HomeMy WebLinkAbout08-1983THERESA BARRETT MALE, ESQUIRE
Plaintiff
V.
MARIA V. GORDON
Defendant
IN THE COURT OF COMMON PLEAS
CUMBERLAND COUNTY, PENNSYLVANIA
69 - PS3 Cm t TAM
CIVIL ACTION - LAW
NOTICE TO DEFEND AND CLAIM RIGHTS
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 defenses or objections to the claim set forth against you. You are warned
that if you fail to do so, the case may proceed without you and a judgment may be entered
against you by the court without further notice for any money claimed in the complaint or for
any other claim or relief requested by the plaintiff. You may lose money or property or other
rights important to you.
YOU SHOULD TAKE THIS PAPER TO YOUR LAWYER AT ONCE. IF YOU DO
NOT HAVE A LAWYER OR CANNOT AFFORD ONE, GO TO, OR TELEPHONE THE
OFFICE SET FORTH BELOW TO FIND OUT WHERE YOU CAN GET LEGAL HELP.
Cumberland County Bar Association
2 Liberty Avenue
Carlisle, PA 17013
717-249-3166
THERESA BARRETT MALE, ESQUIRE
Plaintiff
MARIA V. GORDON
V.
Defendant
IN THE COURT OF COMMON PLEAS
CUMBERLAND COUNTY, PENNSYLVANIA
NO.
CIVIL ACTION - LAW
COMPLAINT
AND NOW, comes the Plaintiff, Theresa Barrett-Male, Esquire, by and through her
attorney Charles Rector, Esquire, and avers the following in support of her Complaint against
Defendant, Maria V. Gordon, as follows:
1. Plaintiff, Theresa Barrett-Male, Esquire, is an attorney at law, with her
principal place of business located at 513 N. Second Street, Harrisburg, Dauphin County,
Pennsylvania, 17101.
2. Defendant is Maria V. Gordon, an adult individual who resides at 127 Ewe
Road, Mechanicsburg, Cumberland County, Pennsylvania, 17055.
3. On or about December 7, 2004, Defendant signed a Fee Agreement with
Plaintiff for legal services, a copy of which is attached hereto, incorporated herein and
marked as Exhibit "A."
4. Although partial payments on the outstanding balance were made, with the
last payment received on August 22, 2005, Defendant has failed, and or refused, to pay the
total amount due and owing of $6,625.50, as of March 31, 2008 (See attached Invoices
marked as Exhibit "B".
5. Pursuant to Section 7 of the Fee Agreement, 1.5% interest has been charged
monthly to all unpaid invoices. Interest will continue to accrue through disposition of this
case. See Exhibit "A" at page 2.
6. Pursuant to the Section 6 of the Fee Agreement, Plaintiff is entitled to receive
and Defendant has agreed to pay all costs of collection, including courts costs and legal fees,
if the account is referred to an attorney for collection. See Exhibit "A" at page 2.
7. As of the filing of this Complaint, Plaintiff has incurred reasonable attorney's
fees from the Law Office of Charles Rector, Esquire, P.C., in the collection of the amounts
due and owing by Defendants incident to the within action, and Plaintiff shall continue to
incur such attorney's fees throughout the conclusion of the proceeding in the amount of thirty
percent (30%) of the balance due and owing to the Plaintiff by the Defendants.
8. The amount of attorney's fees which represents thirty percent (30%) of the
current balance due and owing is the sum of $1,987.65.
9. Any and all conditions precedent to the bringing of this action have been
performed by Plaintiff.
10. The amount in controversy does not exceed the jurisdictional amount requiring
compulsory arbitration.
WHEREFORE, Plaintiff, Theresa Barrett-Male, Esquire, demands judgment in her
favor and against Defendant, Maria V. Gordon, in the amount of $6,625.50, counsel fees in
the amount of $1,987.65, plus the additional interest at 1.5% per month, plus costs and for
such other relief as the Court deems just and appropriate under the circumstances.
RESPECTFULLY SUBMITTED,
arles Rector squire
1104 Fernwood Avenue, Ste. 203
Camp Hill, PA 17011-6912
(717) 761-8101
Attorney for Plaintiff
Date: ,/ -?- /' e
VERIFICATION
I verify that the statements made in the foregoing document are true and correct. I
understand that false statements herein are made subject to the penalties of 18 Pa. C.S.
§ 4904, relating to unsworn falsification to authorities.
Theresa Barrett Male, Esquire
Date: March 24, 2008
RETENTION AGREEMENT
This Agreement, consisting of two pages, is made between Theresa Barrett Male, Esquire and
Maria V. Gordon.
1. Scope of Representation
You are retaining me to represent you in connection with your domestic relations actions.
2. Charges
You will pay for all time spent on your case. This includes personal and telephone
conferences, preparing and reviewing documents and correspondence, reviewing e-mail,
telephone, and other messages, research, trial preparation, court time, and travel time.
Document preparation charges are calculated on a time and value basis. The amount of fees
generated will. depend on several factors, including the issues involved, the other parry's
conduct, and whether the case is resolved without court intervention. I have made no
guarantees regarding the outcome of your case.
3. Costs and Expenses
The hourly rates include in-office photocopying and first-class postage. I bill separately for long
distance telephone charges, certified and registered mail, delivery services, on-line research,
and notary fees. I will not advance filing or other court fees. You must pay these costs and
expenses incurred for out-of-office printing and copying, subpoenas, witness fees, court
reporter and transcription services, and similar expenses within ten (10) days of any request
4. Hourly Rates
Attorney: $200.00
Paralegal: $ 95.00 Legal Assistant: $ 75.00
The minimum billing unit is 3/10ths of an hour. These rates will continue through the matters
covered by this agreement. Thereafter, services will be billed at the then-prevailing rates.
5. Retainer
You will pay a. retainer of $5,000.00. If you pay by check or cash, I will deposit the retainer
directly into my IOLTA ("Interest on Lawyers' Trust Accounts"] account If you pay by credit card,
must deposit the retainer into my general account for transfer to the IOLTA account within
five business days. The interest on IOLTA accounts is remitted to the Commonwealth to fund
legal service programs for the indigent. If I request that you replenish the retainer, I will
provide you with thirty (30) days in which to do so.
r ?,
6. Monthly Statements
you will receive a statement each month reflecting fees and costs incurred in the prior month.
If you do not object to the charges within fourteen (14) days of the statement date, you forfeit
the right to contest the bill at a later date. After the retainer is depleted, you must pay the
service charge statement Ia mailed. Checks returned for
balance due by the end of the month in which
Visa and Mastercard for
insufficient funds are subject to $
payment.
I have the right to retain your file pending payment, and to assert a retaining lien against
papers, documents, or other property coming into my possession, and to retain such property
until my fees are paid. If you fail to comply with this agreement, I will exercise my right to
petition the court to withdraw from your case. You will be liable for the costs of collection,
including court costs and legal fees, if I refer your account to collect fees or costs due for my
services.
7. Finance Charges
I assess finance charges of 1.5% per month (annual rate of 18%) on unpaid balances.
8. Mutual Responsibilities
I will advise you of your legal rights and obligations, keeping you informed about the status of
your case. I will send you copies of all correspondence, pleadings, and other documents
related to the case, whether generated by me, the opposing side, or a third party.
You must notify me immediately of any changes in address, telephone number, or employ-
ment; completing and return promptly all papers or documents I send to you. You must advise
me of all facts essential to your case. Your failure to cooperate with me may compromise my
ability to represent you.
g. Withd rawa I/Term !nation of Professional Relationship
If I withdraw as counsel, whether by agreement or pursuant to a court order, you must pay the
outstanding balance due in full within fourteen days (14) of my written request for payment.
You may terminate this agreement by notifying me in writing and remitting a check for
payment of all outstanding fees and costs.
10. Access to File after Case is Terminated
Clo Iles are subject to a retrieval fee of $25.00 payable in advance.
Theresa Barrett Male, Esquire Maria V. Gordon
Date: December 7, 2004 Date: December 7, 2004
2
Theresa Barrett Male, Esquire
513 North Second Street
Harrisburg, PA 17101
December 31, 2004
Maria V. Gordon
127 Ewe Road
Mechanicsburg, PA 17055
Previous balance of Client funds
12/10/04 Payment to account/TBM ck#6972 from VISA payment 1217/04
12/31/04- Payment from account
New balance of Client funds
Fees
12/7104 TBM
TBM Consultation.
Call to opposing counsel;Prepare Documents; Letter to opposing counsel.
12/8/04 TBM File Documents; Letter to Master;Letter to opposing counsel.
12/9/04 TBM Review message from client.
12/10/04 TBM Review message from client.
12/13/04 TBM Review fax from client.
12/15/04 TBM Call to client.
12/16/04 TBM Review message from client.
12/17/04 TBM Review message from client.
TBM Review E-mail from client.
12/20/04 TBM Review message from client.
TBM Review message from client;Review fax from.
12/22/04 TBM Review message from client (2).
12/23/04 TBM Call to opposing counsel;Call from opposing counsel;Call to client.
Total fees
12/31/04- Payment from account
Balance due
We accept Visa and MasterCard for payment
Amount
$0.00
$5,200.00
($1,880.00)
$3,320.00
Hours
2.00 200.00
1.30 260.00
1.20 240.00
0.30 60.00
0.30 60.00
0.30 60.00
1.20 240.00
0.30 60.00
0.30 60.00
0.80 160.00
0.30 60.00
0.50 100.00
0.60 120.00
1.00 200.00
10.40 $1,880.00
($1,880.00)
$0.00
Theresa Barrett Male, Esquire
513 North Second Street
Harrisburg, PA 17101
January 31, 2005
Maria V. Gordon
127 Ewe Road
Mechanicsburg, PA 17055
Previous balance of Client funds
1 /31 /05- Payment from account
Amount
$3,320.00
($1,638.50)
New balance of Client funds $1,681.50
Fees
Hours
1/3/05 TBM Review message from client re Victim's statement.
' 0.30N
30
0 O CHARGE
00
60
TBM s statement & custody.
Review message from client re Victim . .
1/6/05 TBM Review Letter from opposing counsel;Conference with client. 1.80 360.00
1/7/05 TBM Review fax from client. 0.30 60.00
30NO CHARGE
0
TBM Call to client (left message). .
1
00 200.00
1/9/05 TBM Letter to client (draft). .
0
90 00
180
1/10/05 TBM Review message from client;Revise Letter to client. .
1.00 .
200.00
1/12/05 TBM Call to client. 50
0 100.00
1/13/05 TBM Revise Support Calculations. .
0
30 60
00
1/17/05 TBM Review fax from client;Review message from client. .
.
30NO CHARGE
0
1/19/05 TBM Review message from client (2). .
30NO CHARGE
0
1/20105 TBM Review message from client. .
30NO CHARGE
0
1/24/05 TBM Review message from client. .
00
1 200.00
1/26/05 TBM
TBM Conference with client.
Conference with client;Review message from client. .
1.20 240.00
1/27/05 SCA
TBM Fax to Master.
Review fax from client;Review message from client;Fax to opposing, 0.30
0.70 28.50
140.00
counsel; Supervise Paralegal;Fax to Master.
0
50
00
100
1/28/05 TBM Review message from Master; Review message from client (2);Supervise . .
Paralegal; Review information.
30
0
60.00
1/31/05 TBM Review message from client (2). .
11.60 $1,988.50
Total fees
1131/05- Credit/December 2004 statement adjustment ($350.00)
($1,638.50)
1/31/05- Payment from account
Total payments
Balance due
($1,988.50)
$0.00
We accept Visa and MasterCard for payment
Theresa Barrett Male, Esquire
513 North Second Street
Harrisburg, PA 17101
February 28, 2005
Maria V. Gordon
127 Ewe Road
Mechanicsburg, PA 17055
Previous balance of Client funds
2/10/05- Prothonotary/ck#2945
2/28/05- Payment from account
New balance of Client funds
Fees
2/2/05 TBM
2/3/05 TBM
2/7/05 TBM
2/9/05 TBM
2/10/05 SCA
TBM
TBM
2/11105 TBM
2114/05 TBM
2/15/05 TBM
2/16/05 TBM
2/24/05 TBM
Conference with client.
Letter to Dr. Tan;Letter to client;Review fax from client;Review message from client
re divorce.
Call from client;Call to client.
Review fax from client; Letter to client.
File Petition.
Review fax from client;Letter to opposing counsel.
Review fax from client;Review message from client.
Call from client;Letter to client.
Review Letter from opposing counsel to Custody Conciliator.
Review message from client (2);Supervise Paralegal; Review message from client.
Conference call with client & Mr. Young;Call from client.
Review message from client.
Total fees
Costs advanced
2/17/05- Capital Delivery Service/TBM ck#7049
Total costs advanced
Total fees and costs
2/28/05- Payment from account
Balance due
Amount
$1,681.50
($40.00)
($1,431.50)
$210.00
Hours
1.00 200.00
1.10 220.00
1.10 220.00
0.30 60.00
0.50 47.50
0.30 60.00
0.30 60.00
0.70 140.00
0.30 60.00
0.40 80.00
1.20 240.00
0.30NO CHARGE
7.50 $1,387.50
44.00
$44.00
$1,431.50
($1,431.50)
$0.00
We accept Visa and MasterCard for payment
Theresa Barrett Male, Esquire
513 North Second Street
Harrisburg, PA 17101
March 31, 2005
Maria V. Gordon
127 Ewe Road
Mechanicsburg, PA 17055
Amount
Previous balance of Client funds
3/31/05- Payment from account
$210.00
($210.00)
New balance of Client funds $0.00
Fees
Hours
311105 TBM Review message from client. 0.30N O CHARGE
313/05 TBM Conference with client. 1.00 200.00
3/4105 TBM Review Letter from opposing counsel. 0.30 60.00
3/10105 TBM Letter to client. 0.30 60.00
3/15/05 TBM Review message from client. 0.30 60.00
3/16/05 TBM Conference with client. 1.00 200.00
3/17/05 TBM Review message from client;Review message from Master. 0.30 60.00
3/18/05 TBM Custody Conference; Letter to Master;Letter to client. 3.60 720.00
3/28105 TBM Review Letter from opposing counsel. 0.40 80.00
3/29/05 TBM Review message from client. 0.30 60.00
3/30/05 TBM Review message from client. 0.30NO CHARGE
3/31105 TBM Review message from client. 0.30NO CHARGE
Total fees 8.40 $1,500.00
3/31/05- Payment from account ($210.00)
Balance due $1,290.00
We accept Visa and MasterCard for payment
Theresa Barrett Male, Esquire
513 North Second Street
Harrisburg, PA 17101
April 30, 2005
Maria V. Gordon
127 Ewe Road
Mechanicsburg, PA 17055
Amount
Previous balance due $1,290.00
Fees
Hours
4/1/05 TBM Letter to opposing counsel;Letter to client. 0.90 180.00
4/5/05 TBM Review message from client re Mr. Young;Review message from client re letter. 0.30NO CHARGE
4/19/05 TBM Conference with client. 1.00 200.00
4/27/05 TBM Review fax from client (2). 0.30NO CHARGE
4/28/05 TBM Review fax from client. 0.30NO CHARGE
Total fees 2.80 $380.00
Interest on overdue balance $12.72
Total fees and costs $392.72
Balance due $1,682.72
Your account is 30 days past due. Please remit payment in full immediately.
We accept Visa and MasterCard for payment
Theresa Barrett Male, Esquire
513 North Second Street
Harrisburg, PA 17101
May 31, 2005
Maria V. Gordon
127 Ewe Road
Mechanicsburg, PA 17055
Amount
Previous balance due $1,682.72
Fees
Hours
5/2/05 TBM Call to client. 0.50 100.00
5/3/05 TBM Review Brief;Review fax from client re other issues. 0.50 100.00
5/4/05 TBM Review message from client;Review fax from client; Supervise Paralegal. 0.30 60.00
5/5/05 TBM Letter to client. 0.30NO CHARGE
5/16/05 SCA Fax to client. 0.30 28.50
TBM Review message from client. 0.30 60.00
5118/05 TBM Conference with client. 0.70 140.00
5/20105 TBM Review faxes from client. 0.30 60.00
5122/05 TBM Review Financial Information; Review Stipulation & Master's Opinion;Prepare Support 2.00 400.00
Calculations; Letter to client.
5/23/05 TBM Review message from client. 0.30 60.00
5/25/05 SCA Letter to client. 0.30NO CHARGE
TBM Review message from client (2);Call to Judicial Assistant; Letter to client. 0.60 120.00
5/26/05 TBM Review message from client;Supervise Paralegal;Review message from client. 0.30 60.00
5/31/05 TBM Review Letter from opposing counsel. 0.30 60.00
TBM Call from Attorney Winnick. 0.30 60.00
TBM Review message from client. 0.30 60.00
Total fees 7.60 $1,368.50
Interest on overdue balance $17.02
Total fees and costs $1,385.52
Balance due $3,068.24
Your account is 60 days past due. Please remit payment in full immediately.
We accept Visa and Mastercard for payment
Theresa Barrett Male, Esquire
513 North Second Street
Harrisburg, PA 17101
Maria V. Gordon
127 Ewe Road
Mechanicsburg, PA 17055
June 30, 2005
Amount
Previous balance due
Fees
$3,068.24
Hours
6/1/05 TBM Review message from client; Supervise Paralegal.
6/7/05 TBM Review message from client; Supervise Paralegal; Review fax from client.
6/8/05 TBM Conference with client re bills.
TBM Conference with client re custody.
TBM Review message from client re May statement.
6/9/05 TBM Review message from client;Review fax from client.
6/10/05 TBM Review fax from client;Review message from client;Letter to client.
6/13/05 TBM Review message from client (2).
6/16/05 TBM Letter to Custody Conciliator; Letter to client.
6/17/05 TBM Letter to Custody Conciliator; Letter to client.
6/20/05 TBM Review fax from client;Review letter from PSU (revised).
6/23/05 TBM Letter to client.
6/24/05 TBM Review message from client re appointment.
6/27/05 TBM Review Letter from opposing counsel.
TBM Review message from client (2).
6/28/05 TBM Letter to opposing counsel;Letter to client.
TBM Review message from client.
6/29/05 TBM Call from client.
TBM Review message from client.
6/30/05 TBM Letter to Custody Conciliator;Letter to client.
Total fees
interest on overdue balance
Total fees and costs
6/17/05- Payment/ck#486
6130/05- Credit per letter of July 1, 2005
Total payments
Balance due
0.30 60.00
0.30 60.00
0.30NO CHARGE
0.50 100.00
0.30NO CHARGE
0.30 60.00
1.20 240.00
0.30 60.00
0.70 140.00
0.80 160.00
0.30 60.00
0.30 60.00
0.30NO CHARGE
0.30 60.00
0.30NO CHARGE
0.50 100.00
0.30NO CHARGE
0.60 120.00
0.30NO CHARGE
0.70 140.00
8.90 $1,420.00
$19.12
$1,439.12
($100.00)
($1,000.00)
($1,100.00)
$3,407.36
We accept Visa and MasterCard for payment
Theresa Barrett Male, Esquire
513 North Second Street
Harrisburg, PA 17101
July 31, 2005
Maria V. Gordon
127 Ewe Road
Mechanicsburg, PA 17055
Amount
Previous balance of Client funds $0.00
7/30/05- Payment to account/ck#629 $100.00
New balance of Client funds $100.00
Previous balance due $3,407.36
Fees
Hours
7/5105 TBM Review message from client (4). 0.30NO CHARGE
30NO CHARGE
0
7/6/05 TBM Review message from client re argument court. .
30NO CHARGE
0
7/7/05 TBM Review message from client re support issues. .
0
80 160.00
7/25/05 TBM Review messages from client. .
30
0 60
00
7/26/05 TBM Review message from client-,Review fax from client. .
0.30 .
28.50
7/28/05 SCA Fax to client. 0
40 80.00
TBM Review message from client (2). .
0
30 00
60
7/31/05 TBM Review message from client;Review fax from client. . .
3.00 $388.50
Total fees
Interest on overdue balance $34.73
$423.23
Total fees and costs
$3,830.59
Balance due
We accept Visa and MasterCard for payment
Theresa Barrett Male, Esquire
513 North Second Street
Harrisburg, PA 17101
August 31, 2005
Maria V. Gordon
127 Ewe Road
Mechanicsburg, PA 17055
Previous balance of Client funds Amount
$100.00
$3,830.59
Previo us balance due
Fees
Hours
8/3/05 TBM Conference with client;Letter to opposing counsel. 1.00
30N
0 200.00
O CHARGE
8/4/05 TBM Review message from client. .
50
0 100
00
8/5/05 TBM Review message from client;Review fax from client. .
50
0 .
00
100
8/8/05 TBM Review message from client;Letter to client re support;Review message from client. . .
8/9/05 TBM Review message from client. 0.30
30
0 60.00
60.00
TBM Review fax from client. .
0.30 28.50
8/11/05 SCA
TBM Letter to client.
e from client re charge for review fax from client.
iew messa
R 0.30NO CHARGE
TBM g
ev
Review message from client;Supervise Paralegal. 0.30N O CHARGE
8/12/05 TBM Review Letter from opposing counsel. 0.30 60.00
30NO CHARGE
0
TBM Review message from client. .
30
0 60.00
TBM Review fax from client. .
30NO CHARGE
0
8/17/05 TBM Review message from client. .
30NO CHARGE
0
8/18/05 TBM Review message from client. .
0
30 60.00
8/19/05 TBM Review fax from client. .
0.30 60.00
TBM Call from Deb Salem. 30
0 60.00
8/22/05 TBM Review message from client. .
0.30 28.50
8/23/05 SCA Fax to client. 0.30 28.50
8/24/05 SCA Fax to client. 30
0 60.00
TBM Review message from client & taxes. .
1
00 200.00
8/26105 TBM Prepare Petition, Rule & Order. .
8.10 $1,165.50
Total fees
Interest on overdue balance $37.67
$1,203.17
Total fees and costs ($100.00)
8/22/05- Payment/ck#654
$4,933.76
Balance due
We accept Visa and MasterCard for payment
Theresa Barrett Male, Esquire
513 North Second Street
Harrisburg, PA 17101
Maria V. Gordon
127 Ewe Road
Mechanicsburg, PA 17055
Previous balance of. Client funds
9/30/05- Payment from account
New balance of Client funds
Previous balance due
Fees
9/6/05 TBM Review message from client;Letter to client.
9/13/05 TBM Letter to opposing counsel;Letter to client.
Total fees
Interest on overdue balance
Total fees and costs
9/30/05- Payment from account
Balance due
September 30, 2005
Amount
$100.00
($100.00)
$U.UU
$4,933.76
Hours
0.30 60.00
0.30 60.00
0.60 $120.00
X47.68
$167.65
(1100.00)
$5,001.44
We accept Visa and MasterCard for payment
Theresa Barrett Male, Esquire
513 North Second Street
Harrisburg, PA 17101
Maria V. Gordon
127 Ewe Road
Mechanicsburg, PA 17055
Previous balance due
10/5/05 TBM Letter to opposing counsel;Letter to client.
10/14/05 TBM Letter to opposing counsel;Letter to client.
Total fees
Interest on overdue balance
Total fees and costs
Balance due
Fees
October 31, 2005
Amount
$5,001.44
Hours
0.30 60.00
0.30 60.00
0.60 $120.00
$50.97
$170.97
$5,172.41
We accept Visa and MasterCard for payment
Theresa Barrett Male, Esquire
513 North Second Street
Harrisburg, PA 17101
November 30, 2005
Maria V. Gordon
127 Ewe Road
Mechanicsburg, PA 17055
Previous balance due
11/18/05 SCA Letter to client.
Fees
Amount
$5,172.41
Hours
0.30NO CHARGE
Total fees 0.30 $0.00
Interest on overdue balance
Total fees and costs
Balance due
$50.51
$50.51
$5,222.92
We accept Visa and MasterCard for payment
Theresa Barrett Male, Esquire
513 North Second Street
Harrisburg, PA 17101
Maria V. Gordon
127 Ewe Road
Mechanicsburg, PA 17055
December 31, 2005
Amount
Previous balance due
Interest on overdue balance
Total fees and costs
Balance due
$5,222.92
$52.20
$52.20
$5,275.12
We accept Visa and MasterCard for payment
Theresa Barrett Male, Esquire
513 North Second Street
Harrisburg, PA 17101
Maria V. Gordon
127 Ewe Road
Mechanicsburg, PA 17055
January 31, 2006
Amount
Previous balance due
Interest on overdue balance
Total fees and costs
Balance due
$5,275.12
$52.20
$52.20
$5,327.32
We accept Visa and MasterCard for payment
Theresa Barrett Male, Esquire
513 North Second Street
Harrisburg, PA 17101
Maria V. Gordon
in reference to: Collections
March 12, 2008
Amount
Previous balance due
Interest on overdue balance
Total fees and costs
Balance due
$5,327.32
$1,298.18
$1,298.18
$6,625.50
We accept Visa and MasterCard for payment
a
S
a
00
0)
O
b
m
t 7 r"s c:?
77,
-T' 1-1-1
SHERIFF'S RETURN - REGULAR
CASE NO: 2008-01983 P
COMMONWEALTH OF PENNSYLVANIA:
COUNTY OF CUMBERLAND
MALE THERESA BARRETT
VS
GORDON MARIA V
i
NOAH CLINE , Sheriff or Deputy Sheriff of
Cumberland County,Pennsylvania, who being duly sworn according to law,
says, the within COMPLAINT & NOTICE was served upon
GORDON MARIA V the
DEFENDANT , at 1315:00 HOURS, on the 14th day of April 2008
at 127 EWE ROAD
MECHANICSBURG, PA 17055 by handing to
MARIA V GORDON
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
-q/ pkz L4- /
Sworn and Subscibed to
before me this
of
So Answers:
18.00
10.00
.58
10.00 R. Thomas Kline
.00
38.58 04/15/2008
CHARLES RECTOR
By:
day Deputy Sheriff
A. D.
THERESA BARRETT MALE, ESQUIRE
Plaintiff
MARIA V. GORDON
V.
Defendant
TO THE PROTHONOTARY:
IN THE COURT OF
CUMBERLAND COI
NO. 08-1983
CIVIL ACTION - LA
Please mark as settled, discontinued and withdrawn with
above-captioned matter.
RESPECTFULLY SUBMyrTED,
Sarles Rectef, Esquire
1104 Fernwood Avenue, Ste. 203
Camp Hill, PA 17011-6912
(717) 761-8101
Attorney for the Plaintiff
Date: /a l o e
MON PLEAS
, PENNSYLVANIA
the action filed in the
'?''
??
?
:?
• ,
?
?,
?
.
? ? :: °`?
"
M?. ' ?
??
? ?
? ?: •-t.
'r
? rr
-t
.,,;,?
.?: ?°^ ? ?
"'"C°