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Home My WebLink About12-7722 JOHN OREM and IN THE COURT OF COMMON PLEAS A REGIONAL BONDING CO, :CUMBERLAND COUNTY, PENNSYLVANIA Plaintiffs ~• :CIVIL ACTION -LAW HOLLY HOFFMAN, M.D., , NO. ~°~ - X702 °L- e~ ~ ` 1~~~~ Defendant PRAECIPE FOR WRIT OF SUMMONS . = ~~ .;, -- .~, ~ ;-~ TO: David Buell, Prothonotary cn r '"" '`' ~' Cumberland County, Pennsylvania .~~c:~ , r '~- ~~r ~ ~~ Please issue a Writ of Summons in the above-captioned action: ~ `` : '~' ~ <~, Writ of Summons shall be issued and forwarded to ()Attorney (X) Sheriff: .. ~r~ Holly Hoffman, M.D. 20 Arlington Drive Carlisle, PA 17013 Respectfully submitted, December 21, 2012 PECHT & ASSOCI~,~S, PC BY / /l ~ Rob B1~eIChe~uire Supre {Court ID No. 32594 1205 Manor Drive, Suite 200 Mechanicsburg, PA 17055-4917 (717) 691-9809 Attorney for Plaintiffs Rio a. ~s ~~L~ ems- z77g 2~ a8y`~s JOHN OREM and A REGIONAL BONDING CO, Plaintiffs v. HOLLY HOFFMAN, M.D., Defendant IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA CIVIL ACTION -LAW NO. l02 ?7oL~. ~tu~~l.~~~L. WRIT OF SUMMONS TO THE ABOVE NAMED DEFENDANT: Holly Hoffman, M.D. 20 Arlington Drive Carlisle, PA 17013 YOU ARE NOTIFIED THAT THE ABOVE-NAMED PLAINTIFFS HAVE COMMENCED AN ACTION AGAINST YOU. ~Q~~ David D. Buall,-:1'r~thdr~a~:.:.. December ~~ , 2012 Deputy Pecht & Associates, PC Rob Bleecher, Esquire Supreme Court ID No. 32594 Attorney for Plaintiffs Fh'_ED-0FFjC, Rob Bleecher,Esquire 011- - THE PRO T MONO Tia t�'e, Attorney I.D.No. 32594 Pecht&Associates,PC 2013 APR 1205 Manor Drive, Suite 200 /1: 30 Mechanicsburg,PA 17055 CUt' ERL�ND CDUtiT (717)691-9809 PINS Y( VANIA Attorney for Plaintiffs JOHN OREM and : IN THE COURT OF COMMON PLEAS A REGIONAL BONDING CO, : CUMBERLAND COUNTY,PENNSYLVANIA Plaintiffs V. : CIVIL ACTION-LAW : NO. 2012-7722 HOLLY HOFFMAN, aka HOLLY C. HOFFMAN, aka HOLLY C. BAUER, and aka HOLLY C. H. BAUER And RYAN PRESTON HOFFMAN, aka RYAN PRESTON HOFFMAN-SMITH, Defendants 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 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 WITHOUT YOU AND A JUDGMENT MAY BE ENTERED AGAINST YOU BY THE COURT WITHOUT FURTHER NOTICE FOR ANY MONEY CLAIMED IN THE COMPLAINT OR FOR ANY OTHER CLAIM OR RELIEF REQUESTED BY THE PLAINTIFF. YOU MAY LOSE MONEY OR PROPERTY OR OTHER RIGHTS IMPORTANT TO YOU. YOU SHOULD TAKE THIS PAPER TO YOUR LAWYER AT ONCE. IF YOU DO NOT HAVE A LAWYER OR CANNOT AFFORD ONE, GO TO OR TELEPHONE THE OFFICE SET FORTH BELOW TO FIND OUT WHERE YOU CAN GET LEGAL HELP. CUMBERLAND COUNTY BAR ASSOCIATION LAWYER REFERRAL SERVICE 32 SOUTH BEDFORD STREET CARLISLE,PA 17013-3308 1-800-990-9108 717-249-3166 NOTICIA LE HAN DEMANDADO A USTED EN LA CORTE. Si usted quiere defende se de estas demandas expuestas en las paginas siguientes, usted tiene viente (20) dias de partir de la fecha de la demanda y la notifcacion. Usted debe presentar una apariencia escrita o en persona o por abodago y archivar en la corte en forma escrita sus defensas o sus objeciones a las demandas en contra de su persona. Sea avisado que si usted no se defiende, la corte tomara medidas y peude entrar una orden contra usted sin previo adviso o notificacion. y por cualquier queja o alivio que es pedido en la peticion de demanda. Usted puede perder dinero o sus propiedades o ostros derechos importantes para usted. LLEVE ESTA DEMANDA A UN ABODAGO IMMEDIATAMENTE. SI NO TIENT ABOGADO O SI NO TIENE EL DINERO SUFICIENTE DE PAGAR TAL SERVICIO, VAYA EN PERSONA O LLAME POR TELEFONO A LA OFICINA CUYA DIRECCION SE ENCUENTRA ESCRITA ABAJO PARA AVERIGUAR DONDE SE PUEDE CONSEGUIR ASISTENCIA LEGAL. CUMBERLAND COUNTY BAR ASSOCIATION LAWYER REFERRAL SERVICE 32 SOUTH BEDFORD STREET CARLISLE,PA 17013-3308 1-800-990-9108 717-249-3166 Rob Bleecher,Esquire Attorney I.D.No. 32594 Pecht&Associates,PC 1205 Manor Drive, Suite 200 Mechanicsburg, PA 17055 (717)691-9809 Attorney for Plaintiffs JOHN OREM and : IN THE COURT OF COMMON PLEAS A REGIONAL BONDING CO, : CUMBERLAND COUNTY,PENNSYLVANIA Plaintiffs V. : CIVIL ACTION-LAW : NO. 2012-7722 HOLLY HOFFMAN, aka HOLLY C. HOFFMAN, aka HOLLY C. BAUER, and aka HOLLY C. H. BAUER And RYAN PRESTON HOFFMAN, aka RYAN PRESTON HOFFMAN-SMITH, Defendants COMPLAINT IN BREACH OF CONTRACT AND NOW, come the Plaintiffs John Orem and A Regional Bonding Co., by and through their attorneys Pecht& Associates, PC, and aver the following: 1. Plaintiff John Orem (hereinafter "Orem" or "Plaintiff') is the attorney-in-fact and the agent for Seneca Insurance Company, Inc., 160 Water Street, New York, NY 10038 and is the CEO of A Regional Bonding Co., a Maryland Corporation. 2. Plaintiff A Regional Bonding Co. (hereinafter "Regional" or "Plaintiff') is a bonding company existing under the laws of the State of Maryland. 3. Defendant Holly Hoffman, aka Holly C. Hoffman, aka Holly C. Bauer, and aka Holly C. H. Bauer, is an adult individual who resides at 20 Arlington Street, Carlisle, PA 17013. 4. Defendant Ryan Preston Hoffman, aka Ryan Preston Hoffman-Smith, is an adult individual with a last known address of 20 Arlington Street, Carlisle, PA 17013. 5. Defendant Holly Hoffman is the mother of Ryan Hoffman. 6. On or about May 22, 2009, Defendant Holly Hoffman completed an application for Bail with Seneca Insurance Company, Inc. in the amount of $350,000. A copy of the Application for Bail is attached hereto as Exhibit "A"and made a part hereof. 7. On or about May 21, 2009, Defendants signed an Indemnity Agreement for Surety Bail Bond with Seneca Insurance Company, Inc. in the amount of$350,000. A copy of that agreement is attached hereto as Exhibit`B" and made a part hereof. 8. On or about May 22, 2009, Defendant Holly Hoffman also signed an Indemnity Agreement for Surety Bail Bond with Seneca Insurance Company, Inc. in the amount of $350,000. A copy of the agreement is attached hereto as Exhibit"C" and made a part hereof. 9. The Bail Bond was signed for the purpose of inducing Plaintiffs to supply a Bail Bond to the District Court of Maryland, Frederick County, for the purpose of obtaining the release from jail of Defendant Ryan Hoffman. A copy of the Bail Bond is attached hereto as Exhibit"D"and is made a part hereof. 10. Defendant Holly Hoffman and Defendant Ryan Hoffman are co-obligors on the Indemnity Agreement. 11. Defendants made one initial payment of $17,500 towards the $35,000 amount Defendants agreed to pay in exchange for Plaintiffs providing the $350,000 Bail Bond to the State of Maryland on Defendant Ryan Hoffman's behalf. 12. Thereafter, Defendants made two $300 payments on the outstanding balance of $17,500 and then stopped making payments. 13. Demand has been made upon Defendants to pay the balance of the money owed (i.e., $17,200), but as of this date Defendants have failed to perform on the terms of the Indemnity Agreement. 2 14. The aforesaid Indemnity Agreement has not been released, transferred or assigned by Plaintiffs. 15. Defendants have breached their duty imposed by the aforesaid Indemnity Agreement and are in default under the terms of the said Agreement for, inter alia, failing to make payment when due. 16. By the terms of the Indemnity Agreement, Defendants agreed to pay Plaintiffs' reasonable attorney fees and costs to enforce the Indemnity Agreement upon breach by Defendants. 17. Any and all conditions precedent to payment to Plaintiffs have been satisfied. 18. Notwithstanding Plaintiffs' demands for payment, Defendants' obligations under the terms of the aforementioned Indemnity Agreement remain unsatisfied. 19. The amount due and owing Plaintiffs by Defendants is $17,200 with interest, attorneys' fees and costs. 20. Defendants are in breach of the Indemnity Agreement with Plaintiffs and Plaintiffs have been damaged by that breach. )WHEREFORE, Plaintiffs demand judgment in their favor and against Defendants in the amount of$17,200 Dollars, together with interest at the statutory rate, attorneys' fees and costs. Respectfully submitted, PECHT&AS C ATES, PC Dated: April 23, 2013 By: Rob Bf5L,01her,Esquire Attorridy-11)No. 32594 1205 Manor Drive, Suite 200 Mechanicsburg, PA 17055-4917 (717) 691-9809 Attorney for Plaintiffs 3 VERIFICATION I, John Orem, Plaintiff herein and the Agent and Attorney-In-Fact for Seneca Insurance Company, Inc. and CEO of A Regional Bonding Co., state that the averments contained in this r document are true to the best of my knowledge,information and belief. Further, I am aware that any false statements made herein are made subject to the penalties of 18 Pa. C.S. Section 4904, i relating to unsworn falsification to authorities. Dated: April 22nd 2013 Lam✓ John Or ,Agent and Attorney-In-Fact for Seneca Insurance Company,Inc. and CEO of A Regional Bonding Co. a EXHIBIT "A" APPLICATION FOR BAIL Amt of Bail$35D,0oo.°� Total Charges SENECA INSURANCE CO.,INC.-BAIL BOND DIVISION Premium Chg$ 3S.ppO�' Received _ r Date if Bond: Bond Power No Balance $ Agent ��l 1�Q— Q Jn Bond Power N<oo., Defendant's Booking Name E c Q n }-� � u-�i L`c l rn True Name 5 aw 2 ,u�o Street Address "-e--/I rn .� )Joo( `)'Apt City&State 6 rm.cq.oJ-4#3, �"ilrnv Long S, Home Plane 2-�A0 - a-' -4�-Z�611 Phone 2`tO' 3`S7- I7�of D.O.B U - Sex M Race Height G \ Z� Weight ?7Z�0 Hair 'x-�/ Eyes �".0 Glasses tJo Moustache �b I.D.Marks Birthplacec�,. Pn. ti«....4. <2 f'•(' S.S.# 221-L-2-5% D.L.# Date of Arrest )1'7( r a Where Held F'�'-a rt-k- Giarges Case# Booking# Date to Appear Time Court Jud.Dist. Div.or Dept County Fortner Address Apt# City and State How Long Employer Address Phone Occupation Mo.Income Supervisor How long Previous Arrest Charge Court County Dates Arrested Disposition Previous Bail By Whom Amount of Bail$ On Probation? J\,o Where Probation Officer Vehicle Make Model Year Color License# Real Estate Description Value Mortgage Amount &-er,c Spouse Address City&Shd �� Home Phone Spouse's Cell Phone D.0.8 S.S.# Spouse's Employer. Address Cily&State Phone Spouse's Vehicle Make Model Year Color License# Children Names&Ages REFERENCES: Name Address Phone No. Cell Phone Relationship 4-eL LS CA Father 2. l�r C, '�1-1-iG7-Zo7 _ '�«•2 �o �{,"`� �^ Ch ofa.rl vs1r� Mother 3. YA CU- < !�f!m..Pllc I, 4-/� ov. �(rS�P P4 -Z r� q L6 I - (I z�mth 4. �, ..{ {-&t,K4� 7bra& f� 6,,-W-0-4 I-71' ? o 7-- _Friend �i{ultGSL��'v� M 19 "71"7- INDEMNfTOR NAME a Home Phone'!t7-2 S8-K U 39 Cell Phone zEE 9 Address -A cs(e A 1,7F Statezip soaal i 4e '? 7 D.L# D.O.B. ofi-(k'(`t S-f Relation to Defendarr(__V-- >`o. Employer {< S GL AS S oc,Address N ( (.re�.e c(¢PA c'?o f 3 Phone 7/7-kl 31174 Occupation -2r <1 cis n How Long _ Spouse ��' Spouse's Employer Address Occupation How Long Vehicle Make ynll C S�i o!� Model ItYear 'Z Color ✓i License# G-V--(�C�8 3 INDEMNI70R NAME: Home Phone Cell Phone Address City•Statez Social Security# D.L# D.O.B. Relation to Defendant Employer Address Phone Occupation How Long Spouse Spouse's Employer Address Occupation How Long Vehicle Make Model Year Color License# I certify thethatabove is true and correct I further understand that this is an applicaon for a type of credit and authorize a review of my credit history via petit reporting agency checks. Indemn'itor's Signature (Date) Indemnito nature (Date) Defendant's Signature (pate) SEN-334tev.4/2006 EXHIBIT "B" INDENINITY AGREEMENT FOR SURETY BAIL BOND SENECA INSURANCE COMPANY,INC. 160 Water Street,160 Floor,New York, l`New York 10038 The undersigned,called"First Party,"make application to t ca.�o.\ 'J� _ called"Second Party,"for execution by SENECA INSURANCE CO Vic.,a corporation called of a Bail Undertaking herein referred to as " l Bond"in the penal erne .t of$ �j 'ryY for k� called"Principal,"and in consideration of Second Parry arranging for execution ofcontra ce ofthis Ba Bond,Firk party ddooessiointly and severally agree as follows: FIRST: To pay Second Party S_A Y armt�(where applicable)for the Bar?Bond. The premium is fully earned upon the release of PrincipaL The fact that Defendant m e been improperly arrested or his bail reduced or his cue dismissed shall not obligate the return of any portion of said premium This bond is renewable each year if applicable to your State. First Party agrees to pay to Second Party a renewal premium in the amount stated above,twelve months after the date on which this bond was executed. If said renewal premium is not paid upon written demand,Second Party or Surety has the right to surrender Principal and exonerate the bond pursuant to state regulations. SECOND: To reimburse Second Party and Surety for actual expenses incurred by Second Party or Surety in connection with the arranging and/or execution of Bail Bond or substitution thereof whether or not said Principal refuses to be released after arrangements have been initiated by Second Party,in accordance with the regulations ofthe Insurance Commissioner in effect at the time such expenses are incurred. THIRD: To reimburse Second Party and Surety for actual expenses incurred and caused by a breach by the Principal of any ofthe terms for which the application and Batt Bond were written not in excess ofthe petal amount ofthe Bail Bond,phis any reasonable expenses or liabilities incurred as a result of searching for the recapturing or returning Principal to custody,inured by Second Party or Surety or as necessary in apprehending or endeavoring to apprehend Principal,including legal fees incurred by Second Party or Surety in making application to a court for an order to vacate or to set aside the order of forfeiture or Judgment entered.thereon. FOURTH: To pay the Second Party or Surety,in the event that it is necessary for them to institute suit for a breach of this agreement,a reasonable attorney's fees. FIFTH:To pay Second Party or Surety as collateral upon demand,the penal amount of Bail Bond whenever Second Party or Surety,as a result of information concealed or misrepresented by the First Party or Principal or other reasonable cause,any one of which was material to hazard assumed,deems payment necessary to protect the Second Party or Surety hereunder. Where,as a result of judicial action,bail has been increased, and no collateral or insufficient collateral,in the sole discretion of Second Party or Surety,is flumished to indemnify against such increase in the bail, Second Party or Surety may demand such collateral as will indemnify them against such increased bail. SIXT11 To pay Second Party or Surety immediately upon demand for any default or breach ofthe terms and conditions included herein. SEVENTH-. To aid Second Parry or Surety in securing release or exoneration of Second Party or Surety from all liability under Bail Bond, including the surrender of Principal to Court should Second Party or Surety deem such action advisable. EIGHTH: That all money or other property which the First Party has deposited or may deposit with the Second Party or the Surety may be applied as collateral stc city or indemnity for matters contained herein,and to accomplisb the purposes contained herein,the Second Party and/or Surety is authori-d to lawfully levy upon said collateral in the manner provided by law and to apply the proceeds there from and any and all money deposited to payment or reimbursement for the herein above liabilities,losses,costs,damages and expenses. If colla cr-al received by Second Party is in access ofthe bail forfeited,such excess shall be returned to the depositor immediately upon the application ofthe collateral to the forfeimM subject to any claim of Second Party and Surety for unpaid Premium or the herein above charges. NINTH: Second Party or Surety shall not surrender Principal to=tody prior to the time specified in the Bail Bond for the appearance of the Principal,or prior to any occasion when the presence ofthe Principal in Court is lawfully required,without returning all premium paid. Unless, the surrender is a result of judicial action,information concealed or misrepresented by the Principal or other reasonable cause,any one of which was material to the hazard assumed,the hazard was substantially increased the additional premium,if any,for such increased hazard was not p aid within a reasonable time. TENTH: The obligations hereunder are joint and several and any amounts due shall bear interest at the maximum rate of interest allowed bylaw. The Second Party and the Surety shall not be first obliged to proceed against the Principal on Bail Bond before having recourse against the First Party or any one of them. Prior to foreclosure,bond collateral,including any cash collateral deposited,surety will notify second party that the forfeiture has been issued and that it is the intent ofthe Surety to foreclose against any collateral taken ELEVENTH: In making application for Bail Bond,each of us warrants all statements made by him or her on this application to be true, and we agree to advise Second Party or Surety of any change,including but not limited to change of address or employment of either the Principal or of any of the Fast Party,or any other material change in circumstances,within forty-eight(48)hours after knowledge such change shall have occurred,and the First Party agrees that any failure to So notify shall be reasonable cause for the immediate surrender ofthe PrincipaL TWELFTH: The undersigned agree that these obligations apply to all other Bail Bonds executed for the same charge for which the above mentioned Bail Bond was executed,or of any charge arising out ofthe same transaction,regardless of whether said Bail Bonds are Sled before or after conviction,but not in a greater amount FURTHER,by signing below,I hereby autborize Seneca btsuranee Company.its attorney-in-:Fact orindependent history or other information required in fulfilling the obligations ofthe contractual er i contractor to obtain areport of my credit agnxtnent which we have Catered into. IN WITNESS WHEREOF,the First Party whose names are subscribed to the Indemnity Agreement executed herewith each represents:I have read the indemnity Agreement and 1 know the contents thereof;that I hereby acknowledge receipt of a copy of said Indemnity Agreement:that I am the true and lawful owner of the property,whether real or personal,which if set forth in the Application for Bail(which Application is trade a part hereof by reference as though herein fully set octet)is my p-opety and that I own such property free and clear of all liens or enermbMn=except as so noted,and I further promise not to transfer or encumber any of said property until my liability on said Indemnity Agreement has been released.i understand the Second Party and/or Surety is permitting the said bail to remain in force upon,reliance ofthe statements made by me and I do hereby Day of �f�� 200c setrayband F;A� _ Indemnttor's St (Date) Indemnity Si (Daft) Indettnitor's Signature (Date) L)ePndantXS~ Ike) EXHIBIT "C" )Ali v I all "Ile a t It 109 15 Ob a I i-4 HA a16 lit jE Po .1 to Zia EXHIBIT "D" (III�I�IIII�IIII 11 IIlll�l I�IIII�IQI�I DISTRICT COURT OF MARYLAND FOR Frederick County Located at 100 West Patrick St,Frederick,Maryland 21701 Case No.OU00058569 STATE OF MARYLAND VS. HOFFMAN, RYAN PRESTON AKA: HOFFMAN-SNffM RYAN PRES Hearing or Trial Date:06/17/2009 4424 OLD SWIMMING POOL RD 13RADDOCK HEIGHTS,MD 21714-0000 at 12:30 PM in Courtroom 03 CC#:09-49341 SID:0003415920 LID: DL#: Race:2 Sex:M Ht:6102" Wt:200 Hair.RED Eyes:BLU DOB:01/28/1984 Phone(H):240-357-1709 PhoneM: Charge I Statute I AR/Citation I CJISCode Charge I Statute I ARMitation I CJISCode ASSAULT-FIRST DEGREE I CR 3 202 1 11 1420 ASSAULT-SEC DEGREE I CR 3 203 1 11 1415 RECKLESS ENDANGERMENT I CR 3 204(a)(1)1 111425 CDS POSS W/INT TO DIST I CR 5 602 I 11 0233 CD POSSESSION-MARIHUANA I CR 5 601(ax1)1 1 1 0573 HGV USE/FEL-VIOL CRIME I CR 4204 1 115299 CDS:POSS PARAPHERNALIA I CR 5 619(c)(1)1 15 3550 CDS:POSS PARAPHERNALIA I CR 5 619(c)(1)1 15 3550 More charges on continuation page. BAIL BOND KNOW ALL PERSONS BY THESE PRESENTS: That Uwe,the undersigned,jointly and severally acknowledge that Uwe,our personal representatives,successors,and assigns are held and firmly bound unto the State of Maryland in the penalty sum of$350,000.00 (Three Hundred Fifty Thousand Dollars) with the obligation of the corporation,SENECA INS CO INC which is an insurer or other Surety in the full penalty amount. Power#S999-01222223 THE CONDITION OF THIS BOND IS that the Defendant personally appear,as required,in any court in which the charges are pending,or in which a charging document may be filed based on the same acts or transactions,or to which action may be transferred,removed,or,if from the District Court,appealed. If,however,the Defendant fails to perform the foregoing condition,this bond shall be forfeited forthwith for payment of the above penalty sum in accordance with law. IT IS AGREED AND UNDERSTOOD that this bond shall continue in full force and effect until discharged pursuant of Rule 4-217. AND the undersigned Surety covenants that the only compensation chargeable in connection with the execution of this Bond consisted of a fee,in the amount of$35,000.00. Fee,premium or service charge paid by HOFFMAN,HOLLY (address) 20 ARLINGTON DR,CARLISLE, PA 17013. AND the undersigned Surety covenants that no collateral was or will be deposited,pledged,or encumbered directly or indirectly in favor of the Surety in connection with the execution of the bond except: personal indemitor agreement RELEASE CONDITIONS: The Defendant above is subject to the following condition(s)/restriction(s): PRE-TRIAL SUPERVISION THRU PAROLE AND PROBATION NO CONTACT W/CARRIE MADDOX IN WITNESS WHEREOF,these presents have been executed under seal this 22th day of May,2009. Defendant: (SEAL) Address: (SEAL) Pers.Surety: Defendant (SEAL) Address: Surety/Ins: (SEAL) Address: /1101 tcc.Ar s By Bondsm : (SEAL) Address: s�retY Insu 3 SIGNED, ed,and acknowledged before me: PO Ye + � v No. Date: OS/� 009 Commissioner: ID:B059 For Frederick Co Tracking No'. 096034108122 DV CERTIFICATE OF SERVICE I, Rob Bleecher, Esquire, the attorney for Plaintiff, hereby certify that I have served the foregoing Complaint in Breach of Contract this date by depositing a true and correct copy of the same in the United States mail, first-class postage prepaid, addressed as follows: Holly Hoffman 20 Arlington Street Carlisle, PA 17013 Ryan Preston Hoffinan 20 Arlington Street Carlisle, PA 17013 Dated: April 23, 2013 A - Rob ee fir, squire 4