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HomeMy WebLinkAbout13-7474 Supreme Cod 4 Cour of�Commo Pleas For Prothonotary Use Only: Ovil'Cver,Shi et Docket No: Cu berland"` Count y� '4 'N �3 � y The information collected on this form is used solely for court administration purposes. This form does not supplement or replace the filing and service of pleadings or other papers as required by law or rules of court. Commencement of Action: S El Complaint 0 Writ of Summons 0 Petition Transfer from Another Jurisdiction Declaration of Taking E C Lead Plaintiff's Name: Lead Defendant's Name: T Roy L. Galloway Christine Spillane f Dollar Amount Requested: xi within arbitration limits A I re money damages requested? 0 Yes 0 No 1 0 (check one) 0outside arbitration limits I N Is this a Class Action Suit? 0 Yes 0 No Is this an MDJAppeal? 0 Yes S No 1 A Name of Plaintiff /Appellant's Attorney: L Check here if you have no attorney (area Self- Represented [Pro Sel Litigant) M Nature of the Case Place an "X" to the left of the ONE case category that most accurately describes your PRIMARY CASE. If you are making more than one type of claim, check the one that you consider most important. TORT (do not include Mass Tort) CONTRACT (do not include Judgments) CIVIL APPEALS 0 Intentional 0 Buyer Plaintiff Administrative Agencies 0 Malicious Prosecution 0 Debt Collection: Credit Card 0 Board of Assessment ® Motor Vehicle El Debt Collection: Other ® Board of Elections ` I © Nuisance Breach of Contract [] Dept. of Transportation 0 Premises Liability For Professional Services 13 Statutory Appeal: Other ►S 0 Product Liability (does not include mass tort) E 0 Employment Dispute: � ® Slander/Libel/ Defamation Discrimination I C 0 Other: 0 Employment Dispute: Other 0 Zoning Board T 0 Other: �I 0 Other: O MASS TORT 0 Asbestos i N 0 Tobacco 0 Toxic Tort - DES 0 Toxic Tort - Implant REAL PROPERTY MISCELLANEOUS 0 Toxic Waste Ejectment 0 Common Law /Statutory Arbitration i B ®Other: 0 Eminent Domain /Condemnation 0 Declaratory Judgment 0 Ground Rent Mandamus 0 Landlord /Tenant Dispute Non - Domestic Relations Mortgage Foreclosure: Residential Restraining Order PROFESSIONAL LIABLITY 0 Mortgage Foreclosure: Commercial 0 Quo Warranto 0 Dental 0 Partition 0 Replevin 0 Legal 0 Quiet Title 0 Other: i 0 Medical 0 Other: 1 Q Other Professional: i Updated 1/1/2011 C IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA ROY L. GALLOWAY, : NO: 13 - _2V`7 Plaintiff V. :CIVIL ACTION -LAW -< > CHRISTINE SPILLANE,,' Defendant y 7: cj NOTICE TO DEFEND 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 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 PLAINTIFF. 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, GO TO OR TELEPHONE THE OFFICE SET FORTH BELOW. THIS OFFICE ASSIST YOU WITH HIRING A LAWYER. IF YOU CANNOT AFFORD TO HIRE A LAWYER, THIS OFFICE MAY BE ABLE TO PROVIDE YOU WITH INFORMATION ABOUT AGENCIES THAT MAY OFFER LEGAL SERVICES TO ELIGIBLE PERSONS AT A REDUCED FEE OR NO FEE. CUMBERLAND COUNTY BAR ASSOCIATION 32 SOUTH BEDFORD STREET CARLISLE, PA 17013 1- 800 - 990 -9108 717 -249 -3166 an Roy L. Galloway, Esquire ORIGINAL Sup.Ct. # 206841 717 Market Street, Ste. 102 (717) 737 -330 k= Pro se IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA ROY L. GALLOWAY, : NO: Plaintiff V. : CIVIL ACTION -LAW CHRISTINE SPILLANE, Defendant COMPLAINT AND NOW, this 19 day of December, 2013, comes Plaintiff, Roy Galloway, who files the within Complaint; and avers as follows: 1. Plaintiff is Roy Galloway, who is the sole member of a limited liability corporation, The Law Office of Roy Galloway, LLC that provides legal services and is located at 717 Market Street, Suite 102, Lemoyne, PA 17043. 2. Defendant is an adult individual who resides at 310 S. Park Street, Dallastown, York, Pennsylvania, 17313. 3. On January 7, 2013, the parties entered into a written agreement whereby Plaintiff agreed to represent Defendant in a custody action in the York County Court of Common Pleas in exchange for Defendant paying a one -time retainer of $1,000.00 and $250/hour for legal services rendered after the retainer was exhausted. Attached hereto as Exhibit "A" is a copy of the Agreement entered into between the parties. 4. Plaintiff provided legal representation to Defendant, and she was able to secure custody of his child. 5. Defendant has breached the agreement entered into between the parties by failing to pay for services rendered on her behalf. 6. Plaintiff has reached out to Defendant on numerous occasions to resolve this dispute, but Defendant avoids all attempts at communicating with her and has failed to satisfy her financial obligations. 7. While Plaintiff's representation of Defendant was pending in the York County Court of Common Pleas, Plaintiff attempted to mitigate the damages by seeking leave of court to withdraw from Defendant's case because she was not paying for services rendered, but Defendant refused to join in Plaintiff's Motion to Withdraw as she agreed to do in the agreement when there is a default and Plaintiff was forced to continue representing Defendant without being compensated. 8. Defendant acted in bad faith by reaping the benefits of Plaintiff's services, and failing to satisfy her obligations under the contract and refusing to consent to Plaintiff's withdrawal as outlined in the agreement. 9. As a direct result of Defendant's breach of contract, Plaintiff has suffered financial losses in the form of unpaid wages, court costs, attorney fees and interests. 10. At this time, Defendant owes Plaintiff $1,800.00 for past services rendered, court costs, and attorneys fees of $250/hour to Plaintiff in accordance with the attached agreement for bringing the above - captioned action to enforce the terms of the agreement. WHEREFORE, Plaintiff demands judgment against defendant in an amount within the compulsory arbitration limit of $50,000.0, exclusive of interest and costs, counsel fees and other sanctions, which may be awarded under law. Respectfully submitted, LAW OFFICE OF ROY GALLOWAY, LLC oy L. Galloway, Esquire Supreme Ct. ID 206841 717 Market Street, Ste. 102 Lemoyne, PA 17043 (717) 737 -3300 EXHIBIT "A' RETAINER AGREEMENT This Agreement is entered into by and between the LAW OFFICES OF ROY GALLOWAY, (hereinafter "ATTORNEY") and (hereinafter "CLIENT "). CLIENT hires LAW G OFFICES OF ROY GALLOWAY, LLC and any attorneys, law clerks, paralegals, and legal assistants, hired (as employees or independent contractors) now or in the future by the LAW OFFICES OF ROY GALLOWAY, LLC, to do the following legal work: C- CASE CONTROL CLIENT gives ATTORNEY the right to take all steps in this case that the ATTORNEY believes-worth doing, including filing lawsuits or other legal papers. When ATTORNEY believes it is right to do so, ATTORNEY will give way to the CLIENT to make decisions. RESULTS NOT GUARANTEED CLIENT has been told, recognizes and understands that ATTORNEY has made No GUARANTEE promising the success or outcome of this case. HOW FEES ARE PAID CLIENT agrees to pay to ATTORNEY all legal fees figured as follows: ATTORNEY does legal services and CLIENT agrees to pay to ATTORNEY, a minimums„,., v 9' and a NON - REFUNDABLE RETAINER FEE of $ 1 1 DOO. g a this amount is a true retainer fee and its payment by CLIENT to ATTORNEY guarantees that the ATTORNEY will set time aside for this case. CLIENT understands that the non - refundable retainer allows ATTORNEY to limit the number of clients, giving more time for each client's case. CLIENT understands and agrees that ATTORNEY may deposit this retainer into ATTORNEY'S general bank account instead of a CLIENT trust account and that ATTORNEY may use all roy of it. All legal work will be charged against the retainer. You will be billed at an hourly rate of $250 per hour You will be billed at this rate anytime an ATTORNEY works on your file, including but not limited to time spent writing, reviewing, signing letters, file review, legal research, preparing or responding to interrogatories or other information gathering procedures, preparation of court papers, telephone or conference time with CLIENT, relatives, friends or other persons involved in the case, depositions, meetings with experts, travel time from the office and return, court appearances (which include waiting for a judge, the opposing attorney or a courtroom to open up and any other time spent and/or work performed related to CLIENT'S case. FEES BEYOND RETAINER CLIENT has read and understands that this Agreement calls for any and all fees to be figured on an hourly basis and that the total fee can and probably will be more than the retainer paid under this Agreement. EXPERTS The ATTORNEY may suggest using experts, such as investigators, appraisers, accountants, mental health professionals or social workers. CLIENT understands that it is CLIENT's responsibility and CLIENT's responsibility alone, to hire and pay for the experts. It is also CLIENT'S responsibility to keep ATTORNEY informed of the progress made by each expert throughout CLIENT'S case. PAYMENT OF COSTS CLIENT agrees to pay all postage costs, including First Class and Overnight, as needed. Costs include filing fees, service of papers, deposition and transcript costs, appraisals, parking, in addition to express nail, photocopying and faxing. CLIENT will be billed at the rate of $1.50 per page faxed or received. CLIENT will be billed for photocopies at the rate of fifty cents for each page copied. This charge includes staff time spent making copies. CLIENT understands that these monies are in addition to the retainer. CLIENT UNDERSTANDS THAT IT IS ATTORNEY'S POLICY NOT TO ADVANCE ANY COSTS. CLIENT BY SIGNING BELOW, UNDERSTANDS AND AGREES THAT NO PAPERS CAN BE FILED WITH THE COURT OR DEPOSITIONS SCHEDULED OR SERVICE OF PROCESS" MADE OR APPRAISALS OBTAINED UNTIL CLIENT HAS. DEPOSITED THE MONEY INTO ATTORNEYS TRUST ACCOUNT. IF THERE ARE EMERGENCIES WHEN ATTORNEY ADVANCES ANY COSTS, CLIENT SHALL REIMBURSE ATTORNEY IMMEDIATELY UPON ATTORNEY'S REQUEST. FAILURE OF CLIENT TO REIMBURSE ATTORNEY MAY RESULT IN ATTORNEY WITHDRAWING FROM CLIENT'S FILE. PAYMENT OF MONEY IN TRUST FOR COSTS CLIENT gives the right to ATTORNEY to withdraw money from CLIENT's trust account, to pay back ATTORNEY for actual costs paid by the ATTORNEY. At the end of the case, CLIENT also authorizes ATTORNEY to withdraw money from CLIENT's trust account to reimburse ATTORNEY for unpaid legal fees. BILLING a. HOW BILLS ARE FIGURED: Bills will be figured in tenths of one hour. Each tenth of an hour equals six minutes. b. MINIMUM BILLINGS: CLIENT understands that when ATTORNEY is in the office, ATTORNEY charges a minimum of two - tenths hours (12 minutes) for CLIENT's case, including telephone calls, except for reviewing and signing letters which will be billed for one -tenth hour. BILLED ATTORNEY will bill monthly for legal services. Bills will show the time spent on all work, the work that was done and the billing rate. The bill also shows any credits or money left on account as well as any money due now for work done on CLIENT's case. WHEN PAYABLE Bills are payable immediately when received. Bills not paid within thirty (30) days will be charged a late charge at a simple interest rate of one and a half percent (1.5 %) on the monthly balance. CHANGES IN PAYING If CLIENT wants to make partial monthly payments for ATTORNEY's fees, these arrangements MUST be agreed upon IN ADVANCE IN WRITTING, between ATTORNEY and CLIENT. Any arrangements for payment by CLIENT in monthly installments will require CLIENT to sign a Promissory Note. CREDIT CHECK If ATTORNEY agrees to accept monthly payments from CLIENT, a credit check will be necessary. Upon signing this Agreement, CLIENT gives ATTORNEY the right to do a credit check on CLIENT and obtain a - credit report. BAD CHECKS CLIENT agrees to pay a $37.00 service charge, in addition to any and all bank charges, if CLIENT writes a check that is returned for any reason whatsoever, including insufficient funds or stop payment order. POLICY ABOUT NOT PAYING This law firm is willing to arrange a reasonable payment plan for CLIENT after the initial retainer has been used up. However, if CLIENT refuses to pay the bill or make arrangements to pay the bill within thirty (30) days of the bill being sent, ATTORNEY will file a Motion to Withdraw at the earliest possible time and seek to collect fees and costs owed, plus any late charges due by collection or lawsuit. If client defaults on making payments, CLIENT agrees to pay attorney for reasonable attorney's fees necessary to recover unpaid legal fees, including, but not limited to, filing fees to initiate a. suit and costs for ATTORNEY to hire legal counsel to recover fees. Should attorney perform the work to recover unpaid legal fees, client agrees to reimburse ATTORNEY at the above - referenced billable rate, exclusive of interest. BILLING REOUESTS AND COMPLAINTS Unless CLIENT mails to ATTORNEY a written complaint about a bill within 30 days after the date on the envelope, that bill shall be totally acceptable to CLIENT and CLIENT shall pay the full amount without a complaint. CLIENT may ask for a bill at any time. ATTORNEY will mail a bill to CLIENT within 72 hours of any written request (holidays and weekends excluded). LIEN a. Should CLIENT receive any cash or property by- agreement, settlement or Judgment, or Order during or after CLIENT's case, such as money from the sale of a house, business, etc., CLIENT agrees to have this money deposited into ATTORNEY's trust account and CLIENT gives ATTORNEY authority to pay any balance due ATTORNEY out of this money before transferring the balance to CLIENT. CLIENT agrees that ATTORNEY may file and record this LIEN and/ -or file this Agreement. b. In case this Agreement is ended and attorney's fees and/or costs are owed by the CLIENT, ATTORNEY shall have a lien on all property or assets of CLIENT to secure the fees and/or costs. INSURANCE DISCLOSURE This law firm is protected for Professional Malpractice in the amount of $100,000 per claim and $300,000 aggregate. PROFESSIONAL RELATIONSHIPS ATTORNEY understands that it is the wish of the CLIENT to have ATTORNEY represents CLIENT only so long as CLIENT is totally satisfied with the services done by ATTORNEY and the fees and costs charged by ATTORNEY. CLIENT agrees and it is the wish of ATTORNEY to represent only CLIENT's who: a. Are satisfied with the services of ATTORNEY; b. Does what the ATTORNEYS tell CLIENT to do; and c. Pays ATTORNEY for legal work and court costs spent. APPOINTMENTS ONLY CLIENT understands that the ATTORNEY usually sees CLIENTS after making an appointment, except emergencies. Walk -in appointments are not made, unless an emergency exists OR the attorney is not engaged in work on another matter. CLIENT understands that ATTORNEY May from time to time have to change appointments and that this will be done at the earliest possible time. CLIENT further understands that ATTORNEY may have to change an appointment at the last minute Due to unforeseen circumstances. ATTORNEY apologizes in advance for any and all inconveniences this may cause CLIENT. ATTORNEY would appreciate CLIENT notifying ATTORNEY of any appointments CLIENT is unable to keep. CLIENTS RIGHT TO WITHDRAW CLIENT understands that CLIENT may end this Agreement, with or without cause, in writing to ATTORNEY. ATTORNEY shall return the CLIENT's original file promptly after this Agreement ends. CLIENT understands that CLIENT has the right to talk to another lawyer before signing this Agreement. CLIENT agrees that no legal work will be performed by ATTORNEY until the retainer fee is paid in full. RIGHTS OF CLIENT TO INDEPENDENT REVIEW CLIENT understands that there are to be no additions, strike outs, changes or waivers of any kind whatsoever to this Agreement unless the change is in writing and signed by both ATTORNEY and CLIENT. Further, CLIENT understands that this Agreement applies to this case only not to other cases or legal problems. ACTIONS NOT COVERED BY THIS AGREEMENT CLIENT understands that bringing or defending of appeals in the Superior or Supreme Court of Pennsylvania or any other court of competent jurisdiction is not covered by this Agreement regardless of when the need for such actions may arise. COSIGNER LIABILITY By signing below, I understand that I am accepting full responsibility for the legal fees due to Attorney for representing the client. Further, I understand that Attorney may enforce this Agreement against me even if he does not seek to pursue collections or legal action against the client. I understand that Attorney will not share information regarding the case with me, unless the client releases the attorney to share information with me. I understand that the attorney- client relationship is between the Attorney and the client only and no attorney - client relationship is formed by virtue of my payment of legal fees on client's behalf or acceptance of financial responsibility for legal fees. INCREASE IN HOURLY RATES CLIENT understands and agrees that ATTORNEY may change the hourly rates during the term of this Agreement by giving CLIENT thirty (30) days notice In advance in writing. CLIENT swears or affirms that he or she has read, understands and agrees to this contract which is seven (6) pages in length and has been given a copy of it. r. Date: j Client: i r Date: �,� Attorney: v VERIFICATION I verify that the statements in the foregoing Complaint are true and correct. I understand that any false statements made herein are subject to the penalties of 18 Pa. C.S. § 4904 relating to unsworn falsification to authorities. Date: December 19, 2013 oy Galloway, Plaintiff SHERIFF'S OFFICE OF CUMBERLAND COUNTY Ronny R Anderson Sheriff Jody S Smith i n n Chief Deputy ti • e. I fp s i 1,7'7 Richard W Stewart r Solicitor Roy L. Galloway vs. Case Number Christine Spillane 2013-7474 SHERIFF'S RETURN OF SERVICE 12/19/2013 Sheriff Ronny R Anderson, being duly sworn according to law, states he made diligent search and inquiry for the within named Defendant to wit: Christine Spillane, but was unable to locate the Defendant in the Sheriffs bailiwick. The Sheriff therefore deputizes the Sheriff of York, Pennsylvania to serve the within Complaint& Notice according to law. 12/30/2013 The requested Complaint& Notice served by the Sheriff of York County upon Charlene Spillane, Mother, who accepted for Christine Spillane, at 310 S. Park Street,York Township, Dallastown, PA 17313. Richard P. Keuerleber, Sheriff, Return of Service attached to and made part of the within record. SHERIFF COST: $37.46 SO ANSWERS, January 16, 2014 RON R ANDERSON, SHERIFF )SC SHERIFF'S OFFICE OF YORK COUNTY Richard P Keuerleber r,s ¢ oP,,• PETER J. MANGAN, ESQ. Sheriff Solicitor Reuben B Zeager �, Richard E Rice, II Chief Deputy, Operations , c Chief Deputy,Administration ROY L. GALLOWAY Case Number vs. CHRISTINE SPILLANE 13-7474 CIVIL SHERIFF'S RETURN OF SERVICE 12/30/2013 05:55 PM- DEPUTY COREY STRINE, BEING DULY SWORN ACCORDING TO LAW, SERVED THE REQUESTED COMPLAINT& NOTICE BY HANDING A TRUE COPY TO A PERSON REPRESENTING THEMSELVES TO BE CHARLENE SPILLANE, MOTHER, WHO ACCEPTED AS"ADULT PERSON IN CHARGE" FOR CHRISTINE SPILLANE AT 310 S. PARK STREET, DALLASTOWN, PA 17313. 11REY STRINE, DEPUTY SHERIFF COST: $48.44 SO A A S, glid _.— - all _ _ 0 January 13, 2014 RICHA=D P KEUE' EBER, SHERIFF _COMMONWEALTH OF PENNSYLVANIA Notarial Seal Sheila E.Cook,Notary Public City of York,York County My Commission Expires Feb.1,2017 MEloSER,PENNSYLVANIA ASSOCIATION OF NOTARIES NOTARY Affirmed and subscribed to before me this t .4‘) 13TH day of JANUARY 2014 _ , �``/ :;r;un:ySuu ie Sheriff,Tefecsnit 3rac. IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA ROY L. GALLOWAY, : NO: 13-7474 Plaintiff • v. : CIVIL ACTION-LAW . Z CHRISTINE SPILLANE, • Defendant PRAECIPE FOR JUDGMENT TO THE PROTHONOTARY: Enter Judgment in favor of Plaintiff and against Defendant, Christine Spillane, 310 S. Park St., Dallastown, PA 17313 for want of filing an answer to complaint. Access damages as follows: Debt $1,780.00 c f ; -v Interest from contract of 1.5% z m r1 Fri : On monthly balance $161.63 r cx) -)m Attorney's Fees $800.00 ° =c) c)c"" Court Costs: 5(77- Filing Fee $103.75 Cumberland Sheriff fee $37.46 (refunded $62.54) York Sheriff fee $48.44 (refunded $101.56) Filing fee for default judgment $16.50 Total $2,947.78 ( certify that the foregoing assessment of damages is for specified amounts alleged to be duein the complaint and is calculable as a sum certain from the complaint. ( ant to Pa.R.C.P. 237 (Notice of praecipe for final judgment or decree), I certify that a copy of this praecipe has been mailed to each other party who has appeared in the action or to his/her Attorney of Record. c�-�+ I/O A1,34, e___ Mat tec-L J I ( suant to Pa.R.C.P. 237.1, I certify that written notice of the intention to file this praecipe was mailed or delivered to the party against whom judgment is to be entered and to his/her Attorney of Record, if any, after the default occurred and at least ten days prior to the date of the filing of this praecipe and a copy of the notice is attached. Date: ) :3 )/ `{ Signature: Roy 12 alloway, Pro se 717 Market Street, Ste. 102 Lemoyne, PA 17043 (717) 737-3300 Supreme Court ID No. 206841 NOW, q , 2014, JUDGMENT IS ENTERED AS ABOVE. 1 Prothonotary By: Deputy • IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA ROY L. GALLOWAY, : NO: 13-7474 Plaintiff • v. : CIVIL ACTION-LAW CHRISTINE SPILLANE, • Defendant • NOTICE OF PRAECIPE TO ENTER JUDGMENT BY DEFAUALT FOR FAILURE TO FILE PLEADING To: Christine Spillane, 310 S. Park Street, Dallastown, York, Pennsylvania, 17313. Date of Notice: Tuesday, January 21, 2014 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 DAYS FROM THE DATE OF THIS NOTICE,A JUDGMENT MAY BE ENTERED AGAINST YOU WITHOUT A HEARING AND YOU MAY LOSE YOUR PROPERTY OR OTHER IMPORTANT RIGHTS. YOU SHOULD TAKE THIS PAPER TO YOUR LAWYER AT ONCE. IF YOU DO NOT HAVE A LAWYER, GO TO OR TELEPHONE THE OFFICE SET FORTH BELOW. THIS OFFICE CAN PROVIDE YOU WITH INFORMATION ABOUT HIRIING A LAWYER. IF YOU CANNOT AFFORD TO HIRE A LAWYER, THIS OFFICE MAY BE ABLE TO PROVIDE YOU WITH INFORMATION ABOUT AGENCIES THAT MAY OFFER LEGAL SERVICES TO ELIGIBLE PERSONS AT A REDUCED FEE OR NO FEE. CUMBERLAND COUNTY BAR ASSOCIATION 32 SOUTH BEDFORD STREET CARLISLE,PA 17013 CO 1-800-990-9108 717-249-3166 'r AlC By: Roy . Galloway Attorney I.D. # 206841 717 Market St., Ste. 102 Lemoyne, PA 17043 (717) 737-3300 • P p 4 , The Law Office of Roy Galloway, LLC .1111. XII A January 21, 2014 By First Class Mail Ms. Christine Spillane 310 S. Park St. Dallastown, PA 17313 Re: Roy Galloway v. Christine Spillane Docket No. 13-7474 Subject: Notice of Praecipe to Enter Judgment By Default Dear Ms. Spillane: Please be advised that you were served by the York County Sheriffs Department with a Civil Complaint against you on December 30, 2013. You have failed to file an answer to the complaint in the 20 day timeframe established by the Pennsylvania Rules of Civil Procedure. Enclosed please find a Notice of Praeipe For Entry of Judgment By Default For Failure to File Pleading and the Praecipe for Judgment I intend to file against you. If you would like to avoid a judgment being entered against you, the judgment showing up on your credit report, losing personal property such as your automobile, additional attorneys fees and court costs, I would ask that you pay this debt soon. Please note that you contracted that you would be responsible for my attorney's fees in the event you defaulted and I had to enforce this agreement. To date, $585 in attorney's fees have been accrued from me bringing this action, $103.75 in filing fees, and $250.00 for service of the complaint. Not to mention, you may be assessed interest on your balance at 1.5% on your monthly balance \L.:1. . -st "_. t: [ ,:r. ., r.;. P-A - r■45 - - P - . 2 f roygallowaylaw.com Again, you are hereby warned that you have 10 days to file an answer to this Complaint or satisfy your outstanding debt; otherwise, I intend to seek a default judgment against you and may request that the sheriff levy against you personal property. Very truly yours, Roy L. way IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA ROY L. GALLOWAY, : NO: 13-7474 Plaintiff CO v. : CIVIL ACTION-LAW no CHRISTINE SPILLANE, Defendant • 77 r- RULE 236 NOTICE OF FILING JUDGMENT (X)Notice is hereby given that a JUDGMENT in the above-captioned matter has been entered against you in the amount of$2,947.78 on 26i Y • (X)A copy of all documents filed with the Prothonotary in support of the within judgment is/are enclosed. tI onotary Civi ivision By: If you have any questions regarding this Notice, please contact the filing party: Roy L. Galloway, III, Esquire The Law Office of Roy Galloway, LLC 717 Market Street, Ste. 102 Lemoyne, PA 17043 (717) 737-3300 (This Notice is given in accordance with Pa. R.C.P. 236) Notice Sent to: Christine Spillane 310 S. Park St. Dallastown, PA 17313