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Home My WebLink About12-6107 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, PENNSYL~NdA ~_ vs. : NO. ~- (p/D7 CIVIL TERI~'~ ~--, ~ ~'"~ BRIAN M. BARLOW, :CIVIL ACTION--LAW ~ ~ ~~~~ Defendant '~' a ~ ~'~~ ~~ _ `.' =~ _., _. ....a ., . 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 appeazance personally or by an attorney and filing in writing with the Court your defenses or objections to the claims set forth against you. You aze wazned that if you fail to do so the case may proceed without you and a judgment may be entered against you by the Court without further notice for any money claimed in the Complaint or for any other claim or relief requested by the Defendant. You may lose money or property or other rights important to you. YOU SHOULD TAKE THIS PAPER TO YOUR LAWYER AT ONCE. IF YOU DO NOT HAVE A LAWYER OR CANNOT AFFORD ONE, GO TO OR TELEPHONE THE OFFICE SET FORTH BELOW TO FIND OUT WHERE YOU CAN GET LEGAL HELP. Cumberland County Lawyer Referral Service 32 S. Bedford Street Cazlisle, PA 17013 (717) 240-6200 ~~J -~103.7~' PA i~7'Tt/ ~~- saa8 ~2~a8i388 COYNE & COYNE, P.C. Lisa Marie Coyne, Esq. Pa. Supreme Ct. No. 53788 3901 Market Street Camp Hill, PA 17011-4227 (717) 737-0464 Attorneys for Plaintiff COYNE & COYNE, P.C., Plaintiff vs. BRIAN M. BARLOW, Defendant IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA . NO. CIVIL TERM CIVIL ACTION--LAW COMPLAINT AND NOW comes the Plaintiff, Coyne & Coyne, P.C., and files the within Complaint: 1. Plaintiff is Coyne & Coyne, P.C. a Professional Corporation, with offices located at 3901 Market Street, Camp Hill, Cumberland County, Pennsylvania 17011. 2. Defendant is BRIAN M. BARLOW is an adult individual residing at 239 Wyoming Avenue, Enola, Cumberland County, Pennsylvania 3. On or about August 17, 2005, Defendant engaged the Plaintiff for legal services concerning criminal charges filed against the Defendant 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 and Plaintiff submitted regular invoices to Defendant for payment. 6. Repeated demands for payment in full have been made to Defendant; however, Defendant refuses to pay the invoices. 2 7. As of September 7, 2012, Defendant owes Plaintiff One Thousand Two Hundred Ninety Six and 16/10 Dollars as balance due and owing under the written fee agreement with an interest rate of 1.5% per month, annually 18%. (See Exhibit "B") WHEREFORE, Plaintiff, Coyne & Coyne, P.C., respectfully requests Judgment in the amount of $1,296.16, together with Court costs and Sheriff's costs and accruing interest from date of complaint filing at the rate of 1.5% per month, annually 18%. Dated: ?/ Respectfully submitted, COYNE & COYNE, P.C. c By: LI A ARIE COYNE, ESQU Pa. Ct. No. 53788 3901 Market Street Camp Hill, PA 17011-4227 (717) 737-0464 3 C OYNE & C OYNE A PROFESSIONAL CORPORATION ATTORNEYS AT LAW Henry F. Coyne 3901 Market Street Lisa Marie Coyne Camp Hill, Pennsylvania Austin F. Grogan 17011-4227 August 17, 2005 Mr. $rian M. Barlow 239 Wyoming Avenue Enola, PA 17025 Re: Commonwealth v. Barlow Dear Mr. Barlow: This letter confirms our recent discussion in which I agreed, at your request, to represent you regarding the above-referenced criminal matter and I will appear on your behalf at the preliminary hearing scheduled with District Justice. Pelino. If the criminal charges are bound-over for Court, an additional retainer will be required before formal arraignment. if retained for formal arraignment, we will represent you through verdict/plea and sentence. This representation does not include appellate representation. Although we discussed in detail your case and the procedural position and options which you have, I did not discuss in detail my fee. As I explained to you, because of the nature of the matter, and because of the possibility of the occurrence of unpredictable and unforeseen circumstances, I am not in a position to quote you a final and specific fee for my professional services. However, I indicated to you that I would represent you on an hourly basis. My fee for professional. services is One Hundred Seventy-five Dollars ($175.OOj 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. Please note that this office reserves the right to modify the hourly rate and the rate of interest from time to time with advance notice to you prior to implementation of the changes. During my representation,- Iwill provide you with periodic invoices for services rendered. Payments on invoices are due upon receipt. After thirty (30) days, if an invoice remains unpaid, in whole . or in part, interest will be`charged on the outstanding balance at the rate of One. and a half percent (1.5%) per month, Eighteen Percent (18°l0) per year. Any out-of-pocket expenses directly attributable to your case, including but not limited to private investigator charges, court transcripts, toll calls, postage, photocopies and travel expenses, will be charged to you at cost in addition to the fee. Legal costsand expenses incurred are the obligation of and are to be paid by the client upon billing of same. EXHIBIT "A" Mr. Brian M. Barlow August 17, 2005 Page 2 I acknowledge receipt of a One Thousand Dol-lars ($1,000.00) as anon-refundable retainer fee. If the retainer should be entirely used during the course of my representation, you will be provided an itemized invoice for services rendered and a deposit of another partial retainer may be requested at my option. It is impossible to predict a course that a criminal case will take. Therefore, it is important that you keep me informed of any and all changes in your life once my representation commences. We shall keep you well informed as to the progress of your case. We will send you copies of all papers coming in and going out of our offices, including correspondence, pleadings, and other court documents. Do not make changes or take what may seem like unimportant steps without consultation with me first. Do not hesitate to ask questions. If I am unavailable when you telephone, your call will be returned with reasonable promptness. There will be times when I will be in court, or at meetings, or in conference, which will preclude me from returning your call as quickly as we both might like, but I shall do my best to return your telephone calls as soon as I can. I am pleased to represent you in this matter, and I assure you that I will pursue your matter as diligently, zealously, and expeditiously as possible. 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, AFG/cmc Enclosure CC~YNE & CO , P.C. ~.~ Austin F. Grt g I, BRIAN M. BARLOW, -have read and fully understand the statements above written. I am acknowledging my agreement to the above by signing my signature below. Dated:. ~/~ / ~ S -moo BRIAN M. BARLOW LAW OF1=,LCES OF COYNE & COYNE, P.C. ~9b1:Market Street Camp Hilt, PA 17011-4227 Invoice submitted to: Mr. Brian M. Barlow X39 VF/yoming Avenue Enola, PA 17025 September 07, 2012 In Reference To: Criminal Charges- Drug Possession/Paraphernalia Invoice #16224 Interest on overdue balance Total amount of this bill Previous balance Balance due Amount $10.56 ~. ~~ $10.56 ~~ ~~ $1,285.60 EXHIBIT "B" VERIFICATION The facts set forth in the foregoing are true and correct to the best of the undersigned's knowledge, information and belief and are verified subject to the penalties for unsworn falsification to authorities under 18 Pa. C.S.A. § 4904. Dated: ~ LY Z SHERIFF'S OFFICE OF CUMBERLAND COUNTY Ronny R Anderson Sheriff ~,i Jody S Smith ;. `"` Chief Deputy Richard W Stewart Solicitor Coyne & Coyne PC vs. Brian M Barlow SHERIFF'S RETURN OF SERVICE `f`"t_ +-r~~~~, ~ ~~ ~, ~ '~f } ju" _iJ Hi'~ 1iJ~ ~~ _t r ;~ Case Number 2012-6107 11/02/2012 Sheriff Ronny R Anderson, being duly sworn according to law, states he made diligent search and inquiry for the within named Defendant to wit: Brian M. Barlow, but was unable to locate the Defendant in his bailiwick. The Sheriff therefore returns the within requested Complaint & Notice as "Not Served" at 239 Wyoming Avenue, East Pennsboro Township, Enola, PA 17025. Four attempts at service were made before Complaint expired. Deputies were unable to make contact with anyone at this address, although or October 26, 2012 when attempting service deputy did notice that lights were on but no one answered the door. SHERIFF COST: $44.45 November 02, 2012 SO ANSWERS, ~~~~ ,, ~~ ' ~~, RONNY R ANDERSON, SHERIFF