HomeMy WebLinkAbout94-00476
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the PNdentlellnlu,ance Compeny 01 Amerial
Group Life Claim DIv~lon
PO Box 1215, Newark, NJ 01101.1215
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January 23, 1997
~ Prudential
Judy B. Keirn
237 Middle Road
Newvltle, PA 17241
Insured: WalterJ. Keirn
Policy #: 0-34087
S.S. #: 168.36.6624
Dear MR, Kl1lm:
This is written in regard to the Group Life Insurance claim that we recently received for
Walter J. Keim. This was under Oroup Pollcy 0-34087 issued to Masland Industries
Incorporated.
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According to the beneficiary designated completed by Walter J. Keirn, Judy 8. Keirn and
Brett J. Keirn are named beneficiaries for the proceeds from this policy. We are releasing
the payment due to Judy B. Keirn. We have also been advised that Brett J. Keim is a
minor, since Brett J. Keirn is a minor, payment of his portion of the proceeds can not be
released at this time. However, settlement may be made the court appointed legal
guardian of the properly of estale of the minor beneficiary. If a guardian is to be
appolnled, please provide us with a certified copy of the court order appointing a guardian
of the property or eslate ofBrett J. Keirn.
If court appointment of a guardian will not be pursued or obtained shortly, the proceeds
can be held by Pnldentialuntil the minor beneficiary attains the age of majority, usually
18, We are currently paying interest of 4,25% per annum, although neither the rate of
Interest, nor the practict1 of paying Intp.rest is guurnnteed. OUI' intereRt rate Is adjusted
monthly to reflect short term market rates.
Ifthis mode of settlements is desired, the person who is now responsible for the care and
maintenance of the minor beneficiary should complete the attached fonn Rnd return it to
us. Once we receive this form, we wll\ issue a Settlement Option Three Certificate to
Brett J, Keim. This certificate may be surrendered for the proceeds when Brett J. Keirn
attains the age of majority or when a guardian has been appointed,
(con't on page 2)
Exhibit ^
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Keirn by removing 2 small pieces of glass that were located on the
side of his face near the hair line and repairing the wound with
sutures.
12. Two small scars are located on Brett's face as a result
of the accident.
13. Brett
from William P.
1993, September
14. Dermabrasion was performed by Dr. Graham on August 16,
1993 in an effort to reduce the decree of conspicuousness of the
scars.
J, Keirn visited with and/or received treatment
Graham, Ill, ~1.[), on June Ill, 1!!!!3, August 16,
7, 19!!:J, November 5, 199~1 and February 15, 1!!94,
15, Brett J, Keirn has received no further medical treatment
since August 16, 1993.
16, 'rhe prognosis is good. Attached hereto, labeled Exhibit
"A" and incorporated by reference herein is a copy of a report by
Or, WilHam P. Graham, III, M,D. dated March 4, 1!J94.
17. The medical expenses associated with Brett's treatment
totalled $ 3,503,44, the entire amount of which was paid by state
Farm Insurance Company as a first party benefits, Future medical
expenses, if any, would contlnue to be paid by the Pennsylvania
Motor Vehicle Financial Responsibility Act.
lB. Richard L, Webber, ,Jr" counsel for the minor
Petitioner, has been retained by Petitioners on a contingent fee
basis. A copy of the applicable fee agreement is attached hereto,
labeled Exhibit "B" and incorporated by reference herein.
19, Counsel has tendered a settlement offer to Walter J.
Keirn and Judy 8. Keirn and they have accepted such offer, subject
to approval from your Honorable Court, as follows:
(a) The total sum of the settlement to be paid toward
general damages sustained shall be $ 15,000.00,
(bl counsel for the Petitioners shall receive
$ 3,750.00 of the $ 15,000,00 at the present time,
as attorney fees.
20. Petitioners have discussed the proposed settlement with
counsel and believe that the above settlement is reasonable under
the circumstances.
leI The remaining $ 11,250.00 shall be placed in a
savings account at Harris Savings Dank, 17 West
High Street, Carlisle, PA, to be released to
BRETT KEIM upon his reaching the ase of 18 on
November 12, 2002.
RICHARD L. WEBBER, JR.
Attorney at Law
11 West Big Spring Avenue
P.O. Box 40
Newville, PA 17241.0040
September 25, 1992
Telephone (717) 776-6566
FAX (717) 776-6086
Mr. and Mrs. Walter J. Keim
2S1 Middle Road. Lot 4
Newville. PA 17241
RE: Automobile accident - Aygust 25, 1992
Dear Walter and JUdy:
This letter will confirm our recent disoussion in which I
agreed. at your request, to represent you in the above-referenced
matter.
I have agreed to provide my services on a contingent fee
basis. Thi~. means that I will undertake your representation to
perform the services described below and in return, you will pay
me a percentage of the amount of money received as an award 01
settlement, if any.
My services may include a review of applicable statutes,
research of case law, i.nterview and taking statements of
witnesses, the taking of depositions. retaining the services of
experts where necessary and oonsultations with them, planning and
preparation of appearances, negotiations with insurance adjusters
and opposing counsel, correspondence and meetings and telephone
conversations with you.
My fee will be twenty-five percent (25%) of the amount
recovered if "settlement" is obtained pl'ior to filing court
proceedin9S. My fee will be thirty-three peroent (33'\;) of t,he
amount recovered if a civil action (lawsuit) is filed.
Regardless of whether there is a recovery in your case. and
irrespective of whether a fee is paid to me, out-of-pocket
expenses directly attributable to your oase are required to be
paid by you. These may inolude expenses for such things as
investigative reports, medical reports. court costs, depositions,
witness fees, use and appearance of experts and possible exhibit~
used in tdaJ.
You. as a client of
funds to defray these
representation of you.
mine, will be responsible for advancing
immediate costs as they occur during my
Exhibit "8"
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3101 "B
l.:EH 11t-ICA 1 c OF DEPOSIT
III HARRIS
.. SAVINGS BANK
MAIN OFFice
seCOND AND PINE STREETS' HARRISBURO, PA 17101
KEIM
KEI
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CONTROL NUMf'ER
1L66-310198
AGCOUNT NUMfH:I1
I. ACCOUNT IUMMAAV IICTION
"IN_WALlIR.. RAT! . 911 I.CTION IV
TE OF ARNINGS FREOU NCY OF
PER ANNUM COI,t~.Q~.
6.0501.
~EMI :,,':,N\!
fAnNINOS -- ~t\,~
EARNING9 OISTAIB BEGINNING ___. ._
HIEREAFTER, WITH tHE LA9T DISTRIBUTION ON THE FINAL MA1UAITY DATI!
""S ACCOUNT SUBJECT TO RULES OF CLASS OUTLINED ON n[VERSE sloe
FDlcl " ~~~.~'
INSlINl:l), NON.TAAHIFIRAILI I(~ ~','.ll
t,!!.~J,:
5AVII.\IM41 t
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