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Home My WebLink About97-05454 i'l " I . " I" , ,! I' " , \' "',1 I . "-I ,'i' " , I , ' , , , .t " " " ,,' , , , " ;' , 1 . , \, I, " 1 ~ ~ 1'1' I " "" i'l ,~ 3, At Respondent's request, on September 22, 1997, Petitioners flied a Complaint for Custody and an Emergency Petition for Special Relief for Respondent, docketed to No. 97-5162 Civil Term, and alEo allended an Expedited Custody Conciliation on Respondent's behalf. 4. At Respondent's request, on October 6, 1997, Pelltloners flied a Complaint In Divorce on his behalf, docketed to No, 97-5454. 5. Addlllonally, a Complaint In Support was filed by Respondent on or about October 8, 1991, docketed to #00937 S 1997. 6. Since August of 1997, Pelllloners have been rendering legal services on behalf of the Respondent. 7. As of November 7, 1997, Respondent's outs/andlng legal fees are In excess of $2,000.00, 8, The above referenced fee agreement states "we [Petitioners] reserve the right to terminate our allomey/cllent relationship for nonpayment of fees and costs," 9. On Octobsr 23, 1997, October 31, 1997 and November 14, 1997, Pelltloners advised Respondent that they would be unable to conllnue representing him unless he satisfied his outstanding balance, (A copy of such correspondence is allached hereto and t;ollecllvely marked as Exhibit "B.") 10, To date, Respondent has not only failed to satisfy his outstanding legal obligation, but has also failed to make even a partial payment toward his outstanding balance. 11. The Respondent's failure 10 remit any payment toward such an extensive outstanding balance has caused Petitioners to realize a financial hardship, 12, Moreover, Respondent has repeatedly failed to maintain contact with Pelltloners, More specifically, Respondent changed residences and failed to notify Petitioners. Therefore, for approximately two weeks, Petitioners continued to send time sensillve correspondence to Respondent at his last known address, which apparenlly had gone unread until Petitioners learned from opposing counsel that JEItItY It DUFFIE ItICHAItD w. ~rEWAItT C, 1l0Y WEIDNEIt, III EDMUND G. MYEIU DAVID W, DELUCE ItALPH H WItIGHT, lit DAVID I. LANZA IOSEPH L HrrCHINGS MAItK c. DUFFIE LAW OFFICE~ JOHNSON, DUFFIE, STEWART & WEIDNER A Pro(el5lonal Corporation 301 MARKET STREET P. O. BOX 109 LEMOYNE, PENNSYLVANIA 17043-0109 HOIVoCE A 10HN~ON 0' COUNUL TELEPHONE 717.761.1540 FACSIMILE 717.761.3015 E.MAIL 1I11110Jd,w.com Augus126,1997 Floyd N. King 1440 Garden Avenue New Cumberland, PA 17070 Re: Fee Agreement Dear Mr. King: Thank you for consulting Johnson, Duffie, Stewart & Weidner regarding your domestic relations case, This leller sets forth tha agreement concerning our representation of y"u end I would appreciate receiving a countersigned copy of this letter. Many years of experience have taught us that the ellorney client relationship functions best when both parties are fully aware of the scope of the representation and their respective obligations. The purpose of this letter Is to set forth, In writing, the arrangements concerning our services and our fee, so that we mey avoid any misunderstandings. We have requested a retainer of $250.00, which shall be epplled against the then hourly rate of the allorney performing the service. My Initial rate for this case Is $100.00. As we discussed, due to your financial situation, we have agreed to lower the standard domestic relations retelner rate with the understanding that you will be billed monthly for all work done on your file, You will ba billed for all time spent on your case Including, but not limited to, conferences, telephone calls, pre-trial discovery, trial preparation, document drafting, correspondence and pleadings, negotiations, legal research, court tlma and travel to and from locations away from my office. Your adversery, the opposing allornay or others may engage In ac.;lvltles beyond my control that require time that was not originally contemplated. If this malter has not been concluded within twelve months of the date of this agreement, hourly rates may be adjusted to conform to my prevailing hourly rates. You will be responsible for all c.osts that we may Incur on your behalf. Thase costs Include, but are not limited to, computerized legal research, messengers, experts (Includlno C.P.A" pension evaluators and real estate appraisers) filing fees, service of process fees, depositions, subpoenas and witness fees. It may be necessary to have any real estate appraised, and you will be responsible for that cost. If applicable to your particular situation, It may also be necessary to have a value placed on a business Interest and, again, you wUl be responsible for that cost. These Items should be separetely Itemized on our billing statements. Time spent on your file will be charged In minimum Increments of ten (10) minutes, This Includes telephone cells and correspondence, recognizing the time Involved In retrieving the file, examining the documents or lellers required, In addition to the time spent to consider snd deal with the problem. We reserve the right to terrnlnate our attorneylcllent relationship for nonpayment of fees end costs. We will bill you perlodlcelly and will notify you In advance If It appears that your retainer has been exhausted. If there Is stili e;onslderable work to be done on your case, you may be asked to replenish your retainer. If, howevflr, your case concludes before the lotal charges equallhe amount of the retslner, you will Floyd N, King August 26, 1091 Psge 2 receive s refund of the difference. Any sletement for services rendered must be psld within thirty (30) deys of receipt of the stetement by you. You will be chsrgEld Interest at s yearly rate of 12% (1% per month) on any outstanding balance not paid within thirty (30) days. We reserve the right to terminate our ettorney client relationship If you do not pay our fees and disbursements within thirty (30) days of billing, this polley Is strictly enforced es we do not think It Is fair to esk clients who pay their bills when du'il to finance the legal cost of others who are delinquent. Unfortunately, It Is Impossible to estimate for you the totel emount of time that will have to be devoted to your case. That will depend upon a variety of fsctors, primarily upon whether hearings or e trial will be necessary, the time and effort required, the nature and complexity of the Issues Involved and the degree of cooperation afforded by y'M spouse and your spouse's attorney. Similarly, we cennot guarantee tile results that will be obtained, partlculerly since no one can predict what e court may do In a particular cese. On some occasions, a Court will order one spouse to pay all or part of the other spouse's fees, Sometimes, the Court makes no order for fees and costs, Beceuse fees en<.J costs awards ere totally unpredictable, Court orderll must be considered to be msrely "on account", and you are primarily liable for payment of the total fee. Of course, amounts received pursuant to a Court Order will be credited to your account. We will, of course, keep you closely advised of all progress of your case and provide you with copies of ell correspondence, pleadings, and other documents. We understand that In mstters of this nature, urgent circumstances may arise which may necessitate your talking to your attorney Immediately, We, therefore, have made a strong commitment to respond to all of your InqUiries as soon as possible. However, underslendably there llre occasions when we are not Immediately avatlable because of commitments to other ceses. In such Instances, our assistants are given Instructions as to how to reach us or another attomey In our office, You should never hesitate 10 ask us questions, which we always welcome, You have the right to terminate our services at any time, for any reason. As stated above, we reserve the right to terminate the representation upon your fatlure to pay our fees. and relmburseble expenses within thirty (30) days of billing. We reserve the right to terminate the relationship, for any other reason, upon thirty (30) days written notice to you. We reserve the right to terminate the relationship Immediately In the event that ceuse exists under the Pennsylvania Rules of Professional Conduct, which governs attorneys' behavior. You acknowledge that I hove made no guarantee regarding the disposition of eny phase of your cese. All my expressions relallve to your cese ere only my opinion. Please date and countersign this egreement end e copy so that we will have a mutual memorandum of our understanding, You should retain a copy for your file. ~ IEMY ~ DUFFIE ....CHARD W. HEWMT C. ROY WEIDNE~ 'R. EDMUND C. MYEIU D^VID W. DILUCE ~PH H. W....CYT. IR. D^VID I. L^N~ 105EPH L HITCHING5 MAAK C. DUFFIE KEIIU TEN L W N.5H I,^W OFFICB JOHNSON, DUFFlE, STEWART ^ Prof.ulon.1 Corporation 301 MARKET STREET P. O. BOX 109 LEMOYNE, PENNSYLVANIA l'10i3.0109 & WEIDNER fILE COpy HOMCE ^ IOHN~ON 0, CollN..l. TELEPHONE 717.761.1540 F^CSIMILE 717.761.3015 I.MAIL m.UOJd.w.com November 14,1997 Floyd N. King 4MCD BUilding 54, Suite 3 Box 606 New Cumberland, PA 17070 Re: Floyd N. King v. Carol A. King Dear Floyd: ...~~~..,hIAN~~olI~ laI~~ ~l4lIAl"~___~~~~u....~ ~~is~w~~'~L""IC"__~ ~~"tT ~I"'.,*= ~~l.""IJlIf'\.~~..t~lJL~-'t""41.~~~~r.M* e~~tC1fQre(.=~CIlW'~.I~.~ =1IdJ\IIUtQ~~~~M ~~V'~~~"'- - - ~"l"~- ,1'f<<!'<<l!dIt~~-..r---- . As I am sure you know, you have a substantial outstanding balance with this firm. As I have mentioned to you In numerous pieces of prior correspondence, you will need to satisfy that balance In full, and pursuant to the terms of our fee agreement, provide me with an eddltlonal retainer before any further action can be taken In your case. Your custody hearing Is scheduled for Monday, December 15, 1997. We wlll need several weeks to prepare for that hearing, and therefore, I will need for you to satisfy your outstanding balance, and provide me with an additional $1,000.00 retainer no later than Friday, November 21,1997. I will have no alternative but to withdraw from your case entirely If your balance Is not satisfied by that time. Please contact me upon your recalpt of this leller so that we may decide how best to procaed. I hope that Carol's move to Texas went smoothly and I hope you were able to visit with Adrlen while you were down there. As I mentioned before, It Is absolutely Imperative that you keep In close contact with Adrien while he Is In Texas and away from you. I look forward to hearing from you In the very near future. Very truly yours, JOHNSON, DUFFIE, STEWART & WEIDNER Kelrsten L. Walsh KLW:mh: 1 03317 , , " , , ,.1' ". , , , , C:)' \/., ~~ " -.J " ,1" . ',~ .} .,~ i , 1 . '1 /I,i 'I', >'.) ;, I " .'J,.!., , , , , . ; ~ "I :.1: I' , .4,) 1', r- .i'" , '.;~: ,. ! 'J ":;'l "1 -', Il:> .... " ~ .~~ ~ (') (" ..0 '=><1 .. ~l ( ) ~ ~r' . ..~ '. -., r,l)1 ~ , , ., ......, ... ~ I ,''1 "'"' ~ c::, , I ' . c::1i l., "I I ~ ~ , " ',L) ... ~ , :." II) .).:1, : .., i',ll \ll -- . . S'? ., I , .irn "'" - -. =J ::J .;.J t:~ ..t'> ~ 01 :::J '0 -- ~~ .$ . \ Ilo ~ I' , . - . 1 . ~ :~ " ~: : 0" i~ g~~ z~: o. : ~! 4'- .....: m-o iO' .., -<: >oJ.-c:, : -....\ " " ',! .1 " " " " ,01 , , " " , , ' ~), il 'D 0 ,. ..., .., ""It I :~ "0' , f'll "1 1'.7 " -, I " j~r) I;" , f~) ~... -~ J "I " .... '}(') '",' , I!" \")1'1-' ~ " ,:J, , :') "... " :J 1:0 .... 1,\ " " 3. At Respondent's request, on September 22, 1997, Petitioners filed a Complaint for Custody and an Emergency Petition for Special Relief for Respondent, docketed to No. 97.5162 Civil Term, and also allended an Expedited Custody Conciliation on Respondent's behalf. 4. At Respondent's request, on October 6, 1997, Petllloners flied e Complaint In Divorce on his behalf, docketed to No. 97.5454. 5. Additionally, a Complaint In Support was filed by Respondent on or about October 8, 1997, docketed to #00937 S 1997. 6. Since August of 1997, Petitioners have been rendering legal services on behalf of the Respondent. 7. As of November 7,1997, Respondent's outstanding legal fees are In excess of $2,000.00. 8. The above referenced fee agreement states "we [Petitioners] reserve the right to terminate our attorney/client relationship for nonpayment of fees and costs." 9. On October 23, 1997, October 31, 1997 and November 14, 1997, Petllloners advised Respondent that they would be unable to continue representing him unle$s he satisfied his outstanding balance. (A copy of such correspondence Is attached hereto and collectively marked as Exhibit "8.") 10. To date, Respondent has not only failed to satisfy his outstanding legal obligation, but has also failed to make even a partial payment toward hl~ outstanding balance. 11. The Respondent's failure to remit any payment toward such an extensive outstanding balance has caused Petitioners to realize a financial hardship. 12. Moreover, Respondent has repeatedly failed to maintain contact with Petitioners. More specifically, Respondent changed residences and failed to notify Petitioners. Therefore, for approximately two weeks, Petitioners continued to send time sensitive correspondence to Respondent at his last known address, which apparently had gone unread unlll Petitioners learned from opposing counsel that IEIlIlY ~ DUFFIE IlICH^IlD W. 5TEW^IlT C. 1l0Y WEIDNEIl, 'Il. EDMUND G. MYE~ D^VID W. DILUCE MLPH H WIlIGHT, Ill. D^VID J. L^N~ 'O~EPH L HITCHING5 M^IlK C. DUFFIE L^W OFfICE~ JOHNSON, DUFFIE, STEWART & WEIDNER ^ Proreaalonal Corporatlon 301 MARKET 5T1lEET P. O. BOX 109 LEMOYNE, PENNSYLVANIA 170i3-0109 HOMC! ^ IOHN~ON 0' CO~SlL TELEPHONE 717.761.4510 MCSIMILE 717.761.3015 I.MAIL mIIIOld,w.com August 26, 1997 Floyd N. King 1440 Garden Avenue New Cumbarland, PA 17070 Re: Fee Agreement Dear Mr. King: Thank you for consulllng Johnson, Duffle, Stewart & Weidner regarding your domastlc relations case. this letter sets forth the agreemsnt concerning our representation of you and I would appreciate recalvlng a countersigned copy of this lelter. Many years of experience have tought us that the eltorney client relationship funcllons best when both parties are fully aware of the scojJe of the representallon and their respecllve obllgallons. The purpose of this letter Is to set forth, In writing, tho arrangements concarnlng our services and our fee, so that we may avoid any misunderstandings. We have requested a retainer of $250.00, which shall be applied against the then hourly rate of the altomey perfonnlng the service. My Initial rate for this case Is $100.00. As we discussed, due to your financial sltuallon, we hava agreed to lowar the standard domestic relations retainer rate with the understanding that you will be billed monthly for all work done on your file. You will be billed for all time spent on your case Including, but not limited to, conferences, telephone calls, pre-Irlal discovery, tr1al preperatlon, document drafllng, correspondence and pleadings, negotiations, legal rasearch, court time and travel to and from locations away from my office. Your adversary, the opposing attorney or others may engage In acllvltles beyond my control that raqulre time that was not originally contemplated. If this malter has not been concluded within twelve monllls of the date of this agreement, hourly rates may be adjusted to conform to my prevailing hourly rates. You will be responslbla for alt cosls that we may Incur on your behalf. These coste Include, but are not limited to, computerlzac1legal research, messengers, experts (Including C.PA, panslon evaluators end real estate appraisers) filing fees, service of process fees, deposlllons, subpoenas and witness fess, It may be nscessary to have any real estate appraised, and you will be responsible for that cost. If applicable to your particular sltuallon, It may also be necessary to have e value placed on a buslnass Interest and, again, you will be responsible for that cost. These Items should be sepal'ately Itamlzed on our billing stetemenls. Time spent on your file will be charged In minimum Incremsnts of ten (10) minutes. This Includes telephone calls end correspondence, recognizing the time Involved In retrieving the file, examining the documents or letters required, In addition to the time spent to consider and deal with the problem. We reserve the right to terminate our attomey/cllent relallonshlp for nonpayment of fees and costs. We will bill you periodically and will nollfy you In advance If It appears that your retainer has been exhausted. If there Is stili considerable work to be done on your case, you may be asked to replenish your retelner. If, however, your cass concludes before the total charges equal the emount of the retainer, you will Floyd N. King August 26, 1997 Peg" 2 receive a refund of the difference. Any statemsnt for sarvlces rendered must be peld within thirty (30) days of receipt of the statement by you. You will ba charged Interast at e yeerly rete of 12% (1% per month) on eny outstendlng balence not peld within thirty (30) deys. Ws reserve the right to termlnete our ettorney client reletlonshlp If you do not pey our fees end disbursements within thirty (30) deys of billing. This policy Is strictly enforced as we do not think It Is fair to esk clients who pey their bills when due to finence the legel cost of others who are delinquent. Unfortunetely, It Is Impossible to estlmete for you the totel emount of time that will heve to be devoted to your case. Thet will depend upon e variety of factors, primarily upon whether hearings or e trial will be necessary, the time and effort required, the nature and complexity of the Issues Involved end the degree of cooperation afforded by your spouse end your spouse's ettorney. Slmllerly, we cannot guarantee the results that will be obtelned, particularly since no one cen predict what a court may do In a particular casa. On some occasions, e Court will order one spouse to pey ell or part of the other spouse's fees. Sometimes, the Court makes no ordar for fees end costs. Becausa fees end costs ewards ara totally unpredictable, Court ordars must be considered to bs merely "on eccount", and you ara prlmartly lIeble for payment of the total fee. Of course, amounts received pursuant to a Court Order will ba credited to your eccount. We will, of coursa, keep you closaly advised of ell progress of your case end provide you with copies of ell correspondenca, pleadings, end othar documents. We underntand that In matters of this nature, urgent clrcumstancas may erlse which may necessitate your talking to your ettorney Immediately. We, therefore, have made a strong commitment to respond to atl of your Inquiries as soon as possible. However, understandably there are occasions when we are not Immediately evetlable because of commitments to other r.eses. In such Instances, our esslstants are glvan Instructions aa to how to reach us or another attomey In our office. You should never hesitate to ask us questions, which we always welco:lme. You have the right to terminate our services et any time, for any reason. A.., stated above, we reserve the right to terminate the representation upon your failure to pay our fees, end relmburseble expenses within thirty (30) days of billing. We reserve the right to terminate the relationship, for any other reason, upon thirty (30) days written notice to you. We reservs the right to terminate the relationship Immadlately In the event thet cause exists under the Pennsylvania Rules of Professional Conduct, which governs ettorneys' bshavlor. You acknowledge that I have mede no guarentee regarding the dlspo~ltlon of any phase of your casa. All my axpresslons relative to your cesa ere only my opinion. Pleasa date end countersign this agreament and e copy SO that we will have a mutuel memorendum of our understendlng. You should rst,ln e copy for your file. lIMY i\. DUfFI~ IYCHMD W. 5nWMT c. II.OY W~IDN~~ I~ ~DMUND G. MYlIU D^VID W. DILUC~ MLPH H. W....CHT, I~ D^VID I. L^N~ 10~U'H L HITCHINc:. MMK C. DUFFIE KlIIUTEN L W~H l^W OFflCB f I L E COP Y JOHNSON, DUFFlE, STEWART & WEIDNER ^ Profc..lor..1 Carpor.llon . 301 MARKET STREET HOMC~ ^ 10HN$ON 1'. O. BOX 109 o. COUlln\. L1!MOYNE, PENNSYLVANIA 170i3 -0109 nL'.'HoNB 717.161-4HO ,^ClIMILE 717.761-3015 I.M^IL m,i10Jd,w...m November 14,1997 Floyd N. King 4MCD Building 54, Suite 3 Box 606 New Cumberland, PA 17070 Re: Floyd N, King v, Carol A. King Dear Floyd: "W\NI;~~~rlA ~~~olI"1:i" laI~:;~ ~IAlloAN_._~~~~\A.. __~~nlJ."'4<I'''_~ _~"tT" ~IWtI."IM1i' ~~~_~..tlaM1~"'I~~,*",~~*~ E==~.ft..lIl~lWeCllW'~.~""W~ ~~"'~""*,,V.," ~1MU\fl1Q\"1'''''' ......""""',.l~'<~K~~~GIIlU. l.4lf"~HIVIWI, As I am sure you know, you have a substantial outstanding balanca with this firm. As I have mentioned to you In numerous pieces of prior correspondenca, you will need to satisfy that balance In full, end pursuant to the terms of our fee agreement, provide me with an additional retelner before any further action can be taken In your case. Your custody hearing Is scheduled for Monday, Oecamber 15, 1997. We will need several weeks to prepare for that hearing, and therefore, I wlll need for you to satisfy your outstanding balance, and provide me with an additional $1,000.00 retaIner no later than Friday, November 21, 1997. I will have no altematlve but to withdraw from your case entirely If your balance Is not satisfied by that time. . Please contact me upon your receIpt of this leller so that we may decide how best to procaed. I hope that Carol's move to Texas went smoothly and I hope you were able to visit with Adrlen while you were down there. As I mentioned before, It Is absolutely Imperative that you keep In close contact with Adrlen while he Is In Texas and away from you. I look forward to hearing from you In the very near future. Very truly yours. JOHNSON, DUFFIE, STEWART & WEIDNER I<elrsten L. Walsh KLW:mh:103317 , ' , , , , I' I, , , " I, " " , I " ,., ,I EXHIBIT "B" , , , 1'/ .t' , " . ~ I, I " I., , t ~ " '~ ' ' ."".iiJ.i';~;:,,.,...'ii I, ":.' '~.' I I " L^W OfFICES'l/,,' .;. \~I.~'~.:,~; "I'II~?~'~;!'~,'I;.~'" ",' ; .)', . I l' . .. I.;'., -l"v.,t. r, ' r I I, , , .I' ~ ' . '. I~ !.. I) oJ' I ~,""::',.' ','.'.:. :::'. . . '. ",' JOHNSON, DUFFIE, STEWART N"WI:.IDN,ER \..:....1;',\ ". ~".;C ,:"I;I~;'; ,I. ; :;.': '. "~'L 'S j , I I ,j' "'r'~ 'it' L~' ,t.\~,!..", ".~:l~....~ ".,\,.,;.4, I"~ , 3010,..,I,,,,t,' t'r~lt' ,I,"' :1 ~ 'I" ,I ' : t\ il'!'lli',"::i,,',i:',,: :,":':'1. !";':t'!i'::~".'::':T.i:.:f;~~..\lI1)76H540 P,'()"B.ii~109'~;,'. ;' .,.. .,',' "', :.'" I'., I",' """ ..'...."1'., "'f"'" Tel m761.J0I5 Llmovni"',nn.,lvln,rn04'.Ol09 " t I" 1'/ "". I.., ,---" ....;4 l;,'.l11~.. '~""!"~ " ~.l "L'l\. I', 1',' ..' (",..,: ,l r [~.'!.I'!'.'~I '. I. ( 1, 'i,' '~," ~.', I "t"~r...,t:"~{'~~~,,\'''~''~~',.~Ij''I'~I' ~~. .~.i..L.'~I;~.:i-,.~~-I.._...:...~.. .. _;.,'~u..~~..;.~.~_._..........~ =...."-... .~-97-S-IZ';;::'" 'h. CERTlFICA TE OF SERVICE AND NOW, this \.J. day of December, 1997, the undersigned does hereby certify that she did this date ssrve a copy of Ihe foregoing Pelillon to Withdraw as Counsel Order upon the other parties of rllcord by causing same to be deposited In the United States Mall, certified mall, return receipt requested, et Lemoyne, Pennsylvania, addressed as follows: (") .::J (") Robert P. Kline, Esquire ~ -.J .;/, P.O. Box 461 ~i-t -:-0 -, rf" . ., \n New Cumberland, PA 17070-0461 :..:1, ;-, ,. . 123 !J) <'..:> '6 Floyd N. King r;; :-: .1 .. . ~~~ 'i~J 4MCD :..;,' _J "l Building 54 Suite 3 .... [.; \of' :')Ir .. .-~ .-' ~'1 ~ Box 806 ::; <n New Cumberland, PA 17070 JOHNSON, DUFFIE, STEWART & WEIDNER By: r+J :103909 ,. '!.My R. DUFFIE ....CHMD W. ~TEWMT C. ~OY WEIDNE~ 'R. EDMUND C. MYEIU D^VID W. DILUCE ~PH H. WRlCHT. I~ D^V1D J. ~~ J05EPH L HITCHING5 MMK C. DUffiE KEIR5TEN L WN.5H ~WOFFICE5 fILE COpy JOHNSON, DUFFIE, STEWART & WEIDNER A Prof...lonal Corporation . . 301 MARI<ET STREET HOMCE ^ 10HNSON P. O. BOX 109 0' COUNSEL LEMOYNE, PENNSYLVANIA 170i3.0109 TELEPHONE 717 .761-4,.0 F^CSIMILE 717.761.3015 I.MAIL mlllCld.w.com November 14,1997 Floyd N. King 4MCD Building 54, Suite 3 Box 806 New Cumberland, PA 17070 Re: Floyd N. King v. Carol A. King Dear Floyd: ...~~IotlIiltllV'hlA Vq~~.a~ laI~ ~t ~IAl"KN"._~~~~u....~ __~i st'W.4Itijla(I~M~.ItU$f~ ~~"t"'IJ\W" .*'n..... ~t~~~~=== ~~=~~~~~;:;t~~~~1M As I am sure you know, you have a substanllal outstanding balanca with this firm. As I have mentioned to you In numerous pieces of prior correspondence, you will need to satisfy that balance In full, and pursuant to the terms of our fee agreement, provide me with an aodlllonal retaIner before any further acllon can be taken In your case. Your custody hearing Is scheduled for Monday, December 15, 1997. We will need several weeks to prepare for that hearing, and therefore, I will need for you to satisfy your outstanding balance, and provide me with an additional $1,000.00 retaIner no later than Friday, November 21. 1997. I will have no altematlve but to withdraw from your case entirely If your balance Is not satisfied by that time. Please contact me upon your receipt of this letter so that we may decide how best to proceed. I hope that Carol's move to Texas went smoothly and I hope you were able to visit with Adrlen while you were down there. As I mentioned before, It Is absolutely Imperative that you keep In close contact with Adrlsn while he Is in Texas and away from you. I look forward to hearing from you In the very near future. Very truly yours. JOHNSON, DUFFIE, STEWART & WEIDNER Kelrsten L. Walsh KLW:mh:103317 '...-._-,-.,...~