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IN THE covIn OF COMMON PLEAS OF
CVMBERLAND COUNTY. PENNSYLVANIA
DALE HAIR and NANCY HERTZ
us Guardians of ,JONATHAN IIAII{:
Minor Child and in his owu right
PlaintiW Petitioner.
N().~,.r"'J ('It., I /.t.
v.
Civil Action - Law
Personal Injury
STANLEY R. ROCKEY
Defendant/ Respondent
PETITION FOR LEAVE TO COMPROMISE
MINOR'S ACTION
Pursuaut to Pa.R.C.P. No. 2039, Dale !lair and Nancy Hcrtz, thc parcllls and natural
guardians of minor, Jonathan !lair, hy his allorney, Lee E. Oeslcrling, Esquire, petitions this
Court to enter an order permitting selllemelll in compromise of this action and in support avcrs
the following:
I. Dale Bair and Nancy Hertz arc the natural parents and guardians of minor pluillliff, Jonathan
Bair, who was born on May 20''', 1982, and who is presently 17 years of age.
2. Minor-plaintiff was injured on or about Septemher I I, 1997, at the Carlisle Pike and ABC
West Bowling Lanes in Mechanicsburg, Pennsylvania, when the vehicle being operated by
his father was struck by the vehicle being operated by defendant, Stanley Rockey.
3. The injuries sustained by minor-plaintiff, were cervical acceleration / deceleration injury,
Cervical segmental dysfunction and Cervical kyphosis. Minor-plaintiff has recovered fully
from all of his injuries.
4. All medical expenses incurred hy minor-plaillliff have heen reimhursed through the first party
insurer.
5. Counsel was retained to represent minor-plaintiff on a cOlllingent fee basis of thirty three
(33%) percent of any recovery. Additionally, counsel has incurred the following out of