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Home My WebLink About08-7315ABOM C& ' j?UTLILAKIS Wayne Melnick, Esquire Attorney I.D. No.: 53150 36 South Hanover Street Carlisle, Pennsylvania 17013 (717) 249-0900 ABOM & KUTULAKIS, LLP, IN THE COURT OF COMMON PLEAS Plaintiff OF CUMBERLAND COUNTY VS. ROBERT BRYNER, CIVIL ACTION - LAW Defendant NO. '7 3 / 5- OF 2008 CIVIL TO DEFENDANT ROBERT BRYNER: 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 an attorney and filing in writing with the court your defenses or objections to the claims set forth against you. You are warned that if you fail to do so the case may proceed without you and a judgment may be entered against you by the court without further notice for any money claimed in the complaint or for any other claim or relief requested by the 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 FOR BELOW TO FIND OUT WHERE YOU CAN GET LEGAL HELP. CUMBERLAND COUNTY BAR ASSOCIATION 32 SOUTH BEDFORD STREET CARLISLE, PA 17013 1-800-990-9180 or (717) 249-3166 L 4 T;?OM & &U i ULAKIS Wayne Melnic% Esquire Attorney 1. D. No.: 53150 36 South Hanover Street Carlisle, Pennsylvania 17013 (717) 249-0900 ABOM & KUTULAKIS, LLP, :IN THE COURT OF COMMON PLEAS Plaintiff OF CUMBERLAND COUNTY VS. ROBERT BRYNER, CIVIL ACTION - LAW Defendant NO. -73) S OF 2008 CIVIL COMPLAINT AND NOW, comes the Plaintiff, Abom & Kutulakis, LLP, and makes the following Complaint against the Defendant, Robert Bryner, as follows: 1. The Plaintiff is Abom & Kutulakis, LLP, a Pennsylvania limited liability partnership engaged in the practice of law with an address of 36 South Hanover Street, Carlisle, PA 17013. 2. The Defendant is Robert Bryner, an individual with an address of 12 Cooper Circle, Carlisle, PA 17013. 3. The parties entered a contract for legal representation dated March 18, 2003, a copy of which is attached hereto and marked as Exhibit A. 4. To date, the Defendants have incurred unpaid services with the Plaintiff in the amount of $10,746.51. A copy of Defendant's latest invoice is attached hereto and marked as Exhibit B. 5. Plaintiff has made numerous demands for the outstanding payment. 6. All payments made by Defendant to date have been applied against his outstanding balance. WHEREFORE, the Plaintiff demands Judgment against the Defendant in the amount of $10,746.51 plus reasonable legal fees, costs, and interest as permitted by law. Respectfully submitted, Date: /9?1/ 5- /off ABOM & KUTULAKIS, L.L.P. By: a e Melnick, Esquire Attorney I.D. No. 53150 36 South Hanover Street Carlisle, PA 17013 (717) 249-0900 VERIFICATION I verify that the statements made in the foregoing Complaint are true and correct. understand that false statements herein are made subject to the penalties of Pa.C.S. §4904, relating to unsworn falsification to authorities. Date AJ30M & KUTULAKIS ATTORNEYS AT LAW FEE AGREEMENT 1. KNOW ALL MEN BY THESE PRESENT, that the undersigned, , hereinafter referred to as "Client," does hereby irrevocably name, appoint and retain, the law firm of Abom & Kutulakis, L.L.P., 8 South Hanover Street, Suite 204, Carlisle, PA as my true and lawful attorney, hereafter referred to as "Counsel," in the handling of Client's custody matter, to include filing for Special Relief. 2. With full power and authority to appear on behalf of the Client in any court of record or in any other proceeding whatsoever, as per the limits of this Agreement. 3. And in consideration of services performed and to be performed by Counsel, it is agreed that Counsel shall receive a fee of $600.00 payable upon execution of this Agreement as a non-refundable retainer fee. The retainer fee will be applied to the legal fees, as well as the anticipated filing and administrative fees. In the event that the retainer fee is consumed, Client may be required to submit and additional retainer fee. 4. Client shall be billed at the rate of $150.00 per hour. 5. In addition, it is understood that the Client shall be solely responsible, in addition to the fee, for all costs, expenses and disbursements that are necessary to the defense of the case. Out of pocket expenses for travel, toll calls, expert witnesses, and similar items for certain administrative services, such as photocopying, telecopy transmission and receipt, computer assisted research, special delivery and secretarial overtime specifically related to Client's case, will be billed in addition to the fee set forth above. Date: Date: March 18, 2003 dot ryner ABOM & KUTULAKIS, L.L.P. By: Kara W. Haggerty, Esquire 350 ?p.? 3?a?o3 p.Q2, of ARs??. 3/a8l 3 U 8 SOUTH HANOVER STREET, SUITE 204 CARLISLE, PA 17013 (717) 249-0900 FAx (717) 249-3344 Abom & Kutulakis 36 South Hanover Street Carlisle, PA 17013 Robert Bryner 11 Cooper Circle Carlisle, PA 17013 Ph: (717) 249-0900 Fax: (717) 249-3344 Federal I.D. 25-1877844 Dec 11, 2008 FILE #: 03-089 INVOICE 26718 Attention: RE: Custody and Special Relief Total Fees, Disbursements $0.00 Retainer Applied $0.00 Retainer Remaining $0.00 Previous Balance $10,746.51 Previous Payments $0.00 Interest Paid Since Previous Invoice $0.00 Interest Due $0.00 Balance Due Now $10,746.51 r a C? r ti SHERIFF'S RETURN - REGULAR CASE NO: 2008-07315 P COMMONWEALTH OF PENNSYLVANIA: COUNTY OF CUMBERLAND ABOM & KUTULAKIS LLP VS BRYNER ROBERT MICHELLE GUTSHALL , Sheriff or Deputy Sheriff of Cumberland County,Pennsylvania, who being duly sworn according to law, says, the within COMPLAINT & NOTICE was served upon BRYNER ROBERT the DEFENDANT , at 0923:00 HOURS, on the 3rd day of January , 2009 at 12 COOPER CIRCLE CARLISLE, PA 17013 ROBERT BRYNER by handing to a true and attested copy of COMPLAINT & NOTICE together with and at the same time directing His attention to the contents thereof. Sheriff's Costs: Docketing Service Postage Surcharge Sworn and Subscibed to before me this of So Answers: 18.00 4.50 0?-o .56 10.00 R. Thomas Kline .00 33.06 01/05/2009 ABOM & KUTULAKIS By: ms-?? day Deputy Sheriff A. D. GO u? 4. FP .w ? A% • N TAB OM CSC" U ULAKIS Wayne Melnick, Esquire Attorney I.D. No.: 53150 36 South Hanover Street Caiisk, Pennsylvania 17013 (717) 249-0900 ABOM & KUTULAKIS, LLP, VS. ROBERT BRYNER, TO: Robert Bryner 12 Cooper Circle Carlisle, PA 17013 IN THE COURT OF COMMON PLEAS Plaintiff OF CUMBERLAND COUNTY CIVIL ACTION - LAW Defendant NO. 0 '73 / S OF 2008 CIVIL Date of Notice: February 20, 2009 IMPORTANT NOTICE YOU ARE IN DEFAULT BECAUSE YOU HAVE FAILED TO ENTER A WRITTEN APPEARANCE PERSONALLY OR BY ATTORNEY AND FILE IN WRITING WITH THE COURT YOUR DEFENSES OR OBJECTIONS TO THE CLAIMS SET FORTH AGAINST YOU. UNLESS YOU ACT WITHIN TEN (10) DAYS FROM THE DATE OF THIS NOTICE, A JUDGMENT MAY BE ENTERED AGAINST YOU WITHOUT A HEARING AND YOU MAY LOSE YOUR PROPERTY OR OTHER IMPORTANT RIGHTS. YOU SHOULD TAKE THIS NOTICE TO A LAWYER AT ONCE. IF YOU DO NOT HAVE A LAWYER OR CANNOT AFFORD ONE, GO TO OR TELEPHONE THE FOLLOWING OFFICE TO FIND OUT WHERE YOU CAN GET LEGAL HELP: CUMBERLAND COUNTY BAR ASSOCIATION 32 South Bedford Street Carlisle, PA 17013 1-800-990-9180 or (717) 249-3166 Respectfully submitted, ABOW & KV 7VLASIS, LLP DANE Wayne Melnick, Esq 36 S. Hanover Street Carlisle, PA 17013 (717) 249-0900 ID No. 53150 CERTIFICATE OF SERVICE AND NOW, this 25`' day of February, 2009, I, Emily Filiberti, of Abom & Kutulakis, L.L.P, hereby certify that I did serve a true and correct copy of the foregoing Notice of Intent to Seek Default judgment upon the Defendant by depositing, or causing to be deposited, same in the United States Mail, postage prepaid addressed to the following: Robert Bryner 12 Cooper Circle Carlisle, PA 17013 Emily F' ?-., r,? c? _..; ? -?? --'. f? ? ? -za ,-ra ? ?-; ? ?°.,. ".Y `Y'i '??,- ?.)