HomeMy WebLinkAbout99-03114
DOROTHY SMYSER, guardian for IN THE COURT OF COMMON PLEAS OF
CRISTINA SMYSER, CUMBERLAND COUNTY, PENNSYLVANIA
Plaintiff
VS. ARM, j7 - 311
JEREMY ZINN, CIVIL ACTION - LAW
Defendant
ORDER OF COURT
AND NOW, this z f` , day of 1999, based
upon the Plaintiff's Petition for Court approval of minor's
settlement, it is hereby order that the Plaintiffs' Petition is
approved and the settlement shall be paid for the benefit of the
minor to the guardian and attorney's fees shall be paid in the
amount of .258.
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DOROTHY SMYSER, guardian for IN THE COURT OF COMMON PLEAS OF
CRISTINA SMYSER, CUMBERLAND COUNTY, PENNSYLVANIA
Plaintiff
VB. MISC. NO.
JEREMY ZINN, CIVIL ACTION - LAW
Defendant
ORDER OF COURT
AND NOW, this , day of 1999, based
upon the Plaintiff's Petition for Court approval of minor's
settlement, a hearing shall be held on the day of _
1999, at .m., in Courtroom # at the
Cumberland County Courthouse, Carlisle, Pennsylvania.
DOROTHY SMYSER, guardian for IN THE COURT OF COMMON PLEAS OF
CRISTINA SMYSER, CUMBERLAND COUNTY, PENNSYLVANIA
Plaintiff
VS. MISC. NO.
JEREMY ZINN, CIVIL ACTION - LAW
Defendant
AND NOW, comes the Plaintiffs, Dorothy Smyser, guardian for
Cristina Smyser, by and through their attorney, Patrick F. Lauer,
Jr., and respectfully avers the following:
1. The Plaintiffs are Cristina Smyser who is sixteen years of age
and lives with her mother, Dorothy Smyser at 1815 Walnut Bottom ?.`
i
Road, Newville, Cumberland County, Pennsylvania 17241.
2. The Defendant is Jeremy Zinn who is seventeen years of age and
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currently resides at 411 Steelstown Road, Newville, Cumberland
County, Pennsylvania 17241.
3. The Defendant has insurance through American States Insurance
Company which is located at 333 Baldwin Road, Post Office Box
44446, Pittsburgh, Pennsylvania 1.5205-0846.
4. The claim number assigned by the Defendant's insurance company
is 5330026633BRS and the Claims Representative is Bonnie R. Sailor.
5. The date of this accident was April 29, 1998.
6. The Plaintiff was a passenger in the vehicle driven by
Defendant, Jeremy Zinn on East bound 944 in Cumberland County,
Pennsylvania on April 29, 1998, and she suffered minor injures
which included, but not limited too a posterior scalp laceration
m.'..ro4?r .! S
II which required five staples, abrasions to her left posterior
shoulder region and to her left little finger region.
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7. The Plaintiff followed up with treatment at the Carlisle.
Hospital through her family physician, Dr. George Branscum at the
Belvedere Medical Center.
1 6. The following is a list of medical expenses incurred in this
i
accident. Carlisle Hospital, $1,459.00; Carlisle Community
Ambulance, $358.00; Belvedere Medical Center, $32.00; Total
medical expenses incurred are $1,849.00.
I 9. There was a cat scan of the bria
n which indicated normal,
there was a radiograph lateral cervical spine which indicated it
was normal, and there was no fracture of the left hand.
10. All medical expenses have been paid to date.
11. The Defendant's insurance company has offered $1,500.00 to
settle this claim.
12. Plaintiffs have been informed that they could receive more or'
less if this case was litigated.
13. Plaintiff's attorney requests compensation in the amount of
258 of said settlement.
14. Plaintiffs requests court approval of the $1,500.00 settlement
against the Defendant.
15. Plaintiffs requests that the following be distributed
accordingly; $375.00 to Patrick F. Lauer, Jr., Esquire and the
l balance of $1,125.00 to Cristina Smyser.
? 16. Plaintiffs request that the said sums of money not be placed
II in a trust account because of the sums are not significant and
Plaintiff is in need of the funds.
WHEREFORE, the Plaintiffs respectfully request that the
$1,500.00 settlement be paid for the benefit of the minor, Cristina
Smyser to the guardian of the minor, Dorothy Smyser and that the
Court approves attorney's fees be paid to Attorney Patrick F Lauer,
Jr. in the amount of 258.
Date: S *
Respectfully submitted,
Patrick F. Lauer, Jr., Es re
2108 Market Street, Azte Building
Camp Hill, Pennsylvania 17011-4706
ID# 46430 Tel.. (717) 763-1800
DOROTHY SMYSER, guardian for IN THE COURT OF COMMON PLEAS OF
CRISTINA SMYSER, CUMBERLAND COUNTY, PENNSYLVANIA
Plaintiff
VS. MISC. NO.
JEREMY ZINN, CIVIL ACTION - LAW
Defendant ,
VERIFICATION
We, Dorothy Smyser, guardian for Cristina Smyser, state that
we are the Plaintiffs in the above-captioned case and that the
facts set forth in the above Motion are true and correct to the
best of our knowledge, information, and belief. We realize that
false statements herein are subject to the penalties for unsworn
falsification to authorities under 18 Pa. C.S. S 4904.
Q ?
D othy er
L-_..
Cristina s s r
Date: ?"//- ?
`,/
DOROTHY SMYSER, guardian for
CRISTINA SMYSER,
Plaintiff
Vs.
JEREMY ZINN,
Defendant
IN THE COURT OF COMMON PLEAS OF
CUMBERLAND COUNTY, PENNSYLVANIA
MISC. NO.
CIVIL ACTION - LAW
ATTORNEY VERIFICATION
The undersigned attorney hereby verifies and states that:
1. Fie is the attorney for the Plaintiffs, Dorothy Smyser and
Cristina Smyser;
2. He is authorized to make this verification on behalf of the
clients;
3. The facts set forth in the foregoing Petition are known to him
and not necessarily to his clients;
4. This verification is intended to expedite the litigation;
S. The facts set forth in the foregoing Petition are true and
correct to the best of his knowledge, information, and belief; and
6. He is aware that false statements herein are made subject to
the penalties of 18 Pa. C.S.A. S 4904, relating to unsworn
falsification to authorities.
Respectfully submitted,
Date:
Patrick F. Lauer, Jr., Es u re
2108 Market Street, Aztec uildin
Camp Hill, Pennsylvania 17011-470
ID# 46430 Tel. (717) 763-1800
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PATRICK F. LAUER, 1R.
Attcrney at Law
2108 Madct Street
Antic Building
Camp Hill. PA 17,011
171717ni ISM
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