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Home My WebLink About06-3169 , COYNE & COYNE, P.C. Lisa Marie Coyne, Esq. Pa. Supreme Ct. No. 53788 3901 Market Street Camp Hill, P A 17011-4227 (717) 737-0464 (j. COYNE & COYNE, P.C., Plaintiff Atf-' P/ahoUff : IN THE COURT OF COJwON PLEAS OF : CUMBERLAND comiTY: PENNSYLVANIA , ! vs. : NO. tk - ~(C4 C TERM JOSEPH COREY KEEFER Defendant : CIVIL ACTION--LAW NOTICE YOU HAVE BEEN SUED IN COURT. If you wish to defend a ainst the claims set forth in the following pages, you must take action within twenty (20) days after thi Notice is served, by entering a written appearance personally or by an attorney and filing in writing ith 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 our! without further notice for any money claimed in the Complaint or for any other claim or relief r uested by the Defendant. You may lose money or property or other rights important to you, YOU SHOULD TAKE THIS PAPER TO YOUR LAWYER AT ONC LAWYER OR CANNOT AFFORD ONE, GO TO OR TELEPHO BELOW TO FIND OUT WHERE YOU CAN GET LEGAL HELP. . IF YOU DO NOT HAVE A THE OFFICE SET FORTH Cumberland County Lawyer Referral Servi e 32 S, Bedford Street Carlisle, P A 17013 (717) 240-6200 I COYNE & COYNE, P.C. Lisa Marie Coyne, Esq. Pa, Supreme Ct. No, 53788 3901 Market Street Camp Hill, P A 17011-4227 (717) 737-0464 Attorn s for Plaintiff ON PLEAS OF , PENNSYLVANIA COYNE & COYNE, P.C., Plaintiff : IN THE COURT OF CO : CUMBERLAND COUN vs. : NO. 0(,' ..3'/(. 9 i C~IL TERM JOSEPH COREY KEEFER Defendant : CIVIL ACTION--LA W COMPLAINT AND NOW comes the Plaintiff, Coyne & Coyne, P.C., and files t within Complaint: 1. Plaintiff is Coyne & Coyne, P.C. a Professional Corporati n, with offices located at 3901 Market Street, Camp Hill, Cumberland County, Pennsylvania 17011. 2. Defendant is Joseph Corey Keefer is an adult individua residing at R.D. 1, Box 425, Liverpool, Perry County, Pennsylvania 17045. 3. On or about February 19,2002, Defendant Joseph Corey eefer, engaged the Plaintiff for legal services concerning a criminal matter per the terms outlined and agr ed to by the Defendant as per a written Fee Agreement. (See Exhibit "A"). 4. Plaintiff performed legal services for Defendant and subrni ed an invoice to Defendant for payment. 5. Repeated demands for payment in full have been made to efendant; however, Defendant has refused to pay in full same. 6. As of May 8, 2006, Defendant owes Plaintiff $5,423.51 balance due and owing under the written fee agreement with an interest rate of 1.5% per month, annuall 18%. (See Exhibit "B") 2 WHEREFORE, Plaintiff, Coyne & Coyne, P.C., respectfully req ests Judgment in the amount of $5,423.51, together with Court costs and Sheriffs costs and accruing nterest from date of complaint filing at the rate of 1.5% per month, annually 18%. Respectfully submitted, COYNE & COYNE, P.C. Dated: tjt;/ or- f 11 MARIECO 901 Market Street Camp Hill, P A 1701 -4227 (717) 737-0464 Pa. S, Ct. No. 53788 3 COYNE & COYNE A PROFESSIONAL CORPORATION ATTORNEYS AT LAW HenryF. Coyne Lisa Marie Coyne Austin F. Grogan 3901 Market Street Camp Hill, Pennsylvania 11011-4227 November 1,2003 Mr. Joseph C. Keefer P.O. B01112 Richfield, P A 17086 Re: Commonwealth v. Keefer Dear Joseph: 717-737-0464 Fax: 717-737-5161 Enclosed are invoices itemizing the time dedicated to your represenUr 'on in the above-referenced criminal case. I also enclose a copy of the fee agreement, which you exec d at the start of this case. As indicated in the fee agreement the payment of $7 ,000.00 covered your r sentation through plea and sentence. On November 26, 2002, sentence was imposed upon you per ur guilty plea, entered on September 23, 2002. As you know, since your sentence has been imposed, additional work has been undertaken in this matter. I have continued in the representation at the reduced hourly rate of$ 50.00. My standard hourly rate is $175,00. The post-sentence time dedicated to your case is presently 8.75 hours, At the rate of $150.00 per hour, the total cost of post-sentence work is $4,312.50. As a ofessional courtesy to you, however, I have reduced that itemized amount to $2,500.00. I have ann tated the discount on the attached invoice. Future work will be billed at the rate of$150.00. If you have any questions concerning this discount or the billin innnediately. Otherwise, if you are in agreement with the discount, I respec time, A stamped envelope has been enclosed for your use. With best personal wishes to you, I remain- v cry truly yours, LMC/cmc Enclosures status, please contact me ly request payment at this .c. EXHIBIT "A" /' COYNE & COYNE A PROFESSIONAL CORPORATION ATTORNEYS AT LAW HenryF. Coyne Lisa Marie Coyne 3901 Market Street Camp Hill, Pennsy:Ivania 17011-4227 February 19, 2002 Mr. Joseph C. Keefer P.O. Box 112 Richfield, P A 17086 Re: Commonwealth v. Keefer Dear Joseph: ~, 0'~ .. 717-737-0464 Fax: 717-737-5161 -~ This letter confirms our recent discussion in which I agreed, at yo request, to represent you regarding the above-referenced criminal matter and that I will appear on yo behalf at the preliminary hearing yet to be rescheduled by District Justice Savidge. I will represent y u through trial verdict/plea and sentence. This representation does not include appellate representation 0 post-trial matters. . _' _ ", ,...r , . Although we di~cussed in detail your case' and the procedural pos' . on of the case as well as options which you have, I did not discuss in detail my fee. My fee for pi fessional services is Seven Thousand Dollars ($7,000.00) which covers my representation through trial. Any out-of-pocket expenses directly attributable to your case, includi g but not limited to private investigator charges, court transcripts, toll calls, postage, photocopies an travel expenses, will be charged to you at cost in addition to the fee. Legal costs and expenses incurr d are the obligation of and are to be paid by the client upon billing of same. I respectfully request you to remit to me the sum of Seven Thousan Dollars ($7,000.00) which is to be remitted upon the return of this executed fee agreement. , 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 acknowledge receipt of thi~ letter and your agreement to s e by signing a copy and returning sarne in the enClosed envelope, postage prepaid: , Mr:Joseph C. Keefer February 19, 2002 Page 2 With best personal wishes to you, I remain-- v cry truly yours, COYNE & COYNE P.C. ;b.~ LMC/cmc Enclosure 1, JOSEPH C KEEFER, have read and fully understand the stat ents above written. I am acknowledging my agreement to the above by signing my signature below. Dated: )/"'/'0:'" LAW OFFICES OF COYNE & COYNE, P.C. 3901 Market Street Camp Hill, PA 17011-4227 Invoice submitted to: Mr. Joseph C. Keefer R. D.1, Box 425 Liverpool PA 17045 May 08, 2006 In Reference To: Commonwealth v. Keefer Invoice #13002 Interest on overdue balance Total amount of this bill Previous balance Balance due EXHIBIT "B" Amount $127.03 $127.03 $5,296.48 $5,423.51 . , VERmCATION The facts set forth in the foregoing are true and correct to the best 0 the undersigned's knowledge, information and belief and are verified subject to the penalties for unsworn falsification to authorities under 18 Pa. C.S.A. ~4904. Dated: r../~-/o ~ / I 1L- ~~~ -~ "'" ~ - -.j ~ ~ -.) ~ ~ ('J ~~:':~~ ,..., c::.::I ~ (-,,~ s:-~ I ", o -n ::rJ"Tl n1F :~18 ;~~~ ~_-_.)rn '.~<l '<, on '< 4J .-JO... C'.) r,,' w ,.' ,,*- ~ COYNE & COYNE, P.C. Lisa Marie Coyne, Esq. Pa. Supreme Ct. No. 53788 3901 Market Street Camp Hill, PA 17011-4227 (717) 737-0464 Attorneys for Plaintiff COYNE & COYNE, P.C., Plaintiff : IN THE COURT OF COMMON PLEAS OF : CUMBERLAND COUNTY, PENNSYL VANIA vs. : NO. 06-3169 CIVIL TERM JOSEPH COREY KEEFER, Defendant. : CIVIL ACTION-LAW PRAECIPE TO DISCONTINUE TO THE PROTHONTOARY: Kindly mark this matter as settled and discontinued. COYNE & COYNE, P.C. Dated:~ By: A MARIE COYNE 901 Market Street Camp Hill, PA 17011-4227 (717) 737-0464 Pa. S. Ct. No. 53788 Attorney for Plaintiff I ~, "'" CERTIFICATE OF SERVICE I, Lisa Marie Coyne, Esquire, hereby certify that a true copy of the Praecipe to Discontinue was served upon the below-referenced individual by sending the same by first class mail, postage prepaid, addressed as follows: Joseph Corey Keefer RD 1, Box 425 Liverpool, P A 17045 11~1(o ~ Dated: 2 ".. - 1 ( .-..-1 , ." N ,.-,-, r') :",) __.1 SHERIFF'S RETURN - OUT OF COUNTY r \ CASE NO: 2006-03169 P COMMONWEALTH OF PENNSYLVANIA: COUNTY OF CUMBERLAND COYNE & COYNE PC VS KEEFER JOSEPH COREY R. Thomas Kline / Sheriff or Deputy Sheriff who being duly sworn according to law/ says/ that he made a diligent search and and inquiry for the within named DEFENDANT / to wit: but was unable to locate Him In his bailiwick. He therefore - ,,- - -a ...... - - KEEFER JOSEPH COREY deputized the sheriff of PERRY County/ pennsylvania/ to - serve the within COMPLAINT & NOTICE 15th / 2006 / this office was in receipt of the On June attached return from PERRY Sheriff's Costs: Docketing Out of County Surcharge Dep Perry County Postage So 18.00 9.00 10.00 30.80 1. 02 68.82 /' 06/15/2006 ~, COYNE & COYNE ,/ R. Thomas Kline Sheriff of Cumberland County '1. I 7-0<" Sworn and subscribe to before me - - - ....... -- day of - - this A.D. .- - -' -. In The Court of Common Pleas of Cumberland County, Pennsylvania Coyne & Coyne vs. Joseph Corey Keefer No. 06-3169 civil Now June 61 2006 , , I, SHERIFF OF CUMBERLAND COUNTY, P A, do hereby deputize the Sheriff of Perry County to execute this Writ, this deputation being made at the request and risk of the Plaintiff. .r~~ Sheriff of Cumberland County, PA Affidavit of Senrice Now June 12, , 2006 at 12: 26 o'clock P , -' M. served the within Notice & Complaint upon Joseph Corey Keefer at RD1 Box 425 Liverpool, PA 17045 by handing to Kathy Keefer, Defendants Wife a True & Attes ted copy of the original Notice & Complaint and made known to Her the contents thereof. So answers, Donald E. Smith &~ (t)C~~ ---=:> Dep. Sheriff of Perry County, PA Chief ,20~ COSTS SERVICE MILEAGE AFFIDAVIT $ NOTARIAL SEAL . lfARGAm F. FLICKINGER. NOTARY PU8UC BlOOMAELD BORQ., PERRY COUNTY '. MY COMMISSION EXPIRES FEB. 16. 2008 $ E S : II '\/ h I Nnr qOOZ Vd 'AINi 10,-, Jt{iH:Ui:H-ln:J .:l.:iIH3HS 3Hl .:10 38I.:JdO , '"-i