Loading...
HomeMy WebLinkAbout10-1060TINA HUGHES, Plaintiff V. ROBERT P. HUGHES, Defendant IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA .t NO. /O - /06d G-w? CIVIL ACTION -LAW : IN DIVORCE 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 prompt action. You are warned that if you fail to do so, the case may proceed without you and a decree of divorce or annulment may be entered against you by the court. A judgment may also be entered against you for any other claim or relief requested in these papers by the Plaintiff. You may lose money or property or other rights important to you, including custody or visitation of your children. When the ground for the divorce is indignities or irretrievable breakdown of the marriage, you may request marriage counseling. A list of marriage counselors is available in the Office of the Prothonotary, Cumberland County Courthouse, I Courthouse Square, Carlisle, PA. IF YOU DO NOT FILE A CLAIM FOR ALIMONY, DIVISION OF PROPERTY, LAWYER'S FEES OR EXPENSES BEFORE A DIVORCE OR ANNULMENT IS GRANTED, YOU MAY LOSE THE RIGHT TO CLAIM ANY OF THEM. 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, THIS OFFICE MAY BE ABLE TO PROVIDE YOU WITH INFORMATION ABOUT AGENCIES THAT MAY OFFER LEGAL SERVICES TO ELIGIBLE PERSONS AT A REDUCED FEE OR NO FEE. CUMBERLAND COUNTY BAR ASSOCIATION 32 SOUTH BEDFORD STREET CARLISLE, PA 17013 1-800-990-9108 717-249-3166 3 3S.2. 00 pd 44 ohn F. King, Esquir 6 1 :z W8 11 83J 010Z ek* low ? 759 ?Lt1??ci?-t?3ll? JOHN F. KING LAW, P.C. John F. King, Esquire ID #61919 19 S. Hanover Street Suite 103 Carlisle, PA 17013 Tel.: (717) 258-4343/Fax: (717) 422-5526 TINA HUGHES, Plaintiff V. ROBERT P. HUGHES, Defendant Attorney for Plaintiff IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA Gory ??A-c NO. 16 -1666 CIVIL ACTION -LAW IN DIVORCE COMPLAINT UNDER SECTION 3301(c) OR SECTION 3301(d) OF THE DIVORCE CODE 1. Plaintiff is Tina Hughes, who currently resides at 31 Winchester Gardens, Carlisle, Cumberland County, Pennsylvania 17013, since January 2010. 2. Defendant is Robert P. Hughes, who currently resides at 21 Hidden Noll Road, Carlisle, Cumberland County, Pennsylvania 17013, since 2008. 3. The parties have been bona fide residents in the Commonwealth for at least six (6) months immediately previous to the filing of this Complaint. 4. The Plaintiff and Defendant were married on October 16, 1999, in Carlisle, Cumberland County, Pennsylvania. 5. There have been no prior actions of divorce or for annulment between the parties. 6. The marriage is irretrievably broken. 7. Plaintiff has been advised that counseling is available and that Plaintiff may have the right to request that the Court require the parties to participate in counseling. I WHEREFORE, Plaintiff requests the Court to enter a Decree of Divorce. Respectfully submitted, JOHN F. KING LAW, P.C. Date: February 5 2010 G & 46hn F. King, Esquire 19 S. Hanover Street Suite 103 Carlisle, PA 17013 (717) 258-4343 VERIFICATION I, Tina Hughes, hereby acknowledge that I am the Plaintiff in the foregoing action; that I have read the foregoing Divorce 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 unsworn falsification to authorities. U"? A\ ? Tina Hughes Dated: '_2 /I ( U TINA HUGHES, : IN THE COURT OF COMMON PLEAS Plaintiff :CUMBERLAND COUNT', PENNSYLVANIA v. : NO. 10-1060 ROBERT P. HUGHES, :CIVIL ACTION -LAW Defendant : IN DIVORCE ,,,,, n o o `~ ix~ ~ NOTICE TO DEFEND AND CLAIM RIGHTS ~ ~'" ~ '~ ~ r`~- ,~~ ~~ N ~ You have been sued in court. If you wish to defend against the claims set forth in •follo~ng -:;±t;:; pages, you must take prompt action. You are warned that if you fail to do so, the case ma~yceed~ t'~; c ~ without you and a decree of divorce or annulment may be entered against you by the court. jud~tent a r~r may also be entered against you for any other claim or relief requested in these papers by the ~intif~ You may lose money or property or other rights important to you, including custody or visitation of~'our ~ children. When the ground for the divorce is indignities or irretrievable breakdown of the marriage, you may request marriage counseling. A list of marriage counselors is available in the Office of the Prothonotary, Cumberland County Courthouse, 1 Courthouse Square, Carlisle, PA. IF YOU DO NOT FILE A CLAIM FOR ALIMONY, DIVISION OF PROPERTY, LAWYER'S FEES OR EXPENSES BEFORE A DIVORCE OR ANNULMENT IS GRANTED, YOU MAY LOSE THE RIGHT TO CLAIM ANY OF THEM. 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, THIS OFFICE MAY BE ABLE TO PROVIDE YOU WITH INFORMATION ABOUT AGENCIES THAT MAY OFFER LEGAL SERVICES TO ELIGIBLE PERSONS AT A REDUCED FEE OR NO FEE. CUMBERLAND COUNTY BAR ASSOCIATION 32 SOUTH BEDFORD STREET CARLISLE, PA 17013 1-800-990-9108 717-249-3166 t F. King, Esqu' e ~~~. s~ P~ ~~i ~Y~ ~v37 ~~ ~y~ 9~~. JOHN F. KING LAW, P.C. John F. King, Esquire ID #61919 4076 Market Street Camp Hill, PA 17011 717-695-2222 / 717-695-2207 FAX TINA HUGHES, Plaintiff v. ROBERT P. HUGHES, Defendant Attorney for Plaintiff IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA NO. 10-1060 CIVIL ACTION -LAW IN DIVORCE AMENDED COMPLAINT UNDER SECTION 3301(c) OR SECTION 3301(d): WITH ADDITIONAL COUNT PURSUANT TO Pa.RC.P RULE 1920.13 1. Plaintiff is Tina Hughes, who currently resides at 31 Winchester Gardens, Carlisle, Cumberland County, Pennsylvania 17013, since January 2010. 2. Defendant is Robert P. Hughes, who currently resides at 21 Hidden Noll Road, Carlisle, Cumberland County, Pennsylvania 1701.3, since 2008. 3. The parties have been bona fide residents in the Commonwealth for at least six (6) months immediately previous to the filing of this Complaint. 4. The Plaintiff and Defendant were married on October 16, 1999, in Carlisle, Cumberland County, Pennsylvania. 5. There have been no prior actions of divorce or for annulment between the parties. 6. The marriage is irretrievably broken. 7. Plaintiff has been advised that counseling is available and that Plaintiff may have the right to request that the Court require the parties to participate in counseling. WHEREFORE, Plaintiff requests the Court to enter a Decree of Divorce. COUNTI REQUEST FOR EQUITABLE DIVISION OF MARITAL PROPERTY PURSUANT TO 23 Pa.C.S.A. & 3502(a) 8. The prior paragraphs of this Complaint are incorporated herein by reference thereto. 9. The Plaintiff and Defendant have legally and beneficially acquired property, both real and personal, during their marriage. 10. The Plaintiff and Defendant have been unable to agree as to equitable distribution of the said property to the date of the filing of this Complaint. WHEREFORE, the Plaintiff, Tina Hughes, requests this Court to equitably divide all marital property. Respectfully submitted, JOHN F. KING LAW, P.C. Date: May ~ d~--~ , 2010 ~ c~ J F. King, Esquir 4076 Market Street Camp Hill, PA 17011 717-695-2222 / 717-695-2207 FAX VERIFICATION I, Tina Hughes, hereby acknowledge that I am the Plaintiff in the foregoing action; that I have read the foregoing Amended 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 unsworn falsification to authorities. \ \ tiv~~, Tina Hughes Dated: May , 2010 TINA HUGHES, Plaintiff v. ROBERT P. HUGHES, Defendant h N ~ c 'i 1 ~ x. ~ ~ y ..a . 0.J.1 .y3. ~- ...,~ ~~ CERTIFICATE OF SERVICE r=-` ~'~ N ~' z I hereby certify that I am this 10`h day of February, 2010, serving the forego~tl~`"` ivq~e ~,-~'-, complaint upon the person and in the manner indicated below which service satisfie~ie ~, ~~ requirements of the Pennsylvania Rules of Civil Procedure. '~ ~~ Service by First Class Mail Restricted Delivery addressed as follows: Robert Hughes 21 Hidden Noll Carlisle, PA 17013 ,~/~ I Sharry Semans I'u ~ ~ ~" 1 ~ Complete items 1, 2, and 3. Also complete ~ ~ - ~ ~ item 4 if Restricted Delivery is desired. ~ your name and address on the reverse - t we can return the card to you. 0" ^ Attach this card to the back of the mailpiece, fn O or on the front if space permits. ~ Postage $ 1 Article Addres sed to: ~ Certified Fee O i F ~ ~ / 1 ~ /`•~"~" ~--1 u ! ~tc'J C / w 1 , I' J a % ( ~ ' pt ee Return Rece (Endorsement Regwred) ~ G~ ~ l / ~ / ~r ( rrt IN ~ Restricted Delivery Fea O (Endorsement Reqwred) ~~~ V j , ~ ~ ~~7 /~ /`~Ol~ tit 5 r~ ~ Total Postage & Fees O .. Q O Sent To ~' Stiee[, Apt. No.; PO B No or ox ---------°-------------°-~ 2. Article Number City, State, Z1P+4 (Transfer from service label) "' - " PS FOm1~3811,'February 2004 Domest~ Return Receipt ij a IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA NO. 10-1060 CIVIL ACTION -LAW IN DIVORCE X ~ ~~-°'"~^ Agent ^ Addressee B. Rece~ ed by D nt d Name) C. Date of Delivery rr t A ~n~n D. Is delivery addrisss different from`1t~rrt 1'1 ~ If YES, enter delivery address below: ^ No 3. Service Type ii~ertified Mail ^ Express Mail ^ Registered ^ Return Receipt for Merchandise ^ Insured Mail ^ C.O.D. 4. Restricted Delivery? (Extra Fee) 7006 0100 0005 1039 9092 102595-02-M-1540 TINA HUGHES, IN THE COURT OF COMMON PLEAS OF PLAINTIFF :CUMBERLAND COUNTY, PENNSYLVANIA V. ROBERT P. HUGHES, DEFENDANT NO. 10-1060 CIVIL ORDER OF COURT AND NOW, this 13th day of May, 2010, upon consideration of the Petition for Special Relief filed by Plaintiff, Tina Hughes; IT IS HEREBY ORDERED AND DIRECTED that a hearing in this matter will be held on Wednesday, July 14, 2010, at 3:00 p.m. in Courtroom No. 2 of the Cumberland County Courthouse, Carlisle, Pennsylvania. IT IS FURTHER ORDERED AND DIRECTED that pending the hearing and further Order of Court, Robert P. Hughes and/or any individuaUbroker operating on his behalf shall escrow 65% of the proceeds from the sale of the marital residence, a manufactured housing unit, located at 21 Hidden Noll, Carlisle, PA 17013. By the Court, ~~ M. L. Ebert, Jr., J. John F. King, Esquire Attorney for Plaintiff ~ C7 0 ;-~ ./Robert P. Hughes ~~ ~ 21 Hidden Noll ~<<; ~ ,~-~~-~ ~ -C Carlisle, PA 17013 ~~-,~,,_ -- -~ ~~=~ ~ Park Place Properties ~~ "'~'' `;.~; Attn: Terrance Kimball ~~ ~,, ~`~`~ 51 North Pitt Street ~ o Carlisle, PA 17013 bas ~'~'~iF.s' rn~~I 5~l3~Jd ~ir~ TINA HUGHES, IN THE COURT OF COMMON PLEAS Plaintiff CUMBERLAND COUNTY, PENNSYLVANIA v. N0. 10-1060 ROBERT P. HUGHES, CIVIL ACTION -LAW ,~, ~_ - Defendant IN DIVORCE `~ .' -,_ ._... -~- .'. ~;-, ` ~ ; ~'~ _~ -~ ~ _ CERTIFICATE OF SERVICE ~- `~ - `=~ -" r I hereby certify that I am this 12th day of May, 2010, serving the foregoing amended divorce complaint and petition for special relief upon the person and in the manner indicated below which service satisfies the requirements of the Pennsylvania Rules of Civil Procedure. Service by First Class Mail Restricted Delivery addressed as follows: Robert Hughes 21 Hidden Noll Carlisle, PA 17013 o ~ - - Sherry Semans .,a ~ ~, ~ .•. Q., lT m 0 ~ Postage tJ'1 ~ Certified Fee O L] Return fleceipt Fee (Endorsement Required) 0 Restricted Delivery Fee O (Endorsement Required) r-~ ~ Total Postage & Fees .~ (~ Sent To Rfrastf Ant. Nn.: or PO Box No. --- ------------------------------------------------ City, State, ZlP+4 Postmark Here ^ Complet items 1, 2, and 3. Also complete item 4 if ~e~tricted Delivery is desired. --------------- i Print your name and address on the reverse so that w~ can return the card to you. ----°--------- ^ Attach this card to the back of the mailpiece, ;,or on the front if space permits. A. X ^ Agent 1. Article Addressed to: ,~-~ ~~9 ~t~s ~~ ff ~~~~ tide ~~~ sCe. I~~ /74f3 B~ ived~y,F p/~~ " ~~~ I~ t~ 7 Bl D D. Is delivery address different from item 1? ^ Yes if YES, enter delivery address below: ^ No 3. Service Type y" ertified Mail ^ Express Mail ^ Registered ^ R'eturn Receipt for Merchandis ^ Insured Ma11 ^ C.O.D. 4. Restricted Delivery? (Extra Fee) 2. Article Number (Transfer from service laben 7 a a 6 a y a o a a a 5 1 a 3 9 916 a PS Form 3811, February 2004 Domestic Return Receipt urzsss-o2-nn-ts< a ,~ JUL 0 7 2010 TINA HUGHES, Plaintiff v. ROBERT P. HUGHES, Defendant IN THE COURT OF COMMON PLEAS CUMBERLAND COiJNT~', PENNSYLVANIA NO. 10-1060 CIVIL ACTION -LAW IN DIVORCE ORDER '~ AND NOW this 7 _ day of ~.11 y , 2010, upon consideration of the Motion filed by Plaintiff/ Wife, Tina Hughes, and the Marital Settlement Agreement executed by the parties, it is hereby ORDERED that the broker/agent, Terrance L. Kimball, Park Place Properties, or the authorized agent agent thereof, distribute the funds escrowed in the sale of the marital residence as follows: A. $500.00 to Robert Hughes, by personal delivery or by mailing to 1732 Trindle Road, Carlisle, PA 17015; and B. $5,099.77 to Tina Hugi,e~, payable to Tina I-Iughes, by mailing to John F. King, Esq., 4076 Market Street, Can~ip HiII, PA 170 i 1. BY THE COURT: DISTRIBUTION: John F. King, Esq., 4076 Market St., 4'atnp Full, P'~ 1.7()11 Robert P. Hughes, 1732 Trindle P~ua ~, Carlisle. I'A 17013 ,..~ /Park Place Properties, Attn: '1 ~~~ .~ti~~ ' . Kimball, S 1 N. Pitt Street , Carlisle, PA 17013 ~ ;~ -'~ -- _` - i .; ~ ~ ; } ~~ ~y «Y, _. _ry -`~ (_~ JOHN F. KING LAW,P.C. { : ME FILED-0- T I�� f John F. King,Esq. tt i ID #61919 MO SEp _4 Mtj+ 20 4076 Market Street, Ste 1 Camp Hill, PA 17011 CUPMERLAN Cf1U ' � (717) 695-2222 PENNS yLD COUNT (717) 695-2207 FAX TINA HUGHES, : IN THE COURT OF COMMON PLEAS Plaintiff : CUMBERLAND COUNTY, PENNSYLVANIA V. :NO. 10-1060 ROBERT P. HUGHES, : CIVIL ACTION- LAW Defendant : IN DIVORCE Judge: Han.M.L. Ebert,Jr. PETITION FOR LEAVE TO WITHDRAW AS PLAINTIFF'S COUNSEL AND NOW comes the Petitioner, John F. King, Esquire, seeking leave of this Honorable Court to withdraw as counsel for Plaintiff, Tina Hughes,pursuant to the Rules of Professional Conduct Rule 1.16, and avers as follows: I. Petitioner is counsel of record for Plaintiff herein by virtue of having filed a Divorce Complaint on February 11, 2010. 2. Petitioner and Plaintiff entered into a fee agreement on or about February 9, 2010. See Exhibit"A"attached. 3. Pursuant to said fee agreement, Petitioner has the right to terminate his representation of Plaintiff at any time should Plaintiff not cooperate, not abide by the fee agreement, and/or not pay Petitioner's bills. 4. Despite the execution of a Martial Settlement Agreement, Plaintiff has failed to sign the documents necessary to finalize the divorce, thereby failing to substantially fulfill an obligation to Petitioner regarding his services. 5. Plaintiff has failed to respond to correspondences and telephone messages left by Petitioner since July 2010, shortly after she received a portion of settlement proceeds from the sale of the marital residence. 6. Plaintiff has failed to pay her outstanding bill for services thereby resulting in an unreasonable financial burden on Petitioner. 7. The withdrawal can be accomplished without material adverse effect on the interests of the Plaintiff. 8. Due to the uncooperativeness of the Plaintiff and the terms of the fee agreement, Petitioner hereby respectfully requests that he be allowed to withdraw as counsel for Plaintiff. WHEREFORE, Petitioner seeks leave of this Honorable Court to terminate Petitioner's representation of the Plaintiff and to withdraw his appearance as counsel in the above-captioned matter. Dated: September ' 2013 Respectfully submitted, JOHN F. KING LAW, P.C. By: J King, Esq. ID# 61919 4076 Market Street, Ste 1 Camp Hill, PA 17011 (717) 695-2222 CERTIFICATE OF SERVICE I hereby certify that I am this 3rd day of September, serving the foregoing petition to withdraw appearance upon the person and in the manner indicated below which service satisfies the requirements of the Pennsylvania Rules of Civil Procedure. Service by First Class Mail Restricted Delivery addressed as follows: Tina Hughes 1732 W. Trindle Road Carlisle, PA 17015 Robert Hughes 1732 W. Trindle Road Carlisle, PA 17015 —/olk SIKfarry Semans JOHN F. KING LAW, P.C. 19 SOUTH HANOVER STREET SUITE 103 CARLISLE, PA 17013 717-258"-4343 / 717-422-5526 FAX www.johnfkinglaw.com John F. King, Esq. johnfkinglaw@gmail.com February 9, 2010 Tina Hughes 31 Winchester Gardens Carlisle, PA 17.013 , Re Divorce Dear Tina: I am pleased that you have asked me to represent you in your divorce matter. This letter is a written explanation of my fees, which Pennsylvania law requires attorneys to provide for their clients. I will provide legal services to you on the terms set forth below. 1. This agreement will not take effect, and I 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 I first performed services. The date at the beginning of this agreement is for reference only. 2. You hereby agree to pay me a prepayment of fees and costs of$2,500.00, which will be applied to fees and costs as the same become due. I reserve the right to require an additional deposit (prepayment) in the future. I further reserve the right to cease work upon your failure to replenish the prepayment upon demand. The unused portion of the prepayment, if any, will be refunded. Invoices will be sent to you monthly detailing what fees and costs were incurred in the preceding month and how much of your prepayment remains. Should you make a prepayment by way of credit card, a charge equaling 3% of the prepayment amount will be made against your prepayment in order to reimburse me for processing and handling fees. 3. I feel that the most equitable basis for my 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. My billing is based on an hourly rate of$200.00 per hour and $75.00 per hour for myparalegal's work. The hourly rates will be subject to increase provided we give you 30 days written notice. We will bill you Y 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 I have the right to terminate my representation of you if you do not follow my advice. I may also terminate my representation should it be determined that continuing representation would create an unreasonable financial burden to the law firm..I am not required to file an appeal on your behalf should the case be litigated. 4. Travel time shall be defined as my 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, my schedule will be such that I will leave from somewhere other than my office to attend such a hearing or meeting, and/or return to a place other than the office aft6r 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 meeting/hearing to My next destination. However, this will not exceed the charge for the time it would have taken if I had left from my office or returned to my office. If you are retaining me for a matter involving hearings or a trial in a county other than Dauphin or Cumberland, you have been advised that my 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. 1 expect you to keep current with our billings. I reserve the right to terminate our attorney-client relationship for non-payment of fees or costs. I 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, I will assume that the bill is satisfactory. If it is necessary for me 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. 1 will charge you for the time I 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. We will charge for waiting time in court and elsewhere and for travel time, both local and out of town. 8. -You are hiring me as your attorney to represent you in your divorce matter, including all filings, litigation, negotiation of resolutions, etc. relating to the divorce. I will provide those legal services reasonably required to represent you. No other services will be provided except as specifically requested by you. I 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 I am out of town, most phone calls will be either taken at the time you call, 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, I 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 I may perform for you. 11. You agree to be truthful with me, to cooperate, to keep me 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 tome, as your attorney of record. For this reason it is very important that you forward to me 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. 1 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. 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. I will not hire such personnel unless you agree to pay their fees and charges. I 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, I may have occasion to hold funds in escrow on your behalf. I 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 me at any time. I may withdraw with your consent or for good cause. Good cause includes your breach of this agreement, your refusal to cooperate with me or to follow my advice on a material matter, or any fact or circumstance that would render my continuing representation unlawful or unethical. When my services conclude, all unpaid charges will immediately become due and payable. After my 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 my services, or my withdrawal as your counsel, you have the right to go through the 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 my representation, I 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, memos to the file, notes on the case, legal research, and transcripts of depositions. At the end of five (5) years from the date of our conclusion of my representation, we will destroy your file, retaining only those original documents which may be needed in the future by you. 16. Nothing in this agreement and nothing in my statements to you will be construed as a promise or guarantee about the outcome of your matter. I make no such promises or guarantees. My comments about the outcome of your matter are expressions of opinion only. 17. My paralegal is usually conversant with the status of your file but is not permitted to give any opinions or to advise clients on any legal matters. 18. 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 me, 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. 19. It is not unusual that a client may request that another parry be allowed to communicate with me on his or her behalf(such as a spouse, companion, or parent). If you wish to authorize me 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, I will have no communication with anyone other than you on this matter. You understand that by authorizing a third party to communicate with me, you are waiving the right of confidentiality set forth in paragraph 9 above. I encourage you to call if i have any questions regarding this aspect of our representation. 20. Please countersign this Agreement and return it to me in the enclosed envelope, together with your prepayment of fees and costs, so'that I will have a mutual memorandum of our understanding. Very truly yours, John F. King JFK/sds Enclosure I have read and understood the foregoing terns and agree to them, as of the date John F. King, Esq. first provided services. If more than one party signs below, we each agree to be liable,jointly and severally, for all obligations under this agreement. Tina Hughes SSN: lC0 COMPLETE THE SECTION BELOW ONLY IF YOU WISH TO AUTHORIZE US TO SPEAK WITH SOMEONE ELSE ON YOUR BEHALF. I authorize John F.King,Esq.to discuss any aspect.of my representation with ,whose relationship to me is This authorization will remain in effect until revoked in writing. Tina Hughes TINA HUGHES, : IN THE COURT OF COMMON PLEAS Plaintiff : CUMBERLAND COUNTY, PENNSYLVANIA V. : NO. 10-1060 ROBERT P. HUGHES, : CIVIL ACTION - LAW Defendant : IN DIVORCE RULE TO SHOW CAUSE 1� AND NOW, this day of S t,p , 2013, upon consideration of the foregoing Petition for Leave to Withdraw as Plaintiff s Counsel, the Court grants a Rule to Show Cause why the appearance of John F. King,Esquire,on behalf of Plaintiff should not be allowed to be withdrawn. J� RULE RETURNABLE WITHIN V DAYS FROM THE DATE OF SERVICE OF THIS RULE. ALL PROCEEDINGS TO STAY MEANWHILE. J. Co _ .'. : �✓ ?//6/1-a �r� TINA HUGHES, IN THE COURT OF COMMON PLEAS Plaintiff CUMBERLAND COUNTY, PENNSYLVANIA V• NO. 10-1060 ROBERT P. HUGHES, CIVIL ACTION- LAW Defendant IN DIVORCE c� CERTIFICATE OF SERVICE I hereby certify that I am this 121h day of September 2013, serving the Rule t4 w`(`ause re Petition for Leave to Withdraw upon the person and in the manner indicated beloN5 iicl 84 service satisfies the requirements of the Pennsylvania Rules of Civil Procedure. - `; Service by First Class Mail addressed as follows: Tina Hughes 1732 W. Trindle Road Carlisle, PA 17015 Robert Hughes 1732 W. Trindle Road Carlisle, PA 17015 k- Sha"rry Semans TINA HUGHES, : IN THE COURT OF COMMON PLE Plaintiff : CUMBERLAND COUNTY, PENN ,VAINIIArn t.. `3 -c y''A, V. NO. 10-1060 c -a ROBERT P. HUGHES, : CIVIL ACTION - LAW c-> =-" : Defendant : IN DIVORCE z co MOTION TO MAKE RULE TO SHOW CAUSE ABSOLUTE John F. King, Esquire, respectfully requests this Court to make absolute the Rule to Show Cause which was issued in the above-captioned matter on September 10, 2013, and in support states the following: 1. A Petition for Leave to Withdraw as Plaintiffs Counsel was filed by the Petitioner on September 4, 2013. 2. The Rule to Show Cause was issued on September 10, 2013, and was served on September 12, 2013. 3. To date, no response has been forthcoming from the Plaintiff or Defendant. WHEREFORE, Petitioner respectfully requests that this Court make the Rule to Show Cause Absolute. Respectfully submitted, JOHN F. KING LAW, P.C. Dated: r f _ By: • John F. King, Esq. ID# 61919 4076 Market Street, Ste 1 Camp Hill, PA 17011 (717) 695-2222 CERTIFICATE OF SERVICE I hereby certify that on this_-�/ day of October,2013, I served the foregoing Motion to Make Rule Absolute upon the person and in the manner indicated below which service satisfies the requirements of the Pennsylvania Rules of Civil Procedure. Service by First Class Mail addressed as follows: Tina Hughes 1732 W. Trindle Road Carlisle, PA 17015 Robert Hughes 1732 W. Trindle Road Carlisle, PA 17015 f n F. King, Esq. 4 TINA HUGHES, : IN THE COURT OF COMMON PLEAS Plaintiff : CUMBERLAND COUNTY, PENNSYLVANIA v. : NO. 10-1060 ROBERT P. HUGHES, : CIVIL ACTION - LAW Defendant : IN DIVORCE ORDER tiN AND NOW, this lr K day of C)G,• , 2013, upon consideration of the verified Petition for Leave to Withdraw as Plaintiff's counsel, and Rule to Show Cause, and there being no opposition thereto, it is hereby ORDERED and DECREED that said Petition is granted and that Petitioner, John F. King, Esq.,and the firm of John F. King Law, P.C., be permitted to withdraw their appearance of record for the Plaintiff in the above matter and the Prothonotary shall so mark the docket.. BY THE COURT, \\1\k,AN CT!'SC MO 144-4-1 J- 161 VAs) ash?4" r" 2613 eid- ,rrr�