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Home My WebLink About01-03369 II vs. : IN THE COURT OF COMMON PLEAS OF : CUMBERLAND COUNTY, PENNSYLVANIA : OJ.. 33(,,<} : NO: CIVIL TERM SNELBAKER, BRENNEMAN & SPARE, P.C., Plaintiff, VICKI E. KEELEY, : CIVIL ACTION - LAW Defendant. NOTICE You have been sued in court. If you wish to defend against the claims set forth in the following pages, you must talce 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 a 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. Cwnberland County Bar Association 2 Liberty Avenue Carlisle, PA 17013 (717) 249-3166 SNELBAKER, BRENNEMAN & SPARE, P.C. ,/[!r;",n---- By Attorneys for Plaintiff LAW OFFICES SNELBAKE:R, BRENNEMAN & SPARE - LAW OFFICES S N ELBAKER, BRENNEMAN & SPARE '~. II SNELBAKER, BRENNEMAN & SPARE, P.C., Plaintiff, : IN THE COURT OF COMMON PLEAS OF : CUMBERLAND COUNTY, PENNSYLVANIA OJ. .'33(.,9 : NO: CIVIL TERM vs. VICKI E. KEELEY, : CIVIL ACTION - LAW Defendant. COMPLAINT AND NOW, comes the Plaintiff, Snelbaker, Brenneman & Spare, P.C. and avers the following cause of action: 1. Plaintiff, Snelbaker, Brenneman & Spare, P.C. is a professional corporation under the laws of the Commonwealth of Pennsylvania with an address of 44 West Main Street, Mechanicsburg, Cumberland County, Pennsylvania. Snelbaker, Brenneman & Spare, P.C. was operating under the name of Snelbaker and Brenneman, P.C. until in or about December 1996. 2. Defendant, Vicki E. Keeley is an adult individual with a business address of 2290 South Molly Pitcher Highway, Chambersburg, Franklin County, Pennsylvania 17201. 3. In or about April 1995 Defendant engaged Snelbaker and Brenneman, P.C. at a rate of $90.00 per hour to represent her interests regarding collection of child support. 4. Snelbaker and Brenneman, P.C. and Snelbaker, Brenneman & Spare, P.C. provided legal services to Defendant in the child support case docketed to No: 157 of 1978 in the Court of Common Pleas of Cumberland County, Pennsylvania Domestic Relations Section and an appeal to the Superior Court of Pennsylvania . ","~"x. - . LAW OFFICES SNELBAKER, BRENNEMAN & SPARE from in or about April 1995 through in or about May 1997 (hereinafter "Child Support Suit"). 5. Throughout the time period set forth in Paragraph 4 hereinabove, Plaintiff diligently devoted itself to representation of Defendant's interest. 6. On or about June 30, 1997, Snelbaker, Brenneman & Spare, P.C. prepared an invoice, a true and correct copy of which is attached hereto as Exhibit "A" and incorporated herein by reference, for legal services rendered on Defendant's behalf. The total amount due to Plaintifffrom Defendant as of June 30, 1997 was $3,864.39 which included costs advanced by Plaintiff. The invoice dated June 30, 1997 was mailed to Defendant on that date. 7. Defendant made a $100.00 payment to Plaintiff on account on or about June 24, 1997. Along with said $100.00 payment, Defendant thanked the individual attorney responsible for her case for everything, promised to get her account paid as soon as possible, apologized for the delay and acknowledged the hard work that Plaintiff put into representing her interests in the case. 8. Defendant is justly indebted to Plaintiff in the sum of $3,764.39. 9. The charges for services provided to Defendant were fair, reasonable and customary and were never objected to by Defendant. 10. Despite several demands for payment by Plaintiff to Defendant, Defendant has refused and/or failed to pay the amount due and owing. -2- LAW OFFICES SNELBAKER. BRENNEMAN & SPARE 11 WHEREFORE, Plaintiff demands judgment in its favor and against Defendant in the amount of $3,764.39 together with interest due and costs. I i I, 1.'1' Date: May 3\ II i:1 p i I I SNELBAlR, BRENNEMAN & SPARE, P.C. By if I), Keith O. Brenneman, Esquire 44 West Main Street P.O. Box 318 Mechanicsburg, P A 17055-0318 (717) 697-8528 ,2001 -3- - SNELBAKER, BRENNEMAN & SPARE, P. C. Attorneys at Law P. O. Box 318 44 West Main street Mechanicsburg, PA 17055 (717) 697-8528 June 30, 1997 Vicki E. Keeley 2290 South Molly Pitcher Highway Chambersburg, PA 17201 FOR PROFESSIONAL SERVICES RENDERED Re: Child Support Appeal to Superior Court January 27, 1996 to date Letter to client (2/19/96) Telephone conference w/client (2/20/96) Prepare Notice of Appeal, Order For Transcript (2/20/96) Obtain certified copies of docket (2/21/96) File and serve Notice of Appeal (2/21/96) Draft Docketing Statement for Superior Court (3/4/96) Letter to Prothonotary, Superior Court (3/7/96) Letter to client (3/14/96) Obtain copy of Hearing Transcripts (3/29/96) Prepare Reproduced Record (4/25/96) Draft Brief (5/1/96) Draft Brief (5/9/96) Draft Brief (5/10/96) Prepare Reproduced Record (5/13/96) Review and revise Brief (5/14/96) File and serve Brief (5/14/96) Letter to client (6/11/96) Telephone conference w/Superior Court Prothonotary (8/7/96) Letter to client (8/7/96) Telephone conference w/Superior Court Prothonotary (11/12/96) Letter to Superior.Court Prothonotary (12/3/96) EXHIBIT A -~ -~-- '" - ~,," .r I ~ Vicki E. Keeley June 30, 1997 Page Two Letter to client (12/3/96) Telephone conference w/client (12/31/96) Telephone conference w/Atty. Buckley (12/31/96) Telephone conference w/superior Court Prothonotary (12/31/96) prepare for oral argument (1/6/97) Prepare for oral argument (1/7/97) Oral argument before Pa. Superior Court (1/7/97) Telephone conference w/client (1/7/97) Letter to client (5/23/97) Professional fee: 21.9 hours at $90.00 per hour: $1,971.00 Plus Costs Advanced: Filing fee - Domestic Relations (2/21/96) Filing fee - Superior Court (2/21/96) Hearing Transcripts (3/29/96) Copies of Reproduced Record (4/30/96) $ 35.00 55.00 175.15 110.24 Total Costs Advanced: 375.39 Plus remaining balance of invoice dated 3/15/96: Total Balance Due: 1. 518.00 $3,864.39 EXHIBIT A "~~- ...",....... ',-'__0'1 , ~ , T' ,~ , LAW OFFICES SNELBAKER. BRENNEMAN 8: SPARE 11 CORPORATE VERIFICATION I, Philip H. Spare, Esquire, state that I am a member and secretary of the law firm of Snelbaker, Brenneman & Spare, P.C., the Plaintiff herein, that I am authorized to make this affidavit on its behalf and that the facts set forth in the foregoing Complaint are true upon my personal knowledge, information and belief. I understand that my statements are made subject to the 18 Pa. Cons. Stat. Ann. 9 4904 providing for criminal penalties for unsworn falsification to authorities. "b)~ 0 hilip . Spare:Esquire Date: May 3f, 2001 ;t;j ~ ~ ~~ ... '< !:; ~ ~ ~,p".". ~,. ..P,.. ,. - -, ,."'~{~'",~- - ,-"-"",,,,- "''M ~, ~. ""''-'-> .. ~. ".fr(;rt~.tt.'II' (") c::> f; 0 .., -tf " a5 c.... !l2rT; c::: :--~1 i]'J 2:F ;;c: (',rj~. I ---d71 ~b :~..'i? ." ~;;:-Ci ~8 T"'. :3:: ii?q ~ t;-? orn \0 ;g ~ :;0 -< ~ }\ "' ~ ~ ~ .. v ~ <> .Cl- c ~ t ~ _, ,~"_ _,_~ .'~ _, ,_" _" _" " R(,liilr-YI1iRIlIJ - __""".'",._ ,_~ -'_'r-"~m;= '~<, ,":-T,' ~"""<,,,~~~-~~:""!~"'9''f-'-''iW;llj>;;,'fj_~~~j__Jf~ o,;_.-,!,'~~ . . SHERIFF'S RETURN - OUT OF COUNTY . CASE NO: 2001-03369 P COMMONWEALTH OF PENNSYLVANIA: COUNTY OF CUMBERLAND SNELBAKER BRENNEMAN & SPARE PC VS KEELEY VICKI E R. Thomas Kline , Sheriff or Deputy Sheriff who being duly sworn according to law, says, that he made a diligent search and and inquiry for the within named DEFENDANT , to wit: KELLEY VICKI E but was unable to locate Her in his bailiwick. He therefore deputized the sheriff of FRANKLIN County, Pennsylvania, to serve the within COMPLAINT & NOTICE On June. 28th , 2001 , this office was in receipt of the attached return from FRANKLIN Sheriff's Costs: Docketing Out of County Surcharge Dep. Franklin Co 18.00 9.00 10.00 22.00 .00 59.00 06/28/2001 SNELBAKER, S~ /---;7 . ~ _ c.-- R. homas Kline Sheriff of Cumberland County BRENNEMAN & SPARE Sworn and subscribed to before me ~. this 11;4 day of --.J INLy ~(rV( JA. . . 'i" ... 'V', ! SHERIFF'S RETURN - REGULAR . -. CASE NO: 2001-00069 T COMMONWEALTH OF PENNSYLVANIA: COUNTY OF FRANKLIN SNELBAKER BRENNEMAN & SPARE VS VICKI E KEELEY LAURIE ETTER - DEPUTY , Deputy Sheriff of FRANKLIN County, Pennsylvania, who being duly sworn according to law, says, the within COMPLAINT was served upon KEELEY VICKI E the DEFENDANT , at 1626:00 Hour, on the 14th day of June , 2001 at FRANKLIN CO SHERIFF'S OFFICE 157 LINCOLN WAY EAST CHAMBERS BURG , PA 17201 by handing to VICKI KEEL I a true and attested copy of COMPLAINT together with and at the same time directing Her attention to the contents thereof. Sheriff's Costs: Docketing Service Aff idavi t Surcharge So Answers: 9.00 9.00 4.00 .00 .00 22.00 LAURIE ETTER - DEPUTY By 'f)QJJJUL ~ Deputy Sheriff 06/18/2001 CUMBERLAND COUNTY SHERIFF Sworn and Subscribed to before day of JLlIlt. A.D. Notanal Seal Patricia A. Strine. Notary Public Chambersburg 130ro, Franklin County My Commission Expires Nov. 4, 2004 .~-,..,. '".""- T"~ - -j " ~'"~ .. , LAW OFFICES SNELBAKER. BRENNEMAN & SPARE !1 SNELBAKER, BRENNEMAN & SPARE, P. c., : IN THE COURT OF COMMON PLEAS OF : FRANKLIN COUNTY, PENNSYLVANIA Plaintiff v. : NO. 2001-3369 CIVIL TERM VICKI E. KEELEY, now VICKI E. PETERS, : CIVIL ACTION - LAW Defendant PRAECIPE FOR mDGMENT UPON DEF AUL T PURSUANT TO Pa.R.C.P. 1037(b) TO THE PROTHONOTARY: Please enter judgment against Vicki E. Keely, now known as Vicki E. Peters and in favor of Plaintiff Snelbaker, Brenneman & Spare, P. C. in the amount of $3,764.39 together with interest and costs of this action due to Defendant's failure to file within the required time a pleading to the Complaint in this action. A certified copy of the Complaint containing a notice to defend was served upon the Defendant on June 14,2001. I hereby certify that written notice of intention to file this Praecipe was mailed to the Defendant (the party against whom judgment is to be entered) for failure to plead to the Complaint at least ten days prior to the date of the filing of this Praecipe. A copy of the written notice mailed to the Defendant on July 9, 200 I is attached hereto and incorporated by reference herein as "Exhibit A". SNELBAKER, BRENNEMAN & SPARE, P. C. Date: August 3, 2001 BY:_~ _ Keith o. Brenneman, Esquire 44 W. Main Street Mechanicsburg, P A 17055 (717) 697-8528 Attorneys for Plaintiff "' - ~--<I " .. , LAW OFFICES SNEL8AKER, BRENNEMAN & SPARE ;m , .'" "'.,._., II 'I SNELBAKER, BRENNEMAN & SPARE, P. C., : IN THE COURT OF COMMON PLEAS OF : FRANKLIN COUNTY, PENNSYLVANIA Plaintiff v. : NO. 2001- 3369 CIVIL TERM VICKI E. KEELEY, now VICKI E. PETERS, : CIVIL ACTION - LAW Defendant TO: Vicki E. Keely, now Vicki E. Peters, Defendant Date of Notice: July 9, 2001 IMPORTANT NOTICE YOU ARE IN DEF AUL T BECAUSE YOU HAVE F AILED TO ENTER A WRITTEN APPEARANCE PERSONALLY OR BY ATTORNEY AND FILE IN WRITING WITH THE COURT YOUR DEFENSES OR OBJECTIONS TO THE CLAIMS SET FORTH AGAINST YOU. UNLESS YOU ACT WITHIN TEN DAYS FROM THE DATE OF THIS NOTICE, A JUDGMENT MAY BE ENTERED AGAINST YOU WITHOUT A HEARING AND YOU MAY LOSE YOUR PROPERTY OR OTHER IMPORTANT RIGHTS. YOU SHOULD TAKE THIS NOTICE TO A LAWYER AT ONCE. IF YOU DO NOT HAVE A LAWYER OR CANNOT AFFORD ONE, GO TO OR TELEPHONE THE FOLLOWING OFFICE TO FIND OUT WHERE YOU CAN GET LEGAL HELP: Pennsylvania Lawyer Referral Service Pennsylvania Bar Association 100 South Street P. O. Box 186 Harrisburg,PA 17108 (800) 692-7375 SNELBAKER, BRENNEMAN & SPARE,P. C. By:_ki(~lf 1 t/Z4 - Keith O. Brenneman, Esquire 44 W. Main Street Mechanicsburg, P A 17055 (717) 697-8528 Attorneys for Plaintiff EXHIBIT A f'^ "-,,. .-.~,.~ -;-' _ ~'i". " , , """ ,~- . . LAW OFFICES SNELBAKER. BRENNEMAN & SPARE .~ > '".""" '1," II I CERTIFICATE OF SERVICE I, KEITH O. BRENNEMAN, ESQUIRE, hereby certify that I have on the below date, caused a true and correct copy of the foregoing Important Notice to be served upon the person and in the manner indicated below: FIRST CLASS MAIL. POSTAGE PREPAID, ADDRESSED AS FOLLOWS: Vicki E. Peters, formerly Vicki E. Keeley 2290 Molly Pitcher Highway Chambersburg, P A 1720 I -~ Keith O. Brenneman, Esquire SNELBAKER, BRENNEMAN & SPARE, P. C. 44 W. Main Street P. O. Box 318 Mechanicsburg, PA 17055 (717) 697-8528 Attorneys for Plaintiff Date: July 9, 2001 ,'~' , ~. ,., _-~ h. -,' I' , . LAW OFFICES SNEL8AKER. BRENNEMAN & SPA'RE CERTIFICATE OF SERVICE I, KEITH o. BRENNEMAN, ESQUIRE, hereby certify that I have on the below date, caused a true and correct copy of the foregoing Praecipe to be served upon the person and in the manner indicated below: FIRST CLASS MAIL, POSTAGE PREPAID, ADDRESSED AS FOLLOWS: Vicki E. Peters, formerly Vicki E. Keeley 2290 Molly Pitcher Highway Chambersburg, P A 17201 Keith O. Brenneman, Esquire SNELBAKER, BRENNEMAN & SPARE, P. C. 44 W. Main Street P. O. Box 318 Mechanicsburg, P A 17055 (717) 697-8528 Attorneys for Plaintiff Date: August 3, 2001 '0".',. , ~ I,! , :1 [-j 'I r~ ll:: _,>;>,,~,4~,,~,_ ~ -, =,- .~ -~ ,- ~ -, - -~- ~.r"" __n~ 0 C:J ~ ~ (:) S;; -(Q ~--. ,.,. -vc:;- r- - " ~ ...0 rnrT"\ (;-i 2::"1; I ----l'T'\ , ZC- ' ',', 8 (/J J;:; 0' ,.iX. '- ~cj ..,....-1 F c;; ~:~. ~~:B - -i>r. ....1<,.. ~ ~ 60 <-M ~ Cf! 0 )>c ....., ~ -7 3:i ......... 6' =:l C> -< (fl :< ~ - K ~ &t-J ~.,h' .2 1;-V -V) ~! it gff .~ ~ c -ct G F'- - ~ ...J - " _ ~._.~- "=r--~",Ifl!~,_- ,~__" "-7_~'" _'_' _ _M~1'~",!''';w,j!"$:li:!d~Wjii!l~~~~~\lIf~~''R",~,_"",~~U~L,~~ .' - I