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Home My WebLink About06-4001V COYNE & COYNE, P.C. Lisa Marie Coyne, Esq. Pa. Supreme Ct. No. 53788 3901 Market Street Camp Hill, PA 17011-4227 (717) 737-0464 COYNE & COYNE, P.C., Plaintiff Vs. JAMES EDWARD ANDERSON, Defendant Attorneys for Plaintiff IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA NO. GYP' `66 CIVIL TERM CIVIL ACTION--LAW 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, PA 17013 (717) 240-6200 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 VS. JAMES EDWARD ANDERSON Defendant IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA NO. 0 6 - y04 / CIVIL TERM CIVIL ACTION--LAW COMPLAINT AND NOW comes the Plaintiff, Coyne & Coyne, P.C., and files the within Complaint: 1. 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 JAMES EDWARD ANDERSON is an adult individual residing at 31 Betty Nelson Trailer Court, Lot 128, Carlisle, Cumberland County, Pennsylvania 17013. 3. On or about October 24, 2003, Defendant James Edward Anderson, engaged the Plaintiff for legal services concerning a criminal matter per the terms outlined and agreed to by the Defendant as per a written Fee Agreement. (See Exhibit "A"). 4. Plaintiff performed legal services for Defendant which resulted in an acquittal of all criminal charges and Plaintiff submitted an invoice to Defendant for payment. 5. Repeated demands for payment in full have been made to Defendant; however, Defendant has refused to pay same in full. 6. As of July 13, 2006, Defendant owes Plaintiff $11,911.72 as balance due and owing under the written fee agreement with an interest rate of 1.5% per month, annually 18%. (See Exhibit "B") 2 WHEREFORE, Plaintiff, Coyne & Coyne, P.C., respectfully requests Judgment in the amount of $11,911.72, together with Court costs and Sheriff's costs and accruing interest from date of complaint filing at the rate of 1.5% per month, annually 18%. Dated: 8 Respectfully submitted, COYNE & COYNE, P.C. By: LI A MARIE CO , ESQUIRE a. S. Ct. No. 53788 3901 Market Street Camp Hill, PA 17011-4227 (717) 737-0464 COYNE & COYNE A PROFESSIONAL CORPORATION ATTORNEYS AT LAW Henry F. Coyne 3901 Market Street 717-737.0464 Lisa Marie Coyne Camp Hill, Pennsylvania Fax: 717-737.5161 Austin F. Grogan 17011-4227 October 22, 2003 Mr. James Anderson Cumberland County Prison Carlisle, PA 17013 Re: Commonwealth V. Anderson Dear Mr. Anderson: 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 at the preliminary hearing scheduled on Octoberp,, 2003. 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, court transcripts, 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. ,?7> i I respectfully request you to remit to me the sum of Two Thousand Dollars ($2,000.00) as a non-refundable retainer fee. The retainer is to be remitted upon the return of this executed fee agreement. If the 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 acknowledge 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, COYNE & COYNE, P.C. N kustin Grogan AFG/amd Enclosure I, James Anlerson„ have read and fully understand the statements above written. I am acknowledging my agreement to the above by signing my signature below. Dated:200, n; COYNE & COYNE A PROFESSIONAL CORPORATION ATTORNEYS AT LAW Henry F. Coyne Lisa Marie Coyne Austin F. Grogan Mr. James Anderson 46 Betty Nelson Court Lot 127 Carlisle, PA 1013 Dear James: 3901 Market Street Camp Hill, Pennsylvania 17011-4227 November 24, 2003 Re: Commonwealth v. Anderson 717-737-0464 Fax: 717-737-5161 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, court transcripts, 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. 3V LAW OFFICES OF COYNE & COYNE, P.C. 3901 Market Street Camp Hill, PA 17011-4227 Invoice submitted to: James Anderson 31 Betty Nelson Trailer Court Lot 128 Carlisle PA 17013 July 13, 2006 In Reference To: Various Felony and Misdemeanor Charges Invoice #13109 Interest on overdue balance Total amount of this bill Previous balance Balance due Amount $74.38 $74.38 $11,837,34 $11,911.72 ?Exx'/, L Sa VERIFICATION The facts set forth in the foregoing are true and correct to the best of the undersigned's knowledge, information and belief and are verified subject to the penalties for unworn falsification to authorities under 18 Pa. C.S.A. § 4904. Dated: rf 3 ?? b r / ? op ?. ?i Ql? 0 COYNE & COYNE, P.C. Lisa Marie Coyne, Esq, Pa. Supreme Ct. No. 53788 3901 Market Street Camp Hill, PA 17011-4227 (717) 737-0464 COYNE & COYNE, P.C., Plaintiff Vs. JAMES EDWARD ANDERSON Defendant TO: Mr. James Edward Anderson 31 Betty Nelson Trailer Court, Lot 128 Carlisle, PA 17013 DATE OF NOTICE: August 15, 2006 Attorneys for Plaintiff IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA NO. 06-4001 CIVIL TERM CIVIL ACTION--LAW IMPORTANT NOTICE YOU ARE IN DEFAULT BECAUSE YOU HAVE FAILED TO ENTER A WRITTEN APPEARANCE PERSONALLY OR BY ATTORNEY AND FILE IN WRITING WITH THE COURT YOUR DEFENSES OR OBJECTIONS TO THE CLAIMS SET FORTH AGAINST YOU. UNLESS YOU ACT WITHIN TEN (10) DAYS FROM THE DATE OF THIS NOTICE, A JUDGEMENT MAY BE ENTERED AGAINST YOU WITHOUT A HEARING AND YOU MAY LOSE YOUR PROPERTY OR OTHER IMPORTANT RIGHTS. YOU SHOULD TAKE THIS NOTICE TO A LAWYER AT ONCE, IF YOU DO NOT HAVE A LAWYER OR CANNNOT AFFORD ONE, GO TO OR TELEPHONE THE FOLLOWING OFFICE TO FIND OUT WHERE YOU CAN GET LEGAL HELP: Cumberland County Lawyer Referral System Cumberland County Bar Association 32 S. Bedford Street Carlisle, PA 17013 1-800-990-9108 COYNE & COYNE, P.C. Date: August 15, 2006 ISA MARIE COYNE, Es wire 901 Market Street Camp Hill, PA 170114227 (717) 737-0464 Pa. S. Ct. No. 53788 Plaintiff It CERTIFICATE OF SERVICE I, Lisa Marie Coyne, Esquire, of Coyne & Coyne, P.C., hereby certify that true copy of the foregoing Ten Day Notice was served this date upon the below-referenced individual at the below listed address by way of first class mail, postage pre-paid: Mr. James Edward Anderson 31 Betty Nelson Trailer Court, Lot 128 Carlisle, PA 17013 Dated: Stib ??L? 0? L s Marie Coyne 4 ?i SHERIFF'S RETURN - REGULAR CASE NO: 2006-04001 P COMMONWEALTH OF PENNSYLVANIA: COUNTY OF CUMBERLAND COYNE & COYNE PC VS ANDERSON JAMES EDWARD VALERIE WEARY , Sheriff or Deputy Sheriff of Cumberland County,Pennsylvania, who being duly sworn according to law, says, the within COMPLAINT & NOTICE was served upon ANDERSON JAMES EDWARD the DEFENDANT , at 1708:00 HOURS, on the 24th day of July 2006 at 31 BETTY NELSON TRAILER COURT LOT 128 CARLISLE, PA 17013 by handing to JAMES EDWARD ANDERSON 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: So An?swera.^. Docketing 18.00 Service 4.40 Postage .39 Surcharge 10.00 R. Thomas Kline .00 32.79 ? 07/25/2006 ? COYNE & COYNE Sworn and Subscibed to By: before me this day Deputy eriff of A. D. 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., : IN THE COURT OF COMMON PLEAS OF Plaintiff : CUMBERLAND COUNTY, PENNSYLVANIA vs. JAMES EDWARD ANDERSON Defendant : NO. 06-4001 CIVIL TERM CIVIL ACTION--LAW PRAECIPE FOR ENTRY OF DEFAULT JUDGMENT TO THE PROTHONOTARY: Please enter judgment of default in favor of plaintiff, COYNE & COYNE, P.C., and against defendant, James Edward Anderson, for failure to plead to the complaint in this action within the required time. The complaint contains a notice to defend within 20 days from the date of service thereof. Defendant was served with the complaint on July 24, 2006, and defendant's answer was due to be filed on August 13, 2006. Attached as Exhibit "A" is a copy of plaintiff's written Notice of Intention to File Praecipe for Entry of Default Judgment, which I certify was mailed by regular mail to the defendant at his last known address on August 15, 2006, which was served at least 10 days prior to the filing of this Praecipe. Please enter judgment in favor of Plaintiff and assess damages in the amount of $17,784.59 and accruing interest at the rate of 18% APY and court costs, being the amount demanded in the complaint. Date lilt 0 COYNE & COYNE, P.C. By: = is Marie Coyne, E uire 0,0upreme Ct. No.S 788 3901 Market Street Camp Hill, PA 17011-4227 (717) 737-0464 Attorney for Plaintiff COYNE & COYNE, P.C. Lisa Marie Coyne, Esq. j(` r y ,, Pa. Supreme Ct. No. 53788 + ? -,- a 3901 Market Street a„ Camp Hill, PA 17011-4227 (717) 737-0464 Attorneys for Plaintiff COYNE & COYNE, P.C., : IN THE COURT OF COMMON PLEAS OF Plaintiff : CUMBERLAND COUNTY, PENNSYLVANIA vs. : NO. 06-4001 CIVIL TERM JAMES EDWARD ANDERSON : CIVIL ACTION--LAW Defendant : C 0 - TO: Mr. James Edward Anderson s?• 31 Betty Nelson Trailer Court, Lot 128 m Carlisle, PA 17013 C nQ DATE OF NOTICE: August 15, 2006 z D M C GJ 5 IMPORT ANT NOTICE _ YOU ARE IN DEFAULT BECAUSE YOU HAVE FAILED TO ENTER A WRITTEN APPEARANCE PERSONALLY OR BY ATTORNEY AND FILE IN WRITING WITH THE COURT YOUR DEFENSES OR OBJECTIONS TO THE CLAIMS SET FORTH AGAINST YOU, UNLESS YOU ACT WITHIN TEN (10) DAYS FROM THE DATE OF THIS NOTICE, A JUDGEMENT MAY BE ENTERED AGAINST YOU WITHOUT A HEARING AND YOU MAY LOSE YOUR PROPERTY OR OTHER RvIPORTANT- RIGHTS. YOU SHOULD TAKE THIS NOTICE TO A LAWYER AT ONCE, IF YOU DO NOT HAVE A LAWYER OR CANNNOT AFFORD ONE, GO TO OR TELEPHONE THE FOLLOWING OFFICE TO FIND OUT WHERE YOU CAN GET LEGAL HELP: Cumberland County Lawyer Referral System Cumberland County Bar Association 32 S. Bedford Street Carlisle, PA 17013 1-800-990-9108 COYNE & COYNE, P.C. Date: August 15, 2006 , L 7kv" aISA MARIE COYNE, E uire 901 Market Street Camp Hill, PA 17011-4227 (717) 737-0464 Pa. S. Ct. No. 53788 Plaintiff ., a ?'XHi13?T l9 CERTIFICATE OF SERVICE L Lisa Marie Coyne, Esquire, of Coyne & Coyne, P.C., hereby certify that true copy of the foregoing Ten Day Notice was served this date upon the below-referenced individual at the below listed address by way of first class mail, postage pre-paid: Mr. James Edward Anderson 31 Betty Nelson. Trailer Court, Lot 128 Carlisle, PA 17013 Dated: ?Ob r 0,-- LyMarie Coyne F CERTIFICATE OF SERVICE I, Lisa Marie Coyne, Esquire, of Coyne & Coyne, P.C., hereby certify that true copy of the foregoing Praecipe for Entry of Default Judgment was served this date upon the below-referenced individual at the below listed address by way of first class mail, postage pre-paid: Mr. James Edward Anderson 31 Betty Nelson Trailer Court, Lot 128 Carlisle, PA 17013 Dated: (O Z.l 0 9 CsMarie Coyne t c-n 1 0 u