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HomeMy WebLinkAbout07-4938Johnson, Duffie, Stewart 8 Weidner By: John A. Statler, Esq. I.D. No. 43812 Wade D. Manley I.D. No. 87244 301 Market Street P. O. Box 109 Lemoyne, Pennsylvania 17043-0109 (717) 761-4540 wdm@jdsw.com JAMES E. GRANDON, JR., 901 Sleepy Hollow Road Mechanicsburg, PA 17055 and JIM-JAM, LLP, 380 Market Street Camp Hill, PA 17011 Plaintiff v. HEATHER SGRIGNOLI and ROBERT P. SGRIGNOLI, JR., her husband, 928 Kennedy Valley Road Landisburg, PA 17040 Defendants NOTICE TO DEFEND Attorneys for Plaintiff IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL ACTION -LAW JURY TRIAL DEMANDED 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 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 of any money claimed in the Complaint or 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, GO TO OR TELEPHONE THE OFFICE SET FORTH BELOW. THIS OFFICE CAN PROVIDE YOU WITH INFORMATION ABOUT HIRING A LAWYER. IF YOU CANNOT AFFORD TO HIRE A LAWYER, THIS OFFICE MAY BE ABLE TO PROVIDE YOU WITH INFORMATION ABOUT AGENCIES THAT MAY OFFER LEGAL SERVICES TO ELIGIBLE PERSONS AT A REDUCED FEE OR NO FEE. Cumberland County Bar Association 32 S. Bedford Street Carlisle, Pennsylvania 17013 Telephone: (717) 249-3166 EN LA CORTE DE ALEGATOS COMUN DEL CONDADO DE CUMBERLAND, PENNSYLVANIA DIVISION CIVIL AVISO PARR DEFENDER USTED HA SIDO DEMANDADO/A EN LA CORTE. Si usted desea defender. conta la demanda puestas en las siguientes paginas, usted tienen que tomar accion dentro veinte (20) dias despues que esta Demanda y Aviso es servido, con entrando por escrito una aparencia personalmente o por un abogado y archivando por escrito con la Corte sus defenses o objeciones a las demandas puestas en esta contra usted. Usted es advertido que si falla de hacerlo el caso puede proceder sin usted y un jazgamiento puede ser entrado contra usted por la Corte sin mas aviso por cualquier dinero reclamado en la Demanda o por cualquier otro reclamo o alivio solicitado por Demandante. Usted puede perder dinero o propiedad o otros derechos importante para usted. USTED DEBE LLEVAR ESTE PAPEL A SU ABOGADO ENSEGUIDA. SI USTED NO TIENE UN ABOGADO, VAYA O LLAME POR TELEFONO LA OFICINA FIJADA AQUI ABAJO. ESTA OFICINA PUEDE PROVEERE CON INFORMACION DE COMO CONSEGUIR UN ABOGADO. SI USTED NO PUEDE PAGARLE A UN ABOGADO, ESTA OFICINA PUEDE PROVEERE INFORMACION ACERCA AGENCIAS QUE PUEDAN OFRECER SERVICIOS LEGAL A PERSONAS ELIGIBLE AQ UN HONORARIO REDUCIDO O GRATIS. Cumberland County Bar Association 32 S. Bedford Street Carlisle, Pennsylvania 17013 Telephone: (717) 249-3166 Johnson, Duffie, Stewart 8~ Weidner By: John A. Statler, Esq. I.D. No. 43812 Wade D. Manley I.D. No. 87244 301 Market Street P. O. Box 109 Lemoyne, Pennsylvania 17043-0109 (717) 761-4540 wdm@jdsw.com JAMES E. GRANDON, JR., 901 Sleepy Hollow Road Mechanicsburg, PA 17055 and JIM-JAM, LLP, 380 Market Street Camp Hill, PA 17011 Plaintiff v. HEATHER SGRIGNOLI and ROBERT P. SGRIGNOLI, JR., her husband, 928 Kennedy Valley Road Landisburg, PA 17040 Defendants Attorneys for Plaintiff IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA NO. ~ 7- y~ ~p c-LacX ~lu~- CIVIL ACTION -LAW JURY TRIAL DEMANDED COMPLAINT AND NOW, come the Plaintiffs, James E. Grandon, Jr. and Jim-Jam, LLP, by and through their counsel, Johnson, Duffie, Stewart & Weidner, P.C., and file this Complaint, and in support thereof state as follows: 1. Plaintiff, James E. Grandon, Jr. ("Grandon"), is an adult individual with a residence located at 901 Sleepy Hollow Road, Mechanicsburg, PA 17055. 2. Plaintiff, Jim-Jam, LLP ("Jim-Jam"), is a Pennsylvania limited liability general partnership with a principal place of business located at 3913 Market Street, Camp Hill, PA 17011. 3. At all times relevant to plaintiffs' cause of action, Grandon was an active partner in Jim Jam. 4. Defendant, Heather Sgrignoli ("Sgrignoli"), is an adult individual with a residence located at 928 Kennedy Valley Road, Landisville, PA 17040. 5. Defendant, Robert P. Sgrignoli, Jr., is an adult individual with a residence located at 928 Kennedy Valley Road, Landisville, PA 17040. 6. On or about October, 1996, Sgrignoli entered into an employment arrangement with Grandon whereby Sgrignoli agreed to provide secretarial services for plaintiffs. Pursuant to this arrangement, Sgrignoli was compensated in the amount of $22,000 per year. A copy of the consulting agreement is attached as Exhibit "A." 7. As part of the aforesaid employment arrangement, Sgrignoli prepared, maintained and/or kept in her custody certain business records for plaintiffs, including but not limited to, financial statements, account and disbursement records, blank personal checks of Grandon, blank partnership checks for Jim-Jam, and other records and materials essential to the operation and financing of plaintiffs. Inasmuch as these records were prepared, maintained and/or kept by Sgrignoli in the course of her duties for Grandon, these records are the sole property of plaintiffs. 8. In connection with the aforesaid employment arrangement with Grandon, Sgrignoli maintained in her custody an undetermined number of blank personal checks of Grandon and blank partnership checks for Jim-Jam. These checks are the sole property of plaintiffs. 9. Sgrignoli continued in her capacity as an employee to Grandon for nine (9) years until October 30, 2006, at which time the employment arrangement was terminated. A letter from Grandon, notifying Sgrignoli of her termination as consultant is attached as Exhibit "B." 10. The employment arrangement was terminated as the result of Sgrignoli's breach of the employment agreement by embezzling in excess of $315,000 from Grandon's personal accounts and in excess of $85,000 from Jim-Jam's partnership account. 11. Grandon depended upon Sgrignoli to handle Grandon's personal banking matters and Jim-Jam's partnership matters 12. Grandon assisted Sgrignoli's husband, defendant, Robert P. Sgrignoli, Jr. secure a loan with M&T Bank when the business he operated was in financial difficulty. 13. Bank accounts from Grandon's personal bank account and Jim-Jam's partnership bank account show numerous checks were written from these accounts by Sgrignoli and made payable to M&T Bank to make payments on the loan for defendant, Robert P. Sgrignoli. 14. Upon information and belief, defendant, Robert P. Sgrignoli, Jr., knew, participated, conspired and obtained the benefit of the embezzlement actions of Sgrignoli. 15. Bank accounts from Grandon's personal bank account and Jim-Jam's partnership bank account show numerous checks were written from these accounts by Sgrignoli to support a lavish lifestyle that included the purchase of luxuries such as a Mercedes, a swimming pool and make payments on defendants' credit cards. 16. As the direct and proximate result of Sgrignoli's actions and Robert P. Sgrignoli, Jr.'s, knowledge, participation, conspiracy in and receipt of benefit of the embezzlement actions of Sgrignoli, plaintiffs have sustained financial losses in excess of $315,000 from Grandon's personal accounts and in excess of $85,000 from Jim-Jam's partnership account. 17. Upon information and belief, defendants have misappropriated and used for their own purposes certain amounts of the funds embezzled from plaintiffs. 18. The conduct of defendants, as set forth above, was outrageous, intentional, malicious, willful and in blatant disregard for the rights of plaintiffs. 19. As a result of said conduct, defendants are liable to plaintiffs for punitive damages. COUNT ~-CONVERSION Plaintiffs v. Heather Sgrignoli 20. Plaintiffs incorporate herein by reference each allegation contained in paragraphs 1 - 19, as though the same were set forth at length. 21. Sgrignoli knowingly and without plaintiffs' consent embezzled in excess of $315,000 from Grandon's personal accounts and in excess of $85,000 from Jim-Jam's partnership account. 22. Without the aforesaid funds, Sgrignoli has caused immediate and irreparable harm to plaintiffs' personal financial account, business accounts and business future. 23. Sgrignoli also has knowingly and without justification retained funds and used plaintiffs' funds to acquire goods and services and has refused and/or been unable to return the funds despite plaintiffs' repeated demands that she do so. 24. As the direct and proximate result of Sgrignoli's actions as aforesaid, plaintiffs have suffered and are continuing to suffer immediate and irreparable harm, and have sustained financial losses in excess of $315,000 from Grandon's personal accounts and in excess of $85,000 from Jim-Jam's partnership account. WHEREFORE, plaintiffs demands judgment against Defendant, Heather Sgrignoli, in an amount in excess of the compulsory arbitration amount directed by local rule, and the imposition of punitive damages. COUNT IF-CONVERSION Plaintiffs v. Robert P. SQri_anoli, Jr. 25. Plaintiffs incorporate herein by reference each allegation contained in paragraphs 1 - 24, as though the same were set forth at length. 26. Sgrignoli knowingly and without plaintiffs' consent embezzled in excess of $315,000 from Grandon's personal accounts and in excess of $85,000 from Jim-Jam's partnership account. 27. Plaintiffs have repeatedly made demands upon Sgrignoli to return the aforesaid funds, and Sgrignoli has repeatedly refused to do so. 28. Without the aforesaid funds, Sgrignoli has caused immediate and irreparable harm to plaintiffs' personal financial account, business accounts and business future. 29. Sgrignoli also has knowingly and without justification retained funds and used plaintiffs' funds to acquire goods and services and has refused and/or been unable to return the funds despite plaintiffs' repeated demands that she do so. 30. Upon knowledge and belief, defendant, Robert P. Sgrignoli, Jr., knew, participated, conspired and obtained the benefit of the embezzlement actions of Sgrignoli. 31. As the direct and proximate result of defendant, Robert P. Sgrignoli, Jr.'s, actions as aforesaid, plaintiffs have suffered -and are continuing to suffer immediate and irreparable harm, and have sustained financial losses in excess of $315,000 from Grandon's personal accounts and in excess of $85,000 from Jim-Jam's partnership account. WHEREFORE, plaintiffs demands judgment against Defendant, Robert P. Sgrignoli, Jr., in an amount in excess of the compulsory arbitration amount directed by local rule, and the imposition of punitive damages. COUNT 111-BREACH OF FIDUCIARY DUTY AND MISAPPROPRIATION OF FUNDS Plaintiffs v. Heather SQri_anoli 32. Plaintiffs incorporate herein by reference each allegation contained in paragraphs 1-31, as though the same were set forth at length. 33. By virtue of her relation to Crandon, Sgrignoli owed plaintiffs a fiduciary duty. 34. Upon information and belief, Sgrignoli misappropriated and used for her and her husband's own purposes funds which were advanced and entrusted to her by the plaintiffs, and which were to be used solely in connection with Sgrignoli's work for plaintiffs. 35. As the direct and proximate result of Sgrignoli's actions, plaintiffs have suffered immediate and irreparable harm, and have sustained financial losses in excess of $315,000 from Grandon's personal accounts and in excess of $85,000 from Jim-Jam's partnership account. WHEREFORE, plaintiffs demands judgment against Defendant, Heather Sgrignoli, in an amount in excess of the compulsory arbitration amount directed by local rule, and the imposition of punitive damages. COUNT IV-UNJUST ENRICHMENT Plaintiffs v. Heather SQriarnoli 36. Plaintiffs incorporate herein by reference each allegation contained in paragraphs 1-35, as though the same were set forth at length. 37. Sgrignoli's theft of plaintiffs' personal and business funds, retention and/or conversion of those funds for personal gain constitutes a failure to properly give plaintiffs restitution for property and/or benefits received and Sgrignoli has been unjustly enriched at the expense of plaintiffs. 38. Sgrignoli's .actions constitute an unjust retention of a benefit to the loss of plaintiffs, and Sgrignoli's retention of money and property are against the fundamental principles of justice and good conscience and are patently unfair. 39. As a direct and proximate result of Sgrignoli's unjust retention of the plaintiffs' tangible and intangible property and the proceeds therefrom, plaintiffs have suffered and continue to suffer serious financial injury and inequities that have resulted in substantial damages. WHEREFORE, plaintiffs demands judgment against Defendant, Heather Sgrignoli, in an amount in excess of the compulsory arbitration amount directed by local rule, and the imposition of punitive damages. COUNT V-UNJUST ENRICHMENT Plaintiffs v Robert P. Sgrignoli, Jr. 40. Plaintiffs incorporate herein by reference each allegation contained in paragraphs 1-39, as though the same were set forth at length. 41. Sgrignoli's theft of plaintiffs' personal and business funds, retention and/or conversion of those funds for personal gain and defendant, Robert P. Sgrignoli, Jr.'s knowledge, participation, conspiracy and receipt of the benefit of the embezzlement actions of Sgrignoli constitute a failure to properly give plaintiffs restitution for property and/or benefits received and defendant, Robert P. Sgrignoli, Jr. has been unjustly enriched at the expense of plaintiffs. 42. Robert P. Sgrignoli, Jr.'s actions constitute an unjust retention of a benefit to the loss of plaintiffs, and the Robert P. Sgrignoli, Jr.'s retention of money and property are against the fundamental principles of justice and good conscience and are patently unfair. 43. As a direct and proximate result of Robert P. Sgrignoli, Jr.'s unjust retention of the plaintiffs' tangible and intangible property and the proceeds therefrom, plaintiffs have suffered and continue to suffer serious financial injury and inequities that have resulted in substantial damages. WHEREFORE, plaintiffs demands judgment against Defendant, Robert P. Sgrignoli, Jr., in an amount in excess of the compulsory arbitration amount directed by local rule, and the imposition of punitive damages. COUNT V1~FRAUD Plaintiffs v. Heather Sgrignoli 44. Plaintiffs incorporate herein by reference each allegation contained in paragraphs 1-43, as though the same were set forth at length. 45. In the performance of her duties for Crandon, Sgrignoli represented to Grandon either in writing or orally that the funds and accounting in the personal bank account and partnership bank account were being used for Grandon's personal use or Jim-Jam's business purposes, and that the written accounting for the bank accounts accurately portrayed the receipt and disbursement of funds from those accounts. 46. The representations were made with the intent to induce plaintiffs to allow Sgrignoli to author checks from these accounts which Sgrignoli did to pay funds to Sgrignoli or for the benefit of Sgrignoli and her husband. 47. Plaintiffs believe, and therefore avers, that such representations were materially false as plaintiffs discovered Sgrignoli authored checks from Grandon's personal bank account and Jim-Jam's business bank account which Sgrignoli did use to pay funds to Sgrignoli or for the benefit of Sgrignoli and her husband. 48. Sgrignoli made the representations to plaintiffs with actual knowledge of their falsity at the time they were made, or in reckless disregard of their truth or falsity. 49. In justifiable reliance upon the material misrepresentations of Sgrignoli, plaintiffs allowed Sgrignoli authored checks from Grandon's personal bank account and Jim-Jam's business bank account which Sgrignoli did use to pay funds to Sgrignoli or for the benefit of Sgrignoli and her husband. 50. As a result of the misrepresentations of Sgrignoli, plaintiffs have sustained financial losses in excess of $315,000 from Grandon's personal accounts and in excess of $85,000 from Jim-Jam's partnership account. WHEREFORE, plaintiffs demands judgment against Defendant, Heather Sgrignoli, in an amount in excess of the compulsory arbitration amount directed by local rule, and the imposition of punitive damages. COUNT VI~CONSP/RACY Plaintiffs v. Heather SQri_gnoli 51. Plaintiffs incorporate herein by reference each allegation contained in paragraphs 1-50, as though the same were set forth at length. 52. Sgrignoli committed an unlawful act of theft by unlawful taking, embezzlement, conversion and/or misappropriation of funds when she write numerous checks from Grandon's personal bank account and Jim-Jam's partnership bank account for her personal use and the personal use of her husband, Robert P. Sgrignoli, Jr. 53. Sgrignoli wrote numerous checks from Grandon's personal bank account and Jim-Jam's partnership bank account specifically for the purpose of making a loan payment for the business of her husband, Robert P. Sgrignoli, Jr. 54. Upon information and belief, Sgrignoli combined with and/or entered into an unlawful agreement with her husband, defendant, Robert P. Sgrignoli, Jr., to commit an unlawful act of theft by unlawful taking, embezzlement, conversion and/or misappropriation of funds when she write numerous checks from Grandon's personal bank account and Jim-Jam's partnership bank account for her personal use and the personal use of her husband, Robert P. Sgrignoli, Jr. 55. Upon information and belief, Sgrignoli combined with and/or entered into an unlawful agreement with her husband, defendant, Robert P. Sgrignoli, Jr., to commit an unlawful act of theft by unlawful taking, embezzlement, conversion and/or misappropriation of funds by writing numerous checks from Grandon's personal bank account and Jim-Jam's partnership bank account for the purpose of making a loan payment for the business of her husband, Robert P. Sgrignoli, Jr. 56. Upon information and belief, Sgrignoli conspired with her husband, defendant, Robert P. Sgrignoli, Jr., to commit an unlawful act of theft by unlawful taking, embezzlement, conversion and/or misappropriation of funds by writing numerous checks from Grandon's personal bank account and Jim-Jam's partnership bank account for her personal use and the personal use of her husband, Robert P. Sgrignoli, Jr. and specifically for the purpose of making a loan payment for the business of her husband, Robert P. Sgrignoli, Jr. WHEREFORE, plaintiffs demands judgment against Defendant, Heather Sgrignoli, in an amount in excess of the compulsory arbitration amount directed by local rule, and the imposition of punitive damages. COUNT V11~--CONSPIRACY Plaintiffs v Robert P. S_ari_gnoli, Jr. 57. Plaintiffs incorporate herein by reference each allegation contained in paragraphs 1-56, as though the same were set forth at length. 58. Sgrignoli committed an unlawful act of theft by unlawful taking, embezzlement, conversion and/or misappropriation of funds when she write numerous checks from Grandon's personal bank account and Jim-Jam's partnership bank account for her personal use and the personal use of her husband, Robert P. Sgrignoli, Jr. 59. Sgrignoli wrote numerous checks from Grandon's personal bank account and Jim-Jam's partnership bank account specifically for the purpose of making a loan payment for the business of her husband, Robert P. Sgrignoli, Jr. 60. Upon information and belief, defendant, Robert P. Sgrignoli, Jr., combined with and/or entered into an unlawful agreement with his wife, defendant, Heather Sgrignoli, to commit an unlawful act of theft by unlawful taking, embezzlement, conversion and/or misappropriation of funds when she write numerous checks from Grandon's personal bank account and Jim-Jam's partnership bank account for Sgrignoli's personal use and his personal use. 61. Upon information and belief, Robert P. Sgrignoli, Jr., combined with and/or entered into an unlawful agreement with his wife, defendant, Heather Sgrignoli, to commit an unlawful act of theft by unlawful taking, embezzlement, conversion and/or misappropriation of funds by writing numerous checks from Grandon's personal bank account and Jim-Jam's partnership bank account for the purpose of making a loan payment for his business. 62. Upon information and belief, Robert P. Sgrignoli, Jr., conspired with his wife, defendant, Heather Sgrignoli, to commit an unlawful act of theft by unlawful taking, embezzlement, conversion and/or misappropriation of funds by writing numerous checks from Grandon's personal bank account and Jim-Jam's partnership bank account for his personal use and the personal use of his wife, defendant, Heather Sgrignoli, and specifically for the purpose of making a loan payment for his business. WHEREFORE, plaintiffs demands judgment against Defendant, Robert P. Sgrignoli, Jr., in an amount in excess of the compulsory arbitration amount directed by local rule, and the imposition of punitive damages. JOHNSON, DUFFIE, STEWART & WEIDNER B : "-~ Y John A. tatl r, sq. I.D. No. 438 2 Wade D. Ma I. D. No. 87244 301 Market Street P. O. Box 109 Lemoyne, PA 17043-0109 (717) 761-4540 Attorneys for Plaintiff Date: ~ ~(?(a 7 :307050 7123-38 VERIFICATION I, James E. Crandon, Jr., verify that I am authorized to execute the foregoing document on behalf of Jim-Jam, LLP, and in that capacity I confirm that the facts set forth in the foregoing Complaint are true and correct. This verification is made subject to the penalties of 18 Pa.C.S.A. §4904, relating to unsworn falsifications to authorities. Date: JIM-JAM, LLP VERIFICATION I, James E. Crandon, Jr., that the facts set forth in the foregoing Complaint are true and correct. This verification is made subject to the penalties of 18 Pa.C.S.A. §4904, relating to unsworn falsifications to authorities. Date: ~ ~ ~~_ N ~:~ //--~~ ~.-J 7I ~ V ~ ~ jt t_ _!' "I'e .. ~ '"f `, ~_~ _ ~ ! ~~ ~ ~ ~ ~ D I ~ f_~ -r~ _~ G} C~ Jil~ a `~. `~ BOYLE &WENGER Dennis E. Boyle, Esquire Supreme Court I.D. No. 49618 Laurence C. Kress, Esquire Supreme Court I.D. No. 93137 1525 Cedar Cliff Drive Camp Hill, PA 17011 Counsel For: Robert P. Sgrignoli, Jr. Phone: (717) 737-2430 Facsimile: (717) 737-2452 Email: debovlelu~dennisbovlelaw.com lckress aC7dennisbovlelaw.com JAMES E. GRANDON, JR. and JIM-JAM, LLP, Plaintiffs v. HEATHER SGRIGNOLI and ROBERT P. SGRIGNOLI, JR., her husband IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PA 07-4938 Civil Term JURY TRIAL DEMANDED PRAECIPE FOR ENTRY OF APPEARANCE TO THE PROTHONOTARY: Please enter the appearance of Dennis E. Boyle, Esquire, Laurence C. Kress, Esquire, and the firm of Boyle & Wenger, as counsel on behalf of the Defendant, Robert P. Sgrignoli, Jr. BOYLE &WENGER Dated: September ~, 2007 Dennis E. ,Esquire Supreme Court I.D. No. 49618 Laurence C. Kress, Esquire Supreme Court I.D. No. 93137 Counsel For: Robert G. Sgrignoli, Jr. 1 .~ CERTIFICATE OF SERVICE I hereby certify that on the date written below, a true and correct copy of the Answer to Complaint were served by United States First Class Mail, postage pre-paid, upon those person(s) listed below: John A. Statler, Esquire Wade D. Manley, Esquire Johnson, Duffle, Stewart & Weidner 301 Market Street P. O. Box 109 Lemoyne, PA 17043-0109 !'N Mary u Egan Dated: September, 2007 2 -rt ~ c; ~ to ~r~_ rn rvt~ <- ~ ~,,..3.7 ~a ~ G ~ W ~l Q r ~~, BOYLE & WENGER Dennis E. Boyle, Esquire Supreme Court I.D. No. 49618 Laurence C. Kress, Esqufre Supreme Court I.D. No. 93137 1525 Cedar Cliff Drive Camp Hill, PA 17011 Phone: (717) 737-2430 Facsimile: (717) 737-2452 Email: deboyleCa~dennisboylelaw.com lckress ,dennisboylelaw.com JAMES E. GRANDON, JR. and JIM-JAM, LLP, Plaintiffs v. HEATHER SGRIGNOLI and ROBERT P. SGRIGNOLI, JR., her husband Counsel For: Robert P. Sgrignoli, Jr. IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PA 07-4938 Civil Term JURY TRIAL DEMANDED ANSWER OF DEFENDANT ROBERT P. SGRIGNOLI JR TO COMPLAINT AND NOW comes the Defendant, Robert P. Sgrignoli, Jr., (hereinafter "Sgrignoli") by and through his counsel, Dennis E. Boyle, Esquire, and Laurence C. Kress, Esquire, and Boyle & Wenger, and submits the following Answer to Plaintiffs' Complaint as follows: 1. Admitted. 2. Admitted. 3. Admitted. 4. Denied. It is believed, and therefore averred, that Heather Sgrignoli (hereinafter "Heather"), is currently incarcerated in a Pennsylvania State Prison facility. 5. Admitted. ~ a r 6. Denied. Defendant Sgrignoli is without sufficient knowledge as to form a belief as to the truth of the averments. By way of further answer, Exhibit "A" is a document that speaks for itself. 7. Denied. Defendant is without sufficient knowledge as to form a belief as to the truth of the averments. By way of further answer, Defendant Sgrignoli was not a party to the employment relationship between Heather and Plaintiffs. 8. Denied. Defendant is without sufficient knowledge as to form a belief as to the truth of the averments. Byway of further answer, Defendant Sgrignoli incorporates his answer to paragraph 7 above. 9. Denied in accordance with pazagraphs 7 and 8 above which aze incorporated herein by reference. 10. Admitted in part, denied in part. It is admitted that Heather's employment arrangement was terminated. Defendant Sgrignoli is without sufficient knowledge as to form a belief as to the truth of the averment regazding the reasons for Plaintiffs' termination of Heather or the amounts of any alleged loss, if any at all, as those aze matters exclusively within the control of Plaintiffs. 11. Denied. Defendant is without sufficient knowledge as to form a belief as to the truth of the averment. 12. Denied. It is admitted that Defendant Sgrignoli sought advice from Crandon and that Crandon recommended a loan. It is also only admitted that Defendant Sgrignoli did, in fact, obtain a loan from M&T Bank. 2 ~. 13. Denied. It is specifically denied that any funds from Crandon or Jim-Jam were used to pay for Defendant Sgrignoli's business loan. 14. Denied. Defendant Sgrignoli had no knowledge of Heather's activities while employed by Plaintiffs and did not obtain any benefits from Heather's activities. 15. Denied. Defendant Sgrignoli specifically denies that characterization of their lifestyle as "lavish". By way of further answer, Defendant Sgrignoli is without knowledge of Heather's use of banks or what bank records may or may not demonstrate. By way of fiu~ther answer, it is believed that income from Sgrignoli's business as well as Heather's legitimate income were sufficient to support Sgrignoli's lifestyle. 16. Denied. It is specifically denied that there was a conspiracy between Heather and Defendant Sgrignoli or that Defendant Sgrignoli had knowledge of or participated in any activities of Heather. By way of further answer, Heather acted alone, without the knowledge of Defendant Sgrignoli. 17. Denied. It is specifically denied that Defendant Sgrignoli obtained or used any of Plaintiffs' funds for his own purposes or received any benefit from these funds. 18. Paragraph 18 is a conclusion of law to which no response is required. To the extent the paragraph constitutes a factual averment, it is specifically denied that Defendant Sgrignoli was involved in any conduct that could subject him to civil liability let alone punitive damages. 19. Denied. By way of further answer, Defendant Sgrignoli incorporates his answer to paragraph 18 above. ~. Count I 20-24. These paragraphs are directed to a party other than the answering Defendant. Count II 25. See Defendant's answers as to paragraphs 1 through 24 above. 26. Denied. It is specifically denied that Defendant Sgrignoli embezzled any funds belonging to Plaintiffs or to anyone else. To the contrary, Defendant Sgrignoli has been a law abiding citizen. 27. Denied. It is specifically denied that Defendant Sgrignoli has any funds belonging to Plaintiffs or any legal obligation to return funds. 28. Denied. By way of further answer, Defendant Sgrignoli incorporates his answer to paragraph 27 above. 29. Denied. By way of further answer, Defendant Sgrignoli incorporates his answer to paragraph 27 above. 30. Denied. Defendant Sgrignoli did not receive any benefit from any funds lawfully belonging to Plaintiffs. 31. Denied. By way of further answer, Defendant Sgrignoli incorporates his answer to paragraph 27 above. WHEREFORE, Robert P. Sgrignoli, Jr. demands judgment in his favor and against the Plaintiffs. Counts III and IV 32.-39. These paragraphs are directed to a party other than the answering Defendant. 4 Count V 40. See Defendant's answers to pazagraphs 1 through 39 above. 41. Denied as a conclusion of law. To the extent paragraph 41 constitutes an averment of fact, Defendant Sgrignoli incorporates by reference his responses to pazagraphs 1 through 19 and 25 through 31 above. 42. Denied as a conclusion of law. To the extent pazagraph 41 constitutes an averment of fact, Defendant Sgrignoli incorporates by reference his responses to paragraphs 1 through 19 and 25 through 31 above. 43. Denied as a conclusion of law. To the extent paragraph 41 constitutes an averment of fact, Defendant Sgrignoli incorporates by reference his responses to pazagraphs 1 through 19 and 25 through 31 above. WHEREFORE, Robert P. Sgrignoli, Jr. demands judgment in his favor and against the Plaintiffs. Counts VI and VII 44.-56. These pazagraphs aze directed to a party other than the answering Defendant. Count VIII 57. See Defendant's answers to paragraphs 1 through 56 above. 58. Denied. Pazagraph 58 constitutes a conclusion of law to which no response is necessary. To the extent paragraph 58 constitutes an averment of fact, Defendant Sgrignoli is without knowledge of Heather's actions and did not participate in said actions. 5 59. Denied. By way of further answer, Defendant Sgrignoli incorporates his answers to paragraphs 12 and 13 above. 60. Denied. Paragraph 60 is a conclusion of law to which no response is necessary. By way of further answer, Defendant Sgrignoli had no knowledge of and no involvement in any action by Heather concerning Plaintiffs' funds. 61. Denied. Paragraph 61 is a conclusion of law to which no response is necessary. By way of further answer, Defendant Sgrignoli had no knowledge of and no involvement in any action by Heather concerning Plaintiffs' funds. 62. Denied. Paragraph 62 is a conclusion of law to which no response is necessary. By way of further answer, Defendant Sgrignoli had no knowledge of and no involvement in any action by Heather concerning Plaintiffs' funds. WHEREFORE, the Defendant Robert P. Sgrignoli, Jr. requests this Honorable Court enter judgment in his favor and against the Plaintiffs. BOYLE & WENGER BY~ 1--~~rs..~rs' G i~u~•/~D ennis E. Boyle, Esquire Supreme Court I.D. No. 49618 Laurence C. Kress, Esquire Supreme Court I.D. No. 93137 1525 Cedar Cliff Drive Dated: September~Q, 2007 Camp Hill, FA 17011 Phone: (717) 737-2430 Facsimile: (717) 737-2452 Email: deboylena,dennisboylelaw.com lckressna.dennisbovlelaw.com Counsel for Robert P. Sgrignoli, Jr. 6 VERIFICATION I, Robert P. Sgrignoli, Jr., make the following statements subject to the penalties of 18 Pa.C.S. § 4904, relating to unsworn falsifications to authority, and do hereby state that the facts set forth in the foregoing Answer to Complaint are true and correct to the best of my knowledge, information and belief. Robert P. Sgri h, Dated: September ~, 2007 7 .' CERTIFICATE OF SERVICE I hereby certify that on the date written below, a true and correct copy of the Answer to Complaint were served by United States Fast Class Mail, postage pre-paid, upon those person(s) listed below: John A. Statler, Esquire Wade D. Manley, Esquire Johnson, Duffle, Stewart & Weidner 301 Market Street P. O. Box 109 Lemoyne, PA 17043-0109 Dated: Septembero~ G , 2007 8 t7 n ~ _ ter; r'7"t ' ' r `_~ ; ;:. f t = FV ~ ~-' O ~ ~-- ~ t> "~ .. t,Q C~ , "~- -+~ --~ GJ _ ~ O Johnson, DufTe, Stewart & Weidner By: John A. Statler, Esq. I.D.. No. 43812 Wade D. Manley, Esquire I.D. No. 87244 301 Market Street P. O. Box 109 Lemoyne, Pennsylvania 17043-0109 (717) 761-4540 Attorneys for Plaintiff JAMES E. GRANDON, JR., and JIM-JAM, LLP, Plaintiffs vs. IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA CIVIL ACTION -LAW NO. 07-4938 CIVIL TERM HEATHER SGRIGNOLI and ROBERT P. :JURY TRIAL DEMANDED SGRIGNOLI, JR., her husband, Defendants PRAEC/PE TO THE PROTHONOTARY OF CUMBERLAND COUNTY: In the above-captioned matter, please reinstate the Complaint filed at the Cumberland County Courthouse on August 20, 2007. Respectfully submitted, JOHNSON, DUFFIE, STEWART & WEIDNER UV By: Wa a Ma ey, Esq. Date: ~ J t ~ ~ D :311987 ~'- CERTIFICATE OF SERVICE AND NOW, this ~'-eFay of October, 2007, the undersigned does hereby certify that she did this date serve a copy of the foregoing document upon the other parties of record by causing same to be deposited in the United States Mail, first class postage prepaid, at Lemoyne, Pennsylvania, addressed as follows: Heather Sgrignoli SCI -Muncy P. O. Box 180 Muncy, PA 17756 Robert P. Sgrignoli, Jr. 928 Kennedy Valley Road Landisburg, PA 17040 JOHNSO UFFIE, ST ART & WEIDNER By: C een S. Jense ~°v ~ ~: o ~ - '~ --t? ~.,: ~ ~~ ~., ~ - ~ r ~ n rte-' tr ~' TC7 j~' O ~'' r, t..~ - .^- ~ -c ~ 9y o ~ ~° ~ 't c_r: y SHERIFF'S RETURN - NOT FOUND ~3ASE NO: 2007-04938 P ~„ COMMONTWEALTH OF PENNSYLVANIA COUNTY OF CUMBERLAND GRANDON JAMES E JR ET AL VS SGRIGNOLI HEATHER ET AL R. Thomas Kline ,Sheriff or Deputy Sheriff, who being duly sworn according to law, says, that he made a diligent search and inquiry for the within named DEFENDANT SGRIGNOLI HEATHER but was unable to locate Her COMPLAINT & NOTICE in his bailiwick. He therefore returns the the within named DEFENDANT NOT FOUND as to SGRIGNOLI HEATHER CUMBERLAND COUNTY PRISON 1101 CLAREMONT ROAD CARLISLE, PA 17013 DEFENDANT IS NOT IN CUMBERLAND COUNTY PRISON. Sheriff's Costs: Docketing 18.00 Service 4.80 Not Found 5.00 Surcharge 10.00 So a rs: R. Thomas Kline ~ e ff of Cumberland County HNSON DUFFIE STEWART WEIDNER 11/19/2007 Sworn and Subscribed to before me this day of A.D. SHERIFF'S RETURN - OUT OF COUNTY CEASE NO: 2007-04938 P y COMMONWEALTH OF PENNSYLVANIA: COUNTY OF CUMBERLAND GRANDON JAMES E JR ET AL VS SGRIGNOLI HEATHER ET AL R. Thomas Kline duly sworn according to law, says, that he made a diligent search and and inquiry for the within named DEFENDANT to wit: SGRIGNOLI HEATHER but was unable to locate Her Sheriff or Deputy Sheriff who being in his bailiwick. He therefore deputized the sheriff of LYCOMING serve the within COMPLAINT & NnTTCF County, Pennsylvania, to On November 19th 2007 this office was in receipt of the attached return from LYCOMING Sheriff's Costs: Docketing Out of County Surcharge Postage So 6.00 9.00 10.00 ~~ R. 7 . 97 ~kiex .00 2 5. 9 7 / ~,., ~~/a.9 0 7 11/19/2007 ~ JOHNSON DUFFIE STEWART Sworn and subscribe to before me this day of dmas Kline ff of Cumberland County A.D. SHERIFF'S RETURN - OUT OF COUNTY CASE NO: 2007-04938 P COMMONWEALTH OF PENNSYLVANIA: COUNTY OF CUMBERLAND GRANDON JAMES E JR ET AL VS SGRIGNOLI HEATHER ET AL R. Thomas Kline Sheriff or Deputy Sheriff who being duly sworn according to law, says, that he made a diligent search and and inquiry for the within named DEFENDANT to wit: SGRIGNOLI ROBERT P JR but was unable to locate Him deputized the sheriff of PERRY in his bailiwick. He therefore serve the within COMPLAINT & NOTICE County, Pennsylvania, to On November 19th 2007 this office was in receipt of the attached return from PERRY Sheriff's Costs: So arLS~~rs Docketing 6.00 Out of County 9.00 Surcharge 10.00 ~ R. Dep Perry County 32.70 ~ e Postage 1.55 59.25 ~ ~ ~~ .2 11/19/2007 JOHNSON DUFFIE STEWART Sworn and subscribe to before me this day of omas ~4~.-ine iff of Cumberland County ~lD~ A.D. -In Tl~e Court of Common Pleas of Cumberland County, Pennsylvania James E. Grandon, Jr. et al vs. Heather Sgrignoli et al Serve: Heather Sgrignoli No. 2007-4938 Civil Term Now, August 31, 2007, I, SHERIFF OF CUMBERLAND COUNTY, PA, do hereby deputize the Sheriff of LycomingCounty to execute this Writ, this deputation being made at the request and risk of the Plaintiff. ~'.~ ~~ Sheriff of Cumberland County, PA Affidavit of Service NOW, NOVEMBER 1, , 20 07 , at 10:45 O'C10Ck A. M, served the within REINSTATED COMPLAINT upon HEATHER SGRIGNOLI, INMATE ~~OM1005 at S.C.I., MUNCY, BOX 180, ROUTE 405, MUNCY, PA., by handing to HER PERSONALLY a TRUE AND ATTESTED copy of the original COMPLAINT and made known to xER the contents thereof. So answers, Sworn and subscribed before me this 13 day of Novembe~p 07 ~y'w~a~9 ~~ ~0 t,~V~ill~ll a~F1 M.,4~` ~ 3i~. ~r 6:'oref^ ~l `~~1 ~u _ A, Sheriff of ~LYCOMING COSTS SERVICE_ MILEAGE_ AFFIDAVIT ~ f'°"„ry, BY is ;/.._~ $ 18.00 6.50 2.50 Timothy B. Nelson Deputy $ 27.00 PAID -fin The Court of Common Pleas of Cumberland County, Pennsylvania James E. Crandon Jr At al VS. HeathAr Sgrignoli et al SERVE: Robert P. Sgrignoli Jr No. 07-4938 civil Now, August 22, 2007 , I, SHERIFF OF CUMBERLAND COUNTY, PA, do hereby deputize the Sheriff of P°~' County to execute this Writ, this deputation being made at the request and risk of the Plaintiff. Sheriff of Cumberland County, PA Please mail return of service to Cumberland County Sheriff. Thank you. Affidavit of Service Now, August 2 4 , 20 0 7 , at 1 0 :1 9 o'clock A M. served the within Notice & Complaint upon Robert P. Sgrignoli,Jr. at_ 928 KennedyVAlley Rd. Landisbur , Pa. 17040(Tyrone Tw ) by handing to Cari Sgrignoli, Defendants Daughter-Person in Charge a True & Attested and made known to Her copy of the original Notice & Complaint So answers, the contents thereof. Donald E. Smith Chief Dep. Sheriff of Perry County, PA Sworn and subscribed before me this 2 ~ day of ~g~, 20 ~ ~ V NOTARIAL SEAL MARGARET F. fLICKINGER, NOTARY PUBLIC BLOOMfIELO BORO., PERRY COUNTY MY COMMISSION EXPIRES FEB.16, 2008 COSTS SERVICE _ MILEAGE _ AFFIDAVIT Johnson, Duffie, Stewart ~ Weidner By: John A. Statler, Esquire I.D. No. 43812 Wade D. Manley, Esquire !. D. No. 87244 301 Market Street P. O. Box 109 Lemoyne, Pennsylvania 17043-0109 (717) 761-4540 wdm~jdsw.com JAMES E. GRANDON, JR. and JIM-JAM, LLP, Plaintiffs v. Attorneys for Plaintiffs IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA NO. 07-4938 CIVIL ACTION -LAW HEATHER SGRIGNOLI and JURY TRIAL DEMANDED ROBERT P. SGRIGNOLI, her husband, Defendants PRAECIPE FOR DEFAULT JUDGMENT TO THE PROTHONOTARY: Please enter judgment by default in favor of the Plaintiffs, and against the Defendant, HEATHER SGRIGNOLI, by reason of the failure of the Defendant to enter an appearance or to file an Answer within 20 days of the date of service of the Complaint endorsed with a Notice to Defend, and assess the Plaintiffs damages as follows: Principal Amount $401,255.23 Total $401,255.23 together with judgment interest and attorney fees and costs, as may be determined. I hereby certify that written notice of intention to file this Praecipe was mailed to the Defendant, Heather Sgrignoli, at SCI Cambridge Springs, 451 Fullerton Avenue, Cambridge Springs, PA 16403-1238, on July 1, 2008; said notice being mailed after the default occurred and at least ten (10) days prior to the date of the filing of this Praecipe. A true and correct copy of the aforesaid notice, together with receipt for mailing, are attached hereto as Exhibit "A" and made a part hereof. Respectfully submitted, JOHNSON, DUFFIE, STEWART & WEIDNER By: ~ " Dated: July 11, 2008 Wade . Ma e Attorney I . D. .87244 JUDGMENT AND NOW, this ___1___ day of 2008, judgment in the amount of $401,255.23, together with judgment, interest, and attorney fees and costs, as may be determined, is entered in favor of Plaintiffs, James E. Crandon, Jr. and Jim-Jam, LLP, and against Defendant, Heather Sgrignoli, as directed above. Prothonotary :338206 CERTIFICATE OF SERVICE AND NOW, this ~,~~day of July, 2008, the undersigned does hereby certify that she did this date serve a copy of the foregoing document upon the other parties of record by causing same to be deposited in the United States Mail, first class postage prepaid, and via Certified Mail at Lemoyne, Pennsylvania, addressed as follows: Heather Sgrignoli SCI Cambridge Springs 451 Fullerton Avenue Cambridge Springs, PA 16403-1238 Dennis Boyle, Esquire Boyle Law Offices 1525 Cedar Cliff Drive Camp Hill, PA 17011 JOHNSON, DUFFIE, STEWART & WEIDNER By: ' helle Spangler EXHIBIT A ' JERRY R. DUFFIE RICHARD W. STEWART C. ROY WEIDNER, JR. EDMUND G. MYERS DAVID W. DELUGE JOHN A. STATLER JEFFERSON J. SHIPMAN JEFFREY B. RETTIG KEVIN E. OSBORNE RALPH H. WRIGHT, JR. MARK C. DUFFIE JOHN R. NINOSKY MICHAEL J. CASSIDY jo~s'oN ~UFFIE „~ - MELISSA PEEL GREEVY ROBERT M, WALKER WADE D. MANLEY ELIZABETH D. SNOVER KELLY L. BONANNO OF COUNSEL HORACE A. JOHNSON F. LEE SHIPMAN (1465.2QQ6) I:'-A•L~JI::i~Dttilt~".1d~,1 ~ .rapt?. July 1, 2008 Ms. Heather Sgrignoli SCI Cambridge Springs 451 Fullerton Avenue Cambridge Springs, PA 16403-1238 Re: James E. Grandon, Jr., et al. v. Heather Sgrignoli, et al. Cumberland County C.C.P. Docket No. OT-4938 Dear Ms. Sgrignoli: Enclosed herewith please find a Notice of Intent to Take Default Judgment in regard to the above captioned action. Very truly yours, J~~AO,HNSON, DUFFIE, STEWART &WEIDNER ~v~ Wade D. a ley WDM/Gh: 336993 7123-39 Enclosure cc: Dennis E. Boyle, Esquire (w/enclosure) Mr. James E. Grandon, Jr. (w/enclosure) 301 MARKET STREET P.0. BOX 109 LEMOYNE, PENNSYLVANIA 17043-0109 WWW.JDSW.COM 717.761.4540 FAX:717.761.30I5 MAILC~JDSW.COM JOHNSON, DUFFIE, STEWART &WEIDNER, I'.C. :~ Johnson, Duffie, Stewart 8- Weidner By: John A. Statler, Esquire I.D. No. 43812 Wade D. Manley, Esquire I.D. No. 87244 301 Market Street P. O. Box 109 Lemoyne, Pennsylvania 17043-0109 (717) 761-4540 wdm@jdsw.com JAMES E. GRANDON, JR. and JIM-JAM, LLP, Plaintiffs v. Attorneys for Plaintiffs IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA NO. 07-4938 CIVIL ACTION -LAW HEATHER SGRIGNOLI and JURY TRIAL DEMANDED ROBERT P. SGRIGNOLI, her husband, Defendants NOTICE OF INTENT TO TAKE DEFAULT JUDGMENT TO: Heather Sgrignoli SCI Cambridge Springs 451 Fullerton Avenue Cambridge Springs, PA 16403-1238 DATE OF NOTICE: July 1, 2008 IMPORTANT NOTICE: YOU ARE IN DEFAULT BECAUSE YOU HAVE FAILED TO TAKE ACTION REQUIRED OF YOU IN THIS CASE. UNLESS YOU ACT WITHIN TEN (10) DAYS FROM THE DATE OF THIS NOTICE, A JUDGMENT MAY BE ENTERED AGAINST YOU WITHOUT A HEARING AND YOU MAY LOSE YOUR PROPERTY OR OTHER IMPORTANT RIGHTS. YOU SHOULD TAKE THIS NOTICE TO A LAWYER AT ONCE. IF YOU DO NOT HAVE A LAWYER OR CANNOT AFFORD ONE, GO TO OR TELEPHONE THE FOLLOWING OFFICE TO FIND OUT WHERE YOU CAN GET LEGAL ADVICE. Cumberland County Bar Association 32 South Bedford Street Carlisle, Pennsylvania 17013 Telephone: (717} 249-3166 :336991 JOHNSON, DUFFIE, STEWART & WEIDNER By: ~ Wade . M nl CERTIFICATE OF SERVICE AND NOW, this da of ~~ y , 2008, the undersigned does hereby certify that he did this date serve a copy of the foregoing document upon the other parties of record by causing same to be deposited in the United States Mail, first class postage prepaid, at Lemoyne, Pennsylvania, addressed as follows: Heather Sgrignoli SCI Cambridge Springs 451 Fullerton Avenue Cambridge Springs, PA 16403-1238 Dennis Boyle, Esquire Boyle Law Offices 1525 Cedar Cliff Drive Camp Hill, PA 17011 JOHNSON, DUFFIE, STEWART & WEIDNER By: U`~ ~~ WADE . MANL ,ESQUIRE :336991 ~Q \r ^`... r` t~ ~l b ~`` `~ "l' ~3 G °~° {~' '^ h{ r ". ~'. <~ .; t ,, ~T ice,„ ~_ ~~ Q e~ V A~ A r ~~:~ ~~ L '~ ;4~A (,~ -rr Johnson, Duffie, Stewart ~ Weidner By: John A. Statler, Esq. I.D. No. 43812 Wade D. Manley, Esquire I.D. No. 87244 301 Market Street P. O. Box 109 Lemoyne, Pennsylvania 17043-0109 (717) 761-4540 JAMES E. GRANDON, JR., JIM-JAM, LLP, and Plaintiffs vs. HEATHER SGRIGNOLI and ROBERT P SGRIGNOLI, JR., her husband, Defendants Attorneys for Plaintiff IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA CIVIL ACTION -LAW NO. 07-4938 CIVIL TERM JURY TRIAL DEMANDED CERTIFICATE PREREQUISITE TO SERVICE OF SUBPOENAS PURSUANT TO RULE 4009.22 As a prerequisite to service of subpoenas for documents and things pursuant to Rule 4009.22, Defendant hereby certifies that: 1) A Notice of Intent to serve the subpoenas, with a copy of the subpoenas attached thereto, was mailed or delivered to each party at least 20 days prior to the date on which the subpoenas were sought to be served; 2) A copy of the Notice of Intent, including the proposed subpoenas, are attached to this certificate; 3) No objection to the subpoenas has been received; and 4) The subpoenas to be served are identical to the subpoenas attached to the Notice of Intent. JOHNSON, DUFFIE, STEWART & WEIDNER UV ey: Wade D. Manle ,Esquire Attorney I. D. N 7244 301 Market Str P.O. Box 109 Lemoyne, PA 17043-0109 Telephone (717) 761-4540 Attorneys for Defendants DATE: ~~l(~(ag Johnson, Duffie, Stewart ~ Weidner By: John A. Statler, Esq. I.D. No. 43812 Wade D. Manley, Esquire I.D. No. 87244 301 Market Street P. O. Box 109 Lemoyne, Pennsylvania 17043-0109 (717) 761-4540 JAMES E. GRANDON, JR., and JIM-JAM, LLP, Plaintiffs vs. HEATHER SGRIGNOLI and ROBERT P SGRIGNOLI, JR., her husband, Attorneys for Plaintiff IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA CIVIL ACTION -LAW NO. 07-4938 CIVIL TERM JURY TRIAL DEMANDED Defendants NOTICE OF INTENT TO SERVE SUBPOENAS TO PRODUCE DOCUMENTS AND THINGS FOR DISCOVERY PURSUANT TO RULE 4009.21 TO: Heather and Robert Sgrignoli, Defendants c/o John P. Neblett, Esquire Boyle, Neblett & Wenger 4660 Trindle Road Suite 200 Camp Hill, PA 17011 PLEASE TAKE NOTICE that Defendants intend to serve subpoenas identical to the ones attached to this notice. You have 20 days from the date listed below in which to file on record and serve upon the undersigned an objection to the subpoenas. If no objection is made, the subpoenas may be served. JOHNSON, DUFFIE, STEWART & WEIDNER By: Wade D. M le ,Esquire Attorney I.D. .87244 301 Market Street P.O. Box 109 Lemoyne, PA 17043-0109 Telephone (717) 761-4540 Attorneys for Defendants DATE: ~(,, '~~~ ~',~1 COMMONWEALTH OF PENNSYLVANIA COUNTY OF CUMBERLAND JAMES E. GRANDON, JR., and JIM-JAM, LLP, Plaintiffs vs. File No. 07-4938 CIVIL TERM HEATHER SGRIGNOLI and ROBERT P. . SGRIGNOLI, JR., her husband, Defendants SUBPOENA TO PRODUCE DOCUMENTS OR THINGS FOR DISCOVERY PURSUANT TO RULE 4009.22 TO: Aspire, P.O. Box 105341, Atlanta, GA 30348-5341 (Name of Person or Entity) Within twenty (20) days after service of this subpoena, you are ordered by the court to produce the following documents or things: All documentation pertaining to the mortgage/loan/credit, the application thereof, invoices and payments thereof, acquired by Robert Sgrignoli, Jr. and/or Heather Sgrignoli with respect to account Nos. 4791-0601-0284-3215 and 4791-0600-0869-3193. This shall include any documentation pertaining to either parties' attempts to refinance or assume the mortgage/loan credit. at Wade D. Manlev. Esquire, Johnson, Duffie Stewart & Weidner 301 Market Street Lemoyne PA 17043 (Address) You may deliver or mail legible copies of the documents or produce things requesting by this subpoena, together with the certificate of compliance, to the party making this request at the address listed above. You have the right to seek, in ad vane, the reasonable cost of preparing the copies or producing the things sought. If you fail to produce the documents or things required by this subpoena, within twenty (20) days after its service, the party serving this subpoena may seek a court order compelling you to comply with it. THIS Subpoe~ta WAS ISSUED AT THE REQUEST OF THE FOLLOWING PERSON: NAME: Wade D. Manlev Esquire Johnson Duffie Stewart & Weidner P C ADDRESS: 301 Market Street Lemoyne, PA 17043 TELEPHONE: X717) 761-4540 SUPREME COURT ID # ATTORNEY FOR: Plaintiffs By the Court: DATE: Seal of the Court Prothonotary Deputy COMMONWEALTH OF PENNSYLVANIA COUNTY OF CUMBERLAND JAMES E. GRANDON, JR., and JIM-JAM, LLP, Plaintiffs vs. File No. 07-4938 CIVIL TERM HEATHER SGRIGNOLI and ROBERT P SGRIGNOLI, JR., her husband, Defendants SUBPOENA TO PRODUCE DOCUMENTS OR THINGS FOR DISCOVERY PURSUANT TO RULE 4009.22 TO: Cheer Tvme, Inc., 1400 Hummel Avenue. Lemoyne PA 17043 (Name of Person or Entity) Within twenty (20) days after service of this subpoena, you are ordered by the court to produce the following documents or things: All documentation pertaining to any purchase and/or rental of materials, services or lodging by Robert Sgrignoli, Jr. and/or Heather Sgrignoli, including, but not limited to invoices, payments, proof of payments, correspondence, estimates, reservations, type of accommodations and notices. at Wade D. Manley, Esquire, Johnson Duffle Stewart & Weidner 301 Market Street Lemoyne PA 17043 (Address) You may deliver or mail legible copies of the documents or produce things requesting by this subpoena, together with the certificate of compliance, to the party making this request at the address listed above. You have the right to seek, in ad vane, the reasonable cost of preparing the copies or producing the things sought. If you fail to produce the documents or things required by this subpoena, within twenty (20) days after its service, the party serving this subpoena may seek a court order compelling you to comply with it. THIS Subpoena WAS ISSUED AT THE REQUEST OF THE FOLLOWING PERSON.• NAME: Wade D. Manley, Esauire, Johnson, Duffle, Stewart & Weidner P C ADDRESS: 301 Market Street Lemoyne, PA 17043 TELEPHONE: (7171761-4540 SUPREME COURT ID # ATTORNEY FOR: Plaintiffs By the Court: DATE: Seal of the Court Prothonotary Deputy COMMONWEALTH OF PENNSYLVANIA COUNTY OF CUMBERLAND JAMES E. GRANDON, JR., and JIM-JAM, LLP, Plaintiffs vs. File No. 07-4938 CIVIL TERM HEATHER SGRIGNOLI and ROBERT P SGRIGNOLI, JR., her husband, Defendants SUBPOENA TO PRODUCE DOCUMENTS OR THINGS FOR DISCOVERY PURSUANT TO RULE 4009.22 TO: Crustal Pools, 4175 Roundtop Road, Elizabethtown, PA 17022 (Name of Person or Entity) Within twenty (20) days after service of this subpoena, you are ordered by the court to produce the following documents or things: All documentation pertaining to any purchase and/or rental of materials, services or lodging by Robert Sgrignoli, Jr. and/or Heather Sgrignoli, including, but not limited to invoices, payments, proof of payments, correspondence, estimates, reservations, type of accommodations and notices. at Wade D. Manley. Esquire, Johnson, Duffie, Stewart & Weidner, 301 Market Street, Lemoyne, PA 17043 (Address) You may deliver or mail legible copies of the documents or produce things requesting by this subpoena, together with the certificate of compliance, to the party making this request at the address listed above. You have the right to seek, in ad vane, the reasonable cost of preparing the copies or producing the things sought. If you fail to produce the documents or things required by this subpoena, within twenty (20) days after its service, the party serving this subpoena may seek a court order compelling you to comply with it. THIS Subpoena WAS ISSUED AT THE REQUEST OF THE FOLLOWING PERSON.• NAME: Wade D. Manley, Esquire, Johnson, Duffie, Stewart & Weidner, P.C. ADDRESS: 301 Market Street Lemoyne, PA 17043 TELEPHONE: (717) 761-4540 SUPREME COURT ID # 87244 ATTORNEY FOR: Plaintiffs By the Court: DATE: Seal of the Court Prothonotary Deputy COMMONWEALTH OF PENNSYLVANIA COUNTY OF CUMBERLAND JAMES E. GRANDON, JR., and JIM-JAM, LLP, Plaintiffs vs. File No. 07-4938 CIVIL TERM HEATHER SGRIGNOLI and ROBERT P. SGRIGNOLI, JR., her husband, Defendants SUBPOENA TO PRODUCE DOCUMENTS OR THINGS FOR DISCOVERY PURSUANT TO RULE 4009.22 TO: M&T Mortsa eg Corporation. 2270 Erin Court, P.O. Box 7628, Lancaster, PA 17604 (Name of Person or Entity) Within twenty (20) days after service of this subpoena, you are ordered by the court to produce the following documents or things: All documentation pertaining to the mortgage/loan/credit, the application thereof, invoices and payments thereof, acquired by Robert Sgrignoli, Jr. and/or Heather Sgrignoli with respect to account Nos. 8086084; 8838937001; and 1891386. This shall include any documentation pertaining to either parties' attempts to refinance or assume the mortgage/loan/credit. at Wade D. Manley, Esquire, Johnson, Duffie, Stewart & Weidner 301 Market Street Lemoyne PA 17043 (Address) You may deliver or mail legible copies of the documents or produce things requesting by this subpoena, together with the certificate of compliance, to the party making this request at the address listed above. You have the right to seek, in ad vane, the reasonable cost of preparing the copies or producing the things sought. If you fail to produce the documents or things required by this subpoena, within twenty (20) days after its service, the party serving this subpoena may seek a court order compelling you to comply with it. THIS Subpoena WAS ISSUED AT THE REQUEST OF THE FOLLOWING PERSON.• NAME: Wade D. Manley, Esquire, Johnson, Duffie, Stewart & Weidner P.C ADDRESS: 301 Market Sheet Lemoyne, PA 17043 TELEPHONE: (717) 761-4540 SUPREME COURT ID # 87244 ATTORNEY FOR: Plaintiffs By the Court: DATE: Seal of the Court Prothonotary Deputy COMMONWEALTH OF PENNSYLVANIA COUNTY OF CUMBERLAND JAMES E. GRANDON, JR., and JIM-JAM, LLP, Plaintiffs vs. File No. 07-4938 CIVIL TERM HEATHER SGRIGNOLI and ROBERT P SGRIGNOLI, JR., her husband, Defendants SUBPOENA TO PRODUCE DOCUMENTS OR THINGS FOR DISCOVERY PURSUANT TO RULE 4009.22 TO: Shenk Company, 5016 E. Trindle Road, Mechanicsburg PA 17050 (Name of Person or Entity) Within twenty (20) days after service of this subpoena, you are ordered by the court to produce the following documents or things: All documentation pertaining to any purchase and/or rental of materials, services or lodging by Robert Sgrignoli, Jr. and/or Heather Sgrignoli, including, but not limited to invoices, payments, proof of payments, correspondence, estimates, reservations, type of accommodations and notices. at Wade D. Manley, Esquire. Johnson. Duffle, Stewart & Weidner. 301 Market Street Lemoyne PA 17043 (Address) You may deliver or mail legible copies of the documents or produce things requesting by this subpoena, together with the certificate of compliance, to the party making this request at the address listed above. You have the right to seek, in ad vane, the reasonable cost of preparing the copies or producing the things sought. If you fail to produce the documents or things required by this subpoena, within twenty (20) days after its service, the party serving this subpoena may seek a court order compelling you to comply with it. THIS Subpoena WAS ISSUED AT THE REQUEST OF THE FOLLOWING PERSON.• NAME: Wade D. Manley. Esquire, Johnson, Duffle, Stewart & Weidner, P.C. ADDRESS: 301 Market Street Lemoyne, PA 17043 TELEPHONE: (717) 761-4540 SUPREME COURT ID # 87244 ATTORNEY FOR: Plaintiffs By the Court: DATE: Seal of the Court Prothonotary Deputy COMMONWEALTH OF PENNSYLVANIA COUNTY OF CUMBERLAND JAMES E. GRANDON, JR., and JIM-JAM, LLP, Plaintiffs vs. File No. 07-4938 CIVIL TERM HEATHER SGRIGNOLI and ROBERT P SGRIGNOLI, JR., her husband, Defendants SUBPOENA TO PRODUCE DOCUMENTS OR THINGS FOR DISCOVERY PURSUANT TO RULE 4009.22 TO: AAA Financial, P.O. Box 15026. Wihnin~ton DE 19850 (Name of Person or Entity) Within twenty (20) days after service of this subpoena, you are ordered by the court to produce the following documents or things: All documentation pertaining to the mortgage/loan/credit, the application thereof, invoices and payments thereof, acquired by Robert Sgrignoli, Jr. and/or Heather Sgrignoli with respect to account No. 4265-2967-5327-1573. This shall include any documentation pertaining to either parties' attempts to refinance or assume the m ortgage/loa n/credit. at Wade D. Manley, Esquire, Johnson. Duffle Stewart & Weidner 301 Market Street Lemoyne PA 17043 (Address) You may deliver or mail legible copies of the documents or produce things requesting by this subpoena, together with the certificate of compliance, to the party making this request at the address listed above. You have the right to seek, in ad vane, the reasonable cost of preparing the copies or producing the things sought. If you fail to produce the documents or things required by this subpoena, within twenty (20) days after its service, the party serving this subpoena may seek a court order compelling you to comply with it. THIS Subpoena WAS ISSUED AT THE REQUEST OF THE FOLLOWING PERSON.• NAME: Wade D. Manley, Esquire, Johnson, Duffie Stewart & Weidner P C ADDRESS: 301 Market Street Lemoyne, PA 17043 TELEPHONE: (7171761-4540 SUPREME COURT ID # 87244 ATTORNEY FOR: Plaintiffs By the Court: DATE: Seal of the Court Prothonotary Deputy COMMONWEALTH OF PENNSYLVANIA COUNTY OF CUMBERLAND JAMES E. GRANDON, JR, and JIM-JAM, LLP, Plaintiffs vs. File No. 07-4938 CIVIL TERM HEATHER SGRIGNOLI and ROBERT P SGRIGNOLI, JR., her husband, Defendants SUBPOENA TO PRODUCE DOCUMENTS OR THINGS FOR DISCOVERY PURSUANT TO RULE 4009.22 TO: Allstate, Northeast Regional Office, 1200 Atwater Drive, Malvern, PA 19355 (Name of Person or Entity) Within twenty (20) days after service of this subpoena, you are ordered by the court to produce the following documents or things: All documentation pertaining to any purchase and/or rental of materials, services or lodging by Robert Sgrignoli, Jr. and/or Heather Sgrignoli, including, but not limited to invoices, payments, proof of payments, correspondence, estimates, reservations, type of accommodations and notices. at Wade D. Manley, Esquire, Johnson, Duffle, Stewart & Weidner, 301 Market Street, Lemoyne PA 17043 (Address) You may deliver or mail legible copies of the documents or produce things requesting by this subpoena, together with the certificate of compliance, to the party making this request at the address listed above. You have the right to seek, in ad vane, the reasonable cost of preparing the copies or producing the things sought. If you fail to produce the documents or things required by this subpoena, within twenty (20) days after its service, the party serving this subpoena may seek a court order compelling you to comply with it. THIS Subpoena WAS ISSUED AT THE REQUEST OF THE FOLLOWING PERSON,• NAME: Wade D. Manley. Esquire, Johnson, Duffle, Stewart & Weidner, P.C. ADDRESS: 301 Market Street Lemoyne, PA 17043 TELEPHONE: (717) 761-4540 SUPREME COURT ID # ATTORNEY FOR: Plaintiffs By the Court: DATE: Seal of the Court Prothonotary Deputy COMMONWEALTH OF PENNSYLVANIA COUNTY OF CUMBERLAND JAMES E. GRANDON, JR., and JIM-JAM, LLP, Plaintiffs vs. File No. 07-4938 CNIL TERM HEATHER SGRIGNOLI and ROBERT P. SGRIGNOLI, JR., her husband, Defendants SUBPOENA TO PRODUCE DOCUMENTS OR THINGS FOR DISCOVERY PURSUANT TO RULE 4009.22 TO: AT&T Wireless, Glenridge Highlands Tow, 5565 Glenrid~e Connector, Atlanta, GA 30342 (Name of Person or Entity) Within twenty (20) days after service of this subpoena, you are ordered by the court to produce the following documents or things: All documentation pertaining to the mortgage/loan/credit, the application thereof, invoices and payments thereof, acquired by Robert Sgrignoli, Jr. and/or Heather Sgrignoli with respect to account No. 39111602 and Cingular account No. 34555989-001-40. This shall include any documentation pertaining to either parties' attempts to refinance or assume the mortgage/loan/credit. at Wade D. Manley, Esquire, Johnson, Duffie, Stewart & Weidner, 301 Market Street, Lemoyne, PA 17043 (Address) You may deliver or mail legible copies of the documents or produce things requesting by this subpoena, together with the certificate of compliance, to the party making this request at the address listed above. You have the right to seek, in ad vane, the reasonable cost of preparing the copies or producing the things sought. If you fail to produce the documents or things required by this subpoena, within twenty (20) days after its service, the party serving this subpoena may seek a court order compelling you to comply with it. THIS Subpoena WAS ISSUED AT THE REQUEST OF THE FOLLOWING PERSON.• NAME: Wade D. Manley, Esquire, Johnson, Duffie, Stewart & Weidner, P.C. ADDRESS: 301 Market Street Lemoyne, PA 17043 TELEPHONE: (717) 761-4540 SUPREME COURT ID # 87244 ATTORNEY FOR: Plaintiffs By the Court: DATE: Seal of the Court Prothonotary Deputy COMMONWEALTH OF PENNSYLVANIA COUNTY OF CUMBERLAND JAMES E. GRANDON, JR., and JIM-JAM, LLP, Plaintiffs vs. File No. 07-4938 CIVIL TERM HEATHER SGRIGNOLI and ROBERT P. SGRIGNOLI, JR., her husband, Defendants SUBPOENA TO PRODUCE DOCUMENTS OR THINGS FOR DISCOVERY PURSUANT TO RULE 4009.22 TO: Chase, P.O. Box 15298. Wihnineton, DE 19850-5298 (Name of Person or Entity) Within twenty (20) days after service of this subpoena, you are ordered by the court to produce the following documents or things: All documentation pertaining to the mortgage/loan/credit, the application thereof, invoices and payments thereof, acquired by Robert Sgrignoli, Jr. and/or Heather Sgrignoli with respect to account No. 10-22-2511-053603. This shall include any documentation pertaining to either parties' attempts to refinance or assume the mortgage/loan/credit. at Wade D. Manlev Esquire Johnson Duffie Stewart & Weidner 301 Market Street Lemoyne PA 17043 (Address) You may deliver or mail legible copies of the documents or produce things requesting by this subpoena, together with the certificate of compliance, to the party making this request at the address listed above. You have the right to seek, in ad vane, the reasonable cost of preparing the copies or producing the things sought. If you fail to produce the documents or things required by this subpoena, within twenty (20) days after its service, the party serving this subpoena may seek a court order compelling you to comply with it. THIS Subpoena WAS ISSUED AT THE REQUEST OF THE FOLLOWING PERSON: NAME: Wade D. Manlev, Esquire, Johnson. Duffie Stewart & Weidner P C ADDRESS: 301 Market Street Lemovne, PA 17043 TELEPHONE: X717) 761-4540 SUPREME COURT lD # ATTORNEY FOR: Plaintiffs By the Court: DATE: Seal of the Court Prothonotary Deputy COMMONWEALTH OF PENNSYLVANIA COUNTY OF CUMBERLAND JAMES E. GRANDON, JR., and JIM-JAM, LLP, Plaintiffs vs. File No. 07-4938 CIVIL TERM HEATHER SGRIGNOLI and ROBERT P SGRIGNOLI, JR., her husband, Defendants SUBPOENA TO PRODUCE DOCUMENTS OR THINGS FOR DISCOVERY PURSUANT TO RULE 4009.22 TO: Community Banks, 1570 Manheim Pike, Lancaster, PA 12604 (Name of Person or Entity) Within twenty (20) days after service of this subpoena, you are ordered by the court to produce the following documents or things: All documentation pertaining to the mortgage/loan/credit, the application thereof, invoices and payments thereof, acquired by Robert Sgrignoli, Jr. and/or Heather Sgrignoli with respect to account No. 0319306218. This shall include any documentation pertaining to either parties' attempts to refinance or assume the mortgage/loan credit. at Wade D. Manlev. Esquire, Johnson, Duffie, Stewart & Weidner, 301 Market Street, Lemoyne, PA 17043 (Address) You may deliver or mail legible copies of the documents or produce things requesting by this subpoena, together with the certificate of compliance, to the party making this request at the address listed above. You have the right to seek, in ad vane, the reasonable cost of preparing the copies or producing the things sought. If you fail to produce the documents or things required by this subpoena, within twenty (20) days after its service, the party serving this subpoena may seek a court order compelling you to comply with it. THIS Subpoena WAS ISSUED AT THE REQUEST OF THE FOLLOWING PERSON.• NAME: Wade D. Manlev, Esquire, Johnson, Duffie, Stewart & Weidner, P.C. ADDRESS: 301 Market Street Lemoyne, PA 17043 TELEPHONE: (717) 761-4540 SUPREME COURT ID # ATTORNEY FOR: Plaintiffs By the Court: DATE: Seal of the Court Prothonotary Deputy COMMONWEALTH OF PENNSYLVANIA COUNTY OF CUMBERLAND JAMES E. GRANDON, JR., and JIM-JAM, LLP, Plaintiffs vs. File No. 07-4938 CIVIL TERM HEATHER SGRIGNOLI and ROBERT P SGRIGNOLI, JR, her husband, Defendants SUBPOENA TO PRODUCE DOCUMENTS OR THINGS FOR DISCOVERY PURSUANT TO RULE 4009.22 TO: Day's Inn, 2210 N. Baltimore Avenue, Ocean City, MD 21842 (Name of Person or Entity) Within twenty (20) days after service of this subpoena, you are ordered by the court to produce the following documents or things: All documentation pertaining to any purchase and/or rental of materials, services or lodging by Robert Sgrignoli, Jr. and/or Heather Sgrignoli, including, but not limited to invoices, payments, proof of payments, correspondence, estimates, reservations, type of accommodations and notices. Confirmation No.: P05598. at Wade D. Manley. Esquire, Johnson, Duffie, Stewart & Weidner, 301 Market Street, Lemoyne, PA 17043 (Address) You may deliver or mail legible copies of the documents or produce things requesting by this subpoena, together with the certificate of compliance, to the party making this request at the address listed above. You have the right to seek, in ad vane, the reasonable cost of preparing the copies or producing the things sought. If you fail to produce the documents or things required by this subpoena, within twenty (20) days after its service, the party serving this subpoena may seek a court order compelling you to comply with it. THIS Subpoena WAS ISSUED AT THE REQUEST OF THE FOLLOWING PERSON: NAME: Wade D. Manley, Esquire, Johnson, Duffie, Stewart & Weidner. P.C. ADDRESS: 301 Market Street Lemoyne, PA 17043 TELEPHONE: (7171761-4540 SUPREME COURT ID # 87244 ATTORNEY FOR: Plaintiffs By the Court: DATE: Seal of the Court Prothonotary DepuTy COMMONWEALTH OF PENNSYLVANIA COUNTY OF CUMBERLAND JAMES E. GRANDON, JR., and JIM-JAM, LLP, Plaintiffs vs. File No. 07-4938 CIVIL TERM HEATHER SGRIGNOLI and ROBERT P SGRIGNOLI, JR., her husband, Defendants SUBPOENA TO PRODUCE DOCUMENTS OR THINGS FOR DISCOVERY PURSUANT TO RULE 4009.22 TO: GE Capital Solutions, Business Financine Solutions, 44 Old Rid eg burv Road, Danbury, CT 06810 (Name of Person or Entity) Within twenty (20) days after service of this subpoena, you are ordered by the court to produce the following doctments or things: All documentation pertaining to the mortgage/loan/credit, the application thereof, invoices and payments thereof, acquired by Robert Sgrignoli, Jr. and/or Heather Sgrignoli with respect to account No. 6030-0902-0526-330. This shall include any documentation pertaining to either parties' attempts to refinance or assume the m ortgage/loan/credit. at Wade D. Manleyquire, Johnson, Duffle, Stewart & Weidner, 301 Market Street, Lemovne PA 17043 (Address) You may deliver or mail legible copies of the documents or produce things requesting by this subpoena, together with the certificate of compliance, to the party making this request at the address listed above. You have the right to seek, in ad vane, the reasonable cost of preparing the copies or producing the things sought. If you fail to produce the documents or things required by this subpoena, within twenty (20) days after its service, the party serving this subpoena may seek a court order compelling you to comply with it. THIS Subpoena WAS ISSUED AT THE REQUEST OF THE FOLLOWING PERSON: NAME: Wade D. Man1e~Esquire, Johnson, Duffle, Stewart & Weidner. P.C. ADDRESS: 301 Market Street Lemovne, PA 17043 TELEPHONE: (7171761-4540 SUPREME COURT ID # 87244 ATTORNEY FOR: Plaintiffs By the Court: DATE: Seal of the Court Prothonotary Deputy COMMONWEALTH OF PENNSYLVANIA COUNTY OF CUMBERLAND JAMES E. GRANDON, JR., and JIM-JAM, LLP, Plaintiffs vs. File No. 07-4938 CIVIL TERM HEATHER SGRIGNOLI and ROBERT P SGRIGNOLI, JR., her husband, Defendants SUBPOENA TO PRODUCE DOCUMENTS OR THINGS FOR DISCOVERY PURSUANT TO RULE 4009.22 TO: GMAC, 3451 Hammond Avenue, Waterloo, IA 50702 (Name of Person or Entity) Within twenty (20) days after service of this subpoena, you are ordered by the court to produce the following documents or things: All documentation pertaining to the mortgage/loan/credit, the application thereof, invoices and payments thereof, acquired by Robert Sgrignoli, Jr. and/or Heather Sgrignoli with respect to account No. 020-0670-97530. This shall include any documentation pertaining to either parties' attempts to refinance or assume the mortgage/loan/credit. at Wade D. Manleyquire, Johnson, Duffie, Stewart & Weidner, 301 Market Street, Lemoyne, PA 17043 (Address) You may deliver or mail legible copies of the documents or produce things requesting by this subpoena, together with the certificate of compliance, to the party making this request at the address listed above. You have the right to seek, in ad vane, the reasonable cost of preparing the copies or producing the things sought. If you fail to produce the documents or things required by this subpoena, within twenty (20) days after its service, the party serving this subpoena may seek a court order compelling you to comply with it. THIS Subpoe-ta WAS ISSUED AT THE REQUEST OF THE FOLLOWING PERSON.• NAME: Wade D. Manley, Esquire, Johnson, Duffie, Stewart & Weidner, P.C. ADDRESS: 301 Market Street Lemoyne, PA 17043 TELEPHONE: (717) 761-4540 SUPREME COURT ID # 87244 ATTORNEY FOR: Plaintiffs By the Court: DATE: Seal of the Court Prothonotary Deputy COMMONWEALTH OF PENNSYLVANIA COUNTY OF CUMBERLAND JAMES E. GRANDON, JR., and JIM-JAM, LLP, Plaintiffs vs. File No. 07-4938 CIVIL TERM HEATHER SGRIGNOLI and ROBERT P SGRIGNOLI, JR, her husband, Defendants SUBPOENA TO PRODUCE DOCUMENTS OR THINGS FOR DISCOVERY PURSUANT TO RULE 4009.22 TO: Hilton Kev West, 245 Front Street, Kev West, FL 33040 (Name of Person or Entity) Within twenty (20) days after service of this subpoena, you are ordered by the court to produce the following documents or things: All documentation pertaining to any purchase and/or rental of materials, services or lodging by Robert Sgrignoli, Jr. and/or Heather Sgrignoli, including, but not limited to invoices, payments, proof of payments, correspondence, estimates, reservations, type of accommodations and notices. Reservation No. 324-0650192. at Wade D. Manley, Esquire, Johnson, Duffle, Stewart & Weidner, 301 Market Street, Lemoyne, PA 17043 (Address) You may deliver or mail legible copies of the documents or produce things requesting by this subpoena, together with the certificate of compliance, to the party making this request at the address listed above. You have the right to seek, in ad vane, the reasonable cost of preparing the copies or producing the things sought. If you fail to produce the documents or things required by this subpoena, within twenty (20) days after its service, the party serving this subpoena may seek a court order compelling you to comply with it. THIS Subpoena WAS ISSUED AT THE REQUEST OF THE FOLLOWING PERSON.• NAME: Wade D. Manlev, Esquire, Johnson, Duffie, Stewart & Weidner, P.C. ADDRESS: 301 Market Street Lemoyne, PA 17043 TELEPHONE: (717) 761-4540 SUPREME COURT ID # 87244 ATTORNEY FOR: Plaintiffs By the Court: DATE: Seal of the Court Prothonotary Deputy COMMONWEALTH OF PENNSYLVANIA COUNTY OF CUMBERLAND JAMES E. GRANDON, JR., and JIM-JAM, LLP, Plaintiffs vs. File No. 07-4938 CIVIL TERM HEATHER SGRIGNOLI and ROBERT P. SGRIGNOLI, JR., her husband, Defendants SUBPOENA TO PRODUCE DOCUMENTS OR THINGS FOR DISCOVERY PURSUANT TO RULE 4009.22 TO: Home Depot, 6000 Cazlisle Pike, Mechanicsburg, PA 17050 (Name of Person or Entity) Within twenty (20) days after service of this subpoena, you are ordered by the court to produce the following documents or things: Alt documentation pertaining to the mortgage/loan credit, the application thereof, invoices and payments thereof, acquired by Robert Sgrignoli, Jr, and/or Heather Sgrignoli with respect to account No. 6035-3201-0475-9913. This shall include any documentation pertaining to either parties' attempts to refinance or assume the m o rtgage/loa n/c red it. at Wade D. Manley, Esquire, Johnson, Duffle Stewart & Weidner 301 Mazket Street Lemoyne PA 17043 (Address) You may deliver or mail legible copies of the documents or produce things requesting by this subpoena, together with the certificate of compliance, to the party making this request at the address listed above. You have the right to seek, in ad vane, the reasonable cost of prepazing the copies or producing the things sought. If you fail to produce the documents or things required by this subpoena, within twenty (20) days after its service, the party serving this subpoena may seek a court order compelling you to comply with it. THIS Subpoena WAS ISSUED AT THE REQUEST OF THE FOLLOWING PERSON.• NAME: Wade D. Manley, Esquire, Johnson, Duffie Stewazt & Weidner P C ADDRESS: 301 Market Street Lemoyne, PA 17043 TELEPHONE: (717) 761-4540 SUPREME COURT ID # 87244 ATTORNEY FOR: Plaintiffs By the Court: DATE: Seal of the Court Prothonotary Deputy COMMONWEALTH OF PENNSYLVANIA COUNTY OF CUMBERLAND JAMES E. GRANDON, JR., and JIM-JAM, LLP, Plaintiffs vs. File No. 07-4938 CIVIL TERM HEATHER SGRIGNOLI and ROBERT P. SGRIGNOLI, JR., her husband, Defendants SUBPOENA TO PRODUCE DOCUMENTS OR THINGS FOR DISCOVERY PURSUANT TO RULE 4009.22 TO: John Deere, Landmark Equipment, 1 Roadway Drive, Carlisle, PA 17015 (Name of Person or Entity) Within twenty (20) days after service of this subpoena, you are ordered by the court to produce the following documents or things: All documentation pertaining to the mortgage/loan/credit, the application thereof, invoices and payments thereof, acquired by Robert Sgrignoli, Jr. and/or Heather Sgrignoli with respect to account No. 03-193585267-AA. This shall include any documentation pertaining to either parties' attempts to refinance or assume the mortgage/loan credit. at Wade D. Manley, Esctuire, Johnson, Duffle, Stewart & Weidner 301 Market Street Lemoyne PA 17043 (Address) You may deliver or mail legible copies of the documents or produce things requesting by this subpoena, together with the certificate of compliance, to the party making this request at the address listed above. You have the right to seek, in ad vane, the reasonable cost of preparing the copies or producing the things sought. If you fail to produce the documents or things required by this subpoena, within twenty (20) days after its service, the party serving this subpoena may seek a court order compelling you to comply with it. THIS Subpoe~:a WAS ISSUED AT THE REQUEST OF THE FOLLOWING PERSON.• NAME: ADDRESS: TELEPHONE: SUPREME COURT ID # ATTORNEY FOR: DATE: Wade D. Manley, EsQUire, Johnson, Duffle Stewart & Weidner P C 301 Market Street Lemoyne, PA 17043 X717) 761-4540 Plaintiffs By the Court: Seal of the Court Prothonotary Deputy COMMONWEALTH OF PENNSYLVANIA COUNTY OF CUMBERLAND JAMES E. GRANDON, JR., and JIM-JAM, LLP, Plaintiffs vs. File No. 07-4938 CIVIL TERM HEATHER SGRIGNOLI and ROBERT P SGRIGNOLI, JR., her husband, Defendants SUBPOENA TO PRODUCE DOCUMENTS OR THINGS FOR DISCOVERY PURSUANT TO RULE 4009.22 TO: JP Harris Associates, LLC, 101 Rich Valley Road, Mechanicsburg, PA 17055 (Name of Person or Entity) Within twenty (20) days after service of this subpoena, you are ordered by the court to produce the following documents or things: All documentation pertaining to the mortgage/loan/credit, the application thereof, invoices and payments thereof, acquired by Robert Sgrignoli, Jr. and/or Heather Sgrignoli with respect to account. This shall include any documentation pertaining to either parties' attempts to refinance or assume the mortgagefloan/credit. at Wade D. Manlev, Esquire, Johnson, Duffle Stewart & Weidner 301 Market Street. Lemoyne PA 17043 (Address) You may deliver or mail legible copies of the documents or produce things requesting by this subpoena, together with the certificate of compliance, to the party making this request at the address listed above. You have the right to seek, in ad vane, the reasonable cost of preparing the copies or producing the things sought. If you fail to produce the documents or things required by this subpoena, within twenty (20) days after its service, the party serving this subpoena may seek a court order compelling you to comply with it. THIS Subpoe~ra WAS ISSUED AT THE REQUEST OF THE FOLLOWING PERSON.• NAME: Wade D. Manlev, Esquire Johnson Duffie Stewart & Weidner P C ADDRESS: 301 Market Street Lemovne, PA 17043 TELEPHONE: (717) 761-4540 SUPREME COURT lD # 87244 ATTORNEY FOR: Plaintiffs By the Court: DATE: Seal of the Court Prothonotary Deputy COMMONWEALTH OF PENNSYLVANIA COUNTY OF CUMBERLAND JAMES E. GRANDON, JR., and JIM-JAM, LLP, Plaintiffs vs. File No. 07-4938 CIVIL TERM HEATHER SGRIGNOLI and ROBERT P. SGRIGNOLI, JR., her husband, Defendants SUBPOENA TO PRODUCE DOCUMENTS OR THINGS FOR DISCOVERY PURSUANT TO RULE 4009.22 TO: Kohl's, 6444 Carlisle Pike, Mechanicsburs PA 17055 (Name of Person or Entity) Within twenty (20) days after service of this subpoena, you are ordered by the court to produce the following documents or things: All documentation pertaining to the mortgage/loan/credit, the application thereof, invoices and payments thereof, acquired by Robert Sgrignoli, Jr. and/or Heather Sgrignoli with respect to account No. 033-6386-883. This shall include any documentation pertaining to either parties' attempts to refinance or assume the mortgage/loan/credit. at Wade D. Manley, Esquire Johnson Duffle Stewart & Weidner 301 Market Street Lemoyne PA 17043 (Address) You may deliver or mail legible copies of the documents or produce things requesting by this subpoena, together with the certificate of compliance, to the party making this request at the address listed above. You have the right to seek, in ad vane, the reasonable cost of preparing the copies or producing the things sought. If you fail to produce the documents or things required by this subpoena, within twenty (20) days after its service, the party serving this subpoena may seek a court order compelling you to comply with it. THIS Subpoe~za WAS ISSUED AT THE REQUEST OF THE FOLLOWING PERSON.• NAME: ADDRESS TELEPHONE: SUPREME COURT ID # ATTORNEY FOR: DATE: Wade D. Manley, Esquire Johnson Duffle Stewart & Weidner P C 301 Market Street Lemoyne, PA 17043 (7171761-4540 Plaintiffs By the Court: Seal of the Court Prothonotary Deputy COMMONWEALTH OF PENNSYLVANIA COUNTY OF CUMBERLAND JAMES E. GRANDON, JR., and JIM-JAM, LLP, Plaintiffs vs. File No. 07-4938 CIVIL TERM HEATHER SGRIGNOLI and ROBERT P. SGRIGNOLI, JR., her husband, . Defendants SUBPOENA TO PRODUCE DOCUMENTS OR THINGS FOR DISCOVERY PURSUANT TO RULE 4009.22 TO: Miller Capital Insurance 885 Front Street Harrisburg PA 17102 (Name of Person or Entity) Within twenty (20) days after service of this subpoena, you are ordered by the court to produce the following documents or things: All documentation pertaining to any purchase and/or rental of materials, services or lodging by Robert Sgrignoli, Jr. and/or Heather Sgrignoli, including, but not limited to invoices, payments, proof of payments, correspondence, estimates, reservations, type of accommodations and notices. at Wade D. Manley, Esquire Johnson Duffie Stewart & Weidner 301 Market Street, Lemoyne PA 17043 (Address) You may deliver or mail legible copies of the documents or produce things requesting by this subpoena, together with the certificate of compliance, to the party making this request at the address listed above. You have the right to seek, in ad vane, the reasonable cost of preparing the copies or producing the things sought. If you fail to produce the documents or things required by this subpoena, within twenty (20) days after its service, the party serving this subpoena may seek a court order compelling you to comply with it. THIS Subpoezza WAS ISSUED AT THE REQUEST OF THE FOLLOWING PERSON.• NAME: ADDRESS: TELEPHONE: SUPREME COURT ID # ATTORNEY FOR: DATE: Wade D. Manley, Esquire Johnson Duffie Stewart & Weidner P C 301 Market Street Lemoyne, PA 17043 (717)761-4540 Plaintiffs By the Court: Seal of the Court Prothonotary Deputy COMMONWEALTH OF PENNSYLVANIA COUNTY OF CUMBERLAND JAMES E. GRANDON, JR., and JIM-JAM, LLP, Plaintiffs vs. File No. 07-4938 CIVIL TERM HEATHER SGRIGNOLI and ROBERT P. SGRIGNOLI, JR., her husband, Defendants SUBPOENA TO PRODUCE DOCUMENTS OR THINGS FOR DISCOVERY PURSUANT TO RULE 4009.22 TO: Penn Fuel. 1708 Lancaster Avenue, Columbia, PA 17512 (Name of Person or Entity) Within twenty (20) days after service of this subpoena, you are ordered by the court to produce the following documents or things: All documentation pertaining to the mortgage/loan/credit, the application thereof, invoices and payments thereof, acquired by Robert Sgrignoli, Jr. and/or Heather Sgrignoli with respect to account No. 58-81542 This shall include any documentation pertaining to either parties' attempts to refinance or assume the mortgage/loan/credit. at Wade D. Manlev, Esquire, Johnson, Duffle, Stewart & Weidner 301 Market Street Lemoyne PA 17043 (Address) You may deliver or mail legible copies of the documents or produce things requesting by this subpoena, together with the certificate of compliance, to the party making this request at the address listed above. You have the right to seek, in ad vane, the reasonable cost of preparing the copies or producing the things sought. If you fail to produce the documents or things required by this subpoena, within twenty (20) days after its service, the party serving this subpoena may seek a court order compelling you to comply with it. THIS Subpoena WAS ISSUED AT THE REQUEST OF THE FOLLOWING PERSON.• NAME: Wade D. Manley. Esquire. Johnson. Duffle. Stewart & Weidner P C ADDRESS: 301 Market Street Lemovne. PA 17043 TELEPHONE: (717) 761-4540 SUPREME COURT ID # 87244 ATTORNEY FOR: Plaintiffs By the Court: DATE: Seal of the Court Prothonotary Deputy COMMONWEALTH OF PENNSYLVANIA COUNTY OF CUMBERLAND JAMES E. GRANDON, JR., and JIM-JAM, LLP, Plaintiffs vs. File No. 07-4938 CIVIL TERM HEATHER SGRIGNOLI and ROBERT P SGRIGNOLI, JR, her husband, Defendants SUBPOENA TO PRODUCE DOCUMENTS OR THINGS FOR DISCOVERY PURSUANT TO RULE 4009.22 TO: Proeressive, 6300 Wilson Mills Road, Mayfield Village, OH 44143 (Name of Person or Entity) Within twenty (20) days after service of this subpoena, you are ordered by the court to produce the following documents or things: All documentation pertaining to the mortgage/loan credit, the application thereof, invoices and payments thereof, acquired by Robert Sgrignoli, Jr. and/or Heather Sgrignoli with respect to account Nos. 02098364-9; 02098364-7; and 0209864-6. This shall include any documentation pertaining to either parties' attempts to refinance or assume the mortgage/loan/credit. at Wade D. Manleyquire Johnson Duffie Stewart & Weidner 301 Market Street. Lemoyne PA 17043 (Address) You may deliver or mail legible copies of the documents or produce things requesting by this subpoena, together with the certificate of compliance, to the party making this request at the address listed above. You have the right to seek, in ad vane, the reasonable cost of preparing the copies or producing the things sought. If you fail to produce the documents or things required by this subpoena, within twenty (20) days after its service, the party serving this subpoena may seek a court order compelling you to comply with it. THIS Subpoena WAS ISSUED AT THE REQUEST OF THE FOLLOWING PERSON.• NAME: Wade D. Manley, Esquire, Johnson, Duffie, Stewart & Weidner P C ADDRESS: 301 Market Street Lemoyne, PA 17043 TELEPHONE: (7171761-4540 SUPREME COURT ID # ATTORNEY FOR: Plaintiffs By the Court: DATE: Seal of the Court Prothonotary Deputy COMMONWEALTH OF PENNSYLVANIA COUNTY OF CUMBERLAND JAMES E. GRANDON, JR, and JIM-JAM, LLP, Plaintiffs vs. File No. 07-4938 CIVIL TERM HEATHER SGRIGNOLI and ROBERT P. SGRIGNOLI, JR., her husband, . Defendants SUBPOENA TO PRODUCE DOCUMENTS OR THINGS FOR DISCOVERY PURSUANT TO RULE 4009.22 TO: Tidelands Cazibbean, 5~' Street on Boazdwalk Ocean City MD 21842 (Name of Person or Entity) Within twenty (20) days after service of this subpoena, you are ordered by the court to produce the following documents or things: All documentation pertaining to any purchase and/or rental of materials, services or lodging by Robert Sgrignoli, Jr. and/or Heather Sgrignoli, including, but not limited to invoices, payments, proof of payments, correspondence, estimates, reservations, type of accommodations and notices. Confirmation No.: 43149. at Wade D. Manlev, Esauire Johnson Duffie Stewart & Weidner 301 Market Street Lemovne PA 17043 (Address) You may deliver or mail legible copies of the documents or produce things requesting by this subpoena, together with the certificate of compliance, to the party making this request at the address listed above. You have the right to seek, in ad vane, the reasonable cost of prepazing the copies or producing the things sought. If you fail to produce the documents or things required by this subpoena, within twenty (20) days after its service, the party serving this subpoena may seek a court order compelling you to comply with it. THIS Subpoena WAS ISSUED AT THE REQUEST OF THE FOLLOWING PERSON.• NAME: ADDRESS: TELEPHONE: SUPREME COURT ID # ATTORNEY FOR: DATE: Wade D. Manlev, Esquire Johnson Duffie Stewart & Weidner P C 301 Mazket Street Lemovne, PA 17043 X7171761-4540 Plaintiffs By the Court: Seal of the Court Prothonotary Deputy COMMONWEALTH OF PENNSYLVANIA COUNTY OF CUMBERLAND JAMES E. GRANDON, JR., and JIM-JAM, LLP, Plaintiffs vs. File No. 07-4938 CIVIL TERM HEATHER SGRIGNOLI and ROBERT P. SGRIGNOLI, JR., her husband, , Defendants SUBPOENA TO PRODUCE DOCUMENTS OR THINGS FOR DISCOVERY PURSUANT TO RULE 4009.22 TO: Wells Farso, 4830 Carlisle Pike E3 Mechanicsburg PA 17050 (Name of Person or Entity) Within twenty (20) days after service of this subpoena, you are ordered by the court to produce the following documents or things: All documentation pertaining to the mortgage/loan/credit, the application thereof, invoices and payments thereof, acquired by Robert Sgrignoli, Jr. and/or Heather Sgrignoli with respect to account No. 6537-2727. This shall include any documentation pertaining to either parties' attempts to refinance or assume the mortgage/loan/credit. at Wade D. Manley. Esquire Johnson Duffie Stewart & Weidner 301 Market Street Lemoyne PA 17043 (Address) You may deliver or mail legible copies of the documents or produce things requesting by this subpoena, together with the certificate of compliance, to the party making this request at the address listed above. You have the right to seek, in ad vane, the reasonable cost of preparing the copies or producing the things sought. If you fail to produce the documents or things required by this subpoena, within twenty (20) days after its service, the party serving this subpoena may seek a court order compelling you to comply with it. THIS Subpoena WAS ISSUED AT THE REQUEST OF THE FOLLOWING PERSON.• NAME: ADDRESS: TELEPHONE: SUPREME COURT ID # ATTORNEY FOR: DATE: Wade D. Manley, Esquire Johnson Duffle Stewart & Weidner P C 301 Market Street Lemoyne. PA 17043 X717)761-4540 Plaintiffs By the Court: Seal of the Court Prothonotary Deputy COMMONWEALTH OF PENNSYLVANIA COUNTY OF CUMBERLAND JAMES E. GRANDON, JR., and JIM-JAM, LLP, Plaintiffs vs. File No. 07-4938 CIVIL TERM HEATHER SGRIGNOLI and ROBERT P. SGRIGNOLI, JR., her husband, . Defendants SUBPOENA TO PRODUCE DOCUMENTS OR THINGS FOR DISCOVERY PURSUANT TO RULE 4009.22 TO: Superior Metal Works, Inc. 1416 Trindle Roa Carlisle PA 17013 (Name of Person or Entity) Within twenty (20) days after service of this subpoena, you aze ordered by the court to produce the following documents or things: Records or copies of records relating to Robert Sgrignoli, Jr. and/or heather Sgrignoli's compensation placages and compensation records for the calendar years of 2002, 2003, 2004, 2005 and 2006 including all salary, benefits, perks policies regarding expense reimbursement, policies regarding use of the company vehicles. Copies of Superior's taz returns for the calendar years of 2002, 2003, 2004, 2005 and 2006. Copies of all finance and bank statements for calendar years of 2002, 2003, 2004, 2005 and 2006. at Wade D. Manlev EsQUire Johnson Duffie Stewart & Weidner 301 Mazket Street. Lemoyne PA 17043 (Address) You may deliver or mail legible copies of the documents or produce things requesting by this subpoena, together with the certificate of compliance, to the party making this request at the address listed above. You have the right to seek, in ad vane, the reasonable cost of preparing the copies or producing the things sought. If you fail to produce the documents or things required by this subpoena, within twenty (20) days after its service, the party serving this subpoena may seek a court order compelling you to comply with it. THIS Subpoena WAS ISSUED AT THE REQUEST OF THE FOLLOWING PERSON.• NAME: ADDRESS: TELEPHONE: SUPREME COURT ID # ATTORNEY FOR: DATE: Wade D. Manlev Esouire Johnson Duffe Stewart & Weidner P C 301 Mazket Street Lemovne, PA 17043 (717)761-4540 Plaintiffs By the Court: Seal of the Court Prothonotary Deputy COMMONWEALTH OF PENNSYLVANIA COUNTY OF CUMBERLAND JAMES E. GRANDON, JR., and JIM-JAM, LLP, Plaintiffs vs. File No. 07-4938 CIVIL TERM HEATHER SGRIGNOLI and ROBERT P. SGRIGNOLI, JR., her husband, Defendants SUBPOENA TO PRODUCE DOCUMENTS OR THINGS FOR DISCOVERY PURSUANT TO RULE 4009.22 TO: Harlev Davidson. 6695 Cazlisle Pike. Mechanicsburg PA 17050 (Name of Person or Entity) Within twenty (20) days after service of this subpoena, you aze ordered by the court to produce the following documents or things: All documentation pertaining to any purchase and/or rental of materials, services or lodging by Robert Sgrignoli, Jr. and/or Heather Sgrignoli, including, but not limited to invoices, payments, proof of payments, correspondence, estimates, reservations, type of accommodations and notices. at Wade D. Manlev. Esquire, Johnson Duffle Stewart & Weidner 301 Market Street Lemorne PA 17043 (Address) You may deliver or mail legible copies of the documents or produce things requesting by this subpoena, together with the certificate of compliance, to the party making this request at the address listed above. You have the right to seek, in ad vane, the reasonable cost of preparing the copies or producing the things sought. If you fail to produce the documents or things required by this subpoena, within twenty (20} days after its service, the party serving this subpoena may seek a court order compelling you to comply with it. THIS Subpoena WAS ISSUED AT THE REQUEST OF THE FOLLOWING PERSON.• NAME: Wade D. Manlev, Esquire, Johnson Duffle Stewart & Weidner P C ADDRESS: 301 Market Street Lemoyne, PA 17043 TELEPHONE: (7171761-4540 SUPREME COURT ID # 87244 ATTORNEY FOR: Plaintiffs By the Court: DATE: Seal of the Court Prothonotary Deputy CERTIFICATE OF SERVICE AND NOW, this f ~~ day of ~~~~~~~~~ , 2008, the undersigned does hereby certify that she did this date serve a copy of the foregoing document upon the other parties of record by causing same to be deposited in the United States Mail, first class postage prepaid, at Lemoyne, Pennsylvania, addressed as follows: John P. Neblett, Esquire Boyle, Neblett & Wenger 4660 Trindle Road Suite 200 Camp Hill, PA 17011 JOHNSON, DUFFIE, STEWART & WEIDNER E,li abeth L. ~i er ~ ~. CERTIFICATE OF SERVICE AND NOW, this ~ day of 2008, the undersigned does hereby certify that she did this date serve a copy of the foregoing document upon the other parties of record by causing same to be deposited in the United States Mail, first class postage prepaid, at Lemoyne, Pennsylvania, addressed as follows: John P. Neblett, Esquire Boyle, Neblett & Wenger 4660 Trindle Road Suite 200 Camp Hill, PA 17011 JOHNSON, DUFFIE, STEWART & WEIDNER By: Eli eth L. Zie ~F F. Y~ ~-~ r.a :-~ ~ '[,) ~ ,_e i tl 4 .. __._ t'+7 _. 7 r_'t ......'~ c _I _~ .~ -i r ...,,g ~-..7