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HomeMy WebLinkAbout01-05355PAUL TIMMONS and SALLY TIMMONS, as parents and natural guardians of PAUL BENJAMIN TIMMONS, a minor, 808 Wellington Drive Carlisle, PA 17013 Plaintiffs v. ALAN S. CLEELAND and DIANE C. CLEELAND, 827 Wellington Drive Carlisle, PA 17013 Defendant. 1N THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA NO.: Sit - s3.~ ~c>~ L~t=lL1r'1 CIVIL ACTION LAW PRAECIPE FOR WRIT OF SUMMONS TO THE PROTHONOTARY: Please issue a Writ of Summons to Defendants, Alan S. Cleeland and Diane C. Cleeland in the above-captioned matter. HAFER,LLP Dated: BY: 305 N. Frontlet, PO Box 999 Harrisburg, PA 17108 ID No. 71117 (717)237-7153 WRIT OF SUMMONS To: Alan S. Cleeland and Diane C. Cleeland, Defendants You are notified that the above-named Plaintiff~h~ay/s commenced an action ainst you. -~~LtQ-d (J Prothonotary ty~ Dated: ~~ c,~~="Z~j~ \ L/// rZ-- o ~ Ci~y,Y~i~~<~` ~ Deputy N~ ,~~ ~~ ~~ -.,~^ vJ c c C~ ~-, ~ -- ~, ~~ ~ ~~ z w _~;~, -- ~~ ~~ ~ - L~~J 3.,.i ~~ ', - r: .~, Y _.*. ~ ~~. Z ~ y C t~: , O• rs ~ SEC 1 d 200 ~ PAUL TIMMONS and SALLY TIMMONS, as parents and natural guardians of PAUL BENJAMIN TIMMONS, a minor, 808 Wellington Drive Carlisle, PA 17013 Plaintiffs IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA NO.: 01-5355 v. ALAN S. CLEELAND and DIANE C. CLEELAND, 827 Wellington Drive Carlisle, PA 17013 Defendants CIVIL ACTION LAW ORDER AND NOW, this _~~~ay of LC , 2001, after consideration of the Petition to Approval Compromise Settlement ~ it is hereby ordered and decreed that: a. The Petition is granted; b. Settlement between Plaintiffs and Defendants, by and through their Insurance Company, in the amount of $ 3,000.00 is approved; c. The settlement funds shall be used to pay for the dental bills of the minor, Paul Benjamin Timmons, until he reaches the age of majority. Any excess funds shall not be withdrawn until the minor obtains majority, except as authorized by a prior Order of the Court; d. Proof of the deposit of settlement funds shall be promptly filed of record; and e. Plaintiffs are authorized and duetted to execute a Full and Final Release. Date: Dec. f 7~ 260 ~ C~~° ,z-~~ BY THE COURT: xf r.p llr,_i "~Q'%. ',. ~~ Michele J. Thorp, Esquire Thomas, Thomas & Hafer, LLP P.O. Box 999 305 N. Front Street Harrisburg, PA 17108-0999 (717)237-7153 PAUL TIMMONS and SALLY TIMMONS, : IN THE COURT OF COMMON PLEAS as parents and natural guardians of :CUMBERLAND COUNTY, PENNSYLVANIA PAUL BENJAMIN TIMMONS, a minor, 808 Wellington Drive Carlisle, PA 17013 Plaintiffs NO.: 01-5335 v. CIVIL ACTION LAW ALAN S. CLEELAND and DIANE C. CLEEI~AND, 827 Wellington Drive Carlisle, PA 17013 Defendants PETITION TO APPROVE MINOR'S COMPROMISE SETTLEMENT And now, comes Plaintiffs, Paul Timmons and Sally Timmons, as parents and guardians of Paul Benjamin Timmons, and file this Petition to Approve Minor's Compromise Settlement and auer the following in support thereof: 1. Plaintiffs, Paul and Sally Timmons ("Plaintiffs") are the parents and natural guardians of Minor Paul Benjamin Timmons ("Minor"). 2. Plaintiffs and Minor reside at 808 Wellington Drive, Carlisle, Cumberland County, Pennsylvania 17013. 3. Minor was born on December 14, 1988, and was 7 years old on the date of the accident described herein. 4. Defendants, Alan and Diane Cleeland ("Defendants") reside at 827 Wellington Drive, Carlisle, Cumberland County, Pennsylvania 17013 5. This Petition is filed as a result of an accident which occurred on or about October 26, 1996, on Wellington Drive in Carlisle, Cumberland County, Pennsylvania. 6. By way of summary, the accident involved the Minor attempting to ride his scooter over a ramp erected by Defendants' minor son. 7. As a result of the aforesaid accident, Minor suffered oblique fractures to the maxillary and central incisors, lip lacerations and facial abrasions, removal of a lateral incisor and bonding of the central incisors. Copies of Minor's treatment records with William K. Jenkins, DDS, aze attached hereto, incorporated herein by reference and mazked as Exhibit "A." 8. Minor's dental bills were paid through his parents' dental insurance carrier, with an outstanding balance of $192.00 which was paid by Defendants insurance carrier. 9. Subsequent tests show that the vitality of the Minor's teeth is good and the long term outlook for the Minor is very promising. 10. However, there is the possibility of two root canals and two crowns for the Minor. There is also a possibility of implants being needed at a future date. The cost projection for the same is approximately $3,070.00. 11. At the time of the accident, Defendants were insured by a home owners policy issued by General Accident Insurance Company. Said policy was policy number 4893945. 12. Since the time of issuance of the policy, General Accident Insurance Company became CGU Insurance Company and is currently OneBeacon Insurance Group ("OneBeacon"). 13. On behalf of Defendants, OneBeacon has offered to compromise this claim for the sum of Three Thousand Dollars ($3,000.00). 14. Liability is disputed in this matter. I5. Plaintiffs believe that this offer is fair and in the best interests of the Minor. 16. Plaintiffs will use the settlement funds to pay for the minor's dental care as a result of injury sustained in the accident on October 26, 1996. Any excess settlement funds will be distributed to the minor when he obtains the age of majority. 17. Therefore, Plaintiffs request that this Honorable Court approve the proposed settlement. 18. Additionally, Defendants request that Plaintffs be authorized and directed to execute a full and final general release in the form which is attached hereto, incorporated herein by reference and marked as Exhibit "B." 19. Defendants also request Plaintiffs be authorized and directed to file a discontinuance of record with the Prothonotary of the Court of Common Pleas, Cumberland County. Wherefore, Plaintiffs, Paul and Sally Timmons as parents and natural guardians of Minor Paul Benjamin Timmons, pray this Honorable Court enter an order compromising this action approving the proposed settlement; authorizing and directing Plaintiffs to file a full and final release; and authorizing and directing Plaintiffs to file a Discontinuance of record. Date: V o 0 Date: o a 6 Date: ~ 2. O 1 PAUL TIMMO S /~ ~----° " - crc_.-i SALLY TI S EXHIBIT A ;~ ®VJ3~t4b~ilitY 1.T~o ~~' •++nO+® ~oa6~7o " 55 S~u~h ~®91e~e ~t ~ ~a9is~e, P.~ 17®13 G~~D 2430339 November 6, 1997 William P, Douglas, Esq. Douglas, pouglas & Douglas Attorneys at Law 27 id. High Street Carlisle, PA 17013 REs Paul Benjamin Timmons Dear Atta."Douglass On Saturday morning, October 26th, 1997. we saw Paul (Ben) Timmons for dental trauma to the maxillary arch and lip area. 'Ben was using his scooter and hit an obstruction left on the road by.a neighbor (some sort of object belonging to a skate"board ramp set up) and was thrown forward onto his face. He suffered severe"oblique"fractures to the maxillary central incisors (8"and 9) as well as lip lacerations and facial abrasions. The maxillary 'right pedo lateral was also ih need of removal. It had been dislodged. by the blow. Units 8 and 9 were class I in mobility with wide open root apexes as expected from a child of "8 years of age, Apre-operative X-ray is enclosed. The maxillary central incisors were bonded and:tbe pedo lateral extracted. A conventiohal acid etch bonded resin system was used. Pdo`direct pulp exposures were evident although #9 (left central incisor) was very close .to the pulp horn. Lacerations and abrasions were swabbed and cleansed and iee to be applied post operatively. Prognosis at-this point rated good-with reservations. A follow up visit was scheduled in 3 daps to .access his stasis. On October 29, we tested the vitality of the teeth involved and received no response: This was done through ice testing and electronic stimulation. There was no colflr shift indicating loss of vitality and the mobility was vastly improved. Due to the concern of. the lack of response we scheduled Ben for a follow up in approximately 6 wks, A telephone conaersation with an endodontic office regarding current protocol was placed and they concurred with our"findings that follow up was necessary. At the 6 week follow up, December 5, we repeated the previous test with a good response from both units. An X-ray was taken .and a Copp enclosed. Due to the nature of the response"and lack of eolore shift we felt that Ben could be monitored at his routine .visits as part of his follow up but this does not mean he is completely 'out .of the woods`. ps5.j" '~~IV1 CJ~12\~ - Same Gr5 LV P.~` ~ e ~~ ~p9''~.~ n. ^'kk ... DEG 0 ~ 14'7 Fi~G ~hkiYV~"=-° Page 2 The long term outlook for Ben is very promising but not predictable. Injuries of this nature warrant some monitoring and there will be some follow up care needed. At minimum, ,he will require re-treatment of the resin bond- ing along with occzsional sitalitp testing and radiographic review. When? Ah least once if not twice before he reaches his-18th birthday for the bonding The periodic testing perhaps every 12 to 18 months. This periodic review will allow us to check for the need for any ®ndodontic therapy. Nature in its re pair process can go haywire. This means as time goes by things will either remain stable or things can begin to-self destruct.. Instead of possibly abcessing the teeth can actually begin a destruction process from inside/out, called resorption. If this occurs, he may have to resort to complicated endodontic therapy or lose-the teeth. If lose occurs,- he will enter a more significant phase of dentistry. .Examples of these procedures would include, crown and bridge, implants or .removable prosthetics. Should the worst occur as in lose and the surrounding dentition remain intact, we would recommend single unit implants. This is of .course, providing the remaining teeth continue in their .present state, free of .any restorative treatment.. Reducing or cutting down natural structure is quite unnecessary in this case which would elaminate a bridge.. Its possible to retreat. and touch up the bonding numerous times but he has his whole life ahead and it would be unrealistic not to expect the possibility of individual crowns at a later date in his adulthood. (See. the attached page for cost estimates gathered at todays figures for the various treatment modalities mentioned in this letter.) Should you have any questions, please call our office and Betsy can help you. Sincerely, William R. Jenkins; D.D.S. Enclosures bh/WRJ ,~~FF~~ DEC 0~ 1437 g;~G C;Lt~e~J~a ~'J~~9Pd~ ~Tt~S4"S SYA~~i~s~B~~ C~~R'~~-O~,~aF awe ~f~Dtz~ss 6~Gi£6X'ON~: ABC Benef; Dept. ( ID~~TBS~"S PSG°YRSAT~~9~Y gSY8~~7g P..O. Box 48 ~~NTdSa'S SYA~F~a',~S~tF 9F AC°666,~6 ~~RV9C~9 ~ Fordsmth, Arkansas 72902 1. @/41@~ ! WAYS 8."l$Lfi41009Y1D Po BYPLOTfl$ 9. 88d 4. Pp418pP flI9iNDAT¢ {. IP GULL 41Y1 SYYDeNY p 0860 'BPY{P{I 6tltLD iDYYBO D-' I ,yO. I~,gqAf 9,,gqg455 LCMLOL S~'aiYl Ben,jamin Timm®n3' , ~ ~ t R , X1. IL ~U4 ! 66 9Yi I LwYY York, PA 1 gwtlg fYFOR19A 1/1¢WHO TN POLLOWIroO TWYw4MlNT PLAq: 3 gpTXONIiH WYLY48g OP APoY 1 d/6x41 ~ TO 8klY CLgIW. I N¢W¢YY gUTNONIZ¢ PgTHBroT YIY¢RLY TO TM¢ Y¢LOW •NAMBY YWroTIpT OR Ti ONOYP INYYWgnC[ W¢N¢PITD' 04M¢PWIH¢ 9gTgYLH TO D{l. ~X G- 9~-. 1-6-97 IBY 80 D4$IWY:' Y P p9pY 1B/ YIMBYI 90.78 SIONID }IppY X80 PH190p1 Ogre D0, 0lWg a ® / W o ~evY6i Dr DacurnneuvL i iq "P9 rzL 'If i89. 8pt8l OWL8P p[9ClfpnOW AY004111 1 WW ~m 9\a ~enkg}7s~ S11 1.8=®ad. pLMa8L 0N t eePt - ' '' - ----'•------••--•--- -------•-- • '~~18. YAILIYY 4D81880 ' y ' ----'------- ------'---------------•-------- {8.04p[slN[pT II[PYLi YL AuTa MuPepn J ~ ..': J $$- S~util_ C®llege S4reet -' ae. DTYaW ACnu{Nn $L? t' 5~_____________ia__•_•._•__.__..__.... ~, 6LTT Y4ATd. .IP ______________.___•__.___. __.____._.___.. lB~App ANY 1flW111D$D -CDtl¢¢g9 pT ~ ararlisl~, PennsyTlvania .37013 v AN09p8HP6A@1 19. O8p919T ~OOC. 88C. O{ 4.LY. I8. 88p911P LiLIpD¢ WO. 80. D[0419Y PMOpH HO. ~~ ' i9.li PYOe4p8918. 19 YplO INITIAL - ~ I/ p0. w8g80N IOl'W8PYC8YeWil 10. 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W 1101! ®C7 V ~' ~' f }'{~~ ~i~-.H.E~gy,~. a\69039 ..v 9USi ,i_I fig;:res listed are_on a 'per tooth' basis. _) rP~reatment of the-resin bonding: $2?+5.00 ~) endodontic therapy: -$350-375 3) porcelain to gold alloy crown: $580.00 4) Implant structure: $1400.00 (includes consul and diagnostic tools) _ Implant abutment and single crown $1200.00 This procedure would involve an oral surgeon or a periodontist with the general dentist. 5} Eaam, A-rap, repeat vitality testing: $48-b5 (This is not 'per tooth') *-Nnese figures are based on todays fee schedules. During the course of some of these treatments there maybe a slight change in procedufe or cost at that time so these can be. used as a good baseline of possible ezpenses in the .future. ~~..- r~`~v'~ DEC D ~ 1~"~ hiBG C1-kr~~`'S ~.. EXHIBIT B FULL AND FINAL RELEASE For and in consideration of payment to PAUL TIMMONS and SALLY TIMMONS as parents and natural guardians of PAUL BENJAMIN TIMMONS of the sum of Three Thousand Hundred 00/ 100 Dollars ($3,000.00), We, PAUL TIMMONS and SALLY TIMMONS (hereinafter sometimes referred to as "Releasors"), do hereby release and forever discharge ALAN S. CLEELAND, DIANE C. CLEELAND, GENERAL ACCIDENT INSURANCE COMPANY, CGU INSURANCE COMPANY AND ONEBEACON INSURANCE GROUP, (hereinafter sometimes referred to collectively as "Releasees") their insurers, employees, agents, and any and all other persons and firms, of and from any and all actions, causes of action, claims, demands, damages, costs, loss of services, expenses, compensation, consequential damage, or any other thing whatsoever including claims not only for her personal injuries and damages on account of or in any way growing out of, any and all known and unknown personal injuries, debts, and property damage resulting or to result from in incident that occurred on or about October 26, 1996, in Carlisle, Pennsylvania, Cumberland County, Pennsylvania. We hereby acknowledge and assume all risk, chance, or hazard that the said injuries or damages may be or become permanent, progressive, greater, or more extensive than is now known, anticipated, or expected. No promise or inducement which is not herein expressed has been made to me and in executing this Release, We do not rely upon any statement or representation made by any person, firm, or corporation, hereby released or any agent, physician, doctor, or other person representing them or any of them concerning the nature, extent, or duration of said damages or losses, or the legal liability therefore. We understand that this settlement is the compromise of a disputed claim and that the payment is not to be construed as an admission of liability on the part of the persons, firms, and/or corporations hereby released by whom liability is expressly denied. We further certify, state, acknowledge, warrant, and declare that each and every person, attorney, carrier, entity or association which claims to have a lien on the proceeds of this settlement arising out of this incident, lawsuit, or litigation, is aware of this Release and its terms and We understand that said released parties hereunder are relying expressly upon this unconditional express warranty in making payment hereunder. The Releasors accept responsibility for satisfying any liens that have been asserted against this recovery by any worker's compensation insurance carrier, healthcare provider or insurer, and hereby discharge the Releasees from any such responsibility. In further consideration of the above payment, We for ourselves, our heirs, next of kin, executors, administrators, successors, or assigns, covenant and -2- agree to indemnify and hold harmless ALAN S. CLEELAND, DIANE C. CLEELAND, GENERAL ACCIDENT INSURANCE COMPANY, CGU INSURANCE COMPANY AND ONEBEACON INSURANCE GROUP, their agents, employees, insurance cazriers, and attorneys, from all claims, demands, and suits for damages, costs, loss of services, expenses, or compensation which may azise in the future on account of or in any way growing out of the injuries or damages we sustained in this incident. This Release contains the entire agreement between the parties hereto and the terms of this Release aze contractual and not a mere recital. We certify that we are over eighteen (18) years of age and we further state that we have carefully read the foregoing Release and we know the contents thereof and we have signed the same as our free act and intending to be legally bound thereby. IN WITNESS WHEREOF, we have hereunto set our hands and seal this day of , 2001. WITNESSETH: PAUL TIMMONS SALLY TIMMONS -3- COMMONWEALTH OF PENNSYLVANIA COUNTY OF On this day of 2001, before me personally appeared PAUL TIMMONS AND SALLY TIMMONS, known to me to be the person whose name is subscribed to the within Release, and acknowledged that he executed the same for the purposes therein contained. IN WITNESS WHEREOF, I have hereunto set my hand and official seal. NOTARY PUBLIC My Commission Expires: -4- VERIFICATION I, Paul Timmons, Parent and Natural Guardian of Paul Benjamin Timmons, hereby state that the statements made in the foregoing Petition to Approve Compromise Settlement are true and correct to the best of my knowledge, information and belief. The undersigned understands that the statements therein are made subject to the penalties of 18 Pa.C.S. §4904 relating to unswom falsification to authorities. Paul Timmons, as parent and natural guardian of Paul Benjamin Timmons VERIFICATION I, Sally Timmons, Parent and Natural Guardian of Paul Benjamin Timmons, hereby state that the statements made in the foregoing Petition to Approve Compromise Settlement aze true and correct to the best of my knowledge, information and belief. The undersigned understands that the statements therein are made subject to the penalties of 18 Pa.C.S. §4904 relating to unsworn falsification to authorifies. Sally Ti ns; pazent and natural guardian of Paul Benjamin Timmons ~°s ... CERTIFICATE OF SERVICE I do hereby certify that on this day I served a true and correct copy of the foregoing by first class mail, postage prepaid, addressed to the following: Paul & Sally Timmons 808 Wellington Drive Carlisle, PA 17013 Alan and Diane Cleeland 827 Wellington Drive Carlisle, PA 17013 Thomas, Thomas & Hafer, LLP Date: ) Z-/ r5/~ I P.O. Box 999 Harrisburg, PA 17108-0999 Michele J. Thorp, Esquire Thomas, Thomas & Hafer, LLP P.O. Box 999 305 N. Front Street Harrisburg, PA 17108-0999 (717)237-7153 PAUL TIMMONS and SALLY TIMMONS, : 1N THE COURT OF COMMON PLEAS as parents and natural guardians of :CUMBERLAND COUNTY, PENNSYLVANIA PAUL $ENJAMIN TIMMONS, a minor, 808 Welling on Drive Cazlisle, PA 17013 Plaintiffs N0.:01-3333 S3S.5' v. CIViL AC i ION LAW ALAN S. CLEELAND and DIANE C. CLEELAND, 827 Wellington Drive Carlisle, PA 17013 Defendants PRAEClPE't'y DY~~'CDi~7'~1VU~ _ . .. - - TO THE PROTHONOTARY: Please mark the above-captioned case as settled, discontinued and ended. Respectfully submitted, & ]Eaafer, LLP by 1~iQcliei~J. Thd'rp, Esqu' 1.D. No.: 71117 305 N. iaront Stree l'.O. Bux 999 Date: 10/~.Z/[~'7i. 1~u~risbirrg,PA 17108-0999