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HomeMy WebLinkAbout12-6108_~ 6r~ ~...( COYNE & COYNE, P.C. Lisa Marie Coyne, Esq. Pa. Supreme Ct. No. 53788 3901 Market Street Camp Bill, PA 17011-4227 (717) 737-0464 Attorneys for Plaintiff COYNE & COYNE, P.C., Plaintiff IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA . c -~ vs. : NO. /~ ' ~p~p $ CIVIL TER1V~ ~ ~~ MARK D. LEWIS, Defendant CIVIL ACTION--LAW ~`! ~~: NOTICE ~~~ ~".3 a r-a sue. <=~, !'~ ~- rn __.: ~ _.. rrp ~... r.+. 'l.,.~. ~~ P ~ . r P. ~.; ~. 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 warned that if you fail to do so the case may proceed without you and a judgment may be entered against you by the Court without further notice for any money claimed in the Complaint or for any other claim or relief requested by the Defendant. You may lose money or property or other rights important to you. YOU SHOULD TAKE THIS PAPER TO YOUR LAWYER AT ONCE. IF YOU DO NOT HAVE A LAWYER OR CANNOT AFFORD ONE, GO TO OR TELEPHONE THE OFFICE SET FORTH BELOW TO FIND OUT WHERE YOU CAN GET LEGAL HELP. Cumberland County Lawyer Referral Service 32 S. Bedford Street Carlisle, PA 17013 (717) 240-6200 s .~ 103-75 P~ AT7y e~ ~~ ~?'~ .a s 138 1 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. MARK D. LEWIS, Defendant IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA . NO. CIVIL ACTION--LAW COMPLAINT CIVIL TERM 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 MARK. D. LEWIS is an adult individual residing at 5215 Stuart Drive, Mechanicsburg, Cumberland County, Pennsylvania 3. On or about June 19, 2010, Defendant engaged the Plaintiff for legal services concerning a divorce action 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 Nine Hundred Fifty One and 69/10 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 $951.69, together with Court costs and Sheriff's costs and accruing interest from date of complaint filing at the rate of 1.5% per month, annually 18%. Dated: 2`{ Z.~ Respectfully submitted, COYNE & COYNE, P.C. r ~~ By: L A MARIE COYNE, SQUIRE a. S. Ct. No. 53788 3901 Market Street Camp Hill, PA 17011-4227 (717) 737-0464 3 _... _ .._ . ,._ _ ~~Yit^ / U ~e,r,~ C OYNE & C OYNE '' ~'• ~ A PROFESSIONAL CORPORATION ATTORNEYS AT LAW Henry F. Coyne 3901 Market Street 717-737-0464 Lisa Marie Coyne Camp Hill, Pennsylvania Fax: 717-737-5161 Jaime L. High 17011-4227 www.coyneandcoyne.com Tune 4;`201.0 ~~ C~~ `'~N ` ~ ~~ Mr. Mark D. Lewis By .,, ~~ID 5215 Stuart Drive \ Mechanicsburg, PA 17055 Re: Domestic Relations Dear Mr. Lewis. It was a pleasure speaking with you this morning concerning the divorce action filed by your wife and I gave you an overview of the divorce procedure and divorce laws in Pennsylvania. V~Te also discussed my fee for professional services and that I would provide the following as a written fee agreement which I ask you to review and return to me at your convenience. Because of the .nature of the matter, and because of the possibility of the occurrence of unpredictable and unforeseen circumstances, I am.rnot in a position to quote you a final and specific fee for. my professional services: ~"However;'I indcatEd to you that,I. would represent you on an hourly basis. My fee for professional services is TWO I~ilNDRED" D(3Z,LARS ($zb0 'a0} per--hour.;-,with fr-actions of hours coin uteri in eriods of not less than 15 minutes, whcl takes into ~ceourit interru p p ,ption of,other work. Each such hour is based upon actual work regarding your particular case. We will provide you periodic invoices for services rendered. Payments on invoices are due upon receipt. After thirty (30) days, if an invoice remains unpaid, interest will be charged on the outstanding monthly balance at the rate of One and a half Percent (1.5%), annually Eighteen Percent (18%). This office reserves the right to modify the hourly rate and the rate of interest from time to time with advance notices to you should those changes be implemented. Any out-of-pocket expenses directly attributable to your case, including by way of example court costs/filing fees, toll calls, postage, photocopies and special mailings, e.g., federal express or certified mail, will be charged to you at cost in addition to the fee. Legal costs and expenses incurred ~~re the obligation of and are to be paid by the client upon billing of same. We respectfully request you to remit to me the sum of THREE THOUSAND DOLLARS ($3,000.00) as retainer fee. This retainer will be credited to .your account for services rendered in connection with this case. As work' is performed on your behalf, you will be provided itemized invoices. We expect you to keep cuirent `with our .billings.: ; We reserve the right to terminate our attorney-client relationship for non-payment o"f fees or' costs. _If , his :divorce progresses and' the initial retainer is depleted;. you.will be, required to deposit' additional; retainers., , ` ' ,T EXHIBIT "A" Mr. Mark D. Lewis June 4, 2010 Page 2 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 make changes or take what may seem like unimportant steps without consultation with me first. Do not hesitate to ask questions. If I am unavailable when you telephone, your call will be returned with reasonable promptness. There will be times when I will be in court, or at meetings, or in conference, which will preclude me from returning your call as quickly as we both might like, but I shall do my best to return your telephone calls as soon as I can. During the course of representing you, we provide copies of incoming and outgoing correspondence and documents to you to keep you informed. After your case is concluded, we maintain our files for a period of five (5) yeazs. After that time, we will have files destroyed under conditions that will render the information in those files unusable. I am pleased to represent you in this matter, and I assure you that I will pursue your matter diligently and expeditiously and with my best efforts and expertise. Please acknowledge receipt of this letter and your agreement to same by signing a copy and returning same in the enclosed envelope, postage prepaid. With best personal wishes to you, Iremain-- Very truly yours, JLH/crs Enclosure COYNE & COYNE, P.C. L.. t ime L. High I, Mark D. Lewis, have read and fully understand the statements above written. I am acknowledging my agreement to the above by signing below. Dated: ~ q ~~ ~t~ Mark D. Le ' LAW OFFICES OF COYNE ~ COIGNE, P.C. 3901 Market Street Camp Hill, PA 17011-4227 Invoice submitted to: Mr. Mark Lewis 5215- Stuart Drive Mechanicsburg, PA 17055 September 07, 2012 Invoice #16234 interest on overdue balance Total amount of this bill Previous balance Balance due Amount .~ ~~~~ $7.76 ~~~ $7.76 $943.93 $951.69 EXHIBIT "B" VERIFICATION The facts set forth in the foregoing are true and correct to the best of the undersigned's knowledge, information and belief and are verified subject to the penalties for unsworn falsification to authorities under 18 Pa. C.S.A. § 4904. Dated: Z'{ Z- SHERIFF'S OFFICE OF CUMBERLAND COUNTY Ronny R Anderson Sheriff Jody S Smith Chief Deputy Richard W Stewart Solicitor ?$r??tt? qt +? Rdrlbprf??? / 1= lFV f? 4?! OFFICE r ? T,4E S4ER1FF t- ' PR 4- 2 OCT 16 AM 9, 02 REN?NSYLVANiAN Y Coyne & Coyne PC vs. Mark D. Lewis Case Number 2012-6108 SHERIFF'S RETURN OF SERVICE 10/04/2012 03:41 PM - Ryan Burgett, Deputy Sheriff, who being duly sworn according to law, states that on October 4, 2012 at 1541 hours, he served a true copy of the within Complaint and Notice, upon the within named defendant, to wit: Mark D. Lewis, by making known unto himself personally, at 5215 Stuart Drive, Mechanicsburg, Cumberland County, Pennsylvania 17055 its contents and at the same time handing to him personally the said true and correct copy of the same. SHERIFF COST: $38.45 October 10, 2012 RYAN BURGE , TY SO ANSWERS, Isd RON R ANDERSON, SHERIFF ic; CeuntySuite Sheriff, Teleoso@. Inc.