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HomeMy WebLinkAbout99-06429 ' ? tom E 1 > ell 5 rx Y >. f4 i.d• 1 1?• . t 3a. :+. ._ Zr t? r C - L [ , ? tJ S i ? ? :A.kY ? li ,A ? "T l A 3,- 5C x t } l F l r •ir4} 4 ?{ I 4 J 3 1 }i a+ *l, 00 GRAHAM & MAUER, P.C. BY: LISA J. MAUER, ESQUIRE Attorney I.D. 65426 The Commons at Valley Forge Suite 22, P.O. Box 987 Valley Forge, Pennsylvania 19482 610/933-3333 NICHOLE WALLAK, a minor, by ANGELA BITNER and ROBERT WALLAK parents and custodians Plaintiff v. CHRISTIE PETONYAK and DEBRAPETONYAK Defendants In Re: NICHOLE WALLAK, a minor Attorney for Plaintiff COURT OF COMMON PLEAS CUMBERLAND COUNTY No.: The bulk of counsel's time in this case was spent on overcoming the limited tort threshold on behalf of the client, Nicholc Wallak, minor. (See the State Farm automobile insurance declaration sheet of Angie Bitner, Nichole Wallak's mother, attached hereto.) • Counsel visited and consulted with Nichole's parents in tlicir home. • In addition to having numerous phone calls with Nichole and her mother regarding the medical treatment, counsel reviewed the medical records of all providers. • Counsel corresponded with all medical providers and obtained treatment records. • Counsel arranged for Nichole to have photographs taken of her permanent facial scar. • Counsel conferred with the office of Nichole's treating orthodontist, Richard Cantor, DMD, in order to understand what effect, if any, this motor vehicle accident had on her pre-accident orthodontic work. • Counsel had numerous phone consultations with treating dentist, Gary Davis, DDS, for the purpose of understanding the nature of Nicholc's injury, treatment and prognosis, as well as establishing a permanent dental injury and securing an expert report. Said report written by Dr. Davis is also attached hereto. • Counsel provided all pertinent treatment records to Dr. Davis to facilitate his preparation of said expert report. • Counsel interviewed damages witnesses. • Counsel prepared the equivalent of a trial package of exhibits and a demand package which was submitted to Allstate Insurance Company. A policy limit offer was obtained. • Reviewed and modified Allstate Relcase preserve any potential medical malpractice, health insurance or underinsured motorist claims for client. • Counsel obtained State Farm's consent to settle this claim with the insurer of the tortfeasor, Allstate, in order to protect any future underinsured motorist claim. • Requested assignment of a State Farm underinsured motorist adjuster and communicated with said adjuster regarding Nicholc's injuries, treatment and prognosis in order for State Farm to set their underinsured motorist reserve. • Counsel reviewed the Divorce and Custody Agreement between Nichole's natural parents and advised both parents of their rights and responsibilities under said Agreement as they relate to this settlement. • Counsel obtained the consent of both natural parents to this settlement. • Counsel prepared minor's compromise and made a court appearance related thereto. Respectfully submitted, GRAHAM & MAUER, P.C. -?? (* By: 'CA Lis J. M041r, Esquire Attorney fdr Plaintiff Date: November 18, 1999 0.,, ,..4 u u N , 51 E 19 01-20-1999 UECLAHATIUNS NAGS NAMEDINSURED ONE STATE FARM DR CONCORDVILLE PA 19339 gg 38-2627-552C 340NKERRSVILLE RDMARLIN CARLISLE PA 17013-9438 IuJIhullLnudlullJ,LuluInlLLduL,Illu,IluJ POLICY NUMBER 721 5147-AO5-38B POLICYPERIODJAN 05 19990JUL 05 1999 , , , , DO NOT PAY PREMIUMS SHOWN ON THIS PAGE. SEPARATE STATEMENT ENCLOSED IF AMOUNT DUE. DESCRIBED YEAR MAKE MODEL BODY STYLE VEHICLE IDENTIFICATION NUMBER CLASS VEHICLE 1 1987 MERCURY COUGAR 2DR 1MEBR6030HH699619 1830301 2 1983 FORD F150 PICKUP 1FTDF15Y6DNA27359 183HA01 3 1980 FORD BRONCO SPORT MG U156LGK1802 1A3H101 gCgOE PREMIUM-COVERAGE NNAME?-LIMITS OF LIABILITY V MIT E SEE REVERSE SIDE FOR IMPORTANT MESSAGE A BODILY INJURY/PROPERTY DAMAGE LIABILITY 1- $76.12 LIMITS OF LIABILITY-COVERAGE A-BODILY INJURY 2- 593.18 EACH PERSON, EACH ACCIDENT 3- $71.28 50,000 100,000 C2 2- U3- 1- 2- W3- 1- 2- 3- F 1- 2- Z1 1- 2- 3- LIMITS OF LIABILITY-COVERAGE A-PROPERTY DAMAGE EACH ACCIDENT 50,000 MEDICAL PAYMENTS $17.06 LIMIT OF LIABILITY-COVERAGE C2 S20.92 EACH PERSON $15.99 10,000 UNINSURED MOTOR VEHICLE $6.27 LIMITS OF LIABILITY-COVERAGE U $6.27 EACH PERSON, 56.27 50,000 UNDERINSURED MOTOR VEHICLE S20.16 LIMITS OF LIABILITY-COVERAGE W $20.16 EACH PERSON, 520.16 50,000 FUNERAL BENEFITS S.48 LIMIT OF LIABILITY-COVERAGE F S.48 EACH PERSON LOSS4OF INCOME 1,500 S4.0?- S4.99 53.79 $388.01 TOTAL PREMIUM FOR POLICY PERIOD JAN 05 VEHICLE 1 $124.11 VEHICLE 2 $146.00 VEHICLE 3 $388.01 TOTAL CURRENT 6 MONTH PREMIUM FOR JAN VEHICLE 1 S124.11 VEHICLE 2 S146.00 VEHICLE 3 ----------------------------------------------- EXCEPTIONS AND ENDORSEMENTS CAR 1.2,3 THIS POLICY PROVIDES LIMITED TORT OPTION. EACH ACCIDENT 100,000 EACH ACCIDENT 100,000 1999 TO JUL 05 1999 $117.90 05 1999 TO $117.90 THIS IS YOUR DECLARATIONS PAGE. PLEASE ATTACH IT TO YOUR AUTO POLICY BOOKLET. JOHN Z A M P E L L I J R JUL 05 1999 2627-382 OUR POLICY CONSISTS OF THIS PAGE, ANY ENDORSEMENTS, AND THE POLICY BOOKLET, FORM 9838.7 PLEASE KEEP TOGETHER REPLACED POLICY 7215147-38 NEW POLICY FORM 155-4976 PA4 MUTL VOL RocOFvod SOP-01-99 14:30 from 7175327679 + 16109830570 Pago 1 BQP-01-99 0214E PM GARY DAVIS DDB 7176327679 P.01 S. Davis, D.D.S. 470 Ust Orange 8irest , 9hippensburg, PA 17257 a (717) 6324519 Deer Lisa Mauer, This letter is a foilow-up to our conversation on the phone concerning Nichole Wallak. As you requested, I will use "lay" language whenever possible to explain medical terminology. Nichole was a passenger in a motor vehicle accident, which occurred approximately at 4.30 p.m. on February S. 1999. She was taken to Carlisle hospital where she was diagnosed with a Jew contusion and a lower tooth evuleton which means her tooth came out of Its socket. The triage nurse put the tooth In dental fluid and the hospital contacted Dr. Hecht. Dr. Hecht examined the patient in the hospital and had the patient go directly to his office for to-Implantation of the avulsed tooth. Dr. Hecht diagnosed that the lower right central incisor was totally avulsed (out of socket), the lower left central Incisor was partially avulsed or partially out of its socket, and a 1.5 om laceration (cut) of the lower lip, Dr. Hecht re•hnpitnted the lower right central Incisor, repositioned the left central Incisor and "bonded" them Into place by placing it wire sorost her front six teeth. The total time that the lower right incisor was out of Its "socket" was approximately three hours. Dr. Hecht prescribed the antibiotic PenVK and the pain medication Motdn (800 mg) and saw Nichole on 2/10/99, 2112/99 and 2116199 for follow up visits. On February 16th, Dr. Hecht called me and advised me that as a result of the accident, both lower incisors (824 do #25) needed root cantle as soon as possible. Lower incisors have a nerve and a blood vessel which enters at the and of its roots in an opening we call the apex. The space In the middle of the root where the nerve and blood vessel are located Is called the root canal. During the accident, the nerve and blood vessel going into her lower two front tooth were severed. Like any tissue or organ in your body, the tissue in the space (root canal) in the teeth began to die without its blood supply. As this tissue dies and breaks down, it can cause pain, swelling and an abscess. A root canal procedure removes the Infected nerve, blood vessel and other infected tissue from the root canal space and then fills the space with a special type of filling (Sulfa perch) to seal up the canal. I started the root canal procedure at my office on 2117/99. When f called the patient's mother on 2116/99, she origiruliy declined the root canal treatment however after I Informed hat of the poor prognosis of the two lower tooth without root canals, she made the appointment. The root canal on the lower left incisor was completed on 4113/99 and the root canal on the lower right incisor was completed on 4120199. Nichole was seen several times between February 16th and April 20th by Dr. Hecht for follow-up with the wire splint, general monitoring of the teeth and fot swelling on the floor of the mouth on April 15, 1999. Received Sep-01-99 14:30 from 7175327879 4 18109830570 Pape 2 SEP-01-99 02143 PM GARY DAVIS DDB 7176327679 P.02 .r Nichols was hoepltaliud on 4115199 because of dehydration and possible pain and swelling following Dr. Hecht's incision and drainage from the floor of the mouth. led My of8oo placed composite (white colored) fillings In the root do to Ithe pad t and June 28j 1999, At this tithe the teeth in question were non•symP were not mobile. formed Nichole and bar motwe were able to save the two lower front teeth her that these teeth and the surrounding teeth f have a ' I have In guarded long-term proposla. All root canalled teeth are more brittle than normal healthy teeth because they no longer have a blood supply. This means dust these teeth are more likely to fracture and may need crowns in the future. Another long-term ooncem I have is the possibility of external resorption. The re- Implanted or repositioned teeth can occasionally rosorb. This means that the body's immune system might think the reimplanted teeth are foreign objects and mighwodto "eat up" the teeth. If this were the case or If the teeth edsilo the teeth , they oul e need to be extracted, the bone would need to be "grafted" partial denture, a bridge or Implants. A third concem Is the poelble future rued of the surrounding teeth to have root canals. It is quite possible for these surrounding teeth to develop infections or abscess in the Mira because of the traturia. And finally, my Temporo-Mendibular Joint Syndrome. Trauma to the jeweaconcern Is the n cause Uwe possibility land of dysf mcdon of the Jaw jolet. I do not treat TMJ dysfunctions, however, Dr. Hecht has told me that TNU treatment could range from 5400 for a splint, all the way to $10,000 for tout joint replacement. My opinions have been offered to a reasonable degree of professional certainty. The dental Injurles discussed were a result of the motor vehicle accident on February 8e, 1999. Theta teeth will never return to their pre-accident status and in my professional opinion, I believe there Is likelihood that these teeth could need iltrther treatment In the fidure. I do not know what the average crown or implant foes are in the ama. I am prohibited by law to share fees with other demists. I can however ahem my current fees with you to give you an idea of the possible Awe costs. Crowns $600 X 2 - $1,200 (may need to be replaced every 15.20 years) or 6 unit bridge $600 X 6 $3,600 (may need to be replaced every 15.20 your) or Implants $2,500 . $3,000 per tooth - 56,000 or Root canals $349 . $460 per tooth or TW treatmentS400 - $10,000 or Bone grafting $ 1,500 (may need to be ro-done every 25 years) Sincerely, Owy S. Davis, DDS GRAHAM & MAUER, P.C. BY: LISA J. MAUER, ESQUIRE Attorney I.D. 65426 The Commons at Valley Forge Suite 22, P.O. Box 987 Valley Forge, Pennsylvania 19482 610/933-3333 NICHOLE WALLAK, a minor, by ANGELA BITNER and ROBERT WALLAK parents and custodians Plaintiff v. CHRISTIE PETONYAK and DEBRA PETONYAK Defendants In Re: NICHOLE WALLAK, a minor ORDFR AND NOW, this day of Attorney for Plaintiff COURT OF COMMON PLEAS CUMBERLAND COUNTY No.: , 1999, upon consideration of the foregoing Petition, it is hereby ORDERED that the settlement of this action for the lump sum amount of Twcnty-five Thousand dollars ($25,000) is hereby approved, counsel fees and expenses are allowed, and distribution is dictated as follows: TO: GRAHAM & MAUER, P.C. For costs $ 540.97 TO: GRAHAM & MAUER, P.C. 8,750.00 For counsel fees TO : NICHOLE WALLAK, a minor, to be paid by Allstate Insurance Company 15.709.03 Total S 25,000.00 BY THE COURT: J. ./ 0C'r;1 1, 1990 GRAHAM & MAUER, P.C. BY: LISA J. MAUER, ESQUIRE Attorney I.D. 65426 The Commons at Valley Forge Suite 22, P.O. Box 987 Valley Forge, Pennsylvania 19482 610/933-3333 NICHOLE WALLAK, a minor, by ANGELA BITNER and ROBERT WALLAK parents and custodians Plaintiff v. CHRISTIE PETONYAK and DEBRA PETONYAK Defendants In Re: NICHOLE WALLAK, a minor AND NOW, this -1 to day of 6 Vr-?t L Attorney for Plaintiff COURT OF COMMON PLEAS CUMBERLAND COUNTY , 1999, it is hereby ORDERED and DECREED that a hearing on Plaintiffs Petition for Leave to Compromise Minor's Action will be held on the day of y2rUC-,?.?itt, 1999, at * LX) m. in Courtroom .7 of the Cumberland Country Courthouse, Carlisle, Pennsylvania. ; +y/ u FlLED-OFFICE ?b OF TI t r"G=OIOUOTPRY n q 99Ofr?.p At{ 8102 cup 4 rf i;C? r}{?MY t'C4k:P:S'r1ln ?'U , S _.i ?t? YJ 4 Y` { lFY 9 GRAHAM & MAUER, P.C. BY: LISA J. MAUER, ESQUIRE Attorney I.D. 65426 The Commons at Valley Forge Suite 22, P.O. Box 987 Valley Forge, Pennsylvania 19482 610/933-3333 NICHOLE WALLAK, a minor, by ANGELA BITNER and ROBERT WALLAK parents and custodians Plaintiff v. CHRISTIE PETONYAK and DEBRA PETONYAK Defendants In Re: NICHOLE WALLAK, a minor ORDER AND NOW, this day of Attorney for Plaintiff COURT OF COMMON PLEAS CUMBERLAND COUNTY No.: ql)- Uy2? Cu'j T-,U, , 1999, upon consideration of the foregoing Petition, it is hereby ORDERED that the settlement of this action for the lump sum amount of Twcnty-five Thousand dollars ($25,000) is hereby approved, counsel fees and expenses are allowed, and distribution is dictated as follows: TO: GRAHAM & MAUER, P.C. For costs $ 540.97 TO: GRAHAM & MAUER, P.C. 8,750.00 For counsel fees TO : NICHOLE WALLAK, a minor, to be paid by Allstate Insurance Company 15.709.03 Total $ 25,000.00 BY THE COURT: J. GRAHAM & MAUER, P.C. BY: LISA J. MAUER, ESQUIRE Attorney I.D. 65426 The Commons at Valley Forge Suite 22, P.O. Box 987 Valley Forge, Pennsylvania 19482 610/933-3333 NICHOLE WALLAK, a minor, by ANGELA BITNER and ROBERT WALLAK parents and custodians Plaintiff v. CHRISTIE PETONYAK and DEBRA PETONYAK Defendants In Re: NICHOLE WALLAK, a minor Attorney for Plaintiff COURT OF COMMON PLEAS CUMBERLAND COUNTY No.: gcl•L4,29 ca.t Tit PETITION FOR LEAVE TO COMPROMISE MINOR'S ACTION TO THE HONORABLE, THE JUDGES OF THE SAID COURT: The Petition of Angela Bitner and Robert Wallak, parents and custodians of a minor, Nichole Wallak, respectfully represents that: 1. They are the parents and custodians of Nichole Wallak, a minor, age fifteen, who was injured in an motor vehicle accident on February 8, 1999. 2. Nichole Wallak, a minor, currently resides with her mother, Angela Bitner, at 340 Kerrsville Road in Carlisle, Cumberland County, Pennsylvania 17013. 3. Robert Wallak resides at 1821 Walnut Bottom Road in Newville, Cumberland County, Pennsylvania 17241 4. Plaintiffs parents, Angela Bitner and Robert Wallak, arc divorced and share legal custody of said minor, pursuant to Marriage Settlement Agreement, attached hereto as Exhibit „A„ 5. This petition is brought in Cumberland County and the accident also occurred in Cumberland County, Pennsylvania. 6. The accident occurred when the vehicle in which Nichole Wallak, was a passenger, driven by Defendant Christie Petonyak and owned by Defendant Debra Petonyak, struck a guard rail. 7. As a result of the aforesaid incident, Nichole Wallak sustained injuries to her head, face, neck and mouth. 8. Nichole Wallak was treated by the Carlisle Hospital and Frederick L. Hecht, D.M.D. and received significant treatment following the date of this accident. 9. Nichole Wallak sought further care after being released from the hospital from Currie & Hecht Oral & Maxillofacial Surgeons, Richard J. Cantor, D.M.D, Gary S. Davs, D.D.S., Stephen M. Becker, M. D., Penn's Wood Physical Therapy, and J. Craig Jurgensen, M.D., in addition to a second admission to the Carlisle Hospital. 10. The following expenses have been incurred for treatment of said minor, all of which have been paid in full by Plaintiffs insurance carrier to date. Carlisle Hospital $ 417.67 Belvedere Medical Center 100.00 Stephen Becker, M.D. 178.51 Carlisle Imaging 80.63 Gary Davis, D.D.S. 700.80 Penn's Wood Physical Therapy 224.44 CVS 17.59 RWC Emergency Physicians 33.89 Frederick Hecht, M.D. 699.31 Total Medical Expenses $ 2,452.84 11. Counsel was retained upon a 35% contingent fee basis by Petitioner. Additionally, counsel has incurred the following expenses: US Mail (medical records 6.40 and fee agreement) Smart Corp (Carlisle Hospital records) 51.36 Adams Photography 162.71 Penn's Wood Physical Therapy (records) 25.00 Gary Davis, D.D.S. (Consult & letter) 250.00 Fee for Court Approval 45.50 of Minor's Compromise Total Expenses $ 540.97 12. Petitioners and counsel recommend approval of the lump sum amount of Twenty- Five Thousand Dollars ($25,000.00) with defendant's insurance company because this amount represents the full limit of the tortfcasor's policy. See letter from Allstate, dated September 10, 1999, attached hereto as Exhibit "B". 13. Petitioners approve the proposed settlement because they consider it fair and reasonable and that it adequately compensates the minor for the injuries sustained, and expenses incurred, and they fiuiher approve of the proposed distribution set forth in the Order attached hereto. In the future, Plaintiff may present an underinsured motorist claim should her injuries warrant such a claim. WHEREFORE, Petitioners pray that an Order be entered approving the compromise allowing counsel fees and ordering distribution. Date: October 12, 1999 GRAHAM & MAUER, P.C. By: di'Maue Esgd e Attorney for laintiff «a.:w...:;:.....++r?+cv'?'?M?enta?..:?9?,nw^ro.p+»..oiw:-,+ .„...-=..?r+a?'°w_S?•rt rr rszw. ?,. s:4rm??.rws...rs...KCnareen+.-w.+r-+?+w!,r,...an..,n FLED Cr.ICE f,fi l ' ,,?C,rvhTMY 99 OCT 2 I Pti 2: 12 Cum,&Ema o CfJUNN PENNSYLVANIA GRAHAM & MAUER, P.C. BY: LISA J. MAUER, ESQUIRE Attorney I.D. 65426 The Commons at Valley Forge Suite 22, P.O. Box 987 Valley Forge, Pennsylvania 19482 610/933-3333 NICHOLE WALLAK, a minor, by ANGELA BITNER and ROBERT WALLAK parents and custodians Plaintiff v. CHRISTIE PETONYAK and DEBRA PETONYAK Defendants In Re: NICHOLE WALLAK, a minor Attorney for Plaintiff COURT OF COMMON PLEAS CUMBERLAND COUNTY No.: ATTORNEY VERIFICATION In my professional opinion as counsel in this matter, I believe that the proposed settlement in the lump sum amount of Twenty-Five Thousand dollars ($25,000.00) is reasonable under the circumstances. The proposed settlement reflects the limit of the tortfeasor's policy. In the future, Plaintiff may present an underinsured motorist claim should her injuries warrant such a claim. GRAHAM & MAUER, P.C. t By: 4,k, I _L s J. M #r, E uire Attorney Ibr Plaintiff Date: October 12, 1999 GRAHAM & MAUER, P.C. BY: LISA J. MAUER, ESQUIRE Attorney I.D. 65426 The Commons at Valley Forge Suite 22, P.O. Box 987 Valley Forge, Pennsylvania 19482 610/933-3333 NICHOLE WALLAK, a minor, by ANGELA BITNER and ROBERT WALLAK parents and custodians Plaintiff v. CHRISTIE PETONYAK and DEBRAPETONYAK Defendants In Re: NICHOLE WALLAK, a minor Attorney for Plaintiff COURT OF COMMON PLEAS CUMBERLAND COUNTY No.: AFFIDAVIT OF GUARDIAN I, Robert Wallak, certify that: 1, I am a parent and custodian of Nichole Wallak; 2. Nichole Wallak has had medical treatment for the injuries sustained in the incident which is the subject matter of this action and may require additional treatment in the future; and 3. I approve the proposed settlement of a lump sum payment of Twenty-Five Thousand Dollars ($25,000.00) and the distribution thereof. Gt/ gobert allak Swom to d S ?scrib d before me thisr day of 1999. Notnei eat No ry d County Not Isslon!F IresOct.7,2002 Memuer, Prnn4yM1nnn A5500m in 01 Na'1nc9 GRAHAM & MAUER, P.C. BY: LISA J. MAUER, ESQUIRE Attorney I.D. 65426 The Commons at Valley Forge Suite 22, P.O. Box 987 Valley Forge, Pennsylvania 19482 610/933-3333 NICHOLE WALLAK, a minor, by ANGELA BITNER and ROBERT WALLAK parents and custodians Plaintiff v. CHRISTIE PETONYAK and DEBRA PETONYAK Defendants In Re: NICHOLE WALLAK, a minor Attorney for Plaintiff COURT OF COMMON PLEAS CUMBERLAND COUNTY No.: AFFIDAVIT OF GUARDIAN I, Angela Bitner, certify that: 1. I am a parent and custodian of Nichole Wallak; 2. Nicholc Wallak has had medical treatment for the injuries sustained in the incident which is the subject matter of this action and may require additional treatment in the future; and 3. I approve the proposed settlement of a lump sum payment of Twenty-Five Thousand Dollars ($25,000.00) and the distribution thereof. 1? 0? P & N. &6s:q Angela ner Sworn to and Subscribed before me this (o day of 0 a)C '1999. -Gornfa L. Sholtuy. Na=ry NUT tL•+.•rvJl? Hero. ?LmCednn4 Cnam;y my canniss!v) Dpirny 0.:1. 19.1000 MARRIAGE SETTLEMENT AGREEMENT THIS AGREEMENT made this /3 day of Tvn t. , 1990, by and between Robert James Wallak, (hereinafter referred to as "Husband,") and Angela Jo Wallak, I (hereinafter referred to as "Wife,') . WITNESSETH: WHEREAS, the Husband and Wife were lawfully married on May 28, 198; and WHEREAS, differences have arisen between Husband and Wife in consequence of which they intend to live apart from each other; and WHEREAS, one child was born of this marriage, Nichole Danielle Wallak, born on November 28, 1983 WHEREAS, Husband and Wife desire to settle and determine their rights, obligations and support and custody of the child; and NOW, THEREFORE, the parties intending to be legally bound hereby do covenant and agree as follows; 1. SEPARATION It shall be lawful for each party at all times hereafter to live separate and apart from the other party at such place or places as he or she may from time to time choose or deem fit. The foregoing provisions shall not be taken as an admission on the part of either party as to the lawfulness or unlawfulness of the causes leading to their living apart. i Exhibit "A" 2. Each party shall be free from interference, authority, and 'contact by the other as fully as if he or she were single and unmarried except as maybe necessary to carry out the provisions of the agreement. Neither party shall molest the other or attempt to endeavor to molest the other, nor compel the other to cohabit with the other, or in any way harass or malign the other, nor in any way interfere with the peaceful existence, separate and apart from the other, and each of the parties hereto completely understand and agree that neither shall do or say anything to the child of the parties at any time which might in any way influence the child adversely against the other party. 3. DIVISION OF PERSONAL PROPERTY The parties have agreed to divide between them and already have divided between them to their mutual satisfaction the personal affects, household furniture and furnishings and all other articles of personal property which heretofore have been used by them in common. Neither party will make any claim to any such items which are now in the possession or under the control of the other. 4. AUTOMOBILES The Husband and Wife were the owners of a 1980 Chevy Pick-Up truck and a 1989 Pontiac. The rights and titles to both of these vehicles have been transferred so that at the present time the 1980 Chevy Pick-Up is owned exclusively by the Husband and the 1983 Pontiac is owned and titled exclusively to the Wife. 5. DIVISION OF PROPERTY The real estate owned by the parties as tenants by the entireties situated at 1821 Walnut Bottom Road, Newville, Cumberland County Pennsylvania shall forthwith be conveyed in fee simple to 'the Husband. Husband shall assume full responsibility for the payment of the existing mortgage and note. Husband shall indemnify and save Wife and Wife's grandmother harmless from any liability on the accompanying mortgage and note. Appropriate arrangements shall be made to remove the Wife and the Wife's grandmother from the obligations under the note. t• -6. MARITAL DEBTS Husband shall assume all outstanding marital debts that were incurred prior to the date of separation, November, 1989. 7. SHARED CUSTODY The parties agree that legal custody of their minor child, Nichols shall be joint, with both parties having the right to make major parenting decisions affecting the child's health, education and welfare. Physical custody shall be joint with primary physical custody to the wife and partial physical custody to the Husband, on alternating weekends and at such other times as the parties may agree. 8. CHILD SUPPORT Husband agrees to pay the Wife $45.00 per week for the support of the parties minor child, Nichols. If at the time Nichols graduates from High School and she is qualified to attend and does attend College or a similar institution of higher learning, as a full time student, the husband, if financially able, agrees to pay such support as the Court deems fit and proper under the circumstances at that time. Husband shall be responsible for providing Blue Cross and Blue Shield medical coverage or its equivalent for his daughter Nichole until she reaches the age of 18 if such medical coverage is available as part of the Husband's employment benefits, whether or not such benefits are paid for directly by the employer, by partial contribution by the Husband or by full contribution by the husband. The parties agree that in the event of a material change in the cost of living or the financial circumstances of either party, or of a change in the custody arrangements set forth herein, the amount of the support payments shall be subject to an appropriate adjustment by agreement or, if the parties are unable to agree, by a Court of competent jurisdiction. 9. DEPENDANT TAX DEDUCTIONS The parties agree that the wife shall be entitled now and in the future to take Nichols the parties' minor child as an exemption for income tax purposes. 10. JOINT PILING 08 IRS RETURN Husband and Wife agree to file a separate income tax returns. 11. DIVORCE The parties agree to cooperate with each other in obtaining a final divorce of the marriage. It is agreed that at final settlement the parties will execute and file the necessary consents to obtain the divorce. 12. SUBSEQUENT DIVORCE Nothing herein contained shall be deemed to prevent either of the parties from maintaining a suit for absolute divorce against the other in any jurisdiction based upon any past or future conduct of the other, nor to bar the other from defending any such suit. In the event any such action is instituted or concluded, the parties shall be bound by all of the terms of this agreement. 13. MERGER/INCORPORATION This agreement may be merged with and incorporated into any subsequent Degree in Divorce. 14. CONTINUED COOPERATION The parties agree that they will within fifteen days after the execution of this agreement execute any and all written instruments assignments, releases, deeds or notes or other such writings as may be necessary or desireable for the proper effectuation of this agreement. 1$. BREACH If either party breaches any provision of this agreement, the other party shall have the right, at his or her election, to sue for damages for such breach, and the party breaching this contract shall be responsible for the payment of legal fees and costs incurred by the other in enforcing their rights under this agreement or for seeking such other remedies or relief as may be available to him or her. 0 16. VOLUNTARY AGREEMENT The provisions of this both parties and each party acknowledges e that the agr eunderstood b ment is fair and equitable, that it is being entered into voluntarily, and that it is not the result of any duress or undue influence. 17. WAIVER OF CLAIMS AGAINST ESTATES Except as herein otherwise provided, each party may dispose of his or her property in any way, and each party ereby waives and relinquishes any and all rights he or she may now have or hereafter acquire under the present or future laws of any jurisdiction to share in the property or the estate of the other as a result of the marital relationship, including without limitation, dower, curtesy, statutory allowance, widows allowance, right to take in intestacy, right to take against the will of the other and the right to act as administrator or executor of the other's estate. 18. BINDING AFFECT This agreement shall be binding upon the parties' heirs, successors and assigns. 19. MODIFICATION AND WAIVER Any modification or waiver of any of the provisions of this agreement shall be effective only if made in writing and executed with the same formalities as this agreement. The failure of either party to insist upon strict performance -of any of the provisions of this agreement shall not be construed as a waiver of any subsequent default of the same or similar nature. 20. PRIOR AGREEMENTS It is understood and agreed that any and all prior agreements which may have been made or executed or verbally discussed prior to the data and time of this agreement are null and void and of no affect. 21. ENTIRE AGREEMENT This agreement contains the entire understanding of the parties and there are no representations, warranties, covenants or undertakings other than those expressly set forth herein. 22. DESCRIPTIVE HEADINGS The descriptive headings-used herein are for convenience only. They shall not have any binding affect whatsoever in detafmining the rights or obligations of the parties. 29. APPLICABLE LAW This agreement shall be construed under the laws of the Commonwealth of Pennsylvania. IN WITNESS WHEREOF, the parties set their hands and seals the day and the year first written above. Y obert . Wallak Angel o Wa], ak Commonwealth of Pennsylvania: County of /^'?k-? PERSONALLY APPEARED BEFORE ME, this / 3 day of this in 1990, a notary public, in and for the Commonwealth of Pan lvania, Robert J. Wallak, known to me (or satisfactorily proven to be) the person whose name is subscribed to the within agreement and acknowledged that he executed the same for the purposes herein contained. IN WITNESS•WHEREOF, I have hereunto set my hand and official seal. Commonwealth of Pennsylvania: ,...•l??/'? County of PERSONALLY APPEARED BEFORE ME, this /i day of this W.#.0 , 1990, a notary public, in and for the Commonwealth of Penns ivania, Angela Jo Wallak, known to me (or satisfactorily proven to be) the person whose name is subscribed to the within agreement and acknowledged that he executed the same for the purposes herein, contained. r Exhibit B . YF f}" KUUT CLAIM Omds ew n.,ir X Dews lusts jeW NAxxnstlao PA nllt O FMCS R NUMUJU MONAY4 DNV 14"M September 10, J99 LIRA NAM is?RE mum & NAUiR PO ROK 987 VALLEY =a Pj 19482 i Allsfi?t?' Allstate Insur as Company Claim Numbars 534069!7 R29 Our Insured: D BRA PE MAK Date of Loses y bruary 8, 1999 Your Client: Ni le Vallak Dear No. Hauer: Unclosed pleaselfind the release in the amount we agreed upon to settle your above reference client's claim. This amount reflects our iesured'a policy limits of $25,0 0.00. As requested, I have also enclosed verification of those limits. P ease have your client properly axeauts the release and return it to my attent . As you know, since this settlement is for a minor, we will require court approval. Upon receipt of the approval and executed release, we w114 promptly issue the settlement check. Thank you for t Cooperation in this matter. DONALD A. LICM14 r Allstate Propu +-Casualty Claim service Organisation SN06/0/01/1 ? ? • . : 094.1 ZF T ti L CV ii x_ Va CL. r, } cli GRAHAM & MAUER, P.C. BY: LISA J. MAUER, ESQUIRE Attorney I.D. 65426 The Commons at Valley Forge Suite 22, P.O. Box 987 Valley Forge, Pennsylvania 19482 610/933-3333 NICHOLE WALLAK, a minor, by ANGELA BITNER and ROBERT WALLAK parents and custodians Plaintiff v. CHRISTIE PETONYAK and DEBRA PETONYAK Defendants In Re: NICHOLE WALLAK, a minor AND NOW, this day of Attorney for Plaintiff QG r -- 1999bP COURT OF COMMON PLEAS CUMBERLAND COUNTY No.: 179• G'/?9 l_L T. , 1999, upon consideration of the foregoing Petition, it is hereby ORDERED that the settlement of this action for the lump sum amount of Twenty-five Thousand dollars ($25,000) is hereby approved, counsel fees and expenses are allowed, and distribution is dictated as follows: TO: GRAHAM & MAUER, P.C. For costs $ 540.97 TO: GRAHAM & MAUER, P.C. 8,750.00 For counsel fees TO : NICHOLE WALLAK, a minor, to be paid by Allstate Insurance Company 15.709.03 Total $ 25,000.00 BY THE COURT: J. GRAHAM & MAUER, P.C. BY: LISA J. MAUER, ESQUIRE Attorney I.D. 65426 The Commons at Valley Forge Suite 22, P.O. Box 987 Valley Forge, Pennsylvania 19482 610/933-3333 NICHOLE WALLAK, a minor, by ANGELA BITNER and ROBERT WALLAK parents and custodians Plaintiff v. CHRISTIE PETONYAK and DEBRA PETONYAK Defendants In Re: NICHOLE WALLAK, a minor AND NOW, this day of Or: )' :; ;; 199 Attorney for Plaintiff COURT OF COMMON PLEAS CUMBERLAND COUNTY No.: 99• L 11.24 ez'y T-ta- , 1999, upon consideration of the foregoing Petition, it is hereby ORDERED that the settlement of this action for the lump sum amount of Twenty-f vc Thousand dollars ($25,000) is hereby approved, counsel fees and expenses are allowed, and distribution is dictated as follows: TO: GRAHAM & MAUER, P.C. For costs S 540.97 TO: GRAHAM & MAUER, P.C. 8,750.00 For counsel fees TO : NICHOLE WALLAK, a minor, to be paid by Allstate Insurance Company 15.709.03 Total $ 25,000.00 BY THE COURT: s J. NICHOLE WALLAK, a minor, by ANGELA BITNER and ROBERT WALLAK, parents and custodians, PLAINTIFFS V. CHRISTIE PETONYAK and DEBRA PETONYAK, DEFENDANTS : IN THE COURT OF COMMON PLEAS OF : CUMBERLAND COUNTY, PENNSYLVANIA : 99-6429 CIVIL TERM ORDER OF COURT AND NOW, this 231 day of November, 1999, following a hearing, IT IS ORDERED: (1) Settlement of this minor's claim of Nichole Wallak, born November 29, 1983, in the amount of $25,000, IS APPROVED. (2) Plaintiffs, Angela Bitner and Robert Wallak, parents and guardians of Nichole Wallak are authorized to execute all documents necessary to effectuate this settlement. (3) A counsel fee of $6,250, and expenses of $534.57, ARE APPROVED.' (4) Counsel shall have the net proceeds of $18,215.53 deposited in an interest bearing Investment in the Members First Federal Credit Union IN THE NAME OF NICHOLE WALLAK, BORN NOVEMBER 29,1983. The investment shall contain a notation that NO WITHDRAWAL SHALL BE MADE UNTIL THE MINOR ATTAINS HER MAJORITY WITHOUT AN ORDER OF A COURT OF COMPETENT JURISDICTION. ' We approve a counsel fee of twenty-five percent of the $25,000 rather than thirty-five percent as requested, and do not approve the request of an expense of $6.40 for U.S. Mail In this policy limit settlement. See Shuler v. Seibert, 42 Cumberland L.J. 242(1993). (5) Counsel shall within thirty (30) days of this date file with the Prothonotary, and send a copy to chambers of proof of compliance with paragraph 4 herein. By the Court; Edgar B. yley, . - Lisa J. Mauer, Esquire The Commons at Valley Forge ^"".cryC. ri?? a?q? Suite 22, P.O. Box 987 Valley Forge, PA 19482 For Plaintiffs :sea 4 a pF .. • ,''GP, ITIAAY 99 N01123 hM 10, 38 WND CO M, CUIM SE K NN MV" S M r ..?.j v .°rR iy; q9 Gya9. GRAHAM & MAUER, P.C. ATTOA" MAT•I.AW TIN COMMONS AT VAIJIY rORaN sum 11, P.O. box 907 VAIJAY rORDR, PA WU RONAW M. ORAMAM LISA J. MAVn .uo nrr a,.n,o, w Civil Prothonotary Cumberland County Courthouse One Courthouse Square Carlisle, PA 17013-3387 161019131111 1000710.0000 PAX 101(I) II113- 70 December 16, 1999 11M SL%mnwooD DRtvc nAR mma, PA 17111 (717) 210-0900 (717) 6131200 C, ?o t ni rri'r `i Re: Proof of Compliance of Investment or Net Proceeds of a Minor's Recovery for Nlchole Wallsk199.6429 To Whom It May Concern: Pleuse Ole the attached proof ofconipliance with paragraph 4 ofJudge Bayley's Order in this matter, dated November 23, 1999. Thank you for your time and attention. LJM:mlm Enclosures Sincerely, V . ? I440 LISA J. MA?ER cc: The Ilonorable Edgar B. Bayley (Hand Delivered) y DEC-16-99 THU 15;15 MEMBERS 1ST MTG DEPT FAX NO, 7177956023 P.02 Mem?? FRI)ERAL C.RLiDI'1"r e-" UNION December 16, 1999 Attorney Lisa J. Mauer The Commotls at Valley Forge Suite 22, P.O. Box 987 Valley Forge, Pa 19482 Re: Nichole Wallak Account Dear Me. Mauer: I have received the check that you sent for NIchole Wallak in the amount of $18,215.43. I have established a savings account with a balance of $25.00, and a share certificate number 40 In the amount of 518,190.43, the total in the account #189653, is $18,215.43. The account has been frozen per the court order, the funds will not be released until Nichole reaches her majority on her 10 birthday, or by order of the court. The account number for the savings and the certificate is #189653: the account is In her name only. I am also enclosing a copy of the account and a receipt for the check. If I can be of further assistance to you in this matter, I can be reached at 717-795- 6013. Sincerely, vLossing Compliance Specialist 5000 Louiso Drtvc a P.A. Box 40 0 McehanlcAburg, Pennsylvania 17055 • (717) 697.1161 6 Fax (717) 795.6024 Nocolved Doc-16-99 16:03 from 7177956023 + 16109830570 page 3 DEC-16-99 THU 16:15 MEMBERS IST MTG DEPT FAX NO. 7177956023 P.03 COURT ORDER DO NOT RELUSE FONDS UNTIL 11/29/2001 OR BY COURT ORDRIE 1rS ,. PBD81?URI )?T ?NtOFt: ?' "` -D "• CERTIFICATE `- APPLICATION AND DISCLOSURE DO NOT WRITE ABOVE LINE 17We hereby apply for a Members tot Certificate In the amount and term listed below. MATURITY DATE: 11/29/01 Please Print?? D. NALLX ACCOUNT # 189653 _ MEMBERS NAME:._ SOCIAL 174-64-8787 ADDREB$; 3?i0 REI:R$pILLE 1tOAD -- SECURITY I 717-258-8070 CITY: CCRLI9LE _ STATE: - ZIP CODE: 17013 HOME PHONE NUMBER: WORK NUMBERi _ NIA JOINT OWNER(S) NAME: _ N/A C1 PLEASE DEPOSITS 18,190.43 INTHE FOLLOWING MANNER 0 PLEASE TRANSFER S ^ _ FROM ACCT. NO. _ SUFFIX ilaM? DE$it' ACC PERCINTIRr tAMOUNT I AtIR. I CODE YIELD ?J. A DIVICEND RATE i I 24 NUMBER I =Lazy.-U .-LUL 6.257 . : 22M ( to ' Dir. Pail at Maturity ROS9M02NE YDL • DIP0311' BACK TO CENTINCATI ill • DEPOSIT TO IAVINOS ACCOUNT 121 • DEPOSIT TO CHECKING ACCOUNT Ill • DEPOSIT TO INVESTMENT SAVINGS ACCOUNT 12) • MAIL ME A C81CK l21 MEMBERS SIGNATURE: FRI Caw QUMLOH Fn. r_ DATE:. _1706/.1ggg This Is IOCartlty that the above named person(a) are the owners of a certificate account at 10181711001`1 11 at Federal Credit Union. This certificate may ba redeemed at maturity. The dividend rate and Annual Percentage Yield are Shown above. The Annual Percentage Yield and dividend rata assume that the dividend is added to the principal of the certificate. This OCCOunt IS subject to all terms and conditions stated In the Certificate Account Disclosure, as they may be amended from time 10 time, and Incorporate the same by reference Into this egiaemcnt. Dividends are based on the credit union's earnings at the end of a dividend period and cannot be guaranteed. EARLY WITHDRAWL PENALTIES: A Substantial penalty will Imposed for withdrawals prior to the maturity date that may result in Invasion of principal. The forfeiture IS calculated on the simple interest rate regardless of how long the funds have remained in the account, The penalty for certificates purchased or renewed with a term on one year or teas will be equal to a forfeiture of an amount equal to 90 days' dividends, whether earned or not. The penalty for certificates purchased or renewed with a term of more than one year will be equal to A forfaltura of an amount equal to 180 days' dividends, whether earned or not The credit union will give you at least 20 days notice prior to maturlry. The certificate will eutomaticalty be renewed for another term at the close of business on the initial maturity date or maturity date of any renewal term unless it is redeemed within seven (7) Calendar days. The rate of earnings for any renewal term shall be at the rate the credal union is paying at that time on new certificates of that term. In the event of the death of the certificate owner, the certificate will be surrendered without Incurring tho early withdrawal penalty. MBAs 1; 98.75 Rev, 990 Received DOC-16-99 16:03 from 7177956823 ? 16109830570 page 4 DEC-18-99 THU 15:16 MEMBERS 1ST MTG DEPT FAX NO. 7177956023 P. 04 189653 WALLAK/NICHOLE D 12/16/99 BR: 1 OWN:$ BDs 11/29/1983 340 KERRSVILLE ROAD REF: DEPT:CINY-R PRs PASSWORD: SSN:174-64-87.00 87 AFFINITY CODES PH:(717)258-8070 CARLISLE PA 17013 HOUSEHOLD: 0 WKs(000)000.0000 CR RTs 0 FLAGS: NUMBER DATE MEMO 000001001 12/16/99 COURT ORDERED ACCOUNT NO WITHDRAWALS ALLOWED UNTIL 11/29/01 000001002 12/16/99 AND THEN ONLY BY NICHOLE OR BY AN ORDER OF THE COURT YDL SFX DE8C DT OPEN BALANCE AVAIL RATE YTD DIV LST ACT FLAGS 00 RSA 121699 25.00 0 .0000 40 IBM 121699 18190.43 0 6.2500 •00 121699 R3 TOTAL SHARES PLEDGED; 25025.00 00 121699 22,40 ID:[ I TRAM CODE=[ MEMBERS 1ST FEDERAL CREDIT UNION DATE;[12/16/991 [ j PARAMETERS:[ j Hembere let Federal Credit union j PO Box 409 5000 Louise Drive Kecbanicabur8, Fa 17055 GRAHAM & MAUER, P.C. ATrosNEYs-AT•I.AW 711E COMMONS AT VALLEY FOEGx Surm 22, P.O. Box 997 VALLEY FOEGL, PA 19482 RONALD M. GRAHAM USA J. MAV[H (610) 933.3.W 1.9042194909 FAX (610) 997-0370 1136 SOmmnwoon DEIYE HARRissuRc, PA 17111 (717) 248.0900 (717) 65241200 quo ?rou a an,uur u. Civil Prothonotary Cumberland County Courthouse One Courthouse Square Carlisle, PA 17013-3387 December 16, 1999 Re: Proof of Compliance of Investment of Net Proceeds of a Minor's Recovery for Nichole Wailak; 99-6429 To Whom It May Concern: Please file the attached proof ofcompliance with paragraph 4 ofJudge Bayley's Order in this matter, dated November 23, 1999. Thank you for your time and attention. LJM:mIm Enclosures Sincerely, R 41S WD LISA J. MA? cc: The Honorable Edgar B. Bayley (Hand Delivered) DEC-16-99 THU 15;15 MEMBERS 1ST MTG DEPT FAX NO. 7177958023 P.02 I Mere erg. FT 1?EItAL C:RL'DI'1' UNION December 16, 1999 Attorney Lisa 3, Mauer The Commons at Valley Forge Suite 22, P.O. Box 987 Valley Forge, Pa 19482 Re: NIchole Wallak Account Dear Ms. Matter. I have received the check that you sent for NIchole Wallak in the amount of $18,215.43. I have established a savings account with a balance of 525.00, and a share certificate number 40 in the amount of 518,190.43, the total in the account 6189653, is S 18,215.43. The account has been frozen per the court order, the funds will not be released until NIchole reaches her majority on her 18'h birthday, or by order of the court. The account number for the savings and the certificate is #189653; the account is In her name only. I am also enclosing a copy of the account and a receipt for the check. 6013If I can be of further assistance to you in this matter, I can be reached at 717-795- . Sincerely. vLossing Compliance Specialist 5000 Louise Drive 9 P.Q. Box 40 • \Jachanicshurg, PennsyMania 17055 • (717) 697.1161 0 Fax (717) 7956024 Received Dec-10••99 16:03 from 7177956023 ? 16109830570 page 3 DECr(6-99 THU 15115 MEMBERS 1ST MTG DEPT FAH NO. 7177956023 P,03 COURT ORDER DO NOT RELEASE FONDS UNTIL 11/29/2001 OR EY COURT ORDER 'psi 0§"? 0 D? . n CERTIFICATE - - APPLICATION AND DISCLOSURE DO NOT WRITE ABOVE LINE UWe hereby apply for a Members 1st C11111fl ate In the amount and term listed below. Please Print MEMBERS NAME: NICEOLE D. WALL4LK MEMBERS ADDRESS: 340 EEBRSVILLE ROAD CITY: CARLISLE HOME PHONE NUMBER: 717-258-8070 JOINT OWNER(S) NAMEi _ N/A C] PLEASE DEPOSITS 18,190.43 INTHE FOLLOWING MANNER O PLEASE TRANSFER S _ •- FROM ACCT. NO, - , MATURITY DATE: 11/29/01 ACCOUNT # 189653 _ SOCIAL 174-64-8787 SECURITY N - _ STATE: PA ZIP CODE: 17013 WORK NUMBER: _ N/A SUFFIX i - ARNUAE ? __ - - CERTIFIGT[T[RM I I OEEC.' ACC I ?EAClNTARi I 1 tAMOUNT A/IR. CODE I TIEtO DIVICENO RATE ATE 1 Mf RTIFICe 0 MRTIFICAT[ TIN IE ERTIFICATE ' IYA 24 ?fAOOFTxcEATIfICATE 18.19Q.43 . rSYRIA I T TO MONTH CEATIFICATE - 37N to •?? QaQ??_,_ An A YEAR CEIITIFICATE - 14Yq IF ?• ' 7 YEAR CFRTIIICATF - --I ?- "-`•r-•-•- METN00 Oi OIVIOlRO DISPOSITION STR It • Dir. Part It Maturity 6,noM Employes PttASE COUM?? IIF- i ONEDIi :NUMItR IEOSSNOTNE -? YDL SAME ACCOUNT • DEPOSIT IAC% TO CERTIFICATE 111 i • DEPOSIT TO SAVINOS ACCOUNT (21 •,_?,_ • DEPOSIT to CHECAINC ACCOUNT (2) • DEPOSIT TO INVESTMENT SAVINal ACCOUNT (T) • MAIL ME A CHECK el MEMBERS SIGNATURE: PE)I GQURT_280F.l1_ON_y7T.r. DATE: _ T?/1F11gq9 This Is tocerbty that the above named person(a) are the owners of is Certificate account at Members 1 at Federal Credit Union. This certificate may be redeemed at maturity. The dividend rate and Annual Percentage Yield are shown above. The Annual Percentage Yield and dividend rate assume that the dividend is added to the principal of the CenlfiCAto. This account la subject to all terms and Condalens stated in the Certificate Account Disclosure, as they may be amended from time to time, and incorporate the same by reference Into this agreemcnt. Dividends are based on the credit union's earnings at the end of a dividend period and cannot be guaranteed. EARLY WITHDRAWL PENALTIES: A substantial panaity will imposed for withdrawals priorto the maturity date that may result in Invasion of principal. The forfeiture is calculated on the simplo interest rate regardless of how long the funds have remained in the account. The penalty for Certificates purchased or renewed with a term on one year or leas will be equal to a forfeiture of an amount equal to 00 days' dividends, whether earned or not. The penally for Certificates purchased or renewed with a term of more than one year will be equal to a forfeiture of an amount equal to 180 days' dividends, whether earned or no: The credit union will give you at least 20 days notice pilot to maturity The eorbhcate win outomutkolly be renewed for another term at trio close of business on the initial maturity date or maturity data of any renewal term unless it is redeemed within seven (7) calendar days. The rate of earnings for any renewal term shail be at the rate the credit union is paying at that time on new certificates of that term. In the event of the death of the certificate owner, Into certificate will be surrendered without incurring tho early withdrawal penalty. MGRS 1; 98.85 Rev. Sl00 Received Dec-16-99 16:03 from 7177956023 4 16109830570 DE -16-99 THU 15;16 MEMBERS IST MTG DEPT FAX NO, 7177956023 189653 WALLAK/NICHOLE D 12/16/99 BR: 1 340 KERRSVILLE ROAD REF: DEPT:CINY-R PASSWORDS AFFINITY CODE, CARLISLE PA HOUSEHOLD: 0 CR RT, 0 FLAGS; 17013 page 4 P. 04 DWN:S BD: 11/19/1983 PR, .00 SSN:174-64-8787 PH,(717)258-8070 WK2(000)000.0000 NUMBER DATE MEMO 000001001 12/16/99 COURT ORDERED ACCOUNT NO WITHDRAWALS ALLOWED UNTIL 11/29/01 000001002 12/16/99 AND THEN ONLY BY NICHOLE OR BY AN ORDER OF THE COURT YDL SPX DESC DT OPEN BALANCE AVAIL RATE YTD DIV LST ACT FLAGS 00 RSA 121699 25.00 0 .0000 .00 121699 R3 40 18M 121699 18190.43 0 6.2500 .00 121699 22,40 TOTAL SHARES PLEDGED: 25025.00 MEMBERS 1ST FEDERAL CREDIT UNION DATE;[12/16/99) ID:[ J TRAM CODE:[ J PARAMETERS:[ ( ] Members let Federal Credit union ) PO Box 40. 5000 Louise Drive Mechanicsburg. Pa 17055 u ON t.} BEVERLY E. CHARRON, Plaintiff VS. LEO D. CHARRON, Defendant IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA NO. 99 - 6926 CIVIL IN DIVORCE AND NOW, this /y ytAday of , 2003, counsel having advised the Master's office on September 26, 2002, that the above captioned case was settled, and no agreement having been provided the Master's office, the appointment of the Master is vacated. BY THE COURT, cc: /Samuel L. Andes Attorney for Plaintiff /Ann V. Levin Attorney for Defendant OVA o er, P.J. t y-ly•03 ,; ;. ,, r , ?- ?? ,. ? fir; ? ? . ._. M . ' CL?,' ; ;,y '' r FLi!ii`iiL?',ti?J? #; ? . ,H , ? ? , t i . ,,. a' !.'' _:? Y? ?i. , ? ? 'h` 4? : i, .: T } . j{ (3-l._ _! ^ ? ..? lR.,_. 3". , ., 4P ... ? P " ), '. ?.' 5? ?:?.. [?>- . , ; x. ?, . . ,: ;r..','