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COYNE & COYNE, P.C. ~~ h J
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Lisa Marie Coyne, Esq. 4~,., ~ ~~~
Pa. Supreme Ct. No. 53788 -~~ '- ---~~~
3901 Market Street ~`~'
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Camp Hill, PA 17011-4227 ? ~ --
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(717) 737-0464 Attorneys for Pluinti, f~" - '
COYNE & COYNE, P.C., : IN THE COURT OF COMMON PLEAS O~
Plaintiff :CUMBERLAND COUNTY, PENNSYLVANIA
vs.
NO. /,1 ~ (P~Oq CIVIL TERM
ROBERT J. BARGER :CIVIL ACTION--LAW
AND CYNTHIA L. BARGER,
Husband and wife,
Defendants
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 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
IQ3.75 P~ ATM
C* s3a3
,z~ a ~ X390
COYNE & COYNE, P.C.
Lisa Marie Coyne, Esq.
Pa. Supreme Ct. No. 53788
3901 Mazket 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.
ROBERT J. BARGER
AND CYNTHIA L. BARGER,
Husband and wife,
Defendants
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. Defendants aze ROBERT J. BARGER and CYNTHIA L. BARGER, husband wife, who
are adult individuals residing at 107 Holly Drive, Mechanicsburg, Cumberland County, Pennsylvania,
17055.
3. On or about November 6, 2003, Defendants engaged the Plaintiff for legal services
concerning estate planning and a real estate matter.
4. Plaintiff performed legal services for Defendants which included preparation of respective
Last Will, Living Wills and Powers of Attorney; prepazation of a Deed of conveyance and traveling to the
courthouse to record the Deed.
5. Plaintiff has submitted regular invoices to Defendants for payment and Defendants have
not made a payment since May 2004.
2
6. Repeated demands for payment in full have been made to Defendants; however,
Defendants refuse to pay in full the invoices.
7. As of September 7, 2012, Defendants owe Plaintiff Four Hundred Thirty-Seven Dollars
and 65/100 Dollars ($437.65). (See Exhibit "A").
WHEREFORE, Plaintiff, Coyne & Coyne, P.C., respectfully requests Judgment in the amount of
$437.65, 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: ~ ~-`'t '1-~
Respectfully submitted,
COYNE & COYNE, P.C.
By: --'
I A MARIE CO ,ESQUIRE
. S. Ct. No. 53788
3901 Market Street
Camp Hill, PA 17011-4227
(717) 737-0464
3
LAW OFFICES OF COYN.E & COYN:E, P.C.
X9.01 Market Street
Camp Hill, PA,17011-4227
Invoice submitted to:
Mr. and Mrs. Robert J. Barger
107 Holy Drive
Mechanicsburg, PA 17055
September 07, -2012
In Reference To: Estate Planning
Invoice #16223
Interest on overdue balance
Total amount of this bill
Previous balance
Balance due
Amount
~w. ~'AS.T` ~ ~.
$3.57
$434.08
$437.65
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: ~ 2`'~ Z ~ Y W~-
SHERIFF'S OFFICE OF CUMBERLAND COUNTY
Ronny R Anderson
Sheriff
Jody S Smith
Chief Deputy
Richard W Stewart
Solicitor
0r i 17 A}i 8:
i . .? ,
411 A
Coyne & Coyne PC
vs.
Robert J. Barger (et al.)
Case Number
2012-6109
SHERIFF'S RETURN OF SERVICE
10/04/2012 03:15 PM - Ryan Burgett, Deputy Sheriff, who being duly sworn according to law, states that on October
4, 2012 at 1515 hours, he served a true copy of the within Complaint and Notice, upon the within named
defendant, to wit: Cynthia L. Barger, by making known unto herself personally, at 107 Holly Drive,
Mechanicsburg, Cumberland County, Pennsylvania 17050 its contents and at the same time handing to
her personally the said true and correct copy of the same.
RYAN BURG , D
10/09/2012 07:20 PM - Stephen Bender, Deputy Sheriff, who being duly sworn according to law, states that on
October 9, 2012 at 1920 hours, he served a true copy of the within Complaint and Notice, upon the within
named defendant, to wit: Robert J. Barger, by making known unto himself personally, at 107 Holly Drive,
Mechanicsburg, Cumberland County, Pennsylvania 17050 its contents and at the same time handing to
him personally the said true and correct copy of the same.
SHERIFF COST: $54.45
October 10, 2012
STEPHEN BENDER, DEPUTY
SO ANSWERS,
RON R ANDERSON, SHERIFF
(c'll Caun:,vsuve she:^iff 1'ei.3060`t, Lnf.
COYNE & COYNE, P.C.
Lisa Marie Coyne, Esq. ;-, ,-. ; r~ _y ~ ?', E
Pa. Supreme Ct. No. 53788 ~ ` '
3901 Market Street - -, L t' . ' s ;
Camp Hill, PA 17011-4227 ` "~ +~ ~' ~~`~
(717) 737-04b4 Attorneys for Plaintiff
COYNE & C'OYNE, P.C., : IN THE COURT OF COMMON PLEAS OF
Plaintiff :CUMBERLAND COUNTY, PENNSYLVANIA
vs.
ROBERT J. BARGER
AND CYNTHIA L. BARGER,
Husband and wife,
Defendants
NO. 12-6109 CIVIL TERM
CIVIL ACTION--LAW
PREACIPE TO SETTLE AND DISCONTINUE
To the Prothanotary of Cumberland County:
In accordance with Settlement Agreement reached this date between the parties and the payment in
full of a stipulated amount made by Defendant to Plaintiff, kindly mark this matter as settled and
discontinued.
COYNE & COYNE, P.C.
'" 1,
_ _ r
Dated: ~ E% -r"i' -- ~ ~.._ By: ~ 1iti~- ~w~~. ,c~ ~. _._ __ _--_
LISA MARIE COYNE ES~UIRF,
3901 Market Street
Camp Hill, P.A 17011-4227
(717) 737-0454
Pa. S. Ct. No. 53788
Attorney for Plaintiff