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Home My WebLink About07-5980. .. IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY PErdNSYLVANIA CIVIL ACTION - LAW CIPRIANI & WERNER, P.C Plaintiff D'I - 59gD Ci v i I mum VS. SEAN COURTNEY McLAUGHLIN Defendant COMPLAINT 1. Plaintiff, Cipriani & Werner, P.C. (hereinafter "Plaintiff") is a Pennsylvania corporation duly incorporated under the laws of the Commonwealth of Pennsylvania, with an office located at 1011 Mumma Road, Lemoyne, Pennsylvania, 1.7043. 2. Defendant, Sean Courtney McLaughlin. (hereinafter "Defendant") is an individual residing at 1523 Scarborough Ct. Apt. 102, West Chester, PA 19380. 3. Defendant has availed himself under the laws of the Commonwealth by cantering into an agreement with Plaintiff in Cumberland County, which was to be performed in part in Lancaster County in the state of and in accordance with the laws of the Commonwealth of Pennsylvania. FACTS 4. Plaintiff is a law firm engaged in the business of providing legal representation in the Commonwealth of Pennsylvania. 5. Plaintiff, in part, provides legal representation to individuals involved in child custody matters. 6. On or about August 15, 2005, Defendant entered into a Fee Agreement for legal services with Plaintiff. A true and correct copy of the Fee Agreement is attached hereto and marked as Exhibit "A". 7. Plaintiff provided legal services to Defendant during lengthy and protracted child custody litigation consistent with the terms of the contract from August 15, 2005 to present. A true and correct copy of Plaintiff's Bills for Legal Set-vices are attached hereto and marked as Exhibit "B". 8. Defendant is in default of the terms of the agreement having not made payments to Plaintiff. 9. Plaintiff avers that the Agreement between the parties provides that Plaintiff is entitled to interest at the rate of 6% as set forth in paragraph 2 in Exhibit A. 10. Although repeatedly requested to do so by Plaintiff, Defendant has willfully failed and/or refused to pay the principal balance, interest charges or any part thereof to Plaintiff. COUNT I: BREACH OF CONTRACT 11. Plaintiff incorporates by reference each and every of the preceding paragraphs one (1) through ten (10) as if the same were more fully set forth at length herein. 12. Defendant's refusal to pay as more fully stated above, as well as the amount incurred by Plaintiff for work performed by constitutes a breach of contract as more fully stated above for which Plaintiff is entitled a remedy. 13. Plaintiff has suffered damages as more frilly described above as a direct and proximate result of Defendant's material breach. of the agreement through their acts and/or omissions. COUNT II: UNJUST ENRICHMENT 14. Plaintiff incorporates by reference each and every of the preceding paragraphs one (1) through thirteen (13) as if the same were more fully set forth at length herein in support of its alternative claim for relief. 15. Defendant has been unjustly enriched as a result of the non-payment in the amount of $12,958.75, plus interest, which is rightfully owed to Plaintiff. 16. Plaintiff has suffered damages as more fully described above in the amount of $12,958.75, plus interest, as a direct and proximate result of the non-payment of fees, which is rightfully owed to Plaintiff by Defendant for legal services. COUNT III: DETRIMENTAL RELIANCE 17. Plaintiff incorporates by reference herein each and every of the preceding paragraphs one (1) through sixteen (16) as if the same were more fully set forth at length herein in support of its alternative claim for relief. 18. Plaintiff reasonably and justifiably relied to its detriment on. Defendant's agreement and responsibility to honor their financial obligation to Plaintiff and Defendant's representation to obtain payment for the legal services work performed by Plaintiff. 19. Plaintiff has suffered damages as more fully described above as a direct and proximate result of the non-payment, which is rightfully owed to Plaintiff by Defendant for Plaintiffs legal services. COUNT IV: BREACH OF ORAL CONTRACT 20. Plaintiff incorporates by reference herein each and every of the preceding paragraphs one (1) through nineteen (19) as if the same were more fully set forth herein in support of its alternative claim for relief. 21. The acts and omissions of the Defendant, in refusing to re-pay and/or reimburse Plaintiff for the costs associated with the work performed. by Plaintiff's employees and constitute a material breach of the oral contract more frilly described above to obtain payment from Defendant. 22. Plaintiff has suffered damages as more fully described above as a direct and proximate result of the non-payment, which is rightfully owed to Plaintiff by Defendant for Plaintiffs legal services. WHEREFORE, Plaintiff demands judgment to be entered on Counts 1, 1I,111 and IV of this Complaint against Defendant in the amount of $12,958.75 as described above with appropriate additional interest, together with costs, including attorney's fees, and all other relief that this Honorable Court shall deem appropriate. Respectfully submitted, Paul A. Cacciamani, Esquire Cipriani & Werner, P.C. Attorney for Petitioner ID #88331 Suite 201 1011 Mumma Road Lemoyne, Pennsylvania 17043-1145 (717) 975-9600 VERIFICATION I hereby affirm that the following facts are correct: Cipriani & Werner, P.C., is a Plaintiff in the foregoing action. I have read the Complaint and it is true and correct to the best of my knowledge, information and belief. I hereby acknowledge that the facts set forth in the aforesaid Complaint is made subject to the penalties of 18 Pa.C.S. 4904 relating to unsworn falsification to authorities. Dated: Aut orized Representative of Cipriani & Werner, P.C. EXHIBIT A CIPRIANI & WERNER Dennis 1'. Cullen Jr $ Dennis J. Bonetti " Lewis L. Wolfgang .lason K. Bums - Mark R. 7ogby Paul A Cacciamam -- Stephen R. 112ITI5 David H Radcliff Of Counsel Hal A. Kestler Of Counsel - Also admitted in NJ Also admitted in D C 8: NJ Board Certified Civil 'Fria] Advocate Writer's E-mail: peacciamani mc-wlaw.com Sean McLaughlin 1503 Francis Drive Coatsville, PA 18320 A PROFESSIONAL CORPORATION ATTORNEYS AT LAW Suite 201 1011 Mumma Road Lemoyne, Pennsylvania 17043-1145 Telephone (717) 975-9600 Fax: (717) 975-3846 www.C-WLAW.corn August 15, 2005 RE: Jennifer Lynne McLaughlin v. Sean Courtney McLaughlin Claim No: Our File No.: 9390-15214H FEE AGREEMENT Philadelphia Office: Suite 111 482 Norristown Road Blue Bell, PA 19422-2352 Telephone (610) 567-0700 Pittsburgh Office: Suite 700 650 Washington Road Pittsburgh, PA 15228 Telephone (412) 563-2500 Scranton Office: Suite 210 Oppenheim Building 409 Lackawanna Avenue Scranton, PA 18503-2059 Telephone (570) 347-0600 You have asked this office to represent you in the above-captioned matter. This letter setts forth the agreement concerning our fees to represent you. This agreement shall become effective upon our receipt of a countersigned copy of this letter and the retainer fee. 1. You agree to pay this office a retainer fee of $3000.00. FIVE HUNDRED AND 001!100 (5500.00) DOLLARS of this retainer shall be set aside as a non-refundable fee as it represents our minimum charge for legal services rendered. This non-refundable portion of your retainer is predicated upon the administrative spent in opening your file, setting up your accounts and records, and the assurance you have of our representation of you and our ability to you thereby precluding us from undertaking the representation of others, including your spouse. You understand our policy and agree to the non-refundable portion of your retainer. This non- refundable portion of your retainer will be credited to your billings as we spend time in your behalf. You also agree to pay additional billings pursuant to the terms set forth above. 0 0 2. Our billings will be based upon Attorney Cacciamani's hourly rate of ONE HUNDRED SEVENTY-FIVE AND 00/100 ($175.00) DOLLARS. Should your case require the services of a paralegal, that time will be billed at an hourly rate of SIXTY FIVE AND 00/100 ($65.00) DOLLARS. Examples of billable time include office conferences with the client and/or other counsel, attendance at pre-trial conference(s), depositions, attendance at Domestic Relations Section conferences, Master's Hearings, as well as trials, hearings and other appearances before a Judge and/or jury. It should be emphasized that all telephone calls made by us or to us, including your calls to us, involve the expenditure of time and are therefore billable events for which a minimum time charge of two-tenths of an hour will be added to your account. Appeals will be discussed and billed separately. Additional advanced fees may be required prior to preparation for lengthy and complicated litigation, such as custody hearings, petitions for special relief and equitable distribution hearings. Upon request, we will furnish you with a statement of fees and costs expended that are pertinent to your case. Interest at the rate of 6% shall be applied to balance outstanding for a period in excess of thirty (30) days. 3. You understand that the above-described rates are the rates currently charged by this firm. It is possible that these hourly rates may increase prior to the conclusion of your case due to inflation, increases in costs of living, costs of doing business or other reasons. You agree that you will pay our billings at such increased rates upon notification by the firm of any change in hourly rates. 4. You understand and agree that this firm is not engaged to value the marital assets or to give accounting and tax advice. We do not claim to have expertise in these regards. You must determine, based upon information obtained through the proceedings, which assets you would like to receive, the value of those assets and the economic and tax ramifications concerning the distribution and disposition of all the assets. If appropriate after discussion with us, you may determine that the experts such as accountants or financial advisors should be retained by you to assist in this regard. We do not automatically search titles, determine the validity of income and expense figures supplied, or attempt to verify other underlying data provided as part of the dissolution proceedings. If there are questions in your mind concerning any of these issues, you should discuss them with us and obtain appropriate experts to provide assistance. 5. You will be responsible for all costs which we may incur on your behalf. These costs include but are not limited to filing fees, service of process fees, transcripts, depositions, photocopies, long distance telephone calls, appraisals, witness fees and such fees for accountants, psychologists and other chosen experts as well as other costs incidental to your case. Experts who are retained, whether by us, on your behalf, or directly by you, frequently bill us for their services. You will be required to pay such fees directly. 6. On some occasions, a Court may order one spouse to pay part of or all of the other spouse's fee, expenses and recoverable court costs. Sometimes, it is possible to obtain such a result by agreement. Because fee and cost recoveries are totally unpredictable, such recoveries, if any, must be considered to be merely "on account" and the client remains primarily liable for payment of the total fee. Amounts received pursuant to a Court Order or agreement will be credited to your account. 7. We will keep you informed as to the progress of vour case from time to time. We will send you copies of all relevant documents coming in and going out of our office including important correspondence, pleadings, and other Court documents, or discuss the progress of your case with you. If we are unavailable when you telephone, every attempt will be made to return your telephone call with reasonable promptness. Every reasonable effort will be made to prosecute and/or defend your case promptly and efficiently according to legal, ethical and local practice standards. Because of the uncertainty of legal proceedings, the unpredictability of changes in the law, and many other unknown factors, we cannot and do not warrant or guarantee any results or the final outcome of your case. 8. We reserve the right to withdraw from your case if you have misrepresented or failed to disclose material facts to us, failed to follow our advice, failed to cooperate with us or for any other valid reason, including without limitation the failure to pay our fees in a timely manner. Likewise, you may discharge us at any time for any reason. You will be required to pay for the time expended to turn over the file(s) and other information to you or a substitute counsel and for the time and costs if we must proceed to court to obtain permission to withdraw. We reserve the right to exercise any retaining and/or charging liens as allowed by law. This agreement contains all of the terms of our financial arrangement with you and can only be modified by a written document signed by both parties. Please countersign this agreement and return it to me so that each of us will have a memorandum of our mutual understanding. Very truly yours, CIPRIANI & WERNER By Paul A. Cacciamani, Esquire Receipt acknow, and terms accepted: i . payment of the total fee. Amounts received pursuant to a Court Order or agreement will be credited to your account. %Ve will keep you informed as to the progress of your case from time to time. ill send you copies of all relevant documents coming in and going out of our office including impol-tant correspondence, pleadings, and other Court documents, or discuss the progress of' your case with you. If we are unavailable when you telephone, every attempt will be made to return your telephone call with reasonable promptness. Every reasonable effort be made to prosecute andor defend your case promptly and efficiently according to legal, ethical and local practice standards. Because of the uncertainty of legal proceedings, the unpredictability of changes in the law, and many other unknown factors, we cannot and do not warrant or guarantee any results or the final outcome of your case. g. We reserve the right to withdraw from your case if you have misrepresented or failed to disclose material facts to us, failed to follow our ad%. ice, fulled to cooperate with us or for anv other valid reason, including without limitation the failure to pay our fees in a timely manner. Llke«ise, you may discharge us at any time for any reason. You will be required to pay for the time expended to turn over the file(s) and other information to you or a substitute counsel and for the time and costs if WC must proceed to court to obtain permission to wlthdra,,? % e reserve the right to exercise any retaining andlor charging liens as allowed by law. This ae-reement contains all of the terms of our financial arrangement with you and can only be modified by a written document signed by both parties. Please countersign tills agreement and return it to me so that each of us will hay e a memorandum of our mutual understandin«. y'ery truly yours, CiPRIANi & WERNFR. r ?:- 3111 r?.. ?_aC lainanl, SiIL'1 ---- Receipt ackrno%?. and terms accept.cd: sca11 IcLfi11 h?in jr EXHIBIT B . . Cipriani & Werner, P.C. 650 Washington Road Suite 700 Pittsburgh, PA 15228 EIN #: 25-1779527 PHONE: (412) 563-2500 Sean McLaughlin 1503 Francis Drive Coatsville, PA 18320 September 24, 2005 # 22039 In reference to: CLAIM NO: OUR FILE: 9390-15214H Jenn ifer Lynne McLaughlin v. Sean Courtney McLaughlin Hours Amount 8/5/2005 PAC Draft Answer to Petition for Special Relief and Modification of 0.60 105.00 Custody Order 8/11/2005 PAC Meet with client to discuss future course of litigation 1.20 210.00 8/12/2005 PAC Draft, file and serve Praecipe for Appearance 0.30 52.50 8/1212005 PAC Phone conference with opposing counsel regarding Monday's 0.20 35.00 hearing 8/12/2005 PAC Phone conference with client regarding hearing on Monday, 0.20 35.00 August 15, 2005 8/12/2005 PAC Prepare for hearing 1.50 262.50 8/15/2005 PAC Travel to and from Lancaster, PA to attend hearing 2.00 350.00 8/15/2005 PAC Attend pre-hearing meeting with client/attend 2.00 350.00 hearing/post-hearing discussion with client/file Answer to Petition to Modify Custody Order at Prothonotary 8/15/2005 PAC Letter to Plaintiffs counsel enclosing Answer to Plaintiffs 0.10 17.50 Petition for Special Relief and Modification of a Custody Order 8/15/2005 PAC Fee Agreement Letter 0.20 35.00 8/15/2005 PAC Phone conference with client regarding additional concerns 0.10 17.50 regarding PFA 8116/2005 PAC Letter to Plainitffs counsel regarding communication between 0.20 35.00 our client's i l Cipriani & Werner, P.C. Page: 2 8/16/2005 PAC Letter to client regarding yesterday's hearing events 0.40 70.00 8/18/2005 PAC Phone conference with counsel regarding children's school 0.20 35.00 and pick-up and drop off times 8/18/2005 PAC Phone conference with client regarding children's school and 0.20 35.00 times for custody exchanges 8/22/2005 PAC Receipt and review correspondence from Plaintiffs counsel 0.20 35.00 enclosing additional pleadings and time of scheduled conference 8/22/2005 PAC Letter to client regarding date and time of upcoming hearing 0.40 70.00 as well as status 8/25/2005 PAC Meet with Client to discuss status 0.60 105.00 8/25/2005 PAC Phone conference with court regarding continuance 0.10 17.50 8/26/2005 PAC Draft Continuance Request 0.20 35.00 9/1/2005 PAC Phone conference with client regarding harrassing behavior of 0.10 17.50 plaintiff 9/2/2005 PAC Receipt and review letter, documents and order from Attorney 0.40 70.00 D'Ambrosio 9/2/2005 PAC Phone conference with client regarding Domestic relations 0.20 35.00 issue 9/12/2005 PAC Phone conference with client regarding continuance/mother's 0.20 35.00 move to Chester County For professional services rendered 11.80 2,065.00 Attorney Rate Summary Attorney Hours Rate Amount Paul A. Cacciamani 11.80 175.00 2,065.00 Total Current Billing: 2,065.00 Previous Balance Due: 0.00 Total Now Due: 2,065.00 Cipriani & Werner, P.C. 650 Washington Road Suite 700 Pittsburgh, PA 15228 EIN #: 25-1779527 PHONE: (412) 563-2500 Sean McLaughlin 1503 Francis Drive Coatsville, PA 18320 October 24, 2005 # 22402 In reference to: CLAIM NO: OUR FILE: 9390-15214H Jennifer Lynne McLaughlin v. Sean Courtney McLaughlin Hours 9/21/2005 PAC Phone conferences with client regarding Chester Co. Sheriff 0.20 9/21/2005 PAC Phone conference with Chester Co. Sheriff 0.20 9/21/2005 PAC Receipt and review time-stamped Motion for Continuance and 0.20 Notice of rescheduled conference date 9/21/2005 PAC Letter to client enclosing notice of rescheduled custody 0.10 conference 9/21/2005 PAC Letter to Christine Laney enclosing notice of rescheduled 0.10 custody hearing 10/3/2005 PAC Phone conferences with Client/Lancaster Co DR/letters to 0.50 Lancaster Co DR Amount 35.00 35.00 35.00 17.50 17.50 87.50 For professional services rendered 1.30 227.50 Attorney Rate Summary Attorney Hours Paul A. Cacciamani 1.30 Expenses 9/27/2005 Lancaster Co. Prothonotary Rate Amount 175.00 227.50 86.25 Sub-total Expenses: 86.25 Cipriani & Werner, P.C. Page: 2 Total Current Billing: 313.75 Previous Balance Due: 2,065.00 Total Now Due: 2,378.75 Cipriani & Werner, P.C. 650 Washington Road Suite 700 Pittsburgh, PA 15228 EIN #: 25-1779527 PHONE: (412) 563-2500 Sean McLaughlin 1100 West Chester Pike Unit J-15 West Chester, PA 19382 January 20, 2006 # 24369 In reference to: CLAIM NO: OUR FILE: 9390-15214H Jenn ifer Lynne McLaughlin v. Sean Courtney McLaughlin Hours Amount 10/25/2005 PAC Letter to Attorney Laney enclosing Order and Custody 0.20 35.00 Agreement 10/25/2005 PAC Phone conferences with opposiing counsel regarding 0.30 52.50 stipulation 11/8/2005 PAC Phone conference with opposing counsel regarding current 0.30 52.50 custody situation 11/8/2005 PAC Phone conferences with client regarding custody 0.40 70.00 situation/current issues 11/9/2005 PAC Phone conference with client regarding custody situation 0.20 35.00 11/9/2005 PAC Additional phone conferences with client regarding updated 0.50 87.50 custody situation 11/9/2005 PAC Phone conferences with children's school to determine why 0.30 52.50 they were not allowed to go with client 11/10/2005 PAC Phone conference with client regarding status/future course of 0.20 35.00 litigation 11/11/2005 PAC Phone conference with client regarding current custody 0.20 35.00 situation/potentially filing Petition for Special Relief 11114/2005 PAC Se\eral phone conferences with client regarding current 0.50 87.50 de\elopments in custody case 11/14/2005 PAC Letter to opposing counsel regarding custody situation 0.40 70.00 Cipriani & Werner, P.C. Page: 2 11/14/2005 PAC Letter to Hope Krapf regarding vehicle 0.20 35.00 11/18/2005 PAC Phone conference with client regarding status/custody 0.20 35.00 situation has improved 11/21/2005 PAC Phone conference with client regarding most recent episode 0.20 35.00 involving Mother's boyfriend 11/21/2005 PAC Letter to opposing counsel regarding most recent episode 0.20 35.00 involving Mother's boyfriend 11/28/2005 PAC Phone conferences with client regarding recent events/Petition 0.70 122.50 for Modification of Custody Order 12/1/2005 PAC Meet with client to discuss Custody situation/ Modification 1.00 175.00 Petition 12/1/2005 PAC Draft Modification Petition 1.20 210.00 12/5/2005 PAC Phone conference with client regarding automobile 0.20 35.00 status/driver's license status 12/7/2005 PAC Receipt and review letter from Attorney Schindler regarding 0.10 17.50 status 12/7/2005 PAC Phone conference with client regarding automobile status 0.10 17.50 12/8/2005 PAC Phone conference with client regarding most recent event at 0.20 35.00 children's school 12/9/2005 PAC Phone conference with claimant's counsel regarding 0.40 70.00 Emergency Petition and Hearing 12/9/2005 PAC Receipt and review Petition for Emergency Relief and Order 0.20 35.00 12/9/2005 PAC Phone conference with client regarding Petition/status 0.50 87.50 12/9/2005 PAC Prepare for emergency hearing 1.50 262.50 12/12/2005 PAC Revise Modification Petition 0.40 70.00 12/12/2005 PAC Travel to and from Lancaster PA 2.20 385.00 12/12/2005 PAC Pre-hearing conference with client regarding strategy/attend 1.90 332.50 Hearing/post hearing discussion with client/file Modification Petition 12/12/2005 PAC Draft the Affidavits of Scott and Heidi McLaughlin/ email same 0.60 105.00 to client 12/13/2005 PAC Phone conference with Tom Schindler regarding transferring 0.20 35.00 vehicle into client's name 12/14/2005 PAC Phone conferences with client regarding pick up of 0.40 70.00 children/support issues 12/14/2005 PAC Letter to Tom Schindler regarding transferring car from Hope 0.30 52.50 Krapf to client 12/16/2005 PAC Phone conferences with claimant's counsel regarding 0.40 70.00 Contempt Petition 12/16/2005 PAC Receipt and review Order regarding affidavit 0.10 17.50 Cipriani & Werner, P.C. Page: 3 12/19/2005 PAC Receipt and review faxed letter and Petition for Contempt, 0.20 35.00 Special Relief, Attorney Fees, and Modification of a Custody Order from Attorney Laney 12/19/2005 PAC Phone conference with client regarding Contempt Petition/ 0.30 52.50 hearing on Thursday 12/23/05 12/19/2005 PAC Letter to client enclosing Order 0.10 17.50 12/21/2005 PAC Draft Affidavit 0.20 35.00 12/21/2005 PAC 3 Phone conferences with client regarding tomorrow's hearing 0.40 70.00 12121/2005 PAC Phone conference with Judge Workman's chmabers to confirm 0.10 17.50 time of hearing 12/21/2005 PAC Prepare for hearing before Judge Workman 1.50 262.50 12/22/2005 PAC Travel to and from lancaster to attend next hearing before 2.20 385.00 Judge Workman 12/22/2005 PAC Meet with client prior to hearing before Judge Workman/attend 1.50 262.50 hearing before Judge Workman 12/22/2005 PAC Phone conference with client regarding outcome of hearing 0.40 70.00 12/27/2005 PAC Phone conference with client regarding custody schedule over 0.20 35.00 the weekend 1/9/2006 PAC Receipt and review of Notice and Order with copy of Petition 0.20 35.00 for Contempt, Special Relief, Attorney Fees, and Modification 1/9/2006 PAC Phone conference with client regarding upcoming 0.20 35.00 conference/current status 1/10/2006 PAC Letter to Attorney Schindler regarding the motor vehicle issue 0.20 35.00 1/10/2006 PAC Receipt and review of letter from Attorney Schindler regarding 0.10 17.50 car payments to Hope Krapf 1/10/2006 PAC Receipt and review of Order regarding transportation 0.10 17.50 1/11/2006 PAC Letter to client regarding motor vehicle 0.40 70.00 1/11/2006 PAC Phone conference with opposing counsel regarding upcoming 0.20 35.00 hearing For professional services rendered 25.40 4,445.00 Attorney Rate Summ ary Attorney Hours Rate Amount Paul A. Cacciamani 25.40 175.00 4,445.00 Payments 10/31/2005 Payment 1,000.00 Sub-total Payments: 1,000.00 Cipriani & Werner, P.C. Page: 4 Total Current Billing: 4,445.00 Previous Balance Due: 1,378.75 Total Now Due: 5,823.75 Cipriani & Werner, P.C. 650 Washington Road Suite 700 Pittsburgh, PA 15228 EIN #: 25-1779527 PHONE: (412) 563-2500 Sean McLaughlin 1100 West Chester Pike Unit J-15 West Chester, PA 19382 February 20, 2006 # 24965 In reference to: CLAIM NO: OUR FILE: 9390-15214H Jennifer Lynne McLaughlin v. Sean Courtney McLaughlin Hours Amount 1/13/2006 PAC Phone conference with Tom Schindler, counsel for Hope 0.30 52.50 Krapf, regarding motor vehicle issue 1/13/2006 PAC Phone conference with client regarding motor vehicle issue 0.20 35.00 1/16/2006 PAC Letter to Tom Schindler regarding motor vehicle issue 0.20 35.00 1/18/2006 PAC Phone conference with client regarding upcoming 0.20 35.00 hearing/status of vehicle/custody issues 1/24/2006 PAC Phone conference with client regarding status 0.10 17.50 1/30/2006 PAC Prepare for Custody Conference 1.50 262.50 1/31/2006 PAC Travel to and from Lancaster PA to attend Custody 2.20 385.00 Conference 1/31/2006 PAC Pre-Conference meeting with Client/attend Conciliation 2.50 437.50 Conference/Post Conference Discussion 1/31/2006 PAC Letter to counsel regarding Kevin Coyl 0.20 35.00 2/16/2006 PAC Letter to Sean McLaughlin enclosing Notice of Pre-Hearing 0.20 35.00 conference 2/16/2006 PAC Phone conference with client regarding upcoming 0.10 17.50 heaing/prospective driver For professional services rendered 7.70 1,347.50 Cipriani & Werner, P.C. Attorney Rate Summary Attorney Paul A. Cacciamani Page: 2 Hours Rate Amount '- 7.70 175.00 1,347.50 Total Current Billing: 1,347.50 Previous Balance Due: 5,823.75 Total Now Due: 7,171.25 Cipriani & Werner, P.C. 650 Washington Road Suite 700 Pittsburgh, PA 15228 EIN #: 25-1779527 PHONE: (412) 563-2500 Sean McLaughlin 1100 West Chester Pike Unit J-15 West Chester, PA 19382 April 18, 2006 # 26315 In reference to: CLAIM NO: OUR FILE: 9390-15214H Jennifer Lynne McLaughlin v. Sean Courtney McLaughlin Hours Amount 2/17/2006 PAC Receipt and review of Order scheduling Pre-Trial Conference 0.20 35.00 for April 17, 2006 and Custody Hearing for April 19, 2006 2/17/2006 PAC Letter to Sean McLaughlin enclosing Orders scheduling 0.10 17.50 Pre-Trial Conference and Custody Hearing 2117/2006 PAC Draft Affidavit of Brian Oxley 0.30 52.50 2/17/2006 PAC Phone conference with client regarding behavior of Mother's 0.10 17.50 paramour toward the minor child Aaron. 2/2012006 PAC Phone conference with client regarding Affidavit of Brian Oxley 0.10 17.50 2/21/2006 PAC Receipt and review of Affidavit of Brian Oxley 0.10 17.50 2/21/2006 PAC Letter to Attorney Laney enclosing affidavit of Brian Oxley 0.20 35.00 2/21/2006 PAC Receipt and review of letter from Attorney Laney regarding 0.10 17.50 Affidavit of Mr. Oxley 2/21/2006 PAC Phone conferences with client regarding custody schedule 0.20 35.00 2/27/2006 PAC Phone conference with client regarding hearing on 3/2/06 in 0.10 17.50 Dauphin County 3/1/2006 PAC Phone conferences with client regarding hearing in Dauphin 0.30 52.50 County 3/1/2006 PAC Phone conferences with District Justice Michael Smith 0.30 52.50 3/1/2006 PAC Phone conference with Co-Counsel John Lischau regarding 0.30 52.50 . Cipriani & Werner, P.C. Page: 2 status of hearing in Harrisburg, PA/future course of criminal litigation 3/2/2006 PAC Phone conference with District Justice's office regarding 0.10 17.50 rescheduling of hearing 3/2/2006 PAC Phone conference with Co-Counsel John Lischau regarding 0.10 17.50 rescheduling of hearing 3/21/2006 PAC Phone conference with client regarding current status 0.10 17.50 3/23/2006 PAC Phone conference with opposing counsel regarding status 0.30 52.50 3/23/2006 PAC Letter to oppposing counsel regarding her request for 0.20 35.00 continuance 3/27/2006 PAC Phone conference with client regarding status of 0.20 35.00 litigation/resolution of same 3/28/2006 PAC Phone conference with client regarding continuing litigation for 0.30 52.50 six months/sale of marital home 3/29/2006 DJB Letter to Christine Laney enclosing two signed Uncontested 0.20 35.00 Motions for Continuance and Waiver of Custody Case Time Requirements 3/29/2006 PAC Receipt and review of letter from Attorney Laney with two 0.10 17.50 Uncontested Motions for Continuance 3/29/2006 PAC Letter to opposing counsel enclosing request for continuance 0.20 35.00 4/6/2006 PAC Phone conference with client regarding affidavit/recent 0.20 35.00 situation regarding corporal punishment of children 4/7/2006 PAC Phone conference with opposing counsel regarding status of 0.20 35.00 continuance/new hearing date 4/11/2006 PAC Phone conference with opposing counsel regarding 0.10 17.50 rescheduled heairng date 4/11/2006 PAC Phone conference with client regarding rescheduled hearing/ 0.30 52.50 future course of action with regard to the ongoing litigation 4/11/2006 PAC Letter to client regarding date and time of regarding-scheduled 0.20 35.00 hearing For professional services rendered 5.20 910.00 Attorney Rate Summary Attorney Hours Rate Amount Dennis J. Bonetti 0.20 175.00 35.00 Paul A. Cacci amani 5.00 175.00 875.00 Payments 4/ 11 /2006 Write-off 1,000.00 Cipriani & Werner, P.C. Page: 3 Sub-total Payments: 1,000.00 Total Current Billing: 910.00 Previous Balance Due: 6,171.25 Total Now Due: 7,081.25 Cipriani & Werner, P.C. 650 Washington Road Suite 700 Pittsburgh, PA 15228 EIN #: 25-1779527 PHONE: (412) 563-2500 Sean McLaughlin 1100 West Chester Pike Unit J-15 West Chester, PA 19382 June 20, 2006 # 27760 In reference to: CLAIM NO: OUR FILE: 9390-15214H Jenn ifer Lynne McLaughlin v. Sean Courtney McLaughlin Hours Amount 4/13/2006 PAC Receipt and review of Notices rescheduling Pre-Hearing 0.20 35.00 Conference and Custody Hearing 4/13/2006 PAC Letter to Sean McLaughlin enclosing Notices rescheduling 0.10 17.50 Pre-Hearing Conference and Custody Hearing 4/27/2006 PAC Phone conference with client regarding Affidavit of Erica 0.20 35.00 Higgins/strategy for future course of litigation 518/2006 PAC Phone conference with client regarding current status/affidavit 0.20 35.00 of Erin Higgins 5/8/2006 PAC Letter to client regarding driver affidavit and psychologist 0.20 35.00 5/12/2006 PAC Receipt and review of signed affidavit of Erin Higgins 0.10 17.50 5/12/2006 PAC Letter to Christine Laney enclosing Affidavit of Erin Higgins 0.20 35.00 5/15/2006 PAC Phone conference with client regarding exercising custody 0.20 35.00 rights with new driver 5/22/2006 PAC Phone conference with client regarding children's moving to 0.20 35.00 Chester County and enrollment in different school 5/23/2006 PAC Phone conferences with Kelly of Lancaster Landscaping 0.10 17.50 regarding incarceration 5/2312006 PAC Phone conference with District Attorney's office regarding 0.20 35.00 charges Cipriani & Werner, P.C. 5/23/2006 PAC Phone conference with Clerk of Courts regarding charges 5/23/2006 PAC Phone conference with Lancaster County Prison confirming incarceration/ verifying charges 5/23/2006 PAC Travel to Lancaster, PA to meet with Client 5/23/2006 PAC Meet with Client/travel to Lancaster County Courthouse to discuss charges with Judge/travel to Lancaster County Domestic Relations to attempt to resolve same 5/25/2006 PAC Phone conference with client regarding request for Domestic Relations documentation 5/31/2006 PAC Phone conference with client regarding children's school choice/domestic relation support issues 6/7/2006 PAC Phone conference with client regarding Mother calling police on children For professional services rendered Attorney Rate Summary Attorney Paul A. Cacciamani Page: 2 0.10 17.50 0.20 35.00 2.10 367.50 1.80 315.00 0.10 17.50 0.20 35.00 0.20 35.00 6.60 1,155.00 Hours Rate Amount 6.60 175.00 1,155.00 Total Current Billing: 1,155.00 Previous Balance Due: 7,081.25 Total Now Due: 8,236.25 a > Cipriani & Werner, P.C. 650 Washington Road Suite 700 Pittsburgh, PA 15228 EIN #: 25-1779527 PHONE: (412) 563-2500 Sean McLaughlin 1100 West Chester Pike Unit J-15 West Chester, PA 19382 July 20, 2006 # 28403 In reference to: CLAIM NO: OUR FILE: 9390-15214H Jennifer Lynne McLaughlin v. Sean Courtney McLaughlin Hours Amount 6/21/2006 PAC Phone conference with client regarding current status 0.40 70.00 6/23/2006 PAC Draft, file and serve request for continuance 0.30 52.50 6/29/2006 PAC Receipt and review of letter from Attorney Laney regarding 0.10 17.50 continuance of hearing 6/30/2006 PAC Phone conference with claimant's counsel regarding status 0.20 35.00 6/30/2006 PAC Phone conferences (2) with client regarding school issue 0.30 52.50 717/2006 PAC Phone conference with oppposing counsel school issue 0.20 35.00 7/7/2006 PAC Phone conference with client regarding school issue/upcoming 0.50 87.50 hearing/strategy for resolution 7/12/2006 PAC Receipt and review of signed motion for continuance from 0.10 17.50 Attorney Laney with letter and unavailable dates 7/12/2006 PAC Phone conferences (3) with client regarding child abuse 0.40 70.00 allegations For professional services rendered 2.50 437.50 Attorney Rate Summary Attorney Hours Rate Amount Paul A. Cacciamani 2.50 175.00 437.50 Cipriani & Werner, P.C. Page: 2 Total Current Billing: 437.50 Previous Balance Due: 8,236.25 Total Now Due: 8,673.75 4 • Cipriani & Werner, P.C. 650 Washington Road Suite 700 Pittsburgh, PA 15228 EIN #: 25-1779527 PHONE: (412) 563-2500 Sean McLaughlin 1100 West Chester Pike Unit J-15 West Chester, PA 19382 September 21, 2006 # 29704 In reference to: CLAIM NO: OUR FILE: 9390-15214H Jennifer Lynne McLaughlin v. Sean Courtney McLaughlin Hours Amount 7/13/2006 PAC Draft Emergency Petition for Custody/Proposed Order 1.40 245.00 7/13/2006 PAC Phone conference with client regarding Petition for Emergency 0.30 52.50 Relief 7/13/2006 PAC Receipt and review of documents faxed from client 0.20 35.00 7/14/2006 PAC Letter to Christine Laney attaching Notice of Presentation and 0.20 35.00 Petition for Emergency Relief 7/1412006 PAC Prepare for hearing before Judge Workman 1.20 210.00 7/17/2006 PAC Travel to and from Lancaster, PA to attend hearing on 2.20 385.00 Emergency Petition 7/17/2006 PAC Attend pre-meeting with client regarding Petition and evidence 1.40 245.00 in support of Petition /attend Hearing regarding Petition/ post-hearing discussion with client and opposing counsel regarding future course of litigation 7/18/2006 PAC Letter to client regarding summary of hearing events 0.60 105.00 7/20/2006 PAC Letter to client enclosing Judge Workman's Order/analysis of 0.20 35.00 same 7/24/2006 PAC Letter to Sean McLaughlin enclosing Notice rescheduling 0.20 35.00 Custody/Contempt hearing for September 14, 2006 7/24/2006 PAC Receipt and review of Notice rescheduling Custody/Contempt 0.20 35.00 Hearing for September 14, 2006 4 0 Cipriani & Werner, P.C. Page: 2 7/24/2006 PAC Letter to Christine Laney enclosing notice of rescheduled 0.10 17.50 Custody/Contempt Hearing 7/24/2006 PAC Phone conference with client regarding outcome and analysis 0.20 35.00 of Protection From Abuse case 7/25/2006 PAC Receipt and review of Order rescheduling Pre-Trial Conference 0.20 35.00 for September 7, 2006 7/2512006 PAC Letter to Sean McLaughlin enclosing copy of Order 0.10 17.50 rescheduling Pre-Trial Conference for September 7, 2006 7/25/2006 PAC Phone conference with client regarding Mother's no 0.20 35.00 show/school issues 7/26/2006 PAC Phone conference with John Laschau regarding Protection 0.20 35.00 From Abuse matter 7/26/2006 PAC Receipt and review of proposed Stipulation for Modification of 0.20 35.00 Custody/additonal requested file materials 7/27/2006 PAC Phone conference with client regarding Custody Stipulation 0.20 35.00 7/27/2006 PAC Letter to co-counsel John Lachall regarding proposed Custody 0.20 35.00 Stipulation 8/7/2006 PAC Phone conference with client regarding recent events/custody 0.40 70.00 stipulation/future course of litigation 819/2006 PAC Phone conference with client regarding outcome Courtney's 0.20 35.00 psychiatric evaluation 8/15/2006 PAC Phone conference with client regarding Courtney's situation 0.20 35.00 with Jennifer and Kevin last evening 8/1512006 PAC Letter to opposing counsel regarding status 0.20 35.00 8/17/2006 PAC Phone conference with Chester Co CYF regarding report 0.20 35.00 8/21/2006 PAC Phone conference with Lancaster County Domestic Relations 0.20 35.00 8/21/2006 PAC Phone conference with client regarding tomorrow's DR hearing 0.30 52.50 8/21/2006 PAC Receipt and review of Order of Court scheduling 0.10 17.50 support/contempt hearing for August 22, 2006 from Mr. McLaughlin 8/21/2006 PAC Letter to client regarding Domestic Relations hearing 0.20 35.00 8/22/2006 PAC Phone conference with client regarding hearing 0.20 35.00 results/strategy for future course of litigation 8/30/2006 PAC Phone conference with client regarding possible resolution 0.20 35.00 8/30/2006 PAC Letter to opposing counsel regarding resolution 0.40 70.00 8130/2006 PAC Follow up phone conference with client regarding options for 0.20 35.00 resolution of outstanding litigation 8/31/2006 PAC Draft Pre-Trial Memorandum/prepare exhibits 2.00 350.00 8/31/2006 PAC Phone conferences (4) with client regarding resolution 0.50 87.50 • ? Cipriani & Werner, P.C. Page: 3 8/31/2006 PAC Phone conferences (3) with opposing counsel regarding 0.40 70.00 resolution 9/1/2006 PAC Phone conference with opposing counsel regarding settlement 0.30 52.50 9/1/2006 PAC Phone conference with client regarding resolution 0.10 17.50 9/6/2006 PAC Phone conference with opposing counsel regarding 0.20 35.00 cancellation of tomorrow's conference/status of stipulation 9/6/2006 PAC Phone conference with client regarding cancellation of 0.20 35.00 tomorrow's conference/status of stipulation/ affidavit of new driver 9/6/2006 PAC Letter to opposing counsel regarding resolution 0.20 35.00 9/7/2006 PAC Receipt and review of proposed custody agreement from 0.20 35.00 Attorney Laney 9/8/2006 PAC Phone conference with client regarding opposing counsel's 0.50 87.50 proposal/ discuss counter-proposal 9/8/2006 PAC Phone conference with opposing counsel regarding settlement 0.30 52.50 9/8/2006 PAC Phone conference with client regarding additional settlement 0.30 52.50 proposals 9/13/2006 PAC Phone conference with opoosing counsel regarding changes 0.20 35.00 to stipulation 9/13/2006 PAC Phone conference with client regarding changes to 0.20 35.00 stipulation/status of affidavit for new driver For professional services rendered 18.30 3,202.50 Attorney Rate Summary Attorney Hours Rate Amount Paul A. Cacciamani 18.30 175.00 3,202.50 Payments 8/28/2006 Payment 1,000.00 Sub-total Payments: 1,000.00 Total Current Billing: 3,202.50 Previous Balance Due: 7,673.75 Total Now Due: 10,876.25 A 0 Cipriani & Werner, P.C. 650 Washington Road Suite 700 Pittsburgh, PA 15228 EIN #: 25-1779527 PHONE: (412) 563-2500 Sean McLaughlin 1100 West Chester Pike Unit J-15 West Chester, PA 19382 November 21, 2006 # 30910 In reference to: CLAIM NO: OUR FILE: 9390-15214H Jenn ifer Lynne McLaughlin v. Sean Courtney McLaughlin Hours Amount 9/18/2006 PAC Phone conferences (x4) with opposing counsel regarding 0.40 70.00 stipulation/ continuance for tomorrow's hearing/mother's failure to pick the children up from school 9/18/2006 PAC Phone conference with client (x4)regarding stipulation/ 0.40 70.00 continuance for tomorrow's hearing/mother's failure to pick the children up from school 9/19/2006 PAC Phone conference with client regarding outcome of Domestic 0.30 52.50 Relations Contempt Hearing 9/20/2006 PAC Receipt and review of Petition for Entry of Custody Agreement 0.30 52.50 9/20/2006 PAC Phone conference with client regarding status of 0.20 35.00 Stipulation/Petition filed 9/20/2006 PAC Phone conference with claimant's counsel regarding status of 0.20 35.00 Stipulation/Petition filed 9/22/2006 PAC Extended phone conferences (4) with client attempting to 0.90 157.50 resolve matter 9/22/2006 PAC Extended phone conferences (3) with opposing counsel 0.60 105.00 attempting to resolve 9/25/2006 PAC Travel to Lancaster, PA to attend hearing 1.00 175.00 9/25/2006 PAC Confemece with client prior to hearing/conference with 1.80 315.00 opposing counsel/attend hearing before Judge Workman % I# Cipriani & Werner, P.C. 9/25/2006 PAC Travel from Reading to Lancaster, PA (8) meet with opposing counsel to dicsuss Stipulation(.2)/ travel from Lancaster to West Chester (1.2) Meet with Client (AyTravel from West Chester back to Lancaster (1.1) meet with oppsoing counsel regarding Stipulation (2) Travel from Lancaster back to Harrisburg (1.1) 9/26/2006 PAC Letter to client regarding summary of hearing/future course of litigation 9/29/2006 PAC Receipt and review Order from Judge Workman regarding Custody Stipulation 9/29/2006 PAC Draft letter to client enclosing Order 10/3/2006 PAC Phone conference with client regarding Order For professional seNces rendered Attorney Rate Summary Attorney Paul A. Cacciamani Page: 2 5.00 875.00 0.40 70.00 0.10 17.50 0.10 17.50 0.20 35.00 11.90 2,082.50 Hours Rate Amount 11.90 175.00 2,082.50 Total Current Billing: 2,082.50 Previous Balance Due: 10,876.25 Total Now Due: 12,958.75 ?y' ? ? ? ? N : Q . . ? ; C7 . ? ? ? :? - €': ? ? ?' ?=? i ;TrA f ,'M1 T' ro. '{ c IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL DIVISION Cipriani & Werner, P.C. CASE NUMBER: 07-5980 Plaintiff ISSUE NUMBER: V. Sean Courtney McLaughlin, PLEADING: Defendant PRAECIPE TO REINSTATE COMPLAINT CODE AND CLASSIFICATION: FILED ON BEHALF OF: PLAINTIFF COUNSEL OF RECORD: PAUL CACCIAMANI, ESQUIRE Pa. ID# 88331 CIPRIANI & WERNER, P.C. 1011 Mumma Road, Suite 201 Lemoyne, PA 17043 (717) 975-9600 Fr IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL DIVISION Cipriani & Werner, P.C. ) CASE NO: 07-5980 Plaintiff ) V. ) Sean Courtney McLaughlin, ) Defendant ) PRAECIPE TO REINSTATE COMPLAINT TO: PROTHONOTARY OF CUMBERLAND COUNTY Kindly reinstate the Complaint in the above-referenced matter.. Respectfully submitted, CIPRIANI & WERNER, P.C. BY: P UL CACCIA ANI, ESQUIRE Attorney for the Plaintiff ? a "'` -4 € . c-) M t b r-n P d.. tZi IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL DIVISION Cipriani & Werner, P.C. CASE NUMBER: 07-5980 Plaintiff ISSUE NUMBER: V. Sean Courtney McLaughlin, PLEADING: Defendant PRAECIPE TO ATTACH NOTICE TO DEFEND TO COMPLAINT CODE AND CLASSIFICATION: FILED ON BEHALF OF: PLAINTIFF COUNSEL OF RECORD: PAUL CACCIAMANI, ESQUIRE Pa.ID# 88331 CIPRIANI & WERNER, P.C. 1011 Mumma Road, Suite 201 Lemoyne, PA 17043 (717) 975-9600 IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL DIVISION Cipriani & Werner, P.C. ) CASE NO: 07-5980 Plaintiff ) V. ) Sean Courtney McLaughlin, ) Defendant ) PRAECIPE TO ATTACH NOTICE TO DEFEND TO COMPLAINT TO: PROTHONOTARY OF CUMBERLAND COUNTY Kindly attach the Notice to Defend attached hereto to the Complaint filed on October 11, 2007 in the above-referenced matter. Respectfully submitted, CIPRIANI & WERNER, P.C. BY: ke U ?' ? z ?W_L P UL CACCIAMANI, ESQUIRE Attorney for the Plaintiff IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY PENNSYLVANIA CIVIL ACTION - LAW CIPRIANI & WERNER, P.C Plaintiff VS. SEAN COURTNEY McLAUGHLIN Defendant DOCKET NO.: 07-5980 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 Complaint and Notice are served, by entering a written appearance personally or by attorney and filing in writing with the court your defense 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 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(s). 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 32 S. Bedford Street Carlisle, PA 17013 (717) 249-3166 NOTICIA LE HAN DEMANDADO A USTED EN LA CORTE. Si usted guiere defenderse de estas demandas expuestas en las paginas siguientes, usted tiene viente (20) dias de plazo al partir de la fecha de la demanda y la notification. Usted debe presentar una apariencia excrita o en persona o por abogado y archivar en la corte an forma escrita sus defensas o sus objections a las demandas en contra de su persona. Sea avisado que si usted no se defiende, la torte tomara medidas y puede entrar una orden contra usted sin previo aviso o notification y por cualquier queja o alivio que es predido en la petition de demanda. Usted puede perder dinero o sus propriendades o stros derechos importantes para usted. LLEVE ESTA DEMANDA A UN ABROGADO IMMEDIATAMENTE. SI NO TIENE ABOGADO O SI NO TIENE EL DINERO SUFICIENTE DE PAGAR TAL SERVICIO, VAYA EN PERSONA O LLAME POR TELEFONCO A LA OFICINA CUYA DIRECCION SE ENCUENTRA EXCRITA ABAJO PARA AVERIGUAR DONDE SE PAUEDE CONSEQUIR ASSISTANCIA LEGAL. Cumberland County Bar Association 32 S. Bedford Street Carlisle, PA 17013 (717) 249-3166 N < C-,) V13- ?7 CO s IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL DIVISION CIPRIANI & WERNER, P.C., CASE NUMBER: 07-5980 Plaintiff ISSUE NUMBER: V. PLEADING: SEAN COURTNEY MCLAUGHLIN, PRAECIPE TO ENTER JUDGMENT OF Defendant DEFAULT CODE AND CLASSIFICATION: FILED ON BEHALF OF: Plaintiff COUNSEL OF RECORD: PAUL A. CACCIAMANI, ESQUIRE Pa. ID# 88331 CIPRIANI & WERNER, P.C. 1011 Mumma Road, Suite 201 Lemoyne, PA 17043 (717) 975-9600 IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL DIVISION CIPRIANI & WERNER, P.C., CASE NO: 07-5980 Plaintiff V. SEAN COURTNEY MCLAUGHLIN, Defendant PRAECIPE TO ENTER JUDGMENT OF DEFAULT TO: PROTHONOTARY OF CUMBERLAND COUNTY Kindly enter a default judgment in favor of the Plaintiff, CIPRIANI & WERNER, P.C. and against Defendant, SEAN COURTNEY MCLAUGHLIN, in the amount of $12,958.75. It is certified by the undersigned that the appropriate Notice of Intent to Take Default Judgment was served upon Defendant pursuant to Pa.R.C.P. 237.1 on December 7, 2007. A true and correct copy of the Notice of Intent to Take Default Judgment is attached hereto as Exhibit "A." Respectfully submitted, CIPRIANI & WERNER, P.C. BY: L PAUL A. CACCIAMANI, ESQUIRE Attorney for the Plaintiff CIPRIANI & WERNER A PROFESSIONAL CORPORATION Dennis P. Cullen Jr. $ Dennis J. Bonetti * Lewis L. Wolfgang Jason K. Burns Steven D. Snyder Mark R. Zogby Paul A. Cacciamani Stephen R. Harris Adam L. Seiferth David H. Radcliff Of Counsel Also admitted in NJ $ Also admitted in D.C. & NJ * Board Certified Civil Trial Advocate Writer's E-mail: pcacciamani@c-wlaw.com Sean McLaughlin 66 Harrison Road East West Chester, PA 19382 ATTORNEYS AT LAW Suite 201 1011 Mumma Road Lemoyne, Pennsylvania 17043-1145 Telephone (717) 975-9600 Fax: (717) 975-3846 www.C-WLAW.com December 7, 2007 RE: Cipriani & Werner v. Sean Courtney McLaughlin Our File No.: 9390-15214H Dear Sean: Pittsburgh office: 650 Washington Road, Suite 700 Pittsburgh, PA 15228 Telephone (412) 563-2500 Philadelphia Office: 482 Norristown Road, Suite 111 Blue Bell, PA 19422-2352 Telephone (610) 567-0700 Scranton Office: 409 Lackawanna Avenue, Suite 210 Scranton, PA 18503-2059 Telephone (570) 347-0600 Marlton Office: 1000 Lenola Road Tall Oaks Corporate Center Building Two, Suite 101 Marlton, NJ 08052 Telephone (856) 761-0725 With regard to the above captioned matter, enclosed please find a Notice of Intent to Take a Default Judgment. Very yours, r Paul Cacciamani PAC/peb enclosure UNITEDSTATES Certificate Of J Mailing This Certificate of Mailing provides evidence that mail has been presented to USPS® for mailing. This form may be used for domestic and international mail. N rV h- M oo C) -4- . rn Ca (D •• fV n,i to w I-,,- VI CJ m CL to NJ p ? V w C) 4 t7 N E-4 00 0 W t P. O W J O 1[) Sp y T LA C? %0 wo C) r- * qr- a) r+ PS Form 3817, April 2007 PSN 7530-02-000-9065 iaje5 f C he:5f-ee- , P i 9 3 ;- IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY PENNSYLVANIA CIVIL ACTION - LAW CIPRIANI & WERNER, P.C Plaintiff No.: 07-5980 VS. SEAN COURTNEY McLAUGHLIN Defendant TO: SEAN COURTNEY MCLAUGHLIN (Defendant) DATE OF NOTICE: December 7, 2007 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 DAYS FROM THE DATE OF THIS NOTICE, A JUDGMENT MAY BE ENTERED AGAINST YOU WITHOUT A HEARING AND YOU MAY LOSE YOUR PROPERTY OR OTHER IMPORTANT RIGHTS. YOU SHOULD TAKE THIS PAPER TO YOUR LAWYER AT ONCE. IF YOU DO NOT HAVE A LAWYER, GO TO OR TELEPHONE THE OFFICE SET FORTH BELOW. THIS OFFICE CAN PROVIDE YOU WITH INFORMATION ABOUT HIRING A LAWYER. IF YOU CANNOT AFFORD TO HIRE A LAWYER, WITH INFORMATION ABOUT AGENCIES THAT PERSONS AT A REDUCED FEE OR NO FEE. THIS OFFICE MAY BE ABLE TO PROVIDE YOU MAY OFFER LEGAL SERVICES TO ELIGIBLE Cumberland County Bar Association 32 S. Bedford Street Carlisle, PA 17013 (717) 249-3166 CIPR I,& WERNER, P.C. BY: PAUL A. CACCIAMANI, ESQUIRE Attorney I.D. #88331 1011 Mumma Road, Suite 201 Lemoyne, PA 17043 (717) 975-9600 Attorney for the Plaintiff AVISO IMPORTANTE A: SEAN COURTNEY MCLAUGHLIN (Defendido) FECHA DEL AVISO: December 7, 2007 USTED ESTA EN REBELDIA PORQUE HA FALLADO DE REGISTRAR COMPARECENCIA ESCRITA POR SI MISMO O A TRAVES DE UN ABOGADO Y SOMETER CON LA CORTE SUS DEFENSAS U OBJECCIONES A LOS CARGOS QUE SE HAN PRESENTADO CONTRA USTED. A MENOS QUE USTED ACTUE DENTRO DE DIEZ DIAS DE HABER RECIBIDO ESTE AVISO, LA CORTE PUEDE TOMAR UNA DECISION EN CONTRA SUYA SIN TENER DERECHOS A UNA VISTA Y USTED PUEDE PERDER SU PROPIEDAD U OTROS DERECHOS IMPORTANTES. USTED DEBE LLEVAR ESTE DOCUMENTO A SU ABOGADO INMEDIATAMENTE. SI USTED NO TIENE UN ABOGADO, LLAME O VAYA A LA SIGUIENTE OFICINA. ESTA OFICINA PUEDE PROVEERLE INFORMACION A CERCA DE COMO CONSEGUIR UN ABOGADO. SI USTED NO PUEDE PAGAR POR LOS SERVICIOS DE UN ABOGADO, ES POSIELE QUE ESTA OFICINA LE PUEDA PROVEER INFORMACION SOBRE AGENCIAS QUE OFREZCAN SERVICIOS LEGALES SIN CARGO O BAJO COSTO A PERSONAS QUE CUALIFICAN. Cumberland County Bar Association 32 S. Bedford Street Carlisle, PA 17013 (717) 249-3166 CIER NI & WERNER, P.C. BY: PAUL A. CACCIAMANI, ESQUIRE Attorney I.D. #88331 1011 Mumma Road, Suite 201 Lemoyne, PA 17043 (717) 975-9600 Attorney for the Plaintiff CERTIFICATE OF SERVICE That counsel for the Plaintiff hereby certifies that a true and correct copy of its NOTICE OF INTENT TO ENTER JUDGMENT OF DEFAULT has been served on all counsel of record, by first class, mail, postage pre- paid, according to the Pennsylvania Rules of Civil Procedure, on the 7 day of 2007. Sean Courtney McLaughlin 66 Harrison Road East West Chester, PA 19382 _CIPR?NI & WERNER, P.C. BY: PAUL A. CACCIAMANI, ESQUIRE Attorney I.D. #88331 1011 Mumma Road, Suite 201 Lemoyne, PA 17043 (717) 975-9600 Attorney for the Plaintiff CERTIFICATE OF SERVICE That counsel for the Plaintiff hereby certifies that a true and correct copy of its PRAECIPE TO ENTER JUDGMENT OF DEFAULT has been served on all counsel of record, by first class mail, postage pre-paid, according to the Pennsylvania Rules of Civil Procedure, on the _ 3,-' day of 0 , c e 4 , , 2007. Sean Courtney McLaughlin 66 Harrison Road East West Chester, PA 19382 Respectfully submitted, CIPRIANI & WERNER, P.C. - _? BY: ? ?_' ?i --- - ? PAUL A. CACCIAMANI, ESQUIRE Attorney for the PLAINTIFF n ? W S ;? C J m c-n w 0 h IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL ACTION - LAW CIPRIANI & WERNER, P.C Plaintiff VS. SEAN COURTNEY MCLAUCHLIN Defendant : To: Sean Courtney McLaughlin, Defendant 6 Harrison Road East West Chester, PA 19382 No.: 07-5980 Pursuant to Pennsylvania Rule of Civil Procedure 236, you are hereby notified that on 1A11,067 (date), a Judgment in the amount of 512,958.75 has been entered against you in the above captioned case. Date: lah'3 :7 IF / /v L&- '0. " --"' thonotary I hereby certify that the name and address of the proper person(s) to receive notice is: Sean Courtney McLaughlin 6 Harrison Road East West Chester, PA 19382 SHERIFF'S RETURN - OUT OF COUNTY CASE NO: 2007-05980 P COMMONWEALTH OF PENNSYLVANIA: 'l COUNTY OF CUMBERLAND CIPRIANI & WERNER PC VS MCLAUGHLIN SEAN COURTNEY 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 MCLAUGHLIN SEAN COURTNEY but was unable to locate Him deputized the sheriff of CHESTER serve the within COMPLAINT & NOTICE County, Pennsylvania, to On November 28th , 2007 , this office was in receipt of the attached return from CHESTER Sheriff's Costs: Docketing 18.00 Out of County 9.00 Surcharge 10.00 Dep Chester Co 150.00 Postage 2.23 189.23 ??? \ 11/28/2007 CIPRIANI & WERNER Sworn and subscribe to before me this day of to wit: in his bailiwick. He therefore So answers _-- - R Thomas Kline Sheriff of Cumberland County A. D. Please make any refund payable to,cumberland county sheriff. Thank you. In The Court of Common Pleas f H Cumberland County, Pennsylvania Ciproamo & Werner PC S ER I FF S COSTS 0xv- 6-Tro vs. Date $ X56 Paid Receipt fro. 38/yNo' - Last day to service Sean Courtney McLaughlin Now, October 31, 2007 hereby deputize the Sheriff of I, SHERIFF OF CUMBERLAND COUNTY, PA, do Chester County to execute this Writ, this deputation being made at the request and risk of the Plaintiff. Please mail return of service to Cumberland County Sheriff. Thank you. Affidavit of Service Now, l Sy?m6 , 2002, at 3ys o'clock M served t /f within ( 014%11/4" upon C.P at C by handing to a copy of the original n c?- . s (' mp? c:i yiand made known to k the contents thereof. So answers, 1___? NOTP RiAL Rebecon. S1'en e ian, i„ y West civ, P"'Io., Gieestzr Cou rs My commission expires August 6, 2008 Sworn and ubscribed before _ me this _ay of ,200 0 Sheriff of County, PA -3 Sheriff of Cumberland County, PA COSTS SERVICE $ MILEAGE AFFIDAVIT 07-5980 civil