Greivell & Garrott Johnson LLC 5 Cornell Avenue Hagerstown, MD 21742 t: (240) 310-9150 f: (877) 262-4810 www. GreivellLawOffice.com IN THE CIRCUIT COURT FOR WASHINGTON COUNTY, MARYLAND * * * * * * * * * * * * * * * * * * * * * * * COMPLAINT COMES NOW Plainti ff , Neal Glessner, by and through his attorney, Adam D. Greivell, Esq., and Greivell & Garrott Johnson, LLC, and sues the Defendant, CharDan, LLC, and for reasons states: Parties, Jurisdiction and Venue 1. Plainti ff , Neal Glessner, is an adult resident of Washington County, Maryland. 2. Defendant, CharDan, LLC, is a Maryland limited liability company with its principal place of business in Washington County, Maryland. 3. The events described in this Complaint took place primarily, if not exclusively, in Washington County, Maryland. 4. Jurisdiction and venue are appropriate in Washington County, Maryland. Facts Common to All Counts 5. Plainti ff incorporates and re-alleges the allegations of all preceding paragraphs as if fully set forth herein. Page of 1 10 NEAL GLESSNER 8707 Mapleville Road Boonsboro, MD 21713 Plainti ff v. CHARDAN, LLC Serve On: Daniel Aufdem-Brinke 3 South Main Street Boonsboro, MD 21713 Defendant * * * * * * * * * * * * * * * * CASE NO. E-FILED; Washington Circuit Court Docket: 3/30/2022 6:43 PM; Submission: 3/30/2022 6:43 PM C-21-CV-22-000156 Greivell & Garrott Johnson LLC 5 Cornell Avenue Hagerstown, MD 21742 t: (240) 310-9150 f: (877) 262-4810 www. GreivellLawOf fi ce .com 6. CharDan, LLC (“CharDan”) owns and operates a restaurant in Boonsboro, Maryland named Dan’s Restaurant and Tap House (“Dan’s”). 7. On or about February 18, 2022, Plainti ff visited Dan’s for dinner. 8. During his visit, Plainti ff ordered two burgers and a salad “to go” so he could bring them home to visitors who were staying with Plainti ff 9. At or near 8:00 p.m., approximately 45 minutes after he had placed his “to go” order, Plainti ff commented to his friend, Joseph Michael, who was sitting at the bar (“Friend”), stating something in the nature of “What’s taking so long, I ordered a ‘to go’ order 45 minutes ago.” 10. While Plainti ff ’s comment was not directed at his server (“Server”), the Server nonetheless overheard Plainti ff ’s comment, and snapped at Plainti ff , insisting that Plainti ff needs to be patient because they are very busy. 11. Plainti ff responded that it should not take that long to make two burgers, to which the Server responded that he ordered more than just two burgers. 12. Plainti ff responded, acknowledging that he did, in fact, order a salad, as well, but noted, tongue-in-cheek, that he did not believe it “took too long to ‘cook’ a salad.” 13. The Server departed towards the kitchen in an angry fashion, and returned several minutes later with Plainti ff ’s order, and Plainti ff left. 14. Shortly after Plainti ff departed Dan’s, a manager, Mike Skinner (“Manager”), approached Plainti ff ’s Friend who had been sitting at the bar, and told the Friend to “tell your friend” (meaning the Plainti ff ) that he is no longer allowed at Dan’s. 15. The Friend replied, stating something in the nature of, “I’ll do no such thing, I don’t work for you.” Page of 2 10 Greivell & Garrott Johnson LLC 5 Cornell Avenue Hagerstown, MD 21742 t: (240) 310-9150 f: (877) 262-4810 www. GreivellLawOf fi ce .com 16. The Manager became upset and advised the Friend that both he and Plainti ff are barred from the premises. 17. The Friend advised the Manager that if he wanted to bar him from the establishment, he should call the police. 18. Whereupon, the police were called, and a Boonsboro Police Department o ff icer responded to the scene at approximately 8:30 p.m. 19. The police o ff icer activated his body worn camera and recorded the interactions with the Friend and the Manager. 20. When the police o ff icer asked the Friend what had occurred, the Friend reported to the police o ff icer that he had just been discriminated against. 21. The Friend drove directly to Plainti ff ’s house, arriving at approximately 8:45 p.m., and told the Plainti ff that he’s not going to believe what happened after Plainti ff left. 22. The Friend advised that they had both been banned from Dan’s. 23. When Plainti ff asked why, the Friend explained that, before the police arrived, the Manager exclaimed to the Friend, “You old, white people act like you own everything. Get the fuck out of here!” 24. Both Plainti ff and the Friend are caucasian males over the age of 50. 25. Plainti ff thereafter reached out to Daniel N. Aufden-Brinke (“Dan” - one of the members of CharDan, LLC), through Dan’s Facebook page to discuss the situation. 26. Although Plainti ff had communicated with Dan previously through the Facebook messenger, this time, after Plainti ff sent a message, he was later noti fi ed that he had been blocked. Page of 3 10 Greivell & Garrott Johnson LLC 5 Cornell Avenue Hagerstown, MD 21742 t: (240) 310-9150 f: (877) 262-4810 www. GreivellLawOf fi ce .com 27. Plainti ff thereafter posted a message in the Boonsboro, Maryland Community Group on Facebook (the “Group”), asking if anyone else had been treated poorly by the sta ff at Dan’s. 28. Another manager of Dan’s made the following defamatory post (“Defamatory Post”) on the Group page: 29. The statements made in the Defamatory Post are false and defamatory. Page of 4 10 Greivell & Garrott Johnson LLC 5 Cornell Avenue Hagerstown, MD 21742 t: (240) 310-9150 f: (877) 262-4810 www. GreivellLawOf fi ce .com 30. For example, Plainti ff did not on February 18, 2022, 0r at any time previously “mistreat” Dan’s sta ff or “show[] blatant disrespect for [Dan’s] rules and hours of operation.” 31. On the contrary, Plainti ff has arrived for dinner at Dan’s on several occasions in the past well within Dan’s posted hours of operation, only to have been advised that the kitchen or the entire establishment had been closed early. After addressing these issues with Dan, Dan committed to requiring the sta ff to remain open and to seat diners for the entirety of the posted hours of operation. 32. Moreover, Plainti ff has been unable to locate any “rules” and asserts herein that there are no such “rules.” 33. The statement that “He has never been treated poorly here” is false. 34. In fact, one evening not long before the February 18, 2022 incident, at approximately 7:35 p.m. several of Plainti ff ’s friends and associates arrived at Dan's for dinner. Immediately upon their arrival they were told by Dan’s sta ff that the kitchen is closing and that they needed to order immediately. At approximately 7:45 p.m., Plainti ff and his wife arrived to join the group. They were also instructed by Dan’s sta ff that they needed to order immediately because the kitchen was closed. The server was rude and seemed inconvenienced. 35. At approximately 8:30 p.m. the group paid their check, which was approximately $100. There were no other patrons in the dinning room. The separated bar area had a dozen or more patrons. Moments after paying the check, the quiet background music in the dining room changed to very loud and obnoxious “head-banging" music. This made Plainti ff and his guests very uncomfortable and also made it impossible for his group to continue to their conversations. After the group felt that they were forced to leave, they Page of 5 10 Greivell & Garrott Johnson LLC 5 Cornell Avenue Hagerstown, MD 21742 t: (240) 310-9150 f: (877) 262-4810 www. GreivellLawOf fi ce .com all discussed how poorly the sta ff treated them and how the loud music was an obvious and obnoxious act to force them to leave the establishment 30 minutes prior to published posted time of closing. 36. The statement that “I have personally been verbally attacked by him, and every single one of our bartenders (as well as a few servers) can say the same” is false. 37. Aside from an isolated incident with a single server, where the next day the owner, Dan, agreed with Plainti ff and resolved the issue, Plainti ff has never “verbally attacked” that manager or any other bartender, server, or any other Dan’s sta ff member. 38. The statement that “he emailed our owners trying to get the manager(s) fi red” is false. 39. Plainti ff did message Dan, as previously alleged, but the message to Dan was simply an attempt to respectfully discuss what had occurred on the evening of February 18, 2022, and no e ff ort or suggestion was made to “get the manager(s) fi red.” 40. The statement that the Plainti ff ’s post "is simply a desperate reaching attempt to hurt our business because he can't accept the consequences of his actions like an adult” is false. 41. Plainti ff ’s purpose in making the post was to attempt to ascertain whether he was being singled out for being treated poorly, or whether other patrons have had similar experiences. 42. Plainti ff was able to see that approximately 30 or 40 new people requested access to the Facebook Group within a short period of when his post went up. 43. Defendant, through its agents, had encouraged their friends to join the Group in order to support the Defamatory Post and statements made therein. Page of 6 10 Greivell & Garrott Johnson LLC 5 Cornell Avenue Hagerstown, MD 21742 t: (240) 310-9150 f: (877) 262-4810 www. GreivellLawOf fi ce .com 44. On February 19, 2022, the day after the incident, the manager posted on his Facebook page, “tagging” the Server, a bartender, and a second manager, a picture that states “We have the right to refuse service. Fuck around and fi nd out.” On the post, the manager added, editorially, “Nice try though. 🤙 💯 ” 45. As a direct and proximate result of the Defendant’s actions, Plainti ff has su ff ered, and will continue to su ff er irreparable loss and injury, including but not limited to economic loss, humiliation, embarrassment, emotional distress, strain on relationships, and unlawful deprivation of his protected rights to exercise and enjoy equal treatment in the making and enforcing of contracts in places of public accommodation without regard for age, race and/or color. COUNT I - Unlawful Public Accommodation Discrimination in Violation of State Government Article, § 20-304 46. Plainti ff incorporates and re-alleges the allegations of all preceding paragraphs as if fully set forth herein. 47. Dan’s is a place of public accommodation, which is de fi ned by SG § 20-301 as “a restaurant... principally engaged in selling food or alcoholic beverages for consumption on or o ff the premises...” 48. Pursuant to SG § 20-304, “An owner or operator of a place of public accommodation or an agent or employee of the owner or operator may not refuse, withhold from, or deny to any person any of the accommodations, advantages, facilities, or privileges of the place of public accommodation because of the person's race, sex, age, color, creed, national origin, marital status, sexual orientation, gender identity, or disability.” Page of 7 10 Greivell & Garrott Johnson LLC 5 Cornell Avenue Hagerstown, MD 21742 t: (240) 310-9150 f: (877) 262-4810 www. GreivellLawOf fi ce .com 49. By barring Plainti ff from the facility because he is “old” and “white,” Defendant has refused, withheld from and denied Plainti ff the privileges of a place of public accommodation because of the Plainti ff ’s age, race and/or color. 50. Plainti ff has been damaged as aforesaid as a direct and proximate result of Defendant’s violation of the public accommodations law. WHEREFORE, Plainti ff respectfully requests the following relief: (1) Enter a declaratory judgment fi nding that the foregoing actions of the Defendant violated SG §20-304; (2) Award compensatory damages to Plainti ff in an amount to be determined by a jury that would fully compensate Plainti ff for economic loss, humiliation, embarrassment and emotional distress, in an amount exceeding $75,000.00; (3) Award punitive damages to Plainti ff in an amount to be determined by the jury that would punish Defendant for the willful, wanton, and reckless conduct alleged herein and that would e ff ectively deter similar conduct in the future; (4) Award Plainti ff his reasonable attorneys’ fees and costs; (5) Award pre-judgment interest and post-judgment interest; and (6) Order such other relief as this Court deems just and equitable. COUNT II - Defamation of Character 51. Plainti ff incorporates and re-alleges the allegations of all preceding paragraphs as if fully set forth herein. 52. As set forth above, Defendant and its agents made numerous defamatory communications about the Plainti ff which tended to and did in fact expose Plainti ff to public scorn, hatred, contempt and ridicule. Page of 8 10 Greivell & Garrott Johnson LLC 5 Cornell Avenue Hagerstown, MD 21742 t: (240) 310-9150 f: (877) 262-4810 www. GreivellLawOf fi ce .com 53. Defendant published these defamatory communications to many third parties who reasonably recognized the defamatory nature or the statements. 54. Defendant’s statements about the Plainti ff are false as aforesaid, and the Defendant made the false statements with negligent disregard for the truth of the statements, reckless disregard for the truth of the statements, and/or with actual malice, i.e ., actual knowledge of the falsity of the statements. 55. Moreover, even if the falsity of the above defamatory statements was not known or knowable by the Defendant at the time they made such statements, the falsity of the statements had become known to the Defendant and its failure to retract the statements constitutes an ongoing malicious act of defamation. 56. As set forth above, Defendant’s conduct in defaming the character of the Plainti ff has proximately and actually caused severe reputational harm, emotional distress and fi nancial damages in an amount to be more speci fi cally proven at trial, but exceeding $75,000.00. WHEREFORE, Plainti ff respectfully requests the following relief: (1) Award compensatory damages to Plainti ff in an amount to be determined by a jury that would fully compensate Plainti ff for economic loss, humiliation, embarrassment and emotional distress, in an amount exceeding $75,000.00; (2) Award punitive damages to Plainti ff in an amount to be determined by the jury that would punish Defendant for the willful, wanton, and reckless conduct alleged herein and that would e ff ectively deter similar conduct in the future; (3) Award Plainti ff his reasonable attorneys’ fees and costs; (4) Award pre-judgment interest and post-judgment interest; and Page of 9 10 Greivell & Garrott Johnson LLC 5 Cornell Avenue Hagerstown, MD 21742 t: (240) 310-9150 f: (877) 262-4810 www. GreivellLawOf fi ce .com (5) Order such other relief as this Court deems just and equitable. Respectfully submitted, /s/ Adam D. Greivell Adam D. Greivell, Esquire CPF ID# 0512130328 Greivell & Garrott Johnson, LLC 5 Cornell Avenue Hagerstown, Maryland 21742 (240) 310-9150 adam@greivelllawo ff ice.com Attorneys for Plainti ff , Neal Glessner CERTIFICATE REGARDING RESTRICTED INFORMATION I HEREBY CERTIFY that this document does not contain any restricted information. /s/ Adam D. Greivell Adam D. Greivell, Esquire Page of 10 10 Greivell & Garrott Johnson LLC 5 Cornell Avenue Hagerstown, MD 21742 t: (240) 310-9150 f: (877) 262-4810 www. GreivellLawOffice.com IN THE CIRCUIT COURT FOR WASHINGTON COUNTY, MARYLAND * * * * * * * * * * * * * * * * * * * * * * * DEMAND FOR JURY TRIAL Plainti ff , Neal Glessner, hereby demands a jury trial in this action for all matters triable by jury. Respectfully submitted, /s/ Adam D. Greivell Adam D. Greivell, Esquire CPF ID# 0512130328 Greivell & Garrott Johnson, LLC 5 Cornell Avenue Hagerstown, Maryland 21742 (240) 310-9150 adam@greivelllawo ff ice.com Attorneys for Plainti ff , Neal Glessner CERTIFICATE REGARDING RESTRICTED INFORMATION I HEREBY CERTIFY that this document does not contain any restricted information. /s/ Adam D. Greivell Adam D. Greivell, Esquire Page of 1 1 NEAL GLESSNER 8707 Mapleville Road Boonsboro, MD 21713 Plainti ff v. CHARDAN, LLC Serve On: Daniel Aufdem-Brinke 3 South Main Street Boonsboro, MD 21713 Defendant * * * * * * * * * * * * * * * * CASE NO. E-FILED; Washington Circuit Court Docket: 3/30/2022 6:43 PM; Submission: 3/30/2022 6:43 PM C-21-CV-22-000156 IN THE CIRCUIT COURT FOR CIVIL – NON-DOMESTIC CASE INFORMATION SHEET DIRECTIONS Plaintiff: This Information Report must be completed and attached to the complaint filed with the Clerk of Court unless your case is exempted from the requirement by the Chief Judge of the Court of Appeals pursuant to Rule 2-111(a). Defendant: You must file an Information Report as required by Rule 2-323(h). THIS INFORMATION REPORT CANNOT BE ACCEPTED AS A PLEADING FORM FILED BY: PLAINTIFF DEFENDANT CASE NUMBER CASE NAME: vs. PARTY’S NAME: PHONE: PARTY’S ADDRESS: PARTY’S E-MAIL: If represented by an attorney: PARTY’S ATTTORNEY’S NAME: PHONE: PARTY’S ATTTORNEY’S ADDRESS: PARTY’S ATTTORNEY’S E-MAIL: JURY DEMAND? Yes No RELATED CASE PENDING? Yes No If yes, Case #(s), if known: ANTICIPATED LENGTH OF TRIAL?: hours days PLEADING TYPE New Case: Original Administrative Appeal Appeal Existing Case: Post-Judgment Amendment If filing in an exi s ting case, skip Case Category/ Subcategory section – go to Relief section. IF NEW CASE: CASE CATEGORY/SUBCATEGORY ( Check one box.) TORTS Asbestos Assault and Battery Business and Commercial Conspiracy Conversion Defamation False Arrest/Imprisonment Fraud Lead Paint – DOB of Youngest Plt: Loss of Consortium Malicious Prosecution Malpractice-Medical Malpractice-Professional Misrepresentation Motor Tort Negligence Nuisance Premises Liability Product Liability Specfic Performance Toxic Tort Trespass Wrongful Death CONTRACT Asbestos Breach Business and Commercial Confessed Judgment (Cont’d) Construction Debt Fraud Government Insurance Product Liability PROPERTY Adverse Possession Breach of Lease Detinue Distress/Distrain Ejectment Forcible Entry/Detainer Forclosure Commercial Residential Currency or Vehicle Deed of Trust Land Installments Lien Mortgage Right of Redemption Statement Condo Forfeiture of Property / Personal Item Fraudulent Conveyance Landord-Tenant Lis Pendens Mechanic’s Lien Ownership Partition/Sale in Lieu Quiet Title Rent Escrow Return of Seized Property Right of Redemption Tenant Holding Over PUBLIC LAW Attorney Grievance Bond Forfeiture Remission Civil Rights County/Mncpl Code/Ord Election Law Eminent Domain/Condemn. Environment Error Coram Nobis Habeas Corpus Mandamus Prisoner Rights Public Info. Act Records Quarantine/Isolation Writ of Certiorari EMPLOYMENT ADA Conspiracy EEO/HR FLSA FMLA Worker’s Compensation Wrongful Termination INDEPENDENT PROCEEDINGS Assupmtion of Jurisdiction Authorized Sale Attorney Appointment Body Attachment Issuance Commission Issuance Constructive Trust Contempt Deposition Notice Dist Ct Mtn Appeal Financial Grand Jury/Petit Jury Miscellaneous Perpetuate Testimony/Evidence Prod. of Documents Req. Receivership Sentence Transfer Set Aside Deed Special Adm. – Atty Subpoena Issue/Quash Trust Established Trustee Substitution/Removal Witness Appearance-Compel PEACE ORDER Peace Order EQUITY Declaratory Judgment Equitable Relief Injunctive Relief Mandamus OTHER Accounting Friendly Suit Grantor in Possession Maryland Insurance Administration Miscellaneous Specific Transaction Structured Settlements (City or County) Plaintiff Defendant CC - DCM - 002 (Rev. 10/2021) Page 1 of 3 (Clerk to insert) E-FILED; Washington Circuit Court Docket: 3/30/2022 6:43 PM; Submission: 3/30/2022 6:43 PM C-21-CV-22-000156 If you indicated Liability above, mark one of the following. This information is not an admission and may not be used for any purpose other than Track Assignment. Liability is conceded. Liability is not conceded, but is not seriously in dispute. Liability is seriously in dispute. Abatement Administrative Action Appointment of Receiver Arbitration Asset Determination Attachment b/f Judgment Cease & Desist Order Condemn Bldg Contempt Court Costs/Fees Damages-Compensatory Damages-Punitive Earnings Withholding Enrollment Expungement Financial Exploitation Findings of Fact Foreclosure Injunction Judgment-Affidavit Judgment-Attorney Fees Judgment-Confessed Judgment-Consent Judgment-Declaratory Judgment-Default Judgment-Interest Judgment-Summary Liability Oral Examination Order Ownership of Property Partition of Property Peace Order Possession Production of Records Quarantine/Isolation Order Reinstatement of Employment Return of Property Sale of Property Specific Performance Writ-Error Coram Nobis Writ-Execution Writ-Garnish Property Writ-Garnish Wages Writ-Habeas Corpus Writ-Mandamus Writ-Possession IF NEW OR EXISTING CASE: RELIEF (Check All that Apply) MONETARY DAMAGES (Do not include Attorney’s Fees, Interest, or Court Costs) Under $10,000 $10,000 - $30,000 $30,000 - $100,000 Over $100,000 Medical Bills $ Wage Loss $ Property Damages $ ALTERNATIVE DISPUTE RESOLUTION INFORMATION Is this case appropriate for referral to an ADR process under Md. Rule 17-101? (Check all that apply) A. Mediation Yes No C. Settlement Conference Yes No B. Arbitration Yes No D. Neutral Evaluation Yes No SPECIAL REQUIREMENTS If a Spoken Language Interpreter is needed, check here and attach form CC-DC-041 If you require an accommodation for a disability under the Americans with Disabilities Act, check here and attach form CC-DC-049 ESTIMATED LENGTH OF TRIAL With the exception of Baltimore County and Baltimore City, please fill in the estimated LENGTH OF TRIAL. (Case will be tracked accordingly) 1/2 day of trial or less 3 days of trial time 1 day of trial time More than 3 days of trial time 2 days of trial time BUSINESS AND TECHNOLOGY CASE MANAGEMENT PROGRAM For all jurisdictions, if Business and Technology track designation under Md. Rule 16-308 is requested, attach a duplicate copy of complaint and check one of the tracks below. Expedited - Trial within 7 months of Standard - Trial within 18 months of Defendant’s response Defendant’s response EMERGENCY RELIEF REQUESTED CC-DCM-002 (Rev. 10/2021 ) P age 2 of 3 COMPLEX SCIENCE AND/OR TECHNOLOGICAL CASE MANAGEMENT PROGRAM (ASTAR) FOR PURPOSES OF POSSIBLE SPECIAL ASSIGNMENT TO ASTAR RESOURCES JUDGES under Md. Rule 16-302, attach a duplicate copy of complaint and check whether assignment to an ASTAR is requested. Expedited - Trial within 7 months of Standard - Trial within 18 months of Defendant’s response Defendant’s response IF YOU ARE FILING YOUR COMPLAINT IN BALTIMORE CITY, OR BALTIMORE COUNTY, PLEASE FILL OUT THE APPROPRIATE BOX BELOW. CIRCUIT COURT FOR BALTIMORE CITY (CHECK ONLY ONE) Expedited Trial 60 to 120 days from notice. Non-jury matters. Civil-Short Trial 210 days from first answer. Civil-Standard Trial 360 days from first answer. Custom Scheduling order entered by individual judge. Asbestos Special scheduling order. Lead Paint Fill in: Birth Date of youngest plaintiff Tax Sale Forclosures Special scheduling order. Mortgage Foreclosures No scheduling order. CIRCUIT COURT FOR BALTIMORE COUNTY Expedited (Trial Date-90 days) Attachment Before Judgment, Declaratory Judgment (Simple), Administrative Appeals, District Court Appeals and Jury Trial Prayers, Guardianship, Injunction, Mandamus. Standard (Trial Date-240 days) Condemnation, Confessed Judgments (Vacated), Contract, Employment Related Cases, Fraud and Misrepresentation, International Tort, Motor Tort, Other Personal Injury, Workers' Compensation Cases. Extended Standard (Trial Date-345 days) Asbestos, Lender Liability, Professional Malpractice, Serious Motor Tort or Personal Injury Cases (medical expenses and wage loss of $100,000, expert and out-of-state witnesses (parties), and trial of five or more days), State Insolvency. Complex (Trial Date-450 days) Class Actions, Designated Toxic Tort, Major Construction Contracts, Major Product Liabilities, Other Complex Cases. CC-DCM-002 (Rev. 10/2021) Page 3 of 3 Zip Code Date City Address State Printed Name Signature of Counsel / Party Attorney Number CC-CV-032 (Rev. 11/23/2020) Page 1 of 2 03/31/2022 8:55 AM CIRCUIT COURT FOR WASHINGTON COUNTY, MARYLAND 24 Summit Avenue Hagerstown, Maryland 21740 Civil/Family/Juvenile: 301-790-4972 Criminal: 301-790-7941 General: 301-733-8660 Assignment: 240-313-2540 Maryland Relay Service: 711 Fax Civil/Family/Juvenile: 301-791-0507 To: CHARDAN, LLC SERVE ON: DANIEL AUFDEM-BRINKE 3 SOUTH MAIN STREET BOONSBORO, MD 21713 Case Number: C-21-CV-22-000156 Other Reference Number(s): Child Support Enforcement Number: NEAL GLESSNER VS. CHARDAN, LLC Issue Date: 3/31/2022 WRIT OF SUMMONS You are hereby summoned to file a written response by pleading or motion, within 30 days after service of this summons upon you, in this court, to the attached complaint filed by: NEAL GLESSNER ADAM D. GREIVELL, ESQ 5 CORNELL AVE HAGERSTOWN, MD 21742 This summons is effective for service only if served within 60 days after the date it is issued. Kevin R. Tucker Clerk of the Circuit Court To the person summoned: Failure to file a response within the time allowed may result in a judgment by default or the granting of the relief sought against you. Personal attendance in court on the day named is NOT required. Instructions for Service: 1. This summons is effective for service only if served within 60 days after the date issued. If it is not served within the 60 days, the plaintiff must send a written request to have it renewed. 2. Proof of Service shall set out the name of the person served, date and the particular place and manner of service. If service is not made, please state the reasons. 3. Return of served or unserved process shall be made promptly and in accordance with Maryland Rule 2-126. 4. If this notice is served by private process, process server shall file a separate affidavit as required by Maryland Rule 2-126(a). Circuit Court for Washington County Neal Glessner vs. CharDan, LLC Case Number: C-21-CV-22-000156 CC-CV-032 (Rev. 11/23/2020) Page 2 of 2 03/31/2022 8:55 AM SHERIFF’S RETURN (please print) To: CHARDAN, LLC ID# of the Serving Sheriff’s Name County Sheriff’s office present to the court that I: (1) Served Name of person served on at Date of service Location of service by with the following: Manner of service Summons Counter-Complaint Complaint Domestic Case Information Report Motions Financial Statement Petition and Show Cause Order Interrogatories Other Please specify (2) Was unable to serve because: Moved left no forwarding address No such address Address not in jurisdiction Other Please specify Sheriff fee: $ waived by Instructions to Sheriff’s Office or Private Process Server: 1. This Summons is effective for service only if served within 60 days after the date issued. If it is not served within 60 days, the plaintiff must send a written request to have it renewed. 2. Proof of Service shall set out the name of the person served, date and the particular place and manner of service. If service is not made, please state the reasons. 3. Return of served or unserved process shall be made promptly and in accordance with Rule 2-126. 4. If this summons is served by private process, process server shall file a separate affidavit as required by Rule 2- 126(a). Date Signature of serving Sheriff CC-CV-032 (Rev. 11/23/2020) Page 1 of 2 03/31/2022 8:55 AM CIRCUIT COURT FOR WASHINGTON COUNTY, MARYLAND 24 Summit Avenue Hagerstown, Maryland 21740 Civil/Family/Juvenile: 301-790-4972 Criminal: 301-790-7941 General: 301-733-8660 Assignment: 240-313-2540 Maryland Relay Service: 711 Fax Civil/Family/Juvenile: 301-791-0507 To: CHARDAN, LLC SERVE ON: DANIEL AUFDEM-BRINKE 3 SOUTH MAIN STREET BOONSBORO, MD 21713 Case Number: C-21-CV-22-000156 Other Reference Number(s): Child Support Enforcement Number: NEAL GLESSNER VS. CHARDAN, LLC Issue Date: 3/31/2022 WRIT OF SUMMONS You are hereby summoned to file a written response by pleading or motion, within 30 days after service of this summons upon you, in this court, to the attached complaint filed by: NEAL GLESSNER ADAM D. GREIVELL, ESQ 5 CORNELL AVE HAGERSTOWN, MD 21742 This summons is effective for service only if served within 60 days after the date it is issued. Kevin R. Tucker Clerk of the Circuit Court To the person summoned: Failure to file a response within the time allowed may result in a judgment by default or the granting of the relief sought against you. Personal attendance in court on the day named is NOT required. Instructions for Service: 1. This summons is effective for service only if served within 60 days after the date issued. If it is not served within the 60 days, the plaintiff must send a written request to have it renewed. 2. Proof of Service shall set out the name of the person served, date and the particular place and manner of service. If service is not made, please state the reasons. 3. Return of served or unserved process shall be made promptly and in accordance with Maryland Rule 2-126. 4. If this notice is served by private process, process server shall file a separate affidavit as required by Maryland Rule 2-126(a). E-FILED; Washington Circuit Court Docket: 3/31/2022 8:57 AM; Submission: 3/31/2022 8:57 AM E-FILED Washington Circuit Court 3/31/2022 8:57 AM System System Circuit Court for Washington County Neal Glessner vs. CharDan, LLC Case Number: C-21-CV-22-000156 CC-CV-032 (Rev. 11/23/2020) Page 2 of 2 03/31/2022 8:55 AM SHERIFF’S RETURN (please print) To: CHARDAN, LLC ID# of the Serving Sheriff’s Name County Sheriff’s office present to the court that I: (1) Served Name of person served on at Date of service Location of service by with the following: Manner of service Summons Counter-Complaint Complaint Domestic Case Information Report Motions Financial Statement Petition and Show Cause Order Interrogatories Other Please specify (2) Was unable to serve because: Moved left no forwarding address No such address Address not in jurisdiction Other Please specify Sheriff fee: $ waived by Instructions to Sheriff’s Office or Private Process Server: 1. This Summons is effective for service only if served within 60 days after the date issued. If it is not served within 60 days, the plaintiff must send a written request to have it renewed. 2. Proof of Service shall set out the name of the person served, date and the particular place and manner of service. If service is not made, please state the reasons. 3. Return of served or unserved process shall be made promptly and in accordance with Rule 2-126. 4. If this summons is served by private process, process server shall file a separate affidavit as required by Rule 2- 126(a). Date Signature of serving Sheriff AFFIDAVIT OF SERVICE Case: C-21-CV-22-000156 Court: Circuit Court for Washington County County: Washington, MD Job: 6897611 Plaintiff / Petitioner: Neal Glessner Defendant / Respondent: Chardan, LLC Received by: Integrity Investigations & Processing For: Greivell & Garrott-Johnson To be served upon: Daniel Aufden-Brinke I, Todd Webster, being duly sworn, depose and say: I am over the age of 18 years and not a party to this action, and that within the boundaries of the state where service was effected, I was authorized by law to make service of the documents and informed said person of the contents herein Recipient Name / Address: Daniel Aufden-Brinke, Home: 404 N Main St, Boonsboro, MD 21713 Manner of Service: Personal/Individual, Apr 2, 2022, 12:11 pm EDT Documents: Summons; Complaint; Demand for Jury Trial; Civil Non-Domestic Case Information Report; Interrogatories; Request for Production of Documents; Subpoena; and Notice of Deposition Duces Tecum for the Corporate Designee(s) of Defendant CharDan, LLC (Received Apr 1, 2022 at 6:16pm EDT) Additional Comments: 1) Unsuccessful Attempt: Apr 2, 2022, 12:02 pm EDT at Company: 3 S Main St., Boonsboro, MD 21713 Employee advised Mr. Aufdem-Brinke was not in. Usually only in on Tuesdays. Employee sent a text message to Mr. Aufdem-Brinke who requested affiant serve him at his residence. 2) Successful Attempt: Apr 2, 2022, 12:11 pm EDT at Home: 404 N Main St, Boonsboro, MD 21713 received by Daniel Aufden-Brinke. Age: 7/20/72; Ethnicity: Caucasian; Gender: Male; Weight: 170; Height: 5'11"; Relationship: self; Contact with Daniel Aufdem-Brinke in the front yard of his residence where he provided his personal descriptors and signed affiant's copy of summons as acknowledgment of receipt. I solemnly affirm under the penalties of perjury that the contents of the foregoing paper are true to the best of my knowledge, information, and belief. 04/02/2022 Todd Webster Private Investigator, #106-4376 Date Integrity Investigations & Processing P.O. Box 2493 Hagerstown, MD 21741 301-733-7761 E-FILED; Washington Circuit Court Docket: 4/12/2022 2:13 PM; Submission: 4/12/2022 2:13 PM THOMAS, THOMAS & HAFER, LLP 1025 CONNECTICUT AVE., NW, SUITE 608 WASHINGTON, DC 20036 5781178.1 1 NEAL GLESSNER Plaintiff v. CHARDAN, LLC Defendants. * * * * * IN THE CIRCUIT COURT OF MARYLAND FOR WASHINGTON COUNTY Case No.: C-21-CV-22-000156 * * * * * * * * * * * * ENTRY OF APPEARANCE WILL THE CLERK please enter the appearances of Charles B. Peoples, Esquire, and Nicholas A. Schaufelberger, Esquire, and the law firm of Thomas, Thomas & Hafer, LLP, as the attorneys for Defendant, CharDan, LLC, in the above-captioned case. ________/s/_____________________ Charles B. Peoples, Esquire Attorney ID No. 0812180016 Nicholas A. Schaufelberger, Esquire Attorney ID No. 1612140223 Thomas, Thomas & Hafer LLP 1025 Connecticut Avenue, NW, Suite 608 Washington, DC 20036 202-904-2362 cpeoples@tthlaw.com nschaufelberger@tthlaw.com Attorneys for Defendant E-FILED; Washington Circuit Court Docket: 5/2/2022 10:09 AM; Submission: 5/2/2022 10:09 AM