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Home My WebLink About12-5273 CAPOZZI & ASSOCIATES, P.C., IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PE YLVAN Plaintiffs ' v. Docket No.: S 7 ~ ~ V~ ~ r.;, --i CYMBELINE DUMANDAN, ~ ~ ~ ~ • ~ c-~ z Defendant Confession of Judgment for Mone~" ~ ~ ~ r- r- ~ . .cry CONFESSION OF JUDGMENT WHERE ACTION ~ ~ COMMENCED BY COMPLAINT cr7 ~ Pursuant to the authority contained in the warrant of attorney, the copy of which is attach d to the Complaint filed in this action, I appear for the Defendant and confess judgment in favor of th Plaintiff and against Defendant as follows: a. Billed but unpaid legal services for February through $17,880.19 June 2012 b. Accumulated late char es ursuant to Fee A reement 694.16 Total Amount Due $18,574.35 *Plus interest from date of judgment until Defendant's obligation is satisfied, costs of collection, and court Costs. CAPOZZI ASS AT .C. Date: By: Brandon S. Williams, Esquire Attorney I.D. No.: 200713 P.O. Box 5866 Harrisburg, PA 17110 (717} 233-4101 Attorney for Plaintiff ~~UU~ Q a a7~ ~ a~ 6 ~ 1~~ (Yla~ le CAPOZZI & ASSOCIATES, P.C., IN THE COURT OF COMMON PLEAS OF i CUMBERLAND COUNTY, PE SYLVANIA Plaintiffs ~ , c ~ ~i J ' v. Docket No.: t--~_'. ~ - . -r,•, ; CYMBELINE DUMANDAN, ~ ~ ~ ~ - • c.,,, r- ~aa Defendant Confession of Judgment for Moneys` ~ --+c.~ c~ ~ c~~ COMPLAINT IN CONFESSION OF JUDGMENT FOR MONEY J''=~ ~ NOW COMES, Plaintiff, Capozzi & Associates, P.C., by and through its attorneys, to confess judgment against Defendant and seek legal relief necessary to obtain payment for legal services rendered and presented, but which remain unpaid. In support of the relief requested herein, Capozzi & Associates, P.C. hereby states the following: 1. Plaintiff, Capozzi & Associates, P.C. ("Capozzi"), is Pennsylvania Professional Corporation engaged in the practice of law, with its address at 1200 Camp Hill Bypass, Suite 205, Camp Hill, Cumberland County, Pennsylvania 1701 1. 2. Defendant, Cymbeline Dumandan, is an adult individual currently residing at 3004 Clubhouse Circle, Washington, Washington County, Pennsylvania 15301-5039. 3. In December 2011, Capozzi and Defendant started a professional relationship fo legal services related to the licensure of a Personal Care Home owned by Defendant to be provided to Defendant by Capozzi, as well as additional legal work. A true and correct copy o a Letter of Representation ("Fee Agreement"), dated December 21, 2011, is attached hereto an incorporated herein as Exhibit "A." 4. From the period December 31, 2011 through March 2012, Capozzi provided leg 1 services to Defendant in accordance with the Fee Agreement. 5. The section of the Fee Agreement entitled "Periodic Invoices" provides in part, "Invoices are due upon receipt and must be paid within thirty (30) days unless other acceptable 1 _ _ i arrangements are made in advance." 6. The section of the Fee Agreement entitled "Periodic Invoices" further provides i~ part, "should it be necessary for us to take legal action to collect any overdue invoices, you willll also be responsible for any and all costs of collection including, without limitation, reasonable attorneys fees and expenses." 7. The Fee Agreement authorizes the Confession of Judgment against Defendant fo money due and owing Capozzi upon Defendant's default under the terms of the Fee Agreement. Such provision states as follows: CONFESSION OF JUDGMENT. THE UNDERSIGNED HEREBY EMPOWERS ANY ATTORNEY OF ANY COURT OF RECORD WITHIN THE UNITED STATES OF AMERICA OR ELSEWHERE TO APPEAR FOR THE UNDERSIGNED AND, WITH OR WITHOUT COMPLAINT FILED, CONFESS JUDGMENT AGAINST TH UNDERSIGNED IN FAVOR OF ANY HOLDER HEREOF, UPON THE OCCURRENCE OF AN EVENT OF DEFAULT, AS HEREINABOVE DEFINED, FO THE UNPAID BALANCE OF UNDISPUTED LEGAL FEES, AS DESCRIBED ABOVE, TOGETHER WITH UNPAID INTEREST THEREON, COSTS OF SUIT AN ATTORNEY'S FEES, AS DESCRIBED ABOVE, ON WHICH JUDGMENT ONE OR MORE EXECUTIONS MAY ISSUE FORTHWITH. THE UNDERSIGNED HEREBY FOREVER WAIVES AND RELEASES ALL ERRORS IN SAID PROCEEDINGS, WAIVES STAY OF EXECUTION, AND WAIVES ALL EXEMPTIONS FROM LEV AND SALE OF ANY PROPERTY THAT NOW ARE OR HEREAFTER MAY BE APPLICABLE. NO SINGLE EXERCISE OF THE FOREGOING POWER TO CONFESS JUDGMENT SHALL BE DEEMED TO EXHAUST THE POWER, WHETHER OR NOT ANY SUCH EXERCISE SHALL BE HELD BY ANY COURT TO BE VALID, VOIDABLE OR VOID, BUT THE POWER SHALL CONTINUE UNDIMINISHED AND IT MAY BE EXERCISED FROM TIME TO TIME AS OFTE AS THE HOLDER HEREOF SHALL ELECT UNTIL SUCH TIME AS THE HOLDE SHALL HAVE RECEIVED PAYMENT IN FULL OF THE DEBT, INTEREST, ATTORNEY'S FEES AND COSTS. INTEREST ON THE OBLIGATION EVIDENCE HEREBY SHALL CONTINUE TO ACCRUE AT THE ABOVE-STATED RATE AFTER THE ENTRY OF JUDGMENT HEREON. THE UNDERSIGNED HEREBY WAIVES ITS RIGHTS TO NOTICE AND A HEARING CONCERNING THE VALIDITY OF THE HOLDER'S CLAIMS HEREUNDER AND AGREES AND CONSENTS TO JUDGMENT BEING ENTERED BY CONFESSION IN ACCORDANCE WITH THE TERMS HEREOF AND EXECUTION BEING LEVIED ON SUCH JUDGMENT AGAINST ANY AND ALL PROPERTY OF THE UNDERSIGNED, IN EACH CASE WITHOUT FIRST BEING GIVEN NOTICE AND THE OPPORTUNITY TO BE HEARD ON THE VALIDITY OF THE CLAIM OR 2 i CLAIMS UPON WHICH SUCH JUDGMENT IS ENTERED. 7. Defendant's obligation under the Fee Agreement has not been released, ~I transferred, or assigned by Capozzi or by Defendant. 8. Judgment has not been entered against Defendant in any jurisdiction. 9. This judgment is being entered in connection with a commercial transaction, and is not being entered by confession against a natural person in connection with a consumer credit transaction. 10. Defendant defaulted on her obligation under the Fee Agreement by failing to make payment when due. True and correct copies of the Invoices maintained by Capozzi regarding the legal services rendered to Defendant are attached hereto and incorporated herein a Exhibit "B". 11. To date, Defendant has not contacted Capozzi, and Defendant has not cured the default. A true and correct copy of the demand letter is attached hereto and incorporated herein as Exhibit "C". 12. The amounts due under the Fee Agreement, including unpaid interest and costs o collection as authorized by the Fee Agreement, aze as follows: a. Billed but unpaid legal services for February through $17,880.19 June 2012 b. Accumulated late chaz es ursuant to Fee A reement 694.16 Total Amount Due $18,574.35 *Plus interest from date of judgment until Defendant's obligation is satisfied, costs of collectio , and court costs. WHEREFORE, Capozzi confesses judgment against Defendant in the total sum of $18,574.35, plus post judgment interest, costs of collection, and court costs. 3 Respectfully submitted, I CAPOZZI & ASS CIATE , P C. ,r Date: ~ ` `l~ ' ~ 2 By: ran S. Williams, sq ' Attorney I.D. No.: 200713 P.O. Box 5866 Harrisburg, PA 17110 (717) 233-4101 Attorney for Plaintiff 4 _ ~ CAPOZZI & ASSOCIATES, P.C., IN THE COURT OF COMMON PLEAS OF a Pennsylvania Professional Corporation, :CUMBERLAND COUNTY, PENNSYLVANIA Plaintiff v. NO. CYMBELINE DUMANDEN Defendant :CONFESSION OF JUDGMENT FOR MONEY VERIFICATION I, Andrew R. Eisemann, Esquire, do hereby verify that the facts made in the foregoing Complaint in Confession of Judgment for Money are true and correct to the best of my knowledge, information and belief. I understand that any false statements therein are subject to the penalties contained in Title 18 of the Pennsylvania Consolidated Statutes Section 4904, relating to unsworn falsification to authorities. ~ i~ Date: Q _ ew m ,Esquire Managing r Capozzi & Associates, P.C. P.O. Box 5866 Harrisburg, PA 17110 (717) 233-4101 Attorneys for Plaintiff _ _ > Louis J. Capozzi, Jr., Esquire* 2933 North Front Stteet Daniel K. Natirboff, Esquire Q ~ Harrisburg, PA 17j1 10 Donald R. Reavey, Esquire Ca O gL ssoe~ates P,C. Telephone: (717) 233-4jf01 Craig I. Adler, Esquire tt4y>'"~1 'UJ ` Facsimile: (717) 233-4103 Andrew R. Eisemann. Esquire " www. ozziassociates. om Bruce G. Baron, Esquire , . Dawn L. Richards, Esquire ~ • K; • h Mid-Penn Abstract Com any Philip C. Warholio, Esquire ~ g Matthew A. Thomsen, Esquire 3- ~ ~ Charter Settlement Com • any Brandon S. Williams. Eso~ ~ Telephone: (717) 234- 89 Timothy Ziegler, Reimb. Analyst ~x Facsimile: (717) 234.1 70 Karen L. Fisher, Paralegal ~,;,_~,~.~t ~-:,w.~ Keyoung J. Gill, Paralegal Gwenn M. Keene, Paralegal * (Licensed in 1?A; NJ and MD) (Licensed in PA and NJ) December 21, 2011 Cymbeline Dumanden Resthaven Personal Care Homes 3004 Clubhouse Circle Washington, PA 15301 Re: Letter of Representation Our Matter Number: 706-03 Dear Ms. Dumanden: Our rules of professional ethics require us to set forth our fee arrangement in writing at the commencement of a professional relationship. This letter will describe the scope of services to be provided, the basis for determining the fees for those services and our general terms and conditions for billing. _Scone ~of Representation T'he legal services to be provided by Capozzi & Associates, P.C. to you and Resthaven Personal Care Homes are in connection with an appeal pending before the Department of Public Welfare's Bureau of Hearings and Appeals regarding licensure of one of your Personal Care Homes, appeals of licensure revocations received from the Department of Public Welfare for the other Personal Care Homes, and related regulatory issues regarding the licensure of personal care homes. In addition to the representation described above, you may from time to time ask us to perform additional legal work or undertake your representation in other matters. This letter constitutes your authorization for our Firm to perform the additional legal work or represent you in other matters. We customarily assign the responsibility of coordinating all aspects of our representation of a particular client to one attorney designated the "client coordinator". All work requests are channeled through that professional, who is then responsible for coordinating all work assignments. Of course, we encourage direct communication with the individual attorneys) working on a particular project. The client coordinator also is responsible for billing and responding to all questions relating to client fees and our representation. Louis J. Capozzi, Jr., Esquire will be performing the role of client coordinator for you. Basis for Determininta Fees Fees and Costs for this engagement will be billed to you on an hourly basis. E HIBIT _ ~ i Each attorney and professional staff member in our office prepares accurate and daily time records for each file on which they work. Hourly rates are determined periodically by our office, generally each year, and will vary according to the attorney who provides the services and the type of services requested. A schedule of current hourly rates in effect for our attorneys and professional staff members are enclosed with this letter. There is a minimum charge ofthree-tenths of an hour for phone communications, five-tenths of an hour for review of pleadings, correspondence, or other legal documents, and two hours for the preparation of pleadings and discovery requests and responses. Travel time is from portal to portal. Should the scope of services to be provided be changed or enlarged beyond those described in this letter, we reserve the right to amend or supplement this letter and the fees charged for the change or increase in the scope of services. We bring a team approach to our work product which is designed to provide economically efficient and effective representation by matching the hourly rates and experience of our attorneys to the professional requirements of a particular matter. Where appropriate, we attempt to utilize paralegals for more routine and repetitive matters with the goal of reducing the overall cost without sacrificing any quality in the product, Billin~Terms and Conditions Periodic Invoices. Our firm sends periodic invoices, usually monthly, detailing services rendered during the last billing period plus costs and fees which were advanced on your behalf, such as filing fees, outside reproduction, express mail fees, computerized research costs, any expert or consultant fees incurred on your behalf and travel expenses. There is no charge for in-house photocopying, telephone, telecopier (fax), and postage. ~ ~ Invoices are d.ue upon receipt and must be paid within thirty (30) days unless other acceptable arrangements are made in advance. We reserve the right to charge interest at 1 ''/s% per month for any invoices not paid within sixty (60) days of the date of the invoice. In addition, should it be necessary for us to take legal action to collect any overdue invoices, you will also be responsible for any and all costs of collection including, without limitation, reasonable attorneys fees and expenses. Such reasonable attorney's fees shall include time spent by attorneys employed by this Firm at their usual hourly rates. In addition, the Parties agree that venue, in the event legal action is necessary, is proper in Dauphin County. In connection with collection of a judgment, settlement or other disposition of a case on your behalf, the Firm is authorized to receive and endorse for deposit to our escrow account any checks, drafts, money orders or other forms of payment whether or not made payable to the Firm, and to disburse the proceeds, including attorney's fees and costs, in accordance with the terms of this letter. It is specifically agreed that the proceeds may be applied to any past due account even if the past due account has no relationship to the matter for which the proceeds were collected. Retainer. We will require a retainer for the services to be provided under this engagement in the amount of $5,000.00. We will hold this retainer for your account in our attorney trust account as security for the prompt payment of fees and charges billed to you. Upon the completion of this engagement and payment of all outstanding charges, the retainer will be returned to you, Credit Hold. Should any invoice for fees and costs remain unpaid for a period in excess of sixty (60) days, consistent with our responsibilities under the Rules of Professional Conduct, we reserve the right to temporarily cease work on this engagement until such overdue fees and costs are paid in full or, if our invoices remain unpaid despite efforts at collecting the same, we reserve the right to terminate the representation. I Disputed Billing: It is imperative, under the terms of this agreement, that you notify us in writing of any disputed billing within 15 days of your receipt of a bill. if we do not receive written notice within 15 days, the Parties agree that the amount of the bill can no longer be disputed and that said amount is due and owing. UCC Lien. For value received for undisputed legal services, as described above, and after default of this Fee Agreement in excess of 60 days, intending to be legally bound hereby, you hereby grant and assign and you agree that Capozzi & Associates, P.C. shall have, and there is hereby created in favor of Capozzi & Associates, P.C., a security interest in your tangible and intangible personal property, now or hereafter in existence, including the proceeds thereof and the increases, substitutions, replacements, addipons, and accessions thereto, hereinafter referred to collectively as the "Collateral," to secure that certain obligation of you owed to Capozzi & Associates, P.C. after the declaration of Default of this Fee Agreement. In addition to all rights and remedies given to Capozzi & Associates, P.C. by this Security Agreement, Capozzi & Associates, P.C. shall have all the rights and remedies of a secured party under the Pennsylvania Uniform Commercial Code. I authorize Capozzi & Associates, P.C. to file a financing statement covering the Collateral. Reproduction of Complete File. In the event that you request a complete copy of your file or your file in its entirety, it is understood that you will pay a copy charge of .10 cents per copy and all time spent by our staff and attorneys, at their usual hourly rates, for gathering the file and insuring the requcsted copy is complete. The above paragraph is applicable even if you request your original file because we must keep a copy for our records. CONFESSION OF JUDGMENT. THE UNDERSIGNED HEREBY EMPOWERS ANY ATTORNEY OF ANY COURT OF RECORD WITHIN THE UNITED STATES OF AMERICA,OR ELSEWHERE TO APPEAR FOR THE UNDERSIGNED AND, WITH OR WITHOUT COMPLAINT FILED, CONFESS JUDGMENT AGAINST THE UNDERSIGNED IN FAVOR OF ANY HOLDER HEREOF, UPON THE OCCURRENCE OF AN EVENT OF DEFAULT, AS HEREINABOVE DEFINED, FOR THE UNPAID BALANCE OF UNDISPUTED LEGAL FEES, AS DESCRIBED ABOVE, TOGETHER WITH UNPAID INTEREST THEREON, COSTS OF SUIT AND ATTORNEY'S FEES, AS DESCRIBED ABOVE, ON WHICH JUDGMENT ONE OR MORE EXECUTIONS MAY ISSUE FORTHWITH. THE UNDERSIGNED HEREBY FOREVER WAIVES AND RELEASES ALL ERRORS 1N SAID PROCEEDINGS, WAIVES STAY OF EXECUTION, AND WAIVES ALL EXEMPTIONS FROM LEVY AND SALE OF ANY PROPERTY THAT NOW ARE OR HEREAFTER MAY BE APPLICABLE. NO SINGLE EXERCISE OF THE FOREGOING POWER TO CONFESS JUDGMENT SHALL BE DEEMED TO EXHAUST THE POWER, WHETHER OR NOT ANY SUCH EXERCISE SHALL BEHELD BY ANY COURT TO BE VALID, VOIDABLE OR VOID, BUT THE POWER SHALL CONTINUE UNDIMINISHED AND IT MAY BE EXERCISED FROM TIME TO TIME AS OFTEN AS THE HOLDER HEREOF SHALL ELECT UNTIL SUCH TIME AS THE HOLDER SHALL HAVE RECEIVED PAYMENT IN FULL OF THE DEBT, INTEREST, ATTORNEY'S FEES AND COSTS. INTEREST ON THE OBLIGATION EVIDENCED HEREBY SHALL CONTINUE TO ACCRUE AT THE ABOVE-STATED RATE AFTER THE ENTRY OF JUDGMENT HEREON. THE UNDERSIGNED HEREBY WANES ITS RIGHTS TO NOTICE AND A HEARING CONCERNING THE VALIDITY OF THE HOLDER'S CLAIMS HEREUNDER AND AGREES AND CONSENTS TO JUDGMENT BEING ENTERED BY CONFESSION 1N ACCORDANCE WITH THE TERMS HEREOF AND EXECUTION BEING LEVIED ON SUCH JUDGMENT AGAINST ANY AND ALL PROPERTY OF THE UNDERSIGNED, IN EACH CASE WITHOUT FIRST BEING GIVEN NOTICE AND THE OPPORTUNITY TO BE HEARD ON THE VALIDITY OF THE CLAIM OR CLAIMS UPON WHICH SUCH NDGMENT IS ENTERED. i Attorney's Lien. As provided by Pennsylvania law, we will retain an attorney's lien for payment on ~ all files and other documents and materials collected or generated by this firm in the course of this representation, and reserve the right to retain those files and other materials until paid, in full. If, at any time during the course of our professional relationship, you have any questions regarding our services or our fees, please raise them with me. We strongly encourage open and frank discussions about our work product and fees. We find that good communication enhances our professional relationship with our clients and facilitates our ability to address effectively and economically the legal challenges facing them. If these terms are acceptable to you, please sign this letter and return it to us in the enclosed self- addressed, stamped envelope. The enclosed copy of this letter is for your records. We thank you for the opportunity to continue to perform legal services for you, and we look forward to continuing to work with you. Si rely, ,s''" Louis .T. apozzi, Jr., Es 're /klf Enclosure Accepted and Agreed to: By: C berline Dumandan Owner Resthaven Personal Care Homes Date: ~ 3 ~ ~ ~ ~ i CAPOZZI & ASSOCIATES, P. C. Current Hourly Rates for Attorneys and Professional Staff Members Louis J: Capozzi, Jr. Esquire $250 Daniel K. Natirboff, Esquire $250 Donald R. Reavey, Esquire $250 Craig I. Adler, Esquire $250 Bruce G. Baron, Esquire $250 Andrew R. Eisemann, Esquire $200 Andrew R. Eisemann, Esquire $175 Collection Matters Michael M. Jerominski, Esquire $150 Dawn L. Richards, Esquire $150 Timothy T. Ziegler. Reimbursement Analyst $220 Law Clerks $90 Paralegals $90 _ i CapozZi ~'c Ao Bocsa 6es, P. C. Harrisburg, PA 17110 Ph:{717) 233-4101 Fax:(717) 233-4103 EIN 23-291182 Cymbeline Dumandan, Owner and Administrator February 17, 201 Duman LLC d/b/a Resthaven Personal Care Homes 3004 Clubhouse Circle Washington, PA 15301 File 1196-1 Inv 6289 RE: PCH License Revocation and Non-Renewal DATE DESCRIPTION HOURS AMOUNT TIMEKE ER Jan-03-12 Communicate with Karen Fisher re preparation 1.00 250.00 BG of witness and exhibit lists for hearings; review of same Draft Witness and exhibits Iists; prepare set of 3.20 288.00 K exhibits Jan-04-12 Preparation of Exhibit and Witness lists for 4.00 1,000.00 BG Hearing; telephone call from DPW Counsel re same and Settlement analysis; communicate with Cymbeline Dumandan re same; office conference with Karen Fisher re transmittal of materials for the Hearings; review of exhibits and research for Hearing; a-mails to DPW Counsel re Settlement proposal; draft revised Settlement proposal; communicate with DPW Counsel re possible continuance of January 10 Hearing Prepare additional exhibits for submittal to 1.60 144.00 F BHA with exhibit list; file and serve exhibit and witness lists Jan-OS-12 Communicate with Cymbeline Dumandan re 3.00 750.00 B B status of continuance of Hearing and possible Settlement; research on recent Court decisions related to case; communicate with DPW Counsel re Settlement and Hearing preparation issues; communicate with Cymbeline E HIBIT I _ _ uavvaw rr. v~.uiv a arc s. a cvtuaay a i, vat. Dumandan re same and possible sale of the facilities, with copy to Craig Adler as to same; research on potential buyer of facility File Praecipe to Discontinue and Cancel 0.10 9.00 KF Hearing with Bureau of Hearings and Appeals for Docket # 034-11-0033 Jan-06-12 Telephone call to Pepp regarding "Master" 0.50 100.00 DLR services Communicate with DPWBHA re cancellation 2.50 625.00 BGB of 1/10/2012 Hearing and back up date for 1 /9/2012 Hearing if not completed on that date; communicate with client re same; communicate with DPW Counsel re possible Stay of litigation pending transitions to new operator; communicate with Dawn Richards re contact with Pepp, Inc re becoming a Master for the facilities; communicate with client re preparing for Hearing and status of cases and DPW position on Settlement discussions; telephone call from potential buyer from Bassey Renshaw Nkereuwen of Baken, LLC re waiver of conflict for sale paperwork; a-mail to same re same with copy to Craig Adler and Karen Fisher; communicate with client re status of cases and prepare for Hearing; a-mail and voicemail to PEPP, Inc re becoming Master Prepare exhibits for Hearing 3.20 288.00 KF Jan-07-12 Communicate with client re materials for 3.00 750.00 BGB Hearing and prepare for Hearing; research for Hearing; a-mails to client, with copies to Dawn Richards and Karen Fisher re issues for Hearing; made reservations for overnight stay in Cranberry Jan-08-12 Travel to Washington, PA for meeting with 9.00 2,250.00 BGB client to prepare for Hearing in Pittsburgh and explore Settlement and sale of facility; travel from Washington, PA to Cranberry for overnight stay; prepare for Hearing and new exhibits; prepare amended witness and exhibit lists for Hearing; communicate with client re additional witness (administrator); a-mail to DPW Counsel with copies of amended witness I 11IVV1GG it., V407V 1 0.tj'G J 1'GVl µ0.l 1 1, GV1G and exhibit lists, with copy to client and Karen Fisher Jan-09-12 Hearing in Pittsburgh at Bureau of Hearings 11.00 2,750.00 BGB and Appeals; office conference with DPW and client re Settlement; office conference with client re prepare for hearing, settlement and sale; travel from Cranberry to Pittsburgh for hearing and from Pittsburgh home after hearing; travel home; a-mail to DPW Counsel re status of master; telephone call from Sherry Hill at PEPP, Inc. re master Jan- I 0-12 Office conference with Bruce Baron re 0.60 120.00 DLR Hearing E-mail from Bassey Henshaw on status of sale; 1.00 250.00 BGB communicate with Cybeline Dumandan re same and status of appeal and analysis of issues and problems Jan- I 1-12 Review a-mail from Bruce Baron re appeal 0.60 120.00 DLR and potential sale Jan-12-12 Communicate with Karen Fisher re need for 0.10 25.00 BGB conflict check to represent Bassey Henshaw in sale of facilities Draft Waiver of Conflict on Interest 0.10 9.00 KF Jan-13-12 Telephone call from PEPP, Inc re work at 0.60 150.00 BGB facility as manager and consulting on possible consolidation of licenses; communicate with DPW Counsel on status of matter and possible avenues to Settlement, with copy to client Jan-17-12 Telephone call to and from PEPP re on-site 0.20 40.00 DLR meeting E-mail from cliient with answers to questions 0.30 75.00 BGB and current status of facilities and review of other licensing ordinances in area; communicate with Bassey Henshaw re status of sale Jan-18-12 Telephone call to and from Sherry Hill at 0.80 160.00 DLR PEPP to schedule on-site meeting; a-mail to and from Bruce Baron re same Communicate with Cymbeline Dumandan re 0.30 75.00 BGB working on possible sale; communicate with _ _ _ uivuicc rr, vao7u rage 't 1'cviuaty i i, cuic Dawn Richards re follow up with PEPP, Inc re same; communicate with Bassey Renshaw re setting up phone conference for same i Jan-19-12 Telephone call from Sherry Hill regarding 0.50 100.00 DLR ~ Master Services and schedule Communicate with Dawn Richards re setting 1.00 250.00 BGB up meeting at facility with PEPP, Inc; a-mail to Bassey Renshaw re follow up on sale; communicate with Cymbaline Dumandan re timing for meeting with PEPP consultants; e-mail to Dawn Richards re information required on DPW sq. footage issues to consolidate the licenses Jan-20-12 Communicate with Bruce Baron re PEPP 0.50 100.00 DLR meeting; DPW regulations and building license Telephone call from Bassey Renshaw re 2.00 500.00 BGB Lease/purchase of facility and timing of same, plus getting information for possible appraisal and about PEPP mle in transition and consolidation of the licenses; a-mail to Craig Adler to get prices for same; voicemail to John Parry at PEPP re site visit and consultation on license consolidation; telephone call from John Parry re same and change in DPW policy documents on consolidation requirements; communicate with client on SSI income issue; e-mail to Bassey Renshaw and Craig Adler with form of application for single license and notes on issue Jan-21-12 Strategy and status conference with Bruce 0.10 21.00 ARE Baron re consolidation or sale of facilities and related issues . Communicate with client re SSI impact of 0.30 75.00 BGB residents getting married Jan-23-12 Office conference with Bruce Baron re Master 0.50 100.00 DLR Services and licensing options Telephone call from PEPP Unlimited re costs 2.00 500.00 BGB for consulting services; a-mails to client re same and next steps; communicate with Tim Ziegler re analysis of financial issues; telephone call from PEPP Unlimited (Sherry I~~ ~ iiivuiuc+r. u~o7u ra~,c u rcu?uaiy i i, rv~~ Hill) re planning for future and costs of having a Master at facilities; review DPW memo for Motion to Preclude evidence; begin drafting response to same Jan-24-12 Complete response to ALR Motion to exclude 3.50 875.00 BGB evidence; office conference with Karen Fisher re filing same; update draft Stipulation of Settlement; a-mail to client re same; a-mail to DPW Counsel with copy of response to Motion and note about coming Settlement, with copy to client; communicate with client re analysis of status and next steps in case Review licensure issues and possibility of third 0.50 137.50 CIA party transfer; conference with Bruce Baron File Memorandum of Law in Opposition to 0.20 18.00 KF ARL Motion to Preclude Evidence Jan-25-12 Office conference with Craig Adler re 1.50 375.00 BGB Mortgage issues; a-mail to client to contact Craig Adler re same; telephone call from Bassey Henshaw re Lease/Purchase Agreement preparation; communicate with client re same; office conference with Christina Mahady and telephone call from Dan Natirboff re status of retainer and coverage of costs and their conversations with client re same; a-mail to Craig Adler re status in Lease/Purchase terms information; a-mail to client re need to follow up with her on next steps to Lease/Purchase Jan-26-12 Review of/draft a-mails re possible sale 0.50 137.50 LJC Strategy conference with Craig Adler re 0.30 63.00 ARE confessed Judgment in 2 counties; receipt and review court documents Office conference with Craig Adler re status of 0.30 75.00 BGB work on possible sale and status of possible additional buyer(s) Jan-27-12 Communicate with client re terms for 0.50 125.00 BGB lease/purchase and status of other options; e-mail to Craig Adler re same to draf3 lease/purchase template Jan-31-12 Communicate with Cymbeline Dumandan re 0.30 75.00 BGB status; with copy to Craig Adler; a-mail to _ i 111VVlVV Tf. V{.V/V 1Nbv v -v~wMJ Bassey Henshaw re status of her license and permission to use her name in settlement discussions ~I Totals 61.20 $13,755.00 DISBURSEMENTS Disbursements Receipts Jan-31-12 1 /08/ 12-1 /09/ 12 Travel Expenses - BGB 43 7.19 Research -January 49.90 Totals $487.09 $0.00 Total Fees & Disbursements S 14,242.09 Due Date: 30 Days From Date of Invoice. Any china or disputes regaMing this Invoice or any items thereon must be submitted in writing within 15 days of receipt. Please put Invoice Number on your check, Thank You Capo.Z.zi Ao Bocsa 6es, P. C. Harrisburg, PA 17110 Ph: (717) 233-4101 Fax:(717) 233-4103 E1N 23-291182 Cymbeline Dumandan, Owner and Administrator March 13, 201 Duman LLC d/b/a Resthaven Personal Care Homes 3004 Clubhouse Circle Washington, PA 15301 File 175-1 Inv 6340 RE: Lease/Purchase of Resthaven Personal Care Homes DATE DESCRIPTION HOURS AMOUNT TIMEKEE ER Feb-07-12 Contact counsel for bank, report to client, 1.00 275.00 CI review lease Feb-10-12 Review of/draft a-mails re sale issues ~ 0.50 137.50 LJ Feb-11-12 Review of/draft a-mails from and to Bruce 0.50 137.50 LJ Baron re regulatory issue Feb-12-12 Review of/draft a-mails re status 0.30 82.50 LJ Feb-21-12 Review of/draft a-mails re status/next steps 0.50 137.50 LJ Feb-27-12 Review of/draft a-mails re status of 0.80 220.00 LJ matter/lease provisions Totals 3.60 $990.00 Total Fees & Disbursements 5990. Due Date: 30 Days From Date of Invoice. Any claims or disputes regarding this invoice or any items the on must be submitted in writing within 15 days of receipt. Please put Invoice Number on your check, Thank You _ i CapozZi ~ Ao s~ocsa 6es, P. C. Harrisburg, PA 17110 Fax: 717 233-4103 _ II Ph: (717) 233-4101 ( ) EIN 23 2911821 Cymbeline Dumandan, Owner and Administrator March 13, 201 Duman LLC d/b!a Resthaven Personal Care Homes 3004 Clubhouse Circle Washington, PA 15301 File 1196-11 Inv .6340 RE: PCH License Revocation and Non-Renewal DATE DESCRIPTION HOURS AMOUNT TIMEKE PER Feb-O1-12 Communicate with Cymbaline Dumandan re 0.60 150.00 BG dealing with police report of attack on staff by resident; telephone call from same re DPW survey follow up on same and next steps, and status of preparation of financials related to lease; review of police report Feb-03-12 Review of Complaint in Confession of 0.50 87.50 PC Judgment and attached documents for possible further proceeding Communicate with DPW Counsel re status of 0.30 75.00 BG Settlement; communicate with client re same; e-mail to Bassey Henshaw re status of Agreement for lease; a-mail to Craig Adler re preparation of same Feb-04-12 Telephone call from Cymbaline Dumandan re 0.50 125.00 B new problem with documents at the facilities; research on same Feb-OS-12 Communicate with client re documents issues 1.00 250.00 B ad next steps in moving to Settlement and transfer of licenses; telephone call from client re same; a-mail to Bassey Henshaw re status Feb-06-12 Review of a-mail from Craig Adler re lease; 0.20 35.00 PC office conference with Paul Van Fleet re exhibits for Mortgage foreclosure action _ _ _ i aaa • viv~r i~ . V?wc. 1 ugb L 1V16L1 b11 1 ,J, LV 1 L Lease, draft of Duman LLC to Baken Ent. 1.60 280.00 PVF Comunicate with client re documents to draft 4.00 1,000.00 BGB Lease; communicate with Craig Adler and Paul Van Fleet re same; communicate with client re staffing facility; telephone calls and a-mails to PEPP Unlimited re same; review Order of Department of Welfare Motion from Hearing; communicate with client re closure of part of facility; fraft forms of Notice to Department of Welfare re same; a-mails to and from client re same; a-mails to and from Department of Welfare re same and continuance of Hearing; e-mails to and from Paul Van Fleet re review and comments on draft form of Lease Feb-07-12 Review a-mail to and from Bruce Baron and 0.20 40.00 DLR DPW Redraft lease for Rest Haven; review of lease 1.00 175.00 PVF for Rest Haven Telephone call from clients re scheduling 4.00 1,000.00 BGB Hearing for Wednesday; communicate with DPW Counsel re continuance of same; draft letter to Bureau of Hearings and Appeals to withdraw appeal and cancel Hearing; a-mail to client re same; telephone call from client re same; a-mail to DPW Counsel and client copy of same; communicate with Key Gill re transmittal of same to Bureau of Hearings and Appeals; communicate with Paul Van Fleet re draft lease; review and revise same; a-mail to Bassey Renshaw re status of her interest in leasing and timing of such; telephone call from BHA confirming receipt of same; telephone call from client re status of discussions with DPW about recent violations and lease discussions with Bassey Renshaw Feb-08-12 Telephone call from Sherry Hill from PEPP 1.50 375.00 BGB Unlimited about supplying Administrator Services during transitions; a-mail to Cymbeline Dumandan re same; revised draft lease for transition; a-mail to Paul Van Fleet and Craig Adler re same; revise draft Stipulation of Settlement Feb-10-12 Review of/draft a-mails re sale issues 0.50 137.50 LJC invuit,c tr: o~~rv~ ragC ~ tviai~i, , ~.v ~ ~ E-mail to Bruce Baron re Rest Haven 0.40 70.00 1'VF Communicate with Cymbaline Duman re 1.50 375.00 BGB status and draft Lease; telephone call from same re same; telephone call from Bassey Renshaw re same; office conference re Paul Van Fleet re needed changes to draft Lease; communicate with Bassey Renshaw re Administrative Assistance from PEPP; copies of all to Craig and Karen Fisher Feb-13-12 E-mail from client with map of facility for use 1.00 250.00 BGB in draft exceptions in lease, with copy to Paul Van Fleet, Craig Adler, and Maya Druker for same; communicate with Louis Capozzi Jr. re status of Waiver of Conflict and office conference with Christina Mahady re need for additional retainer; a-mail to Bassey Renshaw re status of licensure activities, Fee Agreement and Waiver of Conflict, with copy to client; update draft Stipulation of Settlement Feb-14-12 Office conference with Paul Van Fleet re status 0.30 75.00 BGB of revised lease; communicate with Cymbeline Dumandan re need for fax of layout of excepted buildings, with copy to Paul Van Fleet Feb-17-12 Redraft lease in accordance with map provided 0.20 35.00 PVF by Bruce Baron Telephone call from Cymbeline Dumandan re 0.50 125.00 BGB status of lease discussions with Baken Enterprises, Inc. and re compliance issues at PCHS pending transfer; office conference with Paul Van Fleet re status of Lease; communicate with Louis Capozzi Jr. re same Feb-20-12 Review of/draft a-mails re status of 0.30 82.50 LJC sale/licensure E-mail to Bassey Renshaw re status of Waiver 0.30 75.00 BGB of Conflict form and Fee Agreement; fax from Duman, LLC with signed Waiver of Conflict .from them; office conference with Christina Mahady re status Feb-21-12 E-mails from Bassey Renshaw re status of new 0.50 125.00 BGB operator application; telephone call from Cymbeline Dumandan re next steps and utvwc~ n: w~vc rr~c ~r lvtat~ii i~, .:vtc payment an~angements; copies of a-mails and status report on matters to Louis Capozzi Jr., Craig Adler and Christina Mahady; a-mail from DPW RTKL Office with information on DPW policies re provisional licenses and ~!I renewal ~ Totals 20.90 $4,942.50 DISBURSEMENTS Disbursements Receipts Feb-03-12 01/04/12 -Federal Express Charge -Delivery 49.17 to Bureau of Hearings and Appeals Pkg#2 01/04/12 -Federal Express Charge -Delivery 49.11 to Office of General Counsel 01/04/12 -Federal Express Charge -Delivery 49.11 to DPW 01/04/12 -Federal Express Charge -Delivery 49.17 to Bureau of Hearings and Appeals Pkg#1 Feb-06-12 Courier 15.00 Feb-29-12 Research 7.28 1/24/12 -Federal Express Charge 32.26 Totals $251.10 $0.00 Total Fees & Disbursements $5,193.60 Due Date: 30 Days From Date of Invoice. Any claims or disputes regarding the invoice or any items thereon must be submftted fn writing within 15 days of receipt. Please put Invoice Number on your check, Thank You _ _ _ _ _ i CapozZi ~ Ao Bocsa 6es, P. C. Hamsburg, PA i 7110 i Ph: (717) 233-4101 Fax:(717) 233-4103 EIN 23-2911821 Cymbeline Dumandan, Owner and Administrator April 18, 2012 Duman LLC d/b/a Resthaven Personal Care Homes 3004 Clubhouse Circle Washington, PA 15301 File 175-1 Inv 6389 RE: Lease/Purchase of Resthaven Personal Care Homes DATE DESCRIPTION HOURS AMOUNT TIMEKEEI~ER Mar-16-12 Redraft Lease Agreement with option to 0.40 70.00 PVI~ purchase Review changes to Lease, draft changes; 1.00 275.00 CIA correspond with client Mar-19-12 Correspondence with Bank Counsel re 0.60 165.00 CI~. forbearance Mar-20-12 Communicate with Bassey/Lease review 0.30 52.50 PV}~ Mar-21-12 Review lease changes with Paul Van Fleet; 0.60 165.00 CI~? correspondence with client Mar-23-12 Redraft Lease; communicate with Cymbeline 0.50 87.50 PV)~ i Mar-25-12 Communicate with Bank Counsel re status of 0.50 137.50 CIl~ forebaerance Totals 3.90 $952.50 i CapozZi ~ Ao Bocsa 6es, P. C. Harrisburg, PA 17110 Ph: (717) 233-4101 Fax:(717) 233-4103 EIN 23-291182 Cymbeline Dumandan, Owner and Administrator April 18, 201 Duman LLC d/b/a Resthaven Personal Care Homes 3004 Clubhouse Circle Washington, PA 15301 File 1196-1 Inv 6389 RE: PCH License Revocation and Non-Renewal DATE DESCRIPTION HOURS AMOUNT TIMEKEE ER Mar-01-12 Telephone call from Cymbaline Dumandan re 0.20 50.00 BG revisions to lease and possible change in approach; office conference with Craig Adler re same; a-mail from Basset' Henshaw re status and possible collapse of sale Mar-21-12 Redraft lease; communicate with Basset' and 0.40 70.00 PV Cymbeline Mar-23-12 Voicemail from Cymbaline Dumandan re cease 1.20 300.00 BG and desist order from Department of Welfare; communicate with DPW Counsel re same, with copies to client; communicate with client re copy of cease and desist document received from DPW and status of resolution of appeals; communicate with client and Basset' Renshaw re status of application for new license, with copy to Craig Adler; a-mail from client with copy of DPW letter; communicate with client re living arrangements for 3 residents pending new licensure Mar-31-12 Review procedural status and actions re 0.10 21.00 A consolidation or sale of facilities and related issues Totals ] .90 $441.00 _ _ _ r invoice o~ ay i rGKG G r?}.nii i u, cv a Total Fees & Disbursements $441.00 Due Date: 30 Days From Date of Invoice. Any claims or disputes regarding this invoice or any items thereon must be submitted in writing within 15 days of receipt. Please put Invoice Number on your check, Thank You - Capozzi ~ Ao Bocsat~es, P. C. Harrisburg, PA 17110 i Ph: (717) 233-4101 Fax:(717) 233-4103 EIN 23-2911821 Cymbeline Dumandan, Owner and Administrator May 18, 2012 Duman LLC d/b/a Resthaven Personal Care Homes 3004 Clubhouse Circle Washington, PA 15301 File 1196-11 Inv 6449 RE: PCH License Revocation and Non-Renewal DATE DESCRIPTION HOURS AMOUNT TIMEKEE ER Apr-03-12 Telephone call from Cymbaline Dumandan re 1.00 250.00 BG options to settle appeals with Department of Welfare if Baken lease deal falls through; office conference with Craig Adler re same; communicate with Tara Pride re status of new licensee; communicate with DPW Counsel re same; with copy of DPW Counsel response to client and Craig Adler Apr-17-12 Communicate with DPW Counsel re status of 0.30 75.00 BG new application, with copy to client; response to Rule To Show Cause on consolidation of Appeals Apr-19-12 Communicate with DPW Counsel re new 1.00 250.00 BG orders re open facilities; telephone call from JoJo Dumandan re same; faxes from client re same; oi~ice conference with Craig Adler re status of account and transfer issues; telephone call from Cymbeline Dumandan re same; communicate with Cymbeline Dumandan re same and that we cannot take on the new matter given payment status Totals 2.30 $575.00 DISBURSEMENTS Disbursements Receip i titvutVC rr. v~rY~v ragc a ,v,ay ,o, s:v,c ,1pr-17-12 Courier Charge 15.00 Totals $15.00 $0.00 Tital Fees h >is~uroements 5590.N Due Date: 30 Days From Date of invoice. Any claims or disputes regarding thin invoice or any items thereon must be submitted in writing within 16 days of receipt. Please put Invoice Number on your check, Thank You _ _ _ ~ _ CapoZ~i ~c Ao Bocia 6es, P. C. Harrisburg, PA 17110 j Ph: (717) 233-4101 Fax:(717) 233-4103 EIN 23-291182 Cymbeline Dumandan, Owner and Administrator June 13, 201 Duman LLC dJb/a Resthaven Personal Care Homes 3004 Clubhouse Circle Washington, PA 15301 File 1196-11 Inv 65041 RE: PCH License Revocation and Non-Renewal DATE DESCRIPTION HOURS AMOUNT TIMEKE PER May-09-12 Communicate with DPW Counsel re status of 0.30 75.00 BG Appeals; communicate with client re same May-10-12 Communicate with DPW Counsel re status of 0.10 25.00 BG new owner's application with copy to client May-18-12 Review Pre-Hearing Conference Order in 0.10 25.00 BG license appeals; communicate with DPW Counsel re status of new licensee May-31-12 Communicate with DPW Counsel re status of O.10 25.00 BG new license application {denied), with copy to C. Dumandan and Craig Adler Totals ~ 0.60 $150.00 Total Fees & Disbursements 5150. 0 Due Date: 30 Days From Date of Invoice. My claims or deputes regarding this invoice or any items the on must be submitted in writing within 15 days of receipt. Please put Invoice Number on your check, Thank You ( Receivables by Client To Jul/10/2012 liaat No. i Naar Iatso I______________________ Omtatandiaq _______---------------I ua N: Haar 6: Natter No. Last R~o~ipt Inv N 11R Data Dates, 1Nwuat Col. Lxs 8illad 30 60 90 > 90 Total Trust Sal 162 Dumas LLC d/b/a Raathawa larsoaal Gra 8 DOE 16-664-1143 175-12 Lease/Purchase of Resthaven personal Care 6 901 Mar/13/2012 XXX 990.00 990.00 990.00 0.00 /63896 Apr/18/2012 XXX 952.50 952,50 952.50 latter Total ~6b-~66~.3'6 436"'66-'T~:36 1196-11 PCH Lic tion and Non-Renewal 62890 Feb/17/2012 Apr/23/2012 Y 5000.00 .XXX 19242.09 9242.09 9242.09 0.00 63402 Mar/13/2012 XXX 5193.60 5193.60 5193.60 63897 Apr/18/2012 ~ XXX 441.00 441.00 441.00 69990 May/18/2012 XXX 590.00 590.00 590.00 65041 Jun/13/2012 XXX 150.00 150..00 150.00 tatter Total ~--34~66~7I.a6~d~-33dI3-di li~at Total -336-5~0~'6-SJ'97~6~13i3S31i~I7~Sf.ii 'otal : i36~~da133~'4-3II ~'-7,3I33-S~~Tf Summary by Collecting Lawyer 30 60 90 > 90 Total XXX - Anonymous 150.00 590.00 1393.50 15425.69 17559.19 Total: -3~dII ~34~3II -13735.3 ~7S35.T3 Hrm Total X66 -3636 -33~6II -I75S4-1~ EPORT SELECTIONS - Receivables by Client payout Template Default .dvanced Search Filter None ~fli ~ i equested by ADMIN W ~ `(/I~ 'inished Tuesday, July 10, 2012 at 02:58:17 PM 'er 10.0 SPS NF3 (10.05.20101203) ratters All aients 3162 Llri lajor Clients All /~Q 0 ,esponaible Lawyer All :lient Intro Lawyer All latter Intro Lawyer All .ssigned Lawyer All 'ype of Law All ;elect From Active, Inactive, Archived Matters latteza Sort by Default lew Page for Each Lawyer No :ollecting Lawyer All .how Balances As of End Date Yes receipts Up To 7/10/2012 +qe From Jul/10/2012 +ging Category-1 30 +ging Category-2 60 +ging Category-3 90 'irm Totals Only No fatter Totals No :lient Totals Only No ~/R balance. is greater than or equal to (5) 0.00 Invoice is outstanding for at least (days) 0 Chow all invoices for included matters No provision for Write-off Exclude WO Prov :ollecting Lawyer Yes summarize by Reap. Lawyer No summarize by Client Intz. Lawyez No summarize by Matter Intr. Lawyer No _ _ _ ~ Louis J. Capozzi, Jr., Esquire* 1200 Camp Hill (Bypass Daniel K. Natirboff, Esquire Ca O 1 8L ssociates P.C. Camp Hill, PA 17011 Donald R. Reavey, Esquire Craig I. Adler, Esquire ttOl'Y! t LQW MallingAddress; P.O. Bpx 5866 Andrew R, Eisemann. Esquire Harrisburg, PA 17110 Bruce G. Baron, Esquire Dawn L. Richards, Esquire Telephone: (717) 2 3-4101 Matthew A. Thomsen, Esquire Facsimile: (717) 2 3-4103 Brandon S. Williams, Esquire Paul R, y~Fjget. Esquire Timothy Ziegler, Sr. Reimb. Analyst July 10, 2012 Erin E. Motter, Jr. Reimb Analyst Mid-Penn Abstract C mpany Karen L. Fisher, Paralegal Charter Settlement C mpany Keyoung J. Gill, Paralegal Telephone: (717) 2 4-3289 Gwenn M. Keene, Paralegal Facsimile: (717) 2 4-1670 '(Licensed in PA, NJ and MD) *'(Licensed in PA and NJ) Cymbeline Y. Dumandan 3004 Clubhouse Circle Washington, PA 15301-5039 Re: Rest Haven Personal Care Home Delinquent Account Balance: $17,880.19, plus costs of collection Our Matter No.: 518-12 Dear Ms. Dumandan: As you are aware, our law firm represented Rest Haven Personal Care Home in a number of legal matters. Please note that there is an outstanding balance due and owing in the amount of $17,880.19, for legal services rendered, and that you are responsible for the payment of the invoices. Enclosed please find copies of the unpaid invoices regarding the above-referenced delinquent balance. Please be advised that if this obligation is not paid within ten (10) days of the date of this letter, we will have no alternative but to institute legal proceedings against you and Rest Haven without further notice, for the full amount owed, plus legal fees and court costs. When suit is filed it may give rise to the following consequences: 1. To defend this suit, it may be necessary for you to appear in court. 2. If a judgment is obtained against you, you may be required to pay court costs, attorney's fees, and interest in addition to the money you now owe. 3. If a judgment is obtained against you, a writ of execution may be issued ordering the seizure and sale of your personal or real property. 4. As a matter of public record, a judgment will negatively affect your credit rating. Please make arrangements to pay the outstanding amount owed of $17,880.19, within 10 days from the date of this letter, to Capozzi & Associates, P.C., 2933 North Front Street, Harrisburg, PA 17110. HIBIT _ We expect that you will honor the terms of your Agreement with our law firm and remit payment. This action is being taken because, despite previous requests for payment, you have i failed to remit payment for the legal services provided. I trust that you will give this Notice your immediate attention. Very y yours, Brandon S. Williams ~Jg Enclosures THIS LETTER AND ANY FUTURE LETTERS FROM OUR FIRM ARE AN ATTEMPT TO COLLECT A DEBT, AND ANY INFORMATION OBTAINED WILL BE USED FOR THAT PURPOSE. 2 _ _ _ _ i CAPOZZI & ASSOCIATES, P.C., IN THE COURT OF COMMON PLEAS OF ~ CUMBERLAND COUNTY, PENNSYLVANI~4 Plaintiffs d~-' 7 ~ . . v. Docket No.: ' CYMBELINE DUMANDAN, Defendant Confession of Judgment for Money -yy, 9... , NOTICE UNDER PA.R.C.P RULE 2958.1 ~ -~C 7' w OF JUDGMENT AND EXECUTION THEREON NOTICE OF DEFENDANT'S RIGHTS ~ ° ~ i Z c~ TO: Cymbeline Dumandan, Defendant: ~ -c. A judgment in the amount of $18,574.35, plus post judgment interest, attorneys' fees and costs of suit, has been entered against you and in favor of the Plaintiff without any prior notice or hearing based on a Confession of Judgment contained in a written agreement or other paper allegedly signed by you. The Sheriff may take your money or other property to pay the judgment at any time after thirty (30) days after the date on which this notice is served on you. You may have legal rights to defeat the judgment or to prevent your money or property from being taken. YOU MUST FILE A PETITION SEEKING RELIEF FROM THE JUDGMENT AND PRESENT IT TO A JUDGE WITHIN THIRTY (30) DAYS AFTER THE DATE ON WHICH THIS NOTICE IS SERVED ON YOU OR YOU MAY LOSE YOUR RIGHTS. YOU SHOULD TAKE THIS PAPER TO YOUR LAWYER AT ONCE. IF YOU DO NOT HAVE A LAWYER OR CANNOT AFFORD ONE, GO TO OR TELEPHONE THE OFFICE SET FORTH BELOW TO FIND OUT WHERE YOU CAN GET LEGAL HELP: CUMBERLAND COUNTY BAR ASSOCIATION 32 SOUTH BEDFORD STREET CARLISLE, PA 17013 1-800-990-9108 717-249-3 .r' ~ i Date: C.7 ' r~~ Z ~ Brandon S. Williams, Esquire Attorney I.D. No.: 200713 Capozzi & Associates, P.C. P.O. Box 5866 Harrisburg, PA 17110 (717) 233-4101 Attorneys for Plaintiff _ _ _ _ _ _ _ -T CAPOZZI & ASSOCIATES, P.C., IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA Plaintiffs ~ ~ _ ~ ~ _ ~ v. Docket No.: ` CYMBELINE DUMANDAN, ~ ~ ~ ~ Defendant Confession of Judgment for Money w ~o -o Q= ~n ~ CERTIFICATE OF RESIDENCE UNDER RULE 2951 ~ ~ N ° r-~, ~ ~ I do hereby certify that the precise residence and complete post office address of the Plaintiff, Capozzi & Associates, P.C., is 1200 Camp Hill Bypass, Suite 205, Camp Hill, Cumberland County, Pennsylvania 17011 -Mailing Address: P.O. Box 5866, Harrisburg, Dauphin County, Pennsylvania 17110. I do hereby certify that the precise residence and complete post office address of the Defendant, Cymbeline Dumandan, 3004 Clubhouse Circle, Washington, Washington County, Pennsylvania 15301. Date: ~ ~ f ~ / L.." Brandon S. Williams, squire Attorney I.D. No.: 200713 Capozzi & Associates, P.C. P.O. Box 5866 Harrisburg, PA 17110 (717) 233-4101 Attorney for Plaintiff _ _ _ _ _ i IN THE COURT OF COMMON PLEAS OF CAPOZZI & ASSOCIATES, P.C., CUMBERLAND COUNTY, PENNSYLVA A Plaintiffs ' ~ ~ n., q ,vc' v, Docket No.: ,a ~ CYMBELINE DUMANDAN, Defendant Confession of Judgment for Money Rule 236 NOTICE OF ENTRY OF JUDGMENT NOTICE OF DEBTOR'S RIGHTS TO: Cymbeline Dumandan, Defendant You are hereby notified that on - ~ ~ ~ , judgmen by confession was entered against you in the sum of $18,57 .35, us p -'ud interest an costs of suit. Date: Protho YOU SHOULD TAKE THIS PAPER TO YOUR LAWYER AT ONCE. IF YOU DO NOT HAVE A LAWYER OF CANNOT AFFORD ONE, GO TO OR TELEPHONE THE OFFICE SET FORTH BELOW TO FIND OUT WHERE YOU CAN GET LEGAL HELP. CUMBERLAND COUNTY BAR ASSOCIATION 32 SOUTH BEDFORD STREET CARLISLE, PA 17013 1-800-990-9108 717-249-3166 I hereby certify that the following is the address of the Defendant(s) stated in the certificate o residence: Cymbeline Dumandan, 3004 Clubhouse Circle, Washington, P 15301-5039. 1 Date: d r ~ r~ Brandon S. Williams, Esquire Capozzi & Associates, P.C. P.O. Box 5866 Harrisburg, PA 17110 (717) 233-4101 Attorney for Plaintiff 5 CAPOZZI & ASSOCIATES, P.C., IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY. PENNSYLVANIA Plaintiffs ~ . Docket No.: 2012-05273 CYMBELINE DUMA.NDAN, Defendant Confession of Judgment for Money PRAECIPE TO ENTER RETURN OF SERVICE -,,~ -- TO THE PROTHONOTARY/CLERK OF SAID COURT: =-~= ,, Kindly enter as a matter of record the attached Affidavit of Service form as proof of ~_~~ personal service of the above-referenced Complaint upon the Defendant. A competent adult served the Complaint upon Defendant in accordance with Pa. R.C.P. No. ~02(aj on October 10, 2012. Dated; _~~ ~/ `r Marc Ar/Cnim, Esquire • Attorn y LD. No.: 9127 ~ ~. -_ Cap zi & .Associates, P.C. P. .Box 5866 Harrisburg, PA 17110 (717) 233-4101 Attorney for Plaintiff 9 CAPOZZI & ASSOCIATES Plaintiff vs. CYMBELINE DUMANCAN Defendant Person to be served (Name and Address): CYMBELINE DUMANDAN 51 FIELDMERE ST ELMONT NY 11003 By serving: CYMBELINE DUMANDAN Attorney: BRANDON S. WILLIAMS. ESQ. Papers Served: PRAE:CIPE TO REINSTATE COMPLAINTCONFESSION OF JUDGMENT WHERE ACTION COMMENCED BY COMPLAINT. COMPLAINT. EXHfBITS. CERTIFICATE. NOTICES Service Data: served Successfully I ]Not Served Dateli"ime: 1(ii 10/12 3:05 PM ( livered a copy to him/her personally [ ) Left a copy wrth a competent household member over 14 years of age residing therein iindicate name & re~ationship at right) [ j Left a copy with a person authorized to accept service, e.g. managing agent. registered agent. etc. (indicate name & official title at right) I f'~II II'~'~') II~II II~II III ~li I~t ~'~ II~II ~~ II'~I ~I I~I) 2 0 1 2 1 0 0 1 7 2 1 5 5 ?~'~~Court Of N PI~P''- CUMBERLAND COUNTY-_ PA__-_-- Venue Docket Nurnber: 2012 5273 AFFIDAVIT OF SERVICE (For Use by Private Service) Cost of Service pursuant to R d:4 3(c) Attempts: DateiTime: ___.4 Date/Time: --.~ - DaieiTime Name of Person Served and relationship/title: CYMBELINE WMANDAN-SELF' e CAPOZZI & ASSOCIATES vs. CYMBELINE DUMANDAN Plarntiff Defendant Person to be served (Name and Address): CYMBELINE DUMANDAN 51 FIELDMERE ST ELMONT NY 11003 By serving: CYMBELINE DUMANDAN Attorney: BRANDON S. WILLIAMS, ESQ. Papers Served: PRAECIPE TO REINSTATE COMPLAINTCONFESSION OF JUDGMENT WHERE ACTION COMMENCED BY COMPLAINT. COMPLAINT. EXHIBITS. CERTIFICATE. NOTICES Service Data: )~pSServed Successfully (]Not Served Date/Time 1 E)/ 10/12 3:05 PM (livered a copy to h'm%her personally (] Left a copy with a competent household member over 14 years of age residing therein (indicate name & relationship at right) (] Left a copy with a person authorized to accept service, e.g. managing agent registered agent. etc. Lindicate name & official title at right) I IIII II IIIII IIII IIII IIIII IIIII INiI Iii III IIN INI IIIII ~I III IIII 2 0 1 2 1 0 0 3 1 7 2 1 5 5 y/ ~=` Court Of N pT'F'AS _~+.~..~''~i'r' CCJMBERLADtD C.OtJN'I'Y~ PA _____ Venue Docket Number: 2012 5273 AFFIDAVIT OF SERVICE jFor Use by Private Service) Cost of Service pursuant to R. 4:C-3(c) $ ---- _ _ Attempts: Date/Time: __.____ Date/Time. _ ___ Date/Time- _ __ Name of Person Served and relationship/title: CYMBELINE DUMANDAN-SELF Description of Person Accepting Service: ' 135-145 YELipW BLACK SEX:F AGE45 _55 HEIGHT: 5 1 -5 3 WEIGHT: ______. __ SKIN: _-_____ HAIR: _____ CirHER. Unserved: [ ]Defendant ~s unknown at the address furnished by the attorney [ ]All reasonable inquiries suggest defendant moved to an undetermined address ( ] No such street in mwnicipality (]Defendant is evading service O No response ~n Date~'Time ___._--__ __ DateiTime: _ _ Other Served Data: Subscribed and Sworr to me this 11th '~ -iyf .~8~ 20~ ~ --- - - -~"_. . r . '! j ..- Notary Signature .~_~ ~-E~ '~--.~ ~~-`l/ .(/ ~~y/// Name of Notary Commission Expiration i. MIc~-GAEL LUBIN was at the time of service a competent adult, over the age of 18 and not having a direct interest in the litigation. I declare under penalty of perjury that the foregoing is tru~/an orrect. x__10 ;11 /20 12 Si e t Pr ess Server Date MI LUBIN :~.J f ~i CAPOZZI & ASSOCIATES, P.C., IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA Plaintiffs V. Docket No.: 2012-05273 Q �. CYMBELINE DUMANDAN, r, Defendant Confession of Judgment for Monte r- po C)o r�- e -v r PLAINTIFF'S MOTION FOR SANCTIONS FOR FAILURE TO PROVIDE DISCOVERY -n NOW COMES Plaintiff, Capozzi &Associates, P.C., by its undersigned attorneys, and makes this Motion for Sanctions for Failure to Provide Discovery: 1. On or about February 26, 2013,this Court granted Plaintiff s Motion for Order to Compel Answers to Post-Judgment Interrogatories ordering Defendant Cymbeline Dumanden to produce answers within 20 days of the Court Order. The Order is attached as Exhibit "A." 2. The time within which the Court directed Defendant to respond to Plaintiff s discovery request has elapsed, and Defendant has failed to produce the ordered discovery.. 3. Defendant has violated the February 26, 2013 Court Order, as well as the Pennsylvania Rules of Civil Procedure pertaining to discovery. 4. No extensions of time have been requested or granted as to compliance with the Court's Order. 5. Sanctions per Pa.R.C.P. 4019(c)(5) are appropriate and requested. 6. Plaintiff should be awarded costs and fees related to the Motion for Sanctions and the Motion to Compel and assessing them against Defendant. WHEREFORE, it is respectfully requested that this Court grant Plaintiff s Motion for Sanctions and accord the requested relief and sanctions. 1 Respectfully submitted, CAPO,Z4I ADLER, P.C. Date: By: // /X ilk .----- Marc A Crum, squire Attom y I.D. No. 91273 P. O. ox 5866 Harr sburg, PA 17110 (717) 233-4101 2 CAPOZZI & ASSOCIATES, P.C., IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY,PENNSYLVANIA Plaintiffs V. Docket No.: 2012-05273 CYMBELINE DUMANDAN, Defendant Confession of Judgment for Money CERTIFICATE OF SERVICE I hereby certify that I have this date caused a copy of the foregoing Motion for Sanctions to be served upon the following by first class U.S. Mail, postage prepaid, addressed as follows: Cymbeline Dumandan 51 Fieldmere Street Elmont,NY 11003 j Date: 12 Marc . Crum, Esquire Atto ey I.D. No. 91273 Ca zzi Adler, P.C. P. . Box 5866 H isburg, PA 17110 (717) 233-4101 5 CAPOZZI & ASSOCIATES, P.C., IN THE COURT&' PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA Plaintiffs V. Docket No.: 2012-05273 CYMBELINE DUMANDAN, Defendant Confession of Judgment for Money ORDER AND NOW, this Ak day of , 2013, upon the Motion for Sanctions filed by Plaintiff, there being no timely response by Defendant to this Court's Order of February 26, 2013, t IT IS HEREBY ORDERED that the�elief e uested tfy Plaintif 's G TED. D e�}dan b ` .3 ` iff's clays nereof, BY T COU J. Distribution: C-) r n ; j� Zymbeline 4 c A. Crum, Esquire, P. O. Box 5866, Harrisburg, PA 17110 m r n Dumandan, 51 Fieldmere Street, Elmont,NY 11003 ' � 2Z+ �" a r-r,G: ,3 MIULICL rc 3 N CAPOZZI & ASSOCIATES, P.C., IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY,PENN4%YLVANtA Plaintiffs c '' V. - Docket No.: 2012-05273 s z rr:r-- CYMBELINE DUMANDAN, hr- " a° Defendant Confession of Judgment for Mona MOTION FOR CONTINUANCE - NOW COMES Plaintiff, Capozzi & Associates, P.C., by its undersigned attorneys, and files this Motion for Continuance and avers as follows: 1. On or about August 23, 2012, this Court entered Judgment by Confession against Defendant. 2. On or about December 11, 2012, counsel for Plaintiff served Defendant with Plaintiff's Post-Judgment Interrogatories addressed to Defendant. 3. On January 18, 2013, counsel for Plaintiff sent Defendant a letter notifying her that, even though it was clearly stated that Defendant was required by law to submit answers to the Interrogatories within thirty (30) days, Plaintiff had not received any response from Defendant. 4. On or about February 26, 2013, this Court granted Plaintiff's Motion for Order to Compel Answers to Post-Judgment Interrogatories ordering Defendant Cymbeline Dumanden to produce answers within 20 days of the Court Order. 5. Due to Defendant's lack of response, this Court issued an Order dated March 28, 2013, scheduling a hearing on sanctions for April 26, 2013 at 1:30 p.m. 6. On April 24, 2013, Plaintiff received notice that the Defendant retained Counsel and was willing to negotiate the terms of a settlement. 1 r � 7. The Parties have initiated negotiations to settle this matter under the terms of a Settlement Agreement and Mutual Release and request the hearing be continued for at least 45 days. WHEREFORE, Capozzi & Associates, P.C. respectfully requests this Court to continue the hearing for a period of at least 45 days. Respectfully submitted, CAPOZZI ADLER, P.C. Date: f o�� By: - Marc Crum, Esquire Attor ey I.D. No. 91273 P. O Box 5866 Ha isburg, PA 17110 (717) 233-4101 2 CAPOZZI & ASSOCIATES, P.C., IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA Plaintiffs V. Docket No.: 2012-05273 CYMBELINE DUMANDAN, Defendant Confession of Judgment for Money ORDER AND NOW, this,day of , 2013, upon consideration of the attached Motion for Continuance, the Motion is GRANTED and the hearing scheduled in this matter on April 26, 2013 is hereby rescheduled and will be held on at . M. BY THE COURT: J. Distribution: Marc A. Crum, Esquire, P. O. Box 5866, Harrisburg, PA 17110 Peter Gleason, Esquire, 626 RXR Plaza, West Tower—6th Floor, Uniondale,NY 11556 4 CAPOZZI & ASSOCIATES, P.C., IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA Plaintiffs V. Docket No.: 2012-05273 CYMBELINE DUMANDAN, Defendant Confession of Judgment for Money CERTIFICATE OF SERVICE I hereby certify that I have this date caused a copy of the foregoing Motion for Sanctions to be served upon the following by first class U.S. Mail, postage prepaid, addressed as follows: Peter Gleason, Esquire S.J. Packman& Associates LLC Attorneys at Law 626 RXR Plaza West Tower - 6th Floor Uniondale, NY 11556 Date: Marc Crum, Esquir - Al ey I.D. No. 9121 Ca zzi Adler, P.C. P. . Box 5866 Harrisburg, PA 17110 (717) 233-4101 5 CAPOZZI & ASSOCIATES, P.C., IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA Plaintiffs V. Docket No.: 2012-05273 CYMBELINE DUMANDAN, e CD Defendant Confession of Judgment for Mor �,` , s r"_ Z ZO -O Car— N mom, CERTIFICATE OF CONCURRENCE rz4 >C-) c:2_n The undersigned hereby certifies that this date he contacted Peter Gleason,.% rn fo4�:3 Defendant, for concurrence or non-concurrence in the foregoing Motion. Peter Glea--n concurred with our Motion. Date: —01 Marc . Crum, Esquir Atto ey I.D. No.: 91273 Ca ozzi Adler, P.C. P. O. Box 5866 Harrisburg, PA 17101 (717) 233-4101 Attorneys for Plaintiff 3 N L CAPOZZI & ASSOCIATES, P.C., IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA Plaintiffs V. Docket No.: 2012-05273 CYMBELINE DUMANDAN, Defendant Confession of Judgment for Money ORDER AND NOW, this o day o 2013, upon consideration of the f/q�� L , attached Motion for Continuance, the Motion is GRANTED and the hearing scheduled in this matter on April 26, 2013 is hereby rescheduled and will be held on //2-0•01A y ,� �� , at 1�►• M. BY THE C J. Distribution: Nc A. Crum, Esquire, P. O. Box 5866, Harrisburg, PA 17110 Peter Gleason, Esquire, 626 RXR Plaza, West Tower–6`h — Floor, Uniondale,NY 11556 Coy i'CS 1` c LL C__ =rn a -am < Cn d =C:) C:i r' _ C n 4 .< '" CAPOZZI & ASSOCIATES, P.C., IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY,PENNSYLVANIA Plaintiffs n N V. Docket No.: 2012-05273 C °— w CYMBELINE DUMANDAN, r - y Nom: Defendant Confession of Judgment for Moneg� —+« Z CD r, C MOTION FOR CONTINUANCE v -) NOW COMES Plaintiff, Capozzi & Associates, P.C., by its undersigned attorneys, and files this Motion for Continuance and avers as follows: 1. The above-captioned matter is scheduled for a hearing on Friday, July 5, 2013. 2. Parties have negotiated a settlement and executed a written Settlement Agreement and Mutual Release (attached). 3. A continuance is requested for at least 60 days to ensure Defendant complies with the Settlement Agreement. WHEREFORE, Capozzi & Associates, P.C. respectfully requests this Court to continue the hearing for a period of at least 60 days. Respectfully submitted, CAP Zh LER, P.C. Date: �8" By: � - Marc . Cru squire Attorney I.D. No. 91273 Yr( Ir7)Box 5866 i sburg, PA 17110 0 233-4101 1 Louis J.Capozzi,Jr.,Esquire's r� Daniel K,Nadrbol%Esquire 1200 Camp 14111 Bypass Donald R.Reawey,Esquire '' P.,* ' Camp Bill,PA 17011 Craig 1.Adler,Esquire�* k'. Matting Address:P.O.Box 5966 Andrew R.fisemann._Esquire Iiarrisbutg,PA 17110 Bruce Q.Baron,Esquire 7J ,:°. Dawn L.Richards,Esquire } Telephone. 717}233-41111 Matthew A.Thomsen,Esquire*� � �" Facsimile.(717)233-4103 Brandon S.Williams,)✓squire .: Patti R.Van Fleet,Esquire ;_ www.capozZia iggiates_com Marc A.Crud,ftui re Timothy Ziegler,Sr.Reimb.Analyst ` Mid-Penn Abstract Company Erin E<Motter,Jr.Reimb Analyst ;;, Charter Settlement Company Kamm L.Fisher,Paralegal Telephone:(717)234-3299 Keyoung J.0111,Paralegal) - A Facsimile:(717)234-1670 Crwenn M.Keene,Paralegal (L=icensed in PA,NJ and MD) "(Licensed-in PA and NJ) April 30,2013 Cymbeline Dumandan 0/0 S.4,Packman&Associates,LLC 626 RXR Plaza West Tower--6'h Floor Uniondale,NY 11556 Re: Settlement Agreement between Capozzi Adler,P.C.and Cymbeline Dumandan Capozzi&Associates,P.C.v.Cymbeline Dumandan Cumberland CCP`No.2012-05273 Settlement Amount: $18,574.35 Our Matter No.: 515-12 Dear Ms.Dumandan: Please accept this letter as confirmation that we agreed on April.25,2013 to settle the above- referenced litigation in the total amount of$I$,574.35 (the"Settlement Amount"). Capozzi Adler, P.C. Vkla Capozzi&Associates,P.C.has agreed to accept the Settlement Amount in monthly. installment payments.("Monthly Installinent.Payments")of$125.00. Monthly Installment Payments will continue until the Settlement Amount is paid in full or until such time as Cymbeline Dumandan files a Petition for protection under the bankruptcy laws. Capozzi Adler,P.C.expressly reserves its rights to seek the payment of the remaining balance upon the filing of a Petition for protection under bankruptcy law,and in no way waives its rights to assert a claim by any lawful means,including but not limited to,filing an allowed Proof of Claim or filing an action to determine the non-dischargeabihty of the debt owed to Capozzi Adler,P.C. This confirms that Capozzi Adler,P,C.will stay the litigation in CaPo2zi&.4isoclates, AC u. Cymbeline Dumandan,Cumberland County Court of Common Pleas,Docket no.2012-05273 (the"Legal Action7),and not enforce its judgment, contingent upon payment of the Settlement Amount in full. Capozzi Adler,P,C.also agrees to waive interest and additional costs of collection contingent upon receipt of timely payments. PA"i'MNT. Monthly Installment Payments in the amount of$125.00 will be due on or before the 1 st of each month with the first Monthly Installment Payment due on or before May 25, 2013, Make the checks payable to"Capozzi Adler,P.C.,"and remit payment to the following address: PI n7 Ii =ui Capozzi Adler,P.C. P.0.Box 5866 Harrisburg,PA 17110 DEFAULT. A Monthly Installment Payment is late if received more than five days after the due date, Failure to cure payment within seven days after receipt of a written notice of late payment,constitutes DEFAULT. In the event of default,Capozzi Adler,P.C, shall exercise its rights under Pennsylvania law to proceed with its claim for the full amount owed,plus interest additional court costs,and attorneys' fees. MMUAL RELEASE. This Settlement Agreement shall be a fully binding and complete settlement and release between Capozzi Adler,P.C. f/k/a Capozzi&Associates,P.C. and Cymbaline Dumandan(the "Parties").regarding all.claims that are the subject of the Legal Action. EN ME AGREEMXNT, This Settlement Agreement contains the entire understanding between and among the Parties,and shall be binding upon and ir=e to the benefit of the executors, administrators,personal representatives,heirs,successors and assigns of each. This Agreement supersedes any prior understandings and agreements among them regarding the subject matter of this Agreement If you have any questions or concerns about this Settlement Agreement,please do not hesitate to call me. Otherwise, if this letter accurately sets forth the terms of our agreement,please sip the acknowledgement and return the original signed letter to our office in the self-addressed, stamped envelope. Thank you for your assistance and cooperation in bringing this matter to an amicable resolution. Very truly yours, M A. Crum /kjg ACKNOWLEDGEMENT Agreed to and accepted by Cymbeline Dunmdan: 1 601 Date C-Ymb eline Dumandan ,rHl$=ER,AND ANY FUTURE LEMRS FROM OUR FMM AM AN ATMMPT TO COLLECT A DEBT,AND ANY INFORMATION OBTAINED WILL BE USED FOR THAT PURPOSE- 2 CAPOZZI & ASSOCIATES, P.C., ; IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA Plaintiffs V. Docket No.: 2012-05273 CYMBELINE DUMANDAN, Defendant Confession of Judgment for Money CERTIFICATE OF CONCURRENCE The undersigned hereby certifies that this date he contacted Peter Gleason, Attorney for Defendant, for concurrence or non-concurrence in the foregoing Motion. Peter Gleason concurred with our Motion. Date: Mar A. Crum, Esquire A rney I.D. No.: 9127' Adler, P.C. P. O. Box 5866 Harrisburg, PA 17101 (717) 233-4101 Attorneys for Plaintiff 2 CAPOZZI & ASSOCIATES, P.C., IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA Plaintiffs V. Docket No.: 2012-05273 CYMBELINE DUMANDAN, Defendant Confession of Judgment for Money CERTIFICATE OF SERVICE I hereby certify that I have this date caused a copy of the foregoing Motion for Sanctions Z� to be served upon the following by first class U.S. Mail, postage prepaid, addressed as follows: Peter Gleason,Esquire S.J. Packman & Associates LLC Attorneys at Law 626 RXR Plaza West Tower - 6th Floor Uniondale,NY 11556 Date: Marc/A. Crum, Esquire Attc rney I.D.No. 91273 apozzi Adler, P.C. O. Box 5866 Harrisburg, PA 17110 (717) 233-4101 4 fit c ) CAPOZZI & ASSOCIATES, P.C., : IN THE COURT OF COMMON PLEAS OF : CUMBERLAND COUNTY, PENNSYLVANIA Plaintiffs v. : Docket No.: 2012-05273 • CYMBELINE DUMANDAN, • • Defendant : Confession of Judgment for Money ORDER AND NOW, this 3 ov.'4ay of LI Le-/ i , 2013, upon consideration of the attached Motion for Continuance, the Motion is GRANTED and the hearing sched led in this Gut- matter on July 5, 2013 i n . A4. �� BY T- COU'T: J. Distribution: ✓Marc A. Crum, Esquire, P. O. Box 5866, Harrisburg, PA 17110 l% Peter Gleason, Esquire, 626 RXR Plaza, West Tower-6th Floor, Uniondale, NY 11556 api r5 i ,lr/I 4� /i3 rn -4 s /2/C - cD --- - �, 3