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Home My WebLink About05-0771NOTICE OF APPEAL COMMONWEALTH OF PENNSYLVANIA COURT OF COMMON PLEAS FROM JUDICIAL DISTRICT DISTRICT JUSTICE JUDGMENT COMMON PLEAS No. NOTICE OF APPEAL Notice is given that the appellant has filed in the above Court of Common Pleas an appeal from the judgment rendered by the District Justice on the date and in the case mentioned below. Tamny Walker 155 D Street 09-1-02 Carlisle PA 17013 OwTC OF aV OGM ENT )IN TKE CAS¢ OF Vl. 11) /2005 Zeplin's Security Group vs. CL41M NO. TA 19 CV-0000578-04 I i LT 19 This block will be signed ONLY when this notation is required under Pa. R.C.P.J.P. No. 1008B. This Notice of Appeal, when received by the District Justice, will operate as a SUPERSEDEAS to the judgment for possession in this case. A46N1 If appellant was Claimant (see Pa. R.C.P.J.P. No. 1001(6) in action before District Justice, he MUST FILE A COMPLAINT within twenty (20) days after filing his NOTICE of APPEAL. Signature of Prothonotary or Deputy PRAECIPE TO ENTER RULE TO FILE COMPLAINT AND RULE TO FILE (This section of form to be used ONLY when appellant was DEFENDANT (see Pa. R.C.P.J.P. No. 1001(7) in action before District Justice. IF NOT USED, detach from copy of notice of appeal to be served upon appellee). PRAECIPE: To Prothonotary Enter rule upon Zeplinl s Security Group appellee (s ), to file a complaint in this appeal -71 Name of appellee(s) (Common Pleas No. I ) within twenty (20) days after service of rule or suffer entry of judgment of non pros. 19cG?? V. Ljw w' Signature of appellant or his ttorney r agent RULE: To Zeplin's Security Group, appellee(s) Name of appellee lsl (1) You are notified that a rule is hereby entered upon you to file a complaint in this appeal within twenty (20) days after the date of service of this rule upon you by personal service or by certified or registered mail. (2) If you do not file a complaint within this time, a JUDGMENT OF NON PROS WI LL BE ENTERED AGAINST YOU. (3) The date of service of this rule if service was by mail is the date of mailing. Date: 2/11 2005 Signatur iProthen or eputV AOPC 312-84 COURT FILE TO BE FILED WITH PROTHONOTARY COMMONWEALTH OF PENNSYLVANIA r-nl InITV nG CUMBERLAND me, D"I NOI. 09-1-02 NOTICE OF JUDGMENTAA eRIPT PLAINTIFF. CIVIL CASE NAME antl ADDRESS rZEPLIN`S SECURITY GROUP 2026 MARKET STREET PO BOX 144 LCAMP HILL, PA 17011 J vs. DEFENDANT: NAME antl ADDRESS WALKER, TAMMY 155 D STREET CARLISLE, PA 17013 L DocketNo.: CV-0000578-04 Date Filed: 11/17/04 vss D, Name. Hon. ROBERT V. MANLOVE Address. 1901 STATE ST CAMP HILL, PA re?P0one. (717y 761-0583 17011-0000 ATTORNEY DEF PRIVATE : DEBRA K. WALLET 24 N 32ND ST CAMP HILL, PA 17011 THIS IS TO NOTIFY YOU THAT: Judgment: Judgment was entered for: (Name) _zRPT *1 a evnTTRTTY C'RC TTP FX7 Judgment was entered against: (Name) w TA xFR m mmy in the amount of $ 4, 1 79 _99 on El Defendants are jointly and severally liable. El Damages will be assessed on: D This case dismissed without prejudice. Amount of Judgment Subject to Attachment/42 Pa.C.S. § 8127 $ Portion of Judgment for physical damages arising out of residential lease $ (Date of Judgment) 1 /1 3 405 (Date & Time) Amount of Judgment $ 4,063.49 Judgment Costs $ 116.50 Interest on Judgment $ .00 Attorney Fees $ .00 Total $ 4,179.99 Post Judgment Credits $ Post Judgment Costs $ Certified Judgment Total $ ANY PARTY HAS THE RIGHT TO APPEAL WITHIN 30 DAYS AFTER THE ENTRY OF JUDGMENT BY FILING A NOTICE OF APPEAL WITH THE PROTHONOTARY/CLERK OF THE COURT OF COMMON PLEAS, CIVIL DIVISION. YOU MUST INCLUDE A COPY OF THIS NOTICE OF JUDGMENTITRANSCRIPT FORM WITH YOUR NOTICE OF APPEAL. EXCEPT AS OTHERWISE PROVIDED IN THE RULES OF CIVIL PROCEDURE FOR DISTRICT JUSTICES, IF THE JUDGMENT HOLDER ELECTS TO ENTER THE JUDGMENT IN THE COURT OF COMMON PLEAS, ALL FURTHER PROCESS MUST COME FROM THE COURT OF COMMON PLEAS AND NO FURTHER PROCESS MAY BE ISSUED BY THE DISTRICT JUSTICE. UNLESS THE JUDGMENT IS ENTERED IN THE COURT OF COMMON PLEAS, ANYONE INTERESTED IN THE JUDGMENT MAY FILE A REQUEST FOR ENTRY OF SATISFACTION WITH THE DISTRICT JUSTICE IF THE JUDGMENT DEBTOR PAYS IN FULL, SETTLES, OR OTHERWISE COMPLIES WITH THE JUDGMENT. U ,.Si't'...^-^........ Date Di,ttlGfJLstioe I ce ify tha this is a true acs' o py ofliha`e or pr ceeoings contiwiriTtqu puymaF L. Date If commission expires first Monday of January, 2006. ?? . AOPC 315-03 DATE PRINTED: 1/13/05 11:43:22 AM PROOF OF SERVICE OF NOTICE OF APPEAL AND RULE TO FILE COMPLAINT (This proof of service MUST HE FILED WITHIN FIVE (5) DAYS AFTER filing the notice of appeal. Check applicdWe boxes) COMMONWEALTH OF PENNSYLVANIA COUNTY OF ; ss AFFIDAVIT: hereby swoar or atf??rn [hat I served a copy of the; Notice of Appeal, Care mon Pleas No upun the Distiit,t Justice designated therein on (rla to of service; ______ I by nk'srmal service by (cernhed) (Iwo'tciedl tndil, sender's receipt attached hereto, and upon the appellee, (oanel___ __. _ ____________ on 19__ i-] by personal service, ? by (ce,Uhed) {rryistoredl all, sender's receipt attached hereto, _J and further That I served the Rule to File a Complaint accompanying the above Notice of Appeal upon the appellee(s) to whom the Rule was addressed on by personal service [ j by (certified) {rrgistooal) mail, sender's receipt attached hereto. SWORN (AFFIRMED) AND SUBSCRIBED BEFORE ME THIS DAY OF 19- Signature o( '!tram Signature of offic,a) before whom affidavit uvas made TWO of official My commission expires on , 19_. COMMONWEALTH Of PENNSYLVANIA COURT OF COMMON PLEAS JUDICIAL DISTRICT NOTICE OF APPEAL Notice is given that the appellant has filed in the above Court of Common Pleas an appeal from the judgment rendered by the District Justice on the date and in the case mentioned below. cefffry WaI!??r 1H D NOTICE OF APPEAL FROM DISTRICT JUSTICE JUDGMENT COMMON PLEAS No. C-?:) 5 -- 7' 1 m_019-? -02 Car! :iF:I- PA once ov mocmeN. ,rv nee cnse of in?,,,.,.?r ;., 13/2;0` 7C Ilil c :iECU :i Y Groutp 'J TA 19 (:7,7-0000578-04 LT 19 De ''}j a 17013 This block will be signed ONLY when this notation is required under Pa. R.C.P J.P. No. 10088. This Notice of Appeal, when received by the District Justice, will operate as a SUPERSEDEAS to the judgment for possession in this case. If appellant was Claimant (see Pa. R.C.P.J.P. No. 7007(6) in action before District Justice, he MUST FILE A COMPLAINT within twenty (20) ' days after filing his NOTICE of APPEAL. Signature of Prothonotary or Deputy PRAECIPE TO ENTER RULE TO FILE COMPLAINT AND RULE TO FILE l7hrs section of form to be used ONLY when appellant was DEFENDANT(see Pa. R.C.P.J.P. No. 1007(7) in action before District Justice. IF NOT USED, detach front copy of notice of appeal to be served upon appellee). PRAECIPE: To Prothonotary Enter rule upon ,3ep3 in's ,`iecuri ty OrotJp I appellee(sl, to file a complaint in this appeal Name of appelleeW (Common Pleas No. ?_ ??r I within twenty (20) days after service of rule or suffer entry of judgment of non pros. Signature of appellant or hi att,,., orrt -or agent 1U LE: To 7epl n`s Security =rot7{? appellee(s) Name of appellee W (1) You are notified that a rule is hereby entered upon you to file a complaint in this appeal within twenty (20) days after the date of rvice of this rule upon you by personal service or by certified or registered mail. (2) If you do not file a complaint within this time, a JUDGMENT OF NON PROS WILL BE ENTERED AGAINST YOU. (3) The date of service of this rule if service was by mail is the date of mailing. 2/? 1 2005 ?c1 (?Q? ,.yam ??4 te: ,xGg-._? F ?f( Signatur (Prothon a a Deputy V 312-84 COUR-I FILE PROOF OF SERVICE OF NOTICE OF APPEAL AND RULE TO FILE C,ON1PL4,INi1 (This proof of service MUST-' Ft',' If) COMMONWEALTH OF PENNSYLVANIA COUNTY OF CUMBERLAND AFFIDAVIT: II++:ro, „, a copy o{ 11 r..Cc r..?p-., , + , , 05-771 Noteolsmi ?+ 2/11q 2005 X 11 rcroihl nl1.u +,? i. r. Zeplin'5 Security GLOUFJ 2/11 _ xk 2005, X ,vhom ?n, 2/11 i 2005 X mail, seride? s o dpi dt4u 1 -rl hrro!c SWORN (AFFIRMED) AND SUBSCR7BL D rJ (i+'+ THIS__ tt' _ DAY OF -1'Y)WL .? - c, . Signature1of oft) 4-11 bclmc whn r . H Cl a-ia w + ..u. NOCGr _j?(,r?j{?L Title at official _.. COMMONWEALTH OF PENNSYLVANIA Notarial Seal Mary M. Loper, Notary Pub1c Carne HM Boro. Cumberland Cmity My Commission Expires Old 27, 2007 Member, Pennsylvania Association Of Notaries r. 1. i ct. ZEPLIN'S SECURITY GROUP, INC., IN THE COURT OF COMMON PLEAS : CUMBERLAND COUNTY, PENNSYLVANIA Plaintiff, V. : NO. 05-771 CIVIL ACTION - LAW TAMMY WALKER, 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) days after this Complaint and notice are served, by entering a written appearance personally or by attorney and filing in writing with the Court your defenses or objections to the claims set forth against you. You are warned that if you fail to do so the case may proceed without you and a judgment may be entered against you by the Court without further notice for any money claimed in the Complaint or for any other claim or relief requested by the Plaintiff. You may lose money or property or other rights important to you. YOU SHOULD TAKE THIS PAPER TO YOUR LAWYER AT ONCE. IF YOU DO NOT HAVE A LAWYER OR CANNOT AFFORD ONE, GO TO OR TELEPHONE THE OFFICE SET FORTH BELOW TO FIND OUT WHERE YOU CAN GET LEGAL HELP. CUMBERLAND COUNTY BAR ASSOCIATION 2 LIBERTY AVENUE Carlisle, PA 17013 (717) 249-3166 NOTICIA Les han demandado a usted en la corte. Se usted guiere defenderse de estas demandas expuestas en las paginas siguientes, usted tiene viente (20) dias de plazo al partir de la fecha de la demanda y la notificacion. Usted debe presentar una apariencia escrita o en persona o por abogado y archhivar en la corte en forma escrita sus defensas o sus objeciones a las demandas en copra de su persona. Sea avisado qui si usted no soe defiende, la corte tomara mmedidas y purde entrar una orden contra usted sin previo aviso o notoficacion y pro cualquier queja o ah%rio que es pedido en la peticion de demanda. Usted puede perder dinero o sus propiedades o otros derechos importantes para usted. LLEVE ESTA DEMANDO A UN ABODAGO IMMEDIATEMENTE. SI NO TIENE ABOGADO O SI NO TIENE EL DINERO SUFICIENTE DE PAGAR TAL SERVICIO, VAYA EN PERSONA O LLAME FOR TELEFONO A LA OFICIAN CUYA DIRECCION SE ENCUENTRA ESCRITA ABAJO PARA AVERIGUAR DONDE SE PUEDE CONSGUIR ASISTENCIA LEGAL. CUMBERLAND COUNTY BAR ASSOCIATION 2 LIBERTY AVENUE Carlisle, PA 17013 (717) 249-3166 ZEPLIN'S SECURITY GROUP, IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA Plaintiff, v. NO: 05-771 CIVIL TERM CIVIL ACTION - LAW TAMMY WALKER Defendant. COMPLAINT AND NOW, comes the Plaintiff, Zeplin's Security Group, by and through its attorneys, Mancke, Wagner & Spreha, and files the following Complaint: 1. The Plaintiff, Zeplin's Security Group, is a Pennsylvania corporation having as a business address 2026 Market Street, P.O. Box 144, Camp Hill, Cumberland County, Pennsylvania. 2. The Defendant, Tammy Walker, is an adult individual with an address of 155 D Street, Carlisle, Cumberland County, Pennsylvania. 3. At all times pertinent hereto, the Defendant was an employee of the Plaintiff. 4. At all times pertinent hereto, the Plaintiff was anticipating the We of part of his business, which if sold, could have adversely effected the continued employment of the Defendant herein. WHEREFORE, Plaintiff requests the Court to grant judgment in the amount of $9,225.79, together with costs and interest. Respectfully submitted, Mancke, Wagner & Spreha -7 By G _ ,-Rwhgd Wagner, Esquire I.D. 423103 2233 North Front Street Harrisburg, PA 17110 (717) 234-7051 Attorneys for Plaintiff Date: A -3- I verify that the statements made in the foregoing document are true and correct. I understand that false statements herein are made subject to the penalties of 18 Pa.C.S. Section 4904, relating to unsworn falsification to authorities. ""Ozr -- DATE: ???VzC )- ?, ?, ?? =L -,? -; IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA ZEPLIN'S SECURITY GROUP, INC Plaintiff V. No. 05-771 Civil Action - Law TAMMY WALKER, Defendant NOTICE TO PLEAD TO: Zeplin's Security Group, Inc. You are hereby notified to file a written response to the enclosed AND NEW MATTER within twenty (20) days from service hereof or a judgment may be entered against you. Debra K. Wallet, Esquire 24 N. 32nd Street Camp Hill, PA 17011 I. D. # 23989 (717) 737-1300 Attorney for Tammy Walker IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA ZEPLIN'S SECURITY GROUP, INC Plaintiff V. No. 05-771 Civil Action - Law TAMMY WALKER, Defendant ANSWER AND NEW MATTER Defendant, Tammy Walker, by and through her attorney, Debra K. Esquire, answers the Complaint as follows: ANSWER 1. ADMITTED. (It is believed that proper corporate name is " leplin's Security Group, Inc.") - 2. ADMITTED. 3. ADMITTED in part and DENIED in part. It is ADMITTEqj that Defendant Tammy Walker [hereinafter Walker] was an employee of Plainti? Zeplin's Security Group, Inc. [hereinafter Employer] until she was fired by Fred W [hereinafter Zeplin] on November 9, 2004. For certain times pertinent to complaint, Walker was not an employee of Employer. 4. ADMITTED. 5. DENIED. It is denied and legally impossible for an incorporated entity to have had any "oral understanding" with Walker. To the extent that contends that a discussion occurred between Walker and Zeplin, Walker admis that Zeplin told Walker he was selling the business. Walker specifically denies al "oral understanding" between Walker and Employer. Walker specifically denies tj# t Zeplin described the payment of money as anything other than a bonus. By way of answer, Zeplin told Walker that he was paying her additional sums of moneyllas a bonus to compensate her if the business were to be sold and she lost her job. Zepli? also told Walker that a further benefit of the sale would be that she could collect compensation when she lost her job. 6. DENIED. It is specifically denied that any oral understanding occurred between the parties that this "bonus" would "have to be returned." There Is no consideration for the payment of the bonus and thus there was no oral 7. It is ADMITTED that the sale of the business did not occur (#i or before November 9, 2004, the date of Walker's termination by Employer. W information or knowledge about whether the business was sold at some further ADMITTED that Zeplin terminated Walker, but the date was November 8, 2004. 8. It is ADMITTED that Zeplin requested the "return" of $9 that Walker has refused to return any money paid to her. It is DENIED received $9,000. It is further DENIED that the return of any pay was a nas no time. It is fiber 9, not ).00 and Walker of some "oral understanding." 9. To the extent that this averment represents a CONCLUSION Of LAW, it is DENIED that there was any contract between Walker and either Employer or Zeplin. To the extent that it may be deemed factual, it is DENIED that any understanding or agreement was made between Employer and Walker or Zeplin and Walker. It is specifically DENIED that Walker has any obligation or legal i to return any money paid to her by Employer. NEW MATTER 10. Walker was an employee-at-will of Employer. 11, In an employment-at-will state, such as Pennsylvania, the la\ ?Jdoes not recognize oral agreements between employees and employer unless they specific promises concerning continued work in exchange for specific 12. Employer made no promises to Walker about continued 13. Zeplin made no promises to Walker about continued work. 14. Zeplin told Walker that after the business was sold she would have no work. 15. The money paid by Employer to Walker, over and above hek regular salary, was described to Walker by Zeplin as a "bonus." 16. Zeplin paid himself a bonus of $10,600.97 at the same time(Walker received the payments. 17. Zeplin paid another employee, Sonata Tsoukatos, a bonus ! the same time Walker and Zeplin received the payments. 18. Walker received the gross sum of $ 3,075.26 in each of three 19. Walker paid her employee share of tax on the full amount of th? bonus received. 20. After the deduction of taxes, Walker actually received $ 6,925 21. The 2004 W-2 statement prepared by Employer and sent to W included these sums as wages paid during tax year 2004. 22. At a prior hearing in this matter, Zeplin testified under oath "t the approximately $9,000.00 represented salary paid to Walker for the months op October, November, and December, 2004. 23. At a prior hearing in this matter, Zeplin testified under oath t*at the $9,000.00 represented salary paid to Walker for her agreement to continue until the business was sold. 24. If the alleged agreement was that the money would be paid btk if the business did not sell during 2004, then Walker made no promise and the agreement was without consideration. 25. If the alleged agreement was that the money would be paid *ck if the business did not sell during 2004, then Walker had no control over the salelland the alleged agreement was no agreement at all. 26. Walker worked through early November and was paid her salary until her termination, with the exception of the final week of pay. 27. At no time after October 1, 2004, did Employer cease paying Walker on the theory that she had already been paid for this same period of time. 28. Employer refused to pay Walker for all of the time worked durog the final week of her employment. 29. When Walker complained about Zeplin's reduction of her pay, ?he was fired by Zeplin. 30. Walker had no understanding, oral or otherwise, that she woul# have any obligation to return any portion of the bonus for any reason. 31. Even if an oral contract existed, which Walker specifically Employer's action of terminating Walker effectively prevented her from con*leting her alleged promise of working until the business was sold. 32. Zeplin turned down at least one offer to buy his business in 33. As a matter of law, one party to a contract cannot collect for performance of the contract when his own actions prevented the 34. Employer's bringing of this action was arbitrary, vexatious, qk in bad faith and Walker is therefore entitled to a reasonable counsel fee as part of t?xable costs of this matter, pursuant to 42 Pa. C.S.A. §2503(9). WHEREFORE, Defendant Tammy Walker respectfully requests grant judgment in her favor and against Plaintiff, together with all costs, reasonable attorney's fee. Debra K. Wallet, Esquire 24 N. 32nd Street Camp Hill, PA 17011 I.D. # 23989 (717) 737-1300 Attorney for Tammy Walker the Court a IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA ZEPLIN'S SECURITY GROUP, INC Plaintiff V. No. 05-771 Civil Action - Law TAMMY WALKER, Defendant VERIFICATION I verify that the statements made in the foregoing document are true ?nd correct to the best of my knowledge, information and belief. I understand that made herein are made subject to the penalties of 18 Pa. C. S. §4904, relating to unsworn falsification to authorities. `i(NV?? _MAtA+ 2L, 2005' DATE TAMMY W IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA ZEPLIN'S SECURITY GROUP, INC., Plaintiff V. No. 05-771 Civil Action - Law TAMMY WALKER, Defendant PROOF OF SERVICE I, Debra K. Wallet, Esquire, hereby certify that on March 22, 2005, true and correct copy of the ANSWER AND NEW MATTER by first-class postage pre-paid, addressed as follows: P. Richard Wagner, Esquire MANCKE, WAGNER & SPREHA 2233 North Front Street Harrisburg, PA 17110 X.h? 1l• wixuw Debra K. Wallet, Esquire 24 N. 32nd Street Camp Hill, PA 17011 I.D. # 23989 (717) 737-1300 Attorney for Tammy Walker served a n r_ ? n - : , =re Ky "'.U' ?, ? '? .. -. ?Y: r'1 i Z> ."AJ ? T Il?r O T ? to ail 7 .?" ?.? +1 ?I ZEPLIN'S SECURITY GROUP, INC., Plaintiff V. TAMMY WALKER Defendant IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA NO.: 05-771 CIVIL TERM CIVIL ACTION - LAW ANSWER TO NEW MATTER AND NOW, comes the Plaintiff, by and through his attorneys and files the following Answer to New Matter. 10. Admitted. 11. Admitted. 12. Admitted. 13. Admitted. 14. It is denied that Zeplin told Walker that after the business was sold she would have no work. 15. Denied in part. It is admitted that money was paid to Walker, however it was Walker as bookkeeper who described the payment as a bonus and she as the bookkeeper marked it as a bonus. 16. Admitted. It is admitted that there was $10,600.97 paid to Zeplin and it is admitted that Walker as the bookkeeper characterized it as a bonus. r 17. It is admitted that another employee was paid. It is further admitted that Walker as bookkeeper marked the payment as a bonus. 18. Admitted. 19. Admitted. 20. Admitted. 21. Admitted. 22. Admitted in part. It is admitted that Zeplin testified under oath that salary was paid to Walker for months during which it was anticipated that Walker may not have a job if the business was sold during that time period and the payment represented an advance of her salary in case the business got sold, however said business did not get sold as anticipated. 23. Denied. It is denied that Zeplin testified under oath that the money represented salary paid to Walker for her agreement to continue working until the business was sold. 24. Denied. It is denied that Walker made no promise, and it is further denied that there is no consideration. Consideration was for Walker to be paid if the business was sold during the time which she then would not have a job. Because the business did not sell, Walker retained a benefit as well as her regular salary. -2- J 25. Denied. It is denied that the lack of control by Walker makes any agreement null and void or abrogates the agreement that the parties had. 26. Admitted. It is admitted that Walker worked through early November and was paid her salary in addition to the aforementioned advance which renders an unjust enrichment to Walker. 27. Denied. It is denied that the employer ceased paying Walker, the employer ceased paying Walker in early November 2004 and is now attempting to recoup that advance that is set forth herein above. 28. Denied. It is denied employer refused to pay Walker for all the times she worked during the final week of her employment. 29. Denied. It is denied that Walker complained about the reduction in pay and it is further denied that she was fired as a result of any Complaint about her reduction in pay. 30. Denied. It is denied that Walker had no understanding that she would be obligated to return a portion of the advance paid to her. 31. Denied. It is denied that the employer took any action that prevented Walker from completing her alleged promise of returning the advance if the business was not sold. 32. Admitted. 33. No answer is required as it is a statement of law which the Plaintiff disputes as being accurate. -3- 34. Denied. It is denied that the employer's bringing of this action was arbitrary, vexatious, or in bad faith and it is further denied that Walker is entitled to reasonable counsel fees. WHEREFORE, Plaintiff requests the Court to dismiss the New Matter of Walker. submitted: P. Rich-ardWagner, Esquire ID #23103 2233 North Front Street Harrisburg, PA 17110 (717) 234-7051 -4- J VERIFICATION I verify that the statements made in the foregoing document are true and correct. I understand that false statements herein are made subject to the penalties of 18 Pa.C.S. Section 4904, relating to unsworn falsification to authorities. DATE: J ?n -YI t' aJ? ]v. T -? ?f'.. ,:J ?YY1 ?. t~1 ?? ?. ).?] ,S1 _?- JI r? > , ?{ t n ,.L ..-. Curtis R. Long Prothonotary OtfiCC of the i3rotbonotarp CumbPrfaub uCountp Renee K. Simpson Deputy Prothonotary John E. Slike Solicitor as - 17[ CIVIL TERM ORDER OF TERMINATION OF COURT CASES AND NOW THIS 29TH DAY OF OCTOBER 2008 AFTER MAILING NOTICE OF INTENTION TO PROCEED AND RECEIVING NO RESPONSE - THE ABOVE CASE IS HEREBY TERMINATED WITH PREJUDICE IN ACCORDANCE WITH PA RCP230.2 BY THE COURT, CURTIS R. LONG PROTHONOTARY One Courthouse Square • Carlisle, Pennsylvania 17013 • (717) 240-6195 • RaV r7»-