The URL can be used to link to this page

Home My WebLink About06-44420 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. ROBERT W. HOLLINGER Defendant IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA NO. V - g4/Jot 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. ROBERT W. HOLLINGER Defendant IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA NO. 0 6 YyYa 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 Robert W. Hollinger is an adult individual residing at 6284 Main Street, East Petersburg, Lancaster County, Pennsylvania. 3. On or about June 10, 2005, Defendant Robert W. Hollinger engaged the Plaintiff for legal services concerning a custody 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 and 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 in full same. 6. As of August 1, 2006, Defendant owes Plaintiff $4,853.15 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 r WHEREFORE, Plaintiff, Coyne & Coyne, P.C., respectfully requests Judgment in the amount of $4,853.15, 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%. Respectfully submitted, COYNE & COYNE, P.C. Dated: y / 4-y Ci- m By: LI A MARIE COYTIE, ESQUIRE Y, S. Ct. No. 537881 3901 Market Street Camp Hill, PA 17011-4227 (717) 737-0464 3 COYNE & COYNE A PROFESSIONAL CORPORATION ATTORNEYS AT LAW Henry F. Coyne Lisa Marie Coyne Austin F. Grogan 3901 Market Street 717-737.0464 Camp Hill, Pennsylvania Fax: 717-737-5161 17011.4227 June 10, 2005 Mr. Robert W. Hollinger 6284 Main Street East Petersburg, PA 17520 Re: Custody Dear Bob: It was a pleasure meeting with you this afternoon concerning custody of your son, Austin David Hollinger. As we discussed, the following is a written fee agreement which I ask you to review and return to me at your convenience. 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. We will provide you periodic invoices for services rendered. Payments on invoices are due upon receipt. After thirty (30) days, if an invoice remains unpaid, interest will be charged on the outstanding monthly.balance at the rate of One and a half Percent (1.5%), annually Eighteen Percent (18%). This office reserves the right to modify the hourly rate and the rate of interest from time to time with advance notices to you should those changes be implemented. We respectfully request you to remit to me the sum of Two Thousand Five Hundred Dollars ($2,500.00) as a retainer fee. This retainer will be credited to your account for services rendered in connection with this case. As work is performed on your behalf, you will be provided itemized invoices. We expect you to keep current with our billings. We reserve the right to terminate our attorney-client relationship for non-payment of fees or costs. If this custody action progresses and the initial retainer is depleted; you will be required to deposit additional retainers. It is impossible to predict a course that a custody action will take. Therefore, it is important that you keep me informed of any and all changes in your life once my representation commences. We shall keep you well informed as to the progress of your case. We will send you copies of all papers coming in and going out of our offices, including correspondence, pleadings, and other court documents. Do not make changes or take what may seem like unimportant steps without consultation with me first. Do not hesitate to ask questions. V' EX ?r , >< r/7 12- Mr. Robert W. Hollinger June 10, 2005 Page 2 If I am unavailable when you telephone, your call will be returned with reasonable promptness. There will be times when I will be in court, or at meetings, or in conference, which will preclude me from returning your call as quickly as we both might like, but I shall do my best to return your telephone calls as soon as I can. I am pleased to represent you in this matter, and I assure you that I will pursue your matter diligently and expeditiously and with my best efforts and expertise, 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, LMClcmc Enclosure I, ROBERT W. HOLLINGER, have am acknowledging my agreement to the abq Dated: `e--n DS COYNE & COYNE, P.C. 1 Y ?^-Li Mane Coyne understand the statements above written. I ROBERT W. o. dj Z LAW OFFICES OF COYNE & COYNE, P.C. 3901 Market Street Camp Hill, PA 17011-4227 Invoice submitted to: Mr. Robert W. Hollinger 6284 Main Street East Petersburg PA 17520 August 01, 2006 In Reference To: Child Custody Modification Invoice #13121 iAterest on overdue balance- Total amount of this bill Previous balance Balance due Amount $132.69 " $132.69 $4,720.46 $4,653.15 ?i r-> '? .t _' 4 ?,. °? ? /. ? (V "r 'pp? _. f 0 SHERIFF'S RETURN - OUT OF COUNTY V ryy?SE NO: 2006-04442 P NC MMONWEALTH OF PENNSYLVANIA: COUNTY OF CUMBERLAND COYNE & COYNE PC VS HOLLINGER ROBERT W 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 TT T T TTT!'YT?n n?nnTim T.T , to wit: but was unable to locate. Him in his bailiwick. He therefore deputized the sheriff of LANCASTER County, Pennsylvania, to serve the within COMPLAINT & NOTICE On August 15th , 2006 , this office was in receipt o attached return from LANCASTER Sheriff's Costs: Docketing Out of County Surcharge Dep Lancaster Co Postage 18.00 9.00 10.00 40.95 7 9.21 ? C.,,,,, 08/15/2006 COYNE & COYNE So answ- r R. Thomas Kline--- Sheriff of Cumberland County 9J? S/ b i, Sworn and subscribe to before me this day of A. D. 113440 C SHERIFF'S OFFICE 50 NORTH DUKE STREET, P.O. BOX 83480, LANCASTER, PENNSYLVANIA 17608-3480 a (717) 299-8200 ?hg SHERIFF SERVICE PLEASE TYPE OR PRINT LEGIBLY. PROCESS RECEIPT, and AFFIDAVIT OF RETURN DO NOT DETACH ANY COPIES. 1 PLAINTIFF/S/ 2 COURT NUMBER PC 06-4442 civil 3 DEFENDANT/S/ 4 TYPE OF WRIT OR COMPLAINT Robert- W Hollinger Notice and Complaint 3 H n M 0 t" L71 H z c? C+7 SERVE 5 NAME OF INDIVIDUAL. COMPANY. CORPORATION, ETC. TO BE SERVED Rnhart w- Hollinger 6 ADDRESS (Street or RFD, Apartment No.. City, Boro, Twp., State and ZIP Code) AT 6284 MAin Street East Petersburg, PA 7 INDICATE UNUSUAL SERVICE: ? DEPUTIZE ? OTHER Cumberland Now, A11attst 4 20 06 1, SHERIFF OF l?'iM4SRiQ1R COUNTY, PA., do hereby deputize the She if f T,Anra,Gtar County to execute this Writ3turn t eof ng to law. This deDutation being made at the reauest and risk of the Dlaintiff. -110 e. SPECIAL INSTRUCTIONS OR OTHER INFORMATION THAT WILL ASSIST IN EXPEDITING SERVICE: CLinberlan Please mail return of service to Cumberland County Sheriff. Thank you. NOTE ONLY APPLICABLE ON WRIT OF EXECUTION: N.B. WAIVER OF WATCHMAN - Any deputy sheriff levying upon or attaching any properly under within writ may leave same without a watchman, in custody of whomever is found in possession, after notifying person of levy or attachment, without liability on the part of such deputy or the sheriff to any plaintiff herein for any loss, destruction or removal of any such property before sheriff's sale thereof 9. SIGNATURE of ATTORNEY or other ORIGINATOR 10 TELEPHONE NUMBER 11 DATE LISA MARIE COYNE, ESQ. = 717-737-0464 8/3/06 12. SEND NOTICE OF SERVICE COPY TO NAME AND ADDRESS BELOW: (This area must be completed if notice is to be mailed) CUMBERLAND COUNTY SHERIFF ONE COURT. HOUSE SQUARE CARLISLE, FVA. 17013 SPACE BELOW FOR USE OF SHERIFF ONLY - DO NOT WRITE BELOW THIS LINE 13.1 acknowledge receipt of the writ t NAME of Authorized LCSO Deputy or Clerk 14 Date Received 15 Expiration/Hearing date orcomplaintasindicated above. ( JAEQKIE MICCICHE 717-390-2309 8/7/06 1 9/5/06 16. I hereby CERTIFY and RETURN that 11l, ave personally served, ? have legal evidence of service as shown in "Remarks", L] have executed as shown in ' Remarks", the writ or complaint described on the individual, company, corporation, etc., at the address shown above or on the individual, company, cor- poration, etc., at the address inserted below by handing a TRUE and ATTESTED COPY thereof. 17 ? 1 hereby certify and return a NOT FOUND because I am unable to locate the individual, company, corporation, etc , named above (See remarks below) 18 Name and title of individual served (if not shown above) (Relationship to Defendant) 19 ?No ce Servi See Remarks Below (No. 30) 20 Address of where served (complete only if different than shown above) (Street or RFD. Apart ment No , City, Boro. Twp 21 Date of Service 22 Time State and Zip Code) 2: Zo EDST 23. ATTEMPTS to Miles Dep. Int. Date Miles Dep. Int. Date Miles Dep. Int. Date Miles Dep. Int. Date Miles Dep. Int. 1 to VAA? 24. Advance Cost 25. Service Costs 26. Notary Cent 27 Mile#gp/PostageLN_F 28 Total Costs 29 COST DUE OR REFUND w 30. REMARK ?r8imon1d1a atih of h'E# n f i'°.:'s. S.T.A.: NOTARIAL SEAL ? L J °"1.1NIFER L. DUNCAN, Ncl_%ry Ptlalic ??? ;1 Laric^star City, Lancaster ;;party to Q "Viy Commission Expires juiy ill, 4308 3 t? p f tS? 4SO fl ok. 31. AFFIRMED and subscribed to before me this I J\/ nature '? 33 ate Dep Sheen . - ??\n De p 34. day of 20 Q?Q Curtis R. Long Prothonotary office of the Protbonotarp Cumberfanb Countp Renee K. Simpson Deputy Prothonotary John E. Slike Solicitor (?)p -!g4jq Zo?CVIL TERM ORDER OF TERMINATION OF COURT CASES AND NOW THIS 28TH DAY OF OCTOBER, 2009, AFTER MAILING NOTICE OF INTENTION TO PROCEED AND RECEIVING NO RESPONSE - THE ABOVE CASE IS HEREBY TERMINATED WITH PREJUDICE IN ACCORDANCE WITH PA R C P 230.2. BY THE COURT, CURTIS R. LONG PROTHONOTARY One Courthouse Square • Carlisle, Pennsylvania 17013 • (717) 240-6195 • Fax (717) 240-6573