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Home My WebLink About00-04299 JUN 27 20~ SHOLLENBERGER & J ANUZZI, LLP 1820 Linglestown Road P.O. Box 6054S Harrisburg, Pennsylvania 171 06~0545 Telephone Number: (717) 234-3700 Fax Number: (717) 234-8212 Attome S for Plaintiff SHANIECSHA PAYNE and SHAKEASHA PAYNE, Her Mother and Natural Guardian Plaintiffs IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA v. NO. 06 - .t.;~9C; C'u:( ~~ SHERRY AMSLER, Respondent CIVIL ACTION - LAW JURY TRIAL DEMANDED ORDER AND NOW this Zi~ day of 111"'"'- ,2000, upon consideration of the Plaintiff's Petition to Approve Compromise Settlement and Distribution of Proceeds, Plaintiff's request for approval of the Compromise Settlement in the above captioned matter is approved. Plaintiff's contingent fee agreement with counsel is approved and Plaintiff's counsel shall collect fees, costs and expenses set forth in Plaintiff's Petition and the exhibits attached hereto from the proceeds of this settlement. The balance of the proceeds shall be deposited in one or more savings accounts in the name of Shaniecsha Payne in banks, building and loan associations or savings and loan associations, deposits of which are insured by a Federal governmental agency provided that the amount deposited in anyone savings institution shall not exceed the amount to which accounts are thus insured. No withdrawal shall be made from any such account until Shaniecsha Payne shall attain her majority, except as authorized by further Order of this Court. Proof of the deposit, along with a signature card for each account, shall be promptly filed of record with the Court. --1~ /f i / J~ .00 k} ? ~f. . , '.1 ,.," -'~' ' 8!ii ~'~~ ~Vl L"-L'~!IlIiiliIIM \tlN'r/1\7ASNN3d , AlNnC)) OMfJl:J]fiMino so:~ ~!d 8, fin!' 00 ILJ\.IiC'i\lvn~;in""";l~;; ~o 1\0 v_ 'l...'..-'.."~. .,1, '..l.. .... 'AI I 1'" -.('r'1~I' , :lV!,J:;1U \"J:} ,:"'1 ~, -' <".<. ; ~ " .",;,.,;"J '1diI .." - '" . . B' ~~_-~ ",! i t", . SHOLLENBERGER & J ANUZZI, LLP 1820 Lillglestown Road P.O. Box 60545 Harrisburg, Pennsylvania 17106-0545 Telephone Number: (717) 234-3700 Fax Number: (717) 234-8212 Attome s for Plaintiff SHANIECSHA PAYNE and SHAKEASHA PAYNE, Her Mother and Natural Guardian Plaintiffs IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA v. NO. SHERRY AMSLER, Respondent CIVIL ACTION - LAW JURY TRIAL DEMANDED . . .'ORDER AND NOW this day of , 2000, upon consideration of the within Petition, a hearing shall be scheduled in the above captioned matter to determine whether or not the Court's approval shall be given to the within Compromise Settlement and Proposed Distribution of Settlement Proceeds. Hearing to be held on the Courtroom Number at day of a.m./p.m. , 2000 in J. SHOLLENBERGER & J ANUZZI, LLP 1820 Linglestown Road P.O. Box 60545 Harrisburg, Pennsylvania 17106-0545 Telephone Nwnber; (717) 234-3700 Fax Nwnber; (717) 234-8212 Attome s for Plaintiff SHANlECSHA PAYNE and SHAKEASHA PAYNE, Her Mother and Natural Guardian Plaintiffs v. IN THE GOURTOF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA n'~,- NO. 01:>-'-/'::<''7? ~ I~ SHERRY AMSLER, Respondent CIVIL ACTION - LAW JURY TRIAL DEMANDED PETITION TO APPROVE COMPROMISE SETTLEMENT & DfSTRIBUTION OF PROCEEDS -- -- AND NOW come the Petitioners, SHANIECSHA PAYNE, a minor, and SHAKEASHA PAYNE, her Mother and natural guardian, by and through their attorneys, SHOLLENBERGER & JANUZZI, LLP, and respectfully represent the following: 1. Petitioner, SHANIECSHA PAYNE, is a minor, having been born on September 5,1995 and resides with Shakeasha Payne, her Mother, at 2407A Cedar Run Drive, Camp Hill, Cumberland County, Pennsylvania. 2. Petitioner, Shakeasha Payne is the Mother and natural guardian of SHANIECSHA PAYNE and is an adult individual residing at the above stated address. 3. On or about April 1 0, 1999, Petitioner, SHANIECSHA PAYNE, suffered injuries in the nature of a right thigh contusion when the vehicle she was riding in was struck by a vehicle being operated by the Respondent. 4. As a result of the above referenced incident, Petitioner, SHANIECSHA PAYNE, required treatment at the Polyclinic Hospital and follow-up treatment with her family physician, Kline Family Practice. Medical bills incurred for said treatment have been paid under the first party benefits coverage of Petitioner, Shakeasha Payne's auto insurance provided by Motorist Mutual Insurance Co. Petitioner has not received any medical treatment for injuries related to this incident since April 30, 1999. Medical records are attached hereto as Exhibit "A". ~' . '..lIl.l<> 5. Petitioner, SHANIECSHA PAYNE, alleges she sustained the above referenced injuries as a result of the negligence of the Respondent named herein. 6. The Respondent, while not admitting liability, has offered to settle this claim for $300.00. 7. The Petitioner, SHANIECSHA PAYNE, by Petitioner, Shakeasha Payne, her Mother and natural guardian, believes that the offer of settlement is fair and reasonable. 8. The Petitioner, SHANIECSHA PAYNE, by Shaakeasha Payne her Mother and natural guardian, has retained the services of SHOLLENBERGER & JANUZZI, LLP. The aforesaid attorneys have agreed to handle this claim without a fee. 9. The Petitioner has further agreed to payout of her share of the recovery any and all costs incurred or advanced on her behalf. The amount of the costs that were incurred and advanced on Petitioner, SHANIECSHA PAYNE's behalf to date in this matter total $45.50. An itemization of all costs is attached hereto, incorporated herein and marked as Exhibit "B". 1 O. The Petitioners request the court approve the compromised settlement and allow the distribution as follows: Shollenberger & Januzzi, LLP (reimbursement of costs advanced) $ 45.50 Shaniecsha Payne, In Trust $254.50 11. The Petitioner, SHANIECSHA PAYNE, by Petitioner, Shakeasha Payne, her Mother and natural guardian, requests that upon approval of the proposed compromise settlement they be authorized to issue a good and sufficient release of any further liability against the Respondent and to discontinue the above action against the Respondent named herein. WHEREFORE, Petitioner, SHANIECSHA PAYNE, by Petitioner, Shakeasha Payne, her Mother and natural guardian, requests this Honorable Court approve the Compromise Settlement and Distribution of Proceeds and approve Petitioner's fee agreement with counsel. . Dated: .<, ~". . ~~, I~~ Respectfully submitted, SHOLLENBERGER & JANUZZI, LLP By: June 22, 2000 C,- "'I _lIli['H__~"jinll!il!tl''''''''~~!$M~ ill&l~li1lJliJ ,,,,~, ,..-,~"ij,'!I'll~:M,~.~.,,,...,,>, _,,'," _, - , ',"0 " " ~,,' - " H.~~''''''''l lln ~ prJ ~ <Q. tl~ fIi ~~ -... ~ ...() t & ~ -...i I Ie) ~ -C>YJ --.......:) p::~ "t .......""~ ~ , o c: ~~ -Ocr' "nf-'~~ z'e; 0~<: ~e'.: iii3 z --j -< ',' c-~ u ~.- :,"~~ :......) 0") :~ ..." ~~ ::0 .~Srf{ :);! ~~,] -< :::> ~ Illl..-Jir >1 o "n .., ~ ,::1 c