARRIS ASSOCIATES, INC., Respondent. IN THECOURT OFCOMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA NO. 02-5469 CIV1L CIVIL ACTION - LAW PRAECIPE TO SUBSTITUTE TO THE PROTHONOTARY: Please substitute the attached verifications for the verification originally attached to the Petition in the Form of an Application to Stay Arbitration. Please substitute the attached page 4 for page 4 originally attached to the Petition in the Form of an Application to Stay Arbitration. Date: November 13, 2002 DOI~NA L FIrSI~ER'~3941b) ALEXANDRA MAKOSKY (80267) Pepper Hamilton LLP 200 One Keystone Plaza North Front and Market Streets P.O. Box 1181 Harrisburg, PA 17108-1181 (717) 255-1155 (717) 238-0575 (Fax) Attorneys for Applicants JTH Tax Services LLC, James S. Harris and Terri Harris, Husband and Wife I, Ian~a S. Harris, hereby verify that tho statements made in tl~ foregOlnt~ Application to Stay Arbitration are trt~ and ootre~t to the bcst of my kn;wled~, information and belief. I understand tha~ tt~ statements in said answer are made subJec~ to t1~ pentltle.~ of 18 Pa.C..q. §. 4~)09 relating to un~wom falsification to nmhoritks. D~d: November 12, 2002 ~li~on m Stay Arbitration ~ ~Iief. ~ ~d=r~d ~= the s=te~n~ ln.~d anawer =e m~e ~ to the ~nal~s of i 8 P~C.S. ~ 4909 relatin8 m unswom f~dflc~n to aU~odties.. personal jurisdiction, and hearing authority vested in AAA, Philadelphia, Pennsylvania, under its Commercial Rules using a panel of three arbitrators." Exhibit B, § 4.6.2, p. 5. 14. The Purchase Agreement arbitration provision is initialed by James P. Harris, as buyer, G.H. Harris, as seller, G.H. Harris, individually, Viola Harris, individually, Paul Adamshick, individually, Patricia Adamshick, individually, and Kathy Harris, individually. Exhibit B, p. 6. Agreement. 15. JTH, James S. Harris and Terri Harris are not parties to the Purchase 16. JTH, James S. Harris and Terri Harris are not signatories to the Purchase Agreement. 17. JTH, James S. Harris and Terri Harris have not entered into an arbitration agreement with G.H. Harris. 18. A contract cannot legally bind persons not a party thereto. Cumberland- Perry Area Vocational-Technical Sch. Auth. v. Bogar & Bink, 396 A.2d 433,435 (Pa. Super. 1978). 19. The arbitration clause in a contract can be enforced only by signatories to a contract. See, e.g., Dayhofflnc. v. H.J. Heinz Co., 86 F.3d 1287, 1296 (3d Cir. 1996). 20. Counsel for Applicants JTH Tax Services LLC, James S. Harris and Terri Harris, husband and wife, contacted counsel for G.H. Harris Associates, Inc., and he does not concur. -4- _CERTIFICATE OF SERVICE I hereby certify that on November 13, 2002, a copy of the foregoing document was served by first class mail, postage prepaid, addressed as follows: Steven E. Gmbb, Esquire Goldberg Katzman & Shipman, P.C. 320 Market Street, Strawberry Square P.O. Box 1268 Harrisburg, PA 17108-1268 John R. Zonarich, Esquire Skarlatos and Zonarich 204 State Street Harrisburg, PA 17101 Katharine LeGeros, Case Manager American Arbitration Association 950 Warren Avenue East Providence, RI 02914 DONNA L FISHER (39410) JTH TAX SERVICES LLC, JAMES S. : IN THE COURT OF COMMON PLEAS OF HARRIS AND TERRI HARRIS, Husband: CUMBERLAND COUNTY, PENNSYLVANIA and Wife, APPLICANTS V. G.H. HARRIS ASSOCIATES, INC., RESPONDENT : 02-5469 CIVIL TERM ORDER OF COURT AND NOW, thisl'l~' day of November, 2002, based upon the motion of G.H. Harris Associates, Inc. for clarification and modification of this court's order of November 13, 2002, IT IS ORDERED: (1) Paragraph 6 of the order of November 13, 2002, providing temporarily that "all proceedings in this matter are stayed pending further order of this court," shall remain in effect and refers to any pending arbitration between G.H. Harris Associates, Inc., and any of the following parties: JTH Tax Services LLC, James S. Harris and Terri Harris, husband and wife? (2) Pursuant to the Judicial Code at 42 Pa.C.S. § 7304(b), the order of November 13, 2002, providing for the petition to show cause why an arbitration should not be permanently stayed to be decided pursuant to Pa. Rule of Civil Procedure 206.7, IS VACATED as improvidently granted. (3) The issue of whether an arbitration between G.H. Harris Associates, Inc., and JTH Tax Services LLC, James D. Harris and Terri Harris, shall be permanently stayed shall be summarily tried pursuant to Section 7304(b) of the Judicial Code, at ' This stay order is not a preliminary injunction issued under Pa. Rule of Civil Procedure 1531(a). 10:45 a.m., Monday, December 2, 2002, in Courtroom Number 2, Cumberland County Courthouse, Carlisle, Pennsylvania. ~Alexandra Makosky, Esquire //~teven E. Grubb, Esquire /,,~ohn R. Zonarich, Esquire :sal JTH TAX SERVICES LLC, JAMES S. HARRIS AND TERRI HARRIS, Husband and Wife, VS. Applicants, G.H. HARRIS ASSOCIATES, INC., Respondent. IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA NO. 02-5469 CIVIL TERM CIVIL ACTION - LAW AFFIDAVIT OF SERVICE COMMONWEALTH OF PENNSYLVANIA : : SS: COUNTY OF DAUPHIN : THE UNDERSIGNED, being duly sworn according to law, does depose and say as follows: 1. That she is a competent adult and an attomey duly admitted to the Bar of the Supreme Court of the Commonwealth of Pennsylvania, having Attorney Identification Number 80267; 2. That on the 14th day of November, 2002, she caused the Order dated November 13, 2002, in the above-captioned action to be served upon the following individuals by mailing a true and correct copy thereof to them by first class United States Mail, postage prepaid, addressed as follows: Steven E. Grubb, Esquire Goldberg Katzman & Shipman, P.C. 320 Market Street, Strawberry Square P.O. Box 1268 Harrisburg, PA 17108-1268 John R. Zonarich, Esquire Skarlatos and Zonarich 204 State Street Harrisburg, PA 17101 Katharine LeGeros, Case Manager American Arbitration Association 950 Warren Avenue East Providence, RI 02914 ALEXANDRA MAKOSK Sworn to and subscribed before me this 14th day of November, 2002 a notary public, in and for the Commonwealth of Pennsylvania. -2- CERTIFICATE OF SERVICE I hereby certify that on November 14, 2002, I served the foregoing Affidavit of Service by placing a tree and correct copy thereof in the United States Mail, first class postage prepaid, addressed as follows: Steven E. Grubb, Esquire Goldberg Katzman & Shipman, P.C. 320 Market Street, Strawberry Square P.O. Box 1268 Harrisburg, PA 17108-1268 John R. Zonarich, Esquire Skarlatos and Zonarich 204 State Street Harrisburg, PA 17101 Katharine LeGeros, Case Manager American Arbitration Association 950 Warren Avenue East Providence, RI 02914 XANDRA MAKOSKY~ JTH TAX SERVICES LLC, JAMES S. HARRIS AND TERRI HARRIS, Husband and Wife, Applicants, VS. G.H. HARRIS ASSOCIATES, INC., Respondent. IN THE COURT OF COMMON PLEAS OF CUMBERLAiND COUNTY, PENNSYLVANIA NO. 02-5469 CIVIL CIVIL ACTION - LAW ACCEPTANCE OF SERVICE I accept service of Petition in the Form of an Application to Stay Arbitration on behalf Respondent G.H. Harris Associates, Inc., effective ~J,a/~,,[~" ./l~. _,z'~,?. and certify that I am authorized to do so. -~S~h-E. Gmbb,'~squire Attorney for Respondent G.H. Harris Associates, Inc. JTH TAX SERVICES LLC, JAMES S. HARRIS and TERRI HARRIS, Husband and Wife, Applicants, VS. G.It. tlARRIS ASSOCIATES, 1NC., Respondent. IN THE COURT OF COMMON PLEAS DAUPHIN COUNTY, PENNSYLVANIA NO. 02-5469 CIVIL CIVIL ACTION--LAW PETITION TO INTERVENE AND NOW come Petitioners James P. Harris & Kathy Harris, husband and wife, and J.P. Harris Associates, LLC, by and through their counsel, Skarlatos & Zonarich LLP, to file this Petition to Intervene in the above-captioned matter and in support thereof aver the following: 1. Petitioners James P. Harris & Kathy Harris, husband and wife, are adult individuals residing at 101 Rich Valley Road, Mechanicsburg, Cumberland County, Pennsylvania, 17050. 2. Petitioner J.P. Harris Associates, LLC is a corporation organized under the laws of the Commonwealth of Pennsylvania with its office located at 101 Rich Valley Road, Mechanicsburg, Cumberland County, Pennsylvania, 17050. 3. Petitioners James P. Harris & Kathy Harris, husband and wife, and J.P. Harris Associates, LLC (hereinafter "JPH "), along with Applicants JTH Tax Services LLC, James S. Harris and Terri Harris, husband and wife (hereinafter "JTH ") are subjects of a Demand for Arbitration issued by Respondent G.H. Harris Associates, Inc. (hereinafter G.H. Harris). 4. The Demand for Arbitration issued by G.H. Harris was pursuant to alleged violations of a covenant not to compete contained within a "Market Region Pumhase Agreement" executed between G.H. Harris and JPH on or about August 25, 2000. 5. On November 12, 2002, JTH presented to this Court a Petition in the form of an Application to Stay Arbitration pursuant to 42 Pa.C.S.A. {} 7304(b) requesting that the Court stay arbitration against JTH because there is no agreement between JTH and G.H. Harris to arbitrate; i.e., JYH are not and never were a party to the Market Purchase Agreement between JPH and G.H. Harris. 6. On November 13, 2002, this Court entered an Order containing a Rule to Show Cause why the arbitration should not be stayed, set forth a briefing schedule and set a date for oral argument. A true and correct copy of the November 13, 2002 Order is attached hereto and incorporated hcrcin as Exhibit "1". 7. Thereafter, on or about November 14, 2002, G.H. Harris filed a Motion for Clarification and to Lift Stay. 8. On November 14, 2002, this Court entered an Order setting December 2, 2002 at 10:45 a.m. as the time when the issue of whether an arbitration between G.H. Harris and JTH shall be permanently stayed shall be summarily tried pursuant to Section 7304(b) of the Judicial Code. A true and correct copy of the November 14, 2002 Order is attached hereto and incorporated herein as Exhibit "2". 9. It is the contention of JPH that the sole issue to be decided at the December 2 proceeding is whether JTH Tax Services LLC, James S. Harris and Terri Harris are parties to and legally bound by the terms of the Market Purchase Agreement between JPH and G.H. Harris. 10. It is the contention of JPH that the issue of whether JTH is a party to and legally bound by the terms of the Market Purchase Agreement between JPH and G.H. Harris is a narrow issue of contract law to be decided by the court. 11. Subpoenas have been issued by counsel for G.H. Harris to a variety of individuals, including James P. Harris, Kathy Harris and Christopher J. Freitas, which concern counsel for JPH that this legal issue may be substantially expanded. 12. If the Court allows this narrow legal issue to be expanded, the legally enforceable interests of JPH at a subsequent arbitration may be affected by the outcome of the December 2 proceeding. 13. If the Court allows this narrow legal issue to be expanded, any testimony offered may be used as evidence against JPH in later proceedings as statements previously recorded. 14. If the Court allows this narrow legal issue to be expanded, any resulting decision b3 the Court may be offered by counsel for G.H. Harris and accepted at subsequent proceedings as matters previously adjudicated. 15. In light of the concerns set forth above, it is imperative that JPH be permitted to intervene in this matter so that its counsel may have an opportunity to participate in the proceeding and effectively represent and protect the legal interests of JPH that may be affected through the course of this proceeding. WHEREFORE, Petitioners James P. Harris & Kathy Harris, husband and wife, and J.P. Harris Associates, LLC respectfully request this Honorable Court to grant this Petition to Intervene in the above-captioned matter. Respectfully Submitted, SKARLATOS & ZONARICH LLP B-~~n~ ~-~-~ I.D. No. 83302 204 State Street Harrisburg, PA 17101 (717) 233- 1000 4 FROM ' FAX NO. : Nov, 22 2~02 03:~0PM P2 NOV-22-2002 FRI 0~:15 Pti SI<aRLATO$ & ZO~IARIOH LLP ha~ ~n Enamored by ~u~ol taxi/or othe~ lhB ~o¢~}~l~t i~ ~ O~ eO~n$Cl 8t~ not o~r o~ it ts ba~l ~il~i~ t~ormnQon t~at w~ have kno<edgc, ~nbrnlatlon m~d bel~f ~ th~ exam t~t ~e e~t~tt of th~ d~ument i$ ~hot of co~ms~l, ~ have celled tl~n coU~OI in makin$ ,hia Vcrifl~on. We bO~ aCkllOwled~ ~mt the fact~ mot fo~h in ~ a¢~id d~ul~t Exhibit 1 NOV-13-2882 12:18 PEPPER,HAMILTON P.03~0Zl ~' JTH TAX SERVICES LLC, JAMES S. : IN THE COURT OF COMMON PLEAS OF HARRIS AND TERRI HARRIS, Husband: CUMBERLAND COUNTY, PENNSYLVANIA and VVife, APPLICANTS : G.H. HARRIS ASSOCIATES, INC., RESPONDENT : 02-5469 CIVIL TERM ORDER OF COURT AND NOW, this ~~---~dal/of November, 2002, upon consideration of the petition in the form of an application to stay arbitration, IT IS ORDERED: 1. A rule is issued upon Respondent G.H. Harris Associates, Inc., to show cause why the arbitration - . Pending before the American Arbitration Association, Case Number 14-199-02058.02, should not be stayed for JTH Tax Services LLC, and James S. Ha~s and Terri Herds, husband and wife. 2. Plaintiff shall file an answer to the petition within twenty (20) days of service. 4. sen~fce. The petition shall be decided pursuant to Pa.R.C.P. 206.7. Deposition, if any, shall be completed within sixty (60) days of the date of 5. Briefs shall be filed in chambers not later than Tuesday, February 18, 2003. Oral argument shall be Conducted in Courtroom Number 2. Cumberland County Courthouse, Carlisle, Pennsylvania at 8:45 a.m., Thursday, February 20, 2003. 6. All proceedings in this matter are stayed Pending further orcle~' of this court. NOU-13-2002.. 12:18 PEPPER,HAMILTON P.04~04 petitioner. :sal Notice of the entry of this order shall be provided to all parties by the Edgar B. Bayley. J.> TOTAL P.04 Exhibit 2 JTH TAX SERVICES LLC, JAMES S. : IN THE COURT OF COMMON PLEAS OF HARRIS AND TERRI HARRIS, Husband: CUMBERLAND COUNTY, PENNSYLVANIA and Wife, APPLICANTS V. G.H. HARRIS ASSOCIATES, INC., RESPONDENT : 02-5469 CIVIL TERM ORDER OF COURT AND NOW, this ~'1~ day of November, 2002, based upon the motion of G.H. Harris Associates, Inc. for clarification and modification of this court's order of November 13, 2002, IT I$ ORDERED: (1) Paragraph 6 of the order of November 13, 2002, providing temporarily that "all proceedings in this matter are stayed pending further order of this court," shall remain in effect and refers to any pending arbitration between G.H. Harris Associates, Inc., and any of the following parties: JTH Tax Services LLC, James S. Harris and Terri Harris, husband and wife? (2) Pursuant to the Judicial Code at 42 Pa.C.S. § 7304(b), the order of November 13, 2002, providing for the petition to show cause why an arbitration should not be permanently stayed to be decided pursuant to P~r. Rule of Civil Procedure 206.7, IS VACATED as improvidently granted. (3) The issue of whether an arbitration between G.H. Harris Associates, Inc., and JTH Tax Services LLC, James D. Harris and Terri Harris, shall be permanently stayed shall be summarily tried pursuant to Section 7304(b) of the Judicial Code, at ' This stay order is not a preliminary injunction issued under Pa. Rule of Civil Procedure 1531(a). 10:45 a.m., Monday, December 2, 2002, in Courtroom Number 2, Cumberland County Courthouse, Carlisle, Pennsylvania. Alexandra Makosky, Esquire Steven E. Grubb, Esquire John R. Zonarich, Esquire :sal J'I'H 'FAX SERVICES LLC, JAMES S. HARRIS and TERRI HARRIS, Husband and Wife, Applicants, VS. G.H. HARRIS ASSOCIATES, INC., Respondent. IN THE COURT OF COMMON PLEAS DAUPHIN COUNTY, PENNSYLVANIA NO. 02-5469 CIVIL CIVIL ACTION--LAW CERTIFICATE OF SERVICE I, Todd F. Tmntz, Esquire, attorney for Petitioners James P. Harris & Kathy Harris, husband and wife, and J.P. Harris Associates, LLC, hereby certify that I this day served a copy of the foregoing Petition upon the person(s) indicated below by facsimile transmission and by depositing a copy of the same in the United States Mail, postage prepaid, at Harrisburg, Pennsylvania, and addressed as follows: Steven E. Grubb, Esquire Goldberg, Katzman & Shipman, P.C. 320 Market Street, Strawberry Square P.O. Box 1268 Harrisburg, PA 17108-1268 Donna L. Fisher Alexandra Makosky pepper Hamilton LLP 200 One Keystone Plaza North Front & Market Streets P.O. Box 1181 Harrisburg, PA 17108-I 181 Dated: SKARLATOS & ZONARICH LLP Todd F. Tmntz, Esquire I.D. No. 83302 204 State Street Harrisburg, PA 17101 (717) 233- 1000 JTH TAX SERVICES LLC, JAMES S. HARRIS and TERRI HARRIS, Husband and Wife, Applicants, VS. G.H. HARRIS ASSOCIATES, 1NC., Respondent. IN THE COURT OF COMMON PLEAS DAUPHIN COUNTY, PENNSYLVANIA NO. 02-5469 CIVIL CIVIL ACTION--LAW ORDER AND NOW, this ~_~:~ day of November, 2002, upon consideration of the Petition to Intervene submitted by Petitioners James P. Harris & Kathy Harris, husband and wife, and J.P. Harris Associates, LLC, said petition is hereby GRANTED. BY THE COURT: Edgar B. Bayleyl~"~e JTH TAX SERVICES, LLC, JAMES S. HARRIS AND TERRI HARRIS, HUSBAND AND WIFE, APPLICANTS IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA G.H. HARRIS ASSOCIATES, INC., RESPONDENT JAMES P. HARRIS AND KATHY HARRIS, HUSBAND AND WIFE, AND J.P. HARRIS ASSOCIATES, LLC, INTERVENERS · 02-5469 CIVIL TERM IN RE: PETITION TO STAY ARBITRATION BEFORE BAYLEY, J. INTERIM ORDER OF COURT AND NOW, this ~'jL. day of December, 2002, IT IS ORDERED that a continuation of the hearing of December 2, 2002, shall be conducted in Courtroom Number 2, Cumberland County Courthouse, Carlisle, Pennsylvania, at 8:45 a.m., Friday, December 27, 2002. A final order with respect to all claims of the applicants will be entered thereafter. 02-5469 CIVIL TERM V~lexandra Makosky, Esquire For ^pplicants v/Steven E. Grubb, Esquire For Respondent j//~[John R. Zonarich, Esquire For Interveners :sal JTH TAX SERVICES, LLC, JAMES S. HARRIS AND TERRI HARRIS, HUSBAND AND WIFE, APPLICANTS G.H. HARRIS ASSOCIATES, INC., RESPONDENT JAMES P. HARRIS AND KATHY HARRIS, HUSBAND AND WIFE, AND J.P. HARRIS ASSOCIATES, LLC, INTERVENERS IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA IN RE: PETITION TO STAY ARBITRATION BEFORE BAYLEY~ J. OPINION AND INTERIM ORDER OF COURT Bayley, J., December 13, 2002:- James S. Harris is the son of James P. Harris. G.H. Harris is the father of James P. Harris and the grandfather of James S. Harris. On August 25, 2000, "G.H. Harris Associates, Inc. (seller)," of Dallas, Pennsylvania, and "Mr. and Mrs. James P. Harris (buyer)," of Mechanicsburg, Pennsylvania, entered into a written Market Region Purchase Agreement. Both the seller and buyer are in the business of collecting delinquent taxes. The buyer purchased a part of the seller's tax collection business. The Agreement prohibits competition and solicitation by the buyer with respect to certain clients of the seller. Paragraph 4.6.1 of the Agreement provides: 02-5469 CIVIL TERM 02-5469 CIVIL TERM In the event of a dispute between the Parties, each Party agrees to attempt resolution through mediation with a mediator provided by the American Arbitration Association ("AAA") in Philadelphia, Pennsylvania, in accordance with the then existing AAA Commercial Rules. Absent favorable results, arbitration notice may be sent within thirty {30) days of the request for mediation. Claims for equitable relief need not be mediated. (Emphasis added.) Paragraph 4.7 of the Agreement provides: Binding Effect: This agreement supersedes all prior agreements, written or oral, between the Parties concerniing the subject matter of this Agreement. It shall be binding upon and inure to the benefit of the undersigned and their representatives, administrators, assigns, and/or successors-in-interest. This Agreement and the non-compete provisions in particular shall be binding upon Buyer, Buyer's wife and children, and upon any and all business entities in which Buyer has any ownership interest, direct or indirect. The person signing for each party warrants that he has the full authority to bind the Party represented. (Emphasis added.) The Agreement was executed as follows: (1) G.H. Harris signed for "G.H. Harris, individually and as President G.H. Harris Associates, Inc." (2) James P. Harris signed for "JAMES P. HARRIS, individually and for his wife, children, and associated business activities." (I--mphasis added.) On October 31, 2002, G.H. Harris Associates, In(:., filed with the American Arbitration Association a Demand for Arbitration against (1) J.P. Harris Associates, LLC, (2) James P. Harris and Kathy Harris, husband and wife, (3) JTH Tax Service, LLC, and (4) James S. Harris and Terri Harris, husband and wife. The Demand seeks relief for (1) an alleged violation by defendants of the restrictive covenant in the Market Region -2- 02-5469 CIVIL TERM Purchase Agreement of August 25, 2000, (2) tortuous interference with contractual relations, and (3) breach of representation and warranties. On November 12, 2002, JTH Tax Service, LLC, and James S. Harris and Terri Harris, filed an application in this court against G.H. Harris Associates, Inc., to stay the arbitration as to them. James P. Harris and Kathy Harris, husband and wife, and J.P. Harris Associates, LLC, has intervened. The Judicial Code at 42 Pa.C.S. Section 730,4(b) provides: On application of a party to a court to stay an arbitration proceeding threatened or commenced the court may stay an arbitration on a showing that there is no agreement to arbitrate. When in substantial and bona fide dispute, such an issue shall be forthwith and summarily tried and determined and a stay of arbitration proceedings shall be ordered if the court finds for the moving pad¥. If the court finds for the opposing party, the court shall order the parties to proceed with arbitration. (Emphasis added.) The application to stay the arbitration was tried on December 2, 2002.' The applicants maintain that they are not bound by the arbitration clause in the Market Region Purchase Agreement because they are not a parlly to that Agreement. They did not execute the Agreement, and they maintain that James P. Harris did not have authority to bind them to the Agreement. A question of whether a party has agreed to arbitrate a dispute is a jurisdictional question to be decided by a court. Smith v. Cumberland Group LTD, 687 A.2d 1167 (Pa. Super. 1997). A party who can establish that there was no agreement to arbitrate is entitled to enjoin an arbitration. Id. In the case sub judice, none of the applicants signed the Market Region Purchase The arbitration is scheduled for mid-January, 2003. -3- 02-5469 CIVIL TERM Agreement of August 25, 2000, that contains the arbitration clause. However, James P. Harris signed for his "children, and associated business activities." G.H. Harris Associates, Inc., maintains that the applicants are subject to the arbitration clause in the Market Region Purchase Agreement because James P. Harris bound them to the Agreement as their agent. In Reifsnyder v. Dougherty, 301 Pa. 328 (1930), the Supreme Court of Pennsylvania stated that there are four grounds upon which an agency relationship can be established: The liability of a principal to third parties for the acts of an agent may rest on the following grounds: (1) Express authority, or that which is directly granted; (2) implied authority, to do all that is proper, usual, and necessary to the exercise of the authority actually granted; (3) apparent authority, as where the principal holds one ()ut as agent by words or conduct; and (4) agency by estoppel, which arises where the principal, by his culpable negligence in failing to supervise the affairs of his agent, allows him to exercise powers not granted to him, and so justifies others in believing he possesses the requisite authority. James S. Harris, age 27, testified that he and his wife Terri Harris, have lived in Columbia, Maryland since 1996. He is a graduate of West Virginia University, and a professional engineer. Since before 2000, he has worked full-time as an engineer on propulsion systems for Carlton Technologies in Maryland. He and his wife incorporated JTH Tax Services, LLC, in Pennsylvania, on October 25, 2001. They are the sole owners of the corporation which is in the business of coll,~-cting delinquent taxes for municipalities in Pennsylvania, the same business as those operated by his father and grandfather. Terri Harris operates the company on a daily basis out of an office in Hanover, Pennsylvania. James S. Harris testified that neither his father nor his -4- 02-5469 CIVIL TERM grandfather's delinquent tax collections business, or any of his relatives, have any interest or working relationship with JTH Tax Services, LLC. The company employs two part-time deputy tax collectors who are also part-time employees of the father's tax collection company, J.P. Harris Associates, LLC. From 1!;)91 to 1994, until he graduated from college, James S. Harris worked part-time during summer school breaks and vacation periods in his grandfather's tax collection business, G.H. Harris Associates, LLC. His wife worked for that company over one Christmas break. She has other experience in debt collection and management. Neither James S. Harris or Terri Harris have ever worked for his father's tax collectio~n business, J.P. Harris Associates, LLC. James S. Harris testified that prior to ^ugust 25, 2000, he was told by his father that his father and grandfather were negotiating an agreement with respect to their businesses, and that his grandfather wanted the agreement to bind him. He told his father that he would not be bound. James P. Harris testified that he signed the Market Region Purchase Agreement for his "children and associated business activities," although he has only one child, James S. Harris. He testified that despite having warranted in the agreement that he has full authority to bind his son, his attorney told him (1) that his signature was not binding on his son, and (2) that his father, G.H. Harris, understood that but he would not allow the language to be taken out of the Agreement. G.H. Harris did not present any testimony to the contrary, nor did he testify on what basis he may have reasonably believed that James P. Harris had authority to bind his son to the Agreement. -5- 02-5469 CIVIL TERM There is clearly no basis upon which Terri Harris can be bound by the arbitration clause in the Market Region Purchase Agreement. Weighing the credibility of all of the witnesses, and considering all of the evidence, we find that James S. Harris did not give his father, James P. Harris, express authority to bind him 'to the Market Region Purchase Agreement. There is no evidence that James P. Harris had implied authority to bind his son to the Agreement as he had no express a[]thority from his son whereby he could act in a necessary, proper and usual exercise of such authority. There is no evidence of any authority that James S. Harris is estopped to deny. In Bennett v. Juzelenos, 791 A.2d 403 (Pa. Super 2002), the Superior Court of Pennsylvania stated: Apparent authority is power to bind a pri~ncipal which the principal has not actually granted but which he leads persons with whom his agent deals to believe that he has granted. Persons with whom the agent deals can reasonably believe that the agent has power to bind his principal if, for instance, the principal knowingly permits the agent to exercise such power or if the principal holds the agent out as possessing such power. (Emphasis added.) In determining the apparent authority of an agent ~ve must look to the actions of the principal, not the agent. Turnway Corp. v. Softer, 461 Pa. 447 (1975). There is nothing in the evidence that would warrant our concluding that James S. Harris did anything which could have led G.H. Harris to reasonably believe that James P. Harris had authority to bind him to the Market Region Purchase Agreement. James S. Harris never worked in his father's tax collection business. He only did some part-time work for G.H. Harris Associates, Inc., when he was in college. He was married and living in Maryland and working as a full-time professional engineer when the Market Region -6- 02-5469 CIVIL TERM Purchase Agreement was signed on August 25, 2000. JTH Tax Services, LLC, did not start business until it was incorporated on October 25, 2001, one year and two months after the Market Region Purchase Agreement was signed. Despite the duplicity of James P. Harris signing the Market Region Purchase Agreement "for his.., children," we find that he did not have apparent authority to bind his son, James S. Harris, to the Agreement. Notwithstanding that James P. Harris is not an officer, director or shareholder in JTH Tax Services, LLC, which was incorporated by his son and daughter-in-law over a year after the Market Region Purchase Agreement was executed, G.H. Harris Associates, Inc., maintains that the corporation is the alter ego of James P. Harris and thus is bound by the arbitration clause in the Agreement. There are federal cases which have held when considering enforcement of an arbitration agreement against non-signatories, the question is whether the non-signatory is bound by the agreement under traditional common law principles of contract and agency law. See BeI-Ray Company, In¢. v. Chemrite, Ltd., 181 F.3d 435 (3d Cir. 1999); E.I. Dupont deNemours and Company v. Rhone Poulenc Fiber and Resin Intermediates, S.A.S., 269 F.3d 187 (3d Cir. 2001). This alter ego argument that JTH Tax Services, LLC is a front/subterfuge/facade for James P. Harris can also be considered as it being an associated business activity of his; therefore, the corporation is bound by the arbitration clause in the Market Region Purchase Agreement signed by him, inter alia, -7- 02-5469 CIVIL TERM "for his.., associated business activities," a party to the Agreement? In retrospect, we believe that at the hearing on December 2"d, we wrongly sustained objections to allowing G.H. Harris Associates, Inc., to present a full record in support of this position. Accordingly, we will schedule another hearing to allow development of a complete record limited to the issue of whether JTH Tax Services, [_LC, is subject to the arbitration provision contained in the Market Region Purchase Agreement of August 25, 2000, because it is the alter ego of James P. Harris and/or is his associated business activity. INTERIM ORDER OF COURT AND NOW, this ~'~"~ day of December, 2002, IT IS ORDERED that a continuation of the hearing of December 2, 2002, shall be conducted in Courtroom Number 2, Cumberland County Courthouse, Carlisle, Pennsylvania, at 8:45 a.m., Friday, December 27, 2002. A final order with respect to all claims of the applicants will be entered thereafter. 2 In Sklaroff v. Sklaroff, 263 Pa. 421 (1919), two men sold a business and entered into a non-competition agreement with the buyer. The sellers later sued the buyers maintaining that they were violating the non-compete agreement by using a company to operate the same kind of business through the agency of' two men who held themselves out as the owners. The trial court held that the company was in reality the business of the two sellers, that the two men were acting as their agents, and that this plan was conceived for the purpose of avoiding the non-competition clause in the contract. An injunction was issued restraining the buyers from competing through the operation of the company. The injunction was upheld by the Supreme Court of Pennsylvania. -8- 02-5469 CIVIL TERM Alexandra Makosky, Esquire For Applicants Steven E. Grubb, Esquire For Respondent John R. Zonarich, Esquire For Interveners :sal By the ~ Edgar B. Bayley, J. ~, -9- JTH TAX SERVICES LLC, JAMES S. ' HARRIS AND TERRI HARRIS, Husband: and Wife, APPLICANTS IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA G.H. HARRIS ASSOCIATES, INC., RESPONDENT JAMES P. HARRIS AND KATHY HARRIS, HUSBAND AND WIFE, AND J.P. HARRIS ASSOCIATES, LLC, INTERVENERS 02-5469 CIVIL TERM ORDER OF COURT AND NOW, this ~,'~ ~ay of December, 2002, upon agreement of all the parties, the hearing currently scheduled for December 27, 2002, IS CANCELLED. The hearing is rescheduled to Friday, January 3, 2003, at 8:45 a.m., in Courtroom Number 2, Cumberland County Courthouse, Carlisle, Pennsylvania. By the~ Edgar B. Bayley, . /Alexandra Makosky, Esquire For Applicants ¢/Steven E. Grubb, Esquire For Respondents C/John R. Zonarich, Esquire For Interveners :sal JTH TAX SERVICES, LLC, JAMES S. HARRIS AND TERRI HARRIS, HUSBAND AND WIFE, Applicants Vo G.H. HARRIS ASSOCIATES, INC., Respondent Vo JAMES P. HARRIS AND KATHY HARRIS, HUSBAND AND WIFE, AND J.P. HARRIS: ASSOCIATES, LLC, : Interveners : IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL ACTION - LAW NO. 02-5469 CIVIL TERM IN RE: TRANSCRIPT OF PROCEEDINGS Proceedings held before the HONORABLE EDGAR B. BAYLEY, J., Cumberland County Courthouse, Carlisle, Pennsylvania, on December 2, 2002, at 10:56 a.m. in Courtroom Number Two. APPEARANCES: ALEXANDRA MAKOSKY, Esquire For the Applicants STEVEN E. GRUBB, Esquire For the Respondent JOHN R. ZONARICH, Esquire For James and Kathy Harris FOR THE PETITIONERS 1. James S. Harris FOR THE RESPONDENT 1. James P. Harris INDEX TO WITNESSES DIRECT 6 54 CROSS 24 2 FOR THE PETITIONERS INDEX TO EXHIBITS MARKED 1. Market Region Purchase Agreement 7 2. Forms to file for company within 15 State of Pennsylvania 3. Employee Dishonesty Bond 19 4. JTH Tax Services, LLC, check 20 5. JTH Tax Services, LLC, letterhead 21 FOR THE RESPONDENT 1. JTH Tax Services, LLC, document 35 2. J.P. Harris Associates, LLC, document 37 3. Information sheet on JTH Tax 40 Services, LLC ADMITTED 60 60 60 60 60 60 60 60 3 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 December 2, 2002, 10:56 a.m. Carlisle, Pennsylvania (Whereupon, the following proceedings were held:) THE COURT: arbitration, right? MS. MAKOSKY: MR. GRUBB: THE COURT: This is a petition to stay an That's right. Correct. Just introduce yourselves, and tell me who is representing whom in this so that I get an understanding. The petitioner is represented by? MS. MAKOSKY: Alexandra Makosky, Your Honor, representing JTH Tax Services, James S. Harris and Terri Harris. MR. GRUBB: Steven Grubb for the respondents. THE COURT: MR. GRUBB: THE COURT: MR. GRUBB: THE COURT: Your last name again? Grubb. For respondents? G.H. Harris. Is anybody else involved? MR. ZONARICH: Yes, Your Honor. THE COURT: Intervener. MR. ZONARICH: John Zonarich, and we filed a petition to intervene on behalf of James and Kathy Harris. 4 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 THE COURT: Now, petitioner is moving then to stay the arbitration as it relates to what parties? MS. MAKOSKY: Your Honor, we're asking for it to stay the arbitration for us, for JTH Tax Services, James S. Harris and Terri Harris. THE COURT: Do they run the tax service? MS. MAKOSKY: We run JTH Tax Services. THE COURT: And those are the only issues I have before me, right? MS. MAKOSKY: Yes. THE COURT: That's the only issue? MS. MAKOSKY: Yes, sir. THE COURT: And I have this motion in limine. I am not going to listen to the merits of the controversy. The issue is whether or not legally the arbitration should proceed. MS. MAKOSKY: THE COURT: MR. GRUBB: Yes, Your Honor. Everybody agree? Yes, Your Honor. MR. ZONARICH: THE COURT: MS. MAKOSKY: in an opening statement? THE COURT: opening statement. Yes. Let's do it. First witness. Your Honor, are you interested Go ahead, I will listen to an Off the record. 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 (Whereupon, opening statements were held off the record.) THE COURT: You may proceed. MS. MAKOSKY: We would like to call James S. Harris then to the stand, Your Honor. Whereupon, JAMES S. HARRIS, having been duly sworn, testified as follows: DIRECT EXAMINATION BY MS. MAKOSKY: Q Jim, will you please give us your full name. A James Scott Harris. Q And where do you live? A I live at 70 Marfield Circle, Hanover, PA. Q Who else lives there with you? A My wife and my two children. Q And how long have you lived in Hanover? A I've lived in Hanover approximately a year, a little over a year. Q And prior to living in your Hanover address, where did you live prior to that? A I lived in Columbia, Maryland, which is between Baltimore and Washington D.C. Q And how long did you live there? A A little over five years. 6 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 Q A Carlton Technologies, Incorporated. the Baltimore/Washington Airport. Services. And where are you working? I'm currently working at a company called They are located near witness? Q And I think Mr. Zonarich has already explained to the Court, but can you please on the record tell us how are you related to James P. Harris? A James P. Harris is my father. And how are you related to Mr. G.H. Harris? He is my grandfather. MS. MAKOSKY: Your Honor, may I approach the THE COURT: Sure. (Whereupon, Petitioners' Exhibit No. 1 was marked for identification.) BY MS. MAKOSKY: Q Jim, I've handed to you what's been marked as Petitioners' Exhibit No. 1. document? A Q A Do you recognize this Yes. What is it? It's a Market Region Purchase Agreement, at Q And are you employed with any other company? A Yes, I'm a partner in a company JTH Tax 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 least what it's titled. agreement. Q I believe it's a non-compete A agreement ? A What is the date of the agreement? August 25th, 2000. When was the first time you saw this The first time I saw this agreement was October of 2002 when it was served to us as a complaint for arbitration. Q Can you flip through that document. I believe you've read that. First of all, have you read this document prior to coming here today? A Yes, I've read it several times. Q Can you just flip through one more time now that it's marked as an exhibit, and tell me do you see your name appearing anywhere on that document? A No, I do not. Q Do you see your wife's name anywhere appearing on that document? A No, I do not. THE COURT: THE WITNESS: THE COURT: BY MS. MAKOSKY: Q Your wife is Terri? Terri Harris. Go ahead. Do you see your signature on that agreement? 8 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 A No, I do not. Q Do you see your wife Terri Harris' signature on that agreement? No, I do not. Did you agree, Jim, to be bound to this A agreement? A Q agreement? A Q No, I did not. And did your wife agree to be bound by this No, she did not. And did you agree to arbitrate any issues before the American Arbitration Association? A No, I did not. Q And I know this is redundant, but did your wife, to the best of your knowledge, agree to arbitrate any disputes before the American Arbitration Association? A No, she did not. Q Can you turn to Section 4.6 of that agreement, which I believe begins on page 5, and if I'm correct it has to do -- that is the section that is dealing with Dispute Resolution and Mandatory Arbitration. A Can you repeat that. Q Sure. Under Section 4.6, I'm starting on page 5 of the agreement, do you see where it's headed -- the heading says Dispute Resolution and Mandatory 9 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 Arbitration? A Yes. Q Is it fair to characterize this section being the area of the contract that is specifically dealing with the parties' agreement as to how arbitration was to be -- was to proceed to the best of your recollection? A Yes. Q On page 6 of the agreement under Section 4.6.8, there is a series of, I believe, seven sets of initials. Are your initials there or your signature of your initials? A Q No, they are not. Is your wife Terri Harris' signature -- are her initials there? A No, they are not. Q Can you also flip for me on page 8 of that agreement where it says Consent. of Spouses and Affected Family Members. Page 8. A I'm sorry. Q That's all right. A I'm there. Q Under this heading of Consent of Spouses and Affected Family Members, does your signature appear on this page? A No, it does not. 10 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 Q Does your wife's signature appear? No, it does not. To the best of your knowledge, Jim, have you A beneficiary? A Q been a third party beneficiary of this agreement between G.H. Harris and James P. Harris? No, I have not. Has your wife been a third party No. When you were served a copy of the demand for arbitration that had this agreement attached to it, what did you do? A We received it actually on.a Friday afternoon. My wife called me at work and came home and read it several times. The first thing we did is we called one of my wife's best friends who is an attorney in the Washington area and discussed this with her and asked if she knew of any attorneys -- THE COURT: Wait a minute. We are here. I got what happened. One way or the other, here we go. BY MS. MAKOSKY: MS. MAKOSKY: THE COURT: Okay. You are petitioner. Q Jim, have you ever discussed the terms of this agreement with your grandfather? 11 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 A With my grandfather? With your grandfather. No. Did you ever discuss any of the terms of this agreement with your father? A No. Q Did you ever give your father power of attorney to sign on your behalf for this agreement? A No. Q Did you ever tell your father that he could sign this agreement for you on your behalf? A No. Q Jim, how old were you in August of 2000? A Twenty-seven years old. Q And where were you living at that time? A Columbia, Maryland. Q And when -- I think you had testified earlier that you had been in Columbia for several years. But when did you move to Columbia? A We moved to Columbia July or -- July and/or August of 1996. Q So how many years had you been living away from your parents' home as of August 2000? A At least five years. I was in college for five years, in grad school for one year where I did not -- 12 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 I was a resident of West Virginia. So it was at least five years, five and half years or more, maybe six years that I didn't live at home. 2000? Q Were you married in August of 2000? Yes. You had a child by that time? Yes. And where were you working in August of A The same company I stated earlier, Carlton Technologies, Incorporated. Q Were you an employee of your father's company in August of 2000? A Of? Q Of your father's, J.P. -- this is where we're going to start getting a little bit confused -- J.P. Harris Associates, LLC, your father's company? company? company? A NO. Are you an employee of his company now? No. Have you ever been an employee of his A NO. Were you an officer of your father's 13 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 A No. Q Have you ever been an officer of your father's company? A No. Q Jim, did you have any conversations with your grandfather -- I think you mentioned it, but let me make sure I've gone over this one more time. Have you had any conversations or discussions with your grandfather before this agreement was signed regarding the breakup of the business between G.H. Harris and James P. Harris? A No. Q Before this agreement was signed in August of 2000, when was the last time you had a discussion or any contact with your grandfather? I believe it was the November, December time A frame of '99. Q And at that time did you have any discussions about the business? A No. Q Have you had any contact with your grandfather since August of 2000? A NO. Have you corresponded with him? We have sent Christmas cards, things of that nature. 14 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 Q Let's just now turn to the focus of JTH Tax Services a little bit. A Okay. Q First of all, can you tell the Court what type of business is JTH Tax Services in? A JTH Tax Services is a delinquent tax collection agency that works for the local municipalities in the State of Pennsylvania, primarily collecting deliquent taxes, per capita taxes, and school and occupation taxes and earned income taxes, as I stated, for townships, counties, and school districts. Q Was JTH Tax Services in existence in August of 2000? 2001. A In August of 2000? Yes. No. When was JTH Tax Services formed? JTH Tax Services was formed late October of MS. MAKOSKY: approach the witness? THE COURT: Your Honor, again, may I Yes (Whereupon, Petitioners' Exhibit No. 2 was marked for identification.) 15 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 BY MS. MAKOSKY: Q Jim, I've handed to you a copy of what's been marked as Petitioner's Exhibit No. 2. Do you recognize this document? A Yes. Q What is it? A This was our forms to file for our company within the State of Pennsylvania. Q Were any amendments filed to this Articles of Incorporation? A No. Q Prior to you filing this Articles of Incorporation, was there any other business entity in which you were operating under for your tax business? A No. Q Who are the owners of JTH Tax Services? A Myself, James Scott Harris, and my wife, Terri Lynne Harris. Q Jim, can you tell us a little bit about your experience in collecting delinquent taxes? A I kind of grew up in this business with both my grandfather and father. My father ran a office for his father out of their own home, so I grew up with that basically. My grandfather ran an office out of northern Pennsylvania. 16 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 I worked for my grandfather, I believe it is, between the years of 1991 and 1994 collecting delinquent taxes in Adams County, Perry County, Franklin County, York County, Dauphin County. I may have missed a couple there, but doing delinquent tax collections over Christmas breaks and summer breaks between '91 and '94 in college. Q And who manages the day-to-day operations now of JTH Tax Services? A My wife does most of the daily operations. Q And what is her experience? A Her experience. She actually also worked over one Christmas break collecting delinquent taxes for G.H. Harris. In addition to that, her background, at least where she worked before we moved to the Pennsylvania area, was in debt management and collections. Q Does James P. Harris, your father, have any ownership interest in your company? A No. Is he an employee of your company? No. Does he manage your company? No. Has he received any profits from your company? 17 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 A No. Q Does Kathy Harris, your mother, have an ownership interest in your company? company? A No. Is she an employee of your company? No. Has she managed your company? No. Has she received any profits from your A No. Q Does your father's co~)any, J.P. Harris Associates, LLC, have any ownership interest in JTH Tax Services? A No. Q Have they received -- has that company -- your father's company received any profits from your company? A No. Q Is it required as part of your services to your clients to file a bond? A Excuse me? Q As part of your -- has a client required you to apply for a bond? A Yes. 18 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 witness? MS. MAKOSKY: Your Honor, may I approach the THE COURT: Yes (Whereupon, Petitioners' Exhibit No. 3 was marked for identification.) BY MS. MAKOSKY: Q Jim, I've handed to you what's been marked as Petitioners' Exhibit No. 3. Are you familiar with this exhibit? A Yes. Q What is it? A It is a bond so that we could -- it's basically a bond. account? banking. Q Your Honor? And in whose name has it been taken out? Under JTH Tax Services.. Does JTH Tax Services have a bank account? Yes. And where do they maintain that bank A It's the same bank that we use for our home It's Allfirst Bank. MS. MAKOSKY: May I approach the witness, THE COURT: Yes. 19 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 BY MS. MAKOSKY: Q (Whereupon, Petitioners' Exhibit No. 4 was marked for identification.) Jim, I've handed to you what's been marked as Petitioners' Exhibit No. 4. A Q A Q account? business? A A Are you familiar with that? Yes. And what is it? This is our company check. And who has authorization to sign that My wife and I. And have you used those checks in your Excuse me? Have you used those checks in your business? Yes. And when -- for instance, can you give an example of when you have used those checks? A If we were paying for stationery or any type of things for the company. Q Do you send monthly reports to your clients? Yes. And what goes in those monthly reports? A check will go in those monthly reports. You mentioned that you do have stationery, 20 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 that you've had to purchase stationery? A Yes. MS. MAKOSKY: I approach the witness? THE COURT: Yes. Your Honor, one more time, may Continue to do so. (Whereupon, Petitioners' Exhibit No. 5 was marked for identification.) BY MS. MAKOSKY: Q I've now handed you what's been marked as Petitioners' Exhibit No. 5. Are you familiar with what that document is? A Yes. Q And what is it? A This is our letterhead. Q Now, I notice there's two pages to that. Can you tell me that you have -- can you tell me why you've got different addresses on your letterhead? A When we received our one account, the business manager for that account re~lested that we had a local mailbox. He said it was a good selling point for us to basically -- with him within his organization, because this is something that has to be voted on, that if it was a local mailing address that we would have a better chance of actually getting the account. Q So it was an unofficial requirement of -- is 21 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 this the Cumberland Valley School District? A Yes, this is the Cumberland V~lley account. Q That they were strongly requesting you to have a post office box in the Mechanicsburg area? A Yes. Q And do you use that post office box for all of your work or how do you decide? A On a percentage basis, I would say probably -- most of our work, I mean, primarily about 50 percent, maybe 60 percent, is through the mail, meaning people will respond to the mail and directly pay their delinquent taxes. So out of the four accounts that we have, three of them go to our Hanover post office box, and everything else, which would just be the Cumberland Valley account, goes to the Mechanicsburg address. So on a percentage basis, it's probably around 30 percent of our mailing goes to that address, and that would be just the delinquents. All correspondence with the Cumberland Valley School District goes through our Hanover post office box. Q So if I just understand correctly, your testimony is that about 30 percent of your work is being sent to the Mechanicsburg office, and 70 percent is going to your Hanover address? 22 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 A Yes. Q And the 30 percent that's going to your Mechanicsburg address is the -- is the delinquent taxpayers sending their money into that post office box? A Yes. Q And that's at the request of the Cumberland Valley School District manager? A Yes. Q But when you are corresponding with that Cumberland Valley -- THE COURT: You are just repeating yourself. I got it the first time. Go ahead. BY MS. MAKOSKY: Q Jim, do you have a computer system set up for your business? A Yes. Q And do you have a licensing agreement with a company to manage the software? A Yes, we have a maintenance agreement. Q Is it my understanding that you also have a private business phone line for your business? A Yes, we have a private phone and fax. Q And that's operating under regular business hours? A Yes, that's through 8:00 to 5:00. We have 23 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 actually three numbers. We have a fax number. We have a regular business number, and we have a 1-800 number which is only for all of our clients to actually call in, not the delinquent taxpayers. MS. MAKOSKY: Thank you. THE COURT: Cross. CROSS EXAMINATION BY MR. GRUBB: Q Mr. Harris, if we could turn to the Exhibit 1 that should be in front of you which is the Market Region Purchase Agreement. Is that in front of you, sir? A Yes. Q If you could please turn to Section 4.7 of that agreement. Let me ask you this ~estion first, Mr. Harris. On the very first page of that document where the buyer is identified, would you agree with me that the buyer, according to this document, is Mr. and Mrs. James P. Harris? A Q A Q A Q A Yes. And they are your father and mother? Yes. And you are their only child? I'm their son, yes. You don't have any brothers or sisters? No. 24 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 Q In Section 4.7, I want to direct your attention to the third sentence which reads -- A The third sentence of ~at section? Q Section 4.7 on page 6. A Sorry. Q Do you see where I am? A Yes. Q It begins with, This agreement and the non-compete provisions in particular shall be binding upon buyer, buyer's wife and children, and upon any and all business entities in which buyer has any ownership interest, so on and so forth through the end. Is it your testimony today that your father and mother could not bind you through this statement in Section 4.7 that I just read to you? A Can you elaborate on that? I don't really understand your question. THE COURT: You are asking him a legal question. BY MR. GRUBB: Q Is it your testimony today that you had no conversations at all with your father or mother about being bound to this agreement? A Can you -- I'm confused with what you're actually asking. I'm sorry. 25 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 Q You had no discussions with your father and mother about this agreement in general.? A No, I had no discussions with my father about this agreement, the terms of this agreement. Q So is it your testimony then that your father, identified as the buyer, could not bind you to this agreement? A Yes. Q And when he says buyer"s wife -- this agreement non-compete shall be binding upon buyer, buyer's wife and children, it's your testimo~f today that your father was overstepping his bounds in that respect? Is He should not have represented that he was that accurate? binding you? A Q Yes. The same holds true for the signature block which is on page 7, James P. Harris individually and for his wife, children, and associated business entities? A What section? I'm sorry. Q Page 7, the signature block at the bottom of the page on the right-hand side where you see your father's signature. Are you with me now? A Yes. Q It says James P. Harris individually and for his wife, children, and associated business entities. Your 26 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 testimony is that your father never spoke to you about binding you to this agreement? A My father mentioned when they were in negotiations that my grandfather was trying to bind me in a contract, and that I said I would never be a part of it, and that was it. So if you're asking directly did he ever ask anything, no, he did not. Q But you did have discussions with your father about being bound to this agreement? A He only mentioned that there was an agreement that they were negotiating and that my grandfather was trying to bind me by it. I said I did not want to be a part of it. Q And was that before the August 28, 2000, time period? A Yes. Q So you affirmatively conveyed to your father you did not want to be bound by this agreement? A I conveyed that I did not want my grandfather to bind me to this agreement. But you did not want to be bound to this Q agreement ? A Q Yes. And you did know about it, you did know about this agreement? 27 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 A No, I did not know about the agreement at all. Ail I knew was that my grandfather and my father were going through some type of an agreement or negotiations of a contract and that my grandfather wanted me included, and I said I did not want to be a part of it. Q When James P. Harris refers to his children here, you in fact testified earlier that you are the only child, correct? A That is correct, I'm the only child. Q So this reference to children here, to your knowledge, could refer to no other child of James P. Harris'? A Q That is correct. Your counsel asked one of your questions whether you -- one of the questions your counsel asked you is whether you considered yourself a third party beneficiary of the agreement. A Yes. Q Exhibit 1. What does it mean to you to be a third party beneficiary? THE COURT: Oh, gosh, I don't even know what a third party beneficiary is without going back and looking in the law books every time I am asked. That is just too complicated. MR. GRUBB: Judge, the only reason I asked 28 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 is he did affirmatively say he didn't consider -- THE COURT: It went over me like water going over a dam. It means nothing. MR. GRUBB: Okay, as long as I know that, Judge. BY MR. GRUBB: Q THE COURT: Don't worry about it. Your testimony earlier was you were never an employee of James P. Harris Associates, LLC, correct? A Yes. Q The extent of your working at James P. Harris Associates was just those summer breaks, Christmas breaks? A I never worked for James P. Harris. I worked for G.H. Harris Associates. Q Okay. Then the extent of your work for G.H. Harris Associates was just the summer breaks, the Christmas breaks, et cetera? A Yes. Q And that was before August of 2000? A Yes. Q Prior to August of 2000, James P. Harris Associates -- James P. Harris did not exist at that point? A What are you -- I'm confused with what you're asking. 29 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 Q Before August of 2000, there was no James P. Harris Associates? A Yes, that is correct. Q It used to be all G.H. Harris? A Yes. Q And they operated out of two offices, one in Dallas, one in Mechanicsburg, is that correct? A That is correct. Q And you operated out of the Mechanicsburg office? A No. The work that I did I worked in Cumberland County including the Cumberland Valley School District area which I grew up in. I worked in Franklin County. I worked in -- did work in Dauphin County in the City of Harrisburg, actually, which was run out of the G.H. Harris Associates' main office. The accounts that I worked that were out of the south office were out of my parents' office in their house was Adams County and Perry County. I also worked in York County, I'm sorry, which was out of the main office. Q When you say main office, you're referring to the Dallas office? A Yes, the Dallas office. Q The south office is the Mechanicsburg office? 3O 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 A Yes. Q Then is it fair to say that your work for G.H. Harris would have been a little bit of both? A Yes. Q Main office -- A Yes. It's been so long it may be 50/50. I mean, I can't really let you know. I don't know. Q Okay. How many summers did you work? A I believe it was three summers. Q And I think you also talked about Christmas break. How many Christmas breaks? A Christmas breaks, Thanksgiving breaks, and spring breaks if I was home I would do work. Q Do you remember how many breaks? A It was every one in between until I was probably a senior in college. Q You were in college four years? A Yes. My undergrad was four years. Q And then did you continue to work during the breaks during your graduate studies? A university. Q breaks? A No, I was a full-time employee at the So, no, I did not. So for four years you would work on your Yeah, I would work sum~ners and holidays or 31 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 whatever. Q You went to West Virginia University? Yes, West Virginia University. And your degree is in? Mechanical and aerospace engineering. Is that the type of work that you do at, I think it was, Carlton Technologies? A Yes. I'm a senior project engineer who designs propulsion systems for spacecraft applications. work? Q Is that a full-time job? That is a full-time job. How many hours a week would you say you A That would be a 40 hour a week job. Do you ever work over 40 hours a week? Occasionally if I'm on travel I would. Do you travel a lot? It really comes and goes. It's however the projects are going. So it's pretty infrequent. Q And that is an operation that is down near the BWI Airport? A Yes, it's adjacent to the BWI Airport. How long a commute is that? Excuse me? How long a commute is that? 32 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 A I drive 42 miles one way. It's anywhere between 45 minutes and 60 minutes to get there. Q Regular nine to five hours? A 7:30 to 4:00. Q 7:30 to 4:00. What time do you usually get home from work? I usually get home around 5:00, depending on A traffic. Q At West Virginia -- you had some graduate studies I understand? A Yes. Q And were they in the same field? A Mechanical and aerospace engineering, yes. Q In any of your education, did you have any experience in tax collection or anything of that nature? A In college, not directly. I mean, I took many different classes that would be in communications, different types of philosophy, psychology classes, basically the humanities which is all that you would probably need at the most to do this type of job. Q And you have not put in your notice or anything at Carlton Technologies or anything of that nature, a notice to quit that job? A No. Q Do you have any plans to quit that job? 33 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 A That's a very difficult question to answer at this time, so I don't have an answer to that. Right now do you have any plans to leave Q that j ob? A Q Right now, no. At this instance, no. I think you said that your wife runs the day-to-day operations at JTH? Yes. What types of day-to-day operations are A there? A data entry. Q present time? A Q Primarily just answering the phone and doing That's about it. Do you have anyone working for JTH at the Just my wife and I. Is there anyone -- do you have any deputy tax collectors who are out knocking on doors? A We have two part-time deputy tax collectors that are contractors. Q And they are? A Chris Freitas and William Nieves. Q They also work for your father? A That I don't know. To add to that, from what I've read or what has been petitioned, I can answer yes. But before that, I would say I don't know. 34 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 Q Do you know if they are the only two that your father employs? A That I don't know. Q They are the only two deputy tax collectors you use, that JTH uses? A Yes. Q In terms of starting up your business, the JTH business, did you have any help from your father or mother in starting up that business? A That's a pretty genera[[ question, but, no. Q None at all? A No. Q You didn't have any help in designing any of your forms or anything of that nature? A No. Q You did that all yourself? Honor? A Yes. MR. GRUBB: this? May I approach the witness, Your (Whereupon, Respondent's Exhibit No. 1 was marked for identification.) MR. GRUBB: Judge, would you like a copy of THE COURT: Yes. 35 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 BY MR. GRUBB: Q Respondent's Exhibit 1. MR. GRUBB: I've handed you what we've marked The redacted part, Your Honor, is just that is the name of the delin(~ent, if you will. In the interest of privacy we've redacted that. THE COURT: Sure. BY MR. GRUBB: Q A Q A Q Do you recognize that document? Is that addressed to me? Yes, sir. Yes. And that is a document JTH Tax Services, LLC. It appears to be an F-1 in the upper left-hand corner? A Yes. Q In the lower left-hand corner of that document there is in capital letters JTH and then a slash Kh. Do you know what that is? A No, I do not. Q Do you know if they are the initials for anything or anyone? A No, I do not. Did you prepare this document? My wife and I did, yes. 36 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 Q Did you have any help from Kathy Harris? A No, I did not. MR. GRUBB: If you could mark this Respondent's Exhibit 2. (Whereupon, Respondent's Exhibit No. 2 was marked for identification.) BY MR. GRUBB: Q I'm handing you what we've marked Respondent's Exhibit 2, Mr. Harris. MR. GRUBB: That again with the redactions, Your Honor, in the interest of privacy. Do you recognize that document? No, I do not. You've never seen this before? No, I have not. In the lower left-hand corner, that says JPH/Kh. Do you know what that stands for? A No, I do not. Q Take a minute to look at those, Mr. Harris, and then the question I want to leave to you, and I do not want you to answer this until you've looked at them, but is this not word for word the exact same document? THE COURT: Is that what you are representing it to be? BY MR. GRUBB: Q A Q A Q 37 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 BY FiR. GRUBB: Q the address? A Q FLR. GRUBB: THE COURT: Yes, as Respondent's Exhibit 1. Do you take his word for it? Other than the J.P. Harris Associates and Yes. And you're saying when you and your wife designed Respondent's Exhibit 1 you did so without any reference or assistance or even looking at Respondent's Exhibit 2? A What we did is we actually called the printer, Capital Business Forms, and instructed the gentleman that we were starting a company. And he sent us a form which then we put our name and basically designed the form so that it would work for our company and then faxed it back to him, and then he did the printing of the forms. Q Even the accreditations in the lower left-hand corner, the JTH/Kh, JPH/Kh, that had to have been changed, correct? A No. Q You didn't change that? A I'm confused with what you're -- Q Well, you're saying -- are you saying Respondent's 2 is a form faxed to you by the guy at the 38 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 print shop? A Yes. Form 2 was faxed to us, and then we basically set everything up so that it would be to our company and then faxed it back to him.. Q And you changed -- did you change the JPH in the lower left-hand corner to JTH? Yes. And you have no idea what that Kh stands A for? A Q Exhibit 2? A Forms. Q A Q A not. Q A Q No, I do not. Who was the guy who faxed you Respondent's Ed Cervance (phonetic) from Capital Business Ed Hermance? No, it's Cervance. Could you spell that? My wife would know how to spell that, I do It's Ed Caravan (phonetic), isn't it? That may be correct. Mr. Hermance works at the Cumberland Valley School District? A I did not say Hermance.. Q You represented that Petitioners' Exhibit 5, 39 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 and take a look at that in front of you, was your letterhead. A Q different letterhead previously? A No. Q You didn't? A No. MR. GRUBB: Yes. That wasn't always the case, was it, you had Mark this Respondent's Exhibit (Whereupon, Respondent's Exhibit No. 3 was marked for identification.) BY MR. GRUBB: Q That says -- I'll give you a minute to look at that. Do you recognize that document? MR. GRUBB: I'm sorry, Judge, I didn't give you a copy. BY MR. GRUBB: Q My question to you was whether or not you recognized that document? A I don't believe so. Q Isn't this a document that you sent out with various business proposals to some of the school districts who were solicited? A No, it was not. 4O 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 anyone? Q A designed this? You never believed that you sent this out to No. Do you have any idea ~lat this document is? I believe -- unfortunately, no. Do you know whether your wife might have A Yeah, this would be something better answered by her, not me. Q But as far as you know~, you don't know whether this ever went out? A That I do not know. Q Did you ever send out any other letters on this letterhead, Mr. Harris? And I'm referring to Respondent's Exhibit 3. A Not that I know of, no.. Q Is it your testimony that you've used Petitioners' Exhibit 5 from the start of your business and no other letterhead? A Yes. Once again, that would actually be better answered by my wife who's actually usually sending the reports out. Q I think in your testimony you referenced, Mr. Harris, that you had given business presentations? A Yes. 41 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 Q had you given? A Q And about how many business presentations Probably a half dozen, six maybe. How did you go about getting a contact who would call you and ask for a business presentation? A Actually I did the calling and I contacted -- the first person I contacted was Charlotte McGowan who was having a tax collectors' meeting, a Franklin County tax collectors' meeting, which was more of a social gathering, and my wife and I were invited to that and sat down and gave a brief five or ten minute overview of our company. At that time our company was not even formed. We were basically giving a presentation trying to see if we would be able to get some work, and if we would, then we would proceed with actually filing for the company. Q Was your father there? A Excuse me? Q Was your father there? A He was at the tax collectors' meeting, yes. Q Did he introduce you at that meeting? A No, he did not. Q He has accompanied you to at least that business presentation? A Yes. 42 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 attended? Q What other business presentations have you A dozen business presentations. were the other ones? Excuse me? You said you attended about six, a half You talked about one. What A I went to -- every job that we -- well, not every job. The tax collectors' meeting was one, and from that meeting we got two jobs out of it and was given a contact for the Tuscarora School District to give Mr. Richard Lopella a call because of some poor service that we heard about. So that then I called Richard Lopella and met with him and also met with Mr. Hermance. Q Hermance? A Ed Hermance of Cumberland Valley School District. Q So the Franklin County Tax Collectors Association we have Mr. Hermance. Did your father accompany you to that meeting with Mr. Hermance? A Excuse me? Q You said you never -- did you meet with Mr. A Yes. I thought you said Franklin County. Tax Collectors Association. At the Franklin County Tax Collectors Hermance? 43 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 Association I did not meet with Ed Hermance, no. Q I'm saying you did attend that and you attended that with your father? A Yes. Q And now Mr. Hermance. Did you attend that meeting with your father? A Did I -- I'm -- MR. ZONARICH: Your Honor, I'm going to object to this line of questioning. I think we're straying from this petition on the stay as to whether it applies -- the arbitration applies to these clients. THE COURT: What is the relevancy? What is the relevancy of this line of questioning? MR. GRUBB: Judge, as explained to you earlier, we believe that JPH is acting through JTH. He's accompanying him, and I think accompanying him to these meetings is very relevant to this inquiry. THE COURT: Wait a minute. The underlying arbitration is an effort by whom to try to enforce the non-compete agreement? MR. GRUBB: THE COURT: G.H. Harris, my client. And the non-compete agreement is signed by James P. Harris and reportedly includes his children? MR. GRUBB: Correct. 44 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 THE COURT: So even though he is a party to the contract, the agreement, J.P. during the course of this negotiation and finalization of this agreement purported to bind him, right? MR. GRUBB: THE COURT: James P. did. James P. did. Why is that not arbitrable? The issue of whether or not this witness is bound goes to whether or not there was authority to bind him which there is purported authority set forth in the agreement that his father bound him. Why doesn't that go to arbitration? What am I doing trying to decide independently whether or not he is bound or not? I am asking the petitioner. MS. MAKOSKY: I'm sorry, I thought you were asking him. THE COURT: I am asking you. You are the one that is trying to keep -- MS. MAKOSKY: I'm sorry. THE COURT: I am asking you. You are the one that is trying to keep him out of arbitration. MS. MAKOSKY: Because, Your Honor, by contract law he has not signed it, and it's very clear that you must be a signatory to a contract in order to be bound to arbitration. THE COURT: If that is the case, that is 45 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 strictly a legal issue, and all this business is really not relevant, is it? MR. GRUBB: Judge, we are trying to apply the non-compete. In other words, we're trying to apply this contract to Mr. Harris and to the JTH defendants. THE COURT: purported the binding. MR. GRUBB: Sure, because his father Correct. But also the secondary argument we have is that not only did his father purport to bind him, but also we believe that the JTH Corporation, which is where we're going with things like -- with this line of questioning, the JTH Corporation we believe is nothing more than a front for the JPH Corporation. THE COURT: Now, that having been said, why isn't that all subject to arbitration since he is purported to be bound in the agreement? First of all, I want to ask you, you are telling me the answer to that is because either he is a party to the contract or he isn't and if he isn't -- and he isn't a party to the contract except if you argue that he is bound by it under this apparent authority, and you are saying that that isn't good enough to get this client into arbitration. MS. MAKOSKY: Your Honor. THE COURT: No, we don't believe it is, Let me hear from the back, from 46 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 the intervener on that issue. MR. ZONARICH: Your Honor, if there is a violation of this agreement by the signatories, the buyers, which were JPH and J.P. Harris Associates -- THE COURT: That is what your client, the grandfather, is saying? MR. ZONARICH: That's correct. MR. GRUBB: His client is the father. I'm sorry. I think we need to be real clear about that. Your client is the father. MR. ZONARICH: My client is the father. THE COURT: It is tough for me to keep these Harrises separated. MR. GRUBB: That's why I interrupted. I apologize. THE COURT: Go ahead. MR. ZONARICH: This gentleman and his client have all the remedies of -- civil remedies and injunctive relief in arbitration against my client that they need and that's -- these issues that he's bringing up here go to -- think so. THE COURT: MR. ZONARICH: I don't know that. He doesn't But, Judge, for him to be able to bind JTH Harris to succumb to a very expensive arbitration that he was not a contract to and to withhold 47 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 his rights to a civil proceeding in the Court of Common Pleas of Cumberland County, or wherew~r, I feel that it's a broad extension -- it's a violation of his rights. He is not a party to that contract, and all his remedies rely in the arbitration against my client JPH,. J.P. Harris Associates. THE COURT: My problem here is going back to the initial objection is how -- all this stuff I don't see how it is relevant on that issue of whether or not this man is subject to being brought into this arbitration. MR. GRUBB: Let me explain it to you this way, Judge. We are trying to enforce a non-compete. One of the parties we're trying to enforce that against is JTH. We believe that is because JPH has set up marketed support at JTH. THE COURT: MR. GRUBB: I understand that. Now, we're trying to enforce this provision in this agreement. In doing that, if we're going to enforce this agreement, or attempt to enforce this agreement against JTH, do we not need to be bound by everything within this agreement including the arbitration clause? If we were just to have gone and sued JTH -- THE COURT: I understand your position a hundred percent. I am just saying ali. this business -- how does this collateral testimony help me on the issue of 48 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 whether or not under this agreement he is subject to arbitration? It seems to me the original statement made by petitioners' counsel is true, whether this man is subject to arbitration, and this man means his wife and his company, be strictly decided under the terms of this agreement. It is in there. Either he is or he isn't. At least argumentatively, without getting to the merits of that yet, you are saying he is because he is purported to be bound by it whether he is a signatory or not, and you are telling me without him being a party to it, a signatory to it, he isn't. Is there anything more that is relevant testimony wise now that I am into this on that issue? MR. GRUBB: we're asking is relevant. Judge, here's why we think what We think the two companies are so intimately related there is no difference between the two companies. THE COURT: But it doesn't make any difference, does it, if in fact he's either subject to arbitration or he isn't under the terms of the non-compete agreement? The arbitration clause covers whether he is or not. I sustain the objection. MR. GRUBB: Okay. THE COURT: To this line of questioning that 49 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 you are on. MR. GRUBB: THE COURT: MR. GRUBB: Okay. Anything else? Judge, if ~[ could ask for clarification on that. Are you saying that the arbitrability or the arbitration clause should be decided by the arbitrators? THE COURT: I am saying that is the issue. The issue, as I see it, now that I am into it and have learned all of these parties' involvement is does this -- does this agreement, that arbitration clause in this agreement in which his father purported to bind him, get him into the arbitration or not get him into the arbitration? That is the issue as I see it. MR. GRUBB: THE COURT: Correct. I do not see it at the moment as being anymore complicated than me interpreting this agreement. We will discuss the merits of that in a moment, but that is what I see the issue as. MR. GRUBB: But, Judge,. if I would have sued JTH in a civil action in equity in Cumberland County, okay, that would have been my alternative had I not initiated an arbitration, the argument then would have been by JTH, well, you're trying to bind me to this agreement then you should be suing me in arbitration. 50 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 THE COURT: That is the life of litigation. I understand your position. What I am simply doing now is sustaining the objection to any further line of this questioning, and I am not discussing the merits of the arbitration clause at the moment. I am just saying that this is not relevant to what I have to decide which is who's in and who's out based on this arbitration clause. MR. GRUBB: So the Judge would not want to hear testimony about the link between the JTH and JPH? THE COURT: that offer, that's right. ~R. GRUBB: I sustained the objection to Judge, just so I don't incur your wrath, you would want questions specifically pertaining to the arbitration clause and his knowledge or involvement in the -- THE COURT: I don't want anything. All I am saying is what you can't do, and what you can't do is the line of questioning that you were working on trying to show a relationship between his company and the prior entities because I do not see the relevancy as to whether or not he is in or out of this arbitration under this clause. MR. GRUBB: That's all I have then, Your Honor. offer of proof though. THE COURT: For purposes of the record, I would like to make an Go ahead. 51 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 MR. GRUBB: As to what questioning I would have liked to have asked Mr. Harris. THE COURT: You are trying to link him -- go ahead. doing. I will let you make the offer.. I know what you are MR. GRUBB: Right, you do, and I just want to put that on the record. THE COURT: MR. GRUBB: Make your offer. Our offer of proof would be to show that Mr. Harris was working -- would be to ask questions because we believe there is a link between JPH defendants as well as the JTH defendants. The questions along those lines such as any assistance that the father might have provided to the son or the daughter-in-law would have been asked, including attendance at meetings, any marketing efforts, any forms as we saw earlier, also the shared deputy tax collectors, Mr. Freitas and Mr. Nieves. We believe that they are the only two deputy tax collectors used by both companies, again showing the link. Also to ask questions about the cover sheet that we had sent up to Mr. Harris as Respondent's Exhibit 3, which is the cover page, to ask him questions about that document as well, basically how he can represent that he knows these townships and boroughs, how he can make the 52 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 statement that JTH knows your people as stated on Respondent's Exhibit 3. All again, Your Honor, in an effort to link the two -- to show the relationship -- to show the relationship in an effort to establish that they are bound by every portion of this agreement, including the non-compete and the arbitration clause. THE COURT: still outstanding? MR. ZONARICH: THE COURT: MS. MAKOSKY: THE COURT: water on down with you. THE WITNESS: THE COURT: petitioner? MS. MAKOSKY: THE COURT: I understand. Is the objection Yes, it is, Your Honor. Sustained. Any redirect? Not at this time, Your Honor. I did get you out. Take your limited. P. Harris. Thank you. Any further testimony, No, Your Honor. Now, I haw~ got you greatly Any testimony, respondent? MR. GRUBB: Yes. I would like to call James Your Honor, I would also ask MR. ZONARICH: for an offer, please. THE COURT: MR. GRUBB: What are you going to show? I'm going to ask him about the 53 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 arbitration clause, Judge, and Section 4.7, who he was binding. THE COURT: Well, to the extent that -- I will let him testify. We will deal with relevancy or admissibility when you come up. Go ahead. Whereupon, JAMES P. HARRIS, having been duly sworn, testified as follows: DIRECT EXAMINATION BY MR. GRUBB: Q Good afternoon, Mr. Harris. Could you please state your name. A James P. Harris. Q And you are the James P. Harris of the James P. Harris Associates Tax Collection Agency -- A Yes. Q -- we've been speaking of? And you were a party to the contract which we have, I believe, up in front of you as Petitioners' Exhibit 17 MR. JAMES S. HARRIS: Your Honor, I took these. Should these exhibits stay up there? THE COURT: Yes. MR. JAMES S. HARRIS: I'm sorry. THE WITNESS: Yes, I was. BY FiR. GRUBB: 54 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 Q And you are involved in an arbitration at present with G.H. Harris Associates? A Yes. Q And you are involved on behalf of you and your wife as well as James P. Harris Associates, the LLC company? A Yes. Q And that is pursuant to Section 4.6 of the Dispute Resolution and Mandatory Arbitration? A Yes, it is. Q And within this document you made representations that you were binding your children, correct? A I signed it only with the understanding from my attorney that if my children -- my one child did not sign it that I could not bind him. My attorney furthermore instructed me that there was some lengthy discussions about this issue with G.H. Harris Associates' attorney at the time, and that he had informed Mr. Harris, Mr. G.H. Harris, that just because the word children is in there and I signed it that I was not binding my child. It was not binding upon him. So it was my understanding that both parties agreed just because of that language the word child wanted -- G.H. Harris wanted that left in there that even 55 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 though I signed it that I was not binded -- I was not binding my child. Q James S. Harris is your only child? A Yes, he is. Q And after that conversation with your attorney, you did not take the language out of the document? A of the document. He wanted it to stay even though he understood that if I signed it my child was still not bound. Q But you did sign a document referring to page 7 James P. Harris, individually and for his wife, children, and associated business entities? A Well, I just explained I signed it because I understood that it would not bind my child. Q When you signed this document, you are identified as the buyer? A That's correct. Q And when you signed this document, you were committing you, yourself, James P. Harris, to all of the terms of this document, were you not? MR. ZONARICH: Your Honor, objection, asked and answered. Mr. G.H. Harris didn't take the language out THE COURT: He did. He signed it. It is 56 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 binding on you, right? THE WITNESS: BY MR. GRUBB: Q That' s correct, Your Honor. Sir, then it's your testimony, Mr. Harris, that this document as it stands, Respondent's Exhibit 1, where it refers to your children is inaccurate? That's correct, especially since I just have A one child. Q So that could only mean one thing when you refer children in there, right? A Right, that I signed it knowing that he was not bound. MR. GRUBB: Judge, I don't have anything further on the arbitration clause. I would like to renew the offer of proof I made before. I would ask this witness questions about his relationship with JTH, the same reason as with the offer that we had stated pertaining to James S. Harris. I presume that you would have sustained that objection so I would like to convey that. THE COURT: You are making the offer. Any Yes, Your Honor. Sustained. objection? MR. ZONARICH: THE COURT: Judge? MR. GRUBB: May I make the offer of proof, 57 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 same? again. THE COURT: The offer is essentially the MR. GRUBB: THE COURT: Is essentially the same. You do not have to formalize it MR. GRUBB: Right. Judge, I have questions for other witnesses that I would have intended to call today pertaining to the relationship between JPH and JTH. I would like to call those witnesses. THE COURT: Well, you need not call those witnesses because I will not allow any questioning on the similar lines with whether it is this father or any other witnesses. So you need not call them individually. MR. GRUBB: Okay. THE COURT: Any further questions of this witness? MR. GRUBB: THE COURT: Now, any cross? MS. MAKOSKY: THE COURT: None of this witness. Let's get this wrapped up first. None, Your Honor. Intervener? MR. ZONARICH: No, Your Honor. THE COURT: Now, you may step down. Why don't you identify the other witnesses and what their positions are. 58 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 Harris. MR. GRUBB: I would intend to call Terri She is of JTH Tax Services. THE COURT: MR. GRUBB: THE COURT: MR. GRUBB: THE COURT: Okay. Would you like me to identify -- Same general offer? Same general offer. Identify every one of the people that you want to call so your record is complete. the wife of the son? MR. GRUBB: yes. this. THE COURT: Terri is Terri is the wife of James S., I am getting pretty good at MR. GRUBB: Judge, we also had subpoenaed the two deputy tax collectors, Christopher Freitas, F-r-e-i-t-a-s, as well as William, I qon't know if I'm saying this right, but Nieves, N-i-e-v-e-s, I believe. They are out here? One, two. And I also intended to call THE COURT: We got them. MR. GRUBB: Kathy Harris, the wife of James P. Harris -- Okay. -- who is the father. And the offer is the same? Same offer.. THE COURT: MR. GRUBB: THE COURT: MR. GRUBB: 59 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 THE COURT: Same objection? MR. ZONARICH: Yes, Your Honor. THE COURT: The objection is sustained. are protected on the record. MR. GRUBB: Thank you. THE COURT: Any testimony, intervener? MR. ZONARICH: No, Your Honor, I have no testimony. You THE COURT: Any rebuttal., petitioner? MS. MAKOSKY: No rebuttal, Your Honor, other than we would like to -- we would join in the objection. THE COURT: Now, do both petitioner and respondent move for the admission of their exhibits that have been marked and testified to so far? MS. MAKOSKY: We move for their admission, Respondent also? We do. Any objections? THE COURT: MR. GRUBB: THE COURT: No, Your Honor. No. Excuse me? I was just going to say no MR. ZONARICH: MR. GRUBB: THE COURT: MR. GRUBB: please. objection from us to the petitioners' THE COURT: Ail exhibits already marked 6O 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 petitioner and respondent are admitted[. The record is closed. Argument, moving party, off the record. (Whereupon, argument was held off the record.) THE COURT: end of the week. counsel. I will have this decided by the I understand it. Well presented, Thank you very much. (Whereupon, the hearing was concluded at 12:28 p.m.) 61 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 CERTIFICATION I hereby certify that the proceedings are contained fully and accurately in the notes taken by me on the above cause and that this is a correct transcript of same. Pamela R. Sh~af~er Official Court Reporte~_~_~ The foregoing record of the proceedings on the hearing of the within matter is hereby approved and directed to be filed. Edgar B. ]~a~.l'~ J. Ninth Judicial ~istrict 62 JTH TAX SERVICES, LLC, JAMES S. HARRIS AND TERRI HARRIS, HUSBAND AND WIFE, APPLICANTS IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA G.H. HARRIS ASSOCIATES, INC., RESPONDENT JAMES P. HARRIS AND KATHY HARRIS, HUSBAND AND WIFE, AND J.P. HARRIS ASSOCIATES, LLC, I NTERVENERS 02-5469 CIVIL TERM IN RE: PETITION TO STAY ARBITRATION BEFORE BAYLEY, J. AND NOW, this ORDER OF COURT ~ day of January, 2003, the application of JTH Tax Services, LLC, James S. Harris and Terri Harris to stay an arbitration filed by G.H. Harris Associates, Inc., with the American Arbitration Association, IS GRANTED. THE ARBITRATION IS STAYED AGAINST JTH TAX SERVICES, LLC, JAMES S. HARRIS AND TERRI HARRIS. __~Edgar B. Bay~.y~ J. / 02-5469 CIVIL TERM Alexandra Makosky, Esquire For Applicants Steven E. Grubb, Esquire For Respondent John R. Zonarich, Esquire For Interveners :sal JTH TAX SERVICES, LLC, JAMES S. HARRIS AND TERRI HARRIS, HUSBAND AND WIFE, APPLICANTS IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA G.H. HARRIS ASSOCIATES, INC., RESPONDENT JAMES P. HARRIS AND KATHY HARRIS, HUSBAND AND WIFE, AND J.P. HARRIS ASSOCIATES, LLC, I NTERVENERS 02-5469 CIVIL TERM IN RE: PETITION TO STAY ARBITRATION BEFORE BAYLEY, J. OPINION AND ORDER OF COURT Bayley, J., January 8, 2003:-- Pursuant to an opinion in support of an interim order dated December 13, 2002, a hearing was conducted on January 3, 2003, for the purpose of determining whether JTH Tax Services, LLC is an alter ego/associated business activity of James P. Harris. The prior opinion is incorporated herein. We find that: (1) James P. Harris, individually and through J.P. Harris Associates, LLC, provided James S. Harris and Terri Harris with information (a) that helped them start JTH Tax Services, LLC, (b) how to market JTH Tax Services, LLC, and (c) where to solicit business. 02-5469 CIVIL TERM (2) JTH Tax Services, LLC, uses the same computer software and same forms provided by the same suppliers to J.P. Harris Associates, LLC. (3) JTH Tax Services, LLC employs two part-time deputy tax collectors who are full-time employees of J.P. Harris Associates, LLC. JTH Tax Services, LLC pays the two deputies for all of the work they do for that corporation. (4) James P. Harris has on many occasions, for the convenience of James S. Harris and Terri Harris, picked up mail for JTH Tax Services, LLC at a Mechanicsburg post office box used by the corporation to service a client, the Cumberland County School District. (5) James P. Harris assisted James S. Harris and Terri Harris in soliciting clients of G.H. Harris Associates, Inc., that James P. Harris and Kathy Harris operating as J.P. Harris Associates, LLC are prevented from servicing because of the restrictive covenant in the Market Region Purchase Agreement dated August 25, 2000. (6) James P. Harris has encouraged clients of G.H. Harris Associates, Inc., to hire JTH Tax Services, LLC. Four such clients have changed to JTH Tax Services, LLC. (7) JTH Tax Services, LLC has not solicited any business from clients of J.P. Harris Associates, LLC. (8) Neither James P. Harris nor Kathy Harris nor J.P. Harris Associates, LLC have any financial interest in or control over JTH Tax Services, LLC. (9) James S. Harris and Terri Harris have skills and the knowledge necessary to -2- 02-5469 CIVIL TERM operate JTH Tax Services, LLC. (10) JTH Tax Services, LLC is operated solely by its owners James S. Harris and Terri Harris. (11) Neither James P. Harris nor Kathy Harris nor J.P. Harris Associates, LLC have received any financial or other type of benefit from the operation of JTH Tax Services, LLC, by James S. Harris and Terri Harris. DISCUSSION We conclude that JTH Tax Services, LLC is not the alter ego or an asSociated business activity of James P. Harris. JTH Tax Services, LLC is solely owned and operated by James S. Harris and Terri Harris. Although James P. Harris has assisted his son and daughter-in-law in their business, and has encouraged clients of G.H. Harris Associates, Inc., to change to JTH Tax Services, LLC, that does not mean that JTH Tax Services, LLC is a front/subterfuge/facade of James P. Harris. There is no intermingling of finances between James P. Harris and J.P. Harris Associates, LLC with JTH Tax Services, LLC. The close relationship between James P. Harris and James S. Harris and Terri Harris does not translate into his operating, controlling, dominating, or having a financial interest of JTH Tax Services, LLC? Even though that close relationship has been detrimental to the business interest of G.H. Harris Associates, Inc., JTH Tax Services, LLC, a non-signatory to the Market Region Purchase See Thomson - CSF, S.A.v. American Arbitration Association, 64 F.3d 773 (1995). -3- 02-5469 CIVIL TERM Agreement, cannot be forced into arbitration on the application of G.H. Harris Associates, Inc. before the American Arbitration Association? For the reasons set forth herein and in the opinion in support of the interim order dated December 13, 2002, the following order is entered. ORDER OF COURT AND NOW, this ~ day of January, 2003, the application of JTH Tax Services, LLC, James S. Harris and Terri Harris to stay an arbitration filed by G.H. Harris Associates, Inc., with the American Arbitration Association, IS GRANTED. THE ARBITRATION IS STAYED AGAINST JTH TAX SERVICES, LLC, JAMES S. HARRIS AND TERRI HARRIS. Alexandra Makosky, Esquire For Applicants Steven E. Grubb, Esquire For Respondent John R. Zonarich, Esquire For Interveners :sal 2 This familial dispute shows that the old adage--blood is thicker than water--does not apply when money is at stake. JTH TAX SERVICES, LLC, JAMES S. HARRIS AND TERRI HARRIS, HUSBAND AND WIFE, Applicants Vo G.H. HARRIS ASSOCIATES, INC., Respondent Vo JAMES P. HARRIS AND KATHY HARRIS, HUSBAND : AND WIFE, AND J.P. HARRIS: ASSOCIATES, LLC, : Interveners : IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL ACTION - LAW NO. 02-5469' CIVIL TERM IN RE: TESTIMONY OF ~WARD F. CARABIN Proceedings held before the HONORABLE EDGAR B. BAYLEY, J., Cumberland County Courthouse, Carlisle, Pennsylvania, on January 3, 2003, in Courtroom Number Two. APPEARANCES: ALEXANDRA MAKOSKY, Esquire For the Applicants STEVEN E. GRUBB, Esquire For the Respondent JOHN R. ZONARICH, Esquire For James and Kathy Harris 1 2 3 4 5 6 7 8 9 10 i1 12 13 14 15 16 17 18 19 20 21 22 23 24 25 January 3, 2003 Carlisle., Pennsylvania (Whereupon, thefollowing~testimony was requested.) MS. MAKOSKY: Your Honor, I would like to call Ed Carabin to the stand, please. Whereupon, EDWARD F. CARABINj. having been duly sworn, testified as follows: DIRECT EXAMINATION BY MS. MAKOSKY: Q name for the record. A Yes, Edward F. Carabin. Q And where do you live? A I live at 6548 Devonshire Heights Road. Q Do you want a glass of water up there? A Yes, that would help. 6548 Devonshire Heights Road, Harrisburg. Q A New Cumberland. Q A Q Mr. Carabin, can you please state your full And where do you work? I'm employed with Capital Business Forms in What's your position there? I'm a salesman. And how long have you been at Capital 2 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 Business Forms? I've been employed there since January of A 1965. Q A Q 19657 1995. You're a loyal employee. As a salesman, what are some of your duties? A Well, normally I would take a prospect and turn him into a customer by soliciting their business and helping them design forms, print them up and deliver them to help them with their business. Q And have you helped JTH Tax Services in getting their forms drafted and ready for print? A Well, Terri called me, I believe it was, the last week in February of this year and stated that they were starting a company, and it was a delinquent tax service, and that she would like to ore, er some forms. So we talked, and she said that she was the daughter-in-law of Kathy and Jim Harris, and so I suggested that we start with their forms as a starting point. Is that something common that you do in your Yes. Obtain forms from other companies and then help out the starting business? Q business? A Q 3 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 A Yes, that's very common. Forms are specific by industry, but a lot of companies within each industry use very similar forms, almost identical. Q You don't have other customers sign an agreement that you have the right to slhare the forms without their knowledge? A I have never had that. Q And there is no copyriglht, to the best of your knowledge, on these forms? A No, not to my knowledge. Q And have you assisted James -- J.P. Harris Associates with their forms? A Yes, since 1995. Q Well, at that point in '95 they were G.H. Harris, correct? A They were G.H. Harris, that's correct. Q And then when J.P. Harris was formed you also assisted them with their forms? A Correct. Q Can you tell me now when Terri called you and asked you to assist her with getting these forms, what -- take me through the process of what you did. A Okay. Terri called and said she was interested in working with me to get some forms. And so I asked her, do you know exactly what you want? And she 4 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 said, well, no, but they would probably be similar to other delinquent tax collectors. So I suggested that J.P. Harris forms are available, perhaps we could use that as a starting point. So she sent me the information by a fax that she needed changed. Basically it was the name and address and phone number and fax number that she needed. Q And so you marked up the form? A Yes. I took her information, marked it up on the form, and we sent it in and had. it printed. Q You marked it up, you sent it back to her, and she then -- A I think I did. Q -- and then she approved it and got it off and printed it? A Right. The reason I say that is because they were all rush orders at first. So we didn't have a lot of -- we didn't have the luxury of time. Q And so there was at least one mistake on that form that Terri later discovered? A Yes, we found that out later. Q And that was the phone number? A Right. Q Who else orders the forlms -- is it just Terri that's ordering the forms for JTH? 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 A Right. Q Has James P. or Kathy Harris ever called you to order forms on behalf of JTH Tax Services? A Not for JTH, no. Q Who paid for the forms that Terri had ordered? A JTH pays for their own forms. Q Does Capital Business Forms treat JTH Tax Services and J.P. Harris Associates as two separate customers? A Q A Yes. And how do they do that? Well, we have a customer code in our computer, and each one is a separate account with a different account number and different, information. MS. MAKOSKY: No further questions. CROSS EXAMINATION' BY MR. GRUBB: Q Is it Mr. Carabin? A Yes. Q I apologize. Caravan all day long. A Q I've been calling you Mr. No problem. Mr. Carabin, do you have any other customers that are delinquent tax collectors? 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 A Not outside of J.P. Harris. Q And when Terri Harris contacted you, she identified herself as the daughter-in-law of James P. Harris, correct? A Yes. Q And you knew she was the daughter-in-law when you recommended that we use the J.P. Harris forms as a starting point? A I thought she probably was, so we used them as a starting point, yes. Q Now, if this had been anyone else, say, for example, I called you up and said I want to start a delinquent tax collection agency and I want to order some forms, would you have provided me James P. Harris Associates' forms? A Q A Perhaps. Perhaps. Why do you say perhaps? It all depends on the circumstances. Perhaps I would pick theirs. Perhaps I would pick another one. I could call a factory and ask them to send me some samples if we had time. You know, it depends on the circumstances. If you had a rush order, I couldn't do that. Q Is the reason you picked James P. Harris forms in this case because Terri Harris was James P. 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 Harris' daughter-in-law? A Perhaps. Q When Terri Harris contacted you, I think your testimony was she had no idea what to order? A That's correct. Q She couldn't name a single form that she wanted to order? A Well, that's true. She knew what she wanted, but she didn't know any of the details. Q When you send the initial form to JTH, does it have the James P. Harris Associates at the top still when you sent that to them? A Yes. Q You were in the courtroom, I believe, most of the day today, and you heard Kathy Harris testify, I believe? A Yes. Q And she said that their forms needed to match, I believe, the software program that they had? A Correct. Q Were you aware when you talked to Terri Harris that JTH also had that software program? A No. Q And in terms of giving the final okay to go ahead and print those forms, that was Terri Harris? 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 A Yes. I informed Terri that they were designed for a specific computer program, and I said you have to make sure they work on your system. If they didn't, you could make adjustments. Q You were there since 1!)95, and therefore I presume you would have also worked when this entity was known as G.H. Harris? Yes. And you did not think to send up G.H. Harris A forms to JTH? A I didn't have too many of them left. clean our files pretty regularly. MR. GRUBB: That's all. Carabin. BY MR. ZONARICH: THE COURT: Intervener. CROSS EXAMINATION Thank you, Mr. We Q Is it safe to say that anybody can get these forms, Mr. Carabin? A Yes, in that industry. Q From you or anybody else? A Yes. Frequently the factories that we have them printed will send them out to other people for samples. MR. ZONARICH: Nothing else. 9 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 excused. Next. THE COURT: Anything further? MS. MAKOSKY: Nothing. THE COURT: Sir, you may step down. (Whereupon, the requested testimony was concluded.) You are 10 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 2O 21 22 23 24 25 CERTIFICATION I hereby certify that the proceedings are contained fully and accurately in the notes taken by me on the above cause and that this is a correct transcript of same. Off'icj. al Court Reporter ~ The forego±ng record of the proceed±rigs on the hearing of the within matter is hereby approved and directed to be filed. 11