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HomeMy WebLinkAbout08-5726KOPE & ASSOCIATES, LLC By: SHANE B. KOPE, ESQ. ATTORNEY ID 92207 4660 Trindle Road, Suite 201 Camp Hill, PA 17011 (717) 761-7573 sbkope@kopelaw.com Attorney for Plaintiffs LYNDA MARTIN AND WENNY WIJAYA, IN THE COURT OF COMMON PLEAS Plaintiffs, CUMBERLAND COUNTY, PA V. : NO. 08- 510'Ve (Civil Term) ELIZABETH SHELLEHAMER, A MINOR, : JURY TRIAL DEMANDED Defendant. N O T I C E TO DEFEND AND CLAIM RIGHTS 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 SOUTH BEDFORD STREET CARLISLE, PA 17013 KOPE & ASSOCIATES, LLC By: SHANE B. KOPE, ESQ. ATTORNEY ID 92207 4660 Trindle Road, Suite 201 Camp Hill, PA 17011 (717) 761-7573 sbkope@kopelaw.com Attorney for Plaintiffs LYNDA MARTIN AND WENNY WIJAYA, IN THE COURT OF COMMON PLEAS Plaintiffs, CUMBERLAND COUNTY, PA V. NO. 0 g- s *7 a. 41 (Civil Term) ELIZABETH SHELLEHAMER, A MINOR, : JURY TRIAL DEMANDED Defendant. COMPLAINT AND NOW comes Plaintiffs, Lynda Martin and Wenny Wijaya, by and through their attorneys, Shane B. Kope, Esq., and Kope and Associates, LLC, and files this Complaint; and in support thereof, they aver the following: 1. Plaintiff Lynda Martin is an adult individual residing at 1422 Holly Pike, Carlisle, Cumberland County, Pennsylvania. 2. Plaintiff Wenny Wijaya is an adult individual residing at 1422 Holly Pike, Carlisle, Cumberland County, Pennsylvania. 3. Defendant Elizabeth Shellehamer is a minor individual residing at 610 South Ridge Road, York Springs, Adams County, Pennsylvania. COUNTI REPLEVIN 4. The averments set forth in the preceding paragraphs are incorporated herein by reference as if fully set forth herein. 5. In September, 2007, pursuant to the Plaintiffs' request, the Defendant began handling the Brittany, JR, during handling classes at Obedience Training Classes of Harrisburg ("OTCH"). 6. In September, 2007, pursuant to the Defendant's request, via Defendant's mother, the Defendant agreed to handle JR in certain dog shows. 7. Pursuant to the Defendant's request, a "Handling Contract" was entered into by all parties on September 18, 2007, wherein each party's responsibilities were described in regards to showing and campaigning JR. Attached hereto as Exhibit "A" is a true and correct copy of said Contract. 8. After winning several shows with the Brittany, the Defendant requested that the Plaintiffs place her on JR's American Kennel Club ("AKC") registration so that the Defendant could use the Brittany in Junior Handling Competitions.' 9. The Plaintiffs agreed to the request and on March 7, 2008, the Plaintiffs placed the Defendant on the Brittany's AKC registration. 10. The Defendant was never included on the Brittany's other registrations such as the United Kennel Club ("UKC") registration, State registration or microchip registration. 1 According to the AKC rules, a dog used in junior handling competitions must be registered or co-registered by the handler or owned by a family member of the handler. Page 2 of 10 11. The Defendant never contributed to any of the expenses of maintaining JR as a show quality dog, including vet care, food, supplements, advertising, promoting or show entries. 12. For reasons unknown to Plaintiffs, the relationship between the Plaintiffs and the Defendant soured and the Defendant cut off all communication with the Plaintiffs in or around April, 2008. 13. On May 8, June 17 and June 19, 2008, the Plaintiffs, through counsel, demanded, inter alia, the Defendant to sign whatever documents were necessary for the removal of Defendant's name from JR's AKC registration. Attached hereto as Exhibit "B" are true and correct copies of said Demand Letters. 14. On July 8, 2008, the Defendant, through counsel, rejected this demand. Attached hereto as Exhibit "C" is a true and correct copy of said Rejection Letter. 15. Although AKC registration is not an ownership document, but a system for, inter alia, tracking the breeding, showing, field training, and other activities of the dog, every person included on the registration must sign off on the registration before the dog can bred. As such, Defendant's refusal to sign off on JR effectively prevents the Plaintiffs from breeding JR for profit or for selling to dog to be used for the same. 16. The Defendant's refusal to sign off on JR, therefore, is interfering with the Plaintiffs' ownership of the dog in that the Plaintiffs are unable to continue in their efforts to increase the value of JR for breeding or selling. WHEREFORE, the Plaintiffs demand that the Defendant sign off on JR's registration along with such other relief as the Court deems appropriate. Page 3 of 10 COUNT II UNJUST ENRICHMENT 17. The averments set forth in the preceding paragraphs are incorporated herein by reference as if fully set forth herein. 18. On November, 2, 2007, pursuant to the Defendant's request, the Plaintiffs agreed to keep the Defendant's Brittany, Annabelle, at the Plaintiffs kennel due to the Defendant's position that the Plaintiffs' kennel was in better condition than that of Defendant's parents. Annabelle stayed at the kennel until March 30, 2008. Attached hereto as Exhibit "D" is a true and correct copy of the Pennsylvania Record of Boarding Kennel, which demonstrates the boarding dates of said dog as required by state law. 19. On November, 17, 2007, pursuant to the Defendant's request, the Plaintiffs agreed to keep the Defendant's Beagle, Keepsake, at the Plaintiffs kennel due to the Defendant's position that the Plaintiffs' kennel was in better condition than that of Defendant's parents. Keepsake stayed at the kennel until March 25, 2008. Attached hereto as Exhibit "D" is a true and correct copy of the Pennsylvania Record of Boarding Kennel, which demonstrates the boarding dates of said dog as required by state law. 20. On February, 17, 2008, pursuant to the Defendant's request, the Plaintiffs agreed to keep the Defendant's Beagle, Buddy, at the Plaintiffs kennel due to the Defendant's position that the Plaintiffs' kennel was in better condition than that of Defendants' parents. Buddy stayed at the kennel until March 4, 2008. Attached hereto as Exhibit "D" is a true and correct copy of the Pennsylvania Record of Boarding Kennel, which demonstrates the boarding dates of said dog as required by state law. Page 4 of 10 21. The total amount of the fees for boarding the Defendant's dogs is $5, 049.00, which is calculated at a rate of $17.00 per day for each dog. Attached hereto as Exhibit "E" is a true and correct copy of the invoice for Boarding said dogs. 22. The Plaintiffs have not been compensated for boarding Defendant's three dogs. 23. The Defendant benefited from the care and better living conditions her dogs received while residing in the Plaintiffs' kennel. 24. From January, 2008, until March, 2008, the Plaintiffs paid $150.00 for the Defendant to be tutored in Algebra due to the Defendant's low grades in said subject. Attached hereto as Exhibit "F" is a true and correct copy of the invoice for said tutor. 25. The Plaintiffs have not been compensated for providing a math tutor for the Defendant. 26. The Defendant benefited from the math tutor provided by the Plaintiffs. 27. Under the circumstances as set forth herein, it would be inequitable for the Defendant not to compensate the Plaintiffs for boarding her three dogs and for providing her a tutor in algebra. WHEREFORE, the Plaintiffs seeks judgment against the Defendant in the amount of $5,199.00 with the continually accruing interest charge at the statutory rate of 6.00% per annum along with such other relief as the Court deems appropriate. COUNT III BREACH OF CONTRACT 28. The averments set forth in the preceding paragraphs are incorporated herein by reference as if fully set forth herein. Page 5 of 10 29. In or around November, 2007, the Plaintiffs were discussing purchasing another class of dog to show and breed. 30. In or around January, 2008, the Defendant suggested that the Plaintiffs purchase a Beagle; in addition, the Defendant requested that she be registered as 1/3 owner of said Beagle so that she may enter and present the Beagle in various dog show. 31. In January, 2008, the Plaintiffs and Defendant entered into a written agreement ("Agreement') titled "Co-Ownership of Dog" whereby the Plaintiffs would (1) purchase the Beagle; (2) cover all expenses surrounding the care of the Beagle; (3) cover all entry and handling fees of the Beagle; and (4) register Defendant as 113 owner of said Beagle. In return, the Defendant would be responsible for training, conditioning, grooming and showing of the Beagle. Attached hereto as Exhibit "G" is a true and correct copy of said Agreement. 32. Other terms of the agreement provided that: All parties would agree to the means by which the Beagle is nurtured, including living arrangements and food. All parties would agree to the conditions concerning the breeding of the Beagle, including when and to whom. All parties would agree to the time and place of the Beagles campaigning for future shows. All parties would agree before selling the Beagle. All parties must agree to use "Hammer Beagles" of breed line for future beagles which are sired by said dog. That buyout of the Beagle would be permitted to all parties at reasonable costs. Attached hereto as Exhibit "G" is a true and correct copy of said Agreement. 33. There was no integration clause contained in the agreement. Attached hereto as Exhibit "H" is a true and correct copy of said Agreement. Page 6 of 10 34. In or around January, 2008, the Plaintiffs purchased the Beagle, Dillon, from Leah Bertagnolli at a price of $640.00, which covered purchase price of the Beagle along with the crate costs; the Plaintiffs also expended an additional amount of $229.00 in air fare, $60.00 gas, and tolls in an amount yet to be determined, which covered shipping costs and expenses surrounding the retrieval of Dillon at Dulles Airport in Washington, D.C. Attached hereto as Exhibit "H" is a true and correct copy of documents representing said costs and expenses. 35. The Plaintiffs also expended an additional $39.00 to cover the registration of Dillon. Attached hereto as Exhibit "I" is a true and correct copy of the document representing said cost. 36. The Plaintiffs also expended additional amounts of $27.50 for Dillon's vet fees and $146.25 for Dillon's show entry and licensing fees 37. The Defendant has retained sole possession of Dillon since his purchase. 38. Following and pursuant to the Agreement, in or around February, 2008, the Plaintiffs paid for the Defendant to attend a handling seminar at a cost of $175.00. 39. In addition to her requirements under the Agreement, the Defendant agreed to work in Plaintiffs' kennel in order to pay for her 1/3 ownership. The Defendant never fulfilled this obligation. 40. In April, 2008, the Defendant had entered Dillon in two dog shows pursuant to the agreement. 41. Plaintiff Martin had acted as agent for the Defendant in these shows, as required by AKC rules and regulations. Page 7 of 10 42. Eventually, and for reasons that are not entirely clear, the relationship between the parties began to sour. 43. In April, 2008, the Defendant cut off all communication with the Plaintiffs regarding Dillon or otherwise. 44. In addition, the Defendant has refused to allow Plaintiffs access to Dillon. 45. The Plaintiffs tried to reach the Defendant through various calls and e-mails, but to no avail. 46. Thereafter, the Plaintiffs' discovered that the Defendant entered Dillon in a dog show under a new agent by the name of Cindy Stable.2 47. In or around, May, 2008, the Defendant's father had contacted the Plaintiffs and offered to purchase Dillon, to which the Plaintiffs refused. 48. Thereafter, the Defendant, again, cut off all communication with the Plaintiffs regarding Dillon or otherwise. 49. Plaintiff Martin tried several times to reach the Defendant through various calls and e-mails. 50. Although no calls were returned, the Defendant, through her mother, did return two a-mails in which she promised that the Defendant and the Defendant's parents would meet with the Plaintiffs to discuss circumstances surrounding Dillon. Attached hereto as Exhibit "J" are true and correct copies of said e-mails. 51. Despite these promises, the Defendant never met with the Plaintiffs. z The show was the Red Rose Classic, which was held in Lebanon, PA, on Sunday May 11, 2008. Page 8 of 10 52. Therefore, on May 6, 2008, Plaintiff Martin called and sent an e-mail to the Defendant whereby the Plaintiffs demanded that the Defendant return Dillon no later than May 7, 2008, at 6:00 p.m. 53. In response, on May 11, 2008, the Defendant, through her mother, sent an e-mail to Plaintiff Martin wherein she asked the Plaintiffs to cease all direct communication with the Defendant and to direct all further communication to Defendant's attorney, James W. Kollas, Esq. Attached hereto as Exhibit "K" is a true and correct copy of said e-mail. 54. In is believed and therefore averred that the Defendant has been showing Dillon in other dog shows without consulting the Plaintiffs.3 55. Since the beginning of April, 2008, the Defendant has been grooming, conditioning, training and caring for Dillon without consulting with the Plaintiffs. 56. It is believed and therefore averred that the Defendant, through her father and / or mother, will breed Dillon with any breed they choose without consulting the Plaintiffs. 57. The Defendant's actions as stated above amount to Breach of Contract. 58. A minor, upon avoiding a contract, must return the consideration received by him or her. Aetna Cas. & Sur. Co. v. Duncan, 972 F.2d 523 (3d Cir. 1992); Prudential Ins. Co. of America v. Ordonoff, 122 Pa. Super. 485, 186 A. 391 (1936). 59. In other words, even though a minor is not obligated to perform his or her contractual promises generally, the minor is required to return any benefit that he or she has received under the contract. Pankas v. Bell, 413 Pa. 494, 198 A.2d 312, 17 A.L.R.3d 855 (1964). 3 See Exhibit H. Page 9 of 10 60. Accordingly, although the Defendant, being a minor, may repudiate or disaffirm the Agreement, she must return Dillon to the Plaintiffs. WHEREFORE, the Plaintiffs demand that the Defendant return Dillon to the Plaintiffs and sign whatever documents are necessary to confer sole ownership and AKC registration to the Plaintiffs along with all monies spent on behalf of Dillon pursuant to the Agreement and such other relief as the Court deems appropriate. Respectfully Submitted, KOPE &SQClATES, LLC Date: R/1 S-Ig 00 7 , Esq. Page 10 of 10 HANDLING CONTRACT This agreement is made this day of ? iede 2007, by and between Lynda Martin of 1422 Holly Pike, Carlisle, Pennsylvania, hereinafter referred to as "owner" and Elizabeth Shellehamer of 610 South Ridge Road, York Springs, Pennsylvania herein referred to as "handler." This agreement is for the sole purpose of showing and campaigning the Male Brittany known as "Junior." Owner and handler hereinafter set forth agree as follows: Owner and handler will come to a mutual agreement as to which shows Junior will be entered in. Owner agrees to complete the necessary arrangements to register Junior by the deadline and will pay for all registra- tion fees. Owner and handler will come to a mutual agreement as to the cost of travel expenses and hotel fees prior to a show so that each party is aware of which expenses and fees will be reimbursed. Handler will present an itemized list after each show at which time owner will reimburse handler upon re- ceipt. Handler will transport Junior to each show [unless otherwise agreed upon by both parties] and will take every precaution to do so in a safe manner. If a veterinarian is needed, handler will make every attempt to contact the owner so that Junior can be taken to the owner's veterinarian. If owner cannot be reached, handler will make arrangements for Junior to see another veterinarian as soon as possible at the owner's expense. Owner will provide food, vitamins and/or medication, etc., for Junior while in the handler's care. Handler agrees to see that Junior is given his food, vitamins and/or medication at the direction of the owner. Owner will allow handler to use owner's grooming equipment to prepare Junior for a show when/if needed. If Junior needs more grooming than handler is able to perform, arrangements will be made for Junior to be groomed either by owner or another parry at owner's expense. Owner will be informed prior to grooming at which time owner can decide whether owner will perform the grooming or an outside party. Owner and/or Handler may void this contract at any time. Signed Owner: Owner Name: Signed Handler: ?r1 A-& Witness: Handler Name: May 15 2008 8:07 LAW OFFICE 717 7636848 p.2 William Lewis Grubb Attorney at Law 3803 Gettysburg Road Camp Hill, Pennsylvania 17011 Tel. (717) 763.5580 Fax. (717) 763-6848 grubblaw@aol.com ' Rick and Theresa Shellehamer 610 South Ridge Road York Springs, PA 17372-8728 Re: Dillon May 8, 2008 am4)? Dear Mr. and Mrs. Shellehamer: Please be advised that I represent the interests of Lynda L. Martin regarding the beagle with. the call name of Dillon_ You are currently in possession of the dog Dillon and Ms. Martin hereby demands the immediate return of her property. Additionally it is demanded that you direct and make available your daughter, Elizabeth, to sign documents as may be necessary for the removal of her name from the American Kennel Club registration for Dillon as well as the Brittany known as Jr. Ms. Martin is the-owner of Dillon, and Elizabeth's name was added to the AKC registration in order for her to show the dog as a Junior Handler. AKC registration is not an ownership document, but a system for tracking the breeding, showing, field trialing and other activities of the dog and -the individuals who are permitted to enter the dog or are responsible for the welfare of the dog. The return of the dog Dillon, any other property belonging to Ms. Martin, and the making available of Elizabeth to sign the appropriate documents shall be no later than May 15, 2008, at the kennel of Ms. Martin, 1422 Holly Pike, Carlisle, PA 17015. Should you not comply with this-demand for the return of her property Ms. Martin is prepared to seek appropriate relief from the courts. Very truly yours, cc: L. Martin LOD'. e ? William L. Grubb, Esquire >. n William Lewis Grubb Attorney at Law 3803 Gettysburg Road Camp Hill, Pennsylvania 17011 Tel. (717) 763-5580 Fax. (717) 763-6848 www.Grubblaw.net June 17, 2008 James W. Kollas, Esquire KOLLAS and KENNEDY 1104 Fernwood Avenue Camp Hill, PA 17011 Re: Martin v. Shellehamer Dear Attorney Kollas: 100PIV Ms. Martin has made a determination as to the value of the dog Dillon based on the purchase price, shipping costs and other expenses associated with obtaining the dog, as well as the increase in value and as a breeding dog which would reasonable expect to command a $500.00 stud fee. Ms. Martin is willing to transfer her ownership, and that of Wenny, for a total of $4,000.00, each of them being paid $2,000.00. This is the equivalent to four (4) stud fees each, and is not an unreasonable figure. In addition there is the matter of an outstanding billing from April 21, 2008 to the Shellehammer's in the sum of $146.25 for dog show entry fees and dog license. Ms. Martin is also demanding the return other items which belong to her and are in the possession of the Shellehammers, which include a crate, two (2) brown show leads, a container of chalk and a bottle of Laser Lites. Ms. Martin denies the allegations and insinuations of improper conduct in your letter of June 16, 2008. Ms. Martin was not at the show. Ms. Hartman was talking to Elizabeth, but it concerned the matter of another dog. Ms. Martin is the owner of a male Brittany known as "Junior", a dog which Elizabeth used when she showed as ,a Junior Handler. By AKC rules, the Junior Handler must be on the dogs registration. The situation between the parties has deteriorated such that Elizabeth must remove her name from Junior's registration, a dog in which she has no ownership interest. There are two separate issues regarding these two different dogs. Let us not confuse them or hold the resolution of one matter hostage in an attempt to gain advantage in the other. It is the appropriate time for Elizabeth to sign the AKC documents necessary to remove her name from the registration of the Brittany dog Junior. I look forward to an expeditious resolution of these matters. Very truly yours, William L. Grubb cc: L. Martin VOAb William Lewis Grubb Attorney at Law 3803 Gettysburg Road Camp Hill, Pennsylvania 17011 Tel. (717) 763-5580 Fax. (717) 763-6848 www.Grubblaw.net June 19, 2008 James W. Kollas, Esquire KOLLAS and KENNEDY 1104 Fernwood Avenue Camp Hill, PA 17011 Re: Elizabeth A. Shellehamer COPY Dear Attorney Kollas: Ms. Martin is the owner of the Brittany with the call name of "Junior", a dog which was previously shown by Elizabeth A. Shellehamer in Junior Showmanship. To comply with AKC regulations regarding Junior Showmanship it was necessary that Elizabeth's name be added to the registration for the dog she was showing. It is my understanding that Elizabeth has signed on and off the registration of other dogs with other owners for show purposes in the past. This is not a situation where the ownership of the dog is in question or at issue, and there is no reasonable excuse for your client's failure to comply with this timely demand. Ms. Martin demands that Elizabeth immediately executes the appropriate documents necessary to remove her name from "Junior's" registration. I can easily meet with you at your office and Elizabeth can sign as required. I look forward to an expeditious resolution of this matter. Very truly yours, William L. Grubb cc: L. Martin LAW OFFICES OF KOLLAS AND KENNEDY 1104 FERNWOOD AVENUE CAMP HILL, PENNSYLVANIA 17011 WILLIAM C. KOLLAS JAMES W. KOLLAS July 8, 2008 Mr. William Lewis Grubb, Esquire 3803 Gettysburg Road Camp Hill, PA 17011 RE: Shellehamer/Martin Lear Attorney Grubb: 0 V ?! OF COUNSEL MARY KOLLAS KENNEDY TELEPHONE NO. (717) 731-1600 FAX NO. (717) 731-1460 I am in receipt of your letters dated June 17 and June 19, 2008. After reviewing the matters therein with my client, we are prepared to make the following response. All issues that remain open between the parties will be resolved at one time. Your suggestion that Miss Shellehamer's name be removed from the registration for "Junior" before resolution of the other issues is therefore rejected. Likewise, your submission of $4,000.00 for purchase of Dillon is rejected as being unreasonable. I enclose for your reference three letters from beagle breeders, namely, Windkist Beagles, Moyer's Beagles,. and Barons-Hounds. All three letters refute your client's claimed price. Most telling is the letter from Leah Bertagnolli of Windkist Beagles, from whom Dillon was obtained. We submit that a reasonable price for Dillon is $680, payable to your client. However, a complete accounting is needed to resolve all outstanding issues. To that end we submit the following statement: To Martin for Purchase of Dillon $ 680.00 To Martin for George Alston Clinic $ 175.00 To Martin for licenses, etc. $_ 146.25 i'G i AlL for Martin $1,001.25 To Shellehamers for work in Kennel - $1,428.00 To Shellehamers for carpentry work done at Martin home and Martin kennel - $ 572.95 To Shellehamers for grooming services - $ 60.00 To Shellehamers for dog food and for Harrisburg Puppy Match & Handling Class - $ 128.83 Amount owed to Shellehamers $1,188.53 As you can see, Ms. Martin owes the Shellehamers an.amount of $1,188.53. Mr. William Lewis Grubb, Esquire July 8, 2008 Page Two Also, we will need the following items returned: 1) Annabelle's (Tung's Miss Tropicana Annabella) rabies certificate; 2) Annabelle's shot record; 3) Two (2) pictures of Best of Breed at Harrisburg for the Male Brittany Special (Junior); 4) Two (2) pictures at Harrisburg of Dillon for Best of Breed and Group 3 Placement; 5) Two (2) pictures of Best of Breed at Timonium for the Male Brittany Spcuiai; 6) Various articles of Miss Shellehamer's clothing; 7) One (1) pair of boots; 8) Dog bed Miss Shellehamer bought for Dillon; 9) Four (4) pictures of various wins of Miss Shellehamer and Annabelle (frames are owned by Ms. Martin). Once the aforesaid amount is paid and the items returned, Miss Shellehamer will execute the AKC documents for "Junior." Of course, Ms. Martin and Ms. Wijaya will be required to execute similar AKC documents for Dillon. This can all be done at one time, at either your office or mine. Thank you for your attention to this matter. Very truly yours, KOLLAS AND KENNY James W. Kollas JWK/car Enclosures cc. Shellehamer 30069 SCOTTLAND ROAD . LAUREL, DE 19956 June 25, 2008 To Whom It May Concern: My name is Kent VanBuren and I own Baron's Hounds, along with my son. We have been showing and breeding AKC beagles in conformation since 1985 and just recently began showing in UKC. We recently purchased a finished Champion Beagle named Tesoros Man After Midnight from Texas. This beagle is an AKC and a UKC Champion. N t the time of purchase was the #3 13" Beagle in the United States. Our purchase price for this beagle was $1,500.00. It is our opinion that a one year old puppy that is unfinished and may not even be able to be bred is definitely not worth $4,000.00. At one year of age and still growing, it is possible he may go over 15" and can never be shown. In addition, most champions are not bred outside of the owner's bitches and certainly not 8 different times unless you are in the business of running a puppy mill. If this one year old, unfinished puppy is worth $4,000.00, than my dual champion must be worth at least $15,000.00; however, I can only dream. We don't know what occurs with other breeds, but this beagle should be sold at a reasonable price which I would put at $800.00. If you have any questions, please be in touch with me. Sincerely, Kent VanByren WINDKIST BEAGLES 4983 W 2150 N OGDEN, UT 84404 801-731-7211 June 28, 2008 Elizabeth Shellehamer 610 South Ridge Rd. York Springs, PA. 17372 To Whom It May Concern: eng?? Regarding the beagle Dillon AKC HP262564/03 and his ownership. In Jan 2007 1 was contacted by Elizabeth Shellehamer in regards to a young beagle I had for sale on my website. At that time another party who Elizabeth was working for as a junior assistant offered to pay for this dog for her. The dog was transferred to Elizabeth on January 22nd 2007. At that time it was my desire and understanding that "Dillon" would live with Elizabeth exclusively and be HER dog to show in the breed and as a junior handler. At NO time was I under the impression that Lynda Martin would claim any ownership to Dillon other than to lend support to Elizabeth and help her with choices on where she might show him. It is my sincere desire that Dillon is to remain with Elizabeth and that her parents are allowed to purchase him outright for $640.00 which is what Lynda paid for him. His worth is only as a companion at this point and he has NO worth whatsoever as a stud dog at this time. His worth as a stud dog at a later time would probably be very limited and I cannot see that he will be in demand for that use. As a reference. The going price for a beagle puppy is 800.00 The price for an older dog is usually the same and I priced Dillion so, that Elizabeth could afford him. Stud fee's for unproven dogs who are not champions would be 250.00. Proven stud dogs who have produced Champions and who are also Champions themselves are 500-600 It is ridiculous to think that Dillon is worth 4000.00 to anyone at this point. Young Champions do not even sell for such a high price. Sincerely, Leah Bertagnolli MOVER'S BEAGLES Bill and Sandy Moyer 570.758.2364 June 22, 2008 To whom it may concern: oqz?) D?-> My name is Bill Moyer and my family and I have been Beagle Breeders for 12 years. Our involvement with the beagle breed has allowed us to become very knowledgeable of the breed. This resulted in my becoming an AKC Field Trial Judge, a PBGA (Pennsylvania Beagle Gundog Association) Show judge and an armature confirmation handler. Being a breeder we have accomplished breeding several field and confirmation Champions. Understanding and practicing the AKC breed standards has given us the knowledge to know what to look for in a beagle of quality. In my opinion, a one year old male beagle which has not fully matured, has not attained a championship, has not been proven (proven meaning = siting quality puppies without genetic flaws) and in fact has not attained an age that would exclude genetic flaws cannot be assessed a value equal to that of an accomplished dog. A beagle dog; as described above; can only be valued as pet quality and no more than the original $600 it was purchased for. The price of $4,000 that was placed on this beagle is outrageous and would never be paid. The only time this beagle would be worth $4,000 is after the above milestones have been met and not before. Should you or anyone have any further questions please contact us at the above address or phone number. Sincerely, l Bill and Sandy Moyer Fn m a a ??vnn m I m z c c ca m O r m z d 0 m A ? O r.: 0 m m ?r v Q Z m r O r r _ m IN III ?k n O tt 1 ? ? z N-A m I Y D m lAr- v p a g e. o. c o e ° Zm v P -N .,Q ? m m CJ -a z 3 z 1 11 mo p30 a -' m D m ?i r G m fil O 0 z Q F z z m r c v4 O m Z Q n m K m z 4 ?y O v v ?i u O 2 G m r n m z m 0 0 4 m m m 1 3 ns m L rrt Q 0 .4c T z 4 ? r x c 1/1 to i i ? r ? i - 17v 4t? I li p IT\ m m ` ? w ?. w 1 I ? Z 6 0 j p3 D D = m n c m 0 10 M z z m r m e m D c O m z O E11 f - m ? m D Q 0 m 2 m Z ? c ? m _r rq z m { r,: n r Z m ? m v z rn r O r r CO) rn 0 .S z Q A z z m r c m? C O m z Q MO m A Boarding Fees for E. Shellehamer Annabelle Starting November 2, 2007 29 days December 31 days January 2008 31 days February 2008 29 days Ending March 30, 2008 30 days TOTAL 150 days X $17.00 TOTAL DUE $2,550.00 Keepsake Starting November 17, 2007 14 days December 31 days January 2008 31 days February 2008 29 days Ending March 16, 2008 16 days TOTAL 121 days X $17.00 TOTAL DUE $2,057.00 Buddy Starting February 17, 2008 13 days Ending March 4, 2008 4 days TOTAL 17 days X $17.00 TOTAL DUE $289.00 04 Annabelle Keepsake Buddy TOTAL DUE $2,550.00 2,210.00 289.00 $5,049.00 CHAR-LYN KENNELS 1422 HOLLY PIKE CARLISLE, PA 17015 717-249-4999 Elizabeth Shellehamer 610 S. Ridge Road York Springs PA 17372 Tutoring for Algebra. - 3 sessions with Brandon Metz $150.00 CHAR-LYN KENNELS 1422 HOLLY PIKE CARLISLE, PA 17015 717-249-4999 Co-Ownership of Dog This contractual agreement made this ,A OvD day of J , 2007 by and between Lynda L. Martin and Wenny Wijaya of 1422 Holl Pike, Carlisle, Pennsylvania, and Elizabeth A. Shellehamer of 610 South Ridge Road, York Springs, Pennsylvania. This agreement is for the purpose of owning, caring, showing and expense for one male Beagle presently known as "Dillon". All parties hereinafter set forth agree as follows: All parties must agree to how Dillon is cared for, such as living arrangements and food. All parties must agree to when and to whom Dillon will be bred to after he completes his championship. All parties must agree to when and where Dillon will be campaigned for future shows. All parties must agree before selling of said dog. All Parties must agree to use "Hammer Beagles" of breed line for future beagles which are sired by said dog. Ms. Martin and Ms Wijaya will be responsible for purchasing and shipping of said dog. Ms Martin and Ms Wijaya will be responsible for any medical expenses, food, vitamins and supplements of said dog. D Ms Martin and Ms Wijaya will be responsible for show entries of said dog. Ms Shellehamer will be responsible for training, conditioning, grooming and showing of said dog. Buyout of Dillon will be allowed at reasonable cost to all parties. Signed Owner: Signed 'Owner: Wit ess: Print Name: Print Name: Print Name: CHAR-LYN KENNELS 1422 HOLLY PIKE CARLISLE, PA 17015 717-249-4999 January 21, 2008 Leah Bertagnolli 4983 W 21250 N Ogden, Utah 84404 Dear Leah: I'm enclosing my company check in the amount of $640.00. This will cover the sale of Dillon and the crate cost. Shipping of Dillon as discussed will be paid by me when I pick him up at the airport. We will plan on picking him up at Dulles Airport on Monday, January 28th per our discussions, on the airline and flight information you had email to me. If there are any changes, please let me know. I am looking forward to having Dillon and begin working with him. He will be the basis of my Beagle breeding line after he finishes his championship. I will contact you in the future for suggestions on breeding Dillon when the times comes. Thank you for everything. Sincerely yours, Lynda L. Martin 2008051632000149:000002 scanned on IMAMGR by Operator IMAMGR on May 16, 2008 at 12:02:47 PM - Page 2 of 2. 11 asr-?-rd^'7F! CHAR•LYN KENNELS 755 ?I 1422 HOLLY PIKE GARUSLE, PA 470154102 717-m wg Date w illan13 176 { pay to t Order t 3 P N AN IN . PK?C rlmk. NA wie .. l.mum rn Fa?..17650J?f/f/Cj l 1.[]3 i312738I. 501044373 N' 0755 4,100000640000, - ._. r •°'-??-?"?-fit----? -;.-?-r- _?--?-- _?-F-_-?-:. r,;=•- wr-:. ??i.=?. i 4Si.i. SAG. ?.%+ Cl/?417 _',V4T' F,? ?.(•; CA F } Cf?:; l- >`PL- 443 LA ? a 3 ? ?? ae?+e? - OSIO00740 F'B-PHlLA rJ _ .. ,. .? . ....., .? 3244,7?7-1516 - I ?, o Uv -no ? , 0 c c .. ^?s 5 ??j 2008Q51632000149000002 IMAMGR 02 20080128 000000000087352300 000000000000064000 000000000755 D 000000005004437368 KRISTIN ADAMS U1-U676-01-1 M. J. MALL SOUTH HANOVER ST CARLISLE, PA 17013 (DPNCBANI( ?Od I PNC Bank Platinum Business Rewards MasterCarc* Februerryy Statement for activity from .tan. 09.2008 through Feb 47, 2048 Inquiries: l-866-Page 395-8773 1 of 2 al CHARLYN KENNELS (COW 000556991) T?tiC'ffsr„? q?1• Activity Summary Previous Balance ............................. ments and Cred'its ........................ P $70.09 $141.07 0 ay Purchases, Advances & Other Debits .6 $2,204 $0.00 FINANCE CHARGES ......................». $2,133.62 New Balance ...................................... Credit and Payment Information Credit Line ... ............................................ Available Credit .......................................... Minimum Payment Due Current Month)... Minimum Payment Due Past Due) ........... Total New Minimum Payment Due.......... Payment Due Date .......» ........................». $15,500.00 $13,368.38 $22.00 $0.00 *".00 Mar. 03,2008 To reduce or avoid Paying addition finance charges on your Purchase b8f8tce. pay the lose! new balance is recoved Any cash balance or glance hander bakvm WHI continue to accrue daily interest until the date your pWn 40A .. Post Trams Date Date 01/09 01108 01/14 01112 01/14 01112 01114 01113 01116 01115 01122 01/21 01122 01/19 01122 01118 01124 01/22 01124 01123 01/24 01123 01/28 01/25 01/28 01125 01/28 o i/29 01/28 02/01 01131 02/01 01/31 02104 02101 1 02/06 02/05 Rel. Nbr D"cKw1urt of Transaction 7811 DRI'Symantecslore.cam 800-441-7234 MN .......................... MERCHANDISEISERVICE RETURN 8585 VALUE CITY FUR00000927 MECHANICSBURG PA ........... 0205 EIGHT & EIGHT SUPERMAR HARRISBURG PA ................ 4442 SHEETZ 00002329 MT HOLLY SPRG PA ................. 0681 MB F DOG SHOWS INFODOG 336.3799352 INC ................. 0490 SHEETZ 00002003 MT HOLLY SPRG PA ....................... 9330 PAYLESSSHOESOU00039214 CAMP HILL PA ................. 3721 WM SUPERCENTER CARLISLE PA .......................... 0018 KENT R RE14TSCHLER LLC CARLISLE PA ..................... 8160 WAL-MART 92574 CARLISLE PA ............................... 3803 14MG-PETMEDS 8007386337 FL ................................ 0437 WAL-MART #1886 MECHANiCSBUR PA ...................... 0053 KIMEB & CO STUDIO FOR CARLISLE PA ........................ 0138 REV PROV CRDT DRI'SYMANTECSTORE.COM................ DEBIT ADJUSTMENT 7738 PETSMART 00015214 CARLISLE PA..... ..................?.. 3573 krivACr ETZ 00002329 MT HOLLY SPRG PA ....................... 1064 R U26 CARLISLE P6419 MERICAN KENNEL CLU 9192339To NY ................ ELTA nnrnnn06898975WASHINGTON DC ................... Amount $70.98 CR $423.99 $74.44 $55.01 $81.50 $44.66 $38.98 .04 $8800 $273.66 $164.20 $77.87 $121.00 $70.98 $65.31 $47.50 $239.00 $39.00 $229.44 2174 Total for account 5472 6500 0132 3187 ............... $2,133.62 4x O a CIS A 41 Shipper's Name and Address Shipper's Account Number Nof Negotiable Air Waybill Issued by Copies 1, 2 and 3 of this Air Waybill are originals and have the same validity. Consignee's Name and Address Consignee's Account Number 11 is agreed that the goods described herein are accepted in apparent good order and condition t as noted) for carriage SUBJECT TO THE CONDITIONS OF CONTRACT ON THE xce (e p REVERSE HEREOF. ALL GOODS MAY BE CARRIED BY'ANY OTHER MEANS INCLUDING ROAD OR ANY OTHER CARRIER UNLESS SPECIFIC CONTRARY INSTRUCTIONS ARE GIVEN HEREON BY THE SHIPPER, AND SHIPPER AGREES THAT THE SHIPMENT MAY BE CARRIED VIA INTERMEDIATE STOPPING PLACES WHICH THE CARRIER DEEMS APPROPRIATE. THE SHIPPER'S ATTENTION 1S DRAWN TO THE NOTICE CONCERNING CARRIER'S LIMITATION OF LIABILITY. Shipper may increase such limitation of liability by declaring a higher value for carriage and paying a supplemental charge !f required. Issuing Carrier's Agent Name and City Accounting Information Agent's IATA Code Account No. Airport of Departure (Addr. of First Carrier) and Requesting Routing Reference Number O tional S i n Information r FlowhIP °ntl o°'" ° °n Fi t C i B to by to by Currency . M AL er Declared Value for Carriage Declared Value for Customs To arr e rs y rro Airport of Destination Reauested F a Amount of Insurance INSURANCE If carrier offers insurance, and such insurance is requested in accordance with the conditions hereof, indicate amount to be insured in figures in box marked "Amount of Insurance'. Handling Information r` ? ? ?Ti- # s,• ?-r, i '- ? t I:> r ,v r ? v+? i );:-y e ? ?a sf t .?. _ SCI These Commodities, technology or software were exported from the United States r l w r ..- + ?• a to in accordance with the Expo1S Administration Regulations, Ultimate destinati No. of Gross k Rate Class Chargeable Rat g Total Nature and Quantity of Goods Pieces omm Weight Charge CP Weight lb . (incl. Dimensions or Volume) R No. Item No. ^-r-^ Prepaid Wei ht:Gha a Collect Other Charges Val n Char Tax Total her Char es Due Agant Shipper certifies that the particulars on the face hereof are correct and that insofar as any part of the consignment contains dangerous goods, such part is property described by name and is in proper condition for carriage by air according to the applicable Dangerous Goods Regulations. Total Other Char as Due Carrier .' ------ - ------ -------- --------------- ----- ___ ---- - - Signature..pf Shipper or his gent Total Prepaid Total Collect Currency Conversion Rates GC Charges -.in Desl.- Currenc QPNCBANK ?`' N, PNC Bank Platinum Business Rewards MasterCard® 91 Februarryy Statement for activity from Jan. 09, 2008 through Feb. 07, 2008 inquiries: t-866-395-8773 CHARM KENNELS (CPN 000556991) BUS Zees Page 1 of 2 ?y Ur Activity Summary i1V>)lri?s M&it#a ar??? gocourl at a gI a- Aat a?mf 5E7472 U0i1 Ot 18 00 Previous Balance ................................. $70.09 Payments and Craft .................... $141.07 Purchases, Advances & Other Debits $2,204.60 FINANCE CHARGES ...........»............ $0.00 New Balance ...... .. .............................. 52,133.62 Credit and Payment Information Credit Line .. ......................................... $15,500.00 Available Credit ........................................... $13,366.38 Minimum Payment Due (Current Month)... $22.00 Minimum Payment Due (Past Due) .,......... $0.00 Total Now Minimum Payment Due.......... $22.00 Payment Due Date .................................». Aar. 03, 2008 To reduce or avoN peying ac?rNorta/ &rranoe charges on your pWChase batarrce. pay the mtai mew balance o/52 (93.62 by 03' Any cash balance or bala?ice (scaler balance Wff contirwe to aaxue daffy interest U06 the date your payment is received. -O11rdf? '$'! ?QO 'tA19tC18 .!MART „_. .. .,._... _.. Post Thm Ref. Date Date Nbr Dew* ftn of Trertsactlon Amount 01109 01/08 7811 DRI'Syrnantecstore.com 800-441-7234 MN .......................... $70.98 CR 01114 01112 8585 01114 01/12 0205 01/14 01/13 4442 01/16 01/15 0681 01/22 01/21 0490 01122 01/19 9330 01/22 01118 3721 01/24 01/22 0018 01124 01/23 8160 01/24 01123 3803 01/28 01126 0437 01/28 01125 0053 01128 0138 01/29 01/28 7738 02/01 01/31 3573 02101 01/31 1064 02104 02/01 6419 02/06 02105 2174 MERCHANDISE/SERVICE RETURN VALUE CITY FUR00000927 MECHANICSBURG PA ........... EIGHT & EIGHT SUPERMAR HARRISBURG PA ................ SHEETZ 00002329 MT HOLLY SPRG PA ....................... MB F DOG SHOWS INFODOG 336-3799352 NC ................. SHEET 00002003 MT HOLLY SPRG PA ....................... PAYLESSSHOES0000039214 CAMP HILL PA ................. WM SUPERCENTER CARLISLE PA .......................... KENT R. RENTSCHLER LLC CARLISLE PA....„ ............... WAL-MART #2574 CARLISLE PA ............................... 14800-PETMEDS 8007386337 FL ................................ WAL-MART #1886 MECHANICSBUR PA ...................... KIMES & CO STUDIO FOR CARLISLE PA ........................ REV PROV CRDT DRI'SYMANTECSTORE.COM ................ DEBIT ADJUSTMENT PETSMART 00015214 CARLISLE PA ........................... SHEETZ 00002329 MT HOLLY SPRG PA ....................... TRACTOR-SUPPLY-CO #1026 CARLISLE PA........... _....... AMERICAN KENNEL CLU 9192339767 NY ..................... DELTA 0060DOOSS98975WASHINGTON DC ................... $423.99 $74.44 $55.01 $81.50 $44.66 $38.98 $88.04 $70.00 $273.68 $164.20 $77.87 $121.00 $70.98 $65-31 $47.50 $39.00 -- ,/deli 5 . $229.44 Total for account 5472 6500 0132 3187 ................ $2,133.62 CAkoe- 1140T I a `" ?3a Dog Registration Application I I"?II I?I? IIf LII??II I?I,II'I IIII AMERICAN ' with the AKC 0 Important information and instructions are on page 2 of * KENNEL CLUB Use this form to register your purebred dog .? ,. this form. Information you omit will delay processing. AKC reserves the right to correct or cancel for cause the registration of this dog and its descendants. Registration is not guaranteed. Processing fees 04"VO - are nonrefundable, and all fees are subject to change without notice. Once submitted, this application becomes the property of the AKC. INTER OWNER COMPLETES BLUE SECTIONS- NEW OWNER COMPLETES RED SECTIONS. Number: HP26256403 Breed BEAGLE Date of Birth JUNE 27, 2007 Dam CH WINDKIST AFTERNOON DELIGHT Sire CH WINDKIST A WALK IN THE PARK HP01354201 (08-04) HM98535001 (01-03) AKC DNA #V252261 Breeder LEAH BERTAGNOLLI Fly Litter Owner LEAH BERTAGNOLLI ? 2@r 4983 W 2150 N, OGDEN, UT 84404-9799-83 ? 'a9Y 414* STEP 1) Choose one of the following two optional registration packages STEP 2) Add the Lost & Found Option Gold Package: $27 (Save $15.901) Silver Package: $17 (Save $3.001) Lost & Found Option: $12 . a •Three-Generation AKC-Certified Pedigree •Three-Generation AKC-Certiled Pedigree L„„,:, Lifetime enrolment in recovery service • A collar tag with your dog's AKC registration number 1 -year Dog C AKC Family Dog magazine subscription $30 in 9-certificates from dog.com For more information visit www akc orgiftffound • Dog Care & Training Video (DVD) ten in 4-.risacatas from doo.com STEP 3) Total the amount due and provide payment information 11111- AKC Registration $ • Basic Registration. AKC Registration Certificate and $15 in e-certificates from dog.com. Gold or Silver Package $ bl- Enter an additional $27 for the Gold Package or $17 for the Silver Package if applicable. • Enter $12 for the Lost & Found Option If applicable. Lost & Found Option $ Calculate the transfer fee. See the Supplemental Transfer Instructions Number of x $5 Transfer Fee $ section on page 2 to determine the amount owed. transfers: Late Fee $ 2008 or • Enter a late fee of $35 if you are you are submitting haft form LY 6, 2009. $65 If you are submitting It after JULY 6, 2009. Total Fee $ 2 0 s I ! € I -0-9 Name 0 Microchip Tattoo Kennel Name Owner's Signature Identif catian Number d toda ! Online Litter Owner(s): Please completely darken the box below to request Limited registration. Limited 998 If the box to the left is completely darkened, the dog is not to be used for breeding. Entry in dog events is restricted. Enter the 3-digitcode that most closely describes your dog. For alternatives, see www.akccolors.org ,/ 1 016 Black & Tan 197 Tan & White 1[/ 027 Black Red & White 291 Blue Tan & White 029 Black Tan & Bkietick 030 Black Tan & White 034 Black White & Tan 063 Brown & Whtte 066 Brown White & Tan 115 Lemon & White 146 Red & White Return this form by mall or go online to register your og y registration is fast and easyl 1) Go to www.akc.ora/dOOre0l 2) Follow the step by step instructions 3) Your PIN for this application is: 56300 Enter the 3-digitcodethat most closely describes your dog. For alternatives, see www.akccolors.org 013 Ticked Continued on page 2. ADREG2 (04/07) M01 F02 HP2625"03 02007 The American Kennel Club Mimi MM flN ?i , Dog Registration Application AF2A1- I (we) still own this dog and apply for registration and to have ownership recorded in my (our) name(s). Are) transferred this dog directly to the owner(s) listed the New Owner(s) section below. i I (we) certify by my (our) signature(s) that all the information appearing on this application is correct and that I (we) am (are) in good standing with the American Kennel Club. I (WE) AGREE THAT ANY CAUSE OF ACTION, CONTROVERSY OR CLAIM ARISING OUT OF OR RELATED TO THIS REGISTRATION OR AS TO THE CONSTRUCTION, INTERPRETATION AND EFFECT OF THIS AGREEMENT SHALL BE SETTLED BY ARBITRATION PURSUANT TO THE APPLICABLE RULES OF THE AMERICAN ARBITRATION ASSOCIATION. HOWEVER, PRIOR TO ARBITRATION ALL APPLICABLE AKC BYLAWS, RU S, REGULATIONS AND PROCEDURES MUST FIRST BE FOLLOWED AS SET FORTH IN THE AKC CHARTER AND BYLAWS, RULES, REGULATIONS, PUBLISHED POLICIES ANDfjiU1DELINES. A - Date of Transfer: -._i-._w°-- -•- K ? € 3 q d i ? 3 Z1 _ s. ... Email • l (we) apply to the American Kennel Club to have a Registration Certificate for this dog issued in my (our) name(s). 1(we) certify that I (we) acquired this dog directly on the date stated above from the Litter Owner(s) and if applicable, that l (we) have complete written authority from the other owner(s) to submit this application to register this dog in all our names. I (we) understand that upon request I (we) will be required to provide to the AKC any such written authorization. I (we) agree to abide by all rules and regulations of the American Kennel Club. I (we) understand that if the Limited box on the Dog Registration Application has been darkened completely by the Litter Owner(s), I (we) will receive a Limited Registration Certificate. I (WE) AGREE THAT ANY CAUSE OF ACTION, CONTROVERSY OR CLAIM ARISING OUT OF OR RELATED TO THIS REGISTRATION OR AS TO THE CONSTRUCTION, INTERPRETATION AND EFFECT OF THIS AGREEMENT SHALL BE SETTLED BY ARBITRATION PURSUANT TO THE APPLICABLE RULES OF THE AMERICAN ARBITRATION ASSOCIATION. HOWEVER, PRIOR TO ARBITRATION ALL APPLICABLE AKC BYLAWS, RULES, REGULATIONS AND PROCEDURES MUST FIRST BE FOLLOWED AS SET FORTH IN THE AKC CHARTER AND BYLAWS, RULES, REGULATIONS, PUBLISHED POLICIES AND GUIDELINES. wen Co owner's Supplemental if you did not acquire this dog directly from the litter owner(s), you must include a Supplemental Transfer Statement With fee for each intermediate transfer Transfer with this application. Multiply the number of Supplemental Transfer Statements by the amount shown under Payment Information on page 1 of this Instructions application and include this amount in the total payment. Note: This form is available on our Web site: www.akc.org. Mailing Address Send this forth and all appropriate fees to: The American Kennel Club, P.O. Box 37902, Raleigh, NC 27627-7902. Additional If there are more than two new owners, contact the AKC for an Additional Signature Forth. NOTE: This form is available on our Web site: www.akc.org. Requirements Authorizations Signatures of persons other than the owners will be accepted only if a properly completed authorization form has been filed with the AKC. NOTE: These forms are available on our Web site: www.akc.org. Assistance Email AKC at info@akc.org or call 919-233-9767 to speak to an AKC Customer Service Representative, Monday - Friday, 8:30 AM - 5:00 PM. Information about the registration process and downloadable forms are available on our Web site: www.akc.org You must provide a valid email address to receive dog.com's e-certificates and an ecedificate for an office visit with a practice participating in the AKC Veterinary Network. By supplying your email address, you consent to receive complimentary a-certificates and communications from AKC and approved third parties. For more details on the AKC Veterinary Network and a list of participating practices, go to www.akc.org/vatnet. ADREG2 (04/07) 1957 AMERICAN ?? KENNEL ??? 1111111IdNU?III?NIN CQmcast Webmail - Email Message http://mailcenter2.comcast.netlwmc/v/wm/482762BD0004778500O.. From: `Teresa Sheteharnee <sheKehaMer4 bargniaiLc0n1> To: <martin1ynda3@comcastnet>, "Lynda Martin" <char-Iynkennelsc@comcast.net>, <9hart914@comcast. net> Date: Sunday, May 04, 2008 7:07:.28 PM 05/04/08 Dear Lynda, I am soooo sorry we haven't been able to get back to you until now. We left for the cabin on Friday and just got back. [We needed a restful weekend away from the hustle and bustle]. We just got home and I checked the phone messages and emails. We would love to get together with you and discuss the dogs. Rick is very busy at work right now. He is on a deadline - he has to remodel 5 apartments by the end of this month and will be working long hours and weekends from now until then. We will see how his week progresses and hopefully we can get together the end of this week or sometime next week. I will be in touch. Teresa Original Message From: <martin1ynda3 ,comcast.net> To: "Elizabeth Shellehamer" <easlv`NNELSgembargmail.com>; <shellehamer4 _embargmail.com> Cc: <ghart9140)-comcast.net> Sent Saturday, May 03, 2008 11:45 AM Subject: Dillon > Hi Theresa, Rick and Elizabether, > I left a message yesterday at 10 am asking that you call me back so that > we can sit down and discuss Dillon. It's now over 24 hrs later and 1 Coxncast Webmail - Email Message http://mailcenter2.comcast_net/Nvmc/v`/Wm/482762BD0004778500O':, > kept away from me and I when I wanted to keep him on occasions only to be > told by Elizabeth that her mother told her to make sure she brought Dillon > with her. I have been told on a few occasions not to touch/handle him. I >. have gone along with everything even against my best instincts- It seems I > have little or no say in this dog which legally is mine. Which now I must > conclude that anything in regards to Dillon would never have been > discussed with me which includes future shows, breeding, etc. 7 > I'm also saddened that my relationship with Elizabeth went from working > together to non existence- I don't know why as it was never told to me. > I have tried to give her opportunities to show dogs because I believed in > her. I have never taken advantage of Elizabeth, befriending her, treating > her life my niece- I have extended this friendship to the rest of the ;>famfly. lhave invitpo Theresa to join us and Elizabeth to the shows in > NJ, givi?a.ss h time t- be : e z=i$h her ?au-g?..t iover..3IC- r:??_•nr•:?+E VIY'l1I<, IIGI ulII LL! IJU kL6U! I I I ti CA %41itt g R.FL°k.`I LIVU I.: I!U, ?}r+c ,?? lrt +11"# #h--+ _C' € *e:- [ +E+_ A+REC? ^,s - i£ru• i i t I i 'sa(JA jeIj peei. itj rki iwvw u M L Y$F IGxiy if syf I t6 iir G.? FLV ifv' ?„/.4. i wt &I i'v? f? I LIn a e4iuGast ?V'e mail - Email Message http://maiiceWer2.comaist.nedwmclvlwn7.'48-2 <64660003E204000.. From: "Teresa. Shetlehamer`* <shetfeharner4@embargrnail.ca To: "Lynda Martin <martinlynda3Lcorncast.net>, "Lynda Miartin" <char 4ynkenneEs@comcast.net> Date: Tuesday M2Y 06 2008-2-157-In P&4 05/08/08 Dear Lynda, Unfortunately, there is no way we can meet with you this week. Rick has those apartments and just found out that he has to have the apartment pool ready to be opened for Memoriai slay Weekend and the people who were supposed to help him are not going to help him now. He's working daylight til dark and then some and can't even go to the dog shows this weekend because he's going to be working. Nothing's going to get done at my place either. it looks like next Wednesday around 3:30 p.m. will work beeause dick has a meeting later that day with someone who wants an addition done in the York Springs area. So 3:30 next Wednesday at our house. Let me know if that, works for you. Teresa Comcast Webmail - Email Message http://maileenter2.comcast.net/wmc/vhvzn/49277'?2A000EB7A400... comcost. From: "Teresa Shellehamer' <shellehamer4@embargmail.com> To: "Lynda Martin" <char-lynkennels@comcast.net>, "Lynda Martin" <martinlynda3@comcast.net> Date: Sunday, May 11, 2008 6:10:31 PM 05/11/08 Dear Lynda, We received your phone message on Friday. As you know, we were at the dog shows this weekend. I am sure you have received our attorney's letter by now and you were instructed not to contact us directly, but to direct everything to our attorney. From now on, we ask that you please do that. James W. Kollas, Esquire KOLLAS AND KENNEDY 1104 Femwood Avenue Suite 104 Camp Hill, PA 17011 717-731-1600 Sincerely, Teresa Walton-Shellehamer VERIFICATION I, Lynda Martin and Wenny Wijaya, Plaintiffs in this matter, verify that the statements made in the foregoing Complaint are true and correct. I understand that false statements herein are made subject to the penalties of 18 Pa. C. S. § 4904 relating to unsworn falsification to authorities. yn a Martin a?? Wenny Wij a Date: l' 1. T . _.... O SHERIFF'S RETURN - OUT OF COUNTY CASE NO: 2008-05726 P COMMONWEALTH OF PENNSYLVANIA: COUNTY OF CUMBERLAND MARTIN LYNDA ET AL VS SHELLEHAMER ELIZABETH 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: SHELLEHAMER ELIZABETH MINOR but was unable to locate Her deputized the sheriff of ADAMS in his bailiwick. He therefore County, Pennsylvania, to serve the within COMPLAINT & NOTICE On October 30th , 2008 , this office was in receipt of the attached return from ADAMS Sheriff's Costs: So answ- Docketing 18.00 Out of County 9.00 Surcharge 10.00 R. Thomas Kline Dep Adams County 84.20 Sheriff of Cumberland County Postage 4.14 ? 125.34 J)1o716 Y 10/30/2008 KOPE & ASSOCIATES Sworn and subscribe to before me this day of A. D. In The Court of Common Pleas of Cumberland County, Pennsylvania Lynda Martin et al ` vs. Elizabeth Shellehaner, a minor 08-5726 civil No. Now, October 14, 2008 , I, SHERIFF OF CUMBERLAND COUNTY, PA, do hereby deputize the Sheriff of Adams County to execute this Writ, this deputation being made at the request and risk of the Plaintiff. ?j Sheriff of Cumberland County, PA Please mail return of service to Cumberland County Sheriff. Thank you. Affidavit of Service Now, within upon at by handing to a and made known to Sworn and subscribed before me this day of , 20 So answers, X D Sberiff N-bl e 'ff of dams County, A COSTS SERVICE _ MILEAGE _ AFFIDAVIT 20 , at o'clock copy of the original M. served the the contents thereof. AINQ03 SWVOV 331N3HS Z0 's v 91 130 8l 03A13338 * * 0 * * 0 0 ** *' * * 0 * * a MASON DIXON BUSINESS FORMS, INC. 39000026 DATE RECEIVED DATE PROCESSED SHERIFF'S DEPARTMENT ADAMS COUNTY, PENNSYLVANIA COURTHOUSE, GETTYSBURG, PA 17325 SHERIFF SERVICE TH NMWCnM- Sea ESHERIFF" on the "INSTRUCTIONS of On IM FOR SERVICE form. PROCESS RECEIPT, and AFFIDAVIT OF RETURN "n print legibly, insurli g r'.a'eiwly of all copies. OF ESS BY Pleass Do not detach any copies. ACRD O N1 1. PLAINTIFF/S/ 2. COURT NUMBER LYNDA MARTIN and WENNY WIJAYA 08-5726 Civil Term 3. DEFENDANTS/ 4. TYPE OF WRIT OR COMPLAINT: ELIZABETH SHELLEHAMER a minor Complaint in CivilAction UAVE 5. NAME OF INDIVIDUAL, COMPANY, CORPORATION, ETC., TO SERVICE OR DESCRIPTION OF PROPERTY TO BE LEVIED, ATTACHED OR SOLD. Elizabetb Sbellebamer, a minor 8. ADDRESS (Street or RFD, Apartment No., City, Boro, Twp., State and ZIP CODE) AT 610 Soutb Ridge Road, York Springs, PA 7. INDICATE UNUSUAL SERVICE: ? PERSONAL ? PERSON IN CHARGE ? DEPUTIZE ? CERT. MAIL ? REGISTERED MAIL ? POSTED ? OTHER Now, , I, SHERIFF OF ADAMS COUNTY, PA., do hereby deputize the Sheriff of County to execute this Writ and make return therof according to law. This deputation being made at the request and risk of the plaintiff. SHERIFF OF ADAMS COUNTY 8. SPECIAL INSTRUCTIONS OR OTHER INFORMATION THAT WILL ASSIST IN EXPEDITING SERVICE. NOTE ONLY APPLICABLE ON WRIT OF EXECUTION: N.B. WAIVER OF WATCHMAN-Any deputy sheriff levying upon or sttadit any property under within writ may lam same without a watchman, in custody of whomever is found in possession, after notifying person of levy or MtadlmsM, without liability on the part of such deputy or the sheriff to any plaintiff herein for any loss, destruction or removal of any such property before sheriff's sale thereof. 9. SIGNATURE of ATTORNEY or other ORIGINATOR requesting service on behalf of: 10. TELEPHONE NUMBER 11. DATE Shane B. Kope, Esq. PLAINTIFF ? DEFENDANT (717) 761-7573 rA 16 n r On ?r ¦ - n ? ?f ewe 1 G wyaa~ vw ern `OoG 12. 1 acknowledge receipt of the writ SIGNATURE of Authorized ACED Deputy cr Clerk and Title 13. Date Received 14. Expiration /79000fdab or complaint as indicated above. 10/15/2008 OClUBER 24L__2008 15. 1 hereby CERTIFY and RETURN that 1 ? have personally served, ? have served person in charge, ? have legal evidence of service as shown in "Remarks" (on reverse) ? have posted the abrnre described property with the writ or complaint described on the individual, company, corporation, etc., at the address shown above or on the individual, company, corporation, etc., at the address inserted below by handing/or Posting a TRUE and ATTESTED COPY therof. 18. K I hereby certNv and return a NOT FOUND because I am unable to locate the individual. comoamr. coronation. etc.. named above. (See remarks below) Is1 17. Name and title of individual served It A person of rik" ape and ftcretion Read Order d? O dstsnOeM a uwM =r ? ibo 19. Address of where served (complete only lf different than shown above) (Street or RFD, Apartment No., City, Soro, Twp., 20. Date of Service 21. Time State and ZIP CODE) REMAM: Unable to locate defendant for service prior to the expiration of the coWlaint. 22. ATTEMPTS Dab Mlles Dsp,Mt, Data MNss Dap.lnt. Dab ? D".htt. DeAe Elles Dep.IM. Daft Miles D"Ant. 0/2 30 JN 10/2 30 JN 0/2 30 KM 0/24 30 JN 23. Advance Costa 24. 25. N. 27. Total Costa 2e X?!lK?Ili REFUND 50.00 Fho.Att 84.20 Pd. 10/27/08 1$65.80 Ck. #19052 AFFIRMED and subscribed to before me this day A surely OMne Print or Type) JAMES 810neWre of Sheriff Dab 10/24/2008 10/24/2008 SHERIFF OF ADAIn COUNTY 33000025 # EPI REJURN OF SARM ( ) (1 ) The Wilma upon , the within named defendant by mailing to prepaid, a true and attested copy thereof at - mail, return receipt requested, postage on the The return receipt signed by defendant on the is hereto attached and made a part of this return. ( ) ( 2 ) Outsift1he Corarno ?wealth, pursuant to Pa. R.C.P. 405 (c) (1) (2), by mailing a true and attested copy thereof at in the following manner: { ) (a) to the defendant by ( } registered ( ) certified mail, return receipt requested, postage prepaid, addressee only on the said receipt being returned NOT signed by defendant, but with a notation by the Postal Authorities that Defendant refused to accept the same. The returned receipt and envelope is allecMd hereto and made a part of this return. And thereafter: ( ) (b) To the defendant by ordinary mail addressed- to defendant at same address, with the return address of the Sheriff appearing thereon, on the I further::eerlffy that after fifteen (15)days from the mailing Vie, l have nvt r4eMved said envelope back from the Postal Authorities. A certificate of mailing is hereto attached as a proof of mailing. ( ) (3) R.y, publication in the Adams County Legal Journal, a weekly publication of general circulation in the County of Adams, Commonwets of Pennsylvania, and OW111 b0w9 Times, a daily newspaper published in the County of Add Commonwealth of P vaais havkw general circulation in said County for successive weeks of The Affidavits from said Adams County Legal Journal and Gallysburg Timms, are here attschod and made part of this return. ( ) ( 4) By mailing to by nak return receipt, requested postage pr paid, on the a true and attested copy teieeo# at The returd by the Postal Authoritips Marked is hereto attached. ( ) ( 5 ) Other SHERIFF'S RETURN - OUT OF COUNTY CASE NO: 2008-05726 P COMMONWEALTH OF PENNSYLVANIA: COUNTY OF CUMBERLAND MARTIN LYNDA ET AL VS SHELLEHAMER ELIZABETH 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: SHELLEHAMER ELIZABETH MINOR but was unable to locate Her deputized the sheriff of ADAMS in his bailiwick. He therefore serve the within COMPLAINT & NOTTCF County, Pennsylvania, to On January 6th , 2009 , this office was in receipt of the attached return from ADAMS Sheriff's Docketing Out of Co Surcharge Dep Adams Postage Costs: 18.00 anty 9.00 10.00 County 150.00 4.11 So answers- R. 'T'homas Kline Sheriff of Cumberland County 01/06/2009 KOPE & ASSOCIATES Sworn and subscribe to before me this day of A. D. L LI ?: C t--4 t 3 In The Court of Common Pleas of Cumberland County, Pennsylvania Lynda Martin et al vs. Elizabeth Shellehamer, a minor No. 08-5726 civil Now, November 24, 2008 , I, SHERIFF OF CUMBERLAND COUNTY, PA, do hereby deputize the Sheriff of Adams County to execute this Writ, this deputation being made at the request and risk of the Plaintiff. 11 Sheriff of Cumberland County, PA Please mail return of service to Cumberland County Sheriff. Thank you. Affidavit of Service Now, , 20 , at o'clock M. served the within upon at by handing to a and made known to Sheriff of Sworn and subscribed before me this day of , 20 copy of the original So answers, COSTS SERVICE _ MILEAGE _ AFFIDAVIT the contents thereof. County, PA AINna0 SWdab AA183HS it a v sZ mm Im 03A13038 MASON DIXON BUSINESS FORMS, INC. 33000026 DATE RECENED DATE PROCESSED SHERIFF'S DEPARTMENT ADAMS COUNTY, PENNSYLVANIA COURTHOUSE, WMSOURG, PA 17325 INSTRUCTIONS: Sae "INSTRUCTIONS FOR SERVICE OF PROCESS BY SHERIFF SERVICE THE SHERIFF" on the reverse of the last (No. 5) copy of No form. Please illy, msurin PROCESS RECEIPT, and AFFIDAVIT OF RETURN Do or print logib detach copies. CSD mW , E, of sit `"Pi°a' 1 PLAINTIFFS/ 2. COURT NUMBER LYNDA MARTIN AND WENNY WIJAYA 08-5726 Civil Term 3. DEFENDANTS/ 4. TYPE OF WRIT OR COMPLAINT: ELIZABETH SH=-tAMER A MINOR Reinstated Ckuplaint in Civil Acticln S. NAME OF INDIVIDUAL, COMPANY, CORPORATION, ETC., TO SERVICE OR DESCRIPTION OF PROPERTY TO BE LEVIED, ATTACHED OR SOLD. Elizabeth Sbellebamer, a minor 6. ADDRESS (Street or RFD, Apartment No., City, Soro, Twp., State and ZIP CODE) AT 610 Soutb Ridge Rd., York Springs, PA 7. INDICATE UNUSUAL SERVICE: ? PERSONAL ? PERSON IN CHARGE ? DEPUTIZE ? CERT. MAIL O REGISTERED MAIL O POSTED O OTHER Now, , I, SHERIFF OF ADAMS COUNTY, PA., do hereby deputize the Sheriff of County to execute this Writ and make return therof according to law. This deputation being made at the request and risk of the plaintiff. SHERIFF OF ADAMS COUNTY S. SPECIAL INSTRUCTIONS OR OTHER INFORMATION THAT WILL ASSIST IN EXPEDITING SERVICE NOTE ONLY APPLICABLE ON WRIT OF EXECUTION: N.B. WAIVER OF WATCHMAN-Any deputy sheriff levying upon or attaching any property under within writ may leave same without a watchman, in custody of whomever is found in possession, after nottfying person of levy or attachment, without liability on the part of such deputy or the sheriff to any plaintiff herein for any loss, destruction or removal of any such property before sheriff's sale thereof. 9. SMATURE of ATTORNEY or other ORKUNATOR requesting service on behalf of: 10. TELEPHONE NUMBER 11. DATE X PLAINTIFF Shane B. Kope, Esq. ? DEFENDANT (717) 761-7573 ra C o ll R r R war_ r n i- %#11111116 1 n a aaa sa. 11160 w 595"o 1.51". 12. 1 acknowledge MOW of the writ SIGNATURE of Authorized ACSD Deputy or Clerk and Title 13. Date Received 14. Expiration date or complaint as indicated above. 11/25/2008 DEC. 19. 2008 15. 1 hereby CERTIFY and RETURN that 1 ? have personally served, ? have served person in charge, ? have legal evidence of service as shown in "Remarks" (on reverse) ? have posted the above described property with the writ or complaint described on the Individual, company, corporation, etc., at the address shown above or on the individual, company, corporation, etc., at the address inserted below by handingtor Posting a TRUE and ATTESTED COPY therof. .e rYi ,..na,, ..A -h- . anT FM Mrs t a -auaa I am unahla to locate the individual. eomnanv_ oorooration. Me.. named above. (See remarks below) $1 17. Name and tide of individual served IS. A pefson of ausaWe age and discretion then reeldltq in the dsfsndam's usual ft" Order plan a atoll.. ? ? 19. Address of where served e?tta only if diff?rent than shown above) St or Rtp, Apartment No., $.fly, Nro, Twp. ?0 Date o Service stm and zip CODE) REMARKS C Unable to serve prior to expiration cam lilt. S?even 6/ - 21. Time atteemmppts were & 12 17/08 ling dates: 12/1/08, 1213/08, 12/4/08 12/8/08 made on the of ll c ' 12/15/ , 1F1 fi h if J . t t . to ca _on at t as de Notes were le t a res s o ce. er s ac con we 22. ATn M TS Deb MSM Oap.lnt. Dab MINs Dsp.hA. Daft MNas Dsp.hvL Dab MSea Dep.int. Dab US" Dep.htt. 23. Advance Costs 24. 25. 28. 27. Total Cogs 2S. COST DUE OR REFUND 501.001 AB.Atty. 40 1 $150.00 Pd. 1/2/09 NONE AFFNWED and subscribed to before me this day * 0" 1 Dap-1IMr" (Please Prim a Too) slgiva re a Sham SM11IFF OF ADAMS COUNTY /' Date 12/17/2008 Dees The return receipt signed by cWendant on the is hereto attached and nwde*pert to P RX () (1) (), by mailing a true t '244MM"'26- Ali aeadl 'Ram *WOO , at in Ow *Nmft C ) (a) to the defendantby ( ) regleftred ( ) corded mail, return receipt requested; Poster Prepaid, addrossee only on the said receipt being returned NOT signed by defendant, but with a natation by the Postal Authorities that p eMt fraae # t e!tae .Aha omm. Tim firmed receipt and envelope is att ed °lesreto and made a part of tfds rtlNkim. And thereat?tar: ( ) (b) To the defendant by ordinary mail addressed to defendant at same address, with the return address of the Sheriff appqw4V Win, on the t fur*w cs y, that after Mean (16)° days foom the -dads, i' ham* not re Ft - said envelope back from the Postal Authorities, _A certificate of rnai g is hereto attached as a proof of nWling. C ) (3) By pWPksitW in MA._ ? l Journal, a %womoy,ppblicatimn of gowal circulation in the County at fk04MO; 06* n of Pennsyhr , and the Gettysburg Titres, a daily ne?apaperp i ed,i0 e:County.,e# Adams, Comm o(.,P*n aeyl r and having gene ciro"ion in said County for she emits .of The twits from said dr. Jawnai and Q q'TI l , horsto; aftcNeand made part of this rn. ( ) C 4) By me", to by -"H, return r r eO reque d, postage Wepaid, on the a trite and aftsl*#,copy thereof at The returned by the Postal KOPE & ASSOCIATES, LLC By: SHANE B. KOPE, ESQ. ATTORNEY ID 92207 4660 Trindle Road, Suite 201 Camp Hill, PA 17011 (717) 761-7573 sbkope@kopelaw.com LYNDA MARTIN AND WENNY WIJAYA, Plaintiffs, V. Attorney for Plaintiffs IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PA NO. 2008-5726 (Civil Term) ELIZABETH SHELLEHAMER, A MINOR, : JURY TRIAL DEMANDED Defendant. MOTION FOR SERVICE BY SPECIAL ORDER PURSUANT TO Pa.R.C.P. 430(a) AND NOW comes the above-named Plaintiffs, Lynda Martin and Wenny Wijaya, by and through their attorney, SHANE B. KOPE, ESQ., and makes the following Motion for Service by Special Order pursuant to Pa.R.C.P. 430(a): 1. On or about September 26, 2008, Plaintiffs, through counsel, filed the above captioned civil action. A copy of the complaint is attached as Exhibit "A". 2. Said civil action sought claims for replevin, unjust enrichment and breach of contract relating to three show dogs. 3. At the time this complaint was filed, Defendant was a minor with an address of 610 S. Ridge Road, York Springs, Adams County, Pennsylvania. 4. At the time this complaint was filed, Plaintiffs, through counsel, instructed the Cumberland County Sheriffs Department to deputize the Adams County Sheriff's Department for service upon the Defendant. The Adams County Sheriffs Department made four attempts to serve the defendant prior to the expiration of the Complaint but was unable to effectuate service. A copy of the Affidavit of Return of Service dated October 24, 2008 is attached as Exhibit "B". 5. Subsequently, the Plaintiffs, through counsel, instructed the Prothonotary's office to reinstate the Complaint. Again, the Cumberland County Sheriffs Department deputized the Adams County Sheriffs Department to effectuate service upon the Defendant. Adams County Sheriff made seven attempts to effectuate service but was unable to do so prior to the expiration of the reinstated Complaint. It is the Sheriff's contention that the Defendant may be avoiding service. A copy of the Affidavit of Return of Service dated December 17, 2008 is attached as Exhibit "C".T 6. The Sheriffs Department has attempted service at different times of the day, has noticed cars in the driveway and lights on in the home of the Defendant while these attempts have been made, but no one has answered the door. 7. As a result of the Defendant avoiding service, Plaintiff has incurred charges in reinstating the Complaint and requesting Cumberland County to deputize the Adams County and will continue to incur these charges for as long as Defendant continues to avoid service. Defendant is aware that the Complaint has been filed and is trying to delay the process. WHEREFORE, Plaintiffs respectfully request this Honorable Court to grant their Motion and allow Defendant to be served by publication. Respectfully Submitted, Dated: , 1 16 have B. Kope, N CC"9 ' Q 0 KOPE & ASSOCIATES, LLC od By: SHANE B. KOPE, ESQ. 1- ATTORNEY ID 92207 - n 4660 Trindle Road, Suite 201 `' •• ?' Camp Hill, PA 17041 (717) 761-7573 sbkope@kopelaw.com Attorney for Plaintiffs LYNDA MARTIN AND WENNY WIJAYA, IN THE COURT OF COMMON PLEAS Plaintiffs, CUMBERLAND COUNTY, PA v. NO. Cg.- 5?ovo (Civil Term) ELIZABETH SHELLEHAMER, A MINOR, : JURY TRIAL DEMANDED Defendant. N O T I C E TO DEFEND AND CLAIM RIGHTS 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 Com laint d p an Notice are served, by entering a written appearance personally or by attorney and filing in writing with the Court your defenses o b c io r o je t ns to the claims set forth against you. You are warned that if you fail to do so the case may proceed without you and d a ju gment may be entered against you by the Courtwithout further notice for an m ne y o y claimed in the Complaint or for any other claim or relief requested by the Plaintiff. Yo u may lose money or property or other rights important to`you. - YOU SHOULD TAKE THIS PAPER TO YOUR LAWYER A T 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 C AN GET LEGAL HELP. CUMBERLAND. COUNTY BAR ASSOCIATION 32 -SOUTH BEDFORD STREET CARLISLE, PA 17013 M R EC E ?" ` v? . C 4-# OP4 p5 ? ?`'? p? ? p InT -tiT •d3.da.L °a5" [ Thee unto set nT, . a r` &I Cofla . Pa. a and t $0 ( . ?J. KOPE & ASSOCIATES, LLC By: SHANE B. KOPE, ESQ. ATTORNEY ID 92207 4660 Trindle Road, Suite 201 Camp Hill, PA 17011 (717) 761-7573 sbkope@kopelaw.com Attorney for Plaintiffs LYNDA MARTIN AND WENNY WIJAYA, IN THE COURT OF COMMON PLEAS Plaintiffs, CUMBERLAND COUNTY, PA V. NO. (Civil Term) ELIZABETH SHELLEHAMER, A MINOR, : JURY TRIAL DEMANDED Defendant. COMPLAINT AND NOW comes Plaintiffs, Lynda Martin and Wenny Wijaya, by and through their attorneys, Shane B. Kope, Esq., and Kope and Associates, LLC, and files this Complaint;, and in support thereof, they aver the following: 1. Plaintiff Lynda Martin is an adult individual residing at 1422 Holly Pike, Carlisle Cumberland County, Pennsylvania. 2. Plaintiff Wenny Wijaya is an adult individual residing at 1422 Holly Pike, Carlisle Cumberland County, Pennsylvania. 3.. Defendant Elizabeth Shellehamer is a minor individual residing at 610 South Ridge Road, York Springs, Adams County, Pennsylvania. COUNTI REPLEVIN 4. The averments set forth in the preceding paragraphs are incorporated herein by reference as if fully set forth herein. 5. In September, 2007, pursuant to the Plaintiffs' request, the Defendant began handling the Brittany, JR, during handling classes at Obedience Training Classes of Harrisburg ("OTCH" ). 6. In September, 2007, pursuant to the Defendant's request, via Defendant's mother, the Defendant agreed to handle JR in certain dog shows. 7. Pursuant to the Defendant's request, a "Handling Contract" was entered into by all parties on September 18, 2007, wherein each party's responsibilities were described in. regards to showing and campaigning JR. Attached hereto as Exhibit "A" is a true and correct copy of said Contract. 8. After winning several shows with the Brittany, the Defendant requested that the Plaintiffs place her on JR's American -Kennel Club ("AKC°) registration so that the Defendant could use the Brittany in Junior Handling Competitions.' 9. The Plaintiffs. agreed to the request and on March 7, 2008, the Plaintiffs placed the Defendant on the Brittany's AKC registration. 10. The Defendant was never included on the Brittany's other registrations such as the United Kennel Club ("UKC") registration, State registration or. microchip registration. 1 According to the AKC rules, a dog used in junior handling competitions must be registered or co-registered by the handler or owned by a family member of the handler. Page 2 of 10 f i 11. The Defendant never contributed to any of the expenses of maintaining JR as a show quality dog, including vet care, food, supplements, advertising, promoting or show entries. 12. For reasons unknown to Plaintiffs, the relationship between the Plaintiffs and the Defendant soured and the Defendant cut off all communication with the Plaintiffs in or around April, 2008. 13. On May 8, June 17 and June 19, 2008, the Plaintiffs, through counsel, demanded, inter alia, the Defendant to sign whatever documents were necessary for the removal of Defendant's name from JR's AKC registration. Attached hereto as Exhibit "`B" are true and correct copies of said Demand Letters. 14. On July 8, 2008; the Defendant, through counsel, rejected this demand: Attached hereto as Exhibit "C" is a true and correct copy of said Rejection Letter. 15. Although AKC registration is not an ownership document, but a system for, inter a/ia, tracking the breeding, showing, field training, and other activities of the dog, every person included on the registration must sign off on the registration before the dog can bred. As such, Defendant's refusal to sign off on JR effectively prevents the Plaintiffs from breeding JR for profit or for selling to dog to be used for the same. 16. The Defendant's refusal to. sign off on JR, therefore, is interfering with the Plaintiffs' ownership of the dog in that the Plaintiffs are unable to continue in their efforts to increase the value of JR for breeding or selling. WHEREFORE, the Plaintiffs demand that the Defendant sign off on JR's registration along with such other relief as the Court deems appropriate, , Page 3 of 10 COUNT II UNJUST ENRICHMENT 17. The averments set forth in the preceding paragraphs are incorporated herein by reference as if fully set forth herein. 18. On November, 2, 2007, pursuant to the Defendant's request, the Plaintiffs agreed to keep the Defendant's Brittany, Annabelle, at the Plaintiffs kennel due to the Defendant's position that the Plaintiffs' kennel was in better condition than that of Defendant's parents: Annabelle stayed at the kennel until March 30, 2008. Attached' hereto as Exhibit "D" is a true and correct copy of the Pennsylvania Record of Boarding Kennel, which demonstrates the boarding dates of said dog as required by state law. 19. On November, 17, 2007, pursuant to the Defendant's request, the Plaintiffs agreed to keep the Defendant's Beagle, Keepsake, at the Plaintiffs kennel due; to the Defendant's position that the Plaintiffs' kennel was in better condition than that of Defendant's parents. Keepsake stayed at the kennel until March 25, 2008. Attached hereto as Exhibit "D" is a true and correct copy of the Pennsylvania Record of Boarding Kennel, which demonstrates the boarding dates of said dog as required by state law. 20. On February, 17, 2008, pursuant to the Defendant's request, the Plaintiffs agreed to keep the Defendant's Beagle, Buddy, at the Plaintiffs kennel due to the Defendant's position that the Plaintiffs' kennel was in better condition than that of Defendants' E parents. Buddy stayed at the kennel until March 4, 2008. Attached.hereto as Exhibit "D"` is a true and correct copy of the. Pennsylvania Record of Boarding Kennel, which demonstrates the boarding dates of said dog as required by state law. Page 4 of 10 21. The total amount of the fees for boarding the Defendant's dogs is $5, 049.00, which is calculated at `a rate of $17.00 per day for each dog. Attached hereto as Exhibit "E" is a true and correct copy of the invoice for Boarding said dogs. 22. The Plaintiffs have not been compensated for boarding Defendant's three dogs. 23. The Defendant benefited from the care and better living conditions her dogs received while residing in the Plaintiffs' kennel. 24. From January, 2008, until March, 2008, the Plaintiffs paid $150.00 for the Defendant to be tutored in Algebra due to the Defendant's low grades in said subject. Attached hereto as Exhibit "F" is a true and correct copy of the invoice for said tutor. 25. The Plaintiffs have not been compensated for providing a math tutor for the Defendant. 26. The Defendant benefited from the math tutor, provided by the Plaintiffs. 27. Under the circumstances as set forth herein; it would be inequitable for the Defendant not to compensate the Plaintiffs for boarding her three dogs and for providing her a tutor in algebra WHEREFORE, the Plaintiffs seeks judgment against the Defendant in the amount of $5,199.00 with the continually accruing interest charge at the statutory rate of 6.00% per annum along with such other relief as the Court deems appropriate. COUNT III BREACH OF CONTRACT S 28. The averments set forth in the preceding paragraphs are incorporated herein by reference as if fully set forth herein. Page 5 of 10 29. In or around November, 2007, the Plaintiffs were.discussing purchasing another class of dog to show and breed.. 30. In or around January, 2008, the Defendant suggested that the Plaintiffs purchase a Beagle; in addition, the Defendant requested that she be registered as 113 owner of said Beagle so that she may enter and present the Beagle in various dog show. 34. In January, 2008, the Plaintiffs and Defendant entered into a written agreement ("Agreement") titled "Co-Ownership of Dog" whereby the Plaintiffs would (1) purchase the Beagle; (2) cover all expenses surrounding the: care of the Beagle; (3) cover all entry and handling fees of the Beagle; and (4) register Defendant as 1/3 owner of said Beagle. In return, the Defendant would be responsible for training, conditioning, grooming and showing of the Beagle. Attached hereto as Exhibit "G is a true and correct copy of said Agreement. 32. Other terms of the agreement provided that: All parties would agree to the means by which the Beagle is nurtured, including living arrangements and food. All parties would agree; to the conditions concerning the breeding of the Beagle, including when and to whom. All parties would agree to the time and place of the. Beagles campaigning for future shows. All parties would agree before selling the Beagle. Y 5 All parties must agree to use "Hammer Beagles" of breed line for future beagles which are sired by said dog. That buyout of the Beagle would be permitted to all parties at reasonable costs. Attached hereto as Exhibit "G" is a true and correct copy of said Agreement. 33. There was no integration clause contained in the agreement. Attached hereto as Exhibit "H" is a true and correct copy of said Agreement. a Page 6 of 10 s 34. In or, around January, 2008; the Plaintiffs purchased.the Beagle, Dillon; from Leah Bertagnolli at a price of $640.00, which covered purchase price of the Beagle along with the crate costs; the Plaintiffs also expended an additional amount of $229.00 in air fare, $60.00 gas, and tolls in an amount yet to be determined, which covered shipping costs and expenses surrounding the retrieval of Dillon at Dulles Airport in Washington, D.C. Attached hereto as Exhibit "H" is. a true and correct copy of documents representing said costs and expenses. 35. The Plaintiffs also expended an additional $39.00 to cover the registration of Dillon. Attached hereto as Exhibit "I" is a true and correct copy of the document representing said cost. 36. The Plaintiffs also expended additional amounts of $27.50 for Dillon's vet fees and $146.25 for Dillon's show entry and licensing fees 37 The Defendant has retained sole possession of Dillon since his purchase. 38. Following and pursuant to the Agreement, in or around February, 2008, the Plaintiffs paid for the Defendant to attenda handling seminar at a cost of $175..00. 39. In addition to her requirements under the Agreement, the Defendant agreed to work in Plaintiffs' kennel in order to pay for her 113 ownership. The Defendant never fulfilled this obligation.> 40. In April,.2008, the Defendant had entered Dillon in two dog shows pursuant to the agreement. 41. Plaintiff Martin had acted as agent for the Defendant in these shows,' as required by AKC rules and regulations. Page 7 of 10 E? i .42. Eventually, and for reasons that are not entirely clear, the relationship between the parties began to sour. 43. In April, 2008, the Defendant cut off all communication with the Plaintiffs regarding Dillon or otherwise. 44. In addition, the Defendant has refused to allow Plaintiffs access to Dillon. 45. The Plaintiffs tried to reach the Defendant through various calls and e-mails, but to no avail. 46. Thereafter, the Plaintiffs' discovered that. the Defendant entered Dillon in a dog show under a new agent by the name of Cindy Stable.2 47. In or around, May, 2008, the Defendant's father had contacted the Plaintiffs and offered to purchase Dillon, to which the Plaintiffs refused. 48. Thereafter, the Defendant, again, cut off all communication with the Plaintiffs regarding Dillon or otherwise. 49. Plaintiff Martin tried several times to reach the Defendant through various calls and e-mails. 50. Although no calls were returned, the Defendant, through her mother, did return two a-mails in which she promised that the Defendant and the Defendant's parents would meet with the Plaintiffs to discuss circumstances surrounding Dillon. Attached hereto as Exhibit "J" are true and correct copies: of said e-mails. r 51. Despite these promises, the Defendant never met with the Plaintiffs. The show was the Red Rose Classic, which was held in Lebanon, PA, on Sunday May 1`1; 2008. Page 8 of 10 Rick and Theresa Shelleharner 6 10 South Ridge Road York Springs, PA 17372-8728 Re: Dillon Dear Mr. and Mrs. Shellehamer. Please be advised that I represent' the interests of Lynda L. Martin regarding the beagle with. the c afl name of Dillon_ You are currently in possession of the dog Dillon and Ms. Martin hereby demands the immediate return of herproperty Additionally, it is demanded that you direct and make available your daughter, Elizabeth, to sign documents as may be necessary for the removal of her name from the American Kennel Club registration for `Dillon as well as the Brittany known as Jr. lids. Martin is the-owner of Dillon, and Elizabeth's name was added to the AKC registration in order for her to shFow the dog' as a Junior Handler. AKC registration is not an ownership document, but a system for trackr`ng the breeding, shoaling, field trialing ` and_ other activities _ of the dog and -the individuals who are permitted to eater the dog or are responsible for the welfare ofthe dog: The return of the dog Dillon, any other property belonging.`to Ms. Martin, and the making available of Elizabeth to sign. the appropriate documents shall be no later than May 15, 2008, at the kennel of Ms. Martin, 1422 Holly Pike, Carlisle, PA 17015: ShouId.you not comply with this-demand for the return of her property Ms. Martin is prepared to seek appropriate relief from the courts. Very truly yours, VVilliam L. Grubb, Esquire cc: L. Martin z ? June 17, 2008 James W. Kollas, Esquire KOLLAS and KENNEDY 1104 Fernwood Avenue Camp Hill, PA 17011 1 Re: Martin v. Shellenaraer 100A Dear Attorney Kollas: Ms. Martin has made a determination as to the value of the dog Dillon based on the purchase price, shipping costs and other expenses associated with obtaining the dog; as well as the increase in. value and as a breeding dog which would reasonable expect to command a $500.00 stud fee. Ms: Martin is willing to transfer her ownership, and that of Wenny, for a total of $4,000.00, each of them being paid $23000.00. This is the equivalent to four (4) stud fees each, and is not an unreasonable figure. In addition there is the matter of an outstanding billing from April 21, 2008 to the Shellehammer's in the sum of $146.25 for dog show entry fees and dog license. Ms. Martin is also demanding the return other items which belong to her and are in the possession of the Shellehammers, which include a crate, two (2) brown. show leads, a container of chalk and a bottle of Laser Lites. Ms. Martin denies the allegations and insinuations of improper conduct in your letter of June 16, 2008. Ms. Martin was not at the show: Ms. Hartman was .talking to Elizabeth, but it concerned the matter of another dog. Ms. Martin is the owner -of a male Brittany known, as "Juniora dog which Elizabeth used when ` she showed as. a Junior Handler. By AKC rules; the Junior Handler must be on the dogs registration. The LAW OFFICES OF KOLLAS AND KENNEDY 1104 FERNwOOD AVENUE CAMP HILL, PENNSYLVANIA 17011 ?t J1 WILLIAM C. KOLLAS JAMES W. KOLLAS OF COt1NSEL MARY KOLLAS KENNEDY July 8, 2008 TELEPHONE NO. (7.17) 731-1600 FAX NO. (717) 731-1460 Mr. William Lewis Grubb, Esquire 3,803 Gettysburg Road Camp Hill, PA 17011 RE: Shellehamer/Martin Deer Attorney Gr abb: Tam in receipt of your letters dated June 17 and June. l 9, 20pg• After,rev' sewing the matters therein with my client, we are prepared to make the following response. All issues that remain open between the parties will be resolved at one tim time. Your suggestion that Miss. Shellehamer's name be removed from the registration for " Junior" before resolution of the Other issues is therefore rejected. Likewise, your submission of $4,000.00 for purchase of Dillon is rejected being unreasonable. I enclose for your reference three letters from beagle ' breeders; namely, Windkist Beagles, Moyer's:Beagles,. and Barons Hounds. All three letters refute your client's claimrd price. Most telling is the letter from Leah Bertagnoili of W' Beagles, from whom Dillon was obtained. lndkist We submit that a reasonable price for Dillon is $680, payable .to our clie However, a complete accounting is needed to resolve all `outstandin `iss nt. we submit the following statement: g s. To that end To Martin for Purchase of Dillon To Martin for George Alston Clinic $ 680.00 To Martin for licenses, etc: $ 175.00 I U l"AL for Martin - 146.25 $1,001.25 To Shellehainers for work in Kennel - $1;428.00 To Shellehamers for carpentry work done at Martin home and Martin kennel To Shellehamers for grooming services $ 572.95 To Shellehamers for clog food and for $ 6Q•OU Harrisburg Puppy Match & Handling Class $ 1 L$ 83 Amount owed to SheIlehamers - $1,188.53 As you can see, Ms_ Martin Owes the ShelIehamers an_amourt of $I. 188.53. - -EXHIBIT " ' l Lung's miss 2) Tropicana Aiuiabe!!a) rabies certificate; Annabelle's shot record; 3) Two (2) pick es of Best of Breed at Harrisburg for the Male Special (Junior); Brittany 4) Two (2) pictures at Harrisburg of Dillon for Best of Placement; Breed:and Group 3 5) Two (2) pictures of Best of Breed at Ti_rnc?ni:?n. for ?' f o Special; ?.?e It1aL Brittany 6) Various articles of Miss Shellehamer's clothing; 7) One (1) Pair of boots; 8) Dog bed Miss Shellehamer bought for Dillon; 9) Four (4) pictures of various wins of miss Shellehamer and (frames are owned by Ms. Martin). Annabelle Once the aforesaid amount is paid and the items returned the AKC documents for "Junior." paid ndcourse ed, Miss Shellmer will required to execute similar Al{C documents for DillonMThis s n and Ms` Wijaya will be at either your office or mine. can all be done at one time, Thank you for your attention to this matter. Very truly yours, KOLLAS AND KENNEDY James W. Kollas JWK/car Enclosures cc. Shellehamer June 25, 200$ 30069 SCOTTLAND ROAD LAUREL., DE 19956 To Whom It May Concern: My name is Kent VanBuren and I own Baron's Hounds, along with my. son. We have been showing and breeding`AKC beagles in conformation since 1985 and just recently began showing in UKC. We recently purchased a finished Champion Beagle named Tesoros Man After Midnight from Texas. This beagle is an AKC and a UKC Champion. 1#t the time of purchase was the #3 13" Beagle in the United States. Our purchase price for this beagle was $1,500.00. it is our opinion that a one, year old puppy that is unfinished and may not even be able to be bred is definitely not worth $4,000.00. At one year of age and still growing, it is possible he may go over 15" and can never be shown. In addition, most champions-are not, outside of the owner's bitches and certainly, ndifferent times unless you, are in the business of running a puppy mill. if this oneyear old, unfinished puppy- is worth $4,000.00, than my. dual champion must be worth at least.$15,000.00; however, I can only dream: We don't know what occurs with other breeds, but this beagle should be sold at a reaso?able price which I would put at S800._00- If you have any questions, please be in touch with me. Sincerely, Kent Van Byren 17 • To Whom It May Concern: Regarding:the beagle Dillon AKC HP262564/03 and his ownership: in Jan 23071 was contacted by Elizabeth Shellehamer in regards to a young beagle 1 (had for sale on my websitd. At that-time another party who Elizabeth was working for as a junior assistant offered to pay for this dog for her. The dog was transferred to Elizabeth on January 22nd-.2007. At that time it was my desire and understanding that "Dillon". would live with Elizabeth exclusively. and be HER dog to show in the breed and as a junior handler. At NO time was .1 under the impression that Lynda Martin would claim any ownership to. Dillon other than to lend support to Elizabeth and help herewith choices on where she might show him. It is my sincere desire that Dillon is to remain with Elizabeth and that 'her parents are allowed to.purchase him outright.for $640.00 which is what Lynda paid for him.. His worth is only as a companion at this point and he has NO worth whatsoever as a stud dog at this time. His worth as a stud dog at a later time would probably be very limited and l cannot see that he will be in demand for that use. As a reference. The going price for a beagle puppy is 800.00 The price for an oiderdog is usually, the same, and i priced Dillion so, that Elizabeth could afford fiirrl. Stud fee's far unproven dogs who are not champions would be 250.00. -Proven stud dogs:who have produced Champions and who are also Champions themselves are 500-600 It is ridiculous to think that Dillon is worth 4000.00 to anyone at this point. Young Champions do not even sell for such a high price. .CilnnPrP1v To whom it may concern: My name is Bill Moyer and my family and I have been Beagle Breeders for 12 years. Our involvement with the beagle breed has allowed us to become very knowledgeable of the breed. This resulted in my becoming an AKC Field Trial Judge, a PBGA (Pennsylvania Beagle Gundog Association) Show Judge and an armature confirmation handler. Being a 'breeder we have accomplished breeding several field and confirmation Champions. . Understanding and practicing the AKC breed standards has given us the knowledge to know what to look for in a beagle of quality. In my opinion, a one year old male beagle which has not fully matured, has not attained a championship, has not been proven (proven meaning = siring quality puppies without genetic flaws) and in fact has not attained an age that would exclude genetic flaws cannot be assessed a value equal to that of an accomplished dog. A beagle dog; as described above; can only be valued as pet quality and no more than the original $6:00 it was purchased for. The price of $4,000 that was placed on this beagle is outrageous and would never be paid. Theonly time. this beagle would be worth $4000 is after the above milestones :have been met and not before. Should you or anyone hate any further questions please contact us at the above address or phone number. Sincerely, Bill and Sandy Moyer • r F? R 3: Z En . ? ? O 'Rip A I - o m z ° ^ A ? cs a m ? m N a ? rn m ? p Cl) C . ` [) l o i o OF 2 Q -v . iTi ` --I !. m p ly1?F r IS, r- C7 -I T o- Of ? o DKO i S §4 r m? D m ? r CO m A Z Q :urns m .. m ` to O r? . ? Q tA Z --i o .? ? J - rn r- zm C I rn z O m r to m Ri in VAi Z? cl) p = ? n g Q ° z ` Boarding Fees for E. Shellehamer Anna Starting November 2, 2007 29 days December 31-days January 2008 31 days Febnary 2008 Ending March 30 2008 29 days , 30 days TOTAL 150 days X$17.00 TOTAL DUE, $2,550.00 Kee Starting November 17, 2007 D 14 days ecember . January-2008 31 days February 2008 31 days Ending March 16, 2008 29 days 16 days TOTAL 12, 1days X $17.00 TOTAL DUE --------- $2,057.00 Bum Starting February 17, 2008 E Ending March 4, 2008 13 days 4 days TOTAL 17 days -X $17.00 TOTAL DUE $289.00 f?CM1BIT --------------- Co-Ownership of Dog This contractual agreement made this da of and between Lynda L. Martin and W Y gz 2007 by enny WiJaya of 1422 HoII -Pike, Carlisle, Pennsylvania, and Elizabeth A Shellehamer of 610 South Ridge Road, York Springs, Pennsylvania: This agreement is for the purpose of owning, canng, howin and ex for one male Beagle presently known as "Dillon g pence All parties hereinafter set forth agree as follows: All parties must agree to how Dillon is cared for; such as living. arrangements and food. All parties must agree to when and to whom Dillon Will: be bred to completes his championship. after he All parties` must agree to when and where Dillon will be cam ai future shows. - P geed for A11 parties must agree before selling of said dog. -T All Parties must agree to use "Hammer Beagles" of breed line f beagles which are sired by said dog. or future CMS. Martin and Ms Wijaya will be responsible for purchasin of said dog. g and shipping Ms Martin and Ms Wijaya will be responsible for any medical food, vitamins and supplements of said dog. expenses, EXHOIT a,; January 21, 2008 J? U ?:03Z 3 i 2 7381: - --. ? ..?. z? 50044373, N. 0 7 5 5 •?i ? .,?? ? ODODI? ? 4CI17[??' ,J ?rrt w 0 94 - DaJ O000d0 FRE-PHI Lei n coo 20080516320001490000.02 Ila2M 0,2 20080128 000000000087352300 000000000000064000 000000000755 D 000000005004437368 kRISTIN ADAM 4 PNCBANK ? N. PNC Bank Platinum Business Rewards MasterCardt& February Statement for activity from .fan. 09, 2008 through Feb. 07, 2008 inquiries: 1-866.395$773 CHARLYN KENNELS (CPN 000556991) BUS 2805 Page ;1 of 2 V`at?tNll? Ban4?'iatitt irt Bustntsiv?atd& MstCa>'att?ocot?nt Ott > gi -nee ail - ?4ocot?ttt 4?2 41.1Y11*407 Activity Surnmary Credit and Payment information Previous Balance . ............................. $70.09 Credit Line............__..._...._....................... $15,500.00 Payments and Credits....... ......... $141.07 Available Credit .......................... ...... $13,366.38 Purchases, Advances & Other Debits $2,204.60 Minimum Payment Due Current Month)... $22,00 FINANCE CHARGES . $0.00 Minimum Payment Due (Past Due) . $0.00 New Balance..„....„.„..... ......... $2,133.62 Total New Minimum Payment Que.......... $22.00 Payment Due Date..... ....... Mar. 03, 2008 To reduce or avoid paying addidionaf finance charges on om purchase balance, pay the loW new balance of $2133.62 by 03CMa Any cash balance or balance bansfer balance 071 continue to accrue dar7y fr WestunN the date your. payment is reosived. 6 rft$1s5Q ??. m . . _:.,.. .N .. .. _...__ Post Ttans Ref. Date Date Arbr Description of Thm"eflon Amount 01]09. 01/08 7811 DRI`Symantecslore.com 800.441=7234 MN.... .................. $70.98. CR MERCHANDISEISERVICE.RETURN 01114 01112 8585 VALUE CITY FUR00000927 MECHANICSBURG PA . $423.99 01/14 01112 0205 EIGHT & EIGHT SUPERMAR HARRISBURG PA............... $74.44 01114 01113 4442. SHEETZ. 00002329 MT HOLLY SPRG PA ....................... $55:01 - 01/16 01115 0681 MB F DOG SHOWS WFODOG 336-3799352 NC $81.50 01/22 01/21 0490 SHEETZ 00002003 MT HOLLY SPRG PA $44.66 01122 01/19 9330 PAYLESSSHOESOU00039214 CAMP HILL- PA $M8.04 01122 01/18 3721 WM SUPERCENTER CARLISLE PA... 01124 01/22 0018 KENT R. RENTSCHLER LLC CARLISLE PA ................ $70.00 01724 01/23 8160 WAL-MART #2574 CARLISLE PA................-.....:....... $273.68 011224 01123 3803 1-800-PETMEDS 8007386337 FL........ $164.20 01128 01125 0437 WAL-MART #1886 MECHANiCSBUR PA .......... $77.87 01128 ' 91125 ` 0053 KIMEB,& CO STUDIO FOR CARLISLE PA:. M..-- ......... $121.00 01128 0138 REV PROV CRDT DRCSYMANTECSTORE.COM.......... ...... $70.98 DERM ADJUSTMENT 01129 01128 7738 PETSMART .00015214 CARLISLE PA.... _. $1;5.31 02/01 01131 3573 SHEETZ 00002329 MT HOLLY SPRGPA.. ....._?.._..:. $47.50 02/01 0,1131 1064 TRACTOR=SUPPLY-001026 CARLISLE PA $239.oo 02104 02101 6419 AMERICAN KENNEL -CLU 9192339767 NY $39.00 02/06 02105 2174 DELTA 00600006898975WASHINGTON DC... .. $229.44 jv?bf // Total for account 5472 6500 0132 3187 „..„..„...„. $2,133.62 U 11?U r7 Shipper's Name and Address Shipper's Account Number - Not Negotiable Air Waybill I Issued by :Copies 1, 2 and 3 of this Air: Waybill are originals and have the same validity. Consignee's Name and Address Corisignees'Account Number it is agreed that `the-goods described herein are accepted in apparent good order and condition (except as noted)' for carriage SUBJECT TO THE CONDITIONS OF CONTRACT ON THE REVERSE HEREOF. ALL GOODS MAY BE CARRIED BY ANY OTHER MEANS INCLUDING ROAD OR ANY OTHER CARRIER UNLESS SPECIFIC CONTRARY INSTRUCTIONS ARE GIVEN HEREON BY THEESHIPPER, AND SHIPPER AGREES THAT THE SHIPMENT MAY BE CARRIED VIA INTERMEDIATE' STOPPING PLACES WHICH THE CARRIER DEEMS APPROPRIATE, THE SHIPPER'S ATTENTION IS DRAWN TO THE NOTICE CONCERNING CARRIER'S LIMITATION OF ' t UABILl7Y..Shipper may increase such limitation of Iiabli " and PaN'n9 a supplemental charge required. H by declaring a higher value for carriage .. it Issuing Carrier's Agent Name and City Accounting Information Agent's IATA Code Account No Airport of Departure -(Addr. of First Carrier) 'and Requesting Routing' Reference Number O tonal h Information To By First Carrier +w 2--k-w- to by to by Currency aca Gth r , Declared Value for Carriage 'Declared Value for Customs 1'?F rrD Cat pro Cou ci, Airport of Destinatam R Flt Amount of Insurance INSURANCE If carrier offers insurance and such insurance is v .f? ) ? ? ? - •d, f?? acowdence'a'Nt the condrtrons hereoi, indicate amount .. to'be insured in'figures in box marked 'Amount of Insurance'. Handling tpfpmrdbon }p t. j. 7hii* commodities, technology or software Were eiported from the United States r t? Brie„ bn to SCI ih accordance. with the Export Acirwastration 'Regulations, Ultimate desanauo r n a No. of Gross Rate Class Cha a Rate - $CPS Weighb - ib odrty Weight / Total r Natura and Quantity of Goods Item N . Charge (aict Dimensions or Volume) % tt?- i' , w,' - y0. :..{j '.? 'r•. C'`I¢T f."`t_'r? 71. _ try r ;j i Rrep9id We ht,Charge' Collect '. Other Charges VaINft Charge { .. r . , - Total Other Charges Due Agent Shipper certifies that the particulars on the face hereof are correct and that insofar as an contains dangerous goods, such part Is property described by name and is in proper condition for carriage by air according to the applicable Dangerous Goods Fajgtattors. Total Other Cha s Due Carrier i -------------- -- --- - >. -------------- .. Signature„ of Stopper or his Agent Total Prepaid Tolai Collect s I ) .. i 0,'PNCBA? PNC Bank Platinum Business Rewards MasterCard@ February Statement for activity from Jan. 09, 2008 through Feb. 07, 2008 Inquiries: 1-866-395-8773 CHARLYN KENNELS (CPN 000556991) sus taus Page 1 of 2 77 Y'oar Ba?ft P #1ticlia i8u 7 es t3wttrde MaB srCard? accourl ?t a gjalioe ;, z . __:. •-.. ;:. _::.- .:: ,"`.::.: -: _...:.- . ; = ._' ? _?CC+?tttlt?,is7?5a0Db??8/i027? Activity Summary Credit and Payment information Previous Balance .............. .................. $70.09 Credit Una. edtt $15,500.00 Payments and Credits ......................... $141.07 Available Gr ................ .... .... ......... ........ $13,388.38 PurdTases, Advances & Other Debits $2,204.60 Minimum Payment Due jCurrent Month)... $22.00 FINANCE CHARGES $0.00 Minimum Payyment Dua ((Past Due) ............ $0.00 Neat/ Balance......... ..... . $2,133.62 Total New MlNmum Payment Due.......... $22,00 Payment Due Date :....., aAar. 03, 2.08 To reduce or avoid Paying ad0ona/ finance dyarges on your purchase balance, Pay the total new balance 0/$2,133.62 by oy o3/oa Any cash balance or balance transfer balance wX corWnue to.aaave. da& interest undl the date your payment is received t1$ISSGIL7118xtAFTii1t,i1iL?A- y- ... F bmdf _ Pcsr Trans fTBf. .._.:_ -... _.. Date Date Or Deschprfon of Transwi1cm Amount 01109 01/08 7811 DRI'Symantecstore:com 800-441.7234 MN ........................ $70.98 CR MERCHANDISE/SERVICE:RETURN 01/14 01/12 8585 VALUE CITY FUR00000927 MECHANICSBURG PA .......... $423:99 01114 01/12 0205 EIGHT& 004TSUPERMAR HARRISBURG PA.___... $74.44 01114 01/13 4442 Sf iEETZ 00002329 MT HOLLY SPRG PA $55.01 01/16 01115 0661 MB F DOG SHOWS iNFDDOG 336-37'99352 NC...-? 01/22 01/21 0490 SHEETZ 06002003 MT HOLLY SPRG PA $ 4.66 0 /22 01119 9330 PAYLESSSHOESOU00039214 CAMP HILL PA ... $3&98 01/22 01/18 3721 WM SUPERCENTER CARLISLE PA.......... ._.._ $88.0401/24 01122 0018 KENT R. RENTSCHLER LLC CARLISLE PA__'--_"-- ....... $70.00 01/24 01123 8160 WAL-IfMART#2574 CARLISLE PA ..............,.:_. _ ._.. $273.68 01/24 01./23 3603 1-800-PETMEDS 8007386337 FL.. ...................... .... $16420 01/28 01125 0437 WAL-MART#1886 MECHANICSBUR PA ................... $77.87 01/28 01125 0053 KIMEB & GO STUDIO FOR CARLISLE PA._........ _.. $121.00 01/28 0138 REV PROV CRDT DR!'SYA4ANTECSTORE.COM ................ $70.98 DEBIT.ADJUSTMENT I. 01129 01/28 7738 PETS IRT 00015214 CARLISLE PA ..... $65 31 02/01 01/31 3573 SHEETZ 00002329 MT HOLLY SPRG PA .. $47.50 021.01 01/31 1064 TRACTOR-SUPPLY-CO #026 CARLISLE PA .....? :_?....... $239.00 j 02/04 02/01 6419 AMERICAN KENNEL:CLU 9182339767 NY ............... ... $39.00 02106 02/05 2174 DELTA 00600000898975WASHINGTON DC _ ................. $229:44 ? A 5 Total for acccun1 5472 6500 0132 3187, ............:.. $2,13342 _.H?? `AMERICAN Dog RegistrationApptication * I?:GN vrNEL (iU?B` use this form to register your purebred dog with the AKC.® Important information CL and instructions. are on pag+ this form. Information you omit will delay processing. AKC reserves the right to correct or cancel for Ci the registration of this dog and its descendants.' Registration is not guaranteed. Processing fee are nonrefundable, and all fees are subject to change without notice. Once submitted, this application becomes the property of the:AKC. UTTER OWNER COMPLETESSLLIE SECTIONS. NEW OWNER COMPLETE=S RED SECTIONS. Litter Information Number: HP2625640 Breed BEAGLE Date of Birth JUNE 27, 2007 Sire CH WINDKIST A WALK IN THE PARK Dam CH WINDKIST AFTERNOON DELIGHT HM98535001 (01-03) AKC DNA #V252261 HP01354201 (08-04) Breeder LEAH BERTAGNOLLI Litter Owner LEAH BERTAGNOLLI@g f 4983 W 2150 N, OGDEN, UT 844049799-83 Farr Payment Information Note: items maybe mailed separately. 4P. STEP 1) Choose one of the following two optional registration packages STEP 2) Add the Lost B. Found Option Gold Package: $27 (Save $15.901) r-1 Silver Package: $17 (Save $3.001) Lost & Found Option: $12 • Three-Generation AKC-CerttTied Pedigree - • Three-Generaton AKC-Certifed Pedigree . Lifetime enrollment in recovery service 1-year AKC Family Dog magazine subscription • $30 in e-certificates from dog.com • AcoIlartag w th your dog's AKC registration number • Dog Care & Training Video (DVD) Formore k*rmahon, vislf www.ake.oWosttound : $40 in e-cwfl6cates from dog.com STEP 3) Total the amount due and provide payment information • Basic Registration. AKG Registration Certificate and $15 in e-certificates from dog.com. AKC Registration $ •F 20 • Enter an additional $27 for the Gold Package or $17 for the Silver Package if applicable Gold or Silver Package $ LJLJ Enter $12 for the Lost $ Found Option if applicable. 00. Lost & Found Option $ Calculate the transfer fee. See the Supplemental Tiansferlnsbudions Number of X $ Transfer Fee $ section on page 2 to determine the amount owed. transfers. L.J d.......,. Enter a late fee of $35 if you are submitting this form after JULY 6, 2008 or Late Fee $ $65 if you are submitting it after JULY 6, 2009. Total Fee $ Payment Method: 1 11 VISA tD AMEX 0 MasterCard Q Discover 0 Check or money order made payable to: American Kennel Club 1 Account Number pdo, not inciude dashes) ?pSlati?l€ mte s:Sr-atu-r Of Cardholder .. Print one capital letter per box Skip a box between words. Choose a unique name. Names are subject to AKC approval. Mal Female . °` a r € L ?) _ ? 1 f E t f Dog Name WZM?? Microchip -or-Tattoo Number, If Applicable Microchip ;l Tattoo ` Kennei ame C -er ek a gs+at c: Ickent55 yi?en Number To Request Limited Re_qistration Important Registration Information Litter Owner(s): Please completely darken the box below to request Return this form by mail or go online to register your dog today! Online Limited registration. registration is fast and easy! Limited if the box to the left Is completely darkened, the 1) Go to www_akc.om/doarea/ ' ` 998 dog is not lobe used for breeding. Entry in dog 2) Follow the step by step instructions events is restricted. 3) Your PIN for.this application ist' 56300 Enterthe 3-digitc6dethat most closely describesyour dog. 7!altemafives? code thatmost Closely describes your dog. Forattematives; see wWUV.akccolors.org see www-akccolors.org 018 Black & Tan 197 Tan & White Tucked 027 Black Red & White 291 Blu e Tan & White 029 Black Tan & Btuetid 030 Black Tan& WMe 034. Black White & Tan 063 Brown & white 068 Brown White s Tan 115 Lemon & White 146 Red & While ' Continued on page 2. t 111111! 111111 m1111119111111111111 wtr 111111 vm ¦¦lan 1111 r¦.r L I (we) still own this dog and apply for registration and to have We) transferred this dog directly to the owner(s) listed ownership recorded in my (our) name(s). ) the New Owner(s) section below. / (we) car* by my (our) signature(s) that ail the information appearing on this application is correct and that f (we) am (areJ in good standing with the American Kennel Club. F (WE) AGREE THATANY CAUSE OF ACTION, CONTROVERSY OR CLAIM ARISING OUT OF OR RELATED TO THIS REGISTRATION OR AS TO THE CONSTRUCTION, INTERPRETATION AND EFFECT OF THIS AGREEYENTSHALLBE SETTLED BY ARBITRATION PURSUANT TO THE APPLICABLE RULES OFTHE AMERICAN ARBITRATION ASSOCIATION. HOWEVER, PRIOR TO ARBITRATION ALL APPLICABLE AKC BYLAWS, RU , REGULATIONS AND PROCEDURES MUST FIRST BE FOLLOWED AS SET FORTH IN THE AKC CHARTER AND BYLAWS, RULES, REGULATIONS, Pi16USHED pOUC1ESAND UIDELWES. /f Date of Transfer: 1 1 € i €: I' x avrr?,fit` e1'?MS@?F ? a'aeazk t'¢:¢truat? rea?'?? .d as ..-. .?.?': !?,WV..... Mamling Address, stac& Zfp coda- 4 t_ "releptivtee *Mu nber Emaii Address pe-syt' Cri-n-la roe 's ._ z f Rams Marne 'ate "IF COIL F . f r 71 r Y ?New _ I k s t (we) applyto the American Kennel Club to-have a Registration Certificate for this dog issued immy (our) name(s). I (we) certify that/ (we) acquired this dog directly on the date stated above from the Utter:Owner(s) and if applicable,. that! (we) have complete written authority from the other owner(s) to submit this application to register this dog in ali our names. I (we) understand that-upon request I (we) W11 be required to provide do:the AKC any such written authorization. I (we) agree to abide by all rules and regulations of the Amencan:Kenne/ Club. l (we) understand that if the limited box on the Dog Registration Application has been darkened corn#ete/y by the Litter Owner(s), l (we) will receive a Limited Registration CertifiCate.I (WE) AGREETHATANY CAUSE OF ACTION, CONTROVERSY OR CLAIM ARISING OUT OF OR RELATED To THIS REGISTRATION OR AS TO THE CONSTRUCTION, INTERPRETATION AND EFFECT OFTHIS AGREEMENT SHALL BE SETTLED BY ARBITRATION PURSUANTTO THE APPLICABLE Rill ES OF THE AMERICAN ARBM: ATION ASSOC1Ai10N. HOWEVER, PRIOR TO ARBITRATION ALL APPLICABLE AKC BYLAWS, RULES, REGULATIONS AND PROCEDURES MUST FIRST SE FOLLOWED AS SET FORTH IN THE AKC CHARTER AND BYLAWS, RULES, REGULATIONS, PUBUSHED POUCIES AND GUiDEUNES: New w"nS+.eii Sr:.n... . F"s P9ivYt£' C?o -G°WG9U sS E6CxBtE1CL Instructions, Requirements, and General information Supplememai if you did not acquire this dog directly from the litter owner(s), you must include a Supplemental Transfer .Statement -With, fee for each intermediate transfer Transfer with this application. Multiply the number of. Supplemental Transfer Statements by the amount shown under Payment Information on page 1 of this )nstructions application and include this amount in the total payment Note: This form is available on our Web site: www.akc.org, Mailing Address Send this form and all appropriate fees to: The American Kennel Club, P.O. Box 37902, Raleigh, NC 27627-7902. Additional if there are more than twonew owners, contact the AKC for an Additional Signature Form. NOTE This form is available on:our Web site: www.akc.org. Requirements Authorizations Signatures of persons other than the owners will be accepted only if a,propedy completed authorization form has been filed with the AKC. NOTE: These forms are available on our Web site: www.akc.org. Assistance Email AKC at info@akc.org or calf 919-233-9767 to speak to an AKC Customer Service Representative, Monday - Friday, 8:30 AM - 5:00 PM. Information about the registration process and downloadabie:forms are available on our Web site: www.akc.org You must provide a valid email address to receive dog.oom's e-certificates and an e-certificate for an office visit with a:practic:e participating in the AKC VeterinaryNetwork. By supplying youremail address, you consent to receive complimentary e-certificates and communications from AKC and approved third parties. For more details on the AKC Veterinary Network and a list of participating pracfices,,go to www.akc.orglvetnet Comcast Webmail -Email Messy ge ht4)://nnailoenter2.comcastnedwrnely/wcnl482762BD0004778 > kept away from me and when I wanted to keep him on occasions oNy to be > told by Elizabeth that her mother told her to make sure she brought Dillon > with her. I have been told on a few occasions not to touch/handle him. > have gone along with everything even against my best instincts. It seems > have little or no say in this dog which legally is mine. Which now I must > conclude. that anything in regards to Dillon would never have been > discussed with me which includes future shows, breeding, etc. I'm also saddened that my relationship with Elizabeth went from working > together to non e)istence_ I don't know why as it was never told to me. > I have tried. to give her opportunities to sh w dogs because l befieved in > her. I have never taken advantage of Elizabeth, befriending her, treating > her like my n iece l have extended this `fr iendship to the rest of the F _ . 1 nave invited f Teresa o Join us and liza- eth to the she' s in K! L: nt.ca ea-C! he r ;-+i.?s.,.+, errs' Fir,. e.si ?.. +.,, _.!r 3?,:... .. .. e?.3av.1€e : :??f =erFa?tr.,. e ii 8.. ..i s1r?a€?: va ii cciaF. F F. V5.+e ?f ?LFE-rE VVi.F &W E4I EwrF ii ICU DEL ?CZi?J i?iE F LF Fri Lfc Si.{?+FE?f e ..?o.1v , G??.F T4.8 F F? - - thrE^a an t c6 fee hrl - we E?: 1r) S a _ .. _gMS _0 TT w 1 F En _e - SHERIFF'S RETURN - OUT OF COUNTY CASE NO: 2008-05726 P .COMMONWEALTH OF PENNSYLVANIA: COUNTY OF CUMBERLAND MARTIN LYNDA ET AL VS SHELLEHAMER ELIZABETH 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: SHELLEHAMER ELIZABETH MINOR but was unable to locate Her deputized the sheriff of ADAMS serve the within COMPLATNT F, TxTnTT07 County, Pennsylvania, to On October 30th , 2008 , this office was in receipt of the attached return from ADAMS Sheriff's Costs: Docketing 18.00 Out of County 9.00 Surcharge 10.00 Dep Adams County 84.20 Postage 4.14 125.34 10/30/2008 KOPE & ASSOCIATES Sworn and subscribe to before me this day of A. D. w t in his bailiwick. He therefore So answer R. Thomas Kline Sheriff of Cumberland County s; , In The Court of Common Pleas of Cumberland County, Pennsylvania Lynda Martin et al vs. Elizabeth Shellehaaer, a minor 08-5726 civil No. Now, October 14, 2008 , I, SHERIFF OF CUMBERLAND COUNTY, PA, do hereby deputize the Sheriff of teams 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, , 20 , at o'clock M. served the within upon at by handing to a and made known to Swom and subscribed before me this day of , 20 copy of the original the contents thereof. So answers, JD heriff .4 CAI- MNXit 000 a f- - [- ffof Adams County, A COSTS SERVICE $ MILEAGE AFFIDAVIT DATE RECEIVED DATE PROCESSED SHERIFF'S DEPARTMENT ADAMS COUNTY, PENNSYLVANIA COURTHOUSE, GETTYSBURG, PA 17325 INSTRUCTIONS: See "INSTRUCTIONS FOR SERVICE OF PROCESS BY SHERIFF SERVICE THE SHERIFF" on the reverse of the last (No. 5) copy of this form. Please PROCESS RECEIPT, and AFFIDAVIT OF RETURN type or print legibly, Insuring roadability of all copies. Do not detach any copies. ACSD ENY.# 1. PLAINTIFFS/ 2. COURT NUMBER LYNDA MARTIN and WENNY WIJAYA 08-5726 Civil Term 3. DEFENDANTS/ 4. TYPE OF WRIT OR COMPLAINT: ELIZABETH SHELL HAME a minor Complaint in CivilActiOD SERVE 5. NAME OF INDIVIDUAL, COMPANY. CORPORATION. ETC., TO SERVICE OR DESCRIPTION OF PROPERTY TO BE LEVIED, ATTACHED OR SOLD. Elizabetb Sbellebamer, a minor 1 6. ADDRESS (Street or RFD, Apartment No., City. Boro, Twp., State and ZIP CODE) AT 610 Soutb Ridge Road, York Springs, PA 7. INDICATE UNUSUAL SERVICE: ? PERSONAL ? PERSON IN CHARGE ? DEPUTIZE ? CERT. MAIL ? REGISTERED MAIL O POSTED ? OTHER Now, , 1, SHERIFF OF ADAMS COUNTY, PA., do hereby deputize the Sheriff of County to execute this Writ and make return therof according to law. This deputation being made at the request and risk of the plaintiff. SHERIFF OF ADAMS CouNTY & SPECIAL INSTRUCTIONS OR OTHER INFORMATION THAT WILL ASSIST IN EXPEDITING SERVICE. NOTE ONLY APPLICABLE ON WRIT OF EXECUTION: N.B. WAIVER OF WATCHMAN-Any deputy sheriff levying upon or attaching any property under within writ may leave same without a watchman, in custody of whomever is found in possession, after notifying person of levy or attachment, without liability on the part of such deputy or the sheriff to any plaintiff herein for any loss, destruction or removal of any such property before sheriffs sale thereof. 9. SIGNATURE of ATTORNEY or other ORIGINATOR requesting service on behalf of: 10. TELEPHONE NUMBER 11. DATE Sbane B. Ko r Esq. APLAINTIFF (717) 761-7573 ? DEFENDANT SPACE BELOW F R E F SHERIFF ONLY - DON T WRIT E WTI LINE 12. 1 acknowledge receipt of the writ SIGNATURE of Authorized ACSD Deputy or Clerk and Tide 13. Data Received 14. Expiration /]mate or complaint as indicated above. 10/15/2008 JOCKIM 24, 2008 15. 1 hereby CERTIFY and RETURN that 1 ? have personally served, ? have served person in charge, ? have legal evidence of service as shown in "Remarks" (on reverse) ? have posted the above described property with the writ or complaint described on the individual, company, corporation, etc., at the address shown above or on the individual, company, corporation, etc., at the address inserted below by handingfor Posting a TRUE and ATTESTED COPY therof. 16. it I hereby certify and return a NOT FOUND because I am unable to locate the individual, company, corporation, etc., named above. (See remarks below) 17. Name and tide of Individual served ter. A person of wit" ape and discretion Read Order then reaidYq in to dshedent's usual wake a above. ? ? 19. Address of where served (complete only If different than shown above) (Street or RFD, Apartment No., City, Boro, Twp., 2D. Date of Service 21. Time State and ZIP CODE) R>!iKAM: Unable to locate defendant for service prior to the expiration of the complaint. 22. ATTEMPTS Date Mbn Dep.htt. Dab Mlles Depant. Data MNes Dsp.kL Dab Muss Dep.Int. Dots MNes Dep.Htt. 0/2 30 JN 10/2 30 JN 0/2 30 KM 0/24 30 JN M. Advance Costs 24. l 25. 1 26. 27. Total Cotes 200=3181M REFUND 50.00 Fky.Atty- 84.20 Pd. 10/27/ 8 1$65.80 Ck. #19052 I AFFIRMED and subscribed to before me this day COMMISSION EXPIRES a I ACKNOWLEDGE RECEIPT OF THE SNOW" RETURN SIGNATURE OF AUTHORIZED ISSUING AUTHORITY AND TITLE. By #&WDW swim (Phase Print or Type) Date Jacob Nel-gon-- 1 C Sidnature JAMES WMLR 110/24/2008 SHERIFF OF ADAMS COUNTY 39. Date Received DonTUnNnTany SHERIFF'S RETURN - OUT OF COUNTY CASE NO: 2008-05726 P COMMONWEALTH OF PENNSYLVANIA: COUNTY OF CUMBERLAND MARTIN LYNDA ET AL VS SHELLEHAMER ELIZABETH 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: SHELLEHAMER ELIZABETH MINOR but was unable to locate Her in his bailiwick. He therefore deputized the sheriff of ADAMS County, Pennsylvania, to serve the within COMPLAINT & NOTICE On January 6th 2009 this office was in .receipt of the attached return from ADAMS Sheriff's Costs: So answers- Docketing 18.00 Out of County 9.00 Surcharge 10.00 R. omas Kline Dep Adams County 150.00 Sheriff of Cumberland County Postage 4.11 191.11 01/06/2009 KOPE & ASSOCIATES Sworn and subscribe to before me this day of A. D. ? ¦ In The Court of Common Pleas of Cumberland County, Pennsylvania Lynda Martin et al vs. Elizabeth Shellehamer, a minor No. 08-5726 civil Now, November 24, 2008 , I, SHERIFF OF CUMBERLAND COUNTY, PA, do hereby deputize the Sheriff of Adams 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, . within upon at by handing to a and made known to Sworn and subscribed before me this day of 20 20 , at o'clock M. served the copy of the original So answers, the contents thereof. Sheriff of COSTS SERVICE MILEAGE AFFIDAVIT County, PA A $ DATE RECEIVED SHERIFF'S DEPARTMENT ADAMS COUNTY, PENNSYLVANIA COURTHOUSE, GETTYSBURG, PA 17325 DATE PROCESSED IN8TrAICTIONS: See "INSTRUCTIONS FOR SERVICE OF PROCESS BY SHERIFF SERVICE THE SHERIFF" on the reverse of the lest (No. 5) copy of this form. Please PROCESS RECEIPT, and AFFIDAVIT OF RETURN "or print leggy. insuring reedstift of an -pies. Do not detach any copies. ACED ENV.t SERVE 10 AT vi ion 5. NAME OF INDIVIDUAL, COMPANY, CORPORATION, ETC., TO SERVICE OR DESCRIPTION OF PROPERTY TO BE LEVIED, ATTACHED OR SOLD. Elizabeth Sbellehamer, a minor 6. ADDRESS (Street or RFD, Apartment No., Co. Boro, Twp., State and ZIP CODE) 610 South Ridge Rd., York Springs, PA 7. INDICATE UNUSUAL SERVICE: 0 PERSONAL O PERSON IN CHARGE O DEPUTIZE 0 CERT MAIL O REGISTERED MAIL 0 POSTED O OTHER Now, , 1, SHERIFF OF ADAMS COUNTY, PA., do hereby deputize the Sheriff of County to execute this Writ and make return therof according to law. This deputation being made at the request and risk of the plaintiff. SHERIFF OF ADAMS COUNTY 8. SPECIAL INSTRUCTIONS OR OTHER INFORMATION THAT WILL ASSIST IN EXPEDITING SERVICE. NOTE ONLY APPLICABLE ON WRIT OF EXECUTION: N.B. WAIVER OF WATCHMAN-Any deputy sheriff levying upon or attaching any property under within writ may leave same without a watchman, in custody of whomever is found in possession, after notifying person of levy or attachment, without liability on the part of such deputy or the sheriff to any plaintiff heroin for any loss, destruction or removal of any such property before sheriffs sale thereof. 9. SIGNATURE of ATTORNEY or other ORIGINATOR requesting service on behalf of: 10. TELEPHONE NUMBER 11. DATE Shane B. Kope, Esq. o DEFENt)A (717) 761-7573 ..? Y Y T .. r v.. r *' ??rilr I? I- LFn 1 N no C RCL w 1 1'11 IIVC 12. 1 acknow ledge receipt of the writ SIGNATURE of Authorized ACSD Deputy or Clerk and Tile 13. to Received 14. Expiration data or complaint as Indicated abon. 11/25/2008 DEC. 19, 2008 15. 1 herby CERTFY and RETURN that 1 0 have personally served. 0 have served person in charge, O have lapel evidence of service as shown in "Remarks" (on reverse) 0 have posted the above described property with the writ or complaint described on the individual, company, corporation, etc., at the address shown above or on the individual, company, corporation, etc., at the address inserted below by handing/or Posting a TRUE and ATTESTED COPY therot. 16. CZ hereby certify and return a NOT FOUND because I am unable to locate the individual, company, corporation, etc., named above. (See remarks below) 17.. Name and title of Individual served 19. A; erson of Buk*b ass and di.aeuon Read Order i= e?? ?! O d.Arwlnrf a anutl 0 19. Address of where served conmplete only If different than shown above) S or RFD, Apartment No., City, Bgro, Twp ??0- Date of Service 21. Time stab ? ZIP ?E) REI!?ARKS c Unable to serve prior to expiration @F com ?Dt. Seven at is were made on the i!Dg dates: 12/1/08, 12/3/08, 12/4/08 12/8/08 12/15/ , W16/08 & 12/17/08. Notes were le t a res"d _on each attempt aski det. to calf sheriff Ys' office. five. contact was 22 ATTEIIPT8 Dab man Dep.lnt Date Miles Dep.Int. Date Miles Dep.lrt Date MBes Dep.lnt. Data Nibs Dep.Int. 23. WAD Advance Costs 1 4. 125. 126. - 27. Total Costs 26. COST DUE OR REFUND "`?J 1$150.00 Pd. 1/2/09 „NONE AFFIRMED and aabac ribsd to before me day, 1 ACWO I LEDGE RECEIPT OF THE $? 'S RETURN SIGNATURE ,. OF AUTHORIZED ISSUING AUTHORITY AND TITLE. 1. PLAINTIFFS/ 2. COURT NUMBER LYNDA MARTIN AND WENNY WIJAYA 08-5726 Civil Term 3. DEFENDANTIV 4. TYPE OF WRIT OR COMPLAINT: ELIZABETH SHELLF.HAMRR A MINOR Zoo instated rrwnnl in Ci '1 Act' 041 V, `?? /I * OX46 Dap. (Pisses Prim ar Typa) Date SOMMw of Sheriff Dee JAMES W IfLa 12/ SHERIFF OF ADAMS COUNTY 39. Dale Received 7 PROTHONOTARY -'qq? I S VERIFICATION I, Shane B. Kope, Esquire, counsel for Plaintiffs in this matter, have read the foregoing Motion for Service by Special Order. I verify that all averments in this Motion relating to the actions of counsel are true and correct and based upon my personal knowledge. I understand that any false statements herein are made subject to the penalties of 18 Pa.C.S. § 4904 relating to unsworn falsifications to authorities. Dated: 1 /Iq /6?- ` ^_,? l 1 (". _._.1 `"C'?. •.iJ C. _.. __? . ?. { , f .. - "1 ??J 5 _. ??. _.. 17 .°' KOPE & ASSOCIATES, LLC By: SHANE B. KOPE, ESQ. ATTORNEY ID 92207 4660 Trindle Road, Suite 201 Camp Hill, PA 17011 (717) 761-7573 sbkope@kopelaw.com Attorney for Plaintiffs LYNDA MARTIN AND WENNY WIJAYA, IN THE COURT OF COMMON PLEAS Plaintiffs, CUMBERLAND COUNTY, PA V. NO. 2008-5726 (Civil Term) ELIZABETH SHELLEHAMER, A MINOR, : JURY TRIAL DEMANDED Defendant. AMENDED MOTION FOR SERVICE BY SPECIAL ORDER PURSUANT TO Pa.R.C.P. 430(a) AND NOW comes the above-named Plaintiffs, Lynda Martin and Wenny Wijaya, by and through their attorney, SHANE B. KOPE, ESQ., and makes the following Motion for Service by Special Order pursuant to Pa.R.C.P. 430(a): 1. On or about September 26, 2008, Plaintiffs, through counsel, filed the above captioned civil action. A copy of the complaint is attached as Exhibit "A". 2. Said civil action sought claims for replevin, unjust enrichment and breach of contract relating to three show dogs. 3. At the time this complaint was filed, Defendant was a minor with an address of 610 S. Ridge Road, York Springs, Adams County, Pennsylvania. 4. At the time this complaint was filed, Plaintiffs, through, counsel, instructed the Cumberland County Sheriffs Department to deputize the Adams County Sheriffs Department for service upon the Defendant. The Adams County Sheriff's Department made four attempts to serve the defendant prior to the expiration of the Complaint but was unable to effectuate service. A copy of the Affidavit of Return of Service dated October 24, 2008 is attached as Exhibit "B". 5. Subsequently, the Plaintiffs, through counsel, instructed the Prothonotary's office to reinstate the Complaint. Again, the Cumberland County Sheriff's Department deputized the Adams County Sheriff's Department to effectuate. service upon the Defendant. Adams County Sheriff made seven attempts to effectuate service but was unable to do so prior to the expiration of the reinstated Complaint. It is the Sheriff's contention that the Defendant may be avoiding service. A copy of the Affidavit of Return of Service dated December 17, 2008 is attached as Exhibit "C". 6. The Sheriffs Department has attempted service at different times of the day, has noticed cars in the driveway and lights on in the home of the Defendant while these attempts have been made, but no one has answered the door 7. As a result of the Defendant avoiding service, Plaintiff has incurred charges in reinstating the Complaint and requesting Cumberland County to deputize the Adams County and will continue to incur these charges for as long as Defendant continues to avoid service. Defendant is aware that the Complaint has been filed and is trying to delay the process. & There have not been any previous judicial rulings on any issues in this or- any related matters. 9. This Complaint has yet to be served on Defendant, therefore there is no counsel of record for the Defendant that can be contacted for concurrence or non- concurrence. WHEREFORE, Plaintiffs respectfully request this Honorable Court to grant their Motion and allow Defendant to be served by publication. Respectfully Submitted, KQPE-&*SSQC! 4ATES, LLC By: 2/ ne B. Kope, sq. Dated: ! [ b / d q Y ?. m a a, 0 ' C7 b co 0 'S 3 C 1T? XS* m m c m • (ZS) l7•S p mf " r ?- y LJ ,J -7 -IC7 L. m z,3 m • r f r ca ` C m m ? z cn ? a -a 2 g ?t ? " t { Boarding Fees for E. Shel lehamer AmAkeUe Starting ` November 2, 2007 December 29 days January 2008 31 days hebniary 200 3I days Ending March 30;1 2608 days 29 . 3O da YS TOTAL 150 days, X 17.00 TOTAL Dom: $2,550:00 Kepse Sng;November 17, 2047 December 14 days January 2008 Y deb nua?2008 31 da s Endiu g March 16, 2008 29 days 16 days TOTAL i2i days - X$17.00 TOT, DUE, $2, 057.00 Buddy StNtin ' 17, 2008 Endin g March 4, 2008 1 days 4 days TOTAL, 17 Sys X$17;00 TOTAL DUE $289:00 ?..?????w<vvutvy:?UV(7Ul scauzed on IMI?MGR b}' operatorlP.IAIvIsR on A4ay I6, 200° at2:02:47 Plot - Page 2of2. e EL.? C"MLYN I ? ' -1422 mv. [BIKE 755 CA UME FA lMt5$102 xt r-ds? . g ;r ?rt?fi2?Jf? F?yWtbe . Oide7`Of ,r t tX 'l, j Af AO f ?` 4 - P BAN 0 art: ?. 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Activi#yr Ssxtnmary Credit and Payment Inforrnatltan Previous-Balance..._... $70.09 Credit Line.. .............. $15,500.00 Is s-and Credits........ $141.07 Available Credit .......... _.....__ ...................... $13,366.38 Purchases, Advances & Other Debits $2,204:60 Minimum Payment Due (Current Manthj . $22:00 FINANCE CHARGES:,. $0.00 Wnimum Parment Due (Past Due)._ . $0.00 New Balance:......_....... $2,133.62 Total' New Minimum Payment ©ue....... $22.00 Payment Due i]ate .... ......:......». Mar, 03, 2008 To An uce or&od paAp as .finance es err pour urct?ase balance paYfhs tntaJ new?saJence of $ 733$2.by D3rtJ3/f?R iQ V cash balance of Wance transfer baler s Wll1 aorrtE nos to accrue dar7y intaresrurditdhe dale your. yaymerit is received. i T- _ :? rf8 A Post Tiara Ref Date Data Nbr ` Aescrfptlnn. of 7ransac ian .41ffDUrrt 131!09 0106 7811 DRt`S}?ma?ntecslore:COM 800-441'=7234 MN ._W..:. $7'0.96 CR MERE W- ftif SE/SEI:RViCE.RETURN 01114 01!12 8585 'VALUE,CITYFUR0000M7 I&CHANiCSBURG PA X423.99 : 01114 '01112 0205EIGHT & EIGHT SUPERMAR HARRISBURG PA . $74.44 01114 07113 .4442 SHEI=TZ.'`. 00002329AATHdLLYSPRG PA _::. $55.01 Ding - D1/15 0681 :MB F DOG SHOWS iNFODOG 3363799352 NC $81.50 Di722 01/21 0490 SHEM `00002003 MT HOLLY SPRG PA . $44.66 01122 .01/19 ' 9330 PAYLE<SSSHOESOU00039214.CAMP HILL PA $38198 01/22 01/18 3721 WM:SUFERCENTER CARLISLE. PA 01)24 01/22 0018 KENT-K RENTSCHLER L:LC CARL GLE -PA $70.00 01/24 01123 3:160 w, L.WR.T*257,4' CARLISLE PA..__. _., ....: $273.68 01/24 01-/23.3W3 1-80D-PETIJEDS 8007386337 FL.._.... $16420 01-M 01/25,• 0437 UVAL-AAA?iT#1886_ MECHANICSBUR PA $77.87 0.1728 oi,12 . 0053 •KIME6.& CO-STUDIO FOR `CAF USU . PA $121..00 01123 0138 REV PROV CRVT`DRrSYMANTECSTORE Cf)M.__:...... $70:98 DEBIT ADJUSTMENT 4.1129 01128 773& :PE7SMART :: D00. 52'14 CARLISLE PA: $c5 31 02101 0=1 3573, SHEETZ :00DD2329- T:HOLLY:SPRG PA'.. $47.50 02/01 01/31 .1064 TRACTOR-SUPPLY-CO #026 CARLISLE PA $238: 92104 02/01 6419 AMERICAN XENNEL?CLl7 .9192339767 NY $39 00 ?. 02!06 02MS 217.4` DELTA OOSDMOS899975WlASHING-TON DC .:?.. $228:44 - 354 Total .#or.8acount -447165 00 01323187-.--.." $2,133,62 /ff0 x r GPM BANK... PNC Bank Pf"num Business Rewards MasterCard® February Statement . for activity from Jan 09, 2008 through Feb. a7, 2008 inquiries. -1-866.385 8773 CHARLYN KENNELS (CPN 000659991) aus 28 05 Page 1 Of 2 Yt3ty? C Ba 3i ?t? fAr Sri frtes0-* R la Me " er ai`d?R a66ou4 at 44 A ttot? Activity Summary Credit and Payment Information Previous Balance $70.09 Credit Line: $15,500.00 Payments and Credits .................. :... $141.07 Available CrecSt ............ _._..: .::.._... 3-_ $13,366.38 Pu?6hases, Advances & Other Debits $2,204.60- Minimum Payment Due Gurrent Allonth $22.D0 FINANCE CHARGES ....... $0.00.: Minimum Payment Due (Past Duo) .......... $0.00 Yew Balance....., ..... 52,133.82 Fatal New Minimum Payment Due.......... $22.00 Payment We Date :. .. Mar. M,'2008 To reduce w avo/d paying aaaGticrral frnance rho es on yourpurc?ase.balance, paythe total new a/ancg a1S2 t33.62 by OY0310a Any cash:batance or balance transisr balance wX continue to.acdue daffy intent vnhY the datejourp . Gymsnt is receired t ,i w . s 4 5 .:.. •.. ._._ 2A.+..a+i ..awu. - .... . •. v. ..-.•.... i_._. c...u z4C .. .: •t _?r "__? _.... s. .. _tv .n. ... ?'? . . Fnsi Trans Ael+. Date Gate Nbr Descn'pdan of 7rartsactlan' A?nCUnf bf109 01/08 7811. DRI'Syrnantecstate=m 800-441.7234 MN 470.98 CR MERCHANDISE/SERVICE RETURN _ 01/14 01112 8585 VALUE• CITY-FUROOD00927 MECHANICSBURG PA .........: $423 99 01114 01/12::0205 SIGHT& EIGHT-SUPERMAR'HARRISBURG PA_____. $74:44 01114 01/1.3. 4442.SHEETZ, 71 00002329:WHOLLY SPRGPA ::. $55.01 0.1/16. 01115 4681 ME F DOG SHOWS,,INFODOG 336-3799352 NC a......, ... $8.1.50 01722 01121 ' -0490' `SHISM D6602003 MT.-HOLLY SPRG PA ......._:....:..:. $44.68 01122" 01119 3330 PAYLESSSHOESOU00039214 CAMP HILL PA....... ....... $38.98 Ot= 01118. '3721 wM SUPERCENTER- CARLISLE PA... _ x68:04 D1124. 01122 0018 KENT.R. RENTSCHLER U:C CARLISLE_ PA.... _ ..... $70:00 D1/24 <.:0it23 `8160;.:WAL-MART#2574 CARLISLE 01/24.' 01/23 3803- 1-600-PETMEDS.' 8007386337'.'FL.:...... $164:20 01/28 01/25 0437:. WkL-UART#1888 MEMANICSSUA PA ......:........ $77x37 01128 01125 DOW:, KWEB & C0`MD10 FOR =CARLISLE PA:_ $12.1:.00 01/28 0138 REV PROV.CRDT :DRrsiwNTECST ORI= Cam ...:...:......» $70.98 DEWTADJUSTMENI 01129 01/28 7738? PErSIMRT 00015214 CARUSLE.: PA ...:: $65 31 02101 o 1131 3573 SHEET2 000=29 UT HOLLY. SPRG PA : _.. $47.50. 02/01 01/31 1064 _ TRACTOR-SUPPLY-CO #026 CARLISLE . PA j? 02104 02f01 6419 AMERICAN KEtrNEL CLU 9.132339757 NY$39 -oo l : r? 5 0" 02106 02/05 2174 DELTA ' 00600006899975WASHINGT•ON DC $22.9:44 Total for account 5472 &5000132 3187 ....w„..,,... $2,133.62 EXHIBlf -- 4 ?? ?c n,r? f 3??a ? _ Dog RegistrationApplicafion c : ??rc?N . _ If IIII?iIf 1?1ffll?f ?l??lt[f ? * Use this form "to register our red d with the AKC: ® Important jnforrnation and ins NNEL CLU y «I truci6risare on F elay processing. AKC reserves the ryght.to: correct or cancel foi ?D?ArDED this form )nforrnatlon you omit wiff delay* the regrstxation of this dog and its descendants. Registm on is not guaranteed: Processing,' are no. nn4dridable, and a[t fees are subject to, change without notice. Once submitted, this application becomes .the Property perty of the:AKC.' LITTER OWNER COMPLEIESSLUE SECTION& NEW OWNER GOMPL?TES Rte SECTIONS. -Utter information Breed BEAGLE Number HP,26256 Date of Birth .JUNE 27, 2007 Sire CH WINDKtST A WALK IN THE PARK Dam CH WINDKIST AFTERNOON DELIGHT HM98535001 (01-03) AKC ONAW252261 HP01354201 (06-!)4) Breeder LEAH BERTAGNOLG Litter Owner LEAH BERTAGNOLLI 4983 W 2150 N,'OGDEN, UT 64404-9799-63 Y. dye .ar STEP 1) Choose one of the following two optional registration packages STEP 2) Add the Lost & Found Option 1-`? Gold Package: $27 (Save $15.901) 17-1 Silver Package: $17 (Save.$3.0D!) ? -I Lost & Found Option: $12 .. . AKC CerWW Pedgme t - ? Three 6enetaflott AKC Cerilfied Pedigae .-- ... • Lifetime Tirse.Gamnit on mvobroo t in mommy serWce 1?ar AKC Family Dog magaAne sutrsdip - ' $30 in e-aer66eates from dog com ' • AmcoW tag i0 you dci0AKC rwmber Dog Care & Trebling Video (DVD) Formom irdoiida6n, o V73N www.akrcoig*Mftrnd $40 in e-cerd6r?tas from dog.cOrn STEP 3). Total the amount due and provide payment information . Basic.Registration. AKC Registration Ceififc ate'and $15 in e-c caies from dogxom AKC Registration $ 21 A • F?rteran additional $27 for the Gold Package or $17 for the Srfver Package if appficabie Gold or Silver Pa6kage - Enter $12 for the Lost & Found Option tT appffcable lost & Found Option $ Calculate the transfer fee. See the S TransferlnstYr Wens Number of = ? x S5 ...? Transfer. Fee $ T section on page 2 to determine the amount owed: bansfers:._. - Enter a late fee of $35 if you are submitting this form after JULY 6, 20!18 or Late Fee ,' $65 if you are `submitting it alter JULY 6, 21109. .._ ..??.? Total Fee. i. Payment Method: ? :VISA -i AMDC f iE MasterCard ? Discover LJ Check or money order made payable to: American Kennel:Club FE^"CfCrt?1 '. »BLE4 E j.60' S'Eot ac0w:#! dzS;m-S) Zra &h* z stick 'x -'ate S.'_-j=.`.Wra at Tame of r T int capletter per box. Skia box between words. Choose a unique name. Names are subject to AKC approval. Pr Mal male F7 i t> OOg Too! R-21 -7F3Tr47T Microchip l 7attac' Litter Owner(s): Please complefety Harken the box below to request Return this form.by mail or go onfine to register your dog todayl Onfine Limited registration. registration is fast and easy! Limited 998 ffthebox to the left is completety darkened, the 1) Go to www.akc.orra/doorea/ dog is not to be used fortireeding. Entry in dog 2) Follow the step by step instructions events is restricted: 3) Your PIN tor.this application is., 56300 Eater the 3-digit codethatmost Gosely describes your dog. Enter the 3-digit code that:most closely describes your dog. .Fora!tematives, see witiwakccolors.org Forattematives, see www.akccolors.org iJ"1 s Ala Black & Tan 197 Tan & White ? t 013 Tided i(J r C27 Blade Red'& white 291 Slue Tan & while k 029 Slack Tin & Bluetic4 0_30 Bieck Tan &White .. - - 034 Brad: vMlie & Tan D63 Brow A White • D66 .Brown: White'& Tan 115 Lemon & white 146 Wtrde, Gonbnusd pn page 2. Dog Registration Application AF24L. t AMERICAN KENNEL .CLUBS HP26256403 ???? ??ati????a ?? ll1fi1NlllllllllNl!! 1.(we) st Il own'th s dog and apply for registration and to have we) transferred this dog directly to thQ owner(s) fisted ownership :recorded in my jour) narnq(s). the New Owner(s) section below. i (rre) oerMy bYmY (our) signature(s) ttiatat/the infomrabon appearing on this app6catinn is corredand Chet / (we) am;(are) in good standing, with the.Amarimn Kennel C/ub. t(w AGREETHAT ANY CAUSE OF ACTION; CONTROVERSYOR CLAIM ARMING OUTOF OR RELATED TO THIS REGISTRATION OR AS TO THE CONSTRUCTION, lXrERPRETA170N AND EFFECT OF,TH AGREEMENT.SHALL BE SET TIED BY ARBRRATiompuRSUANT To THE APPLICABLE RULES OFTHE AMERICAN ARBITRATION ASSOCIATION. HOWEVER,pRIOR TOpRBRR gT10N ALL APPLICABLEAKC BYLAws, RU r, REGULATIONS AND PROCEDURES !RUST FIRST BEPOLLOWED AS SET FORTH IN THE AKC CHARTER AND BYLAWS,. RULES; REGULATIONS PUBLISHED POLICIES AND t11DELNiES B AGNOW" Date of . Fem. w `ca_.°aa? .- .? ?.?. us -------------------- I ? ' t4R=sEefafs-.es atty State af? Zfc- rGf<a .? ? • - ., .. , FU r 0=134 015 t (we)-applyto the American Kennel Club to•have a Registration GerM"rcate for this doossued in my jour) name(s) ! j?ve) certify that t (we).acquired this dog directly on: the date stated atiove from the Lh1ff0wne0) andifz*&:able, iyiatl jwe) have complete written authorty:from flle.Dftr owner(s) to submit !firs appricartign to registe erfs.dog ina/l.aur, namea l (we) understand thatMwn request.l.rwe) i4be required to provide II AKC any such.w iffen auQrorrzation l (we) agree.fo abide by a!! rules and regulations off the AmenimnKenne/ Club. / (we) irnderstandihat i(fhe Limited'boz on the Dog RegistratidnAppNcation has been darkened c0n#et4 byfheLitter owner(s), / (we) wr7/ receive a Lim/tedRega+7raflon C610=31I l (INE) AGREETHATANY CAUSE OFACTION;.CONTROVERSY OR"CLAINARMtNG OUT OF OR RELATED To TM REQMTRAjTO1i OR AS TO THE CONSTRUCTION, INTERPRETATfDNAND.EFFECTDFTHjSAGREEmwrsH LL'BESETTLEDB.YARBITRATIDNPuRSUANTTOTHEAPRJCABLE'RULESOFTHEAMERICANARBrIR TMASSOCIATION.HOWEVER PRIOR TO'ARKMATION ALL APPLICABLEAKC 8YIAWS, RULES, REGULATIONS AND PROCEDURES MUST-MRST BE FOLLOWED AS SETFORTH IN THE AKC CHARTER AND BYLAWS, RULES, 'REGULATKNS,PUBLISHEDPOLICIESAND.GUMa NES: Instructions, Requirernents,:and General Information Supplemental tfyou did not acquire this dog_dirpdyrfr6m the ftterowner(s), you mustindude.a Supplemenfa) Transfer Statement?vith fee for each intermediate transfer Transfer .with this app s. Multiply the number of. Supplemental 'transfer Statements, by. the amountshown Under Payment Information on page 1 of this Irestruetions AppOcalion.and.includethis amount•in the totat,paymeni Nate: This form •is available on our Web.stte: www.akcorg: WEai6ng'Address. Send this form and aA apprbpriatefees to: The American"Kennel Club,'R'O. Box 37902, Raleigh, NC 276277902. Addtticttal if there are more than two nev owners, contact the AKC-for an Addifional Signature Form. NOTE This form is mailable on our Web site: www.akc.org. .Requirements Authorizations Signatures ofpersons other than the owners will be accepted only if a properly completed authorization form has been nledwith:the AM NOM These fomr are available on our Web site.- www-akc.org. Assistance Email AKC at mfo@akc_org or.caft 919-233-9767 to speak to an AKC Customer Service. Representative, Monday - Friday, 8:30 AM 5:00 PM. Information`about-the registration process and dovmloadableforms aie available on our Web site: www.akc.org You musYprovide B:Halid emall address to: receive.dog.com's e-certificates and an e•cetfficate for an otficetisit with a practice partidpating,in the AKC Veterinary:Network $ysgppPAng youremall address,.you'mruent to receive complimentary e-certificates and communications from AKC and-approved third parfies,.Formore details on the AKC Veterinary Network and a list of participating practices, go to www.akc.org/vetnet. .: SHERIFF'S. RETURN - OUT OF COUNTY ,. .CASE NO: 2008-05726 P COMMONWEALTH OF.PENNSYLVANIA: COUNTY OF CUMBERLAND MARTIN LYNDA ET AL VS SHELLEHAMER ELIZABETH R. Thomas Kline Sheriff or Deputy Sheriff.who being duly sworn according to law, s ays, that he made a diligent search and and inquiry for the within named DEFENDANT to wit: SHELLEHAMER ELIZABETH. MINOR but was unable to locate Her in his bailiwick. He therefore deputized the sheriff of ADAMS County,.-Pennsylvania to , serve the within COMPLAINT & NOTICE - On,October 30th ; 2008 this office was.in receipt of the attached return from ADAMS Sheriff's Costs: So answ Docketing 18.00 Out of County 9.00 .Surcharge 10.00 R. Thomas 'Kline Dep Adams County "- 84.20 Sheriff of Cumberland County postage 4.14` 125.34 10/30/2`008 KOPE & ASSOCIATES Swornand subscribe t,o.before me this day of A.D. f R 5. NAME OF INDIVIDUAL. COMPANY, CORPORATION, ETC., TO SERVICE OR DESCRIPTION OF PROPERTY TO BE LEVIED. ATTACHED OR SOLD. Elizabeth Sbellebamer, a minor ADDRESS (Street or RFD, Apartment No., City. Som. Twp., State and ZIP CODE) AT 610 Soutb Ridge Road, York Springs, PA 7. INDICATE UNUSUAL SERVICE: ? PERSONAL O PERSON IN CHARGE O DEPUTIZE ? CERT. MAIL ?'REGISTERED MAN: ? POSTED ? OTHER Now, - 1, SHERIFF OF ADAMS COUNTY, PA., do hereby deputize the Sheriff of County-to execute this Writ and make return therof according to law. This deputation being made at the request and risk of the plaintiff. SHERIFF OP ADMIS couNTY I3 SPECIAL INSTRUCTIONS OR OTHER INFORMATION THAT WILL ASSIST IN EXPEDITING SERVICE NOTE ONLY APPLICABLE ON WRIT OF ExECUTION: N.B. WAIVER OF WATCHMAN-Any deputy sherili bvykV upon or attactany any property under within writ may Wave same without a watchman, in custody of whomever is found in possession, after notifying person of levy or affadirtreM, without liability on the part of such deputy or the sheriff 10 any pWrd iff herein for any loss. destruction or:removal of any such property before sheriff's sale thereof. 9. SIMATURE of ATTORNEY or other ORIGINATOR requesting service on behalf of. 10. TELEPHONE NUMBER 11. DATE KPLAINTIFF Sbane B. Kope, Esq. O DEFENDANT (717 761-7573 PACE OW R USE F SHERIFF ONLY -DO NOT WRITE OW THIS LINE ` 12,-f acknowledge receipt of the writ .r - SIGNATURE of Authorized ACSD Deputy or Clerk and Title 13. Date Recelved 14. Expiration tZooMate complaW ae indicated above. 10/15/2008 ` OCZUM 24 200f 15. 1 hereby COMFY and RETURN that .10 have personally served. ? have served person ins charge, ? have legal evidence of service as shown in "Remarks" (on reverse) ? have hosted the above described property with the Writ or complaint described on the individuat, company, corporation, etc., at the address shorn above or on the individual, company, corporation, etc., at the address inserted below by handing/or Posting a TRUE and ATTESTED COPY therof. Ia. X I hereby certify and return a NOT FOUND' because l am unable to locate the individual. company, corporation, etc., named above. (Sea remarks below) 17. Name, and title of individual served is A piraon or s apr and dharatlon . Head Order ann raaWYq imtM dataWont's mu l place of atada. 0 ? 19...Address of where served (complete only If different than shown above) (Street or RFD, Apartment No., City, Boro. Twp., 20. Date of service 21. Time State and ZIP CODE? RENABI : Unable to locate defendant for service prior to the eXp1ratior; of the complaint. 22 ATTEMPTS Dam man Dep.frat Date Nike Dep.hK ' Date Mon DepJM. Dale MUM Dep.htt. Date. MOss Dep.IM 0/2 `30 JN 10/2 30 JN 0/2 30 KM 0/24 30 JN ?j 1 , 23* Advance Costs 24. 25. 26. ' 27. Total Costs 28?l?3iEREFUND M 00 1 11n.Att 84:`20 Pd 1%27/08 65.86 Gk. #19052 e SO ANSWER. AFIFIRMED and subscribed to before me this N/A By KAWDaP.,shenm rlea- Prart w Type) Date day; of Jacob Nehgan - 10/24/2008 S00" of Sheriff MULLER 10/24/2008 i J Public sffe1111M OF ADNA t OUM Y , DIY C'04RFION EXPIRES • 1 ACKNOW EME'RECEIPT OF, THE S FF'S #iETURN SMATM " 39. 'Date Received OF AUTHORIZE ISSUING AUTHORITY AND Trn.E. i E r ` In The Court of ComBmn Pleas of Cumberland County,' Pennsylvania. Lynda Martin _et al VS. ` . Elizabeth Shellehaner, a minor No. 08-5726 civil Now, November 24. 2008' - , I, SHERIFF OF CU MERLAND COLJNTY, PA,`do hereby deputize the Sheriff of Adams 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, .,120__, at.:, o'clock M -served the within upon at by handing to a copy of the original and made known to the contents thereof. So answers, Sheriff of County, PA COSTS ' Sworn and subscribed before SERVICE $ me this day of 520 . " MILEAGE , AFFIDAVIT o? 1. PLAINTIFFISJ : 2. COURT NUMBER LMA MARTIN AM WEMY.WIJAYA 08-5726 Civil Term 3. DEFENDANTS/ 4. TYPE OF WRIT OR COMPLAINT. ELIZABETH' SEML? aWIM A MINOR einstated Co laint in Civil Actia .R 5. NAME OF INDIVIDUAL, COMPANY, CORPORATION, ETC., TO SERVICE OR DESCRIPTION OF PROPERTY TO BE LEVIED, ATTACHED OR SOLD. Elizabetb Sbellebamer, a minor 6. ADDRESS (Street or RFD, Apartment No.,.City. Boro. Twp., State and ZIP CODE) AT 610 Soutb Ridge Rd., Yotk Springs, PA: 7. INDICATE UNUSUAL SERVICE: ? PERSONAL ? PERSON IN CHARGE ? DEPUTIZE ? CERT. MAIL ? REGISTERED MAIL ? POSTED ? OTHER Now, 1,. SHERIFF OF ADAMS COUNTY, PA., do hereby deputize the Sheriff of County to execute this Writ and make return therof according to law. This deputation being made at the request and risk of the plaintiff. SHBWF of ADAMS COUNTY 9. SPECIAL rarRUCTIONS OR OTHER INFORMATION THAT WILL ASSIST IN EXPEDITING SERVICE. NOTE ONLY APPLICABLE ON WRIT OF EXECUTION: N.B. WAIVER OF WATCHMAN-Any deputy sheriff levying upon or. attaching any properly under within writ may leave same without a watchman, in custody of whomever is found in possession, after notifying person of levy or attachment, without liability on the part of such deputy or the sheriff to any plaintiff herein for any-loss. destruction or removal of any such property before. sheriff's sale Owed. 9. SIGNATURE of ATTORNEY or other ORIGINATOR requesting service on behalf of. 10. TELEPHONE NUMBER 11. DATE S PLAINTIFF . . Sbane B.' Kope, Esq. ? DEFENDANT : (717) 761-7573 SP E LOW FOR USE OF SHERIFF ONLY DON T WRITE -SE ° W THIS 'LINE 12. l acknowledge receipt of the writ SIGNATURE of Authorized ACSD Deputy or Clark and Title 13. Date?Received 14. ExpirationlI date or complaint as indicated above. 11/2S/2008 DEC. 19 2008 15. 1 hereby CERTIFY and :RETURN that 1 ? have personally served.; ? have served person in charge, ? have legal evidence of service as, shown in "Remarks" (onreveme) ? have posted the above described property with the writ or complaint described on, the individual. company; corporation, etc., at :the address shown above or on the individual. company, corporation, etc.. at the address Inserted below by handinglor`Posting a TRUE and ATTESTED COPY therot. 16. IXl'hereby :certiy and return a NOT FUND bemuseI am unable to kbcate the individual, company, corporation, etc., named above. (See remarks beknv) . 17.. Name and title of -indivdual served fl:Ei psreon otauMeWe aye adiscretion Read Order nhiklrry in the dsbnden? of atnde. ? ? 19. Address of where serve?d? (complete only If different than shown above) Street or RFD, Apartment No.,,City. 899, Twp. ?D. Date of Service 21. rare State and ZIP CODE) REP KS _ Ocleble to serve - ef. prior. to expiration C cam int. Seven att t:s were mane OD the tolra?w g dates: 12/],/08, 12/3 083. 12/x+/08 12/8/08 12/15/ , 12/16/ & 1217/08 . No were. le t: a res ?_ora eatb attest ash.. ??. to e32l s? ? s aff;ce: :,tact as 22. ATTEMPTS Date ttelss Ddpant Date YNes " Dap k& Date Mlles Dap.int Dale : mass' Depanc. Data MUes Dep.lrrt. 23. Advance Costs 24. 25. 26. 27. Total Casts 26. COST DUE OR REFUND O.O.& AW.` A?n $150.00 .Pd I; 1/2/09 NONE FFIRMED and subscxrbed to before me this N A I aP Sherm (Pis Print Or Tim Date ty of Jere .Becker 112/17/2008 signature of Slmw Data r JAMES W. MULLER 112/17/2008 Pubic SHER OF ADAM COUNTY r SON EXPIRES - I ACtQ40VA.EDGE RECEIPT OF THE S 5 RETURN SIGNATURE 39. Date Received OF.AUTHORIZED ISSUING AUTHORITY AND TITLE oorSTt- nN0TARY ,. w VERIFICATION I, Shane B. Kope, Esquire, counsel for Plaintiffs in this matter, have read the foregoing Motion for Service by Special Order. I verify that all averments in this Motion relating to the actions of counsel are true and correct and based upon my personal knowledge. I understand that any false statements herein are made subject to the penalties of 18 Pa.C.S. § 4904 relating to unsworn falsifications to authorities. L Dated: /"[ 6 IQ `( t ly ¦ , KOPE & ASSOCIATES, LLC By: SHANE B. KOPE, ESQ. ATTORNEY ID 92207 4660 Trindle Road, Suite 201 Camp Hill, PA 17011 (717) 761-7573 sbkope@kopelaw.com Attorney for Plaintiffs LYNDA MARTIN AND WENNY WIJAYA, IN THE COURT OF COMMON PLEAS Plaintiffs, CUMBERLAND COUNTY, PA V. NO. 2008-5726 (Civil Term) ELIZABETH SHELLEHAMER, A MINOR, : JURY TRIAL DEMANDED Defendant. ORDER AND NOW, this ZS ` day of 46.,. 2009, upon consideration of the within Motion for Service by Special Order Pursuant to Pa.R.C.P. 430(a) filed by Lynda Martin and Wenny Wijaya, and good cause appearing therefore, it is hereby ORDERED and DECREED that the Motion for Service by Special Order is granted. Service may be made by publishing notice of the complaint i `rloy in a newspaper of general circulation in the county. 4-,0 "1 A? I r(t vl&e .,d w-h-C14-4 thGN1 '}b 1L.CV e-'." ddr-... o1 d+?4.dad 'Sae?el++.w I BY THE COURT: ?? ri?? P / E? / L ['f? r b_r. v ?? _ `? d. F! ?? ?y,. y'`-, c? ? ?`'J' Y KOPE & ASSOCIATES, LLC By: SHANE B. KOPE, ESQ. ATTORNEY ID 92207 4660 Trindle Road, Suite 201 Camp Hill, PA 17011 (717) 761-7573 sbkope@kopelaw.com LYNDA MARTIN AND WENNY WIJAYA, Plaintiffs, V. ELIZABETH SHELLEHAMER, A MINOR, Defendant. Attorney for Plaintiffs IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PA NO. 2008-5726 (Civil Term) JURY TRIAL DEMANDED PRAECIPE TO REINSTATE COMPLAINT TO THE PROTHONOTARY: Kindly reinstate the Complaint in the above-captioned Civil Action for an additional thirty days. Date: Respectfully Submitted, Ell ? N ? ? ? I Q G .. i KOPE & ASSOCIATES, LLC By: SHANE B. KOPE, ESQ. ATTORNEY ID 92207 4660 Trindle Road, Suite 201 Camp Hill, PA 17011 (717) 761-7573 sbkope@kopelaw.com Attorney for Plaintiffs LYNDA MARTIN AND WENNY WIJAYA, IN THE COURT OF COMMON PLEAS Plaintiffs, CUMBERLAND COUNTY, PA V. NO. 2008-5726 ELIZABETH SHELLEHAMER, A MINOR, : JURY TRIAL DEMANDED Defendant. PRAECIPE TO DISCONTINUE WITH PREJUDICE TO THE PROTHONOTARY (Civil Term) Please enter the Plaintiffs' voluntary discontinuance with prejudice of the within action pursuant to Pennsylvania Rule of Civil Procedure 229. Respectfully Submitted, PE & Date: I' Alheog By: B. Kam, Esquire Y y ` CERTIFICATE OF SERVICE I, Shane B. Kope, Esquire, do hereby certify that on this 11th day of November, 2009, 1 served a true and correct copy of the foregoing Praecipe to Discontinue with Prejudice via regular U.S. First Class mail, postage prepaid, addressed as follows: Trudy Fehlinger Eckert Seamans Cherin & Mellott, LLC 213 Market Street, Floor 8 Harrisburg, PA 17101 KOPE TES, LLC 9-B. Kope-,Esq. Trindle Road, a 201 (717) 761-7573 I.D. 92207 1; ; li Er^?1'RY rIll 2009 WV 16 P 3: 59 F ?