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Home My WebLink About02-2550LISA M. GREASON, ESQUIRE, tN THE COURT OF COMMON PLEAS OF Plaintiff CUMBERLAND COUNTY, PENNSYLVANIA RAYMOND KISS, Defendant No,: o~. ,2.~5'0 Civil Action Civil Action - Law NOTICE TO DEFEND 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 judgement 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(s). 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 Bar Association 2 Liberty Avenue Carlisle, PA 17013 Phone: (717) 249-3166 LISA M. GREASON, ESQUIRE, IN THE COURT OF COMMON PLEAS OF Plaintiff CUMBERLAND COUNTY, PENNSYLVANIA RAYMOND KISS, Defendant No.: o,~ - ,25 ~ Civil Action Civil Action - Law COMPLAINT Lisa M. Greason, Esquire, Plaintiff, claims damages of the Defendant upon a cause of action of which the following is a statement: 1. Plaintiff, Lisa M. Greason, Esquire, is an attorney with an office located at 50 East High Street, Carlisle, Cumberland County, Pennsylvania, 17013. 2. Defendant, Raymond Kiss, is an adult and individual citizen of the State of New Jersey, who resides at 5 Church Street, Piscataway, New Jersey, 08854. 3. The Defendant and Plaintiff entered into a Fee Agreement on February 22, 2002 in Carlisle, Cumberland County, Pennsylvania, whereby the Plaintiff agreed to represent the Defendant in his custody matter in the Court of Common Pleas of Cumberland County. In return, Defendant agreed to make payments in full on a monthly basis or interest would be charged per annum at a rate of twelve (12%) percent. Further, it was also agreed that Greason Law Office reserved the right to terminate any attorney/client relationship due to nonpayment of fees or costs. (See Fee Agreement attached and marked as Plaintiff's Exhibit "A") 4. The Defendant currently owes the Plaintiff nine thousand, three hundred, twenty-eight dollars and eleven cents ($9,328.11) in legal fees for services performed by the Plaintiff on his behalf. (See Invoice attached and marked as Plaintiff's Exhibit 5. The Defendant has failed to abide by the terms of the fee agreement in that he has not made sufficient payments on legal fees owed. WHEREFORE, Plaintiff demands judgment against Defendant in the amount of $9,328.11 plus interest for legal services. Date: Respectfully Submitted, GREASON LAW OFFICE ~sa M. Gr~sqh,jEsquire 50 East High S~et Carlisle, PA 17013 (717) 241-3030 Supreme Court ID # 78269 VERIFICATION I verify that the statements made in the foregoing Complaint are true and correct. I understand that false statements herein are made subject to the penalties of Pa. C.S. § 4904, relating to unsworn falsification to authorities. Lisa U. Gr/e~S~ ,~uire, Plaintiff Greason Law Office 155 South HanoYer Street * Carlisle, PennsylYania 17013 Phone: (717) 241-3o30 ' ~ax: (7~7) 24~-6878 * £YffGrea~on@ao£com February 22, 2001 Raymond H. Kiss 5 Church Street Piscataway, NJ 08854 RE: Fee Arrangement/Engagement Letter Dear Ray: It was a pleasure speaking with you regarding your case. I am writing at this time to put our fee arrangement into writing. Our office agrees to represent you at our current hourly rates. Work done by myself is billed at the rate of $125.00 per hour. Work done by the law clerks is billed at the rate of $50.00 per hour. You will be billed on a monthly basis and the invoice is due and payable upon receipt. Any bills not receiving payment within 60 days will incur interest charges at 12% per annum. Greason Law Office reserves the right to terminate any attorney/client relationship due to nonpayment of fees or costs. You will be responsible for all costs and expenses due to persons or entities outside Greason Law Office including but not limited to filing fees, deposition transcripts, witness fees, medical reports, investigations, etc., which may be necessary in order to pursue your case, and to reimburse us for any such expenditures which the office may make on your behalf. I require a retainer of $500.00 to begin the work on your case. I have received the initial retainer in your last correspondence. I will place this retainer in my escrow account and draw against it for my fees and costs. If, at any time, I believe it to be necessary, you will be required to replenish your escrow account. If there are any unexpended funds in this account once the work is finalized, these will be returned to you. If you have any questions regarding this fee arrangement or your case, please feel free to contact me. Sincerely, LISA M. GREASON, ESQUIRE Greas~n Law Office Activity Report For the dates: 1/1/2001 to 5/7/2002 Client: Kiss, Raymond Matter: Custody (Defaul0 Bill Detail Date Type Biller 2/13/2001 Fee LMG Description Ho~s Amomt Draft Documents, Telephone Conference with Arty 0.4O $50.O0 2/14/2001 Fee LMG 2/15/2001 Fee LMG 2/19/2001 Fee LMG 2/21/2001 Fee LMG 2/21/2001 Fee LMG 2/28/2001 Pmt 3/6/2001 Fee LMG 3/27/2001 Fee LMG 3/28/200l Fee LMG 3/28/2001 Exp LMG 3/31/2001 Pmt 4/2/2001 Fee LMG 4/8/2001 Fee LMG 4/8/2001 Fee LMG 4/8/2001 Fee LMG 4/16/2001 Fee LMG 4/16/200l Fee LMG 4/18/2001 Fee LMG 4/20/2001 Fee LMG 4/20/2001 Fee LMG 4/23/2001 Fee LMG 4/23/2001 Fee LMG 4/24/2001 Fee LMG 4/25/2001 Fee LMG 4/26/2001 Fee LMG 4/26/2001 Pmt 5/14/2001 Fee LMG 5/15/2001 Fee LMG 5/17/2001 Fee LMG 5/17/2001 Fee LMG 5/20/2001 Fee LMG 5/21/200l Fee LMG 5/22/2001 Fee LMG 5/23/2001 Fee LMG 5/7/2002 Eshelman, Telephone Conference with Atty Gaffi~ey Telephone Conference with Client, Telephone Conference with Atty Gaffi~ey Telephone Conference with Atty Gaffney Read & Review Documents, Motion for Continuance, fax to attorney, Telephone Conference with Client Telephone Conference with Court Research, Telephone Conference with Client, Letter to Client Payment - Thank You! Telephone Conference with Client Telephone Conference with Client, research Courthouse, copies copies Trust Account Payment Read & Review Documents, Draft Documents (Pet. to transfer) Read & Review Documents - letter from At~y Gaffney Draf~ Petitioner, order, Letter to Client Telephone Conference with Client File Petition, copy to Attorney Read & Review Documents, Letter to Client Telephone Conference with Client Telephone Conference with Legal Services re. PFA (2) Telephone Conference with Client Letter to Arty Gaffney, fax to Arty Gafthey Telephone Conference with Court - J. Oler Telephone Conference with Legal Services re. PFA Telephone Conference with Client Telephone Conference with Client (2), Letter to Atty Gaffney Trust Account Payment Telephone Conference with Cliem, Read & Review Documents Telephone Conference with Attorney Telephone Conference with Client, Read & Review Documents Telephone Conference with Client, prepare and fax subpeona prepare for trial Office Conference with Client, Prepare for and Attend Hearing Telephone Conference with Atty Telephone Conference with Arty Gaff-ney, Telephone Conference with Client 0.30 $37.50 0.50 $62.50 1.60 $200.00 0.20 $25.00 1.00 $125.00 ($500.00) EXHIBIT 0.20 $25.00 0.30 $37.50 0.20 $25.00 $3.00 ($90.50) 1.50 $187.50 0.10 $12.50 1.50 $187.50 0.50 $62.50 0.3O $37.50 0.30 $37.50 0.10 $12.50 0.60 $75.00 0.20 $25.00 O.4O $5O.OO O.2O $25.0O 1.00 $125.00 0. I0 $12.50 0.60 $75.00 ($409.50) 0.40 $50.00 0.20 $25.00 0.70 $87.50 0.70 $87.50 1.50 $187.50 4.00 $500.00 O.20 $25.00 0.50 $62.50 Page 1 Greasoh Law Office Activity Report 5/24/2001 Fee LMG 5/25/2001 Fee LMG 5/29/2001 Fee LMG 5/30/2001 Pmt 6/1/2001 Fee LMG 6/4/2001 Fee LMG 6/5/2001 Fee LMG 6/11/2001 Fee LMG 6/11/2001 Exp FF 6/14/2001 Fee LMG 6/19/2001 Fee LMG 6/20/2001 Fee LMG 6/21/2001 Fee LMG 6/21/2001 Exp FF 6/26/2001 Fee LMG 6/27/2001 Fee LMG 6/27/2001 Fee LMG 6/28/2001 Fee LMG 6/29/2001 Pint 7/3/2001 Fee LMG 7/6/2001 Fee LMG 7/10/2001 Fee LMG 7/12/2001 Fee LMG 7/13/2001 Fee LMG 7/13/2001 Fee LMG 7/16/2001 Fee LMG 7/17/2001 Fee LMG 7/17/2001 Fee LMG 7/19/2001 Fee LMG 7/20/2001 Fee LMG 7/20/2001 Exp FF 7/20/2001 Exp FF 7/24/2001 Fee LMG 7/25/200l Fee LMG 7/26/2001 Fee LMG 7/26/2001 Fee LMG 7/27/2001 Fee LMG 7/30/200l Pmt 8/1/2001 Fee LMG Telephone Conference with Client, Read & Review Documents Telephone Conference with Client, Telephone Conference with Atty Gaffiaey Telephone Conference with Client Payment - Thank You! Telephone Conference with Client, Telephone Conference with Arty (2) Telephone Conference with Client, Draft Documents re. jurisdiction research, Draft Documents re. preliminary objections for jurisdiction, Telephone Conference with Client Telephone Conference with Client, retrieval of documents at Courthouse Copies at Courthouse Telephone Conference with Client (2), Telephone Conference with Attorney Telephone Conference with Atty Gaffney, Telephone Conference with Client Read & Review Documents, Letter to Attomey Telephone Conference with Legal Services (4), Courthouse research Courthouse copies Telephone Conference with Client Telephone Conference with Client (2) Read & Review Documents, Letter to Attomey Telephone Conference with Legal Services, Telephone Conference with Judge's Chambers Payment - Thank You! Telephone Conference with Court, Legal Services, and Client re. PFA hearing Letter to Client, Copies to Client Telephone Conference with Client Telephone Conference with Client Read & Review Documents, research, Telephone Conference with Att-/Gaffney Telephone Conference with Atty Gaffney Telephone Conference with Atty Gaffi~ey Telephone Conference with Client Telephone Conference with Client Telephone Conference with Arty Gaffney Depositions Certified Copies Overnight Mail - UPS Telephone Conference with Client, Telephone Conference with Client Atty Berg, Letter to Conciliartor Sunday, Telephone Conference with Arty Gaffney Telephone Conference with Client Telephone Conference with Client Telephone Conference with Sunday Telephone Conference with Client (2), Telephone Conference with Atty Payment - Thank You! Telephone Conference with Client 1.00 $125.00 0.30 $37.50 0.20 $25.00 ($300.00) 1.30 $162.50 0.70 $87.50 4.00 $500.00 0.50 $62.50 0.70 0.60 0.20 1.00 0.10 0.40 0.30 0.40 0.80 0.20 0.40 0.20 1.00 0.20 0.60 0.60 0.20 0.30 4.00 0.60 0.10 0.40 0.20 0.40 0.10 $3.00 $87.50 $75.00 $25.00 $125.00 $10.50 $12.50 $50.00 $37.50 $50.00 ($300.00) $100.00 $25.00 $5O.OO $25.00 $125.00 $25.00 $75.00 $75.00 $25.00 $37.50 $50O.00 $2.00 $15.00 $75.00 $12.50 $50.00 $25.00 $50.OO ($300.00) $12.50 5/7/2002 Page 2 GreasOn Law Office Activity ileport 8/3/2001 Fee LMG 8/6/2001 Fee LMG 8/6/2001 Fee LMG 8/8/2001 Fee LMG 8/20/2001 Fee LMG 8/21/2001 Fee LMG 8/21/2001 Exp FF 8/21/2001 Exp FF 8/24/2001 Fee LMG 8/27/2001 Fee LMG 8/30/2001 Pmt 9/3/2001 Fee LMG 9/6/2001 Fee LMG 9/7/2001 Fee LMG 9/10/2001 Fee LMG 9/13/2001 Fee LMG 9/14/2001 Fee LMG 9/18/2001 Fee MB 9/19/2001 Fee MB 9/19/2001 Fee LMG 9/20/2001 Fee MB 9/20/2001 Fee LMG 9/24/2001 Fee LMG 9/26/2001 Fee MB 9/28/2001 Fee LMG 0/2/2001 Fee LG 10/3/2001 Fee MB 10/5/2001 Fee LG 10/14/2001 Fee MB 10/16/2001 Fee LG 10/17/2001 Fee MB 10/18/2001 Fee MB 10/22/2001 Fee MB 10/25/2001 Fee MB 10/25/200l Fee LG 10/25/2001 Fee LG 10/26/2001 Fee LG 10/28/2001 Fee LG 10/29/2001 Fee LG 10/31/200l Fee LG 11/14/2001 Fee LG 11/15/2001 Fee LG 11/16/2001 Fee LG 11/21/2001 Fee LG Telephone Conference with Client, Read & Review Documents Telephone Conference with Client, Telephone Conference with atty, Letter to Atty. Conciliation Conference Telephone Conference with Client Read & Review Documents Telephone Conference with Arty, Telephone Conference with Client (2), Letter to Atty copies - 100 ~ .25 priority mail Telephone Conference with Client Telephone Conference with Client, Read & Review Documents Payment - Thank You! Telephone Conference with Client Telephone Conference with Client Telephone Conference with Client Letter to Attorney, Read & Review Documents Telephone Conference with Client Draft Documents, Motion to Continue, filing Brief Preparation Brief Preparation Office Conference with Clerk Brief Preparation Telephone Conference with Client Office Conference with Clerk, Read & Review Documents Affidavit preparation Letter to Atty Sunday, copy to client and Arty Gaffney Telephone Conference with Client, Telephone Conference with Atty Carey re. PFA Draft Documents Letter to Client, verification, questions, Office Conference with law clerk Draft Documents - brief prep Read & Review Documents, draft documents re. brief Jurisdiction Brief Jurisdiction Brief Jurisdiction Brief Finalize Brief Telephone Conference with Client finalize brief Telephone Conference with Client finalize brief Read & Review Documents, Prepare for and attend Oral Argument Telephone Conference with Client Telephone Conference with Client, Telephone Conference with Atty Gaffney Telephone Conference with Arty, Telephone Conference with Client, Read & Review Documents Telephone Conference with Arty, Telephone Conference with Sunday 0.3O $37.50 O.4O $50.0O 3.00 $375.00 0.60 $75.00 0.10 $12.50 0.50 $62.50 $25.00 $3.50 O.30 $37.50 0.30 $37.50 ($500.00) 0.20 $25.00 O.30 $37.50 0.30 $37.50 0.30 $37.50 0.30 $37.50 0.60 $75.00 3.00 $150.00 2.00 $100.00 0.50 $62.50 2.00 $100.00 0.20 $25.00 0,40 $50.00 0.40 $20.00 0.20 $25.00 1.00 $150.00 0.20 $10.00 0.50 $75.O0 1.50 $75.00 1.00 $150.00 4.30 $215.00 3.40 $170.00 2.10 $105.00 2.10 $105.00 0.20 $30.00 1.00 $150.00 O.20 $3O.0O 2.00 $300.00 0.40 $60.00 5.00 $750.OO 0.10 $15.00 0.30 $45.00 0.40 $60.00 0.40 $60.00 5/7/2002 Page 3 Greasoh Law Office Activity l~eport 12/3/2001 Fee LG 12/4/2001 Fee LG 12/19/2001 Fee LG 1/11/2002 Fee LG 1/29/2002 Fee CYS 1/30/2002 Fee LG 2/21/2002 Fee LG 2/22/2002 Pmt 2/25/2002 Fee LG 2/26/2002 Fee LG 3/8/2002 Fee LG 3/12/2002 Fee LG 3/18/2002 Fee LG 3/18/2002 Fee CLK 3/18/2002 Fee CLK 3/21/2002 Fee LG 3/25/2002 Fee LG 3/01/2002 Fee LG · 12.~/~-~0~ Pmt Telephone Conference with Sunday & Gaffiaey, Telephone Conference with Cliem Telephone Conference with Client, Telephone Conference with Sunday Read & Review Documents Telephone Conference with client Telephone Conference with client Telephone Conference with Atty Vemey Read & Review Documents Payment- Thank You! Draft Documents Telephone Conference with client, revise documents Telephone Conference with Atty Gaffney, Read & Review Documents, Copies to Client Read & Review Documents, Telephone Conference with Arty Gaffney, Letter to Client Telephone Conference with Ethics board, Telephone Conference with Arty Gaffney, Atty Vemey, Atty Eshelman Copies to Client copy and file pretrial memorandum Prepare pre-trial memorandum Prepare for and Attend Hearing prepare answer and new matter Payment - Thank You! 0.60 $90.00 0.50 $75.00 0.30 $45.00 0.30 $45.00 0.20 $11.00 0.20 $30.00 0.30 $45.00 ($200.00) 1.00 $150.00 0.30 $45.00 0.30 $45.00 0.50 $75.00 1.00 $150.00 0.30 $7.50 1.00 $25.00 2.00 $300.00 5.00 $750.00 1.50 $225.00 ($100.00) Activity Subtotals Fees: Expenses: Other Charges: Payments: 99.90 Hours $11,426.00 $62.00 $0.00 ($2,700.00) 5/7/2002 Page 4 Greason Law Office Activity Report For the dates: 1/1/2001 to 5/7/2002 Activity Totals Hours: Fees: Expenses: Other Charges (net): Payments: 99.90 $11,426.00 $62.00 $0.00 $2,700.00 5/7/2002 Page 5 Greason Law Office Outstanding Balances Re~ort Last Pmt Last Pmt Not Outstanding Client and Matter Date Amount Finalized Finalized Balance Kiss, Raymond -- Custody 4/4/2002 $100.00 $69.25 $9,258.86 $9,328.11 TOTAL OUTSTANDING: $69.25 $9,258.86 $9,328.11 5/7/2002 Page 1 LISA M. GREASON, ESQUIRE, Plaintiff RAYMOND KISS, I~fendant : IN THE COURT OF COMMON PLEAS OF : CUMBERLAND COUNTY, PENNSYLVANIA : : CIVIL ACTION - LAW : NO. 2002-2550 TO: RAYMOND KISS DATE OF NOTICE:X O nO IMPORTANT NOTICE YOU ARE IN DEFAULT BECAUSE YOU HAVE FAILED TO TAKE ACTION REQUIRED OF YOU IN THIS CASE. 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: Lawyer Referral Service Cumberland County Bar Association 2 Liberty Avenue Carlisle, PA 17013 Phone: (717) 249-3166 Carlisle, PA 17013 (717) 241-3030 LISA M. GREASON, ESQUIRE, Plaintiff RAYMOND KISS, Defendant IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA No.: 2002-2550 CivilAction Civil Action - Law CERTIFICATE OF SERVICE I hereby certify that I served a true and correct copy of the Complaint upon Raymond Kiss, by depositing same in the United States Mail, first class, postage pre-paid on the 25 day of May 2002, from Carlisle, Pennsylvania, addressed as follows: Raymond Kiss 5 Church Street Piscataway NJ 08854 Date:<~/~//~2-- GREASON LAW OFFICE Carlisle, PA 17013 (717) 241-3030 Supreme Court # 78269 LISA M. GREASON, ESQUIRE, Plaintiff RAYMOND KISS, Defendant IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL ACTION - LAW NO. 2002-2550 CERTIFICATE OF SERVICE I hereby certify that on this ~'~' day of ~ ,2002, I mailed a true copy of the foregoing Default Notice to the following person at the following address by U.S. Mail First Class Mail, postage prepaid: Mr. Raymond Kiss 5 Church Street Piscataway, NJ 08854 Carlisle, PA 17013 (717) 241-3030 LISA M. GREASON, ESQ., Plaintiff RAYMOND H. KISS Defendant : IN THE COURT OF COMMON PLEAS OF : CUMBERLAND COUNTY, PENNSYVLANIA : NO. 02-2550 CIVIL TERM : CIVIL ACTION - LAW PRAEClPE FOR ENTRY OF JUDGMENT TO: Prothonotary Cumberland County Courthouse 1 Courthouse Square Carlisle, PA 17013 Please enter judgment in favor of Plaintiff, Lisa M. Greason, Esq., and against Defendant, Raymond H. Kiss, for want of ANSWER TO CMPLAINT. (x) Assess damages as follows: Debt: $ 9,328.11 Interest: (through 7/04) $ 2,281.83 Filing Costs: $ 45.50 Total: $11,655.44 Plus additional interest at 12%, cost and expense of suit and actual expenditures to preserve security until date of distribution and to enforce action. (X) I certify that the foregoing assessment of damages is for specified amounts alleged to be due in the complaint and is calculable as a sum certain from the complaint. (X) Pursuant to Pa.R.C.P. 237 (Notice of Praecipe for final judgment or decree), I certify that a copy of this Praecipe has been mailed to each other party who has appeared in the action or to his/her Attorney of Record. (X) Pursuant to Pa.R.C.P. 237.1, I certify that written notice of the intention to file this Praecipe was mailed or delivered to the party against whom judgment is to be II entered and to his/her Attorney of Record, it any, after the default occurred and at least ten days prior to the date of the filing of this Praecipe and a copy of the notice is attached as Exhibit "A" and a certificate of service of Notice is attached as Exhibit "B". Respectfully Submitted GREASON LAW OFFICE Date ~M. G~reason, Esquire ~" P.O. Box 385 Carlisle, PA 17013 (717) 241-3030 Supreme Court ID #78269 Now,. ,2004, JUDGEMENT IS ENTERED AS ABOVE, r thonotary/Clerk, ~i,2il Eiid~¢~~ Deputy LISA M. GREASON, ESQUIRE, Plaintiff RAYMOND KISS, Defe~dmat TO: RAYMOND KISS DATE OF NOTICE:.~O~ 1N THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL ACTION - LAW NO. 2002-2550 IMPORTANT NOTICE YOU ARE IN DEFAULT BECAUSE YOU HAVE FAILED TO TAKE ACTION REQLqRED OF YOU IN THIS CASE. 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: Lawyer Referral Service Cumberland County Bar Association 2 Liberty Avenue Carlisle, PA 17013 Phone: (717) 249-3166 Carlisle, PA 17013 (717) 241-3030 EXHIBIT LISA M. GREASON, ESQUIRE, Plaintiff RAYMOND KISS, Defendant 1N THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CML ACTION - LAW NO. 2002-2550 C g mCA; oF SERVICE I hereby certify that on this /~'~x day of ~//~g~4~ , 2002, I mailed a tree copy of the foregoing Default Notice to the following person at the following a[:~ires~:~y U.S. Mail First Class Mail, postage prepaid: Mr. Raymond Kiss 5 Church Street Piscataway, NJ 08854 50 Ea~ ~ Str~ Carlisle, PA 17013 (717) 241-3030 EXHIBIT ALL-STATEe INTERNATIONAL LISA M. GREASON, ESQ., : IN THE COURT OF COMMON PLEAS OF Plaintiff : CUMBERLAND COUNTY, PENNSYVLANIA RAYMOND H. KISS Defendant : NO. 02-2550 CIVIL TERM : CIVIL ACTION - LAW CERTIFICATE OF SERVICE I hereby certify that I served a true and correct copy of the Praecipe for Entry of Judgment was served upon Defendant, Raymond H. Kiss by depositing same in the United States Mail, first class, postage pre-paid on the '~-/ day of July, 2004, from Carlisle, Pennsylvania, addressed as follows: Raymond H. Kiss 5 Church Street Piscataway, NJ 08854 Carlisle, PA 17013 (717) 241-3030 Supreme Court ID #78269 LISA M. GREASON, ESQ., Plaintiff RAYMOND H. KISS Defendant : IN THE COURT OF COMMON PLEAS OF : CUMBERLAND COUNTY, PENNSYVLANIA : NO. 02-2550 CIVIL TERM : CIVIL ACTION - LAW CERTIFICATE OF RESIDENCE I hereby certify that the precise residence of the Plaintiff is: Lisa M. Greason, Esquire P.O. Box 385 Carlisle, PA 17013 And I certify that the last known address of the Defendant is: Raymond H. Kiss 5 Church Street Piscataway, NJ 08854 Lisa M. Greason, Esquire P.O. Box 385 Carlisle, PA 17013 (717) 241-3030 Supreme Court ID #7826g