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Home My WebLink About04-5992COYNE & COYNE, P.C., Plaintiff VS. NORMAN A. REAM and, MARGARET D. REAM, alkta MARGARET E. REAM, Husband and Wife, Defendants. : IN THE COURT OF COMMON PLEAS OF : CUMBERLAND COUNTY, PENNSYLVANIA NO. 6'41 - SQ 9k CIVIL TERM CIVIL ACTION-Law 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 Bar Association 32 South Bedford Street Carlisle, PA 17013 (717) 249-3166 1 COYNE & COYNE, P.C., : IN THE COURT OF COMMON PLEAS OF Plaintiff : CUMBERLAND COUNTY, PENNSYLVANIA VS. : NO. Q'q- 999 k CIVIL TERM NORMAN A. REAM and, MARGARET D. REAM, a/k/a MARGARET E. REAM, Husband and Wife, Defendants. : 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 Pennsylvania Professional Corporation, with offices located at 3901 Market Street, Camp Hill, Hampden Township, Cumberland County, Pennsylvania. 2. Defendants are Norman A. Ream and Margaret D. Ream, a/k/a Margaret E. Ream, husband and wife, residing at 128 Cambridge Drive, Lower Allen Township, Cumberland County, Pennsylvania. c h a n/, ?StiH r ? A /-7 a,5 J 7r' / 3. On or about September 17, 2003, Defendants contracted for legal services with Plaintiff and Defendants agreed to pay for services at the rate of $175.00 per hour. 4. Plaintiff performed legal services for Defendants and at the end of said representation submitted an invoice to Defendants for payment. (See Exhibit "A") 5. Repeated demands for payment in full have been made to Defendants; however, Defendants have refused to pay same. 6. On February 9, 2004, Defendants through their daughter, Vicki L. Womer, contacted the Plaintiff and requested a payment plan to address Defendants' outstanding and unpaid invoice. 2 7. On March 15, 2004, Plaintiff agreed to accept monthly payments from Defendants for the unpaid invoice and advised Defendants of agreement in writing. (See, Exhibit "B") 8. Despite agreeing to a nominal monthly payment plan to address the unpaid invoice, Defendants have made no payments on the outstanding and unpaid invoice. 9. On October 13, 2004, Plaintiff advised Defendants that a collection action would be initiated against the Defendants after November 1, 2004 if payment was not made on the outstanding and overdue invoice. (See, Exhibit "C"). 10. As of November 30, 2004, Defendants owe Plaintiff $1,143.32 with an interest rate of 1.5% per month, annually 18% accruing on the balance. (See, Exhibit "D"). WHEREFORE, Plaintiff, Coyne & Coyne, P.C., respectfully requests Judgment against the z Defendants in the amount of $1,143.32, together with Court costs and accruing interest from date of complaint filing. Respectfully submitted, COYNE & COYNE, P.C. 17 Dated: By: r c ?- fi _ LISA MARIE. CONE, ESQUIRE 3901 Market Street Camp Hill, PA 17011-4227 (717) 737-0464 Pa. S. Ct. No. 53788 Plaintiff 3 LAW OFFICES OF COYNE & COYNE, P.C. 3901 Market Street Camp Hill, PA 17011-4227 Invoice submitted to: Mr. and Mrs. Norman Ream 128 Cambridge Drive Mechanicsburg PA 17055 February 03, 2004 In Reference To: Elder Law Issues and Estate Planning Invoice #11366 Professional Services 9/17/2003 Meeting w/client Re: Elder Law. 9/23/2003 DIP Memo to DPW; Teleconf. w/ DPW (Dobbs). 9/30/2003 DIP Memo to client; Draft Estate Planning Documents; Telconf. with client 10/8/2003 Teleconf. w/ Mrs. Ream. 10/14/2003 Meeting w/client Re: Execution of Estate Planning Documents, Discuss care of Husband at Nursing Home, Reviewed insurance documents 10/17/2003 Meet w/ client; Travel to Nursing Home to meet w/ Mr. Ream to execute POA; Meet w/ Mrs. Ream to complete Insurance ; DIP Memos to Insurance Cos.; DIP Memo to Mrs. Dobbs. 10/20/2003 Teleconf. w/ Gerber Life Insurance; Peoples Life Insurance; Alliany Re: Change of Ownership Request. 11/1/2003 Teleconf. w/Mrs. Ream Re: Insurance, Car title issue, and Nursing Home Issue 11/3/2003 Meeting w/ Mrs. Ream Re: Deed execution; insurance change; DIP Memo to Gerber Life; DIP Memo to Peoples Life; DIP Memo to American Legion Life 11/7/2003 R/T Travel to Cumberland County Courthouse to record POA & New Deed; DIP Memo to Mrs. Dobbs. 11/16/2003 DIP Memo to client Re: Recorded Documents; DIP Memo to Mrs. Dodds. Hours 1.00 NO CHARGE 0.25 NO CHARGE 1.00 0.25 NO CHARGE 1.00 2.00 0.50 NO CHARGE 0.25 NO CHARGE 0.50 NO CHARGE 1.25 0.50 NO CHARGE /-1 / ' ? -2 Z' Mr. and Mrs. Norman Ream 11/20/2003 Meeting w/client re: Insurance, etc. 11121/2003 D/P Memos to three Insurance Companies Re: Submission of Documentation for Assigning of Ownership of Policies to Mrs. Ream For professional services rendered Additional Charges : Postage Photocopies Long Distance Charges Recording Fees for Deed and Power of Attorney-- Advanced by Coyne & Coyne, P.C Total costs Total amount of this bill Balance due Page 2 Hours 0.50 NO CHARGE 0.50 NO CHARGE Amount 9.50 $918.75 Price 7.40 1.50 0.37 59.50 $68.77 $987.52 $987.52 ?17 e° z COYNE & COYNE A PROFESSIONAL CORPORATION ATTORNEYS AT LAW Henry F. Coyne Lisa Marie Coyne Austin F. Grogan 3901 Market Street Camp Hill, Pennsylvania 17011-4227 717-737-0464 Fax: 717-737-5161 Mrs. Margaret E. Ream 128 Cambridge Drive Mechanicsburg, PA 17055 Dear Mrs. Ream: March 15, 2004 Re: Elder Law/Estate Planning This letter is a follow up to a fax received February 9, 2004 from your daughter, Vicki, as well as teleconference between my secretary and your daughter concerning an invoice for professional services you received from this office. This letter is to verify my secretary informed Vicki that her proposal of a $100.00 a month payment would be acceptable due to the circumstances contained in her fax to me. However, in a letter, dated November 16, 2004, I requested you reimburse this office $59.50 which were recording fees this office advance to the Recorder of Deed's Office on your behalf. Enclosed is a copy of that letter along with the receipt. This fee should be forwarded to this office immediately. With best personal wishes to you, I remain -- Very truly yours, COYNE & COYNE, P.C. Mark Coyne )i/sla/ LMC/amd Encl. Cc: Mrs. Vicki L. Womer r COYNE & COYNE A PROFESSIONAL CORPORATION ATTORNEYS AT LAW Henry F. Coyne Lisa Marie Coyne Austin F. Grogan Sharon F. Clark 3901 Market Street Camp Hill, Pennsylvania 17011-4227 717-737-0464 Fax: 717-737-5161 Mrs. Margaret E. Ream 128 Cambridge Drive Mechanicsburg, PA 17055 Dear Mrs. Ream: October 13, 2004 Re: Elder Law/Estate Planning Your account is a year overdue. I have been extremely patient concerning this account; however, my patience is exhausted. I extended every professional courtesy to you and your family concerning this matter to include my office advancing the filing fees and recording costs for the new deed. Furthermore, when your daughter requested that my office accept a payment plan for this account, I agreed to accept regular monthly payments. However, unfortunately, I have not received any payments whatsoever concerning this account. Enclosed is your current invoice showing a balance due of $1,116.88. Payment in full of this account must be made by November 1, 2004. If not paid in full by November 1, 2004, formal collection action will be initiated. I am disheartened that this matter has reached this point given the fact that I provided you and your family with prompt and comprehensive legal advice and counsel. I look forward to hearing from you. Very truly yours, LMC/amd Encl. COYNE & COYNE, P. . sa Marie Coyne L L v LAW OFFICES OF COYNE & COYNE, P.C. 3901 Market Street Camp Hill, PA 17011-4227 Invoice submitted to: Mr. and Mrs. Norman Ream 128 Cambridge Drive Mechanicsburg PA 17055 October 13, 2004 In Reference To: Elder Law Issues and Estate Planning Invoice #11841 Amount Interest on overdue balance $41.37 Total amount of this bill $41.37 Previous balance $1,075.51 Balance due $1,116.88 ?? ?? z LAW OFFICES OF COYNE & COYNE, P.C. 3901 Market Street Camp Hill, PA 17011-4227 Invoice submitted to: Mr. and Mrs. Norman Ream 128 Cambridge Drive Mechanicsburg PA 17055 November 30, 2004 In Reference To: Elder Law Issues and Estate Planning Invoice #11937 Interest on overdue balance Total amount of this bill Previous balance Balance due Amount $12.12 $12.12 $1,131.20 $1,143.32 ?/? 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 unswom falsification to authorities under 18 Pa. C.S.A. §4904. Dated: I V1 Q' C"} C .r- q c-? { co cn n 'T'I f M m - tii COYNE & COYNE, P.C., : IN THE COURT OF COMMON PLEAS OF Plaintiff : CUMBERLAND COUNTY, PENNSYLVANIA VS. : NO. 04-5992 CIVIL TERM NORMAN A. REAM and, MARGARET D. REAM, alk/a MARGARET E. REAM, Husband and Wife, Defendants. : CIVIL ACTION-Law TO: Mr. Norman A. Ream Mrs. Margaret D. Ream, a/k/a Margaret E. Ream 128 Cambridge Drive Mechanicsburg, PA 17055 DATE OF NOTICE: January 11, 2005 IMPORTANT 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 JUDGEMENT MAY BE ENTERED AGAINST YOU WITHOUT A HEARING AND YOU MAY LOSE YOUR PROPERTY OR OTHER IMPORTANT RIGHTS. YOU SHOULD TAKE THIS NOTICE TO A LAWYER AT ONCE, IF YOU DO NOT HAVE A LAWYER OR CANNNOT AFFORD ONE, GO TO OR TELEPHONE THE FOLLOWING OFFICE TO FIND OUT WHERE YOU CAN GET LEGAL HELP: Cumberland County Lawyer Referral System Cumberland County Bar Association 32 S. Bedford Street Carlisle, PA 17013 1-800-990-9108 COYNE &: COYNE, P.C. Date: January11, 2005 f t.- l LI A MARIE CO E, Esquire 01 Market Street Camp Hill, PA 17011-4227 (717) 737-0464 Pa. S. Ct. No. 53788 Plaintiff CERTIFICATE OF SERVICE I, Lisa Marie Coyne, of Coyne & Coyne, P.C., hereby certify that true copy of the foregoing Ten Day Notice of Intent to Enter Default Judgment was served this date upon the below-referenced individuals at the below listed address by way of first class mail, postage pre-paid: Mr. Norman A. Ream Mrs. Margaret D. Ream, a/k/a Margaret E. Ream 128 Cambridge Drive Mechanicsburg, PA 17055 Dated: //- J-A N - 2FR' Cv-- _ Lis Marie Coyne, squire -mss SHERIFF'S RETURN - REGULAR CASE NO: 2004-05992 P COMMONWEALTH OF PENNSYLVANIA: COUNTY OF CUMBERLAND COYNE & COYNE PC VS REAM NORMAN A ET AL CPL. TIMOTHY REITZ , Sheriff or Deputy Sheriff of Cumberland County,Pennsylvania, who being duly sworn according to law, says, the within COMPLAINT & NOTICE was served upon REAM NORMAN A the DEFENDANT , at 1823:00 HOURS, on the 8th day of December-, 2004 at 128 CAMBRIDGE DRIVE MECHANICSBURG, PA 17055 by handing to MARGARET REAM, WIFE a true and attested copy of COMPLAINT & NOTICE together with and at the same time directing Her attention to the contents thereof. Sheriff's Costs: Docketing 18.00 Service 7.40 Affidavit .00 Surcharge 10.00 Sworn and Subscribed to before me this day of i 4?2eo J A.D. i r thonotary So Answers: R. Thomas Kline 12/09/2004 COYNE & COYNE By: D uty Sheri /f SHERIFF'S RETURN - REGULAR CASE NO: 2004-05992 P COMMONWEALTH OF PENNSYLVANIA: COUNTY OF CUMBERLAND COYNE & COYNE PC VS REAM NORMAN A ET AL CPL. TIMOTHY REITZ Sheriff or Deputy Sheriff of Cumberland County,Pennsylvania, who being duly sworn according to law, says, the within COMPLAINT & NOTICE REAM MARGARET D AKA MARGARET E REAM was served upon the DEFENDANT , at 1823:00 HOURS, on the 8th day of December-, 2004 at 128 CAMBRIDGE DRIVE MECHANICSBURG, PA 17055 by handing to MARGARET REAM a true and attested copy of COMPLAINT & NOTICE together with and at the same time directing Her attention to the contents thereof. Sheriff's Costs: Docketing 6.00 Service .00 Affidavit .00 Surcharge 10.00 .00 16.00 Sworn and Subscribed to before me this 7 day of J vv-.5' A.D. ?1. a So Answers: R. Thomas Kline 12/09/2004 COYNE & COYNE By: De uty Sherif rothonotary Curtis R. Long Prothonotary (Office of the i3rotbonotarp Cumberfanb Countp Renee K. Simpson Deputy Prothonotary John E. Slike Solicitor 6J4 - 9992, , CIVIL TERM ORDER OF TERMINATION OF COURT CASES AND NOW THIS 29TH DAY OF OCTOBER 2008 AFTER MAILING NOTICE OF INTENTION TO PROCEED AND RECEIVING NO RESPONSE - THE ABOVE CASE IS HEREBY TERMINATED WITH PREJUDICE IN ACCORDANCE WITH PA R C P 230.2 BY THE COURT, CURTIS R. LONG PROTHONOTARY One Courthouse Square • Carlisle, Pennsylvania 17013 - (717) 240-6195 • Fax !7171 1en_4c-7'3