HomeMy WebLinkAbout99-00012
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not puy PllIintlITtho $245,00 due lInd ow'ng fllr tho propllrlltlon lInd filing of the bunkruptllY
pelltlon,
7, In June ~)f 1998 Defendllnts hired Plaintifl'to complete cortain extra work in
connection with their bankruptcy proceeding, Defendwlts had fidled to list three creditors Oil the
list of creditors that thcy providcd to Plllintm: so PluintilThad to amend the bankruptcy, with
notice to these creditors, in order for the bankruptcy discharge to affect them.
8, Plaintlfflimely completed this work in June of 1998, Plaintiff paid a $20,00 tiling
fee to bankruptcy court in order to file these amendments, and the attorney's fee for preparing
these amendments was $40.00, This fee is fUr less than Plaintiff's customary and reasonable rate
01'$100,00 an hour, in that it took Plainlifffar longer then four-tenths of one hour to prepare
these documents.
9, PlaintilT, at Defendants' request, IlIter perfonned more extra work for Defendants
in connection with their bankruptcy, Plaintiff, for no additional consideration, prepares or reviews
reaffinnation agreements to be signed by debtors and secured creditors. Plaintiff reviewed such
an agreement between Defendants and Mazda Credit,
10, However, after defendants signed the reaffirmation agreement with Mazda, they
fell behind in their payments to said creditor, Following disd18rge, Mazda repossessed the
collateral, and debtors no longer wanted to continue making payments on a truck loan when the
truck had been repossessed,
11, Plaintiff, facing a short deadline to rescind the reaffirmation agreement sent a letter
on August 13, 199R to Maz.da Americllll Credit by Federal Express two-day delivery, Plaintiff
incun-ed II mailing charge of $1 0,75 for this delivery, and he earned additional attorney's fees of
$50,00 for 0.5 hours of work at $100.00 an hour,
~
.
STL\I'IIEN B. LIPSON,
1'laintilT
: IN TilE COURT OF COMMON PLEAS
: CUMBERLAND COUNTY, PENNSYLVANIA
v,
: CIVIL ACTION - LAW
LARRY A. KAUFFMAN,
alld
: NO. 99-12 CIVil. T1iRM
SANDRA j, KAUFFMAN,
Defendants
Ir~rfi1-) rTl)\\/1
~:::7 \-:::./ 11 11
To: Sandra j, Kauflinan, Defendant
Date of Notice: Fcbruary 5, 1999
IMPORTANT NOTICE
YOU ARE IN DEFAULT BECAUSE YOU HAVE FAILED TO ENTER A WRITTEN
APPEARANCE PERSONALLY OR BY ATTORNEY AND FILE IN WRITING Wl'lll TIlE
COURT YOUR DEFENSES OR OBJECTIONS TO THE CLAIMS SET FORTH AGAINST
YOU, UNLESS YOU ACT WITHIN TEN DA YS FROM TIlE DATE OF THIS NOTICE, A
JUDGMENT MAYBE ENTERED AGAINST YOU WITHOUT A HEARING AND YOU
MA Y LOSE YOUR PROPERTY OR OTIIER IMPORTANT RIGHTS, YOU SHOULD TAKE
HilS NOTICE TO A LAWYER AT ONCE, IF YOU DO NOT HAVE ALA WYER OR
CANNOT AFFORD ONE. GO TO OR TELEI'IIONE TIlE FOLLOWING OFFICE TO FIND
OUT WHERE YOU CAN GET LEGAL HELP:
CUlI1berland County Bur Association
2 Liberty A venuc
Carlisle,PA 17013
Phone: (717) 249-3166
-'
/7/i;-2_- d' 5:""0.---'
. StePhen it Lips~~, 'Plai~til1'
50 I S, Hllnover Street
Cllrlisle, PA 170/3
(717) 249-3929
. u.,. f101TAL ....vle.
CERTIFICATE OF MAILINO
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J.Q1 S. Hanover Sm!!..L___
.ill:.l1s1e. PA 17013
an.,.. of DIIM'''lrv",,1I llddrtll(llCl to'
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Sandra J. Kauffma. lAO ~: -f':o
159 Cedar Lane s::(.:.,j,.., lAm -i~~~d~
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Car 11 s 1 e, p. '" ' , ) Rl !" 111
MAV II UlIO 110.. DOMIJTlC AND INTlfilN t ~,"'A.I" ~
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