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Home My WebLink About06-5463 BRADLEY L. GRIFFIE, t/d/b/a IN THE COURT OF COMMON PLEAS OF GRIFFIE AND ASSOCIATES, : CUMBERLAND COUNTY, PENNSYLVANIA Plaintiff V. CIVIL ACTION - LAW DONNA L. SAYERS :No. 01-5-y6 3 CIVIL TERM Defendants NOTICE TO DEFEND AND CLAIM RIGHTS 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 or 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, GO TO OR TELEPHONE THE OFFICE SET FORTH BELOW. 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, PA 17013 800-990-9108(PA only) (717) 249-3166 BRADLEY L. GRIFFIE, t/d/b/a GRIFFIE AND ASSOCIATES, Plaintiff V. DONNA L. SAYERS Defendant IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL ACTION - LAW : No. PG - 50 G--' CIVIL TERM COMPLAINT AND NOW COMES, Plaintiff, Bradley L. Griffie, Esquire, t/d/b/a Griffie and Associates and files the following Complaint: 1. Plaintiff is Bradley L. Griffie, Esquire, t/d/b/a Griffie and Associates, is an adult individual with a business address of 200 North Hanover Street, Carlisle, Pennsylvania. 2. Defendant is Donna L. Sayers an adult individual currently residing at 1275 Valley Street, Marysville, Pennsylvania. 3. Plaintiff engages in the practice of law, providing services to the general public, and was so engaged at all times related to these proceedings. 4. On or about May 15, 2001 Defendant contacted Plaintiff's law firm and requested legal representation from Plaintiff relative to a prospective divorce case and related collateral issues. 5. Defendant retained the Plaintiff to provide services personally and through his associates in regards to her then pending divorce action and related proceedings. 6. For the period from May 15, 2001 until December 14, 2005. Plaintiff and his associates provided multiple services for which the Defendant was routinely provided with itemized billings. 7. Plaintiff personally met with Respondent in 2005, which meetings included a review of the outstanding billings for services rendered on behalf of the Defendant and discussions of payment arrangements to see that the outstanding obligation owed from Defendant to Plaintiff would be paid in full. 8. At no time did Defendant object to the fees for services rendered and, in fact, repeatedly reaffirmed that the fees for outstanding service would be paid in full by the Defendant to the Plaintiff. 9. Despite providing itemized billings and making repeated requests for payment for services rendered, Defendant has failed and refused to pay for services rendered for the periods indicated, together with interest and costs for said services. 10. Defendant executed a fee agreement letter or engagement letter, which is attached hereto and incorporate as hereby reference as Exhibit "A" in which she agreed to pay for services provided by Plaintiff and his associates. 11. At present, the total amount due and owing from the Defendant to the Plaintiff for services rendered, including fees costs and interest is 15,076.65. WHEREFORE, Plaintiff requests your Honorable Court to enter judgment against the Defendant and in favor of Plaintiff in the amount of 15,076.65, together with costs, fees, and ongoing interest, until said amount is paid full, and in an amount requiring arbitration. y submitted, . Griffie, Esquire Bf- North Hanover Street Carlisle, PA 17013 (717)243-5551 (800)347-5552 VERIFICATION I verify that the statements made in the foregoing document are true and correct. I understand that false statements herein are made subject to the penalties of 18 Pa.C.S. Section 4904, relating to unsworn falsifications to authorities. DATE: S GRIFFIE & ASSOCIATES Attorneys and Counselors At Law Bradley L. Griffie, Esquire Marylou Matas, Esquire Robin J. Goshorn Legal Assistant Reply to: Carlisle June 15, 2001 Donna L. Sayers 32 Trine Avenue Mt. Holly Springs, PA 17065 RE: FEE AGREEMENT Dear Ms. Sayers: 200 North Hanover Street Carlisle. PA 17013 (717) 243-5551 1(800)347-5552 38 North Main Street Chainbersburg, PA 17201 (717) 267-1350 Fax (717) 243-5063 Thank you for consulting us regarding your legal matters. This will confirm our arrangements regarding representation of you and attorney's fees associated with representation of you in your case. From this point forward in your representation, we will keep strict track of all time expended for services rendered on your behalf. This includes, but is not limited to, telephone calls, office conferences, correspondence, attendance at meetings, hearings and similar matters. These services will be billed to you at the rate of $125.00 per hour. While you will not be billed for clerical or secretarial time, with respect to some of the services, we will use the assistance of one of our paralegals or legal assistants and bill for the paralegal's or legal assistant's services at the rate of $30.00 per hour. "Costs" will also be itemized and billed to you. "Costs" are out-of-pocket expenses, such as expert fees (e.g. accountants, appraisers), filing fees, and transcripts, as well as some long distance telephone calls, copying, postage and fax transmissions. We require a standard retainer to be paid in domestic cases in the amount of *$1,000.00. The retainer is held in our escrow or trust account. We bill against this retainer as your case progresses and notify you of this through routine billings. In the event the retainer is used in its entirety, or extensive, involved work is anticipated, we reserve the right to request an additional retainer of an appropriate amount. There are rare circumstances where a retainer could be waived, such as where an agreement is reached that fees will be paid from divorce settlement proceeds. As indicated, these circumstances are rare and, further, require the signing of a separate, recordable Note. EXHIBIT a a s We reserve the right to refuse or withdraw representation in the event retainers, quoted fees or billed fees are not timely paid. In some cases, situations may arise wherein the opposing party may be ordered to pay all or part of the other party's fees. Sometimes the court makes an order for fees and costs. Because fees and costs awards are totally unpredictable, court orders must be considered to be merely "on account" and you are primarily responsible to pay your total fee. Of course, any amounts received pursuant to a court order will be credited on your account. Our office charges interest at the rate of 1% per month or 12% per annum for any billings over 30 days old. There are circumstances when this interest can be waived, but it must be done in writing. All billings will reflect this calculated interest. You should understand that there will be times,%-.,hen I will be in Court, in meetings, or otherwise unavailable to answer your call. At such times, please feel confident to talk with my legal assistant. If you are passing on information, she can deliver it to me without the necessity of your waiting to have me return the call. If you have a question that requires an answer from me, it may be easier and more expeditious for them to obtain the background from you, bring the matter to my attention when I am free, and then have a response to you. If it is necessary that you speak with me directly, I will attempt to return your call as soon as possible. In the event you encounter difficulties in reaching me, feel free to have my staff schedule a brief telephone appointment at a designated time. Every effort will be made to expedite your case promptly and efficiently according to the highest legal and ethical standards. Please sign and date the original of this letter and return it to our office in the enclosed, self-addressed stamped envelope for our records. Retain the copy for your records. Very truly yours, n ,r Maryloi Matas, Esquire MM/rjg I agree to be legally bound by the terms set forth above. DONNA L. SAYE DATE: c?U'D *Retainer not required at this time. BRADLEY L. GRIFFIE, t/d/b/a GRIFFIE & ASSOCIATES, Plaintiff V. DONNA L. SAYERS, Defendant : IN THE COURT OF COMMON PLEAS OF : CUMBERLAND COUNTY, PENNSYLVANIA CIVIL ACTION - LAW NO. 06-5463 CIVIL TERM AFFIDAVIT OF SERVICE I confirm that I did this c day of , 2006, hand deliver a true and attested copy of a Complaint and Notice to Defend and Claim Rights at the following address: fi -. )\JA)()b Tk 410 rlrl?- + 40 41115 dpi NOTARIAL SEAL ISM J. GOSHORN, NOTARY PUBLIC CARLISLE BORO., CUMBERLAND COUNTY MY COMMISSION EXPIRES APRIL 11 200 BRADLEY L. GRIFFIE, t/d/b/a GRIFFIE AND ASSOCIATES, Plaintiff V. DONNA L. SAYERS Defendants To: Donna L. Sayers Date of Notice: October 26, 2006 IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL ACTION - LAW No. 06-5463 CIVIL TERM 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 DAYS FROM THE DATE OF THIS NOTICE, A JUDGMENT 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 CANNOT AFFORD ONE, GO TO OR TELEPHONE THE FOLLOWING OFFICE TO FIND OUT WHERE YOU CAN GET LEGAL HELP. CUMBERLAND COUNTY BAR ASSOCIATION 32 South Bedford Street Carlisle, PA 17013 800-990-9108(PA only) (717) 249-3166 Carlisle, PA 17013 (717)243-5551 (800)347-5552 0 .17 Ca BRADLEY L. GRIFFIE, t/d/b/a IN THE COURT OF COMMON PLEAS OF GRIFFIE AND ASSOCIATES, : CUMBERLAND COUNTY, PENNSYLVANIA Plaintiff V. CIVIL ACTION - LAW DONNA L. SAYERS No. 06-5463 CIVIL TERM Defendants PRAECIPE Please enter judgment by default in the above captioned matter against Defendant and in favor of Plaintiff s in the amount of $15,076.65, together with costs fees and accruing interest. Respectfully Submitted, 0 b-)- I C) C9 Dat ?-'OwIanov Street Carlisle, PA 17013 (717)243-5551 (800)347-5552 N C)D _ Gill '7 ^, n 1 •I "qw BRADLEY L. GRIFFIE, t/d/b/a IN THE COURT OF COMMON PLEAS OF GRIFFIE AND ASSOCIATES, : CUMBERLAND COUNTY, PENNSYLVANIA Plaintiff V. CIVIL ACTION - LAW DONNA L. SAYERS No. 06-5463 CIVIL TERM Defendants CERTIFICATION PURSUANT TO PENNSYLVANIA RULE OF CIVIL PROCEDURE 237.1(2) I, hereby certify that I forwarded a copy of the attached "Important Notice" to the Defendant, Donna L. Sayers by correspondence dated October 27, 2006 to her last known mailing address and to her address of service of the Complaint as follows: 117 Barric Drive, Duncannon, Pennsylvania, 17020. Respectfully Submitted, r . Griffie, Esquire r-a C? G - -v -5n co BRADLEY L. GRIFFIE, t/d/b/a GRIFFIE AND ASSOCIATES, Plaintiff vs. DONNA L. SAYERS, Defendant TO THE PROTHONOTARY: IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA : CIVIL ACTION - LAW NO. 06-5463 CIVIL TERM PRAECIPE Please mark the above captioned Judgment as satisfied and discontinued. DATE: 11 119 /O T GRIFFIE & ASSOCIATES BY 4eey . Gri ffie, Esquire h Hanover Street Carlisle, PA 17013 (717) 243-5551 (800) 347-5552 FILE i-{J HI(:;E OF THE PR^ I F i'DNOTARY 2009 NOV 20 PM 3: 4 3 0' VANjl? e94 way R4--a3 a9.;Ls