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HomeMy WebLinkAbout01-1495COmMONWEAl. TH OF PENNSYLVANIA NOTICE OF APPEAL COURT OF COMMON PLEAS F~OM date and in the case mentioned below. DISTRICT JUSTICE JUDGMENT NOTICE OF APPEAL Notice is given that the appellant has filed in the above Court of Commo~ Pleas an appeal from the judgment rendered by the District Justice on the 9'~e ~/o o ?-/.- o~, /-,,,.,,/~/,,z.~_ ,s 70 ~/,¥' '~A / ~o ~ ~ uc ~zo/ tT 19 I~C,, ,:,-/'- - - This block will be dgnea ONLY Sen this notation is required under P~ R.C.PJ.P.~(G If~oellant was OLAIMANT (see Pa. R.C.P,J.P. No. 1008B. This Notice of Appeal, when received by the District Justice. will operate as a 7007(6)JnactJonbeforeOJstrJctJu~tJce, heMUST SUPERSEDEAS to the judgment for possession in this cas~ FILE A COMPIA#VT wJfft/n twenty (20) clays after filing his IVOTIC,~ of APP£AL. Signature of Prothonotary or Deputy PRAECIPE TO ENTER RULE TO FILE COMPLAINT AND RULE TO FILE (This section of form to be used ONLY when aPl~llant was DEFENDANT (see Pa, R.C.P.J.P. No. 1001(7) in action before District Justice, IF NOT USED, de~ach from copy of notice of al)peal to be served upon appellee). PRAECIPE: To Prothonotary Enter rule upon ~"~'~"~"- ~"~'~'~1~'I~';'~(~ t /~v~,~. . appellee(s), to file a complaint in this apped (Common Pleas N~ 0 /' / /'/ "~ ~'~ ) within twenty (20) days after service of rule or suffer entry of judgment of non pros. (1) You am notified that a rule is hereby entered upon you to file a complaint in this appeal within twenty (20) days after the date of service of this rule upon you by personal service or by certified o~ registered mail (2) If you do not file a complaint within this time, a JUDGMENT OF NON PROS WILL BE ENTERED AGAINST YOU. COURT FILE TO BE FILED WITH PROTHONOTARY PROOF OF SERVI~CE OF NOTICE OF APPEAL AND RULE TO FiLE COMPLAINT IThsproofc~ er cc~MUSTL~E F E,!) WITH~ 'E~V(70~ DAYS AFT~H hli~ ~ ~otce ofap~ep~ C~c a~c bi, boxes COMMONWEALTH OF P[~NNSYL~AN~A AFFIDAVIT: ~x~re x~e~ ~ affr~ thati ervec a copy of the Notc~ ~)f Appe~. Common Pleas No [o (~ate ~> ser¢c~) ._~ ~y pets( /al servi;e b~ ~.~ b) person~ service ] b~ certifieff/ registered} ~a~l erx~e s ~;~c(~mt attached hee~ ~] ardfurt~:e t~at ~er~,ed heR~ietoF~le~C:~r~ ~il ;~, ,~m pa x~i eaboveN¢tce SWORN (AF~ I:t¢~t~) AND L ~ C; BEbi~FO~/ Mft WNV/fi,kSNN~d .,U,NN09 9U:5 Il',! p COMMONWC:ALTH OF PENNSYLVANIA COUNTY OF: CUMBERLAND Mag Dist NO: 09-1-02 DJ Name: HO~ ROBERT V. MANLOVE A~d,es~: 1901 STATE STREET CAMP HILL, PA (717) 761-0583 BArBArA PUCCIO 908 SUNNYSIDE HUMMELSTOWN, PA 17036 THIS IS TO NOTIFY YOU THAT: Judgment: ~ Judgment was entered for: (Name) Judgment was entered against: (Name) 17011-0000 NOTICE OF JUDGMENT/TRANSCRIPT~ CIVIL CASE PLAINTIFF: NAME and ADDRESS ~TTER-DISSINGER, ESQ, MARY A. 400 S STATE RD DISSINGER & DISSINGER ~EYSVILLE, PA 17053 VS. DEFENDANT: NAME and ADDRESS FPUCCIO, ANTHONY, ET AL. 908 SUNNYSIDE ~D HUMMELSTOWN, PA 17036 Docket No.: CV- 0000384- 00 Date F ed: 10/19/00 FOR PT.~TNTIFF P~CCTO, RARRARA R~Q, MAW~ A. in the amount of $ On: (Date of Judgment) r'~ Defendants are jointly and severally liable. F--~ Damages will be assessed on: I--'] This case dismissed without prejudice. ~ Amount of Judgment Subject to AttachmenFAct 5 of 1996 $ [] Levy is stayed for days or [~ generally stayed. ~-~ Objection to lev~' has been filed and hearing will be held Date: Place: (Date & Time) Amount of Judgment $ 988. ~3 Judgment Costs $ 82.25 Interest on Judgment $ .00 Attorney Fees $ .00 Total $ 't, 070.68 Post Judgment Credits Post Judgment Costs Certified Judgment Total $ $ Time: ANY PARTY HAS THE RIGHT TO APPEAL WITHIN 30 DAYS AFTER THE ENTRy OF JUDGMENT BY FILING A NOTICE OF APPEAL W,T. T.E FROT. ONOTARY~C.E.. OF T.~' COURT OF CO"MO. PLEAS, C,V,L ~V,S,O.. YOU MUST.NC'UDE ^ COPY OF ~.~: :E,~ JUD~¢~CJTT F~M W,T. I ceaify that this is a true and co~ ~y dt¢~ o¢~e proceedings c~nta~ ti~e%tudgme~t. My commission expires first Monday of January, 2006 AOPC 315-99 PROM JUDICIAL DISTRICT DISTRICT JUSTICE JUDGMENT NOTICE OF APPEAL N~fice ~s ~iven ~h~t ~e apPe~ant h~s fi~ed in the ab~ve C~ur~ ~f C~mm~n ~leas an appea~ fmrn ~he jud~ mm~ed ~ ~:~.~ ~ ~ t ~f~e of A~I, ~ ~ ~ t~ ~s~t Jus~e, ~ll ~ ~ a l~l(6)inac~;~~,~T /CE A COMP A r S~ of ~ ~ ~ty filing h~ NO~CE PRAECIPE TO ENTER RULE TO FILE COMPLAINT AND RULE TO FiLE' % ~ of fotrn to be used ONLY when appellant was DEFENDANT (see Pa. R. QP.J.P No, 1001(7) ~ ~2Oisttf~ dust~e. ED, ttetach from copy of notice of appeal to be served upon apl~llee}, I - E: To ,m~lee(s),tofileaconX~,d~in~Y~sc~>~al ) within twenty (20) days after service of m~ ~ suffe~ entry of judgment of rule ,s hereby entered ~ you to file a ~ ~n this appeal w~thin twenty (20) days ~ th~ dale Of ~pon you by ~ service or by cetified ~ registered rnaiL not file o comp~nt within fl~s time, a JUDGMENT OF NON PROS WILL BE ENTERED AGAINST YOU. COURT FILE DISSINGER AND DISSINGER, Plaintiffs vs. ANTHONY PUCCIO, and BARBARA PUCCIO, Defendants NOTICE T IN THE COURT OF COM}~ON PLEAS OF CUMBERI~AND COUNTY PENNSYLVANIA CIVIL ACTION AT LAW o.0'1 - qqs cL,'l O DEFEND 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 T~LKE 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. Curaberland County Court House Court Administrator 1 Courthouse Square Carlisle, PA 17013-3387 (717) 240-6200 AMERIC~tNS WITH DISABILITIES ACT OF 1990 The Court of Co/nmon Pleas of Cumberland County is required by law to comply with the Americans with Disabilities Act of 1990. For information about accessible facilities and reasonable accommodations available to disabled individuals having business before the court, please contact our office. All arrangements must by made at least 72 hours prior to any hearing or business before the court. You must attend scheduled conference or hearing. YOU SHOULD TAKE THIS PAPER TO YOUR LAWYER AT ONCE. IF YOU DO NOT HAVE ALAWYER OR CA/FNOT AFFORD ONE, GO TO OR TELEPHONE THE OFFICE SET FORTH BELOW TO FIND OUT WHERE YOU CAN GET LEGAL HELP. CUMBERLA24D COUNTY BAR ASSOCIATION 2 LIBERTY AVENUE CARLISLE, PA 17013 717-249-3166 DISSINGER A/qD DISSINGER, Plaintiffs vs. ~NTHONY PUCCIO, and BA_RBA/kA PUCCIO, Defendants IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY PENNSYLVANIA CIVIL ACTION AT LAW NO. COMPLAINT AlqD NOW comes the Plaintiffs, Dissinger and Dissinger, and respectfully represent the following: 1. The Plaintiff, Dissinger and Dissinger, is a Pennsylvania corporation with an office is located at 28 North Thirty-Second Street, Camp Hill, Cumberland County, Pennsylvania. 2. The Defendants, Anthony Puccio and Barbara Puccio, are adult individuals, who reside at 908 Sunnyside Road, Hummelstown, Dauphin County, Pennsylvania. 3. On December 8, 1998, the consultation with Stephen G. Held, Dissinger at the Plaintiff's Pennsylvania. Defendants had an initial Esquire of Dissinger and office in Camp Hill, 4. The Defendants entered into an oral agreement with Stephen G. Held, Esquire and Dissinger and Dissinger for legal representation in a civil suit against Edward Campbell relating to the purchase of a house. 5. Pursuant to said agreement, Dissinger and Dissinger would require a two-hundred and fifty dollar ($250.00) retainer to begin work and the Defendant's would be billed at an hourly rate of one-hundred and fifty dollars ($150.00) for office work and two-hundred dollars ($200.00) for time spent in court. 6. Also, pursuant to the agreement, the Plaintiff agreed to a one-thousand dollar ($1,000.00) cap on attorneys fees and, once this level was reached, the Plaintiff would gratuitously continue representation but reserve the right, upon notice to the Defendants, to begin charging the Defendants again for services or, in the alternative, withdraw their appearance. 7. The Plaintiff represented the Defendants pursuant to the above referenced agreements. 8. The Plaintiff billed the Defendants in accordance with their oral agreement. (Copies of all bills are attached as Exhibit "A"). 9. The Defendants refused to pay the outstanding legal bills for the services of Dissinger and Dissinger. 10. On February 22, 2001, after a hearing before District Justice Robert V. Manlove, judgment and costs were entered against the Defendants in the amount of one-thousand seventy dollars and sixty-eight cents ($1,070.68). (A Copy of the judgment is attached as Exhibit "B"). 11. The Defendant's have appealed from the District Justice and refuse to pay for the legal services rendered on their behalf. WHEREFORE, the Plaintiff, Dissinger and Dissinger, respectfully request that judgment be entered against the Defendants in the amount of one-thousand seventy dollars and sixty-eight cents ($1,070.68). Respectfully submitted, DISSINGER and DISSINGER MaryA. ~tter Dissinger, Esqufre Attorney for Plaintiff Supreme Court ID # 27736 28 North Thirty-second street Camp Hill, PA 17011 (717) 975-2840 VERIFICATION I, Mary A. Etter Dissinger, verify that the statements made in the Complaint 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. MaryA~ Etter uissinger, ~squire DI SINGER DISSINGER Camp Hill Offices: 717.975.2840/voice * 717.975.3924/fa× Marysville Offices: 717.957.3474/voice * 717.957.2316/fax Anthony and Barbara Puccio 908 Sunnyside Road Humrnelstown, PA 17036 Attention: Mr. and Mrs. Puccio DATE DESCRIPTION Nov-07-00 Interest charged on unpaid balance through November 7, 2000 November 7, 2000 File #: 1-98-589 Inv #: 10505 15.50 Total $15.50 DISBURSEMENTS Costs advanced to Totals Total Fees & Disbursements Previous Balance Previous Payments Balance Due Disbumements 61.50 $61.50 Receipts $0.00 $77.00 $1,033.59 $0.00 $1,110.59 Please remit the outstanding balance due on or before December 5, 2000. Interest will be charged on any unpaid balance after that date. Attorneys at Law 28 North Thirty-Second Street · Camp Hill, PA 17011 400 South State Road · blarysville, PA 17053 DI$SINGER [ DISSINGER Camp Hill Offices: 717.975.2840/voice * 717.975.3924/fax Marysville Offices: 717.957.3474/'¢oice · 717.957.2316/fax Anthony and Barbara Puccio 908 Sunnyside Road Hummelstown, PA 17036 Attention: Mr. and Mrs. Puccio DATE DES CRIPTION Oct-07-00 Interest charged on unpaid balance through Octqber 7, 2000 Totals Total Fees & Disbursements Previous Balance Previous Payments Balance Due October 10, 2000 File #: 1-98-589 ][nv #: 10393 15.28 $15.28 $15.28 $1,018.31 $0.00 $1,033.59 Please remit the outstanding balance due on or before November 5, 2000. Interest will be charged on any unpaid balance after that date. AttorneFs at Law 28 North Thirty-Second Street · Camp Hill, PA 17011 400 South State Road * Marysville, PA 17053 DISSINGER DISSINGER Camp Hill Offices: 717.975.2840/voice * 717.975.3~)24/fax lViarysville Offices: 717.95?.3474/voice * 717.357.2316/fax September 7, 2000 Attention: DATE Sep-07-00 Anthony and Barbara Puccio 908 Sunnyside Road Hummelstown, PA 17036 Mr. and Mrs. Puccio DESCRIPTION Interest charged on unpaid balance through September 7, 2000 Totals Total Fees & Disbursements Previous Balance Previous Payments Balance Due File # 1-98-589 Invoice # 10291 15.05 $15.05 $15.05 $1,003.26 $0.00 $1,018.31 Please remit the outstanding balance due on or before October 5, 2000. Interest will be charged on any unpaid balance after that date. Attorneys at Law 28 North Thirty-Second Street · Camp Hill, PA 17011 400 South ,State Road · Marysville, PA 17053 DI SINGER DISSINGER Camp Hill Offices: 717.975.2840[voice * 717.975.B924[fax blarysville Offices: 717.957.3474/voice · 717.957.2316/fax August 8, 2000 Attention: DATE Aug-07-00 Anthony and Barbara Puccio 908 Sunnyside Road Hummalstown, PA 17036 Mr. and Mrs. Puc, cio DESCRIPTION Interest charged on unpaid balance through August 7, 2000 Subtotal Total Fees & Disbursements: ]Previous Balance Previous Payments Balance Due File #1-98-589 Invoice # 10147 14.83 $14.83 $14,83 $988.43 $0.00 $1,003.26 Please remit the outstanding balance due on or before September 5, 2000. Interest will be charged on any unpaid balance after that date. Attorneys at Law 28 North Thirty-Second Street · Camp Hill PA 17011 400 South State Road · blar)'sville, PA 17053 DIbSINGER [DISSINOER Camp Hill Offices: 717.975.2540/voice · 717.975.3924/fax Marysville Offices: 717.957.3474/voice · 717.957.2316/fax July 10, 2000 Anthony and Barbara Puc, cio 908 Sunnyside Road Hummelstown, PA 17036 Attention Mr. and Mrs. Puccio DATE DESCRII~TION Jul-07-00 Interest charged on unpaid balance through July 7, 2000 File # 1-98-589 Invoice # 9999 Total Total Fees & Disbursements Previous Balance Previou~ Payments Balance Due 14.61 $14.61 $14.61 $973.82 $0.00 $988.43 Please remit the outstanding balance due on or before August 5, 2000. Interest will be charged on any unpaid balance after that date. Attorneys at Law 28 North Thirty-Second Street · Camp Hill, PA 17011 400 South State Road · Marysville, PA 17053 DISSINGER [." DI ,SINGER Camp Hill Offices: 717.975.2840/voice ,~ 717.975.3924/fax /vlarysville Offices: ?17.957.3474/~oice · 717.957.2316/fax June 7, 2000 Anthony and Barbara Pu¢cio 908 Sunnyside Road Hummelstown, PA 17036 Attention: Mr. and Mrs. Puccio DATE DESCRIPTION Jun-07-00 Interest charged on unpaid balance through June 7, 2000 Total Fees Total Fees & Disbursements Previous Balance Previous Payments Balance Due File # 1-98-589 Invoice # 9869 14.39 $14.39 $14.39 $959.43 $0.00 $973.82 Please remit the outstanding balance due on or before July 5, 2000. Interest will be charged on any unpaid balance after that date. Enclosed is a copy of the District Justice Complaint prepared for filing in this matter. If we do not receive payment within the next ten (10) days, the complaint will be filed. We offer VISA and Mastercard for your convenience in making payments over the phone. Attorneys at Law 28 North Thirty. Second Street · Camp Hill, PA 17011 400 South State Road ,,/,larysville, PA 17053 DIbSINGER DISSINGER Camp Hill Offices: 717.975.2840/voice * 717,975.B924/fax Marysville Offices: 717,957.3474/voice * 717.957.2B16/fax 75¸ May 8, 2000 Anthony and Barbara Puccio 908 Sunnyside Road Hummelstown, PA 17036 Attention: Mr. and Mrs. Puccio DATE DESCRIPTION May-07-00 Interest charged on unpaid balance through May 7, 2000 Total File # 1-98-589 Invoice # 9720 14.16 $14.16 DISBURSEMENTS Photo Copies Disbursements 1.20 Receipts Totals $1.20 $0.00 Total Fees & Disbursements Previous Balance Previous Payments Balance Due $15.36 $944.07 $o.00 .$959.43 Please remit the outstanding balance due on or before June 5, 2000. Interest will be charged on any unpaid balance after that date. Attorneys at Law 28 North Thirty-Second Street ,, Camp Hill, PA 17011 400 South State Road ', blarysville, PA 17053 DISSINGER DISSINGER Camp Hill Offices: 717.975.2840/voice * 717.975.3924/fax Marysville Offices: 717.957.3474/volce * 717.957.2316/fax · April 10, 2000 Anthony and Barbara Puccio 908 Sunnyside Road Hummelstown, PA 17036 File # 1-98-589 Invoice # 9592 Attention: DATE Mar-08-00 Mar-17-00 Mar-20-00 Apr-07-00 Mr. and Mrs. Puccio DESCRIPTION Filed Motion Picked up Final Rule Word Processing Lease and letter to client, Atty. Beinhauer and Atty. Getz Draft Release and letter to Atty. Beinhauer, Atty. Getz and client Interest charged on unpaid balance through April 7, 2000 Total Fees Total Fees & Disbursements Previous Balance Previous Payments Balance Due 11.54 $175.04 $175.04 $769.03 $0.00 $944.07 Please rem/t the outstanding balance due on or before May 5, 2000. Interest will be charged on any unpaid balance after that date. Attorneys at Law 28 North Thirty-Second Street · Camp Hill, PA 17011 400 South State Road ,, t, larysville, PA 17053 D SSINGER [.DISSINGER Camp Hill Offices: 717.975.2840/voice · 717.975.3924/fax Marysville Offices: 717.957.3474/voice ,, 717.gs7.2316/fax March 21,2000 Attention: DATE Jan-12-00 Jan-19-00 Anthony and Barbara Puccio 908 Sunnyside Road Hummelstown, PA 17036 Mr. and Mrs. Puccio DESCRIPTION Jan-21-00 Feb-25-00 Feb-28-00 Feb-29-00 Mar-07-00 Filed Petition for Withdraw of Counsel (NC) Picked up Order - Dauphin Co. Court House (Nc) Draft Rule to Show Cause (NC) Word Processing Rule Absolute (NC) Draft Rule Absolute (NC) Word Processing Rule Absolute (NC) Draft of Rule Absolute (NC) Draft Order (NC) Word Processing Order (NC) Interest charged on unpaid balance through March 7, 2000. File # 1-98-589 Invoice # 9471 18.73 Total $18.73 Attorneys at Law 28 Noah Thirty-Second Street · Camp Hill, Pa 17011 400 South State Road · blarysville, PA 17053 Total Fees & Disbursements Previous Balance Previous Payments Balance Due Now $18.73 $750.30 $0.00 $769.03 Please remit the outstanding balance due on or before April5, 2000. Interest will be charged on any unpaid balance after that date. DISSIN©ER DIS$INOER Camp Hill Offices: 717.975.2840/voice · 717.975.3924/fax · Marysville Offices: 717.957.3474~voice · 717.957.2316/fax January 12, 2000 Anthony and Barbara Puccio 908 Sunnyside Road Hununelstown, PA 17036 Dear Mr. and Mrs. Puccio: Previous Balance Payment on Account Current Charges Outstanding Balance Due Attorney Services: Dec-08-99 Jan-03-00 Jan-04-00 Jan-07-00 Miscellaneous Total Attorney Services Secretarial Services: Jan-06-00 Draft letter to clients (NC) Telephone call from Mrs. Puccio Telephone call to Steve (NC) Draft Petition to Withdraw (Nc) Draft revisions to Petition to Withdraw Appearance (NC) (NC) Photocopy and conform Petition to Withdraw Appearance (FF) MATTER ~ 1-98-589 INVOICE ~ 9226 $694.68 $0.00 $55.62 $750.30 $45.00 Afco;'tle),5 ac Law 28 N,orth Thirt?Second Street · Camp Hill, PA 17011 400 South State Road · Marysvilte, PA 17053 Total Secretarial Services Word Processing Services: Dec-09-99 Word Processing letter to clients .(NC) Dec-10-99 Jan~03-00 Jan-04-00 Jan-05-00 Word Processing revisions to letter to client (NC) Word Processing Petition to Withdraw Appearance (NC) Word Processing revisions to Petition to Withdraw Appearance (NC) Word Processing revisions to Petition to Withdraw Appearance (NC) Total Word Processing Services Interest: Jan-07-00 Interest charged on unpaid balance through January 7, 2000. Total Interest Paralegal Services: Jan-03-00 Photo Copies and labeling of exhibits (NC) Total Paralegal Services Total Fees Costs Advanced: Jan-06-99 Photo Copies of Exhibits (FF-24) Dec-09-99 Photo Copies of letter to clients (NC-13) Dec-10-99 Photo Copies of revisions to letter to client (FF/NC-2) Jan-05-00 Photo Copies of revisions to Petition to Withdraw Appearance $0.00 $0.00 $0.00 $0.00 $0.00 $0.00 $10.42 $0.00 $55.4Z Jan-06-O0 Photo Copies of Petition to Withdraw Appearance (FF-30) Total Costs Advance~ Total Fees and Disbursements Trust Account Balance $0.00 $0.00 $55.62 $0.00 Please remit the outstanding balance due on or before February 5, 2000. Interest will be charged on any unpaid balance after that date. Very truly yours, Mary A. Etter Dissinger Attorney at Law MAED:csb DiSSINGER }DISSINOER Camp Hill Offices: 7IT.975.2840/voke · 7IT.975.3924/fax /vlarysville Offices: 717.357.3474/volce · 717.957.2316/fax December 13, 1999 Anthony and Barbara Puccio 908 Sunnyside Road Hummelstown, PA 17036 Dear Mr. and Mrs. Puccio: Previous Balance Payment on Account Current Charges Outstanding Balance Due Attorney Services: Dec-03-99 Study/Review letter from S. Held (NC) Total Attorney Services Interest: Dec-07-99 Interest charged on unpaid balance through December 7, Total Interest Total Fees Costs Advanced: Dec-03-99 Fax from SGH Total Costs Advanced Total Fees and Disbursements Trust Account Balance (NC-$2.00) 1999. Arrorn©,s at Law 28 North Thirty-Second Street · Camp Hill, PA 17011 400 South State Road · ~%taq'sville, PA 17053 MATTER ~ 1-98-589 INVOICE # 9115 $684.41 $0.00 $10.27 $694.68 $0.00 $10.27 $10.27 $0.00 $0.00 $~o.27 $0.00 Please remit the outstanding balance due on or before January 5, 2000. Interest will be charged on any unpaid balance after that date. Very truly yours, Mary A0 Etter Dissinger Attorney at Law MAED:csb DISSINGER DISSINGER Camp Hill Offices: 717.975.2840/voice ,, 717.975.3924/fax Marysville Offices: 717.957.3474~voice * 717.957.2316/fax December 10, 1999 Anthony and Barbara Puccio 908 Sunnyside Road Hum~elstown, PA 17036 Re: Notice of Billing Rate Change Dear Mr. & Mrs. Puccio: In accordance with our engagement letter, we are notifying you that effective January 1, 2000, our billing rates have been increased.. We have not always raised the rates annually, and do not undertake the revisions lightly. We have determined that it is appropriate to begin billing on January 1, 2000, at the increased rates. Please see the attached standard fee schedule. We appreciate the c~nfidence you have expressed in our firm by retaining us to represent you. We will continue to provide you with the same quality of services. Very truly yours, MAED:ces Attachment: 1 File 1-98-589 Mary A. Etter Dissinger Attorney at Law Attorneys at Law 28 North Thirty-Second Street · Camp Hill, PA 17011 400 South State Road * i',tarysville, PA 17053 STANDARD FEES FOR SERVICES ON AN HOURLY BASIS Job Title Work Performed Attorney In Office Attorney At Hearing/In Court or Adversary Proceeding Associate Attorney In office Associate Attorney At Hearing/In Court or Adversary Proceeding Law Clerk/Paralegal Ail Secretary Secretarial Computer Operator Micro Computer/Word Processing Electronic research Use of electronic research Copies Faxed material Sent or received Fees are based on time, portal-to-portal, meetings, conferences, and hearings. Hourly Rate $165.00 $220.00 $100.00 $150.00 $ 75.00 $ 5o.00 $ 50.00 $150.00 $.10 per page $1.00 per page for out of office D I ~ SINGER & D I S SINGER Attorneys At Law 400 South State Road Marysville, PA 17053 717-957-3474 William C. Dissinger Mary A. Etter Dissinger Matthew D. Strohm Please remit all payments to: Ail accounts with balances outstanding after thirty (30) days are charged interest at a rate of 1.5% per month on the outstanding balance. Outstanding balances will not be carried past ninety (90) days. Statements are sent every thirty (30) days. Payment is expected by the date indicated on the statement. Incurred expenses or costs, such as filing fees, doctors' fees, medical reports, expert fees, etc., are billed at cost. DioSINGER DISSINGER Camp Hill Offices: 717.975.2840/voice · 717.975.3924/fax Marysville Offices: 717.957.3474/voice · 717.957.2316/fax November 16, 1999 Anthony and Barbara Puccio 908 Sunnyside Road Hummelstown, PA 17036 Dear Mr. and Mrs. Puccio: Previous Balance Payment on Account Current Charges Outstanding Balance Due Attorney Services: Nov-02-99 Consultation with client Draft Consent of Plaintiff's to Withdraw Counsel (FF) Total Attorney Services Word Processing Services: Word Processing Consent of Plaintiff's to Withdraw Counsel (FF) Total Word Processing Services Interest: Nov-07-99 Interest charged on unpaid balance through November 7, Total Interest Total Fees (FF) 1999. Attorneys at Law 28 North Thirty-Second Street · Camp Hill, PA 17011 400 South State Road · Ma%'sville, FA 17053 MATTER # 1-98-589 INVOICE # 8998 $674.30 $0.00 $10.11 $684.41 $0.00 $0.00 $10.11 $10.11 Costs Advanced: Nov-02-99 Photo Copies of Consent of $0.00 Plaintiffs to Withdraw Counsel (FF/NC-6) Total costs Advanced $0.00 Total Fees and Disbursements $10.11 Trust Account Balance $0.00 Please remit the outstanding balance due on or before December 5, 1999. Interest will be charged on any unpaid balance after that date. Very truly yours, William C. Dissinger Attorney at Law WCD:csb MARY A. ETTER DISSINGER WILLIAM CHESTER DISSINGER STEPHEN GEORGE HELD October 12, 1999 Camp Hill Office: 28 N. Thirty-Second Street Camp Hill, Pennsylvania 17011 717 975-2840 FAX 717 975-3924 Marysvflle Office: 400 South State Road Marysvilre, Pennsylvania 17053 717 957-3474 FAX 717 957-2316 File 1-98-589 Anthony & Barbara Puccio 908 Sunnyside Road Hummelstown, PA 17036 Dear Mr. & Mrs. Puccio: This letter is to inform you that Stephen Go Held is leaving our firm effective Friday, October 22, 1999. I will be taking over your case.. If you have any questions concerning your litigation case, please do not hesitate to call. If you would like to set up an appointment to meet with me concerning your case, please contact me. Very truly yours, William c. Dissinger WCD:ces MARY A, ETTER DISSINGER WILLIAM CHESTER DISSINGER STEPHEN GEORGE HELD October 12, 1999 Anthony and Barbara Puccio 908 Sunnyside Road Hummelstown, PA 17036 Dear Mr. and Mrs. Puccio: Previous Balance Payment on Account Current Charges Outstanding Balance Due Attorney Services: Sep-23-99 Telephone call to Beinhauer Sep-17-99 Telephone call to client (FF) Total Attorney Services Interest: Oct-07-99 Interest charged on unpaid balance through October 7, Total Interest Total Fees Trust Account Balance 1999.' ~LATTER # 1-98-589 INVOICE f 8904 $677.07 $57.07 $54.30 $674.30 $45.00 $9.30 $54.30 $0.00 Please remit the outstanding balance due on or before November 5, 1999. Interest will be charged on any unpaid balance after that date. Very truly yours, SGH:csb Stephen G. Held MARY A. ETTER DIS$1NGER WILLIAM CHESTER DISSINGER STEPHEN GEORGE HELD September 14, 1999 Camp H;II 28 N. Thirty-Second Street Camp Hill, Pennsylvania 17011 717 975-2840 FAX 717 975-3924 MATTER # 1-98-589 INVOICE # 8802 Anthony and Barbara Puccio 908 Sunnyside Road Hummelstown, PA 17036 Dear Mr. and Mrs. Puccio: Previous Balance Payment on Account Current Charges Outstanding Balance Due Interest: Sep-07-99 Interest charged on unpaid balance through September 7, Total Interest Trust Account Balance 1999. $717.06 $5O.OO $10.01 $677.07 $10.01 $o.oo Please remit the outstanding balance due on or before October 5, 1999. Interest will be charged on any unpaid balance after that date. Very truly yours, Stephen G. Held SGH:csb MARY A, £'I-fER DISSINGER WILLIAM CHESTER DISSINGER STEPHEN GEORGE HELD August 9, 1999 Camp Hill Office: 28 N. Thirty-Second S[ree~ Camp H;IL Pennsylvania 17011 717 975-2840 FAX 717 $75-3924 MATTER # 1-98-589 INVOICE # 8696 Anthony and Barbara Puccio 908 Sunnyside Road Hummelstown PA 17036 Dear Mr. and Mrs. Pucclo: Previous Balance Payment on Account Current Charges Outstanding Balance Due Attorney Services: Ju1-12-99 Jul-08-99 Ju1-12-99 Ju1-14-99 Ju1-15-99 Telephone call from Mrs. Puccio (FF) Telephone call to Beinhaur (F~) Telephone call to Rehkamp (NA,NC,LM) Telephone call to client (NA,NC,LM) Telephone call to client (FF/NC) Draft letter to Beinhaur (FF) $706.46 $0.00 $10.60 $717.06 Total Attorney Services $0.00 Word Processing Services: Word Processing letter to Beinhaur (FF) Total Word Processing Services Interest: Aug-07-99 Interest charged on unpaid balance through August 7, $0.00 1999 Total Interest $10.60 Total Fees $10.60 Costs Advanced: Ju1-15-99 Photo Copies of letter to $0.00 Beinhaur (FF/NC-2) Total Costs Advanced $0.00 Total Fees and Disbursements $10.60 Trust Account Balance $0.00 Please remit the outstanding balance due on or before September 5, 1999. Interest will be charged on any unpaid balance after that date. Very truly yours, SGH:csb Stephen G. Held MARY A. E'n'ER DISSINGER WILLIAM CHESTER DISSINGER STEPHEN GEORGE HELD i inger July 8, 1999 Camp Hill OHice: Camp Hill, Fennsylvan~a 17011 717 975-2840 FAX 717 975-3924, MATTER ~ 1-98-589 INVOICE ~ 8604 Anthony and Barbara Puccio 908 Sunnyside Road Hummelstown, PA 17036 Dear Mr. and Mrs. Puccio: Previous Balance Payment on Account Current Charges Outstanding Balance Due $796.02 $100.00 $10.44 $706.46 Attorney Services: May-25-99 May-il-99 May-12-99 May-13-99 Telephone call to Getz (NA,NC,LM) Telephone call from Getz (FF) Telephone call to Sheriff Office (NC) Telephone call to client (NC) Travel to and from Dauphin Co., Searching Tax Office (NC) Study/Review letter from Getz Telephone call to Getz (NA, NC, LM) May-13-99 Telephone call to Getz (NC) May-18-99 Travel to and from Bankruptcy Court Re: Address (NC) May-20-99 Telephone call to Beinhaur (NA,NC,LM) May-27-99 Telephone call to Beinhan (FF) Telephone call to client (FF) Total Attorney Services Interest: Jul-07-99 $0.00 Interest charged on unpaid balance through July 7, 1999. Total Interest Total Fees Trust Account Balance Please remit the outstanding balance due on or before August 5, 1999. Interest will be charged on any unpaid balance after that.date. Very truly yours, $10.44 . $~o.44 $o.oo SGH:csb Stephen G. Held MARY A* ETTER DISSINGER WILLIAM CHESTER DISSINOER STEPHEN GEORGE HELD May 7, 1999 Carn~ H;a Office: 28 N. Thirty-Second Street Camp Hill, Penn=ylvanla 17011 717 975-2840 FAX 717 976-3924. MATTER # 1-98-589 INVOICE # 8396 Anthony and Barbara Puccio 908 Sunnyside Road Hummelstown PA 17036 Dear Mr. and Mrs. Puccio: Previous Balance Payment on Account Current Charges Outstanding Balance Due Attorney Services: Mar-31-99 Apr-06-99 Apr-07-99 Apr-29-99 Telephone call to client (NA,NC,LM) Telephone call to Sheriff (NC) Telephone call to client (NA,NC,LM) Telephone call to client (NA,NC) Telephone call to client (NC) Draft Instructions to Sheriff (NC) Instruction to CES; travel to Dauphin Co. Courthouse (NC) $784.26 $0.00 $11.76 $796.02 Total Attorney Services Interest: May-07-99 Interest charged on unpaid balance through May 7, 1999. Total Interest Total Fees Apr 26/1999 Trust Funds received Apr 29/1999 Trust Funds disbursed Trust Account Balance $0.00 $11.76 $11.76 $45.50 $45.5o $0.oo Please remit the outstanding balance due on or before June 5, 1999. Interest will be charged on any unpaid balance after that date. Very truly yours, SGH:csb Stephen G. Held MARY A, ETTER DISSINGER WIL~.IAM CHESTER DISSINGER STEPHEN GEORGE HELD 'jr April 8, 1999 Camp Hal Office: 28 N. Thirty-Second Street Camp Hill, Pennsylvania 17011 717 975-2840 FAX 717 975-3924 Me~7,~lle Office: 400 5outh State Road MaryIvllle, Pennsylvania 17053 717 957-3474 FAX 717 9157-2316 ~ATTER # 1-98-589 INVOICE ~ 8281 Anthony and Barbara Puccio 908 Sunnyside Road Hu~melstown PA 17036 Dear Mr. and Mrs. Puccio: Previous Balance Payment on Account Current Charges Outstanding Balance Due Attorney Services: Mar-09-99 Mar-10-99 Mar-18-99 Study/Review answer to letter from Getz (NC) Travel to and from Dauphin Co. Courthouse-Research (NC) Telephone call to client Draft letter to clients (NC) Telephone call from client (NC) Telephone call from Mrs. Puccio (NC) $772.67 $0,00 $1 .59 .$784.26 Mar-22-99 Draft Reply to New Matter (NC) Telephone call to client (NC) Draft revisions to Reply to New Motion (NC) Mar-24-99 Consultation with client Travel to and from Dauphin Co. Courthouse (NC) Total Attorney Services Secretarial Services: Mar-22-99 Photocopy and conform Reply to New Matter (NC) Total Secretarial Services Interest: Apr-05-99 Interest charged on unpaid ' balance through April 5, Total Interest Total Fees Costs Advanced: Mar-10-99 1999. Photo Copies Letter to clients (NC-~5) Mar-19-99 Fax from client (NC) Photo Copies letter to Atty. Morris (NC) Mar-22-99 Photo Copies -Reply to New Matter (NC-28) Total Costs Advanced Total Fees and Disbursements Trust Account Balance $0.00 $0.00 $0.00 $0.00 $0.00 $0. O0 $11.59 $0.00 $11.59 $o.oo May 5, 1999. that date. Please remit the outstanding balance due on or before Interest will be charged on any unpaid balance after Very truly yours, Stephen G. Held SGH:csb MARY A. ETTER DI~$1NGER WILLIAM CHESTER DIS~INQER STEPHEN GEORGE HELD March 11, 1999 Camp HIE Grille: 28 N. Thirty. Second St~et Camp Hil(. P~nnsyIvania 17011 717 975-2840 FAX 717 gT~-3924 FAX 717 967-2316 MATTER $ 1-98-589 INVOICE ~ 8173 Anthony and Barbara Puccio 908 Sunnyside Road Hummelstown PA 17036 Dear Mr. and Mrs. Puccio: Previous Balance Payment on Account Current Charges Outstanding Balance Due ======================= Attorney Services: Feb-08-99 Feb-16-99 Feb-25-99 Feb-26-99 Mar-03-99 Study/Review Sheriff's return, review file (N/C) Study/Review Sheriff's return and file (NC) Telephone call from client (NC) Telephone call to Carolene, Re: 237 Notice (NC) Telephone call from Mr. Puccio (NC) Telephone call to Getz (NA,NC,LM) $761.25 $0.00 $11.42 $772.67 Mar-04-99 Mar-09-99 Telephone call to Getz (NC) Instruction to Carolene (NC) Telephone call to Sheriff; telephone call to Getz; telephone call to Churnicoff (NC) Study/Review answer and letter from Getz (NC) Total Attorney Bervioes Interest: Mar-10-99 Interest charged on unpaid balance through March 10, 1999. Total Interest Costs Advanced: Mar-08-99 Photo Copies Notice to Plead and letter from D. Getz (NC) Total Costs A~vanoe4 Trust Aooount Balance $0.00 $00.00 $11.42 $0.00 $o.oo Please remit the outstanding balanoe due on or before April 2, 1999. Interest will be charged on any unpaid balance after that date. Very truly yours, SGH:csb Stephen G. Held MARY A. ETTER DI$SINGER WILLIAM CHESTER DISS~NGER STEPHEN GEORGE HELD February 15, 1999 Camp Hill O~¢e: 28 N. Thirty-Second $~reet Camp Hill. Pennsylvania 170~1 ?~7 975-2840 FAX 717 975-3924 MATTER # 1-98-589 INVOICE ~ 8113 Anthony and Barbara Puccio 908 Sunny$ide Road Hummelstown PA 17036 Dear Mr. and Mrs. Puccio: Previous Balance Payment on Account Current Charges Outstanding Balance Due $750.00 $0.00 $11.25 $761.25 Attorney Services: Jan-06-99 Telephone call to client (NA/NC) Jan-07-99 Telephone call to client (NAn/NC) Telephone call to client (NA/NC/LM) Telephone call from client Jan-!4-99 Draft letter to client - ~;C Consultation with client - NC Draft letter to client Consultation with client Jan-21-99 Draft Praecipe to reinstate complaint; Travel to and from Dauphin county; File Praecipe to reinstate complain; deliver to Sheriff Jan-27-99 Telephone call from client Telephone call to Getz NA/NC - Left message Telephone call from Getz Total Attorney Services Word Processing Services: Jan-15-99 Word Processing letter to clients · Total Word Processing Services Interest: Feb-07-99 Interest charged on unpaid balance through February 7, Total Interest 1999 Total Fees Costs Advanced: Jan-15-99 Photo Copies letter to clients (NC-2) Total Costs Advanced Total Fees and Disbursements Trust Summ~ry: Jan-15-99 Trust Funds received Jan-18-99 Trust Funds disbursed Trust Account Balance 0.00 0.00 11.25 11.25 $11.25 $0.00 $0.00 $11.25 $43.00 $43.00 $0.00 Please remit the outstanding balance due on or before March 6, 199. Interest will be charged on any unpaid balance after that date. Very truly yours, sgh:md Stephen G. Held MARY A. t; i~R DI6SINGER WILLIAM CHESTER DISSINGER STEPHEN GEORGE HELD January 8, 1999 28 N. 'i~l~ty-Sacond Street Camp Hill, Pennaylvania 17011 717 975-2840 FAX 717 97E~3924 FAX 717 967-2316 MATTER # 1-98-589 INVOICE ~ 7992 Anthony and Barbara Puccio 908 Sunnyside Road Ht;mmelstown PA 17036 Dear Mr. and Mrs. Puccio: Previous Balance Payment on Account Current Charges Discount per agreement to stop billing at $1000.00 in services Outstanding Balance Due $0.00 $250.00 $1,142.70 ($142.70) $750.00 Attorney Services: Dec-08-98 Initial consultation with client (NC) Study/Review business trusts Dec-lO-98 Telephone call to client Telephone call to Getz (NA/NC/LM) Travel to and from Court House (NC) Miscellaneous Checked deed of legal title and drafted Complaint Telephone call to Getz Dec-il-98 Draft revisions to Complaint, and draft acceptance of service Telephone call from Dept. of L &I Dec-14-98 Consultation with client and draft letter to Getz Travel to and from Dauphin Co., filed complaint Dec-16-98 Study/Review from Getz Telephone call to Foschi (NA/NC/LM) Telephone call from Foschi Telephone call to client Dec-17-98 Travel to/from Dauphin County filing an acceptance of service Dec-18-98 Draft client Total Attorney Services 1,095.00 Secretarial Services: Dec-11-98 Miscellaneous Conform Complaint Miscellaneous Copy and exhibits Total Secretarial Servioes label 20.00 Word Processing Services: Dec-14-98 Word Processing letter to Attorney Getz Dec-18-98 Word Processing letter to client Total Word Processing Servioee 20.00 Total Fees Costs Advanced: Dec-il-98 Photo Copies Complaint Dec-14-98 Retainer Photo copies letter to Attorney Getz Dec-18-98 Photo Copies letter to client Total Costs Advanced $1~135.00 $7.20 $0.20 $0.30 $7.70 Total Fees and Disbursements $1,142.70 Please remit the outstanding balance due on or before February 5, 1999. Interest will be charged on any unpaid balance after that date. Very truly yours, sgh:md Stephen G. Held MARY A. ETi'ER DISSINGER WILLIAM CHESTER DISSINGER STEPHEN GEORGE HELD December 18, 1998 Camp HiLl office: 25 N. Thirty-Second Street Camp Hill, Pennsylvania 17011 717 975-2840 FAX 717 975-3924 Marysviile Office: 400 South State Road Marys¥ille, PennsyIvani~ 17053 717 957-3474 FAX 717 957-2316 Anthony & Barbara Puccio 908 Sunnyside Road Hummelstown, PA 170366 Dear Mr. & Mrs. Puccio: You have matter. This representation File 1-98-589 asked our firm to represent you in a litigation letter sets forth the agreement concerning our of you and shall be effective upon receipt of the retainer fee. We cannot undertake to do any work on your case until we receive the enclosed agreement signed by you and a retainer in the amount of $250.00. The retainer is a minimum fee and is not refundable. The retainer requested is only to begin your case. We are unable to tell you specifically how much your case will cost through its conclusion. Therefore, it is necessary to represent you on an hourly rate basis. In the event that your litigation matter is not completed within the limits of this retainer fee, we will apply the retainer fee to the work performed and bill you subsequently on an hourly basis. Due to the nature of this matter and the impossibility of determining what course the matter may take, we are unable to establish a flat fee for our professional services. Our billings are based on the present hourly rates set forth in the attached fee schedule. Our hourly rates are adjusted every January. When the hourly rates are adjusted you will be notified. However, it was agreed that all work will cease by this firm at the time of accrual of $1,000.00 in fees. At this time, future representation, if any, will be determined by further negotiation. Costs are our out-of-pocket expenses, such as filing fees, process server fees, transcripts, photocopies, long distance telephone calls, travel mileage, investigators, appraisers, and accountants. Costs will also be itemized and billed on a periodic basis. We will send you statements monthly for legal services and costs. We will bill you at the accrual~of $1,000.00 in fees and expect payment within thirty (30) days of the date of the bill. Our statements are generally premised upon the amount of professional time expended by the attorneys and staff in our office for such services as conferences, telephone conferences, research, court appearances, travel, and other miscellaneous legal services. In addition, other considerations may enter into the setting of a fee, such as: the novelty and difficulty of the issues involved; the result achieved; the amount in dispute; the necessity of a specialized skill requisite to perform the legal service properly; the likelihood that the acceptance of a particular employment will preclude other employment by the attorney; time limitations imposed by the client or by the circumstances; the nature and length of the professional relationship with the client; the area of law involved; and the interruption of other work in progress. It is impossible to determine in advance the amount of time that will be needed to complete your case. We will keep you fully informed of conferences, telephone calls, drafting of documents, research, court time and necessary travel time. We reserve the right to terminate our attorney-client relationship for non-payment of fees or costs. We expect you to keep current with our billings. If your retainer has been exhausted and there is still considerable work to be done on your case, you may be asked to replenish your retainer and costs before our legal work continues. We will keep you informed as to the progress of your case. We will send you copies of all papers coming in and going out of our offices, including correspondence', pleadings and other documents. If we are unavailable when you telephone, your call will be returned with reasonable promptness. There will be times when we will be in Court or at meetings or in conference, which will preclude us from returning your call as quickly as you might like, but we shall do our best to return your telephone calls as soon as we can. At such times, please feel confident to talk with our secretaries. If you are passing on information, they can deliver it to us without the necessity of your waiting to have us return the call. If you have a question that requires an answer from us, it is far easier for them to obtain the background from you, bring the matter to our attention when we are free, and then have a response for you. If it is necessary for you to speak with us directly, we will attempt to return your call as soon as possible. Every effort will be made to expedite your case promptly and efficiently according to the highest legal and ethical standards. Please acknowledge receipt of the enclosed agreement and your acceptance of its terms by signing the enclosed copy and returning it to us so that we will have a mutual memorandum of our understanding. The other copy we have enclosed is for you to keep for your records. We suggest that you keep your copy of the engagement letter in the folder we have provided to you, along with any future correspondence from this office. In addition, if you ever have questions or comments for me in the future, you can write them down on a piece of paper and slip that into the folder for reference the next time you correspond with or call our office. Respectfully, DISSINGER & DISSINGER Accepted this Anthony Puccio Stephen G. Held day of , 1998 Barbara Puccio MARY A. ETTER DISSINGER WILLIAM CHESTER DISSINGER STEPHEN GEORGE HELD Anthony & Barbara Puccio 908 Sunnyside Road Hummelstown, PA 170366 Dear Mr. December 8, 1998 Camp Hill Office: 29 N. Thir[y-Second Street Camp Hill, Pennsylvania 17011 717 975-2840 FAX 717 975-3924 Marys villa Office; 400 South State Road Marysviile. Pen~sylvenia 17053 717 957-3474 FAX 717 957-2316 File 1-98-589 & Mrs. Puccio: You have asked our firm to represent you in a litigation matter. This letter sets forth the agreement concerning our representation of you and shall be effective upon receipt of the retainer fee. We cannot undertake to do any work on your case until we receive the enclosed agreement signed by you and a retainer in the amount of $250.00. The retainer is a minimum fee and is not refundable. The retainer requested is only to begin your case. We are unable to tell you specifically how much your case will cost through its conclusion. Therefore, it is necessary to represent you on an hourly rate basis. In the event that your litigation matter is not completed within the limits of this retainer fee, we will apply the retainer fee to the work performed and bill you subsequently on an hourly basis. Due to the nature of this matter and the impossibility of determining what course the matter may take, we are unable to establish a flat fee for our professional services. Our billings are based on the present hourly rates set forth in the attached fee schedule. Our hourly rates are adjusted every January. When the hourly rates are adjusted you will be notified. Costs are our out-of-pocket expenses, such as filing fees, process server fees, transcripts, photocopies, long distance telephone calls, travel mileage, investigators, appraisers, and accountants. Costs will also be itemized and billed on a periodic basis. We will bill you monthly for legal services and costs and expect payment within thirty (30) days of the date of the bill. Our statements are generally premised upon the amount of professional time expended by the attorneys and staff in our office for such services as conferences, telephone conferences, research, court appearances, travel, and other miscellaneous legal services. In addition, other considerations may enter into the setting of a fee, such as: the novelty and difficulty of the issues involved; the result achieved; the amount in dispute; the necessity of a specialized skill requisite to perform the legal service properly; the likelihood that the acceptance of a particular employment will preclude other employment by the attorney; time limitations imposed by the client or by the circumstances; the nature and length of the professional relationship with the client; the area of law involved; and the interruption of other work in progress. It is impossible to determine in advance the amount of time that will be needed to complete your case. We will keep you fully informed of conferences, telephone calls, drafting of documents, research, court time and necessary travel time. We reserve the right to terminate our attorney-client relationship for non-payment of fees or costs. We expect you to keep current with our billings. If your retainer has been exhausted and there is still considerable work to be done on your case, you may be asked to replenish your retainer and costs before our legal work continues. We will keep you informed as to the progress of your case. We will send you copies of all papers coming in and going out of our offices, including correspondence, pleadings and other documents. If we are unavailable when you telephone, your call will bereturned with reasonable promptness. There will be times when we will be in Court or at meetings or in conference, which will preclude us from returning your call as quickly as you might like, but we shall do our beet to return your telephone calls as soon as we can. At such times, please feel confident to talk with our secretaries. If you are passing on information, they can deliver it to us without the necessity of your waiting to have us return the call. If you have a question that requires an answer from us, it is far easier for them to obtain the background from you, bring the matter to our attention when we are free, and then have a response for you. If it is necessary for you to speak with us directly, we will attempt to return your call as soon as possible. Every effort will be made to expedite your case promptly and efficiently according to the highest legal and ethical standards. Please acknowledge receipt of the enclosed agreement and your acceptance of its terms by signing the enclosed copy and returning it to us so that we will have a mutual memorandum of our understanding. The other copy we have enclosed is for you to keep for your records. We suggest that you keep your copy of the engagement letter in the folder we have provided to you, along with any future correspondence from this office. In addition, if you ever have questions or comments for me in the future, you can write them down on a piece of paper and slip that into the folder for reference the next time you correspond with or call our office. Respectfully, DISSINGER & DISSINGER Accepted this day of Stephen G. Held , 1998 Anthony Puccio Barbara Puccio Job Title Attorney Attorney Associate Attorney Associate Attorney Law Clerk/Paralegal Secretary Computer Operator STANDARD FEES FOR WORK PERFORMED ON AN HOURLY BASIS Work Performed In Office At Hearing/In Court or Adversary Proceeding In Office At Hearing/In Court or Adversary Proceeding All Secretarial Micro Computer/Word Hourlv Rate $150.00 $200.00 $ 9o.00 $125.00 $ 50.00 $ 40.00 Statements are sent every thirty (30) days. Payment is expected by the date indicated on the statement. Ail accounts with balances outstanding after thirty (30) days are charged interest at a rate of 1.5% per month on the outstanding balance. Outstanding balances will not be carried past ninety (90) days. Please remit all payments to: William C. D I S S I N G E R Dissinger & D I S S I N G E R Attorneys At Law 400 South State Road Marysville, PA 17053 717-957-3474 Mary A. Etter Dissinger. Stephen G. Held Incurred expenses or costs, such as filing fees, doctors' fees, medical reports, expert fees, etc., are billed at cost. meetings, conferences, and hearings. Processing $ 40.00 Electronic research Use of Electronic Library $100.00 Copies $.10 per page Facsimiles Sent or received $1.00 per page Fees are based on time, portal-to-portal, for out of office GOMMONWEALTH OF PENNPVLVANIA COUNTY OF: CUMBERLAN Mag Dist. NO: 09-1-02 DJ Name; Hon, Add,ess: 1901 "STATE STREET CAMP HILL, PA Telephone: (717 761-0583 17011-0000 MARY A. ETTER'DISSINGER, ESQ 400 S STATE RD DISSINGER & DISSINGER MARYSVILLE, PA 17053 THIS IS TO NOTIFY YOU THAT: Judgment: [] Judgment was entered for: (Name) ]Judgment was entered against: (Name) NOTICE "' JUDGMENT/TRAnSCRIPT CIVIL CASE PLAINTIFF: / NAME and ADDRESS UETTER-DISSINGER, ESQ, MARY A. 400 S STATE RD DISSINGER & DISSINGER iMARYSVILLE, PA 17053 VS. DEFENDANT: NAME and ADDRESS r-PUCCIO, ANTHONY, ET AL. 908 SUNNYSIDE RD HUMMELSTOWN, PA 17036 L J Docket No.: CV- 0000384- 00 Date Filed: 10/19/00 FOR PT,ATNTIFF RSQ, ~AR¥ A in the amount of $ 1,07o ~;R on: ] Defendants are jointly and severally liable. ] Damages will be assessed on: --']This case dismissed without prejudice. Amount of Judgment Subject to [~ Attachment/Act 5 of 1996 $ [] Levy is stayed for days or [] generally stayed. ] Objection to levy has been filed and hearing will be held: (Date of Judgment) (Date & Time) Amount of Judgment $ 988.43 Judgment Costs ' $ 82.25 Interest on Judgment $ o 00 Attorney Fees $ .00 Total $ 1,070.68 Post Judgment Credits Post Judgment Costs Certified Judgment Total $ $ Date: PEace: Time: ANY PARTY HAS THE RIGHT TO APPEAL WITHIN 30 DAYS AFTER THE ENTRY OF JUDGMENT BY FILING A NOTICE OF APPEAL WITH THE PROTHONOTARY/CLERK OF THE COURT OF COMMON PLEAS, CIVIL DIVISION. YOU ~ -6:~0~ -O' Date ' ~, ~'~ ~/~~ , District Justice I certify that this is a true an~c~t ~y~//o¢: proceedings containing the judgment. ~-~--O~ Date ~¢~ 'I~ District Justice My commission expires first Monday of January, 2006 ;EAL AOPC 315-99 DISSINGER AND DISSINGER, Plaintiffs vs. ~kNTHONY PUCCIO, and BARB~RA PUCCIO, Defendants IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY PENNSYLVANIA CIVIL ACTION AT LAW NO. CERTIFICATE OF SERVICE I, Mary A. Etter Dissinger, Esquire, hereby certify that on the date set forth below I served a true and correct copy of the foregoing document upon the Defendants, ~knthony Puccio and Barbara Puccio, by First Class United States mail addressed as follows: Anthony Puccio 908 Sunnyside Road Hummelstown, PA 17036 Barbara Puccio 908 Sunny$ide Road Hummelstown, PA 17036 Date: · Etter Dissinger, Esquire DISSINGER AND DISSINGER, Plaintiffs vs. ANTHONY PUCCIO, and B~kRBAP. A PUCCIO, Defendants TO: Anthony Puccio Barbara Puccio 908 Sunnyside Road Hummelstown, PA 17036 Date of Notice: May ~ , 2001 IN THE COURT OF COMMON OF CUMBERLAND COUNTY PENNSYLVANIA NO. 01-1495 CIVIL ACTION - LAW PLEAS IMPORTANT NOTICE YOU ARE IN DEFAULT BECAUSE YOU HAVE FAILED TO TA/<E ACTION REQUIRED OF YOU IN THIS CASE. 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 M3tY 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 Court House Court Administrator 1 Courthouse Square Carlisle, PA 17013-3387 717-240-6200 ~A.~~-Etter Dissi~e~ Attorney for Plaintiffs 28 North Thirty-second Street Camp Hill, PA 17011 (717) 975-2840 Supreme Court ID # 27736 DISSINGER AND DISSINGER, PlaintiffS vs. ANTHONY PUCCIO, and BARBA=RA PUCCIO, Defendants IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY PENNSYLVANIA NO. 01-1495 CIVIL ACTION - LAW CERTIFICATE OF SERVICE I, Mary A. Etter Dissinger, Esquire, hereby certify that on the date set forth below I served a true and correct copy of the foregoing document upon the Defendants, Anthony Puccio and Barbara Puccio, by First Class United States mail and by certified, restricted delivery addressed as follows: Anthony Puccio 908 Sunnyside Road Hummelstown, PA 17036 Barbara Puccio 908 Sunnyside Road Hummelstown, PA 17036 Date: Mary ~. Etter Dissinge~, Esquire DISSINGER A-ND DISSINGER, Plaintiffs vs. i~NTHONY PUCCIO, and BA~RBA_RA PUCCIO, Defendants IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY PENNSYLVANIA NO. 01-1495 CIVIL ACTION - LAW AFFIDAVIT OF MAILING COMMONWEALTH OF PENNSYLVANIA COUNTY OF CUMBE RL/LND : ss Mary A. Etter Dissinger, Esquire, attorney for Plaintiffs, being duly sworn according to law, says that she mailed by United States Certified Mail, Restricted Delivery, a true and correct copy of the Plaintiff's Default Notice in this action to the Defendant at her residence, and that Defendant did receive same as evidenced by the signed receipt dated May 30, 2001 attached hereto as Exhibit "A". Sworn to and subscribed befo~ ~ this ~/~f day of /;~7/~g ~. ,. , 2001. Mary A. Etter Di~sm'dger~squire Attorney for Plaintiffs Supreme Court ID # 27736 28 North Thirty-second Street Camp Hill, PA 17011 (717) 975-2840 I1 , SENDER.' I also wfsh to ~eceive the follow- [3 Complete items 1 a,-KI/or 2 for additional sen,ices, il3g services (for an extra fee): Comp~e items 3, 4a, and 4b. d card to you. 1. [] Addressee's Address .~ p~r~t. 2. [] Restricted De~iveP/ 3. Article Addressed to: 4a. Articie Number BARBARA PUCCIO 7000 0600 0025 5540 2271[ 4b. Service Type 908 SUNNYSIDE ROAD [] Registered ~Certifidd a: ~{UMMELSTOWN PA 17036 [] Express Mail [] Insured 8. Addressee's Addrse~ (Oniy if ~questecl and ~ 5. Rec~dd By: ~nt Name) c 6. S seeorAgent) PS Form 3811, December 1994 1025e$-99-a-~)22s Domestic Retum Receipt EXHIBIT "A"