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HomeMy WebLinkAbout02-0856STEVEN HOWELL, ESQUIRE PLAINTIFF, WILLIAM T. WELSHANS, DEFENDANT 1N THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA CIVIL ACTION - LAW NO. 2002 ~£/,- CIVIL TERM 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 COMPLAINT AND NOTICE ARE SERVED BY ENTERING A WRITTEN APPEARANCE PERSONALLY OR BY 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 PLAINTIFF. YOU MAY LOSE MONEY OR PROPERTY OR OTHER IMPORTANT RIGHTS. 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 2 Liberty Avenue Carlisle, Pennsylvania 17017 ~- ~ (717) 249-3166 J ~~eSr~eane~, PA 17070 (717) 770-1277 Supreme Court I.D. 62063 Attorney for Plaintiff Date: February l4,2002 STEVEN HOWELL, ESQUIRE PLAINTIFF, WILLIAM T. WELSHANS, DEFENDANT IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA CIVIL ACTION - LAW NO. 2002 - 856 CIVIL TERM PRAECIPE TO DISCONTINUE TO THE PROTHONOTARY: Please mark the above captioned case as discontinued upon motion by Plaintiff with all claims being marked as paid in full and satisfied. Date: July 15, 2002 ~..,~ven I~owellq~Esquire 619 Bridge Street New Cumberland, PA 17070 (717) 770-1277 Supreme Court I.D. 62063 Attorney for Plaintiff STEVEN HOWELL, ESQUIRE PLAINTIFF, WILLIAM T. WELSHANS, DEFENDANT iN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA CIVIL ACTION - LAW NO. 2002 -~/CIVIL TERM COMPLAINT 1. Steven Howell, Esquire is an attorney with a principal place of business located at 619 Bridge Street, New Cumberland, Cumberland County, Pennsylvania 17070. 2. Defendant William T. Welshans is an adult individual residing at RD 1, Box 57, Allenwood, Union County, Pennsylvania 17810. 3. On February 5, 2001 Defendant retained Plainfiffto represent him in a child custody case in Percy County docketed to Case Number 2000 - 999. A true and correct copy of the Fee Agreement executed by Defendant on February 5, 2001 is attached hereto as Exhibit "A". 5. On or about November 1, 2001 an invoice attached hereto as Exhibit "B" was mailed to Defendant showing his last payment on 9/25/01 of $100.00. 6. The Invoice for November 1,2001 shows an outstanding balance of $970.00 after all payments are credited for work performed by Plaintiff including a Petition for Special Relief and hearing in Perry County on August 21, 2001. 7. Defendant has refused to pay this invoice or make any partial payments since his last payment on 9/25/01. 8. Defendant was informed on more than one occasion that failure to make payments on the invoice would result in Plaintiff filing a Petition to Withdraw. 9. On January 16, 2002 Plaintiff filed a Petition to Withdraw to which Defendant failed to respond. 10. On February 6, 2002 Plaintiff was granted permission to withdraw by Court Order. 11. Plaintiff has demanded repayment from Defendant and on November 19, 2001 Defendant agree to pay $100.00 every two (2) weeks. 12. Defendant failed to make any payments despite receiving invoices dated November 1, 2001, November 16, 2001 and December 17, 2001. 13. The parties~ Fee Agreement authorizes the imposition of 18% per annum interest on all unpaid balances. Interest at ¢48 per diem is due from December 1, 2001 and a claim is made for $35.52 in interest from December 1, 2001 through February 13, 2002 plus a per diem charge of ¢48 thereafter. 14. The parties' Fee Agreement authorizes Plaintiff to recover ail costs of any collection suit including reasonable attorneys' fees and a claim is made for $200.00 to draft and file this Complaint with all other work to be performed at $200.00 per hour. 15. The total amount due Plaintiff as of February 13, 2002 is: $ 970.00 $ 200.00 $ 35.52 $1,205.52 Invoice Baiance 11/1/01 Attorneys Fees Interest From 12/1/01 to 2/13/01 (74 Days at .48 Per Diem) WHEREFORE, Plaintiff respectfully requests this Honorable Court to enter judgment in its favor and against Defendant in the amount $1,205.52 plus interest at ¢48 per diem from February 14, 2002, an award of reasonable counsel fees and court costs. BY: .~ /S~ven Howell,,'Esqui J619 Bridge Street New Cumberland, PA 17070 (717) 770-1277 Supreme Court I.D. 62063 Attorney for Plaintiff VERIFICATION I hereby verify that the statements made in the foregoing document are tree and correct to the best of my knowledge, information and belief. I understand that false statements herein are made subject to the penalties of 18 Pa. C.S.A. §4904, relating to unswom falsification to authorities. Ste ~ Da .~February 14, 2002 R~e 1.5 (b) of~e P~~ R~es of~ofessiun~l Co~du~ gnve~ing a ~e~s profes~on~ re~on~b~es ~at was adopted by ~e Supreme Co~ ofp~0niz on October 1987, ~d is effect~e on Ap~ 1, 1988, as ~m~dcd ~om t~c to t~c by ~cc~ ~der provides: "When the lawyer has not regularly represented the client, the basis or rate of the fee shall be comm, micated to the client, in writing, within a reasonable time after commencing representation." The undersigned, V~\k_; ~.___.~ ~ \ q ~x I~_ ~ , hereinai~er referred to as, "client," hereby retains and employs STEVEN HOWELL, Esquire, to be my attorney for me and in my name, place and stead, to represent me and provide legal services, including all required appropriate research, investigation, conferences, interviews, negotiation, searches, correspondence, telephone conferences, dratting, advice and litigation in the following matter: STEVEN HOWELL, Esquire, will maintain time records and the client may request an itemized bill at any time. The billing rate is Two Hundred Dollars ($200.00) per hour. You will be billed for the time expended by me relating to your case with the minimum charges in six (6) - minute intervals for all work performed, including, but not limited to, office consultations, telephone conversations with kou and any attorneys, correspondence, drafting of STEVEN HOWELL, ESQUIRE Fee Agreem~t/Pag¢ 2 documents, research, negotiations, court time, travel, and any other work performed on client's behalf. It is our policy to receive a retainer from all clients, which is placed in an escrow account and billed against while pur~fing your case. Further, regardless of the retainer paid by the client, client agrees that $500.00 of any retainer is non-refundable once a file has been opened. During the course of the particular matter for which representation has been accepted, if the billing charges exceed the amount in the retainer, client will be asked to replenish the retainer in the amount of $500.00 as well as to pay the periodic billing in full. You will be charged interest on any unpaid balance which is more than thirty (30) days overdue. Interest will be computed at the rate of 1 1/2% per month (18% per annum). A $25.00 service fee will be charged for any check returned because of insufficient funds. We reserve the right in case of unpaid billing statements, upon notification to you, to withdraw from further representation of you and the expenditure of time on your behalf. All bills as submitted are to be paid IN FULL t~romptl¥ upon receipt. Legal costs and expenses incurred are always the obligation of and are to be paid by the client. It is our policy to require all clients to pay in advance on account of known court costs and/or filing fees. Unused costs may be applied to any balance due for legal fees. STEVEN HOWELL, Esquire, shall have the authority to make advanced payments on client's behalf of such amounts as they shall determine best in representing client in these proceedings which advanced payment shall be for expenses, including, but not limited to, toll telephone charges, STEVEN HOWELL, ESQUIRE Fee Agreement/Page 3 photocopies, excess postage, Federal Express mail, travel expenses, deposition expenses, Court costs, accounting and appraisal fees, and fees and expenses of other experts, which are deemed necessary to assist in the preparation and trial or the proper handling of the client's case in the matter for which they are being retained. Our clients are encouraged to discuss our fee arrangements, the progress of their legal matter or the detail of a particular bill. We try to do what is proper and fair. We base our relationship with you on mutual confidence and respect. Client acknowledges that no guarantees have been made as to the final disposition of any phase ofthi.q matter or matters for which STEVEN HOWELL, Esquire, has been retained. I/We hereby authorize Steven Howell, Esquire, or any credit bureau or other investigative agency employed by him> now or at any time in the future, to order and obtain a credit report bom a reporting bureau or fxom any source supplying credit information pertaining to my/our credit and financial responsibility. Fax Statement: This Document and any amendments thereto, may be executed in multiple counterparts by the parties and delivered by way of transmission through a facsimile (FAX) machine and such counterparts shall have the same legal enforceability and binding effect as though it were signed by all parties in off,hal feral In the event that client fails to make payments for costs and expenses and a collection suit is commenced, client agrees that Attorney Howell shall be entitled to recover reasonable attorneys' fees as well as court costs incurred as a result of the collection suit. Client hereby acknowledges receipt of a copy of this Agreement. STEVEN HOWELL, ESQUIRE Fee Agreement/Page 4 IN WITNESS Wi~REOF, and intending to be legally bound, I have hereunto set my hand and seal this day of ,20 ~ (Seal) Client's Social Security Number Client's Social Security Number (Seal) Client's Date of Birth Client's Date of Birth The above appointment and Agreement is hereby approved and accepted this of ~::~ I'~ ~t' x ,20 O\ 3'" day STEVEN HOWELL, ESQUIRE BY: ~ /,/619 Bridge Street New Cumherlsnd, PA 17070 (717) 770-1277 (717) 770-1278 FAX Steven Howell Attorney At Law 619 Bric[ge Street New Cumberlanc[, Pennsylvania 17070 717-770-1277 717-770-1278 Telecopier November 1,2001 William Welshans RD 1, Box 57 Allenwood, PA 17810 For Professional Services (From 8/1/01 to 11/1/01): August 6, 2001 August 14, 2001 August 15, 2001 August 16, 2001 August 21, 2001 August 22, 2001 September 5, 2001 October 1,2001 October 5, 2001 October 15, 2001 October 31, 2001 November 1, 2001 Draft ltr to Atty McGuire (.1 Hours) Draft Petition for Special Relief on home schooling (.5 Hours) Present Petition to Judge Rehkamp; conference w/Atty Wevodau and Judge Rehkamp (.5 Hours) Telecon from client; telecon to school; telecon to client; review fax (.5 Hours) Meet client; prepare questions and exhibits (3.0 Hours) Draft ltr to Atty McGuire with request for information (.25 Hours) Review fax from Atty McGuire; forward to client (.1 Hours) Telecon w/client on faxed documents (.5 Hours) Draft ltr to Atty McGuire (.2 Hours) Telecon w/client (.25 Hours) Review fax from Atty McGuire; forward to client; telecon w/client on fact that new order changes the old orders and removes time for client; recommended modification which client.declined (.25 Hours) Review fax from client; draft ltr to Judge Rehkamp (.2 Hours) SUMMARY OF INVOICE Legal Fees Prior Invoice Subtotal Less Payments $ $ TOTAL NOW DUE $ $1,270.00 (6.35 Hours at $200.00 Per Hour) $ 400.00 (7/31/01) $1,670.00 $ 200.00 (8/6/01) , $ 200.00(8/14/01) 200.00 (8/22/01) 100.00 (9/25/01) 970.00 SHERIFF'S RETURN - OUT OF COUNTY CASE NO: 2002-00856 P COMMONWEALTH OF PENNSYLVANIA: COUNTY OF CUMBERLAND HOWELL STEVEN VS WELSHANS WILLIAM T R. Thomas Kline , Sheriff or Deputy Sheriff who being duly sworn according to law, says, that he made a diligent search and and inquiry for the within named DEFENDANT , to wit: WELSHANS WILLIAM T but was unable to locate Him deputized the sheriff of UNION in his bailiwick. He therefore County, Pennsylvania, to serve the within COMPLAINT & NOTICE On April 12th , 2002 , this office was in receipt of the attached return from UNION Sheriff's Costs: Docketing Out of County Surcharge Dep Union County 18.00 9.00 10.00 12.00 .00 49.00 04/12/2002 STEVEN HOWELL So answers] j// _ ~.-~f/ R. ~Th°n[~ ~i~irle ~ Sheriff of Cumberland County Sworn and subscribed to before me this /&~ day of ~ 3~2- A.D. / /- Pr0th~n~tafy' OUT OF COUNTY DKT. PAGE IN THE COURT OF COMMON PLEAS 17TH JUDICIAL DISTRICT UNION COUNTY, PENNSYLVANIA STEVEN HOWELL ESQ. VS WILLIAM T. WELSHANS NO: 02-856 CIVIL ACTION COMPLAINT UNION COUNTY SHERIFF'S RETURN And now APR 4,, 2002 1 hereby certify and return that I served a copy of the above described , upon , named defendant by personally handing to , at , Union Cotmty, Pennsylvania, on, at .M. a true and correct copy'ofthe above described , and made known to , the contents of the same. AS PER YOUR CONVERSATION THE WRIT IS BEING RETURNED TO YOUR OFFICE NOT SERVED JOHN P. SCHRAWDER, SHERIFF By: - - UNION COUNTY, PA. ROBERT L ULMER / DEPUTY SHERIFF PLAINTWF'S ATTORNEY: STEVEN HOWELL, 619 BRIDGE ST. NEW CUMBERLAND, PA. 17070 DEPOSIT $50.00 RECEIPT # 1730760 REFUND $ CHECK $ SHERIFF'S FEES. DOCKET $ 9.00 ;ERVICE $ SURCHARGE $ EXTRA SERVICE $ AFFIDAVIT $ ,..~, 00 CO MILEAGE $ DEPUTY TIME $ DEPUTIZATION $ CO COSTS $ Commonw~f Pennsylvania: C,0unV] of UniOn : Sworn to and subscribed before me . / Yrotn~r~ EBERHART MyCo~i~no~ & Cle~ ~ Cour~ [ ~sbu~, Union Count, PA [M~ Commission ~lms 1M Mort Jan 2006 TO: FAX #: FROM: STEVEN I~OWELL ATTORNEY AY LAW 619 BR~OGE STRE~ ~W CUMBERLA~, PE~SYLVA~ 17070 717-770-1277 ~ 717.770-1278 F~CS~E TRANSM~ t~STEV~N HOWELL, ESOUIRE SL~YECT: TOTAL PAGES, INCLUDING THIS COVER SI-IEET: _ If you do not receive the total number of pages, or ffthcre are problems with traasmisslon, please call thc t¢Iephone number Listed above, IMPORTANT NOrIC~ The in.forn~tion contained in this me~ag~ {$ £onfi#gntla~ (and may be attorney privileged), mteocled only for the usc of the individual or entity flamed above, ffthe reader of this message is not the intended recipient, you are hereby noticed that any dtsaemln~tion or dJ-cttibutioa of this cor~,~,mioation to anyone other than ~e intended reciptealt is atriotly prolu'btted. Lfyou have received this ¢ommunioation ia error, please notLay us by telephone immediately *.ad return the ari~.~_at message to ua at the above ad&tess via the U,S. mail, Thutk you. Return this fozm to Clanberland County Sheriff's office. In The Court of Common Pleas of Cumberland County, Pennsylvania SERVE: Steven Howell VS. Willi~n T. Welshans same No. 02 856 civil Now, February 22, 2002 , I, SHERIFF OF CUMBERLAND COUNTY, PA, do hereby deputize the Sheriff of union County to execute this Writ, this deputation being made at the request and risk of the Plaintiff. Sheriff of Cumberland County, PA Now, within Affidavit of Service ,20 ,at o'clock M. served the upon at by handing to and made known to copy of the original So answers, the contents thereof. Sworn and subscribed before me this __ day of ., 20 Sheriff of County, PA COSTS SERVICE MILEAGE AFFIDAVIT STEVEN HOWELL, ESQUIRE PLAINTIFF, WILLIAM T. WELSHANS, DEFENDANT IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA CIVIL ACTION - LAW NO. 2002 _~'L CIVIL TERM 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 COMPLAINT AND NOTICE ARE SERVED BY ENTERING A WRITTEN APPEARANCE PERSONALLY OR BY 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 PLAiNTIFF. YOU MAY LOSE MONEY OR PROPERTY OR OTHER IMPORTANT RIGHTS. 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 2 Liberty Avenue Carlisle, Pennsylvania 17012 ~- (717) 249-3166~~ ' BY: /~ev~en ~o~we'~s/q~uir; ' jJ 619 Bridge Street ~ New Cumberland, PA 17070 (717) 770-1277 Supreme Court I.D. 62063 Attomey for Plaintiff Date: February 14, 2002 TRUE ( OPY I: OM RC--GORD STEVEN HOWELL, ESQUIRE PLAINTIFF, WILLIAM T. WELSHANS, DEFENDANT IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA CIVIL ACTION - LAW NO. 2002 - CIVIL TERM COMPLAINT 1. Steven Howell, Esquire is an attorney with a principal place of business located at 619 Bridge Street, New Cumberland, Cumberland County, Pennsylvania 17070. 2. Defendant William T. Welshans is an adult individual residing at RD 1, Box 57, Allenwood, Union County, Pennsylvania 17810. 3. On February 5, 2001 Defendant retained Plaintiff to represent him in a child custody case in Perry County docketed to Case Number 2000 - 999. A true and correct copy of the Fee Agreement executed by Defendant on February 5, 2001 is attached hereto as Exhibit "A". 5. On or about November 1,2001 an invoice attached hereto as Exhibit "B" was mailed to Defendant showing his last payment on 9/25/01 of $100.00. 6. The Invoice for November 1, 2001 shows an outstanding balance of $970.00 after all payments are credited for work performed by Plaintiff including a Petition for Special Relief and hearing in Perry County on August 21, 2001. 7. Defendant has refused to pay this invoice or make any partial payments since his last payment on 9/25/01. 8. Defendant was informed on more than one occasion that failure to make payments on the invoice would result in Plaintiff filing a Petition to Withdraw. 9. On January 16, 2002 Plaintiff filed a Petition to Withdraw to which Defendant failed to respond. 10. On February 6, 2002 Plaintiff was granted permission to withdraw by Court Order. 11. Plaintiff has demanded repayment from Defendant and on November 19, 2001 Defendant agree to pay $100.00 every two (2) weeks. 12. Defendant failed to make any payments despite receiving invoices dated November 1, 2001, November 16, 2001 and December 17, 2001. 13. The parties' Fee Agreement authorizes the imposition of 18% per annum interest on all unpaid balances. Interest at ¢48 per diem is due from December 1, 2001 and a claim is made for $35.52 in interest from December 1,2001 through February 13, 2002 plus a per diem charge of ¢48 thereafter. 14. The parties' Fee Agreement authorizes Plaintiff to recover all costs of any collection suit including reasonable attorneys' fees and a claim is made for $200.00 to draft and file this Complaint with all other work to be performed at $200.00 per hour. 15. The total amount due Plaintiff as of February 13, 2002 is: $ 970.00 $ 200.00 $1,205.52 Invoice Balance 11/1/01 Attorneys Fees Interest From 12/1/01 to 2/13/01 (74 Days at .48 Per Diem) WHEREFORE, Plaintiff respectfully requests this Honorable Court to enter judgment in its favor and against Defendant in the amount $1,205.52 plus interest at ¢48 per diem from February 14, 2002, an award of reasonable counsel fees and court costs. BY: z-//~ Ste/ven Howell,,'l~squire J 619 Bridge Street // New Cumberland, PA 17070 (717) 770-1277 Supreme Court I.D. 62063 Attorney for Plaintiff VERIFICATION I hereby verify that the statements made in the foregoing document are true and correct to the best of my knowledge, information and belief. I understand that false statements herein are made subject to the penalties of 1 $ Pa. C.S.A. §4904, relating to unswom falsification to authorities. Steyen Howell, Es~ire Da .~February 14, 2002 Rule 1.5 (b) of the Pennsylvania Kules of Profession, al Con. duct governing a lawyer's professional responsibilities that was adopted by the Supreme Court of Pennsylvania on October 16, 1987, and is effective on April 1, 1988, as amended from time to time by special Order provides: "When the lawyer has not regularly represented the client, the basis or rate of the fee shall be communicated to the client, in writing, within a reasonable time after commencing representation." The undersigned, V~\k ~ ~ LLt~ \ e, ~ I~_ ~ , hereinaiter referred to as, "client," hereby retains and employs STEVEN HOWELL, Esquire, to be my attorney for me and in my name, place and stead, to represent me and provide legal services, including all required appropriate research, investigation. conferences, interviews, negotiation, searches, correspondence, telephone conferences, drafting. advice and litigation in the following matter: STEVEN HOWELL, Esquire, will maintain time records and the client may request an itemi?ed bill at any time. The billing rate is Two Hundred Dollars ($200.00) per hour. You will be billed for the time expended by me relating to your ~ase with the minimum charges in six (6)- minute intervals for all work performed, including, but not limited to, office consultations, telephone conversations with Fou and any attorneys, correspondence, drafting of STEVEN HOWELL, ESQUI]LE Fee Agreement/Page 2 documents, research, negotiations, court time, travel, and any other work performed on client's behalf.. It is our policy to receive a retainer from all clients, which is placed in an escrow account and billed against while pursafing your case. Further, regardless of the retainer paid by the client, client agrees that $500.00 of any retainer is non-refundable once a file has been opened During the course of the particular matter for which representation has been accepted, if the billing charges exceed the amount in the retainer, client will be asked to replenish the retainer in the amount of $500.00 as well as to pay the periodic billing in full. You will be charged interes~ on any unpaid balance which is more than thirty (30) days overdue. Interest will be computed at the rate of 1 1/2% per month (18% per annum). A $25.00 service fee will be charged for any check returned because ofinsa~flqcient funds. We reserve the fight in case of unpaid billing statements, upon notification to you, to withdraw from further representation of you and the expenditure of time on your behalf. All bills as submitted are to be paid IN FULL promptly upon receipt. Legal costs and expenses incurred are always the obligation of and are to be paid by the client. It is our policy to require all clients to pay in advance on account of known court costs and/or filing fees. Unused costs may be applied to any balance due for legal fees. STEVEN HOWELL, Esquire, shall have the authority to make a~lvanced payments on client's behalf of such amounts as they shah determine best in representing client in these proceedings which advanced payment shall be for expenses, including, but not limited to, toll telephone charges, STEVEN HOWELL, ESQUIRE Fee Agreement/Page 3 photocopies, excess postage, Federal Express mail, travel expenses, deposition expenses, Court costs, accounting and appraisal fees, and fees and expenses of other experts, which are deemed necessary to assist in the preparation and trial or the proper handling of the client's case in the matter for which they are being retained. Our clients are encouraged to discuss our fee arrangements, the progress ofthek legal matter or the detail of a particular bill. We try to do what is proper and fair. We base our relationship with you on mutual confidence and respect. Client acknowledges that no guarantees have been made as to the final disposition of any phase of this matter or matters for which STEVEN HOWELL, Esquire, has been retained. I/We hereby authorize Steven Howell, Esquire, or any credit bureau or other investigative agency employed by him~ now or at any time in the future, to order and obtain a credit report fxom a reporting bureau or from any source supplying credit information pertaining to my/our credit and financial responsibility. Fax Statement: This Document and any amendments thereto, may be executed in multiple counterparts by the parties and delivered by way of transmission through a facsimile (FAX) machine and such counterparts shall have the same legal enforceability and binding effect as though it were signed by all parties in ofibnal form. In the event that client fails to make payments (or costs and expenses and a collection suit is commenced, client agrees that Attorney Howell shall be entitled to recover reasonable attorneys' fees as well as court costs incurred as a result of the collection suit. Client hereby acknowledges receipt of a copy of this Agreement. STEVEN HOWELL, ESQUIRE Fee Agreement/Page 4 IN WITNESS WltF. REOF, and intending to be legally bound, I have hereunto set my hand and seal this day of ,20 ~ (Seal) Client's Social Security Number Client's Date o£ Bi~d~ Client's Social Security Number Client's Date of Birth (Seal) The above appointment and Agreement is hereby approved and accepted this .3'- day STEVEN HOWELL, ESQUI]I.E S~en Hov~ll~ Esquire //619 Bridge Street New Cumberland, PA 17070 (717) 770-1277 (717) 770-1278 FAX Steven Howell Attorney At Law 619 BricIRe Street New Cuml, erlam[, Pennsylvania 17070 717-770-1277 717-770-1278 Telecopier November 1,2001 William Welshans RD 1, Box 57 Allenwood, PA 17810 For Professional Services (From 8/1/01 to 11/1/01): August6,2001 Augustl4,2001 August l5,2001 Augustl6,2001 August 21,2001 August 22, 2001 September 5, 2001 October 1, 2001 October 5, 2001 October 15, 2001 October 31, 2001 November 1,2001 Draft ltr to Arty McGuire (. 1 Hours) Draft Petition for Special Relief on home schooling (.5 Hours) Present Petition to Judge Rehkamp; conference w/Atty Wevodau and Judge Rehkamp (.5 Hours) Telecon from client; telecon to school; telecon to client; review' fax (.5 Hours) Meet client; prepare questions and exhibits (3.0 Hours) Draft ltr to Atty McGuire with request for information (.25 Hours) Review fax from Atty McGuire; forward to client (. 1 Hours) Telecon w/client on faxed documents (.5 Hours) Draft ltr to Atty McGuire (.2 Hours) Telecon w/client (.25 Hours) Review fax from Atty McGuire; forward to client; telecon w/client on fact that new order changes the old orders and removes time for client: recommended modification which client.declined (.25 Hours) Review fax from client: draft Itt to Judge Rehkamp (.2 Hours) SUMMARY OF INVOICE Legal Fees Prior Invoice Subtotal Less Payments $ $ TOTAL NOW DUE $ $1,270.00 (6.35 Hours at $200.00 Per Hour) $ 400.00 (7/31/01) $1,670.00 $ 200.00 (8/6/01) $ 200.00 (8/14/01) ~ 200.00 (8/22/01) '" 100.00 (9/25/01) 970.00