HomeMy WebLinkAbout94-02441
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JAY R. BRADBRHAN. ) IN THE COURT OP COHHON
Plaintiff ) PLBAS OP CUMBERLAND
) COUNTY, PENNSYLVANIA
YB. )
) CIVIL ACTION - LAW
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BBTH WARCHOLA' ) 94 - .2'1'11 CIVI L -r oU.A-\...
Defendant )
I NOTICB
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liTO DEPENDANT NAMED HEREIN:
I YOU HAVE BEEN SUED IN COURT. IP YOU WISH TO DEPEND AGAINST THE CLAIMS SET FORTH IN
ITHE FOLLOWING PAGES, YOU MUST TAKE ACTION WITHIN TWENTY (20) DAYS AFTER THIS COMPLAINT
I AND NOTICE ARE SERVED, BY ENTERING A WRITTEN APPEARANCE PERSONALLY OR BY ATTORNEY AND
PILING IN WRITING WITH THE COURT YOUR DEFENSES OR OBJECTIONS TO THE CLAIMS SET FORTH
I AGAINST YOU. YOU ARE WARNED THAT IF YOU FAIL TO DO SO. THE CASE HAY PROCEED WITHOUT
YOU, AND A JUDGMENT HAY BE ENTERED AGAINST YOU BY THE COURT WITHOUT FURTHER NOTICE POR
I ANY MONEY CLAIMED IN THE COMPLAINT OR FOR ANY OTHER CLAIM OR RELIEP REQUESTED BY THE
I PLAINTIFP. YOU HAY LOSE MONEY OR PROPERTY OR OTHER RIGHTS IMPORTANT TO YOU.
I YOU SHOULD TAKE THIS PAPER TO YOUR LAWYER AT ONCE. IF YOU DO NOT HAVE A LAWYER OR
i CANNOT APPORD ONE, GO TO OR TELEPHONE THE OFFICE BET PORTH BELOW TO FIND OUT WHERE YOU
! CAN GET LBGAL HELP.
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COURT ADMINISTRATOR
POURTH FLOOR, CUMBERLAND COUNTY COURT HOUSE
CARLISLE, PENNSYLVANIA 17013
TELEPHONE: (717) 240-6200
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JAY R. BRADBRHAN,
Plaintiff
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IN THE COURT OF COMMON
PLEAS OF CUHBERLAND
COUNTY, PENNSYLVANIA
vs.
CIVIL ACTION - LAW
BETH WARCHOLA,
94 -.2.,'-1 I
CIVIL -r..u-.-
Defendant
COKPLAINT
AND NOW, comes the Plaintiff by his attorneys, Andes, Vaughn and Bangs, and files
[the following Complaint:
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I 1. Plaintiff, Jay R, Braderman, is an adult individual doing business as as an
lattorney-at-Iaw under the name of Jay R. Braderman with a business address of 128
ILocust Street, Harrisburg, Dauphin County, Pennsylvania.
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!South, Carlisle, Cumberland County, Pennsylvania.
i 3. From July, 1991, through April, 1992, Defendant employed Plaintiff as her
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iattorney for various legal assistance and agreed to pay Plaintiff at the rate of S95.00
[per hour for said services.
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2.
Defendant, Beth Warchola, is an adult individual who resides at 90 Regency
Plaintiff provided Defendant with regular statements of the work performed on
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ibehalf of Defendant, said statements including the amount of time spent on each
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'i particular matter.
5. The number of hours expended for the services provided by Plaintiff to
!;Defendant was 6.3 hours at the rate of S95.00 per hour for a total cost of those
services of S598.50.
6. In addition, Plaintiff prepared a will with instructions for Defendant for a
,cost of S75,OO.
7, Plaintiff performed all work in this matter in a competent and professional
manner.
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8. Plaintiff has made demand upon Defendant for the foregoing sums, yet the
Defendant has failed or refused to pay for those services.
9. Defendant has breached the agreement with Plaintiff by her failure to pay for
the services rendered by Plaintiff on behalf of Defendant.
10. Defendant will also be unjustly enriched if she is not required to pay
Plaintiff for the services rendered in this matter.
VHBRBPOlB, Plaintiff requests jUdgment against Defendant in the amount of $673.50
I plus interest plus costs of suit,
ANDES, VAUGHN & BANGS
Michael L. Bangs
Attorney for Plai iff
Supreme Court ID 1263
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SHERIFF'S RETURN
t:.'GMlNWEAL'Ill OF PENNSYLVANIA:
COUNTY OF ClMBERLAND
In The Court of Common Pleas of
Cumberland County, Pennsylania
No. 94-2441 Civil Term
Complaint in Civil Action Law
and Notice
Jay R. Braderman
VS
Beth Warchola
,lody Seiders
, ~UXitXDeputy Sheriff of
Cunberland County. Pennsylvania. who being duly swom according to law. says,
that he served the within Complaint in Civil Action Law and Notice
upon Reth WArchola
, the defendant. at 2: 30
o'clock
p .M. ~~ / EDST, on the
day of
25
May
. 19 94at
'rho> ClImherl And Countv Courthouse, Sheriff's Dept. . Cunberland County,
One Courthouse Square, Carlisle
Pennsylvania, by handing to Beth Warchol a
a true and attested copy of the Complaint in Civil Action Law and Notic~
and at the same time directing
her
attention to the contents thereof and
the "Notice to Plead" endorsed thereon.
Sheriff's Costs:
DoCketing
Service
Affidavit
Surcharge
So answers:
r>J~-c.<~~
14.00
2.80
2.00
18.80 Pd. by Atty.
5-26-94
R. Thomas Kline, Sheriff
by qocL,-! ~l ~
Deputy Sheriff
Swom and subscribed to before roo
this
3/Ak-
/l.L~
day of
19 91/ A.D.
Ch" (j, n14,-" U/f
Prothonotary