HomeMy WebLinkAbout05-1171rtrvrvsrwwrvtN
COURT OF COMMON PLEAS
916 Judicial District, County Of Cumberland
NOTICE OF APPEAL
FROM
MAGISTERIAL DISTRICT JUDGE JUDGMENT
COMMON PLEAS No. QS'- - / /'7 / U t
NOTICE OF APPEAL
Notice is given that the appellant has filed in the above Court of Common Pleas an appeal from the judgment rendered by the Magisterial District
Judge on the date and in the case referenced below.
Gates, Halbruner & Hatch, P.C. i 09-1-02 I Robert V. Manlove
1013 Mumma Rd. Lemoyne PA 17043
DATE OF JUDGMENT IN THE CASE OF(PkutubM (Defendant)
02/03/2005 Gates, Halbruner & Hatch, P.C. a Countryside HomeWorks, Inc. et al.
DOCKET NO. SIGNA URE OFA PELLANi TTORNEVO AGENT
CV-0000642-04 / C1
i
This block will be signed ONLY when this notation is required under Pa. I appellant was Claimant .C.P.D No. 10 (6) inaction
R.C.P.D.J. No. 10088.
This Notice of Appeal, when received by the Magisterial District Judge, will before a Magisterial District Judge, A COM AINT MUST BE FILED
operate as a SUPERSEDEAS to the judgment for possession in this case. within twenty
(20) days after filing the NOTICE of APPEAL.
Signature of Prothonotary or Deputy
PRAECIPE TO ENTER RULE TO FILE COMPLAINT AND RULE TO FILE
(This section of form to be used ONLY when appellant was DEFENDANT (see Pa.R.C.P.D.J. No. 1001(7) in action before Magisterial District
Judge. IF NOT USED, detach from copy of notice of appeal to be served upon appellee.
PRAECIPE: To Prothonotary
Enter rule upon appellee(s), to file a complaint in this appeal
Name of appellee(s)
(Common Pleas No. ) within twenty (20) days after service of rule or suffer entry of judgment of non pros.
Signature of appellant or attorney or agent
RULE: To appellee(s)
Name of appellee(s)
(1) You are notified that a rule is hereby entered upon you to file a complaint in this appeal within twenty (20) days after the date of service
of this rule upon you by personal service or by certified or registered mail.
(2) If you do not file a complaint within this time, a JUDGMENT OF NON PROS MAY BE ENTERED AGAINST YOU.
(3) The date of service of this rule if service was by mail is the date of the mailing.
Date: _j 20
Signature of Prothonotary or Deputy
YOU MUST INCLUDE A COPY OF THE NOTICE OF JUDGMENT/TRANSCRIPT FORM WITH THIS NOTICE OF APPEAL.
AOPC 312-05
ry rJ
7
' y ?Yr
Cl) `7 CY G'?
6\ ay
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M ? 1'
COMMONWEALTH OF PENNSYLVANIA
nr)i mITv nF- CUM11ZR .amn
Dist. No.:
09-1-02
MW Name: Hon.
ROBERT V. MANLOVE
Add`e55 1901 STATE ST
CAMP HILL, PA
Telephone: (717 ) 761-0583 17011-0000
NOTICE OF JUDGMENT/TRANSCRIPT
CIVIL CASE
PLAINTIFF: NAME and ADDRESS
rGATES, HALBRUNER Cc HATCH, P.C
1013 NWKA ROAD APT/STE 100
LEMOYNE, PA 17043
L J
vs.
DEFENDANT: NAME and ADDRESS
rcoIINTRYSIDE HOMZWORKS INC, ET AL.
122 LANCASTER PIKE SOUTH
WILLOW STREET, PA 17584
GATES, HALBRUNER & HATCH, P.C. L J
1013 MDMM , ROAD APT/STE 100 Docket No.: CV-0000642-04
LEMOYNE, PA 17043 Date Filed: 12/27/04
THIS IS TO NOTIFY YOU THAT:
Judgment: FOR PLAINTIFF
® Judgment was entered for: (Name) r1aTita, TraT.n'gTrNrgy r< Trayrg, P _ A
® Judgment was entered against: (Name) enPR, c- Davin
in the amount of $ 2, Sot _ en on:
D Defendants are jointly and severally liable.
(Date of Judgment) -2-In1/es
(Date & Time)
Damages will be assessed on:
El This case dismissed without prejudice.
lease $ Amount of Judgment $
Amount of Judgment Subject to
AttachmenU42 Pa.C.S. § 8127 $
Portion of Judgment for physical
damages arising out of residential
Judgment Costs $
Interest on Judgment $
Attorney Fees $
Total $
Post Judgment Credits $
Post Judgment Costs $
------------
Certified Judgment Total $
ANY PARTY HAS THE RIGHT TO APPEAL WITHIN 30 DAYS AFTER THE ENTRY OF JUDGMENT BY FILING A NOTICE
OF APPEAL WITH THE PROTHONOTARY/CLERK OF THE COURT OF COMMON PLEAS, CIVIL DIVISION. YOU
MUST INCLUDE A COPY OF THIS NOTICE OF JUDGMENTITRANSCRIPT FORM WITH YOUR NOTICE OF APPEAL.
EXCEPT AS OTHERWISE PROVIDED IN THE RULES OF CIVIL PROCEDURE FOR MAGISTERIAL DISTRICT JUDGES, IF THE
JUDGEMENT HOLDER ELECTS TO ENTER THE JUDGMENT IN THE COURT OF COMMON PLEAS, ALL FURTHER PROCESS MUST
COME FROM THE COURT OF COMMON PLEAS AND NO FURTHER PROCESS MAY BE ISSUED BY THE MAGISTERIAL DISTRICT JUDGE.
UNLESS THE JUDGMENT IS ENTERED IN THE COURT OF COMMON PLEAS, ANYONE INTERESTED IN THE JUDGMENT MAY FILE
A REQUEST FOR ENTRY OF SATISFACTION WITH THE MAGISTERIAL DISTRICT JUDGE IF THE JUDGMENT DEBTOR PAYS IN FULL,
SETTLES, OR OTHERWISE COMPLIES WITH THE JUDGMENT.
(l Date I I " l/ r ba Y CSC , Magisterial District Judge
I certify t? tt this i rue a re c y of t re d roc ings containing the judgment.
S Od Date agisterial District Judge
My commission expires first Monday of January, 2006. SEAL
AOPC 315-05 DATE PRINTED: 2/03/05 11:15:16 AM
COMMONWEALTH OF PENNSYLVANIA
nntlNTYnFF CUMERLAUn
Mag. Dist No.'.
09-1-02
MDJ Name: Hon.
ROBERT V. MANLOVE
Address'. 1901 STATE ST
CAMP HILL, PA
Telephone: (717) 761-0583 17011-0000
NOTICE OF JUDGMENT/TRANSCRIPT
PLAINTIFF: CIVIL CASEntlADDRess NAME rGATES, HALERUNER & HATCH, P.C 7
1013 MOMMA ROAD APT/STS 100
LEMOYNE, PA 17043
L VS.
DEFENDANT: NAME and ADDRESS
r-COUNTRYSIDE HOMEMOR&S INC, ET AL. ,
122 LANCASTER PINE SOUTH
WILLOW STREET, PA 17584
GATES, HALERUNER 4 HATCH, P.C. L J
1013 MUMMA ROAD APT/STE 100 Docket No.: CV-0000642-04
LEMOYNE, PA 17043 Date Filed: 12/27/04
THIS IS TO NOTIFY YOU THAT:
Judgment: to8 PLAINTIF1r
® Judgment was entered for: (Name) t2ATTlQ - AAT.RlorrNn Q a WATrIT' P C.
® Judgment was entered against: (Name) t nUNTyyATny Rommmo1x8 TNC
in the amount of $ 2y n92 0_0_ on:
? Defendants are jointly and severally liable.
? Damages will be assessed on:
? This case dismissed without prejudice.
Amount of Judgment Subject to
? Attachment/42 Pa.C.S. § 8127 $
lease $ (Date of Judgment) 203 /05
? Portion of Judgment for physical
damages arising out of residential
(Date & Time)
Amount of Judgment $
Judgment Costs $
Interest on Judgment $
Attorney Fees $
Total $
Post Judgment Credits $
Post Judgment Costs $
Certified Judgment Total $
ANY PARTY HAS THE RIGHT TO APPEAL WITHIN 30 DAYS AFTER THE ENTRY OF JUDGMENT BY FILING A NOTICE
OF APPEAL WITH THE PROTHONOTARY/CLERK OF THE COURT OF COMMON PLEAS, CIVIL DIVISION. YOU
MUST INCLUDE A COPY OF THIS NOTICE OF JUDGMENT/TRANSCRIPT FORM WITH YOUR NOTICE OF APPEAL.
EXCEPT AS OTHERWISE PROVIDED IN THE RULES OF CIVIL PROCEDURE FOR MAGISTERIAL DISTRICT JUDGES, IF THE
JUDGEMENT HOLDER ELECTS TO ENTER THE JUDGMENT IN THE COURT OF COMMON PLEAS, ALL FURTHER PROCESS MUST
COME FROM THE COURT OF COMMON PLEAS AND NO FURTHER PROCESS MAY BE ISSUED BY THE MAGISTERIAL DISTRICT JUDGE.
UNLESS THE JUDGMENT IS ENTERED IN THE COURT OF COMMON PLEAS, ANYONE INTERESTED IN THE JUDGMENT MAY FILE
A REQUEST FOR ENTRY OF SATISFACTION WITH THE MAGISTERIAL DISTRICT JUDGE IF THE JUDGMENT DEBTOR PAYS IN FULL,
SETTLES, OR OTHERWISE COMPLIES WITH THE JUDGMENT.
Date Magisterial District Judge
I certify t Pat thi a tru orrect p gs containing the judgment.
V/ Date =z4n?e?isterial District Judge
My commission expires first Monday of January, 2006 . SEAL
AOPC 315-05 DATE PRINTED: 2/03/05 11:14:43 AN
Lj
PROOF OF SERVICE OF NOTICE OF APPEAL AND RULE TO FILE COMPLAINT
(This proof of service MUST BE FILED WITHIN TEN (10) DAYS AFTER filing of the notice of appeal. Check applicable boxes.)
COMMONWEALTH OF PENNSYLVANIA
COUNTY OF Cumberland ; ss
AFFIDAVIT: I hereby (swear) (affirm) that I served
l cvil? t
OS -11-71
® a copy of the Notice of Appeal, Common Pleas No.
(date of service) March 3, 2005,
, upon the Magisterial District Judge designated therein on
? by personal service ® by (certified) (registered) mail,
sender's receipt attached hereto, and upon the appellee, (name) Countryside HomeWorks Inc and C David Cope,
on
March 3, 2005 ?by personal service®
sender's receipt attached hereto.
(SWORN) (AFFIR D) AND SUBSCRIBED BEFORE ME
THIS 3 D,A. ch, 2005
?2
S' ure of official before whom affidavit was made
Notarial Seal
Teri L. Walker, Notary Public
Lemoyne Boro Cumberland County
6MeV My Commission Expres"1 20, 2CN)7
by (certified) (registered) mail,
Siy ure f affiant
Je ey L. Shaffer
Legal Assistant
Gates, Halbruner& Hatch, P.C.
Title of official
My commission expires on , 20
AOPC 312A - 05
COMMONWEALTH OF PENNSYLVANIA
COURT OF COMMON PLEAS
9th Judicial District, County Of Cumberland
NOTICE OF APPEAL
FROM
MAGISTERIAL DISTRICT JUDGE JUDGMENT
COMMON PLEAS No.
NOTICE OF APPEAL
Notice is given that the appellant has filed in the above Court of Common Pleas an appeal from the judgment rendered by the Magisterial District
Judge on the date and in the case referenced below.
Gates, Halbruner & Hatch, P.C. 09-1-02 Robert V. Manlove
1013 Mumma Rd. Lemoyne PA 17043
02/03/2005 Gates, Halbruner & Hatch, P.C. vs Countryside HomeWorks, Inc. et al.
DOCKET No. SIGNWUREOF PELLANT UWATTORNEY O AGENT
CV-0000642-04
This block will be signed ONLY when this notation is required under Pa. I appellant was Claimant .C.P.D . No. 10 (6) in action
R.C.P.D.J. No. 10088.
This Notice of Appeal, when received by the Magisterial District Judge, will before a Magisterial District Judge, A COM AWT MUST BE FILED
operate as a SUPERSEDEAS to the judgment for possession in this case. within twenty
(20) days after filing the NOTICE of APPEAL.
Spnatum of Prothonotary or Deputy
PRAECIPE TO ENTER RULE TO FILE COMPLAINT AND RULE TO FILE
(This section of form to be used ONLY when appellant was DEFENDANT (see Pa.R.C.P.D.J. No. 1001(7) in action before Magisterial District
Judge. IF NOT USED, detach from copy of notice of appeal to be served upon appellee.
PRAECIPE: To Prothonotary
Enter rule upon
Name of appellee(s)
(Common Pleas No.
COPY
RULE: To
Name of appellee(s)
, appellee(s)
(1) You are notified that a rule is hereby entered upon you to file a complaint in this appeal within twenty (20) days after the date of service
of this rule upon you by personal service or by certified or registered mail.
(2) If you do not file a complaint within this time, a JUDGMENT OF NON PROS MAY BE ENTERED AGAINST YOU.
(3) The date of service of this rule if service was by mail is the date of the mailing.
Date: _, 20
of Prothonotary or Deputy
YOU MUST INCLUDE A COPY OF THE NOTICE OF JUDGMENT/TRANSCRIPT FORM WITH THIS NOTICE OF APPEAL.
appellee(s), to file a complaint in this appeal
) within twenty (20) days after service of rule or suffer entry of judgment of non pros.
Signature of appellant or attorney or agent
AOPC 312-05
COMMONWEALTH OF PENNSYLVANIA
Oni inITV nF- CUMBERLAND
Mag. Dist. No-
09-1-02
MDJ Name'. Hon.
ROBERT V. MANLOVE
Adaaas. 1901 STATE ST
CAMP HILL, PA
Telephone: (717 ) 761-0583 17011-0000
ATTORNEY FOR PLAINTIFF :
NOTICE OF JUDGMENT/TRANSCRIPT
CIVIL CASE
PLAINTIFF: NAME and ADDRESS
FGATES, HALBRUNER R HATCH, P.C
1013 MUMKh ROAD APT/STE 100
LEMOYNE, PA 17043
L
Vs.
DEFENDANT: NAME and ADDRESS
rCOUNTRYSIDE HOMEWORKS INC, ET AL.
122 LANCASTER PIKE SOUTH
WILLOW STREET, PA 17584
L J
ALBERT N. PETERLIN
GATES HALBRUNER Docket No.: CV-0000642-04
1013 MUMMA RD STE 100 Date Filed: 12/27/04
LEMOYNE, PA 17043
THIS IS TO NOTIFY YOU THAT:
Judgment: FOR PLAINTIFF
® Judgment was entered for: (Name) GA-l Ar ByTn gtt rC Ra rr;T c,
® Judgment was entered against: (Name) i-cl c• DAVTn
in the amount of $ ?,%q2-nn on: (Date of Judgment) 2/na/ns.
Defendants are jointly and severally liable. (Date & Time)
F Damages will be assessed on:
El This case dismissed without prejudice.
I Amount of Judgment Subject to
Attachmel Pa.C.S. § 8127 $
Portion of Judgment for physical
damages arising out of residential
lease $
Amount of Judgment
Judgment Costs
Interest on Judgment
Attorney Fees
Total
Post Judgment Credits
Post Judgment Costs
Certified Judgment Total $
ANY PARTY HAS THE RIGHT TO APPEAL WITHIN 30 DAYS AFTER THE ENTRY OF JUDGMENT BY FILING A NOTICE
OF APPEAL WITH THE PROTHONOTARY/CLERK OF THE COURT OF COMMON PLEAS, CIVIL DIVISION. YOU
MUST INCLUDE A COPY OF THIS NOTICE OF JUDGMENTITRANSCRIPT FORM WITH YOUR NOTICE OF APPEAL.
EXCEPT AS OTHERWISE PROVIDED IN THE RULES OF CIVIL PROCEDURE FOR MAGISTERIAL DISTRICT JUDGES, IF THE
JUDGEMENT HOLDER ELECTS TO ENTER THE JUDGMENT IN THE COURT OF COMMON PLEAS, ALL FURTHER PROCESS MUST
COME FROM THE COURT OF COMMON PLEAS AND NO FURTHER PROCESS MAY BE ISSUED BY THE MAGISTERIAL DISTRICT JUDGE.
UNLESS THE JUDGMENT IS ENTERED IN THE COURT OF COMMON PLEAS, ANYONE INTERESTED IN THE JUDGMENT MAY FILE
A REQUEST FOR ENTRY OF SATISFACTION WITH THE MAGISTERIAL DISTRICT JUDGE IF THE JUDGMENT DEBTOR PAYS IN FULL,
SETTLES, OR OTHERWISE COMPLIES WITH THE JUDGMENT.
U tt.r
Date ,*1aglSter7t&f•D+strict:ludge
•. YL .._.1
I certify that this i true arttl =orrect cppy oft xd Facc"dic>Q lil judgment.
i tJ Date __ ft mot' 1-f, 61 tistSV DlstrlciJudge
My commission expires first Monday of January, 2006 . SEAL
AOPC 315-05 DATE PRINTED: 2/03/05 11:15:16 AM r """"
COMMONWEALTH OF PENNSYLVANIA
r:ni Irl nn. CUMBERLAND
Mag. Dist. No.'.
09-1-02
MDJName: Hon.
ROBERT V. MANLOVE
Anil 1901 STATE ST
CAMP HILL, PA
Telephone: (717) 761-0583 17011-0000
ATTORNEY FOR PLAINTIFF :
ALBERT N. PETERLIN
GATES BALBRUNER
1013 MUMMA RD STE 100
LEMOYNE, PA 17043
NOTICE OF JUDGMENT/TRANSCRIPT
PLAINTIFF: CIVIL CASE
NAME and ADDRESS
rGATES, HALBRUNER & HATCH, P.C
1013 MOMMA ROAD APT/STE 100
LEMOYNE, PA 17043
L
J
VS.
DEFENDANT: NAME and ADDRESS
rCOUNTRYSIDE HOMEWORSS INC, ET AL. 7
122 LANCASTER PIKE SOUTH
WILLOW STREET, PA 17584
L J
Docket No.: CV-0000642-04
Date Filed: 12/27/04
THIS IS TO NOTIFY YOU THAT:
Judgment: FOR PLAINTIFF
® Judgment was entered for: (Name) =Till) 1TAT.nR0N8R b YFA-ril n _ y
® Judgment was entered against: (Name) cnONTRYSSDR RoMWORRS INC
in the amount of $ 2, 11 _ Din. on: (Date of Judgment) 2/na1
? Defendants are jointly and severally liable. (Date & Time)
Damages will be assessed on:
? This case dismissed without prejudice.
? Amount of Judgment Subject to
Attachment/42 Pa.C.S. § 8127 $
Portion of Judgment for physical
damages arising out of residential
lease $
Amount of Judgment
Judgment Costs
Interest on Judgment
Attorney Fees
Total
Post Judgment Credits $
Post Judgment Costs $
Certified Judgment Total $
ANY PARTY HAS THE RIGHT TO APPEAL WITHIN 30 DAYS AFTER THE ENTRY OF JUDGMENT BY FILING A NOTICE
OF APPEAL WITH THE PROTHONOTARY/CLERK OF THE COURT OF COMMON PLEAS, CIVIL DIVISION. YOU
MUST INCLUDE A COPY OF THIS NOTICE OF JUDGMENT/TRANSCRIPT FORM WITH YOUR NOTICE OF APPEAL.
EXCEPT AS OTHERWISE PROVIDED IN THE RULES OF CIVIL PROCEDURE FOR MAGISTERIAL DISTRICT JUDGES, IF THE
JUDGEMENT HOLDER ELECTS TO ENTER THE JUDGMENT IN THE COURT OF COMMON PLEAS, ALL FURTHER PROCESS MUST
COME FROM THE COURT OF COMMON PLEAS AND NO FURTHER PROCESS MAY BE ISSUED BY THE MAGISTERIAL DISTRICT JUDGE.
UNLESS THE JUDGMENT IS ENTERED IN THE COURT OF COMMON PLEAS, ANYONE INTERESTED IN THE JUDGMENT MAY FILE
A REQUEST FOR ENTRY OF SATISFACTION WITH THE MAGISTERIAL DISTRICT JUDGE IF THE JUDGMENT DEBTOR PAYS IN FULL,
SETTLES, OR OTHERWISE COMPLIES WITH THE JUDGMENT.
' Date , Nlagis tnf"blstrict Judge
I certify that thil a true and correct copy of;Rhe rdcdi f` proceed ngs ct£ntai leg the judgment.
i Date Wag sterial Tijsttict Judge
My commission expires first Monday of January, 2006. SEAL
AOPC 315-05 DATE PRINTED: 2/03/05 11:14:43 AM
+.:? 1. "! T_ ?1A
'CJ ` } C7
CY7
PROOF OF SERVICE OF NOTICE OF APPEAL AND RULE TO FILE COMPLAINT
(This proof of service MUST BE FILED WITHIN TEN (10) DAYS AFTER filing of the notice of appeal. Check applicable boxes.)
COMMONWEALTH OF PENNSYLVANIA
COUNTY OF Cumberland as
AFFIDAVIT: I hereby (swear) (affirm) that I served
® a copy of the Notice of Appeal, Common Pleas No.05-1171 Civil Term, upon the Magisterial District Judge
designated therein on
(date of service) March 4, 2005,
on
? by personal service ® by (certified) (registered) mail,
sender's receipt attached hereto, and upon the appellee, (name) Countryside HomeWorks, Inc., and C. David Cope,
March 4, 2005 ?by personal service®
sender's receipt attached hereto.
(SWORN) (AFFIRMED) AND SUBSCRIBED BEFORE ME
THIS 4/DAY OF March, 2005
Signature of official before whom affidavit was made
Notarial Seal
Victoria M. Rankin, Notary Public
Lemoyne Bore, Cumberland County
My Commission Expires Aug. 27, 2006
Member PennsvNn??a nr?..r??rr„?. rX'Jnt?Mas
Title of official
My commission expires on), 200 by (certified) (registered) mail,
Sign rre affiant
Jeffrey L. Shaffer
Legal Assistant
Gates, Halbruner& Hatch, P.C.
AOPC 312A - 05
CERTIFIED MAIL, RECEIF
(Domestic Mail Only; No Insurance Cove!a;
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p Return Reciept Fee Here
(Endorsement Required)
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(Endoreement Required)
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p Ced@led Fee
p Postmark
p Reeiept Fee
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mrv
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(Endorseement Required)
p Restricted Delivery Fee
to (Endorsement Required)
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Total Postage & Fees
$
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ri it
MONWEALTH OF PENNSYLVANIA
COURT OF COMMON PLEAS
9`" Judicial District, County Of Cumberland
FROM
MAGISTERIAL DISTRICT JUDGE JUDGMENT
NOTICE OF APPEAL
I Jotice is given that the appellant has filed in the above Court of Common Pleas an appeal from the judgment rendered by the Magisterial District
udge on the date and in the case referenced below.
IA ME OF APPELLAN I
gates, Halbruner & Hatch, P.C. 09-1-02 Robert V. Manlove
-'""- -
I ,DDRESS OF APPELLAN I 111.
1013 Mumma Rd. Lemoyne PA 17043
rA I t yr dw?rvmrv, ,
)2/03!2005 Gates, Halbruner & Hatch, P.C. Countryside HomeWorks, Inc. et at.
1 -V-0000642-04
I This block will be signed ONLY when this notation is required under Ha.
R.C.P.D.J. No. 10088.
This Notice of Appeal, when received by the Magisterial District Judge, will
Dperate as a SUPERSEDEAS to the judgment for possession in this case.
Signature of Pmrhonotary or Deputy
COMMON PLEAS No. (JS
was
before a Magisterial District Judge, A
within
(20) days after filing the NOTICE of APPEAL.
in action
MUST BE FILED
twenty
PRAECIPE TO ENTER RULE TO FILE COMPLAINT AND RULE TO FILE '
(This section of form to be used ONLY when appellant was DEFENDANT (see Pa.R.C.P.D.J. No. 1001(7) in acflor) beforel Magl p' I District
Judge. IF NOT USED, detach from copy of notice of appeal to be served upon appellee. -r
PRAECIPE: To Prothonotary
_ }tom
co
Enter rule upon appellee(s), to file a comply in tihl? appeal
Name of appellees)
(Common Pleas No.
) within twenty (20) days after service of rule or suffer entry of judgment of non pros.
? Cop y
Signature of appellant or attorney oragent
RULE: To , appellee(s)
Name of appellee(s)
(1) You are notified that a rule is hereby entered upon you to file a complaint in this appeal within twenty (20) days after the date of service
of this rule upon you by personal service or by certified or registered mail.
(2) It you do not file a complaint within this time, a JUDGMENT OF NON PROS MAYBE ENTERED AGAINST YOU.
(3) The date of service of this rule if service was by mail is the date of the mailing.
)ate: __, 20
Prothonotary or Deputy
YOU MUST INCLUDE A COPY OF THE NOTICE OF JUDGMENTliRANSCRIPT FORM WITH THIS NOTICE OF APPEAL.
NOTICE OF APPEAL
OPC 312-05
COMMONWEALTH OF PENNSYLVANIA
.ni INTy nF- CUMBERLAND
Mag. Disc No.'
09-1-02
MDJ Name. Hon.
ROBERT V. MANLOVE
AO&essr 1901 STATE ST
CAMP HILL, PA
laleph,ma: (717) 761-0583 17011-0000
ATTORNEY FOR PLAINTIFF :
NOTICE OF JUDGMENTITRANSCRIPT
PLAINTIFF CIVIL CASE
NAME and ADDRESS
rGATES, HAI,BRDNER & HATCH, P.C
1013 MIIMMA ROAD APT/STS 100
LEMOYNE, PA 17043
L J
VS.
DEFENDANT: NAME and ADDRESS
FCOUNTRYSIDE HOMSWORAS INC, ET AL.
122 LANCASTER PIKE SOUTH
WILLOW STREET, PA 17584
ALBERT N. PETERLIN L J
GATES BALBRUNER Docket No.: CV-0000642-04
1013 MUMMA RD STE 100 Date Filed: 12/27/04
LEMOYNE, PA 17043
THIS IS TO NOTIFY YOU THAT:
Judgment: FOR PLAINTIFF
® Judgment was entered for: (Name) r_ATxG TiAT.RRTTN'RR z nATrFr, p r
® Judgment was entered against: (Name) caps, C DAVID
in the amount of $ 2,592-nn on: (Date of Judgment) 2103 ns
Defendants are jointly and severally liable. (Date & Time)
El Damages will be assessed on:
El This case dismissed without prejudice.
Amount of Judgment Subject to
Attachment/42 Pa.C.S. § 8127 $
Portion of Judgment for physical
damages arising out of residential
lease $
Post Judgment Credits
Post Judgment Costs
$ .00
Certified Judgment Total $ ANY PARTY HAS THE RIGHT TO APPEAL WITHIN 30 DAYS AFTER THE ENTRY OF JUDGMENT BY FILING A NOTICE
OF APPEAL WITH THE PROTHONOTARY/CLERK OF THE COURT OF COMMON PLEAS, CIVIL DIVISION. YOU
MUST INCLUDE A COPY OF THIS NOTICE OF JUDGMENTITRANSCRIPT FORM WITH YOUR NOTICE OF APPEAL.
EXCEPT AS OTHERWISE PROVIDED IN THE RULES OF CIVIL PROCEDURE FOR MAGISTERIAL DISTRICT JUDGES, IF THE
JUDGEMENT HOLDER ELECTS TO ENTER THE JUDGMENT IN THE COURT OF COMMON PLEAS, ALL FURTHER PROCESS MUST
COME FROM THE COURT OF COMMON PLEAS AND NO FURTHER PROCESS MAY BE ISSUED BY THE MAGISTERIAL DISTRICTJUDGE.
UNLESS THE JUDGMENT IS ENTERED IN THE COURT OF COMMON PLEAS, ANYONE INTERESTED IN THE JUDGMENT MAY FILE
A REQUEST FOR ENTRY OF SATISFACTION WITH THE MAGISTERIAL DISTRICT JUDGE IF THE JUDGMENT DEBTOR PAYS IN FULL,
SETTLES, OR OTHERWISE COMPLIES WITH THE JUDGMENT.
} i l
rf Date aMagiaterlai,Distrlct Judge
I certify that this i.5,a true and correct copy of th_2 cecdrdfgs procedingSJ of Irig the judgment.
/ Date "? ?t?. /-? r I1 glstQr fOlstnciJudge
My commission expires first Monday of January, 2006. "•'I SEAL
AOPC 315-05 ..,,,,.,
DATE PRINTED: 2/03/05 11:15:16 AM
Amount of Judgment
Judgment Costs
Interest on Judgment
Attorney Fees
COMMONWEALTH OF PENNSYLVANIA
rnl INTY nF CUMBERLAND
M, 0"I No..
09-1-02
MDJName: Hon.
ROBERT V. MANLOVE
Addrese: 1901 STATE ST
CAMP HILL, PA
eano,e: (717) 761-0583 17011-0000
ATTORNEY FOR PLAINTIFF :
NOTICE OF JUDGMENT/TRANSCRIPT
PLAINTIFF: CIVIL CASNAME E dnDDRE55
FGATES, HALBRUNER & BATCH, P.C
1013 MUMMA ROAD APT/STE 100
LEMOYNE, PA 17043
L
vs.
DEFENDANT: Nnme and AOOaess
FCOUNTRYSIDE HOMEWOR%S INC, ET AL.
122 LANCASTER PIKE SOUTH
WILLOW STREET, PA 17584
L J
ALBERT N. PETERLIN
GATES HALBRUNER Docket No.: CV-0000642-04
1013 MUM MA RD STE 100 Date Filed: 12/27/04
LEMOYNE, PA 17043 esa
THIS IS TO NOTIFY YOU THAT:
Judgment: FOR PLAINTIFF
® Judgment was entered for: (Name) r_ATizq, T7AT RRUxER_ z BATCH, P - n
® Judgment was entered against: (Name) rnamTRYernF trnNFwnRxc INC
in the amount of $ 2 w2 _ nn on: (Date of Judgment) 2103/n5
? Defendants are jointly and severally liable- (Date & Time)
? Damages will be assessed on:
? This case dismissed without prejudice.
Amount of Judgment Subject to
? Attachment/42 Pa.C.S. § 8127 $
Portion of Judgment for physical
damages arising out of residential
lease $
Amount of Judgment $
00
2,500.
Judgment Costs $ 92.00
Interest on Judgment $ .00
Attorney Fees $ .00
Total $ 2,592.00
Post Judgment Credits $
Post Judgment Costs $
Certified Judgment Total $
ANY PARTY HAS THE RIGHT TO APPEAL WITHIN 30 DAYS AFTER THE ENTRY OF JUDGMENT BY FILING A NOTICE
OF APPEAL WITH THE PROTHONOTARY/CLERK OF THE COURT OF COMMON PLEAS, CIVIL DIVISION. YOU
MUST INCLUDE A COPY OF THIS NOTICE OF JUDGMENTTRANSCRIPT FORM WITH YOUR NOTICE OF APPEAL.
EXCEPT AS OTHERWISE PROVIDED IN THE RULES OF CIVIL PROCEDURE FOR MAGISTERIAL DISTRICT JUDGES, IF THE
JUDGEMENT HOLDER ELECTS TO ENTER THE JUDGMENT IN THE COURT OF COMMON PLEAS, ALL FURTHER PROCESS MUST
COME FROM THE COURT OF COMMON PLEAS AND NO FURTHER PROCESS MAY BE ISSUED BY THE MAGISTERIAL DISTRICT JUDGE.
UNLESS THE JUDGMENT IS ENTERED IN THE COURT OF COMMON PLEAS, ANYONE INTERESTED IN THE JUDGMENT MAY FILE
A REQUEST FOR ENTRY OF SATISFACTION WITH THE MAGISTERIAL DISTRICT JUDGE IF THE JUDGMENT DEBTOR PAYS IN FULL,
SETTLES, OR OTHERWISE COMPLIES WITH THE JUDGMENT.
r
Date - -- - Maglst?nsPDistrict, Judge
I certify that thLsis a true and correct copy of,Rhe r6i5aU. o ff, e proceedings c ntaiN' g the-judgment.
Date`` /fv7aglsterial bistrict Judge
My commission expires first Monday of January, 2006. ter, SEAL
AOPC 315-05 DATE PRINTED: 2/03/05 11:14:43 AM
? ?
t-,
'
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?., _
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Gates, Halbruner & Hatch, P.C.
By: Albert N. Peterlin, Esquire
PA Attorney ID No. 84180
1013 Mumma Road, Suite 100
Lemoyne, PA 17043-1144
(717) 731-9600
(717) 731-9627 facsimile
a.oeterlin @ oateslawfirm.com
IN THE COURT OF COMMON PLEAS
FOR CUMBERLAND COUNTY, PENNSYLVANIA
------------------------------------------------------X
GATES, HALBRUNER & HATCH, P.C., :
Plaintiff,
Civil Action
Case No. 05-1171 Civil Term
V.
COUNTRYSIDE HOMEWORKS, INC.
and C. DAVID COPE,
Defendants.
COMPLAINT
Plaintiff, Gates, Halbruner & Hatch, P.C., hereby complains against Defendants,
Countryside HomeWorks, Inc. and C. David Cope, and in support thereof avers as
follows.
1. PARTIES
1. Plaintiff, Gates, Halbruner & Hatch, P.C. ("Plaintiff or the "Law Firm") is a
professional business corporation with offices located at 1013 Mumma Road,
Suite 100, Lemoyne, Cumberland County, Pennsylvania, 17043.
2. Defendant, Countryside HomeWorks, Inc. ("Countryside HomeWorks"), is
a Pennsylvania business corporation with offices located at 124 Lancaster Pike
South, Willow Street, Lancaster County, Pennsylvania, 17584.
3. Defendant, C. David Cope ("Cope"), is an adult individual currently
residing at 122 Lancaster Pike South, Willow Street, Lancaster County, Pennsylvania,
17584.
II. JURISDICTION AND VENUE
4. Jurisdiction is proper pursuant to 42 Pa.C.S.A. § 931(a) where the instant
action involves substantial state questions.
5. Venue is proper pursuant to 42 Pa.C.S.A. § 931(c) and Pa.R.C.P. No.
1006(a) where the cause of action arose or a transaction or occurrence took place out
of which the cause of action arose in Cumberland County, Pennsylvania.
III. BACKGROUND
6. The Law Firm provided certain legal services to Defendants regarding a
civil litigation case instituted against them by James Frazier and Mariella Frazier.
Defendants failed to remit payment for legal services rendered to them in this matter
from June 2004 through and including October 2004 despite demand. A true and
correct copy of the relevant invoices are attached hereto as Exhibit "A" and
incorporated herein by reference as though set forth in full.
7. The Law Firm provided certain legal services to Defendants regarding
2
General Business matters. Defendants failed to remit payment for legal services
rendered to them in these matters from July 2003 through and including September
2004 despite demand. A true and correct copy of the relevant invoices are attached
hereto as Exhibit "B" and incorporated herein by reference as though set forth in full.
8. The Law Firm provided certain legal services to Defendants regarding the
Galen Miller Incorporated matter. Defendants failed to remit payment for legal services
rendered to them in this matter in September 2004 despite demand. A true and correct
copy of the relevant invoices are attached hereto as Exhibit "C" and incorporated herein
by reference as though set forth in full.
IV. CAUSES OF ACTION
COUNT I - BREACH OF CONTRACT
9. Plaintiff incorporates paragraphs 1 through 8 herein by referenced as
though set forth in full.
10. A written contract, including fee letters and numerous invoices, existed
between Plaintiff and Defendants. A true and correct copy of the relevant fee letters
are attached hereto as Exhibits "D" and "E", respectively and incorporated herein by
reference as though set forth in full.
11. Defendants failed to satisfy their obligations as set forth in the fee letters
and numerous invoices by failing to remit payment.
12. As a result of Defendants' default on their obligations, Plaintiff suffered
damages in the amount of three thousand, four hundred ninety-three and 02/100
dollars ($3,493.02).
COUNT II - QUANTUM MERUIT
3
13. Plaintiff incorporates paragraphs 1 through 8 herein by referenced as
though set forth in full.
14. Plaintiff conferred a benefit upon Defendants by providing legal services
as set forth above.
15. Defendants appreciated the benefit of the legal services provided to them
without paying for all of the legal services rendered on their behalf.
16. Defendants accepted and retained the benefit of the legal services
provided by Plaintiff.
17. A written contract does not cover the subject as to which recovery is
sought.
18. It would be inequitable for Defendants to retain the benefit of the legal
services provided to them by Plaintiff without payment of the value of the services
rendered.
V. PRAYER FOR RELIEF
Plaintiff, Gates, Halbruner & Hatch, P.C. respectfully requests this Court enter
judgment in its favor and against Defendants, Countryside HomeWorks, Inc. and C.
David Cope, for compensatory damages in the amount of three thousand, four hundred
ninety-three and 02(100 dollars ($3,493.02), plus interest, attorney's fees, costs and
such other relief as the Court deems just and proper.
Respectfully Submitted,
GATES, HALBRUNER & J4A,TCH, P.C.
Dated: March 10, 2005 By:
4
Fxh?b?? ?
Gates, Halbruner & Hatch, P.C.
1013 Mumtua Road
Suite #100
Lemoyne, PA 17043
(717) 248-6909
Federal I.D. #30-0000518
Countryside HOmeWorks, Inc.
David C. Cope
122Iancaster Pike South
Willow Street PA 17584
INVOICE
litigation - Jarres & Marietta Frazer
Invoice Date March 28, 2003
Period Finding March 15, 2003
Invoice No. 23462
PAYMENT DUEUPON RECEIPT OF STATEMENT
All overdue accounts will be assessed finance charges of 1.5% per month.
We now accept the following credit cards for payment: Airerican Express, Discover, Mastercard & Visa.
Professional Fees
3/4/2003 ANP TELEPHONE CALL TO CLIENT.
3/5/2003 ANP RECIIVED EXECUTED RETAINER AGREEMENT AND
RETAINER FAX TO OPPOSING COUNSEL.. PREPARED
ENTRY OF APPEARANCE TELEPHONE CALL. TO COURT
ADMINISTRATORS OFFICE TELEPHONE CALL TO
CHESTER COUNTYBAR ASSOCIATION. PREPARED
CERTIFICATE OF SERVICE LETTER TO
PROTHONOTARYS OFFICE FAX TO COURT
ADMINISTRATOR'S OFFICE
0.30 @ 100.00/hr
1.00 @ 100.00/hr
30.00
100.00
3/7/2003 ME H CONFERENCE WITH ANP RE CONSTRUCTION
LITIGATION ISSUES FOR DAVID COPE
3/7/2003 ANP RECEIVED FAX FROM MARY ELLEN H. ALIEN,
ESQUIRE REVIEWED PROPOSED SCHEDULING ORDER.
MEETING W ITH MEH. TELEPHONE CALL TO MARY
MEN H. ALLEN, ESQUIRE LEFT DETAILED VOICE
MESSAGE TELEPHONE CALL FROM MARY ELLEN H.
A=, ESQUIRE WENT OVER PROPOSED SCHEDULING
ORDER. TELEPHONE CALL TO PENNSYLVANIA HOME
BUILDERS ASSOCIATION. TELEPHONE CALL TO
CHFSTFR-DELAWARE CHAPTER OF PENNSYLVANIA
HOME BUILDERS ASSOCIATION. TELEPHONE CALL TO
TASA REGARDING EXPERT WITNESSES. LETTER TO
CLIENT.
0.20 @ 150.00/hr
I.00 @ 100.00/hr
30.00
100.00
3/11/2003 ANP RECTIVED NOTICE FROM COURT ADMINISTRATOR 0.30 @ 100.00/hr 30.00
REGARDINGC. DAVID COPES ADDRESS. TELEPHONE
CALL TO PROTHONOTARYS, THEY WANT SOMETHING
IN WRITING. PRAECIPE TO PROTHONOTARY. LETTER
TOPROTHONOTARY.
Page: 2
Gates, Halbruuer & Hatch, P.C.
Litigation -Jarnes & Mariella Frazer
3/11/2003 ANP TELEPHONE CALL TO RON KOBELAN, ARCHITECT
REGARDING SERVING AS AN EXPERT.
3/12/2003 ANP TELEPHONE CALL FROM RON KOBELIN (EXPERT).
TELEPHONE CALL TO CLIENT. TELEPHONE CALL TO
RON KOBELIN.
3/13/2003 ANP REVIEWED COMPLAINT. RESEARCHED AVA11 ABLE
PRELIMINARY OBJECTIONS.
3/13/2003 ANP REVIEWED COMPLAINT. REVIEWED CONTRACT.
REVIEWED CONSENT PETITION. RESEARCHED
CONVERSION AND JURISDICTION OF COURT WHERE
THERE IS AN AGREEMENT TO ARBITRATE PREPARED
PRELIMINARY OBJECTIONS. REVISED PRELIMINARY
OBJECTIONS.
0.30 @ 100.00/hr 30.00
0.50 @ 100.00/hr 50.00
1.00 @ 100.001hr 100.00
4.00 @ 100.00/hr 400.00
Sub-total Fees: 870.00
Payments
3/28/2003 Payment Trust application.
870.00
Sub-total Payments: 870.00
Trust Account
Beginning Balance: 0.00
3/6/2003 2,000.00
3/28/2003 Trust application. -870.00
Ending Balance: 1,130.00
Total Current Billing: 870.00
Previous Balance Due: 0.00
Total Now Due: 0.00
Current Over30 Over60 Over90
870.00 0.00 0.00 0.00
PLEASE VISIT OUR WEBSITE AT W W W.GATESLA W FIRM.COM
Gates, Halbruner & Hatch, P.C.
1013 Mununa Road
Suite # 100
Lemoyne, PA 17043
(717) 248-6909
Federal I.D. #03-0379998
INVOICE
Countryside HomeWorks, Inc.
C. David Cope
1221ancaster Pike South
Willow Street PA 17584
litigation - James & Mariella Frazer
Invoice Date April 28, 2003
Period Ending April 15, 2003
Invoice No. 23995
PAYMENT DUE UPON RECEIPT OF STATEMENT
All overdue accounts will be assessed finance charges of 1.5% per nnonth.
We now accept the following credit cards for payrrent: Discover, Mastercard & Visa.
Professional Fees
2/5/2003 ANP MEETING WITH CLIEN'T'. PREPARED FILE REVIEWED 1.00 @ 100.00/hr 100.00
DOCUMENTS.
3/18/2003 ANP REVISED PRELIMINARY OBJECTIONS. PREPARED 4.00@ 100.00/hr 400.00
MEMORANDUM OF LAW IN SUPPORTTHEREOF.
REVIEWED CASE L A W REGARDING ARBITRATION.
RESEARCHED STANDARD FOR PIERCINGTHE
CORPORATE VE IL
3/20/2003 ANP VOICE MESSACEFROM CLIENT CANCELLING 0.30 @ 100.00/hr 30.00
APPOINTMENT. TELEPHONE CALL TO CLIENT REGARDING
RE-SCHEDULING.
3/23/2003 ANP RESEARCHED ELEMENTS OF FRAUDULENT INDUCEMENT. 12.00 @ 100.001hr 1,200.00
RESEARCHED ELEMENTS OF CONVERSION. RESEARCHED
ELEMENTS OF UTPCPL RESEARCHED "GIST OF ACTION"
EXCEPTION. RESEARCHED "ECONOMIC LOSS"
EXCEPTION. REVISED PRELIMINARY OBJECTIONS.
REVISED BRIEF IN SUPPORT OF PRELIMINARY
OBJECTIONS.
3/24/2003 ANP REVISED PO'S AND BRIEF. PREPARED PO'S AND BRIEF FOR 1.00 @ 100.00/hr 100.00
FILING (NOTICE TO PLEAD, CERTIFICATES OF SERVICE,
VERIFICATION ETC.).
3/25/2003 ANP MEETING WITH CLIENT. 1.40 @ 100.00/hr 140.00
3/25/2003 ANP REVISED PRELIMINARY OBJECTIONS. REVISED BRIEF. 1.50 @ 100.00/hr 150.00
PREPARED PROPOSED ORDERS. REVISED CERTIFICATES
OF SERVICES. REVISED PRAECIPE FOR DETERMINATION.
3/26/2003 MEH CONFERENCE WITH ANP RE PROCEDURAL ISSUFS. 0.20 @ 150.00/hr 30.00
Page: 2
Gates, Hal bruner & Hatch, P.C.
Litigation - James & Mariella Frazer
3/26/2003 ANP FINAL REVISIONS TO PRELIMINARY OBJECTIONS. 2.00 Co) 100.00/hr 200.00
PREPARED FOR FILING. LETTER TO PROTHONOTARY.
Sub-total Fees: 2,350.00
FScpenses
3/5/2003 LONGDISTANCECHARGES. 0.13
3/5/2003 LONG DISTANCE CHARGES. 0.26
3/5/2003 LONG DISTANCE CHARGES. 0.39
3/5/2003 LONGDISTANCECHARGES. 0.39
3/5/2003 LONGDISTANCE CHARGES. 0.39
3/7/2003 LONG DISTANCE CHARGES. 0.39
3/7/2003 LONG DISTANCE CHARGES. 0.91
3/7/2003 LONGDISTANCE CHARGES. 0.26
3/11/2003 LONG DISTANCE CHARGES. 0.52
3/12/2003 LONG DISTANCE CHARGES. 0.13
3/25/2003 LONG DISTANCE CHARGES. 0.13
3/25/2003 LONG DISTANCE CHARGES. 0.26
3/2612003 LONGDISTANCECHARGES. 0.52
3/26/2003 LONGDISTANCECHARGES. 0.13
3/26/2003 LONG DISTANCE CHARGES. 0.13
3/26/2003 LONG DISTANCE CHARGES. 0.26
3/27/2003 PAID TO: FEDERAL EXPRESS CORPORATION 16.46
3/27/2003 PAID TO: GANCOM -PHOTOCOPYING BLUEPRINTS. 7.64
3/31/2003 MILEAGE TO AND FROM GANCOM - PICK UP COPIES. 1.44
Sub-total Expenses: 30.74
Payments
4/28/2003 Payirent Trust application. 1,130.00
Sub-total Pay rents: 1,130.00
Page: 3
Crates, Halhruner & Hatch, P.C.
Litigation - James & Mariella Frazer
Trust Account
Beginning Balance: 1,130.00
4128/2003 Trust application.
-1,130.00
Ending Balance: 0.00
Total Current Billing: 2,380.74
Previous Balance Due: 0.00
Total Now Due: 1,250.74
Current Over30 Over60
2,380.74 0.00 0.00
Over 90
0.00
PLEASE VISIT OUR W EBSITE AT W W W .GATESLA W FIRM.COM
Gates, Halbruner & Hatch, P.C.
1013 Mumma Road
Suite #100
1Pmoyne, PA 17043
(717) 248-6909
Federal I.D. #03-0379998
Countryside HomeWorks, Inc.
C. David Cope
122 UncasterPike South
Willow Street PA 17584
Litigation - James & Mariella Frazer
INVOICE
Invoice Date June 18, 2003
Period Ending June 15, 2003
Invoice No. 24842
PAYMENT DUE UPON RECEIPT OF STATEMENT
All overdue accounts will be assessed finance charges of 1.5% per month.
We now accept the following credit cards for payment: Discover, Mastercard & Visa.
Professional Fees
4/21/2003 ANP RECEIVED AND REVIEWED ANSWER TO P.O.'S. 0.30 @ 100.00/hr 30.00
4/21/2003 ANP REVIEWED ANSWER TO P.O.'S FOR DISPUTED ISSUES OF 3.00 @ 100.00/hr 300.00
MATERIALFACT. REVISED BRIEF. RESEARCHED PA.R.C.P.
206.7 AND THE REQUIR MENTS OF DEPOSING PLAINTIFFS.
LETTER TO PROTHONOTARY.
4/28/2003 ANP TFLFPHONECALLFROMCL1ENTREGARDINGHISRECEIPT 0.30@100.00/hr 30.00
OF MY BRIEF IN SUPPORT OF PRELIMINARY OBJECTIONS.
5/19/2003 ANP TELEPHONE CALL TO COURT ADMINISTRATORS 0.40@100.00/hr 40.00
REGARDING ORAL ARGUMENT.
5/29/2003 ANP TFI HONE CALL FROM EVAN BARENBAUM, ESQUIRE 0.50@ 100.00/hr 50.00
REGARDING ATTORNEY OF RECORD IN CASE LETTER TO
PROTHONOTARY.
6/3/2003 ANP TELEPHONE CALL FROM CLIENT REGARDING SBA LOAN 0.40 @ 100.00/hr 40.00
AND STATUS OF CASE
6/13/2003 ANP RECEIVED AND REVIEWED BRIEF IN OPPOSITION TO PO'S 0.30 @ 100.001hr 30.00
FROM OPPOSING COUNSEL
6115/2003 ANP PREPARED FOR ORAL ARGUMENT REGARDING 2.00@ 100.00/hr 200.00
PRELIMINARY OBJECTIONS TO PLAINTIFFS' COMPLAINT.
Sub-total Fees: 720.00
Expenses
4/23/2003 PAID TO: FEDERAL EXPRESS CORPORATION 17.67
Page: 2
Gates, Halbruuer & Hatch, P.C.
Litigation - 7atnes & Marietta Frazer
4/25/2003 POSTAGE 13.80
5/19/2003 LONGDISTANCECHARGES. 0.78
5/19/2003 LONGDISTANCECHARGES. 0.26
5/23/2003 LONG DISTANCE CHARGES. 0.13
5/29/2003 LONGDISTANCE CHARGES. 1.17
5/30/2003 PAID TO: FEDERAL EXPRESS CORPORATION 14.49
Sub-total Expenses: 48.30
Total Current Billing: 768.30
Previous Balance Due: 1,250.74
Total Now Due: 2,019.04
Current Over 30 Over 60 Over90
768.30 1,250.74 0.00 0.00
PLEASE VISIT OUR W EBSITE AT W W W.GATESLA W FIRM.COM
Gates, Hathruner & Hatch, P.C.
1013 Mumma Road
Suite #100
Lemoyne, PA 17043
(717) 248-6909
Federal I.D. #03-0379998
Countryside HomeWorks, Inc.
C. David Cope
122 Lancaster Pike South
Willow Street PA 17584
Litigation - James & Mariella Frazer
INVOICE
Invoice Date July 25, 2003
Period Fading July 15, 2003
Invoice No. 25253
PAYMENT DUE UPON RECEIPT OF STATEMENT
All overdue accounts will be assessed finance charges of 1.5% per month.
We now accept the following credit cards for payment: Discover, Mastercard & Visa.
Professional Fees
6/IU2003 ANP TRAVEL TO AND FROM CHESTER COUNTY COURTHOUSE 5.00@100.00/hr 500.00
ATTENDED AND PARTICIPATED IN ORAL ARGUMENT OF
PRELIMINARY OBJECTIONS TO THE COMPLAINT.
6/25/2003 ANP TELEPHONE CALL TO CLIENT REGARDING CHECKLIST OF 0.30 @ 100.00/hr 30.00
ACTION ITEMS REGARDINGTHE DEFENSE OF THE
LAWSUIT (ALSO REGARDING SETTLEMENT OF
PROPERTY/LOAN; K WITH DEPAUL PLANNING & DESIGN
AND TOWNSHIP).
6125/2003 ANP LETTER TO CLIENT REGARDING ACTION ITEM LIST. 0.30 @ 100.00/hr 30.00
6/27/2003 ANP TELEPHONE CALL FROM CLIENT REGA RDING WA YPOINT 0.30@100.00/hr 30.00
BANK COMMITMENT LETTER.
7/7/2003 ANP RECEIVED AND REVIEWED ORDER GRANTING OUR 0.30 @ 135.00/hr 40.50
MOTION TO COMPEL ARBITRATION.
Sub-total Fees: 630.50
Fkpenses
611612003 MILEAGETO ANDFROM CHESTER COUNTY FOR ORAL 65.70
ARGUMENT.
6/16/2003 TOLLS. 4.50
Sub-total Expenses: 70.20
Page: 2
Gates, Hal bruner & Hatch, P.C.
Litigation - Janes & Marietta Frazer
Current Over30
700.70 768.30
Total Current Billing: 700.70
Previous Balance Due: 2,019.04
Total Now Due: 2,719.74
Over 60 Over90
0.00 1,250.74
PLEASE VISrf OUR WEBSITE AT W W W.GATFSLAWFIRM.COM
Gates, Halbruner & Hatch, P.C.
1013 Mumma Road
Suite #100
IEmoyne, PA 17043
(717) 248-6909
Federal I.D. #03-0379998
INVOICE
Countryside Horne W o rks, Inc.
C. David Cope
122 Lancaster Pike South
Willow Street PA 17584
Litigation - James & Marietta Frazer
Invoice Date September 9, 2003
Period Ending August 31, 2003
Invoice No. 25948
PAYMENT DUEUPON RECEIPT OF STATEMENT
All overdue accounts will be assessed finance charges of 1.5% per month.
We now accept the following credit cards for payment: Discover, Mastercard & Visa.
Total Current Billing: 0.00
Previous Balance Due: 2,719.74
Total Now Due: 2,719.74
Current Over 30 Over60 Over90
0.00 700.70 768.30 1,250.74
PLEASE VISIT OUR WEBSITE AT W W W.GATESLAWFIRM.COM
Gates, Halbruner & Hatch, P.C.
1013 Murruna Road
Suite #100
Lemoyne, PA 17043
(717) 248-6909
Federal I.D. #03-0379998
INVOICE
Countryside HorreWorks, Inc.
C. David Cope
122 Lancas ter Pike South
Willow Street PA 17584
Litigation - Janes & Mariella Frazer
Invoice Date September 10, 2003
Period Ending August 31, 2003
Invoice No. 26039
PAYMENT DUE UPON RECEIPT OF STATEMENT
All overdue accounts will be assessed finance charges of 1.5% per rnonth.
We now accept the fallowing credit cards for payment: Discover, Mastercard & Visa.
Payments
9/10/2003 Payment
2,719.74
Sub-total Payments: 2,719.74
Total Current Billing: 0.00
Previous Balance Due: 0.00
Total Now Due: 0.00
Current Over-30 Over60
0.00 0.00 0.00
Over 90
0.00
PLEASE VISIT OUR WEBSITEAT W W W.GATESLAWFIRM.COM
Gates, Halbruner & Hatch, P.C.
1013 Mumma Road
Suite #100
Lemoyne, PA 17043
(717) 248-6909
Federal I.D. #03-0379998
INVOICE
Countryside HomeWorks, Inc.
C. David Cope
122 Lancaster Pike South
Willow Street PA 17584
Litigation - James & Marietta Frazer
Invoice Date November 20, 2003
Period Ending November 15, 2003
Invoice No. 26917
PAYMENT DUE UPON RECEIPT OF STATEMENT
All overdue accounts will be assessed finance charges of 1.5% per month.
We now accept the following credit cards for payment Discover, Mastercard & Visa.
Professional Fees
10/23/2003 ANP REC:EIVEDANDREVIEWEDNOTICEOFTRIALIN 0.50@135.00/hr 67.50
NOVIEMBFP, 2003. TELEPHONE CALL TO COURT
ADMINISTRATOR REGARDING ORDER COMPELLING
ARBITRATION. LETTER TO COURT ADMINISTRATOR
REGARDINGREN40VAL FROM TRIAL LIST.
10/28/2003 ANP RESEARCHED CONSTRUCTION INDUSTRY ARBITRATION 1.00@135.00/hr 135.00
RULES OF THE AMERICAN ARBITRATION ASSOCIATION.
TELEPHONE CALL TO JENNIFER AT ARBITRATION
CENTER OF CHESTER COUNTY. TELEPHONE CALL TO
JUDGE SANCHEZ'S SECRETARY REGARDING
JURISDICTION TO ARBITRATE IN CHESTER COUNTY.
10128/2003 ANP CALL FROM JENNIFER AT ARBITRATION OFFICE 0.30 @ 135.00/hr 40.50
REGARDING REMOVAL OF CASE FROM ARBITRATION
LIST AND TRIAL LIST. CALL TO CLB-TqT REGARDING
SAME
11/5/2003 ANP TELEPHONE CALL TO ARBITRATION ADMINISTRATOR 0.30 @ 135.00/hr 40.50
REGARDING BEING STRICKEN FROM ARBITRATION LIST.
Sub-total Fees: 283.50
Ecpenses
10/23/2003 LONG DISTANCE CHARGES. 0.52
10/28/2003 LONGDISTANCECHARGES. 1.69
11/4/2003 LONGDISTANCE CHARGES, 0.78
Page: 2
Gates, Hallruuer & Hatch, P.C.
litigation - James & Mariella Frazer
11/5/2003 LONG DISTANCE CIIARCES. 0.39
Sub-total Expenses: 338
Total Current Billing: 286.88
Previous Balance Due: 0.00
Total Now Due: 286.88
Current Over30 Over6o Over9o
286.88 0.00 0.00 0.00
PLEASE VISIT OUR W EBSITE AT W W W .GATESLA W FIRM.COM
Gates, Halbruner & Hatch, P.C.
1013 Murrmia Road
Suite #100
Iemoyne,PA 17043
(717) 248-6909
Federal I.D. #03-0379998
INVOICE
Countryside HorreWorks, Inc.
C. David Cope
122 Lancaster Pike South
Willow Street PA 17584
Litigation - Janes & Mariella Frazer
hrvoice Date January 12,2004
Period Ending December 31, 2003
Invoice No. 27482
PAYMEN'T' DUE UPON RECEIPT OF STATIMENT
All overdue accounts will be assessed finance charges of 1.5% per month.
We now accept the following credit cards for payment: Discover, Mastercard & Visa.
Total Current Billing: 4.25
Previous Balance Due: 286.88
Total Now Due: 291.13
Current Over30 Over 60 Over90
4.25 286.88 0.00 0.00
PLEASE VISIT OUR WEBSITEAT W W W.GATESLAWFIRM.COM
Gates, Halbraner & Hatch, P.C.
1013 Muria Road
Suite #100
Lemoyne, PA 17043
(717) 248-6909
Federal I.D. #03-0379998
INVOICE
Countryside HorrrWorks, Inc.
C. David Cope
122Iancaster Pike South
Willow Street PA 17584
litigation - lames & Mariella Frazer
Invoice Date January 27, 2004
Period Ending January 15, 2004
Invoice No. 27757
PAYMENT DUE UPON RECEIPT OF STATEMENT
All overdue accounts will be assessed finance charges of 1.5% per month.
We now accept the following credit cards for payment: Discover, Mastercard & Visa.
Total Current Billing: 4.25
Previous Balance Due: 291.13
Total Now Due: 295.38
Current Over30 Over6o Over90
4.25 0.00 286.88 0.00
PLEASE VISIT OUR W EBSITE AT W W W.GATESLA WFIRM.COM
Gates, Halbruner & Hatch, P.C.
1013 Mariam Road
Suite #100
Lemoyne, PA 17043
(717) 248-6909
Federal I.D. #03-0379998
INVOICE
Countryside HomeWorks, Inc.
C. David Cope
122 Lancaster Pike South
Willow Street PA 17584
litigation - Jaires & Mariella Frazer
Invoice Date February 24, 2004
Period Ending February 15, 2004
Invoice No. 28124
PAYMENT DUE UPON RECEIPT OF STATEMENT
All overdue accounts will be assessed finance charges of 1.5% per month.
We now accept the following credit cards for payment Discover, Mastercard & Visa.
Professional Fees
1/28/2004 ANP RECEIVED LETTER DATED JANUARY 22,2004 FROM 3.00@135.00/hr
AMERICAN ARBITRATION ASSOCIATION AND FRAZIER'S
DEMAND FOR ARBITRATION. TELEPHONE CALL TO
CLIENT REGARDINGTHE SAME TELEPHONE CALL TO
CASE MANAGER SUPERVISOR AT AAA. LEFT DETAILED
VOICE MESSAGE REGARDING LOCALE AND EXTENSION
OF TIME TO ANSWER TELEPHONE CALL TO STAND IN
FOR CASE MANAGER AT AAA. LEFT DETAILED VOICE
MESSAGE REGARDING LOCALE AND EXTENSION OF TIME
TO ANSWER. TELEPHONE CALL TO JAMES SARGENT,
ESQUIRE LEFT DETAILED VOICE MESSAGE WITH HIS
ASSISTANT REGARDING A COPY OF THE DEMAND FOR
ARBITRATION AND CONCURRENCE REGARDING
EXTENSION OF TIME TO FILE ANSWER LETTER TO
OPPOSING COUNSEL REGARDING REGARDING SAME
LETTER TO CLIENT REGARDINGLIST OF WITNESSES, ETC.
FOR CONFLICT OF INTEREST DISCLOSURES TO AAA.
RESEARCHED AND REVIEWED RULES AND PROCEDURES
OF AAA FOR CONSTRUCTION INDUSTRY. TELEPHONE
CALL TO CLIENT REGARDING ANS W ER WITH
COUNTERCLAIM AND OBJECTINGTO JURISDICTION OVER
HIM, INDIVIDUALLY.
1/30/2004 ANP RESEARCH ARBITRATION MATTERS AND AAA RULES 3.00 @ 135.00/hr
AND PROCEDURES. REVIEWED DOCUMENTS. BEGAN
PREPARINGROUGH DRAFT OF STATEMENT OF ANSWER
2/4/2004 ANP PR&HEARINGADMBdISTRATIVETELECONFERENCE CALL 1.00 @ 135.00/hr
FROM LOIS ROSINSKI AT AAA WITH OPPOSING
COUNSEL, MARY-ELLEN ALLEN, ESQUIRE TELEPHONE
CALL TO CLIENT REGARDINGPR&HEARING
405.00
405.00
135.00
Page: 2
Gates, Hal bruner & Hatch, P.C.
Litigation - Jaires & Mariella Frazer
TELECONFERENCE CALL AND INFORMATION (LIST OF
W ITNFSS FOR CONFLICTS). PREPARED NOTICE OF
EXTENSION OF TIME AND CERTIFICATE OF SERVICE
LETTER TO LOIS ROSINSKI, CASE MANAGE& AAA
REGARDING NOTICE OF EXTENSION OF TIME
2/4/2004 ANP LETTER FROM LOIS ROSINSKI REGARDING TELEPHONE
CONFERENCE CALL THIS MORNING.
2/12/2004 ANP REVIEWED FILE DOCUMENTS. TELEPHONE CALL TO
CLIENT REGARDINGANSWER TO CLAIMANTS' DEMAND
FOR ARBITRATION.
2/1222004 ANP TELEPHONE CALL FROM CLIENT REGARDINGBUBAING
INSPECTORS NAMES.
2/13/2004 ANP PREPARED STATEMENT OF ANSWER ADDITIONAL
RESEARCH REGARDINGTHE ELEMENTS OF FRAUDULENT
INDUCEMENT. TELEPHONE CALL TO CLIENT REGARDING
INFORMATION NEEDED.
2/14/2004 LRG REVIEWED AND REVISED STATEMENT OF ANSWER FOR
ARBITRATION; ASSISTED WITH PREPARATION OF
STATEMENT OF ANSWER
0.20 @ 135.00/hr
0.50 @ 135.00/hr
0.30 @ 135.00/hr
8.00 @ 135.00/hr
1.50 @ 170.00/hr
2/14/2004 ANP PREPARED STATEMENT OF ANSWER REVIE ED, EDITED 8.00 @ 135.00/hr
AND REVISED STATEMENT OF ANSWER. PREPARED
ANSWERING STATEMENT. PREPARED CHECKLIST FOR
CONFLICTS. LETTER TO LOIS ROSINSKI AT AAA.
PREPARED ANSWER FOR FB.ING AND SERVICE ON ALL
PARTIES.
Egvnses
1/28/2004 LONGDISTANCE-FAX.
1/28/2004 LONG DISTANCE CHARGES.
1/30/2004 LONGDISTANCE CHARGES.
224/2004 LONG DISTANCE CHARGES.
2/9/2004 PAID TO: FEDERAL EXPRESS CORPORATION
2213/2004 LONG DISTANCE-FAX.
2/14/2004 LONG DISTANCE-FAX.
Sub-total Fees:
27.00
67.50
40.50
1,080.00
255.00
1,080.00
3,495.00
0.26
1.17
1.04
0.13
29.98
0.13
0.78
Sub-total Expenses: 33.49
Page: 3
Crates, Halbruner & Hatch, P.C.
litigation - James & Mariella Frazer
Current Over 30
7532.74 4.25
Total Current Billing: 3,532.74
Previous Balance Due: 295.38
Total Now Due: 3,828.12
Over60 Ove190
0.00 286.88
PLEASE VISIT OUR W EBSITE AT W W W.GATESLA WFIRM.COM
Gates, Hatbruner & Hatch, P.C.
1013 Mumma Road
Suite #100
Lemoyne, PA 17043
(717) 248-6909
Federal I.D. #03-0379998
INVOICE
Countryside HomeWorks, Lrc.
C. David Cope
122 Lancaster Pike South
Willow Street PA 17584
litigation - Janes & Mariella Frazer
invoice Date March 16, 2004
Period Ending March 15, 2004
Invoice No. 28554
PAYMENT DUE UPON RECEIPT OF STATEMENT
All overdue accounts will be assessed finance charges of 1.5% per month.
We now accept the following credit cards for payment: Discover, Mastercard & Visa.
Professional Fees
2121/2004 LRG INTER-OFFICE CONFERENCE WITH ATTORNEY ALBERT 0.70 @ 170.00/hr
PETFRL.IN; REVIEWED CORRESPONDENCE TOFRAZE16
ATTORNEY REGARDING SANCTIONS; LEGAL RESEARCH
REGARDINGDRAGONETTI ACT.
2/21/2004 ANP REVIEWED FILE (LETTER TO OPPOSING COUNSEL FROM 2.00@135.00/hr
LAPP; COMPLAINT; DEMAND FOR ARBITRATION;
STATEMENT OF ANSWER; MEMO'S FROM CLIENT TO
ARCHITECT). RESEARCHED RULES OF PROFESSIONAL
CONDUCT, PA.R.CIV.P. 1023.1 AND THE DRAGONETTI ACT
(WRONGFUL USE OF CIVIL. PROCEEDINGS). PREPARED
DRAFT LETTER TO OPPOSING COUNSEL MEETING WITH
LRGREGARDINGDRAFT LETTER. REVISED LETTER.
FAX/LETTER TO OPPOSING COUNEL REQUESTING THE
W ITHDRA W AL OF THE ARBITRATION.
2125/2004 ANP RECEIVED LIST OF MEDIATORS FROM AAA. REVIEWED 1.20 @ 135.00/hr
MEDIATORS QUALIFICATIONS.
3/512004 ANP RECEIVED LETTER DATED MARCH 4, 2004 FROM IRIS C. 0.30 @ 135.00/hr
ROSINSKI. TELEPHONE CALL TO LOIS ROSINSKI AT AAA
REGARDINGSAME LEFT VOICEMESSAGE
31512004 ANP TELEPHONE CALL FROM LOIS ROSINSKI REGARDING 0.30@135.00/hr
FAXING ME A COPY OF THE CORRESPONDENCE SHE
RECEIVED FROM CLAIMANTS.
3/8/2004 ANP FAX FROM LOIS ROSINSKI AT AAA REGARDING 0.30 @ 135.00/hr
CLAIMANTS' OPPOSITION TO RESPONDENTS' MOTIONS
TO DISMISS.
3/11/2004 ANP LETTER FROM JAMES SARGENT, JR., ESQUIRE REGA RDING 0.20 @ 135.00/hr
MEDIATORS (IDENTIFIED IN THE LETTER AS
119.00
270.00
162.00
40.50
40.50
40.50
27.00
Page: 2
Gates, Hal hruner & Hatch, P.C.
Litigation - James & Mariella Frazer
ARBITRATORS).
Sub-total Fees: 699.50
Fkwnses
2/17/2004 PAID TO: FEDERAL EXPRESS CORPORATION
2/17/2004 PAID TO: FEDERAL EXPRESS CORPORATION
2/24/2004 LONG DISTANCE-FAX.
2/25/2004 LONGDISTANCECHARGES.
3/5/2004 LONG DISTANCE CHARGES.
38.03
24.90
0.26
0.13
0.13
Sub-total Expenses: 63.45
Total Current Billing: 767.20
Previous Balance Due: 3,828.12
Total Now Due: 4,595.32
Current
767.20
Over30 Over60 Over90
4.25 4.25 286.88
PLEASE VISIT OUR WEBSITE AT W W W.GATESLA WFIRM.COM
Gates, Halbruner & Hatch, P.C.
1013 Mumma Road
Suite #100
Lemoyne, PA 17043
(717) 248-6909
Federal I.D. #03-0379998
Countryside HomeWorks, Inc.
C. David Cope
122 Lancaster Pike South
Willow Street PA 17584
Litigation - James & Mariella Frazer
INVOICE
Invoice Date April 22, 2004
Period Ending April 19, 2004
Invoice No. 29042
PAYMENT DUE UPON RECEIPT OF STATEMENT
All overdue accounts will be assessed fmance charges of 1.5% per month.
We now accept the following credit cards for payment Discover, Mastercard & Visa.
Professional Fees
3/1612004 ANP LETTER FROM JAMES SARGENT, JR., ESQUIRE REGARDING 0.20 @ 135.00/hr
MEDIATORS.
3/17/2004 MEH CONFII2INCE WITH ANP. 0.20 @ 160.00/hr
3/17/2004 ANY TELEPHONE CALL FROM LOIS ROSINSKI AT AAA. LEFT 0.20 @ 135.00/hr
DETAILED VOICE MESSAGE REGARDINGLIST OF
MEDIATORS. TELEPHONE CALL TO LOIS ROSINSKI AT
AAA. LEFT DETAIIFD VOICE MESSACER REGARDING
SAME
3/17/2004 ANP REVIEWED UNIFORM ARBITRATION ACT REGARDING 0.60 @ 135.00/hr
APPLICATIONS TO STAY ARBITRATIONS. MEETINGWITH
MEH REGARDING STRATEGY (UTILITY OF FILING
APPLICATION TO STAY ARBITRATION IN CHESTER
COUNTY, COURT OF COMMON PLEAS).
3/23/2004 ANP LETTER FROM AAA REGARDING APPOINTMENT OF 1.00 @ 135.00/hr
DAVID ACTON AS MEDIATOR AND DISCLOSURE OF USE
OF CLAIMANTS' LAW FIRM W rr1-1 N PAST YEAR
RESEARCHED MEDIATORS RULES OF PROCEDURE
PREPARED OBJECTION TO APPOINTMENT OF MEDIATOR.
FAXED OBJECTION TO AAA AND OPPOSINGCOUNSEL
4/6/2004 ANP TELEPHONE CALL FROM LOIS ROSINSKI AT AAA 0.20 @ 135.00/hr
REGARDINGWFIETEI ` I AGREE REGARDING OPPOSING
COUNSEL'S SELECTION OF MEDIATORS. LEFT DETAILED
VOICE MESSAGE TELEPHONE CALL TO LOIS ROSINSKI
REGARDING SAME AND IDENTIFYING THAT I HA VE NO
OBJECTION UNLESS MEDIATOR MAKES DISCLOSURE
SIMILAR TO PREVIOUS SELECTED MEDIATOR LEFT
DETAILED VOICEMESSAGE
27.00
32.00
27.00
81.00
135.00
27.00
Page: 2
Crates, Hal bruner & Hatch, P.C.
Litigation - James & Manella Frazer
4/19/2004 ANP RECEIVED LETTER DATED APRIL 15, 2004 REGARDING 0.30 @ 135.00/hr
APPOINTMENT OF B. LEE CHRISTOPHER, ESQUIRE AS
MEDIATOR PREPARED OBJECTION TO APPOINTMENT OF
B. LEE CHRISTOPHER AS MEDIATOR FAXED SAMETO
AAA AND OPPOSINGCOUNSEL
Sub-total Fees:
FxPenses
3/17/2004 LONGDISTANCECHARGES.
Current Over 30
438.32 4,299.94
40.50
369.50
0.26
Sub-total Expenses: 0.26
Total Current Billing: 438.32
Previous Balance Due: 4,595.32
Total Now Due: 5,033.64
Over60 Over90
4.25 291.13
PLEASE VISIT OUR W EBSITE AT W W W .CiATESLA W FIRM.COM
Gates, Halbruner & Hatch, P.C.
1013 Mumma Road
Suite #100
Lemoyne,PA 17043
(717) 248-6909
Federal I.D. #03-0379998
Countryside HomeWorks, Inc.
C. David Cope
1221ancas ter Pike South
Willow Street PA 17584
Litigation - James & Mariella Frazer
INVOICE
Invoice Date June 4, 2004
Period Ending May 31, 2004
Invoice No. 29519
PAYMENT DUE UPON RECEIPT OF STATEMENT
All overdue accounts will be assessed finance charges of 1.5% per month.
We now accept the following credit cards for payment Discover, Mastercard & Visa.
Professional Fees
4/23/2004 ANP TELEPHONE CALL FROM CLIENT REGARDING STATUS OF 0.30 @ 135.00/hr 40.50
CASE
Sub-total Fees: 40.50
Total Current Billing: 114.61
Previous Balance Due: 5,033.64
Total Now Due: 5,148.25
Current Over3O Over 60 Over 90
114.61 438.32 767.20 3,828.12
PLEASE VISIT OUR WEBSITEAT W W W.GATESLAWFIRM.COM
Gates, Halbruner & Hatch, P.C.
1013 Mumm Road
Suite #100
I-emoyne,PA 17043
(717) 248-6909
Federal LD- #03-0379998
Countryside Horw W orks, Inc.
C. David Cope
122 Lancaster Pike South
Willow Street PA 17584
Litigation -Jarnes & Mariella Frazer
INVOICE
Invoice Date June 16, 2004
Period Ending June 15, 2004
Invoice No. 29802
PAYMENT DUE UPON RECLIPT OF STATEMENT
All overdue accounts will be assessed finance charges of 1.5% per month.
We now accept the following credit cards for payment: Discover, Ma stercard & Visa.
Professional Fees
5117/2004 ANP RECEIVED OPPOSINGCOUNSEL'S NEW CHOICES OF 0.30 @ 135.00/hr
MEDIATORS. RECEIVED DISCLOSURE OF SELECTED
MEDIATOR
512412004 ANP TELEPHONE CALLFROM LOIS ROSINSKI AT AMERICAN 0.30 @ 135.00/hr
ARBITRATION ASSOCIATION REGARDING APPOINTMENT
OF YOSUN AS MEDIATOR LEFT DETAILED VOICE
MESSAGE TELEPHONE CALL TO LOIS ROSINSKI
REGARDINGNO OBJECTIONS TO MR. YOSUNS
APPOINTMENT.
5/24/2004 ANP LETTER FROM LOIS ROSINSKI AT AMERICAN 0.30 @ 135.00/hr
ARBITRATION ASSOCIATION REGARDING APPOINTMENT
OF STEPHEN G YUSEM AS MEDIATOR
5/26/2004 ANP TELEPHONE CALL FROM LOTS ROSINSKI AT AAA 0.30 @ 135.00/hr
REGARDINGPRFMEDIATION TELECONFERENCE LIFE
VOICE MESSAGE TELEPHONE CALL TO LOIS ROSINSKI
REGARDINGDATES AND TIME AVAILABLE
5/27/2004 ANP LETTER FROM L-OIS ROSINSKI AT AAA REGARDING 0.30 @ 135.00/hr
PREMEDIATION CONFERENCE CALL
&9/2003 ANP LETTER TO CLIENT REGARDINGPAYME NT OF 0.30 @ 135.00/hr
ATTORNEY'S FEES.
6/14/2004 ANP TELECONFERENCE (PREMEDIATION FIEARING) WITH 1.50@135.00/hr
MEDIATOR AND OPPOSINGCOUNSEL (SARGENT AND
ALLEN). LETTER TO CLIENT REGARDINGPRE-MEDIATION
HEARING. REVIEWED STATEMENT OF ANSWER
TELEPHONE CALL FROM LOTS ROSINSKI, CASE MANAGER
REGARDING FORWARDING EXHIBITS C AND D OF
STATEMENT OF ANSWER DIRECTLY TO MEDIATOR.
40.50
40.50
40.50
40.50
40.50
40.50
202.50
Page: 2
Gates, Halbruner & Hatch, P.C.
Litigation - James & Mariella Frazer
LETTER TO MEDIATOR W ITH EXHIBITS C AND D.
6115/2004 ANP LETTER FROM LOIS C. ROSINSKI, CASE MANAGER AT
AAA REGARDINGMEDIATION HEARING LETTER TO
CLIENT REGARDING SAME
Expenses
5/24/2004 KONG DISTANCE CHARGES.
5/26/2004 LONG DISTANCE CHARGES.
Current Over 30
560.50 438.32
0.30 @ 135.00/hr 40.50
Sub-total Fees: 486.00
0.13
0.26
Sub-total Expenses: 0.39
Total Current Billing: 560.50
Previous Balance Due: 5,148.25
Total Now Due: 5,708.75
Over60 Over90
0.00 4,5957
PLEASE VISIT OUR WEBSITEAT W W W.GATESLAWFIRM.COM
Gates, Halbruner & Hatch, P.C.
1013 Mumma Road
Suite #100
Lemoyne, PA 17043
(717) 731-9600
Federal J.D. #03-0379998
CountrysideHoneWorks, Inc.
C. David Cope
122 Lancaster Pike South
Willow Street PA 17584
INVOICE
Litigation - Janes & Marietta Frazer
Invoice Date July 26, 2004
Period Ending July 16, 2004
Invoice No. 30193
PA YMENT DUE UPON RECEIPT OF STATEMENT
All overdue accounts will be assessed finance charges of 1.5% per month.
We now accept the following credit cards for payment: Discover, Mastercard & Visa.
Professional Fees
6/16r2004 ANP TELEPHONE CALL FROM CLIENTRFGARDINGPAYMINT 0.30@ 135.00/hr 40.50
OF ATTORNEY'S FEES.
6/23/2004 ANP LETTER FROM LOIS ROSINSIQ AT AAA REGARDING 0.30 Co) 135.00/hr 40.50
PAYMENT OF MEDIATION FEES. LETTER TO CLIENT
REGARDING SAME
6130/2004 ANP TELE'HONECALL FROM CLIENT. LEFT DETAILED VOICE 0.40 @ 135.00/hr 54.00
MESSAGE REGARDING RECEIPT OF BUSINESS LOAN.
LETTER FROM STEPHEN G YUSEM, ESQUIRE DATED JUNE
30, 2004. LETTER FROM LOIS C. ROSINSKI, CASE MANAGER
AT THE AMERICAN ARBITRATION ASSOCIATION
REGARDINGMEDIATOR STEPHEN YUSEM'S 11TTER.
TELEPHONE CALL FROM CLIENT REGARDING PAYMENT
OF ATTORNEYS FEES AND COSTS.
7/6/2004 ANP TELEPHONE CALL TOCLIENT. LEFI'VOICE MESSAGE 0.20@135.00/hr 27.00
REGARDINGMEDIATION HEARING AND ATTORNEY'S
FEES.
7/6/2004 ANP TELEPHONE CALL FROM CLIEN'T' REGARDING MEDIATION 0.40 @ 135.00/hr 54.00
HEARING. FAX TO CLIEN'T' REGARDINGDIRECTIONS.
7/612004 ANP TELEPHONE CALL TO CLIENT REGARDING 0.30@135.00/hr 40.50
POST-PONEMENT OF MEDIATION HEARING
7/7/2004 ANP TELEPHONE CALL FROM CLIENT REGARDING PRESENTING 0.30@ 135.00/hr 40.50
QUFSETIONS TO OPPOSING COUNSEL REGARDINGTHE
MATTERS AT ISSUE
7/9/2004 ANP TE.EPHONE CALL FROM CLIENT REGARDING NOT 0.30@ 135.00/hr 40.50
WISHING TO PROCEED WITH MEDIATION.
Page: 2
Gates, Hal bruner & Hatch, P.C.
Litigation - James & Mariella Frazer
7/12/2004 ANP LETTER TOLOISROSINSKI,CASE MANAGER ATAAA
REGARDING CLIFNT NOT INTENDINGTO PROCEED WITH
MEDIATION.
Evpenses
6/21/2004
6/24/2004
6/29/2004
7/6/2004
7/6/2004
7/6/2004
7/9/2004
Payments
7/6/2004
PAID TO: FEDERAL EXPRESS CORPORATION
PAID TO: FEDERAL EXPRESS CORPORATION - DELIVERED
TO COUNTRYSIDE HOMEW ORKS.
PAID TO: AMERICAN ARBITRATION ASSOCIATION
LONG DISTANCE CHARGES.
LONG DISTANCE - FAX.
LONGDISTANCE- FAX.
LONGDISTANCE- FAX.
Payment
5,148.25
Sub-total Payments: 5,148.25
593.75
0.13
0.13
0.13
0.13
624.32
Total Current Billing: 1,009.61
Previous Balance Due: 560.50
Total Now Due: 1,570.11
Current Over30 Over60 Over90
700761 560.50 0.00 0.00
0.30 @ 135.00/hr 40.50
Sub-total Fees: 378.00
14.15
15.90
Sub-total Expenses:
PLEASE VISIT OUR WEBSITE AT W W W.GATESIAWFIRM.COM
Gates, Halbruner & Hatch, P.C.
1013 Mutrvna Road
Suite #100
Urnoyne,PA 17043
(717) 731-9600
Federal I.D. #03-0379998
INVOICE
Countryside HOIreWorks, Inc.
C. David Cope
122 Lancaster Pike South
Willow Street PA 17584
Litigation -James & Mariella Frazer
Invoice Date August 25, 2004
Period Ending August 24, 2004
Invoice No. 30547
PAYMENT DUE (JPON RFC,EIPT OF STATEMENT
All overdue accounts will be assessed finance charges of 1.5% per month.
We now accept the following credit cards for payment: Discover, Mastercard & Visa.
Professional Fees
7/2612004 ANP REVIEWED ARBITRATORS QUALIFICATIONS. 0.40 @ 135.00/hr 54.00
81412003 ANP PREPARED LIST FOR SELECTION OF ARBITRATORS. FAX 0.60 @ 135.00/hr 81.00
TO LOIS ROSINSHI, CASE MANAGER, REGARDING SAME
Sub-total Fees: 135.00
Total Current Billing: 142.29
Previous Balance Due: 1,570.11
Total Now Due: 1,712.40
Current Over30 Over 60 Over9O
142.29 0.00 560.50 0.00
PLEASE VISIT OUR WEBSITEAT W W W.GATESLAWFIRM.COM
Gates, Halbruner & Hatch, P.C.
1013 Mumma Road
Suite #100
Lernoyne, PA 17043
(717) 731-9600
Federal I.D. #03-0379998
Countryside Home W orks, Inc.
C. David Cope
122 Lancaster Pike South
Willow Street PA 17584
Litigation - James & Marietta Frazer
INVOICE
Invoice Date September 20, 2004
Period Ending September 15, 2004
Invoice No. 30877
PAYMENT DUEUPON RECEIPT OF STATEMENT
All overdue accounts will be assessed finance charges of 1.5% pernnnth.
We now accept the following credit cards for payment: Discover, Mastercard & Visa.
Professional Fees
8/30/2004 ANP RECEIVED FAX FROM LOIS C. ROSINSKI REGARDING 0.50 @ 135.00/hr 67.50
DATES A VA BA BLE FOR PRELIMINARY HEARING.
REVIEW ED AVAILABLE DATES AND PREPARED
PRELIMINARY HEARING CALENDAR FORMS. LETTER TO
LOIS C. ROSINSKI REGARDING SAME. LETTER TO CLIENT
REGARDING SAME
8/31/2004 ANP TFI HONE CALL FROM CLIENT REGARDING 0.30 @ 135.00/hr 40.50
PRELIMINARY HEARING NOTICE.
9/3/2004 ANP FACSIMILEDATED SEPTEMBER 3, 2004 FROM LOIS 0.30 @ 135.00/hr 40.50
ROSINSKI AT AAA REGARDING PRELIMINARY HEARING.
E-MAIL FROM LAURA JIMENEZ OF LAMB MCERLANF,
P.C. DATED SEPTEMBER 3, 2004 REGARDING FACSIMILE
FROM LOIS ROSINSKI OF SAME DATE.
Sub-total Fees: 148.50
Expenses
8/17/2004 LONGDISTANCE - FAX. 0.91
8130/2004 LONG DISTANCE - FAX. 0.26
8/31/2004 LONG DISTANCE-FAX. 0.13
9/1/2004 PAID TO: FEDERALEXPRESS CORPORATION 12.04
Sub-total Expenses: 13.34
Page: 2
Crates, Halbruner & Hatch, P.C.
Litigation - James & Mariella Frazer
Total Current Billing: 184.16
Previous Balance Due: 1,712.40
Total Now Due: 1,896.56
Current Over30 Over 60 Over9O
184.16 1,009.61 0.00 560.50
PLEASE VISIT OUR W EBSITEAT W W W.GATESLAW FIRM.COM
Gates, Haffinmer & Hatch, P.C.
1013 Mutntna Road
Suite #100
Lemoyne, PA 17043
(717) 731-9600
Federal I.D. #03-0379998
Countryside HomeWorks, Inc.
C. David Cope
122 Iancaster Pike South
Willow Street PA 17584
INVOICE
Litigation -James & Mariella Frazer
Invoice Date October 18, 2004
Period Ending October 15, 2004
Invoice No. 31220
PAYMENT DUE UPON RECEIPT OF STATEMENT
All overdue accounts will be assessed finance charges of 1.5% per month.
We now accept the following credit cards for payment: Discover, Mastercard & Visa.
Professional Fees
9/2012004 ANP PRELIMINARYTFIFJCONFERENCEHEARING WITH 0.80 @ 135.00/hr 108.00
ARBITRATOR AND OPPOSINGCOUNSEL
9/20/2004 ANP LETTER TOCLIENT REGARDINGPIZELMIINARY 0.60@135.00/hr 81.00
TD_EC'ONFERENCE HFARINGCONDUCTED BYTHE
ARBITRATOR
9/20/2004 ANP FAX FROM LOIS ROSINSHI, CASE MANAGER OF AAA 0.30 @ 135.001hr 40.50
REGARDING ORDER ENTERED PER THIS MORNINGS
PRELIMINARY HEARING WITH ARBITRATOR. LETTER TO
CLIENT REGARDINGSAME
9/21/2004 ANP TELEPHONE CALL FROM CLIENT REGARDING AAA 0.30@135.00/hr 40.50
HEARINGFEES.
9/30/2004 ANP TELEPHONE CALL FROM C. DAVID COPE REGARDING 0.40@135.00/hr 54.00
CASE LETTER TO CLIENT REGARDING W HAT IS
NECESSARYTO DEFEND HIM.
10/4/2004 ANP REVIEWED DOCUMENI'S.PREPARED FORHEARING ON 1.00@135.00/hr 135.00
RESPONDENTS' MOTIONS TO DISMISS. TELECONFERENCE
CALL REGARDING RESPONDENTS' MOTIONS TO DISMISS.
LETTER TO CLIENT REGARDING SAME
10/4/2004 ANP LETTER DATED OCTOBER 4, 2004 FROM IRIS ROSINSKI AT 0.20 @ 135.00/hr 27.00
AAA DENYINGRESPONDEENTS' MOTIONS TO DISMISS.
1017/2004 ANP LETTER FROM CLIENT TERMINATING OUR 0.30 @ 135.00/hr 40.50
REPRESENTATION OF HIM AND HIS COMPANY LETTER
TO CLIENT REGARDING SAME
10/9/2004 ANP FAX DATED OCTOBER 8, 2004 FROM JAMES C SARGENT, N 0.50 @ 135.00/hr 67.50
JR, ESQUIRE REGARDINGDOCt IMENTS AND WITNESSES.
Page: 2
Grates, Halbrtmer & Hatch, P.C
litigation -James & Mariella Frazer
LETTER TO LOIS ROSINSKI AT AAA REGARDING
WITHDRAWAL L E= TO CLIENT REGARDING
BALANCEDUE
Sub-total Fees: 594.00
Expenses
9/30/2004 LONGDISTANCE-FAX.
101412004 LONG DISTANCE-FAX.
10[7/2004 LONG DISTANCE CHARGES.
10/9/2004 LONGDISTANCE-FAX.
Sub-total Epenses:
Current
618.99
0.13
0.13
0.13
0.26
0.65
Total Current Billing: 618.99
Previous Balance Due: 1,896.56
Finance Charge: 24.34
Total Now Due: 2,515.55
Over 30 Over6O Over 90
142.29 1,009.61 560.50
PLEASE VISIT OUR WEBSTTE AT W W W.GATESLA WFIRM.COM
Gates, Halbmner & Hatch, P.C.
1013 Murrim Road
Suite #100
Lemoyne, PA 17043
(717) 731-9600
Federal I.D. #03-0379998
INVOICE
Countryside HomeWorks, Inc.
C. David Cope
122 Lancaster Pike South
Willow Street PA 17584
Litigation - James & Mariella Frazer
Invoice Date November 18, 2004
Period Fading November 15, 2004
Invoice No. 31609
PAYN= DUE UPON RECEIPT OF STATEMENT
All overdue accounts will be assessed finance charges of 1.5% per rronth.
We now accept the following credit cards for paynent Discover, Mastercard & Visa.
Expenses
10/19/2004 PAID TO: FEDERAL EXPRESS CORPORATION 16.37
Sub-total Expenses: 16.37
Total Current Billing: 52.03
Previous Balance Due: 2,515.55
Finance Charge: 35.66
Total Now Due: 2,567.58
Current Over30 Over 60 Over 90
5203 .803.15 142.29 1,570.11
PLEASE VISIT OUR WFBSITE AT W W W.GATESLAWFIRM.COM
Gates, Halbruner & Hatch, P.C.
1013 Nim ma Road
Suite #100
Lemoyne, PA 17043
(717) 731-9600
Federal I.D. #03-0379998
Countryside HomeWorks, Inc.
C. David Cope
122 Lancaster Pike South
Willow Street PA 17584
Litigation - dames & Mariella Frazer
INVOICE
Invoice Date December 20, 2004
Period Ending December 15, 2004
Invoice No. 31988
PAYMENT DUEUPON RECEIPT OF STATEVIEIVT
All overdue accounts will be assessedfinance charges of 1.5 %a per month.
We now accept the following credit cards for payment: Discover, Mastercard & Visa.
Total Current Billing: 35.91
Previous Balance Due: 2,567.58
Finance Charge: 35.91
Total Now Due: 2,603.49
Current Over 30 Over60 Over 90
35.91 5203 .618.99 1,896.56
PLEASE VISIT OUR WEBSITE AT W W W.GATESLAWFIRM.COM
Gates, Halbruner & Hatch, P.C.
1013 Mumma Road
Suite #100
Lenoyne, PA 17043
(717) 248-6909
FederalI.D.#03-0379998
Countryside HomeWorks, Inc.
C. David Cope
122 Lancaster Pike South
Willow Street PA 17584
General Business Matters
INVOICE
Invoice Date September 9, 2003
Period Ending August 31, 2003
Invoice No. 25947
PAYMENT DUE UPON RECEIPT OF STATEMENT
All overdue accounts will be assessed finance charges of 1.5% per month.
We now accept the following credit cards for payment: Discover, Mastercard & Visa.
Professional Fees
7/15/2003 ANP TELEPHONE CALL FROM CLIENT. LEFP VOICE MESSAGE 0.60 @ 135.00/hr
REGARDING SETTLEMENT DELAY. TELEPHONE CALL TO
CLIENT REGARDINGPURCHASE OF 212 WEST HAZEL
STREET, LANCASTER. MEETING WITH MEH. TELEPHONE
CALL TO CLIENT REGARDING HOLDING SOME MONIES IN
ESCROW UNTIL CONTRACT CONDITIONS MEP BY SELLER.
TELEPHONE CALL TO FRANK MINCAREL11, ESQUIRE
(ATTORNEY FOR SELLER). LEFT DETAILED VOICE
MESSAGE REGARDINGCONTRACT CONDITIONS AND
ESCROW OF PORTION OF PURCHA SE PRICE AT
SETTLEMENT.
7/15/2003 ANP TEI.EPHONECALL FROM FRANK MINCARELLI 030@ 135.00/hr
REGARDING SETTLEMENT AND ESCROW OF MONIES.
LEFT DETAILED VOICE MESSAGE TELEPHONE CALL TO
CLIENT REGARDINGESCROW AND REDUCTION OF
PURCHASE PRICE TELEPHONE CALL TO FRANK
MINCARR I.I REGARDINGFSCROW NOT BEING
SUFFICIENT.I-M DETAILED VOICE MESSAGE
7/ 1 612 0 03 ANP TELEPHONE CALL FROM CLIENT REGARDING STATUS OF 0.30 @ 135.00/hr
PROPERTY AND WHETHER CITY IS COMPLYING W IT14
CONTRACT OF SALE
7/17/2003 ANP TELEPHONE CALL TO FRANK MINCARETI,ESQUIRE 0.20@135.00/hr
LEFT MESSAGE REGARDING STATUS OF CONDITIONS
FROM CONTRACT OF SALE
7/17/2003 ANP . TELEPHONE CALL FROM CLIENT. LEFT VOICE MESSAGE 1.60 @ 135.00/hr
REGARDING STATUS. TELEPHONE CALL TO CLIENT
REGARDING SETTLEMENT OF 212 HAZEL STREET,
LANCASTER. TEIEPHONECAILFROM FRANK
81.00
40.50
40.50
27.00
216.00
Page: 2
Gates, Halbruner & Hatch, P.C.
General Business Matters
MINCAREE L ESQ. LEFT VOICE MESSACE. TELEPHONE
CALL TO FRANK MINCAREILL REGARDING ESCROW
AGREEMENT, TELEPHONE CALL TO FRANK MINCAREI J.
LEFF VOICE MESSACEREGARDINGDRAFTINGOF THE
ESCROW AC REEMENT. TELEPHONE CALL TO CLIENT
REGARDING ESCROW AGREEMENT. DRAFTED ESCROW
AGREEMENT. FAX TO FRANK MINCARRII TELEPHONE
CALL TO CLIENT REGARDING WITHOLDING$7,500.00
FROM SETTLEMENT TO BE PLACED IN ESCROW WITH
THIS OFFICE
8/2t/2003 ANP LECTE IFAXTOFRANKMINCARELLIREGARDING 0.30@ 135.00/hr 40.50
ESCROW MONIES.
Sub-total Fees: 445.50
Ownses
8/21/2003 LONG DISTANCE- FAX. 0.52
Sub-total Expenses: 0.52
Trust Account
Beginning Balance: 0.00
7/29/2003 C. David Cope
7,500.00
Ending Balance: 7,500.00
Total Current Bilbng: 446.02
Previous Balance Due: 0.00
Total Now Due: 446.02
Current Over30 Over 60 Over90
446.02 0.00 0.00 0.00
PLEASE VISIT OUR WEBSITEAT W W W.GATESL.A.WFIRM.COM
Gates, Halbruner & Hatch, P.C.
1013 Mumtna Road
Suite #100
IPmoyne,PA 17043
(717) 248-6909
Federal I.D. #03-0379998
Countryside HomeWorks, Inc.
C. David Cope
122 Lancaster Pike South
Wilk)w Street PA 17584
General Business Matters
INVOICE
Invoice Date September 10, 2003
Period Ending August 31, 2003
Invoice No. 26038
PAYMENT DUE UPON RBCFIIPL OF STATEMENT
All overdue accounts will be assessed finance charges of 1.5% per fourth.
We now accept the following credit cards for payment Discover, Mastercard & Visa.
Total Current Billing: 0.00
Previous Balance Due: 446.02
Total Now Due: 446.02
Current Over 30 Over 60 Over 90
0.00 0.00 0.00 0.00
PLEASE VISIT OUR WEBSITEAT W W W.GATFSLAWFIRM.COM
Gates, Halbruner & Hatch, P.C.
1013 Mummna Road
Suite #100
Lemoyne, PA 17043
(717) 248-6909
Federal I.D. #03-0379998
INVOICE
Countryside HomeWorks, Inc.
C. David Cope
122 Lancaster Pike South
Willow Street PA 17584
General Business Matters
Invoice Date September 22, 2003
Period Etding September 17, 2003
Invoice No. 26144
PAYMENT DUE UPON RECEIPT OF STATEMENT
All overdue accounts will be assessed finance charges of 15% per month.
We now accept the following credit cards for payment Discover, Mastercard & Visa.
Professional Fees
9/1512003 ANP REVIEWED LETTERS FROM PRANK MINCARELLI 0.90 @ 135.00/hr 121.50
REGARDING CLEANING OF PREMISES AND REMOVAL OF
COMMERCIAL SCALES. TELEPHONE CALL TO C. DAVID
COPE REGARDING CLEANING OF PREMISES AND
REMOVAL OF COMMERCIAL SCALES. REVIEWED ESCROW
AGREEMENT. LETTER TO FRANK MINCARE[ 11.
TELEPHONE CALL TO CLIENT REGARDINGFAXING A
LETTER OF DEFAULT TO THIS OFFICE TODAY.
9/17/2003 ANP TELEPHONE CALL FROM CLIENT REGARDING REMOVAL 0.30@135.00/hr 40.50
OF SCALES AND CONSTRUCTION OF DRIVEW AY, ETC.
9/1712003 ANP REVIEWED CONTRACT REGARDINGSALF/PURCHASEOF 0.70@ 135.OOlhr 94.50
212 WEST HAZEL STREET. LETTER FROM FRANK
MINCARELLI. LETTER TO FRANK MINCARE LI, ESQUIRE
REGARDING SELLERS BREACH.
Sub-total Fees: 25650
Expenses
9/15/2003 LONG DISTANCE-FAX. 0.13
Sub-total Expenses: 0.13
Page: 2
Gates, Halbruner & Hatch, P.C.
Gneral Business Matters
Total Current Billing: 256.63
Previous Balance Due: 446.02
Total Now Due: 702.65
Current Over 30
256.63 0.00
Over6o Over90
0.00 0.00
PLEASE VISIT OUR WEBSITEAT W W W.GATESLAWFTRM.COM
Gates, Halbruner & Hatch, P.C.
1013 Mumma Road
Suite #100
Lemryne,PA 17043
(717) 248-6909
Federal I.D. #03-0379998
Countryside HomeWorks, Inc.
C. David Cope
122 Lancaster Pike South
Willow Street PA 17584
General Business Matters
INVOICE
Invoice Date October 20, 2003
Period Ending October 20, 2003
Invoice No. 26396
PAIMENT DUE UPON RF:;IIPf OF STATEMENT
All overdue accounts will be assessed finance charges of 1.5% per month.
We now accept the following credit cards for payment: Discover, Mastercard & Visa.
Professional Fees
9/23/2003 ANP REVEEWED LETTER FROM FRANK MINCAREL I 0.40 @ 135.00/hr
REGARDING ESCROW AGREEMENT AND REMOVAL OF
SCALES ETC.
9/30/2003 ANP TELEPHONE CALL FROM CLIENT REGARDINGHIS
REMOVAL OF SCALES AND INSTALLATION OF
DRIVEW AY. NOTES TO FILE
10/6/2003 AMP RECEIVED AND REVIEWED LETTER FROM FRANK
MINCARELLL, ESQUIRE FOR THE AUTHORITY REGARDING
THE RELEASE OF $6,200.00 OF ESCROW MONIES.
TELEPHONE CALL TO CLIENT RF)GARDINGRE EASE OF
ESCROW MONIES. LETTER TO FRANK MINCARELII
REGARDINGCLIENT NOT AGREEING TO REZEASE$6,200.00
OF ESCROW MONIES.
10/16/2003 ANP TELEPHONE CALL FROM CLIENT. LEFT DETAILED VOICE
MESSAGE, REGARDING COMPLETING W ORK, HAVING
INVOICES AND HOW TO PROCEED. TELEPHONE CALL TO
CLIENT REGARDING SAME
10116/2003 ANP RECEIVED AND REVIEWED FAX FROM CLIENT
REGARDING COSTS INCURRED REGARDING PURCHASE OF
LOT#2. TE EPHONECALL TO FRANK MINCAREILI,
ESQUIRE REGARDINGRELEASE OF ESCROW MONIES.
10/20/2003ANP REVIEW ED FILE; CHECK TO CLIENT.
0.40 @ 135.001hr
0.50 @ 135.00/hr
0.40 @ 135.00/hr
54.00
54.00
67.50
54.00
0.40 @ 135.00/hr 54.00
0.20 @ 135.00/hr 27.00
Sub-total Fees: 310.50
Page: 2
General Business Matters
Payments
10/20/2003
Payment
t,O13.15
Sub-total Payments: 1,013.15
Trust Account
10/20/2003
Beginning Balance: 7,500.00
-4,072.74
Gates, Halhruner & Hatch, P.C.
Trust application.
10120/2003 Trust application. -1,013.15
Fading Balance: 2,414.11
Total Current Billing: 310.50
Previous Balance Due: 702.65
Total Now Due: 0.00
Current Over 30 Over 60 Over 90
310.50 446.02 0.00 0.00
PLEASE VISIT OUR W EBSITE AT W W W .GATES7-A W FIRM.COM
Gates, Halbruner & Hatch, P.C.
1013 Mumma Road
Suite #100
Lemoyne,PA 17043
(717) 248-6909
Federal I.D. #03-0379998
INVOICE
Countryside HomeW orks, Inc.
C. David Cope
122 Lancaster Pike South
Willow Street PA 17584
General Business Matters
Invoice Date November 20, 2003
Period Finding November 15, 2003
Invoice No. 26916
Professional Fees
10/22/2003 ANP
1115/2003 ANP
Expenses
11110/2003
Payments
10/20/2003
PAYMENT DUE UPON RF1 EST OF STATEMENT
All overdue accounts will be assessed finance charges of 1.5`70 per mouth.
We now accept the following credit cards for payment Discover, Mastercard & Visa.
TELEPHONE CALLFROMCLffiJTREGARDINGRELEASEOF 0.30@ 135.00/hr
ESCROW MONIES. REVIEWED FILE AND PREPARED CHEEK
REQUEST FOR RELEASE OF ESCROW MONIES.
LETTER TO FRANK MINCARII.LI REGARDING CHECK TO 0.30 @ 135.00/hr
DEVELOPMENT AUTHORITY.
PAID TO: FEDERAL EXPRESS CORPORATION
40.50
40.50
Sub-total Fees: 81.00
Sub-total Expenses
Payment Trust application. 1,013.15
14.21
14.21
Sub-total Payrrcnts: 1,013.15
Page: 2
Gates, Hal bruner & Hatch, P.C.
General Business Matters
Trust Account
Beginning Balance: 2,414.11
IN27/2003 Countryside Horreworks -2,414.11
Ending Balance: 0.00
Total Current Billing: 95.21
Previous Balance Due: 0.00
Total Now Due: 95.21
Current Over30 Over 60 Over9o
95.21 0.00 0.00 0.00
PLEASE VISIT OUR WEBSITEAT W W W.GATESLAWFIRM.COM
Gates, Halbruner & Hatch, P.C.
1013 Mumm Road
Suite it 100
Lemoyne, PA 17043
(717) 248-6909
Federal I.D. #03-0379998
Countryside HornaW o rks, Inc.
C. David Cope
1221aucaster Pike South
Willow Street PA 17584
Ceneral Business Matters
INVOICE
Invoice Date January 12, 2004
Period Ending December 3l, 2003
Invoice No. 27481
PAYMENT DUE UPON RECEIPT OF STATEMENT
All overdue accounts will be assessed finance charges of 1.5% per month.
We now accept the following credit cards for payment: Discover, Mastercard & Visa.
Total Current Billing: 1.43
Previous Balance Due: 95.21
Total Now Due: 96.64
Current Over30 Over60 Over-90
1.43 95.21 0.00 0.00
PLEASE VISIT OUR W EBSITE AT W W W.GATFSLA W FIRM.COM
Gates, Halbruner & Hatch, P.C.
1013 Mumma Road
Suite # 100
Lemoyne, PA 17043
(717) 248-6909
Federal LD.403-0379998
INVOICE
Countryside HorreWorks, Inc.
C. David Cope
122 Lancaster Pike South
Willow Street PA 17584
General Business Matters
Invoice Date January 27, 2004
Period Ending January 15, 2004
Invoice No. 27756
PAYMENT DUE UPON RECEIPT OF STATEMENT
All overdue accounts will be assessed finance charges of 1.5% per month.
We now accept the following credit cards forpayrrent: Discover, Mastercard & Visa.
Total Current Billing: 1.43
Previous Balance Due: 96.64
Total Now Due: 98.07
Current Over 30 Over60 Over90
1.43 0.00 95.21 0.00
PLEASE VISIT OUR WEBSITE AT W W W.GATESLAWFIRM.COM
Gates, Halbruner & Hatch, P.C.
1013 Munum Road
Suite #100
Lemoyne.PA 17043
(717) 248-6909
Federal I.D. #03-0379998
INVOICE
Countryside HOmeW orks, Inc.
C. David Cope
t22 Lancaster Pike South
Willow Street PA 17584
General Business Matters
Invoice Date February 24, 2004
Period Ending February 15, 2004
Invoice No. 28123
PAYMENT DUE UPON RECEIPT OF STATEMENT
All overdue accounts will be assessed finance charges of 1.5% per nnnth.
We now accept the following credit cards for payment: Discover, Mastercard & Visa.
Total Current Billing: 1.43
Previous Balance Due: 98.07
Total Now Due: 99.50
Current Over30 Over60 Over90
1.43 1.43 0.00 95.21
PLEASE VISIT OUR W EBSITE AT W W W .GATESLA W FIRM.COM
Gates, Halbruner & Hatch, P.C.
1013 Murruna Road
Suite #100
Lemoyne, PA 17043
(717) 248-6909
Federal I.D. 403-0379998
INVOICE
Countryside Home W arks, Inc.
C. David Cope
122 Lancaster Pike South
Willow Street PA 17584
Ceneral Business Matters
Invoice Date March 16, 2004
Period Ending March 15, 2004
Invoice No. 28553
PAYMENT DUE UPON RECIIP7' OF STATEMENT
All overdue accounts will be assessed finance charges of 1.5% per tmnth.
We now accept the following credit cards for payment: Discover, Mastercard & Visa.
Professional Fees
2/25/2004 ANP RECEIVED LETTER DATED FEBRUARY 23,2004FROM 0.30@ 135.00/hr
FRANK P. MINCARELLL ESQUIRE REGARDING LACK OF
PROGRESS. LETTER TO CLIENT REGARDING SAME
2125/2004 ANP TELEPHONE CALL FROM CLIENT REGARDING LETTER 0.40@135.00/hr
FROM FRANK MINCAREW, ESQUIRE REGARDING
CLIEN"T"S CONSTRUCTION PROGRESS. RF REVIEWED
LETTER FROM FRANK MINCARELLI, ESQUBRE
2/26/2004 ANP PREPARED RESPONSE LETTER TO LETTER FROM FRANK 050 @ 135.00/hr
MINCAREL11 REGARDING THE PROGRESS OF CLIENTS ON
THE PROPERTY.
3/312004 ANP TELEPHONE CALL FROM CLIENT REGARDINGWAINER OF 0.50@ 135.001hr
MECHANICS' LIEN FOR MARSH CREEK OFFICE COMPLEX.
TELEPHONE CALL TO CLIENT REGARDING NAME OF
ENTITY ENTERED INTO AGREEMENT, DATE OF
AGREEMENT, AND OWNER OF PROPERTY, RESEARCHED
MARSH CREEK CORPORATE CENTER. TELEPHONE CALL
TO CLIEN'T' REGARDINGNO ENTITY BY NAME OF MARSH
CREEK CORPORATE CENTER.
3/312004 ANP TELEPHONE CALL FROM CLIENT REGARDINGFAXING 0.40 @ 135.00/hr
BLANK COPY OF WAIVER DIRECTLY TO MARCH CREEK
CORPORATE SERVICES.
314/2004 ANP TELEPHONE CALL FROM ROGIRHUGGINS, ESQUIRE LEFT 0.20 @ 135.00/hr
DETAIL ID VOICEMESSAGE..
3/5/2004 ANP LETTER DATED MARCH 2, 2004 FROM FRANK P. 0.30 @ 135.00/hr
MINCARFZTI REGARDING FSCROW MONIES AND
PROGRESS OF CLIENT ON CONSTRUCTION OF PROPERTY.
LETTER TO CLIENT REGARDING SAME
40.50
54.00
67.50
67.50
54.00
27.00
40.50
Page: 2
Crates, Halbruner & Hatch, P.C.
General Bus ices s Matters
31512004 ANP TELEPHONE CALL FROM CLIENT. IEFI'VOICE MESSAGE 0.30@ 135.00/hr 40.50
TELEPHONE CALL FROM ROGER HUGGINS, ESQUIRR LEFT
VOICE MESSAGE REGA RDING MARSH CREEK CORPORATE
CENTER AND WAIVER OF MECHANICS' LIENS.
TELEPHONE CALL TO ROGER HUGGINS, ESQUIRE LEFT
VOICEMESSAGE TELEPHONECALLTO CLIENT
RFjGARDING MARSH CREEK CORPORA TE CENTER AND
PAYMENT FOR PROJECT.
318/2004 ANP TELEPHONE CALL FROM ROGER HUGGNS, ESQUIRE LEFT 0.20 @ 135.007hr 27.00
VOICE MESSAGE
Sub-total Fees: 418.50
E7tpenses
314/2004 LANG DISTANCE CHA RGES. 0.13
3/512004 LONG DISTANCE CHARGES. 0.13
31512004 LONGDISTANCE CHARGES. 0.13
Sub-total Expenses: 0.39
Total Current Billing: 420.32
Previous Balance Due: 99.50
Total Now Due: 519.82
Current Over 30 Over6O Over 90
420.32 1.43 1.43 95.21
PLEA SE VISIT OUR W EBSITE AT W W W .GATESLA W FIRM.COM
Gates, Halbruner & Hatch, P.C.
1013 Murrmra Road
Suite # 100
Iernoyne,PA 17043
(717) 248-6909
Federal I.D. #030379998
INVOICE
Countryside flonrWorks, Inc.
C. David Cope
122 Uncas ter Pike South
Willow Street PA 17584
General Business Matters
Invoice Date April 22, 2004
Period Ending April 15, 2004
Invoice No. 29041
PAYMENT DUE UPON RECEIPT OF STATEMENT
All overdue accounts will be assessed finance charges of 1.5% per month.
We now accept the following credit cards for payment Discover, Mastercard & Visa.
Total Current Billing: 7.71
Previous Balance Due: 519.82
Total Now Due: 527.53
Current Over 30 Over 60 Over 90
7.71 421.75 1.43 96.64
PLEASE VISIT OUR W EBSITE AT W W W.GATESLA W FIRM.COM
Gates, Halbruner & Hatch, P.C.
1013 Mumma Road
Suite #100
Lennyne, PA 17043
(717) 248-6909
Federal I.D. 403-0379998
INVOICE
CountrysideHomeWorks, Inc.
C. David Cope
1221ancaster Pike South
Willow Street PA 17584
General Business Matters
Invoice Date June 4, 2004
Period Fording May 31, 2004
Invoice No. 29518
PAYMENT DUE UPON RECEIPT OF STATEMENT
All overdue accounts will be assessed finance charges of 1.5% per month.
We now accept the following credit cards for payment: Discover, Mastercard & Visa.
Total Current Billing: 7.71
Previous Balance Due: 527.53
Total Now Due: 535.24
Current Over 30 Over60 Over90
7.71 7.71 420.32 99.50
PLEASE VJSIT OUR WEBSITE AT W W W .GATESLAWFIRM.COM
Gates, Halbruner & Hatch, P.C.
1013 Munana Road
Suite #100
Iemoyne,PA 17043
(717) 248-6909
Federal I.D. 403-0379998
INVOICE
Countryside Hour-Works, Inc.
C. David Cope
122 Lancaster Pike South
Willow Street PA 17584
General Business Matters
Invoice Date June 16, 2004
Period biding June 15, 2004
Invoice No. 29801
PAYMENT DUE UPON RECEIPT OF STATEMENT
All overdue accounts will be assessed finance charges of 1.5% per month.
We now accept the following credit cards for payment Discover, Mastercard & Visa.
Total Current Billing: 7.71
Previous Balance Due: 53524
Total Now Due: 54295
Current Over 30 Over60 Over90
7.71 7.71 0.00 519.82
PLEASE VISIT OUR W EBSITE AT W W W .GATESLA W FIRM.COM
Gates, Halbruner & Hatch, P.C.
1013 Mumma Road
Suite #100
Lemoyne,PA 17043
(717) 731-9600
Federal I.D.#03-0379998
INVOICE
Countryside Hon eWorks, Inc.
C. David Cope
122 Lancaster Pike South
Willow Street PA 17584
General Business Matters
Invoice Date August 25, 2004
Period Biding August 24, 2004
Invoice No. 30546
PAYMENT DUE UPON RECEIPT OF STATEMENT
All overdue accounts will be assessed finance charges of 1.5% per month.
We now accept the following credit cards for paytrent: Discover, Mastercard & Visa.
Professional Fees
8113/2004 ANP TELEPHONE CA LL FROM CLIENT REGARDING 0.30 @ 135.00/hr
COMMERCIAL LEASE FOR 212 HAZEL STREET AND
REGARDING BJ BALDWIN ELECTRIC.
8/1812004 ANP TEL.EPHONECALL FROM MARY COPE REGARDING 1.20@135.00/hr
STATUS OF COMMERCIAL LEASE AGREEMENT.
PREPARED COMMERCIAL LEASE AGREEMENT.
8/23/2004 ANP TE EP14ONECALLFROM C. DAVID COPERFGARDING 0.30 @ 135.00/hr
GALIN MILLER INCORPORATED AND REFUSAL TO PAY,
EJC.
Sub-total Fees:
Payments
716/2004 Payment 535.24
40.50
162.00
40.50
243.00
Sub-total Payments: 535.24
Page: 2
Gates, Halbruner & Hatch, P.C.
General Business Matters
Total Current Billing: 243.00
Previous Balance Due: 7.71
Total Now Due: 250.71
Current Over30 Over60 Over 90
243.00 0.00 7.71 0.00
PLEASE VISIT OUR W EBSITE AT W W W .GATESLA W FIRM.COM
Gates, Halbruner & Hatch, P.C.
1013 Mumma Road
Suite # too
Lemoyne, PA 17043
(717) 731-9600
Federal I.D. #03-0379998
INVOICE
Countryside Home W orks, Inc.
C. David Cope
122 Lancaster Pike South
Willow Street PA 17584
General Business Matters
Invoice Date September 20, 2004
Period Ending September 15, 2004
Invoice No. 30876
PAYMENT DUE UPON RECEIPT OF STATEMENT
All overdue accounts will be assessed finance charges of 1.5% per moflth.
We now accept the following credit cards for payment: Discover, Mastercard & Visa.
Professional Fees
8/26/2004 ANP TELEPHONECAL-FROM CLIENT REGARDING MARYLAND 0.300135.00/hr 40.50
CONTRACTOR AND HIS DIRECTION TO DE AAY/SUSPEND
INSTITUTITION OF CIVIL ACTION.
9/3/2004 ANP TELEPHONE CA LL FROM CLIENT REGA RDING CITY 0.30@135.00/hr 40.50
INSTALLINGCURBS AND TEARINGOUT HIS SIDEWALK.
9/4/2004 ANP TELEPHONE CALL FROM CLIENT REGARDING CURB AND 0.200135.00/hr 27.00
SIDEWALK. LEFT VOICE MESSAGE.
Sub-total Fees: 108.00
Total Current Billing: 105.00
Previous Balance Due: 250.71
Total Now Due: 358.71
Current Over30 Over 60 Over9o
108.00 0.00 0.00 7.71
PLEA SE VISIT OUR W EBS ITE AT W W W .GATESLA W F[RM.COM
Gates, Halbrmer & Hatch, P.C.
1013 Murrvm Road
Suite #100
Lermyne, PA 17043
(717) 731-9600
Federal I.D. #03-0379998
INVOICE
Countryside Home Works, Inc.
C. David Cope
122LancasterPike South
Willow Street PA 17584
General Business Matters
Invoice Date October 18, 2004
Period Ending October 15, 2004
Invoice No. 31219
PAYMENT DUE UPON RFCIIPI' OF STATEMENT
All overdue accounts will be assessed finance charges of 1.5% pet month.
We now accept the following credit cards forpaynent Discover, Mastercard & Visa.
Ekpenses
9120/2004 LONG DISTANCE-FAX. 0.39
Sub-total Expenses: 0.39
Total Current Billing: 4.04
Previous Balance Due: 358.71
Finance Charge: 3.65
Total NowDue: 362.75
Current Over 30 over 6o Over 90
4.04 243.00 0.00 7.71
PLEASE VISIT OUR WEBSUF AT W W W.GATESLAWFIRM.COM
Gates, Haffinmer & Hatch, P.C.
1013 Munmra Road
Suite # 100
Lermyne,PA 17043
(717) 731-9600
Federal I.D.#03-0379998
INVOICE
Countryside HomeWorks, Inc.
C. David Cope
122 Lancaster Pike South
Willow Street PA 17584
General Business Matters
Invoice Date November 18, 2004
Period Siding November 15, 2004
Invoice No. 31608
PAYMENT DUE UPON RECEIPT OF STATEMENT
All overdue accounts will be assessed finance charges of 1.5% per rmnth.
We now accept the following credit cards for payrnent: Discover, Mastercard & Visa.
Total Current Billing: 5.27
Previous Balance Due: 362.75
Finance Charge: 5.27
Total Now Due: 368.02
Current Over 30 Over 60 Over 90
5.27 112.04 243.00 7.71
PLEASE VISIT OUR WFBSITE AT W W W.CrATESLA WFIRM.COM
Gates, Halbruner & Hatch, P.C.
1013 Nluum m Road
suite #100
Lermyne, PA 17043
(717) 731-9600
Federal LD. #03-0379998
Countryside HorreWorks, Inc.
C. David Cope
1221ancaster Pike South
Willow Street PA 17584
General Business Matters
INVOICE
Invoice Date December 20, 2004
Period Fnding December 15, 2004
Invoice No. 31987
PAYMENT DLE UPON RECEIPT OF STATEMENT
All overdue accounts vdll be assess edfinance charges of 1.5% per month.
We now accept the following credit cards for payment Discover, Mastercard & Visa.
Total Current Billing: 5.27
Previous Balance Due: 368.02
Finance Charge: 5.27
Total NowDue: 373.29
Current Over 30 Over 60 Over 90
5.27 5.27 4.04 358.71
PLEASE VISIT OUR WEBSITE AT W W W.GATFSLA WFIRM.COM
x?,???? ?
Gates, Halbruner & Hatch, P.C.
1013 Mumma Road
Suite #100
Lemoyne,PA 17043
(717) 731-9600
Federal I.D. #03-0379998
Countryside HomeWorks, Inc.
C. David Cope
122 Lancaster Pike South
Willow Street PA 17584
Galen Miller Incorporated
INVOICE
Invoice Date September 20, 2004
Period Ending September 15, 2004
Invoice No. 30878
PA YMENT DUE UPON RECEIPT OF STATEMENT
All overdue accounts will be assessed finance charges of 1.5% per month.
We now accept the following credit cards for paymen t: Discover, Mastercard & Visa.
Professional Fees
9/1512004 ANP TELEPHONE CALL FROM CLIENT REGARDING SENDING 0.30@135.00/hr 40.50
DEMAND LETTER.
Sub-total Fees: 40.50
Total Current Billing: 40.50
Previous Balance Due: 0.00
Total Now Due: 40.50
Current Over-30 Over-60 Over9o
40.50 0.00 0.00 0.00
PLEASE VISIT OUR W EBSITE AT W W W .GATESLA W rIRM.COM
Gates, Halbruner & Hatch, P.C.
1013 Munnu Road
Suite #100
Lerroyne, PA 17043
(717) 731-9600
Federal I.D.#03-0379998
INVOICE
Countryside HotneWorks, Inc.
C. David Cope
122 Lancaster Pike South
Willow Street PA 17584
Galen Miller Incorporated
Invoice Date October 18, 2004
Period Ending October 15, 2004
Invoice No. 31221
PAYMENT DUE UPON RECE[Pf OF STATEMENT
All overdue accounts will be assessed finance charges of 1.5% per Muth.
We now accept the following credit cards for payrnent: Discover, Mastercard & Visa.
Professional Fees
9/17/2004 ANP REVIEWIDFAXFROM C7IENI'RMARDINGCONTRACP 0.50@135.00/hr 67.50
AND CORRESPONDENCE WITH GALEN MIIIFR.
Sub-total Fees: 67.50
Total Current Billing: 67.50
Previous Balance Due: 40.50
Finance Charge: 0.00
Total Now Due: 108.00
Current Over 30 Over60 Over9o
67.50 0.00 0.00 0.00
PLEASE VISIT OUR WEBSITE AT W W W.GATFSLAWFIRM.COM
Gates, Haltinmer & Hatch, P.C.
1013 Muttcm Road
Suite #100
L2rnoyne, PA 17043
(717) 731-9600
Federal I.D.#03-0379998
INVOICE
Countryside HomeWorks, Inc.
C David Cope
122 Lancaster Pike South
Willow Street PA 17584
Galen Miller Incorporated
Invoice Date November 18, 2004
Period Ending November 15, 2004
Invoice No. 31610
PAYMENT DUE UPON RECEIPT OF STATFMENT
All overdue accounts will be assessed finance charges of 1.5% per month.
We now accept the following credit cards for payment-. Discover, Mastercard & Pisa.
Total Current Billing: 1.62
Previous Balance Due: 108.00
Finance Charge: 1.62
Total NOW We: 109.62
Current Over 30 Over 60 Over 90
1.62 108.00 0.00 0.00
PLEASE VISIT OUR WIBSITE AT W W W.OATESLA WFIRM.COM
Gates, Halbnmer & Hatch, P.C.
1013 M irrum Road
Suite #100
Lemoyne, PA 17043
(717) 731-9600
Federal J.D. #03-0379998
Countryside Hone Works, Inc.
C. David Cope
122 Lancaster Pike South
Willow Street PA 17584
Galen Miller Incorporated
INVOICE
Invoice Date December 20, 2004
Period Ending Decetber 15, 2004
Invoice No. 31989
PA YMENT DUF UPON FH-Q OFSTATENTUff
All overdue accounts will be assessed finance charges of 1.5% per month.
We now accept the following credit cards for payrrent: Discover, Mastercard & Visa.
Total Current Billing: 1.62
Previous Balance Due: 109.62
Finance Charge: 1.62
Total NowDue: 111.24
Current Over 30 Over60 Over 90
1.62 1.62 67.50 40.50
PLEASE VISIT OUR W FBSITE AT W W W.GATESLA WFIRM.COM
?Xh `???
LAW OFFICES OF
GATES, HALBRUNER & HATCH, P. -C.
1013 MUMMA ROAD • SUITE 100 • LEMOYNE, PENNSYLVANIA 17043
(717)731-9600• FAX: (717) 731.9627
LOWELL R. GATES
Also Admitted to Massachusetts Bar
MARK E HALBRUNER
Also Admitted to New Jersey Bar
CRAIG A. HATCH
CORY J. SNOOK
ALBERT N. PETERLIN
Also Admitted to Maryland Bar
STACEY L. NACE
ParalegaVOtfice Manager
TRACI L. SEPKOVIC
Paralegal
VALERIE LONG
Paralegal
VIA U.S. FIRST CLASS MAIL
February 14, 2003
C. David Cope C. David Cope, President
122 Lancaster Pike South Countryside Homeworks, Inc.
Willow Street. PA 17584 124 Lancaster Pike South
Willow Street, PA 17584
RE: James Frazier & Mariella Frazier vs.
C. David Cope & Countryside Homeworks, Inc.
Chester CCP; Civil Action No. 01-09468
Dear David:
BRANCH OFFICE:
3 WEST MONUMENT SOUARE, SUITE 304
LEWISTOWN, PA 17044
(717) 248-6909
WEB SITE'.
www-Gat esLawFi rm.co m
CORRESPONDENCE ADDRESS'.
Lemoyne Office
Thank you for entrusting this firm with the civil litigation case brought against you and
Countryside Homeworks, Inc. by James & Mariella Frazier. It is my understanding that we will
be representing you, in this action. It is our Firm's practice to confirm, in writing, the identity of
any client whom we represent, the nature of our undertaking on behalf of that client, and our
billing and 'payment arrangements with respect to our legal services. All consultation is on a
totally confidential basis. You will receive from our Firm periodic statements, usually monthly,
detailing services rendered since the last billing period, plus costs and fees which are advanced
on your behalf for items such as filing fees, photocopying, long-distance telephone calls, postage,
express mail, telecopier (fax) transmissions, computerized legal research and out-of-town travel.
You will be billed on a hourly basis. You will be liable for the value of any work
performed; including any and all costs (including; but not limited to, long distance telephone
fees, copy charges, mileage expenses, filing fees, etc.).
This letter of representation is not effective until this office receives, amorw other things
a retainer in the amount of Two Thousand and 00/100 Dollars ($2,000.00). Upon receipt of the
Retainer Agreement executed by you and the full amount of the above-mentioned retainer, this
agreement will become effective.
Our hourly fees are based primarily upon the amount of time, work, and effort we invest
in your case. We will keep track of the things we do including research, attending meetings,
answering your telephone calls or telephone calls of opposing attorneys, traveling to hearings and
meetings, and preparing letters and other documents. We will keep records as to the work done in
C. David Cope &
Countryside Homeworks, Inc.
February 14, 2003
Page -2-
your case. Our time is recorded in increments of two-tenths (2/10) of an hour. At the present
time, my rate is $100.00 per hour. Although we do not expect a change in the near future, it is
possible that my hourly rates will change during our services to you.
We will bill our services out of the above-referenced retainer. When and if the original
retainer is exhausted, another payment of two thousand and 00/100 dollars ($2,000.00) will be
due to this Office. As each two thousand and 00/100 dollar ($?_ 000 00)pavraent is exhausted an
additional payment in the same amount becomes immediately due Failure to promptly provide
an additional payment, as set forth above, constitutes a material breach of this agreement
We expect you as our client to fully cooperate with our staff and to disclose to the
attorneys all the facts and information which may be material to providing you with our services.
We cannot represent you effectively and provide you with accurate and appropriate documents
without such co-operation. We also expect you to keep us fully informed as to any changes in
your circumstances which may affect our services to you.
It is impossible to determine in advance the exact amount of time and expenses that we
will incur on your behalf. We will keep you informed of the time we spend on this matter and
will provide descriptions on our statements of activities undertaken. We encourage you to
discuss with us any questions you have about the nature or quality of the representation we
provide to you. Misunderstandings can be costly, and we wish to avoid them whenever possible.
I look forward to hearing from you and working with you in the future. If the foregoing
fee arrangement is acceptable, please sign and date on the spaces marked below (page 3 hereof)
and retain one copy for your records. Kindly return the other copy to us in the envelope
provided.
Thank you.
Sincerely,
GATES, HALBRUNER & HATCH, P.C.
Albert N. Peterlin
ANP
Enclosure
C. David Cope &
Countryside Homeworks, Inc.
February 14, 2003
Page -3-
WITNESS
ATTEST
BY: - / Ck,A -0,9z
C. DAVID COPE, SECRETARY
CLIENT
C. DAVID COPE
COUNTRYSIDE HOMEWORKS, INC.
BY:_ 0?G J- ( i
C. DAVID COPE, P IDENT
Date: ;;:," 12003
GATES, HALBRUNER & HATCH, P.C.:
BY. A/1
ALBERT N. ET-(El IN, ES
Date: 12003
WITNESS
LAW OFFICES OF
GATES, HALBRUNER & HATCH, P.C.
1013 MUMMA ROAD SUITE 100 • LEMOYNE, PENNSYLVANIA 17043 ?-
(717) 731-9600 • FAX: (717) 731-9627
LOWELL R. GATES BRANCH OFFICE.
Also Adam Ned to Massachusetts Bar 3 WEST MONUMENT SQUARE, SUITE 304
MARK E HALBRUNER LEWISTOWN, PA 17044
Also Admitted to New Jersey Bar (7171248 6909
CRAIG A. HATCH
CORY 3. SNOOK -1 WEB SITE:
ALBERT N. PETERLIN July 15, 2003 www.GatesLaWFirm.com
Also Admitted to Maryland Bar July
STACEY L NACE
Paralegal/Office Manager
TRACI L SEPKOVIC
Paralegal
VALERIE LONG
Paralegal
VIA U.S. FIRST CLASS MAIL
C. David Cope
122 Lancaster Pike South
Willow Street, PA 17584
RE: Fee Letter
Dear David:
CORRESPONDENCE ADDRESS.
Lemoyne Office
In accordance with our previous conversation, I am writing to confirrn your agreement to
retain our services in order to assist you with general business matters. We are pleased to assist
you in this matter.
It is our Firm's practice to confirm, in writing, the identity of any client whom we
represent, the nature of our undertaking on behalf of that client, and our billing and payment
arrangements with respect to our legal services. All consultation is on a totally confidential
basis. You will receive from our Firm periodic statements, usually monthly, detailing services
rendered since the last billing period, plus costs and fees which are advanced on your behalf for
items such as filing fees, photocopying, long-distance telephone calls, postage, express mail,
telecopier (fax) transmissions, computerized legal research and out-of-town travel.
You will be billed on an hourly basis for any work performed on your behalf. My fee is
based primarily upon the amount of time, work, and effort I invest in your case. I will keep track
of the things I do including research, attending meetings, answering your telephone calls or
telephone calls of opposing attorneys, traveling to hearings and meetings, and preparing letters
and other documents. I will keep records as to the work done in your case. My time is recorded
in increments of two-tenths (2/10) of an hour. At the present time, my hourly rate is $135.00.
Although I do not expect a change in the near future, it is possible that this hourly rate will
change during my services to you. If that is the case, every effort will be made to notify you of
such a change.
I expect you as my client to fully cooperate with our staff and to disclose to the
attorney(s) all the facts and information which may be material to providing you with my
services. I cannot represent you effectively and provide you with accurate and appropriate advice
and/or documents without such co-operation. I also expect you to keep us fully informed as to
C. David Cope
July 15, 2003
Page -2-
any changes in your circumstances which may affect my services to you.
It is impossible to determine in advance the exact amount of time and expenses that I will
incur on your behalf. I will keep you informed of the time I spend on this matter and will provide
descriptions on the statements of activities undertaken. I encourage you to discuss with me any
questions you have about the nature or quality of the representation I provide to you.
Misunderstandings can be costly, and we wish to avoid them whenever possible.
If the foregoing is not in accordance with your understanding of our engagement in any
respect, please contact me so that we may address your concerns promptly. I enjoyed talking
with you, and look forward to working with you in the future.
Sincerely,
Albert N. P
ANP:kbs
CERTIFICATE OF SERVICE
I, Jeffrey L. Shaffer, Legal Assistant, hereby certify that a true and correct copy
of the foregoing Complaint, has been served this day upon the following parties by
United States first class mail, postage prepaid, addressed as follows:
Countryside Homeworks
124 Lancaster Pike South
Willow Street, PA 17584
Date: March 10, 2005
C. David Cope
122 Lancaster Pike South
Willow Street, PA 17584
Respectfully submitted,
GRATES, HALBRUNER & HATCH, P.C.
By: - U
Jef y . Shaffer, Le Assistant
1013 Mumma Road, Kite 100
Lemoyne, PA 17043
(717) 731-9600
(Attorneys for Debtors)
Gates, Halbruner & Hatch, P.C.
By: Albert N. Peterlin, Esquire
PA 84180
1013 Mumma Road, Suite 100
Lemoyne, PA 17043-1144
(717) 731-9600
(717) 731-9627 facsimile
a.l)eterlin@qateslawfirm.com
Attorneys for Plaintiff
IN THE COURT OF COMMON PLEAS
FOR CUMBERLAND COUNTY, PENNSYLVANIA
GATES, HALBRUNER & HATCH, P.C.,
Civil Action
Plaintiff,
V.
COUNTRYSIDE HOMEWORKS, INC.
and C. DAVID COPE,
Defendants.
Case No. 05-1171 Civil
PRAECIPE TO ATTACH NOTICE TO DEFEND TO
TO THE PROTHONOTARY:
Please attach the enclosed Notice to Defend to the Complaint.
Sincerely,
GATES. HALBRUNE" HAM
.C.
Date: March 21, 2005 By:
Gates, Halbruner & Hatch, P.C.
By: Albert N. Peterlin, Esquire
PA 84180
1013 Mumma Road, Suite 100
Lemoyne, PA 17043-1144
(717) 731-9600
(717) 731-9627 facsimile
a.peterlin@qateslawfirm.com
Attorneys for Plaintiff
IN THE COURT OF COMMON PLEAS
FOR CUMBERLAND COUNTY, PENNSYLVANIA
GATES, HALBRUNER & HATCH, P.C.,
Civil Action
Plaintiff,
Case No. 05-1171 Civil
V.
COUNTRYSIDE HOMEWORKS, INC.
and C. DAVID COPE,
Defendants.
NOTICE TO DEFEND
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 and 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.
AVISO
USTED HA SIDO DEMAND
COUTE. Si usted desea de
las demandas que se prese
adelante en las siguientes
tomar accion dentro de los
veinte (20) dias despues de
de esta Demanda y Aviso r
personalmente o por medio
abogado una comparecenci
radicando en la Corte por e
defensas de, y objecciones
demandas presentada aqui
suya. Se le advierte de qu
de tomar accion como se d
anteriormente, el caso pue
usted y un fallo por cualqui
dinero reclamada en la de
cualquier otra reclamacion
/A EN
arse de
mas
as, debe
notifcacion
un
escrita y
rito sus
las
i contra
i usted falla
proceder sin
suma de
inda o
remedio
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
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
2 Liberty Avenue
Carlisle, PA 17013
(717) 249-3166
solicitado por el demandant puede ser
dictado on contra suya por I Corte sin
mas aviso adicional. Usted lj?ede perder
dinero o propiedad u otros d echos
importantes para usted.
LISTED DEBE LLEVAR ESTIrn
DOCUMENTO A SU ABOGA O
INMEDIATAMENTE. SI UST D NO
TIENE UN ABOGADO, LLAM 0 VAYA A
LA SIGUIENTE OFICINA. ES A OFICINA
PUEDE PROVEERLE INFOR ACION A
CERCA DE COMO CONSEG IR UN
ABOGADO.
SI LISTED NO PUEDE PAGARIIPOR LOS
SERVICIOS DE UN ABOGAD ES
POSIBLE QUE ESTA OFI 'INA E
PUEDA PROVEER INFORMA ON
SOBRE AGENCIAS QUE OFR CAN
SERVICIOS LEGALES SIN CA GO O
BAJO COSTO A PERSONAS Q E
CUALIFICAN.
Cumberland County Bar
2 Liberty Avenue
Carlisle, PA 17013
(717) 249-3166
, 'W ,
CERTIFICATE OF SERVICE
I, Jeffrey L. Shaffer, Legal Assistant, hereby certify that a true and
of the foregoing Praecipe to Attach Notice to Defend Complaint, has been
day upon the following parties by United States first class mail, postage
addressed as follows:
Countryside HomeWorks
124 Lancaster Pike South
Willow Street, PA 17584
C. David Cope
122 Lancaster Pike South
Willow Street, PA 17584
copy
this
Respectfully submitted,
Date: March 21, 2005
GATES, HALBRUNER & HA
By: - -- ` L . _
P.C.
Je y L. Shaffer, Leg I ssist
1013 Mumma Road, S ite 100
Lemoyne, PA 17043
(717) 731-9600
(Attorneys for Debtors)
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COUNTRYSIDE HOMEWORKS. INC.
124 Lancaster Pike South
Willow Street, PA 17584
717-786-1024
FAX (717) 786-2991
GATES, HALBRUNER & HATCH, P.C., Civil Action
Plaintiff, Case No. 05-1171 Civil Term
V.
COUNTRYSIDE HOMEWORKS, INC.
and C. DAVID COPE
Defendants.
------------------------------------
1. PARTIES
1. Agreed
2. Agreed
3. Agreed
11. JURISDICTION AND VENUE
4. Agreed
5. Agreed
III. BACKGROUND
6. Agreed in part, denied in part.
7. Agreed in part, denied in part.
8. Agreed in part, denied in part.
IV. CAUSES OF ACTION
1
9. Defendant refers to answers to Paragraphs 1-8.
10. Plaintiff failed to honor contract by submitting invoices and charging fees for services that
were never rendered ie. phone calls that were never made and meetings that never occurred.
11. Plaintiff did not follow the contract requirements pertaining to time segments to be billed and
thus on numerous occasions overbilled for services rendered.
12. Plaintiff failed to perform services required by their contract before the contract was terminated
by either party. This negligence has exposed the Defendants to damages in excess of $250,000.
13. Plaintiff failed to honor the contract by withholding urgent communication, vital information
and necessary documentation all relevant to the case of Frazier v. Countryside Homeworks, Inc.
and C. David Cope.
14. The Plaintiff has included in his compensatory damages claim charges which include amounts
for attorney fees, interest and other services which took place after both parties had terminated the
contract. These charges are not provided for in the contract.
15. Plaintiff breached the contract in not providing the services promised in the contract.
V. COUNTERCLAIM
C. David Cope and Countryside Homeworks, inc. respectfully request relief from the claims of
Compensatory damages and respectfully request judgment in their favor against Plaintiff in the
amount of over $100,000 pending outcome of the trial results of the case of James and Mariella
Frazier v. C. David Cope & Countryside Homeworks, Inc.
Respectfully Submitted,
Dated: April 8, 2005 COUNTRYSIDE HOMEWORKS, INC.
C C ?.
(C. DAVID COPE, PRESIDENT)
0,xi ' i
2
r C`
I->
ILI?
C
l r ?
Gates, Halbruner & Hatch, P.C.
By: Albert N. Peterlin, Esquire
PA 84180
1013 Mumma Road
Suite 100
Lemoyne, PA 17043-1144
(717) 731-9600 telephone
(717) 731-9627 telecopier
a.peterlin@qateslawfirm.com
www.gateslawfirm.com
Attorneys for Plaintiff
IN THE COURT OF COMMON PLEAS
FOR CUMBERLAND COUNTY, PENNSYLVANIA
GATES, HALBRUNER & HATCH, P.C
Plaintiff,
v.
COUNTRYSIDE HOMEWORKS, INC.,
and C. DAVID COPE,
Defendants.
AND NOW, this
day of
2005,
upon consideration of Plaintiffs Preliminary Objections to Counterclaim of Defendants
(the "Objections"), it is hereby ORDERED and DECREED that:
1. The Objections are Sustained;
2. The Counterclaim is dismissed, with prejudice.
Civil Action - Law
Case No. 05-1171 Civil Term
BY THE COURT:
J.
Distribution List:
Albert Nicholas Peterlin, Esquire
Gates, Halbruner & Hatch, P.C.
1013 Mumma Road, Suite 100, Lemoyne, PA 17043
C. David Cope, Individually and as President of
Countryside Homeworks, Inc.
124 Lancaster Pike South, Willow Street, PA 17584
Gates, Halbruner & Hatch, P.C.
By: Albert N. Peterlin, Esquire
PA 84180
1013 Mumma Road
Suite 100
Lemoyne, PA 17043-1144
(717) 731-9600 telephone
(717) 731-9627 telecopier
a.peterlin@qateslawfirm.com
www.gateslawfirm.com
Attorneys for Plaintiff
IN THE COURT OF COMMON PLEAS
FOR CUMBERLAND COUNTY, PENNSYLVANIA
R & HATCH, P.G.
Plaintiff,
Civil Action - Law
Case No. 05-1171 Civil Term
V.
COUNTRYSIDE HOMEWORKS, INC.,
and C. DAVID COPE,
Defendants.
PLAINTIFF'S PRELIMINARY OBJECTIONS
TO COUNTERCLAIM OF DEFENDANTS
Plaintiff, Gates, Halbruner & Hatch, P.C. ("GHH" or "Plaintiff") preliminarily object
to the Counterclaim of Defendants, Countryside Homeworks, Inc. ("Countryside
Homeworks") and C. David Cope ("Mr. Cope") and, in support thereof, avers as follows:
1. On March 14, 2005, Plaintiff filed a Complaint for payment of attorneys'
fees properly due and owing to Plaintiffs by Defendants for legal services rendered in
multiple matters.
2. On or about April 11, 2005, Defendants filed an apparent answer and
counterclaim.
I. DEMURRER
3. A claim may be dismissed pursuant to Pa.R.C.P. No. 1028(a)(4) for legal
insufficiency.
4. Defendants assert a counterclaim in its apparent answer to Plaintiff's
complaint.
5. Defendants requests damages pursuant to a prayer for relief without a
supporting factual basis.
6. The counterclaim requests relief dependent on the outcome of a trial that
has not occurred yet.
7. Further, Defendants admit in their answer to Plaintiff's complaint, that
Plaintiff no longer represents them in the referenced litigation matter.
8. Defendants have failed to set forth a claim upon which relief can be
granted.
II. INSUFFICIENT SPECIFICITY
9. A claim may be dismissed pursuant to Pa.R.C.P. No. 1028(a)(3) for
insufficient specificity.
10. Defendants' counterclaim constitutes a prayer for relief.
11. Defendants have not set forth any factual allegations in support of their
Counterclaim.
12. Upon information and belief, Paragraphs 9 through 15 of Defendants'
answer are denials to the corresponding allegations of Plaintiff's Complaint.
2
13. Defendants are required pursuant to Pa.R.C.P. No. 1019 to set forth facts
sufficient to provide notice to Plaintiff of the claims asserted against it and to permit
Plaintiff to prepare a defense to the claims asserted against it.
14. Defendants have failed to set forth a claim with sufficient specificity.
Ill. FAILURE TO CONFORM TO RULE OF COURT
15. A complaint may be dismissed pursuant to Pa.R.C.P. No. 10128(a)(2) for
failure to conform to law or rule of court.
16. Defendants are required to specifically identify if they are asserting a claim
for professional negligence against Plaintiff pursuant to Pa.R.C.P. No. 1042.2(a).
17. Pursuant to Pa.R.C.P. No. 1042.2(b), this issue is properly raised as a
preliminary objection.
3
PRAYER FOR RELIEF
Plaintiff, Gates, Halbruner & Hatch, P.C., requests this Court enter an Order
sustaining its preliminary objections to the apparent answer and counterclaim of
Defendants, Countryside Homeworks, Inc. and C. David Cope:
a. dismissing the Counterclaim with prejudice for legal insufficiency and/or
insufficient specificity; or, in the alternative;
b. directing Defendants to amend their Counterclaim to satisfy the specificity
requirements set forth in Pa.R.C.P. Nos. 1019 and pleading requirements set forth in
Pa.R.C.P. No. 1042.2(a).
Respectfully submitted,
GAT , HALB UNE AT H, P.
Date: April 12, 2005 By: e ich? s Peterl n, ire?
Attorneys for Plaintiff
4
CERTIFICATE OF SERVICE
I, Jeffrey L. Shaffer, Legal Assistant, hereby certify that a true and correct copy of
the foregoing Plaintiff's Preliminary Objections to Counterclaim of Defendants has been
served this day upon the following parties by United States first class mail, postage
prepaid, addressed as follows:
C. David Cope, Individually and as President of
Countryside Homeworks, Inc.
124 Lancaster Pike South
Willow Street, PA 17584
GATES, HALBRUNER & HATCH, P.C.
Date: April 12, 2005 By: Jeff L. Shaffer, L4
al Assistant
-n.T
Gates, Halbruner & Hatch, P.C.
By: Albert N. Peterlin, Esquire
PA 84180
1013 Mumma Road
Suite 100
Lemoyne, PA 17043-1144
(717) 731-9600 telephone
(717) 731-9627 telecopier
a.peterlin @ gateslawfirm.com\
www.gateslawfirm.com
Attorneys for Plaintiff
IN THE COURT OF COMMON PLEAS
FOR CUMBERLAND COUNTY, PENNSYLVANIA
GATES, HALBRUNER & HATCH, P.C. i Civil Action - Law
Plaintiff,
V.
COUNTRYSIDE HOMEWORKS, INC.,
and C. DAVID COPE,
Case No. 05-1171 Civil Term
PRAECIPE TO LIST CASE FOR ARGUMENT
TO THE PROTHONOTARY:
1. Please list the following matter for argument:
A. Plaintiffs' Preliminary Objections.
2. Counsel or Pro Se Parties who will argue each matter are as follows:
A. For Plaintiffs: Albert N. Peterlin, Esquire of Gates, Halbruner
& Hatch, P.C., 1013 Mumma Road, Suite 100, Lemoyne, PA 17043.
B. For Defendants: C. David Cope, individually and as President of
Countryside Homeworks, Inc..
3. The undersigned will notify all parties in writing within two (2) days that
this case has been listed for argument.
1
4. Argument Court Date: July 6, 2005.
Respectfully submitted,
Date: April 12, 2005
GATES HALBRUNER 8? A CH, P.C.
By: ! / i
Albert N. Pet rlin, Esqu re
Attorneys for Plaintiffs
2
CERTIFICATE OF SERVICE
I, Jeffrey L. Shaffer, Legal Assistant, hereby certify that a true and correct copy of
the foregoing Praecipe to List Case for Argument has been served this day upon the
following parties by United States first class mail, postage prepaid, addressed as
follows:
C. David Cope, Individually and as President of
Countryside Homeworks, Inc.
124 Lancaster Pike South
Willow Street, PA 17584
GATES HALBRUNER & HATCH, P.C.
Date: April 12, 2005 By: Jeffrey L. Shaffer, egal Assistant
Gates, Halbruner & Hatch, P.C.
By: Albert N. Peterlin, Esquire
PA 84180
1013 Mumma Road
Suite 100
Lemoyne, PA 17043-1144
(717) 731-9600 telephone
(717) 731-9627 telecopier
a peterlin@oateslawfirm com\
www.gateslawfirm.com
Attorneys for Plaintiff
IN THE COURT OF COMMON PLEAS
FOR CUMBERLAND COUNTY, PENNSYLVANIA
GATES, HALBRUNER & HATCH, P.C
Plaintiff,
V.
COUNTRYSIDE HOMEWORKS, INC.,
and C. DAVID COPE,
Defendants.
Civil Action - Law
Case No. 05-1171 Civil Term
PRAECIPE TO REMOVE CASE FROM ARGUMENT LIST
TO THE PROTHONOTARY:
Please remove the instant case from the argument List. Plaintiff filed a
praecipe to list its preliminary objections for argument. Plaintiff intended to list its
preliminary objections for argument in July.
Date: April 26, 2005 By:
1
Respectfully submitted,
CERTIFICATE OF SERVICE
I, Albert N. Peterlin, Esquire, hereby certify that a true and correct copy of the
foregoing Praecipe to Remove Case from Argument List has been served this day
upon the following parties by United States first class mail, postage prepaid, addressed
as follows:
`C. David Cope, Individually and
1Countryside Homeworks, Inc.
124 Lancaster Pike South
lWillow Street, PA 17584
Date: April 26, 2005
as President of
GATE LBRUNER
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Gates, Halbruner & Hatch, P.C.
Byron L. McMasters, Esquire
PA 92410
1013 Mumma Road
Suite 100
Lemoyne, PA 17043
P: (717) 731-9600
F:(717)731-9627
b.mcmastersCa)4ateslawfirm.com
www. gateslawrii rm. com
IN THE COURT OF COMMON PLEAS
FOR CUMBERLAND COUNTY, PENNSYLVANIA
GATES, HALBRUNER & HATCH, P.C., : Civil Action - Law
Plaintiffs, Case No. 05-1171 Civil Term
V.
COUNTRYSIDE HOMEWORKS, INC.,
and C. DAVID COPE,
Defendants.
PRAECIPE TO LIST CASE FOR ARGUMENT
TO THE PROTHONOTARY:
Please list the following matter for argument:
A. Plaintiffs' Preliminary Objections.
Counsel or Pro Se Parties who will argue each matter are as
follows:
A. For Plaintiffs: Albert N. Peterlin, Esquire of Gates, Halbruner
& Hatch, P.C., 1013 Mumma Road, Suite 100, Lemoyne, PA
17043.
B. For Defendants: C. David Cope, individually and as
President of Countryside Homeworks, Inc..
3. The undersigned will notify all parties in writing within two (2) days
that this case has been listed for argument.
4. Argument Court Date: August 24, 2005.
Respectfully submitted,
Date: August 1, 2005
GATES, HALBRUNER & HATCH, P.C.
By:
Byron L. McMasters, Esquire
Attorneys for Plaintiffs
CERTIFICATE OF SERVICE
I, Traci L. Sheridan, Legal Assistant, hereby certify that a true and correct copy of
the foregoing Praecipe to List Case for Argument has been served this day upon the
following parties by United States first class mail, postage prepaid, addressed as
follows:
C. David Cope, Individually and as President of
Countryside Homeworks, Inc.
124 Lancaster Pike South
Willow Street, PA 17584
GATES, HALBRUNER & HATCH, P.C.
Date: August 1, 2005 By: Traci L. Sheridan, Legal Assistant
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GATES, HALBRUNER &
HATCH, P.C.,
Plaintiff
VS.
COUNTRYSIDE HOMEWORKS,
INC., and C. DAVID COPE,
Defendants
IN THE COURT OF COMMON PLEAS OF
CUMBERLAND COUNTY, PENNSYLVANIA
CIVIL ACTION - LAW
NO. 05-1171 CIVIL
IN RE: PRELIMINARY OBJECTIONS OF THE PLAINTIFF
BEFORE HESS AND OLER, J.J.
ORDER
AND NOW, this day of September, 2005, following consideration thereof,
the preliminary objections of the plaintiff to the counterclaim of the defendants are
SUSTAINED. Specifically, while the defendants' counterclaim contains a prayer for relief, it
contains no factual allegations in support thereof. Moreover, Pa.R.C.P. 1042.2(a) requires a
pleading to identify each defendant against whom the plaintiff is asserting a professional liability
claim.
In lieu of dismissing the counterclaim, the court herewith grants the defendants twenty
(20) days in which to plead over. In the event that an amended counterclaim is not filed within
twenty (20) days hereof, the defendants shall, thereafter, be barred from asserting same.
BY THE COURT,
/g
Kevi A. Hess, J.
O?
OF 7H-t, " itrY
iM &:,p
-8 i 11 fit{
ITy
Byron L. McMasters, Esquire
For the Plaintiff
C. David Cope, Individually and as President of
Countryside Homeworks, Inc.
124 Lancaster Pike South
Willow Street, PA 17584
:rlm
Curtis R. Long
Prothonotary
office of the Protbonotarp
Cumberfanb Countp
Renee K. Simpson
Deputy Prothonotary
John E. Slike
Solicitor
05 - 1171 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
RCP230.2
BY THE COURT,
CURTIS R. LONG
PROTHONOTARY
One Courthouse Square • Carlisle, Pennsylvania 17013 • (717) 240-6195 • Fax (717) 240-6573