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Commonwealth of Pennsylvania, IN THE COURT OF COMMON PLEAS
Pennsylvania Game Commission CUMBERLAND COUNTY, PENNSYLVANIA
Plaintiff
vs. No. /~ ~ `~ B S I C ~U ~ ~ ~-C ~ M
DANIEL F. PARSON d/b/a .
SHOOTING THE X Civil Term
Defendant
NOTICE
YOU HAVE BEEN SUED IN COURT. IF YOU WISH TO DEFEND AGAINST THE
CLAIMS SET FORTH IN THE FOLLOWING PAGES, YOU MUST TAKE ACTION WITHIN
TWENTY (20) DATS AFTER THIS COMPLAINT AND NOTICE ARE SERVED, BY
ENTERING A WRITTEN APPEARANCE PERSONALLY OR BY AN 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 WIHTOUT YOU AND A JUDGMENT MAY BE NETERED
AGAINST YOU BY THE COURT WITHOUR 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
1-800-990-9108
717-249-3166 ~l0.3 ~ S ~ d ~'
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Commonwealth of Pennsylvania,
Pennsylvania Game Commission
Plaintiff
vs.
DANIEL F. PARSONd/b/a
SHOOTING THE X
Defendant
IN THE COURT OF COMMON PLEAS
CUMBERLAND COUNTY, PENNSYLVANIA
No.
Civil Term
COMPLAINT
NOW, this ~ day of _ ~~, 2012, comes the Plaintiff, Commonwealth of
Pennsylvania, Pennsylvania Game Commission, by and through its Chief Counsel, and makes
this Complaint and for cause would show the following:
1. Plaintiff is the Commonwealth of Pennsylvania, Pennsylvania Game Commission,
(hereinafter, PGC) an independent Commonwealth administrative agency with its principal
offices located at 2001 Elmerton Avenue, Harrisburg, PA 17110.
2. Defendant is Daniel F. Parson d/b/a Shooting the X, with an address of 145 D
Street, Carlisle, PA 17013.
3. By Agent Agreement witnessed June 23, 2009, Defendant was appointed a
hunting and furtaker license agent by and for the PGC. A true and correct copy of this agreement
is here by incorporated herein by reference, attached hereto and marked Exhibit A.
4. Defendant sold licenses for the license years 2011-2012 and 2012-2013 from
October 25, 2011 through November 6, 2012.
5. As of November 6, 2012, the aggregate amount of license dollars due to the PGC
was $6,454.00.
6. This amount should be reduced by $433.00, representing the agent fee for a total
due to the PGC of $6,021.00.
7. On or about November 6, 2012, the PGC attempted to sweep Defendant's account
to recoup the money due the PGC.
The Electronic Funds Transfer failed.
9. A $25.00 fee was assessed against Defendant for this failure, making the total due
to the PGC $6,046.00.
10. Avoid charge was also made against Defendant such that the total due the PGC
was $6,095.10. A true and correct copy of a Sales by Time Period Report, reflecting the amounts
and facts set forth in Paragraphs 5 through 11 is hereby incorporated herein by reference,
attached hereto and marked Exhibit B.
11. The PGC made a claim on the bond provided by Defendant as security for being a
license issuing agent and received $1,000.00 from the bonding company. A true and correct copy
of the check is hereby incorporated herein by reference, attached hereto and marked Exhibit C.
12. The balance due and remaining from Defendant is $5,095.10.
13. Despite demand being made and Defendant being advised in writing where to
send his check, no payment, or other communication, has been forthcoming.
WHEREFORE,, the PGC respectfully requests this Honorable Court to issue and order
judgment against Defendant for the amount of $5,095.10, plus interest and costs according to
law, and direct such other relief as the Court deems just and appropriate.
Respec lly sub fitted,
Date: J ~ ~ ~ ~ ~`(7'" /
B a ley C. Be el, Esquire
I.D. #49681
2001 Elmerton Avenue
Harrisburg, PA 17110-9797
(717)783-6815
VERIFICATION
I, Susan L. Bowman, Licensing Division Chief, in the Bureau of Administration, for the
Pennsylvania Game Commission of the Commonwealth of Pennsylvania, hereby affirm that the
statements made in the foregoing Complaint are true and correct to the best of my knowledge,
information and belief. I understand that this Verification is being made under penalty of 18 P.S.
Section 4904, relating to unsworn falsification to authorities.
c-~ , ~ ~
4
Susan L. Bowman
EXHIBIT A
. ,. .: ~ 103 ~» ~
~} ~~.
~-~--
COMMONWEALTH OF PENNSYLVANIA
`' PENNSYLVANIA GAME COMMISSION
HUNTING LICENSE ISSUING AGENT AGREEMENT ~.
THIS HUNTING LICENSE ISSUING AGENT AGR RRMF.N'r, made and entered into this day
of ~ ~ ZO_, by and~between the Pennsylvania Game Commission (PGC), 2001 Ehnerton
Avenue, Harrisburg, Pennsylvania 17110-9797.
. ~ AND
llA N~~ L F P A ,{~,S o N~ ~ (d/b/a) S l-~ O O~ - N G T l-~ E ~(
(Corporation, LLC, partnership or individual owner name) (Business name, if applicable)
~t ~ ~ STt~C ~ i ~ ~ .
(Street Address) ~ .
C f~ P-~- ~ 5 ~- r P A 17 C~ ~ ~~ . ~ v m ~, C,e c ~ .~ t~
(City) (State) (Zip) (County)
(Issuing Agent).
WI-~REAS, the PGC is authorized to appoint issuing agents to sell hunting and fiirtakPr licenses and
perform other related functions including issuance of DMAP and bobcat hunting/trapping permits; and
WHEREAS, the Issuing Agent has filed an application or applications with the PGC to become an .
Issuing Agent and wazzants that it has the capacity and the authority to enter into this Agreement and that it is
fully qualified, capable and willing to perform all responsibilities and obligations of the Issuing Agent as set
forth in this Agreement and other documents referred to in this Agreement.
NOW 7'HFR RFORE, for and in consideration of the covenants contained herein and intending to be
legally bound, it is agreed between the PGC and the Issuing Agent as foIlows:
Issuing Agent Operations .
1. This Agreement covers ail Issuing Agent operations pertaining to the issuance of hunting and furtaker
licenses and other essential related functions through the Pennsylvania Automated Licensing Service
(PALS) at the business location described in the~original Application for Hunting License Issuing
Agency or the application as amended by the Issuing Agent.
PGC Responsibilities
The PGC, or its duly authorized representatives, shall:
2. Unless the following equipment is not already in place as supplied by the Pennsylvania Fish and Boat
Commission, provide one (1) complete PALS Point of Sale ("POS") or WebPOS set of equipment
compatible with the Lssuing Agent's personal computer as per specifications listed on the completed
equipment survey form and necessary supplies at each authorized Issuing Agent location, as designated
by the Issuing Agent, and provide routine maintenance of the PALS equipment for necessary repairs not
due .to abuse or neglect by the Issuing Agent or the Issuing Agent's employees. PGC, or its duly
authorized agent, will ship equipment within a reasonable time after receipt of this signed'Agreement . -
and will provide installation instructions and training on use of equipment by telephone. County
Treasurers wiIl.be supplied with.one (I) era complete set of WebPOS equipment, if they have chosen
Page 1 of 8
. : ~ this hardware platform as their Primary Point-of--sale mechanism, in addition to the initial set, to handle '-, .
the issuance of antlerless deer licenses.
. 3. Provide appropriate training materials and a~toIl free telephone "helg. desk" service to answer Issuing
Agent's questions and assist with problems related to the~operation of the.system and the PALS
equipment: ~ .
4. Provide informational materials for~the Issuing Agent to distribute to licensees regarding regulation
requirements.
5. Notify the Issuing Agent of the designated amounts to be transferred and the designated day of the
electronic funds transfer (EFT) and transfer such funds from the Issuing Agent's account to the PGC.
6: Provide additional equipment that may be leased at the.Lssuing Agent's expense. All provisions of this
Agreement apply to additional equipment leased by Issuing Agent.
Issuing Agemt Responsibilities
The Issuing Agent shall:
7. Make available licenses and permits for sale to the public in strict accordance with: (1) the terms of this
Agreement; (2) all policies, instructions, rules and regulations issued by the PGC; and (3) all other
applicable laws, regulations, policies and instructions, notices and orders by PGC.
8. Ensure proper use of the PALS POS equipment and follow the PALS operating manual and aIl
subsequent amendments and revisions to the manual..
9. Adhere to all applicable statutory and regulatory requirements and follow the policies and procedures
provided in the Instructions for Issuing Agents manual issued by the PGC.
10. Collect all required customer information at the time of purchase. AIl information provided by the
customer doting purchase, including but not limited to drivers' license number, social security number,
address and ail other personal customer data are the property of the PGC.
;.
11. Veafy, to the best of its ability, that customer information presented is true and correct and will not
knowingly issue a license or permit based on false or misleading customer information.
12. Keep all customer information confidential and not use, release or permit the use of this information for
any purpose not specifically authorized by the PGC or applicable law.
13. Collect survey information as instructed by the PGC.
14. Remain informed and knowledgeable of the laws, regulations and policies governing the requirements
for licenses and permits and stay abreast of the changes in these requirements.
15. Ensure that each employee who sells licenses and permits has a general knowledge of the license types
available and of the laws, regalations, policies and procedures associated with them. Employee training
must-also include instruction in proper handling and operation of PALS equipment, confidentiality of
customer information, security procedures for equipment and stock supplies and where to get assistance
if needed.
16. Be fully responsible for the actions of employees concerning the issuance of authorized items,
associated supplies.and equipment, and indemnify PGC against any and all loss or damage of any nature
to persons or property relating to .or resulting from any action or inaction of Issuing Agent or employees.
Page 2 of 8
~~
17. Return all original 'voided licenses ~d permits to PGC within fifteen (15) days of their issuance.
.Issuing Agent is responsible for paying the license fees for voids that aze not returned within the
specified time frame. Failure to comply with this requirement may.cause PGC to immediately suspend
or terminate Issuing. Agent's ability to issue any license or permit. County Treasurers are required to
retain voided licenses for audit by the Auditor General's Office.
18. Return any and all documents designated liy the PGC within the timeframe specified by the PGC.
19. Maintain, as instructed by PGC, displays, notices or other informational materials relating to licenses
. and permits provided by PGC; distribute to customers and hunting guides other compliance or
educational materials provided by PGC; and promote and market new products or privileges as
instructed by PGC.
20. lvtamtain accurate records and other documents pertaining to this Agreement in accordance with all
applicable laws, regulations, policies, instructions, rules, notices. and orders issued by the PGC and
generally accepted accounting principles.. The Issuing Agent shaIl allow the~PGC, or~other authorized
representatives, access to .periodically inspect, review or audit PALS associated records, reports,
canceled checks and any and all similaz~material pertaining .to this Agreement. These records. shall be
maintained for thirty-one (31) days.following the close of the license yeaz or until the account is paid in
fait. In the event any work is authorized by the PGC to be subcontracted, the Issuing Agent shall
require each:subcontractor to similarly maintain and allow access to such records for audit purposes.
County Treasurers must retain voided licenses, permits and other records for audit purposes by the
Auditor General's Office, Bureau of County Audits. These voided licenses,~peffiits and records are to
be held for a m;nTmum of one (1) year~after date of audit and settlement, before being destroyed by the
County Treasurer. This ruling does not abrogate any county regulations contrary thereto.
21. Sell licenses and permits only at the business location specified in the application or approved by the
PGC, and at a place on the premises accessible to the public,
22. Protect PALS equipment and supplies provided under this agreement from unauthorized, wasteful,
inappropriate or fraudulent use. The equipment and supplies must be placed in a location secure from
abuse; damage, unauthorized use and pilferage. Issuing Agent agrees to use license paper ,,stock only for
purposes of printing licenses and permits. Issuing Agent must promptly notify PGC or its designee of
equipment malfunction. PALS equipment and supplies are assigned to the specific Issuing Agent at the
specific location that is noted on the Issuing Agent application. The equipment and supplies are not
transferable without prior PGC approval. In the event defective .equipment needs to be replaced, Issuing
Agent must return the defective equipment immediately to the specified repair center, as instructed by
the PGC or its duly authorized agent. Issuing Agent will be charged for any such equipment that is not
returned and for equipment that the PGC determines, in its sole discretion, to show obvious signs of
abuse or neglect by Issuing Agent.
23. Provide and maintain the appropriate Internet connection or analog telephone line (either dedicated or
non-dedicated) and access to a grounded electrical outlet that accepts a 3 prong plug. Proper and safe
electrical connections must be maintained from outlet to the PALS terminal and printer.
24. Adhere to all technical automation specifications and requirements prescribed by PGC or its duly
authorized agent.
25. Maintain an.account in a federally insured financial institution organized under the authority of the
Commonwealth of Pennsylvania or the United States ("bank account"). The bank account shall be able-
~to accept EFTS. Issuing Agent shall provide the PGC with all of the account information requested by
the PGC.
Page 3 of S
26. Deposit aIl_ money received fi om the sale. of licenses and'permits in the designated bank account less the ~ ,
amount retained according to law as the Issuing Agent fee. ' . ~ .
27. Sign an Automated Clearing House (ACID authorization agreement, attached hereto as Exhibit A, to
pezmtt the PGC to collect all funds due via an EFT from the designated bank account.
28. Have sufficient funds available in the designated bank account at the time of the EFT, it is a breach of
this Agreement to have insufficient funds at time of EFT. Upon notification of insufficient funds for
payment to PGC, PGC may immediately and without notice suspend or terminate Issuing Agent's
authority to issue licenses and permits, may assess an administrative fee for delinquent collection and/or
may seek other available relief at law or in equity. In addition, the PGC may require the Issuing Agent
to increase the amount of the surety bond or to provide adequate bank account overdraft protection.
29. Be responsible for any fees related to the EFTS and maintenance of the designated bank account
30. Provide written notification using the appropriate PGC form at least 15 days prior to changing banks,
account numbers, ownership status, business status or other information used by PGC or its designee for
the purpose of collecting monies owed by Issuing Agent PGC inay terminate this Agreement if Issuing
Agent changes or suffers changes in any regard described in this paragraph resulting in the Issuing
Agent no longer meeting PGC's criteria for.acceptance for Issuing Agent's participation in PALS.
31. Unless already on file, provide to the PGC at the time of Issuing Agent's execution of this Agreement a
performance bond or iztevocable letter of credit in a form and in the amount to be determined by PGC
for each sales location to ensure full and complete performance by Issuing Agent under this Agreement
The Bond shall be issued fiom a reliable Surety Company acceptable to the PGC and licensed to do
business in the Commonwealth of Pennsylvania and signed by a licensed agent. The surety bond or
iaevocable letter of credit shall remain in full force and effect at all times during the term of this .
Agreement, at Issuing Agent's expense. The bond or irrevocable letter of credit shall ensure, for the
benefit of the PGC, fuIl• and completeperformance of Issuing Agent's, obligations under this Agreement,
including but not limited to Issuing Agent's collection, handling and transfer of funds due to PGC,
protection of the equipment and supplies provided by the PGC to Issuing Agent and aII other obligations
of Issuing Agent under this Agreement
z
32. Notify the PGC by telephone within 48 hours after, and submit a written report within 10 days after, any
fire, theft or natural disaster affecting PALS equipment and supplies or records.
33. Issue. aresident license only to a person who the Issuing Agent determines is a Pennsylvania resident.
34. Notify the licensee buyers of their obligation to sign their full. name in the space provided on the license
form
35. Not o$er or provide licenses or permits free or for any fee not authorized by PGC or applicable law or
regulation. ~ _ ~ - -
Responsibility for Equipment
36. Excegt for events beyond its control, the Issuing Agent shaIl be responsible for the PALS equipment
and all supplies relating to the issuance of licenses and permits.
37. Issuing Agent hereby assumes financial responsibility for any damage to the equipment resulting from
negligence, malicious activity, abandonment, failure to return upon request by the PGC or improper
electrical service to the equipment.
Page 4 of 8
a. Equipment Maintenance; Issuing Agent will caIl the equipment help desk for assistance in
the event of a problem with equipment and will cooperate in carrying out any investigation or
remedial action directed by the help desk. PGC, or its duty authorized representative, will '
repair or replace any defective equipment needed to operate the PALS, provided that the defect
is not caused in whole or in part by (a) Issuing Agent's negligence, misuse'or abuse of the
equipment, (b) loss of equipment (i.e: equipment cannot be located by Agent) due to theft,
misfeasance, malfeasance or any other cause, or (c) damage to or destruction of equipment by
flood, fire, husicane, or other natural disaster or casualty.
b. Equupment Replacement: PGC, or its duly authorized agent, will maintain a record of
equipmen in Issuing Agent's possession by serial number. If Issuing Agent's equipment
malfunctions and must be replaced, PGC or its agent will supply a functional piece ~of
replacement equipment and instructions. Issuing Agent shall follow the instructions furnished
with respect to return of the ma].fiinctioning piece of equipment and any peripheral items .
.(cables, etc.).. If Issuing Agent does not retum a replaced piece of equipment within thirty (30)
days of receipt of replacement equipment, Issuing Agent may be charged for the cost of the
replacement equipment. PGC may collect equipment charges through EFT in an amount
determined by PGC.
c. Additional Equipment: Issuing Agent may rent additional equipment for a fee. PGC may
collect additional equipment rental fees through EFT for all additional equipment requested by
Issuing Agent in an amount and at a frequency determined by PGC. '
38. Issuing Agent shall carry appropriate insurance covering PALS equipment and supplies in an amount to
be determined by PGC. Issuing Agent shalt provide proof of insurance coverage upon the request of
PGC.
PGC Access to PALS Operations
39. Issuing Agent agrees to allow the PGC access to all materials and equipment related to the PALS
operations.
40. The PGC .may make inspections during normal business hours with or without notice to the Issuing
Agent to determine whether the Issuing Agent is complying with the terms of this Agreement.
Liability
4.1. Issuing Agent shall be responsible for, and liable to PGC for, receipt, protection and transfer of all
proceeds from the sale of licenses and permits regardless of the manner of payment, and for all losses
incurred due to theft, credit card fees and insufficient funds checks: ~ -
42. Issuing Agent agrees to hold all funds received from the sale of licenses and permits, less the Issuing
Agent's fee, in trust for the PGC. The Issuing Agent agrees to accept the responsibility and duties of
Trustee for all funds collected on behalf of the PGC. Funds collected for licenses and permits are
Commonwealth funds, and any use of such funds in any way not specifically authorized under this
Agreement is prohibited.
43. The Issuing Agent agrees to indemnify, defend and save and hold harmless the PGC, its officers,
employees and agents from and against any and aIl liability, claims, judgments or costs of whatsoever
kind and nature for injury to, or death of any person or persons and far the loss or damage to any
property resulting from or arising out of the tYSe, service, operation or performance of its responsibilities
under this Agreement and resulting from or arising out of the acts or omissions of the Issuing Agent, or
any of its employees, agents or representatives.
Page 5 of 8
Duration of Issuing Agent Agreement; Transferability
44. This Agreement shall be effective upon the date that the final required signature is obtained. The initial
term of the Agreement shall be a period of five (5) years; and the Agreement shall continue in fall force
and effect upon the same terms and conditions for~an additional one. (1) year term and thereafter in
. successive one (1) year terms, unless and until the Agreement is terminated as provided herein:
45. The Issuing Agent shall notify the PGC in writing at least 30 days before any change of business
location, nature. of business, or ownership. The PGC shaIl reconsider an Agreement based on the
original application criteria when there is a change in business location, nature of business, or
ownership. The PGC shall terminate the Agreement if the Issuing Agent no longer meets the criteria for
acceptance of an original application. ~ -
Remedies of PGC; Termination of Agreement .
46. This Agreement may be terminated by the PGC without~cause or for the convenience of PGC, by the
PGC giving the Issuing Agent fifteen (15) days notice prior to the effective date of such termination,
and this Agreement may be terminated by Issuing.-Agent by giving the PGC thirty (30) days notice prior
to the effective date of such termination ~ This Agreement may also be terminated and the Issuing
Agent's right to seIl licenses and permits to ;Hated by the PGC for any reason provided for herein.
Any such termination for cause shaIl be effective immediately upon the giving of notice to the Issuing
Agent, unless otherwise stated in such notice. In addition to the grounds for PGC termination stated
elsewhere in the Agreement, this Agreement may be terminated in the event:
a. The PGC finds that the Issuing Agent provided false or misleading information on the Issuing
Agent's application to the PGC; or,
b. The "PGC finds that the Issuing Agent, while performing its duties as an issuing agent of the
PGC under this Agreement, acted in a manner prejudicial to the public confidence in the
integrity of the PALS or the PGC; or,
-.
c. ~ The PGC finds that the Issuing Agent failed to process 200 or more combined general hunting
and furtaker license transactions annually.
47. In addition, the PGC may elect to suspend this Agreement until the Issuing Agent returns to compliance
if the PGC finds that the Issuing.Agent:
a. Changed business location without proper notice to the PGC; or
b_: Failed to account for materials and equipment for operation of the PALS; or
c. Failed to comply with a term or condition of this Agreement; or .
d. Committed an act that impairs the Issuing Agent's reputation for honesty and integrity related to
fulfilling its duties as an Issuing Agent of the PGC; or
e. Failed to properly display PALS equipment and materials; or
f. Failed to have the financial stability or responsibility to act as an Issuing Agent including, but
not limited to, evidence of inadequate accounting records or a failure to maintain sufficient
Page b of 8
funds from the sale of electronic licenses and permits in the appropriate financial institution
account ~ ~ - • ~ ~ ,.
Miscellaneous Provisions
48. The Issuing Agent agrees that, in its capacity as an Issuing Agent, it will sell licenses and pernzits,• and
otherwise act on behalf of the Commonwealth and the PGC. However, at all times that it is acting in
this capacity, the Issuing Agent shall be acting as an independent contractor and not as an employee of
the PGC. - '
49. No person, on the grounds of race; creed, color, national origin, age, sez, or disability, shall be excluded
from participation in, be denied the proceeds or benefits. of, or be otherwise subjected to discrimination
in performance of this Agreement.
50. Any amendments or modifications to this Agreement shall be in writing and shall not be effective until
duly executed by the parties to this Agreement. This Agreement and any executed amendments
constitute the entire agreement between the parties with regard to the matters set forth herein.
51. This Agreement is exclusive between the parties and may not be assigned, delegated or transfeired in
whole or in part by the Issuing Agent without the prior written approval of the PGC.
52. Any and all notices required or permitted undeL.this Agreement shaIl be delivered to the parties at the
addresses indicated at the beginning of this Agreement.
53. This Agreement shaIl be governed by and interpreted and enforced in accordance with the laws of the
Commonwealth of Pennsylvania (without regard to any conflict of laws provisions) and the decisions of
the Pennsylvania courts. Issuing Agent consents to the jurisdiction of any court of the Commonwealth
of Pennsylvania and any federal courts in Pennsylvania, waiving any claim or defense that such forum is
not convenient or proper. Issuing Agent agrees that any such court shall have in personam jurisdiction
over it and consents to service of process in any manner authorized by Pennsylvania law.
54. In the event that any one or~more of the provisions herein contained shall be held to be in. violation of or
not enforceable because of any law, it is understood that said provisions ~shaIl be d:eemed.modified to the
extent necessary to comply with said law, or if such modification would be impracticable, shall be
.deemed deleted and none of the other rig_ hts or obligations herein shaIl be prejudiced or rendered
unenforceable by reason thereof.
IN WITNESS WI~REOF, the parties have caused this Agreement to be duly executed intending to be bound
thereby. •
. o h+, ~ n~ ~~ (date) ~.
ATTEST:
Administrative Secre
Approv Legality d Form
//~
PGC Chief Counsel •
(file: PGC A~°ent A~eement )-• ~ -
Page'? of 8
Executive Director or Designee
~ (o~$ ~~~
Ezhibit A
~~ 1 ~ 1 ~-~--~
AUTHORIZATION AGA;FII~NT
FOR ELECTRONIC FUNDS TRANSFER (EF1~ .
Issuing Agent Name
Owner or Authorized Corporate Officer ~~ j ~1 ('. I~ar~d~1-~ i
Mailing Address ~ ~ ~~'~~~" C~Ad' ~ (~~ !~~
Issuing Agent Number
Phone Number (71 ~1 ~a Fax Number (7/ ~) ~- ~y " ~ ~~
Contact Person~L`,(yZ i tL ~ ~~A~Sd -°~
Phone Number of Contact Person (7~7 ) ~~ ` ~O ~7 N
Name of Financial Institution C.Di('Y1 P.r~~~. ~i°(1,ei7a.1 C'{p ~~ «Y~ it'd
Address ~ O . ~(7K L, D 1 ( C~.Ir I i 5 ! ~ _ f ~~ O ~ ~ . .
Phone Number (~L~~ ~'~• " ~L~/D(~ ~ /~
Exact Name as it appears on Account ~r ! ~~ ~ ~ N(~ ~~
Transit Routing/ABA Number (9 digits) ~ .~ ~ ~ ~? ~' ~~
Account Number _Q ~ .~ ~ $ D ~~ ~
Type of Account: ~ Checking Account ^ Savings Account
I hereby authorize the Pennsylvania Game Commission (PGC), or its duly authorized agent, to make automatic withdrawals for
license, permit, equipment rental and other fees, as applicable, on a schedule determined by the PGC from my checking or
savings account, located at the Financial Institution (FI) named above, and authorize the FI to charge sucJ,i~ withdrawals to my
listed account. The. amount of such PGC withdrawal will be equal to the amount shown on my electronic funds transfer (EF1~
notification of transaction; of which I am provided a record: Adjusting entries to correct errors and to collect additional charges,
which may include cost of equipment replacement and penalties, are also authorized according to my agreement~with the PGC.
Owner or Officer N
(as indicated above
Signed: ~'+ ~ 1 t=1.- ~ A~-5o •~
(Ple a t)
~ Title OWN 1(~
Date• ~ ' 01 ~- ald~ ~(
sxooTnvc TxE x ~ - 409
145 D STREET
(;,ARi •i•Si.R, PA 17013
so-erazrz~is
PT-I.717386-0087
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P
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~ MYq• w
YCk.
CORNERSTONE
Federal Credit Umon
P.O. Boz 1161, Cnrlisla PA 77013
EXHIBIT B
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EXHIBIT C
ADMINISTRATIVE BUREAUS:
Michelle R. McAvoy
CNA Surety
101 S. Reid Street, Suite 300
Sioux Falls, SD 57103-7046
Re: Shooting The X
LID #4815143
BOND #70733340
CLAIM #9A 337781
Dear Ms. McAvoy:
ADMINISTRATION ................... ...717-787-5670
HUMAN RESOURCES .......... ...717-787-7836
FISCAL MANAGEMENT........ ...717-787-7314
CONTRACTS AND
PROCUREMENT .................. ..717-787594
LICENSING ......................... ...717-787-2084
OFFICE SERVICES .............. ...717-787-2116
WILDLIFE MANAGEMENT......... ...717-787-5529
INFORMATION 8. EDUCATION... ...717-787286
WILDLIFE PROTECTION ........... ...717-783526
WILDLIFE HABITAT
MANAGEMENT ........................ ...717-787 E818
REAL ESTATE DIVISION....... ...717-787566
AUTOMATED TECHNOLOGY
SERVICES ............................... ...717-787076
www. Dac. state. Da. us
COPY
Thank you for submitting your company's check number 100074104 in the amount of
$1,000 to settle the above referenced bond claim. We appreciate your cooperation in settling this
claim in a timely manner.
Sincerely,
~on,v.. ~i''i . ~wrti..ov`,
Susan L. Bowman, Chief
Hunting License Division
SLB:jIa
Regional Director Myers
LES Danley
COMMONWEALTH OF PENNSYLVANIA
Pennsylvania Game Commission
2001 ELMERTON AVENUE
HARRISBURG, PA 17110-9797
"To manage all wild birds, mammals and their habitats
for current and future generations. "
November 6, 2012
LICENSE DIVISION
717-787-2084
0
0
0
0
0
D
0
0
m
V
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m
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a
0
a
0
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' ~~I~ ~~ii~ I~~II# ~~~~i' ~ ~' ~ 1
CNA
333 S WABASH AVE STE 41 S
- CHICAGO IL 60604
CHA suRErr
a~P~r~af~. Cum#~ Gt?ty",;,t~;Slpn
Tad c - ~ P'~ '=3
a,.. \ ~'~
..•~ N ~ ! :.. 0
~.
~ ~'fo ~:xpe~dite handling of your claim, please include our claim number on all future,correspondence to us.
1 Insun~d/Clierit Claimant
~ _ _ _SHOCII"IPIG THE X. LLC PA GAME COMMISSION
Gate of L.csS lot al WC Ind to Date From - thru Dates Suff/DT TRAN EXP
_ __o::~Le~t~_I__ code
011 21
Pay Amount
Code
$1,000.00
$1,000.00
_ Fl aa:~On
__ ILID dE4E 17073
_-
Tt~ ert;wr~r •rjmely delivery of yotu check, please verify that the address on tins check is complete and correct. if not, please
notify y~aa claims representative with the correct information. ThaNc you.
SJBLRt 8.23.06 v PLEASE DETACH BEFORE CASHING
s~~'~~ I - - - - - 56-1544
1 00074 1 04 Oat
UNDERWRITTEN BY: Date Issued Bank Acct.
WESTERN SURETY COMPANY 10/30/12 631506706
~a ~ e ~• e
Claim Number Desk Code InsuredlClient Issuing Off.
_ _ 9A. ~3778f CR SHOOTING THE X LLC No. 9A
Pref ~: & Contract NNo. Claimant Date of Loss
__WSC -70733340 PA GAME COMMISSION' OS 16 12'
------
From-thru (Dates) In Payment of
___-_!___ LID #4817073
000244
PENNSYLVANIA GAME COMMISSION
HUNTING LICENSE DIVISION
2001 ELMERTON AVENUE
HARRISBURG PA 17110-9797
PAID OIVE THOUSAND AND NO/100TH5 ------------
------------------------•----------------------------__ Dollars
Dollars' • Cents
TO PI:NNSYLV4NIA GAME COMMISSION ******$1,000.00
o 'THE; HUNTING LICENSE DIVISION
$ ORDEiI 2001: ELMERTDN AVENUE ~~rZ/v~,^~/`~
o,~~ HARRISEU~G PA 17110-9797
J
JPNIOrgan Chase BBnF:, NA OhlO VOID IF NOT CASHED IN SIX
MONTHS FROM MONTH OF ISSUE
n^C]3~00074L0411' t:044LL5443t: 63L506706u'
rq r-i -
CJ)
^�C ko 1C;
IN THE COURT OF COMMON PLEAS OF THE NINTH JUDICIAL DISTRICT OF
PENNSYLVANIA
COMMONWEALTH OF PENNSYLVANIA, COUNTY BRANCH: Cumberland
PENNSYLVANIA GAME COMMISSION,
Plaintiff CIVIL ACTION—LAW
NO. 12-7251 Civil
vs.
Daniel Parson,
Defendant
PETITITION FOR APPOINTMENT OF ARBITRATORS
TO THE HONORABLE, THE JUDGES OF SAID COURT:
Audrey J. Broucek, counsel for the plaintiff in the above action(or actions), respectfully
represents that:
1. The above-captioned action is at issue.
2. The claim of the plaintiff in the action is$5,095.10. The counterclaim of the
defendant in the action is $0.
The following attorneys are interested in the case as counsel or are otherwise disqualified
to sit as arbitrators: Audrey J. Broucek and Thomas L. McGlau hlin.
WHEREFORE,your petitioner prays your Honorable Court to appoint three (3)
arbitrators to whom the case shall be submitted. d �
c�
Audrey J. B66ceV
Assistant Counsel
Commonwealth of Pennsylvania
Pennsylvania Game Commission
ID #208483
2001 Elmerton Avenue
Harrisburg, PA 17110-9797
Phone: (717) 787-4250 ext. 3617
Fax: (717) 787-6957
abroucekgpa.gov
� d�
R
is r.
Jz,No3
9.
YL PWSC tU T),
IN
Commonwealth of Pennsylvania, IN THE COURT OF COMMON PLEAS
Pennsylvania Game Commission CUMBERLAND COUNTY,PENNSYLVANIA
Plaintiff
vs. NO. 12-7251 CIVIL TERM
Daniel F. Parson d/b/a :
Shooting the X
Defendant
ENTRY OF APPEARANCE
To the Clerk of Courts:
Please enter my appearance for the plaintiff in the above-captioned case.
Audrey J. B. Esq. Date
Name and Address of Attorney for Plaintiff:
Audrey J. Broucek,Esq.
2001 Elmerton Avenue
Harrisburg,PA 17110
Supreme Court ID No.: 208483
Phone: 717-787-4250 Ext. 3617
Email: abroucek&a.gov
r--
■ Or
T°11:1 kb''7"1 t
2�13 Ply 3 2
� I�BERLANJUN 13 D Clrit��r`���.
PENNSYLVANIA
IN THE COURT OF COMMON PLEAS OF THE NINTH JUDICIAL DISTRICT OF
PENNSYLVANIA
COMMONWEALTH OF PENNSYLVANIA, • COUNTY BRANCH: Cumberland
PENNSYLVANIA GAME COMMISSION, •
Plaintiff • CIVIL ACTION—LAW
•
NO. 12-7251 Civil
•
vs. •
•
Daniel Parson, •
Defendant •
•
ORDER OF COURT
AND NOW, 2,144.1_,2_,. /3 , 20 , in consider 'on of the foregoing petition,
y c ratvi .) , Esq., et/ti_ / , Esq.,
and 1 .'/4/i '._ d./.
, Esq., are appointed arbitrato s in the above-
captioned action as prayed for.
BY THE COURT,
/40
, P.J.
VI-kw/as L . me c/a
v /udr #6/-0 c°
4;a' frx.a.
Jew
In the Court of Common Pleas of Cumberland
Plaintiff _ 7Q -S—/
SAN County, Pennsylvania No. /
Defendant
Civil Action–Law.
Oath
We do Solemnly swear(or affirm)A`at we will support, obey and defend the Constitution of the United States
and th C n titution o ommonwealth and that we will discharge the duties of our office with fidelity.
g- e_ ��Q�-
Sig ffa ture —_ Signature Signature
Qk) /C,�P2 ,a ?-OAZ".5�
Name (Chairman) Name Name
Law Firmer Law Firm Law Firm
J1-1&tv o -T., d le 2d.-s 4wS
Address Address Address Cor1�5 ie i A 1-701N
City, Zip City, Zip City, Zip
Award
We,the undersigned arbitrators, having been duly appointed and sworn (or affirmed),make the following
award: (Note: If damages for delay are awarded, they shall be separately stated.)
12 PcUv r 07' q-n,e /6z
. /
Arbitrator, issents. (Insert name if applicable.)
D f Hearing:
Date o g
Date of Award: (Chairman)
Notice of Entry of Award
Now,the �3 day of , 20 /.� , at Za , _.M.,the above
award was entered upon the docket dn1d no ice thereof given by mail to the parties or their attorneys.
Arbitrators' compensation to be paid upon appeal: $
By:
Prothonotary Deputy
ILU r )
+ 1. T
ht €q 3vL�
Z013 JUL 23 QM 1o: Q
CUMBERLAND couwy
PEN SyLVA,HIA
f bat, ;el
r�uc ej 7
`ti
I
EA Lanz ��w S S�O�tJ In the Court of Common Pleas of Cumberland
Plaintiff / 1 q �--�
County, Pennsylvania No. o� 7cal
Defendant
Civil Action—Law.
Oath
We dos 101emnly swear(or affirm at we will support, obey and defend the Constitution of the United States
and th C n titution o ommonwealth and that we will discharge the duties of our office with fidelity.K. �-
Signature �_ Signature Signature
-' U.S.POSTAGE;
David D.Buell
Prothonotary
Suite 100 _10
� F 1(E. $
ZIP 17013
One Courthouse Sq. 02 1"
Cariisle,PA 17013 fir= � � t 0001368848-
Daniel F. Parson
Shooting The X
145 D Stre -
Carlisle, P
w� r
I
COMMONWEALTH OF IN THE COURT OF COMMON PLEAS
PENNSYLVANIA, : CUMBERLAND COUNTY,PENNSYLVANIA
PENNSYLVANIA GAME : n
COMMISSION ct !a
nW
Plaintiff : CIVIL ACTION-LAW
c 'am
V. : NO. 12-7251 CIVIL P-<„
DANIEL F. PARSON z c') X—
Defendant °
PRAECIPE FOR JUDGMENT ON THE ARBITRATION AWARD
To: Prothonotary,
Kindly enter a judgment on the arbitration award dated July,23,2013 in the above
captioned case against Daniel F.Parson in the amount of$5,095.10,plus interests and
costs from the date of Award.
I certify that a true copy of the Praecipe for Judgment on the Arbitration Award was
mailed to Defendant.
l
Audrey J. rklaintiff
Esquire
Attorney or
I.D. #208483
2001 Elmerton Avenue
Harrisburg,PA 17110-9797