HomeMy WebLinkAbout99-01885
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HENRY F. COYNE
^ltorncys. al Law
390 1 Morkct Slreet
OunI'HiII.l'^ 17011.4227
(717) 7:l7.n464
LISA MARIE COYNE
June 2, 1994
Re:
Domestio
D ~ [g D\Yl~1 ~
~I J.N i1994 Ii!:
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Mrs, Maria Peffer
413 Pi t t Street
Snola, PA 17025
Dear Mrs. Peffer:
This letter will confirm our recent discussion in which
I agreed, at your request, to represent you in the above
captioned matter.
As I explained to you, because of the nature of the
matter, and because of the possibility of the occurrence of
unpredict~ble and unforeseen circumstances, I am not in d
position to quote you a final and specific fee for my
professional services. This is particularly true in a
situation such as yours, which is essentially adversary in
nature. Even though it appears that this may be an
unoontested divoroe, we must prepare for equitable
distribution of marital property plus other possible issues.
I have agreed to accept a retainer in the amount of
Five Hundred Dollars ($500.00) which is not refundable.
I will maintain time records which you may periodically
review upon your request. It should be understood that
during the course of representation, my time will be kept at
the rate of One Hundred Twenty-five Dollars <$125.00) per
hour, with minimum charges of 15 minutes for telephone
conversations, correspondence or work performed on your
behalf.
If time charges exceed the amount of the non-refundable
retainer, you will receive additional bills.
Legal costs and expenses incurred are the obligation of
and are to be paid by the client upon billing of same.
It is impossible to predict a course that a domestic
dispute and case will take. Sometimes it branches out into
property questions and various forms of litigation.
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VERDlCA1TON
The facts set forth in the foregoing are true and correclto the best of the undenligned's
knowledge. infonnation and belief and are verified subject to the penalties for unswom
falsification to authorities under 18 Pa. C.S.A. ~4904.
Dated: -:;:d ~ / 'I r
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SHERIFF'S RETURN - REGULAR
CASE NO: 1999-01885 P
COMMONWEALTH OF PENNSYLVANIA:
COUNTY OF CUMBERLAND
COYNE HENRY F ET AL
VS.
PEFFER MARIA C
CPL. MICHAEL BARRICK , Sheriff or Deputy Sheriff of
CUMBERLAND County, Pennsylvania, who being duly sworn according
to law, says, the within NOTICE AND COMPLAINT IN was served
upon PEFFER MARIA C the
defendant, at 13:43 HOURS, on the 5th day of April
1999 at 413 PITT ST
ENOLA, PA 17025 ,CUMBERLAND
County, Pennsylvania, by handing to MARIA C. PEFFER
a true and attested copy of the NOTICE AND COMPLAINT IN
together with ASSUMPSIT
and at the same time directing Her attention to the contents thereof.
Sheriff's Costs:
Docketing
Service
Affidavit
Surcharge
18.00
9.92
.00
8.00
$3~. ~~
So answe~.:.; /. ~,/ /-?
?"""~~A!. /~c
K. lhomas K11ne, ~her1fI
"'",Y F. CO"" ~
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Sworn and sUbscribe~before me
this j.,{/L day of 1'1 {
19 A.D.
CERTIFICATE OF SERVICE
I, Lisa Maric Coyne, Esquire, hereby certify that truc copy of Plaintiffs Important Noticc
Pursuant to Pa. R.C.P. 237.1(a)(2) was this date scrvcd upon the below-refercnccd individuals by
first class U.S. Mail, postage prcpaid at the below referenced address:
Mrs. Maria C. Peffer
413 Pitt Street
Enola, P A 17025
Datcd: 2i ~ 9'\
A MARIE CO E, Esquire
YNE & COYN ,P.C.
90 I Markct Strcet
Camp Hill, PA 17011-4227
(717) 737-0464
Pa. S. Ct. No. 53788
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CF.RTIFICATF. OF SF.RVICF.
I, Lisa Marie Coyne, Esquire, hereby certify that true eopy of Petition for Entry of Judgment of
Default was served this date upon the below-rcrcrenced individual hy at the hclow listed addres< by way
of First class mail, postage prepaid:
Ms. Marie C. Peffer
413 Pill Street
Enola, P A 17025
Dated: /C, rc/r/ '1 1
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>>,fi~~cY
isa Marie Coyne, Esq e
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