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Home My WebLink About02-4291DAUPHIN ASSOCIATES, INC. 1830 South 19th Street Harrisburg, PA 17104 Plaintiff GRANT ELECTRICAL CONTRACTING, INC. 610 Alexander Spring Road Carlisle, PA 17013 Defendant IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL ACTION - LAW NO. 0o'~'- 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 / (800) 990-9108 Date: September 9, 2002 KEEFER WOOD ALLEN & RAHAL, LLP Eugen"~lc. Pepinsky, Jr. Attorney I.D. #23702 210 Walnut Street P.O. Box 11963 Harrisburg, PA 17108-1963 (717) 255-8051 Attorneys for Plaintiff DAUPHIN ASSOCIATES, INC. 1830 South 19th Street Harrisburg, PA 17104 Plaintiff GRANT ELECTRICAL CONTRACTING, INC. 610 Alexander Spring Road Carlisle, PA 17013 Defendant IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CiVIL ACTION -LAW NO. NOTICIA Le han demandado a usted en la code. Si usted quiere defenderse de estas demandas expuestas en las paginas siguientes, usted tiene viente (20) dias de plazo al padir de la fecha de la demanda y la notificacion. Usted debe presentar una apariencia escrita o en persona o por abogado 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 code tomara medidas y puede entrar una orden contra usted sin previo aviso o notificacion y por cualquier queja o alivio que es pedido en la peticion de demanda. Usted puede perder dinero o sus propiedades o otros derechos importantes para usted. LLEVE ESTA DEMANDA A UN ABODAGO INMEDIATAMENTE. SI NO TIENE 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 ABA JO PARA AVERIGUAR DONDE SE PUEDE CONSEGUIR ASISTENCIA LEGAL. CUMBERLAND COUNTY BAR ASSOCIATION 2 Liberty Avenue Carlisle, PA 17013 (717) 249-3166 / (800) 990-9108 Date: September 9, 2002 KEEFE~LLEN & RAHAL, LLP By: Eugene'S. Pepinsky, Jr. Attorney i.D. #23702 210 Walnut Street, P.O. Box 11963 Harrisburg, PA 17108-1963 (717) 255-8051 Attorneys for Plaintiff DAUPHIN ASSOCIATES, INC. 1830 South 19th Street Harrisburg, PA 17104 Plaintiff GRANT ELECTRICAL CONTRACTING, INC. 610 Alexander Spring Road Carlisle, PA 17013 Defendant IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL ACTION - LAW NO. 0,2 - Date: September 9, 2002 COMPLAINT 1. The parties and their address(es) are set forth in the caption. 2. At the instance and request of Defendant, Plaintiff sold and delivered to Defendant, which received, accepted and used certain materials and services as more fully referenced in the true and correct copy of Plaintiff's business records hereto attached as Exhibit A. 3. The sums charged for the same were: (a) what the Defendant(s) agreed to pay therefor; and (b) the fair, reasonable and market value thereof. 4. Despite demand, the balance remains unpaid. WHEREFORE, judgment is demanded of Defendant for $22,942.01, plus service charges (interest) as hereafter accrue, costs of suit and attorney's fees. KEEFER WOOD ALLEN & RAHAL, LLP By: Eu~~. ~epinsky, ,Jr. Attorney I.D. #23702 210 Walnut Street, P.O. Box 11963 Harrisburg, PA 17108-1963 (717) 255-8051 Attorneys for Plaintiff -2- $E?-0~'200~ OI:20P~ +717986D385 T-305 P ~02/007 , F-Ogl The undersigned Lynn Raver, hereby vedfles and states that: 1. He is Credit Manager of Dauphin Associates, Inc., Plaintiff herein; 2. He is authorized to make this Verification on its behalf; 3. The facts set forth in the foregoing Complaint are true and correct to the best of his knowledge, information and belief; and 4. He is aware that false statements herein are made subject to the penalties of 18 Pa. C.S. § 4904, relating to unsworn falsification to authorities. Dated: September 9, 2002 Lynn Raver ~--" ~' SE~OS'ZOOZ' 01:ZOPM FRO~CED HBG CREDIT OFEICE D&uphgn Elec%ri~ STATEMENT l)auphin l)aaCom · +Tl79869383 T-305 P.003/007 . F-Ogl 06-5e~-02 .1.4:34 ReL':0252/.02 2/~, AMOUMT F. NCLOSE~ I FEDERAL TAX ID~: 23-0610520 +?17986938J $EP-09-2002' OI:ZOPM FROM-CED HBG CREDIT 0FEICE Da, uph'i n Elec~rlc STATEMENT Dauphin l)mCom · +?17[$6g$83 ?1305 P 004/007 O(~-S~D-O2 14:34 Re£:02~2102 AMOUNT ~-.NCLOSED I 0023 't nvoloe 0208r12-21E]203 22.14 351.31 23.47 3/10/02 .22- 27,98 3/10/D2 .2~- 2B2,28 233.05 4/1~/02 2.21- SEr~-O¢~-2002' 01:20P~ FROM-CEO HBG CREDIT 0FEICE D&upl~n STATEMENT Dauphin DalaCom · +717986g$8~ T-~0$ P~00$/00?. F-0gl 0~-S~D-02 14:34 R~£:0252102 AMOUNT ENCLOSED FEDERAL TAX ID'~: 23-D~10S20 PA.fiT DO5 INVOICE TOT,~L. .. - ............ ................................. ~ .................................................. 20,233.63 ........................................................ 20,233,63 +7179869585 $EP-09-2002 01:21PM FROM-CED HBG CREDIT OFEICE STATEMENT +71~'981;g383 T-305 P 00~/00~* F-091 O6-Sep-02 .t4:37 Re£:025210~. 2/2 I_AMOUNT ENCLOSED FEDERAL TAX ID~ 23-0510S20 .oo 4.99 ................................................ 264,29 +'71 FROM-CED HBG CREDtT OFEfCE +7]79869383 DAUPHIN ELECTRIC GRANT ELECTRIC 60 ALEXA/wqDR SPRNG RD CARLISLE, PA 17013 STATEMENT LOCATION 4160 -- LEGEND CDC Casll Disc COR Correc~ion AGE DATE REFERENCE 90 11/26/01 4160-411990 90 11/26/01 4160-412058 90 11/26/01 4160-412060 90 11/26/01 4160-412061 90 01/07/02 4160-414894 90 02/26/02 SVC 4160-865745 90 03/26/02 SVC 4160-867917 90 04/26/02 SVC 4160-869953 60 05/26/02 SVC 4160-871992 DISCOUNT T-305 P .007/007. F-OOf 9AGE 1 ACCOUNT NO. DATE 02-39360 09/09/02 CHARGES CREDITS -- 34.23 1,836.19 .00 1.15 60.91 .00 1.74 92.04 .58 30.66 .00 5.40 285.98 .00 · 00 34.58 .00 .00 34.58 .00 .00 34.58 .00 .00 34.58 .O0 Status of Account Current 30 Days 60 Days 90 Days .00 .00 34.58 2,409.52 Balance Due 2,444.10 SHERIFF'S RETURN CASE NO: 2002-04291 p COMMONWEALTH OF PENNSYLVANIA: COUNTY OF CUMBERLAND DAUPHIN ASSOCIATES INC VS GRANT ELECTRICAL CONTRACTING I REGULAR BRYAN WARD Sheriff or Deputy Sheriff of Cumberland County, Pennsylvania, who being duly SWorn according says, the within COMPLAINT & NOTICE was served upon GRANT ELECTRICAL CONTRACTING INC to law, DEPENDANT at 152~2:0~ HOURS, at 610 ALEXANDER SPRING ROAD the on the !2t~ day of S~tember, 2002 CARLISLE, PA 17013 ALAN UNGER, PRESIDENT by handing to a true and attested copy of COMPLAINT & NOTICE together with and at the same time directing ~is attention to the contents thereof. Sheriff,s Costs: Docketing 18.00 Service Affidavit 3.45 .00 Surcharge 10.00 .00 31.45 Sworn and Subscribed to before me this ~2~- day of o /13/2oo2 KEEPER WOOD ALLEN RAHAL By: ~ IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA DAUPHIN ASSOCIATES, INC., Plaintiff VS. GRANT ELECTRICAL CONTRACTING, INC., Defendant CIVIL ACTION - LAW NO. 02-4291 ANSWER The Answer of Grant Electrical Contracting, Inc., a Pennsylvania corporation, by and through its counsel, Cunningham & Chemicoff, P.C., to the Complaint filed by Dauphin Associates, Inc. is as follows: 1. Admitted. 2. The averments contained in Paragraph 2 represent conclusions of law to which no response is required and the averments are therefore denied. If and to the extent it is later judicially determined that an answer is required, then Defendant specifically denies that the business records attached to Plaintiff's Complaint as Exhibit "A" represent evidence supporting the avermems contained in Paragraph 2 as such documems appear to be nothing more than self- serving invoices generated by the Plaintiff which are not signed or acknowledged by Defendant Grant Electrical Contracting, Inc., or any agent thereof. Strict proof of the averments contained in Paragraph 2 is demanded, if relevant, at time of trial. 3. The averments contained in Paragraph 3 represent conclusions of law to which no response is required and the averments are therefore denied. If and to the extent it is later judicially determined that an answer is required, then Defendant specifically denies agreeing to pay Plalntiffthe sums set forth in Plaintiff's Complaint. Strict proof thereof is demanded, if relevant, at time of trial. As further answer, Defendant herein incorporates its answer to Paragraph 2 of Plaintiff's Complaint by reference as if more fully set forth. 4. Defendant specifically denies owing the sums set forth in Plaintiff's Complaint and strict proof thereof is demanded, if relevant, at time of trial. WHEREFORE, Defendant Grant Electrical Contracting, Inc. respectfully requests this Court enter an Order dismissing Plaintiff's Complaint with prejudice and further awarding Defendant all such other relief as is just and proper. Date: Respectfully submitted, Henry W. V[~ E~k, Esquire Attorney 1.1M#83087 2320 N. Second Street P.O. Box 60457 Harrisburg, PA 17106-0457 (717) 238-6570 i8/11/2882 ~2:49 7i72432799 GRANT ELECTRIC PAGE 85 foresoin~ ~rs ia the ~swcr ~e t~e ~d ~ to ~e b~t of my ~w~Se, info~a~n ~ b~e~ I u~ ~t ~y t~se state--ts ~n ~de a~ ~bj~t to the p~ti~ of l 8 Pa, C.S.~ ~904, r~a~g to un.om ~dfi~n tO ~fles. TOTAL P, 1~5 0CT-11-2002 16:15 7172432799 99% P.05 CERTIFICATE OF SERVICE I, Henry W. Van Eck, Esquire, do hereby certify that a true and correct copy of the ANSWER was placed in the United States Mail, postage pre-paid in Harrisburg, Pennsylvania on this date, on the following: Eugene E. Pepinsky, Jr. 210 Walnut Street P.O. Box 11963 Harrisburg, PA 17108-1963 Date: Respectfully submitted, CUNNINGHAM & CHERNICOFF, P.C. 2320 North Second Street P.O. Box 60457 Harrisburg, PA 17106-0457 (717) 238-6570 DAUPHIN ASSOCIATES, INC., Plaintiff VS, GRANT ELECTRICAL CONTRACTING, INC., Defendant IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA NO.: 02-4291 CIVIL 2002 AMENDED ENTRY OF APPEARANCF TO THE PROTHONOTARY: Please enter the appearance of Donald M. Lewis III, of Keefer Wood Allen & Rahal, LLP, on behalf of plaintiff, Dauphin Associates, Inc. in the above matter, along with the appearance of Eugene E. Pepinsky, Jr., previously entered in this matter. A single copy of all items sent to Mr. Lewis alone will be sufficient. Respectfully submitted, KEEFER WOOD ALLEN & RAHAL, LLP Dated: October 24, 2002 By ~" UGF, blE'E. PEPINSKY, JR. Attorney I.D. #23702 DONALD M. LEWIS III Attorney I.D. #58510 210 Walnut Street P.O. Box 11963 Harrisburg, PA 17108-1963 (717) 255-8051 and -8038 Attorneys for Plaintiff CERTIFICATE OF SERVICE I, Donald M. Lewis III, Esquire, one of the attorneys for plaintiff, Dauphin Associates, Inc., hereby certify that I have served the foregoing paper upon counsel of record this date by depositing a true and correct copy of the same in the United States mail, first-class postage prepaid, addressed as follows: Henry E. Van Eck, Esquire 2320 North Second Street P.O. Box 60457 Harrisburg, PA 17106-0457 Dated: October 24, 2002 KEEFER WOOD ALLEN & RAHAL, LLP ~ Lewis III DAUPHIN ASSOCIATES, INC., Plaintiff VS. GRANT ELECTRICAL CONTRACTING, INC., Defendant IN TIlE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA NO.: 02-4291 CIVIL 2002 .PETITION FOR APPOINTMENT OF ARBITRATORS TO THE HONORABLE, THE JUDGES OF SA/D COURT: Donald M. Lewis llI, counsel for the plaintiff in the above action, respectfully represents that: 1. The above-captioned action is at issue. 2. The claim Of the plaintiff in the action is $22,942.01, plus accrued service charges (interest) and attorney's fees and other costs. Defendant has not asserted a counterclaim. The following attorneys are interested in the case as counsel or are otherwise disqualified to sit as arbitrators: Donald M. Lewis ffl, Eugene E. Pepinsky, Jr., Henry W. Van Eck. WHEREFORE, your petitioner prays your Honorable Court to appoint three (3) arbitrators to whom the case shall be submitted. Respectfully submitted, KEEFER WOOD Al ] ~EN & RAHAL, LLP Dated: October ,2~ ,2002 EUG~_J~E. PEPINSKY, JR. Attorney I.D. #23702 DONALD M. LEWIS m Attorney I.D. #58510 210 Walnut Street P.O. Box 11963 Harrisburg, PA 17108-1963 (717) 255-8051 and -8038 CERTIFICATE OF SERVICE I, Donald M. Lewis I1/, Esquire, one of the attorneys for plaintiff, Dauphin Associates, Inc., hereby certify that I have served the foregoing paper upon counsel of record this date by depositing a tree and correct copy of the same in the United States mail, first-class postage prepaid, addressed as follows: Henry E. Van Eck, Esquire 2320 North Second Street P.O. Box 60457 Harrisburg, PA 17106-0457 Dated: October ~}/, 2002 KEEFER WOOD AI J.~N & RAHAL, LLP ~Lewis ll/ DAUPHIN ASSOCIATES, INC., Plaintiff VS. GRANT ELECTRICAL CONTRACTING, INC., Defendant IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA NO.: 02-4291 CIVIL 2002 ORDER OF COURT AND NOW, this , ~'~.5 r~day of (.~7~, f the foregoing petition, ~ /~z:~r.~ ~/~d//~J~J ~~_'~/ ,Esq.,and are appointed arbitrators in the above-captioned action as prayed for. ,2002, in consideration of , Esq., BY THE COURT: O'A"~'.Z In The Court '.of Common Pleas of C,~.herland County, Pennsylvania We do solemnly swear (or affirm) that wa will support, obey and defend the Constitution of the United States and the Constiru~.~on. of this Common- wealth and that we will discharge the duties of We, the undersigned arbitrators, having been duly appointed and sworn (or.affirmed), make the follo~-inE award: (Note: .If damages for delay are awar4ed, they shall be separately stated.) applicable.) Date of Hearing:~ Date of Award: . Arbitrator, dissents. (Inseru name if NOTICE OF KNTRY OF AWARD Now, the :z~'-c-~day ,,, of , ~3, a~?;0~ ,, ~__._WH., the above award was entered upon th nd notice thereof given b7 mail to =he parties or their Arbitrators' compensation to be paid upon appeal: $ ~ ~?0. ~ By: W P~6thono tary Depuzy Dauphin Associates, Inc. Plaintiff . v. Grant Electrical Contracting, Inc. Defendent IN THE COURT OF COM~.0N P~AS CI~ERLA~ COU%~TY, PE2~_VLVA~UL& ~To. 02-4291 NOTICE OF APPF~L FROM AWARD OF BO~ OF ARBITRATORS TO ~ PROTHONCT~RY: Notice is given t~hat Grant Electrical COntracting, {~a!s the aw~d of t~ bo~d of' ~bitr~tors ente~d ~ this case on February 18, 2003 . A J~y t~i~. Is deeded ~ . (~.eakk box if a J~y tri~ de~ded. ~he~se J~. tri~ is ~i~ed.) I ~by ce~ify that (1) th~ co~ensatfon of ~the &~bitrators D~s been oaid, or ~ application ~S been ~de' for permission to proceed fo= pauperisJ~ (Stri!~ out~ Luapp!icab!e clause.) Appe~l~t (k Attorney z.or ApPe=~t N~: T~. de~d for J~ trial on a~ from com~so~.~bitration is g~ed by ~e lO07.1 (b). (b) No affidavit or ~rification is ~~ed. PRAECIPE FOR LISTING CASE FOR TRIAL (Must be typewritten and submitted in duplicate) TO THE PROTHONOTARY OF CUMBERLAND COUNTY Please list the following case: (Check one) ( ) for JURY trial at the next term of civil court. ( ~X ) for trial without a jury. CAPTION OF CASE (entire caption must be stated in full) Dauphin Associates, Inc. (check one) (X) Assumpsit ( ) Trespass Trespass (Motor Vehicle) (Plaintiff) VS. Grant Electrical Contracting, Inc. VS. (Defendant) ( ) (other) The trial list will be called on June 10, 2003 and Trials commence on July 7, 2003 Pretrials will be held on June 18~ 2003 (Briefs are due 5 days before pretrials.) (The party listing this case for trial shall provide forthwith a copy of the praecipe to all counsel, pursuant to local Rule 214-1.) No. 02-4291 Civil ........... xl~c. 2_002 Indicate the attorney who will try case for the party who files this praecipe: ._D_o__n~_ld__.M .... L_e..w._i.s III Keefer Wood Allen & Raha_i~_LLP, PO Box 11963, H~[ris~u~rg~_[A._..27108__-.l_963. ........... Indicate trial counsel for other parties if known: H___enry__E ..... V_a_n_.E_ck,_._E. squir, e ............ 2320 North Second Street, P.O. Box 60457 ................................. Harrisburg, PA 17106-0457 ............................... This case is ready for trial. Signed: _~_ _~ Print Name: _.~ .~Le_wis_, _III Attorney for: ~'_lai_n._t.iff Date: May 13, 2003 DAUPHIN ASSOCIATES, INC. V. GRANT ELECTRICAL CONTRACTING, INC. : IN THE COURT OF COMMON PLEAS OF : CUMBERLAND COUNTY, PENNSYLVANIA : : NO. 2002-4291 CIVIL : : : CIVIL ACTION - LAW : : ORDER OF COURT AND NOW, this 19~ day of MAY, 2003, a pretrial conference in the above-captioned matter is SCHEDULED for FRIDAY, MAY 30, 2003, at 10:00 a.m. in Chambers of the undersigned judge, Cumberland County Courthouse, Carlisle, Pennsylvania. Pretrial memorandum shall be submitted by counsel in accordance with C.C.R.P. 212-4, at least five (5) days prior to the pretrial conference. TRIAL in the matter will be scheduled at the pretrial conference. Counsel are directed to have their calendars available. ~onald M. Lewis III, ESQ. ~,~enry E. Van Eck, Esq. Taryn Dixon Court Administrator Edward E. Guido, J. Taryn N. Dixon Court Administrator OFFICE OF THE COURT ADMINISTRATOR CUMBERLAND COUNTY COURT OF COMMON PLEAS I Courthouse Square · Carlisle, PA 17013 Phone (717) 240-6200 (717) 697-0371 (717) 532-7286 (717) 240-6460 FAX Melissa H. Calvaneili Assistant Court Administrator MEMORANDUM TO: FROM: DATE: IN RE: The Honorable Edward E. Guido Melissa H. Calvanelli, Assistant Court Administrator May 15, 2003 02-4291 Civil Dauphin Associates, Inc. Grant Electrical Contracting, Inc. The above case is assigned to you for a non-jury trial. Please provide me with copies of your scheduling orders and final disposition date so that I can monitor the case for statistical purposes. . Attachment PRAECIPE FOR LISTING CASE FOR TRIAL (Must be typewritten and submitted in duplicate) TO THE PROTHONOTARY OF CUMBERLAND COUNTY HAY 1,5 2003 Please list the following case: (Check one) ( ) for JURY trial at the next term of civil court. ( X ) for trial without a jury. CAPTION OF CASE (entire caption must be stated in full) (check one) { X ) Assumpsit r::L.~__ ( ) Trespass ( ) Trespass (Motor Vehic'l~) Dauphin Associates, lac. (Plaintiff) VS, Grant Flectr'lcal Contract±ng, Inc. VS. (Defendant) ( ) (other) The trial list will be called on June lO, 2003 and Trials commence on July 7, 2003 Pretrials will be held on June 18~ 2003 (Briefs are due 5 days before pretrials.) (The party listing this case for trial shall provide forthwith a copy of the praecipe to all counsel, pursuant to local Rule 214-1.) NO. 02-4291 Civil xl~k 2..002 Indicate the attorney who will try case for the party who files this praecipe: _D_o_n_.a_ld__M_, ..L_e. wis III Keefer Wood Allen & Raha_i._L_LP, PO Box i!9_~3, F~a~r. isburg,_P~A._ 17108._-1963. .......... Indicate trial counsel for other parties if known: H__.enry_.~ .... V_a_~_ Eck,_.E. squir, e ......... 2320 North Second Street, P.O. Box 60457 Harris_burg, PA 17106-0457 ........ This case is ready for trial. Print Na'~;~( ._Le_w'isz .II_! .......... -- Date: ~a__y. 13, 2003 ............. Attorney for: P.la.~_n..t..iff DAUPHIN ASSOCIATES, INC., : Plaintiff : : V. : : GRANT ELECTRICAL CONTRACTING,: INC. : Defendant : IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL ACTION - LAW NO. 02-4291 CIVIL 2002 IN RE: PRETRIAL CONFERENCE At a pretrial conference held Friday, May 30th, 2003, before the Honorable Edward E. Guido, Judge, present for the Plaintiff was Donald M. Lewis, III, Esquire, and present for the Defendant was Henry W. Van Eck, Esquire. This is a contract case for electrical goods and materials supplied. Counsel anticipate it will take two to three hours to try. There are no complicated legal issues. Any motions in limine, with supporting authority, shall be filed by July 1, 2003. Any responses, with supporting authority, shall be filed by July 15, 2003. The parties are directed to premark all trial exhibits and to exchange all trial exhibits with opposing counsel by June 20, 2003. Any objection, other than to relevance, shall be made in the form of a motion in limine. Trial in this matter shall be held on July 28, 2003, at 1:00 p.m. Settlement negotiations are ongoing. However, counsel are not optimistic that a settlement will be reached. ~ By Edward E. ~o, J. Donald M. Lewis, III, Esquire For Plaintiff Henry W. Van Eck, Esquire For Defendant srs DAUPHIN ASSOCIATES, INC., Plaintiff V GRANT ELECTRICAL CONTRACTING, INC., Defendant IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL ACTION - LAW 02-4291 CIVIL TERM IN RE: AGREEMENT OF THE PARTIES ORDER OF COURT AND NOW, this 28th day of July, 2003, upon agreement of the parties, we hereby find in favor of Dauphin Associates, Inc., and against the Defendant, Grant Electrical Contracting, Inc., in the amount of $20,000.00, plus costs. Plaintiff may enter judgment on this verdict. By the Court, Edward E. Guido, J. ~nald M. Lewis, III, Esquire For the Plaintiff ~Henry W. Van Eck, Esquire For the Defendant :mae DAUPHIN ASSOCIATES, INC., Plaintiff VS. GRANT ELECTRICAL CONTRACTING, INC., Defendant IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA NO.: 02-4291 CIVIL 2002 PRAECIPE TO THE PROTHONOTARY: Pursuant to Pa. R. Civ. P. 236, please enter judgment in favor of the plaintiff and against defendant in the amount of $20,000.00, in accordance with the attached order of Court dated July 28, 2003. Respectfully submitted, KEEFER WOOD ALLEN & RAHAL, LLP Dated: July 30, 2003 E. PEPINSKY, JR. Attorney I.D. #23702 DONALD M. LEWIS Ill Attorney I.D. #58510 210 Walnut Street P.O. Box 11963 Harrisburg, PA 17108-1963 (717) 255-8051 and -8038 Attorneys for Plaintiff DAUPHIN ASSOCIATES, : INC., : Plaintiff : V : : GRANT ELECTRICAL : CONTRACTING, INC., : Defendant : IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL ACTION - LAW 02-4291 CIVIL TERM IN RE: AGREEMENT OF THE PARTIES ORDER OF COURT AND NOW, this 28th day of July, 2003, upon agreement of the parties, we hereby find in favor of Dauphin Associates, Inc., and against the Defendant, Grant Electrical Contracting, Inc., in the amount of $20,000.00, plus costs. Plaintiff may enter judgment on this verdict. By the Court, Edward E. Guido, J. or ald M. Lewis, III, Esquire the Plaintiff Henry W. Van Eck, Esquire For the Defendant :mae CERTIFICATE OF SERVICE I, Donald M. Lewis III, Esquire, one of the attorneys for plaintiff, Dauphin Associates, Inc., hereby certify that I have served the foregoing paper upon counsel of record this date by depositing a true and correct copy of the same in the United States mail, first-class postage prepaid, addressed as follows: Henry E. Van Eck, Esquire 2320 North Second Street P.O. Box 60457 Harrisburg, PA 17106-0457 Dated: July 30, 2003 KEEFER WOOD ALLEN & RAHAL, LLP DAUPHIN ASSOCIATES, INC., Plaintiff VS. GRANT ELECTRICAL CONTRACTING, INC., Defendant IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA NO.: 02-4291 CIVIL 2002 PRAEClPE FOR WRIT OF EXECUTION (Money Judgments) TO THE PROTHONOTARY: PLEASE ISSUE WRIT OF EXECUTION IN THE ABOVE MATTER, (1) Directed to the Sheriff of Cumberland County, Pennsylvania; (2) against Grant Electrical Contracting, Inc., Defendant; (3) and index this writ against Grant Electrical Contracting, Inc., Defendant (4) and direct the Sheriff to levy on: All personal property located at 610 Alexander Spring Road, Carlisle, PA 17013, including office equipment, furniture and furnishings, figures and motor vehicles. Total Sum Due (Principal & Interest) as of August 1,2003 Plus: Interest Due from August 1,2003 to Date of Sale Prothonotary Costs Sheriff's Costs Dated: September 15, 2003 $20,000.00 per diem $3.29/day $15.00 $ WRIT OF EXECUTION and/or ATTACHMENT COMMONWEALTH OF PENNSYLVANIA) NO 02-4291 Civil COUNTY OF CUMBERLAND) CIVIL ACTION - LAW TO THE SHERIFF OF CUMBERLAND COUNTY: To satisfy the debt, interest and costs due DAUPHIN ASSOCIATES, INC., Plaintiff (s) From GRANT ELECTRICAL CONTRACTING, INC., 610 ALEXANDER SPRING ROAD, CARLISLE, PA 1'/013 (1) You are directed to levy upon the property of the defendant (s)and to sell ALL PERSONAL PROPERTY LOCATED AT 610 ALEXANDER SPRING ROAD, CARLISLE, PA 17013, INCLUDING OFFICE EQUIPMENT, FURNITURE AND FURNISHINGS, FIGURES AND MOTOR VEItICLES. (2) You are also directed to attach the property of the defendant(s) not levied upon in the possession of GARNISHEE(S) as follows: and to notify the garnishee(s) that: (a) an attachment has been issued; (b) the garnishee(s) is enjoined from paying any debt to or for the account of the defendant (s) and from delivering any property of the defendant (s) or otherwise disposing thereof; (3) If property of the defendant(s) not levied upon an subject to attachment is fotmd in the possession of anyone other than a named garnishee, you are directed to notify him/her that he/she has been added as a garnishee and is enjoined as above stated. Amount Due $20,000.00 L.L. $.50 Interest DUE FROM 8/1/03 TO DATE OF SALE - PER DIEM $3.29/DAY Atty's Corem % Due Prothy $1.00 Arty Paid $123.45 Other Costs Plaintiff Paid Date: SEPTEMBER 16, 2003 (Send CURTIS R. LONG Prothonot~ P-.EQUESTING PARTY: Name DONALD M. LEWIS, IH, ESQUIRE Address: KEEFER, WOOD, ALLEN & RAHAL 210 WALNUT ST. P.O.BOX 11963 HARRISBURG, PA 17108~1963 Attorney for: PLAINTIFF Telephone: 717-255-8000 Supreme Court ID No. Deputy R. THOMAS KL~NE Sheriff EDWARD L. SCHORPP Solicitor OFFICE OF THE SHERIFF One Courthouse Square Carlisle, Pennsylvania 17013 November 21, 2003 Dauphin Associates, Inc. VS Grant Electrical Contracting, Inc. No. 2001-4291 Civil Term Property Claim Determination RONNY R. ANDERSON Chief Deputy JODY S, SMITH Real Estate Deputy Dear Sir, Reference is made to Property Claim dated November 13, 2003, entered by Alan Unger, pertaining to Writ of Execution No. 2002-4291 Civil Term, Dauphin Associates, Inc vs Grant Electrical Contracting, Inc. R. Thomas Kline, Sheriff, has determined that the claimant, Alan Unger, in the above mentioned property claim, is prima facie the owner of the property set forth therein, So Ans~er~, R. Thomas Kline, Sheriff CC; Donald Lewis, III Arty for Pltff Grant Electrical Contracting, Deft. Alan Unger, Claimant I~ROPERTY CLAIM Dauphin Associates, Inc. In the Court of Common Pless Cumberl~d County, Pennsylva W~tNo. 02-4291 Civil Grant EleVc~rical Contracting, Inc. 610 Alexande~ ~pring xoad 6arll~le, FA i/ol3 TO THE SHERIFF OF CUMBERLAND COUNTY, PENNSYLVAlWIA The property list~l below sad levied upon in ibis ca~e is not the propelW of the defendant, but i,~ the property of the undersigned. A list of the cl~r~d property and the values thereof are: LIST OF PROPERTY VALUE See Attached Exhibit "A" $89,500 TI~ CLAIMANT OBTAINED T1TL~ TO TItE PROPERTY AS FOLLOWS: See Bill of Sale attached as Exhibit "B" County of~ above list Sworn and subscribed ~o before me Not~ry Public Notarial Seal Linda B. Deaven, Notary Public City Of Harrisburg, Dauphin County MyOommission Expoes Feb, 25, 2006 b~ dul~law,~and says that the ilan G. Unger '"" C'ah'nam~" ~ FRONT OFFICE LARGE CORNER DESK STORAGE CABINET BOOKSHELF SMALL FILE CABINET COMPUTER & MONITOR PRINTER PLOTTER LARGE WOODEN DOLPHIN STATUE 2 CHAIRS CALCULATOR PRINT ROOM BROWN DESK LARGE FILE CABINET TAN PLAN CENTER PLAN STORAGE CABINET WHITE 2 SWIVEL CHAIRS PRINTER DIAZIT COPIER DRAWING BOARD LIGHT DRY EASE BOARD BREAK ROOM 2 STORAGE CABINET WHITE/TAN TABLE REFRIDGE 4 FOLDING BROWN CHAIRS CHAIR GRAY METAL DESK TOASTER CONFERENCE ROOM LARGE TABLE BROWN BOOK CASE STORAGE CABINET BROWN SWIVEL CHAIR 9 CHAIRS 2 FOLDING CHAIRS SMALL TABLE BROWN PAPER F_.A~EL JEFF OFFICE BROWN DESK 2 BOOK CASES 3 SMALL FILE CABINET BROWN SWIVEL CHAIR FOLDING CHAIR COMPUTER & MONITOR PRINTER BATTERY BACK UP CALCULATOR ANSWER MACHINES 2 2ND VACANT OFFICE E X H I B I T "a" DESK METAL LA~GE BOOK CASE SMALL FILE CABINET LARGE DRAWING TABLE DP,AWING HOLDER SWIVEL CHAIR CALCULATOR MONITOR BATTERY BACK UP 1 ST VACANT OFFICE 2 DESKS DRAWING BOARD BOOK SHELF MONITOR SWIVEL CHAIR CALCULATOR LAURA OFFICE 3 FILE CABINETS TAN 2 MED FILE CABINETS TAN 3 SMALL FILE CABINET GRAY BROWN DESK BOOK SHELF PRINTER STAND 2 SWIVEL CHAIRS COPIER FAX MACHINE COMPUTER & MONITOR CALCULATOR BATTERY BACK UP PRINTER ALAN OFFICE LEATHER COUCH SWIVEL CHAIR 2 CHAIRS 2 BROWN/BLACK DESK LAPTOP COMPUTER & MONITOR 2SMALL FILE CABINET BOOK SHELF STORAGE CABINET DRAWING HOLDER DRAWING STORAGE PAPER SHREADER CALCULATOR 3 COMPUTER 2 MONITOR 2 BATTERY BACKUP MISC SUPPLIES AND SMALL OFFICE EQUIP BREAKDOWN OF TOOLS PURCHASED 1.25 BEND 12 LADDER 12 LADDER 12 LADDER 4 LADDER 4 LADDER 4 LADDER 4 LADDER 4 LADDER 4 LADDER 4 LADDER 6 LADDER 6 LADDER 6 LADDER 6 LADOER 6 LADDER 6 LADDER 6 LADDER 6 LADDER 6 LADDER 6 LADDER 6 LADDER 6 LADDER 6 LADDER 6 LADDER 8 LADDER 8 LADDER 8 LADDER 8 LADDER 8 LADDER 8 LADDER A LADDER BAND SAW BAND SAW BAND SAW BAND SAW BD HAMMER DRILL " BD HAMMER DRILL ' BD HAMMER DRILL BD HAMMER DRILL BD HAMMER DRILL BD HAMMER DRILL BD HAMMER DRILL BD R ANGLE DRILL BD R ANGLE DRILL BD R ANGLE DRILL BD R HAMMER DRILL BO SALZALL BD SALZALL BD SALZALL BD SCREW GUN BENDER HYD 1/2 TO 1,5 SENDER HYD 2' TO 4" STRING BLOWER CORE DRILL AND ACCESSORIES STEIL CUT SAW DEWALT HAMMER DRILL DEWALT HAMMER DRILL EXTENSION LADDER EXTENSION LADDER EXTENSION LADDER EXTENSION LADDER EXTRNSION LADDER FASTRAK GUN GANG BOX GANG BOX GANG BOX GANG BOX LARGE GENERATOR GENERATOR GRINDER HEAT GUN HEAT GUN HEAT GUN HEATER HOT BOX 4" HOT SOX 4" JIG SAW JONSON BAR JONSON SAR KO SET NYD KO SET HYD KO SET SMALL MACHO ROTARY HAMMER DRILL MACHO ROTARY HAMMER DRILL MACHO ROTARY HAMMER DRILL MC CADDY MILWALKIE HAMER DRILL MILWALKIE HAMER DRILL MILWALKIE HAMER DRILL MILWALKIE HAMER .DRILL MILWALKIE HAMER DRILL MILWALKIE HAMER DRILL MILWALKIE HAMER DRILL MILWALKIE R ANGLE DRILL MILWALKIE R ANGLE DRILL MILWALKIE R ANGLE DRILL MILWALKIE R ANGLE DRILL MILWALKIE R ANGLE DRILL MILWALKIE SALZALL MILWALKIE SAI~J-L MILWALKIE SALT_ALL MILWALKIE SALZALL MILWALK1E SALT_ALL MILWALKIE ~ALZAJ. L MILWALKIE SALZALL MILWALKIE SAI. ZALL PtPE VICE PVC PLUG SET REEL STAND REEL STAND REEL ~TAND REEL STAND ROPE LARGE SANDER SANDER SIZZOR LIFT SIZZOR UFT SIZZOR LIFT SKILL ~AW SMALL GANG SMALL GANG SMALL KO SET SMALL KO SET SMALL KO SET SMALL KO SET SMALL SCAFFOLD SMALL SCAFFOLD SCAFFOLD STILTS STUD PUNCH STUD PUNCH STUD PUNCH STUD PUNCH STUD REEL STUD REEL STUD REEL STUD REEL STUD REEL STUD REEL STUD REEL STUD REEL STUO REEL TAMPER THREADER TOOL BOX TRANSIT TUGGER W~RE CART WIRE CART WIRE CART SHELVING MISC HAND TOOLS CORDS,BENDERS,SHOUVELS, DRILL BITS ETC AND THE REMAINDER OF TOOLS NOT LISTED HERIN C~AHT ELECTRIC PAGE DOLPHINS FRONT LOADER BACK HOE TRENCHER STORAGE TRAILER SHED PORTABLE LIGHTS DIESEL POWER VEHICLES INVENTORY Page 4 of 4 JUL-11-2BO3 11:33 71?2432799 99~ P.85 000000 zz~z z~z~z~ CO · 8/24/94 00478160902 EXEMPT J q SC LOSURE ' E~ Ej,;IPT ' By FEDERAL ALAN G UNGER 1937 SPRING ROAD CARLZSL~ PA 17013 PRINT) BILL OF SALE KNOW ALL MEN BY THESE PRESENTS, that GRANT ELEC'I;RICAL CONTRACTING, INC., a Pennsylvania business corporation ("Seller"), for and in consideration of the sum of Eighty-Nine Thousand Five Hundred Dollars ($89,500.00) and other good consideration, the receipt of which is hereby acknowledged, hereby sells, grants, conveys and transfers unto ALAN G. UNGER, an adult individual of Cumberland County, Pennsylvania ("Buyer"), the following: 1. Miscellaneous and all furniture, equipment, tools, vehicles, and inventory of Seller including but not limited to those items that are set forth on Exhibit "A", attached hereto and made a part hereof. Seller does hereby covenant and warrant that it is the owner of the Assets and that it has the right to sell such Assets. . IN WITNESS WHEREOF, GRANT ELECTRICAL CONTRACTING, INC. has executed this Bill of Sale the date set forth below. Date: GRANT ELECTRICAL CONTRACTING, INC. Alan G. Unger, Presidefiff' msm\docs\b-sale\gec-agu FRONT OFFICE LARGE CORNER DESK STORAGE CABINET BOOKSHELF SMALL FILE CA~INET COMPUTER & MONITOR PRINTER PLOTTER LARGE WOODEN DOLPHIN STATUE 2 CHAIRS CALCULATOR PRINT ROOM BROWN DESK LARGE FILE CABINET TAN PLAN CENTER PLAN STORAGE CABINET WHITE 2 SWIVEL CHAIRS PRINTER DIAZ)T COPIER DRAWING BOARD LIGHT DRY EASE BOARD B REA,K ROOM 2 STORAGE CABINET WHITE/TAN TABLE REFRIDGE 4 FOLDING BROWN CHAIRS CHAIR GRAY METAL DESK TOASTER CONFERENCE ROOM LARGE TABLE BROWN BOOK CASE STORAGE CABINET BROWN SWIVEL CHAIR 9 CHAIRS 2 FOLDING CHAIRS SMALL TABLE BRQWN PAPER EASEL JEFF OFFICE BROWN DESK 2 BOOK CASES 3 SMALL FILE CABINET BROWN SWIVEL CHAIR FOLDING CHAIR COMPUTER & MONITOR PRINTER BATTERY BACK UP CALCULATOR ANSWER MACHINES 2 2ND VACANT OFFICE E X H I B I T "a" DESK METAL LARGE BOOK CASE SMALL FILE CABINET LARGE DRAWING TABLE DRAWING HOLDER SWIVEL CHAIR CALCULATOR MONITOR BATTERY BACK UP 1 ST VACANT OFFICE 2 DESKS DRAWING BOARD BOOK SHELF MONITOR SWIVEL CHAIR CALCULATOR LAURA OFFICE 3 FILE CABINETS TAN 2 MED FILE CABINETS TAN 3 SMALL FILE CABINET GRAY BROWN DESK BOOK SHELF PRINTER STAND 2 SWIVEL CHAIRS COPIER FAX MACHINE COMPUTER & MONITOR CALCULATOR BATTERY BACK UP PRINTER ALAN OFFICE LEATHER COUCH SWIVEL CHAIR 2 CHAIRS 2 BROWN/BLACK DESK LAPTOP COMPUTER & MONITOR 2SMALL FILE CASINET BOOK SHELF STORAGE CASINET DRAWING HOLDER DRAwiNG STORAGE, PAJ~ER SHREADER CALCULATOR 3 COMPUTER 2 MONITOR 2 BATTERY BACKUP MISC SUPPLIES AND SMALL OFFICE EQUIP BREAKDOWN OF TOOLS PURCHASED 1,25 BEND 12 LADDER 12 L~DDER 12 LADDER 4 LADDER 4 LADDER 4 LADDER 4 LADDER 4 LADDER 4 LADDER 4 LADDER 6 LADDER B LADDER 6 LADDER 6 LADDER 6 LADDER 6 LADDER 6 LADDER B LADDER 6 LADDER 6 LADDER 6 LADDER 6 LADDER 6 LADDER 6 LADDER 8 LADDER 8 LADDER 8 LADDER 8 LADDER 8 LADDER 8 LADDER A LADDER BAND SAW BAND SAW BAND SAW BAND SAW BD HAMMER DRILL · BD HAMMER DRILL* BD HAMMER DRILL BD HAMMER DRILL BD HAMMER DRILL BD HAMMER DRILL BD HAMMER DRILL BD R ANGLE DRILL BD R ANGLE DRILL BD R ANGLE DRILL BD R HAMMER DRILL BD SALZALL BD SAL.Z. ALL BD SALZALL BD SCREW GUN RENDER HYD 1/2 TO 1.5 BENDER HYD 2' TO 4" STRING BLOWER CORE DRILL AND ACCESSORIES STEIL CUT SAW DEWALT HAMMER DRILL DEWALT HAMMER DRILL EXTENSION LADDER EXTENSION LADDER EXTENSION LADDER EXTENSION LADDER EXTRNSION LADDER FASTRAK GUN GANG BOX GANG BOX GANG BOX GANG BOX LA~GE GENERATOR GENERATOR GRINDER HEAT GUN HEAT GUN HEAT GUN HEATER HOT BOX 4" HOT BOX 4" JIG SAW JONSON BAR JONSON BAR KO SET HYD KO SET HYD KO SET SMALL MACHO ROTARY HAMMER DRILL MACHO ROTARY HAMMER DRILL MACHO ROTARY HAMMER DRILL MC CADDY MILWALKIE HAMER DRILL M]LWALKIE HAMER DRILL MILWALKIE HAMER DRILL MILWALK1E HAMER .DRILL MILWALKIE HAMER DRILL MILWALKIE HAMER DRILL MILWALKIE HAMER DRILL MILWALKIE R ANGLE DRILL MILWALKIE R ANGLE DRILL MILWALKIE R ANGLE DRILL MILWALKIE R ANGLE DRILL MILWALKIE R ANGLE DRILL MILWALKIE SALZALL MI)_WALKIE SALZALL MILWALKIE SALZALL M~LWALKIE SAI~AJ_L M[LWALKIE SALZALL MILWALKIE 8ALZALL M~LWAL~IE SAL.Z,ALL MILWALKIE ,%a, LZAL L P~PE VICE PVC PLUG SET REEL STAND REEL STAND REEL STAND REEL STAND ROPE LARGE SANOER SANDER SIZZOR LIFT SIZZOR UFT SIZZOR LIFT SKILL SAW SMALL GANG SMALL GANG SMALL KO SET SMALL KO SET SMALL KO SET SMALL KO SET SMALL SCAFFOLD SMALL SCAFFOLD SCAFFOLD STILTS STUD PUNCH STUD PUNCH STUD PUNCH STUD PUNCH STUD REEL STUD REEL STUD REEL STUD REEL STUD REEL STUD REEL STUD REEL STUD REEL STUD REEL TAMPER THREADER TOOL BOX TI::b~qSIT TUGGER W~RE CART WIRE CART WIRE CART SHELVING M~SC HAND TOOLS CORDS,BENDERS,SHOUVELS. DRILL BiTS ETC AND THE REMAINDER OF TOOLS NOT LISTED HERIN DOLPHINS FRONT LOADER BACK HOE TRENCHER STORAGE TRAILER SHED PORTABLE LIGHTS DIESEL POWER VEHICLES INVENTORY Page 4 of 4 00000000 m zm~mm m m~m~m~ m ~ 610 'ALEXANDER SPRING RD ' ~ ,. 'CARLISLE:PA 17013 r ~ ~.~,~,~~ ALLEN D BIEHLER ...,,..,.,,,,,,,,..,,,.,,,,.,,.,., (TYPE OR PRINT) Certificate ol Title musl be submitted within 20 days, unless the purchaser is a registered dealer holding the vehicle toe WARNING - FEDERAL AND STATE LAWS REQUIRE THAT YOU STATE THE MILEAGE (ODOMETER READING) IN CONNECTION WiTH THE TRANSFER OF OWNERSHIP. FAILURE TO COMPLETE OR PROVIDING A FALSE STATEMENT MAY RESULT iN FINES AND/OR iMPRISONMENT. IMPORTANT NOTICE Please be advised that in lieu of notarization on this form, verification of a person's signature by an issuing agent who is licensed as a vehicle dealer by the Pennsylvania State Board of Vehicle Manufacturers, Dealers and Salespersons, or its employee is acceptable. The signature and printed name of the issuing agent or the issuing agent's employee, date of verification, the issuing agentJlicensed dealership's dealer identifi- cation number (DIN) and business name, must be listed in the space provided for notarization. Vehicle seller and purchaser must sign only in the presence of an officer empowered to administer oaths or an authorized agent as identified above. ,, ... ,.-.. '.. ,:;'.:.....:,~., x *,, ~,~,,,,~,,*~,* ~Z%~:~ ~:~; i · !.. ..-. :~-.. ALAN _G..~.UNGER , .. ALAN G UNGER 23~ RED TANK RD BOILING SPROS PA ALLEN D B!EHLERt ACTfNG:' {TYPE[ OR PRINT) Cer~ifica{e o! ~tle must be submitted within 20 day~, unless Ihe purchaser is a registered dea~er holding the vehicle for retie. WARNING - FEDERAL AND STATE LAWS REQUIRE THAT YOU STATE THE MILEAGE (ODOMETER READING) IN CONNECTION WITH THE TRANSFER OF OWNERSHIP. FAILURE TO COMPLETE OR PROVIDING A FALSE STATEMENT MAY RESULT IN FINES AND/OR IMPRISONMENT. IMPORTANT NOTICE Please be advised that in lieu of notarization on this form, verification of a person's signature by an Issuing agent who is licensed as a vehicle dealer by the Pennsylvania State Board of Vehicle Manufacture[s, Dealers and Salespersons, or its employee is acceptable. The signature and printed name of the issuing agent or the issuing agent's employee, date of verification the issuing agent/licensed dealership's dealer identifi- cation number (DIN) and business name, must be listed in the space provided for notarization. Vehicle seller and purchaser must sign only in the presence of an officer .,.empowered to administer oaths or an authorized agent as identified above. ~'~ ~' ~,', ~ = ,', = .~ ~ ",, ~/'/~,11 ~;.~.~ ~7.~::;~,..~;:.i: tT.',~/']J/.t'"'''~'''':''''" ............ " LU (CATE OF TITLE FOIl A VEHICLE· O00G CARLISLE PA'17013 039036 ALAN O UNGER 610 ALEXANDER SPRING R CARLISLE PA .17013 Im~6:l'd ;,lll[Pf:l I[l]~ I i[ll;ll I I I l:l:ILgll II1:1~ l hq ~[1111¢~:I Ill) ALLEN D'BTEHLER :; WARNING - FEDERAL AND STATE LAWS REQUIRE THAT YOU STATE THE MILEAGE (ODOMETER READING) IN CONNECTION WITH THE TRANSFER OF OWNERSHIP. FAILURE TO COMPLETE OR PROVIDING A FALSE STATEMENT MAY RESULT IN FINES AND/OR IMPRISONMENT. IMPORTANT NOTICE Please be advised that in lieu of notarization on this form, verification of a person's signature by an issuing agent who is licensed as a vehicle dealer by the Pennsylvania State Board of Vehicle Manufacturers, Dealers and Salespersons, or its employee is acceptable. The signature and printed name of the issuing agent or the' issuing agent's employee, date of verification, the issuing agent/licensed dealership's dealer identifi- cation number (DIN) and business name, must be listed in the space provided for notarization. Vehicle seller and purchaser must sign only in the presence of an officer empowered to administer oaths or an authorized agent as identified above. ~_~~:CER, TIFICATE OF TITLEiFOR VEHICLE ~ ]~.~ ]UU~3~J~]~-~=~ ::,:~'~;::::..:::~ - ~ ~ 3 ~ ~ ~ .;~:~::::, ..: .. · :~:~ . . .B~ ............. ~ ........................ B~ ............................................................ ~ .................. ........... ~ ..................................... ~=~ ......... ._.., ....... ~,== .oB~.=, ....................... ALAN G'UNGER', 610 ~ L~XJ~'NDER CARLISLE ~PA 17l]t3 039036 ALAN G UNGER 610 ALEXANDER SPRING RD CARLISLE PA' 171313 WARNING - FEDERAL AND STATE LAWS REQUIRE THAT YOU STATE THE MILEAGE (ODOMETER READING) IN CONNECTION WITH THE TRANSFER OF OWNERSHIP. FAILURE TO COMPLETE OR PROVIDING A FALSE STATEMENT MAY RESULT IN FINES AND/OR IMPRISONMENT. IMPORTANT NOTICE Please be advised that in lieu of notarization on this form, verification of a person's signature by an issuing agent who is licensed as a vehicle dealer by the Pennsylvania State Board of Vehicle Manufacturers, Dealers and Salespersons, or its employee is acceptable. The signature and printed name of the issuing agent or the issuing agent's employee, date of verification, the issuing agentJlicensed dealership's dealer identifi- cation number (DIN) and business name, must be listed in the space provided for notarization. Vehicle seller and purchaser must sign only in the presence of an officer empowered to administer oaths or an authorized agent as identified above. . SUBSCRISED AND SWORN CHECK HERE ~A'RLISLE PA~17013 039036 ALAN G UNGER 610 ALEXANDER SPRING RD CARLISLE PA 17013 ALLEN D.BIEHLER. i ~ ,~U~.C~EC~< [] WARNING - FEDERAL AND STATE LAWS REQUIRE THAT YOU STATE THE MILEAGE. (ODOMETER READING) IN CONNECTION WITH THE TRANSFER OF OWNERSHIP. FAILURE TO COMPLETE OR PROVIDING A FALSE STATEMENT MAY RESULT IN FINES AND/OR IMPRISONMENT. IMPORTANT NOTICE Please be advised that in lieu of notarization on this form, verification of a person's signature by an issuing agent who is licensed as a vehicle dealer by the Pennsylvania State Board of Vehicle Manufacturers, Dealers and Salespersons, or its employee is acceptable. The signature and printed name of the issuing agent or the issuing agent's employee, date of verification, the issuing agent/licensed dealership's dealer ~dentifi- cation number (DIN) and business name, must be listed in the space provided for notarization. Vehicle seller and purchaser must sign only in the presence of an officer empowered to administer oaths or an authorized agent as identified above. [~a. ~-~ ~ ,, =,,, =,,,,,~'~:~;~[~ """"'""~""" ............ "'"'-" .......... '~'"T'~ ............ SUBSCRIBED AND SWORN TO BEFORE ME; SUBSCRIBBD AND SWORN ~' TO BEFORE ME: ~ STAT~ CHECK HERE IF APPLICAT ON FOR DEALER TITLE AND COMPLETE SECTION D. TITLING FEES A~ ,0 -~,RLISLE PA 1701,3 039036 ALAN G UNGER 610 ALEXANDER SPRING CARLISLE PA 17013 RD 8ECON~ ALLEN O BIEHLER WARNING - FEDERAL AND STATE LAWS REQUIRE THAT YOU STATE THE MILEAGE (ODOMETER READING) IN CONNECTION WITH THE TRANSFER OF OWNERSHIP. FAILURE TO COMPLETE OR PROVIDING A FALSE STATEMENT MAY RESULT IN FINES AND/OR IMPRISONMENT, IMPORTANT NOTICE Please be advised that in lieu of notarization on this form, verification of a person's signature by an issuing agent who is licensed as a vehicle dealer by the Pennsylvania State Board of Vehicle Manufacturers, Dealers and Salespersons, or its employee Is acceptable. The signature and printed name of the issuing agent or the issuing agent's employee, date of verification, the issuing agenUlicensed dealership's dealer identifi- cation number (DIN) and business name, must be listed in the space provided for notarization. Vehicle seller and purchaser must sign only in the presence of an officer empowered to administer oaths or an auth.o, rized agent as identified above. SUBSCRIBED AND SWORN TO BEFORE ME: iCC.! [] CHECK HERE IF APPLICATION FOR DEALER TITLE AND COMPLETE ~FCTmn~ n TITI I~ E 039036 ALAN O UNGER 61{3 ALEXANOER SPRING RD CARLISLE PA~17013 ALLEN D 8IEHLER deceased ~ goes to his/he~' heirs or mate). zrP WARNING - FEDERAL AND STATE LAWS REQUIRE THAT YOU STATE THE MILEAGE (ODOMETER READING) IN CONNECTION WITH THE TRANSFER OF OWNERSHIP. FAILURE TO COMPLETE OR PROVIDING A FALSE STATEMENT MAY RESULT IN FINES AND/OR IMPRISONMENT. IMPORTANT NOTICE Please be advised that in lieu of notarization on this form, verification of a person's signature by an issuing agent who is licensed as a vehicle dealer by the Pennsylvania State Board of Vehicle Manufacturers, Dealers and Salespersons, or its employee is acceptable. The signature and printed name of the issuing agent or the issuing agent's employee, date of verification, the issuing agent/licensed dealership's dealer identifi- cation number (DIN) and business name, must be listed in the space provided for notarization. Vehicle seller and purchaser must sign only in the presence of an officer empowered to administer oaths or an authorized agent as identified above. SUBSCRIBED AND SWORN TO BEFORE ME: ' SUBSCRIBED AND SWORN lc. r~CHECK HERE IF APPLICATION FOR DEALER TITLE AND COMPLETE SECTION D. TITLING FEES $ -- ~-FTHE2qY'-'.RHB6~6,%~ 1994 FOKO. " - ' '.. '""::~' . · - . ...., · . · . ALAN G UNGER ~'~"~'~'~"~ ALLEN O BIEHLER ""~L aS~ON NUMBER (TYPE OR PRINT) Certificate of Title must be submitted within 20 days, unless the purChaser is a registered dealer holding the vehicle ;or WARNING - FEDERAL AND STATE LAWS REQUIRE THAT YOU STATE THE MILEAGE (ODOMETER READING) IN CONNECTION WITH THE TRANSFER OF OWNERSHIP. FAILURE TO COMPLETE OR PROVIDING A FALSE STATEMENT MAY RESULT IN FINES AND/OR IMPRISONMENT. IMPORTANT NOTICE Please be advised that in lieu of notarization on this form, verification of a person's signature by an issuing agent who is licensed as a vehicle dealer by the Pennsylvania State Board of Vehicle Manufacturers, Dealers and Salespersons, or its employee is acceptable. The signature and printed name of the issuing agent or the issuing agent's employee, date of verification, the issuing agent/licensed dealership's dealer identifi- cation number (DIN) and business name, must be listed in the space provided for notarization. Vehicle seller and purchaser must sign only in the presence of an officer empowered to administer oaths or an authorized agent as identified above. ............. :r' '""' ..... '-"fmmmimi l CARLISLE. 67013 039036 ALAN -G 'UNGER 610 ALEXANDER SPRING RD CARLISLE .PA" 17013 ALLEN O BIEHLER TO BEFORE ME: .. . be ~edl~.~ ~,)~ Tenants v~r~J1 Right o~ Survivorship' (On death of ~e WARNING - FEDERAL AND STATE LAWS REQUIRE THAT YOU STATE THE MILEAG~E ~ ~ (ODOMETER READING) IN CONNECTION WITH THE TRANSFER OF OWNERSFiIP. - .. FAILURE TO COMPLETE OR PROVIDING A FALSE STATEMENT MAY RESULT IN FINES AND/OR IMPRISONMENT. IMPORTANT NOTICE Please be advised that in lieu of notarization on this form, verification of a person's signature by an issuing agent who is licensed as a vehicle dealer by the Pennsylvania State Board of Vehicle Manufacturers, Dealers and Salespersons, or its employee is acceptable. The signature and printed name of the issuing agent or the issuing agent's employee, date of verification, the issuing agentJlicensed dealership's dealer [dentifi- cation number (DIN) and business name, must be listed in the space provided for notarization. Vehicle seller and purchaser must sign only in the presence of an officer empowered to administer oaths or an authorized agent as identified above. SUBSCRIBED AND SWORN TO BEFORE ME: CHECK HERE IF APPLICATION FOR DEALER TITLE AND COMPLETE SECTION D. TITLING FEES $ -- SUBSCRIBED AND SWORN C, ERTi~ICATE OF TITLE ~OR A VEHICLE ALAN G VNGER 61rl ALEXANDER SPR[NG RD CARLISLE PA '17013 · (TYPE OR PRINT) Certificate of T~tle must be submitted within 20 days, unless [he purChaser is a registered dealer holding Ihe vehicle for WARNING - FEDERAL AND STATE LAWS REQUIRE THAT YOU STATE THE MILEAGE (ODOMETER READING) IN CONNECTION WITH THE TRANSFER OF OWNERSHIP. FAILURE TO COMPLETE OR PROVIDING A FALSE STATEMENT MAY RESULT IN FINES AND/OR IMPRISONMENT. IMPORTANT NOTICE Please be advised that in lieu of notarization on this form, verification of a person's signatur~ by an issuing agent who is licensed as a vehicle dealer by the Pennsylvania State Board of Vehicle Manufacturers, Dealers and Salespersons, or its employee Is acceptable. The signature and printed name of the issuing agent or the issuing agent's employee, date of verification, the issuing agent/licensed dealership's dealer identifi- cation number (DIN) and business name, must be listed in the space provided for notarization. Vehicle seller and purchaser must sign only in the presence of an officer empowered to administer oaths or an authorized agent as identified above. A .L&l~*~ ~. ,,.,., ~,,-,, =,,,, ,=l~..:F;t~,i;~.~,~:~.~'~t~::~'.~ ~:;~.~,r''~''"'' .............. . ........... SUBSCRIBED AN~ SWORN TO BEFORE ME; SUBSCRIBED AND SWORN TO BEFORE ME; LAST RRST SUBSCRIBED AND SWORN r'ALAN .G .dNG. E~R ': '2; ~a ^L~XANOE" :sP~ ALAN G UNGER 610 ALEXANDER SPRING RD CARLISLE PA 17013 WARNING - FEDERAL AND STATE LAWS REQUIRE THAT YOU STATE THE MILEAG'E (ODOMETER READING) 1N CONNECTION WITH THE TRANSFER OF OWNERSHIP. FAILURE TO COMPLETE OR PROVIDING A FALSE STATEMENT MAY RESULT IN FINES AND/OR IMPRISONMENT. IMPORTANT NOTICE Please be advised that in lieu of notarization on this form, verification of a person's signature by an issuing agent who is licensed as a vehicle dealer by the Pennsylvania State Board of Vehicle Manufacturers, Dealers and Salespersons, or its employee is acceptable. The signature and printed name of the issuing agent or the issuing agent's employee, date of verification, the issuing agentJlicensed dealership's dealer identifi- cation number (DIN) and business name, must be listed in the space provided for notarization. Vehicle seller and purchaser must sign only in the presence of an officer empowered to administer oaths or an authorized agent as identified above. (/3 Zip iC. ~-']CHECK HERE IF APPLICATION FOR DEALER TITLE AND COMPL~-TF ~.F~TIC3N 13 111'1 I~J~ ;:K;:~ · .~ ODONETER [ ERAL LAH CARLISLE PA 17053 ALAN G uNGER ~50 ALEXANDER SPRING RD ! CARLISLE PA I7013 ~i,,,.~..~.~,~,~,.~o~,,~.P..,.,~,.~ 'ALLEN D BIEHLER :Iiallff,ll[Ihlil],llllll,ld ]lla~mkLi ],hJ:ll[ ': : : ' (TYPE OR PRINT) Certilicam of Title must be submitled within 20 days, unleSS Ihe purchaser is a registered dealer holding the vel,cie WARNING - FEDERAL AND STATE LAWS REQUIRE THAT YOU STATE THE MILEAGE (ODOMETER READING) IN CONNECTION WITH THE TRANSFER OF OWNERSHIP. FAILURE TO COMPLETE OR PROVIDING A FALSE STATEMENT MAY RESULT iN FINES AND/OR IMPRISONMENT. IMPORTANT NOTICE Please be advised that in lieu of notarization on this form, verification of a person's signature by an issuing agent who is licensed as a vehicle dealer by the Pennsylvania State Board of Vehicle Manufacturers, Dealers and Salespersons, or its employee is acceptable. The signature and printed name of the issuing agent or the issuing agent's employee, date of verification, the issuing agent]licensed dealership's dealer Identifi- cation number (DIN) and business name, must be listed in the space provided for notarization. Vehicle seller and purchaser must sign only in the presence of an officer empowered to administer oaths or an authorized agent as identified above. IC~I [] CHECK HERE IF APPLICATION FOR DEALER TITLE AND COMPLETE SECTION D. TITLING FE£S $ -- :~R'I~jIF'ICAT£-OF TITLE,FoR 'A VEHICLE LA~ ALAN G UNGER blD ALEXANDER SPRING RD CARLI'SLE PA ALLEN D BIEHLER WARNING - FEDERAL AND STATE LAWS REQUIRE THAT YOU STATE THE MILEAGE (ODOMETER READING) IN CONNECTION WITH THE TRANSFER OF OWNERSHIP. FAILURE TO COMPLETE OR PROVIDING A FALSE STATEMENT MAY RESULT IN FINES AND/OR IMPRISONMENT. IMPORTANT NOTICE Please be advised that in lieu of notarization on this form, verification of a person's signature by an issuing agent who is licensed as a vehicle dealer by the Pennsylvania State Board of Vehicle Manufacturers, Dealers and Salespersons, or Its employee is acceptable. The signature and printed name of the issuing agent or the issuing agent's employee, date of verification, the issuing agenUlicensed dealership's dealer identifi- cation number (DIN) and business name, must be listed in the space provided for notarization. Vehicle seller and purchaser must sign only in the presence of an officer empowered to administer oaths or an authorized agent as identified above. SUSSCRISEO AND SWORN TO BEFORE ME: SUE-SCRIBED AND SWORN ,C I [] CHECK HERE IF APPLICATION FOR DEALER Ti'rLE AND COMPLETE SECTION D, TITLING FEES $ __ DAUPHIN ASSOCIATES, INC., Plaintiff VS. GRANT ELECTRICAL CONTRACTING, INC., Defendant IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA NO.: 02-4291 CIVIL 2002 AFFIDAVIT OF SERVICE re DEPOSITION SUBPOENA COMMONWEALTH OF PENNSYLVANIA COUNTY OF CUMBERLAND DAUPHIN ASSOCIATES, INC., Plaintiff GRANT ELECTRICAL CONTRACTING, INC., Defendant TO: Alan G. Unger File No. SUBPOENA TO ATTEND AND TESTIFY 02-4291 Civil 2002 610 Alexander Spring Road C&rlisle, PA 17013 1. You are ordered by the court to come to at at the offices of Keefer Wood Allen & Rahal, LLP, 210 Walnut Street. - .... (Speci~ cou~mom orotherplace) Harrisburg , Dauphin Count, Pennsylvania, on Wednesday, December ]7, 2003 10:00 o'clock, A.M.,to testi~ on behalf of olaintiff in the above case, and to remain until excused. And bring with you the following: If you fail to attend or to produce the documents or things required by this subpoena, you may be subject the sanctions authorized by Rule 234.5 of the Pennsylvania Rules of Civil Procedure, including but not limited Io costs, attorney fees and imprisonment. REQUESTED BY A PARTY/ATTORNEY IN COMPLIANCE WITH Pa. R. C. P. No. 234.2(a): Name: Donald M. Lewis III Address: Keefer Wood Allen & Rahal, LLP 210 Walnut St., P. O. Box 11963. Harrimburg, PA Telephone: 717-255-8038 Supreme Court ID ~ 58510 Date: JL),¢'C--..'~ O~;~..~ /Seal of the Court 17108-1963 BY THE COURT:.~,F ~ . Official Note: This form of subpoena shall be used whenever a subpoena is issuable, including hearings in connection m;h depositions and before arbitrators, masters, commissioners, etc. in compliance w~th Pa. R. C. P. No. 234.1. ;f a subpoena for a production of documents, records or things is desired, comale[e paragraon 2. (Eft. 7/97) _AFFIDAVIT OF SERVICE -,, PROOF OF SERVICE DAIE ?LAC~ fi lo ~qlexander- ,.~,rrn3 SERVED ON (PKINT NAME) ~ OF ~CE '~ BY ~ N~) D~ON OF I declare under penalty of perjury under the laws of the United States of America that the foregoing information contained in the Proof of Service is true and correct. SWORN AND SUBSCRIBED TO BEFORE ME MONTHflo~ DAY ~)9 YEAR ~f_~ ..~ ~i ~fP~on A~[mini~ating O~ttl~ Municil:filit~ County t ~OT~_s~ I · ~ ~H~AN [~. L~/A~ NC}TARY PHRI IG I Executed on /c~' ~- (0 Date Signature of Server Address of Server CERTIFICATE OF SERVICE I, Donald M. Lewis III, Esquire, one of the attorneys for plaintiff, Dauphin Associates, Inc., hereby certify that I have served the foregoing paper upon counsel of record this date by depositing a true and correct copy of the same in the United States mail, first-class postage prepaid, addressed as follows: Henry E. Van Eck, Esquire 2320 North Second Street P.O. Box 60457 Harrisburg, PA 17106-0457 Dated: December 12, 2003 KEEFER WOOD ALLEN & RAHAL, LLP R. Thomas Kline, Sheriff, who being duly sworn according to law, states this writ is returned STAYED. Sheriff's Costs: Docketing Poundage Advertising Law Library Prothonotary Mileage Sumharge Levy Post Pone Sale Garnishee TOTAL 18.00 1.26 1.50 3.45 20.00 20.00 64.21 Advance Costs: 150.00 Sheriff's Costs: 64.21 $ 85.79 Refunded to Atty on 12/18/03 Sworn and Subscribed to before me This )'0 ~day of ~ 2003 A.D. . ~p~, · ~ Pl'othonotary So Answers: R. Thomas Kline, Sheriff B~ Claudia A. Brewbal/e~r