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Home My WebLink About12-5669 ~ r ua=. TNT ~'t;~ i FiC++~~~~ ~ ~ z s~~ ~ ~ a~ c~ CUMBERI_A?~D CQUNT`f' COYNE & COYNE, P.C, #'E~NSYf.VANIt~ Lisa Marie Coyne, Esq. Pa. Supreme Ct. No. 5788 3901 Market Street Camp Hill, PA 17011-4227 (717) 737-0464 Attorneys for Plaintiff COYNE & COYNE, F.C, : IN THE COURT OF COMMON PLEAS OF Plaintiff :CUMBERLAND COUNTY, PENNSYLVANIA vs. : NO. - S CQ CIVIL TERM BRENDA L. STEFANIOWICH, :CIVIL ACTION--LAW Defendant NOTICE YOU HAVE BEEN SUED IN COURT. If you wish to defend against the claims set forth in the following pages, you must take action within twenty (20) days after this Notice is served, by entering a written appearance personally or by an attorney and filing in writing with the Court your defenses or objections to the claims set forth against you. You are warned that if you fail to do so the case may proceed without you and a judgment may be entered against you by the Court without further notice for any money claimed in the Complaint or for any other claim or relief requested by the Defendant. You may lose money or property or other rights important to you. YOU SHOULD TAKE THIS PAPER TO YOUR LAWYER AT ONCE. IF YOU Ia0 NOT HAVE A LAWYER OR CANNI~T AFFORD ONE, GO TO OR TELEPHONE THE OFFICE SET FORTH BELOW TO FIND OUT WHERE YOU CAN GET LEGAL HELP. Cumberland County Lawyer Referral Service 32 S. Bedford Street Carlisle, PA 17013 (717) 240-6200 S ~i Ib3.~S ~Gi~ 1 C tc., ~ S 30S ~~~~v5~s COYNE & COYNE, P.C. Lisa Marie Coyne, Esq. Pa. Supreme Ct. No. 53788 3901 Market Street Camp Hill, PA 17011-4227 (717) 737-0464 Attorneys fore Plaintiff COYNE & COYNE, P.C, : IN THE COURT OF COMMON PLEAS OF Plaintiff :CUMBERLAND COUNTY, PENNSY1r.VANIA vs. : NO. CIVIL TERM BRENDA L. STEFANgWICH, :CIVIL ACTION--LAW Defendant COMPLAINT AND NOW comes the Plaintiff, Coyne & Coyne, P.C., and files the within Complaint: 1. Plaintiff is Coyne & Coyne, P.C. a Professional Corporation, with offices located at 3901 Market Street, Camp Hi11, Cumberland County, Pennsylvania 17011. 2. Defendant is BRENDA L. STEFANOWICH is an adult individual residing at 4183 Grouse Court, Apt. 106, Mecharnicsburg, Cumberland County, Pennsylvania, 17020. 3. On or about February 23, 2004, Defendant engaged the Plaintiff for legal services concerning a divorce matter per the financial terms outlined and agreed to by the Defendant as per a written Fee Agreement. ' (See Exhibit "A"). 4. Plaintiff performed legal services for Defendant which included successfully obtaining child and spousal support and obtaining a favorable equitable distribution settlement in a divorce action. 5. Plaintiff has submitted regular invoices to Defendant for payment. 2 - irr _ _ _ 6. Repeated demands for payment in full have been made to Defendant; however, Defendant refuses to pay in full the invoices. 7. As of September 7, 2012 Defendant owes Plaintiff Twenty-two Thousand Forty-three and 25/100 Dollars ($22,048.25) as balance due and owing under the written fee agreement with an interest rate of 1.5% per month, annually 18%. (See Exhibit "B") WHEREFORE, (Plaintiff, Coyne & Coyne, P.C., respectfully requests Judgment in the amount of $22,043.25 together witth Court costs and Sheriff's costs and accruing interest from date of complaint filing at the rate of 1.5% per month, annually 18%. Respectfully submitted, COYNE & COYNE, P.C. Dated: l I Z By: IS MARIE COYN ,ESQUIRE . Ct. No. 53788 3901 Market Street Camp Hill, PA 17011-4227 (717) 737-0464 3 TT r C OYNE & C OYNE A PROFESSIONAL CORPORATION ATTORNEYS AT LAW Henry F. Coyne 3901 Market Street 717-737-0464 Lisa Marie Coyne Camp Hill, Pennsylvania Fax: 717-737-5161 Austin F. Grogan 17011-4227 February 23, 2004 Mrs. Brenda L. Stefanovich 4183 Grouse Court, Apt. 106 Mechanicsburg, PA 17050 Re: Domestic Relations Dear Brenda: Thank you far retaining us as your legal counsel concerning your pending divorce. As we discussed, the followitng is a written fee agreement which I ask you to review and return to me at your convenience. Because of the nature of the matter, and because of the possibility of the occurrence of unpredictable and unfpreseen circumstances, I am not in a position to quote you a final and specific fee for my professional services. However, I indicated to you that I would represent you on an hourly basis. My fee for professional services is One Hundred Seventy-five Dollars ($175.00) per hour, with fractions of hours computed in periods of not less than 15 minutes, which takes into account interruption of other work. Each such hour is based upon actual work regarding your particular case. We will provide you periodic invoices for services rendered. Payments on invoices are due upon receipt. After thirty (~0) days, if an invoice remains unpaid, interest will be charged on the outstanding monthly balance at the rate of One and a half Percent (1.5%), annually Eighteen Percent (18%). This office reserves the right to modify the hourly rate and the rate of interest from time to time with advance notices to you should those changes be implemented. Any out-of-pocket expenses directly attributable to your case, including by way of example court costs/filing fees, toll falls, postage, photocopies and special mailings, e.g., federal express or certified mail, will be charged to you at cost in addition to the fee. Legal costs and expenses incurred are the obligation of and are t~ be paid by the client upon billing of same. We respectfully request you to remit to me the sum of Two Thousand Five Hundred Dollars ($2,500.00) as anon-refundable retainer fee plus filing fees. This retainer will be credited to your account for services rendered in connection with this case. As work is performed on your behalf, you will be provided itemized invoices. We expect you to keep current with our billings. We reserve the right to terminate our' attorney-client relationship for non-payment of fees or costs. If this divorce progresses and the initiial retainer is depleted, you will be required to deposit additional retainers. It is impossible to predict a course that a divorce action will take. Therefore, it is important that you keep me informed of any and all changes in your life once my representation commences. We shall keep you well informed as to the progress of your case. We will send you copies of all papers coming in and going out of our offices, including correspondence, pleadings, and other court documents. Do not ~1 ^ Mrs. Brenda L. Stefanovich February 23, 2004 Page 2 make changes or take what may seem like unimportant steps without consultation with me first. Do not hesitate to ask questions. If I am unavailable when you telephone, your call will be returned with reasonable promptness. There will be times when I will be in court, or at meetings, or in conference, which will preclude me from returning your call as quickly as we both might like, but I shall do my best to return your telephone calls as soon as I can. I am pleased to represent you in this matter, and I assure you that I will pursue your matter diligently and expeditiously and with my best efforts and expertise. Please acknowledge receipt of this letter and your agreement to same by signing a copy and returning same in the enclosed envelope, postage prepaid. With best personal wishes to you, Iremain-- Very truly yours, COYNE & COYNE, P.C, A ti F. Grogan AFG/amd Enclosure I, Brenda L. Stefanowich, have read and fully understand the statements above written. I am acknowledging my agreement to the above by signing below. Dated: BRENDA L. STEFANOWICH LAW OFFICES OF COYNE & COYNE, P.C. 3901 Market Street Camp Hill, PA 1 701 1-4227 Invoice submitted to: Mrs. Brenda Stefanowich 4183 Grouse Court, Apt., 106 Mechanicsburg, PA 17050 September 07, 2012 In Reference To: Divorce Invoice #16237 Amount Interest on overdue balance $268.61 Total amount df this bill $268.61 Previous balanc~e $21,774.64 Balance due $22,043.25 t T ~T, VERIFICATION The facts set forth in the foregoing are true and correct to the best of the undersigned's knowledge, infolrtnation and belief and are verified subject to the penalties far unsworn falsification to authorities under 18 Pa. C.S.A. § 4904. Dated: ~ Z /Z `/2~ - COYNE & COYNE,P.C. Lisa Marie Coyne, Esq. Pa. Supreme Ct.No. 53788 3901 Market Street Camp Hill, PA 17011-4227 (717)737-0464 Attorneys for Plaintiff COYNE & COYNE,P.C, IN THE COURT OF COMMON PLEAS OF Plaintiff CUMBERLAND COUNTY,PENNSYLVANIA VS. NO. 12-5669 CIVIL TERM S21 BRENDA L. STEFANOWICH, CIVIL ACTION—LAW = Defendant ' PRAECIPE FOR ENTRY OF DEFAULT JUDGMENT TO THE PROTHONOTARY: Enter judgment in favor of Plaintiff, Coyne &Coyne,P.C. and against Defendant,Brenda L. Stefanowich for want of an answer. Amount claimed in complaint: $22,043.25 Interest: at the rate of 18%(APY)plus court costs Total: $22,043.25 plus 18% interest (APY) from date of lndg�nent and court costs. I certify that written notice of the intention to file this Praecipe was mailed or delivered to the party against whom judgment is to be entered and to his/her attorney of record, if any, after the default occurred and at least ten(10)days prior to the date of the filing of this Praecipe. A copy of the Notice is attached. R.C.P.237.1 COYNE&COYNE,P.C. Date By: QMarie Coyne,Esquire is Ct.No. 53788 Market Street Camp Hill,PA 17011-4227 (717)737-0464 Attorney for Plaintiff Judgment in the amount of$22,043.25 plus 18% interest from date of judgment plus court costs is entered in favor of Plaintiff, Coyne & Coyne, P.C. and against the above named Defendant, Brenda L. Stefanowich for vent of an answer. J Prothonotary,Cumberland County k S64 C or 1;z ri i COYNE&COYNE,P.C. Lisa Marie Coyne,Esq. Pa.Supreme Ct.No. 53788 3901 Market Street Camp Hill,PA 17011-4227 (717)737-0464 Attorneys far Plaintiff'' COYNE&COYNE,P.C, : IN THE COURT OF COMMON PLEAS OF Plaintiff : CUMBERLAND COUNTY,PENNSYLVANIA VS. : NO. 12-5669 CIVIL TERM : BRENDA L.STEFANOWICH, :CIVIL ACTION—LAW Defendant TO: Mrs.Brenda Stefanowich 4814 Virginia Road Mechanicsburg,PA 17050 DATE OF NOTICE D,F,QMOM12,2012 I4EQRTAK NOTICE YOU ARE IN DEFAULT BECAUSE YOU HAVE FAILED TO ENTER A WRITTEN APPEARANCE PERSONALLY OR BY ATTORNEY AND FILE IN WRITING WITH THE COURT YOUR DEFENSES OR OBJECTIONS TO THE CLAIMS SET FORTH AGAINST YOU. 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 RoRORTANT 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 Lawyer Referral Service 32 S.Bedford Street Carlisle,PA 17013 (717)249-3166 Date: Z !Z COYNE&COYNE,P.C. , • _ By: (.. SA MARIE qbYNE,ESQUIRE 3901 Market Street Camp Hill,PA 17011-4227 (717)73749" Pa.S.Ct.No.53788 Attorney for Plaintiff CERTIFICATE OF SERVICE I,Lisa Marie Coyne,Esquire,hereby certify that a true copy of PlainfCs Ten Day Notice of Default was served upon the below-referenced individual by sending the same by first class mail, pub prepaid,addressed as follows: Mrs.Brenda Stefanowich 4814 Virginia Road Mechanicsburg,PA 17050 Dated: /Z I 'Z LI A CO QUIRE