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HomeMy WebLinkAbout09-0561l FRIEDMAN & KING, P.C. PENNSYLVANIA V. IN THE COURT OF COMMON PLEAS Plaintiff, CUMBERLAND COUNTY LYDELL V. MULDROW, SR. Defendant NO: 4"V/ el'Ui I -Qkrn CIVIL ACTION AT LAW-COLLECTION ARBITRATION NOTICE TO DEFENDANT NAMED HEREIN: 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 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 FORTH BELOW TO FIND OUT WHERE YOU CAN GET LEGAL HELP. CUMBERLAND COUNTY BAR ASSOCIATION 32 S. Bedford Street Carlisle, PA 17013 1-800-990-9108 717-249-3166 Le han demandado a usted enla corte. Si usted quiere defenderse de estas demandas expuestas en las paginas siguientes, usted tiene viente (20) dias de plazo al partie de la fecha de la demanda y la notificacion. Usted debe presentar una apariencia escrita o en persona o por abogado y archivar en la corte en forma escrita sus defensas o sus objeciones a las demandas en contra de su persona. Sea avisado que si usted no se defiende, la corte tomara medidas y puede entrar una orden contra usted sin previo aviso o notificacion y por cualquier queja o alivio que es pedido en la peticion de demanda. Usted puede perder dinero o sus propiedades o otros derechos importantes para usted. LLEVE ESTA DEMANDA A UN ABOGADO IMMEEDIATAMENTE. SI NO TIENE ABOGADO O SI NO TIENE EL DINERO SUFICIENTE DE PAGAR TAL SERVICIO, VAYA EN PERSONA O LLAME POR TELEFONO A LA OFICINA CUYA DIRECCION SE ENCUENTRA ESCRITA ABAJO PARA AVERIGUAR DONDE SE PUEDE CONSEGUIR ASISTENCIA LEGAL. CUMBERLAND COUNTY BAR ASSOCIATION 32 South Bedford Street Carlisle, PA 17013 1-800-990-9108 717-249-3166 JOHN F. KING LAW, P.C. King, Esqu ire J.leV Hanover StreetSuite 103 , PA 17013 (717) 258-4343 -2 t -2 d0 (717) 422-5526 FAX Dated: JOHN F. KING LAW, P.C. John F. King, Esq. ID #61919 19 S. Hanover Street, Suite 103 Carlisle, PA 17013 (717)258-4343 (717)422-5526 (fax) Attorney for Plaintiff FRIEDMAN & KING, P.C. IN THE COURT OF COMMON PLEAS Plaintiff, CUMBERLAND COUNTY PENNSYLVANIA V. NO: 0 9 - SG 1 Cccn -1 ?t.. LYDELL V. MULDROW, SR. Defendant CIVIL ACTION AT LAW-COLLECTION ARBITRATION COMPLAINT AND NOW comes the Plaintiff, Friedman & King, P.C., and brings the within Complaint against the Defendant, Lydell Muldrow, and avers as follows: Plaintiff, Friedman & King, P.C., is a corporation professional organized and existing under the laws of the Commonwealth of Pennsylvania with its principal place of business located at 19 S. Hanover Street, Suite 103, Carlisle, PA 17013. 2. Defendant, Lydell V. Muldrow, Sr., is an adult individual whom Plaintiff believes, and therefore avers, resides at 2902 Chesterbrook Court, Apt. 211, Camp Hill, PA 17011. 3. On or about September 19, 2006, Plaintiff entered into a fee agreement with Defendant whereby Plaintiff agreed to provide legal services to Defendant. A copy of the fee agreement is attached hereto as Exhibit A. 4. During the course of providing services to Defendant, Plaintiff maintained books of account on the services that it rendered and the costs that it incurred on Defendant Lydell V. Muldrow, Sr.'s behalf, which accounts are an accurate and running account of all debits and credits for the provision of such services and incurrence of such costs. 5. Invoices were mailed to Defendant setting forth the services which had been rendered by Plaintiff on behalf of Defendant, the reasonable value being charged for the services, and any outstanding balance due on services rendered prior to that time. See copy of invoices attached hereto as Exhibit B. 6. On or about February 4, 2008, Plaintiff rendered the last of numerous written accounts to Defendant in the amount of $10,051.36. (See Exhibit B.) 7. Although Plaintiff has demanded payment of the balance due of $10,051.36, Defendant has failed to pay all or any part of the balance due Plaintiff. 8. Plaintiff performed its obligations under the agreement between it and Defendant by providing valuable services to Defendant and incurring costs on his behalf, the fair and reasonable value remaining unpaid of which is $10,051.36. 9. Plaintiff has performed its services for Defendant fully and satisfactorily, and conformed to, and complied with, all of the terms and conditions required of it under the written agreement between it and Defendants. 10. Exhibit A provides for a carrying charge of 18% APR ( 1 1/2% per month), together with any costs associated with the collection of a past due account to be paid by the Defendant. 11. Despite Defendant's obligation to pay Plaintiff for the services performed and costs incurred on his behalf, and despite Plaintiffs demands on Defendant for such payment, Defendant has wrongfully failed and refused to pay to Plaintiff the sums due it. 12. Defendant has had an opportunity to scrutinize the accounts. 13. Defendant has agreed to or acquiesced in the correctness of the accounts. 14. Defendant has never questioned or objected either specifically or generally to the numerous accounts rendered. 15. WHEREFORE, Plaintiff, demands judgment against Defendant in the amount of $10,051.36 together with interest, costs of collection as provided in paragraph 10 herein, and costs of suit, all in an amount not in excess of $50,000.00 and, therefore, is bound by compulsory arbitration. Respectfully submitted, JOHN F By: 103 Carlisle, PA 17013 (717) 258-4343 (717) 422-5526 Attorney for Plaintiff VERIFICATION I, John F. King, Esq., hereby acknowledge that I am the President of the Plaintiff corporation in the foregoing action; that I have read the foregoing complaint; and the facts stated therein are true and correct to the best of my knowledge, information and belief. I understand that any false statements herein are made subject to penalties of 18 Pa. C.S. Section 4904, relating to unworn falsification to authorities. F. King, Esq. dent of Friedmanzi , P.C. Dated: h Zc 2-00g x1??6? t ? m o d %oc ®a31?A93E S3183S 00008 " 'FRIEDMAN & KING, P.C. 600 N. 2nd Street, Fifth Floor P.O. Box 984 Harrisburg, PA 17108 (717)236-8000 (717)236-8080 (fax) friedmanandkina@hotmail.com Richard S. Friedman John F. King September 19, 2006 Mr. Lydell V. Muldrow, Sr. 2902 Chesterbrook Court, Apt. 211 Camp Hill, PA 17011 Dear Mr. Muldrow: We are pleased that you have asked our firm to represent you in your divorce, custody and support matters, said divorce complaint having already beery filed by Yom, wife. This letter is a written explanation of our fees, which Pennsylvania law requires attorneys to provide for their clients. We, Friedman & King, P.C., will provide legal services to you on the terms set forth below. 1. This agreement will not take effect, and we will have no obligation to provide legal services, until you return a signed copy of this agreement. This agreement will take effect when you have performed the conditions stated in Paragraphs 1 and 2, but its effective date will be retroactive to the date we first performed services. The date at the beginning of this agreement is for reference only. 2. Although it is customary for us to receive a prepayment of fees and costs, we have waived a prepayment in your particular case. However, you are giving authority for our final bill to be paid by way of monies escrowed from the sale of the marital residence. 3. We feel that the most equitable basis for our fee is to determine how much time is spent on your matter. It is impossible to determine in advance the amount of time that will be needed to complete your case or the amount of fees and costs which you may incur. In the case of litigation or domestic cases, this frequently depends on the nature of the controversies and the willingness of the parties to resolve their differences out of court. Our billing is based on an hourly rate starting at $250.00 per hour for Richard Friedman, Esquire, $225.00 per hour for John F. King, Esquire, and $75.00 per hour for any paralegal or legal assistant's work. However, we are discounting the hourly rate for Mr. King to$200.00. The hourly rates will be subject to increase provided we give you 30 days written notice. We will bill you monthly on a time- expended basis. Although we do not send itemized bills as a matter of course, we do provide a general explanation of the nature of the services provided and the actual hours expended during each billing period. We also maintain in our office records of time used for conferences, telephone calls, drafting documents, research, court time and, if necessary, travel time. These records will be available to you upon request. Fractions of hours are computed in periods of not less than two-tenths (2/10) of an hour for phone calls and written communications. The interruption of other work or phone calls is taken into consideration. In some instances we find it more expedient to bill predetermined set fees for certain services to be performed; i.e., uncontested divorce, incorporation of business, etc. Charges for preparation of documents are calculated on a time plus value basis. You will not be billed for clerical or secretarial time. As is the case with most attorneys, based on the complexity of the issues involved and based on the results obtained, the final bill may be raised accordingly. Further, you hereby acknowledge that Friedman & King, P.C. has the right to terminate its representation of you if you do not follow the advice of the law firm. It may also terminate its representation should it be determined that continuing its representation would create an unreasonable financial burden to the law firm. Friedman & King, P.C. is not required to file an appeal on your behalf should the case be litigated. 4. Travel time shall be defined as our time traveling from our office to meetings, hearings, trials, support conferences, etc. (and returning thereto) in the furtherance of your interests in your matter. Often, our schedule will be such that we will leave from somewhere other than our office to attend such a hearing or meeting, and/or return to a place other than the office after such a hearing or meeting. Travel time in such an instance shall be calculated from the place of origin to the meeting/hearing, and the place of the meetingthearing to our next destination. However, this will not exceed the charge for the time it would have taken if we had left from our own office or returned to our own office. If you are retaining us for a matter involving hearings or a trial in a county other than Dauphin, you have been advised that our fees will likely exceed those which would be charged by local counsel, and counsel in the county in which the matter is pending would not have any or as much travel time for which you will be billed. 5. We expect you to keep current with our billings. We reserve the right to terminate our attorney-client relationship for non-payment of fees or costs. We expect our invoices to be paid in full within the month in which they are received. You should review your invoice promptly. If you fail to object to the charges in the month within which the bill is sent, we will assume that the bill is satisfactory. In the event of any fee dispute or failure to pay fees and costs, or if you feel that this office has not properly represented you and that you have a claim against this office, either you or this office has the right to demand binding and final arbitration under the rules and regulations of the American Arbitration Association as your sole and exclusive remedy. If it is necessary for us to proceed against you for payment of our bill, you will be responsible for paying all costs of collection, including the reasonable value of our services to proceed against you. 6. All bills are due within thirty (30) days. A carrying charge of eighteen (18%) percent APR (1 1/2% per month) will be added after thirty (30) days. 7. We will charge you for the time we spend on telephone calls relating to your matter, including but not limited to calls with you, with court personnel, with opposing counsel, with experts or other witnesses, and with other individuals involved in or material to your matter. The legal personnel assigned to your matter will confer among themselves about the matter, as required. When they do confer, usually only one will charge for the time expended. However, if more than one of our legal personnel attends a meeting, court hearing or other proceeding, each will charge for the time spent. We will charge for waiting time in court and elsewhere and for travel time, both local and out of town. 8. You are hiring us as your attorneys, to represent you in your divorce, custody and support matters. We will provide those legal services reasonably required to represent you, which we expect will include any and all litigation in defense of the divorce action filed by Alice R. Muldrow, and any and all additional litigation or negotiations involving the custody actions with Alice R. Muldrow and Suzette Simpson. No other services will be provided except as specifically requested by you. We will take reasonable steps to keep you informed of progress and to respond to your inquiries, and will return your calls as promptly as possible. Unless we are out of town, most phone calls will be either taken at the time you call us, or returned the same day. 9. An attorney's services are subject to certain laws and ethical guidelines concerning confidentiality. This means that anything confidential which you disclose to this office must be held in confidence by this office and cannot be revealed unless the refusal to reveal it would involve this office in unethical or illegal activities. This right of confidentiality only applies when you meet in private with an attorney and/or any member of his staff. Should you choose to have a family member or friend present during our meetings, your right of confidentiality has been waived, and although this is extremely unlikely, should your attorney be subpoenaed to testify against you in an adversarial proceeding, we would not be able to assert confidentiality as a reason not to give testimony. You are encouraged when dealing with highly adversarial matters to meet alone with your attorney. 10. Unless we make a different agreement in writing, this agreement will govern all future services we may perform for you. 11. You agree to be truthful with us, to cooperate, to keep us informed of developments, to abide by this agreement, to pay our bills on time, and to keep us advised of your address, telephone number and whereabouts. Frequently, courts or other governmental agencies will send documents directly to you, as a party to litigation or as a principal in a business, and they will not send copies to us, as your attorney of record. For this reason it is very important that you forward to us any documents, papers, or correspondence which have been sent directly to you from the court or from any, other source which may have any bearing on this matter. 12. We may incur various costs and expenses in performing legal services under this agreement. You agree to pay for those costs and expenses in addition to the regular fees. If you are being billed on a contingent basis, you understand that these costs will be subtracted from your net proceeds (after subtraction of Friedman & King's fees). Upon request, you agree to pay these costs in advance. The costs and expenses commonly include process servers' fees, fees fixed by law or assessed by courts and other agencies (so-called "filing fees"), court reporters' fees, messenger, overnight delivery and other delivery fees, sheriffs fees, parking and other local travel expenses, photocopying charges if they become excessive and must be performed out of the office, on-line computer research time, and other similar items. To aid in the preparation or presentation of your case, it may become necessary to hire doctors or other expert witnesses. We will not hire such personnel unless you agree to pay their fees and charges. We will select any expert witnesses to be hired. For out of town travel, you agree to pay meals, lodging and all other costs of any necessary out-of-town travel by personnel. You will also be charged the hourly rates for the time legal personnel spend traveling (see paragraph 4). 13. As previously stated, all fees must be paid on a current basis. Should there be outstanding fees at the conclusion of your matter, they must be paid when the case is concluded. Additionally, this office may require that you execute a judgment note or lien upon property or the proceeds of equitable distribution in our favor to secure payment of fees and costs. This office also reserves the right to retain all funds which we receive on your behalf, from any source, to guarantee payment of fees and costs. Regarding funds held in escrow: During the course of our representation, we may have occasion to hold funds in escrow on your behalf. We reserve the right to apply funds held in escrow to pay outstanding billings for services and costs advanced before remitting the balance of the funds held in escrow to you. 14. You may discharge us at any time. We may withdraw with your consent or for good cause. Good cause includes your breach of this agreement, your refusal to cooperate with us or to follow our advice on a material matter, or any fact or circumstance that would render our continuing representation unlawful or unethical. When our services conclude, all unpaid charges will immediately become due and payable. After our services conclude, we will, upon your request, deliver your file to you or your representative, along with any funds or property of yours in our possession. 15. Within ninety (90) days of the conclusion of our representation, whether this occurs because of completion of your matter, your discharge of our services, or our withdrawal as your counsel, you have the right to go through our file and secure copies of anything you wish. If you do not choose to request originals or copies from your file within ninety (90) days after the conclusion of our representation, we will assume that you are waiving this right. At the end of said ninety (90) day period, this office will remove from the file and destroy all nonessential documents, such as court pleadings which are of record at the court house, our memos to the file, our notes on the case, our legal research, and transcripts of depositions. At the end of five (5) years from the date of our conclusion of our representation, we will destroy your file, retaining only those original documents which may be needed in the future by you. 16. On some occasions, a court will order one spouse to pay part or all of the other spouse's fees. Sometimes, the court makes no order for fees and costs. However, as our client, you are primarily responsible for the payment of our total fees. Of course, amounts received pursuant to court order will be credited to your account. 17. Nothing in this agreement and nothing in our statements to you will be construed as a promise or guarantee about the outcome of your matter. We make no such promises or guarantees. Our comments about the outcome of your matter are expressions of opinion only. 18. Our paralegal and secretaries are usually conversant with the status of your file but are not permitted nor are they qualified to give any opinions or to advise clients on any legal matters. 19. As a result of the firm's representation, it may be necessary to gather information protected by federal and state privacy laws. By signing this fee agreement and hiring the firm, you authorize the firm or its representative, to gather any and all information it or they may deem necessary for the prosecution of your claim. This authorization acknowledges the fact that such gathering and disclosure of information may be to a third party not bound by the privacy laws or any other agreement or obligation of confidentiality. Also, you understand that upon conclusion of your case, the firm would normally hold your file and records for possible use on your behalf in the future. However, you further understand that you have the absolute right to notify the firm that you desire to have you records destroyed, or to pick them up to be retained by you. 20. It is not unusual that a client may request that another party be allowed to communicate with us on his or her behalf (such as a spouse, companion, or parent). If you wish to authorize us to communicate with a third individual on your behalf, you must fill out the information at the bottom of this letter and sign your name a second time on the line below the information. Otherwise, we will have no communication with anyone other than you on this matter. You understand that by authorizing a third party to communicate with us, you are waiving the right of confidentiality set forth in paragraph 9 above. We encourage you to call if you have any questions regarding this aspect of our representation. t ? f 21. Please countersign this Agreement and return it to us in the enclosed envelope, so that we will have a mutual memorandum of our understanding. JFK/ka Enclosures I have read and understood the foregoing terms and agree to them, as of the date Friedman & King, COMPLETE THE SECTION BELOW ONLY IF YOU WISH TO AUTHORIZE US TO SPEAK WITH SOMEONE ELSE ON YOUR BEHALF. I authorize Friedman & ng, P.C. to discuss any aspect of my representation with hose relationship to me is This authorization will remain in effect til revoked in writing. cx k,d, + t3 c Mr. Lydell V. Muldrow, Sr. 2902 Chesterbrook Court, Apt. 211 Camp Hill, PA 17011 November 14, 2006 SERVICES RENDERED BY JOHN F. KING, ESQUIRE 06/30/06 Initial consultation (1 hr. no charge), further discussions with client, dictation of letters to Domestic Relations and to Attorney Kelley, telephone conference to opposing counsel, letter to opposing counsel 1.0 09/19/06 Receipt/review of letter from Attorney Kelley, conference with client, letter to Attorney Kelley, letter to opposing counsel 1.0 10/18/06 Telephone conference to opposing counsel, conference with client, letter to opposing counsel, telephone conference to Attorney Kelley 1.4 10/19/06 Telephone conference from Attorney Kelley .2 10/20/06 Two telephone conferences with client, memo .6 10/20/06 Lengthy conference, dictation of Income and Expense and Inventory 4.5 10/25/06 Travel to and from York, conference with Attorney Dell, attendance at Master's conference, conference with opposing counsel 4.5 13.2 hours @ $200.00 per hour j2&40.00 TOTAL DUE $2,640.00 December 13, 2006 Mr. Lydell V. Muldrow, Sr. 2902 Chesterbrook Court, Apt. 211 Camp Hill, PA 17011 SERVICES RENDERED BY JOHN F. KING, ESQUIRE 11/29/06 Attendance at Preliminary Conference with Master regarding special hearing to establish separation date 3.0 3.0 hours @ $200.00 Per hour $ 600.00 COSTS ADVANCED: York County Prothonotary (subpoenas) $ 16.00 BALANCE DUE as per prior billing $2,640.00 TOTAL DUE $3,256.00 Del: Please begin making regular payments of $500.00 per month. AM- t Mr. Lydell V. Muldrow, Sr. January 11, 2007 2902 Chesterbrook Court, Apt. 211 Camp Hill, PA 17011 SERVICES RENDERED BY JOHN F. KING, ESQUIRE 12/07/06 Receipt/review of Master's Memo, letter and telephone conference to client 12/14/06 Telephone conference to client regarding 12/15/06 submittal 12/20/06 Letter from Attorney Laskey, letter to Master Baughman 1.1 hours @ $200.00 per hour $ 220.00 COSTS ADVANCED: York County Prothonotary (subpoenas) $ 8.00 Witness fees for Painter, Cuff, Brownson, Henderson, (2) Muldrows ($15.00 ea.) $ 90.00 BALANCE DUE as per prior billing 11256.00 TOTAL $3,574.00 Minus payment z -L35.00 TOTAL DUE $3,439.00 .5 .2 .4 FRIEDMAN & KING, P.C. 600 N. 2nd Street, Fifth Floor P.O. Box 984 Harrisburg, PA 17108 (717)236-8000 (717)236-8080 (fax) friedmanandking@hotmail.com Richard S. Friedman John F. King February 20, 2007 Mr. Lydell V. Muldrow, Sr. 2902 Chesterbrook Court, Apt. 211 Camp Hill, PA 17011 SERVICES RENDERED BY JOHN F. KING, ESQUIRE THROUGH 2/19/07 12/07/06 Receipt/review of Master's Memo, letter and telephone conference to client 5 12/14/06 Telephone conference to client regarding 12/15/06 submittal .2 12/20/06 Letter from Attorney Laskey, letter to Master Baughman .4 1/4/07 Masters conference in York, letter to opposing counsel 2.4 1/11/07 Long telecon with Ms. Laskey, review of fax, telecon with Lydell 1.0 1/12/07 Preparation for and attendance at hearing re: Separation date 8.0 2/6/07 Travel to and from and attendance at day 2 of hearing on separation date 4.5 2/19/07 Letter from opposing counsel, telecon to opposing counsel, memo .4 17.4 hours @ $200.00 per hour $3,480.00 COSTS ADVANCED: York County Prothonotary (subpoenas) ' Witness fees for Painter, Cuff, Brownson, Henderson, (2) Muldrows ($15.00 ea.) BALANCE DUE as per prior billing TOTAL Minus payment TOTAL DUE $ 8.00 $ 90.00 $3,256.00 $6,834.00 135.00 $6,699.00 FRIEDMAN & KING, P.C. 600 N. 2"a Street, Fifth Floor P.O. Box 984 Harrisburg, PA 17108 (717)236-8000 (717)236-8080 (fax) friedmanandkingc?hotmail com March 7, 2007 Mr. Lydell V. Muldrow, Sr. 2902 Chesterbrook Court, Apt. 211 Camp Hill, PA 17011 Richard S. Friedman John F. King SERVICES RENDERED BY JOHN F. KING, ESQUIRE THROUGH 2/28/07 2/20/07 3 way conference call with opposing counsel and Master, memo, correspondence 3 hours @ $200.00 per hour $60.00 BALANCE DUE as per prior billing $6,699.00 SUBTOTAL $6,759.00 Minus payment 3 500.00 TOTAL DUE $3,259.00 .5 FRIEDMAN & KING, P.C. 600 N. 2nd Street, Fifth Floor P.O. Box 984 ( Harrisburg, PA 17108 (717)236-8000 (717)236-8080 (fax) friedmanandking@hotmail.com Richard S. Friedman John F. King April 10, 2007 Mr. Lydell V. Muldrow, Sr. 2902 Chesterbrook Court, Apt. 211 Camp Hill, PA 17011 SERVICES RENDERED BY JOHN F. KING, ESQUIRE THROUGH 3/31/07 3/7/07 Telecon to client, memo to Barb .3 3/15/07 Preparation of pretrial statement, telecon with Ms. Lasky, revisions to pretrial statement, memo 1.4 3/23/07 Meeting with client 1.2 3/30/07 Travel to and from and attendance at settlement conference 4.0 6.9 hours at $200.00 per hour $1,380.00 COSTS ADVANCED: Conrad Siegel Actuaries 550.00 BALANCE DUE as per prior billing 3,259.00 TOTAL DUE 5$ ,189.00 7 ? FRIEDMAN & KING, P.C. 600 N. 2nd Street, Fifth Floor P.O. Box 984 Harrisburg, PA 17108 (717)236-8000 (717)236-8080 (fax) friedmanandkin& hotmaiI.com Richard S. Friedman John F. King May 7, 2007 Mr. Lydell V. Muldrow, Sr. 2902 Chesterbrook Court, Apt. 211 Camp Hill, PA 17011 SERVICES RENDERED BY JOHN F. KING, ESQUIRE THROUGH 4/30/07 4/12/07 Fax from Atty Laskey re mortgage payoff, calculation of payoff, telecon to Del .5 4/25/07 Prep for third Master's Conference 2.0 4/26/07 Travel to and from and attendance at third Master's Conference, telecon with Del 3.5 6.0 hours at $200.00 per hour $1,200.00 BALANCE DUE as per prior billing 5,189.00 TOTAL DUE $6389.00 FRIEDMAN & KING, P.C. 600 N. 2"d Street, Fifth Floor P.O. Box 984 r Harrisburg, PA 17108 (717)236-8000 (717)236-8080 (fax) friedmanandkinjt@hotmail.com Richard S. Friedman John F. King June 5, 2007 Mr. Lydell V. Muldrow, Sr. 2902 Chesterbrook Court, Apt. 211 Camp Hill, PA 17011 SERVICES RENDERED BY JOHN F. KING, ESQUIRE THROUGH 5/31/07 5/11/07 Meeting with client 2.0 5/24/07 Meeting with opposing counsel re resolution of case negotiations 2.4 4.4 hours at $200.00 per hour $880.00 BALANCE DUE as per prior billing 6,389.00 TOTAL DUE $7,269.00 i FRIEDMAN & KING, P.C. 600 N. 2"d Street, Fifth Floor P.O. Box 984 Harrisburg, PA 17108 (717)236-8000 (717)236-8080 (fax) fried manandking®hotmail com Richard S. Friedman John F. King July 6, 2007 Mr. Lydell V. Muldrow, Sr. 2902 Chesterbrook Court, Apt. 211 Camp Hill, PA 17011 SERVICES RENDERED BY JOHN F. KING, ESQUIRE THROUGH 6/30/07 6/8/07 Meeting with Del, memo 5 .5 hours at $200.00 per hour $100.00 BALANCE DUE as per prior billing 7,269.00 TOTAL DUE 17J69.00 Del - given your recent receipt of funds, and the upcoming hearing proceedings, please forward payment. John c FRIEDMAN & KING, P.C. 600 N. 2nd Street, Fifth Floor P.O. Box 984 Harrisburg, PA 17108 (717)236-8000 (717)236-8080 (fax) friedmanandking@hotmail.com Richard S. Friedman John F. King August 2, 2007 Mr. Lydell V. Muldrow, Sr. 2902 Chesterbrook Court, Apt. 211 Camp Hill, PA 17011 SERVICES RENDERED BY JOHN F. KING, ESQUIRE THROUGH 7/31/07 7/19/07 Telecon with Attorney Laskey re 7/25 hearing / stipulation of non-contested facts, fax to Laskey .4 7/20-23/07 Meetings to prepare 2.0 7/25/07 Travel to and from and attendance at Master's hearing, memo to file 7.0 9.4 hours at $200.00 per hour $1,880.00 BALANCE DUE as per prior billing 7,369.00 COSTS ADVANCED: York County Prothonotary, required filing fee 75.00 TOTAL DUE $9,324.00 DEL - Please call to discuss payment of this large outstanding balance. John r . f FRIEDMAN & KING, P.C. 3820 Market St. Camp Hill PA 17011 717)236-8000 (717)236-8080 (fax) friedmanandking@hotmail.com Richard S. Friedman John F. King September 17, 2007 Mr. Lydell V. Muldrow, Sr. 2902 Chesterbrook Court, Apt. 211 Camp Hill, PA 17011 SERVICES RENDERED BY JOHN F. KING, ESQUIRE THROUGH 8/31/07 8/16/07 Preparation of Proposed Findings of Fact, Conclusions of Law and Argument 2.5 2.5 hours at $200.00 per hour $500.00 COSTS ADVANCED: UPS overnight delivery 27.36 BALANCE DUE as per prior billing 9,324.00 TOTAL DUE $9,851.36 DEL - I must speak with you immediately. John FRIEDMAN & KING, P.C. 3820 Market St. Camp Hill PA 17011 717)236-8000 (717)236-8080 (fax) friedmanandkinL, hotmail com Richard S. Friedman John F. King January 4, 2008 Mr. Lydell V. Muldrow, Sr. 2902 Chesterbrook Court, Apt. 211 Camp Hill, PA 17011 BALANCE OVERDUE as per prior billing $9,851.36 . *-to FRIEDMAN & KING, P.C. 3820 Market St. Camp Hill PA 17011 717)236-8000 (717)236-8080 (fax) friedmanandkin-z@hotmail com Richard S. Friedman John F. King February 4, 2008 Mr. Lydell V. Muldrow, Sr. 2902 Chesterbrook Court, Apt. 211 Camp Hill, PA 17011 12/10/07 Telephone conference from Attorney Laskey, review of Master's Report, telephone conference to Attorney Laskey, letter to client 8 12/21/07 Telephone conference from Attorney Laskey, letter to client .2 1.0 hours @ $200.00 per hour $ 200.00 BALANCE OVERDUE as per prior billings L2,851.36 TOTAL DUE $10,051.36 FRIEDMAN & KING, P.C. 3820 Market St. Camp Hill PA 17011 717)236-8000 (717)236-8080 (fax) fried manandking®hotmail com Richard S. Friedman John F. King February 4, 2008 Mr. Lydell V. Muldrow, Sr. 2902 Chesterbrook Court, Apt. 211 Camp Hill, PA 17011 12/10/07 Telephone conference from Attorney Laskey, review of Master's Report, telephone conference to Attorney Laskey, letter to client 8 12/21/07 Telephone conference from Attorney Laskey, letter to client .2 1.0 hours @ $200.00 per hour $ 200.00 BALANCE OVERDUE as per prior billings 9 851.36 TOTAL DUE $10,051.36 FRIEDMAN & KING, P.C. 3820 Market Street Camp Hill, PA 17011 (717)236-8000 (717)236-8080 (fax) friedmanandking®hotmail com Richard S. Friedman John F. King July 9, 2008 Mr. Lydell V. Muldrow, Sr. 2902 Chesterbrook Court, Apt. 211 Camp Hill, PA 17011 Dear Dell: It's been a number of months since we've communicated. I believe the last time we spoke, you indicated that you were planning on sending us a substantial payment after your tax filing. We have not received that payment, nor have we received any payment from you whatsoever. As I was reviewing some overdue bills, I noted that your balance as of the February bill was $10,051.36. Unfortunately, the firm cannot afford to continue to carry this outstanding balance. As I believe you are aware, we have never applied our interest carrying charge to your bill, although the fee agreement does allow it. If you begin making regular monthly payments in a minimum of $300.00 per month, I will forego the application of the interest. Please note the first payment must be received no later than August 1, 2008, and the beginning of each month thereafter. If not, I will be forced to apply interest to your bill from the date that the charges were incurred, and will also be forced to seek a judgment in favor of the firm for your outstanding amount owed. Thank you very much for your immediate attention to this matter. Very truly yours, JFK/bp John F. King DICTATED BUT NOT READ 70 SHERIFF'S RETURN - REGULAR CASE NO: 2009-00561 P COMMONWEALTH OF PENNSYLVANIA: COUNTY OF CUMBERLAND FREEDMAN AND KING PC VS MULDROW LYDELL V SR RONALD E HOOVER , Sheriff or Deputy Sheriff of Cumberland County,Pennsylvania, who being duly sworn according to law, says, the within NOTICE was served upon MULDROW LYDELL V SR the DEFENDANT , at 0018:58 HOURS, on the 5th day of February-, 2009 at 2902 CHESTERBROOK COURT APT 211 CAMP HILL, PA 17011 LYDELL V. MULDROW a true and attested copy of NOTICE COMPLAINT together with and at the same time directing His attention to the contents thereof. Sheriff's Costs: Docketing Service Affidavit Surcharge Sworn and Subscibed to before me this of So Answers: 18.00 11.70 .00 10.00 R. Thomas Kline .00 39.70 02/06/2009 FRIEDMAN & KING By: a_4exg;?e day Deputy Sheriff by handing to A. D. rv • i -t ?rV> .,..+ ?. .fix. Zr " .+??' JOHN F. KING LAW, P.C. John F. King, Esq. ID #61919 19 S. Hanover Street, Suite 103 Carlisle, PA 17013 (717)258-4343 (717)422-5526 (fax) Attorney for Plaintiff FRIEDMAN & KING, P.C. IN THE COURT OF COMMON P?EAS Plaintiff, CUMBERLAND COUNTY PENNSYLVANIA V. NO: 09-561 LYDELL V. MULDROW, SR. Defendant CIVIL ACTION AT LAW-COLLECTION ARBITRATION PRAECIPE FOR DISCONTINUANCE Pursuant to Pennsylvania Rule of Civil Procedure 229, please mark the above captioned case as voluntarily discontinued and settled. Dated: March f ??-, 2009 Respectfully submitted: