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HomeMy WebLinkAbout96-02960 II' ~ ~ I' ->> " 3 , " " , , , I ~ ' , ! >-... I , " ~ 1 , " ,~ I , " I \ " , I, , , I I', I " " I , I , I' , i I It , /, i, t " , I' , i ,f, I" " I' .,'; ,I I' i , , , " ;'1 " ,,' , " I . I , , " /,', , , - I . , , I .. " I ,I' " , , " " " ) ,,' '," . , ~I ~ "" I" ~ ~ . f'\, ~ ' , , " \ ,~ ' , , r'l " ,.,1 rB 'l~ ~~ ~~ I 0 ~~~ ~ 5:':'~ ~S2~ ~ ~~~ ~ ::a<o Ul~aJ "" :>~ 0 ;:j m ~ , .' .' " DALEY LAW OFFICES I029.)C~FllY DI,IVE HARRISBURG, PENNSYLVANIA 17109 (17) 657-4795 _ t . ~ I'" . , . " \ . . . 'k ~, ,\\', ~ \:)' ~ ' ~~ ",. , ~~ ~ rI-. \:J ~ ~~ " 1''') I, ~ J~.~ -' ~ ~;~ ! ~i~ 31 ::; 8 ~ ~ ~ ~ . , . . I - DALEY LAW. OFFICES 1029 SCENERY DRIVE HARRISBURG. PtNNSYLV ANIA 1 7109 (717) 657.4795 " I i " " ",] " I Ha. Viotoria Wheeler Page Two September 25, 1995 Legal aervioea are oharged on the baais of attorney time. Thia time ia oharged for in-person oonferences, telephone oonferenoea, attendanoe at hearinga, meetings or oonferenoes, reaearoh and preparation time, preparation of legal documents and lettera, and any and all other aervices rendered on your behalf by the attorney at the hourly rate stated above. I bill time in unita of one-tenth (0.1) of an hour. The minimum billing unit for any work done 0.1 hour (6 minutes). I generally do not charge for reasonable secretarial service or clerical time. In the event that your file remains active for more than one year, I reaerve the right to notify you of increases in the billing ratea, and you hereby agree to pay the increased hourly rate. COlTS The hourly attorney's fee does not include any out-of-pocket oosts which must be paid. Out-of-pocket expenses and legal costs inolude, but are not limited to, excess postage, courier feea, toll oalla, deposition expenses, travel expenses, court filing fees, court coats, accounting and appraisal fees, sheriff fees, and the fees and expense a of expert witnesses and/or consultants in order to asaiat you in the preparation, possible trial, or proper handling of your case. I do not charge for reasonable mileage or regular poatage. I ahall have the authority to advance such out- of-pocket costs on your behalf in such amounts aa I determine are prudent in represanting you in your legal matter. ADDITIOIIAL ADVAHCID PAYMlIITS It is the policy of our firm to have all work pai.d for in advance by the initial nonrefundable retainer and by additional advanced payments. In most cases, the initial retainer does not oover all of the attorney's fees and out-of-pocket costs which muat be paid. You will be asked to make additional advanced payments to cover on-going attorney's fees and costs which will be necessary to fully represent your best interests. The total coat associated with resolving any legal matter will vary depending on the complexity of the issues, the parties, and the approach advanced by the opposing attorney. M ma. Victoria Wheeler Page Three September 25, 1995 STATIJIB1IT8 You are responftible for all fses, coats and expenaea. You will receive an itemized statement on a regular baais. Any amount due is to be paid within thirty (30) daya of the .tatement date. A late payment charge of one (1') percent, per month, which ia an annual percentage rate of (12') pllrcent, will be added to all unpaid balances over thirty (30) dars, The minimum late payment charge for unpaid balances over th rty (30) days will be $.50. Failure to kAep your account current could lead to withdrawal of our firm's representation. In the event that our firm ia required to in.titute any legal action for collection of fees, expenses, or costs due to us for our services, I also will have the right to receive rea.onable attorneys fees and coata in bringing such action againat you. If any balance is due on your bill at the end of your case, you may be requeated to sign a judgment note, with intereat, to inaure the balance of the fee. This policy may also be applied to anI billa accruing and unpaid, as we go along. I alao re.erve the r ght to diacontinue our repreaentation of you if all bills are not paid in conformity with thia agreement. If you find that you are having difficulty keeping your account current, you should discuss the matter directly with me or with our firm's billing manager. OrrICK 'ROC.DURlS While the rendering of legal services and payment of feea form the basis of our relationship, the attorneys understand that legal mattera often involve periods of personal transition which generate many questiona about the future. Our firm believes that good communication is a key to a productive attorney/client relationship. Our office will aend you copiea of relevant papers coming into and going out of our officea, including correspondence, plelldings and other Court documenta. Pleaae aend me copies of any documents you receive relating to your caae. If I am not available to you when you telephone, I will attempt to return your call within a rea.onable am~unt of time. Ha. Victoria Wheeler Pag'e Four September 25, 1995 However, there will be tjmes when I will be in Court, at meetings or in conference when you call which will prevent me from returning your call as quickly aa we both might like, and there are times we will &imply miss each other's call. During those times, it is often helpful for you to send me a note with any questions or to explain a particular problem. Please remember that my secretary will offer any assistance that ahe can, but you must keep in mind that she is not a lawyer and cannot give you any legal advice. If your problem is urgent, please let the 8ecretary know. OUR UPUIIUfTATIOII or YOU It is impossible to predict the course that any legal matter may take. Sometimes it branches out into forms of litigation whi.ch were not readily ,ppl1rent at the beginning of the case. It is impoasible to predict the amount of time that will be neceS8ary to complete your case. I will use my best judgment to determine the amount of time and the nature of the services that will be performed in your best interest. I will take whatever action I can to move your case along, but I have no control over delays that might be caused by the opposing partr or the court system. It is not unusual to have some lapaeH of t me between legal communications, actions, and proceedings due to the personal readjustment process that occurs for most people who are going through a legal matter and due to legal rules and court procedures. Every effort will be made to expedite your case promptly and efficiently according to the highest legal and ethical standard.. I am committed to offering you the strongeHt guidance and direction in the event that you are prompted to make a decision which our experience indicates might harm you. While it is your case And you must make the financial and value jUdgments as opposed to decisions involving the law and knowledge of the Courts, if I become convinced that your judgment i. counterproductive to your best interests, I will indicate that to you in the strongest possible terms and may withdraw our firm'a representation and terminate our attorney/client relationahip in the event that you persist. I ,) M.. Victoria Wheeler Page rive September 25, 1995 Similarly, our advice and guidance is ba.ed in large part on information you provide. In order to maintain our cuetomary legal and ethical .tandarde, I muat feel confident that you are aoting with complete candor and truthfulnee8. If I become convinoed that rou are not acting or intend not to act in euch a manner, I will ndicat.e thia to YOUI, and if you persi.t, I may withdraw our firm'a repreeentation and terminate our attorney/client relation.hip. Should our firm'8 withdrawal become nece.aary for the foregoing or any other rea80n including your requeet, you will be charged for the time expended to accomplish our withdrawal. HI8CILLAIIIOU8 Unfortunately, as with life, there are no guarantees in the law. By aigning this letter, you acknowledge that I have made no guaranteee a. to the diapoaition of any pha.e of thi. matter and other matt.er. for which you have retained our firm, and you aoknowledge that all etatements made by me are carefully oon.idered opinions. If you do not under8tand any of the word. or terma in thia letter, pleaee call me. Your decision to be a reaponaible party in the attorney/olient relationehip i. an important one I intend to be a. clear ae poeaible in thi. letter And feel it ie the firat .tep in helping to establi8h a relatione hip that is open and direot. We uk that you Acknowledge receipt of this lettftr and your acceptance of it and the term8 contained in the letter by aigning the copy and returning it to my office with your retainer in the amount of $500.00 in order for me to begin work on thi. matter. I am unable to do any work on your behalf or repreaent you ae your attorney until I receive the signed copy of thia letter and your retainer fee. If you plAn to wait more than thirty (30) daya to return thia letter with your retainer, please call my office to confirm the hourly rate and advance payment a. I cannot definitely be bound to the8e rate8 for an undetermined period of time. A. I indicated at our office conference, our attorney/client relationship does not begin until I am aotually retained by you. " " . DALEY LAW OFFICES 1111') Sn~:\:lR" DRIVE' HARRISUl'l\.li, "A ,"11)1) . I''''''f h~;.11l)~ . FAX ,'"1"1 M",\I}% February 10, 1996 Ms. Victoria Wheeler 889 Acri Drive Mechanicsburg, PA 17055 Re: Statement of Fee for Professional Services Rendered ~ . .... Jan. 17, 1996 Previous Statement Jan. 30, 1996 Payment Received -- THANK YOU Carryover Balance $644,00 200,00 $444.00 Jan. 19, 1996 Telephone conference with Sam Andes regarding proposlll for settlement (.3 hr.) Jan,25, 1996 Review correspondence and copy to client (.3 hr.) Jan,30, 1996 Review leller and draft response and revisions (.8 hr,) 1.4 hrs. @ $140,00 per hour Carryover Balance Total Amount Due $196.00 444,00 $640 00 KCD:jad All accounts not paid within thlny (30) days will be charged a late charge of one (1%) perccnt per month, twelve (12%) perccnt per year. .. DALEY LAW OFFICES [1111) S([I\:I:Rr lHlJ\'E . HAH.RISUlfKtl, pj\ 1"1111) . f~ I"l h\1. 1"')\ . fAX 1.1"111'''. "Jilt! .' April 15. 1996 Ms. Victoria Wheeler 889 Acrl Drive Mechanicsburg, PA 17055 Re: Statement of Fee for Professional Services Rendered " , ..' Mar, II, 1996 Previous Statement Payments Received to Date Interest Canyover Balance $744.40 0.00 7,44 $751.84 Mar. 18, 1996 Review correspondence (.1 hr.) Mar, 20, 1996 Telephone conference with Attorney Andes and client; letter to Allorney Andes regarding settlement (2,0 hrs,) Mar, 29, 1996 Leller to Attorney Andes; preparation of Marriage Settlement Agreement (2,2 hrs,) Apr, 04, 1996 Office conference with dient regarding various issues and notes to the file (1.4 hrs,) S,7 hrs, @ $140,00 per hour Carryover Balance Total Amount Due $ 798.00 751.84 SU49 84 KCDjad AU accounts not paid within thiny (30) days wiU be charged a late charge of one (1 %) percent per month. twelve ( 12%) percent per year, I ! ~ I " ' 1'1 !! 'I ,I" I {II [, llli; II(' 1,'1",',1 I"" 'il,II',,1 I I 'til. ;."tlfl' ''r'l ',I{\I, j ;" I'i 'II I 'I t: it P 11'1 /otPI . I"i' i.", !I_I !'Y'; I ^I\I' " 'I " " '1lil,1 I I,'" 'I r,' ""lil"!', II I, 'r ~, Iii I I.; ~ II' ' '1.'.1 I I, "I l'i'lli'l , ',(1,1 J.'/, ,. W(ll'fI ,1' , ~ 1 I ,II j j I I , ~) "huI , , ,\1 l!I.' .'1 " " ", "'1,01 I " " , I ,I I, I " 1 '" " I!' ~ . j . I J I \ ~ J , , " .'I,.il 1 l'1l1 \I,'ll dlld, 11111.),1 II J: Ill: ',iJ\F /0;, ,)':1>: 11 I.i ~ 11"'1 lit '/ I' Till! \..\ Ij , I, 'j) I '1 H I ,'II,,' '11 II, I . II ' _' I' ~ l.'.' I I r I:' t U j l~ \ 1114. I.I!II Lll ~ ~,' PI'1 'f-I;,\}l-,[' I',', I, I_Ill '....,11.,'\ 111 , ,'"r,"'1111 JI-Il 1,1111'1' - ',vI'I I:! I:'i, I:' , , \(11, J 1\ n 1,1: ", JIiNJ,,'l',' I' :'l' 1';',',)1':, '" HLTII1",11 I 1:1,,' "', q\) ) I: ,\' 1: ~ ; 1..!" i _ . !4 , I ,,'I" '1 'I II '~t~~::;~.~; -~, ,. '-., /'!1T:1r,....r, I' '1'1'''11 I j 1'1,,'11 , " ,', , , -:-.... hl'l I, 11 I";, ' ':.i, ,I I;: , k I I j .'1' ~ " I,ll,' I,):;) 1I"I'! , , , , " , I t , !. ,', , I, ;.'1 , !i " , , i , 1'(.\ II j I'i) """:', ,'Ifi'\ 'It!::. q~ 11'):, .:\ J'{'l" " "'I~. 1','11 , , Ch~ Q n' i , V-ff' , ','1" ./~,~ \~, , I , ' " i' ' KATHLEEN CAREY DALEY, PlaintitT : IN THE COURT OF COMMON PLEAS : CUMBERLAND COUNTY, PENNSYLVANIA v, VICTORIA N, WHEELER, . NO. f h - 0;'; &CJ clt.,jA:2!.41'1 : CIVIL ACTION - LAW . Defendant lRAECIPE FOR A LIS PENDENS , " To the Prothonotary: , . Please index the above-captioned action as a lis pendens against the following real property: 889 Acri Road Mecl1.anicsburg, PA 17055 Au./ t{ V trf!. 3<1 . Deed to Victoria N Wheeler is recorded at P~e. oJ. '7 ""_ in the Office of the Recorder of Deeds of Cumberland County. Legal description attached, I hereby cenitY that this action affects an interest in the above described real property as set forth in the complaint. TRUE COP''Y H~Oi'~ RECORD In T8.'\timony wl'l'Ilrool, I ""fll unto bon my hand ::00 the seal \II saki Coort al Callt~. Pa. Thi d~ ,bv 01 >~a... ", 9.1:':') """J. "17. ProIhonollry //" I J /' ;{ By l./.l//d.C,;c.U., 'e 'L20' thleen Carey Daley, F,.s'qu DALEY LAW OFFICES 1029 Scenery Drive Harrisburg, P A 17109 (717) 657-4795 Attorney for PlaintitT ......."""""""...... r .r" ". ',. ow , ~I~....~, I , . , , ,1'1 OFFICe l)r fl!", Oint ';'I\'~IF' I' ~ Kit ZU ~ so r\\ '96 e,' ',\ I. '...L lltJlll ::,r VI AtHA 'I., ,11 ., " .,.j ~~ ~, .~ " ", ---., ..~.,~ . -:' ._,....- , " I. , , , " M m.. Victoria Wheeler Page Three September 25, 1995 ITATIUIIH'l8 You are, responsible for all fees, costa and expensea. You will receive an itemized statement on a regular basis. Any amount due is to be paid within thirty (30) day. of the atatement date. A lat.<> payment charge of one (It) percent, per month, which ia an annud percentage rate of (12\) percent, will be added to all unpaid balances over thirty (30) dars, The minimum late payment charge for unpaid balances over th rty (30) days will be $.50. Failure to keep your account current could lead to withdrawal of our fi~'s representation. In the event th~t our fi~~ is required to institute any legal action for collection of fees, expenses, or costs due to us for our services, I also will have the right to receive reasonable attorneys fees and costs in bringing such action against you. If any balance is due on your bill at the end of your case, you may be requested to sign a judgment note, with interest, to insure the balance of the fee. This policy may also be applied to anr billa accruing and unpaid, as we go along. I also reserve the r ght to diacontinue our repreeentation of you if all bills are not paid in conformity with this agreement. If you find that you are having difficult.y keeping your account current, you should discuss the matter directly with me or with our firm's billing manager. OFFICI PROCIDURlS While the rendering of legal services and paym~nt of fees form the basia of our relationship, the attorneys understand that legal mattera often involve periods of personal transition which generate many queBtions about the future. Our firm believes that good communication is a ke:,' ':0 a productive attorney/client relationship. Our office will send you copies of relevant papers coming into and going out of our offices, including correspondence, pleadings and other Court documents. Plea.e send me copies of any documents you receive relating to your caBe. If I am not available to you when you telephone, I will attempt to return your call within a reasonable amount of time. ...., Ma. Victoria Wheeler Page Four September 25, 1995 However, there will be times when I will be in Court, at meetings or in conference when you call which will prevent me from returning your call as quickly as we both might :ike, and there are times we will .imply miss each other's call. During those times, it is often helpful for you to send me a note with any questions or to explain a particular problem. Please remember that my secretary will offer any assistance that .he can, but you must keep in mind that she is not a lawyer and cannot give you any legal advice. If your problem ie urgent, pleaae let the secretary know. OUR RBPRB8BHTATION OF YOU It is imposeible to predict the couree that any legal matter may take. Sometimes it branches out into forms of litigation which were not readily appa~ent I\t the beginning of the caee. It is impo.sible to pradict the amount of time that will be necessary to complete your case. I will use my best judgment to determine the amount of time and the nature of the services that will be performed in your best interest. I will take whatever action I can to move your case along, but I have no control over delays that might be caused by the opposing party or the court system. It is not unusual to have some lapses of time between legal communications, actions, and proceedings due to the personal readjustment process that occurs for most people who are going through a legal matter and due to legal rules and court procedures. Every effort will be made to expedite your case promptly and efficiently according to the highest legal and ethical standards. I am committed to offering you the strongest guidance and direction in the event that you are prompted to make a decision which our experience indicates might harm you. While it is your case and you must make the financial and value judgments as opposed to decisions involving the law and knowledge of the Courts, if I become convinced that your judgment ia counterproductive to your best interests, I will indicate that to you in the strongest possible terms and may withdraw our firm'. representation and terminate our attorney/client relationship in the event that you persist. M.. Viotoria Wheeler Page Pive September 25, 1995 Similarly, our advice and guidance is based in large part on information you provide. In order to maintain our customary legal and ethical standards, I mu.t feel confident that you are acting with complete candor and truthfulness. If I become convinced that rou are not acting or intend not to act in suoh a manner, I will ndicate this to you;, and if you persist, I may withdraw our firm's representation and terminate our attorney/olient relationahip. ' Should our firm's with~cawal become necessary for the foregoing or any other reason including your requeat, you will be charged for the time expended to 4ccomplioh our withdrawal. HISC~T.T .WBOUS Unfortunately, as with life, there are no guaranteea in the law. By aigning thia letter, you acknowledge that I have made no guarantee. as to the di8p08ition of any phase of thia matter and other mattera for which you have retained our firm, and you acknowledge that all statements made by me are carefully conaidered opiniona. If you do not understand an}' of the word. or terms in thi8 letter, please call me. Your decision to be a responsible party in the attorney/client relationahip ia an important one I intend to be a. clear aa possible in thi8 letter and feel it ia the first atep in helping to eatablish a relationahip that is open and direct. We ask that you acknowledge receipt of this letter and your acceptanoe of it and the terms contained in the letter by aigning the copy and returning it to my offioe with your retainer in the amount of $500.00 in order for me to begin work on this matter. I am unable to do any work on your behalf or represent you aa your attorney until I reoeive the aigned copy of this letter and your retainer fee. If you plan to wait more than thirty (30) days to return thia letter with your retainer, please call my office to confirm the hourly rate and advance payment aa I cannot definitely be bound to theae rates for an undetermined period of time. As I indicated at our office conference, our attorney/olient relation.hip doe8 not begin until I am actually retained by you.