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HomeMy WebLinkAbout03-1273Double Gold, Inc., : Plaintiff : : V, : Purofirst International, Inc., : Puroclean, Inc., Puroclean of : Susquehanna Valley, Inc., Dan Miller,: Robert Miller, Mary Miller, : Joseph Scarlata and Bruce Vogt, : Defendants : IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA NO. 03- /~ ?'-~ CIVIL TERM CIVIL ACTION - LAW NOTICE YOU HAVE BEEN SUED IN COURT. If you wish to defend against the claim.~ 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 attorney 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 of for any other claim or relief requested by the Plaintiff. 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 Double Gold, Inc., Plaintiff Vo Purofirst International, Inc., Puroclean, Inc., Puroclean of Susquehanna Valley, Inc., Dan Miller, Robert Miller, Mary Miller, Joseph Scarlata and Brace Vogt, Defendants · IN THE COURT OF COMMON PLEAS OF · CUMBERLAND COUNTY, PENNSYLVANIA · NO. 03-/,~ CIVIL TERM CIVIL ACTION - LAW COMPLAINT 1. Double Gold, Inc. is a Pennsylvania Corporation with its principle address as 2322 North Seventh Street, Harrisburg, Dauphin County, Pennsylvania. 2. Defendant Purofirst International, Inc. is a Florida corporation with a last known business address of 5350 Northwest 35th Avenue, Fort Lauderdale, Florida 33309. 3. Puroclean, Inc. is a Florida corporation which is either a subsidiary of or is controlled completely by Defendant Purofirst International, Inc. with a last known business of 5350 Northwest 35th Avenue, Fort Lauderdale, Florida 33309. 4. Dan Miller is an adult individual with a last known address of 220 Fox Drive, Mechanicsburg, Cumberland County, Pennsylvania 17055. 5. Robert Miller is an adult individual with a last known address of 220 Fox Drive, Mechanicsburg, Cumberland County, Pennsylvania 17055· 6. Mary Miller is an adult individual with a last known address of 220 Fox Drive, Mechanicsburg, Cumberland County, Pennsylvania 17055. 7. Puroclean of Susquehanna Valley, Inc. is a Pennsylvania corporation with a last known address of 220 Fox Drive, Mechanicsburg, Cumberland County, Pennsylvania 17055. 8. Defendant Brace Vogt is an adult individual with a last known address of 2149 Big Island View Road, Hayes, Virginia 23072. 9. Defendant Joseph Scarlata is an adult individual with a last known address of 7006 Nandina Lane, Tamarac, Florida 33321. 10. On or about June 15, 1995, Plaintiff Double Gold, Inc., by its president, Michael Goldberg, did enter into a franchise license agreement with Defendant Purofirst International, Inc. 11. On or about July 26, 2002, Defendant Purofirst International, Inc. and Defendant Puroclean, Inc. did grant a similar franchise to Defendants, Dan Miller, Robert Miller and Mary Miller. 12. At various times after July 2002, Defendant Joseph Scarlata and Defendant Bruce Vogt, in their capacity as individuals and also agents of Defendants Purofirst International, Inc. and Puroclean, Inc., did enter Cumberland County, Pennsylvania under the specific directions of Purofirst International, Inc. and Puroclean, Inc. and on behalf of Defendants Dan Miller, Robert Miller and Mary Miller. 13. At all times relevant from at least July 2002, the Defendants, upon entering into Cumberland County, did make various contacts with insurance agents and insurance adjusters with principle business places in Cumberland County, Pennsylvania and did make certain representations to said agencies and adjusters. 14. At all times relevant hereto, Plaintiff Double Gold, Inc., operating a Purofirst franchise referenced above and known as Purofirst Capital Region, did have ongoing business relationships with the insurance agents and claims adjusters which relationships were ongoing, profitable business relationships whereby Plaintiffs did provide services to the insured customers of said insurance agencies and claims adjusters. 15. At all times relevant hereto, Defendants Scarlata and Vogt in their individual capacity and as agents of Defendants Purofirst International, Inc. and Puroclean, Inc. did accompany either Defendant Dan Miller, Defendant Robert Miller or Defendant Mary Miller to the various meetings held in Cumberland County with insurance agents and claims adjusters and did, during said meetings, did make untrue statements regarding the relationship between Plaintiff's business and the new franchise owned and operated by Defendants Millers, did make fraudulent representation of material facts relating to the relationship of the Plaintiff's business and the new franchise operated by Defendants Millers and did attempt to induce and interfere with the contractual relationships between the various insurance agencies and claims adjusters and Plaintiff's business. 16. Specifically, during the various meetings held in Cumberland County, Defendants Scarlata and Vogt, acting in their individual capacities and as agents for Defendants Purofirst International, Inc. and Puroclean, Inc. and on behalf of and in conjunction with Defendants Dan Miller, Robert Miller and Mary Miller did attempt to induce the various agents and claims adjusters to provide certain types of business to Defendants Millers, did misrepresent the business association between the Defendants Millers Puroclean franchise and Plaintiff's Purofirst franchise, did attempt to fraudulently induce the various agents and claims adjusters located in Cumberland County, Pennsylvania, to refer business to Defendants Millers' Puroclean franchise as a substitute for Plaintiff's Purofirst franchise and published untrue statements of fact or opinion which was likely to result in the financial harm to Plaintiff concerning the fact that Plaintiff's business was a direct competitor of Defendants Millers' new Puroclean franchise. 17. At all times relevant hereto Defendants Scarlata and Vogt, acting in their individual capacities and as agents for Defendants Purofirst International, Inc. and Puroclean, Inc., as well as on behalf of and in conjunction with Defendants Dan Miller, Robert Miller and Mary Miller did, by creating a false impression with the various insurance agents and claims adjusters that the new Puroclean franchise, owned by Defendants Millers, was either a subcontractor of Plaintiff Purofirst franchise, an affiliated business of Plaintiff's Purofirst franchise or a substitute franchise doing work no longer provided by Plaintiff's Purofirst franchise all with the intent to financially harm Plaintiff's business seeking to have future business, to the specific detriment of Plaintiff, referred to Defendants Millers' Puroclean franchise. 18. At all times relevant hereto Defendants Scarlata and Vogt, in their individual capacities and as agents for Defendants Purofirst International, Inc. and Puroclean, Inc. and acting as agents for and in conjunction with Defendants Dan Miller, Robert Miller and Mary Miller did financially harm Plaintiff's business by acting and publishing untrue statement of facts, fraudulent misrepresentation of material facts and intentionally inducing others to not perform contractually with Plaintiffs all in detriment to Plaintiffs and resulting in the loss of business to Plaintiffs which Plaintiffs otherwise would have received, if not for the fraud, injurious falsehood, or intentional interference with contractual relations. 19. At all times relevant hereto the various insurance agents and claims adjusters, all located in Cumberland County, Pennsylvania, did rely on the fraudulent misrepresentations, injurious falsehoods of Defendants Scarlata and Vogt and Defendants Millers did, at various times, refer business to Defendants Millers Puroclean franchise that otherwise would have been referred to Plaintiff's Purofirst franchise as a direct and proximate result of the fraud, injurious falsehoods, fraudulent misrepresentations or non-disclosure and interference with contractual relations perpetrated on them by all Defendants. 20. On or about September 4, 2002, Plaintiff Double Gold, Inc., through its franchise, Purofirst Capital Region did schedule a seminar as an educational opportunity for insurance agents and insurance adjusters and did prepare a list of names of such agents and adjusters that would be in attendance. 21. The conference was taught by Defendant Bruce Vogt and the list of names of attendees was provided to Defendant Vogt, and Plaintiff alleges, to Defendant Scarlata who, in turn, as alleged above, did make contacts with one or more of the individuals on this list to induce business away from Plaintiff and its franchise to the franchise, Puroclean of Susquehanna Valley, Inc., owned by Defendants Dan Miller, Robert Miller and Mary Miller. COUNT I FRAUD Double Gold, Inc. v. Purofirst International Inc. 22. At all times relevant hereto Defendant Purofirst International, Inc. did fraudulently misrepresent a material fact to another person intending that this individual rely on Defendant's misrepresentation, which misrepresentation was relied on by the individuals, and Plaintiff, Double Gold, Inc., was injured financially and such misrepresentation was a substantial factor in bringing about the harm suffered by the Plaintiff. 23. At all times relevant hereto, Defendant Purofirst International, Inc., by the actions of its agents and, its franchisees Defendants Millers, did fraudulently misrepresent material facts to various insurance agents and claims adjusters located throughout Cumberland County, Pennsylvania, with the specific purpose of inducing such individuals to provide business to Defendants Millers' Puroclean franchise. 24. As a direct and proximate result of said fraudulent misrepresentations Plaintiff Double Gold, Inc. did lose business solely as a result of the fraudulent misrepresentations of Defendant, its agents and its franchisees. WHEREFORE, for all the above reasons, Plaintiff Double Gold, Inc. respectfully requests this Court to find in its favor and against the Defendant in an amount in excess of $25,000.00. COUNT II FRAUD Double Gold, Inc. v. Puroclean, Inc. 25. At all times relevant hereto Defendant Puroclean, Inc. did fraudulently misrepresent a material fact to another person of a material fact intending that this individual rely on Defendant's misrepresentation, which misrepresentation was relied on by the individuals, and Plaintiff, Double Gold, Inc., was injured financially and such misrepresentation was a substantial factor in bringing about the harm suffered by the Plaintiff. 26. At all times relevant hereto Defendant Puroclean, Inc., by the actions of its agents, and, and its franchisees Defendants Millers, did fraudulently misrepresent material facts to various insurance agents and claims adjusters located throughout Cumberland County, Pennsylvania, with the specific purpose of inducing such individuals to provide business to Defendants Millers' Puroclean franchise. 27. As a direct and proximate result of said fraudulent misrepresentations Plaintiff Double Gold, Inc. did lose business solely as a result of the fraudulent misrepresentations of Defendant, its agents and its franchisees. WHEREFORE, for all the above reasons, Plaintiff Double Gold, Inc. respectfully requests this Court to find in its favor and against the Defendant in an amount in excess of $25,000.00. COUNT III FRAUD Double Gold, Inc. v. Joseph Scarlata 28. At all times relevant hereto Defendant Joseph Scarlata, in his individual and agency capacity, did fraudulently misrepresent to another person of a material fact intending that this individual rely on Defendant's misrepresentation, which misrepresentation was relied on by the individuals, and Plaintiff, Double Gold, Inc., was injured financially and such misrepresentation was a substantial factor in bringing about the harm suffered by the Plaintiff. 29. At all times relevant hereto Defendant Joseph Scarlata, in his individual and agency capacity, by the actions of its agents, and its franchisees Defendants Millers, did fraudulently misrepresent material facts to various insurance agents and claims adjusters located throughout Cumberland County, Pennsylvania, with the specific purpose of inducing such individuals to provide business to Defendants Millers' Puroclean franchise. 30. As a direct and proximate result of said fraudulent misrepresentations Plaintiff Double Gold, Inc. did lose business solely as a result of the fraudulent misrepresentations of Defendant, its agents and its franchisees. WHEREFORE, for all the above reasons, Plaintiff Double Gold, Inc. respectfully requests this Court to find in its favor and against the Defendant in an amount in excess of $25,000.00. COUNT IV FRAUD Double Gold, Inc. v. Bruce Vogt 31. At all times relevant hereto Defendant Bruce Vogt, in his individual and agency capacity, did fraudulently misrepresent another person of a material fact intending that this individual rely on Defendant's misrepresentation, which misrepresentation was relied on by thc individuals, and Plaintiff, Double Gold, Inc., was injured financially and such misrepresentation was a substantial factor in bringing about the harm suffered by the Plaintiff. 32. At all times relevant hereto Defendant Bruce Vogt, in his individual and agency capacity, by the actions of his agents, and its franchises Defendants Millers, did fraudulently misrepresent material facts to various insurance agents and claims adjusters located throughout Cumberland County, Pennsylvania, with the specific purpose of inducing such individuals to provide business to Defendants Millers' Puroclean franchise. 33. As a direct and proximate result of said fraudulent misrepresentations, Plaintiff Double Gold, Inc. did lose business solely as a result of the fraudulent misrepresentations of Defendant, its agents and its franchises. WHEREFORE, for all the above reasons, Plaintiff Double Gold, Inc. respectfully requests this Court to find in its favor and against the Defendant in an amount in excess of $25,000.00. COUNT V FRAUD Double Gold, Inc. v. Dan Miller 34. At all times relevant hereto Defendant Dan Miller, in his individual and agency capacity, did fraudulently misrepresent a material fact to another person intending that this individual rely on Defendant's misrepresentation, which misrepresentation was relied on by the individuals, and Plaintiff, Double Gold, Inc., was injured financially and such misrepresentation was a substantial factor in bringing about the harm suffered by the Plaintiff. 35. At all times relevant hereto Defendant Dan Miller, in his individual and agency capacity, by the actions of his agents, and its franchises Defendants Millers, did fraudulently misrepresent material facts to various insurance agents and claims adjusters located throughout Cumberland County, Pennsylvania, with the specific purpose of inducing such individuals to provide business to Defendants Millers' Puroclean franchise. 36. As a direct and proximate result of said fraudulent misrepresentations, Plaintiff Double Gold, Inc. did lose business solely as a result of the fraudulent misrepresentations of Defendant, his agents and its franchises. WHEREFORE, for all the above reasons, Plaintiff Double Gold, Inc. respectfully requests this Court to find in its favor and against the Defendant in an amount in excess of $25,000.00. COUNT VI FRAUD Double Gold, Inc. v. Robert Miller 37. At all times relevant hereto Defendant Robert Miller, in his individual and agency capacity, did fraudulently misrepresent a material fact to another person intending that this individual rely on Defendant's misrepresentation, which misrepresentation was relied on by the individuals, and Plaintiff, Double Gold, Inc., was injured financially and such misrepresentation was a substantial factor in bringing about the harm suffered by the Plaintiff. 38. At all times relevant hereto Defendant Robert Miller, in his individual and agency capacity, by the actions of his agents, and his franchises Defendants Millers, did fraudulently misrepresent material facts to various insurance agents and claims adjusters located throughout Cumberland County, Pennsylvania, with the specific purpose of inducing such individuals to provide business to Defendants Millers' Puroclean franchise. 39. As a direct and proximate result of said fraudulent misrepresentations, Plaintiff Double Gold, Inc. did lose business solely as a result of the fraudulent misrepresentations of Defendant, his agents and its franchises. WHEREFORE, for all the above reasons, Plaintiff Double Gold, Inc. respectfully requests this Court to find in its favor and against the Defendant in an amount in excess of $25,000.00. COUNT VII FRAUD Double Gold, Inc. v. Mary Miller 40. At all times relevant hereto Defendant Mary Miller, in her individual and agency capacity, did fraudulently misrepresent a material fact to another person intending that this individual rely on Defendant's misrepresentation, which misrepresentation was relied on by the individuals, and Plaintiff, Double Gold, Inc., was injured financially and such misrepresentation was a substantial factor in bringing about the harm suffered by the Plaintiff. 41. At all times relevant hereto Defendant Mary Miller, in her individual and agency capacity, by the actions of her agents, and its franchises Defendants Millers, did fraudulently misrepresent material facts to various insurance agents and claims adjusters located throughout Cumberland County, Pennsylvania, with the specific purpose of inducing such individuals to provide business to Defendants Millers' Puroclean franchise. 42. As a direct and proximate result of said fraudulent misrepresentations Plaintiff Double Gold, Inc. did lose business solely as a result of the fraudulent misrepresentations of Defendant, her agents and its franchises. WHEREFORE, for all the above reasons, Plaintiff Double Gold, Inc. respectfully requests this Court to find in its favor and against the Defendant in an amount in excess of $25,000.00. COUNT VIII Fraud Double Gold, Inc. v. Puroclean of Susquehanna Valley, Inc. 43. At all times relevant hereto Defendant Purofirst of Susquehanna Valley, Inc. through its agents and franchisees did publish untrue statements of fact or opinion, which it knew was likely to result in harm to the financial interest of Plaintiff because the action of third persons, in reliance upon the statement, would provide business normally reserved and referred to Plaintiff to Defendant Miller's new Puroclean franchise and, at all times relevant hereto, Defendant Purofirst. WHEREFORE, for all the above reasons, Plaintiff Double Gold, Inc. respectfully requests this Court to find in its favor and against the Defendant in an amount in excess of $25,000.00. COUNT VIX INJURIOUS FALSEHOOD Double Gold, Inc. v. Purofirst International, Inc. 44. At all times relevant hereto Defendant Purofirst International, Inc. through its agents and franchisees did publish untrue statements of fact or opinion, which it knew was likely to result in harm to the financial interest of Plaintiff because the action of third persons, in reliance upon the statement, would provide business normally reserved and referred to Plaintiff to Defendant Miller's new Puroclean franchise and, at all times relevant hereto, Defendant Purofirst International, Inc. intended to interfere with the interests of Plaintiffs and further knew that the statements made by its agents and franchisees were not tree and directly communicated such untrue statements to the various insurance agents and claims adjusters so that they would rely on the same and refer future business to Defendants Millers and their new Puroclean franchise. WHEREFORE, for all the above reasons, Plaintiff Double Gold, Inc. respectfully requests this Court to find in its favor and against the Defendant in an amount in excess of $25,000.00. COUNT X INJURIOUS FALSEHOOD Double Gold, Inc. v. Puroclean, Inc. 45. At all times relevant hereto Defendant Puroclean, Inc., through its agents and Franchisees, did publish untrue statements of fact or opinion, which it knew was likely to result in harm to the financial interest of Plaintiff because the action of third persons, in reliance upon the statement, would provide business normally reserved and referred to Plaintiff to Defendant Miller's new Puroclean franchise and, at all times relevant hereto, Defendant Puroclean, Inc. intended to interfere with the interests of Plaintiffs and further knew that the statements made by its agents and franchisees were not true and directly communicated such untrue statements to the various insurance agents and claims adjusters so that they would rely on the same and refer future business to Defendants Millers and their new Puroclean franchise. WHEREFORE, for all the above reasons, Plaintiff Double Gold, Inc. respectfully requests this Court to find in its favor and against the Defendant in an amount in excess of $25,000.00. COUNT X1 INJURIOUS FALSEHOOD Double Gold, Inc. v. Joseph Scarlata 46. At all times relevant hereto Defendant Joseph Scarlata, in his individual and agency capacity, did publish untrue statements of fact or opinion, which he knew was likely to result in harm to the financial interest of Plaintiff because the action of third persons in reliance upon the statement would provide business normally reserved and referred to Plaintiff to Defendant Miller's new Puroclean franchise and, at all times relevant hereto, Defendant Joseph Scarlata intended to interfere with the interests of Plaintiffs and further knew that the statements made by his agents and franchisees were not tree and directly communicated such untrue statements to the various insurance agents and claims adjusters so that they would rely on the same and refer future business to Defendants Millers and their new Puroclean franchise. WHEREFORE, for all the above reasons, Plaintiff Double Gold, Inc. respectfully requests this Court to find in its favor and against the Defendant Joseph Scarlata in an amount in excess of $25,000.00. COUNT XII INJURIOUS FALSEHOOD Double Gold, Inc. v. Bruce Vogt 47. At all times relevant hereto Defendant Bruce Vogt, in his individual and agency capacity, did publish untrue statements of fact or opinion, which he knew was likely to result in harm to the financial interest of Plaintiff because the action of third persons, in reliance upon the statement, would provide business normally reserved and referred to Plaintiff to Defendant Miller's new Puroclean franchise and, at all times relevant hereto, Defendant Bruce Vogt intended to interfere with the interests of Plaintiffs and further knew that the statements made by his agents and franchisees were not tree and directly communicated such untrue statements to the various insurance agents and claims adjusters so that they would rely on the same and refer future business to Defendants Millers and their new Puroclean franchise. WHEREFORE, for all the above reasons, Plaintiff Double Gold, Inc. respectfully requests this Court to find in its favor and against the Defendant Bruce Vogt in an amount in excess of $25,000.00. COUNT XIII INJURIOUS FALSEHOOD Double Gold, Inc. v. Dan Miller 48. At all times relevant hereto Defendant Dan Miller, in his individual and agency capacity, did publish untrue statements of fact or opinion, which he knew was likely to result in harm to the financial interest of Plaintiff because the action of third persons, in reliance upon the statement, would provide business normally reserved and referred to Plaintiff to Defendant Miller's new Puroclean franchise and, at all times relevant hereto, Defendant Dan Miller intended to interfere with the interests of Plaintiffs and further knew that thc statements made by his agents and franchisees were not true and directly communicated such untrue statements to thc various insurance agents and claims adjusters so that they would rely on thc same and refer future business to Defendants Millers and their new Puroclean franchise. WHEREFORE, for all the above reasons, Plaintiff Double Gold, Inc. respectfully requests this Court to find in its favor and against the Defendant Dan Miller in an amount in excess of $25,000.00. COUNT XIV INJURIOUS FALSEHOOD Double Gold, Inc. v. Robert Miller 49. At all times relevant hereto Defendant Robert Miller, in his individual and agency capacity, did publish untrue statements of fact or opinion, which he knew was likely to result in harm to the financial interest of Plaintiff because the action of third persons, in reliance upon the statement, would provide business normally reserved and referred to Plaintiff to Defendant Miller's new Puroclean franchise and, at all times relevant hereto, Defendant Robert Miller intended to interfere with the interests of Plaintiffs and further knew that the statements made by his agents and franchisees were not true and directly communicated such untrue statements to the various insurance agents and claims adjusters so that they would rely on the same and refer future business to Defendants Millers and their new Puroclean franchise. WHEREFORE, for all the above reasons, PlaintiffDouble Gold, Inc. respectfully requests this Court to find in its favor and against the Defendant Robert Miller in an amount in excess of $25,000.00. COUNT XV INJURIOUS FALSEHOOD Double Gold, Inc. v. Mary Miller 50. At all times relevant hereto Defendant Mary Miller, in her individual and agency capacity, did publish untrue statements of fact or opinion, which she knew was likely to result in harm to the financial interest of Plaintiff because the action of third persons, in reliance upon the statement, would provide business normally reserved and referred to Plaintiff to Defendant Miller's new Puroclean franchise and, at all times relevant hereto, Defendant Mary Miller intended to interfere with the interests of Plaintiffs and further knew that the statements made by her agents and franchisees were not tree and directly communicated such untrue statements to the various insurance agents and claims adjusters so that they would rely on the same and refer future business to Defendants Millers and their new Puroclean franchise. WHEREFORE, for all the above reasons, Plaintiff Double Gold, Inc. respectfully requests this Court to find in its favor and against the Defendant Mary Miller in an amount in excess of $25,000.00. COUNT XVI INJURIOUS FALSEHOOD Double Gold, Inc. v. Puroclean of Susquehanna Valley, Inc. 51. At all times relevant hereto Defendant Puroclean of Susquehanna Valley, Inc. through its agents and franchisees did publish untrue statements of fact or opinion, which it knew was likely to result in harm to the financial interest of Plaintiff because the action of third persons, in reliance upon the statement, would provide business normally reserved and referred to Plaintiff to Defendant Miller's new Puroclean franchise and, at all times relevant hereto, Defendant Puroclean of Susquehanna Valley, Inc. intended to interfere with the interests of Plaintiffs and further knew that the statements made by its agents and franchisees were not true and directly communicated such untrue statements to the various insurance agents and claims adjusters so that they would rely on the same and refer future business to Defendants Millers and their new Puroclean franchise. WHEREFORE, for all the above reasons, Plaintiff Double Gold, Inc. respectfully requests this Court to find in its favor and against the Defendant Puroclean of Susquehanna Valley, Inc in an amount in excess of $25,000.00. COUNT XVII FRAUDULENT MISREPRESENTATION OR NON-DISCLOSURE Double Gold, Inc. v. Purofirst International, Inc. 52. At all times relevant hereto Defendant Purofirst International, Inc., through its agents and franchisees did publish a misrepresentation or a misleading representation seeking to have various insurance agents and claims adjusters rely on such misrepresentation or a misleading representation to the detriment of the Plaintiff with the stated purpose of having business normally reserved and referred to Plaintiff Double Gold, Inc. to Defendant Miller's new Puroclean franchise. 53. At all times relevant hereto, the various insurance agents and claims adjusters all located in Cumberland County, Pennsylvania, did rely on said material misrepresentation or a misleading representations and did refer business to Defendant Millers' Puroclean franchise to the financial detriment of Plaintiffs Double Gold, Inc. WHEREFORE, for all the above reasons, Plaintiff Double Gold, Inc. respectfully requests this Court to find in its favor and against the Defendant Purofirst International, Inc. in an amount in excess of $25,000.00. COUNT XVIII FRAUDULENT MISREPRESENTATION OR NON-DISCLOSURE Double Gold, Inc. v. Puroclean, Inc. 54. At all times relevant hereto Defendant Puroclean, Inc., through its agents and franchisees did publish a misrepresentation or a misleading representation seeking to have various insurance agents and claims adjusters rely on such misrepresentation or a misleading representation to the detriment of the Plaintiff with the stated purpose of having business normally reserved and referred to Plaintiff Double Gold, Inc. to Defendant Miller's new Puroclean franchise. 55. At all times relevant hereto, the various insurance agents and claims adjusters all located in Cumberland County, Pennsylvania, did rely on said material misrepresentation or a misleading representations and did refer business to Defendant Millers' Puroclean franchise to the financial detriment of Plaintiffs Double Gold, Inc. WHEREFORE, for all the above reasons, Plaintiff Double Gold, Inc. respectfully requests this Court to find in its favor and against the Defendant in an amount in excess of $25,000.00. COUNT XIX FRAUDULENT MISREPRESENTATION OR NON-DISCLOSURE Double Gold, Inc. v. Joseph Scarlata 56. At all times relevant hereto Defendant Joseph Scarlata, in his individual and agency capacity, did publish a misrepresentation or a misleading representation seeking to have various insurance agents and claims adjusters rely on such misrepresentation or a misleading representation to the detriment of the Plaintiff with the stated purpose of having business normally reserved and referred to Plaintiff Double Gold, Inc. to Defendant Miller's new Puroclean franchise. 57. At all times relevant hereto, the various insurance agents and claims adjusters all located in Cumberland County, Pennsylvania, did rely on said material misrepresentation or a misleading representations and did refer business to Defendant Millers' Puroclean franchise to the financial detriment of Plaintiffs Double Gold, Inc. WHEREFORE, for all the above reasons, Plaintiff Double Gold, Inc. respectfully requests this Court to find in its favor and against the Defendant Joseph Scarlata in an mount in excess of $25,000.00. COUNT XX FRAUDULENT MISREPRESENTATION OR NON-DISCLOSURE Double Gold, Inc. v. Bruce Vogt 58. At all times relevant hereto Defendant Bruce Vogt, in his individual and agency capacity, did publish a misrepresentation or a misleading representation seeking to have various insurance agents and claims adjusters rely on such misrepresentation or a misleading representation to the detriment of the Plaintiff with the stated purpose of having business normally reserved and referred to Plaintiff Double Gold, Inc. to Defendant Miller's new Puroclean franchise. 59. At all times relevant hereto, the various insurance agents and claims adjusters all located in Cumberland County, Pennsylvania, did rely on said material misrepresentation or a misleading representations and did refer business to Defendant Millers' Puroclean franchise to the financial detriment of Plaintiffs Double Gold, Inc. WHEREFORE, for all the above reasons, Plaintiff Double Gold, Inc. respectfully requests this Court to find in its favor and against the Defendant in an amount in excess of $25,000.00. COUNT XXI FRAUDULENT MISREPRESENTATION OR NON-DISCLOSURE Double Gold, Inc. v. Dan Miller 60. At all times relevant hereto Defendant Dan Miller., in his individual and agency capacity, did publish a misrepresentation or a misleading representation seeking to have various ~nsurance agents and claims adjusters rely on such misrepresentation or a misleading representation to the detriment of the Plaintiff with the stated purpose of having business normally reserved and referred to Plaintiff Double Gold, Inc. to Defendant Miller's new Puroclean franchise. 61. At all times relevant hereto, the various insurance agents and claims adjusters all located in Cumberland County, Pennsylvania, did rely on said material misrepresentation or a misleading representations and did refer business to Defendant Millers' Puroclean franchise to the financial detriment of Plaintiffs Double Gold, Inc. WHEREFORE, for all the above reasons, Plaintiff Double Gold, Inc. respectfully requests this Court to find in its favor and against the Defendant Dan Miller in an amount in excess of $25,000.00. COUNT XXII FRAUDULENT MISREPRESENTATION OR NON-DISCLOSURE Double Gold, Inc. v. Robert Miller 62. At all times relevant hereto Defendant Robert Miller, in his individual and agency capacity, did publish a misrepresentation or a misleading representation seeking to have various insurance agents and claims adjusters rely on such misrepresentation or a misleading representation to the detriment of the Plaintiff with the stated purpose of having business normally reserved and referred to Plaintiff Double Gold, Inc. to Defendant Miller's new Puroclean franchise. 63. At all times relevant hereto, the various insurance agents and claims adjusters all located in Cumberland County, Pennsylvania, did rely on said material misrepresentation or a misleading representations and did refer business to Defendant Millers' Puroclean franchise to the financial detriment of Plaintiffs Double Gold, Inc. WHEREFORE, for all the above reasons, Plaintiff Double Gold, Inc. respectfully requests this Court to find in its favor and against the Defendant in an amount in excess of $25,000.00. COUNT XXI FRAUDULENT MISREPRESENTATION OR NON-DISCLOSURE Double Gold, Inc. v. Mary Miller 64. At all times relevant hereto Defendant Mary Miller, in her individual and agency capacity, did publish a misrepresentation or a misleading representation seeking to have various insurance agents and claims adjusters rely on such misrepresentation or a misleading representation to the detriment of the Plaintiff with the stated purpose of having business normally reserved and referred to Plaintiff Double Gold, Inc. to Defendant Miller's new Puroclean franchise. 65. At all times relevant hereto, the various insurance agents and claims adjusters all located in Cumberland County, Pennsylvania, did rely on said material misrepresentation or a misleading representations and did refer business to Defendant Millers' Puroclean franchise to the financial detriment of Plaintiffs Double Gold, Inc. WHEREFORE, for all the above reasons, Plaintiff Double Gold, Inc. respectfully requests this Court to find in its favor and against the Defendant in an amount in excess of $25,000.00. COUNT XXI FRAUDULENT MISREPRESENTATION OR NON-DISCLOSURE Double Gold, Inc. v. Puroclean of Susquehanna Valley, Inc. 66. At all times relevant hereto Defendant Susquehanna Valley, Inc., in its individual and agency capacity, did publish a misrepresentation or a misleading representation seeking to have various insurance agents and claims adjusters rely on such misrepresentation or a representation to the detriment of the Plaintiff with the stated purpose of having business normally reserved and referred to Plaintiff Double Gold, Inc. to Defendant Miller's new Puroclean franchise. 67. At all times relevant hereto, the various insurance agents and claims adjusters all located in Cumberland County, Pennsylvania did rely on said material misrepresentation or a misleading representations and did refer business to Defendant Millers' Puroclean franchise to the financial detriment of Plaintiffs Double Gold, Inc. WHEREFORE, for all the above reasons, Plaintiff Double Gold, Inc. respectfully requests this Court to find in its favor and against the Defendant Puroclean of Susquehanna Valley, Inc. in an mount in excess of $25,000.00. COUNT XXII INTENTIONAL INTERFERENCE WITH CONTRACTUAL RELATIONS Double Gold, Inc. v. Purofirst International, Inc. 68. At all times relevant hereto Defendant Purofirst International, Inc., did intentionally induce various insurance agents and claims adjusters to not perform a contract with Plaintiff Double Gold, Inc., through its Purofirst franchises, by making fraudulent misrepresentations, injurious falsehoods or creating a false impression of the actual relationship in the mind of these various third parties and, as a result, said third parties did refer business to Defendant Millers' new Puroclean franchise that otherwise would have been referred to Plaintiff's Double Gold, Inc. franchise. WHEREFORE, for all the above reasons, Plaintiff Double Gold, Inc. respectfully requests this Court to find in its favor and against the Defendant in an amount in excess of $25,000.00. COUNT XXIII INTENTIONAL INTERFERENCE WITH CONTRACTUAL RELATIONS Double Gold, Inc. v. Puroclean, Inc. 69. At all times relevant hereto Defendant Puroclean, Inc., did intentionally induce various insurance agents and claims adjusters to not perform a contract with Plaintiff Double Gold, Inc., through its Purofirst franchises, by making fraudulent misrepresentations, injurious falsehoods or creating a false impression of the actual relationship in the mind of these various third parties and, as a result, said third parties did refer business to Defendant Millers' new Puroclean franchise that otherwise would have been referred to Plaintiff's Double Gold, Inc. franchise. WHEREFORE, for all the above reasons, Plaintiff Double Gold, Inc. respectfully requests this Court to find in its favor and against the Defendant in an amount in excess of $25,00O.00. COUNT XXIV INTENTIONAL INTERFERENCE WITH CONTRACTUAL RELATIONS Double Gold, Inc. v. Joseph Scarlata 70. At all times relevant hereto Defendant Joseph Scarlata., did intentionally induce various insurance agents and claims adjusters to not perform a contract with Plaintiff Double Gold, Inc., through his Purofirst franchises, by making fraudulent misrepresentations, injurious falsehoods or creating a false impression of the actual relationship in the mind of these various third parties and, as a result, said third parties did refer business to Defendant Millers' new Puroclean franchise that otherwise would have been referred to Plaintiff's Double Gold, Inc. franchise. WHEREFORE, for all the above reasons, Plaintiff Double Gold, Inc. respectfully requests this Court to find in its favor and against the Defendant Joseph Scarlata in an amount in excess of $25,000.00. COUNT XXV INTENTIONAL INTERFERENCE WITH CONTRACTUAL RELATIONS Double Gold, Inc. v. Bruce Vogt 71. At all times relevant hereto Defendant Bruce Vogt, did intentionally induce various insurance agents and claims adjusters to not perform a contract with Plaintiff Double Gold, Inc., through his Puro£~rst franchises, by making fraudulent misrepresentations, injurious falsehoods or creating a false impression of the actual relationship in the mind of these various third parties and, as a result, said third parties did refer business to Defendant Millers' new Puroclean franchise that otherwise would have been referred to Plaintiff's Double Gold, Inc. franchise. WHEREFORE, for all the above reasons, Plaintiff Double Gold, Inc. respectfully requests this Court to find in its favor and against the Defendant Bruce Vogt in an amount in excess of $25,000.00. COUNT XXVI INTENTIONAL INTERFERENCE WITH CONTRACTUAL RELATIONS Double Gold, Inc. v. Dan Miller 72. At all times relevant hereto Defendant Dan Miller, did intentionally induce various insurance agents and claims adjusters to not perform a contract with Plaintiff Double Gold, Inc., through his Purofirst franchises, by making fraudulent misrepresentations, injurious falsehoods or creating a false impression of the actual relationship in the mind of these various third parties and, as a result, said third parties did refer business to Defendant Millers' new Puroclean franchise that otherwise would have been referred to Plaintiff's Double Gold, Inc. franchise. WHEREFORE, for all the above reasons, Plaintiff Double Gold, Inc. respectfully requests this Court to find in its favor and against the Defendant Dan Miller in an amount in excess of $25,000.00. COUNT XXVII INTENTIONAL INTERFERENCE WITH CONTRACTUAL RELATIONS Double Gold, Inc. v. Robert Miller 73. At all times relevant hereto Defendant Robert Miller, did intentionally induce various insurance agents and claims adjusters to not perform a contract with Plaintiff Double Gold, Inc., through his Purofirst franchises, by making fraudulent misrepresentations, injurious falsehoods or creating a false impression of the actual relationship in the mind of these various third parties and, as a result, said third parties did refer business to Defendant Millers' new Puroclean franchise that otherwise would have been referred to Plaintiff's Double Gold, Inc. franchise. WHEREFORE, for all the above reasons, Plaintiff Double Gold, Inc. respectfully requests this Court to find in its favor and against the Defendant Robert Miller in an amount in excess of $25,000.00. COUNT XXVIII INTENTIONAL INTERFERENCE WITH CONTRACTUAL RELATIONS Double Gold, Inc. v. Mary Miller 74. At all times relevant hereto Defendant Mary Miller, did intentionally induce various insurance agents and claims adjusters to not perform a contract with Plaintiff Double Gold, Inc., through her Purofirst franchises, by making fraudulent misrepresentations, injurious falsehoods or creating a false impression of the actual relationship in the mind of these various third parties and, as a result, said third parties did refer business to Defendant Millers' new Puroclean franchise that otherwise would have been referred to Plaintiff's Double Gold, Inc. franchise. WHEREFORE, for all the above reasons, Plaintiff Double Gold, Inc. respectfully requests this Court to find in its favor and against the Defendant Mary Miller in an amount in excess of $25,000.00. COUNT XXIX INTENTIONAL INTERFERENCE WITH CONTRACTUAL RELATIONS Double Gold, Inc. v. Puroclean of Susquehanna Valley, Inc. 75. At all times relevant hereto Defendant Puroclean of Susquehanna Valley, Inc., did intentionally induce various insurance agents and claims adjusters to not perform a contract with Plaintiff Double Gold, Inc., through its Purofirst franchises, by making fraudulent misrepresentations, injurious falsehoods or creating a false impression of the actual relationship in the mind of these various third parties and, as a result, said third parties did refer business to Defendant Millers' new Puroclean franchise that otherwise would have been referred to Plaintiff's Double Gold, Inc. franchise. WHEREFORE, for all the above reasons, Plaintiff Double Gold, Inc. respectfully requests this Court to find in its favor and against the Defendant Puroclean of Susquehanna Valley, Inc. in an amount in excess of $25,000.00. Re.~pectfully Su bmi~m~y, Ron Turo Esquire Turo Law Offices 28 South Pitt Street Carlisle, PA 17103 (717) 245-9688 Attorney for Plaintiff VERIFICATION I verify that the statements made in the foregoing Complaint are true and correct. I understand that false statements herein are made subject to the penalties of 18 Pa.C.S. §4904 relating to unsworn falsification to authorities. Date Michael Goldberg, Presid~-~ Double Gold, Inc. Double Gold, Inc., Plaintiff : IN THE COURT OF COMMON PLEAS OF : CUMBERLAND COUNTY, PENNSYLVANIA Purofirst International, Inc., : NO. 03- Puroclean, Inc., Puroclean of Susquehanna Valley, Inc., Dan Miller,: Robert Miller, Mary Miller, Joseph Scadata and Bruce Vogt, Defendants : /d ~-~ CIVIL TERM CIVIL ACTION - LAW AFFIDAVIT OF SERVICE I HEREBY CERTIFY THAT I served a true and correct copy of Complaint filed in the above captioned case upon Bruce Vogt, by certified mail, return receipt requested on March 25, 2003 addressed to: Bruce Vogt 2149 Big Island View Road Hayes, VA 23072 and did thereafter receive same as evidenced by the attached Post Office receipt card dated March 27, 2003. I VERIFY THAT THE STATEMENTS MADE IN THE FOREGOING AFFIDAVIT OF SERVICE ARE TRUE AND CORRECT TO THE BEST OF MY KNOWLEDGE, INFORMATION AND BELIEF, I UNDERSTAND THAT FALSE STATEMENTS HEREIN MADE ARE SUBJECT TO THE PENALTIES OF 18 PA.C.S. SECTION 4904 RELATING TO UNSWORN FALSIFICATION TO AUTHORITIES. Ron Turo, Esquire 28 South Pitt Street Carlisle, PA 17013 (717) 245-9688 Attorney for Plaintiff 13- rl-i r,- Postage rtl Certified Fee Return Receipt Fee 13" (Endorsement Required) 1::3 1:::3 Restricted Delivery Fee r-'3 (Endorsement Required) Total Poataga & Fees I.rl I'M $ 3-,5? Postmark ~" SENDER: I also wish to receive the fo#ow- [] Complete item~ 1 and/or 2 for additional services, lng services (for an extra fee): Complete items 3, 4a, and 4b. [] Pdnt your name and address on the reverse of this form so that we can retum this card to you. 1. [] Addressee's Address [3 Attach this form to the front of the mailpiece or on the back if space does not ~ ~ _ permit. ' ". !_1 Mestricted Delivery [] Write 'Return Receipt Requested' on the mailpiece below the article number. n The Return Receipt will show to whom the article was delivered and the date delivered. · ' 7001 2510 0009 2827 8349 :~ ------ ~-=~ .. ~ [] Registered ~ertified 7_149 :B].g .Lsla_nd vsew m3. ~¢ [] Express Mail [] Insured Hayes, V~ 23072 Ret r r h n i  iptfo Me c~andise []COD 7. Date of Delive-'~-~ 5. Re~"[v-ed By: (Prlnt Name) L) 8. Addressee's Address (Only, if requested and ~ 6. Signature ~Addressee orA~fnt) PS Form 3811, December 1994 102595-99-B-0223 Domestic Return Receipt Double Gold, Inc., Plaintiff · IN THE COURT OF COMMON PLEAS OF · CUMBERLAND COUNTY, PENNSYLVANIA Purofirst International, Inc., 'NO. 03-1273 CIVIL TERM Pumclean, Inc., Puroclean of Susquehanna Valley, Inc., Dan Miller, ' Robert Miller, Mary Miller, Joseph Scarlata and Bruce Vogt, · CIVIL ACTION - LAW Defendants AFFIDAVIT OF SERVICE I HEREBY CERTIFY THAT I served a true and correct copy of Complaint filed in above captioned case upon Joseph Scadata, by certified mail, return receipt requested on March 25, 2003 addressed to: Joseph Scadata 7006 Nandina Lane Tamarac, FL 33321 and did thereafter receive same as evidenced by the attached Post Office receipt card dated March 29, 2003. I VERIFY THAT THE STATEMENTS MADE IN THE FOREGOING AFFIDAVIT OF SERVICE ARE TRUE AND CORRECT TO THE BEST OF MY KNOWLEDGE INFORMATION AND BELIEF, I UNDERSTAND THAT FALSE STATEMENTS HEREIN MADE ARE SUBJECT TO THE PENALTIES OF 18 PA.C.S. SECTION 4904 RELATING TO UNSWORN FALSIFICATION TO AUTHORITIES. TURO LAW OFFICE,~ Ron Turo, Esquire '" 28 South Pitt Street Carlisle, PA 17013 (717) 245-9688 Attomey for Plaintiff t'rl Postage Certified Fee Return Receipt Fee (Endomement Required) Restricted Delivery Fee (Endorsement Required) Total Postage & Fees .. /. 7 &" .,$ 5,57 ~ENDER: I also wish to receive the follow- D Complete items I and/or 2 for additional services, ing services (for an extra fee): Complete items 3, 4a, and 4b. El Print your name and address on the reverse of this form so that we can retum this card to you. 1. [] Addressee's Address [] Attach this form to the front of the mailpiece, or on the beck if space does not permit. 2. [] Restricted Delivery 13 Write "Return Receipt Requested' on the mailplece below the article number. [] Tde~.weRetre~? Receipt will show to whom the article was delivered and the date 3, Article Addressed to: ~~ 000fl 2827 8~32 7006 Nandi. na Lane ~T~,~ ~,~ ~ii'Cenified Tamarac, FL 33321 ~[~pr?~.~il i~1 I-Ilnsured ~tu~pt fo?,?r~handise rq COD ,. 5. R~ceived By'.~6nt Name) 8. Add~s~ ;l~dress (O~ly if requested and - ~'S Form 3~1 1, December 1994 t o2sgs-~-s-022~ Domes~c Return Rec~pt Double Gold, Inc., Plaintiff International, Inc., Puroclean, Inc., Puroclean of : Susquehanna Valley, Inc., Dan Miller,: Robert Miller, Mary Miller, Joseph Scadata and Bruce Vogt, Defendants : · IN THE COURT OF COMMON PLEAS OF · CUMBERLAND COUNTY, PENNSYLVANIA · NO. 03-1273 CIVIL TERM CIVIL ACTION - LAW AFFIDAVIT OF SERVICE I HEREBY CERTIFY THAT I served a true and correct copy of Complaint filed in the above captioned case upon Purofirst International, Inc., by certified mail, return receipt requested on March 25, 2003 addressed to: Purofirst International, Inc. 5350 Northwest 35th Avenue Fort Lauderdale, FL 33309 and did thereafter receive same as evidenced by the attached Post Office receipt card dated March 28, 2003. I VERIFY THAT THE STATEMENTS MADE IN THE FOREGOING AFFIDAVIT OF SERVICE ARE TRUE AND CORRECT TO THE BEST OF MY KNOWLEDGE, INFORMATION AND BELIEF, I UNDERSTAND THAT FALSE STATEMENTS HEREIN MADE ARE SUBJECT TO THE PENALTIES OF 18 PA.C.S. SECTION 4904 RELATING TO UNSWORN FALSIFICATION TO AUTHORITIES. Date TURO LAW OFFICES Robert J. I~derig, E~squire dj 28 South Pitt Street Carlisle, PA 17013 (717) 245-9688 Attorney for Plaintiff Postage Certified Fee Return Receipt Fee (Endorsement Required) Restricted Delivery Fee (Endorsement Required) Total Postage & Fees $ /. D.3o 7 Postmark Here SENDER: [] Complete items I and/or 2 for additional services. Complete items 3, 4a, and 4b. [] Print your name and address on the reverse of this form so that we can return this card to you. El Attach this form to the front of the mailpiece, or on the back if space does not permit. [] Write "Return Receipt Requested' on the mailpiece below the article number. [3 The Return Receipt will show to whom the article was delivered and the date delivered. I also wi~h rtO receive the follow- ing services (for an extra fee): 1. [] Addressee's Address 2. [] Restricted Delivery 3. Article Addressed to: 7001 25113 0009 2827 8363 4b. Service Type Purof:Lrst Intez~atio~al I~c.  5 350 ~~ 35~ ~. ~. ~,~r~le, ~ 33309 ~RetumReceiptforaemhandise ~COD 7. Date of Deiive~ ~ ~~)~8. Addressee'sAddress(~lyi'r~uest~and PS Fo~ 3811, D~r 19~ 102595-99-B-0223 Domes~c Return Receipt Double Gold, Inc., Plaintiff Vo · IN THE COURT OF COMMON PLEAS OF · CUMBERLAND COUNTY, PENNSYLVANIA Purofirst International, Inc., 'NO. 03-1273 Pumclean, Inc., Puroclean of Susquehanna Valley, Inc., Dan Miller, · Robert Miller, Mary Miller, Joseph Scarlata and Bruce Vogt, CIVIL ACTION - LA~W Defendants CIVIL TERM AFFIDAVIT OF SERVICF I HEREBY CERTIFY THAT I served a true and correct copy of Complaint filed in the above captioned case upon Puroclean, Inc., by certified mail, return receipt requested on March 25, 2003 addressed to: Puroclean, Inc. 5350 Northwest 35th Avenue Fort Lauderdale, FL 33309 and did thereafter receive same as evidenced by the attachedi Post Office receipt card dated March 28, 2003. I VERIFY THAT THE STATEMENTS MADE IN THE FOREGOING AFFIDAVI OF SERVICE ARE TRUE AND CORRECT TO THE BEST OF MY KNOWLEDGE, INFORMATION AND BELIEF, I UNDERSTAND THAT FALSE STATEMENTS HEREIN MADE ARE SUBJECT TO THE PENALTIES OF 18 PA.C.S. SECTION 4904 RELATING TO UNSWORN FALSIFICATION TO AUTHORITIES. TURO LAW OFFICES "-Robert J. Mu~erig, EsqUire''-~ 28 South Pitt Street Carlisle, PA 17013 (717) 245-9688 Attorney for Plaintiff rn Postage Certified Fee Return Receipt Fee (Endorsement Required) Restricted Delivery Fee (Endorsement Required) Total Postage & Fees $ Postmark SENDER' '1 c ' al~o wish to receive the follow- [] omplete items 1 and/or 2 for additional services, lng services (for an extra fee): Complete items 3, 4a, and 4b. [] Print your name and address on the reverse of this form so that we can return this J , card to you. I 1. [] Addressee s A{ddress [] Attach this form to the front of the ma p ece, or on the back if space does not / ~ ...... _..P?~nit'_ - I "" L_J Hestricteo uellvery [] wnte "Return Heceipt Requested' on the mailpiece below the ad cie number. [] The Retum Receipt will show to whom the article was delivered and the date delivered. !, 3. Article Addressed to: - , ................. ~oc:lean, Inc. 7001 2510 0009 2827 8356 4b. Service Type ! 5350 ['~o~~. 35'~'t AVCo [] Registered ~ii~'Certified ~, ~'~c. laurie=dale, :PA 33309 I ~ Express Mail ~ I~sur~ ~Retum Receipt for Memhandise 7. Date of Delive~ ~ _ ~ec~K"~Y~dnt~e' ~ J8. Addre~ee'sAddress(~lyif~est~and ~ 6.~gqature (A~ssee orAg~t) ~ ~ -- PS For~ 381 ~,~r 1~ l O2595-~-~23 ~0c R~rn R~pt SHERIFF'S RETURN CASE NO: 2003-01273 p COMMONWEALTH OF PENNSYLVANIA: COUNTY OF CUMBERLAND DOUBLE GOLD INC VS PUROFIRST INTERNATIONAL INC ET REGULAR ROBERT BITNER , Sheriff or Deputy Sheriff of Cumberland County, Pennsylvania, who being duly sworn according to law, says, the within COMPLAINT & NOTICE was served upon MILLER DAN the DEFENDANT at 220 FOX DRIVE at .1844:00 HOURS, on the ~7th day of March , 2003 MECHANICSBURG, PA 17055 by handing to ROBERT MILLER, VICE PRESIDENT ADULT IN CHARGE a true and attested copy of COMPLAINT & NOTICE together with and at the same time directing His attention to the contents thereof. Sheriff,s Costs: Docketing 18.00 Service 7.59 Affidavit .00 Surcharge 10.00 .00 35.59 Sworn and Subscribed to before me this /D~ day of ~Prothonot ary ' So Answers: R. Thomas Kline 03/31/2003 RON TURO By. ~ Deputy SK&~riff SHERIFF'S RETURN - REGULAR CASE NO: 2003-01273 p COMMONWEALTH OF PENNSYLVA/~IA: COUNTY OF CUMBERLAND DOUBLE GOLD INC VS PUROFIRST INTERNATIONAL INC ET ROBERT BITNER , Sheriff or Deputy Sheriff of Cumberland County, Pennsylvania, who being duly sworn according to law, says, the within COMPLAINT & NOTICE was served upon MILLER ROBERT the DEFENDANT at 220 FOX DRIVE at 1844:00 HOURS, on the 27th day of March , 2003 MECHANICSBURG, PA 17055 ROBERT MILLER by handing to a true and attested copy of COMPLAINT & NOTICE 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 /D ~ day of  ? ~ A.D. l~r6thonot ary So Answers: R. Thomas Kline 03/31/2003 RON TURO By- . } Deputy SHERIFF'S RETURN CASE NO: 2003-01273 p COMMONWEALTH OF PENNSYLVANIA: COUNTY OF CUMBERLAND DOUBLE GOLD INC VS PUROFIRST INTERNATIONAL INC ET REGULAR ROBERT BITNER , Sheriff or Deputy Sheriff of Cumberland County, Pennsylvania, who being duly sworn according to law, says, the within COMPLAINT & NOTICE was served upon MILLER MARY the DEFENDANT at 220 FOX DRIVE at 1844:00 HOURS, on the 27th day of March 2003 MECHANICSBURG, PA 17055 by handing to ROBERT MILLER, VICE PRESIDENT ADULT IN CHARGE a true and attested copy of COMPLAINT & NOTICE 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 /D ~ day of So Answers: 03/31/2003 RON TDRO .... SHERIFF'S RETURN - REGULAR CASE NO: 2003-01273 p COMMONWEALTH OF PENNSYLVANIA: COUNTY OF CUMBERLAND DOUBLE GOLD INC VS PUROFIRST INTERNATIONAL INC ET ROBERT BITNER , Sheriff or Deputy Sheriff of Cumberland County, Pennsylvania, who being duly sworn according to law, says, the within COMPLAINT & NOTICE was served upon PUROCLEAN OF SUSQUEHANNA VALLEY INC the DEFENDANT at 220 FOX DRIVE at 1844~00 HOURS, on the ~7th day of March , 2003 MECHANICSBURG, PA 17055 by handing to ROBERT MILLER, VICE PRESIDENT ADULT IN CHARGE a true and attested copy of COMPLAINT & NOTICE together with and at the same time directing Hi~s attention to the contents thereof. Sheriff,s Costs: Docketing 6.00 Service Affidavit .00 .00 Surcharge 10.00 .00 16.00 Sworn and Subscribed to before me this /D ~ day of A.D. P~othonotary ~ -/ So Answers: R. Thomas Kline " 03/31/2003 RON TURO 9puty Sheriff- Double Gold, Inc., Plaintiff, Ye Purofirst International, Inc., Puroclean, Inc. Puroclean of Susquehanna Valley, Inc., Dan Miller, Robert Miller, Mary Miller, Jospeh Scarlata and Bruce Vogt, Defendants. : IN THE COURT OF COMMON : PLEAS OF : CUMBERLAND COUNTY, : PENNSYLVANIA : : NO. 03-1273 : CIVIL ACTION -- LAW CIVIL TERM PRAECIPE TO ENTER APPEARANCE TO THEPROTHONOTARY: Kindly enter my appearance on behalf of all Defendants in the above-captioned matter. en BALL, MURREN & CONNELL 2303 Market Street Camp Hill, PA 17011 (717) 232-8731 Attorney for Defendants Double Gold, Inc., Plaintiff, Ye Purofirst International, Inc., Puroclean, Inc. Puroclean of Susquehanna Valley, Inc., Dan Miller, Robert Miller, Mary Miller, Jospeh Scarlata and Bruce Vogt, Defendants. : IN THE COURT OF COMMON PLEAS OF : CUMBERLAND COUNTY, PENNSYLVANIA : NO. 03-1273 CIVIL TERM : CIVIL ACTION -- LAW PRAECIPE TO SETTLE, DISCONTINUE AND END, WITH PREJUDICE TO THEPROTHONOTARY: Turo Law Offices 28 South Pitt Street Carlisle PA 17103 (717) 245-9688 Attorney for Plaintiff Kindly mark the above matter settled, discontinued and ended, with prejudice. Ball, Murren & Connell 2303 Market Street Camp Hill, PA 17011 (717) 232-8731 Attorney for Defendants