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Home My WebLink About05-4548 COYNE & COYNE, P.c., Plaintiff : IN THE COURT OF COMMON PLEAS OF : CUMBERLAND COUNTY, PENNSYLVANIA vs. : NO. 05 -4s-'-f~ CIVIL TERM CHRISTOPHER PASSAMONTE and JANNA PASSAMONTE, his wife Defendants : CIVIL ACTION--LA W NOTICE YOU HAVE BEEN SUED IN COURT. If you wish to defend against the claims set forth in the following pages, you must take action within twenty (20) days after this Notice is served, by entering a written appearance personally or by an attorney and filing in writing with the Court your defenses or objections to the claims set forth against you. You are warned that if you fail to do so the case may proceed without you and a judgment may be entered against you by the Court without further notice for any money claimed in the Complaint or for any other claim or relief requested by the Defendant. You may lose money or property or other rights important to you. YOU SHOULD TAKE THIS PAPER TO YOUR LAWYER AT ONCE. IF YOU DO NOT HAVE A LAWYER OR CANNOT AFFORD ONE, GO TO OR TELEPHONE THE OFFICE SET FORTH BELOW TO FIND OUT WHERE YOU CAN GET LEGAL HELP. Cumberland County Lawyer Referral Service 32 S. Bedford Street Carlisle, P A 17013 (717) 240-6200 I COYNE & COYNE, P.C., Plaintiff : IN THE COURT OF COMMON PLEAS OF : CUMBERLAND COUNTY, PENNSYLVANIA vs. : NO. 0:1- 'IS'V$!' CIVIL TERM CHRISTOPHER P ASSAMONTE and JANNA PASSAMONTE, his wife Defendants : CIVIL ACTION--LA W COMPLAINT AND NOW comes the Plaintiff, Coyne & Coyne, P.C., and files the within Complaint: I. Plaintiff is Coyne & Coyne, P.c. a Professional Corporation, with offices located at 3901 Market Street, Camp Hill, Cumberland County, Pennsylvania 17011. 2. Defendant is Christopher Passamonte and Janna Passamonte, husband and wife, are adult individuals residing at 1296 Kingsley Road, Camp Hill, Cumberland County, Pennsylvania. 3. On or about November 25, 2003, Defendant Passamonte, engaged the Plaintiff for legal services concerning criminal matters per the terms outlined and agreed to by the Defendant per written fee agreement. (See Exhibit "A") 4. Plaintiff performed legal services for Defendant and submitted InVOIces to Defendant for payment. 5. Repeated demands for payment in full have been made to Defendant; however, Defendant has refused to pay same. 2 6. Defendant entered a guilty plea and was sentenced and legal representation in this matter is concluded. 7. As of August 24 2005, Defendant owes Plaintiff a balance of $3,370.36 which continues to be unpaid and is accruing interest per the written fee agreement at the rate of 1.5% per month, annually 18%. (See Exhibit "B") WHEREFORE, Plaintiff, Coyne & Coyne, P.C., respectfully requests Judgment in the amount of $3,370.36, with Court costs and Sheriffs costs and accruing interest from date of complaint filing at the rate of 1.5% per month, annually 18%. Respectfully submitted, COYNE & COYNE, P.C. ('_.~" . ' Dated: / 5' c: P ~ [; By: 3 COYNE & COYNE A PROFESSIONAL CORPORATION ATTORNEYS AT LAW HemyF. Coyne Lisa Marie Coyne Austin F. Grogan 3901 Market Street Camp Hill, Pennsylvania 17011-4227 717-737-0464 Fax: 717-737-5161 November 25, 2003 Mr. Christopher Passamonte 1296 Kingsley Road Camp Hill, PA 1701\ Re: Commonwealth v. Passamonte Dear Chris: This letter confirms our recent discussion in which I agreed, at your request, to represent you regarding the above-referenced criminal matter and I will appear on your behalf through trial or negotiated plea. Although we discussed in detail your case and the procedural position and options which you have, I did not discuss in detail my fee. As I explained to you, because of the nature of the matter, and because of the possibility of the occurrence of unpredictable and unforeseen circumstances, I am not in a position to quote you a final and specific fee for my professional services. However, I indicated to you that I would represent you on an hourly basis, My fee for professional services is ONE HUNDRED Seventy-five Dollars ($175.00) per hour, with fractions of hours computed in periods of not less than 15 minutes, which takes into account interruption of other work. Each such hour is based upon actual work regarding your particular case. Please note that this office reserves the right to modify the hourly rate and the rate of interest from time to time with advance notice to you prior to implementation of the changes. During my representation, I will provide you with periodic invoices for services rendered. Payments on invoices are due upon receipt. After thirty (30) days, if an invoice remains unpaid, in whole or in part, interest will be charged on the outstanding balance at the rate of One and a half percent (1.5%) per month, Eighteen Percent (18%) per year. Any out-of-pocket expenses directly attributable to your case, including but not limited to private investigator charges, stenographer fees, court transcripts, polygraph testings, toll calls, postage, photocopies and travel expenses, will be charged to you at cost in addition to the fee. Legal costs and expenses incurred are the obligation of and are to be paid by the client upon billing of same. Exhibit "A" Mr. Christopher Passamonte November 25, 2003 Page 2 I respectfullv request vou to remit to me the sum of Fifteen Thousand ($15.000.00) as a non-refundable retainer fee. The retainer, in full, is to be remitted upon the return of this executed fee agreement which must be return to this office no later than January 21, 2004. Please note that your preliminary hearing, as you know, is scheduled for January 29, 2004. Ifthe retainer should be entirely used during the course of my representation, you will be provided an itemized invoice for services rendered and a deposit of another partial retainer may be requested at my option. I am pleased to represent you in this matter, and I assure you that I will pursue your matter as diligently, zealously, and expeditiously as possible. Please aclmowledge receipt of this letter and your agreement to same by signing a copy and returning same in the enclosed envelope, postage prepaid. With best personal wishes to you, I remain-- Very truly yours, AFG/amd Enclosure r;oYJfE & C~O., C. 1 :ub~ (jwA~,", F Gro I, Christopher Passamonte, have read and fully understand the statements above written. I am acknowledging my agreement to the above by signing my signature below. Dated: ~\5'\~~ (' Q,.. \~HO~ Christopher Passamonte LAW OFFICES OF COYNE & COYNE, P,C. 3901 Market Street Camp Hill, PA 17011-4227 Invoice submitted to: Mr. Christopher Passamonte 1296 Kingsley Road Camp Hill PA 17011 August 24, 2005 In Reference To: Criminal Investigation Invoice #12496 Amount Interest on overdue balance $71.58 Previous balance $71.58 $3,298.78 Total amount of this bill Balance due $3,370.36 Exhibit "B" fd~p o o<;? ~ ~. 9--- ~\ ~ - ~ , ) <./' d C) c- @ r-'~ ,..,;:.:;; ....-" c.rl (;') t'\ C) ~1l ::;J i\l~ ~' ; ;:"~l , r--.J r... ., ('t"! SHERIFF'S RETURN - REGULAR CASE NO: 2005-04548 P COMMONWEALTH OF PENNSYLVANIA: COUNTY OF CUMBERLAND COYNE & COYNE PC VS PASSAMONTE CHRISTOPHER ET AL KENNETH GOSSERT Sheriff or Deputy Sheriff of Cumberland County, pennsylvania, who being duly sworn according to law, says, the within COMPLAINT & NOTICE was served upon PASSAMONTE CHRISTOPHER the DEFENDANT , at 1424:00 HOURS, on the 20th day of September, 2005 at 716 ERFORD ROAD CAMP HILL, PA 17011 by handing to CHRISTOPHER PASSAMONTE a true and attested copy of COMPLAINT & NOTICE together with and at the same time directing His attention to the contents thereof. Sheriff's Costs: Docketing Service Postage Surcharge 18.00 24.00 .37 10.00 .00 52.37 So Answers: -f;",,">if~;':d"-i:'-l.:ft:~ R. Thomas Kline 09/21/2005 COYNE & COYNE me this day of Sworn and Subscribed to before By: SHERIFF'S RETURN - REGULAR CASE NO: 2005-04548 P COMMONWEALTH OF PENNSYLVANIA: COUNTY OF CUMBERLAND COYNE & COYNE PC VS PASSAMONTE CHRISTOPHER ET AL KENNETH GOSSERT , Sheriff or Deputy Sheriff of Cumberland County,Pennsylvania, who being duly sworn according to law, says, the within COMPLAINT & NOTICE was served upon PASSAMONTE JANNA the DEFENDANT , at 1424:00 HOURS, on the 20th day of September, 2005 at 1296 KINGSLEY ROAD CAMP HILL, PA 17011 by handing to CHRISTOPHER PASSAMONTE, HUSBAND a true and attested copy of COMPLAINT & NOTICE together with and at the same time directing His attention to the contents thereof. Sheriff's Costs: Docketing Service Affidavit Surcharge So Answers: 6.00 .00 .00 10.00 .00 16.00 -.. ",,~," ~~'''''//",.;,'f''' ),,, ~:::;'::~';~~. ".' '~~~', " - ~~ "'c.'".,~.- R. Thomas Kline 09/21/2005 COYNE & COYNE A.D. Sworn and Subscribed to before By: me this day of COYNE & COYNE, P.C. BY: Henry F. Coyne, Esquire Pa. Supreme Ct. No. 06250 Lisa Marie Coyne, Esquire Pa. Supreme Ct. No. 53788 3901 Market Street Camp HilI, PAl 70 I 1-4227 (717) 737-0464 Attorneys for Plaintiffs COYNE & COYNE, P.e., Plaintiff : IN THE COURT OF COMMON PLEAS OF : CUMBERLAND COUNTY, PENNSYL VANIA vs. : NO. 05-4548 CIVIL TERM CHRISTOPHER PASSAMONTE and JANNA P ASSAMONTE, his wife Defendants : CIVIL ACTION--LA W To the Prothonotary: Please mark the above-captioned action settled and discontinued. COYNE & COYNE, P.C. Dated: 10 fl:>-Ia) By: 1i~ii2#(~ 3901 Market Street CampHiII,PA 17011-4227 (71 7) 737-0464 Pa. S. Ct. No. 06250 ':::2 '-~~ ~ C) ::.=:~ w o -n ....; MF~: i~._,. I,.!? co