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Ileana Lawson,
Individually and as
Executrix of the Estate
of Keith J. Lawson,
Deceased,
In the Court of Common pleas
cumberland County, pennsylvania
plaintiff
No. r;fc. -' 5>7 /0
(t - . f;
.I._ClL'\:.'
v.
Liberty Mutual Insurance
Company,
Civil Action - Law
Defendant
Praecipe for Writ of summons
To the Prothonotary:
please issue a Writ of Summons against the Defendant,
Liberty Mutual Insurance Company. Defendant Liberty Mutual
Insurance Group can be served at 5021 Louise Drive,
Mechanicsburg, Cumberland County, Pennsylvania.
Respectfully submitted,
Law Offices of
Timothy A. Shollenberger
Attorneys for plaintiff
Date: October -g
, 1996
LAW OFFICES OF
TIMOTHY A. SHOLLENBERGER
1820 lINGLESTCWN ROAD. P.O. !'lOX 60545 . HARRISBURG. PA 17106.0545
(717) 234.]700 . FAX (717) 234.8212
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In the Court of Common Pleas
Cumberland County, Pennsylvania
Ileana Lawson,
Individually and as
Executrix of the Estate
of Keith J. Lawson,
Deceased,
petitioner
No. 96-5510 Civil Term
v.
Liberty Mutual Insurance
Company,
Respondent
Civil Action - Law
o r del'
And Now, this day of
1996, upon the petition to Approve Compromise Settlement and
Distribution of Proceeds as filed by Ileana Lawson,
Individually and as Executrix of the Estate of Keith J.
Lawson, by and through her attorney, Timothy A.
Shollenberger, Esq. of the Law Offices of Timothy A.
Shollenberger, a hearing is scheduled on said petition to be
held on the day of , 1996 at
a.m./p.m. in Courtroom No. , Cumberland
County Courthouse.
J.
LAW OFFICES OF
TIMOTHY A. SHOLLENBERGER
1820 LlNGLESTOWN ROAD. roo BOX 110545 . HARRISBURG, rA 171(16.0545
(717) 230700 . FAX (717) 2H.A212
.(
)
'.
Ileana Lawson,
lndividually and as
Executrix of the Estate
of Keith J. Lawson,
Deceased,
In the Court of Common pleas
Cumberland County, pennsylvania
Petitioner
No. 96-55l0 Civil Term
v.
Liberty Mutual Insurance
Company,
Respondent
Civil Action - Law
Petition to Approve Compromise Settlement
and Distribution of Proceeds
To the Judge of Your Honorable Court:
And Now, comes the Petitioner, Ileana Lawson,
Individually and as Executrix of the Estate of Keith J.
Lawson, by and through her attorneys, the Law Offices of
Timothy A. Shollenberger, and does respectfully petition the
Court as follows:
1. Petitioner, Ileana Lawson, is the Executrix of the
Estate of Keith J. Lawson by virtue of Letters Testamentary
granted by the Register of Wills of Cumberland County,
Pennsylvania on July 28, 1993. A copy of these letters are
attached hereto and incorporated by reference herein as
Exhibit "A".
2. Petitioner, Ileana Lawson, is the wife of the
Decedent and at all times herein relevant resided at 3825
Conestoga Road, Camp Hill, Cumberland County, pennsylvania.
Jurisdiction of this Court in the under insured motorist
portion of this case is conferred by virtue of the
provisions of the policy of insurance issued to petitioner
by Respondent which mandates that the case proceed in the
County in which the petitioner resides.
3. Respondent, Liberty Mutual Insurance Company, is
an insurance company licensed to transact the business of
insurance in the commonwealth of Pennsylvania with offices
LAW OfFICES OF
TIMOTHY A. SHOLLENBERGER
1820 L1NGLESTOWN ROAn. P.O. OOX OOS45 . HARRISI\URG. PA 17106.0545
(7171234.1700 . FAX (717) HH12IZ
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at 5021 Louise Drive, Mechanicsburg, Cumberland County,
pennsylvania.
4. On or about July 1l, 1993, Petitioner's Decedent
suffered serious injuries when the vehicle in which he was
riding collided with a vehicle on Van Reed Road (8. R. 3055)
in Spring Township, Berks County, Pennsylvania.
5. As a result of the aforesaid injuries,
Petitioner's Decedent died at the scene of the collision on
July 11, 1993.
6. As a result of the Decedent's death, Petitioner,
Ileana Lawson, advised Thomas E. Hoffmeier and his insurance
carrier of her intention to initiate a wrongful death and
survival claim against Thomas E. Hoffmeier.
7. Thomas E. Hoffmeier offered a settlement in the
case of One Hundred Thousand ($100,000) Dollars. This
amount represented the liability limit of Mr. Hoffmeier's
policy of insurance issued to him by State Farm Insurance
Companies. A copy of State Farm's certification of the
policy limit is attached hereto as Exhibit "B".
8. petitioner has retained the services of Timothy A.
Shollenberger, Esq. of the Law Offices of Timothy A.
Shollenberger to represent the Estate of the Decedent for
this claim. The Petitioner has agreed to pay a 25% fee to
said attorneys. This fee represents a re&lction of
counsel's customary fee of 33 1/3% and of the agreed upon
fee of 33 1/3% once an arbitrator is selected. A copy of
said Contingent Fee Agreement is attached hereto and
incorporated by reference herein as Exhibit "C".
9. On October 3, 1994, a hearing was held before the
Honorable Judge Grim in Berks County, pennsylvania, who
approved the settlement with Mr. Hoffmeier, counsel fees of
25%, the allocation of the net settlement proceeds as
between the wrongful death and survival actions and the
disposition of the settlement proceeds. A copy of said
Order is attached as Exhibit "D".
2
LAW OFFICES OF
TIMOTHY A. SHOLLENBERGER
1820 lINGLESTOWN ROAD . P.O. BOX 60545 . HARRISBURG, PA 17106.0545
(717) 234.]700 . FAX (7\7) 234-8212
01. ~
lO. Because Petitioner was able to obtain Mr.
Hoffmeier's payment with a "pro tanto" release, petitioner
then initiated suit in the Court of Common Pleas of Berks
County versus John Wright, who was operating a vehicle
immediately in front of Mr. Hoffmeier on Van Reed Road, on
the grounds, inter alia, that Mr. Wright had stopped his
vehicle without sufficient purpose and that his negligence
was a concurring cause of the death of Keith J. Lawson. Mr.
Wright then joined Mr. Hoffmeier as an Additional Defendant.
11. At the time of this collision, Respondent Liberty
Mutual had issued to Petitioner and Keith J. Lawson a policy
of insurance providing under insured motorist coverage of
$100,000 per person/$300,000 per accident. A copy of the
declaration page of said policy is attached hereto and
incorporated by reference herein as Exhibit "E".
12. Petitioner's Decedent, Keith J. Lawson,
purportedly waived stacking of under insured motorist
coverage under said policy through execution by the first-
named insured (Keith J. Lawson) of a form that comports with
the language of ~1738 of the Pennsylvania Motor Vehicle
Financial Responsibility Law. A copy of said form is
attached as Exhibit "F".
13. After settling with Mr. Hoffmeier, but before the
third party case went to trial, Petitioner made a demand
upon the Respondent for the $100,000 limit of the
underinsured motorist policy, even though they had not yet
exhausted the limit of the policies of insurance covering
Mr. Wright.
14. Respondent did not honor Petitioner's demand
arguing, inter alia that until Petitioner's claim against
Mr. Wright was resolved, it was not obligated to pay the
policy limit.
15. Arbitrators were selected and the issue was
briefed and a hearing held on March 7, 1996. As a result of
that hearing, the arbitrators decided that Petitioner could
3
LAW OFFICES OF
TIMOTHY A. SHOLLENBERGER
1820 llNOLESTOWN ROAD' P.O. BOX 60545 . UARRISBURO, PA 17106.0545
(717) 214.1700 . FAX (7J?) 234,8212
.(
$
,
collect the limit without first exhausting the liability
bonds or policies applicable to Mr. Wright, but that any
verdict against Mr. Wright would be reduced dollar for
dollar by the amount of underinsured motorist benefits paid
to Petitioner.
16. After extensive pre-trial preparation involving
the expenditure of several hundred of hours of time,
Petitioner's third party case was tried to verdict during
the week of August 26, 1996. Jury selection and the trial
lasted four and one-half (4 1/2) days and resulted in a
verdict in favor of Petitioner and against Mr. Hoffmeier in
the amount of $588,000. While the jury found that Defendant
Wright was negligent, they further found that his negligence
was not a legal cause of the collision in question. Thus,
Petitioner was unable to collect any portion of the verdict
and has effectively exhausted the limits of the policies of
insurance of both Hoffmeier and Wright.
17. petitioner did not appeal the verdict of the jury.
18. Following the trial, petitioner renewed her demand
for the limit of the underinsured motorist policy.
19. Respondent has now offered the policy limit in
exchange for the Release which is attached hereto and
incorporated by reference herein at Exhibit "G".
20. Counsel has expended considerable time and
resources in the handling of this claim and its collateral
matters. petitioner would ask the Court to consider the
following with regard to the efforts and requested fee of
counsel:
a. the requested fee is a reduction from
counsel's normal fee of 33 1/3%;
b. that the handling of this underinsured
motorist case involved novel issues
relating to exhaustion of limits and
whether it was necessary to exhaust the
limits of both the policy of Thomas
Hoffmeier and the policy of John Wright
as a precursor to Petitioner's
4
lAW OFFICES Of
TIMOTHY A. SHOLLENBERGER
1820 UNGLESTOWN ROAD . P.O. OOX OOH5 . HARRISBURG, PA I7lCtJ.0S45
(7!7) 214.3700 . FAX (717) HH1Il
of subrogation is attached hereto as Exhibit
llHIl ;
j. Counsel conducted an extensive
investigation including contact and
interview with a potential joint
tort feasor and interviews and statements
from several witnesses;
k. Counsel was involved in numerous hours
with respect to the precise wording of
the Pro Tanto Joint Tortfeasor Release
that Mr. Hoffmeier and State Farm
executed in exchange for the settlement
draft. Said Release preserved not only
Petitioner's underinsured motorist
claim, but also preserved Petitioner's
right to collect the full amount of her
damages, less $100,000 from the
potential joint tort feasor;
1. Counsel spent considerable hours meeting
with the Petitioner, as well as with
Michael Cherewka, Esq., the attorney
handling the Estate of the Deceased.
The discussions at these meetings
included, but were not limited to, the
following:
1. the facts and allegations supporting a
case against a potential joint
tort feasor and the pros and cons of
pursuing that claim;
2. an explanation of a Pro Tanto Joint
Tortfeasor Release, as opposed to a Pro
Rata Joint Tortfeasor Release;
3. the results of the investigation
conducted by counsel and its
ramifications;
4. various potential sources of recovery of
which there are four (4), including the
liability coverage of the Respondent,
two (2) policies covering Mr. Wright and
the Petitioner's underinsured motorist
coverage; and,
5. the underlying data and conclusions of
expert witnesses.
6
LAW OFFICES OF
TIMOTHY A. SHOLLENBERGER
1820 llNGlESTOWN ROAD . p.o. AOX 60545 . HARHISRURG, PA 17106.0545
(7171134.)700 . FAX (7171 l14.H21l
.
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m. Counsel had conducted asset checks of
the Respondent, as well as a potential
joint tortfeasor;
n. Petitioner's counsel has fifteen (15)
years experience in the handling of
personal injury claims with
concentration in the area of automobile
insurance law; has written and spoken on
this subject at seminars throughout the
Commonwealth and tried personal injury
cases to verdict in five (5) counties
and the Middle District of Pennsylvania.
21. Counsel, in the handling of the underinsured
motorist portion of this case has incurred costs and
expenses which counsel is to be reimbursed under the terms
and conditions of the Contingent Fee Agreement entered
between themselves and the Petitioner. The total of these
costs and expenses as of the time of the filing of this
petition are $1,163.71. An itemized statement setting forth
these costs and expenses is attached hereto and incorporated
by reference herein as Exhibit "In.
22. petitioner believes and therefore avers that the
following persons are the beneficiaries of the proceeds of
the aforesaid settlement:
Name Relationship Address
Ileana Lawson Wife 3825 Conestoga Road
Camp Hill, PA 17011
Courtney Lawson (Minor) Son 3825 Conestoga Road
(D.O.B. -- 9/30/86) Camp Hill, PA 17011
Bradley Lawson (Minor) Son
(D.O.B. -- 3/18/89)
23. Petitioner believes and
3825 Conestoga
Camp Hill, PA
therefore avers that
Road
17011
the
Estate of the Decedent, Keith J. Lawson, has no current
outstanding debt.
24. Petitioner respectfully requests this Honorable
Court approve the following calculation of the settlement
proceeds available for distribution:
7
LAW OFFICES OF
TIMOTHY A. SHOllENBERGER
1820 L1NGLESTOWN ROAD. P.O. BOX tiOS4S . HARRISBURG, PA 17106.0H5
(717) 234.3700 . FAX (117) B4.8212
..
..
Gross Settlement Proceeds
Less Attorney's Fees
Less Costs Advanced
$100,000.00
- 25,000.00
1.163.71
Proceeds Available for
Distribution
S 73.836.29
25. The Petitioner believes and therefore avers that a
fair allocation of the net proceeds of the settlement are to
place 25% into the survival portion of the settlement and
75% into the wrongful death portion of the settlement. The
Court of Common pleas of Berks County previously approved
such an allocation with regard to distribution of Mr.
Hoffmeier's policy limit.
26. Petitioner requests that the proceeds of the
survival action be turned over to Michael Cherewka, Esq.,
Harrisburg, Dauphin County, Pennsylvania, who is handling
the Estate for purposes of approval and distribution.
27. Pursuant to 20 Pa. C.S.A. ~2101 et ~,
petitioner believes and therefore avers that the wrongful
death portion of the settlement be apportioned as follows:
Ileana Lawson 1/3rd share
Courtney Lawson 1/3rd share
Bradley Lawson 1/3rd share
28. The Petitioner requests that upon approval of the
proposed compromised settlement and receipt of the proceeds
thereof, she be authorized to execute the Release which is
attached hereto as Exhibit "G".
Wherefore, the Petitioner, Ileana Lawson, respectfully
requests this Honorable Court:
a. Approve the Petitioner's Contingent Fee
Agreement and allow deductions from the
settlement in the amount of counsel fees,
costs and expenses set forth therein and set
forth in the Exhibits attached hereto;
b. Order that the wrongful death and survival
portions of the net settlement proceeds be
allocated and distributed as set forth in the
Plaintiff's Petition;
8
LAW OFFICES OF
TIMOTHY A, SHOLLENBERGER
1820 L1NGlESTOWN ROAD. P.O. BOX 60545 . HARRISBURG, PA 17106.0545
(717) 234.3700 . FAX (711) 234.8212
\.
. I
SHORT CERTUICATE - LETTERS TESTA. .::NTARY
J"'.
.".....
COi>IMONWEALTH OF PENNSYLVANIA
} 55
COL":'-iTY OF CUMBERLAND
I. ~IARY C. LEWIS. Register of Wills in and for the County of cumberland. in the Commonwealth of
Pennsylvania. DO HEREBY CERTIFY that on the 28TH
19~. LETTERS TESTAMENTARY on the Estate of
KFITH.1 \ AW<;ON
day of
,1111 Y
deceased, were granted to
11 FANA n I A"I<;ON
having first been qualified well and truly to administer the same. And I further certify that no revocation of said
Letters appears of record in my office.
Date of Death JULY 11, 1993
Social Security N0135 - 38 - 5681
Given unto my hand and seal of office
:\OT VALID WiTHOUT OHIGl:"AL SIG:"OATt,.;RE Ai'\O IMPRESSlD SEAL
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EXHIBIT "A"
,
SUTI 'AUII\
State Farm Insurance Companies
~
INSIoII...NC'
.
.1",
April 12, 1994
Harrisburg Ser....ice Center
, 15 Limekiln Rond
P,O. Box 257
New Cumberland, PA 17070.0257
TIMOTHY A. SHOLLENBERGER
POBOX 60545
HARRISBURG, PA 17106-0545
,b.,PR 1 '3 1994
RE: Claim Number:
Date of Loss:
Our Insured:
38-6565-787
July ll, 1993
Thomas E. Hoffmeier
Dear Mr. Shollenberger:
Regarding the Estate of Keith Lawson, in response to your letter
of 3l March 1994, the only State Farm policy that applies to this
loss is the policy on the vehicle involved. This policy, number
5997-938-380 issued to Thomas E. Hoffmeier provides Bodily Injury
Liability coverage with limits of $100,000 each person{$300,000
each accident. If you hav enay questions, please call me.
sincerely,
ttuau.~ ll?[ Y/lvfit ; j{Z
Edward A. MCMerti, III
Claim Specialist
(717) 774-9078
State Farm Mutual Automobile Insurance Company
Pennsylvania Act 6 of 1990, Section 1827 requires us to inform
you that: "Any person who knowingly and with intent to injure
or defraud any insurer files an application or claim containing
any false, incomplete or misleading information shall, upon
conviction, be subject to imprisonment for up to seven years and
payment of a fine of up to $15,000."
EXHIBIT "B"
HOME OFFICES; BLOOMING TON, IlL1~JOIS 61710.0001
..
....
....
FOWER OF ATl'ORHEY
AND
CONTINGENT PRE AGREEKENT
I/We Ileana Lawson do
hereby retain MEYERS, DES FOR & SHOLLENBERGER of Harrisburg,
Pennsylvania, as my/our attorneys to negotiate for us a
settlement or to institute for me/us in my/our name(s) any
legal proceedings or actions that in their jUdgment are
necessary in connection with my/our claim for damages
sustained on the 11th day of July
19~, against: Thomas E. Hoffmeier and any
other person, firm, corporation or entity who may be
responsible for my/our claim, and/or to obtain an amicable
settlement.
I/We hereby give to my/our attorneys, a Power of
Attorney to execute all documents connected with the claim
for the prosecution of which the attorney is retained,
including pleadings, contracts, commercial paper, settlement,
agreements, compromises and releases, verifications,
dismissals, orders, settlement checks and all other documents
that I/we could properly execute in connection with this
lawsuit.
I/We agree not to settle or adjust the above claim or
any proceedings arising from said claim nor to discuss said
claim with any other persons.
MEYERS. DES FOR & SHOLLENBERGER
410NQRTHSECONDSTREET . PO BOX 1062 . HAFlRI$BURG.PA 17108 EXHIBIT "e"
17171236.9,128 . FAX [7171236.2817
.r,
I/We agree to fully cooperate with my/our said attorneys
in the prosecutio~ of the claim that comprises the subject
matter of this Agreement. This includes, but is not limited
to, making myself/ourselves available for legal proceedings
and consultations with my/our said attorneys; keeping my/our
said attorneys informed as to my/our current mailing address,
phone number and the current status of my medical condition.
I/We warrant that the information which I/we have
supplied and will supply during the course of these legal
proceedings is true and accurate, and has not been and will
not be obtained through fraud or illegal activities.
I/We agree to pay attorneys' fees from the total amount
recovered from any source, except first party benefits
(i. e., work loss and medical benefits), on account of my/our
bodily injury claim, including my/our claim for uninsured or
underinsured motorist benefits, on the following basis:
.25%~
~ of total
sum recovered
Settlement of third party tort
claim prior to filing of legal
action.
33 Y3 o/u/IB:.
~of total sum
recovered
)i{,~OOf~l
sum recovered
Settlement of third party tort
claim on or after filing of legal
action.
Settlement of uninsured or
underinsured motorist claims
prior to selection of my/our
arbitrator.
33 Y3 "',/0 -f!}r
48% 0 f_ total sum
recovered
Settlement of uninsured or
under insured motorist claims
after selection of my/or
arbitrator.
;,."
2
MEYERS. OESFOR & SHOLLENBERGER
410 NORTH SECOND STReET . P O. BOX 1062 . HARRISBURG. PA, 17\08
(7171236-9428 ~ FAX!7171236.2817 -
.,...~
Costs: Costs ar~ to be paid from my/our share of the
total amount recovered and include, but are not limited to:
photocopies; fax charges; postage; notaries; long distance
telephone charges; mileage for attorneys and staff;
investigation charges; photographs; court costs; LEXIS
research charges: medical records costs: fee for police
report; deposition costs: expert witness fees; stenographer
costs; and, video deposition fees.
In the event that no recovery is obtained on this claim,
the attorneys will make no charges for their time or
services. However, any costs or expenses which the attorneys
may have advanced on behalf of the claim must be paid by
me/us upon request by said attorneys.
As one possible settlement option, l/we authorize the
said attorneys to explore the possibility of a structured
settlement through the use of deferred periodic payments.
l/we agree that if my/our claim is settled through such
structure, the attorneys' fees may be paid directly to said
attorneys from the insurance company, either in one lump sum
payment at settlement, or, at the sole option of said
attorneys and/or insurance company, deferred into future
payments. However, in any event, said attorneys' fees shall
be calculated in the percentage as set forth above based upon
the cost of the structured settlement or present value
thereof in accordance with applicable law.
All medical bills for which I am legally responsible
incurred as a result of my/our injuries shall be chargeable
;,..1"
3
MEYERS. DESFOR & SHOllENBERGER
1\ 10 NORTH SECOND STREET . POBOX 1062 . HARRISBURG. PA 17108
17171236.91\28 . FAX17\7i236.2817 ..
LIBERTY MUTUAL FIRE l~SURANCE COMPANY
Ll~ TYGUA~O AUro PQLICY.0ECLA TIONS
JOSTON. MASSACHUSETTS
C..IU....."....Ct"ll:l" I v
?Auc I. OF
POL~C'( NUMBER
~-236-585478-002 I. i
NAMED .~suAeo AND MALLING ADDRESS
KEITH J LAWSON
ILEANA 0 LA W SO/I
3825 CONESTOGA RD
CAMP HILL PA 1701l-14l7
THESE OECLAAA nONS EFFECTIVE
09/22/921
JcRVICE CALL OR "RITe:
FRESE C A
5021 LOUISE OR PO flOX 2007
MECHANICSeURG PA 17055
717-795-8703/800-722-5104
CLIENT~ 000000000001152 ACCOUNT~ 9Ci438013
POLICY PERIOD: 08/27/92 TO 0&/27/93 12:0lAM STANDARD TIME AT THE ADDRESS OF TH~
NAMED INSURED AS STATED I~ THE POLICY.
CHANGES MADE: SUBSTITUTE VEH I.
ADD LOSS PAYEE-VEH 1
PREMIUM AOJUSTMENT FROM 09/22/12 TO J8/27/93:
"EHl
S ..7
VEHZ
TOTAL ADJUSTMENT: $
47.00
PART
A.LIAB IL ITY
80DILY INJU~Y $ 100.GOO EACH PE~SON
S 300.uOO EACH ACCIDENT
PROPERTY DAMAGE S 50.000 EACH ACCIOENT
C.UNINSURED MOTORISTS
BODILY INJURY S 100.000 EACH PERSON
S 300.000 eACH ACCIDENT
UNDERINSURED MOTORISTS
eODILY INJURY S lOO.OOO EACH PERSON
S 300.000 EACH ACCIDENT
COVERAGE IS PROVIDED WHERE A
PREMIUM IS SHO.N FOR THE COVERAGe
VEHl VEH2
COVERAGES AND LIMITS UNOER YOUR AUTO POLICY:
LIMITED TORT OPTIONS SELECTED
PART A. C. UNDER INSURED MOTORISTS PREMIUM
s 1.54
149
FIRST PARTY aENEFITS
lO.COO MEDICAL EXPENSE
l.500 FUNERAL EXPENSE
o INC.OME LOSS
a ACCIDENTAL DEATH
~ 29
28
CONTINUED ~EXT PAuc
7bs nolic'l, inclUding ill! endorsemonts an<lched is counlersiqned by:
';:':~~TA,,'
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\ ' .,~: CE".
,l,UTHOf'lI':[O Af:I'RE~[t;I"I;...E
EXHIBIT "E"
,
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...FJJA-. ,:,V ~
EXHIBIT "F"
I ~. ~ of.t
--,
.-
REJECTION OF UNDERINSURED MOTORISTS PROTECTION
By signing this waiver, I am rejecting underinsured motorist cQver:.Jge under thIs policy, for myself and all relatives residing
in my household, Underinsured cQver:lge protects me and relatives hying in my household for losses and damages suffered
if injury is caused by the negligence of a driver who does not have enough Insurance to pay for all losses and damages.
I knowingly and voluntarily reject this coverage.
f First l\amed Insured'"
CNDERINSURED COVERAGE LI:l-lITS
By signing this waiver. I am r~jecting Slacked limits of underinsurcd motorist CO\ t;:rag~ under the policy for myself and
members of my household under which lh~ limits of coverage available would be the sum of limits for each mOlor vehicle
insured under the policy. Instead th~ limits of coverage that I am purchasing shall be reduced to the limits staled in the'
policy. I knowingly and voluntarily reject th~ si.acked limits of CQvei'age, I understand that my premiums will be reduced if
I reject this coverage.
~..
~~-Pt~~
Signature of First j\'amecllnsured*~
_%.7."11
Dale
~Th(' Flrq \ameli Insured listed on the rolic~ must sign and date the wai\'t~r for it !O be \',~lid.
It\lKT IOn RI
I understand said PAYERS by reason of agreeing to this compromise payment,
neither admit nor deny liability of any sort and said PAYERS have made no agreement
or promise to do or omit to do any act or thing not herein set forth and I further
understand that this Release is made as a compromise to avoid expenses and to
terminate all controversy and/or claims for injuries or damages of whatsoever nature,
known or unknown, including future developments thereof, in any way growing out
of or connected with said incident or the uninsured/underinsured motorist coverage
obligations under Policy AJ2-238-585478-002 1 issued to Keith J. Lawson and Ileana
D. Lawson by or on behalf of Liberty Mutual Insurance Company.
I admit that no representation of fact or opinion has been made by the said
PAYERS or anyone on their behalf to induce this compromise with respect to the
extent, nature, or permanency of the injuries sustained by Keith J. Lawson, deceased,
or as to the likelihood of future complications or recovery therefrom and that the sum
paid is solely by way of compromise of a disputed claim, and that in determining said
sum there has been taken into consideration the fact that serious or unexpected
consequences might result from the present injuries, known or unknown, from said
incident, and it is therefore specifically agreed that this Release shall be a complete
bar to all claims or suits for injuries or damages of whatsoever nature resulting or to
result from said incident or the uninsured/underinsured motorist coverage obligations
under Policy AJ2-238-585478-002 1 issued to Keith J. Lawson and Ileana D. Lawson
by or on behalf of Liberty Mutual Insurance Company.
FREEFORM
Commerce Plan
5000 TilghmJn Street. SUltc 300
Allentown. Pennsylvania 18104
TeI'pho"" (21J) 398-9800
LIBERTI M
MUTUAL~
.,..,
.-.
AUGUST 25, 1993
TIMOTHY SHOLLENBERGER, ESe.
MEYERS, DESFOR & SHOLLENBERGER
410 NORTH SECOND ST.
P.O. BOX 1062
HARRISBURG PA 17108
INSURED:
CLAIMANT:
DATE OF LOSS:
FILE NUMBER:
KEITH J LAWSON
ESTATE OF KEITH J LAWSON
07111/93
AL356-033671-03
Dear Mr. Shollenberger:
This letter is to inform you that you have Liberty Mutual's consent to
settle with State Farm in the above matter and that we will waive our
subrogation interest Please provide me with written confirmation if and
when State Farm's policy limits have been paid and provide proof that no
other insurance applies to this case. Please call me if you have any
questions.
Sincerely,
DAVID L GUFFY
Claims Department
Ext 265
Liberty Mutual Insurance Group/Boston
Equ:l1 Opportunity Employer
EXHIBIT "H"
Oct 07 19'36
Law Offices of Tllothy A. Shollenberger
Client Ledger - Accounting only; "ATlER: 960368
Jan 01 1m TO Oct 07 19'36
PAGE
DATE
------------------------------------.-.-------.-.--.-.---...---.-.-----.-.--------------.-.--.------.----...------------------------
RECEIVED FRO" / PAID TO
ElPUIATION
CHE' 1...------- G ENE R A L -...------1 BLD 1--------- T R U S T _",,,"'_1
lKV' RECEIPTS DISBS FEES lKV RECEIPTS DISBS BALANCE
------------------------------------.-.------------.-.----------------.-.-.--------.-.--.....-....--....-------------------------...
cum: 368 - Lawson, l1e
IlATTER: 960368 RE: Estste of Keith La..on
Dee 31 95 CLIm OPEKlKG BAWCE
DISBUIlSEIlEITS BAUICE FORVARD : UKBILLED
Dee 31 95 CLIEIT OPEKlKG BAUllCE
DISBumEKTS BALANCE FORWARD : URBILLEO
Dee 31 95 CLIm OPElIIKG BAWCE
DISBURSE!EITS BALARCE FORWARD : UNBILLED
Jan 01 96
Telephone Dee. long distance
Jan 01 96
Telephone Dee. Cellulor One
Jan 31 96
Postage Jan. postage charges
Jan 31 96
Postage Jan. postage charges
Jan 31 96
Photocopies Jan. copy charges
Jao 31 96
Facsllllles Jan. fax chargea
Feb 19 96 Lexla-Kelis 4305
Lexla, Vestlaw Jan bill
Feb 29 96
Facshilies Feb. fax charges
Feb 29 96
Photocopies Feb. Photocopy Chargea
Feb 29 96
Telephooe Feb. long dlotance
"or 05 96 Kelly Keicher 368
Photocopies
br 19 96 Ray Bench 408
Expert Vitness Fees Rehlner
"or 31 96
Facalllllea "arch Fax Charges
"or 31 96
Poatage April postage charges
"ar 31 96
Photocopies "arch photocopy charges
br 31 96
Telephone Cellular One - TAS/KJJ
"or 31 96
Telephone "arch long dlatance
Apr 03 96 Traffic Saftey Investigations
Coata Refund of retainer
Apr 08 96 Cleckner & Fearen 484
Outalde Professional 1/2 of neutral arbitrator
RESP. LAVYER: 1 - T. A. Shollenberger
387.47
2378.24
-387.47
1.25
1.50
1.88
5.43
19.50
5.00
28.00 '*"
2.00
0.50
1.50
2.00
500.00
3.00
2.06
2.40
1.50
1.50
-181.25
429.00 ~
~ Tho~8 ~co5f-5
C lei iff! 3.5 parr
o~ r~e uIl.JeY'/1I5..red
(Y) ot5Y' I 6 -r rI <J ~ fY) -
(/1 i/ o'ff'W> uJttlVed)
EXHIBIT "I"
Oct rJ 1996
Law Offlcee of Ulothy A. Sholleoberger
Client Ledger - Accouotiog onlYi IlATTER: S68368
Jan 01 1994 TO Oct 07 1996
PAGE 2
.--------------------------------.--------.-.------------------------------------.--------------------------.-----------------------
----------------------------------.-.-------------------------------------------...-------------------------------------------------
RECEIVED F1lOII 1 PAID TO
ElPUlATIOl
CHE' 1_____000__ GEl ERA L _000_000001 BLD 1000.000__ T R U S T .000__000_1
IIV' RECEIPTS DISBS FEES IIV RECEIPTS DISBS BALAXCE
DATE
Apr 311 96 0.96
Postage April postlge charges
Apr 311 96 0.911
Photocopies April photocopy charges
!lay 31 96 1.59
Fscaililies Kay fsx charges
!lay 31 96 3.25
Postage llay postage charges
!lay 31 96 2.10
Photocopies Bay photocopies
Bay 31 96 4.59
Telephooe Bay long distance ($306) *'
Jun 10 96 A Craig Bouatoo, Pbd 65'3 m,lli
Outside Professiooal
Jun 11 96 Anthony Parker 665 69.44
!ileage/Parking
Jun 17 96 Berta Couoty Prothonotary 679 2Ull
Filing Fees - Prothonotary certified suhpoenaes
Jun 19 96 2.08
lotary
Jun 2Il 96 Jeff Pattersoo 688 19.08
Expert Witness Fees lileage and witness fee
Jun 21 96 Charles Hyne... Jr 690 7.80
!iscellaoeous witoess fee
Jun 21 96 Ratheryo Vicki Sproesser 691 7.10
!iscellaneous witness fee
Jun 21 96 Diane Hart... 692 6.40
!iscellaneous witness fee
Jun 21 96 Clarence ! Lereh, Jr 693 5.00
!isce11oneous witness fee
Jun 21 96 Officer J S Dougherty 694 6.48
!iscellanenus witness fee
Jun 30 96 25.67
Postage June pootage charges
Jun 30 96 118.20
Photocopies June photocopies
Jun 30 96 148.59
Facaililies JuDe fax charges
Jun 30 96 42.08
Telephone June long distance
Jul 03 96 Capital !essenger Service 704 65.08
delivery to Atty R. Orwig
Jul 03 96 David A S.lth 706 105.32
copies
Jul 03 96 A Business Conference Call m 52.60
4 line conf call 6/25
Oct 'IfI 19'36
Lay Offices of Tloothy A. Shollenberger
Client Ledger' Accounting only; nATTER: 96i368
Jan 81 1994 TO Oct 87 1996
PAGE 4
...........-.-------------.---------------------------------------------------------------------------------------------------------
DATE
RECEIVED FRON / PAID TO
EIPLillTIOI
CHE' 1---------- GEl ERA L ------.-.-1 BUO 1------.-- T R U S T ----------1
IIV' RECEIPTS DISBS FEES 11I'I RECEIPTS DISas BAUNCE
--------------------------------------------------------------------------------------------------------..--------------------------
Aug 31 96 45.75
Photocopies August copy charges
Aug 31 96 14.511
Telephone Aug. long distance
Aug 31 96 25.511
Telephone Cellular One - TAS/KJJ earphone
Sop 83 96 Kelly !!elcher 9J3 46.18
Nileage/Parking
Sop 83 96 Dr A Craig Houston 938 1296.00
Expert Vi loess Fees
Sop 83 96 Robson l.apina Inc. 948 3981.00
Expert Vitness Fees
Sop 1M 96 Vicki Sprosser 949 9.00
nileage/Parking reilburseaent - parking
Sop 119 96 Robson Lapina -645.00
Ck'447B, 9/5, refund on Layson final hill (see
ck'948, 9/38
Sop 18 96 Anthony Parker 965 24.1B
meage/Parking
Sop 25 96 225.78
Haopton Inn - Reading (see ck'4759, NBNA Alerica,
9/25) *'
Sop 26 96 Cuoberland County Prothonotary 10V 45.511
Filing Fees - Prothonotary
Oct 83 96 Cuoberland County Prothonotary 1051 45.511
Filing Fees - Prothonotary
Sop 26 96 Cuoberland County Prothonotary 1027 -45.511
Filiog Fees - Prothonotary VOID Ck - reisoued on
10/3, ckll051
Oct 'IfI 96 Angino & Rayner 1056 333.00 ~
Prof services - arhitrator bill *'""
Oct 'IfI 96 17.65
Photocopies Oct photocopies *
Oct 'IfI 96 4.56
Postage Oct poatage
:::::::::::::==:::==:::=::::::::::=::::::::::::::::::::::;:::::::::===::::::::::::=======:::::::::::::::::::::::::::::::::::::::::::
TOTALS FOR REPORT PERIOD:
TOTALS UP TO EHDIHG DATE:
DIS8URSEIlEHTS .
16111.51
16111.51
ALLOCATIONS .
870.13
870.13
FEES -
0.00
0.00
RECEIPTS '
826.25
826.25
GEHERAL BAL. ,
16155. 39
16155. 39
TRUST TOTAL
0.00
0.00
:::::::::::::::::::=::=:::::::::::::::::::::::::::::::::::::::::::::::::::::::::::::::::::::::::::::::::::::::::::::::::::::::::::::
Oct '1111996
La. Offices of T1lOtby A. Shollenberger
Client Ledger - Accounting only; nATTER: 96e(l68
Jan II 19'34 TO llc:t '111 1996
PAGE 5
------------------------------------------------------------------------------------------------------------------------------------
------------------------------------------------------------------------------------------------------------------------------------
RECEIYED FROn I PAID TO
EJPUlATIOI
CHE' 1-.-------- GEl ERA L -.--------1 BUD 1----.---- T R U S T ----------1
IIV' RECEIPTS DISBS FEES !IV RECEIPTS DISBS BAWCE
DATE
1ft REPORT SELECTIDIS tit
REPORT: Client Ledger
DATE: non Oct '111 11:54:13 1996
IlATTER: 968368
CLIEIT:
LAWYER: all lawyers
SEARCII lEY:
STARTIIG DATE: g.{flll
ERnIIG DATE: 96lll'1f1
ACCOOITIIG OILY OR TRUST OILY: Accounting only
I TOTALS OILY: 10
I
I
I
,
I
I
I
,
,
,
.1
"
Ls'\.'" ,I,; I' _ '..'
TiMOTHY .0.. SHl)LI.i::l'lel::Hlit:"
1 e20 L:noI3;;trJ'Hn Road
P.O. 60:160545
Harri~tIJr("J, PA 171 rJ).i).;4.5
ESTATE OF KEITH LAWSON
CARD 3 SIDE 1
.; 13alanc.(: hrrwJi"d
Tv (Of\1pvte.' (~1(d_
o
o
DATE DESCRIPTION ATTY CHARGE PAYMENT cy~~,~~!
14~-M
10/95 October lona dist, nce ~ <YO lq9 .
11/95 Inn at REading 68 90 I ~ '" 'M
11/95 Jeiiiiifer Kristoff 25 0 588 46
11/05 Britt Anderson 46 7 635 24
11 "'" C',n"_' ~ h~~'"", 1R , 1~71 A?
" 'a~ ,,' ,,'::n"'ou ?~ n, l~aQ A?
,~ _no : ~~ 25 0 1723 42
, ,~', a ~ i ",,_'ono Mo n 2" 0 1748 42
" 'a~ Uo"" M_ I n. '0_ 60 8 809 22
,,~o ! ..."" ' ~r R la~n rn?
" .,no Vn"" - 'nOC' 333 0 2293 05
ct/Nov posta-ae 9 8 !?W? ?1
ct'Nov Xerox 72 aO 2375 13
non poC'tane % 2376 00
nOn 90 1?17~ 00
"_00 T._n~ "i C'r"nnP 1 25 1?17Q ?A
.;
C - CONFERENCE
L - LETTER
R - RESEARCH
M - MEMO
TC - TELEPHONE CALL
RDA - RECEIVED ON ACCOUNT
CC - COURT. COSTS
I - INVESTIGATIONS
CR - COURT REPORTER
NT - NOTARY FEE
Lsw Offices of
TIMOTH't A SHOLLENBERGER
1.9;20 Lhl~I')st()'N~ Road
PO Bex G0545
H::trr:2burg, PA 171 C.3-0SJ5
ESTATE OF :~.RITH LAWSON
DESCRIPTION ATTY . CHARGE I PAYMENT I C\!~f'U~]:
DATE
4/95- -=-. ! 689 92
postaae 2 5. J:O? I';Q
4/95 Photocooies 1 8 hOd .ll
4/95 LonN Distance Tel. 8 00 702 39
5/95 Lona Distance Tel. 1 ,nn 705 39
<;/q~ 1 ~~~~m Exhibi s 30 00 735 39
5/95 Mail Boxes Etc. 40 07 775 46
5/95 Charles Hvneman Jr 5 00 780 46
5/95 Vicki Soroesser 6 40 786 86
~ "" ,nn ~'rtman 5 70 792 56
5/95 postaae 2: 7 814 31
5/95 Photocooies 18 6{ 832 91
6/95 ComDuterized Reoor . 402 25 1235 16
6/95 postaae 6 35 l241 5l
6/95 PHotocopies j tJu 1244 51
6/95 Lona Distance 71>0 !~~. ~.
il95 Lona Distance 4 DC l255 152
7/95 Huahes Albr~aht 181' 00 1443 52
7/95 TAS (milea.ae 31 90 1475 42
7/95 Mail Boxes 1 50 1476 92
iT95 Mail Boxes 1 50 1478 42
7/95 Cellular 1 5 479 92
8/95 Lona Distance 4 uu l48: 92
8/95 postaqe (JulY) 32 1484 24
9/95 postaae 32 1484 %
9-/95 Lona Distance 4 on 1 dRR %
CARD 2, SIDE 2
1
C - CONFERENCE
L - LETTER
R - RESEARCH
M - MEMO
TC - TELEPHONE CALL
ROA - RECEIVED ON ACCOUNT
CC - COURT. COSTS
I - INVESTIGATIONS
CR - COURT REPORTER
NT - NOTARY FEE
STATEMENT
Law Offices of
TIMOTHy A. SHOLLENBERGm
1820 LlnglesiO'Nn Road
P.O. Box 50545
Harrisburg. PA 17106-0545
CARD 2, SIDE 1
ESTATE OF KEITH J. LAWSON
9
DATE DESCRIPTION A1TY CHARGE PAYMENT . CURRENT
656 72
R/a4' n~~"'Ne 14 6 671 l8
a/1/94 Rerks County Sheri f 12 0 1-683 l8
114/a4 Mead Data Control
(LEXIS) 65 0 ~748 TI
R/a4 IT ,,"',... 3 50 l751 68
8/94 Photoconies 8 90 1760 58
lO/4/94 Reimbursed bv
State Farm 1~U qb --z4 ~ 112
10/6/94 Mi1eaae Reim. TAS 36 4' 28~ !52
a/q4 p". 2 285 81
,n/OA n~~..,NC , 10 286 91
9/94 Seot. Photocooies 4 _U 2~1 )1
11/94 Cellular TAS 11 00 302 01.
11/94 postaae 29 302 30
,.,/04 Postaae 5 02 507 32
12/94 Oct.-Dec. photoco~ ~es 6 nO 513 82
2/95 Notarv 2 100 515 82
2/95 Photoconies IJan.) 39 20 555 2
1/95 posta"e 3 03 558 5
3/95 postmaster b IUU ""4 5
3/95 Lona Distance (Jan -Mar. 3. 00- 567- 5
3/95 Lona Distance 4 0 671 05
4/a" ('tv. Proth. 12 00 683 5
4/95 Berks Ct". Proth. 6 00 689 5
3/95 postage 87 689 2
C - CONFERENCE
L - LETTER
R - RESEARCH
M - MEMO
TC - TELEPHONE CALL
ROA - RECEIVED ON ACCOUNT
CC - COURT. COSTS
1 - INVESTIGATIONS
CR - COURT REPORTER
NT - NOTARY FEE
Ileana Lawson,
Individually and as
Executrix of the Estate
of Keith J. Lawson,
Deceased,
In the Court of Common Pleas
Cumberland County, Pennsylvania
Petitioner
No. 96-5510
v.
Liberty Mutual Insurance
Company,
civil Action - Law
Respondent
Certificate of Service
I, Rebecca S. Rusbatch, Secretary to Timothy A.
Shollenberger, do hereby certify that I have served a
certified, time-stamped copy of the executed Court's Order
relative to the Petition to Approve Compromise Settlement
and Distribution of Proceeds by depositing a true copy in
the United States Mail, postage paid, at Harrisburg,
Pennsylvania, addressed as follows:
Jeffrey B. Rettig, Esq.
Thomas, Thomas << Hafer
P. O. Box 999
Harrisburg, PA 17108-0999
Respectfully submitted,
Law Offices oJ':
Timothy A. Shollenberger
Attorn~y~ for petitio~er
/, '/
" ./ , / /
B~ -;; Lc(./ I d....v-r-h
Rebec as. Rtisbatch!
Secre ary to
Timothy A. Shollenberger
Date: October 15, 1996
LAW OFFICES OF
TlMOrnV A. SHOLLENBERGER
1820 L1NGLESTOWN ROAD . P,O. BOX 60545 . HARRISP,URG, PA 17106.0545
(717) 234-3700 . FAX (717) 234-8212
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lAW OFFICES OF
TIMOnlY A. SHOLLENBERGER
1810 lINGLF$TOWN ROAD . P.O. BOX 60545 . HARRISBURG, PA 17I(1t!.OH5
(717)2].0700 . FAX (717) B4.Rlll
Certificate of Service
I, Rebecca S. Rusbatch, Secretary to Timothy A.
Shollenberger, do hereby certify that I have served a true
copy of the within Acceptance of Service by depositing a
true copy in the United States Mail, postage paid, at
Harrisburg, Pennsylvania, addressed as follows:
Jeffrey B. Rettig, Esq.
Thomas, Thomas & Hafer
P. O. Box 999
Harrisburg, PA 17108-0999
Respectfully submitted,
Law Offices of
Timothy A. ShOllenberger
Attorneys for Plaintiff
~~U4-
Rebe ca S. usbat h
Secretary to
Timothy A. Shollenberger
Date: October 15, 1996
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