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HomeMy WebLinkAbout08-4938Leonard Tintner, Esquire Supreme Court I.D. #06859 BOSWELL, TINTNER & PICCOLA 315 N. Front Street PO Box 741 Harrisburg, PA 17108-0741 (717) 236-9377 (717)236-9316-fax Itintnerftbtpalaw.com Attorneys for Plaintiff THE DREXEL GROUP, INC., PLAINTIFF : IN THE COURT OF COMMON PLEAS : CUMBERLAND COUNTY PENNSYLVANIA' V. CARLETON COMMUNICATIONS, INC., DEFENDANT NO. D $- 9 4 3 F Lc' ,v CIVIL ACTION - LAW NOTICE YOU HAVE BEEN SUED IN COURT. If you wish to defend against the claims set forth in the following pages, you must take action within twenty (20) days after this Complaint and Notice are served, by entering a written appearance personally or by attorney and filing in writing with the Court your defenses or objections to the claims set forth against you. You are warned that if you fail to do so, the case may proceed without you and a judgment may be entered against you by the Court without further notice for any money claimed in the Complaint 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 OR CANNOT AFFORD ONE, GO TO OR TELEPHONE THE OFFICE SET FORTH BELOW TO FIND OUT WHERE YOU CAN GET LEGAL HELP. CUMBERLAND COUNTY BAR ASSOCIATION 32 S. Bedford Street Carlisle, PA 17013 (717) 249-3166 NOTICIA Le han demandado a usted en la corte. Si usted quiere defenderse de estas demandas expuestas en [as paginas siguientes, uted tiene viente (20) dias de plazo al partir de la fecha de le demanda y la notificacion. Usted debe presentar una apariencia escrita o en persona o por abogado y archivar en la corte en forma escrita sus defensas os sus objeciones a leas demandas en contra de su persons. Sea avisado que si usted no se defiende, la corte tomara medidas y peude entrar una order contra usted sin pervio aviso o notificacion y por cualquier queja or alivio que es pedido en la peticion de demanda. Usted peude perder dinero os sus propiedades o ostros derechos importantes para usted. LLEVE ESTA DEMANDA A UN ABODAGO IMMEDIATAMENTE. SI NO TIENE ABOGADO O SI NO TIENE EL DINERO SUFICIENTE DE PAGAR RAL SERVICIO, VAYA EN PERSONA O LLAME POR TELEFONE A LA ICINA CUYA DIRECCION SE ENCUENTRA ESCRITA ABAJO PARA VERIGUAR DONDE SE UEDE CONSEGUIR ASISTENCIA LEGAL. CUMBERLAND COUNTY BAR ASSOCIATION 32 S. Bedford Street Carlisle, PA 17013 (717) 249-3166 Leonard Tintner, Esquire Supreme Court I.D. #06859 BOSWELL, TINTNER & PICCOLA 315 N. Front Street PO Box 741 Harrisburg, PA 17108-0741 (717) 236-9377 (717) 236-9316 - fax ItintnerObtpalaw.com Attorneys for Plaintiff THE DREXEL GROUP, INC., PLAINTIFF V. CARLETON COMMUNICATIONS, INC., DEFENDANT IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY PENNSYLVANIA' NO. 0 OR-' V q-3 ?-cjv-i + rm CIVIL ACTION - LAW COMPLAINT Plaintiff, The Drexel Group, Inc., by its attorneys, Leonard Tintner, Esquire, and Boswell, Tintner & Piccola, and presents its complaint against Defendant, Carleton Communications, Inc., as follows: 1. Plaintiff, The Drexel Group, Inc., is a Pennsylvania corporation, with its office located at 1832 Market Street, Camp Hill, Cumberland County, Pennsylvania 17011. 2. Defendant, Carleton Communications, Inc., is a Pennsylvania corporation, with its principal place of business located at 937 Nixon Drive, Mechanicsburg, Cumberland County, Pennsylvania 17055. -1- BREACH OF CONTRACT 3. Paragraphs 1-2 are incorporated herein as if as if fully reproduced herein. 4. Plaintiff is a business that supplies temporary workers to customers who desire same. 5. In March 2007, Plaintiff and Defendant entered into a contract for the supply of temporary personnel. A copy of the executed Contract is attached hereto and identified as Exhibit "A." 6. Temporary workers were supplied by Plaintiff, as employees of Plaintiff, and were employed at Defendant's business from March 2007 through September 2007. 7. From March 2007 through September 2007, the following temporary workers were employed at Defendant's place of business: Ricki C. Chisholm, Heather N. Courtney, Marior J. Morales, Richard A. Sherwood, Davon Williams, Yaskany Morales and John Mackley, 8. Defendant was billed on a weekly basis, which invoices prior to May 24, 2007, were paid. 9. The unpaid invoices due to Plaintiff are from work performed by its employees May 14, 2007 through the week ending September 27, 2007. Copies of the invoices are attached hereto and identified hereto as Exhibit "B." -2- 10. The amount due on the invoices supplied to Defendant totals $30,872.47. 11. Defendant has made payments totaling $3,588.34 on the amount due and owing. 12. The current outstanding balance due is $27,284.05. 13. Despite Plaintiffs numerous attempts to collect this amount, Defendant has continuously refused to make payment to Plaintiff for the balance due. WHEREFORE, Plaintiff demands judgment in an amount not in excess of $50,000.00, which amount requires submission of this matter to compulsory arbitration, plus interest and costs of suit. COUNT II UNJUST ENRICHMENT 14 Plaintiff incorporates Paragraphs 1 through 13 as if fully reproduced herein. 15. Plaintiff provided Defendant with employees performing labor, as reqeusetd by Defendant, totaling $27,284.05; Plaintiff having done so to the benefit of Defendant, Defendant became liable for the just and reasonable amount of the hourly rate paid to Plaintiffs employees. 16. Defendant has been unjustly enriched by accepting the labor of Plaintiff's employees and not paying the total amount due for the same. 17. Plaintiff has demanded that Defendant pay the total amount due, but Defendant has refused to do so. -3- WHEREFORE, Plaintiff demands judgment in an amount not in excess of $50,000.00, which amount requires submission of this matter to compulsory arbitration, plus interest and costs of suit. RESPECTFULLY SUBMITTED, BOSWi?LL/VINTNER BY: L,?06natd Tintrrer, Esquire Attorney for Plaintiff The Drexel Group, Inc. DATE: August 15, 2008 -4- DR br EL GROUP I Ne. OIL Ne. 1832 Market Street phone: 717-730-9841 camp )gill, PA 17011 Fmt: 717-730-9845 March 15, 2007, Mike Couch, Carleton Communications Inc. 937 Nixon Drive Mechanicsburg Pa 17055 Dear Mr. Couch, ! would like to take this opportunity to thank you for considering The Drexel Group, Inc. for your staffing solutions. As we discussed, The Drexel Group, Inc. will provide a temporary employee, Rick! Chisolm, to start as a temp to hire position at your company for the 3`d shift 11:00 p.m. to 7:00 a.m. We will apply the hours worked started on March 13, 2007 and deduct them from the 480, required to become your employee. After 480 work hours Rick! will become your permanent employee with no additional cost to your company. The agreed bilw r hour. If employee Is needed for overtime which is over 40 hours per weeand half for the over time hours only. This rate includes 6 employee pay ayroll taxes, advertising, interviewing, unemployment compensation, workers compensation coverage. ?I Once again, I would like to thank you for your consideration, and The Drexel Croup, Inc. looks forward to servicing your company. If there are any questions or concerns that I may assist you 0 with, please contact me at your earliest convenience.. SI l ely. ` f wren Shirk Business Development The Drexel Group, Inc. 1832 Market Street Camp Hill, PA 17011 ?'j'?ti Phone: 717-730-9841 Fax: 717-730-9845 Cell 717.612.581124/7 service :::.F-mail: karen agbedrexelorouo.com Signature ` Date J ?"' 7 The Drexel Group, Inc. INVOICE 1832 Market Street Camp Hill, PH 17011 Phone: 717-730-9841 Fax: 717-730-4048 978'35 05/24/2007 1722 05/20/2007 1 :::1 CARLETON COMMUNICATIONS BOB BEERS 937 NIXON DR MECHANICSBURG, PA 17055 BOB BEERS 937 NIXON DR MECHANICSBURG, PA 17055 CHISHOLM, RICKI C CHISHOLM RICKI C R 40.OOHRS @ /2.7f ,13.07 = 510, 39 7 $52g?00 , OT 3.OOHRS @ /9./3 18'56 = 5 350 COURTNEY, HEATHER NI R 40.OOHRS @ 11,73 1Y.S6 = 510 pO 1540* COURTNEY, HEATHER NI OT 9.50HRS @ /j,/,? 20.ES = /s/ 7y $ MORALES; VARIO J R 26.25HRS @ 12.15 13:-,X = 33,4_0 - SHERWOOD, RICHARD A R 34.25HRS @ /2.75 12'15 = 1-13 to /r9 WILLIAMS, DAVON R 40.OOHRS @ J2-15 jj-M = 00 1510 $S"-K WILLIAMS, DAVON OT 2.50HRS 19.13 282 = R 3 y7 83 $56:63 TOTAL CHARGES $2 58 •?? 5$8 3b 2 f83y Page, Total Due Please return this portion with your payment Disregard this notice if payment has been made. TERMS: Due Upon Receipt. REMIT TO: The Drexel Group, Inc. PO Box 742 Camp Hill, PA 17011 ? ,2, 38831 The Drexel Group, Inc. INVOICE 1832 Market Street Camp Hitt, Pfl 17011 Phone:717-730-9841 fax:717-730-4048 97835 06/01/2007 1759 05/27/2007 CARLETON COMMUNICATIONS BOB BEERS 937 NIXON DR MECHANICSBURG, PA 17055 BOB BEERS 937 NIXON DR MECHANICSBURG, PA 17055 Releten(c Description ArTiDunt CHISHOLM, RICKI C R 40.OOHRS @ 12.75 _ omm 9o - X040 6 , CHISHOLM, RICKI C OT 2.25HRS @ /9./3 ;U = Y3 $?g COURTNEY, HEATHER NI R 40.OOHRS @ /2.75 13-30 = 00 5/0 Z(0 $ COURTNEY, HEATHER NI OT 7.75HRS @ /9. 0 ?g?15 = /H8 $4 MORALES, MARIO J _ -.._..__R.. :... 40.OOHRS @. /2.75 .33 < = 6/0 °-o $548'00 MORALES, MARIO J OT 8.50HRS @ 1193 2A:25 = /.oPz b/ $f•7R'T3 5/20/2007 MORALES, MARIO J R 8.OOHRS @ 12.75 4a- 56 = °o /OZ $x-60 SHERWOOD, RICHARD A R 40.OOHRS @ 12,75 -U n = 1j /o pO $y1rti0 SHERWOOD, RICHARD A OT 3.75HRS @ /9•/3 1,9.1.3 = 71 7,1/ V4-f4 WILLIAMS, DAVON R 40.OOHRS @ /2,-)-5 L3. = ? ?/? ao $ 544 WILLIAMS, DAVON OT 7.75HRS /9. 13 20!15 A17 z6 $ "94 TOTAL CHARGES $ 3 3,;? -R 5'/ 3,Z25 Page, Total Due .- Please return this portion with your payment Disregard this notice if payment has been made. Customer ID TERMS: Due Upon Receipt. 97835 Invoice iDat "C' :,4 VVeekending D. REMIT TO: 1-06MI/2007 -- 1790 0512712007 The Drexel Group, Inc. PO Box 742 Camp Hill, PA 17011 ? ???X59( $,3„ 189.63 The Drexel Group, inc. iNVOicE 1832 Market Street Camp Hitt, PH 17011 Phone: 717-730-9841 Fax: 717-730-4048 Customer 'O Numbei • Date 97835 06/07/2007 1789 06/03/2007 CARLETON COMMUNICATIONS BOB BEERS 937 NIXON DR MECHANICSBURG, PA 17055 BOB BEERS 937 NIXON DR MECHANICSBURG, PA 17055 • • • CHISHOLM, RICKI C R 40.OOHRS @ /?.?S }QS = /DpO CHISHOLM, RICKI C OT 7.75HRS @ /1'/-? COURTNEY, HEATHER NI R 40.OOHRS @ 12.75 13-Q = 5)0 °D W w- COURTNEY, HEATHER NI OT 18.50HRS @ 19.1.3 2G29 = 3 53 91 W*13 ._=. MORALES, MARIO J - - -#2 -AO,.OOHRS-@ 12,73 j4!56 -51 d pO- - g9gg,db - .. MORALES, MARIO J OT 2.25HRS @ 19.13 2o2n = if3 ` W.'s SHERWOOD, RICHARDA R 40.OOHRS @ X ,75 1, = 31a oo $ 'Qd SHERWOOD; RICHARD A OT 5.50HRS @ 19./3 22- /o5 $ "-n WILLIAMS, DAVON R 40.OOHRS @ /2.73 12.50 = o /50 510- WILLIAMS, DAVON OT 31.25HRS 19•/3 2025 = 31 59'7 TOTAL CHARGES 3, -7 9.8 'y 3 7982AI Page, Total Due Please return this portion with your payment Disregard this notice if payment has been made • TERMS: Due Upon Receipt. 97835 oice Date IrIV0,C(, Wcekending Date Inv REMIT TO: The Drexel Group, Inc. PO Box 742 Camp Hill, PA 17011 • 3?7gf 2`/ The Drexel Group, Inc. ! N VO t c E It 32 Market Street Camp Hill, Pfl 17011 Phone:717-730-9841 Fai: 717-730-4048 Customer ID PO Number invoice [)dt(, Invoic(7 Weekending Date 97835 06/14/2007 1821 06/10/2007 CARLETON COMMUNICATIONS BOE BEERS 937 NIXON DR MEC'HANICSBURG, PA 17055 BOB BEERS 937 NIXON DR MECHANICSBURG, PA 17055 Description ArnDu nt CHISHOLM, RICKI C R 30.25HRS @ /2.73.a.a-of = 383 $393 COURTNEY, HEATHER NI R 40.OOHRS @ /? •75 .?3? = 510 00 §54"0 COURTNEY, HEATHER NI OT 6.OOHRS @ 19:13 2085 = //y 78 $12"Z MORALES, MARIO J R 40.OOHRS @ /2.73 J3-< = ?5/p X5'8' MORALES, MARIO-J-._ _. _._ ._- ,• OT 1.75HRS @ 19.1.3 ;30.'15 = 33 98 ^ MORALES, YASKANY R 34.50HRS @ 12,75 12rT6 = .1-1-39 00 g WILLIAMS, DAVON R 40.OOHRS @ ?Z X5,3, = 510 -71 WILLIAMS, DAVON OT 6.OOHRS 201x= 1 50 TOTAL CHARGES . 57 Page Total Due Please return this portion with your payment. Disregard this notice if payment has been made. C-US401'ner ID PO Number TERMS: Due Upon Receipt. 97835 Invoice Date Invoice Weekending Date REMIT TO: 1A21 08110 007 The Drexel Group, Inc. PC) Box 742 Camp Hill, PA 17011 INVOICE TOTAL x-5'1 The Drexel Group, Inc, INVOICE 1832 market Street Camp Hill, Pfl 17011 Phone: 717-730-9841 fax: 717-730-4048 Customer ID Pt Number I Invoice Date Invoice 41f Weekending Date 1 97835 06/21/2007 1854 06/17/2007 CARLETON COMMUNICATIONS BOB BEERS 937 NIXON DR MECHANICSBURG, PA 17055 BOB BEERS 937 NIXON DR MECHANICSBURG, PA 17055 stir COURTNEY, HEATHER NI COURTNEY, HEATHER NI MORALES, MARIO J MORALES, YASKANY s - WtLL1AMS, DAVON WILLIAMS, DAVON R OT R R R--,-. OT 40.OOHRS @ A? 15 13!55 _ 6.75HRS @ /qJ3 IQ-?T = 5.50HRS @ 12.75 „13-K = 5.50HRS @ /2.75 12-?T = 40.00HRS @ 12:73 33.6'0" _ 13.OOHRS /9 13 ,2@'15 = 570o10 $546'ff /?z 9 U" 70 i3 70 $?BT3 -51 O o0 60?. 2 H8 ?? s2es,r TOTAL CHARGES $ ,32 ° s i, s'ss / 538 oB Page. Total Due Please return this portion with your payment Disregard this notice if payment has been made. Customer ID PO Numbet TERMS: Due Upon Receipt. 97835 'Invoice Date ee ending Date REMIT TO: The Drexel Group, Inc. PO Box 742 Camp Hill, PA 17011 INVOICE /? 53S' U TOTAL J B2fk32 1ne Drexel Group, inc. INVOICE 1832 market Street Camp Hill, Pfl 17011 Phone: 717-730-9841 Fax: 717-730-4048 Customer ID •O Number Date 97835 06/28/2007 1883 06/24/2007 • CARLETON COMMUNICATIONS BOB BEERS 937 NIXON DR MECHANICSBURG, PA 17055 BOB BEERS 937 NIXON DR MECHANICSBURG, PA 17055 keference • , HEATHER NI R 40.OOHRS @ !2.75 J.8r8>r= pO ,510 , HEATHER NI OT 22.75HRS @ /'./3.2"5 = H3 5 z/ X468'6'§ MACKLEY, OHN R. R 2.OOHRS @ /?.7S 13-W = 25 5° 7 ARIO J R 15.OOHRS @ /2. 75 13-W = 25 4SKANY ._ R -7.OOHRS @ 12,73 12? _ 8 AVON R 40.OOHRS @ 12.75 ? = 510 oa AVON OT 22.75HRS 26.25 = 11353'1 $469'89 TOTAL CHARGES $Z,3E0-13 .? / 9G yz Page Total Due _ Please return this portion with your payment Disregard this notice if payment has been made. Customer ID PO Number TERMS: Due Upon Receipt. 97835 Invoice Date • Weekendincy Date REMIT TO: Q9/2A/2nQ7 1 A R.14 06194/2007 71 The Drexel Group, Inc. PO Box 742 Camp Hill, PA 17011 •? J?-33 i ne urexei croup, i ne. ?v vo t c 1832 market Street Camp Hill, PH 17011 Phone: 717-730-9841 Fax: 717-730-4048 Customer ID . PO Number • . Weekencling Date 97835 07/05/2007 1908 07/0112007 CARLETON COMMUNICATIONS BOB BEERS 937 NIXON DR MECHANICSBURG, PA 17055 BOB BEERS 937 NIXON DR MECHANICSBURG, PA 17055 Reference Descriptior f =I Amount COURTNEY, HEATHER NI R 40.OOHRS @47-75 -la-IT = * 510' * COURTNEY, HEATHER NI OT 8.25HRS @ I V3 20 no = /37 RZ P157 S6 MACKLEY, JOHN R. R 7.50HRS @ 12.75 13 = q5 ?°? $19'1 15 MORALES, MARIO J R 32.75HRS @ /-1.75 13-10 = y/7$44rn WILLIAMS., DAWN-. ?--40:UGHRS-e@ /2-75. $a< = 0-. WILLIAMS, DAVON OT ffi.50HRS .2e?-5 = 315, $333 TOTAL CHARGES $ .2) oo(o 64' lo(e ? G?(o Page Total Due Please return this portion with your payment Disregard this notice if payment has been made. Custorner'll) PO Number TERMS: Due Upon Receipt. 97835 Invoice D. Invoice 1 Weekending Date REMITTO: OZ1/ 007 The Drexel Group, Inc. PO Box 742 Camp Hill, PA 17011 INVOICE 200 TOTAL me ure- xel Group Inc. INVOICE 1832 Market Street Camp Hill, PH 17011 Phone: 717-730-9841 Fax: 717-730-4048 Customer PO Number, ?. • 97835 1007112/2007 1934 07/08/2007 CARLETON COMMUNICATIONS BOB BEERS 937 NIXON DR MECHANICSBURG, PA 17055 BOB BEERS 937 NIXON DR MECHANICSBURG, PA 17055 Reletenc(; Description COURTNEY, HEATHER NI R 40.OOHRS @ /2.75 13-Jr = $ l D o o $54fl'f? COURTNEY, HEATHER NI OT 7.25HRS @ 20-25 = /3$ 69 MORALES, MARIO J R 40.OOHRS @ /2.75-13r9Vr= 5100' $, 4'U O MORALES, MARIO J OT 4.50HRS @ /9./.3 28'19-= $ 6 °9 IyIORALES, XASKANY._.•.. - R - 1175HRS /2.7 31 . .. . WILLIAMS; DAVON R 40.OOHRS @ 12.75 ja-s'= ? j p 00 U4 p0 WILLIAMS, DAVON OT 5.50HRS /9.?.3,1s2r= J05 2z $w-58 TOTAL CHARGES .$2,144.63 .21035 3/ 3/ o?D 33 Page, Total Due _ Please return this portion with your payment Disregard this notice if payment has been made. Customer 0 Number TERMS: Due Upon Receipt. 197835 Invoice Date lNeekending Date REMIT TO: The Drexel Group, Inc. PO Box 742 Camp Hill, PA 17011 • 203531 x` 63 The. Drexel Group, Inc. INVOICE 1832 Market Street Camp Hill, PA 17011 Phone:717-730-9841 fax: 717-730-4048 Customer ID PO Number Invoice Date Invoice # Weekending Date 97835 =07/26/2007 1982 07/22/2007 CARLETON COMMUNICATIONS BOB BEERS 937 NIXON DR MECHANICSBURG, PA 17055 BOB BEERS 937 NIXON DR MECHANICSBURG, PA 17055 Reietenc.(; Description COURTNEY, HEATHER NI R 40.OOHRS @ 42.73 1,3.W= 510 om $54B pp COURTNEY, HEATHER NI OT 15.50HRS @ /9.13 28125 = 296 52 $8 MORALES, MARIO J R 34.25HRS @ 12.75 13-W = y36 $? MORALES, YASKANY R 16.25HRS @ 12.5 (yp5 = /9 .20-7 9 WILLIAMS, DAVON R - - 40.OOHRS @ iz.-75 13.56 = : o - q.. -510 25 $glp-DO.. WILLIAMS, DAVON OT 19.25HRS @ /s i3 292r= 3&1? $3801 TOTALCHARGES $ 6 a,3ZS "5 Page Total Due Please return this portion with your payment Disregard this notice if payment has been made. Customer ID 110 Number TERMS: Due Upon Receipt. 797835 Invoice D. • • Date 1 REMIT TO: The Drexel Group, Inc. PO Box 742 Camp Hill, PA 17011 0 ?, 348' s The Drexel Group, Inc. INVOICE 1832 market Street Camp Hill, Pfl 17011 Phone: 717-730-9841 fax: 717-730-4048 Customer ID PO Number i Weekending Date 97835 08/02/2007 2008 07/29/2007 CARLETON COMMUNICATIONS BOB BEERS 937 NIXON DR MECHANICSBURG, PA 17055 BOB BEERS 937 NIXON DR MECHANICSBURG, PA 17055 Description Amount COURTNEY, HEATHER NI R 40.OOHRS @ 12.75 = $510.00 COURTNEY, HEATHER NI OT 9.25HRS @ 19.13 = $176.95 MORALES, MARIO J R 40.OOHRS @ 12.75 = $510.00 MORALES, MARIO J OT 0.25HRS @ 19.13 = $4.78 WILLIAMS, DAVON "-- - R 40.OOHRS @ 12175 = $510.00 WILLIAMS, DAVON OT 2.OOHRS @ 19.13 = $38.26 TOTAL CHARGES $1,749.99 Page 1 Total Due $1,749.99 Please return this portion with your payment Disregard this notice if payment has been made. Customer ID iPO Number TERMS: Due Upon Receipt. 97835 Jnv oice 1. Weekending 6. REMIT T®: 08/02/2007 2008 07/29/2007 The Drexel Group, Inc. PO Box 742 Camp Hill, PA 17011 INVOICE TOTAL $1,749.99 The Drexel Group, Inc. INVOICE 1832 market Street Camp Hill, PH 17011 Phone:717-730-9841 fax: 717-730-4048 ¦ F- Customer ID PO Number Jr,,voice Date Weekending Date 97835 08109/2007 2032 08/05/2007 CARLETON COMMUNICATIONS BOB BEERS 937 NIXON DR MECHANICSBURG, PA 17055 BOB BEERS 937 NIXON DR MECHANICSBURG, PA 17055 Descriptmri e COURTNEY, HEATHER NI R 40.OOHRS @ 12.75 = $510.00 COURTNEY, HEATHER NI OT 1.50HRS @ 19.13 = $28.70 MORALES, MARIO J R 26.OOHRS @ 12.75 = $331.50 WILLIAMS, DAVON R 40.OOHRS @ 12.75 = $510.00 WILLIAMS; DAVON= OT .1.50HRS @ - 19.13 = _.._$28,70 _- TOTAL CHARGES - $1,408.90 Page 1 Total Due $1,408.90 Please return this portion with your payment. Disregard this notice if payment has been made. • .e Customer]D TERMS: Due Upon Receipt. 97835 71 • 1. • REMIT TO: 08/09/2007 2032 08/0512007 The Drexel Group, Inc. PO Box 742 Camp Hill, PA 17011 • • $1,408.90 The Drexel Group., Inc. INVOICE 1832 market Street Camp Hill, PH 17011 Phone: 717-730-9841 Fax: 717-730-4048 Customer ID PO Number Invoice,# Weekending,Date 77 08/16/2007 2057 08/12/2007 CARLETON COMMUNICATIONS BOB BEERS 937 NIXON DR MECHANICSBURG, PA 17055 BOB BEERS 937 NIXON DR MECHANICSBURG, PA 17055 Reference Description Arn0Ljnt COURTNEY, HEATHER NI R 40.OOHRS @ 12.75 = $510.00 COURTNEY, HEATHER NI OT 1.50HRS @ 19.13 = $28.70 MORALES, MARIO J R 7.OOHRS @ 12.75 = $89.25 WILLIAMS, DAVON R 40.OOHRS @ 12.75 = $510.00 WILLIAMS,•DAVON OT -- 1.-60HRS @ 19.13 _ $28.70 TOTAL CHARGES _- $1,166.65 Page 1 Total Due $1,166.65 Please return this portion with your payment Disregard this notice # payment has been made. • '• Number TERMS: Due Upon Receipt. F797835 'Invoice D. • - • Date REMIT TO: 0811612007 2057 08/12/2007 The Drexel Group, Inc. PO Box 742 Camp Hill, PA 17011 INVOICE TOTAL $1,166.65 The Drexel Group, Inc. INVOICE 1832 market Street Camp Hill, Pfl 17011 Phone: 717-730-9841 fax: 717-730-4048 •• Number • Weekending D ate 97835 0812312007 2077 08/19/2007 CARLETON COMMUNICATIONS BOB BEERS 937 NIXON DR MECHANICSBURG, PA 17055 BOB BEERS 937 NIXON DR MECHANICSBURG, PA 17055 Please return this portion with your payment Disregard this notice if payment has been made. Customer 'i TERMS: Due Upon Receipt. 97835 Invoice D. • ®. REMITTO: 0812312007 2077 08/19/2007 The Drexel Group, Inc. PO Box 742 Camp Hill, PA 17011 C TOTAL $1,020.00 The Drexel Group, Inc. INVOICE 1832 market Street Camp Hill, Pfl 17011 Phone: 717-730-9841 fax: 717-730-4048 Customer 11) Invoi(e Date I Invoice # • Weekending 'Date 97835 0813012007 2099 08126/2007 CARLETON COMMUNICATIONS BOB BEERS 937 NIXON DR MECHANICSBURG, PA 17055 Please return this portion with your payment. Disregard this notice if payment has been made. Custome,-ID PO Number TERMS: Due Upon Receipt. 97835 Invoice .invoice ' . REMIT TO: 08/30/2007 2099 08/26/2007 The Drexel Group, Inc. PO Box 742 Camp Hill, PA 17011 BOB BEERS 937 NIXON DR MECHANICSBURG, PA 17055 INVOICE TOTAL $892.51 The Drexel Group, Inc, INVOICE 1832 Market Street Camp Hilt, Pfl 17011 Phone: 717-730-9841 fax: 717-730-4048 Customer P• Number • • D. 1 97835 09/06/2007 2124 09/02/2007 CARLETON COMMUNICATIONS BOB BEERS 937 NIXON DR MECHANICSBURG, PA 17055 BOB BEERS 937 NIXON DR MECHANICSBURG, PA 17055 Please return this portion with your payment. Disregard this notice if payment has been made. Customer ID PO'Number TERMS: Due Upon Receipt. 97835 Invoice Date Invoice Weekending Date REMIT TO: o9/06/2007 2124 09/02/2007 The Drexel Group, Inc. PO Box 742 Camp Hill, PA 17011 INVOICE TOTAL $533.91 The Drexel Group, Inc. INVOICE 1832 !Market Street Camp Hill, PH 17011 Phone:717-730-9841 fax:717-730-4048 Customer I D PO Number Invoice Date Invoice tt I • 09/13/2007 2150 0910912007 777 31 CARLETON COMMUNICATIONS BOB BEERS 937 NIXON DR MECHANICSBURG, PA 17055 BOB BEERS 937 NIXON DR MECHANICSBURG, PA 17055 Please return this portion with your payment. Disregard this notice if payment has been made. Customer ?ID PO Number TERMS: Due Upon Receipt. 97835 • 1-961.1 6. REII IT TO: 09/13/2007 2150 09/0912007 The Drexel Group, Inc. PO Box 742 Camp Hill, PA 17011 t • $1,020.00 The Drexel Droup, inc. 1832 market Street :amp hill, Pfl 17011 Phone:717-730-9841 fax: 717-730-4048 INVOICE Customer ID PO Number Invoice Date "leekending Date 9777 F 09/20/2007 2179 09/16/2007 CARLETON COMMUNICATIONS BOB BEERS 937 NIXON DR MECHANICSBURG, PA 17055 BOB BEERS 937 NIXON DR MECHANICSBURG, PA 17055 Please return this portion with your payment. Disregard this notice if payment has been made. Customer ID TERMS: Due Upon Receipt. 97835 Invoice !. Weekending !. REMIT TO: 09/20/2007 2179 0911612007 The Drexel Group, Inc. PO Box 742 Camp Hill, PA 17011 INVOICE TOTAL $514.78 The Drexel Group, Inc. INVOICE 1832 market Street Camp Hill, PH 17011 Phone:717-730-9841 fax: 717-730-4048 Customer ID PO Number -Weekendirig Date 97835 09/27/2007 2212 09/23/2007 CARLETON COMMUNICATIONS BOB BEERS 937 NIXON DR MECHANICSBURG, PA 17055 BOB BEERS 937 NIXON DR MECHANICSBURG, PA 17055 Please return this portion with your payment. Disregard this notice ii payment has been made. Customer ID PO Number TERMS: Due Upon Receipt. 97835 • m • 1, REMIT TO: 09/27/2007 2212 09/23/2007 The Drexel Group, Inc. PO Box 742 Camp Hill, PA 17011 $229.51 v THE DREXEL GROUP, INC., : IN THE COURT OF COMMON PLEAS PLAINTIFF : CUMBERLAND COUNTY PENNSYLVANIA' V. . NO. CARLETON COMMUNICATIONS, INC., DEFENDANT : CIVIL ACTION - LAW VERIFICATION I, Robert Johnson, Secretary of The Drexel Group, Inc., Plaintiff, hereby verify that the facts contained in the foregoing Complaint are true and correct to the best of my knowledge, information and belief. I understand that false statements herein are subject to the penalties of 18 Pa.C.S.A. §4904 relating to unsworn falsification to authorities. G)- ROBERT JOHN DATE: THE DREXEL GROUP, INC., PLAINTIFF V. CARLETON COMMUNICATIONS INC., , DEFENDANT I, Romayne R. Johnson, : IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY PENNSYLVANIA' . NO. : CIVIL ACTION - LAyy VERIFICATION President of The Drexel Group, Inc., Plaintiff, hereby verify that the facts contained in the foregoing Complaint are true and of my knowledge, information and belief. I understand correct to the best that false statements herein are subject to the penalties of 18 Pa.C.S.A. §4904 relating to unsworn falsification to authorities. A!VNE R JOHN ON DATE: o r ?a Co ' V -?Al ( ( SHERIFF'S RETURN - REGULAR CASE NO: 2008-04938 P COMMONWEALTH OF PENNSYLVANIA: COUNTY OF CUMBERLAND DREXEL GROUP INC THE VS CARLETON COMMUNICATIONS INC ROBERT BITNER , Sheriff or Deputy Sheriff of Cumberland County,Pennsylvania, who being duly sworn according to law, says, the within COMPLAINT & NOTICE was served upon CARLETON COMMUNICATIONS INC the DEFENDANT , at 1115:00 HOURS, on the 26th day of August 2008 at 937 NIXON DRIVE MECHANICSBURG, PA 17055 by handing to YVETTE PICKEL, ADULT IN CHARGE a true and attested copy of COMPLAINT & NOTICE together with and at the same time directing Her attention to the contents thereof. Sheriff's Costs: ? Docketing 7/4/ 08 Service Postage Ott Surcharge So Answers: 18.00 11.00 .59 ? 10.00 R. Thomas Kline .00 39.59 08/27/2008 BOSWELL TINTNER PICCOLA Sworn and Subscibed to before me this day By: Deputy Sheriff of A. D. Leonard Tintner, Esquire Supreme Court I.D. #06859 BOSWELL, TINTNER & PICCOLA 315 N. Front Street PO Box 741 Harrisburg, PA 17108-0741 (717) 236-9377 (717)236-9316-fax I1tintner9bbtpalaw.com Attorneys for Plaintiff THE DREXEL GROUP, INC., PLAINTIFF V. CARLETON COMMUNICATIONS, INC., DEFENDANT : IN THE COURT OF COMMON PLEAS : CUMBERLAND COUNTY PENNSYLVANIA' NO. 08-4938 CIVIL ACTION - LAW NOTICE TO: CARLETON COMMUNICATIONS, INC. DATE OF NOTICE: SEPTEMBER 22, 2008 You are in default because you have failed to enter a written appearance personally or by an attorney and file in writing with the Court your defenses or objections to the claims set forth against you. 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 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, PA 17013 (717) 249-3166 BOSWELL, TINTNER & PICCOLA By: x? A" eonard Tintner, Esquire DATE: September 22, 2008 CERTIFICATE OF SERVICE I do hereby certify that I have served on this date a true and correct copy of the foregoing Notice on the following by first-class mail, postage prepaid and addressed as follows: Carleton Communications, Inc. 937 Nixon Drive Mechanicsburg, PA 17055 a/ ?_. ta "?' Denise L. Foster, Paralegal Date: September 22, 2008 cx? b'_.. cn m (V r) lqi ? ,C -C - r Leonard Tintner, Esquire Supreme Court I.D. #06859 BOSWELL, TINTNER & PICCOLA 315 N. Front Street PO Box 741 Harrisburg, PA 17108-0741 (717) 236-9377 (717)236-9316-fax Itintner tbtpalaw.com Attorneys for Plaintiff THE DREXEL GROUP, INC., PLAINTIFF V. CARLETON COMMUNICATIONS, INC., DEFENDANT : IN THE COURT OF COMMON PLEAS : CUMBERLAND COUNTY PENNSYLVANIA' NO. 08-4938 CIVIL ACTION - LAW PRAECIPE TO THE PROTHONOTARY: KINDLY ENTER JUDGMENT in favor of Plaintiff and against the Defendant, Carleton Communications, Inc., in the amount of $27,284.05, plus interest at the legal rate of 6% , and costs of suit, for failure to answer a properly endorsed complaint. The 10-Day Notice was given to the Defendant on September 22, 2008. A copy of the Notice is attached hereto as Exhibit "A." BOSWELL, T By: ER & PICCOLA 7 DATE: October 3, 2008 M ? r i C(OPY Leonard Tintner, Esquire Supreme Court I.D. #06859 BOSWELL, TINTNER & PICCOLA 315 N. Front Street PO Box 741 Harrisburg, PA 17108-0741 (717) 236-9377 (717)236-9316-fax ItintnerAbtpalaw.com Attorneys for Plaintiff THE DREXEL GROUP, INC., PLAINTIFF IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY PENNSYLVANIA' V. : NO. 08-4938 CARLETON COMMUNICATIONS, INC., . DEFENDANT : CIVIL ACTION - LAW ty r77 NOTICE TO: CARLETON COMMUNICATIONS, INC. 37- - Tk -° C.0 jrn DATE OF NOTICE: SEPTEMBER 22, 2008 You are in default because you have failed to enter a written appearance personally or by an attorney and file in writing with the Court your defenses or objections to the claims set forth against you. 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 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, PA 17013 (717) 249-3166 BOSWELL, TINTNER & PICCOLA By: )4,A eonard Tintner, Esquire DATE: September 22, 2008 CERTIFICATE OF SERVICE do hereby certify that I have served on this date a true and correct copy of the foregoing Notice on the following by first-class mail, postage prepaid and addressed as follows: Carleton Communications, Inc. 937 Nixon Drive Mechanicsburg, PA 17055 Denise L. Foster, Paralegal Date: September 22, 2008 w . THE DREXEL GROUP, INC., PLAINTIFF V. CARLETON COMMUNICATIONS, INC., DEFENDANT : IN THE COURT OF COMMON PLEAS : CUMBERLAND COUNTY PENNSYLVANIA' NO. 08-4938 CIVIL ACTION - LAW CERTIFICATE OF RESIDENCE I hereby certify that the addresses of the parties in the above-captioned action are as follows: The Drexel Group 1832 Market Street Camp Hill, PA 17011 Plaintiff Carleton Communications 937 Nixon Drive Mechanicsburg, PA 17055 Defendant WELL, TINTNER & PICCOLA 1 'D'enise L. Foster, Paralegal O THE DREXEL GROUP, INC., PLAINTIFF V. CARLETON COMMUNICATIONS, INC., DEFENDANT : IN THE COURT OF COMMON PLEAS : CUMBERLAND COUNTY PENNSYLVANIA' NO. 08-4938 CIVIL ACTION - LAW TO: CARLETON COMMUNICATIONS, DEFENDANT You are hereby notified that on October 3, 2008, judgment has been entered against you in the above-captioned case in the amount of $27,284.05, plus interest at the legal rate of six (6%) percent, plus costs of suit. DATE: October 3, 2008 s " P. 42?r rothonotary I hereby certify that the following is the address of the DefendaIi 0Kd nt stated in the Certificate of Residence: Carleton Communications 937 Nixon Drive Mechanicsburg, PA 17055 TO: CARLETON COMMUNICATIONS, DEFENDANT Por este medio se le esta notificando que el October 3, 2008, el siguiente Fallo ha sido antodo en contra suya en el caso mencionado en el epigrafe. FECHA: October 3, 2008 Protonotario Certifico que la siguiente direccion es la del defendido/a segun indicada en el certificado de residencia: Carleton Communications 937 Nixon Drive Mechanicsburg, PA 17055 v IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY PENNSYLVANIA CIVIL DIVISION y-«g THE DREXEL GROUP, File No. Amount Due $27,284.05 PLAINTIFF Interest at legal rate of 6% from 8/18/08 Atty's Comm V. Costs CARLETON COMMUNICATIONS, INC., DEFENDANT TO THE PROTHONOTARY OF THE SAID COURT: The undersigned hereby certifies that the below does not arise out of a retail installment sale, contract, or account based on a confession of judgment, but if it does, it is based on the appropriate original proceeding filed pursuant to Act 7 of 1966 as amended; and for real property pursuant to Act 6 of 1974 as amended. PRAECIPE FOR EXECUTION Issue writ of attachment to the Sheriff of CUMBERLAND County, for debt, interest and costs, as above, directing attachment against the above-named garnishee(s) for the following property (if real estate, supply six copies of the description; supply four copies of lengthy personalty list) LEVY ON ALL PROPERTY, INCLUDING OFFICE EQUIPMENT, COMPUTERS, FURNITURE. APPLIANCES, TELEVISIONS. CASH. ETC., LOCATED AT: 937 NIXON DRIVE, MECHANICSBURG, PA 17055 and all other property for the defendant(s) in the possession, custody or control of the said garnishee(s). (Indicate) Index this writ against the garnishe ) as a lis pendens against real estate of the defendant(s) described in the attached exhibit. DATE: October 3, 2008 Signature: Print Name: eonard Tintner, Esquire Address: 315 N. Front St., P.O. Box 741 Harrisburg, PA 17108-0741 Attorney for: Plaintiff Telephone: (717) 236-9377 Supreme Court I.D. No.: 06859 %t 9s Su. ?O Eft C Q '.J\ c7 u I VC r d r-? Cy- c3? .a J • V ? lY ? ?'?.? - ; a 35 v' Leonard Tintner, Esquire Supreme Court I.D. #06859 BOSWELL, TINTNER & PICCOLA 315 N. Front Street PO Box 741 Harrisburg, PA 17108-0741 (717) 236-9377 (717)236-9316-fax Itintner(Mbtyalaw.com Attorneys for Plaintiff THE DREXEL GROUP, INC., PLAINTIFF V. CARLETON COMMUNICATIONS, INC., DEFENDANT : IN THE COURT OF COMMON PLEAS : CUMBERLAND COUNTY PENNSYLVANIA' NO. 08-4938 CIVIL ACTION - LAW PRAECIPE TO THE PROTHONOTARY: KINDLY ADD a Garnishee, Members 1St Federal Credit Union, to the Writ of Execution, originally filed with this Court on October 3, 2008. The levy should be made on any and all bank accounts, including savings and checking accounts, in the name of the Defendant, Carleton Communications, Inc. The address of Members 1St Federal Credit Union is: 1711 Spring Road, Carlisle, PA 17013. BOSWELL, TINTNER & PICCOLA By: jeo&narrd Ti tner, Esquire DATE: October 8, 2008 E?. ray' '"il --t A ?..... _T. f ,l In ^? I 4a 1 {...J WRIT OF EXECUTION and/or ATTACHMENT COMMONWEALTH OF PENNSYLVANIA) COUNTY OF CUMBERLAND) TO THE SHERIFF OF CUMBERLAND COUNTY: To satisfy the debt, interest and costs due THE DREXEL GROUP Plaintiff (s) From CARLETON COMMUNICATIONS, INC., 937 NIXON DRIVE MECHANICSBURG, PA 17055 (1) You are directed to levy upon the property of the defendant (s)and to sell LEVY ON ALL PROPERTY, INCLUDING OFFICE EQUIPMENT, COMPUTERS, FURNITURE, APPLICATIONS, TELEVISIONS, CASH, ETC., LOCATED AT: 937 NIXON DRIVE, N0084938 Civil CIVIL ACTION - LAW MECHANICSBURG, PA 17055. (2) You are also directed to attach the property of the defendant(s) not levied upon in the possession of MEMBERS 1sT FEDERAL CREDIT UNION, 1711 SPRING ROAD, CARLISLE, PA 17013 GARNISHEE(S) as follows: ANY AND ALL BANK ACCOUNTS, INCLUDING SAVINGS AND CHECKING ACCOUNTS, IN THE NAME OF THE DEFENDANT, CARLETON COMMUNICATIONS, INC. and to notify the garnishee(s) that: (a) an attachment has been issued; (b) the garnishee(s) is enjoined from paying any debt to or for the account of the defendant (s) and from delivering any property of the defendant (s) or otherwise disposing thereof, (3) If property of the defendant(s) not levied upon an subject to attachment is found in the possession of anyone other than a named garnishee, you are directed to notify him/her that he/she has been added as a garnishee and is enjoined as above stated. Amount Due$27,284.05 L.L.$.50 Interest AT LEGAL RATE OF 6% FROM 8/18/08 Atty's Comm % Due Prothy $2.00 Atty Paid $159.09 Plaintiff Paid Date: 10/03/2008 (Seal) REQUESTING PARTY: Other Costs C R. Long, Pp- By: Deputy Name LEONARD TINTNER, ESQUIRE Address: 315 N. FRONT STREET PO BOX 741, HARRISBURG, PA 17108-0741 Attorney for: PLAINTIFF Telephone: 717-236-9377 Supreme Court ID No. 06859 Leslie Tomeo, Esquire Attorney I.D. No. 200198 711 N. 2°d Street, Ste. 5 Harrisburg, PA 17102 Phone: (717) 525-0281 Email: l.tomeo a comcast Attornev for Defendant THE DREXEL GROUP, INC. Plaintiff IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA : No. 08-493 01 V. CARLETON COMMUNICATIONS, INC. : CIVIL ACTION -LAW Defendant MOTION TO VACATE DEFAULT JUDGMENT AND NOW, comes the defendant, Carleton Communications, by and through its counsel, Leslie Tomeo, Esquire, and files this Motion to Vacate Default Judgment averring as follows: 1. Defendant, Carleton Communications, was served with a complaint in the above captioned matter on August 23, 2008. 2. On or about the beginning of August 2008, CEO, Chuck Rothstein, severity unbeknownst to him, began experiencing health complications. 3. Mr. Rothstein's health condition and complications were a direct cause in the non response to this legal matter. 4. Mr. Rothstein was the person accountable for this matter and was personally handling it at the time when his health issues began and eventually led, most recently, to the onset of a coma. 5. Mr. Rothstein is now recuperating at home and wishes to have an opportunity to participate in the litigation process. Respectfully submitted, Dated: I oA/v? Leslie To eo, Esquire 711 N. 2° Street, Ste. 5 Harrisburg, PA 17102 (717) 525-0281 THE DREXEL GROUP, INC. V. Plaintiff CARLETON COMMUNICATIONS, INC. Defendant IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA :No. 08-4938 : CIVIL ACTION -LAW CERTIFICATE OF SERVICE I, Leslie Tomeo, Esquire, attorney for Defendant, do hereby certify that I this day served a copy of the Motion to Vacate Default Judgment upon the following via first class mail: Leonard Tinter, Esq. Boswell, Tinter & Piccola 315 N. Front Street PO Box 741 Harrisburg, PA 17105 Dated: l61?91o g Leslie Torn o, Esquire VERIFICATION I, Leslie Tomeo, hereby state that I am an attorney for Carleton Communications, Inc., the named Defendant in the above captioned litigation and that, while I do not have personal knowledge of all the facts recited in the foregoing Answer, the information contained therein has been collected and made available to me by others and the information contained therein is true and correct to the best of my knowledge and belief based upon the information made available to me. Dated: to%/Qg 0"Z'le 0" 111 eTome, Esquire JV Leslie Tomeo, Esquire Attorney I.D. No. 200198 711 N. 2°d Street, Ste. 5 Harrisburg, PA 17102 Phone: (717) 525-0281 Email: l.tomeo a,comcast.net Attorney for Defendant THE DREXEL GROUP, INC. Plaintiff :No. 08-4938 V. CARLETON COMMUNICATIONS, INC. IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA : CIVIL ACTION -LAW Defendant ANSWER AND NOW, comes the defendant, Carleton Communications, by and through its counsel, Leslie Tomeo, Esquire, and files this Answer averring as follows: 1. Defendant admits the averment contained within paragraph number 1. 2. Defendant admits the averment contained within paragraph number 2. BREACH OF CONTRACT 3. Paragraphs 1-2 are incorporated herein as if fully reproduced herein. 4. Defendant admits the averment contained within paragraph number 4. 5. Defendant admits the averment contained within paragraph number 5. 6. Defendant admits the averment contained within paragraph number 6. 7. Defendant admits the averment contained within paragraph number 7. 8. Defendant admits the averment contained within paragraph number 8. EAt b;t "11' 9. Defendant denies the averment contained within paragraph number 9. 10. Defendant denies the averment contained within paragraph number 10. 11. Defendant denies the averment contained within paragraph number 11. 12. Defendant denies the averment contained within paragraph number 12. 13. Defendant denies the averment contained within paragraph number 13. COUNT II UNJUST ENRICHMENT 14. Paragraphs 1 through 13 above are incorporated here as if fully reproduced herein. 15. Defendant denies the averment contained within paragraph number 15. 16. Defendant denies the averment contained within paragraph number 16. 17. Defendant denies the averment contained within paragraph number 17. Respectfully submitted, Dated: /0' '/? P l ` Leslie Tome Esquir490 e 711 N. 2°d S reet, Ste. 5 Harrisburg, PA 17102 (717) 525-0281 THE DREXEL GROUP, INC. Plaintiff IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA No. 08-4938 V. CARLETON COMMUNICATIONS, INC. CIVIL ACTION -LAW Defendant CERTIFICATE OF SERVICE I, Leslie Tomeo, Esquire, attorney for Defendant, do hereby certify that I this day served a copy of the Answer upon the following via first class mail: Leonard Tinter, Esq. Boswell, Tinter & Piccola 315 N. Front Street PO Box 741 Harrisburg, PA 17105 Dated: /o/9r/v 8' Leslie Tom o, Esquire VERIFICATION I, Leslie Tomeo, hereby state that I am an attorney for Carleton Communications, Inc., the named Defendant in the above captioned litigation and that, while I do not have personal knowledge of all the facts recited in the foregoing Answer, the information contained therein has been collected and made available to me by others and the information contained therein is true and correct to the best of my knowledge and belief based upon the information made available to me. Dated: 0/f /gyp eslie Tome ,Esquire ?i ? G:? l --s ? .... l_r' ? .y.,? ....y °i'y d s ' % .. j.3 .' ..?... • , p'. ... ?,? ) .„fie ;`} ;. '_ ?y;_ _.. 4;? ?`? ? :'fie , w a r i Leonard Tintner, Esquire Supreme Court I.D. #06859 BOSWELL, TINTNER & PICCOLA 315 N. Front Street PO Box 741 Harrisburg, PA 17108-0741 (717) 236-9377 (717)236-9316-fax ItintnerObtpalaw.com Attorneys for Plaintiff THE DREXEL GROUP, INC., PLAINTIFF : IN THE COURT OF COMMON PLEAS : CUMBERLAND COUNTY PENNSYLVANIA' V. NO. 08-4938 CARLETON COMMUNICATIONS, INC., DEFENDANT : CIVIL ACTION - LAW /An s w e r-S tv INTERROGATORIES TO GARNISHEE TO: MEMBERS 1ST FEDERAL CREDIT UNION IMPORTANT NOTICE TO GARNISHEE! A. You are required to file answers to the following interrogatories within twenty (20) days after service upon you. Failure to do so may result in judgment against you. B. The term "Defendant(s)" means the individual(s) against whom the Writ of Execution is issued. C. "You" means the main office and all branch offices of Members 1 st Federal Credit Union. D. By service of the Writ of Execution upon you, all property of the Defendant subject to the attachment which was then in your possession, custody or control was attached, including all property of the Defendant which comes in into your possession. f L $ . INTERROGATORIES IN ATTACHMENT 1. At the time you were served with these Interrogatories or any subsequent time, did you owe Carleton Communications, Inc., any money, were you liable to it on any negotiable or other written instrument, or did it claim that you owed it any money or were liable to it for any reason? no 2. At the time you were served with these Interrogatories or at any subsequent time, was there in your possession, custody or control or in the joint possession, custody or control of yourself and one or more other persons any property of any nature owned solely or in part by the Defendant? nD 3. At the time you were served with these Interrogatories or at any subsequent time, did you hold legal title to any property of any nature owed solely or in part by the Defendant or in which Defendant held or claimed any interest? no 6 " 4. At the time you were served with these Interrogatories or at any subsequent time, did the Defendant transfer or deliver any property to you or to any person or place pursuant to your direction or consent and, if so, what was the consideration therefore? no 5. At the time you were served with these Interrogatories or at any subsequent time, did you pay, transfer or deliver any money or property to the Defendant, to any person or place pursuant to Defendant's direction or otherwise discharge any claim or the Defendant against you? no 6. At the time you were served with these Interrogatories or at any subsequent time, did you have any safe deposit boxes, pledges, documents of title, securities, notes, coupons, receivables, collateral, checking, savings, tax or other accounts or deposits in which Defendant has an interest? qes 7. At the time you were served with these Interrogatories or at any subsequent time, did you hold as fiduciary any property in which the Defendant has any interest? no I rt 8. At the time you were served with these Interrogatories or at any subsequent time, did you hold any Treasury Bill, repurchase Agreement or any other type of investment or commercial paper in which the Defendant has any interest? 0 0 9. At the time you were served with these Interrogatories or at any subsequent time, did you have property of the Defendant or property in which he has any interest on deposit or otherwise in your possession, custody or control other than that property indicated in your answers to the previous Interrogatories? no 10. Have you ever owed money to the Defendant or held any property belonging to Defendant? If so, state when you either satisfied the debt or disposed of the property and in what manner, for what consideration, and to whom? 60 11. At the time you were served with these Interrogatories, what are the account balances of the Defendant, in the account names of Carleton Communications, Inc.? gWjn S - 118015.71 X5,9-7 9 .q3 BOSWKQ Tlr DATE: October 8, 2008 J J1 w THE DREXEL GROUP, INC., PLAINTIFF V. CARLETON COMMUNICATIONS, INC., DEFENDANT : IN THE COURT OF COMMON PLEAS : CUMBERLAND COUNTY PENNSYLVANIA' NO. 08-4938 CIVIL ACTION - LAW II '' lp VERIFICATION ?? ?f S I'lGl.? i , of Members 1" Federal Credit Union, hereby verify that the! facts' contained in the foregoing Answers to Interrogatories are true and correct to the best of my knowledge, information and belief. I understand that false statements herein are subject to the penalties of 18 Pa.C.S.A. §4904 relating to unsworn falsification to authorities. DATE: 10117/pf ter`, ) INN, WRIT OF EXECUTION and/or ATTACHMENT C04NALTH OF PENNSYLVANIA) N0084938 Civil COUNTY OF CUMBERLAND) CIVIL ACTION - LAW TO THE SHERIFF OF CUMBERLAND COUNTY: To satisfy the debt, interest and costs due THE DREXEL GROUP Plaintiff (s) From CARLETON COMMUNICATIONS, INC., 937 NIXON DRIVE MECHANICSBURG, PA 17055 (1) You are directed to levy upon the property of the defendant (s)and to sell LEVY ON ALL PROPERTY, INCLUDING OFFICE EQUIPMENT, COMPUTERS, FURNITURE, APPLICATIONS, TELEVISIONS, CASH, ETC., LOCATED AT: 937 NIXON DRIVE, MECHANICSBURG, PA 17055. (2) You are also directed to attach the property of the defendant(s) not levied upon in the possession of MEMBERS 1sT FEDERAL CREDIT UNION, 1711 SPRING ROAD, CARLISLE, PA 17013 GARNISHEE(S) as follows: ANY AND ALL BANK ACCOUNTS, INCLUDING SAVINGS AND CHECKING ACCOUNTS, IN THE NAME OF THE DEFENDANT, CARLETON COMMUNICATIONS, INC. and to notify the garnishee(s) that: (a) an attachment has been issued; (b) the garnishee(s) is enjoined from paying any debt to or for the account of the defendant (s) and from delivering any property of the defendant (s) or otherwise disposing thereof; (3) If property of the defendant(s) not levied upon an subject to attachment is found in the possession of anyone other than a named garnishee, you are directed to notify him/her that he/she has been added as a garnishee and is enjoined as above stated. Amount Due$27,284.05 L.L.$.50 Interest AT LEGAL RATE OF 6% FROM 8/18/08 Atty's Comm % Due Prothy $2.00 Atty Paid $159.09 Plaintiff Paid Date: 10/03/2008 Other Costs CiTr _ . Long, Pr ary (Seal) By: Deputy REQUESTING PARTY: Name LEONARD TINTNER, ESQUIRE Address: 315 N. FRONT STREET PO BOX 741, HARRISBURG, PA 17108-0741 Attorney for: PLAINTIFF Telephone: 717-236-9377 Supreme Court ID No. 06859 TRUE 00"'PY FROM RECOR) TwA f rywhe ,1 Mme t my nt1 the M Said ?1W. Pa OE :1 d 01 130 COI ?d ??wrc ?f GNV-183643 33183HS 3H1 30 301AJQ THE DREXEL GROUP, INC., Plaintiff V. CARLETON COMMUNICATIONS, INC., Defendant IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL ACTION - LAW NO. 08-4938 CIVIL TERM ORDER OF COURT AND NOW, this 22°d day of October, 2008, upon consideration of Defendant's Motion To Vacate Default Judgment, it is ordered that: 1. A Rule is issued upon Plaintiff to show cause why Defendant is not entitled to the relief requested; 2. Plaintiff shall file an answer to the motion within 21 days of the date of this order; 3. The petition shall be decided under Pa. R.C.P. 206.7; 4. Depositions shall be completed within 49 days of the date of this order; 5. Argument shall be held on Wednesday, January 28, 2009, at 1:30 p.m., in Courtroom No. 1, Cumberland County Courthouse, Carlisle, Pennsylvania. 6. Briefs shall be submitted at least seven days prior to argument. BY THE COURT, ZLeonard Tinter, Esq. 315 N. Front Street Harrisburg, PA 17105 Attorney for Plaintiff I 60, .8 WV LZ 130 OOOZ , 61: ? Leslie Tomeo, Esq. 711 N. Second Street Suite 5 Harrisburg, PA 17102 Attorney for Defendant :rc / v`;. 7 08 M ...& Leonard Tintner, Esquire Supreme Court I.D. #06859 BOSWELL, TINTNER & PICCOLA 315 N. Front Street PO Box 741 Harrisburg, PA 17108-0741 (717) 236-9377 (717) 236-9316 -fax ItinbvvC btealaw.com Attorneys for Plaintiff THE DREXEL GROUP, INC., PLAINTIFF V. CARLETON COMMUNICATIONS, INC., DEFENDANT MEMBERS 1ST FEDERAL CREDIT UNION, GARNISHEE : IN THE COURT OF COMMON PLEAS : CUMBERLAND COUNTY PENNSYLVANIA' NO. 08-4938 CIVIL ACTION - LAW PRAECIPE TO THE PROTHONOTARY: KINDLY enter judgment against the Garnishee, Members 1St Federal Credit Union, in the amount of $5,000.00, pursuant the Garnishment filed with this Court on October 8, 2008. BOSWELL, TINTNER & PICCOLA 4eonard By: Tintner, Esquire DATE: October 27, 2008 Ab. THE DREXEL GROUP, INC., PLAINTIFF V. : IN THE COURT OF COMMON PLEAS : CUMBERLAND COUNTY PENNSYLVANIA' : NO. 08-4938 CARLETON COMMUNICATIONS, INC., DEFENDANT : CIVIL ACTION - LAW MEMBERS 1sT FEDERAL CREDIT UNION, GARNISHEE TO: MEMBERS 1sT FEDERAL CREDIT UNION, GARNISHEE You are hereby notified that on October 27, 2008, judgment has been entered against you in the above-captioned case in the amo t of $5,000. 0. DATE: October 27, 2008 othonota I hereby certify that the following is the address of the Garnishee stated in the Certificate of Residence: Members 1' Federal Credit Union 5000 Louise Drive, PO Box 40 Mechanicsburg, PA 17055 TO: MEMBERS 1sT FEDERAL CREDIT UNION, GARNISHEE Por este medio se le esta notificando que el October 27, 2008, el siguiente Fallo ha sido antodo en contra suya en el caso mencionado en el epigrafe. FECHA: October 27, 2008 Protonotario Certifico que la siguiente direccion es la del defendido/a segun indicada en el certificado de residencia: Members 1 ' Federal Credit Union 5000 Louise Drive, PO Box 40 Mechanicsburg, PA 17055 THE DREXEL GROUP, INC., PLAINTIFF V. CARLETON COMMUNICATIONS, INC., DEFENDANT MEMBERS 1sT FEDERAL CREDIT UNION, GARNISHEE IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY PENNSYLVANIA' NO. 08-4938 CIVIL ACTION - LAW CERTIFICATE OF RESIDENCE I hereby certify that the addresses of the parties in the above-captioned action are as follows: The Drexel Group 1832 Market Street Camp Hill, PA 17011 Plaintiff Carleton Communications 937 Nixon Drive Mechanicsburg, PA 17055 Defendant Members 1St Federal Credit Union 5000 Louise Drive, PO Box 40 Mechanicsburg, PA 17055 Garnishee BO L L, TINTNER & PICCOLA 7 _06C WLI, Deni . Foster, Paralegal Q -n CZ) ~ O 1 N ?? r` Leonard Tintner, Esquire Supreme Court I.D. #06859 BOSWELL, TINTNER & PICCOLA 315 N. Front Street PO Box 741 Harrisburg, PA 17108-0741 (717) 236-9377 (717)236-9316-fax Itintner(a?btpalaw com Attorneys for Plaintiff THE DREXEL GROUP, INC., PLAINTIFF V. CARLETON COMMUNICATIONS, INC., DEFENDANT TO THE PROTHONOTARY: : IN THE COURT OF COMMON PLEAS : CUMBERLAND COUNTY PENNSYLVANIA' : NO. 08-4938 : CIVIL ACTION - LAW PRAECIPE KINDLY SATISFY the Judgment entered against Garnishee, Members 1St Federal Credit Union, originally filed with this Court on October 27, 2008. BOSWELL, TINTNER & PICCOLA By: od Tintner, Esquire DATE: November 10, 2008 .. ._J _ ? ?'* ? ' F? ?? `? ;-?; ., ` i •e. THE DREXEL GROUP, INC., Plaintiff V. CARLETON COMMUNICATIONS, INC., Defendant IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL ACTION - LAW NO. 08-4938 CIVIL TERM IN RE: DEFENDANT'S MOTION TO VACATE DEFAULT JUDGMENT ORDER OF COURT AND NOW, this 12'h day of November, 2008, upon consideration of the attached letter from Leslie Tomeo, Esq., the argument previously scheduled in the above matter for January 28, 2009, is cancelled. BY THE COURT, r J. esley OlqrJr., J. !onard Tinter, Esq. 315 N. Front Street Harrisburg, PA 17105 Attorney for Plaintiff eslie Tomeo, Esq. 711 N. Second Street Suite 5 Harrisburg, PA 17102 Attorney for Defendant :rc L S .Z W8 £ I A©N 880Z b uRw% r iJ.l3u Hi ?O Leonard Tintner, Esquire Supreme Court I.D. #06859 BOSWELL, TINTNER & PICCOLA 315 N. Front Street PO Box 741 Harrisburg, PA 17108-0741 (717) 236-9377 (717)236-9316-fax Itintner(abtaalaw.com Attorneys for Plaintiff THE DREXEL GROUP, INC., PLAINTIFF V. CARLETON COMMUNICATIONS, INC., DEFENDANT : IN THE COURT OF COMMON PLEAS : CUMBERLAND COUNTY PENNSYLVANIA' NO. 08-4938 : CIVIL ACTION - LAW PRAECIPE TO REISSUE GARNISHMENT TO THE PROTHONOTARY: KINDLY REISSUE the garnishment against the Garnishee, Members 1St Federal Credit Union, originally filed with this Court on October 27, 2008. The levy should be made on any and all bank accounts, including savings and checking accounts, in the name of the Defendant, Carleton Communications, Inc. The address of Members 1St Federal Credit Union is: 1711 Spring Road, Carlisle, PA 17013. BOSWELL, TINTNER IC OLA By: eonard Tintner, Esquire DATE: December 17, 2008 C 45 -n -Cl WRIT OF EXECUTION and/or ATTACHMENT COMMONWEALTH OF PENNSYLVANIA) COUNTY OF CUMBERLAND) N0084938 Civil CIVIL ACTION - LAW TO THE SHERIFF OF CUMBERLAND COUNTY: To satisfy the debt, interest and costs due THE DREXEL GROUP Plaintiff (s) From CARLETON COMMUNICATIONS, INC., 937 NIXON DRIVE MECHANICSBURG, PA 17055 (1) You are directed to levy upon the property of the defendant (s)and to sell LEVY ON ALL PROPERTY, INCLUDING OFFICE EQUIPMENT, COMPUTERS, FURNITURE, APPLICATIONS, TELEVISIONS, CASH, ETC., LOCATED AT: 937 NIXON DRIVE, MECHANICSBURG, PA 17055. (2) You are also directed to attach the property of the defendant(s) not levied upon in the possession of MEMBERS 1sT FEDERAL CREDIT UNION, 1711 SPRING ROAD, CARLISLE, PA 17013 GARNISHEE(S) as follows: ANY AND ALL BANK ACCOUNTS, INCLUDING SAVINGS AND CHECKING ACCOUNTS, IN THE NAME OF THE DEFENDANT, CARLETON COMMUNICATIONS, INC. and to notify the garnishee(s) that: (a) an attachment has been issued; (b) the garnishee(s) is enjoined from paying any debt to or for the account of the defendant (s) and from delivering any property of the defendant (s) or otherwise disposing thereof, (3) If property of the defendant(s) not levied upon an subject to attachment is found in the possession of anyone other than a named garnishee, you are directed to notify him/her that he/she has been added as a garnishee and is enjoined as above stated. Amount Due$27,284.05 L.L.$.50 Interest AT LEGAL RATE OF 6% FROM 8/18/08 Atty's Comm % Due Prothy $2.00 Atty Paid $159.09 Plaintiff Paid Other Costs Date: 10/03/2008 C ' R. Long, P? tar (Seal) By: Deputy REQUESTING PARTY: Name LEONARD TINTNER, ESQUIRE Address: 315 N. FRONT STREET PO BOX 741, HARRISBURG, PA 17108-0741 Attorney for: PLAINTIFF Telephone: 717-236-9377 Supreme Court ID No. 06859 4L r ro C? m n v a- =i- a 1 J C: 00 lp"11 Leonard Tintner, Esquire Supreme Court I.D. #06859 BOSWELL, TINTNER & PICCOLA 315 N. Front Street PO Box 741 Harrisburg, PA 17108-0741 (717) 236-9377 (717)236-9316-fax Itintner(&btpalaw.com Attorneys for Plaintiff THE DREXEL GROUP, INC., PLAINTIFF V. RECEIVED JAN 0 5 2009 IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY PENNSYLVANIA' NO. 08-4938 CARLETON COMMUNICATIONS, INC., DEFENDANT : CIVIL ACTION - LAW ANSWER L INTERROGATORIES TO GARNISHEE TO: MEMBERS 1ST FEDERAL CREDIT UNION IMPORTANT NOTICE TO GARNISHEE! A. You are required to file answers to the following interrogatories within twenty (20) days after service upon you. Failure to do so may result in judgment against you. B. The term "Defendant(s)" means the individual(s) against whom the Writ of Execution is issued. C. "You" means the main office and all branch offices of Members 1St Federal Credit Union. D. By service of the Writ of Execution upon you, all property of the Defendant subject to the attachment which was then in your possession, custody or control was attached, including all property of the Defendant which comes in into your possession. .a INTERROGATORIES IN ATTACHMENT 1. At the time you were served with these Interrogatories or any subsequent time, did you owe Carleton Communications, Inc., any money, were you liable to it on any negotiable or other written instrument, or did it claim that you owed it any money or were liable to it for any reason? No 2. At the time you were served with these Interrogatories or at any subsequent time, was there in your possession, custody or control or in the joint possession, custody or control of yourself and one or more other persons any property of any nature owned solely or in part by the Defendant? No 3. At the time you were served with these Interrogatories or at any subsequent time, did you hold legal title to any property of any nature owed solely or in part by the Defendant or in which Defendant held or claimed any interest? 1.C) 4. At the time you were served with these Interrogatories or at any subsequent time, did the Defendant transfer or deliver any property to you or to any person or place pursuant to your direction or consent and, if so, what was the consideration therefore? No 5. At the time you were served with these Interrogatories or at any subsequent time, did you pay, transfer or deliver any money or property to the Defendant, to any person or place pursuant to Defendant's direction or otherwise discharge any claim or the Defendant against you? No 6. At the time you were served with these Interrogatories or at any subsequent time, did you have any safe deposit boxes, pledges, documents of title, securities, notes, coupons, receivables, collateral, checking, savings, tax or other accounts or deposits in which Defendant has an interest? F 7. At the time you were served with these Interrogatories or at any subsequent time, did you hold as fiduciary any property in which the Defendant has any interest? No 8. At the time you were served with these Interrogatories or at any subsequent time, did you hold any Treasury Bill, repurchase Agreement or any other type of investment or commercial paper in which the Defendant has any interest? No 9. At the time you were served with these Interrogatories or at any subsequent time, did you have property of the Defendant or property in which he has any interest on deposit or otherwise in your possession, custody or control other than that property indicated in your answers to the previous Interrogatories? No 10. Have you ever owed money to the Defendant or held any property belonging to Defendant? If so, state when you either satisfied the debt or disposed of the property and in what manner, for what consideration, and to whom? No 11. At the time you were served with these Interrogatories, what are the account balances of the Defendant, in the account np nes of Carleton Communications, Inc.? 3JS1 nfE Ghee Q1 I gr70 I -25,0 aC,?I. -se $300.o0 ,*AAJOrq aempfio? Kc+s not iv,gen DATE: December 17, 2008 THE DREXEL GROUP, INC., PLAINTIFF V. CARLETON COMMUNICATIONS, INC., DEFENDANT : IN THE COURT OF COMMON PLEAS : CUMBERLAND COUNTY PENNSYLVANIA' NO. 08-4938 CIVIL ACTION - LAW VERIFICATION I, I u n?C?. f , of Members 1St Federal Credit Union, hereby verify that the facts con fined in the foregoing Answers to Interrogatories are true and correct to the best of my knowledge, information and belief. I understand that false statements herein are subject to the penalties of 18 Pa.C.S.A. §4904 relating to unsworn falsification to authorities. ?JQ-11,1.l? DATE: C.0 SHERIFF'S RETURN - GARNISHEE CASE NO: 2008-04938 P COMMONWEALTH OF PENNSLYVANIA COUNTY OF CUMBERLAND DREXEL GROUP INC THE VS CARLETON COMMUNICATIONS INC And now NOAH CLINE ,Sheriff or Deputy Sheriff of Cumberland County of Pennsylvania, who being duly sworn according to law, at 0015:40 Hours, on the 5th day of January , 2009, attached as herein commanded all goods, chattels, rights, debts, credits, and moneys of the within named DEFENDANT , CARLETON COMMUNICATIONS INC hands, possession, or control of the within named Garnishee MEMBERS 1ST FEDERAL CREDIT UNION 1166 WALNUT BOTTOM ROAD CARLISLE, PA 17013 Cumberland County, Pennsylvania, by handing to BRIAN PETERS (BRANCH MANAGER) personally three copies of interogatories together with 3 and attested copies of the within WRIT OF EXECUTION the contents there of known to His . Sheriff's Costs: Docketing Service Affidavit Surcharge Sworn and Subscribed to before me this in the true and made So a .00 ? .00 .00 Thomas Kline .00 Sheriff of Cumberland County .00 .00 01/06/2009 day of 13Y Deputy Sheriff A.D co Leonard Tintner, Esquire Supreme Court I.D. #06859 BOSWELL, TINTNER & PICCOLA 315 N. Front Street PO Box 741 Harrisburg, PA 17108-0741 (717) 236-9377 (717)236-9316-fax ItintnerObtpalaw.com Attorneys for Plaintiff THE DREXEL GROUP, INC., PLAINTIFF : IN THE COURT OF COMMON PLEAS : CUMBERLAND COUNTY PENNSYLVANIA' V. : NO. 08-4938 CARLETON COMMUNICATIONS, INC., DEFENDANT : CIVIL ACTION - LAW PRAECIPE TO WITHDRAW GARNISHMENT WRIT TO THE PROTHONOTARY: KINDLY withdraw the Garnishment entered against Garnishee, Members 1St Federal Credit Union, filed with this Court on December 17, 2008. BOSWELL, TINTNER & PICCOLA J By evx eonard Tintner, Esquire DATE: January 9, 2009 0 % ?i C WO '4',• 'Fin R. Thomas Kline, Sheriff, who being duly sworn according to law, states this writ is returned ABANDONDED. No action has been taken in the last six months. Sheriff's Costs: Docketing Law Library Prothonotary Service Garnishee Surcharge Levy Poundage $18.00 .50 2.00 Zvi .00 9.00 40.00 '0.00 2.09 $135,,51 So A 4?? ', , ,R. ThoeKkS Kline, Sheriff U- a L z ergeant cn - zL N ,j 1 O 0 _. o 0£ f ri 01 130 8001 ? ?I F1S 3N ?r? Q`33WOv m c ?- `y l A ? f-1.66 c 0 r 5-C) ?- L L? 7/5-66 '1 -3 Li 0 - (o ? /Z f,-- . n s n? 4 -.c W WRIT OF EXECUTION and/or ATTACHMENT £ tSSGc:E COMMONWEALTH OF PENNSYLVANIA) COUNTY OF CUMBERLAND) N008-4938 Civil CIVIL ACTION - LAW TO THE SHERIFF OF CUMBERLAND COUNTY: To satisfy the debt, interest and costs due THE DREXEL GROUP Plaintiff (s) From CARLETON COMMUNICATIONS, INC., 937 NIXON DRIVE MECHANICSBURG, PA 17055 (1) You are directed to levy upon the property of the defendant (s)and to sell LEVY ON ALL PROPERTY, INCLUDING OFFICE EQUIPMENT, COMPUTERS, FURNITURE, APPLICATIONS, TELEVISIONS, CASH, ETC., LOCATED AT: 937 NIXON DRIVE, MECHANICSBURG, PA 17055. (2) You are also directed to attach the property of the defendant(s) not levied upon in the possession of MEMBERS 1sT FEDERAL CREDIT UNION, 1711 SPRING ROAD, CARLISLE, PA 17013 GARNISHEE(S) as follows: ANY AND ALL BANK ACCOUNTS, INCLUDING SAVINGS AND CHECKING ACCOUNTS, IN THE NAME OF THE DEFENDANT, CARLETON COMMUNICATIONS, INC. and to notify the garnishee(s) that: (a) an attachment has been issued; (b) the garnishee(s) is enjoined from paying any debt to or for the account of the defendant (s) and from delivering any property of the defendant (s) or otherwise disposing thereof; (3) If property of the defendant(s) not levied upon an subject to attachment is found in the possession of anyone other than a named garnishee, you are directed to notify him/her that he/she has been added as a garnishee and is enjoined as above stated. Amount Due$27,284.05 L.L.$.50 Interest AT LEGAL RATE OF 6% FROM 8/18/08 Atty's Comm % Due Prothy $2.00 Atty Paid $159.09 Plaintiff Paid Other Costs Date: 10/03/2008 (Seal) REQUESTING PARTY: Name LEONARD TINTNER, ESQUIRE Address: 315 N. FRONT STREET PO BOX 741, HARRISBURG, PA 17108-0741 Attorney for: PLAINTIFF Telephone: 717-236-9377 Supreme Court ID No. 06859 24't?(?L Curti R. Long, Pro ary By: Deputy r- ' 3a- -?'- . Leonard Tintner, Esquire Supreme Court I.D. #06859 BOSWELL, TINTNER & PICCOLA 315 N. Front Street PO Box 741 Harrisburg, PA 17108-0741 (717) 236-9377 (717)236-9316-fax ItintnerO-btpalaw.com Attorneys for Plaintiff THE DREXEL GROUP, INC., PLAINTIFF V. : IN THE COURT OF COMMON PLEAS : CUMBERLAND COUNTY PENNSYLVANIA' NO. 08-4938 CARLETON COMMUNICATIONS, INC., DEFENDANT : CIVIL ACTION - LAW PRAECIPE TO SETTLE & DISCONTINUE TO THE PROTHONOTARY: KINDLY DOCKET THE JUDGMENT in this case as Paid in Full, Satisfied and Discontinued. BOSWELL, TINTNER & PICCOLA By: ?L" Hard Tintner, Esquire DATE: September 2, 2009 2609 Sty' - 2 P! 3; 3 1