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HomeMy WebLinkAbout03-3125COMMONWEALTH OF PENNSYLVANIA COURT OF COMMON PLEAS JUDICIAL DISTRICT NOTICE OF APPEAL FROM DISTRICT JUSTICE JUDGMENT COMMON PLEAS Na n3 -- 3' ar C,1-61 NOTICE OF APPEAL T I? a' qJ* Notice is given that the appellant has filed in the above Court of Common Pleas on appeal from the judgment Tendered by the District Justice on the date and in the case mentioned below. NAME OF AML ANT MAG. DST. No OR NAME OF DA ADDRESS OF APPELLANT CITY STATE ZIP CODE 10 7 3 9 f? u cF?4r?q + T? Al a? FA.S 4- 4?rYtJZ7SJ>3 rO 17 Z6 $ DATE OF JUDGMENT I N THE CASE OF (Pleinf ) (Ce/enaa'Rl /? _ pj rnAn-T SR Gosinn?-i•r Jr 44-Soc- vs 2VEnS rr L-inti O.AIM SIGNATURE OF APPELLANT OR HIS ATTORNEY tM AGENT CV TJboofoo-a3 LT This block will be signed ONLY when this notation is required under Pa. R.CPJP. No. If appellant was CLAIMANT (see Pa. R.C.P.J.P. No. 1008& This Notice of Appeal, when received by the District Justice, will operate as a 1001(6) in action before District Justice, he MUST SUPERSEDEAS to the judgment for possession in this case FILE A COMPLAINT within twenty (20) days after Signature of Prothonotary or Deputy filing his NOTICE of APPEAL. PRAECIPE TO ENTER RULE TO FILE COMPLAINT AND RULE TO FILE (This section of form to be used ONLY when appellant was DEFENDANT (see Pa. R.C.P.J.P. No. 1001(7) in action before District Justice. IF NOT USED, detach from copy of notice of appeal to be served upon appellee). PRAECIPE: To Prothonotary Enter rule upon VVXA C'L-i A 6-y n aT ,y 1315 y?- , appellee(s), to file a complaint in this appeal NaTre or appe(ke(s) (Common Pleas Na aCZ7.i- IAS ) within twenty (20) days after service of rule or suffer entry of judgment of non pros. SignMnre of appeFant or his aaorw Dr agent RULE: To Ms?tisA ??I„ }F, et ASSdc• appellee(s)• NaTle of appelive(s) (1) You are ratified that a rule is hereby entered upon you to file a complaint in this appeal within twenty (20) days after the date of service of this rule upon you by personal service or by certified or registered mail. (2) If you do not file a complaint within this time, a JUDGMENT OF NON PROS WILL BE ENTERED AGAINST YOU. (3) The date of service of this rule if service was by nail is the date of mailing. Date: ?µ 2 0?3. ??k if7i / of Prornonamry « Deputy AOPC 312-90 COURT FILE TO BE FILED WITH PROTHONOTARY PROOF OF SERVICE OF NOTICE OF APPEAL AND RULE TO FILE COMPLAINT (This goof of service MUSTBE FILED WITHIN TEN 00) DAYS AFTER ;`iiing the nobce of appeal. Gz eck applicable boxesi COMMONWEALTH OF PENNSYLVANIA COUNTY OF ; SS AFFIDAVIT: I hereby swear or affirm chat I served ? a copy of tfhe Notice of Appea. Common Pleas Na upon tbn, D=st ic: J astice. deriynated tt eroo ?-xi (data of service) E] by personal service El by ice `ified; ?regfsteredl mail, senders receipt attached hereto, and upon the appei;ee- I came; on _ _? _? ? by persona`; service ? by (certified) (registered) mait, senders ieceipr attached hereto. ? rind further that i served the Rule to File a Complaint accompanying the abode Notice of Appeal upon the appOlee(s} to whore the Rule was addressed on -__-- _-- ? by per unvf .,rrv cg cr ceiJf ed) mail, sender's receipt attached hereto. SWORN (AFFIRMED! AND SUBSCRIBED BEFORE MB TNIS DAY OF or" , T+(ie p! 0 ?ifir?h n r__, r, v ZU II. \J COMMONWEALTH OF PENNSYLVANIA COUNTY OF: CUMBERLAND Mag. Dist. No 09-1-02 DJ Name: Hon. ROBERT V. MANLOVE ACd,ess: 1901 STATE STREET CAMP HILL, PA Telephone: (717 ) 761-0583 17011-0000 LYNN STEVENS 10738 BUCHANAN TRAIL EAST WAYNESBORO, PA 17268 t NOTICE OF JUDGMENT/TRANSCRIPT PLAINTIFF/JUDGMEV??DEHTORASE FMARIA P COGNETTIEa6cAMOCIATES 210 GRANDVIEW AVE APT/STE 102 CAMP HILL, PA 17011 L VS. J DEFENDANT/JUDGMENT CITQ an DRESS FSTEVENS, LYNN 10738 BUCHANAN TRAIL EAST WAYNESBORO, PA 17268 L DocketNo.: CV-0000100-03 Date Filed: 2/28/03 THIS IS TO NOTIFY YOU THAT: Judgment: FOR PT.ATNTIFF ® Judgment was entered for: (Name) 74ARTA P mr.ATRrPTT & ARRnCTATRR ® Judgment was entered against: (Name) 9TRVRNS, LYNN in the amount of $ 4,011;-76 on: (Date of Judgment) 6/02/03 El Defendants are jointly and severally liable. (Date & Time) El Damages will be assessed on: 0 This case dismissed without prejudice. I Amount of Judgment Subject to Attachment/Act 5 of 1996 $ Amount of Judgment $ 3,933.26 Judgment Costs $ 82.50 Interest on Judgment $ .00 Attorney Fees $ .00 Total $ 4,015.76 Post Judgment Credits $ Post Judgment Costs $ Certified Judgment Total $ ANY PARTY HAS THE RIGHT TO APPEAL WITHIN 30 DAYS AFTER THE ENTRY OF JUDGMENT BY FILING A NOTICE OF APPEAL WITH THE PROTHONOTARY/CLERK OF THE COURT OF COMMON PLEAS, CIVIL DIVISION. YOU MUST INCLUDE A COPY OF THIS NOTICE OF JUDGMENT/TRANSCRIPT FORM WITH YOUR NOTICE OF APPEAL. EXCEPT AS OTHERWISE PROVIDED IN THE RULES OF CIVIL PROCEDURE FOR DISTRICT JUSTICES, IF THE JUDGMENT HOLDER ELECTS TO ENTER THE JUDGMENT IN THE COURT OF COMMON PLEAS, ALL FURTHER PROCESS MUST COME FROM THE COURT OF COMMON PLEAS AND NO FURTHER PROCESS MAY BE ISSUED BY THE DISTRICT JUSTICE. UNLESS THE JUDGMENT IS ENTERED IN THE COURT OF COMMON PLEAS, ANYONE INTERESTED IN THE JUDGMENT MAY FILE A REQUEST FOR ENTRY OF SATISFACTION WITH THE DISTRICT JUSTICE IF THE JUDGMENT DEBTOR PAYS IN FULL, SETTLES, OR OTHERWISE COMPLIES WITH THE JUDGMENT. ©3 Date Fbi'M4 tJustice lr ? I certify that this is a tr '( c y the egg=he ceedings in To ilgmer}t ///.i ?Z?4S Date °t. 4 trict ,)u'stLce My commission expires first Monday of January, 2006.^ SEAL AOPC 315-03 DATE PRINTED: 6/03/03 1:18:41 PM J 1 h U _ C ) _t R MARIA P. COGNETTI & ASSOCIATES MARIA P. COGNETTI, ESQUIRE Attorney I.D. No. 27914 210 Grandview Avenue, Suite 102 Camp Hill, PA 17011 Telephone No. (717) 909-4060 Attorneys for Plaintiff MARIA P. COGNETTI, t/d/b/a : IN THE COURT OF COMMON PLEAS MARIA P. COGNETTI & ASSOCIATES, : CUMBERLAND COUNTY, PENNSYLVANIA Plaintiff v : NO. 03 - 3125 CIVIL LYNN STEVENS, : CIVIL ACTION - LAW Defendant NOTICE TO DEFEND 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 the 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 Avenue Carlisle, PA 17013 (717) 249-3166 MARIA P. COGNETTI & ASSOCIATES MARIA P. COGNETTI, ESQUIRE Attorney I.D. No. 27914 210 Grandview Avenue, Suite 102 Camp Hill, PA 17011 Telephone No. (717) 909-4060 Attorneys for Plaintiff MARIA P. COGNETTI, t/d/b/a : IN THE COURT OF COMMON PLEAS MARIA P. COGNETTI & ASSOCIATES, : CUMBERLAND COUNTY, PENNSYLVANIA Plaintiff v : NO. 03 - 3125 CIVIL LYNN STEVENS, Defendant COMPLAINT AND NOW, comes Plaintiff, Maria P. Cognetti, Esquire, t/d/b/a Maria P. Cognetti & Associates ("Cognetti & Associates"), who files this Complaint against Defendant, Lynn Stevens, and in support thereof avers as follows: Plaintiff is Cognetti & Associates, a sole proprietorship consisting of one attorney licensed to practice and engaged in the practice of law before the various state and federal courts, with offices located at 210 Grandview Avenue, Suite 102, Camp Hill, Cumberland County, Pennsylvania. 2. Defendant is Lynn Stevens, an adult individual, who resides at 10738 Buchanan Trail East, Waynesboro, Franklin County, Pennsylvania. COUNT I - BREACH OF CONTRACT 3. In December, 2000, Defendant requested Cognetti & Associates to represent him in a custody matter against Suzanne Stevens, which custody matter involved Defendant's two minor children, Cole Stevens and Kara Stevens. 4. Defendant agreed in writing to compensate Cognetti & Associates on an hourly basis at its regular hourly rates plus cost of suit. This agreement was confirmed in writing, a copy of which is incorporated herein, made a part hereof, and attached hereto as Exhibit "A." From December, 2000 through November, 2001, Cognetti & Associates undertook such representation of Defendant. Cognetti & Associates' services included, without limitation, the following: a. Preparation of and filing of a Petition for Modification of Custody Order and Request for Psychological Evaluation; b. Preparation for and attendance at Custody Conciliation Conference; C. Preparation of an extensive Pre-Trial Memorandum; d. Preparation for and attendance at Pre-Trial Conference before the Court; and e. Preparation of detailed Offers of Proof for each and every witness on Defendant's lengthy witness list. 6. True and correct copies of the invoices mailed to Defendant detailing the work performed, fees billed, and costs incurred are incorporated herein, made a part hereof, and attached hereto as Exhibit "B." Cognetti & Associates mailed monthly invoices to Defendant totaling $10,733.56 for its services. 8. To date, Defendant has paid Cognetti & Associates a total of $6,800.00 leaving a principal balance due and owing of $3,933.56. 9. Despite demand therefor, Defendant has failed and refused to pay Cognetti & maintained books of account on the services that it rendered and the costs that it incurred on Defendant's behalf, which accounts are an accurate and running account of all debits and credits for the provision of such services and incidence of such costs. 17. Monthly invoices were mailed to Defendant setting forth the services which had been rendered by Cognetti & Associates on Defendant's behalf during the previous month, the fair and reasonable amount being charged for the services, and any outstanding balance due on services rendered prior to that time. True and correct copies of the accounts sent to Defendant are collectively incorporated herein, made a part hereof, and attached hereto as Exhibit "B." 18. During the course of Cognetti & Associates' representation of Defendant, Defendant made payments in the amount of $6,800.00 on the outstanding balance of its account, leaving a principal balance due of $3,933.56. 19. Although Cognetti & Associates has demanded payment of the balance due of $3,933.56, Defendant has failed and refused to pay all or any part of the balance due to Cognetti & Associates or to otherwise contact Cognetti & Associates regarding payment. 20. Cognetti & Associates performed its obligations under the agreement between it and Defendant by providing valuable legal services to Defendant and incurring costs on his behalf, the fair and reasonable principal value remaining unpaid of which is $3,933.56. 21. Cognetti & Associates has performed its services for Defendant fully and satisfactorily, and conformed to, and complied with, all of the terms and conditions required of it under the agreement between it and Defendant. 22. Despite Defendant's obligation to pay Cognetti & Associates for the services performed and costs incurred on its behalf, and despite Cognetti & Associates' demands on Defendant for such payment, Defendant has wrongfully failed and refused to pay Cognetti & Associates the sums due it. 23. Defendant has had an opportunity to scrutinize the accounts. 24. Defendant has pointed out one minor error in one bill, which error was of an insignificant nature. 25. Defendant has never questioned or objected either specifically or generally to any of the numerous accounts rendered, except the minor error as set forth above. WHEREFORE, Plaintiff, Cognetti & Associates, demands judgment in its favor and against Defendant, Lynn Stevens, in the amount of $3,933.56, plus interest and costs of suit. Respectfully Submitted: MARIA P. COGNETTI & ASSOCIATES Date: July 30, 2003 By: 4TI, MA P. OG ESQUIRE Attorney I.D. No. 27914 210 Grandview Avenue, Suite 102 Camp Hill, PA 17011 Telephone No. (717) 909-4060 MAPa C®GNF,= & ASs®ciATEs Attorneys and Counselors at Law Maria P. Cognetti' Attorney at Law 'Fellow-American Academy of Matrimonial Lawyers December 6, 2000 PERSONAL AND CONFIDENTIAL Mr. Lynn Stevens 7985 Lyons Road Waynesboro, PA 17268 RE: RETAINER Dear Mr. Stevens: H. Allison Wright Attorney at Law Karen A. Sheriff Paralegal It was a pleasure to meet with you. Thank you very much for your confidence in retaining us to represent you with respect to your current domestic situation. We look forward to working with you. The purpose of this letter is to set forth, in writing, the arrangements concerning our fee so that we may avoid any misunderstandings. As we discussed, your bill will be based upon our hourly rates for all time devoted to your case at the hourly rates for the attorney and/or paralegal performing the service and the periods during which services were performed based upon intervals of tenth(s) of an hour. We try to have the work done at the level which will be most efficient in terms of rates and costs to you. The time charged includes not only meeting with you and court appearances, but also drafting and reviewing pleadings and correspondence, telephone conversations with you, your spouse's attorney and other parties, time spent with witnesses, legal research, and travel. Please understand that all hourly rates charged to our clients may be increased from time to time by our firm, which is usually done each year or so. As we discussed, my rate for this case initially will be $225.00 per hour. The rates of the other attorneys in our firm that may be working on your case range from $100_600 to $225.00 per hour and our paralegals' rates range from $50.00 to $80.00 per hour. In addition to the charges for professional services, you will be responsible for timely reimbursing us for all of our own out-of-pocket disbursements, such as charges for long distance telephone calls, filing fees paid to the court, expert, appraisal, investigative and witness fees, Practice Limited to Matrimonial Law 210 Grandview Avenue, Suite 102 ? Camp Hill, PA 17011 Telephone (717) 909-4060 ? Fax (717) 909-4068 E-mail C:nonrttil.aw(n -M r- December 6, 2000 Page 2 travel expenses, overtime secretarial time, messengers, transcripts of depositions, telecopies and photocopies. We will be sending you monthly statements as your case proceeds containing a description of how we have been spending our time on your behalf We reserve the right to charge interest and/or to terminate our attorney-client relationship if you do not pay our fees and disbursements within thirty days of billing. As we discussed, we will require a retainer, which we have set at $5,000.00, which is an advance deposit to be applied toward payment of your future bills. It is not, however, a minimum or maximum fee. Thus, if we conclude your case before the total hourly charges equal the amount of the retainer, you will receive a refund of the difference. On the other hand, if the total hourly charges exceed the amount of the retainer before our work is completed, you will be required to provide a new retainer. Unfortunately, it is virtually impossible to estimate for you the total amount of time that will have to be devoted to your case. That will depend upon a variety of factors, including but not limited to whether hearings or a trial will be necessary, the time and effort required, the nature and complexity of the issues involved and the degree of cooperation afforded by your spouse and your spouse's attorney. Similarly, we obviously cannot guarantee the results that will be obtained, particularly since no one can predict what a court may do in a particular case. The scope of our representation is limited to negotiations with the goal of settlement and litigation at the trial level. In the event that you or your spouse wish to take an appeal from any trial level decisions, we will have to discuss whether we will continue to represent you at the Appellate level. Cases of this kind require that your attorney be as familiar as possible with all of the facts bearing on the issues, regardless of how trivial or potentially embarrassing you may believe them to be. Therefore, it is essential that you share all even remotely relevant facts with us. We will, of course, keep you closely advised of the progress of your case and provide you with copies of all correspondence, pleadings and any other relevant documents. You should never hesitate to ask us questions, which we always welcome. We understand that in matters of this nature, urgent circumstances may arise which may necessitate your talking to us immediately. We therefore make a strong commitment to respond to all of your inquiries as soon as possible. As we discussed, my paralegal, Ms. Sheriff, may be working with me on this matter and you should always feel free to contact her. However, understandably there are occasions when we are not immediately available because of commitments to other cases. In such instances, my secretary is given instructions as to how to reach us. December 6, 2000 ) 1 r," Page 3 r ------------------ If this letter correctly conforms with your understanding of our arrangement concerning fees and costs, we would appreciate your signing the enclosed copy of this letter in the space indicated and returning it to me together with your check payable to Maria P. Cognetti & Associates in the amount of $5,000.00 for our retainer. Of course, should you have any questions or comments about this letter or the arrangements discussed above, please do not hesitate to give me a call. I look forward to working with you. Very truly your, , Maria., C6gne MPC/lar Enclosure I HAVE READ THE ABOVE RETAINER LETTER AND IT CORRECTLY SETS FORTH MY UNDERSTANDING IN REGARD TO MY FEE ARRANGEMENT AND REPRESENTATION BY MARIA P. COGNETTI & ASSOCIATES. DATED: I Zl 6 1746/- Lynn Stevens Lynn MubWmily uw%,W.LtrA4twmu•Lynn.mt pd MARIA P. COGNETTI & ASSOCIATES Attorneys and Counselors at Law 210 Grandview Avenue, Ste. 102 Camp Hill, Pa 17011 (717) 909-4060 Page: 1 Lynn Stevens January 05, 2001 10738 Buchanan Trail East Client Number 180C Waynesboro PA 17268 Statement No: 7525 Family Law 12/11/00 Telephone call with client 12/18/00 Review correspondence from client 12/29/00 Telephone call with client Prepare Praecipe; letter to Prothonotary For Current Services Rendered 162.00 Copies 1.50 Fax Charge 5.00 Postage 0.55 Total Expenses Thru 12/31/00 7.05 Total Current Work 169.05 Total Payments for 12/31/00 -169.05 Balance Due $0.00 Client Funds 12/11/00 Client deposit to Retainer 5,000.00 12/31/00 Payment from Escrow - Fees -169.05 Ending Client Funds Balance $4,830.95 MARIA P. COGNETTI & ASSOCIATES Attorneys and Counselors at Law 210 Grandview Avenue, Ste. 102 Camp Hill, Pa 17011 (717) 909-4060 Page: 1 Lynn Stevens February 05, 2001 10738 Buchanan Trail East Client Number 180C Waynesboro PA 17268 Statement No: 7743 Family Law 01/02/01 Prepare Petition for Modification of Custody Order and Psychological Evaluation; letter to Attorney 01/04/01 Review Petition 01/05/01 Telephone call with client 01/08/01 Telephone call with attorney Conference with client 01/09/01 Letter to Prothonotary; letter to attorney 01/10/01 Telephone call with Prothonotary 01/15/01 Review fax from client 01/17/01 Telephone call with attorney 01/18/01 Telephone call with client 01/24/01 Review note from client For Current Services Rendered 473.00 Copies 5.40 Long Distance Charge 1.12 Fax Charge 10.00 Postage 8.36 Total Expenses Thru 01/31/01 24.88 Total Current Work 497.88 Total Payments for 01/31/01 -497.88 Balance Due $0.00 Lynn Stevens Family Law Client Funds Beginning Client Funds Balance O1/18/01 Filing Fee - Franklin Co. Prothonotary 31/31/01 Payment from Escrow - Fees Page: 2 February 05, 2001 Client Number 180C Statement No: 7743 $4,830.95 -200.00 -497.88 Ending Client Funds Balance $4,133.07 MARIA P. COGNETTI & ASSOCIATES Attorneys and Counselors at Law 210 Grandview Avenue, Ste. 102 Camp Hill, Pa 17011 (717) 909-4060 Page: 1 Lynn Stevens February 27, 2001 10738 Buchanan Trail East Client Number 180C Waynesboro PA 17268 Statement No: 7938 Family Law 02/01/01 Telephone call with Court Administrator; prepare Motion for Contempt Telephone call with client 02/02/01 Telephone call with attorney 02/06/01 Telephone call with attorney Telephone call with client 02/08/01 Review Petition Letter to Court Administrator 02/15/01 Review fax from attorney 02/16/01 Review fax from client For Current Services Rendered 340.00 Copies 8.40 Fax Charge 15.00 Postage 3.38 Total Expenses Thru 02/28/01 26.78 Total Current Work 366.78 Total Payments for 02/27/01 -366.78 Balance Due $0.00 Client Funds Beginning Client Funds Balance $4,133.07 02/27/01 Payment from Escrow - Fees -366.78 Ending Client Funds Balance $3,766.29 MARIA P. COGNETTI & ASSOCIATES Attorneys and Counselors at Law 210 Grandview Avenue, Ste. 102 Camp Hill, Pa 17011 (717) 909-4060 Lynn Stevens 10738 Buchanan Trail East Waynesboro PA 17268 Family Law Page: 1 April 09, 2001 Client Number 180C Statement No: 8090 03/01/01 Telephone call with client; telephone call with attorney 03/02/01 Review fax from attorney Review custody file; prepare Custody Conciliation Memo 03/05/01 Review fax from client; review correspondence from attorney Telephone call with client; telephone call with attorney 03/06/01 Multiple telephone calls with attorney Telephone call with client 03/07/01 Telephone call with client; telephone call with Maryland attorney Telephone call with attorney 03/08/01 Telephone call with client 03/11/01 Review Custody Conciliation Memo 03/12/01 Review correspondence from Maryland counsel Telephone call with client; revise and review Custody Conciliation Memo Telephone call with client 03/13/01 Conference with client 03/14/01 Telephone call with client 03/16/01 Telephone call with client 03/19/01 Telephone call with client; revise Custody Conciliation Memo 03/20/01 Letter to Court 03/23/01 Review Custody Conciliation Memo Attend Custody Conference 03/26/01 Telephone call with client For Current Services Rendered 1,861.50 Page: 2 April 09, 2001 Lynn Stevens Client Number 180C Statement No: 8090 Family Law 11.55 Copies 1.38 Long Distance Charge 20.00 Fax Charge 7,72 Postage Total Expenses Thru 03/31/01 40.65 1,902.15 Total Current Work Total Payments for 03/31/01 -1,902.15 $0.00 Balance Due Client Funds Beginning Client Funds Balance $3,766.29 -1,902.15 03/31/01 Payment from Escrow - Fees Ending Client Funds Balance $1,864.14 Mi )k P. COGNETTI & ASSOCIATES Attorneys and Counselors at Law 210 Grandview Avenue, Ste. 102 Camp Hill, Pa 17011 (717) 909-4060 Page: 1 Lynn Stevens May 02, 2001 7985 Lyons Road Client Number 180C Waynesboro PA 17268 Statement No: 8357 Family Law 34/02/01 Review fax from attorney; review Conference Summary Report )4/04/01 Review Court Order and CSRI(????) )4/10/01 Telephone call with client )4/19/01 Review fax from client; telephone call with client )4/26/01 Telephone call with client For Current Services Rendered 242.50 Copies 2.55 Long Distance Charge 1.55 Fax Charge 15.00 Total Expenses Thru 04/30/01 19.10 Total Current Work 261.60 Total Payments for 04/30/01 -261.60 Balance Due $0.00 Client Funds Beginning Client Funds Balance $1,864.14 )4/30/01 Payment from Escrow - Fees -261.60 Ending Client Funds Balance $1,602.54 MK. I P. COGNETTI & ASSOCIATES Attorneys and Counselors at Law 210 Grandview Avenue, Ste. 102 Camp Hill, Pa 17011 (717) 909-4060 Lynn Stevens 7985 Lyons Road Waynesboro PA 17268 Family Law 15/02/01 Telephone call with client 15/03/01 Review Complaint; telephone call with client )5/07/01 Telephone call with client 15/08/01 Telephone call with client 15/11/01 Telephone call with psychologist )5/15/01 Telephone call with psychologist 15/21/01 Review correspondence from attorney )5/22/01 Telephone call with attorney 15/25/01 Lengthy telephone call with client For Current Services Rendered Long Distance Charge Postage Total Expenses Thru 05/31/01 Total Current Work Total Payments for 05/31/01 Balance Due Client Funds Beginning Client Funds Balance 15/31/01 Client deposit to Retainer 15/31/01 Payment from Escrow - Fees Page: 1 June 08, 2001 Client Number 180C Statement No: 8561 353.50 1.13 1.23 2.36 355.86 -355.86 $0.00 $1,602.54 2,000.00 -355.86 Ending Client Funds Balance $3,246.68 P. COGNETTI & ASSOCIATES Attorneys and Counselors at Law 210 Grandview Avenue, Ste. 102 Camp Hill, Pa 17011 (717) 909-4060 Lynn Stevens 7985 Lyons Road Waynesboro PA 17268 Family Law Page: 1 July 09, 2001 Client Number 180C Statement No: 8778 )6/06/01 Review fax from client; review fax from attorney )6/07/01 Review correspondence from attorney Lengthy telephone call with client; letter to attorney )6/11/01 Telephone conference with client; telephone call with psychologist 36/12/01 Telephone call with psychologist )6/13/01 Review fax from attorney 06/14/01 Review fax from client Multiple telephone calls with client (three); multiple telephone calls with attorney 06/15/01 Review correspondence from attorney (two) Telephone call with client 06/18/01 Letter to attorney 06/19/01 Telephone call with client 06/20/01 Review fax from client 06/21/01 Letter to attorney; telephone call with client 06/22/01 Telephone call with client; review fax from attorney Review fax from attorney 06/25/01 Telephone call with client 06/26/01 Review fax from client Review fax from client 06/27/01 Telephone call with client; telephone call with attorney For Current Services Rendered Copies Fax Charge Postage Total Expenses Thru 06/30/01 1,002.50 4.20 60.00 2.80 67.00 J Lynn Stevens Family Law Total Current Work Total Payments for 06/30/01 Balance Due Client Funds Beginning Client Funds Balance 6/30/01 Payment from Escrow - Fees Ending Client Funds Balance Page: 2 July 09, 2001 Client Number 180C Statement No: 8778 1,069.50 -1,069.50 $0.00 $3,296.68 -1,069.50 $2,177.18 M }1 P. COGNETTI & ASSOCIATES Attorneys and Counselors at Law 210 Grandview Avenue, Ste. 102 Camp Hill, Pa 17011 (717) 909-4060 Page: 1 Lynn Stevens August 03, 2001 7985 Lyons Road Client Number 180C Waynesboro PA 17268 Statement No: 8989 Family Law 07/03/01 Telephone call with client 07/05/01 Review fax from attorney Telephone call with client 07/16/01 Telephone call with psychologist 07/17/01 Review fax from attorney 07/31/01 Review fax from client For Current Services Rendered 230.00 Copies 1.35 Long Distance Charge 2.68 Fax Charge 15.00 Postage 0.68 Total Expenses Thru 07/31/01 19.71 Total Current Work 249.71 Total Payments for 07/31/01 -249.71 Balance Due $0.00 Client Funds Beginning Client Funds Balance $2,177.18 07/31/01 Payment from client and/or transfer from retainer -249.71 Ending Client Funds Balance $1,927.47 M, P. COGNETTI & ASSOCIATES Attorneys and Counselors at Law 210 Grandview Avenue, Ste. 102 Camp Hill, Pa 17011 (717) 909-4060 Lynn Stevens 7985 Lyons Road Waynesboro PA 17268 Family Law 09/04/01 Review correspondence 09/05/01 Telephone call with psychologist; telephone call with client; telephone call with Jim (two) 09/07/01 Telephone call with psychologist; review fax from attorney 09/10/01 Review Court Order; review fax from client Telephone call with psychologist 09/12/01 Telephone call with psychologist 09/13/01 Telephone call with psychologist; telephone conference with psychologist and attorney; telephone call with client; telephone call with attorney Telephone call with psychologist Update custody pleadings index 09/14/01 Telephone call with client Page: 1 October 01, 2001 Client Number 180C Statement No: 9552 09/25/01 Conference with client; telephone call with Dr. Shienvold Letter to Melissa Jackson Prepare Release For Current Services Rendered Copies Long Distance Charge Fax Charge Postage Total Expenses Thru 09/30/01 Total Current Work Total Payments for 09/30/01 Balance Due 919.00 9.00 0.38 60.00 2.38 71.76 990.76 -990.76 $0.00 Client Funds MARIA P. COGNETTI & ASSOCIATES Attorneys and counselors at Law 210 Grandview Avenue, Ste. 102 Camp Hill, Pa 17011 (717) 909-4060 Lynn Stevens 10738 Buchanan Trail East Waynesboro PA 17268 Family Law 10/03/01 Letter to Melissa Jackson Prepare Pre-Trial Memorandum 10/04/01 Letter to Prothonotary 10/08/01 Review fax from client 10/09/01 Review correspondence from Dr. Shienvold Page: 1 November 05, 2001 Client Number 180C Statement No: 9691 10/11/01 Review fax from attorney 10/12/01 Review fax from attorney; review fax from client; review documents from Melissa Jackson Prepare for Pre-Trial Conference; update custody pleading index 10/15/01 Attend Pre-Trial with Judge Walsh 10/16/01 Telephone call with psychologist 10/19/01 Review Pre-Trial order; telephone call with Court; letter to court; review fax from attorney 10/23/01 Telephone call with attorney Telephone call with client 10/24/01 Telephone call with attorney (2) 10/25/01 Review e-mail from client; prepare offers Telephone call with client 10/26/01 Multiple telephone calls with attorney; review fax; telephone call with client; telephone call with psychologist 10/28/01 Telephone call with attorney Prepare offers; telephone call with client 10/29/01 Letter to Prothonotary Telephone call with client Finalize letter to Court; letter to client; review fax from attorney; telephone call with attorney; telephone MARIA P. COGNETTI & ASSOCIATES Attorneys and Counselors at Law 210 Grandview Avenue, Ste. 102 Camp Hill, Pa 17011 (717) 909-4060 Lynn Stevens 10738 Buchanan Trail East Waynesboro PA 17268 Family Law Page: 1 December 04, 2001 Client Number 180C Statement No: 9688 .1/01/01.Telephone call with Carie Bowmaster; telephone call with client; telephone call with psychologist .1/02/01 Telephone call with client; multiple telephone calls with attorney; e-mail client .1/05/01 Telephone call with attorney; letter to attorney (no charge) For Current Services Rendered Copies Long Distance Charge Fax Charge Postage Total Expenses Thru 11/30/01 Total Current Work Previous Balance Balance Due 225.00 3.75 2.08 10.00 3.65 19.48 244.48 $3,688.78 $3,933.26 PAST DUE n r, ? `C ??? : _ a r. -- r''.i ? J r=n G ?7 O i (,Y ^ ?.tl ( T V l -? 1 `i 7 MARIA P. COGNETTI & ASSOCIATES MARIA P. COGNETTI, ESQUIRE Attorney I.D. No. 27914 210 Grandview Avenue, Suite 102 Camp Hill, PA 17011 Telephone No. (717) 909-4060 Attorneys for Plaintiff MARIA P. COGNETTI, t/d/b/a : IN THE COURT OF COMMON PLEA MARIA P. COGNETTI & ASSOCIATES, : CUMBERLAND COUNTY, PENNSYLVANIA Plaintiff V. : NO. 03 - 3125 CIVIL LYNN STEVENS, Defendant AFFIDAVIT OF SERVICE I, MARIA P. COGNETTI, ESQUIRE, do hereby certify that a true and correct copy of the Complaint was served upon the Defendant by certified mail, return receipt requested, on the 7' day of August, 2003. The original signed return receipt, number 7002 0510 0003 646 7055, is attached hereto and made a part hereof. Date: August 18, 2003 By: MARIA P. COGNETTI & MARIA?. COG d TTI, ESQUIRE Attorney I.D. No. 27914 Sworn to and subscbed f7i day befor me this 8 of 2003. 210 Grandview Avenue, Suite 102 Camp Hill, PA 17011 Telephone No. (717) 909-4060 Kaien A SherM, NbWokkk Palmyra eoro, Lebanm Cw* commission Expires May IS, 2006 m SENDER: 9 • Complete items 1 and/or 2 for additional services. 'm • Complete items 3, 4a, and 41b. • Print your name and address on the reverse of this farm so that we card to you. or on the back if space • Attach this form to the front of the mailpiece, d - permit. . The Return r Receipt Requested" on the mailpiece below the article N y The Return n Receipt will show to whom the article was delivered and delivered. 0 3. Article Addressed to: O d Mlr. C.yr?r S?-vans E O l3$ /3U C4?ar?an Tro Wp `ragbcllo, Pa 172(eg 5. Received By L-'tnn 6. Signature: (A X o L T _2 PS Form 3811 ?q AS I also wish to receive the following services (for an n return ins extra fee): oes not 1. 11 Addressee's Address •? 2.13 Restricted Delivery y number. he date Consult postmaster for fee. a u 4a. Article Number w S' "? oo63 ( 4c0 , 7ooz- 0510 0 4b. Service Type +?c ^L3 Certified 0 % ? Registered ? Express Mail ? Insured C Return Receipt for Merchandise ? COD 7. Date of Deli ery 0 0 6. Address e's dress (only if requested T ano' fee is paid) m t ca tl t H , December 1994 102595-9e-a-o11e C Cl r J G?. 2 ?- Lynn A. Stevens, Pro Sb 10738 Buchanan Trail East Waynesboro, PA 17268 MARIA P. COGNETTI, t/d/b/a MARIA P. COGNETTI & ASSOCIATES, PENNSYLVANIA PLAINTIFF : IN THE COURT OF COMMON PLEAS : CUMBERLAND COUNTY, V. LYNN A. STEVENS, PROSE DEFENDANT NO. 03 - 3125 CIVIL CIVIL ACTION - LAW PRAEQPE FOR ENTRY OF APPEARANCE TO THE PROTHONOTARY: Please enter my appearance to represent myself in the above captioned matter. Respectfully submitted, Lynn Stevens, Pro Se 10738 Buchanan Trail East Waynesboro, PA 17268 Telephone No. (717) w o ? a y N - 06 a Lynn A. Stevens, Pro 5a 10738 Buchanan Trail East Waynesboro, PA 17268 MARIA P. COGNETTI, t/d/b/a : IN THE COURT OF COMMON PLEAS MARIA P. COGNETTI & ASSOCIATES, : CUMBERLAND COUNTY, PENNSYLVANIA PLAINTIFF V. : NO. 03 - 3125 CIVIL : CIVIL ACTION - LAW LYNN A. STEVENS, PROSE, DEFENDANT ANSWER TO COMPLAINT AND COUNTERCLAIM AND NOW, comes Defendant, Lynn A. Stevens and files the following answer and counterclaim to the complaint filed by Plaintiff, Maria P. Cognetti, t/d/b/a Maria P. Cognetti & Associate's: ANSWER TO COMPLAINT 1. On information and belief, the averment of paragraph 1 is admitted. 2. Admitted ANSWER TO COUNT 1- BREACH OF CONTRACT 3. Denied as stated. Defendant, Lynn A. Stevens met with Plaintiff early in December 2000 to discuss with Ms. Cognetti her possible representation in a proposed custody matter involving his two minor children, Cole Stevens and Kara Stevens. 4. Denied as stated. Plaintiff's Exhibit "A", dated December 6, 2000 and signed by Defendant December 8, 2000, is not just agreement in writing to compensate Plaintiff; It also, delineates Plaintiff's responsibilities. 5. Denied as stated. Plaintiff's detailed invoices for the period of December 2000 through November 2001 speak for themselves. 6. Denied as stated. It is admitted said Exhibit "B" is attached to Plaintiff's Complaint. It is denied any inference said invoices are true and correct. 7. On information and belief, the averment of paragraph 7 is admitted. 8. Admitted in part Denied in Part. Admitted Defendant paid Plaintiff at least $6,800. Denied any inference Defendant owes Plaintiff $3,933.56. 9. Admitted in part. Denied in part. Admitted Defendant has made demand for payment of $3,953.56. Denied any inference Defendant owes Plaintiff $3,933.56. 10. The averments of paragraph 10 of the Complaint are Plaintiff's conclusions of law to which no response is required. To the extent a response is required, the averments are denied. 11. The averments of paragraph 11 are Denied. WHEREFORE, defendant, Lynn Stevens, respectfully request that the Complaint in its entirety be dismissed at Plaintiff's cost. COUNT II - OUANTUM MERUIT/UNJUST ENRICHMENT 12. No response necessary 13. The averments of paragraph 13 are Denied. 14. The averments of paragraph 14 are Denied. 2 WHEREFORE, defendant, Lynn Stevens, respectfully request that the complaint in its entirety be dismissed at Plaintiff's cost. COUNT III ACTION ON ACCOUNT STATED. 15. No response necessary. 16. It is admitted Plaintiff maintained books of account during the course of representation of Defendant. It is denied said books of account are accurate. 17. It is admitted Plaintiff mailed monthly invoices to Defendant. It is Denied the amount charged was fair and reasonable. 18. The averments of paragraph 18 are Denied as stated. It is admitted, Defendant deposited $6,800.00 in a retainer account with Plaintiff. It is denied that Defendant owes Plaintiff $3,933.56. 19. The averments of paragraph 19 are Denied. Defendant without any admission or denial of correctness or incorrectness of the Plaintiff's invoices, offered Plaintiff $1,966.78 as full settlement of the account. Plaintiff refused said offer. 20. It is Denied that Plaintiff, "Cognetti & Associates" performed its obligations under the agreement between Plaintiff, "Cognetti & Associates" and Defendant. It is Denied Plaintiff, "Cognetti & Associates provided valuable legal services to Defendant or that Plaintiff, "Cognetti & Associates" charges were fair and reasonable. It is further Denied that Defendant owes Plaintiff $3,933.56. 21. The averments of paragraph 20 are Denied. Plaintiff did not perform the services for Defendant fully and satisfactorily. Nor, did Plaintiff conform to or comply with the terms of the agreement. 22. The averments of paragraph 22 are Denied. Defendant without any admission or denial of correctness or incorrectness of the Plaintiff's invoices, offered Plaintiff $1,966.78 as full settlement of the account. Plaintiff refused said offer. 23. Denied. 24. It is admitted that Defendant pointed out one error in one bill. Any inference that only one error exist in Plaintiff's invoices is Denied. 25. It is Denied that Defendant did not question Plaintiff's billing. Defendant repeatedly questioned Plaintiff's about the services purported to have been performed. WHEREFORE, defendant, Lynn Stevens, respectfully request that the complaint in its entirety be dismissed at Plaintiff's cost. COUNT II - QUANTUM IFOnrrinNV?rr GNRICHFi'eNT' 14. Paragraphs 1 through 13 of this counterclaim are incorporated herein as though set forth here at length. 15. Cognettl & Associates did not complete negotiations with the goal of settlement and/or litigation at the trial level in the Lynn Stevens matter of custody. 16. Lynn Stevens is entitled to a complete or partiall refund of the amount of money he deposited in Cognettl & Associates retainer account. WHEREFORE, Lynn Stevens, demands judgment on his counterclaim against Plaintiff, Cognetti & Associates in the amount of $10,688.78 or such amount as the Court deems appropriate. Respectfully submitted, L Lynn Stevens, Pro Se 10738 Buchanan Trail East Waynesboro, PA 17268 Telephone No. (717) 404-5266 !? c' z Ir, ? ng ' 4C ± u} cJ CV 22 'fiv= Cn U71 C . tL 4 i? ? L\Closed Files\Stevens-L\Pleadings\Answer to Countenlaimwpd MARIA P. COGNETTI & ASSOCIATES MARIA P. COGNETTI, ESQUIRE Attorney I.D. No. 27914 210 Grandview Avenue, Suite 102 Camp Hill, PA 17011 Telephone No. (717) 9094060 September 4, 2003 Attorneys for Plaintiff MARIA P. COGNETTI, t/d/b/a IN THE COURT OF COMMON PLEAS MARIA P. COGNETTI & ASSOCIATES, CUMBERLAND COUNTY, PENNSYLVANIA Plaintiff V. No. 03-3125 CIVIL LYNN A. STEVENS, PRO SE, Defendant CIVIL ACTION -LAW ANSWER TO COUNTERCLAIM AND NOW, comes Plaintiff, Maria P. Cognetti, Esquire, and files the following Answer To Counterclaim and in support thereof respectfully represents as follows: COUNT I - BREACH OF CONTRACT 1. Denied. It is specifically denied that Defendant, Lynn Stevens, met with Plaintiff, Maria Cognetti, Esquire on December 5, 2000. To the contrary, Defendant met with Maria Cognetti, Esquire's Associate, H. Allison Wright, Esquire, on December 5, 2000. 2. Admitted with clarification. This was the charge for a consult with Attorney Wright. 3. Admitted. 1XIosed Files\Stevm-LU'leadings\Amwer to Counterclaim.wpd September 4, 2003 4. Admitted with clarification. Although it is admitted that the sentence quoted by Defendant does appear in the Fee Agreement, the sentence is taken out of context. A copy of the Fee Letter is attached to Plaintiffs original Complaint and speaks for itself. Admitted. 6. Admitted. Admitted. 8. Admitted with clarification. The balance was $104.21. 9. Admitted with clarification. Plaintiff did advise Defendant in a phone conversation on October 20, 2001, that she would no longer represent him. That conversation was followed up with an email to Defendant on October 30, 2001. In light of ]Defendant's continued comments regarding conspiracies and cover-ups, and his implied threats of suing Plaintiff for malpractice, Plaintiff had no choice but to terminate her services. Additionally, Plaintiff had recently sent Defendant a request for an additional $5,000.00 pursuant to the terms of the Fee Agreement which funds Defendant did not wish to pay. 10. Admitted. 11. Admitted. 12. Admitted with clarification. Cognetti and Associates, i.e., Maria P. Cognetti, Esquire, did in fact fulfill their obligations under the Fee Agreement entered into on December 8, 2000. Defendant is now simply unhappy with the outcome of hi s case. No guarantees were ever made to Defendant in accordance with the terms of the Fee Agreement, which specifically states, 1:\Closed Files\Stevens-L\Pleadings\Answer to Comaerclaim.wpd September 4, 2003 "[w]e obviously cannot guarantee the results that will be obtained, particularly since no one can predict what a Court may do in a particular case." 13. Denied. It is specifically denied that Plaintiff failed to perform. It is further denied that Defendant has suffered additional costs in obtaining and acquainting new counsel with the existing situation. COUNT II - QUANTUM MERUIT/UNJUST ENRICHMENT 14. Paragraphs 1 through 13 of Defendant's Counterclaim and Plaintiffs Answers thereto are incorporated herein as set forth at length. 15. Denied. As stated previously, Defendant's quote from the Fee Agreement was taken out of context. Plaintiff was under no obligation to continue representation of Defendant given the circumstances surrounding his paranoia with regard to conspiracies and cover ups among the individuals involved in the matter. Furthermore, Plaintiff could not continue to represent Defendant in light of his implied threat of a malpractice action. 16. Denied. It is specifically denied that Defendant is entitled to a complete or partial refund of the amount of money he deposited in Cognetti and Associates' retainer account. Those funds were received by Plaintiff as payment for services rendered. Defendant also has additional fees in excess of $3,900.00 which are due Plaintiff. 1AClosed Files\Stevens-L\Pleadings\Answer to Countmlaim.wpd September 4, 2003 WHEREFORE, Plaintiff requests that this Honorable Court deny Defendant's Counterclaim and request for damages in the amount of $10,688.78. Respectfully Submitted: MARIA P. COGNETTI & ASSOCIATES r Date: September 4, 2003 By: MARIA . COGN? TI, ESQUIRE Attorney I.D. No. 27914 210 Grandview Avenue, Suite 102 Camp Hill, PA 17011 Telephone No. (717) 909-4060 L\Closed Files\Stevens-L\Pleadings\Answer to Countemlaimwpd September 4, 2003 VERIFICATION I, Maria P. Cognetti, Esquire, hereby verify and state that the facts set forth in the foregoing document are true and correct to the best of my information, knowledge and belief. I understand that false statements herein are made subject to the penalties of 18 Pa. C.S.A. §4904 relating to unworn verification to authorities. llawk? ' 'wz Maria P. Cognet , squire DATE: September 4, 2003 l:\Closed Fi1es\Stevms-L\P1mdings\Answer to Comterclaimmpd September 9, 2003 CERTIFICATE OF SERVICE I, Maria P. Cognetti, Esquire, do hereby certify that on this date I served the foregoing Answer to Counterclaim by depositing a true and exact copy thereof in the United States mail, first class, postage prepaid, addressed as follows: Mr. Lynn Stevens 10738 Buchanan Trail East Waynesboro, PA 17268 /MARIA P. COGNE?TTTII & ASSOCIATES Date: September 9, 2003 By: MARIA P. C ETTI & ASSOCIATES Attorney I.D. No. 27914 210 Grandview Avenue, Suite 102 Camp Hill, PA 17011 Telephone No. (717) 909-4060 ? C y c_± t,.x O ` ri rii .?..? ?? ? f r ? _ _ ;, _v ,; .?. _ _- r:?`-? ?^C.. L7 'DIY? _ _ ?1 ?-) ? (? J _` 1XIosed Files\Stevens-LPleadings\Petition for Appointment of Arbitrators.wpd MARIA P. COGNETTI, t/d/b/a MARIA P. COGNETTI & ASSOCIATES, Plaintiff V. LYNN A. STEVENS, PRO SE, Defendant September 4, 2003 IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA No. 03-3125 CIVIL CIVIL ACTION - LAW ORDER OF COURT 76_ AND NOW, to wit, this // day of 2003, upon consideration of the foregoing Petition, ?(?i?6 /)fir T-squire,acc?rcJ/1?G???? Esquire, and (., J!- )90c ) , Esquire, are appointed arbitrators in the above-captioned action as prayed for. 44 BY THE C J. >.? ?" E ?? l,? ?? •, ?j ?, 1XIosed Files\Stevens-UPleadings\Petition for Appointment of Arbitrators.wpd September 4, 2003 MARIA P. COGNETTI & ASSOCIATES MARIA P. COGNETTI, ESQUIRE Attorney I.D. No. 27914 210 Grandview Avenue, Suite 102 Camp Hill, PA 17011 Telephone No. (717) 909-4060 Attorneys for Plaintiff MARIA P. COGNETTI, t/d/b/a IN THE COURT OF COMMON PLEAS MARIA P. COGNETTI & ASSOCIATES, CUMBERLAND COUNTY, PENNSYLVANIA Plaintiff V. No. 03-3125 CIVIL LYNN A. STEVENS, PRO SE, Defendant CIVIL ACTION -LAW PETITION FOR APPOINTMENT OF ARBITRATORS TO THE HONORABLE, THE JUDGES OF SAID COURT: Maria P. Cognetti, Plaintiff in the above action, respectfully represents that: 1. The above-captioned action is at issue. 2. The claim of the Plaintiff in the action is $3,933.56. The Counterclaim of the Defendant in the action is $10,688.78. The following attorneys are interested in the case as counsel or are otherwise disqualified to sit as arbitrators: None. IAClosed Files\Stevens•L\PleadingsTetition for Appointment of Arbitrators.wpd September 4, 2003 WHEREFORE, your Petitioner prays your Honorable Court to appoint three (3) arbitrators to whom the case shall be submitted. Respectfully Submitted: MARIA P. COGNETTI & ASSOCIATES Date: September 4, 2003 By: MARIA P. OGN T I, ESQUIRE Attorney I.D. No. 27914 210 Grandview Avenue, Suite 102 Camp Hill, PA 17011 Telephone No. (717) 909-4060 MClosed Files\Stevens-L\Pleadings\Petition for Appointment of Arbitrators.wpd September 9, 2003 CERTIFICATE OF SERVICE I, Maria P. Cognetti, Esquire, do hereby certify that on this date I served the foregoing Petition for Appointment of Arbitrators by depositing a true and exact copy thereof in the United States mail, first class, postage prepaid, addressed as follows: Mr. Lynn Stevens 10738 Buchanan Trail East Waynesboro, PA 17268 MARIA P. COGNETTI & ASSOCIATES Date: September 9, 2003 By: MARIA . CO TTI & ASSOCIATES Attorney I.D. No. 27914 210 Grandview Avenue, Suite 102 Camp Hill, PA 17011 Telephone No. (717) 909-4060 n - n c_ -;, ?:`, ? ,.-, ?_ _.,. i. .'tl ..'J l f: ?.. i ,?' V, ?. ?` , V (? M 1 U` ipha,A-P, CdGUfTrl HdAA } ) v. ) ?-YnIAJ S3?Vr3NS ? CAiM NOTICE OF MiTRY OF We do solemnly swear (or affirm) that we will support, obey and defend the Constitution of the United States and th Constitution of this Common- wealth and chat we will discharge the dutiesof our , ce^aith Ad itv. AWARD We, the undersigned arbitrators, having been duly appointed and sworn (or affirmed), make the following award: (Note: If damages for delay are awarded, they shall be separately stated.) 1N ukhof of NaRh,Ja , bn VjFtJu.,04 G Ucyerl Arbitra applicable.) Date of Hearing:JhLt2.2g ZVD` Date of Award: zo Zao Now, award was parties or the-?6"d--ay of entered upon the their attorneys. Arbitrators' compensation to be paid upon appeal: $ c290, 6/N In The Court of Common Pleas of Cumberland County, Pennsylvania .To. 1>3_, 3i z5 ?, 1 19 AWARD hf rLLL , IF? at .,=, L.U., the above dodkket and notice hereof given by mail to the ? ? oityhyo?na Denu ?vm -v mg ?C N N U1 gCl j,n U t?Q 0. my SaZ - V O"CW , ?4-, Spa J. Mc,n-2nx-(- - (YL:ajnLs -I- 2cLE ?j b. /(3?wY LcvL - c?zu.gto?? May 19, 2004 I:\Closed Files\Stevens-UArbi[ralionWppeal from Award of Arbitm[ors.wpd MARIA P. COGNETTI, t/d/b/a : IN THE COURT OF COMMON PLEAS MARIA P. COGNETTI & ASSOCIATES, CUMBERLAND COUNTY, PENNSYLVANIA Plaintiff V. LYNN STEVENS, Defendant NO. 03- 3125 CIVIL ACTION - IN LAW NOTICE OF APPEAL FROM AWARD OF BOARD OF ARBITRATORS TO THE PROTHONOTARY: Notice is given that Maria P. Coanetti. Esquire appeals from the award of the board of arbitrators entered in this case on April 30, 2004 . A jury trial is demanded ? . (Check box if a jury trial is demanded. Otherwise jury trial i? waived.) I hereby certify that: 1. The compensation of the arbitrators has been paid, or 2 (Strike out the inapplicable clause) Date: May 19, 2004 AppellAorAt y for Appellant NOTE: The demand for jury trial on appeal from compulsory arbitration is governed by Rule 1007.1(b), (B) No affidavit or verification is required. p 4Q 7kt 7-1 P ? D A'J f ? C T (fl (t': F rt N O O .C nIM N CJi i 3 ?C`7 C) , rn -! o =? Curtis R. Long Prothonotary office of the Vrotbonotarp Cumberlanb Countp Renee K. Simpson Deputy Prothonotary John E. Slike Solicitor 03 -21-2-5 CIVIL TERM ORDER OF TERMINATION OF COURT CASES AND NOW THIS 5TH DAY OF NOVEMBER 2007 AFTER MAILING NOTICE OF INTENTION TO PROCEED AND RECEIVING NO RESPONSE - THE ABOVE CASE IS HEREBY TERMINATED WITH PREJUDICE IN ACCORDANCE WITH PA R C P 230.2. BY THE COURT, CURTIS R. LONG PROTHONOTARY One Courthouse Square • Carlisle, Pennsylvania 17013 • (717) 240-6195 • Fax (717) 240-6573