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HomeMy WebLinkAbout11-9528 FILED-OFriCw N1 fA" ' LAW OFFICES OF PETER J. RUSSO, P.C. OF THE PROTHO BY: Peter J. Russo, Esquire 2011 DEC 2$ AM 10: it 5 PA Supreme Court ID: 72897 Elizabeth J. Saylor, Esquire CUMBERLAND COUNTY PA Supreme Court ID: 200139 PENNSYLVANIA 5006 E. Trindle Road, Suite 100 Mechanicsburg, PA 17050 Telephone: (717) 591-1755 LAW OFFICES OF PETER J. RUSSO, P.C., : IN THE COURT OF COMMON PLEAS OF Plaintiff : CUMBERLAND COUNTY, PENNSYLVANIA V. CIVIL ACTION -LAW DONNA J. RHOADES, 11 _ Q S .2 B Defendant NO. CIVIL TERM 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 complaint and notice are served, by entering a written appearance personally or by attorney and filing in writing with the court your defenses or objections to the claims set forth against you. You are warned that if you fail to do so the case may proceed without you and a judgment may be entered against you by the court without further notice for any money claimed in the complaint or for any other claim or relief requested by the plaintiff. You may lose money or property or other rights important to you. YOU SHOULD TAKE THIS PAPER TO YOUR LAWYER AT ONCE. IF YOU DO NOT HAVE A LAWYER, 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 LE L SERVICES TO ELIGIBLE PERSONS AT A REDUCED FEE OR NO FEE. 5' ? q.2. oa Cumberland County Bar Association 32 South Bedford Street Carlisle, PA 17013 717-249-3166 1-800-990-9108 0 LAW OFFICES OF PETER J. RUSSO, P.C. BY: Peter J. Russo, Esquire PA Supreme Court ID: 72897 Elizabeth J. Saylor, Esquire PA Supreme Court ID: 200139 5006 E. Trindle Road, Suite 1.00 Mechanicsburg, PA 17050 Telephone: (717) 591-1755 LAW OFFICES OF PETER J. RUSSO, P.C., Plaintiff V. DONNA J. RHOADES, Defendant : IN THE COURT OF COMMON PLEAS OF : CUMBERLAND COUNTY, PENNSYLVANIA : CIVIL ACTION -LAW NO. 611 VIZ- COMPLAINT AND NOW COMES, the Plaintiff, Law Offices of Peter J. Russo, P.C., and avers the following in support of its claims: 1. Plaintiff, Law Offices of Peter J. Russo, P.C., is a Pennsylvania Professional Corporation doing business in the Commonwealth of Pennsylvania with its principle place of business at 5006 East Trindle Road, Suite 100, Mechanicsburg, PA 17050. 2. Defendant, Donna J. Rhoades, an adult individual with a last known address of 6 Bourbon Red Drive, Mechanicsburg, PA 17050. 3. Beginning on or about June 26, 2009, Plaintiff agreed to provide professional legal services to Defendant for a fee. 4. Plaintiff and Defendant entered into a written Fee Agreement regarding said services. The Fee Agreement is attached hereto and incorporated herein as Exhibit "A". 5. Paragraph three (3); page one (1) of the Fee Agreement states, "the current charge for [Elizabeth Saylor's] time is $170.00 per hour for out of court time and $190.00 for actual court time. The charge for legal assistants, paralegals, and law clerks is $85.00 per hour. The minimum 3 billing unit for any work done is .17 hours, or ten minutes. No additional charge is made for secretarial and clerical services. We agree to bill you at these rates through December 31 of this year. All services rendered after that time will be charged at the rates then in effect." 6. Paragraph four (4); page two (2) of the Fee Agreement states, "Our office requires invoices to be paid in full within thirty (30) days of the billing date." 7. Paragraph one (1), page three (3) of the Fee Agreement states, "if you have any questions concerning any time of charge it is your responsibility to bring them to our attention within thirty (30) days of the date of the statement. Because investigation of billing inquires is time consuming and burdensome to office operations and unfairly increases cost of representation to other clients, we must charge a search expense of $50.00 per hour for staff personnel for the investigation of any billing inquiry made after thirty days. Attorney time for such inquires will be billed at regular hourly rates. " 8. Paragraph five (2); page two (2) of the Fee Agreement states, "we will impose finance charges of 18 percent per annum as permitted by law on amounts unpaid after thirty (30) days, as well as charges for any time involved in collection..." 9. Plaintiff provided the legal services per the Fee Agreement. 10. Plaintiff provided Defendant with multiple statements reflecting the services rendered. 11. Plaintiff has repeatedly attempted to collect full payment from Defendant. 12. Despite Plaintiff s efforts, Defendant has refused to render payment in full. 13. Plaintiff believes and therefore avers that as of December 19, 2011, Defendant owes Plaintiff $19,640.31 for services previously rendered, plus 18% interest per annum ($3,029.74 per annum or $8.30 per diem) from December 20, 2011 forward, plus costs, and reasonable attorney's fees. 4 COUNT I - BREACH OF CONTRACT 14. Plaintiff re-alleges the allegations set forth hereof and incorporates them herein by reference as though set forth herein at length. 15. Plaintiff contracted with Defendant to perform the services set forth on Exhibit "A". 16. Plaintiff performed said services. 17. Plaintiff contacted Defendant on several occasions thereafter to request payment for the services rendered. 18. Although duly demanded by Plaintiff, the balance due has not been paid. WHEREFORE, Plaintiff claims damages from Defendant in an amount that does not exceed the mandatory arbitration amount plus interests, costs, attorney's fees and any other appropriate damages. Rem miUed; LAW OFFICES OF PETER-TIZUSSO, P.C. Peter J. Russo, Esquire Attorney I.D. No. 72897 Elizabeth J. Saylor, Esquire Attorney I.D. No. 200139 5006 E. Trindle Road, Suite 100 Mechanicsburg, PA 17050 Telephone: (717) 591-1755 5 VERIFICATION I, e. . " \ 0. , , o , verify that the statements made in the forgoing document 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 to authorities. C +-C, , Dated: 1 ",)? ? a? ?,q o t \ Print Title: 0 Signature 6 (ObIN LAW OFFICES OF PETER ).RUSSO P .c. ATTORNEYS AT LAW 5006 E. Trindle Road, Suite 100, Mechanicsburg, PA 17050 Phone: (717) 591-1755 Fax: (717) 591-1756 Peter J. Russo, Esquire Elizabeth J. Saylor, Esquire Ashley R. Sipe, Paralegal Amber L Southard, Paralegal GENERA, LmGATm FEE AGREEMENT Dear Donna, This is to confirm. our conversation, at which time we discussed the following legal concern and whether this office would represent you in connection with these matters. Scope of Representation: The following explanation of our billing procedures is intended to supply you with general information regarding payment for your legal representation and to confirm the arrangements for payment of your legal fees. An effective attorney-client relationship is based upon complete understanding and mutual respect and it is therefore important that you review the contents of this letter carefully and call me if you have any questions. The current charges for our time range between $170.00 and $225.00 per hour for out of court time. Specifically, Liz charges $170.00 per hour and Peter charges $225.00 per hour for in office time. Liz charges $190.00 per hour and Peter charges $225.40 per hour for out of office time. The charge for legal assistants, paralegals and law clerks is $85.00 per hour. The minimum billing unit for any work done is .17 hours, or ten minutes. Drafting or review of any document, including emails will be billed at a minimum of .17. We agree to bill you at these rates through December 31 of this year. All services rendered after that time will be charged at the rates then in effect. Costs, for which you will be charged separately, include reimbursement for out-of-pocket expenses such as filing fees, process server fees, travel expenses, transcripts, printing costs, toll telephone charges, postage, computer assisted research, and, on occasion, fees for investigators, appraisers or accountants although such persons will usually be hired by you if their services are required. Fees for specific cost charges are made in accordance with the attached schedule. Client's Initials ?il?. Page One of Four (Ohl 14n Page 2 of 4 Genera! Litigation Fee Agreement A non refundable retainer of $1,500.00 is required before any work can be undertaken on your behalf. Your balance shall not fail below $100.00 at any given time. **CLIENT'S INITIALS All evidentiary and appellate court appearances are billed at a minimum of four (4) hours computed at the regular hourly rate of the attorney representing you or the actual time spent at the proceeding when more than four hours is required. All other charges are computed on the basis of time expended in providing you with legal advice and representation. If you require representation at a trial or hearing, it will be necessary for you to deposit an additional retainer equal to twice the actual court time anticipated. This requirement is necessary because evidentiary court appearances are time intensive for the attorney and preclude the undertaking of other work for an extended period of time, not only during the actual hearing, but in the period of advance preparation as well. Most evidentiary proceedings require two to three hours of preparation time for each hour of scheduled court time. If complex questions of fact or law are involved, this time can increase substantially. It is not possible to estimate in advance the total charges for your legal work since the amount of time required is dependent upon the circumstances of your personal situation. In order for our office to undertake the responsibility of being your representative, you must be willing to make a financial commitment to this matter. Our office requires invoices to be paid in full within thirty (30) days of the billing date. After thirty days has passed without payment, our office may cease representing you, and further reserves the right to add interest to any outstanding balance and/or to turn the matter over to an outside entity for collection. If you cannot agree to this commitment, we cannot represent you and thus request that you do not enter into this fee agreement. By signing and returning this fee agreement, we will assume that you are willing and able to take on this financial responsibility. Like other creditors, we will impose finance charges of 18 percent per annum as permitted by law on amounts unpaid after 30 days, as well as charges for any time involved in collection, including time spent negotiating and drafting alternative payment arrangements. In the event that we feel we must pursue legal action against you in order to collect any outstanding balance, you will be responsible for any and all attorneys' fees and costs associated therewith. All payments received on account for fees billed will be credited first to the most recent charges on your account. Client's Initials ?!? Page Two of Four f01IN Page .3 of 4 General Litigation Fee Agreement low) If you have any questions concerning any time or charge it is your responsibility to bring that item to our attention within thirty days of the date of the statement. Because investigation of billing inquiries is time consuming and burdensome to office operations and unfairly increases cost of representation to other clients, we must charge a search expense of $50 per hour for staff personnel for the investigation of any billing inquiry made after thirty days. Attorney time for such inquiries will be billed at regular hourly rates. You will at all times have the right to terminate our services upon written notice to that effect. We will at all times have the right to terminate our services upon written notice to that effect in the event that you fail to cooperate with us in any reasonable request, to timely pay the monthly statements in full as submitted, to replenish the retainer, or if we determine in our reasonable discretion that to continue our services to you would be unethical or impractical. There are many roads to the same destination; some are long and arduous and others are direct and easy. One of your most important considerations in deciding between various courses of action, or inaction, should always be the expense involved and this is based upon the amount of time which must be expended. We will attempt to represent you in the most time efficient manner possible and will, from time to time, suggest things that you can do to minimize your legal expenses. The following are some suggestions which have proved helpful to other clients and we would like to share them with you. We encourage you to adopt these procedures because they not only minimize expenses but, even more importantly, tend to produce a better ultimate result: 1. Avoid unnecessary telephone calls. If you have a question or information which can wait, make a note of it so that you can cover several items in one personal or telephone conference. 2. Leave messages. If you need to impart information which need not be discussed immediately, either leave the information with the secretary who answers the telephone or send a note. All of the attorneys in this office spend considerable amounts of time in court and we are therefore frequently unable to speak with you on the telephone when you call. I will attempt to return your telephone calls as soon as I reasonably can do so. In many situations, you should ask to speak with a legal assistant who can answer many factual questions for you and can relay information to me. Every employee in this office is bound to hold confidential any information received form a client. However, ONLY an attorney may give you legal advice. 3. Read everything. You will receive copies of all documents and letters concerning your legal business which are either sent or received. You should maintain your own file which will duplicate the one which we are keeping. This will enable you to refer to the documents as necessary and will provide you with a permanent record of your case. Client's Initials bE Page Three of Four v -' . O Page 4 of 4 Genera! litigation Fee Agreement 4. Make notes. Write everything down: questions, .information, lists of pros and cons, everything. If you do, you will avoid repetition and you will not overlook anything important. 5. Ask questions. You must be in a position to make informed and intelligent decisions. The only dumb question is the one you fail to ask. While we cannot guarantee a particular result, you may be assured that we will utilize the resources and expertise of this office to your best advantage. If you wish us to represent you, such representation will begin upon receipt by us of the enclosed copy of this letter, signed by you and your retainer payment. You should retain the original of this letter for your own records. If you do not wish to retain counsel at this time, you may arrange to be seen on a consultation basis at the same hourly rate, with the understanding that our representation of you does not begin until your retainer has been received. Again, should you have any questions or concerns, please feel free to contact me. Very truly yours, Law Offices of Peter J. Russo, P.C. I, Donna Rhoades, have read the foregoing three pages and understand the terms and conditions of this Fee Agreement and they are acceptable to me. My signature herein is my express acknowledgment and acceptance of the terns of this Agreeme )1_ ! Donna Rhoades Date: ??.tr 1 ?q CERTIFICATE OF SERVICE I hereby certify that I have on this day served a true and correct copy of the Complaint, upon the following person, in the manner indicated: Sheriffs Delivery Donna Rhoades 6 Bourbon Red Drive Mechanicsburg, PA 17050 DATE: -4 r 8 SHERIFF'S OFFICE OF CUMBERLAND COUNTY Ronny R Anderson Sheriff Jody S Smith Chief Deputy Richard W Stewart Solicitor ?q?tith al putt+brp????? ? b r ( !? Wi``a?t i ll?? 2012 JAN 17 All 9: 08 UMBERLAND GO?.?i't?T`? PENNSYLVANIA Law Offices of Peter J. Russo, PC vs. Donna J. Rhoades Case Number 2011-9528 SHERIFF'S RETURN OF SERVICE 01/10/2012 01:55 PM - Shawn Gutshall, Deputy Sheriff, who being duly sworn according to law, states that on January 10, 2012 at 1355 hours, he served a true copy of the within Complaint and Notice, upon the within named defendant, to wit: Donna J. Rhoades, by making known unto herself personally, at The Cumberland County Sheriffs Office, 1 Courthouse Square, Room 303, Carlisle, Cumberland County, Pennsylvania 17013 its contents and at the same time handing to her personally the said true and correct copy of the same. SHERIFF COST: $38.00 January 11, 2012 S G SHALL, DEPUTY SO ANSWERS, RON R ANDERSON, SHERIFF c? Cci.u;Suite Sher'f. Telex,„oft.. L•r -1?, ED-OFFICI + Y LAW OFFICES OF PETER J. RUSSO, P.C.PROTHONOTARY BY: Peter J. Russo, Esquire PA Supreme Court ID: 72897 2C12 FEB - l P 2: B' Elizabeth J. Saylor, Esquire ? UMBERLAND COUNTY PA Supreme Court ID: 200139 DENNSYLVANIA 5006 E. Trindle Road, Suite 100 Mechanicsburg, PA 17050 Telephone: (717) 591-1755 LAW OFFICES OF PETER J. RUSSO, P.C., : IN THE COURT OF COMMON PLEAS OF Plaintiff : CUMBERLAND COUNTY, PENNSYLVANIA V. : CIVIL ACTION -LAW DONNA J. RHOADES, . Defendant NO. 11-9528 CIVIL TERM TO: Donna J. Rhoades 6 Bourbon Red Drive Mechanicsburg, PA 17050 Date of Notice: January 31, 2011 YOU ARE IN DEFAULT BECAUSE YOU HAVE FAILED TO TAKE 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 MAY LOSE YOUR PROPERTY OR OTHER IMPORTANT RIGHTS. YOU SHOULD TAKE THIS NOTICE TO A LAWYER AT ONCE. IF YOU DO NOT HAVE A LAWYER OR CANNOT AFFORD ONE, GO TO OR TELEPHONE THE FOLLOWING OFFICE TO FIND OUT WHERE YOU CAN GET LEGAL HELP: Cumberland County Bar Association 32 South Bedford Street Carlisle, PA 17013 717-249-3166 1-800-990-9108 THE AW OFFICES OF PETER J. RUSSO, P.C. Peter? , Esquire ID #72897 Elizabeth J. Saylor, Esquire ID # 200139 5006 E. Trindle Road, Suite 100 Mechanicsburg, PA 17050 Phone: (717) 591-1755 Attorneys for Plaintiff J Date: f? ?? LAW OFFICES OF PETER J. RUSSO, P.C. BY: Peter.f. Russo, Esquire PA Supreme Court ID: 72897 Elizabeth J. Saylor, Esquire PA Supreme Court ID: 200139 5006 E. Trindle Road, Suite 100 Mechanicsburg, PA 17050 Telephone: (717) 591-1755 LAW OFFICES OF PETER J. RUSSO, P.C., : IN THE COURT OF COMMON PLEAS OF Plaintiff : CUMBERLAND COUNTY, PENNSYLVANIA V. CIVIL ACTION -LAW DONNA J. RHOADES, Defendant NO. 11-9528 CIVIL TERM CERTIFICATE OF SERVICE I hereby certify that on Tuesday, January 31, 2012, I have served a true and correct copy of the foregoing document upon the following persons, in the manner indicated: Via Regular U.S. Mail Donna J. Rhoades 6 Bourbon Red Drive Mechanicsburg, PA 17050 THE LAW OFFICES OF PETER J. RUSSO, P.C. BY: r r i* tt'Or I' ICS H Fj;OT1?0I?1? ; .?, LAW OFFICES OF PETER J. RUSSO, P.C. BY: Peter J. Russo, Esquire 2012 f EB 22 Pty 3: 4 3 PA Supreme Court ID: 72897 Elizabeth J. Saylor, Esquire CUMBERLAND COUNTY PA Supreme Court ID: 200139 PENNSYLVANIA 5006 E. Trindle Road, Suite 100 Mechanicsburg, PA 17050 Telephone: 717) 591-1755 LAW OFFICES OF PETER J. RUSSO, P.C., : IN THE COURT OF COMMON PLEAS OF Plaintiff : CUMBERLAND COUNTY, PENNSYLVANIA V. : CIVIL ACTION -LAW DONNA J. RHOADES, Defendant NO. 11-9528 CIVIL TERM To the Prothonotary: PRAECIPE FOR ENTRY OF DEFAULT JUDGMENT Please enter a Judgment of Default in the amount of Nineteen Thousand Six Hundred Forty and 31/100 ($19,640.31) Dollars for services previously rendered, plus 18% interest per annum ($3,029.74 per annum or $8.30 per diem) from December 20, 2011 forward, plus costs, and reasonable attorney's fees, in favor of Plaintiff, Law Offices of Peter J. Russo, P.C., and against Defendant, Donna J. Rhoades, for failure to plead to the Complaint in this action within the required time. The Complaint contains a Notice to Defend within Twenty (20) Days from the date of service thereof Plaintiff filed the Complaint on December 28, 2011, Defendant was served with the Complaint on January 10, 2012 by Sheriff, and an Answer to the Complaint was due on or before January 30, 2012. Attached as Exhibit "A" is a copy of Plaintiffs' Written Notice of Intention to File Praecipe for Entry of Default Judgment, which I certify was mailed by regular U.S. mail to the Defendant at her last known address on January 31, 2012, which is at least Ten (10) Days prior to the filing of this Praecipe. 411,o,5o pA Azr/ C# 44 zoo P.* a7l383 NAca M" Date: THE LAW OFFICE OF PETER J. RUSSO, P.C. Attorney I.D. No. 72897 ` Elizabeth J. Saylor, Esquire Attorney I.D. No. 200139 Attorneys for Plaintiff 5006 E. Trindle Road, Suite 100 Mechanicsburg, PA 17050 Telephone: (717) 591-1755 Peter usso, Es LAW OFFICES OF PETER J. RUSSO, P.C. BY: Peter J. Russo, Esquire PA Supreme Court ID: 72897 Elizabeth J. Saylor, Esquire PA Supreme Court ID: 200139 5006 E. Trindle Road, Suite 100 Mechanicsburg, PA 17050 Telephone: (717) 591-1755 LAW OFFICES OF PETER J. RUSSO, P.C., : IN THE COURT OF COMMON PLEAS OF Plaintiff CUMBERLAND COUNTY, PENNSYLVANIA V. : CIVIL ACTION -LAW DONNA J. RHOADES, Defendant NO. 11-9528 CIVIL TERM AFFIDAVIT OF NON-MILITARY SERVICE Commonwealth of Pennsylvania ) ) ss: County of Cumberland ) The undersigned, being duly sworn according to law, deposes and says that the Defendant(s) is/are not in the Military or Naval Service of the United States or Allies, or otherwise within the provisions of the Soldiers' and Sailors' Civi Ief Act3Y ?5?fi-94 Q, as amended: Peter usso, Sworn to and subscribed Before me this 11 day of V;ejpGXA,j , 2012 Notary Publ c E9MMONWE" Notarial Seal Ashley R. Malcolm, Notary Public Hampden TWp., Cumteriand County My Commlsslor? res pet 12WNW 2015 MEMBER, PEWMIL NIA AMSOCU TARIES EXHIBIT "A" . ?1LED???Q?gTAh? LAW OFFICES OF PETER J. RUSSOO.P.V'-: F 03 BY: Peter J. Russo, Esquire V PA Supreme Court ID: 72897 2012 ly'[ Y Elizabeth J. Saylor, Esquire '?MgEIR AND AN p PA Supreme Court ID: 200139 pENNSY? 5006 E. Trindle Road, Suite 100 Mechanicsburg; PA 17050 Telephone: (717) 591-1755 LAW OFFICES OF PETER J. RUSSO, P.C., : IN THE COURT OF COMMON PLEAS OF Plaintiff : CUMBERLAND COUNTY, PENNSYLVANIA V. CIVIL ACTION -LAW DONNA L RHOADES, Defendant : NO. 11-9528 CIVIL TERM TO: Donna J. Rhoades 6 Bourbon Red Drive Mechanicsburg, PA 17050 Date of Notice: January 31, 2011 YOU ARE IN DEFAULT BECAUSE YOU HAVE FAILED TO TAKE 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 MAY LOSE YOUR PROPERTY OR OTHER IMPORTANT RIGHTS. YOU SHOULD TAKE THIS NOTICE TO A LAWYER AT ONCE. IF YOU DO NOT HAVE A LAWYER OR CANNOT AFFORD ONE, GO TO OR TELEPHONE THE FOLLOWING OFFICE TO FIND OUT WHERE YOU CAN GET LEGAL HELP: Cumberland County Bar Association 32 South Bedford Street Carlisle, PA 17013 717-249-3166 1-800-990-9108 THE AW OFFICES OF PETER J. RUSSO, P.C. Peter , Esquire ID #72897 Elizabeth J. Saylor, Esquire _ ID # 200139 5006 E. Trindle Road, Suite 100 Mechanicsburg, PA 17050 Phone: (717) 591-1755 Attorneys for Plaintiff Date: 3? ?? LAW OFFICES OF PETER J. RUSSO, P.C. BY: Peter J. Russo, Esquire PA Supreme Court ID: 72897 Elizabeth J. Saylor, Esquire PA Supreme Court ID: 200139 5006 E. Trindle Road, Suite 100 Mechanicsburg, PA 17050 Teleohone: (717) 591-1755 LAW OFFICES OF PETER J. RUSSO, P.C., : IN THE COURT OF COMMON PLEAS OF Plaintiff : CUMBERLAND COUNTY, PENNSYLVANIA V. CIVIL ACTION -LAW DONNA J. RHOADES, Defendant : NO. 11-9528 CIVIL TERM CERTIFICATE OF SERVICE I hereby certify that on Tuesday, January 31, 2012, I have served a true and correct copy of the foregoing document upon the following persons, in the manner indicated: Via Regular U.S. Mail Donna J. Rhoades 6 Bourbon Red Drive Mechanicsburg, PA 17050 THE LAW OFFICES OF PETER J. RUSSO, P.C. LAW OFFICES OF PETER J. RUSSO, P.C. BY: Peter J. Russo, Esquire PA Supreme Court ID: 72897 Elizabeth J. Saylor, Esquire PA Supreme Court ID: 200139 5006 E. Trindle Road, Suite 100 Mechanicsburg, PA 17050 Telephone: (717) 591-1755 LAW OFFICES OF PETER J. RUSSO, P.C., : IN THE COURT OF COMMON PLEAS OF Plaintiff : CUMBERLAND COUNTY, PENNSYLVANIA V. : CIVIL ACTION -LAW DONNA J. RHOADES, Defendant NO. 11-9528 CIVIL TERM CERTIFICATE OF SERVICE I hereby certify that on - i? I have served a true and correct copy of the foregoing document upon the followingp rsons, in the. manner indicated: Regular U.S. Mail Donna J. Rhoades 6 Bourbon Red Drive Mechanicsburg, PA 17050 THE LAW OFFICES OF PETER J. RUSSO, P.C. BY: Ashley R. Malcolm, Paralegal Date: a- I -1 2 LAW OFFICES OF PETER J. RUSSO, P.C. BY: Peter J. Russo, Esquire PA Supreme Court ID: 72897 Elizabeth J. Saylor, Esquire PA Supreme Court ID: 200139 5006 E. Trindle Road, Suite 100 Mechanicsburg, PA 17050 Telephone: (717) 591-1755 LAW OFFICES OF PETER J. RUSSO, P.C., : IN THE COURT OF COMMON PLEAS OF Plaintiff CUMBERLAND COUNTY, PENNSYLVANIA V. : CIVIL ACTION -LAW DONNA J. RHOADES, Defendant NO. 11-9528 CIVIL TERM NOTICE Pursuant to Rule 236 of the Supreme Court of Pennsylvania, you are hereby notified that a JUDGMI?NT has been entered against you in the above proceeding in the amount of $19,640.31 plus 18% interest per annum ($3,029.74 per annum or $8.30 per diem) from December 201, 2011 until paid in full including post judgment interest and that enclosed herewith is a copy of all documents filed in support of said judgment. If you have any questions concerning this notice, please call Peter J. Russo at 717-591-1755 ext 102. Prothonotary