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HomeMy WebLinkAbout12-5365 Bryan Shook Esquire Tel" ~EZ~~~~t#~' . ID # 203250 Dethlefs-Pykosh Law Group, LLC 7~~2 AU~ 28 PM z° 2132 Market Street Camp Hill. Pennsylvania 17011 Telephone-(717)975-9446 ~~M ~~~p Fax - r 9r-23o9 P'~~SYLVANI ~ E3Shool.~~i-;dnl~la~~.com, Attorneys for Plaintiff. Kevin Mackay James D. Hughes, Esquire ID # 58884 Scott T. Wvland ID # 52660 Salzmann Hughes, P.C. 354 Alexander Spring Road, Suite 1 Carlisle. Pennsvlvania 17015 Telephone - (717) 249-6333 Fax - (717) 249-7334 .IHu~hes~a salzmannhu~hes.com Attorneys for Carlisle Productions, [nc. and Lance Miler KEVIN MACKAY, LANCE MILLER, and: IN THE COURT OF COMMON PLEAS OF CARLISLE PRODUCTIONS, INC. :CUMBERLAND COUNTY, PENNSYLVANIA Plaintiffs v. :CIVIL ACTION -LAW JERRY L. MOORE, DAN MATHIS, JR., : No: 12- -CIVIL TERM Individually as well as t/a IDONI-MATHIS GENERAL PARTNERSHIP, and DOMENICO IDONI, Individually as well as tla IDONI-MATHIS GENERAL PARTNERSHIP, Defendants :JURY TRIAL DEMANDED NOTICE TO DEFEND 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 ~ judgment may be entered against you by the Court without further notice for any money claimed in the Complaint or for any 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 OR KNOW A LAWYER, THEN YOU SHOULD GO TO OR TELEPHONE THff OFFICE SET FORTH BELOW TO FIND OUT WHERE YOU CAN GET LEGAL HELP: CUMBERLAND COUNTY LAWYER REFERRAL SERVICE 2 LIBERTY AVENUE r.y~-, CARLISLE, PA 17013 (717) 249-3166 NOTICIA Le han demandado a usted en la Corte. Si usted quiere defenderse de estas demandas expuestas en las paginas signuientes, usted tiene vienta (20) dias de plazo al partir de al fecha de la demands y la notification. Usted debe presentar urha apariencia escrita o en persona a por abogado y archivar en la Corte en forma escrita sus defensas o sus objectiones a las demandas en contra de su persona. Sea avisado que si usted no se fefiende, la Corte tomara medidas y puede una Orden contra ust$d sin previo aviso o notification y por cualquier queja o akuvui que es pedido en 'la petition de demands. Usted puedo parder dinero o sus propiedades o otros derechds importantes pars usted. LLEVE ESTA DEMANDA A UN ABODAGO IMMEDIATAMENTE. SI NO TIENE ABOGADO O SI NO TIENE EL DIMERO SUFICIENTE DE PAGAR TAL SERVICIO, VAYA EN PERSONA O LLAME POR TELEPONO A LA OFICINA CUYA DIRECCIOw SE EMCUENTRA ESCRITA ABAJO PARA AVERIGUAR DONDE SE PUEDE CONSSGUTA ASISTENCIA LEGAL. CUMBERLAND COUNTY LAWYER REFERRAL SERVICE 2 LIBERTY AVENUE CARLISLE, PA 17013 (717) 249-3166 2 Bryan w`. Shook. Esquire ID # 203250 Dethlefs-Pykosh Law• Croup, LLC 2132 Market Street Camp Hill, Pennsylvania 17011 I~elephone - (717) 975-9446 fax - 17) 975-2309 BShook~a;d Irlati.com Attorneys for Plaintiff. Kevin Mackay James D. Hughes, Esquire ID # 58884 Scott ~f. Wyland I D # 52660 Salzmann Hughes, P.C. 354 Alexander Spring Road. Suite 1 Carlisle. Pennsvlvania 17015 Telephone - (717) 249-6333 Fax - (717) 249-7334 .U iu hes~asalzmannhuQhes.com Attorneys for Carlisle Productions, (nc. and Lance Miller KEVIN MACKAY, LANCE MILLER, and: IN THE COURT OF COMMON PLEAS OF CARLISLE PRODUCTIONS, INC. :CUMBERLAND COUNTY, PENNSYLVANIA Plaintiffs v. :CIVIL ACTION -LAW JERRY L. MOORE, DAN MATHIS, JR., : No: 12- -CIVIL TERM Individually as well as t/a IDONI-MATHIS GENERAL PARTNERSHIP, and DOMENICO IDONI, Individually as well as t/a IDONI-MATHIS GENERAL PARTNERSHIP, Defendants :JURY TRIAL DEMANDED COMPLAINT AND NOW, come the Plaintiffs, Kevin Mackay, Lance Miller and Carlisle Productions, Inc., by and through their attorneys, the DETHLEFS-PYKOSH LAWV GROUP, LLC, by Bryan W. Shook, Esquire for Kevin Mackay and SALZMANIN HUGHES, P.C., by James D. Hughes, Esquire and Scott T. Wyland, Esquire for Lanoe Miller and Carlisle Productions, Inc., who make the within Complaint against the Defendants, Jerry L. Moore, Dan Mathis, Jr., individually, as well as trading as, the 3 - _ _ i Mathis-Idoni General Partnership, Domenico Idoni, individually, as well as trading as, the Mathis-Idoni General Partnership and, in support thereof, avers as follows: 1. Plaintiff, Kevin Mackay, is an adult individual currently residing in Valley Stream, Nassau County, Long Island, New York. 2. Plaintiff, Lance Miler, is an adult individual currently residing in Cumberland County, Pennsylvania. 3. Plaintiff, Carlisle Productions, Inc., is a duly registered Pennsylvania business corporation with a registered office address and principal place of business located at 1000 Bryn Mawr Road, Carlisle, Cumberland County, Pennsylvania 17013. 4. Plaintiff, Carlisle Productions, Inc. annually produces, inter alia, an event known ~s Corvettes at Carlisle. 5. Corvettes at Carlisle is one of the largest gatherings of Corvettes and Corvette enthusiasts in the country and is held annually the last weekend in August at the Carlisle Fairgrounds, Carlisle, Cumberland County, Pennsylvania. 6. Upon information and belief, Defendant, Jerry L. Moore, is an adult individual currently residing at 1514E 27th Avenue, Tampa, Florida 33605. 7. Upon information and belief, Defendant, Dan Mathis, Jr., is an adult individual currently residing at 216 South Hesperides Street, Tampa, Florida 33609. 8. Upon information and belief, Defendant, Domenico Idoni, is an adult individual currently residing at 5910 Great Star Drive, Number 207, Clarksville, Marylamd 21029. 9. Upon information and belief, Defendants, Dan Mathis, Jr. and Domenico Idoni, entered into a partnership agreement and trade as the Mathis-Idoni General 4 Partnership with regard to a certain 1960 Chevrolet Corvette (VIN: 00867S103535) which is the subject of this litigation. JURISDICTION 10. As more particularly averred infra, the actions of Defendants giving rise to this matter all occurred while Defendants were in Carlisle, Cumberland County, Pennsylvania in August 2012. 11. As more particularly averred infra, this Honorable Court has personal and subject matter jurisdiction over the Defendants in this matter pursuant to 42 Pa. C.S.A. 5301, 5303, 5304. 12.As more particularly averred infra, preferred venue properly lies with this Honorable Court pursuant to Pa. R.C.P. 1006. ALLEGATIONS COMMON TO ALL COUNTS Briggs Cunningham 1960 24 Hours of Le Mans Race Team 1960 Chevrolet Corvette (VIN: 00867S103535) - a/k/a CUNNINGHAM #1 13. The 1960 Chevrolet Corvette (VIN: 00867S103535) which is the subject of this litigation is one of three Chevrolet factory supported cars which were campaigned at Le Mans, France on June 25th and 26th, 1960 during the famous endurance race known as 24 Hours of Le Mans by the Briggs Cunningham racing team. 14. Briggs Swift Cunningham II, was a wealthy, well connected American automotive race team owner in 1960. 15. The Briggs Cunningham team was a private endeavor with the full, albeit unofficial, support of the Chevrolet Motor Division of General Motors which fielded three Corvettes for the 1960 race in Le Mans, France. 5 _ i 16.In 1960, Briggs Cunningham had personal connections with Ed Cole, then General Manager of Chevrolet, as well as Zora Arkus-Dontov, then the Director of High Performance Vehicles at General Motors. 17.It was through these connections that Briggs Cunningham, through his company, Jaguar of New York, Distributors, Inc., was able to purchase, at discount, from Chevrolet the three 1960 Corvettes which were fielded for the 1960 24 Hours of Le Mans by the Briggs Cunningham team. 18. These vehicles were specifically: a. Cunningham #1 - (VIN: 008675103535) b. Cunningham #2 - (VIN: 00867S104117) c. Cunningham #3 - (VIN: 00867S102538) 19.A11 three of the aforementioned cars were invoiced from Don Allen Midtovun Chevrolet, Inc. in the early part of 1960. 20. Following the very successful 1960 campaign at Le Mans, France, where the Cunningham #3 car finished eighth overall and first in its class, the three Brigs Cunningham team cars were decommissioned; their original street tuned fuel injected engines were reinstalled and the cars were sold to the public by Bill Frick, part of the Briggs Cunningham 1960 Le Mans team effort. 21. The subject 1960 Corvette (sometimes simply referred to herein as "Cunninghaim #1 had been lost and largely unaccounted for following an accident during the 19~i0 Le Mans race where it rolled and caught on fire. 22. Cunningham #2 has been located and is currently owned by a private individual in California. 6 23. Cunningham #3 has been located and is currently owned by Plaintiff, Lance Miller. 24. The Cunningham #3 car was restored by Plaintiff, Kevin Mackay. 25. The Cunningham #3 car and its history and the involvement of Plaintiffs, Miller and Mackay, was the subject of a documentary known as "The Quest". The search for the lost Cunningham 1960 Chevrolet Corvettes 26.In 1993, Plaintiff, Kevin Mackay, sought the assistance of a private investigator, David Raisner, who wrote to Automobile Club de I'Ouest, the entity which annually organizes the 24 Hours of Le Mans. 27.As luck would have it, on July 2, 1993, Mr. Raisner received a facsimile transmission from the Automobile Club de I'Ouest which listed the serial numbers of the three 1960 Briggs Cunningham Le Mans team cars. (A copy of facsimile transmission is attached hereto, made part hereof and marked as Exhibit "A"). 28. Mr. Raisner immediately shared the list of serial numbers with Plaintiff, Kevin Mackay, who, in turn, immediately began his quest to locate the missing cars. 29. Plaintiff, Kevin Mackay, had the vehicle identification numbers, provided to him ~y Automobile Club de I'Ouest, run through a fifty state DMV database which revealed to him the last known owners of the Corvettes. 30. Plaintiff, Kevin Mackay, continually had this database searched for changes or additional information, including whether any of the vehicles were listed as salvaged or stolen, which they were not. 31. Plaintiff, Kevin Mackay, in 1993, discovered through these efforts that the subject Corvette, Cunningham #1, was last titled in Florida by one Jerry L. Moore on 7 i September 5, 1974 and issued title number 08536629. (A copy of Mr. Mackay's search results are attached hereto, made part hereof and marked as Exhibit "B"). 32. Plaintiff, Kevin Mackay, actively and diligently searched for Mr. Jerry L. Moore, from the time he first learned of his name, even going so far as to hire a private investigator and personally going to the last known address of Mr. Moore on Delaware Street in Tampa, Florida, in an effort to locate Mr. Moore to ascertain more information regarding the car and its then current wherabouts. 33. Plaintiff, Kevin Mackay, was never successful in locating Mr. Moore. 34. Plaintiff, Kevin Mackay and the late Chip Miller, co-founder of Plaintiff, Carlisle Productions, Inc. and father of Plaintiff, Lance Miller, were friends. 35. Plaintiff, Mackay, found the Cunningham #3 car for Chip Miller in 2000 and at the same time provided Chip Miller with the VIN for the Cunningham #1 car. 36. Although the car was thought to possibly have ended up crushed or in a junkyard, Chip Miller never stopped searching for the Cunningham #1 car. 37. Upon Chip Miller's untimely death in March 2004, it was his wish to have the VIN Hof the #1 car published so that if the vehicle was ever located it could be traced to the 1960 Le Mans race and its Briggs Cunningham heritage. 38. Chip Miller's wish was followed and the VIN was published by Briggs Cunninghaim historian Lawrence (Larry) Berman. The long lost Cunningham #1 1960 Chevrolet Corvette is found 39. In late June 2012, Rick Carr, acting on behalf of the Carr family and the estate of his late father, the Honorable Richard W. Carr (sometimes hereinafter simply referred o 8 _ _ _ i as "Judge Carr"), was charged with the responsibility of liquidating a large warehouse in St. Petersburg, Florida which contained belongings of his father. 40.In the warehouse was a car which Mr. Carr identified as a "broken-down ald creation". 41. In an effort to learn more about the car, Mr. Carr searched the vehicle and located the vehicle identification number, 00867S103535. 42. Mr. Carr next plugged the aforementioned VIN into a computer Internet search via Google which lead him to Larry Berman's website which lists the serial numbers !of all of the Briggs Cunningham team cars. 43. Mr. Carr contacted Mr. Berman who in turn put Mr. Carr in contact with Plaintiff, Lance Miller. 44. Plaintiff, Lance Miller, following up on his father, Chip Miller's wishes, positively identified the car in the Carr warehouse as the long lost Cunningham #1 car, Lance Miller buys the long lost Cunningham #1 1960 Chevrolet Corvette 45. After lengthy telephone and email communications, Plaintiff, Lance Miller, negotiated for the purchase of the subject car from Mrs. Pamela C. Carr through Rick Carr. 46. Throughout the purchase negotiation and at all times material hereto, Plaintiff, Lande Miller, was situate in Carlisle, Cumberland County. 47. Plaintiff, Lance Miller, never went to Florida to view this vehicle prior to purchasing it and executed and negotiated the entire transaction from Carlisle, Cumberland County, Pennsylvania. 48. The Carr family, was made aware of and consented to Plaintiff, Lance Miller, intentions that the vehicle would be unveiled to the public, for the first time, on 9 ~ Friday, August 24, 2012 at the Corvettes at Carlisle event produced by Plaintiff, Carlisle Productions, Inc. in Carlisle, Cumberland County, Pennsylvania. 49. The driving factor for the Carr family to sell the vehicle to Plaintiff, Lance Miller, was the Carr family knew the car was going to be well cared far, restored to its original Briggs Cunningham 1960 Le Mans livery and cherished forever. 50. Plaintiff, Lance Miller, purchased the car from Mrs. Pamela C. Carr on July 20, 201'2 for good consideration and the sum of $75,000.00. (A copy of the bill of sale from Mrs. Pamela C. Carr to Plaintiff, Lance Miller, is attached hereto, made part hereof and marked as Exhibit "C"). 51.The bill of sale indicates that the subject 1960 Chevrolet Corvette (VIN: 00867S103535) was sold free and clear of all liens, encumbrances and liabilities whatsoever and was noted to be free and clear of any lawful/adverse claims of any person whomsoever and with the warranty that the Carr family was the lawful owner of the vehicle and had the full right and authority to enter into a contact to sell the vehicle to Plaintiff, Lance Miller. 52. Plaintiff, Lance Miller, paid for the car via a bank wire originating at a Metro Bartk branch in Carlisle, Cumberland County, Pennsylvania. 53. Thomas C. Sunday, Inc. an automotive transport company which specializes in the enclosed transportation of rare, collectible and exotic vehicles and which is located in New Kingston, Cumberland County, Pennsylvania, was next hired to pick up the subject vehicle from the Carr family in St. Petersburg, Florida. Lance Miller honors his late father's wish and sells the long lost Cunningham #1 1960 Chevrolet Corvette to Kevin Mackay 10 _ i 54. Chip Miller had an agreement with Plaintiff, Kevin Mackay, that if Chip ever located the Cunningham #1 car, Chip would give Kevin the first opportunity to buy it, just as Kevin had done for Chip in 2000 on the Cunningham #3 car. 55. Lance Miller, ever aware of his father's wishes immediately contacted Plaintiff, Kevin Mackay, after learning of the existence and whereabouts of the Cunningham #1 car. 56. Plaintiff, Kevin Mackay, independently verified that the car in the Carr family's possession was in fact the long lost Cunningham #1 car. 57. Plaintiff, Kevin Mackay, was able to make this verification based upon his intimate knowledge of the modifications made to the chassis' and the bodies of the 1960 Briggs Cunningham Le Mans cars and from his research and restoration of tMe Cunningham #3 car for Plaintiff, Lance Miller and his father Chip Miller. 58. Plaintiff, Lance Miller, from his office in Carlisle, Cumberland County, Pennsylvania, wrote up and executed a bill of sale transferring ownership of the subjact Cunningham #1 1960 Corvette from himself to Plaintiff, Kevin Mackay, for the sum of $75,000, exactly the amount he paid the Carr family just a few days day prior on July 20, 2012. (A copy of the bill of sale from Plaintiff, Lance Miller to Plaintiff, Kevin Mackay, is attached hereto, made part hereof and marked as Exhibit "D"). 59. At all times material hereto, the Carr family knew of and did not, nor does the Carr family object to, the arrangement of Plaintiffs, Lance Miller and Kevin Mackay. 60. The identity of Plaintiff, Kevin Mackay, as the owner of the vehicle was to be kept a secret, from the public, until the public unveiling of the vehicle at 3:30pm on Friday, August 24, 2012 at the Corvettes at Carlisle event produced by Plaintiff, Carlisle Productions, Inc. in Carlisle, Cumberland County, Pennsylvania. 11 i 61. News that the long lost Cunningham #1 Corvette race car had been found spread like wildfire through social media and traditional media outlets in late July and August 2012. 62. The spreading news of the finding of the car prompted, Plaintiff. Carlislle Productions, Inc., to issue a statement concerning the subject vehicle and Plaintiff Carlisle Productions, Inc. in turn used the media and publicity as an opportunity to further publicize the unveiling of the vehicle. The unveiling does not take place 63. The subject Cunningham #1 Corvette was privately shown to a select number of enthusiasts and media personnel on Thursday evening, August 23, 2012 at the Miller family garage in Carlisle, Cumberland County, Pennsylvania. 64. This private showing was reported in the Friday, August 24, 2012 issue of tMe Carlisle Sentinel. 65. The public unveiling was set for Friday, August 24, 2012 and was publicized prominently by the Patriot News online on August 22, 2012 in their Friday, Auguist 24, 2012 issue as being the "really big draw this year [at Corvettes at Carlisle]". 66.On Friday, August 24, 2012 at 10:15AM EDT, Jerry Garrett, columnist with The New York Times, emailed Plaintiff, Lance Miller, and informed Mr. Miller for the first time that a man in Tampa, Florida, specifically, Defendant, Dan Mathis, Jr., had contacted him and informed him that his father, Dan Mathis, Sr, was a drag racer who previously owned the Cunningham #1 car and who claims it was stolen in the 197as. (A copy of this email is attached hereto, made part hereof and marked as Exhibit «E„ 12 67. Plaintiff, Lance Miller, was then contacted by telephone by Keith D. Skorewicz, Esquire, at 12:43PM EDT who purported to be the attorney representing Defendants, Mathis and Idoni, as well as their partnership the Idoni-Mathis General Partnership. 68. Mr. Miller who was busy overseeing the hectic Corvettes at Carlisle event referred Attorney Skorewicz to his attorney, the undersigned, James D. Hughes, Esquire. 69.Attorney Skorewicz sent to the undersigned, James D. Hughes.. Esquire, what purports to be a copy of the front side of a Florida Certificate of Title in the name of Defendant, Dan Mathis, Jr. issued on August 17, 2012. (A copy of this August 17, 2012 Florida Certificate of Title is attached hereto, made part hereof and marked ~s Exhibit "F"). 70. As a result of and as soon as Plaintiffs learned of the adverse ownership assertions of Defendants, and out of an abundance of caution, Plaintiffs cancelled the public unveiling of the Cunningham #1 Corvette, which had been scheduled for Friday, August 24, 2012 at 3:30pm. 71.On Friday, August 24, 2012 at 3:30pm, the time scheduled for the public unveiling, Plaintiff, Lance Miller, had one of his marketing team members make the following public statement: We f•iad hoped to present the 1960 Number 1 Le Mans Corvette to you today. As you probably know, after Lance Miller purchased the car in Florida and brought it to Pennsylvania, we held an event last night to reveal it. As you also know, Lance has sold the car to a third party, who wished to remain anonymous at this time. Unfortunately, for security reasons, the car has had to be moved to an undisclosed location. While we are disappointed, as I am sure you are, it was important to respect the buyer's wishes in this matter. We have confidence that the car will be well 13 _ i cared for, and we hope its back here in Carlisle at a future show looking better than ever. 72.After the statement was made, Defendants, Mathis and Idoni, who were in the audience, became irritated that the car was not going to be presented. 73. Upon information and belief, Defendants, Mathis and Idoni, presented at the Carlisle Barracks of the Pennsylvania State Police (hereinafter referred to as "PSP") on Saturday, August 25, 2012 where they falsely represented to PSP that Defendant, Mathis, was the title owner of the subject vehicle and that the car was stolen and that a police report had been filed in Hillsborough County, Florida. 74. Upon information and belief, PSP did not require a copy of the stolen vehicle policce report to be produced immediately because Defendant, Mathis, showed a retired Hillsborough County, Florida, Reserve Sheriff's Deputy Badge to the PSP officer. 75.On Saturday, August 25, 2012, Pennsylvania State Police as well as Carlisle Borough Police arrive at the Miller Family's home as well as the Carlisle Fairgrounds looking for the subject vehicle. 76. PSP threatened to get a search warrant and shut down the Corvettes at Carlisle event in an effort to search for and locate the vehicle being touted as stolen by Defendants, Mathis and Idoni. 77. After extensive discussions with the undersigned counsel, James D. Hughes, Esquire, PSP and the Cumberland County District Attorney's office eventually relented and upon information and belief deemed the matter to be civil in nature and not criminal. COUNT I -DECLARATORY ACTION 14 i Plaintiff, Kevin Mackay v. Defendants, Jerry L. Moore, Dan Mathis, Jr., individually as well as trading as the Mathis-Idoni General Partnership, Domenico Idoni, individually as well as trading as the Mathis-Idoni General Partnership 78. Plaintiff, Kevin Mackay, hereby realleges and incorporates paragraphs 1 through 77 of the Complaint herein by reference as if fully set forth at length. 79. Plaintiff, Kevin Mackay, hereby requests a declaration of ownership of the subjecct vehicle from this Honorable Court consistent with Pa. R.C.P. 1601, et seq. and pursuant to 42 Pa. C.S.A. § 7531, et seq. the "Declaratory Judgments Act." 80.On or about July 20, 2012, Plaintiff, Lance Miller, as more particularly described supra, entered into a contract for the purchase of the subject certain 1960 Chevrolet Corvette (VIN: 00867S103535) from the Carr family in St. Petersburg, Florida. 81.On or about July 23, 2012, Plaintiff, Kevin Mackay, as more particularly described supra, entered into a contract for the purchase of the subject certain 1960 Chevrolet Corvette (VIN: 00867S103535) from Plaintiff, Lance Miller. 82.A11 conditions precedent under both contacts were performed and the subject vehicle was delivered, to Carlisle, Pennsylvania in August 2012. 83. Plaintiff, Lance Miller, acquired right and title to the subject vehicle and all of its parts, from the Carr family, in the due course of business. 84. Plaintiff, Kevin Mackay, acquired right and title to the subject vehicle and all of its parts, from Plaintiff, Lance Miller, in the due course of business. 85. Both Plaintiffs, Lance Miller and Kevin Mackay, are bona-fide, good faith, purchaseirs for value. 86. The subject vehicle was purchased, on a bill of sale from an individual in Tampa, Florida, by the Honorable Richard W. Carr, a Judge in Pinellas County, Florida in 15 approximately 1976 as a derelict, rolling chassis, with a highly modified custom body with no motor, transmission or interior. 87. Upon information and belief, Judge Carr acquired right and title to the subject vehicle and all of its parts, from and unknown person in Tampa in the 1970s. 88. Upon information and belief, Judge Carr was abona-fide, good faith, purchaser fior value. 89. Judge Carr died in 2010. 90. The Carr family warranted and guaranteed, as more particularly described supra, that no interest adverse to their family's interest or the interest of the late Honorable Richard W. Carr existed in or against the subject vehicle. 91. Pursuant to 13 Pa. C.S.A. 2401(2), Plaintiffs, Lance Miller and Kevin Mackay as well as the Carr family and Mrs. Pamela C. Carr, took all steps necessary to transfier ownership of the subject vehicle to Plaintiff, Lance Miller and in turn to Plaintiff, Kevin Mackay, by the aforementioned bills of sale in late July 2012. See Semple v. State Farm Mut. Auto. Ins. Co., 215 F.Supp. 645 (E.D. Pa. 1963). 92. The failure to be able forward a Certificate of Title to Penndot for processing does not operate to prevent the transfer of ownership of the vehicles herein. Dept. of Transp. v. Walker, 584 A.2d 1080 (Pa. Commw. Ct. 1990). 93. Upon information and belief, Defendant, Jerry L. Moore, claims that he is the same Jerry L. Moore, who is shown on Plaintiff, Kevin Mackay's, 1993 title history search who titled the subject vehicle in Florida on September 5, 1974. 94. Upon information and belief, Defendant, Jerry L. Moore, presented at the Florida Department of Motor Vehicles on August 16, 2012, after learning of the discovery, 16 _ _ _ i history and provenance of the Cunningham #1 car and had the Florida DMV reissue the Certificate of Title in his name. 95. Upon information and belief, Defendant, Jerry L. Moore, alleges that he sold the car to Dan Mathis, Sr., who was a drag racer in the 1970s. 96. Upon information and belief, Defendant, Dan Mathis, Jr., alleges that the subject vehicle was stolen while in his father's possession in the 1970s; Dan Mathis, Jr. would have been approximately nine years old at the time. 97. Upon information and belief, the subject vehicle has never been reported stolen. 98. Upon information and belief, the subject vehicle was lawfully acquired by Judge Carr in approximately 1976. 99. A search of the United States Department of Justice's National Motor Vehicle Tide Information System (NMVTIS) was performed on August 28, 2012 for VIN "00867S103535" and the search returned that the subject vehicle was not reported as stolen or a total loss in the NMVTIS database. (A true and correct copy of the August 28, 2012 NMVTIS search results for VIN "00867S103535" are attached hereto, made part hereof and marked as Exhibit "G"). 100. A search of the National Insurance Crime Bureau (NICB) VINCheck database was performed on August 28, 2012 for VIN "00867S103535" and returned that the subject vehicle has not been identified as a vehicle listed in the NICB VINCheck Theft Records or the NICB VINCheck Total Loss Records. (A true and correct copy of the August 28, 2012 NICB search results for VIN "00867S103535" are attached hereto, made part hereof and marked as Exhibit "H"). 17 101. Upon information and belief and after reasonable investigation of Plaintiffs, the subject vehicle has not been reported as stolen with Criminal Justice Information Services Division of the Federal Bureau of Investigation's, National Crime Information Center (NCIC). 102. Accordingly, the subject vehicle has not been reported stolen to the State of Florida, the Commonwealth of Penns}+Ivania, the United States Department of Justice National Motor Vehicle Title Information System, the National Insurance Crime Bureau or the FBI's National Crime Information Center. 103. Plaintiff, Kevin Mackay, accordingly claims all right to title and ownership of the subject vehicle and all of its parts. 104. The legal burden is upon the Defendants to show that they have a possessory interest and ownership interest superior to that of Plaintiff in the subject vehicle before Plaintiff can be deprived of his interest and enjoyment in the subject vehicle. 105. Any claims of ownership by the Mathis-Idoni General Partnership or by Domenico Idoni or Dan Mathis, Jr. are, upon information and belief, opportunistic. 106. Any claims of ownership by the Mathis-Idoni General Partnership or ~y Domenico Idoni or Dan Mathis, Jr. are, upon information and belief, champertous. 107. Upon information and belief, any title held by any Defendant(s) is void ab inito. Hertz Corp. v. Hardy, 197 Pa. Super. 466, 476 (1962). See also, Southeast Fist Nat'l Bank v. Security Peoples Trust Co., 480 F. Supp. 1345, 1348 (W.D. Pa. 19T9) (Holding that where "an automobile title certificate which is improperly issued due'to false representations as to the ownership of an automobile coming from without the State is void ab initio"). 18 _ 108. The efforts undertaken by Defendants to have a Certificate of Title issued in the name of Defendant, Dan Mathis, Jr., on either August 16, 2012 or August 17, 2012 have, upon information and belief, been made in an effort to contravene the rights of Plaintiff in the subject vehicle without due process. WHEREFORE, Plaintiff, Kevin Mackay, respectfully requests that this Honorable Court enter judgment in his favor and against Defendants, Jerry L. Moore, Dan Mathis, Jr., individually as well as trading as the Mathis-Idoni General Partnership, Domenico Idoni, individually as well as trading as the Mathis-Idoni General Partnership, and accordingly declare Plaintiff, Kevin Mackay, the true and lawful sole owner of the certaiin 1960 Chevrolet Corvette (Cunningham #1) (VIN 00867S103535) and all of its parts. COUNT II -DISPARAGEMENT Plaintiff, Kevin Mackay v. Defendants, Jerry L. Moore, Dan Mathis, Jr., individually as well as trading as the Mathis-Idoni General Partnership, Domenico Idoni, individually as well as trading as the Mathis-Idoni General Partnership 109. Plaintiff, Kevin Mackay, hereby realleges and incorporates paragraphs 1 through 108 of the Complaint herein by reference as if fully set forth at length. 110. As more particularly described herein, the individual or collective actions of Defendants have disparaged the pedigree and provenance of the subject vehicle. 111. The subject automobile is, as described supra, a very significant Corvette raoe car with a very close knit group of followers and enthusiasts who record every movement of such Briggs Cunningham, Le Mans and significant Corvette vehicles. 112. Any negative activity surrounding a rare car, such as the subject car, serves to cloud the pedigree and provenance of the vehicle which, in turn, negatively affects the value of the vehicle on the open market. 19 113. Through the efforts of Defendants, Plaintiff has suffered a loss of the enjoyment and opportunity to display and publically unveil the subject vehicle and announce his plans for the future of the subject vehicle. 114. The pedigree and provenance of the subject vehicle will forever be negatively affected by the actions leading up to and including the filing of this action. 115. By way of example, the pedigree and provenance of the subject vehicle will forever be tarnished by the actions of Defendants, Mathis and Idoni on Fridaiy, August 24, 2012 and Saturday, August 25, 2012 in Carlisle, Cumberland County, Pennsylvania. 116. By way of further example, the pedigree and provenance of the subject vehicle will forever be tarnished by all Defendants actions in obtaining Certificate of Title fbr the subject vehicle in the name of Dan Mathis, Jr. after knowing the vehicle hid been sold to Plaintiff, Lance Miller. 117. Plaintiff believes and therefore avers that this effect on the pedigree and provenance of the subject vehicle is as a direct and proximate result of the allegations of Defendants to the public, including Jerry Garrett of The New York Times. 118. The actions of Defendants have been made without privilege or justification. WHEREFORE, Plaintiff, Kevin Mackay, respectfully requests that this Honorable Court enter judgment in his favor and against Defendants, Jerry L. Moore, Dan Mathis, Jr., individually as well as trading as the Mathis-Idoni General Partnership, Domenibo Idoni, individually as well as trading as the Mathis-Idoni General Partnership, jointly and 20 severally, in an unliquidated amount in excess of the compulsory arbitration limit together with interest, costs and attorney's fees. COUNT III -DEFAMATION Plaintiffs, Kevin Mackay, Lance Miller and Carlisle Productions, Inc. v. Defendartit, Dan Mathis, Jr. 119. Plaintiffs, Kevin Mackay, Lance Miller and Carlisle Productions, Inc., hereby reallege and incorporate paragraphs 1 through 118 of the Complaint herein by reference as if fully set forth at length. 120. Upon information and belief, Defendants have spoken or otherwise published defamatory statements about Plaintiffs, Kevin Mackay and/or Lance Miller, which attack on the integrity and moral character of Plaintiffs, Kevin Mackay and/or Lance Miller. 121. By way of specific example, Defendant, Dan Mathis, Jr., is quoted by Jerry Garrett of The New York Times as saying "The Miller Group and Kevin Mackay have been in this business for 30 years; they know better than this All they have to do, is do the right thing. It just stuns me that they have instead decided to involve themselves in a criminal enterprise, for which I am going to seek prosecution". 122. The imputation of involvement in a criminal enterprise clearly reflects upon Plaintiffs' veracity, integrity in the conduct of their business and overall moral character and the same is slanderous per se. 123. The quoted statement above made by Defendant, Mathis, is false. 124. Upon information and belief, the quoted statement above made by Defendafit, Mathis, was made with malice. 21 - _ i 125. Upon information and belief, the quoted statement above made by Defendant, Mathis, was made without privilege. 126. Upon information and belief, the quoted statement above made by Defendant, Mathis, was made without regard for or with reckless disregard for the truth. WHEREFORE, Plaintiffs, Kevin Mackay, Lance Miller, Carlisle Productions, Inc., respectfully request that this Honorable Court enter judgment in their favor and agairyst Defendant, Dan Mathis, Jr., in an unliquidated amount in excess of the compulsory arbitration limit together with interest, costs and attorney's fees. Further, Plaintiffis, Kevin Mackay, Lance Miller, Carlisle Productions, Inc., request punitive damages for the willful and wanton acts of Defendant, Mathis, in defaming Plaintiffs, Mackay and Miller. COUNT IV - TORTIOUS INTERFERENCE WITH EXISTING AND PROSPECTIVE BUSINESS RELATIONS Plaintiff, Carlisle Productions, Inc. v. Defendants, Jerry L. Moore, Dan Mathis, Jr., individually as well as trading as the Mathis-Idoni General Partnership, Domenico Idoni, individually as well as trading as the Mathis-Idoni General Partnership 127. Plaintiff, Carlisle Productions, Inc., hereby realleges and incorporates paragraphs 1 through 126 of the Complaint herein by reference as if fully set forth at length. 128. Plaintiff, Carlisle Productions, Inc., as part of this year's Corvettes at Carlisle automotive event promoted the public unveiling of the subject 1960 Cunningham #1 vehicle. 129. News of the finding of the vehicle and the proposed August 24, 2012 unveilinig, as described more particularly supra, was extensively covered by the news amd social media alike. 130. Carlisle Productions, Inc., has contractual and prospective contractual business relations with third parties outside the scope of this lawsuit. 22 131. Upon information and belief, the actions of Defendants in arriving at the Carlisle Fairgrounds and attempting to assert their alleged interest in the vehicle in a public fashion with the aid of law enforcement has and was intended to harm the existing relations of Carlisle Productions, Inc. and those third parties and harm and prevent prospective relations of Carlisle Productions, Inc. from occurring. 132. Upon information and belief, Defendants enjoy no privilege or justification for their statements and/or actions. 133. Plaintiff believes and therefore avers that this effect on the pedigree and provenance of the subject vehicle is as a direct and proximate resu{t of the allegations of Defendants to the public, including Jerry Garrett of The New Ydrk Times. 134. Further, any defamatory statement made against Plaintiff, Lance Miller, can be ascribed to Plaintiff, Carlisle Productions, Inc., by reason of Plaintiff, Lance Miller, being publicly known as being the co-owner of Carlisle Productions, Inc. 135. The motive of Defendants in this action has been wholly self-serving. 136. The conduct of the Defendants was exhibited publicly at the Carlisle Fairgrounds and the Miller family home on August 24, 2012 and August 25, 2012 during the Corvettes at Carlisle automotive event. WHEREFORE, Plaintiff, Carlisle Productions, Inc., respectfully requests that this Honorable Court enter judgment in their favor and against Defendants, Jerry L. Moose, Dan Mathis, Jr., individually as well as trading as the Mathis-Idoni General Partnership, Domenico Idoni, individually as well as trading as the Mathis-Idoni General Partnership, 23 jointly and severally, in an unliquidated amount in excess of the compulsory arbitration limit together with interest, costs and attorney's fees. COUNT V -TRADE LIBEL Plaintiff, Carlisle Productions, Inc. v. Defendant, Dan Mathis, Jr., 137. Plaintiff, Carlisle Productions, Inc., hereby realleges and incorporates paragraphs 1 through 136 of the Complaint herein by reference as if fully set forth at length. 138. Upon information and belief, Defendant, Dan Mathis, Jr., has made false statements concerning the business of Plaintiff, Carlisle Productions„ Inc. 139. By way of specific example, Defendant, Dan Mathis, Jr., is quoted by Jerry Garret of The New York Times as saying "The Miller Group and Kevin Mackay have been in this business for 30 years; they know better than this All they have to do, is do the right thing. It just stuns me that they have instead decided to involve themselves in a criminal enterprise, for which I am going to seek prosecution". 140. Upon information and belief and based upon the actions of Defendant, Mathis, exhibited on August 24, 2012 and August 25, 2012, the aforesaid statement by Defendant, Mathis, was directed towards, Plaintiff, Carlisle Productions, Nnc., and intended to cause pecuniary loss. 141. In the alternative that Defendant, Mathis, did not intend that Plaintiff, Carlisle Productions, Inc., suffer a pecuniary loss, Defendant, Mathis, knew or should have recognized that publication of the aforesaid statement would result in pecuniary loss to Plaintiff, Carlisle Productions, Inc. 142. Carlisle Productions, Inc. has suffered a pecuniary loss as a direct and proximate result of Defendant, Mathis', actions and publication. 24 ~ 143. Upon information and belief, Defendant, Mathis, knew or should have known that the aforesaid statement was false or made it with reckless disregard of its truth or falsity. WHEREFORE, Plaintiff, Carlisle Productions, Inc., respectfully requests that thNs Honorable Court enter judgment in their favor and against Defendant, Dan Mathis, Jm., in an unliquidated amount in excess of the compulsory arbitration limit together with interest, costs and attorney's fees. Respectfully Submitted, r Date: 8` a. ~ a By: _ Bryan .Shook, Esquire Dethlefs-Pykosh Law Group, LLC ID 203250 2132 Market Street Camp Hill, Pennsylvania 17011 Telephone: (717) 975-9446 Attorney for Plaintiff, Kevin Mackay. L8 Z Date: ~,F' By: _ Ja ughes, Esquire I D 58 4 Scott . Wyland, Esquire j ID 52660 alzmann Hughes, P.C. 354 Alexander Spring Road, Suite 1 Carlisle, Pennsylvania 17015 Telephone: (717) 249-6333 Attorney for Plaintiffs, Lance Miller and Carlisle Productions, Inc. 25 _ _ T. tlER1FICATIQN i hereby verify that the sfiatements of fact made in the foregoing documents are true and correct to the best of my knowledge, information and bel're#. f undersfiand that any false staternerrts thenain are subject th the criminal penakies contained in 18 ~'a C_ S. § 4904, relating to unsworn falsification fo authorities. Date: ~ ~ ~ r ~ ~ _ Name: Kevin Mackay 26 VERIFICATION I hereby verify that the statements of fact made in the foregoing documents art true and correct to the best of my knowledge, information and belief. I understand that any false statements therein are subject to the criminal penalties contained in ~ 8 Pa C. S. § 4904, relating to unsworn falsification to authorities. Date: ~C~/~ ~r~`~- dam :Lance Miller 27 VERIFICATION I hereby verify that the statements of fact made in the foregoing documents are true and correct to the best of my knowledge, information and belief. I understand that any false statements therein are subject to the criminal penalties contained in 18 Pa S. Section 4904, relating to unsworn falsification to authorities. s Date: ~ a ~ ~ rlisle Productions,~l c. By: ~ (printed name) Title: • c~cN,n ~ 28 t s;i~ ~ rwr,~.r.. n a , kid, ~ ~R~~t1iT BUC~ATT~ ' ~ l E ~ f~ i vi ti, 5 1 r~i ti p' i' i < 5, x> r~ 3rd t1 ~ r ~ ~o Qh~ 5 ~~~L r ,i,. fir i 1 4~ !r , Y ~ ~~'~a. tai ~a r camas g~~ fi ~ v~~ A _ ~ _ a3 ~ - _ oJP~LIa~'E ~ ~tiiJ~ . `i'P, fiL~~..~j:~1v..L . . ~ .'~L >9i,, ~ 1 tt~~ ti .r-~ Z~TSURA2vC~.. U~_,~k-t. ~•.i:_ - -I k._~?t ~'A:~T~= ,~s cb1A~~' . o o c-~ :x°~ _ _ r~lip~~s rr-:~-F~:~~~~- i,, ` _ r. J?~15T R~~ Li- t 'i'~- ,i -:r,.. ~:r: I~iivl F. L . 0 1~, . ~~t. Y.i z ~ `Y0.\}'. II 13 { r~ r:. !~1 . H.. . ~ i, _ . ~ ii V _ _ i Ju1201204:17p Dr. Wharton ~ 727-327-2668 p.2 Vehicle Bill of Sale BE ET KNOWN that 1, Pamela G. Carr {hereinafter referred to as "Seller"}, residing aL 611-23'~ Avenue North, St. Petersburg, County of Pinellas, State of Florida, for good canstideration, and upon payment of the sum of seventy-five thousand dollars ($75,t?00), do this day, July 20, 2012, grant, convey, sell and transfer to Lance Miller, residing at 100{? Bryn Mawr Road, Carlisle, PA, (hereinafter referred to as `Buyer"), the following described motor vehicle (hereinafter referred tca as the °Vehide"}_ 1960 Chevrolet Corvette Vehicle Serial Number tJ0867510353li Setter's Represerrtatlans and Warranties Seller represents and warrants to Buyer that: 1. Seller is the lawful owner of the Vehide with the full legal right and authority to enter into the transactions contemplated hereby and to sell, transfer and convey the Vehide in accordance with the terms hereo#; 2. the transfer of the Vehide is rightful:. 3. the Vehicle is free of alt liens, encumbrances and liabilities whatsoever, and is free and clear of any lawfutiadverse claims of any person whomsoever, 4. Seller shall diligently defend, protect, lndemrrify and hold harmless Buyer and Buyer's lawful successors, executors, heirs and assigns from any and aA adverse claims made against ~e Vehide by any persons whomsoever. Seller's tiltarra?rttes Relating to the wehlcie Seller hereby notifies Buyer, and Buyer hereby acknowledges and agrees, #hat the Vehide is being sold "as Is and where is" with the full and complete understanding that the Vehide is not in roadworthy or running condition and is not a complete automobile; without warranty of any kind.. either expressed or implied, regarding the oorxiition of fhe Vehide. TYIe following terms apply: 1. It is the Buyer's responsibility to pick up the automobile at its current location in St. Petersburg, Florida no later than August 1, 2012; 2. The Seller will assume no Liability for any delivery cost or for insuring the Vehide anytime after the sale; 3. The Seller wiN make available io the Buyer the Vehide for delivery anytime poor to the August 1, 2012 delivery date; A. The Buyer is completely responsible for the safety and condition of the automobile upon sale, 5, Seller assumes no responsibility for any repairs regardless of any oral statements made about the Vehide. Pamela C. Can Owner t..ance Miller ;3uyer - _ - _ _ _ ~ Bill of Sale To whom it may concern: Be it known that 1, Lance Miller (hereinafter referred to as "Seller"j, residing at 10 Bayberry Road, Carlisle, Pennsylvania for good consideration, and upon payment of the sum of seventy-five thousand dollars ($75,000), do this day, July 23, 2012, grand, convey, sell and transfer to Kevin Mackay, residing at 13~ East Fairview Rvenue, Vaiiey Stream, New York (hereinafter referred to as "Buyer"j, the fallowing described motor vehicle (hereinafter referred to as the "Vehicle"j. 1960 Chevrolet Cunningham Corvette #1 Vehicle Seria! Number 008fi7Sid3535 Seller`s Representa#ions and Warranties Seller represents and warrants to Buyer that: 1j Seller is the lawful owner of the Vehicle with the full legal right and authority to enter into the transactions contemplated hereby and to sell, transfer and convey the Vehicle in accordance with the terms hereof; 2j The transfer of the Vehicle is rightful; 3j The Vehicle is free of all liens, encumbrances and liabilities whatsoever, and is free and clear bf any lawful/adverse claims of any person whomsoever; 4j 5ell share diligently defend, protect, indemnify and hold harmless Buyer and Buyer's lawful successors, executors, heirs and assigns from any and all adverse claims made against the Vehicle by any!persans whomsoever. Seller's Warranties Relating to the Vehicle Seiler hereby notifies Buyer, and Buyer hereby acknowledges and agrees, that the Vehicle is being solid "as is and where is" with the full and complete understanding that the Vehicle is not in roadworthy ar running condition and is not a complete automobile; without warranty of any kind, either expressed or implied, regarding the condition of the Vehicle. The following terms apply: 1j The Buyer is completely responsible far the safety and condition of the automobile upon sale; Zj Seller assumes na responsibility far any repairs regardless of any anal statements made abou>4 the Vehicle. 3j The Buyer will continually purchase dinner to the Seller, when together, from here an out. Seller ~ ~!~`,L„rl,.~-c ~G4~t~ Lance Miller / 717.385-1553 Own e r Buyer Kev Mackay / 516-3~ -1486 Buyer Kurt Williams From: Harold Brandt [NaroldB~cariisleever~ts.c©m] Sent: Friday; August 2~, 2012 1:Ofi PM To: Kurt WilliarrEs Subject: F1~'~': Mathis c(ain~ rYi From: frar~ee Miller Sent: Friday, August 24, 2Q12 1,01 PP~f Ta: t-iaroid Brandt Subject: i=4vd: 6~tathis ciaim Set7.t frutn tt~y iC'hi~i2ti; Begin forwarded message: Fiona. t E Garrett ~i~3a~-rc~t~(cr,,°msn.cam= l~ii~~: t1ti~,12St ~~'f, 717 ~~:~I:~6 L~~i~1 EDT To: Lance ~-Ii11er ~~I<ance)1~1~ue~u'Iisleevents.cot~- Sut~ject: I1lathis ciaixta Eli L.an~e, A n~~il~ ~E~ 7"a1~~pa, I~l~~., Dan `Mathis ir,, ~~~rites t~~ n~c; iii art email that ihe~l Le'llans Cc:trt~~ttc. 1~~.1o11~ed far a time to his father Dan Sr., a black drab; t 7.cer ~:~~~~o did tl~ie strans;~ t1c~d~~~,~~ark c,n it, is3d c:_7°~~-raigned it at dray*strips in central ~'loric~a. 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