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Home My WebLink About01-05956 ll,~ " i COYNE & COYNE, P.C., Plaintiff : IN THE COURT OF COMMON PLEAS OF : CUMBERLAND COUNTY, PENNSYLV ANlA VS. : NO. 0 I ~sqSb CIVIL TERM DANlELLE E. VAUGHN, Defendant : CIVIL ACTION--LA W NOTICE YOU HAVE BEEN SUED IN COURT. If you wish to defend against the claims set forth in the following pages, you must take action within twenty (20) days after this Notice is served, by entering a written appearance personally or by an 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 Defendant. You may lose money or property or other rights important to you. YOU SHOULD TAKE TmS 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 Lawyer Referral Service 2 Liberty Ave. Carlisle, P A 17013 (717) 240-6200 I ':~!,'l~'~, "...'_" ",,",_, ",) _ f ". '"'< 'I r,,, ",--- ""1~"' . COYNE & COYNE, P.C., Plaintiff : IN THE COURT OF COMMON PLEAS OF : CUMBERLAND COUNTY, PENNSYLVANIA vs. : NO. (')/- 5:9S"1.. CIVIL TERM DANIELLE E. VAUGHN, Defendant : CIVIL ACTION--LA W COMPLAINT AND NOW comes the Plaintiff, Coyne & Coyne, P.C., and files the within Complaint: 1. Coyne & Coyne, P,C. is a Professional Corporation, with offices located at 3901 Market Street, Camp Hill, Cumberland County, Pennsylvania 17011. 2. Danielle E. Vaughn is an adult individual residing at 280 Dogwood Drive, Hershey, Dauphin County, Pennsylvania. 3. On or about June 3, 1999, Defendant Vaughn, engaged the Plaintiff for legal services concerning various domestic relations issues to include protection from abuse, support, and divorce action and Defendant agreed to pay for services at the rate of$150.00 per hour. 4. Plaintiff performed legal services for Defendant and at the end of said representation submitted an invoice to Defendant for payment. (See Exhibit "A"). 5. Repeated demands for payment in full have been made to Defendant; however, Defendant has refused to pay same. 6. Defendant owes Plaintiff $1 ,252.31 as balance due and owing with an interest rate of 1.5% per month, annually 18%. 2 i";~'1'!j!J!I~~J , ~ ~" ,--- ' I, .. ~ " , .- . WHEREFORE, Plaintiff, Coyne & Coyne, P.C" respectfully requests Judgment in the amount of $1,252.31, together with Court costs and accruing interest from date from date of complaint filing. Respectfully submitted, COYNE & COYNE, P.C. Dated: f> 9 ()~ T II By: - L A MARIE CO 01 Market Street CampHill,PA 17011-4227 (717) 737-0464 Pa. S. Ct. No. 53788 3 '-1f'-V1~ _,nrn ,_ ,,~~ '~'-,' ',' I -, . ~ r - o .~ , " , l' LAW OFFICES OF COYNE & COYNE, PoCo 3901 Market Street Camp Hill PA 17011-4227 Invoice submitted to: Ms. Danie11e Eo Vaughn 280 Dogwood Drive Hershey PA 17033 October 8, 2001 In Reference To:Domestic Relations Invoice # 10310 Amount Interest on overdue balance $7.83 $7.83 Total amount of this bill Previous balance $1,244.48 Balance due $1,252.31 Your account is severly delinquent-- a collection action may be commenced-- Please bring your account current EXHIBIT "A" "m'~~.-- _ ','1'" ~, "-";~ ,~",~ ," ',',,, 1""1 ,-, J " , .' VERIFICATION The facts set forth in the foregoing are true and correct to the best of the undersigned's knowledge, information and belief and are verified subject to the penalties for unswom falsification to authorities under 18 Pa. C.S.A.. ~ 4904. Dated: p r (Jet" PI '!f"''''~M~l\'J_, <'''~ , ~,~, , ~.~ - 0" ro~ w_~'~ _,._ ~~'" ;.",,,",,,-,,,'- '.~~A"",'.;OI~""; ~"~""" "~","~.",,~,,-.~~,, .. ~, ' ~'"_'_~'" ,F...='''"" 'c ~""",...--, '. . " f:J (::) ~ -Gq. 0 C' ,-, .~ c ;,,"'i ~ r; ~ s:: C) ,-..! 0 -ote n "cD ~ rnrn ...... 2::0 .-~f"-l 8 8 ""7C;; ~~'3 ~ ") ..... & 05,,::::' 0"' ...... ~ 2"~ S~ ...... ~~~, -'" -.J I J Z\,) _.~ ...g ,......C1 t!? ;:5)"n "-J U f :>>c: .-1 -.J p: Z N ~ r ::t C:;) ,\,0- ~ {; ~ ~j _L~'h"""', _,~~.~~~.",~~__ "':1"<"'!!&'llli~fMj:;q'~?~--''''';;:''""",'':;;'''''\'~:l<''''!Or'''-'' '-"'IH'Oi~":~' <"(.f--;r>i.f-j''''~':if*\i;;'~__~:'W';!if-0-<i!'b";~:!:1!~f_;'Hfl1R!'ffi'fl~~~~~.:_' ~~K!_,~ " . SHERIFF'S RETURN - OUT OF COUNTY CASE NO: 2001-05956 P COMMONWEALTH OF PENNSYLVANIA: COUNTY OF CUMBERLAND COYNE & COYNE P C VS VAUGHN DANIELLE 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: VAUGHN DANIELLE E but was unable to locate Her in his bailiwick. He therefore deputized the sheriff of DAUPHIN County, Pennsylvania, to serve the within COMPLAINT & NOTICE On November 2nd, 2001 , this office was in receipt of the attached return from DAUPHIN Sheriff's Costs: Docketing Out of County Surcharge Dep Dauphin Co 18.00 9.00 10.00 30.50 .00 67.50 11/02/2001 COYNE & COYNE S~ R. Thomas Kline Sheriff of Cumberland County Sworn and subscribed to before me thi s y""E' day of ~ chol A.D. ~a.~~. Prothono~a +~""'P'Mr.fL, _ ~,"'" ."~ l~!' ~ "~~.""~"'" " ~__~_ M .., @ffitt of tlre ~4exiff William T. Tully Solicitor J. Daniel Basile Chief Deputy Mary Jane Snyder Real Estate Deputy Michael W. Rinehart AssislaDt Chief Deputy Dauphin County Harrisburg, Pennsylvania 17101 ph: (717) 255-2660 fax: (717) 255-2889 Jack Lotwick Sheriff Commonwealth of Pennsylvania COYNE & COYNE PC vs County of Dauphin VAUGHN DANIELLE E Sheriff's Return No. 3050-T - -2001 OTHER COUNTY NO. 01-5956 AND NOW:October 24, 2001 at 1: 35PM served the wi thin NOTICE & COMPLAINT upon VAUGHN DANIELLE E by personally handing to HER 1 true attested copy (ies) of the original NOTICE & COMPLAINT and making known to him/her the contents thereof at 280 DOGWOOD DR. HERSHEY, PA 17033-0000 Sworn and subscribed to So Answers, Jf~ before me this 30TH day of OCTOBER, 2001 ~l'<if). "..Jtep'lV7U l-. (+ JOAMuU I PROTHONOTARY She i 0 PD 10/24/2001 155745 By Sheriff's Costs: $30. RCPT NO KLINGER ::~~,~,;!j~." --"7^"';--"'_'_'0' ,'< 111 '_. _ ~ _" ~ I ,.,- ,- ,0. - ~. ....~" ,,-" ""' In 'the Court of Common Pleas of Cumberland County, Pennsylvania Coyne & Coyne VS. Danielle E. Vaughn ERVE: same No. 01 5956 civil Now, October 17, 2001 ,I, SHERIFF OF CUMBERLAND COUNTY, PA, do hereby deputize the Sheriff of Dauphin . County to execute this Writ, this deputation being made at the request and risk ofthe Plaintiff. "../,.;' L/-d' ~~.J<4~ Sheriff of Cumberland County, PA Mfidavit of Service Now, ,20~,at o'clock M. served the within upon at by handing to copy of the original a and made known to the contents thereof. So answers, Sheriff of County, PA Sworn and subscribed before me this _ day of , 20 COSTS SERVICE lVllLEAGE AFFIDAV1T $ .$ ,~:Il".,c"", ^ 0,'.1"'_' ',"""'C- I' ,~ "- ,- - " f1,.1 . " COYNE & COYNE, P.C., Plaintiff : IN THE COURT OF COMMON PLEAS OF : CUMBERLAND COUNTY, PENNSYL VANIA VS. : NO. 01-5956 CIVIL TERM DANIELLE E. VAUGHN, Defendant : CIVIL ACTION - LAW TO: Danielle E. Vaughn 280 Dogwood Drive Hershey, P A 17033 DATE OF NOTICE: August 22,2003 IMPORTANT NOTICE YOU ARE IN DEFAULT BECAUSE YOU HAVE FAILED TO ENTER A WRITTEN APPEARANCE PERSONALLY OR BY ATTORNEY AND FILE IN WRITING WTIH THE COURT YOUR DEFENSES OR OBJECTIONS TO THE CLAlMS SET FORTH AGAINST YOU. UNLESS YOU ACT WITHIN TEN (10) DAYS FROM THE DATE OF THIS NOTICE, A JUDGMENT MAY BE ENTERED AGAINST YOU WTIHOUT A HEARlNG AND YOU MAY LOSE YOUR PROPERTY OR OTHER IMPORTANT RIGHTS. YOU SHOULD TAKE THIS NOTICE TO A LAWYER AT ONCE. IF YOU DO NOT HAVE A LAWYER OR CANNOT AFFORD ONE, GO TO OR TELEPHONE THE FOLLOWING OFFICE TO FIND OUT WHERE YOU CAN GET LEGAL HELP, Cumberland County Lawyer Referral System Cumberland County Bar Association 32 S. Bedford Street Carlisle, P A 17013-3302 1-800-990-9108 Date: August 22, 2003 COYNE & COYNE, P.C. ,Yl' S MARIE COYNE, I Market Street Camp Hill, PA 17011-4227 (717) 737-0464 Pa. S. Ct. No. 53788 Plaintiff -'1?:m~:t:l'] . ''''';~o'''.'"-' ',,, _~. ,_" ,_~~~'""_" .'_~' I -t ,_..,. . ' COYNE & COYNE, P.c., Plaintiff : IN THE COURT OF COMMON PLEAS OF : CUMBERLAND COUNTY, PENNSYLVANIA VS. : NO. 01-5956 CIVIL TERM DANIELLE E. VAUGHN, Defendant : CIVIL ACTION - LAW CERTIFICATE OF SERVICE I, Lisa Marie Coyne, Esquire, hereby certify that a true copy of Plaintiff s Ten Day Notice of Default was served upon the below-referenced individual by sending the same by first class mail, postage prepaid, addressed as follows: Ms. Danielle E. Vaughn 280 Dogwood Drive lIershey,Pi\ 17033 Dated: (j k .t./ rJ$ { I 'f~ilI)~__" "I'"',> '>"T,_ ,,),t' _,,,,". ~_~~_" __ 1'""',,','~__ ',-,-' -I -r<. ,_ J ~~!;3_~ . ~_liIlIiJ1Il-.\'ll_ "",,11, lJlJ1!m, - .~,,- -..-<<.,-",~~~"~~~> ~.- (~\\ 1 a C) 0 c w -n <" """ -~ -or>:; c= III [11 nl G:J C:"1= L:Xl , zt;:- N --~If-n '''9 ~~~ 0; .~ ~~~:: '~C) """ ...---rl :3: ,::>:n ~(-~ -~o J> ,~~~ '2 ;'S::;.rn ~- ."" 2; '-1 :=> ~ -< (,.) -< ~~!t1I!'i?!1il'm'v."'"'-,"~f)":~,f',;n\'_"'~K""~~I%:~~!f~~~~~~~~_,\J~~~:,'-