HomeMy WebLinkAbout03-2321IN RE: ANDREW C. TEATS, a minor, : IN THE COURT OF COMMON PLEAS
by his legal custodians, MELODY A. CUMBERLAND COUNTY, PENNSYLVANIA
TEATS and CHESTER P. TEATS,
Petitioners NO.: O ~ ~ J., ~' ~. i
PETITION FOR APPROVAL OF MINOR SETTLEMENT
AND NOW, this day of May, 2003, comes Petitioners by their attorneys, Mancke,
Wagner, Tully & Spreha, who respectfully represent:
1. Andrew C. Teats is a minor who was born on October 3, 1993 and resides with your
Petitioners who are the grandparents of Andrew C. Teats, at 123 Oak Flat Road, Newville,
Pennsylvania, 17241.
2. Since January 1995, Andrew C. Teats has resided with Melody A. Teats and Chester
Teats, your Petitioners herein who have legal and physical custody of Andrew C. Teats. A copy
of said Court Order is attached hereto and made a part hereof as Exhibit "A."
3. On November 21, 2002, at or near Commerce Drive, South Middletown Township,
Cumberland County, Pennsylvania, Andrew C. Teats was a passenger in a vehicle driven by
Melody A. Teats which was involved in an accident at or near Commerce Ddve as previously
indicated.
4. At the aforesaid time and place a vehicle driven by Richard L. Kauffman of 508 S. Pitt
Street, Carlisle, Pennsylvania, was traveling generally northeast and around a curve when it came
onto the wrong side of the roadway, stdking the vehicle driven by Melody A. Teats.
05/14/"2003 09:22 72 77769459
CHESTER M. TEATS
and MELODY ANN TEATS
HEATHER MARIE TEATS
and JOEL COX
NEWVILLEPRINT
PAGE 01
IN THE COURT OF COLSON PLEAS OF
CUMBERLAND COUNTy, PENNSYLVANIA
No.
IN CUSTODY
pRD£R
AND NOW, this ~day of ~ 1998, Upon agreement
of the parties, legal and Physical custody of Andrew
Christopher Teats, born October 3, 1993, is granted to the
maternal grandparents, Chester M. Teats and Melody Ann Teats
with visitation by the natural parents as the parties may
agree.
BY THE COURT,
TRUE COPY FROM RECORD
In T~stimony whereof, I h 'r.. ,,~.~ ~t my hand
and the seal of said Court at Carlisle, p~.
..... ..............
IN RE: ANDREW C. TEATS, a minor, IN THE COURT OF COMMON PLEAS
by his legal custodians, MELODY A. : CUMBERLAND COUNTY, PENNSYLVANIA
TEATS and CHESTER P. TEATS,
Petitioners NO.: 4~)~ ~ .Z. ~' ~. I
PETITION FOR APPROVAL OF MINOR SETTLEMENT
AND NOW, this day of May, 2003, comes Petitioners by their attorneys, Mancke,
Wagner, Tully & Spreha, who respectfully represent:
1. Andrew C. Teats is a minor who was born on October 3, 1993 and resides with your
Petitioners who are the grandparents of Andrew C. Teats, at 123 Oak Flat Road, Newville,
Pennsylvania, 17241.
2. Since January 1995, Andrew C. Teats has resided with Melody A. Teats and Chester
Teats, your Petitioners herein who have legal and physical custody of Andrew C. Teats. A copy
of said Court Order is attached hereto and made a part hereof as Exhibit "A.'
3. On November 21, 2002, at or near Commerce Ddve, South Middletown Township,
Cumberland County, Pennsylvania, Andrew C. Teats was a passenger in a vehicle driven by
Melody A. Teats which was involved in an accident at or near Commerce Drive as previously
indicated.
4. At the aforesaid time and place a vehicle driven by Richard L. Kauffman of 508 S. Pitt
Street, Carlisle, Pennsylvania, was traveling generally northeast and around a curve when it came
onto the wrong side of the roadway, striking the vehicle driven by Melody A. Teats.
5. Pursuant to the Pennsylvania Rules of Civil Procedure, 2039, Petitioners herein desire
to settle the personal injury case involving the injuries suffered by Andrew C. Teats at the time of
the accident, which injuries included a concussion and laceration of the forehead for which
treatment was given at the Carlisle Hospital and follow up treatment performed by Dr. Frederick
Hecht.
6. There are no permanent injuries, other than minor scarring which is being revised, for
Andrew C. Teats and all medical bills have been paid by Shelby Mutual Insurance Company, which
was the insurance company for Melody A. Teats' vehicle.
7. At the time of this accident, the Kauffman vehicle was insured by Geico Insurance which
had a $300,000.00 single limit policy.
8. GEICO has indicated a willingness to settle with Andrew C. Teats and with Melody A.
Teats. Melody Teats was seriously injured in the accident, which injuries required surgery and
hospitalization at Carlisle Hospital, Hershey Medical Center and Forest Park Nursing home and for
which she continues to seek follow up treatment.
9. Your Petitioners are requesting the Court to approve the settlement of $10,000.00 to be
given to Andrew C. Teats in an account pursuant to Court Order, which account cannot be
distributed until such time as Andrew C. Teats is eighteen (18) years of age or by further Court
Order.
10. There will be no attorney fees deducted from the settlement amount.
WHEREFORE, your Petitioners pray that a hearing be held to approve the settlement.
Respectfully submitted,
Mancl~~Y & Spreha
John B~ yancke, Esq.
I.D. # 01~12
2233 North Front Street
Harrisburg, PA 17110
(717) 234-7051
Attorneys for Petitioners
05/14/2003 09:22
7177769459
NEWVILLEPRINT
PAGE 01
CHESTER M. TEATS
and MELODY ANN TEATS
H~ATHERMARIE TEATS
and JOEL COX
IN THE COURT OF COMMON PLEAS OF
CUMBERLAND COUNTY, PENNSYLVANIA
NO. 98-~9Q& CZVZL i998
IN CUSTODY
ORDER
AND NOW, this ~day of ~ 1998, upan agreemen~
of the parties, legal and physical custody of A~/drew
Christopher Teats, born October 3, 1993, is granted to the
maternal grandparents, Chester M. Teats and Melody Ann Teats
with visitation by the natural parents as the parties may
agree.
BY THE COURT,
TRUE COPY FROM RECORD
In Testimony whereof, I h 'r.. ~.~!~ set my hand
and the seal of said Court at Carlisle, P~,
_ ...... ......
~~. Proth notar~
05/14/2003 09:22 71777~9459
NEWVILLEPRINT
PAGE 02
'CHESTER M. TEATS
and MELODY ANN TEATS
HF2%THERF~M~IE TEATS
and JOEL COX
1. Chester M.
::
::
::
::
::
IN THE COURT OF COMMON PLEAS OF
CUMBERLAND COUNTY, PENNSYLVANIA
NO. 98- CIVIL 1998
IN CUSTODY
S?IPULA?ION
Teats and Melody Ann Teats
are the
maternal grandparents of Andrew Christopher Teats .bo~n
october 3, 1993, at Carlisle.
2. Heather Marie Teats is the natural mother of Andrew
Christopher Teats born October 3, 1993.
3. Joel Cox is the natural father.
4. Andrew Christopher Teats has lived with the
maternal grandparents since January 1995.
5. The parties agree that Chester M. Teats and Melody
Ann Teats have legal and physical custody of Andrew
Christopher Teats, born October 3, 1993, with visitation as
the parties may agree.
WITNESS:
Chester M. Teats
Melody An~f~e~ts
J~el Cox /
{SEAL)
(SEAL)
0~/1~/2003 09:22
71777694S9
· CHESTER M. TEATS
and MELODY ANN TEATS
HEATHER MARIE TEATS
and JOEL COX
NEWVILLEPRINT
PAGE 83
IN THE COURT OF COMMON PLEAS OF
CUMBERLAND COUNTY, PENNSYLVANIA
NO. 98- CIVIL 1998
IN CUSTODY
~OMPLAINT FOR CUSTODY
1. Plaintiffs are Chester M. Teats and Melody Ann
Teats reside at 123 Oak Flat Road, Newville, Cumberland
County, Pennsylvania, 17241.
2. Defendants are Heather Marie Teats who resides at
102B Lincoln Street, Carlisle, Pennsylvania, 17013, and Joel
Cox who resides at 446 North Pitt Street, Carlisle,
Pennsylvania, 17013.
3. Plaintiffs seek custody of Andrew Christopher
Teats, their grandson, born October 3, 1993.
4. Heather Marie Teats, age 19, is the natural mother.
Joel Cox, born September 16, 1974, is the natural
father.
The natural parents are not married.
The child, Andrew Christopher Teats, has resided
with the plaintiffs, the maternal grandparents, since
January 1995.
6. Plaintiff has not participated as a party or
witness, or in another capacity, in other litigation
concerning the custody for the child in this or another
court.
05/14/2003 09:22 7177769459 NEWVILLEPRINT PAGE 04
Plaintiff has no information of a custody
proceeding concerning the child pending in a court of this
Commonwealth.
Plaintiff does not know of a person not a party to
the proceedings who has physical custody of the child or
claims to have custody or visitation rights with respect to
the child.
7. The best interest and permanent we].fare of the
child will be served by granting the relief requested
because the plaintiffs have been the primary caretakers of
the child since January 1995.
8. Each parent whose parental rights to the child have
not terminated and the persons who have physical custody of
the child have been named as parties to this action.
WHEREFOKE, plaintiffs, the maternal grandparents
request the court to grant custody of Andrew Christopher
Teats to them.
~___~_F~nces H. Del Duca
Attorney for Plaintiffs
Dated: ~~, 1998
05714/2003 09:22
717776945B
NEWVZLLEPRZNT
PAGE 85
I verify that the statements made in this affidavit are
true and correct. I understand that false statements herein
are made subject to the penalties of 10 Pa.C.S. Sec. 4904
relating to unsworn falsification to authorities.
Dated: ~ ~/~
VERIFICATION
I hereby verify that the statements made in this document are true and correct. I understand
that false statements herein are made subject to the penalties of 18 Pa.C.S. Section 4904, relating to unswom
falsification to authorities.
Date /
Chester Teats
VERIFICATION
I hereby verify that the statements made in this document are true and correct. I understand
that false statements herein are made subject to the penalties of 18 Pa.C.S. Section 4904, relating to unswom
falsification to authorities.
Date
Melody Teats
IN RE: ANDREW C. TEATS, a minor,
by his legal custodians, MELODY A.
TEATS and CHESTER P. TEATS,
Petitioners
IN THE COURT OF COMMON PLEAS
CUMBERLAND COUNTY, PENNSYLVANIA
NO.:
AND NOW, this,~day of ~'~ I ,2003, upon consideration of the ~thin
Petition, it is hereby ORDERED and DECREED that a headng be held on the ~'~'~ay of
~,~,z~/~_. ,2003, at,~' ~ ~ o'clock~t .m. in Courtroom No.~'~ of the Cumberland
County Courthouse, Carlisle, Pennsylvania.
NOTICE OF SAID HEARING shall be given to Geico Insurance Company, Jaci Todd, Sr.
Claims Examiner, One Geico Boulevard, Fredericksburg, VA 22412-0001.
BY THE
Distribution:
Jaci Todd, Sr. Claims Examiner
Geico Insurance, One Geico Boulevard, Fredericksburg, VA 22412-0001
John B. Mancke, Esquire
2233 N. Front Street, Harrisburg, PA 17110
IN RE: ANDREW C. TEATS, a minor,
by his legal custodians, MELODY A.
TEATS and CHESTER P. TEATS,
Petitioners
AND NOW, this ~day of
IN THE COURT OF COMMON PLEAS
CUMBERLAND COUNTY, PENNSYLVANIA
NO.:
o%-z zl
,2003, the settlement of $10,000.00 is
hereby approved and the legal guardians, Melody A. Teats and Chester P. Teats, are authorized
to sign any and all releases to give approval of this settlement and it is further ordered that the sum
of $10,000.00 be deposited in the name Andrew C. Teats, and such amount shall be deposited in
one or more savings accounts in the name of the minor in a bank, building and loan association,
or savings and loan association, which deposits are insured by a federal government agency. It
is further provided and ordered that no withdrawal can be made from any account until the minor,
Andrew C. Teats, has attained his majodty (18 years of age) except as authorized by prior Order
of the Court. It is further ordered that proof of the deposit shall be promptly filed of record with the
Prothonotary.
IN RE: ANDREW TEATS, a minor,
by his legal custodians, MELODY A.
TEATS and CHESTER P. TEATS,
Petitioners
IN THE COURT OF COMMON PLEAS
CUMBERLAND COUNTY
PENNSYLVANIA
NO: 03-2321
PROOF OF DEPOSIT
TO THE PROTHONOTARY:
Please file the attached as proof of deposit in the above-captioned matter.
Respectfully submitted,
Mancke, Wagner & Spreha
John B~Es"'~q uire
I.D. #07212
2233 North Front Street
Harrisburg, PA 17110
(717) 234-7051
Attorneys for Petitioners
Al)AMS COUNIY
NATIONAL BANK
Toll-Free 888/334-ACNB (2262) ~ www.acnb.com
712AC81 ,~o0 80503~508D $i0000.00 D
9J.34549~
PHS FAX HO, P, 2
Print Key Output
5722SS1 VSR1M0 010525 ACNBANK
Page
08/11/03 09:24:18
Displ. ay Device ..... : NVMTEL2~
User . ......... : LINDSAIq3
-~005 Savings Account Inquiry Next display: 02 20-g700-1
09:22:58 Basic Account Data NVMTEL25
* ......... Account Name/Address .......... *
Account r[uraber: 9].34549 IBA A ANDREW C TEATS
Short name~ TEATS ANDREW C M CHESTER AND MELODY TEATS CUSTO
TIN: 190-74-6541 TIN Crt: C BR: 801 123 OAK FLAT ROAD
* ............ Balance Data ............ *
Cu~:ze~:~t: balance: 10,000.00
Avail balance: 10,000.00
Avail tomorrow: 10,000.00
Memo ~.~ala~ce: IQ,000.00
Hold amount;: 0
Che~:k CR balance: , O0
Interest dile: 1.30
~nt pd tb~ year:
In~ pd last yea'r: .00
NEWVILLB PA 1724%
* .......... Customer Activity ............ *
Stops/holds active:
Date last contact: 8.-06-03
Date last active: 8-O6-03
Date last deposit: 8-06-03
Amount last deposit: 10,000.00
Account Data ............ * * ....... Previo~s Statement Data ......... ·
Product ~ype; 4
St,~tement code/cycle: C / 20
Date opened: 8-05-03
processed thru: 8-10-03
F3.~EXjL F10=ACct inquiry charge
Last stmt date: 8-05-03
Last stmt balance: .00
Checks/deposits since: 0 / ~
Service charge type/plan: A 2
Combined stmt/nbr copies: N 0
Fl3=Inqn/iry window F15=Restart
This statement is true and correct to the best of n~y knowledge.
All deposits held at this bank are insured by FDIC. up to
Page two of this statement describes the authorization of this
account as to withdrawal restrictions.
i.
Dougla~-/R. Lind~ay
F~lrmers National Bank of Newville
a division of Adams County National Bank
A,o,,-l,-us 1./.OH 9:56 J FiBS HL/.,/ .~s PAX KO. 7:7+776+4855
Print Key Output
C)10525 ACNBANK
Page
08/11/03 09:24:47
Dis~0, a~ DevJ ce. ..... : NVMTEL25
gser . ......... : LINDSAYD
90 .014%, i
Display Memo/Tickler Item
Transact ion D~lbsystem
010009134549 TEATS MA00
MEMO01
Item ZD ........ :
~r~mary of J:icer .... :
Secondary of~:icer , . , :
Required ~'Lew .....
Expira~,io~% dar. e .... :
reddingr
2 l=Me~o, 2~Req~ired view
4=Required view tickler
Miscellaneous memo
3=Tickler
1
D=NO, 1=Yes
2 signatures required COURT 0RD~R ATTACHED TO
SIGNATURE CARD. NO WITHDRAWAL CAN BE MADE UNDER
o/0o/oo
18
F3=Exit. F1 :l.=Additior~al data