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Home My WebLink About99-06884J'. J' a` a 1 v V ' ?i Nil n O` i'; COYNE S COYNE, P.C., : IN THE COURT OF COMMON PLEAS OF Plaintiff, : CUMBERLAND COUNTY, PENNSYLVANIA V. :NO. 99- 1999 CIVIL ACTION -LAW CHAD J.STRAUSBAUGH, Defendant. 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 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 GE"r LEGAL HELP. Cumberland County Lawyer Referral Cumberland County Bar Association 2 Liberty Avenue Carlisle, PA 17013 1-800-990-9108 COYNE & COYNE, P.C., Plaintiff, V. CHAD J. STRAUSBAUGH, Defendant. IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA :NO. ?9- CIVIL ACTION - LAW COMPLAIN T I. Coyne & Coyne, P.C. is a Pennsylvania Professional Corporation with offices located at 3901 Market Street, Camp Hill, Cumberland County, Pennsylvania 17011. 2. Chad J. Strausbaugh is an adult individual residing at 117 North Lincoln Street, Palmyra, Pennsylvania 17078. 3. On or about February 2, 1999, Defendant Strausbaugh, contracted for legal services with Plaintiff concerning various matters to include child custody and child support. (A true and correct copy of the contract is attached hereto as Exhibit "A"). q• Plaintiff performed legal services for Strausbaugh and at the end of said representation, an invoice was submitted to Strausbaugh for payment. (A true and correct copy of the contract is attached hereto as Exhibit "B"). 5, Repeated demands for payment in full have been made to Strausbaugh; however, Strausbaugh has refused to pay same. 2 WHEREFORE, Plaintiff, Coyne S Coyne, P.C., respectfully requests Judgment in the amount of 54,509.44, together with Court costs and interest from date of Judgment. Respectfully submitted, COYNE S COYNE, PC Dated: /Vov. V^-- LISA MARIE COYNE, E. C 3 1 Market Street Camp Hill, PA 17011-4227 (717) 737-0464 Pa. S. Ct. No. 53788 Attorney for Plaintiff COYNE & COYNE, P.C. Attorneys at Lazv Henry F. Coyne Lisa Marie Coyne January 2S, 1999 Mr. Chad J. Strausbaugh 195 Ashford Drive Enola, PA 17025-2303-95 Re: Child Support Obligation 3901 Market Street Camp Bill, Pa. 1701111227 Telephone: (717) 737-0464 Facsimile: (717) 737-5161 Dear Chad: It was a pleasure meeting with you recently. As we discussed, the following is a written fee agreement which I ask you to review and return to me at your convenience. As I explained to you, because of the nature of the matter, and because of the possibility of the occurrence of unpredictable and unforeseen circumstances, I am not in a position to quote you a final and specific fee for my professional services. However, I indicated to you that I would represent you on an hourly basis. My fee for professional services is One Hundred Fifty Dollars (S150.00) per hour, with fractions of hours computed in periods of not less than 15 minutes, which takes into account interruption of other work. Each such hour is based upon actual work regarding your particular case. I will provide you periodic invoices for services rendered. Payments on invoices are due upon receipt. After thirty (30) days, if an invoice remains unpaid, interest will be charged on the outstanding monthly balance at the rate of One and a half Percent (1.5%), annually Eighteen Percent (18%). This office reserves the right to modify the hourly rate and the rate of interest from time to time with advance notice to you should those changes be implemented. Any out-of-pocket expenses directly attributable to your case, including but not limited to postage, court fees/filing fees, copy work, court reporter services, or travel expenses, will be charged to you at cost in addition to the fee. Legal costs and expenses incurred are the obligation of and are to be paid by the client upon billing of same. V;4C?e? {o 1I co 0.7„r_ )asa I respectfully request you to remit to me the sum of retainer fee. This retainer is to be remitted upon the return of this executed fee agreement. To the extent that the retainer is depleted, you will be provided interim invoices. It is impossible to predict a course that a domestic relations case will take. Therefore, it is important that you keep me informed of any and all changes in your life once my representation commences. "..? n Mr. Chad J. Strausbaugh January 28, 1999 Page 2 Do not make changes or take, what may see, unimportant steps without consultation with me first. Do not hesitate to ask questions. However, bear in mind that while we attempt to promptly return all telephone calls, under certain circumstances, we might have some delay in returning your calls, particularly when preparing for or in trial on another case. I am pleased to represent you in this matter, and I assure you that I will pursue your matter diligently and expeditiously. Please acknowledge receipt of this letter and your agreement to same by signing a copy and returning same in the enclosed envelope, postage prepaid. With best personal wishes to you, I remain-- Very truly yours, COYNE S. COYNE, P.C. r a Marie oyne LMC/crs Enclosure I, CHAD J. STRAUSBAUGH, have read and fully understand the statements above written. I am acknowledging my agreement to the above by signing below. Dated: CHAD I STRAUSBAUGH Law offices of Coyne L Coyne, P.C. 3901 Market Street Camp Hill PA 17011-4227 Invoice submitted to: Mr. Chad Strausbaugh 117 N. Lincoln Street Palmyra PA 17078 November 9, 1999 In Reference To:Support Invoice #11452 Interest on overdue balance Total amount of this bill Previous balance Amount $17.45 $17.45 $4,491.99 Balance due $4,509.44 ?r 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 unworn falsification to authorities under 18 Pa. C.S.A. §4904. IWA PM ?t .a LI) CJ ? ' , SHERIFF'S RETURN - OUT OF COUNTY CASE NO: 1999-06884 P COUNTYCOMMONWEAOFLCUMBERLANDTH OF COYNE & COYNE PC VS. STRAUSBAUGH CHAD J Sheriff, who being duly sworn according R. Thomas Kline for the within that he made a dgent search and inquiry to law, says, named defendant, to wit. STRAUSBAUGH CHAD J Him in his bailiwick. He tnere,.u?= but was unable to locate County, Pennsylvania. LEBANON deputized the sheriff of to serve the within NOTICE & CIVIL ACTION 1999 this office was in receipt of On November 24th, County, Pennsylvania. LEBANON the attached return from So answers:-, Sheriff's Costs: -' Docketing 19.00/?' -rii:: comas r ine, of County 8.00 Surcharge 43.0 DEP. LEBANON CO 78 0 COY14E/1999YNE Sworn and subscribed to before me this 13 day of l?r: .,,. ?•? 19 Cj? A.D. i? ,1 is l<< L` ?oc?on`o?ary / , !TICr & CJMr1J.INT No. 99-6884 CIVIL COYNE & COYNE, P.C. VS. Lebanon, PA., November 22, 1999 (RETURN TO CUMBERLAND CO. SHERIFF) DOCKET PAGE 14489 CHAD J. STRAUSBAUGH STATE OF PENNSYLVANIA ) COUNTY OF LEBANON ) SS: Charles E. Williams, Deputy Sheriff, being duly sworn according to law, deposes and says that he served the within NOTICE & COMPLAINT Upon CHAD J. STRAUSBAUGH, the within named DEFENDANT, by handing a true and attested copy thereof, personally, to Jessica M. Lingle, she being his girlfriend and person in charge at the time of service, on November 19, 1999, at 2:05 o'clock P.M., at his residencelv117 North by Lincoln Street, Palmyra (Borough), Lebanon County, Y making known to her the contents of the same. ? Sworn to and subscribed before me this 22nd day of November, A.D., 1999 Notary Public So ANSWERS, 5 I/ ' DEPUTY SHERIFF SHERIFF SHERIFF'S COSTS IF ABOVE PROCEEDINGS Advanced costs paid on 11/19/99 Check No. 26606 Amount 43.70 Costs incurred: Amount 31.30 Refund: Check. No. 74GG All Sheriff's costs shall be due and payable when services are performed, and it shall be lawful for him to demand and receive from the party instituting the proceedings, or any party liable for the costs thereof, all unpaid sheriff's fees on the same before he shall be obligated by law to make return 20, 1911, P.L. 1072 In The Court of Common Pleas of Cumberland County, Pennsylvania Coyne & Coyne, ?%:C. Chad J. Strausbaugh No 99_6884 Civil Now, 11/16/99 , 19_, I, SI-IER[FF OF CUMBERLAND COUNTY, PA, do hereby deputize the Sheriff of Lebanon County to execute this Writ, this deputation being made at the request and risk of the Plaintiff. Sheriff of Cumberland County, PA Affidavit of Service NoNv. within 19 , at o'clock M. served the upon of by handing to a copy of the original and made known to So answers, Sheriff of COSTS Sworn and subscribed before SERVICE _ me this _ day of , 19 MILEAGE _ AFFIDAVIT the contents thereof. County, PA S S (71.737-6464 v;.,, COYNE & COYNE, P.C., Plaintiffs, V. CHAD.1. STRAUSBAUGH, Defendant. TO: Mr. Chad J. Strausbaugh 117 North Lincoln Street Palmyra, PA 17078 : IN THE COURT OF COMMON PLEAS : CUMBERLAND COUNTY, PENNSYLVANIA : No. 99-6884 CIVIL TERM : CIVILACTION --LAW DATE OF NOTICE: December 10, 1999 IMPORTANT NOTICE YOU ARE IN DEFAULT BECAUSE YOU HAVE FAILED 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 (10) DAYS FROM THE DATE OF THIS NOTICE, A JUDGEMENT 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 CANNNOT 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 2 Liberty Avenue Carlisle, PA 17013 1-800.990-9108 Date: December 10, 1999 COYNE & C?OYNE, P.C. ?Lror? G'L-.?l ILI A MARIE COYNB, Esquire 3 01 Market Street Camp hill, PA 17011-4227 (717) 737-0464 Pa. S. Ct. No. 53788 Plaintiff COYNE & COYNE, P.C., : IN THE COURT OF COMMON PLEAS Plaintiffs, : CUMBERLAND COUNTY, PENNSYLVANIA No. 99-6884 CI V I1, TERM CHAD .1. STRAUSDAUGH, CIVIL ACTION -- LAW . Defendant. 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 individuals by sending the same by facsimile and first class mail, postage prepaid, addressed as follows: Mr. Chad J. Slrausbaugh 117 North Lincoln Street Palmyra, PA 17078 Dated: 10 - i.)rC +(LIANE, ESQUIRE i- r -= ?•; ?? ?' '? f` ?:, - ., , . ?.. c. .. ,, - ?c. .. :,; •' J717) 737-0464 -'` COYNE & COYNE, P.C., : IN THE COURT OF COMMON PLEAS OF Plaintiffs, : CUMBERLAND COUNTY, PENNSYLVANIA V. : NO. 99-6884 CIVIL TERM CHAD J. STRAUSBAUGH, Defendant, : CIVIL ACTION - LAW PRAECIPE FOR ENTRY OF DEFAULT.IUDGMENT FOLLOWING SERVICE OF RULE 237.1 NOTICE To The Prothonotary: Please enter judgment of default in favor of Plaintiff, Coyne & Coyne, P.C., and against Defendant, Chad J. Strausbaugh for Defendant's failure to plead to the Complaint in this action within the required time. The Complaint contains a notice to defend within 20 days from the date of service thereof. Defendant was served with the Complaint on November 19, 1999, and Defendant's answer was due to be filed on December 9, 1999. Attached as Exhibit "A" is a copy of Plaintiffs written Notice of Intention to File Praecipe for Entry of Default Judgment, which I certify was mailed by regular mail to the Defendant at his last known address and to his attorney of record on December 10, 1999, which is at least 10 days prior to the filing of this Praecipe. Please assess damages in the amount of $4,509.44 plus court costs and interest from November 10, 1999, being the amount demanded in the Complaint. Dated: O TUL S(JS(1 Lt ?/t,-- L )9A MARIE COYN , ESQUIRE 'Coyne & Coyne, P.C. 3901 Market Street Camp Hill, PA 17011-4227 (717) 737-0464 Pa. S. Ct. No. 53788 li..i? FC / 5/`. D ` r G r- COYN & COYNE, P.C., : IN THE COURT OF COi ENION PLEAS - v ' LA Plaintiffs, : CUMBERLAND COUNTY, PENNSYLVA:N 4 V. No. 99-6884 CIVIL. TERil1 CHAD J. STRAUSBAUGH, Defendant. CIVIL ACTION- LAN ni TO: Mr. Chad J. Strausbaugh G71 c 117 North Lincoin Street - Palmyra, PA 17078 - = DATE OF NOTICE: December 10, 1999 BTORTANT NOTICE YOU ARE IN DEFAULT BECAUSE YOU HAVE FAILED 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 (10) DAYS FROM THE DATE OF THIS NOTICE, A JUDGEMENT 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 CANNNOT 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 2 Liberty Avenue Carlisle, PA 17013 1-800-990-9108 Date: December 10, 1999 COYNE & COYNE, P.C. LIVA MARIE CO`(NE, Esquire 3901 Market Street Camp Hill, PA 170114227 (717) 737-0464 Pa. S. Ct. No. 53788 Plaintifj- COYNE & COYNE, P.C., : L N THE COURT OF COiVIri ION PLEAS Plaintiffs, : CUMBERLAND COUNTY, PENNSYLVANIA V. No. 99-6884 CIVIL. TERiiN1 CHAD J. STRAUSBAUGH, Defendant CIVEL ACTION -LAW . CERTIFICATE OF SERVICE I, Lisa Marie Coyne, Esquire, hereby certify that a true copy of Plaintiffs Ten Day Notice of Default was served upon the below-referenced individuals by sending the same by facsimile and first class mail, postage prepaid, addressed as follows: Mr. Chad J. Strausbaugh 117 North Lincoln Street Palmyra, PA 17078 Dated: 10- Dec -91 - MARIE CO ,ESQUIRE 4 T O ? Q `n 60 - O IN THE COURT OF COMMON PLEAS OF CUMIIF.RLAND COUNTY PENNSYLVANIA Civil, DIVISION COYNE & COYNE, P.C., Plaintiff, V. CHAD J. STRAUSBAUGI I, Defendant. File No. 99-6884 Amount Due: 84,509.44 Interest: From November 11, 1999 Ally's Commission: Costs: TO THE PROTHONOTARY OF THE SAID COUNTY: The undersigned hereby certifies that the below does not arise out of a retail installment sale, contract, or account based on a confession of judgment, but if it does, it is based on the appropriate original proceeding filed pursuant to Act 7 of 1966 as amended; and for real property pursuant to Act 6 of 1974 as amended. PRAECIPE FOR E\ECl1TION Issue writ of execution in the above matter to the Sheriff of LEBANON COUNTY, for debt, interest and costs upon the following described property of the defendant: levy on all furniture, electronic equipment, automobile equipment, tools, supplies, furnishings, and property located at Defendant's residence of 117 N. Lincoln Street, Palmyra, Lebanon County, Pennsylvania and 647 E. Main Street, Annville, Lebanon County, Pennsylvania and R.D. No. 1, Box 1900, Monroe Valley Road, Jonestown, Lebanon County, Pennylvania. Levy and seize Defendant's motor vehicles: 1. 1996 Dodge Truck Tag No. Autobdy VIN No. 3B7HF13YOT615291S 2. 1986 Chevy Truck 'rag No. CCV4674 VIN No. IGSEKI8C6GF111450 3. 1982 Florida Tag No. AJF28 VIN NO. A12RC0714CM000326 Date: I I A-v C- q5 ¢S LISA/MARIE COYNE, ESPUIRE Att cy for the Plaintiff 3901 Market Street Camp Hill, PA 17011-4227 (717) 737-0464 Pa.. Supreme Ct. No. 53788 O O? I WRIT OF EXECUTION and/or ATTACHMENT COMMONWEALTH OF PENNSYLVANIA) NO. COUNTY OF CUMBERLAND) TO THE SHERIFF OF Lebanon COUNTY: 99-6884 Civil Term_ CIVIL ACTION - LAW To satisfy the debt, interest and costs due Coyne & Coyne, P.C. from Chad J. Strausbaugh, 117 N. Lincoln Street, Palmyra, Lebanon County, PA and 647 E. Main Street, Annville, Lebanon County, PA and R.D.No. 1, Box 1900, Monroe Valley Road, Jonestown, Lebanon County, PA DEFENDANT(S) (1) You are directed to levy upon the property of the delendant(s) and to sell levy on all furniture, electronic equipment, automobile equipment, tools, supplies, furnishings, and property located at Defendant's residence of 117 N. Lincoln Street, Palmyra, Lebanon County, PA, and 647 E. Main Street, Annville, Lebanon County, PA and R.D.No. 1, Box 1900, Monroe Valley Road, Jonestown, Lebanon County, PA Le3W_a SI--S4'i zP Defendant's motor vehicles: 1. 1996 Dodge Truck Tag No. Autobdy 11 VIN No. 3B7HF13YOT6152918; 2. 1986 Chevy Truck Tag No. CCV4674 VIN No. 1G8EK18C6GF111450; 3. 1982 Honda Tag No. AJF28 VIN No. JH2RC0714CM000326 GARNISHEE(S) as follows: and to notify the garnishee(s) that: (a) an attachment has been issued; (b) the garnishee(s) is/are enjoined from paying any debt to or for the account of the defendant(s) and from delivering any property of the defendant(s) or otherwise disposing thereof; (3) liproperlyof thedefendant(s) not levied upon an Subject to attachment is found in the possession of anyone other than a named garnishee, you are directed to notify hinvher that he/she has been added as a garnishee and is enjoined as above stated. Amount Due $4,509.44 Interest from November 11, 1999 Ally's Comm % Ally Paid $150.70 Plaintiff Paid Date: Augua 15 2000 REOUESTING PARTY: Name Lisa Marie Coyne, Esq. Address: 3901 Market Street Canto Hill, PA 17011-4227 Attorney for: Plaintiff Telephone: 717-737-0464 Supreme Court ID No. 53788 L.L. $.50 Due Prothy $1.00 Other Costs Prothonotary, Civil Division Deputy