HomeMy WebLinkAbout07-7511• r
ArthurA Kusic, Esquire
Supreme Court No. 07207
4201 Crums Mill Road
Harrisburg, PA 17112
(717) 540-5610 / fax (717) 540..7618 Attorney for Plaintiff
GRIFFIE & ASSOCIATES : IN THE COURT OF COMMON PLEAS
Plaintiff CUMBERLAND COUNTY, PENNSYLVANIA
V. CIVIL ACTION -LAW
CHARLES COOVER and NO ~I?y/ c1t ` r-
AMY COOVER
Defendants
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 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 JUDGh ENT MAY BE ENTERED
AGAINST YOU BY THE COURT WITHOUT FURTHER NOTICE FOR ANY
MONEY CLAIldiED IN THE COMPLAINT OR FOR ANY OTHER CLAIM OR
RELIEF REQUESTED BY THE PLAINTIFF. YOU MAY LOSE MONEY OR
PROPERTY OR OTHER RIGHTS IlOORTANT 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 THE
TELEPHONE OR THE OFFICE SET FORTH BELOW TO FIND OUT WHERE YOU
CAN GET LEGAL HELP.
CUMBERLAND COUNTY BAR ASSOCIATION
32 SOUTH BEDFORD STREET
CARLISLE, PA 17013
1-800-990-9108
717-249-3166
?. r,,, C"' •j't 7` r }r..vr,'trwq+ 1: 717 '.f .*%e
77
Ak`I'HI R A. RUSK
GRIFFIE & ASSOCIATES : IN THE COURT OF COMMON PLEAS
Plaintiff CUMBERLAND COUNTY, PENNSYLVANIA
V.
CIVIL ACTION - LAW
NO. o 7_ // & i-
??
CHARLES COOVER and
AMY COOVER
Defendants
COMPLAINT
AND NOW comes Plaintiff by and through its attorney Arthur A. Kusic,
Esquire and respectfully makes its Complaint as follows:
1. Plaintiff, Griffie & Associates is a sole proprietorship with offices
located at 200 North Hanover Street, Carlisle, Cumberland County,
Pennsylvania, 17013.
2. Defendants, Charles Coover and Amy Coover, husband and
wife, residing at 117 Railroad Lane, Shippensburg, Cumberland County,
Pennsylvania, 17257.
3. On or about July 18, 2005 and continuing from time to time
through to or about July 10, 2006, Plaintiff provided legal services to the
Defendants.
4. Plaintiff in good faith provided the legal services to the
Defendants and thereafter billed the Defendants for the legal services
rendered to him. A copy of Plaintiff's statements are attached hereto,
made a part hereof and marked Exhibit "A".
5. The prices charged Defendants by Plaintiff were Plaintiffs usual
customary and reasonable charges.
6. Plaintiff has credited Defendant's account with all monies
received on the account, thereby leaving a balance due and owing of
$9,400.00.
7. Plaintiff did render legal services to the Defendants with the
reasonable expectation that payment for such services would be made by
the parties benefited.
8. Should Defendants not be held liable to Plaintiff for payment of
the aforesaid services rendered, Defendants would be unjustly enriched at
Plaintiff's expense by having received legal services without paying for the
legal services rendered.
9. Plaintiff has made demands upon the Defendant for the balance
due and owing of $9,400.00, which demands remain unheeded.
10. Plaintiff avers that the amount claimed due does not exceed
the jurisdictional amount requiring arbitration referral under local rule.
11. This is an attempt to collect a debt. Any information obtained
will be used for that purpose.
Arthur A Kusic, Esquire
Supreme Court No. 07207
4201 Crums Mill Road
Harrisburg, PA 17112
(717) 540-5610 / fax (717) 540-7618 Attorney for Plaintiff
GRIFFIE & ASSOCIATES : IN THE COURT OF COMMON PLEAS
Plaintiff CUMBERLAND COUNTY, PENNSYLVANIA
V. CIVIL ACTION - LAW
NO.
CHARLES COOVER and
AMY COOVER
Defendants
VERIFICATION
I, Bradley L. Griffie the owner of Griffie &
Associates. verify that the statements made in Plaintiffis Complaint are true and
correct to the best of my knowledge, information and belief and that I am
authorized to make this Verification of behalf of Griffie & Associates. I
understand that false statements made herein are subject to the penalties of 18
Pa.C.S.A. Section 4904, relating to unworn falsification to authorities.
GRIFFIE & ASSOCIATES
Date: 1211Vlb -7
EXMIT A
GRIFFIE & ASSOCIATES
200 North Hanover Street
Carlisle, PA 17013
Invoice submitted to:
Charles & Amy Coover
August 4, 2005
Invoice #36083
Professional services
Hours Amount
07/18/05 Initial Office Conference with Client 1.30 50.00
For professional services rendered 1.30 $50.00
Balance due ?SU.UU
THIS STATEMENT REFLECTS ALL SERVICES RENDERED AND PAYMENTS RECEIVED
AS OF JUNE 30, 2005.
We accept Visa, Mastercard and Discover.
GRIFFIE & ASSOCIATES
200 North Hanover Street
Carlisle, PA 17013
Invoice submitted to:
Charles & Amy Coover
117 Railroad Lane
Shippensburg PA 17257
September 2, 2005
In Reference To:Adoption
Invoice #36580
Professional services
08/22/05 Telecon with Client
08/29/05 Receipt and Review of document from
client; Preparation of Preliminary
Objections; Preparation of Notice of
Intention to Adopt; Preparation of
Petition for Adoption; Preparation of
Petition for Involuntary Termination of
Parent a1_Rights
08/30/05 Telecon with Client
For professional services rendered
Previous balance
07/21/05 Payment - thank you
09/02/05 Payment from account
Total payments
0.10 25.00
1.80 450.00
0.10 NO CHARGE
2.UU $475.UU
$50.00
-$50.00
--$475.00
-$525.00
Charles & Amy Coover
Balance due
Page .2
Amount
$0.00
THIS STATEMENT REFLECTS ALL SERVICES RENDERED AND PAYMENTS RECEIVED
AS OF JULY 31, 2005.
We accept Visa, Mastercard and Discover.
Previous balance of Client funds $0.00
08/31/05 Deposit to account $2,500.00
09/02/05 Payment from account -$475.00
New balance of Client funds
$2,025.00
GRIFFIE & ASSOCIATES
200 North Hanover Street
Carlisle, PA 17013
Invoice submitted to:
Charles & Amy Coover
117 Railroad Lane
Shippensburg PA 17257
October 6, 2005
In Reference To:Adoption
Invoice #36690
Professional services
09/01/05 Telecon with Client
Proof/finalize docs
09/07/05 Receipt and Review of Correspondence
and document from Atty. Lindsey;
Correspondence to client; Preparation
of Answer
09/09/05 Receipt and Review of Custody
Conference Notice; Correspondence and
document to client; Correspondence to
Atty. Verney; Receipt and Review of
Correspondence and document from Atty.
Miller; file POs, Termination Petition,
Adoption Petition, and Adoption Notice
09/12/05 Walk through Answer; Correspondence and
document to Atty. Miller;
Correspondence and document to client;
Revise Answer; Preparation of Lising
Praecipe
Hours Amount
0.10 NO CHARGE
0.20 50.00
0.80 200.00
0.70 175.00
1.60 400.00
Charles & Amy Coover Page 2--
Hours Amount
09/13/05 Telecon with Client; Correspondence to 0.50 125.00
Judge Hess
09/15/05 Receipt and Review of Correspondence 1.30 325.00
and document from Atty. Miller;
Correspondence and document to Atty.
Miller; Preparation of Motion for
Protective Order; Preparation of
Affidavit of Service; Preparation of
Amended Answer
09/20/05 Telecon with Judge Hess and Atty. 0.50 125.00
Miller; research
09/22/05 Receipt and Review of Order; 0.10 NO CHARGE
Correspondence and document to client
File Protective Motion 0.20 50.00
09/29/05 Receipt and Review of Order; Receipt 0.10 25.00
and Review of Correspondence from Atty.
Miller; Correspondence and document to
client
09/30/05 Correspondence and document to Atty. 0.30 75.00
Miller; file Amended Answer
For professional services rendered 6.40 $1,550.00
10/06/05 Payment from account -$1,545.00
Balance due $5.00
THIS STATEMENT REFLECTS ALL SERVICES RENDERED AND PAYMENTS RECEIVED
AS OF SEPTEMBER 30, 2005.
We accept Visa, Mastercard and Discover.
Charles & Amy Coover Page 3
Amount
Previous balance of Client funds $2,025.00
09/12/05 Withdrawal from account/filing fee -$480.00
10/06/05 Payment from account -$1,545.00
New balance of Client funds $0.00
S F.71 FFI E G kC Q, ?C:IATEc
_?1?; 1` rth pia ,x,7,7 -r `tr eet
Invoice submitted to:
Charles & Amy Coo-,,Ter
_7 RC'-oad ?ar?e
Shippensburg PA: 17257
w cyTT;am-1 _ 0 0 5
In Fe_?erence To:kdoption
_17t'o_Ce ?1 -
Prof_= C)r,a1 ser\,1ces
T'?_e-on G' th Reg_ster f W S, `le i co_ ??. 80 ?00. 00
Gy. ,h .,l en ; Telecon G. I 7_.t ' l?'i ?er
cr-r tt 1%e-nev
Telecon with Client 0 0
50.00
10/12/05 F:eceipt and Review of document from 0.40 100.00
client; Correspondence to client
1C 18/05 Receipt and Review of Order; Receipt 0.60 150.00
and P.eview of facsimile from Atty.
Miller; Correspondence to Attv. Miller;
Telecon message to Atty. Miller;
Telecon with Atty. Miller (multiple)
10/19%05 Correspondence and document to client 0.10 25.00
10/21/03- Receipt and Review of Correspondence 0.40 100.00
from client
For ti)rcfessional services rendered 2.50 `625.00
Previous balance Tr
Charles & Amy Coover
10/14/05 Payment from account
11/03/05 Payment from account
Total payments
Balance due
Page 2
Amount
-$5.00
-$625.00
-$630.00
$0.00
THIS STATEMENT REFLECTS ALL SERVICES RENDERED AND PAYMENTS RECEIVED
AS OF OCTOBER 31, 2005.
We accept Visa, Mastercard and Discover.
Previous balance of Client funds $0.00
10/14/05 Deposit to account $1,000.00
10/14/05 Payment from account -$5.00
11/03/05 Payment from account -$625.00
New balance of Client funds $370.00
GF; - r.S '--ATE
r'= N_'r r' ridnC'v?-T-1" titrceL.
ar PA
Invc?ce submitted to:
Chart es & ATtlj, Coover
117 Railroad Lane
Shippensburcg PA 17257
!Je e-nl'=r _/ 2005
_- Reference To. Ldoptlor_
?YJ-eSs! oilal Lei 4'1C.J.hours Amount
G5 Te e,-On W T-h ?l-e!.t; rrep ?'11aiT, l.on OJT r1 LJ LI ?J UC)
?... i. T_Jri ?Jn._-:1l.iCY!t.. r
?' ?t
dC U, ?T!cnt ?C,
N?
"!1!04/05 Receipt and Review of Correspondence 0.10 NO CHARGE
and document from client
1_1/"10i 05 Pile Petition for Continuance; Receipt U . 40 100.00
and Review of Correspondence from Atty.
hiller; Telecon with Client;
Correspondence to Atty. Miller
11/16/05 Telecon with Register of Wills; 0.31 0 75.00
facsimile to Register of Wills; review
notes from client
11%17/05 Telecon with Client 0.20 50.00
11/18/05 File criminal checks; Receipt and 0.40 100.00
Review of notes from client
Charles & Amy Coover
For professional services rendered
Additional charges:
11/11/05 Costs advanced for fax to Atty. Miller
11/14/05 Costs advanced for fax to client
11/16/05 Costs advanced for fax to Register of Wills
Total costs
Total amount of this bill
11/04/05 Payment - thank you
12/02/05 Payment from account
Total payments
Balance due
2.50
2.50
3.00
$8.00
$433.00
-$100.00
-$333.00
-$433.00
$0.00
THIS STATEMENT REFLECTS ALL SERVICES RENDERED AND PAYMENTS RECEIVED
AS OF OCTOBER 31, 2005.
We accept Visa, Mastercard and Discover.
Previous balance of Client funds $370.00
11/30/05 Deposit to account $2,000.00
12/02/05 Payment from account -$333.00
Page 2
Hours Amount
1.80 $425.00
New balance of Client funds $2,037.00
l
Charles & Amy Coover Page 2
THIS STATEMENT REFLECTS ALL SERVICES RENDERED AND PAYMENTS RECEIVED
AS OF DECEMBER 31, 2005.
We accept Visa, Mastercard and Discover.
Amount
Previous balance of Client funds $2,037.00
Charles & Amy Coover Page 2
Hours Amount
01/17/06 Secure certified order 0.20 50.00
01/18/06 Receipt and Review of Correspondence 0.20 NO CHARGE
from client
01/20/06 Receipt and Review of document from 0.30 75.00
client
01/23/06 Multiple Teleconferences to Prison Rep. 0.50 125.00
01/24/06 Multiple calls to prison system; 0.90 225.00
Telecon with Warden Gainery;
Correspondence to.Defendant;
Correspondence to Warden Gainey;
Telecon message to client
01/26/06 Meeting with travel; serve 2.00 500.00
subpoena
For professional services rendered 17.90 $4,425.00
Additional charges:
01/06/06 Costs advanced for fax to Atty. Miller 4.50
01/10/06 Costs advanced for overnight express mail to 15.08
Costs
?? advanced
now& for overnight express mail to 15.08
Costs advanced for Certifying Subpoenas 4.00
Costs advanced for fax to XNNW? 4.00
Costs advanced for fax to 3.50
Total costs $46.16
Total amount of this bill $4,471.16
??` ? , .
"'`?
Charles & Amy Coover
Page 3
Amount
02/01/06 Payment from account
Balance due
-$1,942.00
$2,529.16
THIS STATEMENT REFLECTS ALL SERVICES RENDERED AND PAYMENTS RECEIVED
AS OF JANUARY 31, 2006.
We accept Visa, Mastercard and Discover.
Previous balance of Client funds $2,037.00
01/17/06 Withdrawal from account/Register of wills -$15.00
for certified copies
01/30/06 Withdrawal from account/dmft?? -$80.00
02/01/06 Payment from account -$1,942.00
New balance of Client funds $0.00
ft'
I '11111111M
GRIFFIE & ASSOCIATES
200 North Hanover Street
Carlisle, PA 17013
Invoice submitted to:
Charles & Amy Coover
117 Railroad Lane
Shippensburg PA 17257
March 7, 2006
In Reference To:Adoption
Invoice #37947
Professional services
02/02/06 Receipt and Review of Order;
Correspondence and document to client;
Correspondence to us ?
02/06/06 Receipt and Review of document from
Atty. Miller; Correspondence and
document to client; Correspondence and
document to Atty. Miller
02/10/06 Telecon with Client
02/14/06 Receipt and Review of Correspondence
from client
Telecon with Atty. Miller; conference
with Atty. Miller and Judge Hess
02/15/06 Telecon with Judge Hess and Atty. Miller
Receipt and Review of transcript;
Correspondence and document to client
Hours Amount
0.40 100.00
0.30 75.00
0.30 75.00
0.10 NO CHARGE
0.80 200.00
0.20 50.00
0.10 NO CHARGE
Charles & Amy Coover
02/27/06 Receipt and Review of Correspondence
from client
For professional services rendered
Additional charges:
01/25/06 Costs advanced for fax to Warden
Total costs
Total amount of this bill
Previous balance
02/13/06 Payment from account
03/07/06 Payment from account
Total payments
Page 2
Hours Amount
0.10 25.00
2.30 $525.00
2.50
$2.50
$527.50
$2,529.16
-$2,529.16
-$527.50
-$3,056.66
Balance due $0.00
THIS STATEMENT REFLECTS ALL SERVICES RENDERED AND PAYMENTS RECEIVED
AS OF FEBRUARY 28, 2006.
We accept Visa, Mastercard and Discover.
Previous balance of Client funds $0.00
02/13/06 Deposit to account $4,029.16
02/13/06 Payment from account -$2,529.16
02/20/06 Withdrawal from account/payment to Court -$81.20
Reporter
03/07/06 Payment from account -$527.50
New balance of Client funds $891.30
GRIFFIE & ASSOCIATES
200 North Hanover Street
Carlisle, PA 17013
Invoice submitted to:
Charles & Amy Coover
117 Railroad Lane
Shippensburg PA 17257
April 3, 2006
In Reference To:Adoption
Invoice #38101
Professional services
Hours Amount
03/07/06 Office Conference with clients 1.50 375.00
03/10/06 Research 2.50 625.00
Receipt and Review of document from 0.40 100.00
Atty. Miller; Telecon with Atty.
Miller; Telecon with Judge's office
03/12/06 Research 2.00 500.00
03/13/06 Research; Preparation of Brief; hand 3.50 875.00
deliver Brief; review file;
revise/finalize Brief; Correspondence
and document to Atty. Miller
03/14/06 Telecon with Telecon with 1.00 250.00
401W, Telecon message to 4?;
Preparation of Subpoenas; review notes
03/15/06 Office Conference with clients 2.00 500.00
?'tit*
Charles & Amy Coover
Page 2
Hours Amount
03/15/06 Receipt and Review of Home study at 0.50 125.00
courthouse; secure Subpoenas
03/16/06 Telecon with Sheriff's Dept. Telecon 5.50 1,375.00
with ? Preparation for hearing;
Telecon with Atty. Prosser
03/17/06 Preparation for hearing; hearing 8.00 2,000.00
For professional services rendered 26.90 $6,725.00
Additional charges:
03/15/06 Costs advanced for overnight mail for Subpoenas 39.00
(3)
Costs advanced for Subpoenas 20.00
Total costs $59.00
Total amount of this bill
04/03/06 Payment from account
Balance due
$6,784.00
-$871.30
$5,912.70
THIS STATEMENT REFLECTS ALL SERVICES RENDERED AND PAYMENTS RECEIVED
AS OF MARCH 31, 2006.
We accept Visa, Mastercard and Discover.
Previous balance of Client funds
03/16/06 Withdrawal from account/subpoenas
04/03/06 Payment from account
New balance of Client funds
$891.30
-$20.00
-$871.30
$0.00
GRIFFIE & ASSOCIATES
200 North Hanover Street
Carlisle, PA 17013
Invoice submitted to:
Charles & Amy Coover
117 Railroad Lane
Shippensburg PA 17257
May 2, 2006
In Reference To:Adoption
Invoice #38388
Professional services
03/17/06 Receipt and Review of Correspondence
from client
04/12/06 Receipt and Review of Opinion; Receipt
and Review of Correspondence from Atty.
Miller; Telecon message to Atty. Miller
Telecon with Atty. Miller
04/14/06 Office Conference with client
04/19/06 Review transcript; Preparation of
Petition; Correspondence and document
to Atty. Miller
04/20/06 Research; file/walk through Petition
for Special Relief; Preparation of
Petition for Special Relief;
Preparation of Preliminary Objections;
revise Petition
Hours Amount
0.20 NO CHARGE
0.30 75.00
0.30 75.00
1.60 400.00
1.50 375.00
3.00 750.00
Charles & Amy Coover
Page 2
Hours Amount
04/21/06 Research; hearing; conference with Judge
Correspondence and document to client
04/26/06 Preparation of Custody Complaint
Preparation of Subpoenas
04/28/06 File Complaint; serve Subpoena
For professional services rendered
Additional charges:
04/20/06 Costs advanced for fax to Atty. Miller
04/28/06 Costs advanced for Subpoenas
Costs advanced for Custody Complaint
Total costs
Total amount of this bill
Previous balance
04/19/06 Payment - thank you
05/02/06 Payment from account
Total payments
1.00 250.00
0.10 NO CHARGE
0.50 125.00
0.20 50.00
0.20 50.00
8.90 $2,150.00
12.00
16.00
112.00
$14U.UU
$2,290.00
$5,912.70
-$912.70
-$20.00
-$932.70
Balance due $7,270.00
THIS STATEMENT REFLECTS ALL SERVICES RENDERED AND PAYMENTS RECEIVED
AS OF APRIL 30, 2006.
tl
Charles & Amy Coover Page 3
We accept Visa, Mastercard and Discover.
Amount
Previous balance of Client funds $0.00
04/11/06 Deposit to account/voided check on 3/15 to $20.00
Orphans Court
05/02/06 Payment from account -$20.00
New balance of Client funds
$0.00
ti
GRIFFIE & ASSOCIATES
200 North Hanover Street
Carlisle, PA 17013
Invoice submitted to:
Charles & Amy Coover
117 Railroad Lane
Shippensburg PA 17257
June 2, 2006
In Reference To:Adoption
Invoice #38507
Professional services
Hours Amount
05/03/06 Review file; Telecon with Philly prison 3.50 875.00
system (2x); Correspondence and
Subpoena to Philly prison system;
Office Conference with clients
05/04/06 Telecon messages to am (2); 0.80 200.00
Telecon with Legal Offices (2x);
Telecon with ?
05/05/06 Telecon with Philly Legal Offices; 6.00 1,500.00
Preparation for hearing; review docs;
hearing
05/11/06 Telecon message to client; Telecon 0.10 NO CHARGE
message to Atty. Miller; Receipt and
Review of Order
Telecon with Clients 1.00 250.00
05/15/06 Telecon with Clients 1.20 NO CHARGE
41 1 Y
Charles & Amy Coover
05/17/06 Telecon with Prothonotary; secure
record; Preparation of Petition for
Special Relief; Preparation of Petition
for Stay; Correspondence and document
to Atty. Miller; Correspondence and
document to client
05/18/06 Receipt and Review of dots from client
05/19/06 Review Petition (3x)
05/22/06 Revised Petition
For professional services rendered
Additional charges:
05/03/06 Costs advanced for fax to Legal Affairs,
Philadelphia
Total costs
Interest on overdue balance
Total amount of this bill
Previous balance
05/03/06 Payment - thank you
Balance due
Page 2
Hours Amount
1.80 450.00
0.30 NO CHARGE
1.50 375.00
0.30 NO CHARGE
16.50 $3,650.00
4.00
$4.00
$101.85
$3,755.85
$7,270.00
-$1,000.00
$10,025.85
THIS STATEMENT REFLECTS ALL SERVICES RENDERED AND PAYMENTS RECEIVED
AS OF MAY 31, 2006.
We accept Visa, Mastercard and Discover.
Charles & Amy Coover Page 3
Current 30 Days 60 Days 90 Days 120 Days
3,755.85 2,290.00 3,980.00 0.00 0.00
4 ..
GRIFFIE & ASSOCIATES
200 North Hanover Street
Carlisle, PA 17013
Invoice submitted to:
Charles & Amy Coover
117 Railroad Lane
Shippensburg PA 17257
July 6, 2006
In Reference To:Adoption
Invoice #38774
Professional services
06/12/06 Receipt and Review of Correspondence
from clients; Correspondence to client
For professional services rendered
Previous balance
06/01/06 Credit for interest charged
06/01/06 Credit/filing fee
07/05/06 Payment - thank you
Total payments
Balance due
Hours Amount
0.30 NO CHARGE
0.30 $0.00
$10,025.85
-$101.85
-$100.00
-$424.00
-$625.85
$9,400.00
THIS STATEMENT REFLECTS ALL SERVICES RENDERED AND PAYMENTS RECEIVED
AS OF JUNE 30, 2006.
46 , I V
Charles & Amy Coover
We accept Visa, Mastercard and Discover.
Current 30 Days 60 Days
Page 2
90 Days 120 Days
0.00 3,755.85 2,290.00 3,354.15 0.00
GRIFFIE & ASSOCIATES
200 North Hanover Street
Carlisle, PA 17013
Invoice submitted to:
Charles & Amy Coover
117 Railroad Lane
Shippensburg PA 17257
August 4, 2006
In Reference To:Adoption
Invoice #38992
Professional services
07/10/06 Receipt and Review of Correspondence
and document from client
For professional services rendered
Previous balance
Hours Amount
0.20 NO CHARGE
V. 6V yv.vv. $9,400.00
Balance due ?y,gVV.VV
THIS STATEMENT REFLECTS ALL SERVICES RENDERED AND PAYMENTS RECEIVED
AS OF JULY 31, 2006.
We accept Visa, Mastercard and Discover.
Current 30 Days 60 Days 90 Days 120 Days
0.00 0.00 3,755.85 . 2,290.00 3,354.15
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SHERIFF'S RETURN - REGULAR
CASE NO: 2007-07511 P
COMMONWEALTH OF PENNSYLVANIA:
COUNTY OF CUMBERLAND
GRIFFIE & ASSOCIATES
VS
COOVER CHARLES ET AL
VALERIE WEARY , Sheriff or Deputy Sheriff of
Cumberland County,Pennsylvania, who being duly sworn according to law,
says, the within COMPLAINT & NOTICE was served upon
COOVER CHARLES the
DEFENDANT
, at 1901:00 HOURS, on the 4th day of January , 2008
at 117 RAILROAD LANE
SHIPPENSBURG, PA 17257
AMY COOVER
by handing to
a true and attested copy of COMPLAINT & NOTICE
together with
and at the same time directing Her attention to the contents thereof.
Sheriff's Costs:
Docketing
Service
Postage
Surcharge
fagq ?,
18.00
17.28
.58
10.00
.00
45.86
Sworn and Subscibed to
before me this day
of ,
So Answers:
7
R. Thomas Kline
01/07/2008
ARTHUR KUSIC /
By: '//
Deputy Sheriff
A. D.
CASE NO: 2007-07511 P
SHERIFF'S RETURN - REGULAR
COMMONWEALTH OF PENNSYLVANIA:
COUNTY OF CUMBERLAND
GRIFFIE & ASSOCIATES
VS
COOVER CHARLES ET AL
VALERIE WEARY
, Sheriff or Deputy Sheriff of
Cumberland County,Pennsylvania, who being duly sworn according to law,
says, the within COMPLAINT & NOTICE was served upon
COOVER AMY the
DEFENDANT at 1901:00 HOURS, on the 4th day of January , 2008
at 117 RAILROAD LANE
SHIPPENSBURG, PA 17257 by handing to
AMY COOVER
a true and attested copy of COMPLAINT & NOTICE together with
and at the same time directing Her attention to the contents thereof.
Sheriff's Costs: So Answers:
Docketing
Service 6.00
00
. y
Affidavit .00
Surcharge 10.00 R. Thomas Kline
n
/2 a?Df .00
16.00
01/07/2008
ARTHUR KUSIC
Sworn and Subscibed to By:
before me this day Deputy Sheriff
of A.D.
GRIFFIE & ASSOCIATES : IN THE COURT OF COMMON PLEAS
Plaintiff CUMBERLAND COUNTY, PENNSYLVANIA
v CIVIL ACTION - LAW
: NO. 07-7511
CHARLES COOVER and
AMY COOVER
Defendants
PRAECIPE
TO THE PROTHONOTARY:
Please mark the above captioned matter as Satisfied, Settled,
Discontinued and Ended.
RESPECTFULLY SUBMITTED:
ARTH A. SI ESQUIRE
4201 Crums Mill Road
Harrisburg, PA 17112
(717) 540-5610
Supreme Court No. 07207
1
Arthur A Kusic, Esquire
Supreme Court No. 07207
4201 Crums Mill Road
Harrisburg, PA 17112
(717) 540-5610 / fax (717) 540-7618 Attomey for Plaintiff
GRIFFIE & ASSOCIATES : IN THE COURT OF COMMON PLEAS
Plaintiff CUMBERLAND COUNTY, PENNSYLVANIA
V. CIVIL ACTION - LAW
NO. 07-7511
CHARLES COOVER and
AMY COOVER
Defendants
CERTIFICATE OF SERVICE
I, Arthur A. Kusic, Esquire, do hereby certify that on t e day of
a47 , 2008, 1 placed in the United States mail a true and
correct copy of Plaintiffs Praecipe to Satisfy, Settle, Discontinue and End
with first class postage affixed and addressed to the following:
Charles Coover and
Amy Coover
117 Railroad Lane
Shippensburg, PA 17257
hur ; Esquire
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