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Home My WebLink About14-6091 Supreme Court of, ennsylvania Court 104 Common'Pleas For Prothonotary Use Only: Civil,Cover Sheet ti Docket No: Cumberland r , G County ly f The information collected on this form is used solely for court administration purposes. This form does not supplement or replace the filing and service of pleadings or other papers as required bylaw or rules of court. Commencement of Action: S E Complaint 0 Writ of Summons ' Petition 0 Transfer from Another Jurisdiction EI Declaration of Taking E C Lead Plaintiff's Name: Lead Defendant's Name: T Wayne F. Shade Joan M. Beattie Are money damages requested? Yes No Dollar Amount Requested: Elwithin arbitration limits I (check one) EI outside arbitration limits N Is this a Class Action Suit? E_I Yes Ex No Is this an MDJAppeal? n Yes El No A Name of Plaintiff/Appellant's Attorney: Bradley L. Griffie, Esquire Check here if you have no attorney(are a Self-Represented 1Pro Se] Litigant) Nature of the Case: Place an"X"to the left of the ONE case category that most accurately describes your PRIMARY CASE. If you are making more than one type of claim,check the one that you consider most important. TORT(do not include Mass Tort) CONTRACT(do not include Judgments) CIVIL APPEALS Intentional F-1 Buyer Plaintiff Administrative Agencies El Malicious Prosecution El Debt Collection:Credit Card E Board of Assessment 0 Motor Vehicle Debt Collection:Other Ci Board of Elections 71 Nuisance r❑ Dept.of Transportation Premises Liability ❑ Statutory Appeal:Other S CI Product Liability(does not include mass tort) El Employment Dispute: I' Discrimination Slander/Libel/Defamation C Q Other: Employment Dispute:Other = Zoning Board T - Other: I E] Other: O MASS TORT 0 Asbestos N 0 Tobacco Toxic Tort-DES ❑ Toxic Tort-Implant REAL PROPERTY MISCELLANEOUS l Toxic Waste El Ejectment E] Common Law/Statutory Arbitration B 0 Other: 0 Eminent Domain/Condemnation 0 Declaratory Judgment 1 Ground Rent Mandamus Landlord/Tenant Dispute -1 Non-Domestic Relations 3 Mortgage Foreclosure:Residential Restraining Order PROFESSIONAL LIABLITY I—I Mortgage Foreclosure:Commercial Quo Warranto Dental El Partition El Replevin Legal LJ Quiet Title 0 Other: Medical Other: Other Professional: Updated 1/1/2011 4 WAYNE F. SHADE, : IN THE COURT OF COMMON PLEA F Plaintiff CUMBERLAND COUNTY, PENNSNR CIVIL ACTION—LAW X� '� //__ 4 V. xa C) a NO. 14 - CIVIL TF c7 � � JOAN M. BEATTIE, =C:1 ,c Defendant NOTICE You have been sued in Court. If you wish to defend against the claims set forth in the following pages, you must take action within twenty(20) days after this Complaint and Notice are served, by entering a written appearance personally or by attorney and filing in writing with the Court your defenses or objections to the claims set forth against you. You are warned that if you fail to do so the case may proceed without you and a judgment may be entered against you by the Court without further notice for any money claimed in the Complaint or for any other claim of relief requested by the Plaintiff. You may lose money or property or other rights important to you. YOU SHOULD TAKE THIS PAPER TO YOUR LAWYER AT ONCE. IF YOU DO NOT HAVE A LAWYER OR CANNOT AFFORD ONE, GO TO OR TELEPHONE THE OFFICE SET FORTH BELOW TO FIND OUT WHERE YOU CAN GET LEGAL HELP. 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 32 South Bedford Street Carlisle, Pennsylvania 17013 Telephone: (717) 249-3166 r' e, Esquire r ie &Associates, 9S ire Supreme Court No. 34349 200 North Hanover Street Carlisle,Pennsylvania 17013 Telephone: 717-243-5551 Attorneys for Plaintiff c� 3 ( � 3��17q WAYNE F. SHADE, : IN THE COURT OF COMMON PLEAS OF Plaintiff CUMBERLAND COUNTY, PENNSYLVANIA CIVIL ACTION—LAW V. NO. 14 - CIVIL TERM JOAN M. BEATTIE, Defendant COMPLAINT 1. Plaintiff WAYNE F. SHADE is an adult individual who has at all times pertinent hereto been duly licensed in the practice of law in the Commonwealth of Pennsylvania and whose offices are currently located at 53 West Pomfret Street, Carlisle, Cumberland County, Pennsylvania 17013. 2. Defendant JOAN M. BEATTIE is an adult individual who resides at 75 Partridge Circle, Carlisle, Cumberland County, Pennsylvania 17013. 3. On June 24, 1996, Defendant entered into a written fee agreement with Plaintiff for legal representation in connection with Defendant's domestic relations proceedings. A copy of said agreement is attached hereto and incorporated herein by reference as though fully set forth. 4. On September 5, 2012, Plaintiff sent a statement for services and expenses to Defendant for services from November 15, 2010, through August 23, 2012, in the amount of$23,720.40. 5. Plaintiff has repeatedly demanded payment of his counsel fees, but Defendant has refused to pay them. WHEREFORE, Plaintiff demands judgment against Defendant in the amount of $23,720.40 plus costs and interest at the legal rate from September 5, 2012. r iffie, Esquire ie & ssociates, P.C. Supreme Court No. 34349 200 North Hanover Street Carlisle, Pennsylvania 17013 Telephone: 717-243-5551 Attorney for Plaintiff I verify that the statements made in the foregoing Complaint are true and correct. I understand that false statements herein are made subject to the penalties of 18 Pa. C.S. § 4904, relating to unsworn falsification to authorities. Date: October .11, 2014 Wayne F. Shade v WAYNE F. SHADE ATTORNEY AT LAW 53 WEST POMFRET STREET CARLISLE,PENNSYLVANIA 17013 (717)243-0220 (800)243-0220 FAX(717)249-0017 June 24, 1996 Ms. Joan M. Beattie P.O. Box 24 Carlisle, Pennsylvania 17013 Re: Beattie v. Beattie Dear Ms. Beattie: Pennsylvania law requires that the fee arrangement between the attorney and the client be placed in writing. Therefore, this letter will confirm our discussion in this office on June 13, 1996, concerning our willingness to represent you with regard to your domestic relations proceedings. Because of the nature of such proceedings and the possible occurrence of unforeseen complications, we are not in a position to quote you a final and specific fee for our services. Our fees will be billed at the rate of $150.00 per hour; and we will maintain time records which you may review at anytime. This hourly rate will prevail until January 2, 1997, after which it may be increased if it should become necessary for us to increase our fee schedule. It should be understood that we keep an itemized record of our conferences, telephone calls, document drafting, research, Court time and travel time, if any. Our records of time expended are kept in fractions of hours with a minimum of one-tenth hour for each activity. The preparation of certain documents such as pleadings and agreements may be billed upon a flat-rate basis rather than a time-expended basis. We ordinarily send bills only upon reaching significant points in your case as opposed to sending monthly bills. However, you may request an itemized bill at anytime. It should also be understood that our fees will not be limited by any Court award of attorney fees in the case and that any Court costs and other expenses incurred in connection with this matter will be reimbursable in addition to our fees for services rendered. We will make every effort to keep you as well informed as to the progress of your case as possible. If we are unavailable when you call, we will make every effort to return your call as quickly as possible. i . tea Wayne F. Shade, Esquire to Ms. Joan M. Beattie June 24, 1996 Page 2 If this arrangement is in accordance with your understanding, please acknowledge your agreement in the space provided below and return this letter to our office. You may retain the enclosed copy for your files. Should you have any questions in any respect, please do not hesitate to call. We appreciate the opportunity of representing you in this matter of importance to you; and we assure you that we will pursue your case as diligently and expeditiously as possible. Very truly yours,, Wayne , . Shade WFS/ct Enclosures Acknowledged and agreed this e?, `' "day of June, 1996. Joan Beattie COURT OF COMMON PLEAS OF CUMBRLAND COUNTY, PENNSYLVANIA Wayne F Shade 53 W Pomfret Street Carlisle, PA 17013 Plaintiff V Joan M Beattie 75 Partridge Circle Carlisle, PA 17013 Defendant CIVIL ACTION LAW No. 14-6091 ANSWER Plaintiff - Wayne F Shade whose office is located at 53 W Pomfret St, Carlisle PA 17013 Defendant - Joan M Beattie who resides at 75 Partridge Circle, Carlisle PA 17013 d r Z -r~y. la rr r W <C) -a c 'an. = C) . 73 My answer to this complaint is that I honestly believe that Mr Shade took advantage of my circumstances dragging this case on for over 16 years. I was diagnosed with Multiple Sclerosis in 2002 and my cognitive abilities have been compromised by this disease. Mr Shade knew that and I feel he used that to his advantage. I also had a fiancee, who passed away in 2008, who had a considerable amount of money and I did inherit quite a bit from him. I honestly believe that Mr Shade knew all along that there was a guarantee of money , so he intentionally dragged this case on as long as he could. I have already paid him $120,917.75 and I got nothing in the divorce settlement..my ex-husband got it all! Mr Shade claims I owe him a balance of $23,720.40 and I don't think I do. I have never received monthly statements from Mr Shade over the 16 years. Thank you Your Honor Sincerely Yours Joan.M Beattie Ronny R Anderson Sheriff Jody S Smith Chief Deputy Richard W Stewart Solicitor SHERIFF'S OFFICE OF CUMBERLAND COUNTY OPTICS OF THE SHERIFF ::, Liv -OFFft„ THE p ROTHONO ►1:.,� 2814 NOV —5 Piet 3: 4 6 CUMBERLAND COUNTY PENNSYLVANIA Wayne F Shade vs. Joan M Beattie Case Number 2014-6091 SHERIFF'S RETURN OF SERVICE 10/23/2014 11:19 AM - Deputy William Cline, being duly sworn according to law, served the requested Complaint & Notice by "personally" handing a true copy to a person representing themselve o be the Defendant, to wit: Joan M Beattie at 75 Partridge Circle, North Middleton Township, Carli- e; 'A 1 013. SHERIFF COST: $35.27 LL M CLINE, DEPUTY SO ANSWERS, October 24, 2014 RONNTY R ANDERSON, SHERIFF (c) CountySuite Sheriff, Teleasoft, Inc. IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA WAYNE F. SHADE Plaintiff VS JOAN M. BEATTIE Defendant N0.14-6091 CIVIL? RULE 1312-1 The Petition for Appointment of Arbitrators shall be substantially i following form: THE PETITION FOR APPOINTMENT OF ARBITRATORS rn c-� -n ry TO THE HONORABLE, THE JUDGES OF SAID COURT: Bradley L. Griffie , counsel for the plaintiff/defendant in the above action (or actions), respectfully represents that: 1. The above -captioned action (or actions) is (are) at issue. 2. The claim of plaintiff in the action is $23,720.40, costs and interest The counterclaim of the defendant in the action is None The following attorneys are interested in the case(s) as counsel or are otherwise disqualified to sit as arbitrators: Wayne F. Shade, Esquire (Plaintiff) WHEREFORE, your petitioner prays your Honorable Court to appoint three (3) arbitrators to whom the case shall be submitted. Respectfully submitted, AND NOW, , 20 , in consideration of the foregoing petition, Esq., and Esq., and Esq., are appointed arbitrators in the above captioned action (or actions) as prayed for. By the Court, KEVIN A. HESS, P.J. 31/7 T IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA WAYNE F. SHADE Plaintiff VS JOAN M. BEATTIE Defendant RULE 1312-1 following form: N0.14-6091 CIVIL int .C - MW rn :3 r- 3> - 2 The Petition for Appointment of Arbitrators shall be substantially e---' THE PETITION FOR APPOINTMENT OF ARBITRATORS TO THE HONORABLE, THE JUDGES OF SAID COURT: Bradley L. Griffie , counsel for the plaintiff/defendant in the action (or actions), respectfully represents that: 1. The above -captioned action (or actions) is (are) at issue. 2. The claim of plaintiff in the action is $23,720.40, costs and interest The counterclaim of the defendant in the action is None -4 ru-a C) -0 C�3 N) above The following attorneys are interested in the case(s) as counsel or are otherwise disqualified to sit as arbitrators: Wayne F. Shade, Esquire (Plaintiff) WHEREFORE, your petitioner prays your Honorable Court to appoint three (3) arbitrators to whom the case shall be submitted. Respectfully submitted, AND NOW,4e,„AfAi / %, 20/ei , in consideration of the foregoing petition, Vd�7<�Q Esq., and4� Esq., and captioned action (or actions) as prayed for. 3�pi G ill . 8e6 V-4;pies )M,%d Ia/f?l/ appointed are arbitrators ii theabove By the Court, e KEVIN A. S, P.J. e= C-, 0 X- -4 . Cr I ck1 3itor