HomeMy WebLinkAbout00-03562
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IN THE COURT OF COMMON PLEAS
OF CUMBERLAND COUNTY
SARAH SMITH
BY DESALES SMITH AND
PATRICIA SMITH HER
PARENTS AND GUARDIANS
Petitioner
:
:
CIVIL ACTION -- LAW
v.
NO:Cb-35W>~
JURY TRIAL DEMANDED
AMY HOKE,
Defendant
:
ORDER
AND NOW this
"2~
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day of
J' 0117 <-- , 2000 upon
consideration of the Petition to Approve Minor Settlement, it is
hereby ordered that settlement of the claim of Sarah Smith with
respect to the above captioned case is hereby approved as follows:
TOTAL SETTLEMENT: $8,000.00
ATTORNEY'S FEES: $2,666.66
LITIGATION EXPENSES TO BE REIMBURSED TO
SPERO T. LAPPAS, ESQUIRE: $313.84
NET DISTRIBUTABLE TO THE MINOR: $5019.50
All Monies distributable to the minor are to be
Deposited in a federally insured trust account to be chosen at the
discretion of the minor's parents. Such monies shall be maintained
in that account until March 18, 2006 when the minor attains the
age of 18 years, or until further order of court.
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CUMBEHLA~iJ COUNTY
PENNSYLVANIA
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It is further ordered that the Petitioner's, Desales and
Patricia Smith are hereby authorized to execute the general release
disposing of this action.
BY THE COURT:
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The Law Offices of SPERO T. LAPPAS
205 State Street
Post Office Box 808
Harrisburg, Pennsylvania 17108-0808
(717) 238-4286
By: ANN E. ARIANO, Esquire
Pa. Supreme Court identification no. 65178
ATTORNEYS FOR THE PETITIONER
IN THE COURT OF COMMON PLEAS
OF CUMBERLAND COUNTY
SARAH SMITH
BY DESALES SMITH AND
PATRICIA SMITH HER
PARENTS AND GUARDIANS
Petitioner
:
:
:
CIVIL ACTION -- LAW
:
:
NO:OO-3~ ~
v.
:
: JURY TRIAL DEMANDED
AMY HOKE,
Defendant
:
PETITION TO SETTLE AND COMPROMISE MINOR SETTLEMENT
AND NOW, comes SARAH SMITH a minor by DESALES SMITH AND
PATRICIA SMITH her Parents and Guardians and by their attorneys,
The Law Offices of SPERO T. LAPPAS, and respectfully represent as
follows:
1. Sarah Smith is a minor born on March 18, 1988 who
currently resides in the custody of the petitioners, Desales and
patricia Smith.
2. Amy Hoke is an adult individual residing at 501 Holly
Lane, Mechanicsburg, Cumberland County, pennsylvania, 17055.
3. On or about July 27, 1998 the Defendant drove a car which
The Law Offices of SPERO T. LAPPAS
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struck and collided with a vehicle operated by Desales Smith in
which Sarah Smith was a passenger.
4. This accident occurred on South Market Street,
Mechanicsburg, Cumberland County, Pennsylvania.
5. As a result of the events described above, Sarah Smith
suffered damages and injuries including thoracic muscular strain in
her back.
6. Sarah received medical care and treatment from the
following providers of medical, hospital and health care services:
Mechanicsburg Family Practice Center, Orthopedic Institute of
Pennsylvania and Rehab Medicine Associates.
7. The petitioners and Defendant's insurance company have
reached a compromise regarding the claims for injuries suffered by
Sarah smith in the form of a lump sum payment in the amount of
$8,000.00 (eight thousand dollars) in full settlement of this
claim.
8. Both the petitioner through her parents and petitioner's
counsel are satisfied that the offer of settlement is in her best
interest for the fOllowing reasons:
(a) It eliminates the inherent risk of litigation.
(b) I tel i m i n ate s the
possibility that a jury would find against the
Plaintiff on liability and thereby prevent her
from receiving any compensation.
(c) It eliminates the risk that a jury, even if
finding for the Plaintiff on liability, would
return a verdict of less than the settlement
amount.
The Law Offices of SPERO T. LAPPAS
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9. In pursuing the claim against Amy Hoke, the petitioners
engaged the Law Offices of SPERO T. LAPPAS, under contingency fee
providing that the said law firm would be paid 33 1/3% of any
settlement obtained before the filing of suit and 37% if it is
necessary to file suit. Because the present action was filed for
the sole purpose of presenting this petition, counsel claim 33 1/3%
and not 37% for each claim. (Exhibit A).
10. The Law Offices of SPERO T. LAPPAS have incurred costs in
the amount of $313.84 for Sarah smith relative to medical record
fees, filing fees and photocopy expenses. (Exhibit B).
11. The petitioner requests that this Court distribute the
present payment of $8,000.00 for Sarah Smith as follows:
a. To Spero T. Lappas, Esquire: $2666.66 as legal fees.
b. To Spero T. Lappas, Esquire: $313.84 for costs of
li tigation
c. $5019.50 to the minor to be deposited in a federally
insured trust account to be chosen at the discretion of the minor's
parents. Such monies shall be maintained in that account until
March 18 2006 when the minor attains the age of 18 years, or until
further Order of this Court.
12. If the court sees fit to approve the proposed compromise
settlement, the petitioners, Desales and Patricia Smith request
that they be authorized to execute the release attached hereto and
marked as Exhibit c.
13. The petitioners requests that this Court distribute the
The Law Offices of SPERO T. LAPPAS
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present payment of $8,000.00 for Sarah smith as follows:
a. To Spero T. Lappas, Esquire: $2,666.66 as legal fees.
b. To Spero T. Lappas, Esquire: $313.84 for costs of
litigation.
c. To the minor: $5019.50 to be deposited in a federally
insured trust account to be chosen at the discretion of the minor's
parents. Such monies shall be maintained in that account until
March 18, 2006 when the minor attains the age of 18 years, or until
further Order of this Court.
WHEREFORE, petitioners, Desa1es smi th and Patricia Smith
request that this Honorable Court enter an Order approving the
foregoing compromise settlement directing the distribution of
proceeds set forth herein, and authorizing the petitioners to
execute the general release disposing of these actions and
attatched to this Petition as Exhibit C.
RESPECTFULLY SUBMITTED,
By:
Law Offices of SPERO T. LAPPAS
0~2~
~ ARIANO, Esquire
Pa. Supreme ct. 10 no. 65178
205 State Street
P.O. Box 808
Harrisburg, PA 17108-0808
(717) 238-4286
ATTORNEYS FOR THE PETITIONER
.
The
The Law Offices of SPERO T. LAPPAS
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The Law Offices of SPERO T.
LAPPAS
205 State Street
Harrisburg, Pennsylvania 17108-0808
(717) 238-4286
FEE AND RETAINER AGREEMENT - - CIVIL!CIVrL RIGHTS CASE
DEAR DESALES SMITH, PARENT OF SARAH SMITH:
The following pages consti tute the Fee and Retainer
Agreement in your case. Please review tbis agreement
carefu1.ly before signing. If you have any questions
about this agreement or about. any of its terms, please
discuss them with us before signing. Then, please sign
this agreement and fill in your correct address and
telephone number on the last page.
Thank you.
The Law Offices of SPERO T. LAPPAS
1. "CLIENT" means-1~S'c /eJ ond?G +r, ~/~ S'f)",~, ?oYev'-rf.s
tf-S czra.h Sr,,/1"h
2. "THIS CASE" means any and all claims for damages which
CLIENT has or may have against any person, persons, entities or
firms as a result of AN AUTOMOBILE ACCIDENT ON OR ABOUT 7/27/98, as
well as any of the happenings, circumstances, events, legal rights,
or claims which relate to or are involved therewith; and the
presentation or litigation of such claims.
3 . "LAPPAS" means SPERO T. LAPPAS, Esquire, and The Law
Offices of SPERO T. LAPPAS, 205 State Street, P.O. Box 808,
Harrisburg, PA 17108, (717) 238-4286.
RETAINER
4. CLIENT hereby names, appoints and retains LAPPAS as
CLIENT I S true and' lawful attorney in the handling, prosecution,
settlement, or trial of any claim for injuries or damages which
CLIENT may have in this case.
5. CLIENT further grants LAPPAS full power and authority to
appear on behalf of CLIENT in any court of record or any
administrative proceeding, or any other proceeding whatsoever, to
do and perform all and every act and thing whatsoever that may be
requisite and necessary to be done in and about the above premises
as fully to all intents and purposes as CLIENT might or could do if
.:personally present; hereby ratifying and confirming all that LAPPAS
shall lawfully do or cause to be done therein by virtue of these
presents.
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EXHIBIT
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LEGAL FEES
6. In consideration of services already performed or to be
performed by LAPPAS, it is agreed that LAPPAS shall receive a
contingent fee ~n the form and am~unt of a percentage of any and
all RECOVERY wh~ch CLIENT may rece~ve or has received relative to
or as a result of this case. The percentage fee shall be computed
as follows:
a. 33 1/3% (one third) of any RECOVERY prior to the filing
of a lawsuit.
b. 37% of any RECOVERY after the filing of a lawsuit but
before the beginning of jury selection at trial.
c. 40% of any RECOVERY after the beginning of any trial but
before the filing of a notice of appeal by any person or
party.
d. 45% of any RECOVERY after the filing of a notice of
appeal by any person or party.
If the law applicable to this case allows for the taxation or
imposition of CLIENT'S attorney's fees against any Defendant, and
if such a claim is in fact made and granted, or if the right of the
CLIENT or the attorney to make such application is settled either
before, during or after trial or appeal, then LAPPAS will receive
any attorney's fees awarded or received in addition to, and not
instead of, the percentage contingent fees described in this
Agreement. If the case is settled after the return of a jury's
verdict in favor of the plaintiff, then -- in a case in which the
law allows for the request for the imposition of plaintiff's legal
fees against the defendant or in a case in which the law authorizes
the plaintiff or plaintiff's counsel to petition or apply for
attorneys' fees -- any amount in the settlement in excess of the
amount of the verdict (exclusive of those amounts which are
described in the settlement agreement to constitute non-attorneys
fees costs of the litigation, or interest) shall be conclusively
presumed to constitute attorneys' fees and LAPPAS shall be entitled
to receive that amount in addition to any contingent fee allowed by
this agreement.
PAYMENT OF COSTS
7. CLIENT understands that LAPPAS may be required to advance
on CLIENT'S behalf costs which are, in LAPPAS'S sole discretion,
necessary and required to the proper handling of this case. Such
possible costs include without limitation: court and filing fees;
stenographic and transcription costs; service and investigative
fees; research and computerized research fees; medical and hospital
records costs; witness and expert witness fees; duplication,
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printing or photocopy costs or fees (in-house or otherwise)' and
litigation expenses. '
8. CLIENT agrees to pay such costs and expenses at the time
of recovery.
MISCELLANEOUS
9. CLIENT acknowledges that no promises or assurances have
been made concerning the outcome or likely outcome of this case.
10. If at any time during the course of this case LAPPAS
determines that, for whatever reason, he feels this case is not
worth pursuing, he shall have the right to remove himself as
counsel for CLIENT, upon compliance with the requirements of the
Pennsylvania Rules of Professional Conduct. CLIENT shall then have
the right to retain substitute counsel of CLIENT'S choice and
CLIENT shall owe no money to LAPPAS as legal fees. CLIENT shall
remain responsible for the payment of all outstanding costs
advanced.
11. CLIENT shall be and remains personally liable for all
personal, medical, hospital, or other expenses which CLIENT has
incurred or will incur, and CLIENT agrees to pay those expenses
either before or after any recovery in this case. CLIENT expressly
recognizes and agrees that LAPPAS shall not be responsible for any
of those expenses.
12. CLIENT agrees to cooperate fully in all aspects of this
case including:
a.
b.
c.
d.
e.
f.
g.
providing LAPPAS with full, timely, complete, accurate,
and truthful information on all matters and subjects
involved in this case or its handling and litigation;
providing LAPPAS with full, timely, complete, accurate,
and truthful information on all matters and subjects
relating to CLIENT'S background and personal history;
providing LAPPAS with full, timely, complete, accurate,
and truthful answers to all questions which LAPPAS asks;
keeping all scheduled appointments;
promptly signing and returning all documents sent to
CLIENT for signature;
immediately notifying LAPPAS of any changes of address,
telephone number or employment;
immediately notifying LAPPAS of any significant
developments in CLIENT'S personal or legal situation or
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circumstances, including the occurrence of any lawsuits,
arr~sts, or the receipt of any legal notices from any law
off~ces, courts, public agencies, public officials or any
other person or office, or any significant changes in
CLIENT'S health or medical condition;
h. contacting LAPPAS no less frequently than once per month
to discuss the progress of this case.
. 13. The parties recognize that the decision to accept or
reJect any settlement offer is exclusively the decision of CLIENT.
However, if LAPPAS advises CLIENT to accept a settlement offer and
CLIENT decides nonetheless to reject such offer, then the legal
fees in this case shall in no event be less than one third of such
rej ected settlement offer and all costs advanced by LAPPAS on
CLI~NT's behalf shall immediately be due and payable from CLIENT.
Further legal services or reptesentation may be withheld, or legal
representation may be terminated, at LAPPAS's discretion, until
such fees and costs are paid. The provisions of this paragraph
will apply even if this case later results in a recovery less than
the rejected offer, or no recovery. If the ultimate recovery is
greater than the rejected offer then the regular contingent fee
provisions of this agreement shall apply.
14. This agreement cancels and revokes any other agreement
whereby CLIENT hired or employed any lawyer or firm other than
LAPPAS to represent CLIENT in this case. CLIENT hereby discharges
all attorneys other than LAPPAS as CLIENT's legal representative or
counsel in connection with this case.
15. In the event that CLIENT discharges LAPPAS as CLIENT's
attorney before there is any recovery in this case, then when a
recovery does occur CLIENT' shall pay LAPPAS (as fee for any work
performed by LAPPAS prior to the discharge) a percentage of
CLIENT's recovery to be determined as follows:
a. 33 1/3% (one third) of any RECOVERY if LAPPAS is
discharged prior to the filing of a lawsuit.
b. 37% of any RECOVERY if LAPPAS is discharged after the
filing of a lawsuit but before the beginning of jury
selection at trial.
c. 40% of any RECOVERY if LAPPAS is discharged after the
beginning of any trial but before the filing of a notice
of appeal by any person or party.
d. 45% of any RECOVERY if LAPPAS is discharged after the
filing of a notice of appeal by any person or party.
CLIENT agrees that CLIENT and any subsequent attorney hired by
CLIENT will honor LAPPAS's right to receive this fee after
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discha~ge and that any?ubsequent attorney shall, upon presentation
~f a slgned copy of thlS fee agreement, protect LAPPAS's interests
ln such fee and shall distribute such fee to LAPPAS out of the
proceeds of any recovery.
16. If CLIENT violates any of the terms of this AGREEMENT
LAPPAS shall have the right to discontinue providing legal service~
t~ CLIE~ and withdr~w his appearance from any litigation involved
wlth thlS case. If lt becomes necessary for LAPPAS to withdraw as
CLIENT'S attorney because of CLIENT'S breach of any of the terms of
this AGREEMENT, LAPPAS may file the necessary Motion to Withdraw
with any appropriate Court and may represent to the court in such
motion that CLIENT by this AGREEMENT authorizes such a motion and
withdrawal. By signing below CLIENT gives LAPPAS permission to
make such a representation.
17. The legal services covered by this letter may be provided
by any attorney provided by LAPPAS'S office.
18. This agreement supersedes any and all prior agreements
made concerning LAPPAS', S representation of CLIENT in this case.
LAPPAS and CLIENT both agree by their signatures that the promises
contained in this letter constitute new and adequate consideration
for this agreement.
19. CLIENT understands that this Agreement only covers legal
services rendered in connection with THIS CASE. Any other legal
services which CLIENT may request of LAPPAS (including any defense
to counterclaims or crossclaims that may be involved in the
litigation of THIS CASE) will be performed for a fee to be agreed
upon at the time of such request; or in the absence of a specific
fee agreement, at LAPPAS' then prevailing hourly rate.
20. As used throughout this document, "RECOVERY" means any
money, payment, promise to pay, or any other thing or things of
value whatsoever (of any nature whatsoever) which CLIENT receives
on account of or because of THIS CASE or on account of or because
of any of the happenings, circumstances, events, legal rights, or
claims which relate to or are involved with THIS CASE. RECOVERY
also includes but is not limited to payment or repayment of pre-
existing debts. forgiveness or satisfaction of any of debts or
claims of others against CLIENT or for which CLIENT is actually or
allegedly responsible, payment of any sums of money or other things
of value to CLIENT or to others on CLIENT's behalf or any other
things of value which client receives or becomes eligible to
receive on account of or because of THIS CASE.
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21. CLIENT certifies that CLIENT's correct mailing address
and telephone number are:
:,)es<le.s c:~.'\.d. .p~ofr,'('(~ S/h./'-+l1, 1 c:d'E <'\fs ocf..Jccrc<0 SiY'l/"--f-h
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(CLIENT's address)
area code X ' telephone number >< {, s' 7-1'(3 V
I/WE HAVE READ THIS FEE AND RETAINER AGREEMENT, UNDERSTAND IT, AND
COMPLETELY AGREE TO ITS TERMS.
Date:
,- I; 99
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DESALES AND?~'~SMITH, PARENTS OF
SARAH SMITH
Date:
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DESALES AND " ,'l" c; SMITH PARENTS OF
OF SARAH SMITH
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SPERO T. LAPPAS, Esquire
Date:
q- /- 99
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The Law Offices of SPERO T. LAP~AS
205 state street
Post Office Box 808
Harrisburg, Pennsylvania 17108-0808
Telephone (717) 238-4286
FAX (717) 238-4826
June 8, 2000
In re:
SARAH SMITH
SETTLEMENT OF DISTRIBUTION OF SETTLEMENT PROCEEDS
The following entries constitute the STATEMENT OF DISTRIBUTION
OF SETTLEMENT PROCEEDS in your case. Please review this statement
carefully. If you have any questions about this statement or about
any of its terms, please call us to discuss your questions. Then,
please sign this statement on the line or lines indicated for your
signature to indicate your agreement with this distribution and to
authorize us to distribute your settlement proceeds as shown.
After it is signed, please return the signed document to our
office.
Thank you.
The Law Offices of SPERO T. LAPPAS
1.
ANTICIPATED SETTLEMENT PROCEEDS
$8,000.00
2. DISTRIBUTION
To the Law Offices of SPERO T. LAPPAS
LEGAL FEES (33 1/3% of $8,000.00)
OFFICE EXPENSES
$2,666.66
The Law Offices of SPERO T. LAPPAS
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1.
COSTS ADVANCED
A. Rehab Medicine Assoc.
(medical records)
$51. 65
B.
CapitOl Copy Service
$20.80
C.
Nationwide Insurance
(fee for First Party Benefits File)
Prothonotary - Cumberland County
(filing fee)
$35.00
D.
$45.50
E.
Cumberland County Sheriff
(service fee)
$100.00
$29.14
F.
Quadra-Med (medical records)
2. IN-HOUSE PHOTOCOPYING
DATE DESCRIPTION
9/2/99 Letter to Susan Philson 2
9/27/99 Letter to Rehab. Assoc. 3
10/20/99 Letter to Rehab. Assoc. 2
2/15/00 Letter to Ortho. Instit. 2
2/15/00 Letter to Ortho. Instit. 3
2/15/00 Letter to Debra Humberston 2
2/15/00 Letter to Katie Barthel 2
2/15/00 Letter to Sandy Uhrich 2
2/16/00 Letter to Tina Witmer 2
2/16/00 Letter to clients 2
3/02/00 Letter to adjustor w/encl. 101
3/16/00 Letter to Amy Dicato 2
4/4/00 Letter to Susan Philson 2
copies 127 x .25 = $31. 75
TOTAL OFFICE EXPENSES: $313.84
The Law Offices of SPERO T. LAPPAS
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3. SUMMARY
a. To the Law Offices of Spero T. Lappas - legal
fees $2,666.66
b. To the Law Offices of Spero T. Lappas - office
expenses $313.84
c. To Sarah Smith the balance to be deposited in a
federally insured trust account to be chosen at the
discretion of the minor's parents. Such monies shall be
maintained in that account until March 18, 2006 when
Sarah Smith attains the age of 18 years, or until
further Order of Court.
$5019.50
d. Total Distribution of Settlement Proceeds
$8,000.00
MEMORANDUM
FROM: Desales and Patricia smith, parents and natural guardians
of Sarah Smith, a minor.
TO: The Law Offices of SPERO T. LAPPAS
IN RE: APPROVAL OF STATEMENT OF DISTRIBUTION OF SETTLEMENT
PROCEEDS
I have reviewed the above STATEMENT OF DISTRIBUTION OF
SETTLEMENT PROCEEDS and we completely agree with all parts thereof,
including all proposed distributions of settlement proceeds. We
authorize and request Spero T. Lappas, Esquire to distribute the
settlement proceeds as indicated above.
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DESALES SMITH
VJ ~~ ~ xL7JUU e- dcCO
PATRICIA SMITH
The Law Offices of SPERO T. LAPPAS
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GENERAL RELEASE
F or the consideration of EIGHT THOUSAND AND 00/100' S Dollats ($8,000.00), receipt of which is hereby
acknowledged, I/we release and discharge, and for myself/ourselves my/our heirs, representatives, executors,
administrators, successors and assigns, do hereby remise, release and forever discharge Amy Hoke, hereinafter
referred to as the releasee(s), his/her/their/its heirs, executors, administrators, insurers, successors and assigns, and
any and all other persons, firms, corporations, associations, of and from any and all causes of action, suits,
judgments, claims and demands of whatsoever kind, in law or in equity, known and unknown, which I/we now have
or may hereafter have, and/or which the minor Sarah Smith now has or may hereafter have, especially the claimed
legal liability of releasee(s), which liability releasee(s) expressly deny(ies), arising from or by reason of any and all
bodily or personal injury and/or property damage known and unknown, foreseen and unforeseen which heretofore
has/have been or which hereafter may be sustained by me/us or the minor aforementioned arising out of the accident
on or about July 27, 1998, at or near Mechanicsburg, in the County of Cumberland, in the State of Pennsylvania, in
which the minor aforementioned sustained personal injuries and/or property damage.
I/We agree that the consideration set forth above is specifically applicable to and paid to me/us with respect to any and
all damage to any property, either real or personal, of mine/ours or the minor aforementioned, and with respect to any
and all personal or bodily injury of mine/purs or the minor aforementioned, whether presently known or unknown,
foreseen or unforeseen or which may subsequently develop and the consequences thereof, all as atising from the
aforementioned accident.
I/We further agree that the consideration set forth above is specifically applicable to and paid to me/us with respect to
any right of contribution the I/we or theminor aforementioned may have against the reieasee(s), his/her/their/its heirs,
executors, administrators, insurers, successors and assigns relative to claims of others that may be brought against
me/us or the minor aforementioned by reason of said accident.
I/We further agree that the consideration set forth above is specifically applicable to my/our agreement that I/we or
the minor aforementioned will not join nor attempt to join the releasee(s), his/her/their/its executors, administrators,
insurers, successors and assigns in any capacity, in any action that may be brought against me/us or the minor
aforementioned arising out of said accident.
In consideration of the aforesaid payment, I/we for myself/ourselves and my/our heirs, representatives, executors,
administrators, successors, and assigns do hereby:
(1) agree to indemnify and hold forever harmless the releasee(s) and his/her/its/their representatives,
administrators, or assigns, against loss from any and all further claims, demands or actions that may
hereafter be made at any time or brought against the releasee(s) by me/us or the minor
aforementioned, or by anyone in our. behalf for the purpose of enforcing a further claim, for which
this release is given;
(2) , warrant that I/we have received no money or other valuable consideration from any other person or
persons by reason of any causes of action, suits, covenants, agreements, judgments, claims and
demands of whatsoever kind, which I/we now have or may hereafter have, for injuries to person or
property arising out of the aforementioned accident or for the other matters for which this release is
given.
REL3__
EXHIBIT
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GENERAL RELEASE
Intending to be legally bound thereby, WITNESS my/our hand(s) and seales) this
day of
WITNESS
(Seal)
Father-Guardian
(Seal)
Mother
(Seal)
Minor
NOTICE:
Any person who knowingly and with intent to defraud any insurance company or other person files an application for insurance or
statement of claim containing any materially false information or conceals for the purpose of misleading, information concerning any
fact material thereto conunits a fraudulent insurance act, which is a criIne and subjects the person to criminal and civil penalties. II
REL3
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49819_1
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GENERAL RELEASE
Claim #010170378320
Author: Susan G. Philson
/csi
REL3
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Page 3
49819_1
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The Law Offices of SPERO T. LAPPAS
205 state street
Post Office Box 808
Harrisburg, Pennsylvania 17108-0808
(717) 238-4286
By: ANN E. ARIANO, Esquire
Pa. Supreme Court identification no. 65178
ATTORNEY FOR THE PETITIONERS
IN THE COURT OF COMMON PLEAS
OF CUMBERLAND COUNTY
VERIFICATION
The undersigned hereby verifies that the facts averred in this
/-..,:.s
Motion are true and correct to the best of ~ knowledge,
information, and belief.
This Verification is made subject to the penalties of 18
Pa.C.S.A. Section 4904 relating to unsworn falsification to
authorities.
RESPECTFULLY SUBMITTED,
By: e:>~~
DESALES SMITH
DATE: r a
I
, 2000
The Law Offices of SPERO T. LAPPAS
Page 5
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The Law Offices of SPERO T. LAPPAS
205 State Street
Post Office Box 808
Harrisburg, Pennsylvania 17108-0808
(717) 238-4286
By: ANN E. ARIANO, Esquire
Pa. Supreme Court identification no. 65178
ATTORNEY FOR THE PETITIONERS
IN THE COURT OF COMMON PLEAS
OF CUMBERLAND COUNTY
VERIFICATION
The undersigned hereby verifies that the facts averred in this
Motion are true and correct to the best of her knowledge,
information, and belief.
This Verification is made subject to the penalties of 18
Pa.C.S.A. Section 4904 relating to unsworn falsification to
authorities.
RESPECTFULLY SUBMITTED,
By:
Lp~~~
PATRICIA SMITH
DATE: ~ 8'
, 2000
The Law Offices of SPERO T. LAPPAS
Page 6
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CASE NO: 2000-03562 P
SHERIFF'S RETURN - REGULAR
COMMONWEALTH OF PENNSYLVANIA:
COUNTY OF CUMBERLAND
SMITH SARAH ET AL
VS
HOKE AMY
WILLIAM DIEHL
Sheriff or Deputy Sheriff of
Cumberland County, pensylvania, who being duly sworn according to law,
says, the within PETITION AND ORDER
HOICE AMY
was served upon
the
RESPONDANT
, 2000
, at 1619:00 HOURS, on the 10th day of July
at 501 HOLLY LANE
MECHANICSBURG, PA 17055
LINDA SMITH, MOTHER OF DEFT.
by handing to
a true and attested copy of PETITION AND ORDER
together with
and at the same time directing Her attention to the contents thereof.
Sheriff's Costs:
Docketing
Service
Affidavit
Surcharge
18.00
5.58
.00
10.00
.00
33.58
Sworn and Subscribed to before
me this /9!i::. day of
.
/!
i }.A~c2wD A.D.
- o. 7J'U,,~.,./Ig..,>
r thonotary I
So Answers:r~~
R. Thomas Kline
07/11/2000
SPERO T. LAPPAS
By:
~~