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Home My WebLink About03-0635STEVEN R. ROBINSON, Plaintiff IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA JACKSON BOYD, also known as JEB BOYD, LISA BOYD, and J & L AUTOWORKS, Defendants DOCKET NO. 0,3 : CIVIL ACTION - LAW PRAECIPE TO ISSUE WRIT OF SUMMONS TO THE PROTHONOTARY: Please issue a Writ of Summons against the above- referenced Defendants. The Defendants may be served at the following addresses: Jackson Boyd, a/k/a Jeb Boyd and Lisa Boyd 1335 Lutztown Road Mechanicsburg, PA 17055 J & L Autoworks 1335 Lutztown Road Mechanicsburg, PA 17055 Respectfully submitted, FENSTERMACHER AND ASSOCIATES, P.C. Jol~ I~. Fenstermacher S?.preme Court I.D. #29940 ~ 15 East Trindle Road Mechanicsburg, PA 17050 (717) 691-5400 Attorney for Plaintiff Commonwealth of Pennsylvania County of Cumberland WRIT OF SUMMONS STEVEN R. ROBINSON Plaintiff Vs. JACKSON BOYD, ALSO KNOWN AS JEB BOYD, LISA BOYD, AND J & L AUTOWORKS 1335 LUTZTOWN ROAD MECHANICSBURG, PA 17055 Defendant Court of Common Pleas No. 03-635 CIVIL TERM In CivilAction-Law To JACKSON BOYD, ALSO KNOWN AS JEB BOYD, LISA BOYD, AND J & L AUTOWORKS You are hereby notified that STEVEN R. ROBINSON, the Plaintiff has / have commenced an action in Civil Action-Law against you which you are required to defend or a default judgment may be entered against you. (SEAL) Date FEBRUARY 11, 2003 Attorney: CURTIS R. LONG Prothonotary Name: JOHN R. FENSTERMACHER, ESQUIRE Address: FENSTERMACHER AND ASSOCIATES, P.C. 5115 EAST TRINDLE ROAD MECHANICSBURG, PA 17050 Attorney for: Plaintiff Telephone: 717-691-5400 Supreme Court ID No. 29940 SHERIFF'S RETURN - REGULAR CASE NO: 2003-00635 P COMMONWEALTH OF PENNSYLVANIA: COUNTY OF CUMBERLAND ROBINSON STEVEN R VS BOYD JACKSON ET AL RONALD HOOVER , Sheriff or Deputy Sheriff of Cumberland County, Pennsylvania, who being duly sworn according to law, says, the within WRIT OF SUMMONS was served upon BOYD JACKSON AKA JEB BOYD the DEFENDANT at 1335 LUTZTOWN ROAD , at 0954:00 HOURS, on the 19th day of February , 2003 MECHANICSBURG, PA 17055 RICK SCMITT, EMPLOYEE a true and attested copy of WRIT OF SUMMONS by handing to ADULT IN CHARGE together with and at the same time directing His attention to the contents thereof. Sheriff's Costs: Docketing 18.00 Service 4.83 Affidavit .00 Surcharge 10.00 .00 32 .83 Sworn and Subscribed to before me this '/~ day of ~~ ~2~ ~ A.D. ! /~Pro~t[h~no~-r~~ · So Answers: R. Thomas Kline 02/20/2003 FENSTERMACHER & ASSOCIATES By: / ~, Deputy Sheriff SHERIFF'S RETURN - REGULAR CASE NO: 2003-00635 P COMMONWEALTH OF PENNSYLVANIA: COUNTY OF CUMBERLAND ROBINSON STEVEN R VS BOYD JACKSON ET AL RONALD HOOVER , Sheriff or Deputy Sheriff of Cumberland County, Pennsylvania, who being duly sworn according to law, says, the within WRIT OF SUMMONS was served upon BOYD LISA the DEFENDANT at 1335 LUTZTOWN ROAD , at 0954:00 HOURS, on the 19th day of February , 2003 MECHANICSBURG, PA 17055 RICK SCMITT a true and attested copy of WRIT OF SUMMONS by handing to ADULT IN CHARGE together with and at the same time directing His attention to the contents thereof. Sheriff's Costs: Docketing 6.00 Service .00 Affidavit .00 Surcharge 10.00 .00 16.00 Sworn and Subscribed to before me this 7 day of A.D. Prothonotarl? / g So Answers: R. Thomas Kline 02/20/2003 FENSTERMACHER & ASSOCIATES By: Deputy Sheriff SHERIFF'S RETURN - REGULAR CASE NO: 2003-00635 P COMMONWEALTH OF PENNSYLVANIA: COUNTY OF CUMBERLAND ROBINSON STEVEN R VS BOYD JACKSON ET AL RONALD HOOVER , Sheriff or Deputy Sheriff of Cumberland County, Pennsylvania, who being duly sworn according to law, says, the within WRIT OF SUMMONS was served upon J & L AUTOWORKS the DEFENDANT at 1335 LUTZTOWN ROAD , at 0954:00 HOURS, on the 19th day of February , 2003 MECHANICSBURG, PA 17055 RICK SCMITT a true and attested copy of WRIT OF SUMMONS by handing to ADULT IN CHARGE together with and at the same time directing His attention to the contents thereof. Sheriff's Costs: Docketing 6.00 Service .00 Affidavit .00 Surcharge 10.00 .00 16.00 Sworn and Subscribed to before me this ~ ~ day of ~ ~rothoh6tar~'; So Answers: R. Thomas Kline 02/20/2003 FENSTERMACHER & ASSOCIATES Deputy Sheriff STEVEN R. ROBINSON, Plaintiff IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA DOCKET NO. 03-635 CIVIL TERM JACKSON BOYD, also known as JEB BOYD, LISA BOYD, and J & L AUTOWORKS, Defendants CIVIL ACTION - LAW NOTICE YOU HAVE BEEN SUED IN COURT. If you wish to defend against the claims set forth in the following pages, you must take action within twenty (20) days after this Complaint and Notice are served by entering a written appearance personally or by attomey and filing in writing with the Court your defenses or objections to the claims set forth against you. You are warned that if you fail to do so the case may proceed without you and a judgment may be entered against you by the Court without further notice for any money claimed in the Complaint or for any other claim or relief requested by Plaintiffs. You may lose money or property or other rights important to you. YOU SHOULD TAKE THIS PAPER TO YOUR LAWYER AT ONCE. IF YOU DO NOT HAVE A LAWYER OR CANNOT AFFORD ONE, GO TO OR TELEPHONE THE OFFICE SET FORTH BELOW TO FIND OUT WHERE YOU CAN GET LEGAL HELP. CUMBERLAND COUNTY BAR ASSOCIATION 2 LIBERTY AVENUE CARLISLE, PA 17013 (717) 249-3166 STEVEN R. ROBINSON, Plaintiff Vo JACKSON BOYD, also known as JEB BOYD, LISA BOYD, and J & L AUTOWORKS, Defendants IN THE COURT OF COMMON PLEAS 'OF CUMBERLAND COUNTY, PENNSYLVANIA DOCKET NO. 03-635 CIVIL TERM CIVIL ACTION - LAW COMPLAINT AND NOW, comes the Plaintiff, Steven Robinson, by and through his attorneys, the Offices of Fenstermacher and Associates, and files this Complaint as follows: 1. Plaintiff Steven Robinson ("Robinson")is an adult individual currently residing at 2303 Marseille Court, Valrico, Florida. 2. Defendant J & L Autoworks ("J&L") is a Pennsylvania Corporation with an address for conducting business at 1335 Lutztown Road, Mechanicsburg, Pennsylvania. 3. Defendant Jackson Boyd ("Jackson"), also known as Jeb Boyd, is owner of J&L and has an address for conducting business at 1335 Lutztown Road, Mechanicsburg, Pennsylvania. 4. Defendant Lisa Boyd ("Lisa") is owner of J&L and has an address for conducting business at 1335 Lutztown Road, Mechanicsburg, Pennsylvania. 5. J&L is a business that repairs and services automobiles and performs state inspections. J&L is owned and operated by Jackson and Lisa Boyd. 6. On June 1995 Robinson, who was attending the US Army War College at the time, approached Jackson at J&L to discuss the restoration and purchase of a 1971 P1800 Volvo that was located on J&L's property. 7. During the discussion Jackson claimed J&L specialized in restoring European automobiles such as the Volvo P1800. 8. During the discussion Jackson stated J&L could completely restore the Volvo and sell it to Robinson for between $6,000 and $8,000. 9. An oral contract was formed on June 20, 1995 when Robinson agreed to purchase and pay for restoring the Volvo. On this date Robinson paid Jackson $2000 for the purchase price of the Volvo and placed a down payment of $1000 to begin the restoration work. Copies of the receipts and checks are attached hereto as Exhibit "A". 10. Upon receipt of payments Jackson said he would bill Robinson for future parts and labor as the restoration progressed. 11. At this time Robinson was told the vehicle would be ready for pick up in June or July of 1996. 12. On February 29, 1996 Robinson received a letter from Lisa Boyd describing the restoration status and requesting another payment to continue the body work and parts purchasing (attached hereto as Exhibit "B"). 2 13. On March 5, 1996 Jackson complied with this request by paying J&L $3000 with his credit card (copy of credit card statement attached hereto as Exhibit "C"). 14. On June of 1996 Jackson visited J&L to see how the restoration was progressing. During this visit it became apparent that the car would not be finished by the estimated date of June or July of 1996. At time this Jackson requested an additional payment of $1500 to continue the restoration. Robinson wrote a check for this amount and Jackson promised the car would be finished during the winter of 1997 (copy of the check is attached hereto and included in Exhibit "A"). 15. On August 21, 1996 Robinson received an invoice from Lisa Boyd for $1333.92 that also requested an additional payment of $1500 for further repairs (attached hereto as Exhibit "D"). After speaking with Jackson about these figures Robinson sent a check for $1500 on September 8, 1996. 16. On June 13, 1997 Robinson forwarded Jackson another check for $1500 for further restoration work (attached hereto as Exhibit "E"). 17. On September 6, 1997 Robinson received a letter from Lisa Boyd requesting a payment of $3000 for body and other mechanical work (attached hereto as Exhibit "F"). Lisa claimed J&L was going to "wrap this job up over the winter." 18. On September 13, 1997 Robinson forwarded a $3000 check to Jackson. 19. Communication continued between Robinson and Jackson between September 1997 and March 1999. 3 20. On April 1999 Robinson purchased leather seat covers for the Volvo totaling $670.20 (copy of checking statement attached hereto as Exhibit "G"). Robinson had the covers sent to J&L. 21. The last correspondence between Robinson and J&L was in March of 2000 when Jackson updated Robinson on the current restoration status (attached hereto as Exhibit "H'). No final date of completion was given. To date Robinson has paid $12,670.20 towards restoration and ownership 22. of the Volvo. 23. To date Robinson does not possess or have title to the Volvo and the work has not been completed despite such work having been paid for. COUNT I Breach of Contract 24. Paragraphs 1 through 23 are incorporated herein by reference. 25. Robinson has fulfilled all the provisions of the agreement on his part to be performed. He has paid for the car in full and has paid every invoice sent to him in furtherance of the restoration. 26. Defendants have failed to perform pursuant to the contract. Defendants have not conveyed title to the Volvo and have not completed the restoration in a timely, proper, and workmanlike manner. 4 27. Defendants have wholly failed to restore the Volvo and convey legal title to Plaintiffs despite such being expressly agreed to by the parties. 28. Defendants have failed and refused to cure the aforesaid breach, despite Robinson's repeated demand. WHEREFORE, Plaintiff respectfully requests this Honorable Court enter Judgment for Plaintiff and against Defendants in an amount less than the compulsory arbitration limits, together with interest, costs and any other relief the Court deems fair and proper. COUNT II Negligence 29. Paragraphs 1 through 28 are incorporated herein by reference. 30. Defendants had a duty to Robinson to perform their services in a reasonable and workmanlike manner. 31. Defendants breached said duty by failing to restore the automobile and convey title despite Robinson's full compliance and payment for work and supplies. 32. Robinson has lost the benefit of his bargain and sustained damages by expending thousands of dollars in restoration work that has not been, and never will be, completed. 5 33. Had Robinson been aware that the automobile would never be restored he would not have paid $2000 for the purchase price or the over-S10,000 cost of never- ending restoration work. WHEREFORE, Plaintiff respectfully requests this Honorable Court enter Judgment for Plaintiff and against Defendants in an amount less than the compulsory arbitration limits, together with costs, interest and any other relief the Court deems fair and proper. COUNT III Fraud 34. Paragraphs 1 through 33 are incorporated herein by reference. 35. Defendants represented to Robinson that they would perform the services set forth in the contract, and further that they would perform such services in a reasonable, workmanlike, and timely manner. Defendants claimed to be able to restore the Volvo, which they did not. Furthermore, the Defendants falsely claimed the Volvo would be finished by June or July of 1996. 36. Defendants had actual knowledge of their inability to perform the restoration in a timely and workmanlike manner. 37. Defendants made these representations with the intent to defraud Robinson. Robinson was told J&L could restore the Volvo for the purpose of inducing Robinson to rely upon the representations and act in reliance thereon. 6 38. Robinson was unaware of the falsity of the representations and justifiably relied on the truth of such representations in entering into the contract with the Defendants. 39. Due to Robinson's reliance on Defendants' misrepresentations, he has suffered damages, as previously set forth herein. WHEREFORE, Plaintiffs respectfully request this Honorable Court enter Judgment for Plaintiffs and against Defendants in an amount less than the compulsory arbitration limits, plus costs, interest and any other relief the Court deems fair and proper. COUNT IV Unfair Trade Practices and Consumer Protection Law 73 P.S. § 201-1 et seq. 40. Paragraphs 1 through 39 are incorporated fully herein by reference. 41. Defendants' actions, as more fully set forth herein, constituted an unfair and/or deceptive act or practice in violation of 73 P.S. Section 201-1 et seq. 42. Defendants represented that their services have characteristics, uses or benefits that they did not have. Specifically, Defendants were not skilled in automobile restoration as evidenced by the substantial cost and excessive amount of time spent to date on the Volvo's restoration. 7 43. Defendants represented that their services were of acceptable standard, quality or grade when in fact they could not restore or deliver a restored 1971 Volvo within a seven year time span. 44. Defendants failed to comply with the terms of the agreement with Robinson in that they did not properly restore or deliver the Volvo within a reasonable amount of time. 45. Defendants engaged in fraudulent and deceptive conduct which created a likelihood of confusion or of misunderstanding by representing to Robinson that the Volvo could be properly restored when in fact it remains unfinished even after seven years and $12,670.20 in restoration costs. 46. Robinson has suffered actual damages as a result of the violation of the Pennsylvania Unfair Trade Practices and Consumer Protection Law by defendants. 47. Plaintiffs damages include the amount paid for restoration to date. Such restoration has not been completed. 48. 73 P.S. § 201-9.2 permits a trebling of damages and the recovery of attorney fees. WHEREFORE, Plaintiff respectfully requests this Honorable Court enter Judgment for Plaintiff and against Defendants in an amount less than the compulsory arbitration limits, together with costs, interest, attorneys fees, and any other relief the Court deems fair and proper. 8 COUNT V Intentional Misrepresentation 49. Paragraphs 1 through 48 are incorporated fully herein by reference. 50. Defendants represented to Robinson that they would fully repair and restore the automobile. 51. Such representations were material to the transaction as Robinson's desire was to have the car fully restored. 52. Defendants' representations were made falsely, with knowledge or a reckless disregard to their truth. The Defendants were aware that they could not fully restore and were not going to fully restore the automobile. 53. Defendants' misrepresentations were made with the intent of misleading Robinson into relying upon them. 54. Robinson was justified in relying on the misrepresentations because Defendants claimed their business was experienced in European automobile restoration work. 55. Robinson's damages were proximately caused by his reliance on Defendants' misrepresentations. Robinson expended thousands of dollars on the belief that Defendants could restore the Volvo. WHEREFORE, Plaintiffs respectfully request this Honorable Court enter Judgment for Plaintiffs and against Defendants in an amount less than the compulsory 9 arbitration limits, plus costs, interest and any other relief the Court deems fair and proper. DATED: Respectfully submitted, FENSTERMACHER AND ASSOCIATES, P.C. B,.,('Y"/ -3'o~n R. Fenstermacher \ Supreme Court I.D. #29940 .... 5115 East Trindle Road Mechanicsburg, PA 17050 (717) 691-5400 Attorney for Plaintiff 10 EXHIBIT 'A' LTC 2303 VALRICO TEL, (813) ORDER OF THE EXCHANGE P. o. BOX 189 - ~: ~O ~ ~OO ~ ~ LTC VALRICO TEL (813) PAY TO T ORDER TIlE EXCHANGE LTC 23O3 VALRiCO, TEL (813) PAY TO TH'E''' ORDER OF THE EXCHANGE P. o. BOX 189 - FOR ,: ~O ~ ~O0 ~ ~ 83-11/1011 OI, LARS 83-1111011 LARS 7376 83-1111011 OLLARS III Fl~B- PHI Lf~ ,..-~ -~-~-x--~-,~ M t XED 0.~ 1 O- 0004 05008i205 06-24-97 d~a~ ...... o3io ooo4- ....... -' .......... Q .....O~ - EXHIBIT 'B' J & L AUTOWORKS ~pecia~zing in Sales, Service and Parts for ~ritish 914otorcai~ Jeb and Lisa Boyd Stvvon 1L Robinson 23O3 Malsoillo Court Valrico, FL 33594 Dear Enclosed is aa invoib~ and pa~ li~kel~ fo~ work c~mp~ and paris ~ to dam on your 1971VolvoPlg00. Wchavo strippedtl~.~aadintetior ofthe carin prepar~ for paint and body work= We plan to remove thc engine and engine compartment peripherals prior to shipping thc car to thc body shop to insure a clean job in thc engine compamncnt. At thc present time, we hawe made tentative arrangements to deliver thc car to thc body shop wc have ~clccted on or about March 11. Also enclosed arc pictures of your cea' h~ progress; wc will conthmc to kccp a photographic record of this restoration for your As you can sec from thc enclosed invoices, we have dcplct~d your ~ $1000.00 deposit. At lids time, wv would ~ you to pay th~ balanc~ of thc invoices, $1280.48, and provide an addilkmal $1000.00 for ongoing operations. We will utilize the next $1000.00 to complete thc cng~c removal and purchase mst repair panels for the body repaY. Wc ~ probably need an additional dc~x~/t for the body shop in lat~ March; I will ¢oota~t you again when we need this next deposit. Singly, L/sa Boyd J & L Autoworks 1335 Lutztown Road Mechanicsburg PA 17055 N N EXHIBIT 'C' LIMIT '10~IN(; I)ATE CARD NUMBERI5~ ~6607 PRM 6000 NO YR REFERENC~ N~MBER' --- V I S A G O L D TRANSACTIONS FOR CARD NUMBER q3ZS_ 1505~..0~907 6q07 ..... ~-- E2~qSZ7006075219075780503~'~: IR5 Iq~ffE:~A~R[S~ATEANTA GA 6010 27~616~060790002Z571~088 5 20 3 19 CASH ADVANCE 100 00 N~NN-DIXIE TAM/$256 LITHI VALRICO FL 6011 AZ~275506085776~OSZ1008Z 5 26 ~ 2~ ALAHO RENT-A-CAR TAMPA FL ~$87 155 87 J24492156090799091701065 ~ 01 5 29 EARTHLINK NETNORK INC 19 95 PASADENA CA 5969 KZq610096100507080000006 4 10 ~ 08 TAMPA BAY BUSINESS 60 71 TAMPA FL 5994 ..................... PAYMENTS, ADJUSTMENTS AND OTHERS ................... ~-- 07q3270060997q5099Z~8~5 4 08 q 08 PAYMENT RECEIVED, THANK YOU $50100CR NITHOUT LEAVING HOME SEND FLONERS TO SOMEONE SPECIAL. JUST CALL THE FLONER CLUB AT 1-800-800-SEND Z~ HOURS A DAY, 7 DAYS A MEEK. A GREAT NAY TO SAVE MONEY ... MOVE BALANCES TO YOUR L0N RATE NACHOVIA CARD! ANY TIME YOU NEED FREE TRANSFER CHECKS CALL 1-800-2ql-7990. AVERAGE DAILY BALANCE q51~61 NUMBER OF DAYS IN BILLING CYCLE 29 ~'EMIZED FINANCE CHARGES~ ~'~FINANCE CASH PERIODIC ~---CHARGE ADVANCE -{- RA]E ~TOTAL OF ~ PREVI~S ~ CASH ITEMIZED FtNA~'E / ~LANCE ~ADVANCES HARGE J CHARGE CIIARGES) ~00 3~02 . 5~02 ~36~61 ~ C~ll ~N~IILYcoag~, 'm~ PERi.AGE [ ~. 0.68 o8.2~ ~ a 1~5~oo ~ PLEASE SEE REVERSE FOR IMPO~ANT INFORMA~ON PURCHASES AND OILIER CHARGES ~21~53 NEW =BALANCE MINIMUM PAYMENT EXHIBIT 'D' J & L AUTOWORKS Special~zing in Sales, Service and Parts for ~itish 9elotorcars Jeb and Usa Boyd 21, 1996 Stcvcn R. Robimon 2303 ~c Corn1 Valrico, FL 33594 Dear St~w~, Enclosed is an invoic~ for wozk and omsid~ mpa~ ~ to da~ on your 19'/1 Volvo PIS00. Wcc, mnplot~c ~of~o~~~ andl~carlmsbccn sandblasted to bare metal Thc first Sldlmaent of ~mir panels was rccciveat at thc body section of thc oar. Tho' ar~ now ~ on thc floor and roc]~ rcDairs which ar~ expected to bc complete in appro~ly on~ Tho body &op lm asked that wo se~ur~ a n,~w or good u~ ~ f~ ~ t~ ~hc ext~nsi~ mst along tho wold mares aswdl as a ihln ama on th~ top surfaco of~ ~. we wi~ be able to leave the shop OhO good u~l fend~ richer and $475.00 poorer. I am sufc you wal bc able to scc thc logic in rcplaccmc~ of tho fender wlum you review thc record of your car's ~orafion. Wc will acqu~ add,Jotul piclurcs of thc body work in progro~ when we deliver thc fender. As you can mc from the enclosed invoices, wc have d~-~ictcd your last dclm~L At this time, wc would like you to pay thc balance on 1~O. 3581, $1333.92, and provide an ~ $1500.00 for ongoing opo'ali~. Wc will utili~ this $1500.00 to pu~has~ thc LF ft~dor, pay for ongoing body r~s, and be~in unit r~p~r, i.e., s~Wwr, al~nator, and ropai~ andmak~ some plans for fl~int~orr~tion. Wcwillk~you postod. J & L Autoworks 1335 Lutztown Road Mechanicsburg PA 17055 717-258-5524 X J & L AUTOWORKS 1335 Lutztown Road · Mechanicsburg, PA 17055 DATE EXHIBIT 'E' THE ,: 1,0 ]. l, O0'~l, $ ii' LL EXHIBIT 'F' EXHIBIT 'G' 6( ~ommerclal Street P.O. Box 189 Atchison, KS 66002-0189 913-367-6000 2MEMBER FD~ LTC STEVENR ROBINSON KATHRYN ROBINSON 2303 MARSEILLE CT VA[RICO FL 33594-7248 o5/o4/~9 CYCLE-201 *** CHECKING ACCOUNT TRANGACTIONS *** DATE DESCRIPTION DEBITS '~*'AOTO'I'~:]H~'~itT'BO'RO PA 670.20/ 99999999 04-20-99 19~53 04/22 DEPOSIT 09/23 AAFES MAC DILL G MAC DILL A F~ 11.60f 99999999 04-23-99 05t09 04/23 AAPESMACOILLMAMACOILLAF FL 50.29," 99999999 04-23-99 00s22 04/26 PAYOFF LOAN98029288 1,164.59~. 09/26 FOREIGN ATM FEE 1.50-- 0000315A 04-24-99 13=11 04/26 ATM FEE 1.50~ 04-26-99 12=28 04/26 AT&T CL717-25 800-657-24 NJ 6.08~' 00 $0003 04-2%-99 02=34 0%/26 APP~T. AN TAMPA FL 60.3%~ 0( )00801 0%-24-99 01=48 04/26 MACDI] MACOITJ-AF FL 200.00~ 033 04-26-99 12t28 BRANDON FL 300 115A 04-24-99.13~11 04-29-99 12tll DILL G MAC DILL A FL .25/ 99999 04-29-99 06~18 AF F~ 19.34'W' )99999 200.00/ -o5/o3 05/03 05/03 0%-29-99 -RET I~ET 800-726-01 34.94,,W 999999 0%-30-99 PAYMENT 166.68-- PL-O00000000805: ATM FEE .50~ MAC DILL G FL / !99999999 0 ~z20 FCU AF FL 200.01 PL057061 12t06 100.00/ 2,781.67 o4/o; 04/0 06 o4/: 04/: BY 3,588. 04/07 5,528., 4,720. 04/13 3,437.8 2,89 )7 04/19 3, 66 900.66 04/23 3,'838.7~ 1. 67 %,350.72 05/04 3,937.17 04/08 5,326.98 04/14 3,390.07 04/20 4,551.54 04/26 2,104.76 Banking Partner EXHIBIT 'H' J&L Autoworks From: To: Sent: Subject: "J&L Autoworks" <j_lautoworks@pa.net> <Steve Robinson> Wednesday, March 01, 2000 9:20 AM Volvo Update Steve, I'm sorry I did not get back to you before · It's nuts around here. I'm trying to get my holdover projects out of the shop and on the road. I am diligently but slowly getting things sorted out. Do you have e-mail? I typed this on the computer so you could actually read it and get my e-mail address so you can rattle my cage on a regular basis without the long distance charges. If you bug me regularly, I will try and update you as we get closer to the road. I still am not having a lot of luck finding the right chrome parts, if I have to I'll try and find rechroming reasonably priced. I hope all is well and let's stay in touch. If you bug me constantly my shame and conscience will force me to keep plugging along at a better rate. You have been unbelieveably patient. Thanks, Jeb Boyd J&L Autoworks 1335 Lutztown Road Mechanicsburg,PA 17055 717-258 -5524 j_lautoworks@pa, net 3/1/00 VERIFICATION I, Steven Robinson, hereby certify and verify that the facts set forth in the foregoing Complaint are true and correct to the best of our knowledge, information and belief. I understand that any false statements herein are subject to the penalties of 18 Pa. C. S. §4904 relating to unsworn falsification to authorities. Steven Robinson DATE: CERTIFICATE OF SERVICE AND NOW, on this 14th day of March, 2003, I, John R. Fenstermacher, Esquire, hereby certify that I have served the foregoing Complaint by mailing a true and correct copy by United States first class mail and Certified Mail addressed as follows: JACKSON BOYD, also known as JEB BOYD J&L Autoworks 1335 Lutztown Road Mechanicsburg, PA 17055 LISA BOYD J&L Autoworks 1335 Lutztown Road Mechanicsburg, PA 17055 J&L AUTOWORKS 1335 Lutztown Road Mechanicsburg, PA 17055 FENSTERMACHER AND ASSOCIATES, P.C. By: / / ~f(~hn~R. Fenstermacher CERTIFICATE OF SERVICE AND NOW, on this 14th day of March, 2003, I, John R. Fenstermacher, Esquire, hereby certi~ that I have served the foregoing Complaint by mailing a true and correct coPY by United States first class mail and Certified Mail addressed as follows: JACKSON BOYD, also known as JEB BOYD J&L Autoworks 1335 Lutztown Road Mechanicsburg, PA 17055 LiSA BOYD J&L Autoworks 1335 Lutztown Road Mechanicsburg, PA 17055 J&L AUTOWORKS 1335 Lutztown Road Mechanicsburg, PA 17055 FENSTERMACHER AND ASSOCIATES, P.C. By:~ · Complete items 1, 2, and 3. Also complete Item 4 if Res~cted DelJYe~y is desired. · Print your name and address on the reverse so that we can return the card to you. · Attach this card to the back of the meilplece, ..___or on the front if space permits. 1. A~icle Addressed to: J&L AUtoworks .1335 Lutztown Road Mechanicsburg, PA 17055 i'-I Agent tern 17 r'iyes if YES, enter deflvery adcrress below: [] No ~[~-xpress M~iJ [] Registered ~J~Retum Receipt for Metchan(Jise i ,PS Form 3811, August 2001 ,tern 41~f:lestncted Defivery is d;s'~- to you. · Attach this card to the back of the mailpieca, or on the front if space permits. Lisa Boyd J&L Autoworks 1335 Lutztown Road Mechanicsburg, PA 17055 2. Azticle Number If YES, enter delivery address below: [--I NO 3. SerVice Type ~ertifled Marl ~ ~pr~s Mail ~ , ~ Insu~ M~I ~eturn R~ for ~ ~C.~D rr,~,~?e?~o,~e~ce/,~be~ 7001 1940 0006 8634 8360 Ps Form 3811, August 2001 Domestic Return Receipt · Complete items 1, 2, and 3. Also complete ~tem 4 if Restrfcted Delivery is desired. · Print your name and address on the reverse so that we can return the card to you. · Attach this card to the back of the maflplece, or on the front if space permits. 1. Article Addressed to: Jackson Boyd a/k/a Jeb Boyd J&L Autoworks .1335 Lutztown Road Mechanicsburg, PA 17055 2. Article Number ~ ~r~r=~ fro~ .~,,/ce ~be~) 7 0 0 1 PS Form 3811, August 2001 102595-01 -M.2509 ~ ~-I Addressee S Ice Type 1940 0006 8634 8377 IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL DIVISION PRAEClPE FOR WRIT OF EXECUTION Caption: Steven R. Robinson, Plaintiff vs. Jackson Boyd, also known as Jeb Boyd, Lisa Boyd, and J & L Autoworks, Defendants ( ) Confessed Judgment (x) Other File No. 03-635 Civil Term Amount Due $12,670.20 Interest 6~ amnually from date of Judgment Atty's Comm Costs $552.42 TO THE PROTHONOTARY OF THE SAID COURT: The undersigned hereby certifies that the below does not arise out of a retail installment sale, contract, or account based on a confession of judgment, but if it does, it is based on the appropriate original proceeding filed pursuant to Act 7 of 1966 as amended; and for real property pursuant to Act 6 of 1974 as amended. Issue writ of execution in the above matter to the Sheriff of Cumberland for debt, interest and costs, upon the following described property of the defendant(s) County, Ail personal property located at 1335 T.ut~tow-n Road, MechanJcsburg, PA 17055 PRAECIPE FOR ATTACHMENT EXECUTION Issue writ of attachment to the Sheriff of County, for debt, interest and costs, as above, directing attachment against the above-named garnishee(s) for the following property (if real estate, supply six copies of the description; supply four copies of lengthy personalty list) and all other property of the defendant(s) in the possession, custody or control of the said garnishee(s). Date (Indicate) Index this writ against the garnishee(s) as a lis pendens against~ real estate of the defendant(s) described in the attached exhibit. - '~-~(~L/ June 30. 2003 Signature: Print Name: termacher. Esquire k. Fedstermacher and Associates, P.C. Address: ~-._~15 East TrJnd'l~, Rn~.d Mechanicsburg, PA 17050 Attorney for: Plaintiff Telephone: (717) 691-5400 Supreme Court ID No.: (over) Notes: If real property, supply six copies of description including improvements and an original and copy of affidavit of ownership (PaR.C.R No. 3129). If lengthy personalty list, supply four copies of list, To index writ, file separate praecipe with writ. WRIT OF EXECUTION and/or ATTACHMENT COMMONWEALTH OF PENNSYLVANIA) NO 03-635 Civil COUNTY OF CUMBERLAND) CIVIL ACTION - LAW TO THE SHERIFF OF CUMBERLAND COUNTY: To satisfy the debt, interest and costs due Steven R. Robinson, Plaintiff (s) From Jackson Boyd, also known as Jeb Boyd, Lisa Boyd, and J & L Autoworks (1) You are directed to levy upon the property of the defendant (s)and to sell All personal property located at 1335 Lutztown Road, Meehanicsburg, PA 17055. (2) You are also directed to attach the property of the defendant(s) not levied upon in the possession of GARNISHEE(S) as follows: and to notify the garnishee(s) that: (a) an attachment has been issued; (b) the garnishee(s) is enjoined from paying any debt to or for the account of the defendant (s) and from delivering any property of the defendant (s) or otherwise disposing thereof; (3) If property of the defendant(s) not levied upon an subject to attachment is found in the possession of anyone other than a named garnishee, you are directed to notify him/her that he/she has been added as a garnishee and is enjoined as above stated. Amount DueS12,670.20 L.L.$.50 Interest 6% annually from date of judgment Atty's Comm % Atty Paid $146.83 Plaintiff Paid Date: July 2, 2003 (Seal) Due Prothy $1.00 Other Costs$552.42 CURTIS R. LONG Prothonotary Deputy REQUESTING PARTY: Name John R. Fenstermacher, Esq. Address: Fenstermacher and Associates 5115 East Trindle Rd., Mechanicsburg, PA 17050 Attorney for: Plaintiff Telephone: 717-691-5400 Supreme Court ID No. 29940 STEVEN R. ROBINSON, Plaintiff JACKSON BOYD, also known as JEB BOYD, LISA BOYD, and J & L AUTOWORKS, Defendants : IN THE COURT OF COMMON PLEAS OF : CUMBERLAND COUNTY, PENNSYLVANIA : DOCKET NO. 03-635 CIVIL TERM : CIVIL ACTION - LAW PRAECIPE TO SATISFY JUDGMENT TO THE PROTHONOTARY: Please mark the judgment entered in this action SATISFIED. DATED: Respectfully submitted, FENSTERMACHER AND ASSOCIATES, P.C. // J~t~n R Censtermacher ,,,.. Supreme Court I.D. ~Y29940 ~115 East Trindle Road Mechanicsburg, PA 17050 (717) 691-5400 Attorney for Plaintiff CERTIFICATE OF SERVICE AND NOW, this ..,~r~day of March, 2004, I, John R. Fenstermacher, hereby certify that I have served the foregoing Praecipe to Satisfy Judgment by mailing a true and correct copy by United States first class mail, postage prepaid, addressed as follows: John Piazza, III, Esquire 416 Pine Street, Suite 401 Williamsport, PA 17701 FENSTERMACHER AND ASSOCIATES, P.C. S~,~ J~)nn I~. I-enstermacher R. Thomas Kline, Sheriff, who being duly sworn according to/aw, states this Writ is returned ABANDONED, no action taken in six months. Sheriff's Costs: Docketing 18.00 Poundage 2.29 Advertising 10.00 Law Library .50 Prothonotary 1.00 Mileage 9.66 Misc. Surcharge 40.00 Levy 20.00 Post Pone Sale 15.00 Garnishee TOTAL 116.45 Sworn and Subscribed to before me this/,~ay of 2004 A.D. ~ t. ~,-.. ,tho ot Advance Costs: 150.00 Sheriff's Costs: 116.45 33.55 Refunded to Arty on 04/29/04 R. Thomas Kline, S~ieriff