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HomeMy WebLinkAbout11-3530COYNE & COYNE, P.C. Lisa Marie Coyne, Esq. Pa. Supreme Ct. No. 53788 3901 Market Street FILED-OFFICE OF THE PROTHONOTARY Camp Hill, PA 17011-4227 2011 APR -7 PM 3: 24 (717) 737-0464 CUh1gERLANO CCAforneysfor Plaintiff COYNE & COYNE, P.C., Plaintiff vs. JORDANA SARVER, Defendant IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA NO. ,? -?S3y CIVIL, TERM : CIVIL ACTION--LAW NOTICE 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 Notice is served, by entering a written appearance personally or by an attorney and filing in writing with the Court your defenses or objections to the claims set forth against you. You are warned that if you fail to do so the case may proceed without you and a judgment may be entered against you by the Court without further notice for any money claimed in the Complaint or for any other claim or relief requested by the Defendant. 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 Lawyer Referral Service 32 S. Bedford Street Carlisle, PA 17013 (717) 240-6200 Iaoueaa Ct,* 9yv 025l(o55 COYNE & COYNE, P.C. Lisa Marie Coyne, Esq. Pa. Supreme Ct. No. 53788 3901 Market Street Camp Hill, PA 17011-4227 (717) 737-0464 Attorneys for Plaintiff COYNE & COYNE, P.C., Plaintiff vs. JORDANA SARAVER, Defendant IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA NO. CIVIL TERM CIVIL ACTION--LAW COMPLAINT AND NOW comes the Plaintiff, Coyne & Coyne, P.C., and files the within Complaint: 1. Plaintiff is Coyne & Coyne, P.C. a Professional Corporation, with offices located at 3901 Market Street, Camp Hill, Cumberland County, Pennsylvania 17011. 2. Defendant is JORDANA SARVER is an adult individual residing at 17 W. Factory Street, Apt. 2, Mechanicsburg, Cumberland County, Pennsylvania 3. On or about December 29, 2010, Defendant engaged the Plaintiff for legal services concerning a child support and custody matter per the financial terms outlined and agreed to by the Defendant as per a written Fee Agreement. (See Exhibit "A") 4. Plaintiff performed legal services for Defendant which included successfully obtaining child support obligation against father of Plaintiffs child. 5. Plaintiff submitted regular invoices to Defendant for payment. 6. Repeated demands for payment in full have been made to Defendant; however, Defendant refuses to pay the invoices. 2 7. As of April 6, 2011, Defendant owes Plaintiff One Thousand and 65/10 Dollars as balance due and owing under the written fee agreement with an interest rate of 1.5% per month, annually 18%. (See Exhibit "B") WHEREFORE, Plaintiff, Coyne & Coyne, P.C., respectfully requests Judgment in the amount of 51,000.65, together with Court costs and Sheriff's costs and accruing interest from date of complaint filing at the rate of 1.5% per month, annually 18%. Dated: G 2,v /t Respectfully submitted, COYNE & COYNE, P.C. By: LIS 7MARIE COYNE ESQUIRE a. . . No. 53788 3901 Market Street Camp Hill, PA 17011-4227 (717) 737-0464 3 COYNE & COYNE A PROFESSIONAL CORPORATION ATTORNEYS AT LAW i Henry F. Coyne 3901 Market Street 717-737-0464 Lisa Marie Coyne Camp Hill, Pennsylvania Fax: 717-737-5161 Jaime L. High 17011-4227 www.coyneandcoyne.com December 29, 2010 Ms. Jordana Sarver 17 W. Factory Street, Apt. 2 Mechanicsburg, PA 17055 Re: Domestic Relations Dear Ms. Sarver: It was a pleasure speaking with you today concerning your child supporthearing for January 6, 2011. We also discussed my fee for professional services and that I would provide the following as a written fee agreement which I ask you to review and return to me at your convenience. This fee agreement concerns the hearing for January 6, 2011 only and any additional services would be subject to an additional retainer. Because of the nature of the matter, and because of the possibility of the occurrence of unpredictable and unforeseen circumstances, I am not in a position to quote you a final and specific fee for my professional services. However, I indicated to you that I would represent you on an hourly basis. My fee for professional' services is' TWOr HUNDRED DOLLARS ($200.00) per hour, with fractions of hours computed in periods of riot less` than 15 minutes; which takes into account interruption of other work. Each such hour is based upon actual work regarding your particular case. We will provide you periodic invoices for services rendered. Payments on invoices are due upon receipt. After thirty (30) days, if an invoice remains unpaid, interest will be charged on the outstanding monthly balance at the rate of One and a half Percent (1.5%), annually Eighteen Percent (18%). This office reserves the right to modify the hourly rate and the rate of interest from time to time with advance notices to you should those changes be implemented. Any out-of-pocket expenses directly attributable to your case, including by way of example court costs/filing fees, toll calls, postage, photocopies and special mailings, e.g., federal express or certified mail, will be charged to you at cost in addition to the fee. Legal costs and expenses incurred are the obligation of and are to be paid by the client upon billing of same. We respectfully request you to remit to me the sum of EIGHT HUNDRED DOLLARS ($800.00) as retainer fee. This retainer will be credited to your account for services rendered in connection with this case. As work is performed on your behalf, you will be provided itemized invoices. 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. If this support case progresses and the initial retainer is depleted, you will be required to deposit additional retainers. 1 r. Ms. Jordana Sarver December 29, 2010 Page 2 It is impossible to predict a course that a support action will take. Therefore, it_is important that you keep me informed of any and all changes in your life once my representation commences. We shall keep you well 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 court documents. Do not make changes or take what may seem like unimportant steps without consultation with me first. Do not hesitate to ask questions. If I am unavailable when you telephone, your call will be returned with reasonable promptness. There will be times when I will be in court, or at meetings, or in conference, which will preclude me from returning your call as quickly as we both might like, but I shall do my best to return your telephone calls as soon as I can. During the course of representing you, we provide copies of incoming and outgoing correspondence and documents to you to keep you informed. After your case is concluded, we maintain our files for a period of five (5) years. After that time, we will have files destroyed under conditions that will render the information in those files unusable. I am pleased to represent you in this matter, and I assure you that I will pursue your matter diligently and expeditiously and with my best efforts and expertise. Please acknowledge receipt of this letter and your agreement to same by signing a copy and returning same in the enclosed envelope, postage prepaid. Very truly yours, COYNE & COYNE, P.C. Jaime L. High JLH/crs Enclosure I, Jordana Sarver, have read and fully understand the statements above written. I am acknowledging my agreement to the above by signing below. Dated: (? LAW OFFICES OF COYNE & COYNE, P.C. 3901 Market Street Camp Hill, PA 17011-4227 Invoice submitted to: Jordana R. Sarver 17 W. Factory Street, Apt. 2 Mechanicsburg PA 17055 April 06, 2011 In Reference To: Child Support Invoice #15560 Professional Services 3/20/2011 Review file; D/P Memo to Client Re: Overdue Invoice For professional services rendered Interest on overdue balance Total amount of this bill Previous balance Balance due Hours Amount 1.00 NO CHARGE w.uu $18.58 $18.58 $982.07 $1,000.65 VERNICATION The facts set forth in the foregoing are true and correct to the best of the undersigned's knowledge, information and belief and are verified subject to the penalties for unworn falsification to authorities under 18 Pa. C.S.A. §4904. Dated: ZD 1 ` FILED-CFF1CE 1)F THE PRCTHONC)T,,%F? { COYNE & COYNE, P.C. Lisa Marie Coyne, Esquire Pa. Supreme Ct. No. 53788 3901 Market Street Camp Hill, PA 17011-4227 (717) 737-0464 2011 APR 28 PH 12: 03 CUMBERLAND CCf;1r ? ': €'ENNSYLVAHI/? Attorney for Plaintiff COYNE & COYNE, P.C., : IN THE COURT OF COMMON PLEAS OF Plaintiff : CUMBERLAND COUNTY, PENNSYLVANIA vs. JORDANA SARVER, Defendant NO. 11-3530 CIVIL TERM CIVIL ACTION--LAW PREACIPE TO SETTLE AND DISCONTINUE To the Prothonotary of Cumberland County: In accordance with Settlement Agreement reached this date between the parties and the payment in full of a stipulated amount made by Defendant to Plaintiff, kindly mark this matter as settled and discontinued. Respectfully submitted: Dated: COYNE & COYNE, P.C. '7?2_ By: S:) Lis arie Coyne, 96quire a. S. Ct. No. 5378 3901 Market Street Camp Hill, PA 17011-4227 (717) 737-0464 Attorney for Plaintiff