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HomeMy WebLinkAbout12-4581IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA Martha Statler 3473 Molly Pitcher Hwy South Chambersburg, PA 17202; Wilmer Singleton 870 Woodlawn Drive Chambersburg, PA 17201; Pure Word Partners LLC 3473 Molly Pitcher Hwy South Chambersburg, PA 17202; and rri 70 CIO 0 1 C i -,, v c-? 777 Pure Word Press LLC 3473 Molly Pitcher Hwy South Chambersburg, PA 17202. Plaintiffs, No. Ja _ g5T 1 elvtz- 011 V. Donald F. Nori, Jr. 267 Chestnut Drive Shippensburg, PA 17257; and Destiny Image Inc. 167 Walnut Bottom Road Shippensburg, PA 17257 Defendants. Civil Action JURY TRIAL DEMANDED COMPLAINT 0 N#ro?3 h'f? NOTICE YOU HAVE BEEN SUED IN COURT. If you wish to defend against the claims set forth in the folio, 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 defen 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 fc any money claimed in the complaint or for any other claim or relief requested by the plaintiff. You m? lose money or property or other rights important to you. YOU SHOULD TAKE THIS PAPER TO YOUR LAWYER AT ONCE. IF YOU DO NOT HAVE A LAWYER, GO TO OR TELEPHONE THE OFFICE SET FORTH BELOW. THIS OFFICE CAN PROVIDE YOU WITH INFORMATION ABOUT HIRING A LAWYER. IF YOU CANNOT AFFORD TO HIRE A LAWYER, THIS OFFICE MAY BE ABLE TO PROVIDE YOU WITH INFORMATION ABOUT AGENCIES THAT MAY OFFER LEGAL SERVICES TO ELIGIBLE PERSONS AT A REDUCED FEE OR NO FEE. Cumberland County Bar Association 32 South Bedford Street Carlisle, PA 17013 1800-990-9108 or 717-249-3166 2 The Parties 1. Plaintiff Martha Statler is a citizen of Pennsylvania with an address of 3473 Molly Pitcher Hwy South, Chambersburg, PA 17202. 2. Plaintiff Wilmer Singleton is a citizen of Pennsylvania with an address of 870 Woodlawn Drive, Chambersburg, PA 17201. 3. Plaintiff Pure Word Partners LLC is a Pennsylvania Limited Liability Company with an address of 3473 Molly Pitcher Hwy South, Chambersburg, PA 17202. 4. Plaintiff Pure Word Press LLC is a Pennsylvania Limited Liability Company with an of 3473 Molly Pitcher Hwy South, Chambersburg, PA 17202. 5. Defendant Donald Nori, Jr. is a citizen of Pennsylvania with an address of 267 Chestnut Drive, Shippensburg, Cumberland County, PA 17257 and a business address of 167 W Bottom Road, Shippensburg, Cumberland County, PA 17257. 6. Defendant Destiny Image Inc. is a Pennsylvania corporation with a principal place of business of 167 Walnut Bottom Road, Shippensburg, Cumberland County, PA 17257. Jurisdiction and Venue 7. This action arises out of a series of defamatory statements made by defendants. 8. Defendant Nori is a resident of Cumberland County, Pennsylvania, and, accordingly, this Court has jurisdiction over this matter. 9. Defendant Destiny Image Inc. is a resident of Cumberland County, Pennsylvania, and, accordingly, this Court is the appropriate venue for this matter. 10. Jurisdiction and venue are appropriately in this Court under 42 Pa.C.S.A Section 5301. 11. The damages sought by plaintiffs exceed the arbitration limits of this Court. Facts Common to All Counts 12. Defendant Donald F. Nori ("Nori") is the President of Destiny Image Inc. ("Destiny 3 13. Upon information and belief, Defendant Nori publishes a personal blog, which is located al http://truth 1979.wordpress. com. 14. Destiny Image is a Christian-themed publisher located in Shippensburg, Cumberland C Pennsylvania. 15. Plaintiffs Wilmer Singleton ("Singleton") and Martha Statler ("Statler") are former employees of Destiny Image. 16. Singleton is not a public figure as that term is defined for purposes of Pennsylvania and United States law. 17. Singleton is not a limited public figure as that term is defined for purposes of Pennsyl and United States law. 18. Statler is not a public figure as that term is defined for purposes of Pennsylvania and U States law. 19. Statler is not a limited public figure as that term is defined for purposes of Pennsylvania United States law. 20. Singleton's employment with Destiny Image ended on or about June 1, 2011. 21. Statler's employment with Destiny Image ended on or about April 15, 2011. 22. In 2011, Singleton and Statler, along with a third individual, Dana Loche, formed Pure W Partners LLC ("Pure Word Partners") and Pure Word Press LLC ("Pure Word Press") 23. As of early 2012, Dana Loche ceased to be associated with Pure Word Partners and Pure Word Press. 24. Pure Word Partners and Pure Word Press are engaged in the business of publishing Christian-themed literature and providing publishing support to authors of Christi literature. 4 T 25. On October 24, 2011, Nori emailed the employees of Destiny Image and falsely stated Singleton and Statler were engaged in illegal activity. A true and correct copy of the Octo 24, 2011 email is attached hereto as Exhibit A. The contents of Exhibit A are herein as if set forth in full. 26. Defendant Nori sent the October 24, 2011, defamatory email in his role as President of Destiny Image. 27. The October 24, 2011, defamatory email was sent on behalf of Destiny Image. 28. Destiny Image and Nori are each the author of the October 24, 2011 email. 29. The October 24, 2011 email states that "Marti, Wilmer and Dana have been illegally funneling money from Destiny Image to their private firm [i.e., Pure Word Partners and Word Press]." 30. The statement that "Mart[ha Statler], Wilmer [Singleton] and Dana have been illegally funneling money from Destiny Image to their private firm" is false as to Statler, Singleton, Pure Word Partners and Pure Word Press. 31. The October 24, 2011 email states that "[t]hese are criminal offenses." 32. The statement that "[t]hese are criminal offenses" implies to a reasonable person that the author is stating that Statler and Singleton engaged in criminal conduct and that they used Pure Word Partners and Pure Word Press as vehicles to do so. 33. The statement that "[t]hese are criminal offenses" and the implication that Statler and Singleton engaged in criminal conduct are false. 34. Statler and Singleton did not engage in criminal conduct of the type identified in the Octo 24, 2011 email. 5 35. On or about June 2, 2012, the statement that Singleton and Statler were engaged in illegal activity was repeated and expanded upon in a blog posted on the internet at suspected-in-conspiracy-to-steal-from-former-employe r/. A true and correct copy of the website as it appeared on June 27, 2012, is attached hereto as Exhibit B. The contents of Exhibit B are incorporated by reference as if set forth in full. 36. Upon information and belief, Defendant Nori is the owner of the blog titled http://truthl979.wordpress.com and the author of the statement appearing in Exhibit B. 37. Nori's June 2, 2012 blog post states that "[i]t is believed that Marti [i.e., Statler], Wilmer [i.e., Singleton], and Dana have stolen money from a former employer, caused harm to the quality of many products, and nationally to discredit the employer to business clients and others within the industry." 38. The only former employer that Statler, Wilmer, and Loche have in common is Destiny Image. 39. The defamatory statement in the blog post that Statler and Singleton have stolen money Destiny Image is false. 40. The defamatory statement in the blog post that Statler and Singleton caused harm to the quality of many of Destiny Image's products is false. 41. The defamatory statement in the blog post that Statler and Singleton discredited Destiny Image to clients and others within the Christian-themed publishing industry is false. 42. Nori's June 2, 2012 blog post further states that "[t]hey may have been using funds to finance the fledgling company, which would be fraud if true." 6 43. The defamatory innuendo that Statler and Singleton used unemployment funds to finance Pure Word Partners and/or Pure Word Press is false. 44. The defamatory innuendo that Statler and Singelton committed fraud is false. 45. Nori's June 2, 2012 blog post further states that Statler and Singleton engaged in "a conspiracy to steal money" from Destiny Image. 46. The defamatory statement that Statler and Singleton were part of a conspiracy to steal from Destiny Image is false. 47. Nori's June 2, 2012 blog post further states that Dana Loche "is believed to have funneled money [stolen from Destiny Image] to [Singleton] and [Statler][.]" 48. The defamatory statement that Statler and Singleton received ill-gotten funds from Loche i; false. 49. Nori's June 2, 2012 blog post further states that "[o]ver $20,000 was stolen in this fashion and many business projects severely damaged." 50. The phrase "in this fashion" in the June 2, 2012 bog post refers to the false statement that Loche funneled money to Statler and Singleton. 51. The defamatory veiled accusation that Statler and Singleton received over $20,000 in stolen from Destiny Image is false. 52. The defamatory veiled accusation that Statler and Singleton participated in conduct that damaged Destiny Image's projects is false. 53. Nori's June 2, 2012 blog post ends by stating "[l]et this be a warning to any that consider a business relationship with these individuals." 54. This "warning" is defamatory to Singleton, Statler, Pure Word Partners, and Pure Word Press. 7 55. Nori's June 2, 2012 blog post, as a whole, defames Singleton and Statler both explicitly because it implies the existence of undisclosed, defamatory facts. 56. Upon information and belief, Destiny Image and Nori have made other similar defamatory statements regarding Singleton, Statler, Pure Word Partners, and Pure Word Press to individuals and businesses within the Christian-themed publishing community. 57. As a result of the defamatory statements made by Destiny Image and Nori, Singleton and Statler have suffered personal humiliation. 58. As a result of the defamatory statements made by Destiny Image and Nori, Singleton and Statler have suffered mental anguish. 59. As a result of the defamatory statements made by Destiny Image and Nori, Singleton and Statler have suffered injuries to their reputations. 60. As a result of the defamatory statements made by Destiny Image and Nori, Singleton and Statler have been impaired in their standing in the Christian-themed publishing community 61. As a result of the defamatory statements made by Destiny Image and Nori, Pure Word Partners and Pure Word Press have lost an undetermined number of clients. 62. As a result of the defamatory statements made by Destiny Image and Nori, an number of business partners have refused to deal with Pure Word Partners and Pure Word Press. Count I - Defamation (Statements contained in October 24, 2011 email) 63. The contents of paragraphs 1 through 62 are incorporated herein as if set forth in full. 64. The statement set forth in the October 24, 2011 email (Exh. A) that Singleton and Statler were engaged in illegal activity is defamatory per se. 8 65. The statement set forth in the October 24, 2011 email that Singleton and Statler were engaged in illegal activity is false. 66. The statement set forth in the October 24, 2011 email that Singleton and Statler were "illegally funneling money" to Pure Word Partners and Pure Word Press is false. 67. The statement set forth in the October 24, 2011 email that Singleton and Statler were engaged in illegal activity was published via email to the employees of Destiny Image. 68. The statement set forth in the October 24, 2011 email that Singleton and Statler were engaged in illegal activity references Singleton and Statler by name and also references private firm"; accordingly, the email refers to all the Plaintiffs. 69. The statement set forth in the October 24, 2011 email that Singleton and Statler were engaged in illegal activity was understood by the recipients of the email as defamatory. 70. Upon information and belief, this false and defamatory statement was believed by one or more of its recipients to be true; i.e., one or more recipients of the email believe that Singleton and Statler have engaged in illegal activity as stated in the email from Nori and Destiny Image. 71. Upon information and belief, some of the individuals who received the false and statement have repeated it to others who know Singleton and Statler. 72. Upon information and belief, this false and defamatory statement has lowered the of Singleton and Statler among those who have been exposed to the statement. 73. Upon information and belief, this false and defamatory statement has damaged the of Pure Word Partners and Pure Word Press among those who have been exposed to the statement. 9 74. Within the Christian-themed publishing company, the integrity, trustworthiness, and mor character of individuals and their companies are of paramount importance. 75. Singleton and Statler were injured by the publication of the defamatory email. 76. Pure Word Partners and Pure Word Press were injured by the publication of the defamatc email. 77. Upon information and belief, Nori and Destiny Image published the defamatory email wi the knowledge of its falsity and/or with reckless or negligent disregard of its truth or falsi Thus, this statement was made with malice, bad faith, wantonness, and ill-will toward Plaintiffs' professional reputations and with the intent to harm Plaintiffs' reputations witl^ the Christian-themed publishing community. 78. This statement has damaged Pure Word Partners' and Pure Word Press' good business reputation and Singleton's and Statler's professional reputations. 79. This statement has caused Singleton and Statler to suffer mental anguish and personal humiliation. 80. This statement has caused Plaintiffs to incur pecuniary damages in the nature of lost busir opportunities. 81. Therefore, Plaintiffs requests compensatory damages in the amount of lost revenues and compensatory damages for the loss of value of their reputations and goodwill and for the humiliation and anguish experienced by Singleton and Statler, as well as any special darn proved. In addition, Plaintiffs requests that the Court award punitive damages in an amot sufficient to prevent Defendants and others from making defamatory statements and engaging in reprehensible behavior. Count II - Defamation (Statements contained in Nori's June 2, 2012 bloiz Dostina) 10 82. The contents of paragraphs 1 through 62 are incorporated herein as if set forth in full. 83. The statements published in Nori's June 2, 2012 blog post (Exh. B) that Singleton and were engaged in illegal activity are defamatory per se. 84. The statements published in Nori's June 2, 2012 blog post that Singleton and Statler were engaged in illegal activity are false. 85. The statements published in Nori's June 2, 2012 blog post that Singleton and Statler were engaged in illegal activity are publicly available on the internet and, therefore, were published. 86. The statements published in Nori's June 2, 2012 blog post that Singleton and Statler were engaged in illegal activity reference Singleton and Statler by name and reference their business, i.e., Pure Word Partners and Pure Word Press; accordingly, these statements to the Plaintiffs. 87. The statements published in Nori's June 2, 2012 blog post that Singleton and Statler were engaged in illegal activity were understood by the readers of the internet posting as defamatory. 88. The statements published in in Nori's June 2, 2012 blog post that Singleton and Statler Pure Word Partners and Pure Word Press in furtherance of illegal activity are defamatory se. 89. The statements published in Nori's June 2, 2012 blog post that Singleton and Statler used Pure Word Partners and Pure Word Press in furtherance of illegal activity are false. 90. The statements published Nori's June 2, 2012 blog post that Singleton and Statler used Word Partners and Pure Word Press in furtherance of illegal activity are publicly available the internet and, therefore, were published. 11 91. The statements published in Nori's June 2, 2012 blog post that Singleton and Statler used Pure Word Partners and Pure Word Press in furtherance of illegal activity reference Singleton and Statler by name and reference their business, i.e., Pure Word Partners and Word Press; accordingly, these statements refer to the Plaintiffs. 92. The statements published in Nori's June 2, 2012 blog post that Singleton and Statler used Pure Word Partners and Pure Word Press in furtherance of illegal activity were understood by the readers of the internet posting as defamatory. 93. The statements published in Nori's June 2, 2012 blog post that Singleton and Statler in other unsavory, underhanded, and dishonest conduct are defamatory per se. 94. The statements published in Nori's June 2, 2012 blog post that Singleton and Statler in other unsavory, underhanded, and dishonest conduct are false. 95. The statements published Nori's June 2, 2012 blog post that Singleton and Statler engaged i other unsavory, underhanded, and dishonest conduct are publicly available on the internet and, therefore, were published. 96. The statements published in Nori's June 2, 2012 blog post that Singleton and Statler were engaged in engaged in other unsavory, underhanded, and dishonest conduct reference Singleton and Statler; accordingly, these statements refer to the Plaintiffs. 97. The statements published in Nori's June 2, 2012 blog post that Singleton and Statler in other unsavory, underhanded, and dishonest conduct were understood by the readers of internet posting as defamatory. 98. Upon information and belief, these false and defamatory statements were believed by one or more readers to be true; i.e., one or more readers of the internet posting believe that Si and Statler have engaged in illegal activity, have used Pure Word Partners and/or Pure W 12 T Press as a vehicle to do, and/or have engaged in other unsavory, underhanded, and dishone,t conduct as stated in Nori's June 2, 2012 blog posting. 99. Upon information and belief, some of the individuals who viewed the false and defamatory' statements have repeated them to others who know Singleton and Statler. 100. Upon information and belief, these false and defamatory statements have lowered the reputation of Singleton and Statler among those who have been exposed to the statement. 101. Upon information and belief, these false and defamatory statements have damaged the reputation of Pure Word Partners and Pure Word Press among those who have been to the statement. 102. Within the Christian-themed publishing company, the integrity, trustworthiness, and moral character of individuals and their companies are of paramount importance. 103. Singleton and Statler were injured by the publication of the defamatory blog post. 104. Pure Word Partners and Pure Word Press were injured by the publication of the defamatory blog post. 105. Upon information and belief, Nori published the defamatory blog post with the knowledge of its falsity and/or with reckless or negligent disregard of its truth or falsity. Thus, these statements were made with malice, bad faith, wantonness, and ill-will toward Plaintiffs' professional reputations and with the intent to harm Plaintiffs' reputations within the Christian-themed publishing community. 106. These statements have damaged Pure Word Partners' and Pure Word Press' good business reputation and Singleton's and Statler's professional reputations. 107. These statements have caused Singleton and Statler to suffer mental anguish and humiliation. 13 108. These statements have caused Plaintiffs to incur pecuniary damages in the nature of lost business opportunities. 109. Therefore, Plaintiffs requests compensatory damages in the amount of lost revenues compensatory damages for the loss of value of their reputations and goodwill and for the humiliation and anguish experienced by Singleton and Statler, as well as any special darr proved. In addition, Plaintiffs requests that the Court award punitive damages in an amot sufficient to prevent Defendants and others from making defamatory statements and engaging in reprehensible behavior. -F posting) 110. The contents of paragraphs 1 through 62 are incorporated herein as if set forth in full. 111. The statements published on Nori's June 2, 2012 blog posting on the internet (Exh. B) identify Singleton and Statler by name. 112. The statements were published on the internet and are publicly available. 113. The statements that Singleton and Statler were engaged in illegal conduct and other unsavory, underhanded, and dishonest conduct set forth in Nori's June 2, 2012 blog post place Singleton and Statler in a false light. 114. The statements that Singleton and Statler were engaged in illegal conduct and other unsavory, underhanded, and dishonest conduct set forth in Nori's June 2, 2012 are highly offensive to a reasonable person. 115. The statements that Singleton and Statler were engaged in illegal conduct and other unsavory, underhanded, and dishonest conduct set forth in Nori's June 2, 2012 are false. 14 116. Defendant Nori knew the statements were false, or was recklessly indifferent to the of the statements, when he made the statements that Singleton and Statler were engaged i illegal conduct and other unsavory, underhanded, and dishonest conduct set forth in Nori's June 2, 2012. 117. The false statements set forth in Nori's June 2, 2012 blog post are unprivileged. 118. As a direct consequence of the false statements published by Nori, Singleton and S incurred harm to their privacy interests, anxiety about their professional standing among personal and business colleagues and clients, and pecuniary loss damages. 119. Singleton and Statler request compensatory damages in the amount of the damage to professional reputations. In addition, Singleton and Statler request that the Court award punitive damages in an amount sufficient to prevent Nori and others from engaging in fals, light invasion of privacy and engaging in reprehensible behavior Count IV - Trade Defamation (Statements contained in October 24, 2011 email and statements in June 2, 2012 blog posting) 120. The contents of paragraphs 1 through 62 are incorporated herein as if set forth in full. 121. Singleton, Statler, Pure Word Partners, and Pure Word Press are engaged in the of publishing Christian-themed literature. 122. The statements in Exhibit A and B are defamatory. 123. The false statements published in Exhibits A and B attributing criminal and fraudulent behavior to Singleton and Statler and alleging the use of Pure Word Partners and Pure W Press in furtherance of such behavior were made in an attempt to persuade prospective business partners of Singleton and Statler to avoid doing business with them and their company. 15 124. The false statements published in Exhibits A and B were understood by the recipients of the statements to be defamatory. 125. The false statements published in Exhibits A and B disparaged Singleton's and Statler' professional reputations and standing in the Christian-themed publishing community. 126. The false statements published in Exhibits A and B were intended to cause financial to ;s to Plaintiffs and/or Defendants should have known that the publication of the false statement would cause financial loss to Plaintiffs. 127. Plaintiffs have suffered financial loss as a result of the false statements by Defendants. WHEREFORE, Plaintiffs Wilmer Singleton, Martha Statler, Pure Word Partners LLC, and Pure Word Press LLC request that this Court enter judgment in their favor, jointly and severally, against Defendants Destiny Image Inc. and Nori awarding Plaintiffs the followir. (1) compensatory damages to the full extent permitted by law, including pecuniary damage to Pure Word Partners and Pure Word Press and pecuniary damages and damages for humiliation and mental anguish to Singleton and Statler; (2) punitive and exemplary damages; (3) reasonable attorneys' fees and costs; and (4) such other just and equitable reli as the Court deems appropriate damages in an amount exceeding $50,000, court costs, and any and all other relief to which they are entitled. 16 Respectfully submitted, David T. Miller PA ID # 84433 Melissa Furrer Miller PA ID # 84520 Miller & Miller Law Firm LLC 950 Walnut Bottom Road Suite 15-209 Carlisle, PA 17015 717.609.4930 (T) 888.277.8370 (F) david ,mmlawfirmllc.com Attorneys for Plaintiffs Wilmer Singleton Martha Statler, Pure Word Partners LLC, and Pure Word Press LLC 17 Exhibit A Don Nor! <dnj@destinyimage.com> To: subscribers@destinyimage.com Mon, Oct 24, 2011 at 9:54 AM It has been discovered that Marti, Wilmer, and Dana have been illegally funneling money from Destiny Image to their private firm. In an attempt to hide the activities, they a,-PO Box and the name of a sub-contractor for the bill-to address. However, the name o=L* C is registered to Wilmer, and its address is MartPs personal address. Dana processed invoices to send them money. These are criminal offenses. Action is being taken at this time. If anyone has additional' information you would like to share, now is the time to come forward. Don Nori President Destiny Image, Inc. N -722-6774 (Matthew 11:12, James 1:4, Galatians 5:19-24 - NKJV) This message is intended only for the use of the individual ,or entity to whom it is addressed and may contain information which is privileged and confidential, the disclosure of which is prohibited bylaw. If you are not the intended recipient please do not disclose, copy or take any action in reliance on it. If you received this message by mistake please ten us by reply and delete it from your system. Exhibit B 6/27/12 Wilmer Singleton, marti Statler, and Dana Loche suspected in conspiracy to steal from former employer.... TruthIWWs Bldg Just another WordPress.conl site Wilmer Singleton, marti Statler, and Dana Loche suspected in conspiracy to steal former employer. Posted on June 2.2012 It is believed that Marti, Wilmer, and Dana have stolen money from a former employer, caused harm t the quality of many products, and have reached out nationally to discredit the employer to business client and to others within the industry. They deny any wrong doing and deny that they actively lie about their acti ns. Although the suspicion is tied to physical facts and client testimony. There is no denying the facts. A usines, name and web domain were registered to Wilmer and Marti shortly after being released by their form (T employer. They may have been using unemployment funds to finance the fledgling company, which would be fraud if true. Dana continued to hold a position within the former employer's company. This is how the conspiracy to steal money occurred. She used this position to create false invoices for work that was never performed. She got these invoices paid by the company and is believed to have funneled the money to Wilmer and Marti, whom she was communicating with by email to be part the their newly formed company. Over $20,000 was stolen in this fashion and many business projects severely damaged. Let this be a warning to any that consider a business relationship with these individuals. Truth ADVERTISEMENT Share' w Twitter Facebook Like this: Like Be the first to like this. This entry was posted in clans Loche, mart stater, Wilmer singleton and tagged dana loche, marti Statler, Wilmer Singleton. Bookmark the Dermalink. Truth 1979's Blog Theme: Twenty Ten Blog tit WbixMess. coin. wordpress.coml.../wlmer-singleton-marti-statler-and-dana-Loche-suspected-in-conspiracy-to-steal-... 1/1 VERIFICATION 1 am one of the plaintiffs in his matter and verify that the factual averments contained in the foregoing Complaint are true to my personal knowledge Dat? E Z qvW Sworn before me thisl day Of June, 2012 [Seal] OOMMONwEA?TH OF PENNSYWANUI L Notarial Seal Heather A. Somers, Notary Public chamberslxn Borg, Franklin County My COMMIssi0n Expires May 23, 2016 MEMBER, PEMMSVI.VAMfA TM OF MOYAM VERIFICATION I am one of the plaintiffs in his matter and verify that the foregoing Complaint are true to my personal knowledge Dated: k-k" ? Sworn before me this t41 Of June, 201 _ 2 [Seal) COMMONWEALTH of PB+INSYI.VANIA Notarial Seal heather A. Somers, Notary Public Chambersburg Bore, Franklin County CommlWW Expires May 23, 2016 MEMBER PENNSYLYMIA ASIodam" OF Norte SHERIFF'S OFFICE OF CUMBERLAND COUNTY Ronny R Anderson Sheriff Jody S Smith Chief Deputy Richard W Stewart Solicitor auulr at C111t1b"14114 OFFICE . " -1,E S"ERIFF THE PRIDIMCMUIAI'?,"? ?x`12 AUG -7 AM 9.01 C'UMBErILAN COU?d'F', PENNSYLVANIA Martha Statler Case Numbe vs. Destiny Image, Inc. (et al.) 2012-4581 SHERIFF'S RETURN OF SERVICE 07/30/2012 12:29 PM - Shawn Gutshall, Deputy Sheriff, who being duly sworn according to law, states that on Ju 30, 2012 at 1229 hours, he served a true copy of the within Complaint and Notice, upon the within nai defendant, to wit: Donald F. Nori, Jr., by making known unto Patricia Komes, Administrative Assistant Destiny Image, Inc. at 167 Walnut Bottom Road, Shippensburg, Cumberland County, Pennsylvania 17571 its contents and at the same time handing to her personally the said tr and correct copy of tF same. HALL, 07/30/2012 12:29 PM - Shawn Gutshall, Deputy Sheriff, who being duly sworn according to law, states that on Jul) 30, 2012 at 1229 hours, he served a true copy of the within Complaint and Notice, upon the within nary defendant, to wit: Destiny Image, Inc., by making known unto Patricia Komes, Administrative Assistant Destiny Image, Inc. at 167 Walnut Bottom Road, Shippensburg, Cumberland County, Pennsylvania 17571 its contents and at the same time handing to her personally the said true and correct copy of the same. _ SHERIFF COST: $64.45 SO ANSWERS, August 01, 2012 NNY R ANDERSON, SHERIFF (c) CountySuite Sheriff, Teleosoft: Inc.