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Home My WebLink About00-05569 'i' '''' - ~ '"1, i I " GLENN T. WOLFORD, Individually, and as Executor of the Estate of CAROLYN L. WOLFORD, Petitioners IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA NO. 00-$'5'1.1' eOL(-l~ CIVIL ACTION-LAW v. ANITA HENRY, ERIE INSURANCE EXCHANGE and ERIE INSURANCE GROUP, Respondents ORDER AND NOW, this ~ day of August, 2000, the Petition for Approval of the Settlement of the Wrongful Death and Survivor Claims is granted, payable$73,840.24 to Glenn T. Wolford, Individually, and as Executor of the Estate of Carolyn L. Wolf< d $26,159.76 to Martson Deardorff Williams & Otto. 1. I Cop'\e"Q~ flileuJyJ !J- /1. (j(J -'"'''''''~~'l!nJ'''-'''''~-'ltll~~"~_~n1i\~~iW<t,g~~~-'>- , , ,~, ,'"' - .,~ ~,- ~,~~" -'-- ~'C,,' --~ - ~ ,", J] "', ['."~"';"""V ~ "'""'!lti~ .. ""'O".~~ (") Cl 0 C 0 -n S "" .-4 --0 OJ c:::: -X ;"1" :!J mm G') '-;r,:; Z::D me;;: 719 ~~: s~o !;20 :0- :c:H ~o ::;1: 05 -0 - ...c-rn >c - 0 .. ~. ~ w N; '-< S~; ". , '--', F:\FILES\DA TAFILE\Gendoc.cur\99712-pet.2Inlm Created:'08l09/0010:51:27AM ReviSed: 08111100 10:46:41 AM 9971.2 GLENN T. WOLFORD, Individually, and as Executor of the Estate of CAROLYN L. WOLFORD, Petitioners IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYL VANIA NO. 017-55(.9 ~ 7p..- CIVIL ACTION-LAW v. ANITA HENRY, ERIE INSURANCE EXCHANGE and ERIE INSURANCE GROUP, Respondents PETITION FOR APPROVAL OF THE SETTLEMENT OF THE WRONGFUL DEATH AND SURVIVOR CLAIMS 1. Petitioner is Glenn T. Wolford, an adult individual residing at 2074 Reservoir Drive, Carlisle,PA 17013. 2. The Respondent Anita Henry is an adult individual residing at 615 Hamilton Street, Carlisle, PA 17013-1925. 3. The Respondents Erie Insurance Exchange and Erie Insurance Group are insurance carriers licensed to conduct business in Pennsylvania with an address at 4901 Louise Drive, Rossmoyne Business Center, P.O. Box 2013, Mechanicsburg, PA 17055. 4. On or about October 27, 1999, Plaintiffs decedent, Carolyn L. Wolford was a right front-seat passenger in a 1989 Honda Accord, owned and operated by Respondent Anita Henry. 5. As the Henry vehicle was proceeding in the right-hand south-bound lane of Route 81 in Cumberland County, a small teal colored car came in to the Plaintiffs lane of travel, in which Mrs. Henry was driving. 6. Respondent Anita Henry lost control of the 1989 Honda Accord resulting in it swerving off the roadway and across the berm before flipping upside down in a ditch on the left-hand side ofthe roadway. 7. As a result of the vehicle flipping, Carolyn L. Wolford was ejected from the vehicle and died as a result of her injuries. 8. On or about November 16, 1999, Glenn T. Wolford was appointed Executor ofthe Estate of Carolyn Wolford. 9. At the time of the automobile accident in question, Anita Henry was covered by a policy of insurance with the Erie Insurance Exchange/Erie Insurance Group, Policy Number ~ ,",--' ';; Q031506544H, which provided liability coverage in the amount of$l 00,000 per person or $300,000 per accident. A copy of the declarations sheet for that policy covering the date of the accident is hereby attached as Exhibit "A". 10. Erie Insurance Exchange/Erie Insurance Group has offered its $1 00,000 policy limits to Glenn Wolford and the Estate of Carolyn Wolford. 11. The Petitioner Glenn Wolford is also covered by a policy of motor vehicle insurance that provides for under-insured motorist benefits with Erie Insurance Exchange/Erie Insurance Group. 12. Erie Insurance has given their consent to settle to the Petitioners and waived their subrogation rights against Anita Henry. A copy of that written consent to settle letter is hereby attached as Exhibit "B". 13. Petitioners are represented by the firm of Martson Deardorff Williams & Otto and have a 25% contingency agreement with said law firm, 14. Counsel has incurred out-of-pocket costs necessary to pursue the claim of$I,159. 76. 15. Although Petitioners do not believe it is necessary to obtain Court approval since there are no heirs which are minors or incompetents, Erie has requested that Court approval be obtained. WHEREFORE, Petitioners request that this Court grant the Petition for Approval of the Settlement of the Wrongful Death and Survivor Claims which Petitioners would have against Anita Henry in exchange for a General Release in favor of Anita Henry and to Erie Insurance to the extent it provided liability coverage under the Henry vehicle. By George B. Faller, Jr., Esqu' LD. Number 49813 Ten East High Street Carlisle, PA 17013-3093 (717) 243-3341 Date: 2'\\\\00 Attorneys for Petitioners "~'l" S9H , ERIE INSURANCE EXCHANGE PIONEER FAMILY AUTO POLICY , . . CONTINUATION NOTICE AA7805 FETROW INS ASSOCIATES 03/15/99 TO 03/15/00 Q03 1506544 H ROBERT W HENRY & ANITA R HENRY 615 HAMILTON ST CARLISLE PA 17013-1925 AGENT - FETROW INS ASSOCIATES ***** AGENT PHONE - (717) 249-3340 401 EAST LOUTHER STREET CARLISLE PA 17013 0000 ************************************************************ * CONGRATULATIONS! A PIONEER EXPERIENCE RATING CREDIT HAS * * BEEN APPLIED TO YOUR POLICY PREMIUM. * ************************************************************ ITEM AUTO 1 2 4. AUTOS COVERED YR MAKE 91 HOND CIVIC DX 89 HOND ACCORD LXI VIN 1HGED3545ML081896 1HGCA5542KA016475 ST PA PA TER 4F 4F SYM 5 K RATING CLASS A2BL-MULTI A1BS-MULTI DDP ITEM 5. INSURANCE IS PROVIDED WHERE A PREMIUM, OR INCL, IS SHOWN FOR THE COVERAGE. COVERAGES, LIMITS AND ANNUAL PREMIUMS ARE AS FOLLONS- TOTAL ANNUAL PRBMIUM FOR EACH AUTO TOTAL ANNUAL POLICY PREMIUM ITEM 6. APPLICABLE POLICY, ENDORSEMENTS, EXCEPTIONS TO DECLARATIONS ITEMS ALL AUTOS - FAP 04/97, UF-9033 04/98*, AFPN01 10/98*, AFPA03 10/98*. AUTO 1 - AFPU01 06/98*. AUTO 2 - AFPU01 06/98*. #1 #2 *****GOOD DRIVER RATES APPLY***** ALL PRIVATE PASSENGER VEHICLES. - -- 87 70 70 56 25 29 6 7 1 1 1 1 20 20 66 66 35 29 115 92 426 371 $ 797 --- THE FULL TORT OPTION APPLIES TO LIABILITY PROTECTION- BODILY INJURY $100M/PERSON $300M/ACC PROPERTY DAMAGE $50M/ACC FIRST PARTY BENEFITS- MEDICAL EXPENSE $10M INCOME LOSS $ 1M/MONTH , $5M MAXIMUM ACCIDENTAL DEATH $5M FUNERAL BENEFIT $1.5M UNINSURED MOTORISTS COVERAGE- BOD INJ $100M/PERSON $300M/ACC-STACKED UNDER INSURED MOTORISTS COVERAGE- BOD INJ $100M/PERSON $300M/ACC-STACKED PHYSICAL DAMAGE COVERAGES- COMPREHENSIVE - $100 DED COLLISION - $200 DED PASSIVE RESTRAINT DISCOUNT APPLIES - AUTOMATIC BELTS AUTO 1 Exhibit "A" ;J~ ~ ********~********************************************************** * FI~ST ACCIDENT FORGIVENESS APPLIES. THE FIRST SURCHARGE FOR A '* *. . FUT~y,:E AT- FAULT ACCIDENT WILL BE "WAIVED. * ******~************************************************************ EXPLANATION OF ADULT &/OR YOUTHFUL DRIVER RATING CLASS AUTO 1-TO WORK 11-14 MILES ONE WAY, 8,501 OR MORE MILES ANNUALLY AUTO 2-TO WORK LESS THAN 6 MILES ONE WAY, UP TO 8,500 MILES ANNUALLY ND WFS . lIiiij "'^"'O'^;, 02/13/99 , " """17'1 " , MISCELLANEOUS INFORMATION ITEM 7. EACH AUTO WE INSURE WILL BE PRINCIPALLY GARAGED AT THE ADDRESS SHOWN IN ITEM 1, UNLESS ANOTHER ADDRESS IS SHOWN BELOW. ITEM 9. UNLESS A CO-OWNER OR LIENHOLDER IS LISTED BELOW, THE NAMED INSURED IS THE SOLE OWNER OF EACH AUTO WE INSURE. ******************************************************************************** * DRIVER 1 ROBERT W HENRY 2 ANITA R HENRY ST LICENSE NUMBER PA 17076314 PA 20404063 BIRTH DATE 04/26/56 10/03/63 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 COMMITS A FRAUDULENT INSURANCE ACT, WHICH IS A CRIME AND SUBJECTS THE PERSON TO CRIMINAL AND CIVIL PENALTIES. YOUR COLLISION COVERAGE AND DEDUCTIBLE APPLY TO PRIVATE PASSENGER AUTOS YOU OR A RESIDENT RELATIVE RENT FOR 45 DAYS OR LESS. THIS IS SUBJECT TO LIMITS, TERMS AND CONDITIONS IN THE POLICY. THE LAWS OF THE COMMONWEALTH OF PENNSYLVANIA, AS ENACTED BY THE GENERAL ASSEMBLY, ONLY REQUIRE THAT YOU PURCHASE LIABILITY AND FIRST-PARTY MEDICAL BENEFIT COVERAGES. ANY ADDITIONAL COVERAGES OR COVERAGES IN EXCESS OF THE LIMITS REQUIRED BY LAW ARE PROVIDED ONLY AT YOUR REQUEST AS ENHANCEMENTS TO THE BASIC COVERAGES. BELOW ARE ANNUAL PREMIUMS FOR THE MINIMUM REQUIRED COVERAGES AND LIMITS FOR FULL TORT. # 1 # 2 BODILY INJURY $15M/PERSON $30M/ACC PROPERTY DAMAGE $5M/ACC FIRST PARTY BENEFITS - MEDICAL EXPENSE $5M 50 62 22 40 49 24 Q03 1506544 INVOICE INFORMATION: DATE DUE PAYMENT DUE 03-15-99 06-15-99 09-15-99 12-15-99 199.00 201.00* 201.00* 202.00* 04 I / ."'" ." .~ '"-''' ", ~'~ ~ ERIE INSURANCE GROUP "~.... Branen Office' 4901 Louise Dr. . Rossmoyne 81Jtiness Camer. P.O. Bole 2013 . Mechanicsburg, PA 17055-0710 ~ _ Pi'lon. (717) 795-9200' Toll Fr.. HOQ-38,'1304' Fa. (717) 795-2315' hlt,oJlwww,o,;e-insuranc,,-cDrn ERIE. ,~ ERIE HIlG BRANCH --- - , ~,+ .:..-' ,--" ,'dC- . "iIiIlK ~002 *' .. .. ~ June 8, 2000 George V. Faller, Jr., Esq, Manson, Deardorff, Williams & Otto Ten East High Street Carlisle, PA 17013 Re: ERIE Claw BIDE Insured: Your Clients: Your File #010170457294 Glenn T. & Carolyn L. Wolford Glenn T. & Carolyn L. Wolford #9971.2 Dear Mr. Faller: 'N: .. We are writing in regard to your previous request for consent to se!tl~ the underlying Bodily Injury claim through Erie Insurance Group under Claim #010170457298. You have our permission to settle our insured'S Bodily Injury claim for Erie Insurance Group's Bodily Injury Liability limit of $100,000,00 in accordance to Claim #010170457298 under policy issued !o Robert and Anita Henry under Policy #Q03 1506544 in effect on the date of loss, October 27, 1999. Erie Insurance Group will not pursue any subrogallon when an Underinsured Motorists claw is presented under the policy issued to GleM T. Wolford and Carolyn L. Wolford, under policy #Q03210I263_ If you have any questions in regard to this matter, please do not hesitate to contact me at the telephone number listed below. Sincern () 4lL: /t:na QjJ 0;; fu~ uU Lori Renaldi- W aqar U Telephone Claims Representative Harrisburg Branch Claims (717) 795-2288 (717) 795-2315 (Fax) LR:lh Exhibit "E" 49:lO2_1 ',. < ~; , . .. '. VERIFICATION The foregoing Petition for Approval of the Settlement of the Wrongful Death and Survivor Claims is based upon information which has been gathered by my counsel in the preparation of the lawsuit. The language of the document is that of counsel and not my own. I have read the document and to the extent that it is based upon information which I have given to my counsel, it is true and correct to the best of my knowledge, information and belief. To the extent that the content of the document is that of counsel, I have relied upon counsel in making this verification. This statement and verification are made subject to the penalties of18 Pa. C.S. Section 4904 relating to unsworn falsification to authorities, which provides that if I make knowingly false averments, I may be subject to criminal penalties. 4 :? ~/~ Glenn T. Wolford Individually, and as Executor of the Estate of Carolyn L. Wolford lillflilL. ~ -- ~~"'" :u,.lI~.liiiJMfiItl~iiillilIi .' --J.liiiiIiiil1~11r.'~~ mili!i!i~i'!h;fcMU....O'iiISI"' -"""''''-''-~- '. ~ (") 0 0 0 C c:> p ~ ~ ~ ., J:>o f"'" ~CD ~ :T;':TI It:. ~ rllrn, G'i Z:n If:. Z' r: d enS:;: -n, I ~ . ""f' 6 ,--". ..0 ..........::::..... ~ ~CJ C><J """ ..,; .() , >'0 ~ -1.c=H ~o 6~ ~ L.> ~ >c .,.;j - ~ Z ~ W r- i =< co ::u -< J "" ",.~ GLENN T. WOLFORD, Individually, and as Executor of the Estate of CAROLYN L. WOLFORD, Petitioners IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYL VANIA NO. 00-5569 CIVIL TERM CIVIL ACTION-LAW v. ANITA HENRY, ERIE INSURANCE EXCHANGE and ERIE INSURANCE GROUP, Respondents ORDER AND NOW, this 'Z' day of November, 2000, the Petition for Approval of the Settlement ofthe Under Insured Motorist Claim under the Wrongful Death and Survival Acts is granted in the amount of$325,000.00, payable $243,750.00 to Glenn T. Wolford, Individually, and as Executor of the Estate of Carolyn L. Wolford and $81,250.00 to Martson IJe illiams & Otto. ,/,.-/' / t~ J/- 2/-00.. RX3 ( _~Ili'."".'""".~ ll>Iti"t:lI"'~'!i'1!"....;j,~",~",iiffiljW~O!IiiliRiW)';;:;Wri:""))~~A~~~~1 \i\\'f1i\\i,S~\N~g 11"n'" 'nr-t'~, 1'11'-. \'t,-nl,-I~10" 'n \v i'l "J' "', .,... \.1. \; '".',-, '" ~_.7 \.11 G'I.(.; ~O '.',.i\'-J,'! )-d\I,,:V\'._'-) . 38\ ,,[__ " ,.' .~,,~,.~~..,~,-<,,'~" ,~_" _f..,,,,,,, "/'" ""I)n r:n v l'i.' l~ l,.... "-'-"- :j,Q--'C~_: \\~~ ---'., "-, ~,),'J ", ,_ ",,.-,,>- i"~," ~, - ~wl''''.'" ff~'l'-'- . iW'IlO.~!!ii:4ill:fljjllf;'!ilmDiiltilli'fllii~fl1ll ~.~ ,,--,. ~ I~'" J2i ,~ .^ r~ilI~.~~' F:\FILES\DA TAFILE\Gendoc.cur\99712-pet.3/mah Created: 08/09/00 10:51:27 AM Revised: 11f20fOO04:56:32PM 997i.2 GLENN T. WOLFORD, Individually, and as Executor ofthe Estate of CAROLYN L. WOLFORD, Petitioners IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYL VANIA NO. 00-5569 CIVIL TERM CIVIL ACTION-LAW v. ANITA HENRY, ERIE INSURANCE EXCHANGE and ERIE INSURANCE GROUP, Respondents PETITION FOR APPROVAL OF THE SETTLEMENT OF THE UNDER INSURED MOTORIST CLAIM UNDER THE WRONGFUL DEATH AND SURVIVAL ACTS 1. Petitioner is Glenn T . Wolford, an adult individual residing at 2074 Reservoir Drive, Carlisle, P A 17013. 2. The Respondents Erie Insurance Exchange and Erie Insurance Group are insurance carriers licensed to conduct business in Pennsylvania with an address at 4901 Louise Drive, Rossmoyne Business Center, P.O. Box 2013, Mechanicsburg, P A 17055. 3. On or about October 27, 1999, Plaintiffs decedent, Carolyn L. Wolford was a right front-seat passenger in a 1989 Honda Accord, owned and operated by Anita Henry. 4. As the Henry vehicle was proceeding in the right-hand south-bound lane of Route 81 in Cumberland County, a small teal colored car came in to the Plaintiffs lane of travel, in which Mrs. Henry was driving, 5. Respondent Anita Henry lost control of the 1989 Honda Accord resulting in it swerving off the roadway and across the berm before flipping upside down in a ditch on the left-hand side of the roadway. 6. As a result of the vehicle flipping, Carolyn L. Wolford was ej ected from the vehicle and died as a result of her injuries. 7. On or about November 16,1999, Glenn T. Wolford was appointed Executor ofthe Estate of Carolyn Wolford. 8. At the time of the automobile accident in question, Anita Henry was covered by a policy of insurance with the Erie Insurance Exchange/Erie Insurance Group, Policy Number Q03l506544H, which provided liability coverage in the amountof$l OO,OOOperperson or $300,000 '-, "~,' I .'- '"ilil:' per accident. A copy of the declarations sheet for that policy covering the date of the accident is hereby attached as Exhibit "A", 9. Erie Insurance Exchange/Erie Insurance Group has paid its $100,000 policy limits to Glenn Wolford and the Estate of Carolyn Wolford which payment was approved by this Court by Order ofthe Honorable Edgar B. Bayley dated August 10th 2000, (A copy ofthat Order is hereby attached as Exhibit" A".) 1 O. The Petitioner Glenn Wolford is also covered by a policy of motor vehicle insurance that provides for under insured motorist (VIM) benefits with Erie Insurance Exchange/Erie Insurance Group. That policy provides for VIM coverage limits of $300,000.00, with stacking for two vehicles. (A copy of that Declaration Sheet is hereby attached as Exhibit ''B''. 11. Erie Insurance and the Petitioners have agreed to settle the VIM claim for $325,000.00. 12. Petitioners are represented by the firm of Martson Deardorff Williams & Otto and have a 25% contingency agreement with said law firm. 13. Although Petitioners do not believe it is necessary to obtain Court approval since there are no heirs which are minors or incompetents, Erie has requested that Court approval be obtained. WHEREFORE, Petitioners request that this Court grant the Petition for Approval of the Settlement of the Under Insured Motorist Claim under the Wrongful Death and Survival Acts in the amount of$325,000.00, payable $243,750.00 to Glen T. Wolford, Individually, and as Executor of the Estate of Carolyn L. Wolford and $81,250.00 to Martson Deardorff Williams & Otto, By Geor e . al er, Jr., Esqui LD, Number 49813 Ten East High Street Carlisle, P A 17013-3093 (717) 243-3341 Date: Attorneys for Petitioner I " """,," """""'F'i""i'Ii."""'i""""""'II,'ic,J),,,,,'!%,,,'I') """"II""""",&LL """"",,,,,JI,),L,,,,,,,,,,,m,,,,,,;,;,,,, """;"),""}_.~",;"",",""",,,;,;;",,",,,,,",",;""\1)I,",""""JJ,",",""""""",""","",,,,,,',',:,",:"""(,",""",""","""tl:rJ!L"":I::,("""' ",""",":,"'",,"""",,","I,",:, If l'llERIE ';.:,'.',1, Im'.. INSURANCE I ~~ GROUP i} ~ 100 Erie' Ins, PI, j;:~~ ERIE Erie, PA 16530 ::,:.1 8 i ,.,,~ ERIE INSURANCE EXCHANGE PIONEER FAMILY AUTO POLICY CONTINUATION NOTICE l . .~..,.....X~'h", _". ~~., "x....,'~.,.,~.,.,w<.'w,.j:K:~ ::',:Jj@;nMMB,~~1~~~l~1~@#%W~1~,'}~n'lM~M~Wi$~!~.:':"'::": Y:~h_ i [t:~~;f1.@\~i~~~i~~f.:~~;~!!!t1!~~tJ!m.~~~,~r1;;:~~~~;;:t~~;~:a;~ -, '''-''-'.-, _W_V'.~ W ':":~'V".-.~C-:-c,'O:'~0~w: '_',v:-"':~~v:,;,,:,,"';"':_"::~'o~' . , 'I AA7646 FETROW INS ASSOCIATES ::" ", .~..... ...~.~.;~ .:~...: .:I_~ :'.~;.:': ",." .'."'~Mt~liID~!lfHt.1MlWif.ilil1:t~gf~;m~~f:' '. 'N~ ~: .... {. " 03/22/99 TO 03/22/00 Q03 2201263 H [f;~~~:[ilijn~ti~@Mf:~~:'j; .~' . .. ....' :........ ! il a t~ ::;1 ";':1 , Jj ;~ ~;,-,~ "'I ""1 'i II '"J H I ITEM jl (1 I 1 i 1 ij 1,,,11I,,,111,,,,,,11,,11.,,,111I11,1.1.,1,1111,,,1.1.,11,,1,1 GLENN T WOLFORD & CAROLYN L WOLFORD 2074 RESERVOIR DR CARLISLE PA 17013-1099 AS LISTED BELOW AGENT - FETROW INS ASSOCIATES ***** AGENT PHONE - (717) 766-3200 5299 E. TRINDLE RD. MECHANICSBURG PA 17055 3552 ************************************************************ * CONGRATULATIONS! A PIONEER EXPERIE~CE RATING CREDIT HAS * * BEEN APPLIED TO YOUR POLICY PREMIUM.' * * * ** * * * * * * * **** * * ** ** *** * * * ** ** * * * * **** **** *,* * * * ** ** * ** * * * * * , ITEM AUTO 1 2 4. AUTOS COVERED ., YR MAKE VIN ST TER SYM RATING CLASS, DDP 93 DODG INTREPID 2B3ED46TOPH642891 PA 4F 7 A1BS-MULTI 93 DODG DAKOTA 1B7FL26G6PS152929 PA 4F 4 A1BS-MULTI . 5 ",l:~~~~~~~ I ~o~gx~g~? ~~~SA A~~~~m1AL O~R~~~5Ms I fJH2r'Fb~~o~~~ ill #2 *****GOOD DRIVER RATES APPLY***** ALL PRIVATE PASSENGER VEHICLES. 70 70 56. .56 37 52 8 11 1 1 1 2 30 43 21 21 78 78 26 85 12 457 ~~ --- THE FULL TORT OPTION APPLIES TO LIABILITY PROTECTION- BODILY INJU~YS300M/PI!jR, SON $300M/ACC PRQPERl'Y DAMAGg S100M/ACC . ,,'.. FIRST PARTY BENEFI'1'S- MEDICALEXP~NSE S100M INCOME LOSS!SlM/MONTH, $15M MAXIMUM ACCIDENTAL DgATH S5M FUNERAL BENEFIT S2.5M EXTRAORDINARY;MEOICAL BENEFITS $1000M UNINSURED MOTORISTS COVERAGE- BOD INJ S300M7PERSON S300M,ACC-STACKED UNDERINSURED,MOTORISTS COVER GE- BOD INJ S300M!PERSON S300M ACC-STACKED PHYSICAL DAMAGE COVERAGES- COMPREH~NSIVE - $100 DED COLLISION ~;S250 DED OPTIONAL COVERAGES- TRANSP EXPENSES - COLL $20/DAY, $900/LOSS 12 TOTAL ANNUAL PREMIUM FOR EACH AUTO 446 TOTAL ANNUAL POLICY PREMIUM $ 903 ITEM 6. APPLICABLE POLICY, ENDORSI!iMENTS, EXCEPTI07NS TO DECLARAT7IONS ITEMS ALL AUTOS - FAP 04/.97, UF-9033 04/98*, AFPN01 10 98*, AFPA03 10 98*. AUTO 1 - AFPU01 06~98*. AUTO 2 - AFPU01 06,98*. MULTI POLICY DISCOUNT APPLIES - AMOUNT OF DISCOUNT IS $ 31 PASSIVE RESTRAINT DISCOUNT APPLIES - DUAL AIRBAGS AUTO 1 ************************************************************** * YOU HAVE SEEN INSURED WITH THE ERIE FOR AT LEAST 15 YEARS. * * THI S PClLI CY WI'LL NOT BE SURCHARGED FOR FUTURE ACCIDENTS. * * ** * * * * * * * * * * * * ** * * * ** * * * *"* * * * * * ** * * * *** * * * * * * * * * * * ** ** * * * * * * * EXHIBIT "B" i1?n~a:t~.4.'1 ".SEE REVERSE SIDE*" YD WFS 02/20/9 ;, ..~ ~ @b (ci) (~ 't. _ ~n;. AUG 11 2DOofIJ GLENN T. WOLFORD, Individually, and as Executor of the Estate of CAROLYN L. WOLFORD, Petitioners . ,. :' IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA eOli~ NO. 00 - $ S'fo 7' CIVIL ACTION-LAW v. ANITA HENRY, ERIE INSURANCE EXCHANGE and ERIE INSURANCE GROUP, Respondents ORDER .', ANn NOW, this (oIk. day of August, 2000, the Petition for Approval of the Settlement of the Wrongful Death and Survivor Claims is granted; payable$73,840.24 to Glenn T. Wolford, IndividUally, and as Executor of the Estate of Car01yn L. Wolford and $26,159.76 to Mattson; / Deardorff Williams & Otto. rc; ~ g~ ,T'RUE ()OPYFROM RECORD In Testimony"".,." tJlere _set my hano an~ tile of said '. atl.'"ft!1I..... Th, . ,... IOIIJ. EXHIBIT "A" ~i",,~ ' ~~~~ - ." ~,""il<l;l~~:;- VERIFICATION The foregoing Petition for Approval of the Settlement of the Under Insured Motorist Claim under the Wrongful Death and Survival Acts is based upon information which has been gathered by my counsel in the preparation of the lawsuit. The language of the document is that of counsel and not my own. I have read the document and to the extent that it is based upon information which I have given to my counsel, it is true and correct to the best of my knowledge, information and belief. To the extent that the content of the document is that of counsel, I have relied upon counsel in making this verification. This statement and verification are made subject to the penalties of 18 Pa. C.S. Section 4904 relating to unsworn falsification to authorities, which provides that if I make knowingly false averments, I may be subj ect to criminal penalties. ~ ;::::> t//~ Glenn T. Wolford Individually, and as Executor of the Estate of Carolyn L. Wolford ~\." ' "U;~t:'~L1 ,'. ,. ~~" ~ ."~.~ "IWm_~'lnfl'ff"M'~-0II!dililj~)11*ji$I~1\li!l'W.m:j:r '_~.~ '. -, " ~, ,.,< ~,~ ,,~ , " J.a" ,.......~~.,. " "',Jl n .(::) () C C:I "'1 .?~ -r,; r';'i ;:5 ITI [, -J';:: - :':'1 -, ~ 2' !"'-,) ~'j U) -' ", r; "...,., :::.:1 ~:) ]:.~ C) -..,.-,. ~=2 ...ll:~ () :i-; C; m C.: u :-:.: :.:;:j ~ 'e, 5j <:l -< .~,'- 'f , ~ " :~"o'"' ,. , . Gb~Y\. T WIl /(;,re{ vs. ~l1t En'~ II'fSur-lif'tce ) I <<...fIt 6n~ I" v G.roo In the Court of Common Pleas of Cumberland County, Pennsylvania J-O 00 No. {)6 - 5::>6 r Civil. 19 Pt Y11 k b:xcltG. f~ ~ ~ C#4L Ot'/a1 ~J~W{ljI, To Prothonotary ? tlOO 19 "'~"'~;>.'i8i "-~~toililll,~ii;jg~~~I\lli~il.I;t:li ~ ,i~~lllBiIl!'''''''''-''''''''''filIIlIj~iIilIil' -~" ~~ " No. Term, 19 _ vs. PRAECIPE Filed 19 , Atty. (') g 0 Ii "fi t::l ~:-" .., ~~ M T':zl I '-;~ "'Om .~~_lG <)):' -0 ~--p..J ig 'r--' :.x ~ ':D 00 ~ Zm 0 ~ i\) ?i (,.) -< ,,~, , ',","..' .. ^" - ~""",,~~,"p'-- '" -" ~ l'