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Home My WebLink About99-07596V. R .e 04.1 IN RE: THOMAS J. CHILCOTE and KATHARINE B. CHILCOTE, Parents and Natural Guardians of TIMOTHY J. CHILCOTE, A Minor, Petitioners IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA (-q4J) f.(.(SCC!/YI - ?hd ORPHANS=6OURT-DlVtSION NO. y'?• 7S9G Cu ORDER AND NOW, this J 91A day of A6Cc *,(9n , IGc(9 , upon consideration of the Petitioners' Petition for Approval of Minor Settlement, IT IS HEREBY ORDERED AND DECREED THAT: A hearing has been scheduled in this matter for Rn t 3 Q000 at .Q'. oo AM/PM. , vn CCcvr e o m `?0.' ??; BY THE ' r /M44-4 ?a-a8-99 RK,? , J. - :, IN RE: THOMAS J. CHILCOTE and KATHARINE B. CHILCOTE, Parents and Natural Guardians of TIMOTHY J. CHILCOTE, A Minor, Petitioners ORDER AND NOW, this day of IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA ORPHANS' COURT DIVISION NO. , upon consideration of the Petitioners' Petition for Approval of Minor Settlement, IT IS HEREBY ORDERED AND DECREED THAT: 1. The settlement in favor of Timothy J. Chilcote, a minor, IS HEREBY APPROVED; 2. Liberty Mutual Insurance Co., as insurer of Steven Junkin, is hereby directed to pay $10,000.00 made payable to Petitioners with said amount to be deposited at the Pennsylvania State Bank in the name of Timothy J. Chilcote with Thomas J. Chilcote as the custodian with the restriction that no withdrawals can be made from the account without Court approval until Timothy J. Chilcote is 18 years of age. 3. Petitioners Thomas J. Chilcote and Katharine B. Chilcote, as parents and natural guardians of Timothy J. Chilcote, a minor, are hereby authorized to execute the General Release. BY THE COURT, , J. IN RE: THOMAS J. CHILCOTE and KATHARINE B. CHILCOTE, Parents and Natural Guardians of TIMOTHY J. CHILCOTE, A Minor, Petitioners IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA n Cw..k ni.cLi....; C-...) NO. I'9 . 9 S94, a& _f Tug-. PETITION FOR APPROVAL OF MINOR SETTLEMENT Thomas J. Chilcote and Katharine B. Chilcote, Petitioners herein, as parents and natural guardians of Timothy J. Chilcote, a minor, by and through Thomas, Thomas & Hafer, LLP and Jeffrey B. Rettig, Esquire, hereby files this Petition for Approval of Minor Settlement and in support thereof avers as follows: The Petitioners herein are Thomas J. Chilcote and Katharine B. Chilcote, parents and natural guardians of Timothy J. Chilcote, a minor, who currently resides at 880 Hawthorne Avenue, Mechanicsburg, Cumberland County, Pennsylvania. 2. The minor, Timothy J. Chilcote, is currently 14 years of age, having been bom on December 1, 1985. Timothy J. Chilcote currently resides with his parents, Thomas J. Chilcote and Katharine B. Chilcote, at 880 Hawthorne Avenue, Mechanicsburg, Cumberland County, Pennsylvania. 3. On June 25, 1998, minor Timothy J. Chilcote was a passenger in an automobile owned and being driven by Thomas J. Chilcote. That vehicle was on Route 581 in Cumberland County exiting onto Central Boulevard when it was hit by a vehicle operated by Steven Junkin who was insured by Liberty Mutual Insurance Company. 4. Steven Junkin resides at 424 Ridgeview Drive, Dillsburg, Pennsylvania. 5. At the time of the accident, Steven Junkin was insured by a policy of insurance issued by Liberty Mutual Insurance Company, policy number A02-288-635442-807. 6. As a result of this accident, minor Timothy J. Chilcote suffered traumatic injury resulting in headaches, neck pain and abdominal distress. Timothy J. Chilcote received treatment for these injuries from Michael Warner, D.C., with his last treatment on August 27, 1999. All medical bills to date, equaling $4,638.55, have been paid to the best of Petitioners' knowledge. 8. To settle this claim, the Petitioners have agreed to accept a lump sum payment by Liberty Mutual Insurance Company in the amount of $10,000.00 made payable to Timothy J. Chilcote. In exchange for this payment, Thomas J. Chilcote and Katharine B. Chilcote have agreed to execute a Release of All Claims, a copy of which is attached hereto as Exhibit "A". 9. Petitioners herein believe that the settlement enumerated in this Petition is fair and equitable and is in the best interest of the minor. 10. Liberty Mutual Insurance Company has offered to pay the sums set out in this Petition toward an amicable resolution of the claims in exchange for Court approval and a Release of All Claims. Liberty Mutual will also pay all Court costs and legal fees incurred with respect to the instant Petition for Court Approval of this minor settlement. WHEREFORE, Petitioners respectfully request that this Honorable Court enter an Order approving the foregoing compromise settlement directing the distribution of proceeds thereof as set forth above and authorizing the Petitioners, upon payment of the aforesaid sums, to execute a Full and Final Release as attached hereto. Respectfully submitted, THOMAS, THOMAS & HAFER, LLP EXHIBIT "All > -RELEASE AND SETTLEMENT OF CLAIM l?-f l For the sole consideration of the undersigned hereby releases and fore a)( A., C?iR.??- r)q?aaa-oa (File No ) dollars.($ ???C •" `??--+ c.w _ 19 -t Q, ana do Hereby covenant to mpemmty ano save narm)ess me sa?aparty.or yam •. and a B ? auist all claims and demands whatsoever 'on account . of or, in any way growiig'out of said occurrence orits results both tt and 'property. ' This release expresses a full and complete. SETTLEMENT of all liability claimed and de nied,'rcgardlese adequacy of the above consideration, and the acceptance of ihis,release shall not operate as an admission of liability on the anyone nor as an :estoppel, waiver or bar with respect to any olaim .the party or parties released may have against the undei Witness my hand and seal. . YOU ARE MAKING A FINAL SETTLEMEN (1) Dated 19 THIS IS A RELEASE: READ BEFORE SIGN I (4) (wim 'sipm ) . (Addrtu) (5) _ (wimus' Sirm.) (Add=) ASC-250R6 e?rusw "%WR the of VERIFICATION I hereby verify that the avennents made in the foregoing Petition for Approval of Minor Settlement are true and correct. I understand that false statements herein are made subject to the penalties of 18 Pa. C.S.A. 4904 relating to unswom falsification to authorities. Dated: !C- - t3 1991 Thomas J. ilcote 15'L! AY-?,, v V' z? V J` LL"? L. r: C.? Li L_ i_) 'l ll?\ I VV IN RE: THOMAS J. CHILCOTE and KATHARINE B. CHILCOTE, Parents and Natural Guardians of TIMOTHY J. CHILCOTE, A Minor, PETITIONERS IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA 97--7S94, ORDER OF COURT AND NOW, thistf-- day of January, 2000, following a hearing: (1) The petition to approve this minor's settlement in the amount of $10,000, IS GRANTED. (2) Steven Junkin, through his insurance carrier Liberty Mutual Insurance Co., shall deposit $10,000 in the highest interest bearing account at the Pennsylvania State Bank in the name of Timothy J. Chilcote, a minor, born December 1, 1985. (3) The account shall contain the following notation: "NO WITHDRAWAL CAN BE MADE PRIOR TO THE MINOR ATTAINING HIS MAJORITY WITHOUT AN ORDER OF A COURT OF COMPETENT JURISDICTION." (4) Jeffrey B. Rettig, Esquire, shall file proof of compliance with this order with the Prothonotary with a copy to be forwarded to chambers. By the Court, Jeffrey B. Rettig, Esquire For Petitioners J. :saa 14K I??i1f CFA L? ?!•.?1 ?'1 .ter ?nJtfV\1 In Re: THOMAS J. CHILCOTE and : IN THE COURT OF COMMON PLEAS KATHARINE B. CHILCOTE, CUMBERLAND COUNTY, PENNSYLVANIA Parents and Natural Guardians of TIMOTHY J. CHILCOTE, A Minor, Petitioners NO. PRAECIPE TO FILE CERTIFICATE OF DEPOSIT In accordance with the Court's Order, a copy of which is attached hereto, please file a copy of Certificate of Deposit Number 040194. Respectfully submitted, THOMAS, THOMAS & HAFER, LLP By: q- -- Je r y B. Rettig, Esqui e JAS! 11" Luuii IN RE: THOMAS J. CHILCOTE and KATHARINE B. CHILCOTE, Parents and Natural Guardians of TIMOTHY J. CHILCOTE, A Minor, PETITIONERS IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA ORDER OF COURT AND NOW, this !Y (/" day of January, 2000, following a hearing: (1) The petition to approve this minor's settlement in the amount of $10,000, IS GRANTED. (2) Steven Junkin, through his insurance carrier Liberty Mutual Insurance Co., shall deposit $10,000 in the highest interest bearing account at the Pennsylvania State Bank in the name of Timothy J. Chilcote, a minor, born December 1, 1985. (3) The account shall contain the following notation: "NO WITHDRAWAL CAN BE MADE PRIOR TO THE MINOR ATTAINING HIS MAJORITY WITHOUT AN ORDER OF A COURT OF COMPETENT JURISDICTION." (4) Jeffrey B. Rettig, Esquire, shall file proof of compliance with this order with the Prothonotary with a copy to be forwarded to chambers. By the Court, Edgar t-4B;iyley, J. Jeffrey B. Rettig, Esquire For Petitioners saa - D !:l .1?.t . ?i. ' •i'? r. -..•.. a C7j fl3iT? n n a N n CYCTOMCM SIpNATYAEICI ? cr) 2 Fe•::° `? to 9"-,? ? <? O 1 c in ..{. pp p ? yC V C-) ?Yoc°e - - Him iJ? o V V O1 cE.-SvE?S< ?N ip ? a L Z - i o:? 9 O W ur p .rryy CU?1 E3EeY^?..° ? ? O pea-?.-•-e _ _ ?p? '-, q SC<i-mG O• 7 Z H =F ?3W ? W W 0 ?m w w r ? U m J N s ° ?E5-?.r O p W M z W W W q m T J J¢W ? VI M ? < :6 Q 0 -? Uw p (''? ?S ?ry w O i-ii iF SQ III ? n S? F F> Q 00 WJ< g I == W~° Y¢j Q.„ W JW m ulh > F HER 5 . O .Ji26? 6 Ci Z. z WOtj 7 Z • z< K p? R. 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