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Home My WebLink About01-0482 fx ~I " ",_~,-__,_ _, ~~.,_,~".;~_~ 'm' ..'"'" 'j( ( , ." , , .. '. IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYL VANIA KNAUER & ASSOCIATES, L.S.C Plaintiff IN THE COURT OF COMMON PLEAS, CUMBERLAND COUNTY V. JOSEPH A. HEWITT Defendant No.OI;:'-I~;) Civil Term JURY TRIAL DAMANDED NOTICE TO DEFEND AND CLAIM RIGHTS 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 TillS PAPER TO YOUR LAWYER AT ONCE. IF YOU DO NOT HA VB 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, Pennsylvania 17013 (717) 249-3166 '. . , "-, ;.-- ~.- - .~ .-j---~-" "'" - - ",-' " -~ r ... , , NOTICIA Le han demaandado a usted en la corte. Si usted quieie defenderse de estas demandas expuestas en las paginas siguientes, usted tiene viente (20) dias de plazo al partir de la fecha de la demanda y la notificacion. Usted debe presentar una apariencia escrita 0 en persoa 0 por abogado y archivar en la corte enforma escrita sus defensas 0 sus objections alas demandas en contra de su persona. Sea avisado que si usted no se defiende, la corte tomara medidas y puede entrar una orden contra usted sin previo aviso 0 notificacion y por cualquier queja 0 alivio que es pedido en la peticion de demanda. Usted puede perder dinero 0 sus propiedades 0 otros derechos importanted para usted. LLEVE ESTA DEMANDA A UN ABOGADO INMEDIATAMENTE. SI NO TIENE ABOGADO 0 SI NO TIENE EL DINERO SUFICIENTE DE P AGAR TAL SERVICIO, VA Y A EN PERSONA 0 LLAME POR TELEFONO A LA OFICINA CUY A DIRECCION SE ENCUENTRA ESCRITA ABAJO PARA A VERIGUAR DONDE SE PUEDE CONSEGUIR ASISTENCIA LEGAL. CUMBERLAND COUNTY BAR ASSOCIATION 2 Liberty Avenue Carlisle, Pennsylvania 17013 (717) 249-3166 Respectfully submitted, DAVID W. KNAUER, L.S.C. = ~) Date: January 23,2001 David W. Knauer, Es e Attorney for the Plaintiff AttorneyI.D. No. 21582 411- A East Main Street Mechanicsburg, PA 17055 (717) 795-7790 , ....~ . I " "-~ =-~ ""!'ili1; ... , , .' KNAUER & ASSOCIATES, L.S.C Plaintiff IN THE COURT OF COMMON PLEAS, CUMBERLAND COUNTY V. JOSEPH A. HEWITT Defendant No. O/-4TJ-Civil Term JURY TRIAL DAMANDED COMPLAINT 1. The Plaintiff Knauer and Associates is a corporation organized and doing business under the laws of the Commonwealth of Pennsylvania with an address of 411A East Main Street, Mechanicsburg, Pennsylvania 17055, an assignee of David W. Knauer P.C. 2. The Defendant Joseph A. Hewitt is an adult individual with an address of 600 West Walnut Street, Palmyra, Pennsylvania 17078. 3. The Plaintiff and its assignor provided legal services for the Defendant for several matters including but not limited to representing him in a will contest with respect to the Estate of Bessie A. Wolfersberger and matters involving Tuscorora Township, Perry County, Pennsylvania. 4. The Plaintiff and its assignor and the Defendant agreed that the representation would be on an hourly basis. 5. The Plaintiff rendered to the Defendant bills totaling $9,158.15, to wit: a.) February 19, 1998 bill for services rendered with respect to the Estate of Bessie A. Wolfersberger in the amount $5,482.50; =.- ," ~-, - ~'" " "" ,0, ~', '~o_----",- { " b.) February 19,1998 bill for services rendered with respect to zoning and other matters involved with Tuscarora Township in the amount of $1 ,190.15; c.) March 25, 2000 bill for services rendered with respect to the Estate of Bessie A. Wolfersberger in the amount of $2,485.50; The Plaintiff has marked as exhibits "A" through "e", attached hereto and incorporated herein by reference thereto true and correct copies of the aforesaid bills. 6. The Plaintiff provided to the Defendant a recapitulation of the billS, showing the amount of the bills and the funds paid. The Plaintiff marks as Exhibit "D", attaches hereto and incorporated herein by reference thereto true and correct copies of the aforesaid recapitulation. 7. The Defendant paid $6,050.00, leaving a balance owed of $3,108.15. 8. The Plaintiff made demand on the Defendant to pay the remaining outstanding bills by letters dated February 14, 2000, March 25, 2000, May 24, 2000 and August 28, 2000. The Plaintiff has marked as Exhibit "E" through "H" and incorporated herein by reference thereto true and correct copies of the aforesaid letters. 8. The Defendant refused to pay the aforesaid unpaid balance of the bills. 9. The Plaintiff and its assignor's bills were the usual, customary, and reasonable charges the Defendant agreed to pay. 1 O. The Plaintiff is entitled to payment of the unpaid balance of the bills. c~, ~ ~"'. ," ^ I. _ ", ..,;,. -}!+ , WHEREFORE, the Plaintiff demands judgment in its favor and against the Defendant in the amount of $3,108.15 with interest on the unpaid balance. Date: January 23,2001 Respectfully submitted, KNAUER & ASSOCIATES, L.S.C. ~~ Attorney for Plaintiff Attorney I.D. No. 21582 411-A East Main Street Mechanicsburg, PA 17055 (717) 795-7790 , , .' , , ,'w ".,__ c. " "'1< , 6j) a~i~ 'liJ. X naUC1I",. @. e. ATTORNEYS At LAW 411 A East Main Street Mechanicsburg, PA 17055 (717) 795-n90 DAVID W. KNAUER February 19, 1998 MARK D. SCHWARTZ Mr. Joseph Hewitt 600 West Walnut Avenue Palmyra, PA 17078 RE: Estate of Bessie Wolfersberger Bill for Services Rendered Date Description Time Charge 08/29/96 Extensive office conference with client; reviewed documents; prepared reply to Co-Executor's petition for sanctions and removal of client as executor; called Estate counsel's office; left message to return call. 3.20 480.00 08/30/96 Called Estate counsel's office; left message to return call. .20 30.00 09/03/96 Filed Praecipe to Enter Appearance and reply to 1.40 210.00 motion to remove client as executor, etc.; drafted letter to Estate counsel; returned Estate counsel's call; left message to return call. 09/09/96 Called Estate Counsel's office; left message to return .20 30.00 call. 09/1 0/96 Called Estate Counsel's office; left message to return .20 30.00 call. 09/19/96 Receipt and revieW of title search from The Sentinel 0.50 75.00 agency. 09/23/96 Called Estate Counsel's office; left message to return .20 30.00 call. 11/19/96 Receipt and review of ...,I.,I.~ _.r:.. ~,I...... sel. .20 30.00 EXHIBIT b :;; A ~ "0_ . -'-"".'",' ,.., "C~ _. , - -~O, -.. ,'-" -, " , 12/04/96 Called Estate Counsel's office; left message to returh .20 30.00 call. 12/05/96 Extensive telephone conference with Estate Counsel. .30 45.00 12/18/96 Telephone calls to client regarding Humane Society .50 75.00 concerns with sheep. 1 0/02/96 Receipt and review of Order of the Honorable Warren .20 30.00 G. Morgan scheduling hearing on petition to remove client as executor. 10/03/96 Called Estate Counsel's office; left message to return .50 75.00 call. Extensive telephone conference with estate counsel who will require co-executor to retain his own counsel if he wishes to pursue removal of client as executor. 01/31/97 Receipt and review of letter from James Morgan, .20 30.00 Esquire. 03/04/97 Receipt and review of letter from client .20 30.00 03/10/97 Meeting with Attorney Morgan. .30 45.00 04/07/97 Meeting with client. .50 75.00 04/23/97 Drafted letter to Attorney Morgan. .20 30.00 04/30/97 Receipt and review of letter from Attorney Morgan. .20 30.00 08/28/97 Receipt and review of letter from R. Mark Thomas, .20 30.00 Esquire. 09/12/97 Drafted letter to Attorney Thomas. .20 30.00 09/29/97 Receipt and review of letter from client. .20 30.00 1 Of 02/97 Receipt and review of Order and Petition scheduling .30 45.00 hearing. 10/10/97 Drafted petition to remove James Spangler as Co- 3.0 450.00 Executor. 10/15/97 Receipt and review of letter from Attorney Thomas. .20 30.00 10/20/97 Meeting with client. .50 75.00 10/21/97 Receipt and review of letter from Attorney Thomas. .20 30.00 10/29/97 Receipt and review of letter from client. AO 60.00 12/08/97 - ~.1eeting with client; drafted legal memorandum on 5.0 750.00 12/09-97 behalf of client. 12/08/97 - Preparation for hearing; reviewed file; attendance at 12.0 1,800.00 12/12/97 hearings on December 10 & December 12, 1997; reviewed legal memorandum filed by Attorney Thomas. 12/17/97 Preparation for and meeting with Attorney Thomas to 1.50 225.00 narrow issues, to provide for procedure to ~'2solve estate issues, and to plan to conclude estate. 01/14/98 Drafted letter to Attorney Morgan confirming that his .30 45.00 bill has been paid. 01/17/98 Telephone conference with Attorney Boyanowski to 1.00 150.00 confirm that her bill had been paid; drafted letter confirming same; receipt and review of letter from Attorney Morgan; drafted letter to Attorney Thomas forwarding letter of Attorney Morgan. 02/12/98 Drafted letter to Attorney Thomas forwarding letter of .30 45.00 Attorney Boyanowski and confirming meeting with Executors. 02/13/98 Drafted letter to client regarding meeting of Executors. .30 45.00 12/17/97- Numerous telephone conferences with Attorney 1.0 150.00 02/18/98 Thomas. Total Charges $5,400.00 Plus Expenses Advanced 82.50 $5,482.50 Less Retainer 2.200.00 Total Amount Due $3,282.50 , DAVID W. KNAUER 6Da~i() W. :KnaUl1r, @.e. ATTORNEYS AT LAW 411 A East Main Street Mechanicsburg, PA 17055 (717) 795-7790 February 19, 1998 MARK D. SCHWARTZ Mr. Joseph Hewitt 600 West Walnut Avenue Palmyra, PA 17078 RE: Tuscarora Township Zoning Date 04-07-97 04-08-97 04-23-97 05-02-97 05-09-97 05-27-97 06-05-97 06-13-97 06-24-97 07-12-97 Bill for Services Rendered' Descriotion Time Charae 0.50 50.00 0.30 30.00 3.00 300.00 0.20 20.00 0.60 60.00 Office appointment with client Telephone conference with Jerry A. Philpott, Esquire Visit to Hewitt farm with Mr. George Fleisher Telephone conference with Attorney Philpott Receipt and review of letter with township ordinances from Attorney Philpott Drafted letter to Attorney Philpott 0.30 30.00 Receipt and review of letter from Attorney Philpott 0.20 20.00 Telephone call from client 0.20 20.00 Receipt and review of letter from Attorney Philpott 20.00 0.20 Visit to Hewitt farm (Mr. Fleisher, client, and Attorney Knauer) 400.00 4.00 'This invoice is for work performed on or after April 7, 1997. You were previously billed for work performed from August 30, 1996, through April 6, 1997, which was paid by the retainergiven to us when you hired us to represent ou in this matter. On April 7, 1997, you provided an additional retainer of $600. '- '~ - ' '_ ,:::<;:","" d "I, ....,.' ,.);",_ oi:;-,:,i';-,,-,j;f" -"'~~, "'t':;"",_i..~:i:"_ n' ~ ~,.,;; " ~ ~ 07 ~ 15-97 Receipt and review of letter from Attorney Philpott 0.20 20:00 07-23-97 Drafted letter to Attorney Philpott 0.20 20.00 07-30-97 Receipt and review of letter from client 0.20 20.00 08-11-97 Receipt and review of letter from client 0.20 20.00 09-12-97 Office meeting with client 0.50 50.00 09-19-97 Drafted letter to Attorney Philpott 0.30 30.00 09-24-97 Receipt and review of letter from Attorney Philpott 0.20 20.00 10-08-97 Drafted letter to Attorney Philpott 0.20 20.00 10-10-97 Receipt and review of letter and enclosures from 0.20 20.00 Attorney Philpott Total Charges $1,170.00 Plus Expenses Advanced 20.15 $1,190.15 Less Retainer 600.00 Total Amount Due $ 590.15 ! .....-, , L~C-' ""~ _,_>,,,,,~_',,,,""'h_~ -"'_>..1"-"."_~,, - ~ "'!il ATTORNEY BILL AND TIME EXPENDED ESTATE OF BESSIE WOLFERSBERGER 1998 4-15 Receipt, review, and analysis of the April 13, 1998 decision of the Honorable Warren G. Morgan finding in favor of Mr. Hewitt. .2 Telephone call to Mr. Thomas's office. He was noUn and left word to request a return telephone call. .1 Telephone call to Mr. Hewitt to inform him that Judge Morgan had found in his favor on the third lot. .2 4-16 Telephone conference with Mr. Thomas who informed me that he had not yet spoken with his clients but would inform me of their decision. .2 Letter to Mr. Hewitt with copy of Judge Morgan's decision and update on status of case after Judge Morgan's decision. .3. 4-27-29 Two telephone calls to Mr. Thomas' office. Left word to call. .2 5-1 Receipt and review of letter from Mr. Hewitt. .2 5-4 Extensive letter in reply to Mr. Hewitt's letter received on May 1, 1998. 1.0 5-14 Telephone call to Mr. Thomas to determine if his clients had appealed Judge Morgan's April 13, 1998 decision. Secretary informed me that Mr. Thomas had not filed an appeal. Left word to call to determine if his client's may have changed attorneys again. .2 5-18 Receipt and review of letter from Mr. Hewitt. .2 5-21 Short conference with Thomas who informed me that his clients will not appeal Judge Morgan's decision. .3 5-21 Letter to Mr. Hewitt reporting that Mr. Thomas's clients will not appeal. .3 8/29 Extensive conference with client, review of documents, preparation of reply to other executor's petition for sanctions and removal of client as co-executor. 3.0 8/29 Telephone conference with Estate counsel's office, left word to call. .2 8/30 Telephone conference with Estate Counsel's office, left word to call. .2 ~ ., . " -"'~ . "'- , ',oj, ,'~' ;.: ., I ~I >,"",'" ',,< ",....~""" . ~-' "-"'01'1 .' 9/2 File reply to executor's motion to remove client as executor, etc. 1.0 9/3 Returned Estate counsel's call. Telephone conference with Estate counsel's office, left word to call.2 9/9 Telephone conference with Estate Counsel's office, left word to call. .2 9/10 Telephone conference with Estate counsel left word call. .2 9-23 Telephone call to Estate Counsel's office, left word to call. .2 10-2 Receipt and review of Order of the Honorable Warren G. Morgan scheduling hearing on other executor's petition to remove client as executor. .2 10-3 Telephone call to Estate Counsel's office, left word to call. .2 Estate Counsel returned telephone call. Extensive telephone conference with her. She will require co-executor to retain his own counsel if he wishes to pursue removal of client as executor. .3 10-10 Drafting and filing of Petition to Remove Spangler as Co-Executor. 3.0. 10-29 Reading and review of letter from Mr. Spangler. .5 11-13 Receipt and review of November 13, 1998 letter of Mr. Thomas with respect to estate accounts. .2 11-19 Receipt and Review of letter from Estate counsel. .2 12-4 Phone call to Estate Counsel, left message. .2 12-5 Extensive telephone conference with Estate Counsel. .3 12-18 Telephone calls to Mr. Hewitt Re: Humane Society concerns with sheep. .5 1999 01-21 Receipt and review of letter from Mr. Hewitt. .2 01-22 Phone call from Sue Helm. .2 01-23 Phone call to Mark Thomas, Esquire. .2 05-27 Telephone conference with Rachel Helm who called with respect to Perry County case. .2 " 2000 02-03 Receipt and review of Mr. Hewitt's letter concerning erroneous information that we had place a lien against his property. .2 Letter to Mr. Hewitt with status of the estate and informing him that we had not placed any lien on his property or taken an action against him. .4 Telephone conference with Attorney Thomas requesting update on when the estate would be completed. .3 Total 16.0 Hours @ 150.00 Per Hour ..........--..................---.............. $2,400.00 COSTS ADVANCED 03/99 Deeds (Dauphin County) 85.50 Total Costs Advanced 85.50 Total Costs & Outstanding Bill 2,485.50 ~ ~,,- , Knauer & Associates, LSC 41lA E. Main St., Mechanicsburg, PA 17055 Attorneys-at-Law Telephone, (7! 7) 795-7790 Fax, (717) 795.7793 David W. Knauer JOSEPH HEWITT WOLFERSBERGER ESTATE & TUSCARORA TOWNSHIP ZONING TOTAL BILLING HISTORY 2/19/1998 2/19/1998 3/25/2000 Zoning Bill (see attached) Estate Bill (see attached) Estate Bill (see attached) 1,190.15 5,482.50 2,485.50 Total Zoning and Estate Bills 9,158.15 TOTAL REIMBURSEMENT/FEE HISTORY 8/11/1996 Fee for Wolfersberger Estate 200.00 8/30/1996 Fee for Wolfersberger Estate 250.00 9/3/1 996 Retainer for Wolfersberger Estate 2,000.00 600.00 4/7/1997 Retainer for Tuscarora Township Zoning 8/4/1998 Fee for Wolfersberger Estate 3,000.00 Total Zoning and Estate Reimbursement/Fees 6,050.00 TOTAL OUTSTANDING BILL 3,108.15 PA YMENT UPON RECEIPT EXHIBIT 'll I tJ .~ .' ~, --.~. . -.>< -, t. ~~- ., --- >.--- - , . ".,.-'".;' .,-, ,,' - ~ Cl I I . . Knauer & Associates, LSC 411A E. Main St., Mechanicsburg, P A 17055 Attorneys-at-Law Telephone: (717) 795-7790 Fax: (717) 795.7793 David W. Knauer February 14, 2000 Mr. Joseph Hewitt 600 West Walnut Avenue Palmyra, PA 17078 RE: Estate of Bessie A. Wolfersberger Dear Mr. Hewitt: This acknowledges receipt of your letter wherein you stated that we had placed a lien against your property. You are mistaken. We have not filed any lien or taken any adverse action against you. I did review your accounts with us and I include herewith a statement of all bills owed to us. We would appreciate payment of the balance on your bills. Last week I spoke with R. Mark Thomas, Esquire who is counsel for your co- executor James Spangler. Mr. Thomas informed me that the estate had insufficient funds to pay both the state inheritance and the federal estate taxes. I requested him to provide us with a copy of the documentation with respect to the taxes. I will await receipt of the documentation to support his statement. I enclose a copy of said letter to him. Thank you for your prompt attention in this matter. If you have any question, please do not hesitate to contact me. Very truly yours, ~~ l~-J(~~ David W. Knauer DWK:wdm Enclosures \wpdocslhewittI02-09-00hewitt.ltr ,- ~~,--'-"""'-'~'." --<.~'_"'.',,-'-.-~' ~ ' - . . . . Knauer & Associates, LSC 411A E. Main St., Mechanicsburg, P A 17055 Attorneys-at-Law Telephone: (717) 795.7790 Fax: (717) 795.7793 David W. Knauer March 25, 2000 Mr. Joseph Hewitt 600 West Walnut Avenue Palmyra, PA 17078 RE: Estate of Bessie A. Wolfersberger Dear Mr. Hewitt: Please reference my letter of letter of February 14, 2000 in which I provided you with your outstanding bill with our firm. Since that letter, I have had no response from you and no payment of the bill. This letter is to inform you that if you do not pay the bill or reach an acceptable payment plan with us within within ten days of the date of this letter that we will be forced to file suit against you for payment of your bill. I do hope that it will be unnecessary to take that step however we will do so if the bill is not paid. Ve....ry truly yours, ;',-1. -.1111 t:<7flA~/ '. j ~j 'fP--- --- David W. Knauer DWK:ahk \wpdocslhewitt\03.25-00hewitt.ltr ."':~B . .J!F........ r , " , , " . '-. - , - ..~~; -, -,- , ." . .-~ . ~ ~~ L:'" ., , . . Knauer & Associates, LSC 411A E. Main St., MechanicsbUtg, PA 17055 Attorneys-at-Law Telephone: (717) 795.7790 Fax: (7! 7) 795-7793 David W. Knauer May 24, 2000 Mr. Joseph Hewitt 600 West Walnut Avenue Palmyra, PA 17078 RE: Estate of Bessie A. Wolfersberaer/Tuscarora Township Zonina Matters Dear Mr. Hewitt: You had questioned our bills against your payments, therefore, I enclose herewith a complete billing history and all previously sent bills for your account with our firm, together with a certificate of mailing. Unless you pay the entire outstanding amount of $3,108.15 by June 5, 2000, I will start suit against you to collect our fees. Upon commencement of suit, we will obtain a judgment and the Sheriff will seize and sell any of your property that they are able to seize. I do hope that it will not be necessary for us to start suit, but we must be paid for our work just as you wanted to be paid for your work. () tr~IY yours, ~ ~/f 1440/ David~~:' DWK:bm Enclosures IwpdocslhewittIOS-24-00hewitt.llr EXHIBIT '= ) G- .;-,_......,.,.~~..:--_......r;:..~..'"- '. ---'.";-.-- ------ ~'<~-.-.,-.,.--.. . , rr_' ,-,-- ^"". '"- --~ ~-, ",",-,. --,.,,,,,,,,--,~,,,,,,~~;-,,,,--,,-,,,-.-~^-, "'-'"" . '- Knauer & Associates, LSC Attorneys-at-Law 411A. East Main Street, Mechanicsburg, PA 17055 Telephone: (717) 795-7790 Fax: (717) 795.7793 Email: knauer@earlv.com David W. Knauer August 28, 2000 Mr.-Joseph Hewitt . - - 600 West Walnut Avenue Palmyra, PA 17078 RE: Estate of Bessie A. Wolfersberger and Knauer v. Hewitt Dear Mr. Hewitt: Please find enclosed a courtesy copy of the District Justice Complaint we are filing against you for non-payment of our bill, a copy of the June 15,2000 letter ofR. Mark Thomas, Esquire and my letter ofthe i'lbove date in response thereto. With respect to his request for contribution from the executors and beneficiaries to make up a $42, 000 shortfall of funds to pay the Pennsylvania Inheritance Tax, his proposal is that each beneficiary be responsible for their pro- rata portion of the unpaid taxes based on the value of the property they inherited. He informed me that he valued your share of the shortfall as approximately $ As to the legal position, I believe that you should not have to make any contribution because the accounting information was withheld from you despite our numerous requests for copies of the accounting. I must call to your attention that you should retain legal counsel for the conclusion of the estate. I will co-operate fully with your new counsel to transfer your files and provide he or she with any information that may assist in responding to the requested payment. Very truly yours, ,I - ~! David W. Knauer DWK:bm \company\Hewitt\08-28-00hewitt.ltr EXHIBIT .l! i H .,' __ ._ ",~: '_~_', :-f';~"-~';:-;"'::;X-:":_, ~'~ . ._ p' ',:, ~,o, ~,","'" c_. ~_..~ ~ -,' ','~ -- .'-'-- "",',"f . . . . VERI Fie AT ION Subject to the penalties of 18 Pa. C.SA 4904 relating to unsworn falsification to authorities, we hereby certify that the facts in the foregoing pleading are true and correct to the best of our information and belief. Date: ~-:?3-~1 ~~:J - - '"' _, ""u_ .'<,,' ,,,_ _r'_ __ ~, ." '" , ~, '':'~, . . , . . . . ~ KNAUER & ASSOCIATES, L.S.C Plaintiff IN THE COURT OF COMMON PLEAS,CUMBERlAND COUNTY V. JOSEPH A. HEWITT Defendant No. Civil Term JURY TRIAL DAMANDED CERTIFICATE OF SERVICE I, David W. Knauer, hereby certify that I did this 23rd day of January, 2001, serve a true and correct copy of the within document on all counsel of record by United States mail, first class, prepaid addressed as follows: Joseph A. Hewitt 600 West Walnut Street Palmyra, PA 17078 D'~~ Attorney for Plaintiff Attorney I.D. No. 21582 411-A East Main Street Mechanicsburg, PA 17055 (717) 795-7790 i . .J1i I I .. ~; ~ ron ~D~:fF\CE . ..Y ",.1-;."...,""1/.\ ~ 0.... If,r ,.,f"....,'[,OTAP,'{ 'I" . ill_ I ~ \',.,1 ,; h,,' .. 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'ilj_.s.tlatl~ ..~ ~ C& \ leo/ ~.c)13.=&k(s'- [M........ uJJd4th- DiLu.m I [fill ~ i {Jaue- k/l4ll.M.- f1~ _ Jq5-77ft; J Lf#A fad~ S; rtitd~ I u. -t\;;+rI1.,d/-V-,v( ~ i 1 9wit'/J;t!Y:1f~f; 1~7Y ], ------ j -~ - ,~.,,"".......__....... ~"-"" "lIlI~''''''~~ "'''_.'. _H~"' , I I , i I . ,. ~j~~'>>ffr!jj'" .......l ~_ "_~~" ~~"..d~~,~.~.. ~"..__~_." ,~ ~;, -~'1k,Jfj;'ifti'i:0-m,;~;)'lii'@ ,,,,,~,',;t-'!4:,~,,,!ilil,*$~,~~OOl~ ^r:Mill'...mWol~0!>.?""IlI!!illiti;;i~Jirlt\l!i~~~_,~..~*~1>,,,,''''''''d0~,,,_~ffil!tili~~!ll' "'-. If!! -"~~~- """,,', ??1tL ~. \ "tf4~ tzJv ~? I ~TI ~~~~; .~~_. _>:~N''''''' .". ,,,,,,,,,,,,,,-,,,.,__~,""',,__"'_b,,,~'~"'__'>,_ .__~, " __.""'.,'~ ."__, "n ~~__~_~,_ t ~~~fTh1!~11ff~ "~- .-----'''-.- ---~-_.,.,~ - . MQW&O 1NfORMAT10N~. Ar;:lV1CB-- AT?YOCAcY - - , - . TEN EAST H)GH STR~ET CARLtSLE, 'pEN'N~YLVANIA 170-13 Mr.Jos~ph A. Hewitt .600 West Walnut:Stteet .PalmYra'PA17078 - --, . ~ it:~ M~&:6 ArrORNEYS & COUNSELLORS AT LAw WILllAJ.\oI F. MARTSON JOHN B. FOWLER 1II EDWARD L. SCHORPf:' OANI"EL K. DEARDORFF THOMAS J. WILLlAMS .. Ivo V. OTTO 1II GEORGE B. FALLER JR.' CARL C. RISCH MARK A: DENLINGER '"BOARD CERTIFIED CIVIL TRlAL SPECIAUST TtN EAsT HIGH SnEET ,CAlll1SLli. PENNSYl,VANlA 170 1:3 TELEPHONE (717)243-3341 FAqlMILE (717) 243-1850 I~TERNET - ~.mdwo.com June 19,2001 , Mr. Joseph A. Hewitt 600 West Walnut Street Palmyra, P A 17078 RE:. Knauer & Associates, L.S.C. v. Joseph A. HeWitt . No.01-482-CumberlanilCountyC.C.P. -Dear Mr. Hewitt: P\II'suant to your request, I am providing you with directions to oUr office: 1. . Interstate 76 (Turnpike) to Exit 16 2. Get off at Exit l6--Carlisle exit Stay in the right lane and follow signs for Rt 11 South (CarlislelHatrisburg Pike). 3. Continjle on Rt 11 into Carlisle. 4. There are 8 traffic lights tothe Square. (2.8 mi.) Rt. 11 becomes Hanover Street at some poinfalong the way. 5. At the Square (intersection of Hanover and High Streets.) turn left. MDWO is on your right, about 3 buildings down from the Courthouse. If you wish to park in our parking lot: 1.. Continue on East High Street to the fIrst light. 2. Turn right onto Bedford Street 3. At the alley, Liberty Avenue, turn right. 4. Go 3/4 of the way down the alleyway. INFORMATION. ADVICE. ADVOCACY'" .,., ~"'--'-'~~-"'. -. '. 1-- , .-< . Mr. Joseph A. Hewitt June19,2001 Page 2 5. Our parking entrance is directly across from the gray, concrete block building for Liberty Millworks; . 6. Turn right into our parking. The firm name is on the building. ,You may park in any space and enter through the rear entrance to our offices. Very truly yours, MARTSON DEARDORFF WILLIAMS & OTTO Edward L. Schorpp ELS/tde F:\FILES\DATAFll.E\MISCleIs-ARB.mh INFORMATION. ADVICE. ADVOCACy'M " - ~~ [ '"~" IL~, M~&:6 . Ar:rORNEYS & COUNSELLORS AT LAw WILLIAM E MARTSON ]OHN B. FOWLER III EDWARD L. SCHORPf DANIEL K DEARDORFF THOMAS J. WILLIAMS .. Ivo V. OTTO III GEORGE B. FALLER]R." CARL C. RISCH MARK A. DENLlNCER "BOARD'CERTIFIED CiViL TRIAL SPECIALIST TEN EAsr HIGH STREET CARLISLE,PENNSYLVANIA 17013 TElEPHONE (717) 243-3341 FACSIMILE (717) 243-1851} INTERNET www.mdwo.com June 19, 2001 David W.Knauer, Esquire 411-A EaSt Main Street Mechanicsburg, PA 17055 RE: Knauer & Associates, L.S.C. v. Joseph A. Hewitt No. 01-482 - Cumberland County C.C.P. Dear Attorney Knauer: I enclose for your information and file a copy of a letter I received from Mr. Hewitt. Very truly yours, MARTSON DEARDORFF WILLIAMS & OTTO Edward L. Schorpp ELS/tde Enclosure F:\FILES\DA T-AFILE\MJSC\els.:ARB.dn INFORMATION. ADVICE. ADVOCACY'" ~ ~ " ,,~ I..... ,_~ ~ "'~ _ '<-'c- _ ,ok" _ w' c', -, '",I i ,I " 'I , 'I Ii " 1 1 :1 :1 ,I MARTSON DEARDORFF WILLIAMS & OTTO MQW&'O ATTORNEYS & COUNSELLORS AT LAw WILLIAM F. MARTSON JOHN B. FOWLER III EDWARD L. SCHOi(l'P DANIEL K. DEARDORFF THOMA:; J. WILLIAMS' Ivo V. Orro III GEORGE B. FALLER JR.' CARL C. RISCH MARKA. DENLINGER "'BOARD CEJlTIFlED CIVIL TRIAL SPECIALIST TEN EAsT HIGH STREET CARLISLE, PEN-NSVLV....~IA 17013 TELEPHONE (717) 243-3341 FACSIMILE (717)243-1850 INTERNET www.mdwo.com ~ ,(Q1 (Q) cg May 29, 2001 David W. Knauer, Esquire 4ll-A East Mflin Street Mechanicsburg, PA 17055 Mr. Joseph A. Hewitt 600 West Walnut Street Palmyra,PA 17078 RE: Knauer & Associates, L.S.C. v. Joseph A. Hewitt , No. 01-482 -Cumberland County CC.P. Dear Attorney Knauer and Mr. Hewitt: , Enclosedplease find a Notice of Hearing scheduling the arbitration in the above referenced matter for August &, 2001 at 9:00 a.m. .in the Law Offices of Martson Deardorff Williams & Otto, Ten East High Street, Carlisle, Pennsylvania. Very truly yours, MARTSONDEARDORFF WILLIAMS & OTTO EdwardL Schorpp ELS/tde Enclosure ' cc: Karl Rominger, Esquire (w/enc.) Kathleen K. Shaulis, Esquire (w/enc.) F:\FILES\DA T AFlLEIMISaels-ARB.ltr INFORMATION. ADVICE. ADVOCACy'M ,~ "" '''.- ;,,1 -~ .c ;;:; ,_ "',."''' . ""c'_:;;; ~ '~'''-' ';;" "':'-, IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA KNAUER & ASSOCIATES, L.S.C Plaintiff IN THE COURT OF COMMON PLEAS, CUMBERLAND COUNTY V. JOSEPH A. HEWITT Defendant No. tit -t.jf;) Civil Tenn JURY TRIAL DAMANDED NOTICE TO DEFEND AND CLAIM RIGHTS 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 A venue Carlisle, Pennsylvania 17013 (717) 249-3166 ,.'-.' ",-,- , --, o~ ,- >"';"~ '" :~--- .' ,I .,,~ -- ~ "'" ,-.,. .' '''''''' -:;-".J'" - .,,~ '__, ~ ~___ - "-~--;:- NOTICIA Le han demaandado a usted en la corte. Si usted quieie defenderse de estas demand as expuestas en las paginas siguientes, usted tiene viente (20) dias de plazo al partir de la fecha de la demanda y la notificacion. Usted debe presentar una apariencia escrita 0 en persoa 0 por abogado y archivar en la corte enforma escrita sus defensas 0 sus objections alas demandas en contra de su persona. Sea avisado que si usted no se defiende, la corte tomara medidas y puede entrar una orden contra usted sin previo aviso 0 notificacion y por cualquier queja 0 alivio que es pedido en la peticion de demanda. Usted puede perder dinero 0 sus propiedades 0 otros derechos importanted para usted. ,j; LLEVE EST A DEMANDA A UN ABOGADO IN MEDIA T AMENTE. SI NO TIENE ABOGADO 0 SI NO TIENE EL DINERO SUFICIENTE DE P AGAR TAL SERVICIO, V A Y A EN PERSONA 0 LLAME POR TELEFONO A LA OFICINA CUY A DIRECCION SE ENCUENTRA ESCRIT A ABAJO PARA A VERIGUAR DONDE SE PUEDE CONSEGUIR ASISTENCIA LEGAL. CUMBERLAND COUNTY BAR ASSOCIATION 2Liberty Avenue Carlisle, Pennsylvania 17013 (71 7) 249-3166 Respectfully submitted, DAVID W. KNAUER, L.S.C. CiJJ:i!~r(~ (fnt-) David W. Knauer, Es . e Attorney for the Plaintiff Attorney J.D. No. 21582 411-A East Main Street Mechanicsburg, P A 17055 (717) 795-7790 Date: January 23, 2001 .", r" "", ~' . ""'" "'" l;;" ~~,,-,,'" , ,"N',. ",_, ; , KNAUER & ASSOCIATES, L.S.C Plaintiff IN THE COURT OF COMMON PLEAS, CUMBERLAND COUNTY V. JOSEPH A. HEWITT Defendant No. Civil Term JURY TRIAL DAMANDED COMPLAINT 1. The Plaintiff Knauer and Associates is a corporation organized and doing business under the laws of the Commonwealth of Pennsylvania with an address of 411 A East Main Street, Mechanicsburg, Pennsylvania 17055, an assignee of David W. Knauer P.C. 2. The Defendant Joseph A. Hewitt is an adult individual with an address of 600 West Walnut Street, Palmyra, Pennsylvania 17078. 3. The Plaintiff and its assignor provided legal services for the Defendant for several matters including but not limited to representing him in a will contest with respect to the Estate of Bessie A. Wolfersberger and matters involving Tuscorora Township, Perry County, Pennsylvania. 4. The Plaintiff and its assignor and the Defendant agreed that the representation would be on an hourly basis. 5. The Plaintiff rendered to the Defendant bills totaling $9,158.15, to wit: a.) February 19, 1998 bill for services rendered with respect to the Estate of Bessie A. Wolfersberger in the amount $5,482.50; 1 ,,",,-,j to"~ .. ...- ;C/'__' .-_ 1_ - ,,-,0, _ ~o-" " "(,-,,,,~,_'>,_:\,.~"-,"ic.:::,>;'i,--:_:,,>."O "_"__~"_"~, b.) February 19,1998 bill for services rendered with respect to zoning and other matters involved with Tuscarora Township in the amount of $1,190.15; c.) March 25, 2000 bill for services rendered with respect to the Estate of Bessie A. Wolfersberger in the amount of $2,485.50; The Plaintiff has marked as exhibits "A" through "C", attached hereto and incorporated herein by reference thereto true and correct copies of the aforesaid bills. 6. The Plaintiff provided to the Defendant a recapitulation of the bills, showing the amount of the bills and the funds paid. The Plaintiff marks as Exhibit "D", attaches hereto and inCQrporated herein by reference thereto true and correct copies of the aforesaid recapitulation. 7. The Defendant paid $6,050.00, leaving a balance owed of $3,108.15. 8. The Plaintiff made demand on the Defendant to pay the remaining outstanding bills by letters dated February 14, 2000, March 25, 2000, May 24, 2000 and August 28, 2000. The Plaintiff has marked as Exhibit "E" through "H" and incorporated herein by reference thereto true and correct copies of the aforesaid letters. 8. The Defendant refused to pay the aforesaid unpaid balance of the bills. 9. The Plaintiff and its assignor's bills were the usual, customary, and reasonable charges the Defendant agreed to pay. 1 O. The Plaintiff is entitled to payment of the unpaid balance of the bills. - , ~ I . " ~"". . -1"'.-,'_,'.,,___., ,-- "-,<--~--"..""-- "-__'~'~1'i">;~~,j>",;'.;;?",-~-., --:, "~"i WHEREFORE, the Plaintiff demands judgment in its favor and against the Defendant in the amount of $3,108.15 with interest on the unpaid balance. Respectfully submitted, KNAUER & ASSOCIATES, L.S.C. avid W. Knauer, Es . e Attorney for Plaintiff Attorney 1.0. No. 21582 411-A East Main Street Mec;hanicsburg, PA 17055 (717) 795-7790 Date: January 23, 2001 TRlJECOPY FROM RECORD tn T6litlmooy Wile/eo!, I here unto. my llano and the _ of said COIIrt at Carllsle. Pi. ~ O)~;~ 1.~ ~ PrOthon~ ." -, ~ ,," I, '" ~ '",.'-~ "" -b,o," "'", < ,,",,' -, '". -,', ,-"-,,~ ~-- - ,.,' , 6Da~id ltJ. :J(naugr, ~.e. ATTORNEYS AT U>..W 411 A East Main Street Mechanicsburg, PA 17055 (717) 795-7790 DAVID W. KNAUER February 19, 1998 Mr. Joseph Hewitt 600 West Walnut Avenue Palmyra, PA 17078 RE: Estate of Bessie Wolfersberger Bill for Services Rendered Date Description 08/29/96 Extensive office conference with client; reviewed documents; prepared reply to Co-Executor's petition for sanctions and removal of client as executor; called Estate counsel's office; left message to return call. 08/30/96 Called Estate counsel's office; left message to return call. Time 3.20 .20 MARK D. SCHWARTZ Charge 480.00 30.00 09/03/96 Filed Praecipe to Enter Appearance and reply to 1.40 210.00 motion to remove client as executor, etc.; drafted letter to Estate counsel; returned Estate counsel's call; left message to return call. 09/09/96 Called Estate Counsel's office; left message to return .20 30.00 call. 09/10/96 Called Estate Counsel's office; left message to return .20 30.00 call. 09/19/96 Receipt and review of title search from The Sentinel 0.50 75.00 agency. 09/23/96 Called Estate Counsel's office; left message to return .20 30.00 call. 11/19/96 Receipt and review of ~ ..-. lsel. .20 30.00 EXHIBIT I .4 , , ,-~ = " - "', I:.. _~_'---_~- - - - L _,_'"",_=~"_~",_,__'x' _"0'_ _.". ,-~O_,~,,_ 12/04/96 Called Estate Counsel's office; left message to return .20 30.00 call. 12/05/96 Extensive telephone conference with Estate Counsel. .30 45.00 12/18/96 Telephone calls to client regarding Humane Society .50 75.00 concerns with sheep. 10/02/96 Receipt and review of Order of the Honorable Warren .20 30.00 G. Morgan scheduling hearing on petition to remove client as executor. 10/03/96 Called Estate Counsel's office; left message to return .50 75.00 call. Extensive telephone conference with estate counsel who will require co-executor to retain his own counsel if he wishes to pursue removal of client as executor. 01/31/97 Receipt and review of letter from James Morgan, .20 30.00 Esquire. 03/04/97 Receipt and review of letter from client .20 30.00 03/10/97 Meeting with Attorney Morgan. .30 45.00 04/07/97 Meeting with client. .50 75.00 04/23/97 Drafted letter to Attorney Morgan. .20 30.00 04/30/97 Receipt and review of letter from Attorney Morgan. .20 30.00 08/28/97 Receipt and review of letter from R. Mark Thomas, .20 30.00 Esquire. 09/12/97 Drafted letter to Attorney Thomas. .20 30.00 09/29/97 Receipt and review of letter from client. .20 30.00 10/02/97 Receipt and review of Order and Petition scheduling .30 45.00 hearing. 10/10/97 Drafted petition to remove James Spangler as Co- 3.0 450.00 Executor. 10/15/97 Receipt and review of letter from Attorney Thomas. .20 30.00 10/20/97 Meeting with client. .50 75.00 10/21/97 Receipt and review of letter from Attorney Thomas. .20 30.00 .. ' ,"'I". . r, '","' < ". ~ -'~'" ,= ~- ,,,.--~~ >~, -1'--;, 10/29/97 Receipt and review of letter from client. .40 60.00 12/08/97 - ~.1eeting with client; drafted legal memorandum on 5.0 750.00 12/09-97 behalf of client. 12/08/97 - Preparation for hearing; reviewed file; attendance at 12.0 1,800.00 12/12/97 hearings on December 10 & December 12, 1997; reviewed legal memorandum filed by Attorney Thomas. 12/17/97 Preparation for and meeting with Attorney Thomas to 1.50 225.00 narrow issues, to provide for procedure to resolve estate issues, and to plan to conclude estate. 01/14/98 Drafted letter to Attorney Morgan confirming that his .30 45.00 bill has been paid. 01/17/98 Telephone conference with Attorney Boyanowski to 1.00 150.00 confirm that her bill had been paid; drafted letter confirming same; receipt and review of letter from Attorney Morgan; drafted letter to Attorney Thomas forwarding letter of Attorney Morgan. 02/12/98 Drafted letter to Attorney Thomas forwarding letter of .30 45.00 Attorney Boyanowski and confirming meeting with Executors. 02/13/98 Drafted letter to client regarding meeting of Executors. .30 45.00 12/17/97 - Numerous telephone conferences with Attorney 1.0 150.00 02/18/98 Thomas. Total Charges $5,400.00 Plus Expenses Advanced 82.50 $5,482.50 Less Retainer 2.200.00 Total Amount Due $3,282.50 .",.. , , -'""~' . - ..'",,~''''','.h~.' " ,',;0 , ""'-";",c, q) a\1i() 'it). :KnaUIlI', ~. e. ATTORNEYS AT LAW 411 A East Main Street Mechanicsburg, PA 17055 (717) 795-7790 DAVID W. KNAUER February 19, 1998 MARK D. SCHWARTZ Mr. Joseph Hewitt 600 West Walnut Avenue Palmyra, PA 17078 RE: Tuscarora Township Zoning Bill for Services Rendered' Date Description Time Charae 04-07-97 Office appointment with client 0.50 50.00 04-08-97 Telephone conference with Jerry A. Philpot!, Esquire 0.30 30.00 04-23-97 Visit to Hewitt farm with Mr. George Fleisher 3.00 300.00 05-02-97 Telephone conference with Attorney Philpott 0.20 20.00 i , ., 05-09-97 Receipt and review of letter with township ordinances 0.60 60.00 I ., from Attorney Philpott l 05-27-97 Drafted letter to Attorney Philpott 0.30 30.00 , 8 l: ., 06-05-97 Receipt and review of letter from Attorney Philpott 0.20 20.00 " ~ " 20.00 11 06-13-97 Telephone call from client 0.20 '" " :1 , " 06-24-97 Receipt and review of letter from Attorney Philpott 0.20 20.00 07-12-97 Visit to Hewitt farm (Mr. Fleisher, client, and Attorney 4,00 400.00 Knauer) 'This invoice is for work performed on or after April 7, 1997. You were previously billed for work performed from August 30,1996, through April 6, 1997, which was paid by the retainer given to us when you hired us to represent vou in this matter. On April 7, 1997, you provided an additional retainer of S600. EXHIBIT I () - '-., ",'--.' '" _I .,.;0' "'_'" ,,;t, """ .~ c___, ""'""'-','''_,,' <_~c__ I'j': 07-15-97 . Receipt and review of letter from Attorney Philpott 0.20 20.00 07-23-97 Drafted letter to Attorney Philpott 0.20 20.00 07 -30-97 Receipt and review of letter from client 0.20 20.00 08-11-97 Receipt and review of letter from client 0.20 20.00 09-12-97 Office meeting with client 0.50 50.00 09-19-97 Drafted letter to Attorney Philpott 0.30 30.00 09-24-97 Receipt and review of letter from Attorney Philpott 0.20 20.00 10-08-97 Drafted letter to Attorney Philpott 0.20 20.00 10-10-97 Receipt and review of letter and enclosures from 0.20 20.00 Attorney Philpott Total Charges $1,170.00 Plus Expenses Advanced 20.15 $1,190.15 Less Retainer 600.00 Total Amount Due $ 590.15 '0 , ~ ,., ,,-,' 'S';' ',' "',I oe,_,'__"-__-,,. "',',;" > -, "".'. -,'--'~' '_"-"iJ: ',~",-,-" .. .', ~>:,if :-l: Ii: it !I, il ii ! ~ if ii 'C ATTORNEY BILL AND TIME EXPENDED ESTATE OF BESSIE WOLFERSBERGER : ~ ! 'l 1998 4-15 Receipt, review, and analysis of the April 13, 1998 decision of the Honorable Warren G. Morgan finding in favor of Mr. Hewitt. .2 Telephone call to Mr. Thomas's office. He was not in and left word to request a return telephone call. .1 Telephone call to Mr. Hewitt to inform him that Judge Morgan had found in his favor on the third lot. .2 Letter to Mr. Hewitt with copy of Judge Morgan's decision and update on status of case after Judge Morgan's decision. .3. ~ :~ I r r !, 4-16 Telephone conference with Mr. Thomas who informed me that he had not yet spoken with his clients but would inform me of their decision. .2 4-27-29 Two telephone calls to Mr. Thomas' office. Left word to call. .2 5-1 Receipt and review of letter from Mr. Hewitt. .2 5-4 Extensive letter in reply to Mr. Hewitt's letter received on May 1, 1998. 1.0 5-14 Telephone call to Mr. Thomas to determine if his clients had appealed Judge Morgan's April 13, 1998 decision. Secretary informed me that Mr. Thomas had not filed an appeal. Left word to call to determine if his client's may have changed attorneys again. .2 5-18 Receipt and review of letter from Mr. Hewitt. .2 5-21 Short conference with Thomas who informed me that his clients will not appeal Judge Morgan's decision. .3 5-21 Letter to Mr. Hewitt reporting that Mr. Thomas's clients will not appeal. .3 8/29 Extensive conference with client, review of documents, preparation of reply to other executor's petition for sanctions and removal of client as co-executor. 3.0 8/29 Telephone conference with Estate counsel's office, left word to call. .2 8/30 Telephone conference with Estate Counsel's office, left word to call. .2 EXHIBIT ~ ~ (- ..,. - ,. ',"" . "., "-'1--.- " _'n' , .-- 912 File reply to executor's motion to remove client as executor, etc. 1.0 913 Returned Estate counsel's call. Telephone conference with Estate counsel's office, left word to cal1.2 919 Telephone conference with Estate Counsel's office, left word to call. .2 9110 Telephone conference with Estate counsel left word call. .2 9-23 Telephone call to Estate Counsel's office, left word to call. .2 10-2 Receipt and review of Order of the Honorable Warren G. Morgan scheduling hearing on other executor's petition to remove client as executor. .2 10-3 Telephone call to Estate Counsel's office, left word to call. .2 Estate Counsel returned telephone call. Extensive telephone conference with her. She will require co-executor to retain his own counsel if he wishes to pursue removal of client as executor. .3 10-10 Drafting and filing of Petition to Remove Spangler as Co-Executor. 3.0. 10-29 Reading and review of letter from Mr. Spangler. .5 11-13 Receipt and review of November 13, 1998 letter of Mr. Thomas with respect to estate accounts. .2 11-19 Receipt and Review of letter from Estate counsel. .2 12-4 Phone call to Estate Counsel, left message. .2 12-5 ExtEinsive telephone conference with Estate Counsel. ,3 12-18 Telephone calls to Mr. Hewitt Re: Humane Society concerns with sheep. .5 1999 01-21 Receipt and review of letter from Mr. Hewitt. .2 01-22 Phone call from Sue Helm. .2 01-23 Phone call to Mark Thomas, Esquire. .2 05-27 Telephone conference with Rachel Helm who called with respect to Perry County case. .2 '" ~' - ." , .' ,~ - - , ,--, ., ," .'---," -~ ,- , " ,,- ' -"'''--" .""'>""'''"'''>'--'_ >.".0; 2000 02-03 Receipt and review of Mr. Hewitt's letter concerning erroneous information that we had place a lien against his property. .2 Letter to Mr. Hewitt with status of the estate and informing him that we had not placed any lien on his property or taken an action against him. .4 Telephone conference with Attorney Thomas requesting update on when the estate would be completed. .3 Total 16.0 Hours @ 150.00 Per Hour m__________________m_m___________________ $2,400.00 COSTS ADVANCED 03/99 Deeds (Dauphin County) 85.50 Total Costs Advanced 85.50 Total Costs & Outstanding Bill 2,485.50 , --~ --" "';,-,: I J I .1 I I I ,... -, Knauer & Associates, LSC 411A E. Main St., Mechanicsburg, PA 17055 Attorneys-at-Law Telephone, (717) 795.7790 Fax, (717) 795.7793 David W. Knauer JOSEPH HEWITT WOLFERSBERGER ESTATE & TUSCARORA TOWNSHIP ZONING TOTAL BILLING HISTORY 2/19/1998 Zoning Bill (see attached) 1,190.15 2/19/1998 Estate Bill (see attached) 5,482.50 2,485.50 3/25/2000 Estate Bill (see attached) Total Zoning and Estate Bills 9,158.15 TOTAL REIMBURSEMENT/FEE HISTORY 8/11/1996 Fee for Wolfersberger Estate 200.00 8/30/1996 Fee for Wolfersberger Estate 250.00 9/3/1996 Retainer for Wolfersberger Estate 2,000.00 600.00 4/7/1997 Retainer for Tuscarora Township Zoning 8/4/1998 Fee for Wolfersberger Estate 3,000.00 Total Zoning and Estate ReimbursemenUFees 6,050.00 TOTAL OUTSTANDING BILL 3,108,15 PA YMENT UPON RECEIPT EXHIBIT ~ ; () ~, ,. ~' <' "".. - .'",",- .--'",,-, - -~. - Knauer & Associates, LSC 411A E. Main St., Mechanicsburg, PA 17055 Attorneys-at-Law Telephone: (717) 795.7790 Fax: (717) 795.7793 Dayid W. Knauer February 14, 2000 Mr. Joseph Hewitt 600 West Walnut Avenue Palmyra, PA 17078 RE: Estate of Bessie A. Wolfersberger Dear Mr. Hewitt: This acknowledges receipt of your letter wherein you stated that we had placed a lien against your property. You are mistaken. We have not filed any lien or taken any adverse action against you. I did review your accounts with us and I include herewith a statement of all bills owed to us. We would appreciate payment of the balance on your bills. Last week I spoke with R. Mark Thomas, Esquire who is counsel for your co- executor James Spangler. Mr. Thomas informed me that the estate had insufficient funds to pay both the state inheritance and the federal estate taxes. I requested him to provide us with a copy of the documentation with respect to the taxes. I will await receipt of the documentation to support his statement. I enclose a copy of said letter to him. Thank you for your prompt attention in this matter. If you have any question, please do not hesitate to contact me. Very truly yours, ~S?t l~-J (tJt:J David W. Knauer DWK:wdm Enclosures \wpdocs\hewitt\02.09-00hewltt.ltr EXHI!:IIT .!i ~ C , ~ - ,_,. I ,- ,-- _ ,--~ 1 ,.. li-,' 1 ~ ' 1- - '.''d,'-__'"'' , ",J.-' .., '.. -, " c'__, _c '" -~" -- N':;;', Knauer & Associates, LSC 411A E. Main St., Mechanicsburg, PA 17055 Attorneys-at-Law Telephone: (717) 795.7790 Fax: (717) 795.7793 David W. Knauer March 25, 2000 Mr. Joseph Hewitt 600 West Walnut Avenue Palmyra, PA 17078 f:: ,. Ii " " "I iJ RE: Estate of Bessie A. Wolfersberger !:1 Dear Mr. Hewitt: Please reference my letter of letter of February 14, 2000 in which I provided you with your outstanding bill with our firm. \1 Ij 'l1 ", ,I: I" 'I~ ,I. :,~1 Since that letter, I have had no response from you and no payment of the bill. i' ,~ This letter is to inform you that if you do not pay the bill or reach an acceptable payment plan with us within within ten days of the date of this letter that we will be forced to file suit against you for payment of your bill. , ,i1 ~i Ve,.fY truly yours, . 1 ()M1lt/~~/ David W. Knauer 11 'J ! li Ii 1 " I': f, [I I i,1 I do hope that it will be unnecessary to take that step however we will do so if the bill is not paid. DWK:ahk IwpdocslhewittI03-25-00hewitt.ltr . EXHIBIT ! j r , - C ,"< ,,' ~., ~ '" ~_ .u ,-, -,~ ~ "',;,.- Knauer & Associates, LSC 411A E. Main St., Mechanicsburg, A 17055 Attorneys-a t. Law Telephone: (717) 795.7790 Fax: (717) 795.7793 David W. Knauer M Y 24,2000 Mr. Joseph Hewitt 600 West Walnut Avenue Palmyra, PA 17078 RE: Estate of Bessie A. Wolfersber Dear Mr. Hewitt: You had questioned our bills agai st your payments, therefore, I enclose herewith a complete billing history and a I previously sent bills for your account with our firm, together with a certificate of mailing. Unless you pay the entire outstan ing amount of $3,108.15 by June 5, 2000, I will start suit against you to collect our fe s. Upon commencement of suit, we will obtain a judgment and the Sheriff will sei e and sell any of your property that they are able to seize. I do hope that it will not be necessary for us to start suit, but we must be paid for our work just as you wanted to be paid for your work. ~! tr~IY yours, t);fi(r ~~o/ David ~1ie~' DWK:bm Enclosures \wpdocs\l1ewitl\05.24-00hewitlJlr EXHIBIT Ii " G- i ~ .' ii'C L<, _.--" , ,I ._; -~-- = ,"> _-,.:.c. ..e,.;'; '..,~"~ _~.'._fij/"\& --_~'-- Knauer & Associates, LSC Attorneys-at-Law 411A. East Main Street, Mechanicsburg, P A 17055 Telephone, (717) 795.7790 Fax: (717) 795.7793 Em3il: knauer@earlv.com David W. Knauer August 28, 2000 Mr. Joseph Hewitt 600 West Walnut Avenue Palmyra, PA 17078 RE: Estate of Bessie A. Wolfersberger and Knauer v. Hewitt Dear Mr. Hewitt: Please find enclosed a courtesy copy of the District Justice Complaint we are filing against you for non-payment of our bill, a copy of the June IS, 2000 letter ofR. Mark Thomas, Esquire and my letter of the above date in response thereto. With respect to his request for contribution from the executors and beneficiaries to make up a 842, 000 shortfall of funds to pay the Pennsylvania Inheritance Tax, his proposal is that each beneficiary be responsible for their pro- rata portion of the unpaid taxes based on the value of the property they inherited. He informed me that he valued your share of the shortfall as approximately 8 As to the legal position, I believe that you should not have to make any contribution because the accounting information was withheld from you despite our numerous requests for copies of the accounting. I must call to your attention that you should retain legal counsel for the conclusion of the estate. I will co-operate fully with your new counsel to transfer your files and provide he or she with any infoffi1ation that may assist in responding to the requested payment. . .very truly yours, David W. Knauer DWK:bm \company\H ewi tt\08 -2 8-00h ewi tt.ltr EXHIBIT I B .H ..:.~, , - l. _ ~, " 0_ , _ " '_,.-. . j "' .""'. r ,'"e',,-'-- ",',- ",>1 '''"",,,C' - - '-' ""~~ -', VERIFICATION Subject to the penalties of 18 Pa. C.S.A. 4904 relating to unsworn falsification to ii authorities, we hereby certify that the facts in the foregoing pleading are true and correct to the best of our information and belief. Date: ~--?3-,fi'-o I . C' ~uJJ;\J1J~ fv~ ~ e ~ , - 7"""""~ . "=-.=~'~~ -- ~ ~..=, -. '" ~,-~, ~ "~-~- .-~.-~-"~- 'OfFICE OF TI\t SHERIF!", CUKBU'_MiD COUNTY" JnH 23 4 24 PM '01 {'pYLI::1 r: \1r"\\ 10.__;_ PENNSYLVANIA ~"" .- .,..,lII!i~~~~~ ' '- - , ~II .Iii! r '-10 ,~_, ,i#IlpImI~~ ,.' ':' ~~-- ,-~ "1 } l' KNAUER & ASSOCIATES, L.S.C Plaintiff IN THE COURT OF COMMON PLEAS, CUMBERLAND COUNTY V. JOSEPH A. HEWITT Defendant No. Civil Term JURY TRIAL DAMANDED CERTIFICATE OF SERVICE I, David W. Knauer, hereby certify that I did this 23rd day of January, 2001, serve a true and correct copy of the within document on all counsel of record by United States mail, first class, prepaid addressed as follows: Joseph A. Hewitt 600 West Walnut Street Palmyra, PA 17078 David W. Knauer Attorney for Plaintiff Attorney I.D. No. 21582 411-A East Main Street Mechanicsburg, PA 17055 (717) 795-7790 i ,~ '^ , ~" ". ., ~.--- IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA KNAUER & ASSOCIATES, L.S.C Plaintiff IN THE COURT OF COMMON PLEAS,CtmJBERLA1iD COUNTY V. JOSEPH A. HEWITT Defendant No. 01-482 Civil Term JURY TRIAL DAMANDED NOTICE TO DEFEND AND CLAIM RIGHTS 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. , ':: 1:--1 , ~ -; 'i '. 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. CUMBERLA1iD COUNTY BAR ASSOCIATION 2 Liberty Avenue Carlisle, Pennsylvania 17013 (717) 249-3166 '.-, ,-I '-'-,.." - ...c. ~r.' : '.,"'" NOTICIA Le han demaandado a usted en la corte. Si usted quieie defenderse de estas demandas expuestas en las paginas siguientes, usted tiene viente (20) dias de plazo al partir de la fecha de la demanda y la notificacion. Usted debe presentar una apariencia escrita 0 en persoa 0 por abogado y archivar en la corte enforma escrita sus defensas 0 sus objections alas demandas en contra de su persona. Sea avisado que si usted no se defiende, la corte tomara medidas y puede entrar una orden contra usted sin previo aviso 0 notificacion y por cualquier queja 0 alivio que es pedido en la peticion de demanda. Usted puede perder dinero 0 sus propiedades 0 otros derechos importanted para usted. LLEVE ESTA DEMANDA A UN ABOGADO INMEDIATAMENTE. S1 NO TIENE ABOGADO 0 S1 NO TIENE EL DINERO SUF1CIENTE DE P AGAR TAL SERV1C10, VA Y A EN PERSONA 0 LLAME POR TELEFONO A LA OF1CINA CUY A DIRECC10N SE ENCUENTRA ESCRITA ABAJO PARA A VERIGUAR DONDE SE PUEDE CONSEGUIR AS1STENC1A LEGAL. CUMBERLAND COUNTY BAR ASSOCIATION 2 Liberty Avenue Carlisle, Pennsylvania 17013 (717) 249-3166 Respectfully submitted, DAVID W. KNAUER, L.S.C. David . Knauer, Esquire Attorney for the Plaintiff Attorney I.D. No. 21582 4l1-A East Main Street Mechanicsburg, P A 17055 (717) 795-7790 Date: January ~ 2001 , ,~ ,J- <2 'i .,-: -- -;.".' _~.' , ... - ;,",. KNAUER & ASSOCIATES, L.S.C Plaintiff IN THE COURT OF COMMON PLEAS, CUMBERLAND COUNTY V. JOSEPH A. HEWITT Defendant No. 01-482 Civil Term JURY TRIAL DAMANDED (tfl4G/IDtI COMPLAINT 1. The Plaintiff Knauer and Associates is a corporation organized and doing business under the laws of the Commonwealth of Pennsylvania with an address of 411A East Main Street, Mechanicsburg, Pennsylvania 17055, an assignee of David W. Knauer P.C. 2. The Defendant Joseph A. Hewitt is an adult individual with an address of 600 West Walnut Street, Palmyra, Pennsylvania 17078. 3. The Plaintiff and its assignor provided legal services for the Defendant for several matters including but not limited to representing him in a will contest with respect to the Estate of Bessie A. Wolfersberger and matters involving Tuscorora Township, Perry County, Pennsylvania. 4. The Plaintiff and its assignor and the Defendant agreed that the representation would be on an hourly basis. 5. The Plaintiff rendered to the Defendant bills totaling $9,563.15, to wit: .O<_'^ '-,",_ 0" .;._ ,.,_--"''._n_"'_-__, a.) February 19, 1998 bill for services rendered with respect to the Estate of Bessie A. Wolfersberger in the amount $5,482.50; b.) February 19,1998 bill for services rendered with respect to zoning and other matters involved with Tuscarora Township in the amount of $1,190.15; c.) March 25, 2000 bill for services rendered with respect to the Estate of Bessie A. Wolfersberger in the amount of $2,485.50; d.) January 26,2001 bill for services rendered with respect ot the Estate of Bessie A. Wolfersberger in the amount of $405.00 The Plaintiff has marked as exhibits "A" through "D", attached hereto and incorporated herein by reference thereto true and correct copies of the aforesaid bills. 6. The Plaintiff provided to the Defendant a recapitulation of the bills, showing the amount of the bills and the funds paid. The Plaintiff marks as Exhibit "E", attaches hereto and incorporated herein by reference thereto true and correct copies of the aforesaid recapitulation. 7. The Defendant paid $6,050.00, leaving a balance owed of $3,108.15. 8. The Plaintiff made demand on the Defendant to pay the remaining outstanding bills by letters dated February 14, 2000, March 25, 2000, May 24, 2000 and August 28, 2000. The Plaintiff has marked as Exhibit "F" through "I" and incorporated herein by reference thereto true and correct copies of the aforesaid letters. 9. In addition to the aforesaid bills, the Plaintiff also performed additional services between February 7, 2000 and August 28, 2000 in the amount of $405.00 _~,- _'.;. "'0 '__ ,,' ~. " r! .:. f:: '; I,: I 1'; ,-,- ~---. . ,--- ,-,..,. """,,,I;~~J ~. ." .~. - ".. ,F' -J; ',,", '.- c '. ~ ~--. ,:" - j,i 10. The Defendant refused to pay the aforesaid unpaid balance of the bills. 11. The Plaintiff and its assignor's bills were the usual, customary, and reasonable charges the Defendant agreed to pay. 12. The Plaintiff is entitled to payment of the unpaid balance of the bills. WHEREFORE, the Plaintiff demands judgment in its favor and against the Defendant in the amount of $3,513.15 with interest on the unpaid balances and costs of suit. Respectfully submitted, KNAUER & ASSOCIATES, L.S.C. Date: January 26, 2001 avid W. Knauer, Esquire Attorney for Plaintiff Attorney 1.0. No. 21582 411-A East Main Street Mechanicsburg, PA 17055 (717) 795-7790 ,~ - , 'i-_ .'-'.i. ,..:,,'-. '-. ~ VERI FIe A T ION Subject to the penalties of 18 Pa. C.S.A. 4904 relating to unsworn falsification to authorities, we hereby certify that the facts in the foregoing pleading are true and correct to the best of our information and beliei. YJtM1Jj.~- !; [': ',:-~ --::-... ...' ~ ,""",'~ c, I - - -o.-."J.' .;, ,-_~ . " " <-~ J KNAUER & ASSOCIATES, L.S.C Plaintiff IN THE COURT OF COMMON PLEAS, CUMBERLAND COUNTY V. JOSEPH A. HEWITT Defendant No. Civil Term JURY TRIAL DAMANDED CERTIFICATE OF SERVICE I, David W. Knauer, hereby certify that I did this 26th day of January, 2001, serve a true and correct copy of the within document on all counsel of record by United States mail, first class, prepaid addressed as follows: Joseph A. Hewitt 600 West Walnut Street Palmyra, PA 17078 ~(jj(~ Davl~W. Knauer Attorney for Plaintiff Attorney I.D. No. 21582 411-A East Main Street Mechanicsburg, PA 17055 (717) 795-7790 -'-T ,-.,. " ]-,-- ;L- "I _,_,c,_._' ,,,, 6Da~id lC). j(nauq~, qf).e. ATIORNEYS AT LAW 411 A East Main Street Mechanicsburg, PA 17055 (717) 795-7790 DAVID W. KNAUER February 19, 1998 Mr. Joseph Hewitt 600 West Walnut Avenue Palmyra, PA 17078 RE: Estate of Bessie Wolfersberger Bill for Services Rendered Date Descriotion 08/29/96 Extensive office conference with client; reviewed documents; prepared reply to Co-Executor's petition for sanctions and removal of client as executor; called Estate counsel's office; left message to return call. 08/30/96 Called Estate counsel's office; left message to return call. " _~____.~,""""'(_,,_~,,'; -,_~~, ~, -__ - . _ ."" .'C Time 3.20 .20 MARK D. SCHWARTZ Charqe 480.00 30.00 09/03/96 Filed Praecipe to Enter Appearance and reply to 1.40 210.00 motion to remove client as executor, etc.; drafted letter to Estate counsel; returned Estate counsel's call; left message to return call. 09/09/96 Called Estate Counsel's office; left message to return .20 30.00 call. 09/10/96 Called Estate Counsel's office; left message to return .20 30.00 call. 09/19/96 Receipt and review of title search from The Sentinel 0.50 75.00 agency. 09/23/96 Called Estate Counsel's office; left message to return .20 30.00 call. 11/19/96 Receipt and review 0 sel. .20 30.00 EXHIBIT i1 l!A" I '" c . ' -',-,'-, . ". , ".1 :,~ ,'" --, '-. ,,'y ,=--.',-, _' ' 0",'-" ""~ ~-< -._ ." 12/04/96 Called Estate Counsel's office; left message to return .20 30.00 call. 12/05/96 Extensive telephone conference with Estate Counsel. .30 45.00 12/18/96 Telephone calls to client regarding Humane Society .50 75.00 concerns with sheep. 1 0/02/96 Receipt and review of Order of the Honorable Warren .20 30.00 G. Morgan scheduling hearing on petition to remove client as executor. 10/03/96 Called Estate Counsel's office; left message to return .50 75.00 call. Extensive telephone conference with estate counsel who will require co-executor to retain his own counsel if he wishes to pursue removal of client as executor. 01/31/97 Receipt and review of letter from James Morgan, .20 30.00 Esquire. 03/04/97 Receipt and review of letter from client .20 30.00 03/10/97 Meeting with Attorney Morgan. .30 45.00 04/07/97 Meeting with client. .50 75.00 04/23/97 Drafted letter to Attorney Morgan. .20 30.00 I:' 04/30/97 Receipt and review of letter from Attorney Morgan. .20 30.00 08/28/97 Receipt and review of letter from R. Mark Thomas, .20 30.00 Esquire. 09/12/97 Drafted letter to Attorney Thomas. .20 30.00 09/29/97 Receipt and review of letter from client. .20 30.00 10/02/97 Receipt and review of Order and Petition scheduling .30 45.00 hearing. 10/10/97 Drafted petition to remove James Spangler as Co- 3.0 450.00 Executor. 10/15/97 Receipt and review of letter from Attorney Thomas. .20 30.00 10/20/97 Meeting with client. .50 75.00 10/21/97 Receipt and review of letter from Attorney Thomas. .20 30.00 -~, ~ To ~, t, ,I c, , - '",,- '.' ,c___ ~_,' , . 'i-l'-~' ,,""'--" ""'-'v"..' ',-"__' ._~ 10/29/97 . Receipt and review of letter from client. .40 60.00 12/08/97 - ~.~eeting with client; drafted legal memorandum on 5.0 750.00 12/09-97 behalf of client. 12/08/97 - Preparation for hearing; reviewed file; attendance at 12.0 1,800.00 12/12/97 hearings on December 10& December 12, 1997; reviewed legal memorandum filed by Attorney Thomas. 12/17/97 Preparation for and meeting with Attorney Thomas to 1.50 225.00 narrow issues, to provide for procedure to resolve estate issues, and to plan to conclude estate. 01/14/98 Drafted letter to Attorney Morgan confirming that his .30 45.00 bill has been paid. 01/17/98 Telephone conference with Attorney Boyanowski to 1.00 150.00 confirm that her bill had been paid; drafted letter confirming same; receipt and review of letter from Attorney Morgan; drafted letter to Attorney Thomas , ';j forwarding letter of Attorney Morgan. ,'1 '" 02/12/98 Drafted letter to Attorney Thomas forwarding letter of .30 45.00 >0" ,:: Attorney Boyanowski and confirming meeting with Executors. , 02/13/98 Drafted letter to client regarding meeting of Executors. .30 45.00 12/17/97 - Numerous telephone conferences with Attorney 1.0 150.00 02/18/98 Thomas. Total Charges $5,400.00 Plus Expenses Advanced 82.50 $5,482.50 Less Retainer 2.200.00 Total Amount Due $3,282.50 " ,- ,,-" '~ . " "'- " . - ,~^ l'_"~,,'_" ~,~,.,(...' '-"'~;'l_' -;','-',,'c"_ " _" ", --C'" ". 6DaviJ 11). Xnaug,... @.e. ATTORNEYS AT LAW 411 A East Main Street Mechanicsburg, PA 17055 (717) 795-7790 DAVID W. KNAUER February 19, 1998 MARK D. SCHWARTZ Mr. Joseph Hewitt 600 West Walnut Avenue Palmyra, PA 17071;3 I RE: Tuscarora Township Zoning Bill for Services Rendered' Date Descriotion Time Charoe 04-07-97 Office appointment with client 0.50 50.00 04-08-97 Telephone conference with Jerry A. Philpott, Esquire 0.30 30.00 04-23-97 Visit to Hewitt farm with Mr. George Fleisher 3.00 300.00 05-02-97 Telephone conference with Attorney Philpott 0.20 20.00 05-09-97 Receipt and review of letter with township ordinances 0.60 60.00 from Attorney Philpott 05-27 -97 Drafted letter to Attorney Philpott 0.30 30.00 06-05-97 Receipt and review of letter from Attorney Philpott 0.20 20.00 06-13-97 Telephone call from client 0.20 20.00 06-24-97 Receipt and review of letter from Attorney Philpott 0.20 20.00 07-12-97 Visit to Hewitt farm (Mr. Fleisher, client, and Attorney 4.00 400.00 Knauer) 'This invoice is for work performed on or after April 7, 1997. You were previously billed for work performed from August 30,1996, through April 6, 1997, which was paid by the retainer given to us when you hired us to represent ou in this matter. On April 7, 1997, you provided an additional retainer of $600. EXHIBIT I w 6 tl 07-15-97 Receipt and review of letter from Attorney Ptlilpott 0.20 20.00 07-23-97 Drafted letter to Attorney Philpott 0.20 20.00 07-30-97 Receipt and review of letter from client 0.20 20.00 08-11-97 Receipt and review of letter from client 0.20 20.00 09-12-97 Office meeting with client 0.50 50.00 09-19-97 Drafted letter to Attorney Philpott 0.30 30.00 09-24-97 Receipt and review of letter from Attorney Philpott 0.20 20.00 10-08-97 Drafted letter to Attorney Philpott 0.20 20.00 10-10-97 Receipt and review of letter and enclosures from 0.20 20.00 Attorney Philpott Total Charges $1,170.00 Plus Expenses Advanced 20.15 $1,190.15 Less Retainer 600.00 Total Amount Due S 590.15 -,.-,,;,.. "-.-' '-. "~". ' >~. -:1 .-, c,,' ',; ,.~ _, ,"' _~,' "/- <._'_. - '; ATTORNEY BILL AND TIME EXPENDED ESTATE OF BESSIE WOLFERSBERGER 1998 4-15 Receipt, review, and analysis of the April 13, 1998 decision of the Honorable Warren G. Morgan finding in favor of Mr. Hewitt. .2 Telephone call to Mr. Thomas's office. He was not in and left word to request a return telephone call. .1 Telephone call to Mr. Hewitt to inform him that Judge Morgan had found in his favor on the third lot. .2 4-16 Telephone conference with Mr, Thomas who informed me that he had not yet spoken with his clients but would inform me of their decision. .2 Letter to Mr. Hewitt with copy of Judge Morgan's decision and update on status of case after Judge Morgan's decision. .3. 4-27-29 Two telephone calls to Mr. Thomas' office. Left word to call. .2 5-1 Receipt and review of letter from Mr. Hewitt. .2 5-4 Extensive letter in reply to Mr. Hewitt's letter received on May 1, 1998. 1.0 5-14 Telephone call to Mr. Thomas to determine if his clients had appealed Judge Morgan's April 13, 1998 decision. Secretary informed me that Mr. Thomas had not filed an appeal. Left word to call to determine if his client's may have changed attorneys again. .2 5-18 Receipt and review of letter from Mr. Hewitt. .2 5-21 Short conference with Thomas who informed me that his clients will not appeal Judge Morgan's decision. .3 5-21 Letter to Mr. Hewitt reporting that Mr. Thomas's clients will not appeal. .3 8/29 Extensive conference with client, review of documents, preparation of reply to other executor's petition for sanctions and removal of client as co-executor. 3.0 8/29 Telephone conference with Estate counsel's office, left word to call. .2 8/30 Telephone conference with Estate Counsel's office, left word to call. .2 '" ,_', ,"'., , ~I '_.',,..,".'_ ""_~-,,,_ "'.;.'""'oO'~ --""-, ~'*' ,'-~, 9/2, File reply to executor's motion to remove client as executor, etc. 1,0 9/3 Returned Estate counsel's call. Telephone conference with Estate counsel's office, left word to cal1.2 9/9 Telephone conference with Estate Counsel's office, left word to call. ,2 9/10 Telephone conference with Estate counsel left word call. .2 9-23 Telephone call to Estate Counsel's office, left word to call. .2 10-2 Receipt and review of Order of the Honorable Warren G. Morgan scheduling hearing on other executor's petition to remove client as executor. .2 10-3 Telephone call to Estate Counsel's office, left word to call. ,2 Estate Counsel returned telephone call. Extensive telephone conference with her. She will require co-executor to retain his own counsel if he wishes to pursue removal of client as executor. .3 10-10 Drafting and filing of Petition to Remove Spangler as Co-Executor. 3.0. 10-29 Reading and review of letter from Mr. Spangler. .5 11-13 Receipt and review of November 13, 1998 letter of Mr. Thomas with respect to estate accounts. .2 11-19 Receipt and Review of letter from Estate counsel. .2 12-4 Phone call to Estate Counsel, left message. .2 12-5 Extensive telephone conference with Estate Counsel. .3 12-18 Telephone calls to Mr. Hewitt Re: Humane Society concerns with sheep. .5 1999 01-21 Receipt and review of letter from Mr. Hewitt. .2 01-22 Phone ,call from Sue Helm. .2 01-23 Phone call to Mark Thomas, Esquire. .2 05-27 Telephone conference with Rachel Helm who called with respect to Perry County case. .2 ,.'> " "', " I-",-__I_'_",_.,.,,_~. <(-; "-'"",~ ,~-~:j,;:~ ,:__.., "~"_'.'" :_,-;-t.. ;,"', _~ __~,,__;," 2000 02-03 Receipt and review of Mr. Hewitt's letter concerning erroneous information that we had place a lien against his property. .2 Letter to Mr. Hewitt with status of the estate and informing him that we had not placed any lien on his property or taken an action against him. .4 Telephone conference with Attorney Thomas requesting update on when the estate would be completed. .3 Total 16.0 Hours @ 150.00 Per Hour __n_____m____________________n__m_m____ $2,400.00 COSTS ADVANCED 03/99 Deeds (Dauphin County) 85.50 Total Costs Advanced 85.50 Total Costs & Outstanding Bill 2,485.50 .,,;,",. "'-,. ;-',-.,".".,-. , -'_h -,".".- " ',fi._i,~~~_.., "_~-,,-o.:+_:'_""'_'_' ",,' ~ .': ~." ell"! ',' /. _ _, JOSEPH HEWITT ATTORNEY'S BILL FOR PROFESSIONAL SERVICES RENDERED FROM FEBRUARY 3. 2000 02-07- Telephone conference with Mark Thomas, Esquire who, informed me that 02-11 the estate was insolvent without sufficient funds to pay death taxes. .2 02-14 Letter to Mr. Thomas confirming the telephone conference wherein he informed me of the insolvency of the estate. .3 Letter to Mr. Hewitt informing him that Mr. Thomas had informed us that the estate was insolvent and was without funds to pay death taxes. .3 03-25 Letter to Mr. Hewitt informing him that we would no longer represent him if he did not pay his outstanding bill. No Charge 03-29 Receipt and review of letter from Mr. Hewitt. .3 05-24 Letter to Mr. Hewitt with respect to his outstanding bill. No Charge 06-16 Receipt and review of letter from Mr. Thomas concerning insolvency of the estate, his opinion that the Co-Executors and heir Joyce Seibert should make up the deficit to pay the death taxes. .2 07-03 Letter to Mr. Thomas in response to his letter of June 16, 2000. .3 07-27 Receipt of Mr. Thomas' letter with respect to surcharge of the estate. .2 08-23 Telephone conference with Mr. Thomas with respect to the insolvency of the estate and the amount of the insolvency. .3 08-24 Letter to Mr. Thomas informing him of termination of our representation of Mr. Hewitt and also of the pro rata contribution that Mr. Hewitt was not responsible for. .3 08-28 Letter to Mr. Hewitt with respect to status of the estate and transfer of file should he retain additional counsel. .3 Total 2.7 Hours @ 150.00 Per Hour ______m__________________________________ $405.00 EXHIBIT i I Lc.oJi '...- , - ~ . , " -, .'- .,"- ,,">,'.'; ',c,.,,,,""'-- ."1 ~ , _,m._, '__"~-'_, .. _". _ _~"", '":,-,,,.~. '.,-~-~ .,<;; ..",'%, "",,;., ;",. ''''^' -,; JOSEPH HEWITT ATTORNEY'S BILL FOR PROFESSIONAL SERVICES RENDERED FROM FEBRUARY 3. 2000 02-07- Telephone conference with Mark Thomas, Esquire who, informed me that 02-11 the estate was insolvent without sufficient funds to pay death taxes. .2 02-14 Letter to Mr. Thomas confirming the telephone conference wherein he informed me of the insolvency of the estate. .3 Letter to Mr. Hewitt informing him that Mr. Thomas had informed us that the estate was insolvent and was without funds to pay death taxes. .3 03-25 Letter to Mr. Hewitt informing him that we would no longer represent him if he did not pay his outstanding bill. No Charge 03-29 Receipt and review of letter from Mr. Hewitt. .3 05-24 Letter to Mr. Hewitt with respect to his outstanding bill. No Charge 06-16 Receipt and review of letter from Mr. Thomas concerning insolvency of the estate, his opinion that the Co-Executors and heir Joyce Seibert should make up the deficit to pay the death taxes. .2 07 -03 Letter to Mr. Thomas in response to his letter of June 16, 2000. .3 07-27 Receipt of Mr. Thomas' letter with respect to surcharge of the estate. .2 08-23 Telephone conference with Mr. Thomas with respect to the insolvency of the estate and the amount of the insolvency. .3 08-24 Letter to Mr. Thomas informing him of termination of our representation of Mr. Hewitt and also of the pro rata contribution that Mr. Hewitt was not responsible for. .3 08-28 Letter to Mr. Hewitt with respect to status of the estate and transfer of file should he retain additional counsel. .3 Total 2.7 Hours @ 150.00 Per Hour ______m_______________nm_..m_..__m $405.00 Sd' '---1- - ,<-~ - -;,.---,,-~ -./--" ".,. .,. ,.-." .. Knauer & Associates, LSC 411A E. Main St., Mechanicsburg, PA 17055 Attorneys-at-Law Telephone: (717) 795.7790 Fax: (717) 795.7793 Da\"id W. Knauer JOSEPH HEWITT WOLFERSBERGER ESTA TE & TUSCARORA TOWNSHIP ZONING TOTAL BILLING HISTORY 2/19/1998 Zoning Bill (see attached) 1,190.15 2/19/1998 Estate Bill (see attached) 5,482.50 2,485.50 3/25/2000 Estate Bill (see attached) Total Zoning and Estate Bills 9,158.15 TOTAL REIMBURSEMENT/FEE HISTORY 8/11/1996 Fee for Wolfersberger Estate 200.00 8/30/1996 Fee for Wolfersberger Estate 250.00 9/3/1996 Retainer for Wolfersberger Estate 2,000.00 600.00 4/7/1997 Retainer for Tuscarora Township Zoning 8/4/1998 Fee for Wolfersberger Estate 3,000.00 Total Zoning and Estate ReimbursemenVFees 6,050.00 TOTAL OUTSTANDING BILL 3,108.15 PA YMENT UPON RECEIPT EXHIBIT I fA..t. II ,-' ,. ",,,,-,- , -k__,I, '". '.~ "~'"'' .;,-- ....,L ,,,.~< ' --,~"" -,-- ~'- c Knauer & Associates, LSC 411A E. Main St., Mechanicsburg, PA 17055 Attorneys-at-Law Telephone: (717) 795-7790 Fax: (717) 795-7793 David \Y.I. Knauer February 14, 2000 Mr. Joseph Hewitt 600 West Walnut Avenue Palmyra, PA 17078 RE: Estate of Bessie A. Wo/fersberger Dear Mr. Hewitt: This acknowledges receipt of your letter wherein you stated that we had placed a lien against your property. You are mistaken. We have not filed any lien or taken any adverse action against you. I did review your accounts with us and I include herewith a statement of all bills owed to us. We would appreciate payment of the balance on your bills. Last week I spoke with R. Mark Thomas, Esquire who is counsel for your co- executor James Spangler. Mr. Thomas informed me that the estate had insufficient funds to pay both the state inheritance and the federal estate taxes. I requested him to provide us with a copy of the documentation with respect to the taxes. I will await receipt of the documentation to support his statement. I enclose a copy of said letter to him. Thank you for your prompt attention in this matter. If you have any question, please do not hesitate to contact me. Very truly yours, ~.s:{ l~-J (~~ David W. Knauer DWK:wdm Enclosures \wpdocs\hewit1\02-09~OOhewit1.ltr ~' -. - . " . ,"I", ., l:",,", -.,-' , ,,' ,"~' <. - ~-, "'~ _ 0 ~_ Knauer & Associates, LSC 411A E. Main St., Mechanicsburg, PA 17055 Attorneys-at-Law Telephone: (717) 795.7790 Fax: (717) 795-7793 Dadd W. Knauer March 25, 2000 Mr. Joseph Hewitt 600 West Walnut Avenue Palmyra, PA 17078 RE: Estate of Bessie A Wolfersberger Dear Mr. Hewitt: Please reference my letter of letter of February 14, 2000 in which I provided you with your outstanding bill with our firm. Since that letter, I have had no response from you and no payment of the bill. This letter is to inform you that if you do not pay the bill or reach an acceptable payment plan with us within within ten days of the date of this letter that we will be forced to file suit against you for payment of your bill. I do hope that it will be unnecessary to take that step however we will do so if the bill is not paid. Ve,\ry truly yours, /./;fl'~ /11 (r;'JN~ , /ifvLf:J-UJ ~0' David W. Knauer DWK:ahk IwpdocslhewittI03-25-00hewitt,llr >"1 " ,- "f"".' "," "' "~", ""-,'-' ,,;'''k' " r:.' I" '" """; " ,,-<'''i ''', ,,'0' -~,<;.> .; ~', "'J; _.",-~'---'~, d-" ,',. " . Knauer & Associates, LSC 411A E. Main St., Mechanicsburg, PA 17055 Attorneys-a t- Law Telephone: (717) 795-7790 Fax: (717) 795.7793 Da\'id W. Knauer May 24, 2000 Mr. Joseph Hewitt 600 West Walnut Avenue Palmyra, PA 17078 RE: Estate of Bessie A. Wolfersberqer/Tuscarora Township Zonina Matters Dear Mr. Hewitt: You had questioned our bills against your payments, therefore, I enclose herewith a complete billing history and all previously sent bills for your account with our firm, together with a certificate of mailing. Unless you pay the entire outstanding amount of $3,108.15 by June 5, 2000, I will start suit against you to collect our fees. Upon commencement of suit, we will obtain a judgment and the Sheriff will seize and sell any of your property that they are able to seize. I do hope that it will not be necessary for us to start suit, but we must be paid for our work just as you wanted to be paid for your work. [to"~<<<J/ David W. Kn uer DWK:bm Enclosures \wpdocslhewitt\OS-24-00hewitt"llr EXHI$IT I~ '"-. " . ~, - ~ ' ,,"-~, --.~.. Knauer & Associates, LSC Attorneys-at-Law 41lA. East Main Street, Mechanicsburg, PA 17055 Telephone: (717) 795.7790 Fax: (717) 795-7793 Email: knauer@earlv.com David W. Knauer w ~__ ",,",'0 e' ,,__ r,-' . August 28, 2000 Mr. Joseph Hewitt 600 West Walnut Avenue Palmyra, PA 17078 RE: Estate of Bessie A. Wolfersberger and Knauer y_ Hewitt Dear Mr. Hewitt: Please find enclosed a courtesy copy of the District Justice Complaint we are filing against you for non-payment of our bill, a copy of the June 15, 2000 letter ofR. Mark Thomas, Esquire and my letter of the above date in response thereto. With respect to his request for contribution from the executors and beneficiaries to make up a 842, 000 shortfall of funds to pay the Pennsylvania Inheritance Tax, his proposal is that each beneficiary be responsible for their pro- rata portion of the unpaid taxes based on the value of the property they inherited. He infonned me that he valued your share of the shortfall as approximately 8 As to the legal position, I believe that you should not have to make any contribution because the accounting infonnation was withheld from you despite our numerous requests for copies of the accounting. I must call to your attention that you should retain legal counsel for the conclusion of the estate. I will co-operate fully with your new counsel to transfer your files and provide he or she with any information that may assist in responding to the requested payment. Very truly yours, David W. Knauer DWK:bm \com pan y\Hewi tt \08- 28-00 hewi tt.l tr ExHIBIT .~ It. D ~( ;,! C* ""iL~D-1!i'tIC.'1= _ .rl.'- ',.I' I j ,,- Of" 'I'" PHQTHONOTARY 0\ .H,!j 29 PM 3: 50 CUMdERt/oND COUNW PENt,SYLVANIA ;; Ii I i j I I I J- '"" '--'""', J' ,-<" "'" _~"", .- "h_~,,~ KNAUER & ASSOCIATES, L.S.C Plaintiff IN THE COURT OF COMMON PLEAS, CUMBERLAND COUNTY V. JOSEPH A. HEWITT Defendant No. 01-482 Civil Term JURY TRIAL DAMANDED PLAINTIFF'S REQUESTS FOR ADMISSION (FIRST SET) TO THE DEFENDANT JOSEPH HEWITT Within thirty (30) days of the date of service of these Plaintiffs Requests for Admission (First Set), for the purposes of this action only, you are requested to admit the truth of any matters within the scope of Pa.R.C.P. 4003.1 through Pa.R.C.P NO. 4003.5 inclusive set forth in the request that relate to statements or opinions of fact or of the application of law to fact, including the genuineness authenticity, correctness, execution, signing, delivery, mailing or receipt of any document described in this request. The Plaintiff incorporates herein by reference thereto Pa.R.C.P. No. 4014, Pa.R.C.P. No. 4003.1, Pa.R.C.P. No. 4003.5 and Pa.R.C.P. No. 4019(d). For the purposes of these requests for admission, as appropriate, the singular is also the plural, the masculine and feminize gender are requested in accordance with the sex of the party or parties answering or objecting or on behalf of whom the answers or objections are made and - ,.. '^ 1:__ -'. '. .';;.<;. . - ~ -,' '~, .'" the third party includes both genders as c\foresaid and the third party pronoun "it" as to corporations, other business entities or other type of entities not hereinbefore set forth. Pursuant to Pa.R.C.P. No. 4014(b) the matters that the Plaintiff has requested you to admit shall be deemed admitted unless within thirty (30) days of service of these requests for admission you serve upon the Plaintiff an answer verified by you or an objection signed by you or by your counsel. If an objection is made, the reasons therefore shall be stated. The answer shall admit or deny the matter or set forth in detail the reasons why you cannot truthfully do so. A denial shall fairly meet the substance of the requested admission, and when good faith requires that you qualify the answer or deny only a part of the matter you are requested to admit, you shall specify so much of it as true and qualify or deny the remainder. You may not give lack of information or knowledge as a reason for failure to admit or deny unless you state that you have made reasonable inquiry and that the information known or readily obtainable by you is insufficient to enable you to admit of deny the request for admission. If you consider that a matter of which an admission has been requested presents a genuine issue of trial you may not, on that ground alone, object to the request. You may, subject to the provisions of Pa.R.C.P. No. 4019(d) deny the matter or set forth reasons why you cannot admit or deny it. 'Co'_' .,~. ,-" , ' ~ . -. A_ . , -<._ ,C'Co I, These requests for admission are continuing and in the event that you learn or come to believe that any objection, answer or admission made in response to these Plaintiff's Requests for Admission (First Set) is no longer true, then you have a duty to supplement your response to these requests. Respectfully submitted, KNAUER & ASSOCIATES, L.S.C. Date: January 26, 2001 David W. Knau ,Esquire Attorney for Plaintiff Attorney 1.0. No. 21582 411-A East Main Street Mechanicsburg, PA 17055 (717) 795-7790 . liIiir)~,-- , j j i i1 'j j :1 I J I .., ~L " .-,; .j b.) February 19,1998 bill for services rendered with respect to zoning and other matters involved with Tuscarora Township in the amount of $1,1 90.15; i I i I J I I 1 1 I I j I :'1 ~ i I II , ,I i I .i II 1 I 'I 1 1 i 'I :1 I j 1. The Plaintiff and its assignor provided legal services for the Defendant for several matters including but not limited to representing him in a will contest with respect to the Estate of Bessie A. Wolfersberger and matters involving Tuscorora Township, Perry County, Pennsylvania. 2. The Plaintiff and its assignor and the Defendant agreed that the representation would be on an hourly basis. 3. The Plaintiff rendered to the Defendant bills totaling $9,563.15, to wit: a.) February 19,1998 bill for services rendered with respect to the Estate of Bessie A. Wolfersberger in the amount $5,482.50; c.) March 25, 2000 bill for services rendered with respect to the Estate of Bessie A. Wolfersberger in the amount of $2,485.50; d.) January 26,2001 bill for services rendered with respect ot the Estate of Bessie A. Wolfersberger in the amount of $405.00 The Plaintiff has marked as exhibits "A" through "0", attached hereto and incorporated herein by reference thereto true and correct copies of th~aforesaid bills, 4, The Plaintiff prOVided to the Defendant a recapitulation of the bills, .- ~,. -I "', -, '-i: showing the amount of the bills and the funds paid. The Plaintiff marks as Exhibit "E", attaches hereto and incorporated herein by reference thereto true and correct copies of the aforesaid recapitulation. 5. The Defendant paid $6,050.00, leaving a balance owed of $3,108,15. 6. The Plaintiff made demand on the Defendant to pay the remaining outstanding bills by letters dated February 14, 2000, March 25,2000, May 24, 2000 and August 28, 2000. The Plaintiff has marked as Exhibit "F" through "I" and incorporated herein by reference thereto true and correct copies of the aforesaid letters. 7. In addition to the aforesaid bills, the Plaintiff also performed additional services between February 7, 2000 and August 28,2000 in the amount of $405.00 8. The Defendant refused to pay the aforesaid unpaid balance of the bills. g. The Plaintiff and its assignor's bills were the usual, customary, and reasonable charges the Defendant agreed to pay. 10. The Plaintiff is entitled to payment of the unpaid balance of the bills in the amount of $3,513.15 plus interest and costs of suit.. Respectfully submitted, Date: January 26, 2001 KNAUER & ASSOCIATES, L.S.C. ~ifi~= Attorney for Plaintiff Attorney I.D. No. 21582 411-A East Main Street Mechanicsburg, PA 17055 (717) 795-7790 I ~ ._""' ,- i, ,~. '4 ""'" I'-",'-~ ,~ - ~I 'I 'I I I ,:1 Gj)a~ld It). .:Kn,aUl1r, @.e. February 19, 1998 MARK D. SCHWARTZ I .1 i I , I I I I I i I I ,.\ " I i I , I ',i I I i I , , , ATTORNEYS AT LAW 411 A East Main Street Mechanicsburg, PA 17055 (717) 795-7790 DAVID W. KNAUER Mr. Joseph Hewitt 600 West Walnut Avenue Palmyra, PA 17078 RE: Estate of Bessie Wolfersberger Bill for Services Rendered Date Description Time Charge 'I 08/29/96 Extensive office conference with client; reviewed documents; prepared reply to Co-Executor's petition for sanctions and removal of client as executor; called Estate counsel's office; left message to return call. 3.20 480.00 '-I ;1 "~1 ;'! 08/30/96 Called Estate counsel's office; left message to return call. .20 30.00 09/03/96 Filed Praecipe to Enter Appearance and reply to 1.40 210.00 motion to remove client as executor, etc.; drafted letter to Estate counsel; returned Estate counsel's call; left message to return call. 09/09/96 Called Estate Counsel's office; left message to return .20 30.00 call. 09/10/96 Called Estate Counsel's office; left message to return .20 30.00 call. 09/19/96 Receipt and review of title search from The Sentinel 0.50 75.00 agency. 09/23/96 Called Estate Counsel's office; left message to return .20 30.00 call. 11/19/96 Receipt and review 0 sel. .20 30.00 EXHIBIT ..,... ~ Ll A I' D .11. Z!', _.,___ _~_,., _,,',. c~ - ," ',_ ~,,__~" _'=__0._ - fj U 12/04/96 Called Estate Counsel's office'; left message to return .20 30.00 call. 12/05/96 Extensive telephone conference with Estate Counsel. Ji .30 45.00 In 11i ,~'i 12/18/96 Telephone calls to client regarding Humane Society \1 .50 75.00 " , Ii concerns with sheep. i.! ~~ J 10/02/96 Receipt and review of Order of the Honorable Warren .20 30.00 :1:-: '(I G. Morgan scheduling hearing on petition to remove :i\ I~ I client as executor. "I I 10/03/96 Called Estate Counsel's office; left message to return ,::J .50 75.00 ~ I call. Extensive telephone conference with estate :H j' counsel who will require co-executor to retain his own k\ ii:j counsel if he wishes to pursue removal of client as ;~J ! ,j executor. Ii ,.I ,~! :~j 01/31/97 Receipt and review of letter from James Morgan, .20 30.00 i.1 Esquire. n II ~'I 03/04/97 Receipt and review of letter from client .20 30.00 il ',;: 03/10/97 Meeting with Attorney Morgan. .30 45.00 H ~j 11 04/07/97 Meeting with client. 75.00 ~i .50 i ~ i ,-'1 ':1 f! 04/23/97 Drafted letter to Attorney Morgan. 30.00 ,! .20 11 .1 i' :1 04/30/97 Receipt and review of letter from Attorney Morgan. .20 30.00 il 11 " 08/28/97 Receipt and review of letter from R. Mark Thomas, .20 30.00 " !i Esquire. 11 09/12/97 Drafted letter to Attorney Thomas. .20 30.00 09/29/97 Receipt and review of letter from client. .20 30.00 10/02/97 Receipt and review of Order and Petition scheduling .30 45.00 hearing. 10/10/97 Drafted petition to remove James Spangler as Co- 3.0 450.00 Executor. 10/15/97 Receipt and review of letter from Attorney Thomas. .20 30.00 10/20/97 Meeting with client. .50 75.00 10/21/97 Receipt and review of letter from Attorney Thomas. .20 30.00 DAVID W. KNAUER ~ I , "--d, q)o~id W. 3ClOU",.., @.e. ATTORNEYS AT LAW 411 A EaSt Main'Street Mechanicsburg, PA 17055 (717) 795-7790 February 19, 1998 Mr. Joseph Hewitt 600 West Walnut Avenue Palmyra, PA 17078 RE: Tuscarora Township Zoning Date 04-07-97 04-08-97 04-23-97 05-02-97 05-09-97 05-27 -97 06-05-97 06-13-97 06-24-97 07-12-97 Bill for Services Rendered' Description Office appointment with client Telephone conference with Jerry A. Philpott, Esquire Visit to Hewitt farm with Mr. George Fleisher Telephone conference with Attorney Philpott Receipt and review of letter with township ordinances from Attorney Philpott Drafted letter to Attorney Philpott Receipt and review of letter from Attorney Philpott Telephone call from client Receipt and review of letter from Attorney Philpott Visit to Hewitt farm (Mr. Fleisher, client, and Attorney Knauer) ._ ~ '\,. "_', o;,_,~-;,~""("o"'~~'_"'~' ,," Time 0.50 0.30 3.00 0.20 0.60 0.30 0.20 0.20 0.20 4.00 ''''"-',-<~ MARK D. SCHWARTZ Charqe [j I:i; i i,1 i: " i::i 50.00 ;~i ,;~ 'Ii '0 , 30.00 .:: j~! 300.00 20.00 60.00 30.00 20.00 20.00 20.00 400.00 'This invoice is for work performed on or after April 7, 1997. You were previously billed for work performed from August 30, 1996, through April 6, 1997, which was paid by the retainer given to us when you hired us to represent ou in this matt r. On April 7, 1997, you provided an additional retainer of S600. EXHIBIT I u () II . .- .-- ." ,.1. ;."",,_;1_. ','-, ." " ,'.' -o,___.,c'_~'" -.~,",.;.~.:...,::,~-_'^' ,.""~ .' '_"l_ 07-15-97 .Receipt and review of letter from Attorney Philpott 0.20 20.00 07-23-97 Drafted letter to Attorney Philpott 0.20 20.00 07-30-97 Receipt and review of letter from client 0.20 20.00 08-11-97 Receipt and review of letter from client 0.20 20.00 09-12-97 Office meeting with client 0.50 50.00 09-19-97 Drafted letter to Attorney Philpott 0.30 30.00 09-24-97 Receipt and review of letter from Attorney Philpott 0.20 20.00 10-08-97 Drafted letter to Attorney Philpott 0.20 20.00 10-10-97 Receipt and review of letter and enclosures from 0.20 20.00 Attorney Philpott Total Charges $1,170.00 Plus Expenses Advanced 20.15 $1,190.15 Less Retainer 600.00 Total Amount Due S 590.15 .,. . ,', -,.o'- "~- ., '" '"h'~''' '''''''ro''"", ~'r_".-<","~"".",,,',-, ,-~ ': ATTORNEY BILLANDT1ME EXPENDED ESTATE OF BESSIE WOLFERSBERGER 1998 4-15 Receipt, review, and analysis of the April 13, 1998 decision of the Honorable Warren G. Morgan finding in favor of Mr. Hewitt. .2 ;i '11 , , 11: Telephone call to Mr. Thomas's office. He was not in and left word to request a return telephone call. .1 d' " ,'i ;i! Telephone call to Mr. Hewitt to inform him that Judge Morgan had found in his favor on the third lot. .2 ::' ';; ',1 ::i cil :~ 4-16 Telephone conference with Mr. Thomas who informed me that he had not yet spoken with his clients but would inform me of their decision. .2 ;~ " i~ :'! Letter to Mr. Hewitt with copy of Judge Morgan's decision and update on status of case after Judge Morgan's decision. .3. 11 :-; i~ 4-27-29 Two telephone calls to Mr. Thomas' office. Left word to call. .2 i~ !~ ::1 5-1 Receipt and review of letter from Mr. Hewitt. .2 i~ " :'1 i~i I~ 5-4 Extensive letter in reply to Mr. Hewitt's letter received on May 1, 1998. 1.0 C L 1:1 5-14 Telephone call to Mr. Thomas to determine if his clients had appealed Judge Morgan's April 13, 1998 decision. Secretary informed me that Mr. Thomas had not filed an appeal. Left word to call to determine if his client's may have changed attorneys again. .2 5-18 Receipt and review of letter from Mr. Hewitt. .2 5-21 Short conference with Thomas who informed me that his clients will not appeal Judge Morgan's decision. .3 5-21 Letter to Mr. Hewitt reporting that Mr. Thomas's clients will not appeal. .3 8/29 Extensive conference with client, review of documents, preparation of reply to other executor's petition for sanctions and removal of client as co-executor. 3.0 8/29 Telephone conference with Estate counsel's office, left word to call. .2 8/30 Telephone conference with Estate Counsel's office, left word to call. .2 EXHIBIT ltC {( ~ ~ ., ,~ ,,' "" ~ .~'"~ ~ , ':1 9/2 File reply to executor's motion to r:move. client as executor, etc. 1.0' 9/3 Returned Estate counsel's call. Telephone conference with Estate counsel's office, left word to cal1.2 , : 9/9 Telephone conference with Estate Counsel's office, left word to call. .2 9/10 Telephone conference with Estate counsel left word call. .2 9-23 Telephone call to Estate Counsel's office, left word to call. .2 'f 10-2 Receipt and review of Order of the Honorable Warren G. Morgan scheduling hearing on other executor's petition to remove client as executor. .2 !ii h' 10-3 Telephone call to Estate Counsel's office, left word to call. .2 Estate Counsel returned telephone call. Extensive telephone conference with her. She will require co-executor to retain his own counsel if he wishes to pursue removal of client as executor. .3 :~i " " 10-10 Drafting and filing of Petition to Remove Spangler as Co-Executor. 3.0. "; i~1 I~ '\! 10-29 Reading and review of letter from Mr. Spangler. .5 11-13 Receipt and review of November 13, 1998 letter of Mr. Thomas with respect to estate accounts. .2 ',; . 11-19 Receipt and Review of letter from Estate counsel. .2 12-4 Phone call to Estate Counsel, left message. .2 12-5 Extensive telephone conference with Estate Counsel. .3 12-18 Telephone calls to Mr. Hewitt Re: Humane Society concerns with sheep. .5 1999 01-21 Receipt and review of letter from Mr. Hewitt. .2 01-22 Phone call from Sue Helm. .2 01-23 Phone call to Mark Thomas, Esquire. .2 05-27 Telephone conference with Rachel Helm who called with respect to Perry County case. .2 . ~~,'-' ^ ,-;Co'" I. ~,,~" c~_ , ~,--4'O~,~" -, "b-;;,'lli""i~~"'\"'i.' -,',,,;--,, ""'~ 2000 02-03 Receipt and review of Mr. Hewitt's letter concerning erroneous information that we had place a lien against his property. .2 Letter to Mr. Hewitt with status of the estate and informing him that we had not placed any lien on his property or taken an action against him. .4 Telephone conference with Attorney Thomas requesting update on when the estate would be completed. .3 Total 16.0 Hours @ 150.00 Per Hour ___._...___._..___....__.___..______m________ $2,400.00 COSTS ADVANCED 03/99 Deeds (Dauphin County) 85.50 Total Costs Advanced 85.50 Total Costs & Outstanding Bill 2,485.50 - -.., "'" . -,,~ ...'-' ~ ,. ,- ,. .'" , < - ~" JOSEPH HEWITT ATTORNEY'S BILL FOR PROFESSIONAL SERVICES RENDERED FROM FEBRUARY 3. 2000 02-07- Telephone conference with Mark Thomas, Esquire who, informed me that 02-11 the estate was insolvent without sufficient funds to pay death taxes. .2 02-14 Letter to Mr. Thomas confirming the telephone conference wherein he informed me of the insolvency of the estate. .3 .1 :'1 ~ Letter to Mr. Hewitt informing him that Mr. Thomas had informed us that the estate was insolvent and was without funds to pay death taxes. .3 " , 03-25 Letter to Mr. Hewitt informing him that we would no longer represent him if he did not pay his outstanding bill. No Charge 1 q 03-29 Receipt and review of letter from Mr. Hewitt. .3 05-24 Letter to Mr. Hewitt with respect to his outstanding bill. No Charge I,!, 06-16 Receipt and review of letter from Mr. Thomas concerning insolvency of the estate, his opinion that the Co-Executors and heir Joyce Seibert should make up the deficit to pay the death taxes. .2 " , :~ :f I'! 07-03 Letter to Mr. Thomas in response to his letter of June 16, 2000. .3 07 -27 Receipt of Mr. Thomas' letter with respect to surcharge of the estate. .2 08-23 Telephone conference with Mr. Thomas with respect to the insolvency of the estate and the amount of the insolvency. .3 08-24 Letter to Mr. Thomas informing him of termination of our representation of Mr. Hewitt and also of the pro rata contribution that Mr. Hewitt was not responsible for. .3 08-28 Letter to Mr. Hewitt with respect to status of the estate and transfer of file should he retain additional counsel. .3 Total 2.7 Hours @ 150.00 Per Hour ___m__m_____m___...__________________ $405.00 ~ 11 EXHIBIT l Lj)JJ >" ,,_,. ~', C'_ ,~"" ,,-, - "'-'--["_..:i~"'''_ ,,_', p--..,,-' ,."~ _'-~"'._'_ ~~'". '"~O-_ I i-i 'I JOSE.PH HEWITT ATTORNEY'S BILL FOR PROFESSIONAL SERVICES RENDERED FROM FEBRUARY 3. 2000 .-] . , , Letter to Mr. Hewitt informing him that Mr. Thomas had informed us that the estate was insolvent and was without funds to pay death taxes. .3 I ,I I ,I I I ;'1 I 1 I :1 II " Ii ,j i'~ ij I ,I 'I 'I !'I Ii I' I II i'l 'I I I i I I I ! I I I .I 'i j :1 I il I, I ! 1 I ! 02-07- Telephone conference with Mark Thomas, Esquire who, informed me that 02-11 the estate was insolvent without sufficient funds to pay death taxes. .2 02-14 Letter to Mr. Thomas confirming the telephone conference wherein he informed me of the insolvency of the estate. .3 03-25 Letter to Mr. Hewitt informing him that we would no longer represent him if he did not pay his outstanding bill. No Charge 03-29 Receipt and review of letter from Mr. Hewitt. .3 05-24 Letter to Mr. Hewitt with respect to his outstanding bill. No Charge 06-16 Receipt and review of letter from Mr. Thomas concerning insolvency of the estate, his opinion that the Co-Executors and heir Joyce Seibert should make up the deficit to pay the death taxes. .2 07 -03 Letter to Mr. Thomas in response to his letter of June 16, 2000. .3 07 -27 Receipt of Mr. Thomas' letter with respect to surcharge of the estate. .2 08-23 Telephone conference with Mr. Thomas with respect to the insolvency of the estate and the amount of the insolvency. .3 08-24 Letter to Mr. Thomas informing him of termination of our representation of Mr. Hewitt and also of the pro rata contribution that Mr. Hewitt was not responsible for. .3 08-28 Letter to Mr. Hewitt with respect to status of the estate and transfer of file should he retain additional counsel. .3 Total 2.7 Hours @ 150.00 Per Hour ..._mm_m__mm..mm_____.____m $405.00 ,-.. " ' Knauer & Associates, LSC . 411A E. Main St., Mechanicsburg, PA 17055 Attorneys-a t- Law Telephone, (717) 795.7790 F;cx, (717) 795.7793 Da\'id W. Knauer JOSEPH HEWITT WOLFERSBERGER ESTATE & TUSCARORA TOWNSH/P ZONING TOTAL BILLING HISTORY 2/19/1998 Zoning Bill (see attached) 1,190.15 2/19/1998 Estate Bill (see attached) 5,482.50 3/25/2000 Estate Bill (see attached) 2,485.50 Total Zoning and Estate Bills 9,158.15 TOTAL REIMBURSEMENT/FEE HISTORY 8/11/1996 Fee for Wolfersberger Estate 200.00 8/3011996 Fee for Wolfersberger Estate 250.00 9/3/1996 Retainer for Wolfersberger Estate 2,000.00 4/7/1997 Retainer for Tuscarora Township Zoning 600.00 814/1998 Fee for Wolfersberger Estate 3,000.00 Total Zoning and Estate Reimbursement/Fees 6,050.00 TOTAL OUTSTANDING BILL 3,108.15 PA YMENT UPON RECEIPT EXHIBIT I ~tl( , ,n '<",.,.." , . ~'I Knauer & Associates, LSC 411A E. Main St., Mechanicsburg, P A 17055 Attorneys-at- Law Telephone, (717) 795.7790 Fox, (717) 795.7193 Dayid W. Knauer February 14, 2000 Mr. Joseph Hewitt 600 West Walnut Avenue Palmyra, PA 17078 RE: Estate of Bessie A. Wo/fersberger Dear Mr. Hewitt: This acknowledges receipt of your letter wherein you stated that we had placed a lien against your property. You are mistaken. We have not filed any lien or taken any adverse action against you. I did review your accounts with us and I include herewith a statement of all biils owed to us. We would appreciate payment of the balance on your bills. Last week I spoke with R. Mark Thomas, Esquire who is counsel for your co- executor James Spangler. Mr. Thomas informed me that the estate had insufficient funds to pay both the state inheritance and the federal estate taxes. I requested him to provide us with a copy of the documentation with respect to the taxes. I will await receipt of the documentation to support his statement. I enclose a copy of said letter to him. Thank you for your prompt attention in this matter. If you have any question, please do not hesitate to contact me. Very truly yours, ~~ l~-J (1Jt~ David W. Knauer DWK:wdm Enclosures \wpdocs\hewjt1i02.09.00hewi~.I:r i " EXHIBIT t<r~ , 0_ h_' ~, ~"~ Knauer & Associates, LSC 41lA E. Main St., Mechanicsburg, P A 17055 Attorneys-at-Law Telephone: (7J 7) 795-7790 Fax: (7! 7) 795-7793 David W. Knauer March 25, 2000 Mr. Joseph Hewitt 600 West Walnut Avenue Palmyra, PA 17078 RE: Estate of Bessie A. Wolfersberger Dear Mr. Hewitt: Please reference my letter of letter of February 14, 2000 in which I provided you with your outstanding bill with our firm. Since that letter, I have had no response from you and no payment of the bill. This letter is to inform you that if you do not pay the bill or reach an acceptable payment plan with us within within ten days of the date of this letter that we will be forced to file suit against you for payment of your bill. I do hope that it will be unnecessary to take that step however we will do so if the bill is not paid. Ve...ry truly yours, . , <'/[w/lt/[;$JJU David W. Knauer DWK:ahk \wpdocs\hewjn\03.25-00hev..jtt.l~r EXHIBIT I (y]w -,~ Knauer & Associates, LSC 411A E. Main St., Mechanicsburg, P A 17055 Attorneys-at-Law Telephone: (7li) 795.7790 Fax: (717) 795.7i93 Dayid W. Knauer May 24,2000 Mr. Joseph Hewitt 600 West Walnut Avenue Palmyra, PA 17078 RE: Estate of Bessie A. Wolfersberqer/Tuscarora Township ZoninG Matters Dear Mr. Hewitt: You had questioned our bills qgainst your payments, therefore, I enclose herewith a complete billing history and all previously sent bills for your account with our firm, together with a certificate of mailing. Unless you pay the entire outstanding amount of $3,108.15 by June 5, 2000, I will start suit against you to collect our fees. Upon commencement of suit, we will obtain q judgment and the Sheriff will seize and sell any of your property that they are able to seize. I do hope that it will not be necessary for us to start suit, but we must be paid for our work just as you wanted to be paid for your work. () tr~IY yours: ';j;y A ;&4,(// David W. Kn uer DWK:bm Enclosures \wpdocs\hewitt\OS-24-00hewitt./Ir EXHIBIT I~ .' .~ ' ,,~ ;-,' '. .- .,' '.J--;~" --,-',;,",.:..' ""'-"-~~''-';"'__~'''_ " ~, _"-~_ Knauer & Associates, LSC Attor~eys'at-Law 411A. East Main Street, 11echanicsburg, PA 17055 Telephone: (717) 795.7790 Fax: (717) 795-7793 EmaiI: knauer@earlv.com David \Xl. Knauer August 28, 2000 Mr. Joseph Hewitt 600 West Walnut Avenue Palmyra, P A 17078 RE: Estate of Bessie A. Wolfersberger and Knauer v. Hewitt Dear Mr. Hewitt: Please find enclosed a courtesy copy of the District Justice Complaint \\.e are filing against you for non-payment of our bill, a copy of the June 15, 2000 letter ofR.l\lark Thomas, Esquire and my letter of the above date in response thereto. With respect to his request for contribution from the executors and beneficiaries to make up a 542, 000 shortfall of funds to pay the Pennsylvania Inheritance Tax, his proposal is that each beneficiary be responsible for their pro- rata portion of the unpaid taxes based on the value of the property they inherited. He infonned me that he valued your share of the sbortfall as approximately S As to the legal position, I believe tbat you sbould not bave to make any contribution because tbe accounting infomlation was withheld from you despite our numerous requests for copies of the accounting. I must call to your attention that you should retain legal counsel for tbe conclusion of the estate. I will co-operate fully with your new counsel to transfer your files and provide be or she with any infomlation tbat may assist in responding to the requested payment. .very truly yours, David W. Knauer DWK:bm \com pany\H ewi tt \08- 28-00 h ewi t t.1 tr EXHIBIT ~t( :il i . I ., ;", " ". -'-''; ..., KNAUER & ASSOCIATES, L.S.C Plaintiff IN THE COURT OF COMMON PLEAS, CUMBERLAND COUNTY V. JOSEPH A. HEWITT Defendant No. Civil Term JURY TRIAL DAMANDED CERTIFICATE OF SERVICE I, David W. Knauer, hereby certify that 1 did this 26rd day of January, 2001, serve a true and correct copy of the within document on all counsel of record by United States mail, first class, prepaid addressed as follows: Joseph A. Hewitt 600 West Walnut Street Palmyra, PA 17078 ()a:J1J~ David W. Knad r Attorney for Plaintiff Attorney I.D. No. 21582 411-A East Main Street Mechanicsburg, PA 17055 (717) 795-7790 j' FiLED-()i=PCE Ol:n.:!: Df)fyunr.,o-rARY , ., 11..,. r r iV', ,',j '< I,: 01 JP.M 2q f'Y 3' 1:"0 n!ll .... II .;:1 V""t "E'r::e',' I"~ "r' 'NTY . . If. --/-( "i\ll) i ' V 'f. I....,,;..,.! a'. vUU PENNSYLvi\NIA i I I J 1 y;f1 -" ,.~~~~-, ~, " . .~ . I ~ ; " 6DaviJ '(1), XnouQr-, @.e. ATTORNEYS AT LAW 411 A East Main Street Mechanicsburg. PA 17055 (717} 795.7790 DAVID W. KNAUER February 19, 1998 MARK D. SCHWARn; Mr. Joseph Hewitt 600 West Walnut Avenue Palmyra, PA 17078 RE: Estate of Bessie Wolfersberger Bill for Services Rendered Date Descriotion Time Charge 08/29/96 Extensive office conference with client; reviewed 3,20 480.00 documents; prepared reply !o Co-Executor's petition for sanctions and removal of client as executor; called Estate counsel's office; left message to return call. 08/30/96 Called Esta!e counsel's office; left message to return ,20 30.00 call. 09/03/96 Filed Praecipe to Enter Appearance and reply to 1.40 210.00 motion to remove client as executor, etc.; drafted letter to Estate counsel; returned Estate counsel's call; left message to return call. 09/09/96 Called Esta!e Counsel's office; left message to return ,20 30,00 call. 09/10/96 Called Estate Counsel's office; left message to return .20 30.00 call. 09/19/96 Receipt and review of title search from The Sentinel 0.50 75,00 agency. 09/23/96 Called Estate Counsel's office; left message to return ,20 30.00 call. 11/19/96 Receipt and review 0' ~ Isel. ,20 30,00 EXHIBIT '. tlAl/ . ;; " ,~ -" -~ - I ~" . 12/04/96 Called Estate Counsel;s office; left message to return ,20 30.00 call. 12/05/96 Extensive telephone conference with Estate Counsel. .30 45,00 12/18/96 Telephone calls \0 client regarding Humane Society .50 75.00 concerns with sheep. 10/02/96 Receipt and review of Order of the Honorable Warren ,20 30,00 G. Morgan scheduling hearing on petition to remove client as executor. 10/03/96 Called Estate Counsel's office; left message to return .50 75,00 call. Extensive telephone conference with estate counsel who will require co-executor to retain his own counsel if he wishes to purwe removal of client as executor. 01/31/97 Receipt and review of letter from James Morgan, ,20 30,00 Esquire. 03/04/97 Receipt and review of letter from client .20 30,00 03/10/97 Meeting with Attorney Morgan. .30 45.00 04/07/97 Meeting with client. .50 75.00 04/23/97 Drafted leller to AHorney Morgan. ,20 30,00 04/30/97 Receipt and review of leHer from Attorney Morgan. .20 30.00 08/28/97 Receipt and review of letter from R, Mark Thomas, ,20 30.00 Esquire. 09/12/97 Drafted letter to Attorney Thomas. .20 30.00 09/29/97 Receipt and review of letter from client. ,20 30,00 10/02/97 Receipt and review of Order and Petition scheduling .30 45.00 hearing. 10/10/97 . Drafted petition to remove James Spangler as Co- 3,0 450.00 Executor. 10/15/97 Receipt and review of letter from Attorney Thomas. .20 30.00 10/20/97 Meeting with client. .50 75,00 10/21/97 Receipt and review of letter from Attorney Thomas, .20 30.00 ~ :... .~..- =~~ - . "I .. -, "~~"I~-:' 1 0/29/97 Receipt and review of letler from client. .40 60.00 12/08/97 - L~eeting with client; drafted legal memorandum on 5.0 750.00 12/09-97 behalf of client. 12/08/97 - Preparation for hearing; reviewed file; attendance at 12.0 1,800.00 12/12/97 hearings on December 10 & December 12, 1997; reviewed legal memorandum filed by Attorney Thomas. 12/17/97 Preparation for and meeting with Attorney Thomas to 1.50 225.00 narrow issues, to provide for procedure to :esolve estate issues, and to plan to conclude estate. 01/14/98 Drafted letter to Attorney Morgan confirming that his .30 45,00 bill has been paid. 01/17/98 Telepr-.one conference with A1\orney Boyanowski to 1.00 150,00 confirm that her bill had been paid; drafted letter confirming same; receipt and review of letter from P.ttorney Morgan; drafted letter to Attorney Thomas forwarding letter of Attorney Morgan. 02/12/98 Drafted letter to Attorney Thomas forwarding letter of .30 45.00 Attorney Boyanowski and confirming meeting with Executors. 02/13/98 Drafted letter to client regarding meeting of Executors. ,30 45.00 12/17/97- Numerous telephone conferences with Attorney 1.0 150.00 02/18/98 Thomas, Tot,1I Charges $5,400.00 Plus Expenses Advanced 82,50 $5,482.50 Less Retainer 2.200,00 Total Amount Due $3,282.50 "~~ l_~" ~, ~_J ~~'~""'<, ' 6DaviJ '(1), XrUIUQr-, @.e. ATTORNEYS AI LAW 411 A East Main Street Mechanicsburg, PA 17055 (717) 795-7790 DAVID W. KNAUER February 19, 1998 ; MARK D. SCHWARTZ1 Mr. Joseph Hewitt 600 West Walnut Avenue Palmyra, PA 17078 RE: Tuscarora Township Zoning Bill for Services Rendered" Date Description Time Charae 04-07 -97 Office appointnient VJith cl:ent 0,50 50.CO 04-08-97 Telephone conference wi;h Jerry A. Phiipoti, Esquire 0.30 30.00 04-23-97 Visit to Hewitt farm with Mr. George Fleisher 3,00 300.00 05-02-97 Telephone conference with !',tlorney Philpott 0,20 20.00 05-09-97 Receipt and reviev/ of 1et~er v,tiih to'Nnship crdinances 0.60 60,00 from Attorney PhilpoH 05-27-97 Drafted letter to Attorney Philpott 0,30 30.00 06-05-97 Receipt and review of letter from Attorney PhilpoH 0.20 20.00 06-13-97 Telephone call from client 0.20 20,00 06-24-97 Receipt and review of letter from Attorney PhilpoH 0,20 20.00 07-12-97 Visit to HewiH farm (Mr. Fleisher, client, and Attorney 4.00 400.00 . Knauer) 'This invoice is for work performed on or after April 7, 1997. You were previously billed for work performed from August 30, 1996, throu9h April 6, 1997, which was paid by the retainer given to us when you Mired us !o represent vou in this matter. On April 7, 1997, you provided an additional retainer of S600. EXHIBIT I ~1 () ~l , ,).~ -,,', ,~, ~ - -=~"~ ~ ,~. ~ -".... ~ - - .I ~I "'" -~'''''~'jjj~lc)_ L 07-15-97 Receipt and review of letter from Attorney Philpoll 0.20 20.00 07-23-97 Drafted Jetter to Attorney Philpott 0,20 20.00 07-30-97 Receipt and review of letter from client 0.20 20.00 08-11-97 Receipt and review of letter from client 0,20 20.00 09-12-97 Office meeting wilh client 0.50 50.00 09-19-97 Drafted letter to Altorney Philpoll 0.30 30.00 09-24-97 Receipt and review of letter from Attorney Philpott 0,20 20.00 10-08-97 Drafted leller to Attorney Philpott 0,20 20.00 W-10-97 Receipt and revie\', of Jetter and enclosures from 0,20 20.00 p.,ttorney Philpott Total Charges 51,170.00 Plus Expenses /"dvanced 20.15 51,190.15 Less Retainer 600.00 Total Amount Due S 590.15 -'~' ~'=- . I , 1lIiIfiij)'''''''~o ATTORNEY BILL AND TIME EXPENDED ESTATE OF BESSIE WOLFERSBERGER 1998 4-15 Receipt, review, and analysis of the April 13, 1998 decision of the Honorable Warren G. Morgan finding in favor of Mr, Hewitt. .2 Telephone call to Mr. Thomas's office. He was not in and left word to request a return telephone call. .1 Telephone call to Mr. Hewitt to inform him that Judge Morgan had found in his favor on the third lot. .2 4-16 Telephone conference with Mr. Thomas who inforrned me that he had not yet spoken with his clients but would inform me of their decision. .2 Letter to Mr. Hewitt with copy of Judge IV10rgan's decision and update on status of case after Judge Morgan's decision. ,3. 4-27-29 Two telephone calls to Mr. Thomas' office. Left word to call. .2 5-1 Receipt and review of letter from Mr. Hewitt. ,2 5-4 Extensive letter in reply to Mr. Hewitt's letter received on May 1, 1998. 1.0 5-14 Telephone call to Mr. Thomas \0 determine if his clients had appealed Judge Morgan's Apri113, 1998 decision. Secretary informed me that Mr. Thomas had not filed an appeal. Left word to call to determine if his client's may have changed attorneys again. ,2 5-18 Receipt and review of letter from Mr. Hewitt. .2 5-21 Short conference with Thomas who informed me that his clients will not appeal Judge Morgan's decision. .3 5-21 Letter to Mr. Hewitt reporting that Mr. Thomas's clients will not appeal. .3 8/29 Extensive conference with client, review of documents, preparation of reply to other executor's petition for sanctions and removal of client as co-executor. 3.0 8/29 Telephone conference with Estate counsel's office, left word to call. .2 8/30 Telephone conference with Estate Counsel's office, left word to call. .2 '. J! " " ~ EXHIBIT /LC {( -',-'", ~/: "" ....L ~lI-""'""'" -~ I " - 9/2 File reply to executor's motion to remove client as executor, etc. 1.0 9/3 Returned Estate counsel's call. Telephone conference with Estate counsel's office, left word to cal1.2 '" , , Ii 9/9 Telephone confereQce with Estate Counsel's office, left word to call. .2 9/10 Telephone conference with Estate counsel left word call. .2 9-23 Telephone call to Estate Counsel's office, left word to call. ,2 10-2 Receipt and review of Order of the Honorable Warren G. Morgan scheduling hearing on other executor's petition to remove client as executor. .2 10-3 Telephone call to Estate Counsel's office, left word to call. .2 Estate Counsel returned telephone call. Extensive telephone conference with her. She will require co-executor to retain his own counsel if he wishes to pursue removal of client as executor. .3 10-10 Drafting and filing of Petition to Remove Spangler as Co- Executor. 3.0. 10-29 Reading and review of letter from Mr. Spangler. .5 11-13 Receipt and review of November 13, 1998 letter of Mr. Thomas with respect to estate accounts. .2 11-19 Receipt and Review of letter from Estate counsel. .2 12-4 Phone call to Estate Counsel, left message. ,2 12-5 Extensive telephone conference with Estate Counsel. .3 12-18 Telephone calls to Mr. Hewitt Re: Humane Society concerns with sheep. .5 1999 01-21 Receipt and review of letter from Mr. Hewitt. .2 01-22 Phone call from Sue Helm. ,2 01-23 Phone call to Mark Thomas, Esquire. .2 05-27 Telephone conference with Rachel Helm who called with respect to Perry County case. .2 --- < ,~, ,..,~, .d~. ~ =. ,~=.1 ~ .'" ~w;,i: 2000 02.03 Receipt and review of Mr. Hewitt's letter concerning erroneous information that we had place a lien against his property. .2 Letter to Mr. Hewitt with status of the estate and informing him that we had not placed any lien on his property or taken an action against hirn. .4 Telephone conference with Attorney Thomas requesting update on when the estate would be completed. .3 Total 16.0 Hours @ 150.00 Per Hour ...___m'___'..___'.___...'___u'___..m___U $2,400.00 COSTS ADVANCED 03/99 Deeds (Dauphin County) 85,50 Total Costs Advanced 85.50 Total Costs & Outstanding Bill 2,485.50 .., I '" .""""~."",, ~<'~ JOS!:PH HEWITT ATTORNEY'S BILL FOR PROFESSIONAL SERVICES RENDERED FROM FEBRUARY 3. 2000 02.07- Telephone conference with Mark Thomas, Esquire who, informed me that 02-11 the estate was insolvent without sufficient funds to pay death taxes. ,2 02-14 Letter to Mr. Thomas confirming the telephone conference wherein he informed me of the insolvency of the estate. .3 Letter to Mr. Hewill informing him that Mr. Thomas had informed us that the estate was insolvent and was without funds to pay death taxes. .3 03-25 Letter to Mr. Hewill informing hirn that we would no longer represent him if he did not pay his outstanding bill. No Charge 03.29 Receipt and review of letter from Mr. Hewitt. ,3 05-24 Letter to Mr. Hewill with respect to his outstanding bill. No Charge 06-16 Receipt and review of letter from Mr. Thomas concerning insolvency of the estate, his opinion that the Co-Executors and heir Joyce Seibert should make up the deficit to pay the death taxes. .2 07-03 Letter to Mr. Thomas in response to his letter of June 16, 2000. .3 07-27 Receipt of Mr. Thomas' letter with respect to surcharge of the estate. .2 08-23 Telephone conference with Mr. Thomas with respect to the insolvency of the estate and the amount of the insolvency. .3 08-24 Letter to Mr. Thomas informing him of termination of our representation of Mr. Hewitt and also of the pro rata contribution that Mr. Hewill was not responsible for. ,3 08-28 Letter to Mr. Hewitt with respect to status of the estate and transfer of file should he retain additional counsel. .3 Total 2.7 Hours @ 150.00 Per Hour _.___m.____n._._mn__n______...__.m S405.00 EXHIBIT j LlDL( -"' , : .. _ti"'="-~ "' .~~, "' ~" ~ '""'IllI~ ' JOSEPH HEWITT ATTORNEY'S BILL FOR PROFESSIONAL SERVICES RENDERED FROM FEBRUARY 3, 2000 02.07- Telephone conference with Mark Thomas, Esquire who, informed me that 02-11 the estate was insolvent without sufficient funds to pay death taxes. .2 02-14 Letter to Mr. Thomas confirming the telephone conference wherein he informed me of the insolvency of the estate. .3 letter to Mr. Hewitt informing him that Mr. Thomas had informed us that the estate was insolvent and was without funds to pay death taxes. .3 03-25 Letter to Mr. Hewitt informing him that we would no longer represent hirn if he did not pay his outstanding bill. No Charge 03.29 Receipt and review of letter frorn Mr. Hewitt. .3 05-24 Letter to Mr. Hewitt with respect to his outstanding bill. No Charge 06-16 Receipt and review of letter from Mr. Thomas concerning insolvency of the estate, his opinion that the Co. Executors and heir Joyce Seibert should make up the deficit to pay the death taxes. .2 07-03 Letter to Mr. Thomas in response to his letter of June 16,2000. .3 07-27 Receipt of Mr. Thomas' letter with respect to surcharge of the estate. ,2 08-23 Telephone conference with Mr. Thomas with respect to the insolvency of the estate and the arnount of the insolvency. ,3 08-24 Letter to Mr. Thomas informing him of termination of our representation of Mr. Hewitt and also of the pro rata contribution that Mr. Hewitt was not responsible for. .3 08-28 Letter to Mr. Hewitt with respect to status of the estate and transfer of file should he retain additional counsel. .3 Total 2.7 Hours @ 150.00 Per Hour ..........._.............._..____.._._u.__ $405.00 ". ,",';-:'-__"'''--:'~'-;._-:",: ;"_e,.. l~ ~~"",~, ~ " Knauer & Associates, LSC 411A E. Main St., Mechanicsburg, PA 17055 Arrorneys-at-Law Te\eFhon<: <(17) 795.7790 h" (il7) 795.i793 D:wid '"J.l. Kr.:mer JOSEPH HEWITT WOLFERSBERGER ESTATE & TUSCARORA TOWNSHIP ZONING TOTAL BILLING HISTORY 2/19/1998 Zoning Biil (see ;:;tt;:;ched) 1,190.15 2/19/1998 Es\;:;te 8iil (see cH;:;ched) 5,482,50 3/25/2000 ES\cte Bill (see aH;:;ched) 2,485.50 To\al Zoning and Estate Bills 9,158.15 TOTAL REIMBURSEMENT/FEE HISTORY 8/11/1996 Fee for WolfersberGer Est;:;:e 200.00 8/30/1996 Fee for WolfersberGer Est;:;:e 250.00 9/3/1996 Re\;:;iner for Wolfersberger Es\ate 2,000.00 600.00 3,000,00 4/7/1997 Retainer for Tusc;:;rora Tm'mship Zoning 8/4/1998 Fee for Wolfersberger Es\ate Total Zoning and Estate ReimbursementiFees 6,050.00 TOTAL OUTSTANDING BILL 3,108.15 PA Y/,I,ENT UPON RECEIPT EXHIBIT I ~tl{ - ~," '. Knauer & Associates, LSC 411A E. }"iain Sr., Mechanicsburg, PA 17055 Artorne):s-ai:-Law Telephone: (ilil i95.ii90 Fa:.:: <ili) i95.j'i93 D;:yid \Y.J. K:;;;uer Februarj 14, 2000 I"/,r. Joseph Hewitt 600 West Walnut Avenue Palmyra, PA 17078 RE: Estate of Bessie A. 'IIo/fersberger Dear h'lL He'Nitt: This aCf-r,O\',I:ecces receict ci VC~T Jetter ....'heiein \'cu stated t'nEt \....e had D12ced a -- '. ) . ]:en cga~~st YOL'r prc;::erty. Yew ere r;~:;stc).\€n. '/,-,le have r;ct fj:ed any lien or 1a~€n any adverse action cQc;nst yeLl. I did review your accounts \'.'ith us and I include herewith a statement or a1l bills owed to us. We wculd appreciate payment oi the balance en your bills. Last week I spoke with R. I\!,ark Thomas, Esquire who is counsel for your co- executor James Spangler. t'/,r. Thcrnas lnfcrrred me that the estate had insufficient fL!~ds to pay both the state inheri1ar;ce c~d the 1eceral esta~e taxes. I reques!ed him to prcvice us with a copy cr the documer,t;:;ticn with respect to the taxes. I will a\'iait receipt or the coct:rr,entation to support his statement. I enclose a copy oi said Jetter to him. Thank you for your prompt alteOlian in ',his matter. If you have any ques'tion, please co not hesilate to conlacl me. / Very truly yours, 1?eu,~ l~-J ({fc) David W. Knauer DWK:wdm E:"lclC!l.:res \.....?~ocs\hew;~':O.2~ C? OC.r.e....:~.::r EXHIBIT - f I.<ffJ -- , ~ IU -"~ li.JlJ~1 Knauer & Associates, LSC 411A E. Main St., Mechanicsburg, PA 17055 Attorneys-at-Law Tf}fpho",f: (737) 795.7790 Fax: (737) 795.7793 Dc\":d \Y). ~H:er March 25, 2000 Mr. Joseph Hewitt 600 West Walnut Avenue Palmyra, PA 17078 RE: Estate of Bessie A. Wo/fersberger Dear Mr. Heviitt: Please referer.ce my letter cf 1e\tcr of Fetruarj :4, 2COO in ,,','hich I po'.'iced you ~I,'ith yeur ouis12rd:ir.g bill \'l'ith QUi i;rm. Since that letter, I have had no response from you and no payment of the bill. This letter is to inform you that if you do not pay the biil or reach an accep!able payment plan with us within within tei") days of the date of this letter that Vie will be forced to file suit against you for payment of your bill. I do hope that it wj!J be ur,recessarJ:o take that s:ep r.c',','ev,H we 'I','iil co so if the bill is net paid. Ve.r'J truly yours, i ii/I. ~ /) :' I. r;'..:n/v-Z/ , / Lf/v!{j...U J 'i~ David W. Knauer DWK:ahk '....?6cts\t-lewi~\O::..~S.tl~l'1e.....i':"l.1~r ~ ~ " 3 EXHIBIT tJ.(]u ",,'"-- ~ ~~ '" ~~ Knauer & .A.ssociates, LSC 411A E. Main St., lviechanicsburg, P A 17055 Attorneys-at-Law Tel'j>ho"", (i1i) i9;.ii90 F<:>:: OJi) i9;.ii93 D:a\'id \v. Kn::'l;tT May 24, 2000 Mr. Joseph Hewitt 600 West Walnut Avenue Palmyra, PA 17078 RE: Estate of Bessie A. Wolfersberaer/Tuscarora Township Zonina Matters Dear Mr. He'Niit: You had questioned our bills against your payments, therefore, I enclose herewith a complete bil1ing history and all previously sent bills for your account with our firm, together with a certificate of maiiing. Unless you pay the entire outstanding amount of 53,108.15 by June 5, 2000, I will start suit against you to collect ol.Jr fees. Upon commencement of suit, we wi!1 obtain a judgment and the Sheriff wiil seize and se;1 any of your property that they are able to seize. I do hope that it will not be necessary for us to start suit, but we must be paid for our work just as you wanted to be paid for your work. Uf"i truly yours: ;' <~ l / . UjJ-1 v" (fJ70..{/.l.., David W. K~a'(;er DWK:bm EnclosurES \"\'pdocs\hewjn\05.2~ .OO!"',e'r..-j:1.I:r EXHIBIT ~ I~ ',",:",-" 'T','^""~,' J. ~~~ . ~ " - " < j lJl I:L:h" ,'.-f'- Knauer & Associates, LSC Attorneys-at-Law 411A. East ?\fain Street, ?\1echanicsburg, PA 17055 TelepholOe: m7l 795.7790 Fa.~: m i) i95.i793 Em1!il: kn:::uer@e;;;rh".com Da\.jd W. Kn.uer August 28, 2000 :-'lr. Joseph Hewill 600 West Walnut Avenue Palmyra, PA l70i8 RE: Estate of Bessie A. Wolfersberger and Kmuer v, Hewin Dear :-'lr. Hewill: Please find enclosed a counesy copy of the Dislricl Justice Complainl we are filing against you for l;on.payment of our bill, a copy of the June] 5, :2000 leilcr of R. :-'1 ark Thomas, Esquire and my lener oithe above dale in response 11;erelO, With respect to his request for contribution from the exeCUlors and beneficiaries to make up a S42, 000 sbonfall of funds 10 payt)le Pennsyh'al1ia Inheritance Tax, his proposal is that each beneficiary be responsible for their pro- rata ponion of the unpaid taxes based on the value of the propeny they inllerited. He infomled me that he nJued your share of the shonfall as approximately S As to the legal position, I believe Ihat you should not llave to J113ke 3l1Y contribution because \lle accounting infon112\ion W35 withheld from you despite our numerous requests for copies of the accoullting. I must call to your anemion that you sllould retain legal counsel for tlle conclusion of the estate. I will co-operate fully with your new counsel to transfer your files and provide he or she with any infomlationthat may assist in responding 10 tl1e requested payment. 'very truly yours, David W. Knauer DWK:bm \company\H cwi It\08. 2 8. OOhewi It. 1 Ir EXHIBIT I ~ ~( . ,,:,:"c.""',-:~-' ~_~M~ .' I " , ;"':1 6DaviJ '(1), XnouQr, @.e. ATTORNEYS AT LAW 411 A Easl Main Street Mechanicsburg. PA 17055 (717) 795-7790 DAVID W. KNAUER February 19, 1998 MARK D. SCHWART2 Mr. Joseph Hewitt 600 West Walnut Avenue Palmyra, PA 17078 RE: Estate of Bessie Wo/fersberger Bill for Services Rendered Date Descriation Time Charge 08/29/96 Extensive office conference wiih client; reviewed 3.20 480,00 documents; prepared reply to Co-Executor's petition for sanctions and removal of client as executor; called Estate counsel's office; left message to return call. 08/30/96 Called Estaie counsel's office; left message to return ,20 30.00 call. 09/03/96 Filed Praecipe to Enier Appearance and reply to 1.40 210,00 motion to remove client as executor, etc.; drafted letter to Estate counsel; returned Estate counsel's call; left message to return call. 09/09/96 Called Estate Counsel's office; left message to return .20 30.00 call. 09/10/96 Called Estate Counsel's onice; left message to return ,20 30,00 call. 09/19/96 Receipt and review of title search from The Sentinel 0.50 75.00 agency. 09/23/96 Called Estate Counsel's office; left message to return .20 30.00 call. 11/19/96 Receipt and review 0 sel. .20 30,00 EXHIBIT ~ IIA" . ;;; " ,3 ....bf.(",i=. _i 12/04/96 Called Estate Counsel's office; left message to return .20 30.00 call. 12/05/96 Extensive telephone conference with Estate Counsel. ,30 45.00 12/18/96 Telephone calls to client regarding Humane Society ,50 75.00 concerns with sheep. 10/02/96 Receipt and review of Order of the Honorable Warren ,20 30.00 G. Morgan scheduling hearing on petition to remove client as executor. 10/03/96 Called Estate Counsel's office; left message to return .50 75,00 call. Extensive telephone conference with estate counsel who will require co-executor to retain his own counsel if he wishes to purwe removal of client as executor. 01/31/97 Receipt and review of letter from James Morgan, .20 30,00 Esquire, 03/04/97 Receipt and review of letter from client ,20 30.00 03/10/97 Meeting with Attorney Morgan. .30 45.00 04/07/97 Meeting with client. .50 75.00 04/23/97 Drafted letter to Atiorney Morgan. ,20 30,00 04/30/97 Receipt and review of letier from Attorney Morgan. ,20 30,00 08/28/97 Receipt and review of letter from R. Mark Thomas, ,20 30.00 Esquire. 09/12/97 Drafted letter to Attorney Thomas. .20 30,00 09/29/97 Receipt and review of letter from client. ,20 30,00 10/02/97 Receipt and review of Order and Petition scheduling .30 45.00 hearing. 10/10/97 Drafted petition to remove James Spangler as Co- 3.0 450.00 Executor. 10/15/97 Receipt and review of letter from Attorney Thomas. ,20 30.00 10/20/97 Meeting with client. .50 75.00 10/21/97 Receipt and review of letter from Attorney Thomas. ,20 30.00 ~ ~~ . ~~. 10/29/97 Receipt and review of letter from client. .40 60.00 12/08/97 - ~.1eeting with client; drafted legal memorandum on 5,0 750.00 12/09-97 behalf of client. 12/08/97 - Preparation for hearing; reviewed file; attendance at 12.0 1,800.00 12/12/97 hearings on December 10 & December 12, 1997; reviewed legal memorandum filed by Attorney Thomas. 12/17/97 Preparation for and meeting with Aitorney Thomas to 1.50 225.00 narrow issues, to provide for procedure to rEsolve estate issues, and 10 plan to conclude estate. 01/14/98 Drafted letter to Attorney Morgan confirming that his ,30 45.00 bill has been paid, 01/17/98 Telephone conference viith Attorney Boyanowski to 1.00 150.00 confirm that her bill had been paid; drafted letter confirming same; rEceipt and reviEw of letter from p.,ttorney Morgan; drafted Jetter to Attorney Thomas forwarding letter of Attorney Morgan. 02/12/98 Drafted letter to Attorney Thomas forwarding letter of .30 45.00 Attorney Boyanowski and confirming meeting with Executors. 02/13/98 Drafted letter to client regarding meeting of Executors. ,30 45,00 12/17/97- Numerous telephone conferences with Attorney 1.0 150,00 02/18/98 Thomas. Total Charges $5,400.00 Plus Expenses Advanced 82,50 $5,482.50 Less Retainer 2.200,00 Total Amount Due $3,282.50 I ~" ~.~. ~L, " -" . '-~ -JIl[Jl~lM~,.. GDovid (1), :JCHHtG?r-, g:>.e, ATTORNEYS AT LAW 41 1 A East Main Sire et Mechanicsburg, PA 17055 (717) 795-7i90 DAVID W. KNAUER February 19, 1998 MARK D. SCHWARTZ Mr. Joseph Hewitt 600 West Walnut Avenue Palmyra, PA 17078 RE: Tuscarora Township Zoning Bill for Services Rendered' Date Description Time Charae 04-07 -97 Office appointn"'lent v/iih ci:ent 0,50 50.00 04-08-97 Telephone conlerence \'d,h Jerry A. Philpot\, Esquire 0,30 30.00 04-23-97 Visit to Hewitt farm with Mr. George Fleisher 3,00 300.00 05-02-97 Telephone conference with Attorney Phi!poit 0,20 20,00 05-09-97 Receipt and fevievJ of Jet:er \,,1j~h to\'_'nship crdinances 0.60 60.00 from Attorney Philpott 05-27-97 Drafted letter to Al\orney Philpott 0,30 30.00 06-05-97 Receipt and review of letter from Attorney Philpott 0.20 20.00 06-13-97 Telephone call from client 0,20 20.00 06-24-97 Receipt and review of letter from Attorney Philpott 0.20 20.00 07-12-97 Visit to Hewitt farm (Mr. Fleisher, client, and Attorney 4.00 400.00 Knauer) 'This invoice is for work performed on or after Jl,pril 7, 1997. You were previously billed for work performed from August 30, 1996, through April 6, 1997, which was paid by the retainer given to us when you hired us to represent you in this matler. On April 7, 1997, you provided an additional retainer of S600. EXHIBIT I ~f 6 ?l ,"' l. __.,_ --"",,,.,,~'" ~- ~~ ,,; " ~,..~ 07-15-97 Receipt and review of letter from Altorney Philpoll 0.20 20.00 07-23-97 Drafted letter to Attorney Philpott 0.20 20.00 07-30-97 Receipt and review of letter from client 0.20 20.00 08-11-97 Receipt and review of le\\er from client 0,20 20.00 09-12-97 Office meeting with client 0.50 50.00 09-19-97 Drafted le\\ef to Attorney Philpott 0,30 30.00 09-24-97 Receipt and review of leiler from Attorney Philpott 0,20 20.00 10-08-97 Drafted letter to A1torney Philpott 0,20 20.00 10-10-97 Receipt and review of letter and enclosures from 0,20 20.00 p.,t1orney Philpot1 Total Charges S1,170.00 Plus Expenses Advanced 20:15 S1,190.15 Less Retainer 600.00 Total Amount Due S 590.15 ~, - ~&l ~~~"'''-<. ATTORNEY BILL AND TIME EXPENDED ESTATE OF BESSIE WOLFERSBERGER 199B 4-15 Receipt, review, and analysis of the April 13, 1998 decision of the Honorable Warren G. Morgan finding in favor of Mr. Hewitt. .2 Telephone call to Mr. Thomas's office. He was not in and left word to request a return telephone call. .1 Telephone call to Mr. Hewitt to inform him that Judge Morgan had found in his favor on the third lot. .2 4-16 Telephone conference with Mr. Thomas who informed me that he had not yet spoken with his clients but would inform me of their decision. ,2 Letter to Mr. Hewitt with copy of Judge tv10rgan's decision and update on status of case after Judge Morgan's decision. .3. 4-27-29 Two telephone calls to Mr. Thomas' office. Left word to call. ,2 5-1 Receipt and review of letter from Mr. Hewitt. .2 5-4 Extensive letter in reply to Mr. Hewitt's letter received on May 1, 1998. 1.0 5-14 Telephone call to Mr. Thomas to determine if his clients had appealed Judge Morgan's April 13, 1998 decision. Secretary informed me that Mr. Thomas had not filed an appeal. Left word to call to determine if his client's may have changed attorneys again. .2 5-18 Receipt and review of letter from Mr. Hewitt. ,2 5-21 Short conference with Thomas who informed me that his clients will not appeal Judge Morgan's decision. .3 5-21 Letter to Mr. Hewitt reporting that Mr. Thomas's clients will not appeal. .3 8/29 Extensive conference with client, review of documents, preparation of reply to other executor's petition for sanctions and removal of client as co-executor. 3.0 8/29 Telephone conference with Estate counsel's office, left word to call. .2 8/30 Telephone conference with Estate Counsel's office, left word to call. ,2 EXHIBIT b lie k J I,' ~' ~. 9/2 File reply to executor's motion to remove client as executor, etc. 1.0 9/3 Returned Estate counsel's call. Telephone conference with Estate counsel's office, left word to cal1.2 9/9 Telephone conference with Estate Counsel's office, left \vord to call. .2 9/10 Telephone conference with Estate counsel left word call. .2 9-23 Telephone call to Estate Counsel's office, left word to call. .2 10-2 Receipt and review of Order of the Honorable Warren G. Morgan scheduling hearing on other executor's petition to rernove client as executor. .2 10-3 Telephone call to Estate Counsel's office, left word to call. .2 Estate Counsel returned telephone call. Extensive telephone conference with her. She will require co-executor to retain his own counsel if he wishes to pursue removal of client as executor. ,3 . 10-10 Drafting and filing of Petition to Remove Spangler as Co-Executor. 3.0. 10-29 Reading and review of leller from Mr. Spangler. .5 11-13 Receipt and review of November 13, 1998 leller of Mr. Thomas with respect to estate accounts. .2 11-19 Receipt and Review of letter from Estate counsel. .2 12-4 Phone call to Estate Counsel, left message. .2 12-5 Extensive telephone conference with Estate Counsel. .3 12-18 Telephone calls to Mr. Hewitt Re: Humane Society concerns with sheep..5 1999 01-21 Receipt and review of letter from Mr. Hewitt. ,2 01-22 Phone call frorn Sue Helm. .2 01-23 Phone call to Mark Thomas, Esquire. .2 05-27 Telephone conference with Rachel Helm who called with respect to Perry County case. .2 -- ~"-,,~.~~ -~- I 'l~;'~ 2000 02.03 Receipt and review of Mr. Hewitt's letter concerning erroneous information that we had place a lien against his property. .2 Letler to Mr. Hewitt with status of the estate and informing hirn that we had not placed any lien on his property or taken an action against him. .4 Telephone conference with Attorney Thomas requesting update on when the estate would be completed. .3 Total 16.0 Hours @ 150.00 Per Hour ..m"m"m..___.mO.O.....muOO._____U $2,400.00 COSTS ADVANCED 03/99 Deeds (Dauphin County) 85.50 Total Costs Advanced 85.50 Total Costs & Outstanding Bill 2,485.50 '-.,.,..',...... - ","",,,,,,",",~~ . . " . ~r "~' , -"''''l':'l-''''' JOSEPH HEWITT ATTORNEY'S BILL FOR PROFESSIONAL SERVICES RENDERED FROM FEBRUARY 3. 2000 02.07- Telephone conference with Mark Thomas, Esquire who, informed me that 02-11 the estate was insolvent without sufficient funds to pay death taxes. ,2 02-14 letter to Mr. Thomas confirming the telephone conference wherein he informed me of the insolvency of the estate. .3 Letter to Mr. Hewitt informing him that Mr. Thomas had informed us that the estate was insolvent and was without funds to pay death taxes. ,3 03-25 Letter to Mr. Hewitt informing him that we would no longer represent him if he did not pay his outstanding bill. No Charge 03.29 Receipt and review of letter from Mr, Hewitt. ,3 05.24 letter to Mr. Hewitt with respect to his outstanding bill. No Charge 06-16 Receipt and review of letter from Mr. Thomas concerning insolvency of the estate, his opinion that the Co-Executors and heir Joyce Seibert should make up the deficit to pay the death taxes. .2 07-03 Letter to Mr. Thomas in response to his letter of June 16,2000. ,3 07.27 Receipt of Mr. Thomas' letter with respect to surcharge of the estate. ,2 08-23 Telephone conference with Mr. Thomas with respect to the insolvency of the estate and the amount of the insolvency, .3 08-24 letter to Mr. Thomas informing him of termination of our representation of Mr. Hewitt and also of the pro rata contribution that Mr. Hewitt was not responsible for. ,3 08.28 Letter to Mr. Hewitt with respect to status of the estate and transfer of file should he retain additional counsel. .3 Total 2.7 Hours @ 150.00 Per Hour ............__....n..._..n.......______.. $405.00 EXHIBIT j [COlf -'e--' ~,,_~"O~. - , I ~ """""=_"fI'.i~'" JOSEPH HEWITT ATTORNEY'S BILL FOR PROFESSIONAL SERVICES RENDERED FROM FEBRUARY 3. 2000 02.07 - Telephone conference with Mark Thomas, Esquire who, informed me that 02-11 the estate was insolvent without sufficient funds to pay death taxes. .2 02.14 Leiter to Mr. Thornas confirming the telephone conference wherein he informed me of the insolvency of the estate. .3 Letter to Mr. Hewitt informing him that Mr. Thomas had informed us that the estate was insolvent and was without funds to pay death taxes. .3 03.25 Letter to Mr. Hewitt informing him that we would no longer represent him if he did not pay his outstanding bill. No Charge 03-29 Receipt and review of letter frorn t,,r,r. Hewitt. ,3 05.24 Leiter to Mr. Hewitt with respect to his outstanding bill. No Charge 06-16 Receipt and review of letter from Mr. Thomas concerning insolvency of the estate, his opinion that the Co-Executors and heir Joyce Seibert should make up the deficit to pay the death taxes. .2 07.03 Letter to Mr. Thomas in response !o his letter of June 16, 2000. .3 07.27 Receipt of Mr. Thomas' letter with respect to surcharge of the estate. ,2 08-23 Telephone conference with Mr. Thomas with respect to the insolvency of the estate and the amount of the insolvency. ,3 08-24 Letter to Mr. Thomas informing him of terrnination of our representation of Mr. Hewitt and also of the pro rata contribution that Mr. Hewitt was not responsible for. .3 08-28 Letter to Mr. Hewitt with respect to status of the estate and transfer offi)e should he retain additional counsel. .3 Total 2.7 Hours @ 150.00 Per Hour _.n....._.uo.......____........_._._...__ S405.00 Knauer & l\.ssociates, LSC 411A E. Main St., Iv\echanicsburg, PA 17055 Attorneys-at-Law Telephone: (717) 795.7790 Fa" (7] 7) 795.7793 D:-l.\"id 'w, Knauer JOSEPH HEWITT WOLFERSBERGER ESTATE & TUSCARORA TOWNSHIP ZONING TOIAL.BILLlNG HISTORY 2/19/1998 Zoning Bill (see attached) 1,190.15 2/19/1998 Estate Bill (see attached) 5,482,50 3/25/2000 Estate Bill (see attached) 2,485.50 Total Zoning and Estate Bills 9,158.15 rqrAL REIMBWR~.r;jY1ENT/FEE HISTORY 8/11/1996 Fee for Wolfersberger Estate 200,00 8/30/1996 Fee for Wolfersberger Estate 250.00 9/3/1996 Retainer for Wolfersberger Estate 2,000,00 4/7/1997 Retainer for Tuscarora Township Zoning 600.00 8/4/1998 Fee for Wolfersberqer Estate - ~ 3,000.00 Total Zoning and Estate Reimbursement/Fees 6,050.00 TOTAL OUTSTANDING BILL 3,108.15 PA YMENT UPON RECEIPT Knauer & Associates, LSC 411A E. Main St., Mechanicsburg, PA 17055 Attorneys-at-Law Telephone,(7l7) 'i95.Ti90 Fax, (717) 795-7793 Da\.id 'Jl. Knaue-r February 14, 2000 rvlr, Joseph Hewitt 600 West Walnut Avenue Palrnyra, PA 1'7078 RE: Estate of Bessie A. Wo/fersberger Dear Mr, Hewitt: This acknowledges receipt of your letter wherein you stated that we had placed a lien against your property. You are mistaken, We have not filed any lien or taken any adverse action against you. I did review your accounts with us and I include herewith a statement of all bills owed to us. We would appreciate payment of the balance on your bills. Last week I spoke with R. Mark Thomas, Esquire who is counsel for your co- executor James Spangler. Mr. Thomas informed me that the estate had insufficient funds to pay both the state inheritance and the federal estate taxes. I requested him to provide us with a copy of the docurnentation with respect to the taxes. I will await receipt of the documentation to support his statement. J enclose a copy of said letter to him. Thank you for your prompt attention in this matter. If you have any question, please do not hesitate to contact me. Very truly yours, ~~,SJ( l~-J ({jT.~ David W, Knauer DWK:wdm Enclosures ~wpdocs\hewitt\02.09~OOhev/jt1,1:r Knauer & A.ssociates, LSC 41lA E. Main St., Mechanicsburg, PA 17055 Attorneys-at-Law Telephone: (717) 795.7790 Fax: (717) 795.7793 David vi. Knauer March 25, 2000 Mr. Joseph Hewitt 600 West Walnut Avenue Palmyra, P/\ 17078 RE: Estate of Bessie A. Wolfersberger Dear Mr. Hewitt: Please reference my letter of letter of February 14, 2000 in which I provided you with your outstanding bill with our firm, Since that letter, I have had no response from you and no payment of the bill. This leller is to inform you that if you do not pay the bill or reach an acceptable payrnent plan with us within within ten days of the date of this leller that we will be forced to file suit against you for payment of your bill. I do hope that it will be unnecessary to take that step however we will do so if the bill is not paid. Ve,ff truly yours, , , ,,' ;' , -. /) / ( J/ ',,' !().tf1J-l;j ,y::$VJZ/ , I David W. Knauer DWK:ahk \wpdocs\hew\tt\03-25-00hewln.\tr Knauer & Associates, LSC 411A E. Main St., Mechanicsburg, PA 17055 Attorneys-at-Law Telephone, {H7} 795.7790 Fax, (717) 795.7793 D:wld W. Kn'auer May 24, 2000 Mr. Joseph Hewitt 600 West Walnut Avenue Palmyra, PA 17078 RE: Estate of Bes$ie A. WoffersberqerlTuscarora TowI1$hip..loninq Matters Dear Mr. Hewitt: You had questioned our bills against your payrnents, therefore, I enclose herewith a complete billing history and all previously sent bills for your account with our firm, together with a certificate of mailing. Unless you pay the entire outstanding amount of $3,108.15 by June 5, 2000, I will start suit against you to coilect our fees. Upon commencement of suit, we wiil obtain a judgment and the Sheriff will seize and sell any of your property that they are able to seize, I do hope that it will not be necessary for us to start suit, but we rnust be paid for our work just as you wanted to be paid for your work. . '1) tr~IY yours, hu.;,ff j1/a{0~/ David ~11;:~ DWK:bm Enclosures \wpdocs\hewltt\OS-24-00hewlttftr ....bt.w- '" '1""'k;, Knauer & Associates, LSC Attorneys-at-Law 411A. East ~iain Street, ~fechaniC5burg, PA 17055 TeJepho,"e: (7 Ii} 795.7790 Fax: (717) 795-7793 Em?il: kn:;uer@e:nh'.com Da,'id W. Knauer August 28, 2000 ,,1r. Joseph Hewin 600 West Walnut Avenue Palmyra, PA ] iOIS RE: Estole of Bessie A. Wolfersberger and Knouer v. Hewill Dear "lr. Hewin: Pleose find enclosed a counes)' copy ofl11e District Juslice Comploll1l we ore filing ogains1 you lor l1on-poymer:1 of our bill, a copy of l)le June 15, :2000 :encr of R, "lerk Thomas, Esquire <-nd my lener 011he obove date in response t]:ereto, With respectlo his request for cOl1lribulion from tlle executors and beneficiaries to make up a S42, 000 shonfall of funds to paY1be Pe11l1sY]Y2nia Inheritance Tax, his proposal is 1hat each beneficiary be responsible for iJleir pro- rata ponion of the unpaid laxes based on lhe value oflbe propeny lhey inlleriled. He infomled me lh21 he v2lued your share ofl11e shonfall2s approximolely S As 10 lhe legal posilion, I believe lhat you should not 112ve 10 l110ke oilY cODlribution because lhe 2ccouDling informalion was wilhheld from you despile our numerous requests for copies oflhe 2ccouming. 1 must call 10 your anemion lhat you should retain legal counsel for the conclusion of the estale. I will co-operate fully "llh your new counsel 10 transfer your files and provide he or she with any infomlationlhat may assist in responding to the requested payment. ,Very lruly yours, David W. Knauer DWK:bm \company\Hewi 11\08- 28-00hewi It.! Ir EXHIBIT I ~ ~( " " , , "- 'lil'.h.": Knauer & Associates, L.S.C. IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA NO. 01-482 CIVIL TERM 19 vs. Joseph A. Hewitt RULE 1312.1. The Petition for Appointment of Arbitrators shall be substantialIy in the following form: PETITION FOR APPOINTMENT OF ARBITRATORS TO TIIE HONORABLE, TIIE JUDGES OF SAID COURT: David W. Knauer . counsel for the plaintiffldefendant in the above action (or actions), respectfully represents that: 1. The above-captioned' actio!) (or actions) is (are) at issue. 2. Theclaimoftheplaintiffintheactionis$ 3.5n.15 plll" "r.td interest and costs. The counterclaim of the defendant'in the action is The following attorneys are interested in the case(s) as counselor are otherwise disqualified to sit as arbitrators: None WHEREFORE, your petitioner prays your Honorable Court to appoint three (3) arbitrators to whom the case shall be submitted. foregoing petition, Esq., and evd/A~A(_h,,/}A a..., Li.,a..J actions) ~ prayed for. GJ;~ ORDER OF COURT ,,~ ~~inconSiderationOfthe ( Esq., ~~ , Esq., are appointed arbitrators in the above captioned action (or PJ. )" n: F\PP ~,in 1) I hI " h~__ P-:-~ ~;~ h '3 . " \ / I ,'... ..' '" i"" ""'IV ,,,U' \~':i-~~-,-';! ,',.i",:U I_AJU!'t I V ,V ,....' e,_; ",,,., " \l^ PE\\~NSY~/!-\r\ii\ .; / ~.O() PeL IJ+~ Q':It- 791 p,:..!:l I/OSLf{) I i ~ ~ j I 5 II I I 1\ 1ij . I I (") 0 c -' c "--;;1 ;;:: ".. "O'rn ." -n ~.~ ::::J 1~~ tES: N G) -'<"" !<c -0 ;-l~~ ~8 '3: 'z~ r:~ ,0. .1 )>c: -i ~ W ~ 0 -- ((] ((:.:.)',\ \'.:::!) L@ /1 r:.:..< ~---::. , -,. . ..I " "( v- . F:\FILES\DA T AFILE\MISC\els-ARB.l Created: 02/0519502:40:44 KNAUER & ASSOCIATES, 1.S.C, Plaintiff IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA v. NO. 01-482 CIVIL ACTION - LAW JOSEPH A. HEWITT, Defendant JURY TRIAL DEMANDED TO: David W. Knauer, Esquire 411-A East Main Street Mechanicsburg, P A 17055 Mr. Joseph A. Hewitt 600 West Walnut Street Palmyra, PA 17078 NOTICE OF HEARING YOU ARE HEREBY NOTIFIED that the undersigned arbitrators appointed by the Court in the above captioned matter will meet for the purpose of their appointment on Wednesday, August 8,2001 beginning at 9:00 a.m, in the Law Offices of Marts on Deardorff Williams & Otto, Ten East High Street, Carlisle, Pennsylvania, at which time and place you may appear and be heard, together with your witnesses and counsel, if you so desire. DATED: May 29,2001 ~~f Edward 1. Schorpp, Esquire - Chairman Karl Rominger, Esquire, Arbitrator Kathleen K. Shaulis, Esquire, Arbitrator U,S, POSTAL SERVICE CERTIFICATE OF MAILING MAY BE USED FOR DOMESTIC AND INTERNATIONAL MAil, DOES NOT PROVIDE FOR INSURANCE-POSTMASTER Received From: Knauer & Assoclatel I "Ill'" ~rvIrA" C'.nrpnralJon 411 AE. Main Sir... PS Form 3817. Mar, 1989 o BIJ o "0 g ;~ II :5;'1 !J ~~ ",.iIIl"~""-'l~:Il", ....\:l\~~P!f~ 0'" "..'~-"'\ .... '\1.~~' .~ ~. ~.~J"~ ~, ~ v, .tn~J~.Jl!". >>'~;~:'1#~~8~: RJ >4. ~,W' .ffitaCl~ "~c:::J ' g ~jj ~ w (;'l (;'l . m " :0 "li<'..- -" ;',;.; ,,-,- c' . I~ . '=jY::" ;~' _ '~ _; L.. _ ,I ' , ' ,', . -liIlIiiiliI' ,-- ''',j " /0, . -',' - "" ... ",I" ' ,-,c__ ,,,.' '^ _ ,,~i~ " " ".d -' ,"~' . '" "~ " . " 1 ",<< . .' - ,-; "- .,,' ""'l') . . ,.. . ~, ,.. ,- , -' I,,,~ J. " .," ,,' _ ~~"::~ .. ~dJ-~ ~~~ ~/ty?t~d aa "Q?LJ2- ~.Jt. 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" ,;/i'c/,',' .c"L;ID .i'::'~O" '<i''i''; . I .' 'i".<" '. .: ~~~:::";:: ;.J; "!.,;,, ,,;"iW","'" ''''::::,f;\2iJ!f(;;i;(~f"' <?'i:; "4 ' <'/'" '.'.. '~~~t~..:..' ~.,.fjt.[~tt:j:;~gj%)~;q't:ti~$';': Ih';"!~~ ',; :' '..,',' .(.i : .' "~ '~\i;~:!' . . .....f"'{ ....;:.~~v::. ,. ili:ci~;:~:}~:;~:I'j~ :~:'c.'01 :.,.,;:. "';"""" ".,,:,,; ";'i',-i "c,' . i .' i!l(, (tt;," " .~..... ,;; ',' ,. .' 'O:i ,;/',. m~"ilj'Ji~lU\~,: .."" ,i" .'fil;" .<: . (.1>.:-...-'./ f ;, " '," : ,j ;: " . ~~"'itj'~l1t'"" ..~~~~ . .. '. (~~OQO~ . . j! ~A; _ ..... ", .,." "'~' '.'ir;,-,,""'" ".' ,,'j...~ :. . ...' C':,;.' , "' \", "ic;':':', :,'ii. i..'"".. .... , ,",'i'" ....., > .,' .. ..' ";;ci" ..., ,. ,c"."..., , ",',"0...' ,<cc""""'(,' ",i,';;':';;' ;~~~i;:,:: , ' :;::" " '.' ". "'. . ""."' ""," .,""', .,.'._,'", .". :;::),~, .' -, , iIllIilI~..~- .",,,,..oo''''''''''''l~iilj "~-'Ii.'l!B~ -"~' ~ ( .d/lt . .~"""~..."= ~~, " .,,,,,j ~I ,I _~_ ~ "'~ "".~"," SHERIFF'S RETURN - NOT FOUND ! CASE NO: 2001-00482 P COMMONWEALTH OF PENNSYLVANIA COUNTY OF CUMBERLAND KNAUER & ASSOCIATES L S C VS HEWITT JOSEPH A R. Thomas Kline ,Sheriff or Deputy Sheriff, who being duly sworn according to law, says, that he made a diligent search and inquiry for the within named defendant, DEFENDANT HEWITT JOSEPH A but was unable to locate Him in his bailiwick. He therefore returns the COMPLAINT & NOTICE , NOT FOUND , as to the within named DEFENDANT , HEWITT JOSEPH A SPOKE WITH BETH ON 1/24/01 REQESTING ADDL FUNDS NECCESSARY TO DEPUTIZE LEBANON CO., FUNDS WERE NO'!'. RECEIVED IN OUR OFFICE, PAPER EXPIRED ON 2/23/01. Sheriff's Costs: Docketing NOT FOUND RETURN OUT OF COUNTY Surcharge 18.00 5.00 9.00 10.00 .00 42.00 ,-7 :~~ Sheriff of Cumberland County KNAUER & ASSOCIATES 02/26/2001 Sworn and subscribed to before me this ol. '1t!:: day of ~L".. ) OL{}f)1 A.D. ~(j,~ P honotary ~ , V,S, POSTAL SERVICE CERTIFICATE OF MAILING MAY BE USED FOR DOMESTIC AND INTERNATIONAL MAIL, DOES NOT PROVIDE FOR INSURANCE-POSTMASTER o ~ Received From: Knauer & AssocIatea I "llAI !ClAN."'" Cn~pnrQtIon 411 A E. Main Street " :t> PS Form 3817. Mar. 1989 r j ! ....~ I =" .~ ., , .'-,., ~,",' / ! In the Court of Common Plea. of v. ) ) ) ) ) ) \ CumberllDd County, PellUylvall.ia KNAUER & ASSOCIATES, L.S.C. 110. 01 , 482 ltx 2001 JOSEPH A. HEWITT CIVIL OATH We do lolamly near (or affirm) that ve will lupport, obey and defeDd the CODlt1tutioD of the UDited States IDd the CODSt1~t1oll of this ComI!Icm- ...". ... ""', _ will ......... ... ..,... ~ Edward L. Schorpp, Esquire - C airman --:? . ~ ............. Kar 're - Arb~ tor Kat AWARD We, the undersigned arbitrators, having been duly appointed and aworn (or :affirmed), IIl&ke the following award: (Note: If damages for delay are awarded, they shall be aeparately stated.) ?UtE R.-vb /,,) ~II9VoR ~,:- ~E ~/~~ """';:>A/b ~r....v..S"',;:=- ;;::r-~ L:>~~./UO~,/A/ 7?'.,e .A..4l:7d~7 0; ., .:S:/OG'./.s-; ;O~{/.s c::~.s7'S, , , \ applicable. ) Arbitrator, dissents. {Insert name if Date of ?~~ :7"""'- . -- . '!t~ NOTICE OF ENTRY OF AWARD Now. the ,?r~ day of 4LtglAst , 19:JaJ/. atjo:30. il..M.. the above award was entered upon the docket and notice thereof given by mail to the parties or their attorneys. Bearing: g'-$ ~ 0 / gr-f?-o/ Date of Award: Arbitrators' compensation paid upon appeal: $ /)90.00 to be tIC~-R~~ . .. PTol::J6tary . l. By: ~J~//J /JJ1Jl/Y CfJ1i . Deputy . Fllm"OfFICE OF T!"!E Ft::GT\o{GNOTARY 0\ AUG -8 AM 10::i8 CUMBERLAi'iD COUNTY PENNSYLVANIA Copy ~ ,'ve" \'0 C.q, Cdfy fYl~\l~c\ to Davl'd., W, l{nQl.\cor c- '- I_~ Copy Ma,fe&t-+e> JD'&f'p" fA). (JeW! If i II . ~ . . II ~ i I I J I ~ ~. /VL,~.0~ (;). k'~ K.~, 4. ~~ I Ii n: <I Gu...:z:; . /0.5'- or 9-- '\)~