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Home My WebLink About00-06291 '-'-~ ~ '. ,,-' .~" . . :..w,_"""i: IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA DAVID P. PERKINS AND JERRY A. WEIGLE t/dlb/a WEIGLE, PERKINS & ASSOCIATES Plaintiffs, CIVIL ACTION - LAW vs. NO. to. ~::29 I ;;J ROBERT J. BECKER Defendant. NOTICE You have been sued in court. If you wish to defend against the claims set forth in the following pages, you must take action within twenty 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 judgement 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 LA WYWER 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, Pennsylvania 17013 717-249-3166 WEIGLE, PERKINS & ASSOCIATES - ATTORNEVS AT LAW ~ 126 EAST KING STREET - SHIPPENSBURG, PA 17257-1397 , , .~ ,-,;", '- - -,,-,,; ,', '1""'-'-,,=% IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA DAVID P. PERKINS AND JERRY A. WEIGLE t/d/b/a WEIGLE, PERKINS & ASSOCIATES Plaintiffs, CIVIL ACTION - LAW vs. NO. IJ-{J-(.J. '11 &;x;p r~ ROBERT J. BECKER Defendant. COMPLAINT 1. Plaintiff, Weigle, Perkins & Associates, is a law firm and partnership, organized and existing under the laws of the Commonwealth of Pennsylvania with its principal place of business located at 126 East King Street, Shippensburg, Cumberland County, Pennsylvania. 2. Defendant, Robert J. Becker is an individual and citizen of the Commonwealth of Pennsylvania with an address at 2242 Lindsay Lot Road, Shippensburg, Pennsylvania. 3. On April 18, 1996, Plaintiff entered into an agreement with Defendant whereby Plaintiff agreed to provide legal services to Defendant and Defendant agreed to pay Plaintiff one hundred dollars ($100.00) per hour, its customary and usual fees for the services performed and all costs incurred on his behalf in connection with services rendered. 4. During the course ofjts legal representation of Defendant, Plaintiff maintained books of account on the services that it rendered and the costs that it incurred WEIGLE, PERKINS & ASSOCIATES - ATTORNEYS AT LAW - 126 EAST KING STREET - SHIPPENSBURG, PA 17257-1397 """ . -,-- -., '~ '~,,"""'I<Il4*,c" on Defend,ant's behalf, which accounts are an accurate and running account of all debits and credits for the provision of such services and incurrence of such costs, 5, Periodic invoices were mailed to Defendant setting forth the services which had been rendered by Plaintiff on Defendant's behalf during the previous months, the reasol)able value being charged for the services, and any outstanding balance due on services rendered prior to that time, 6. During the course of Plaintiff's representation of Defendant, Defendant made periqdic payments on the outstanding balance of his account. 7, On or about March 2, 2000, Plaintiff rendered the last of numerous written accounts t\l Defendant in the amount of$I,092.50, A true and correct copy ofthe accounts sent to Defendant are attached to and incorporated into this complaint as Exhibit A. 8. Although Plaintiff has demanded payment of the balance due of $1,092.50, Defendanthas failed to pay all or any part of the balance due Plaintiff, 9, Plaintiff performed its obligations under the agreement between it and Defendanj: by providing valuable legal services to Defendant and incurring costs on his behalf; the fair and reasonable value remaining unpaid of which is $1,092.50. 10. Plaintiff has performed its services for Defendant fully and satisfactorily, and conformed to, and complied with, all of the terms and conditions required of it under the oral aweement between it and Defendant. 11. Despite Defendant's obligation to pay Plaintiff for the services performed and costs incurred on his behalf and despite Plaintiff' s demands on Defendant for such payment, Defendant has wrongfully failed and refused to pay to Plaintiff the sums due it. WEIGLE, PERKINS & ASSOCIATES - ATTORNEVS AT LAW - 126 EAST KING STREET - SHIPPENSBURG, PA 17257-1397 C',. ". - -- ,~- .', l'lIiIJ.;~<!'"".,""",,, 12. Defendant has had an opportunity to scrutinize the accounts. 13. Defendant has agreed to or acquiesced in the correctness of the accounts. 14. Defendant has never questioned or objected either specifically or generally to the numerous accounts rendered. WHEREFORE, Plaintiff, Weigle, Perkins & Associates, demands judgment against Defendant in the amount of$I,092.50 together with costs and any other relief this court deems appropriate. Dated: 9/S-/00 , rry A. igle, Esquire I.D. # 0162 WEIGLE, PERKINS & ASSOCI 126 East King Street Shippensburg, P A 17257 Telephone: (717) 532-7388 VERIFICATION I verify that the statements made in the foregoing Complaint are true and correct. I understand that false statements herein are made subject to the penalties of 18 Pa. C.S. 4904, relating to unsworn falsification to authorities. Dated: Cf I ~ / 0 ~ a~ WEIGLE. PERKINS & ASSOCIATES - ATTORNEYS AT LAW - 126 EAST KING STREET - SHIPPENSBURG, PA 17257-1397 ~ ~ F\LE Robert Becker c/o Ms. Patricia Pursell 2242 Lindsay Lot Road Shippensburg, P A 17257 ~~.. WEIGLE, PERKINS & ASSOCIATES Attornevs-at- Law 126 East King Street Shippensburg, PA 17257-1397 Ph(717) 532-7388 Fax:(717) 532-6552 File #: In\' #: DATE Mar-02-00 DESCRIPTION Billing fee HOURS AMOUNT 0,00 10,00 Totals 0.00 Tut:11 Fees & l}ishursements Pre\'iolls Balance Pre\'iolIs Payments Balance Due Now EXflIBIT A $10,00 ~, ""-, "'-='"""-',",'>;.;. March 2, 2000 BeckerRobert 1260 SIO.OO $1.OR2,50 $0,00 SI,092.50 - ~'"""~"'._'~"'k","~I', WILLIAM R. MARK (191 :.1980) JERRY A. WEIGLE DA VlD p, PERKINS MARK, WEIGLE AND PERKINS Attorneys-aI-La,,' 126 EAST KI:-iG STREET SIIIPPENSBURG. PENNSYLVANIA 17257-1397 TELEPHONE (717) 532,7388 OR (717) 776-1295 FA,.'( (717) 532-6552 APotiate JOSEPH p, RUANE f-' February 15, 1999 Robert Becker c/o Ms, Patricia Pursell 2242 Lindsay Lot Road Shippensburg P A 17257 Additional charges: Amount 2/15/99 Billing Fee 10,00 Total costs $10,00 Balance as per prior Statement $1,072.50 Balance due $1,082.50 PA YMENT IS DUE UPON RECEIPT OF THIS BILL. PLEASE MAKE CHECK PAYABLE TO "MARK, WEIGLE AND PERKINS". A billing fee of ten dollars ($10,00) per monthly statement will be charged after thirty (30) days, c , , - -.&,~......."'" WILLIAM R. l\L\RK (191 :2-19!iO) .JERR\' A. WEIGLE DAVID p, PERKINS MARK, WEIGLE AND PERKINS Attorne.l's-al-Lall' 126 EAST KING STREET SIIIPPENSBURG, PE:<i,'i,WLVANIA 17257-1397 Associate .JOSEPI/ p, RUANE TELEPHONE (717) 532-7388 OR (717) 776--1295 FAX (717) 532-6552 F ~ ~ ~~ January 7, 1999 - Robert Becker c/o Ms, Patricia Pursell 2242 Lindsay Lot Road Shippensburg P A 17257 Additional charges: Amount 1/7/99 Billing Fee ]0,00 Total costs $10,00 Balance as per prior Statement $1,062.50 Balance due $1,072.50 PAYMENT IS DUE UPON RECEIPT OF THIS BILL. PLEASE MAKE CHECK PAYABLE TO "MARK, WEIGLE AND PERKINS", A billing fee often dollars ($10,00) per monthly statement will be charged after thirty (30) days, . ~"... ......"f__,'''''''''''~NO''''', Robert Becker Page 2 Hours Amount 5/28/98 Preparation for hearing 1.00 100,00 5/29/98 Representation at District Justice preliminary hearing 1.00 100.00 6/11/98 Telephone call with client and correspondence 0,25 25,00 6/17/98 Office conference - correspondence regarding ARD 0,50 50,00 qualification 8/24/98 Telephone call to District Justice and District Attorney 0,25 12,50 9/27/98 Review of correspondence from District Attorney's office - 0,25 25.00 short correspondence back to District Attorney's office 10/1/98 Correspondence to Cumberland County District Attorney's 0,25 25,00 office 10/2/98 Returned call to Cumberland County District Attorney's office 0.25 25,00 regarding assault charge 10/23/98 Call from District Attorney's office regarding assault case 0,25 25,00 10/26/98 Returned call to Cumberland County District Attorney's office 0,25 25,00 regarding Becker plea bargarin 10/28/98 Correspondence to client - previous calls from District 0,50 50,00 Attorney's office 11/18/98 Call to client - short correspondence to District Attorney's 0,25 25,00 office 11/20/98 Representation at arraignment and sentence regarding simple 2.25 225.00 assault charge For professional services rendered 11.25 $1,] 12,50 Balance as per prior Statement $475,00 - . - ~ .""'iwIr~vI"'t"'" Robert Becker Page 3 Amount 7/5/96 Payment - thank you ($300.00) 7/24/96 Payment - thank you ($175:00) 1217/98 Payment from account ($50,00) Total payments ($525,00) Balance due $1,062.50 PAYMENT IS DUE UPON RECEIPT OF THIS BILL. PLEASE MAKE CHECK PAYABLE TO "MARK, WEIGLE AND PERKINS", A billing fee of ten dollars ($10,00) per monthly statement will be charged after thirty (30) days. Previous balance of Client funds 5/5/98 Deposit to account 12/7/98 Payment from account $0,00 $50.00 ($50,00) New balance of Client funds $0,00 '.,-.,.-.;>-, iiliilii/"" '~U'" "_~'",,-"._ 'r._ . ~f_. ~ ~, '""~.~~~,1JliH-~.M<~t,.!j"j1WJ' .... ~ -- ".- ,-, ,'~~ . .~^ , "'- -,--,,---~,- -."~ -- , ,.,-, ~"' ,~> ..-,,, -. ., ~~ i t- ~ ~ \\ "- C) "- ~ ~ & \ ~ ~ \ . ~ :11l!ll'l1t;m.dl.' ~,'~~~'- - ~~ ~ ~ \~ " . ~ (') c: $: ri{~ ~~ ~:~.: 1<0 ?;g S;.~ ~ .< " ~ (..-:l e> 0') M .." o -n ::'j -L-n " rn i:= -om :nO C:~,..l, 5::-J>f, :!J z(") Om ~. ~ .r:- " :x N .. r ()) ~ ~f~"'~- . ~~".. - ~- - - -~.,~=~",-" ~"",-; SHERIFF'S RETURN - REGULAR CASE NO: 2000-06291 P COMMONWEALTH OF PENNSYLVANIA: COUNTY OF CUMBERLAND PERKINS DAVID P ET AL VS BECKER ROBERT J HAROLD J. WEARY , Sheriff or Deputy Sheriff of Cumberland County,pennsylvania, who being duly sworn according to law, says, the within COMPLAINT & NOTICE was served upon BECKER ROBERT J the DEFENDANT , at 1251:00 HOURS, on the 25th day of September, 2000 at CUMBERLAND CO SHERIFF'S OFC ONE COURTHOUSE SQUARE CARLISLE, PA 17013 by handing to ROBERT J. BECKER a true and attested copy of COMPLAINT & NOTICE together with and at the same time directing His attention to the contents thereof. Sheriff's Costs: Docketing Service Affidavit Surcharge 18.00 13.02 .00 10.00 .00 41.02 So Answers: rl'7/' . ~ ~~f--'" R. Thomas Kline 09/27/2000 MARK WEIGLE & PERKINS Sworn and Subscribed to before By: 7j,A--'t,~ ~j--b~ Deputy erHf me this 6<& day of (@rl;, J". , d trtrO A . D . Ch. (}.~nr'f rothonotary , _<l!Ji_Wi .0( - IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA DAVID P. PERKINS AND JERRY A. WEIGJLE tJdlblal WEIGLE, PERKINS & ASSOCIATES Plaintiffs, CIVIL ACTION - LAW NO. 00-6291 Civil Vs. ROBERT J. BECKER, Defendant PRAECIPE FOR ENTRY OF DEFAULT JUDGMENT To: Prothonotary Please enter default judgment against the Defendant, Robert J. Becker, in the amount of One Thousand Ninety-two Dollars and Fifty Cents ($1,092.50) together with costs. I hereby certify that written notice of intent to file this praecipe was mailed to th efendant on December 12, 2000 (copy attached). y\ December 27. 2000 Dated WEIGLE, PERKINS & ASSOCIATES - ATTORNEYS AT LAW - 126 EAST KING STREET - SHIPPENSBURG, PA 17257-1397 IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA DAVID P. PERKINS AND JERRY A. WEIGLE tJdfb/al WEIGLE, PERKINS & ASSOCIATES Plaintiffs, CIVIL ACTION - LAW NO. 00-6291 Civil Vs. ROBERT J. BECKER, Defendant To: Robert J. Becker Date of Notice: December 12,2000 IMPORTANT NOTICE YOU ARE IN DEFAULT BECAUSE YOU HAVE FAILED TO ENTER A WRITTEN APPEARANCE PERSONALLY OR BY ATTORNEY AND FILE IN WRITING WITH THE COURT YOUR DEFENSES OR OBJECTIONS TO THE CLAIMS SET FORTH AGAINST YOU. UNLESS YOU ACT WITHIN TEN DAYS FROM THE DATE OF THIS NOTICE, A mDGMENT MAY BE ENTERED AGAINST YOU WITHOUT A HEARING AND YOU MAY LOSE YOUR PROPERTY OR OTHER IMPORTANT RIGHTS. YOU SHOULD TAKE THIS NOTICE TO A LAWYER AT ONCE. IF YOU DO NOT HAVE A LAWYER OR CANNOT AFFORD ONE, GO TO OR TELEPHONE THE FOLLOWING OFFICE TO FIND OUT WHERE YOU CAN GET LEGAL HELP. Cumberland County Bar Association 2 Liberty Avenue Carlisle, Pennsylvania 17013 717-249-3166 i ''\, i ',,--, Jerry A, Weigle, Esquire I.D. #01624 WEIGLE, PERKINS & ASSOCIA 126 East King Street Shippensburg, P A 17257 Telephone (717)532-7388 CLlJ WEIGLE, PERKINS & ASSOCIATES - ATTORNEYS AT LAW - 126 EAST KING STREET - SHIPPENSBURG, PA 17257-1397 "' c, ! ... " ~-~.' 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