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Home My WebLink About07-2033r Guy H. Brooks, Esquire I.D. #49672 GOLDBERG KATZMAN, P.C. 320 Market Street P.O. Box 1268 Harrisburg, PA 17108-1268 (717) 234-4161 Amy Cook and William Cook, her husband, 1907 Roxbury Court Mechanicsburg, PA 17055 Plaintiffs V. Michael J. Bechtel 506 Susquehanna Street Marysville, PA 17053 Defendant IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA CIVIL ACTION - LAW NO: 97-.203,3 a0d PRAECIPE TO ISSUE WRIT OF SUMMONS Please issue a Writ of Summons against the Defendant named above in this matter. Date: April 1 d? 5 2007 Goldberg Katzman, P.C. 5./4v- GUq. Brooks, Esquire 32arket Street P.O. Box 1268 Harrisburg, PA 17108-1268 717-234-4161 r? L ?? R7 FT, r NO C? 1' t?3 "C (Ai • Guy H. Brooks, Esquire I.D. #49672 GOLDBERG KATZMAN, P.C. 320 Market Street P.O. Box 1268 Harrisburg, PA 17108-1268 (717) 234-4161 Amy Cook and William Cook, IN THE COURT OF COMMON PLEAS her husband, CUMBERLAND COUNTY, 1907 Roxbury Court PENNSYLVANIA Mechanicsburg, PA 17055 Plaintiffs CIVIL ACTION - LAW V. NO: 0? - ?n 3r3 euj Michael J. Bechtel 506 Susquehanna Street Marysville, PA 17053 Defendant WRIT OF SUMMONS TO: Michael J. Bechtel 506 Susquehanna Street Marysville, PA 17053 YOU ARE NOTIFIED THAT THE ABOVE-NAMED PLAINTIFF HAS COMMENCED AN ACTION AGAINST YOU. Date: 1.0 L?"&j ??J' Prothonotary /?L SHERIFF'S RETURN - OUT OF COUNTY CASE NO: 2007-02033 P COMMONWEALTH OF PENNSYLVANIA: COUNTY OF CUMBERLAND COOK AMY ET AL VS BECHTEL MICHAEL J R. Thomas Kline Sheriff or Deputy Sheriff who being duly sworn according to law, says, that he made a diligent search and and inquiry for the within named DEFENDANT , to wit: BECHTEL MICHAEL J but was unable to locate Him deputized the sheriff of PERRY in his bailiwick. He therefore County, Pennsylvania, to serve the within WRIT OF SUMMONS On April 19th , 2007 , this office was in receipt of the attached return from PERRY Sheriff's Costs: Docketing 18.00 Out of County 9.00 Surcharge 10.00 Dep Perry County 33.40 Postage .78 / p1 71.18 ? ?? ??t P 04/19/2007 GOLDBERG KATZMAN Sworn and subscribe to before me this day of So answers: R. Thomas Kl' e Sheriff of Cumberland County A. D. In The Court of Common Pleas of Cumberland County, Pennsylvania Amy Cook et al vs. Michael J. Bechtel No. 07-2033 civil Now, April 12, 2007 , I, SHERIFF OF CUMBERLAND COUNTY, PA, do hereby deputize the Sheriff of _ Perry County to execute this Writ, this deputation being made at the request and risk of the Plaintiff. Sheriff of Cumberland County, PA Affidavit of Service Now, within upon at by handing to a and made known to copy of the original the contents thereof. So answers, Sheriff of Sworn and subscribed before me this day of , 20 COSTS SERVICE _ MILEAGE _ AFFIDAVIT County, PA 20 , at o'clock M. served the SHERIFF'S RETURN In the Court of Common Pleas Of the 41St Judicial District of Pennsylvania- Perry County Branch No. 2007-2033 Cumberland County Amy Cook and William Cook VS Michael J. Bechtel 506 Susquehanna St. Marysville, PA 17053 Carl E. Nace, Sheriff, who being duly sworn according to law, says that he made a diligent search and inquiry for the within named Defendant(s) to wit Michael J. Bechtel, but was unable to locate him/her in his bailiwick. He therefore returns the within Writ of Summons, for the above named Defendant(s) Michael J. Bechtel, at 506 Susquehanna St. Marysville, PA 17053, NOT FOUND. DEFENDANT HAS MOVED BACK TO CARLISLE, PA WITH HIS MOTHER. Sincerely, Sworn an subscribed to before me this day of nr 2007. a1A NOTARIAL SEAT. MARGARET F. FLIWNGER, NOTARY PUBLIC BLOOMFIELD BOR%, PERRY COUNTY MY COMMISSION EXPIRES FEB. 16 2008 Carl E. Nace Sheriff of Perry County Guy H. Brooks, Esquire r.D. #49672 GOLDBERG KATZMAN, P.C. 320 Market Street P.O. Box 1268 Harrisburg, PA 17108-1268 (717) 234-4161 Amy Cook and William Cook, her husband, 1907 Roxbury Court Mechanicsburg, PA 17055 Plaintiffs V. Michael J. Bechtel 506 Susquehanna Street Marysville, PA 17053 Defendant IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA CIVIL ACTION - LAW NO: G 7 - x033 WRIT OF SUMMONS TO: Michael J. Bechtel' 506 Susquehanna Street Marysville, PA 17053 co gv YOU ARE NOTIFIED THAT THE ABOVE-NAMED PLAINTIFF HAS COMMENCED AN ACTION AGAINST YOU. n`. Date: Prothonotary Biel TRUE COPY FROM RECORD In Testimony whir of, E h :re unto set my hand and the seal of said =5-,:;rt at Carlisle, Pa. This ...../a.. ` 1?> ... day of. .?y?......, ......... Prothonotary C- c :6 cj ? ! ,c 'J tI' Thomas J. Weber, Esquire (#58853) GOLDBERG KATZMAN, P.C. 320 Market Street P.O. Box 1268 Harrisburg, PA 17108-1268 (717) 234-4161 Amy Cook and William Cook, Plaintiffs V. Michael J. Bechtel Defendant IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA CIVIL ACTION - LAW a433 NO: 07-23TCivi1 PETITION FOR APPROVAL OF SETTLEMENT PERTAINING TO A MINOR 1. Amy and William Cook are the parents of Ethan Cook, with a date of birth of April 8, 2003. 2. On or about April 14, 2005, a motor vehicle being operated by Amy Cook, in which Ethan Cook was a passenger, was rear-ended by Michael Bechtel. 3. At the time of the accident, Ethan Cook was properly secured in a child restraint car seat and, as a result, escaped serious injury. 4. Although he was not seriously injured, the young child was obviously shaken by the accident and has displayed some fear of loud noises which, to a certain extent, persists to this day. 5. The undersigned counsel's office has represented Amy, William and Ethan Cook in pursuit of a possible recovery of damages sustained in the accident from Mr. Bechtel and/or his insurer. 6. Settlement has been reached on behalf of Amy Cook for the injuries she received as the driver of the motor vehicle. As an adult, this settlement does not require judicial approval. 7. The insurer for Michael Bechtel has offered $1,000 to resolve the claims of Ethan Cook. 8. Amy and William Cook believe that acceptance of this amount at this time is in the best interests of their child. 9. Although Ethan still has some residual fear of loud noises, it is difficult, if not impossible, to determine the direct causal connection between this and the motor vehicle accident. 10. Ethan Cook did not require medical treatment following the automobile accident. 11. Ethan Cook appears to be a well-adjusted four and a half year old and participates regularly without incident in a pre-school program. 12. Undersigned counsel is not taking any fee from the settlement for Ethan Cook, nor are they seeking reimbursement for any expenses incurred in representing his interests. As a result, if the settlement is approved, the entire $1,000 will go to the benefit of Ethan Cook. 13. As stated, Ethan's parents believe that the settlement is in his best interests. 14. If the settlement is approved, the Cooks will place the $1,000 in Ethan's existing TAP account to assist with funding his college education. WHEREFORE, Amy, William and Ethan Cook respectfully request that this Court issue an order approving the settlement of Ethan's claim against Michael Bechtel in the amount of $1,000. Respectfully submitted, BE G AN, P.C. Date: March 17, 2008 Tho J. eb Esquire (58853) Goldberg Katzman, P.C. 320 Market Street P.O. Box 1268 Harrisburg, PA 17108-1268 Phone: (717) 234-4161 Fax: (717) 234-6808 VERIFICATION I, Amy Cook, hereby acknowledge that I have read the foregoing document and that the facts stated therein are true and correct to the best of my knowledge, information and belief. I understand that any false statements herein are made subject to penalties of 18 Pa. C.S. Section 4904, relating to unsworn falsification to authorities. Date: Amy Cook VERIFICATION I, William Cook, hereby acknowledge that I have read the foregoing document and that the facts stated therein are true and correct to the best of my knowledge, information and belief. I understand that any false statements herein are made subject to penalties of 18 Pa. C.S. Section 4904, relating to unsworn falsification to authorities. Date: ?Z 0 William Cook CERTIFICATE OF SERVICE I hereby certify that I am this date serving a copy of the foregoing document upon the following via First Class Mail, which service satisfies the requirements of the Pennsylvania Rules of Civil Procedure: Michael J. Bechtel c/o Cindy Belski Claim Representative State Farm Insurance Companies Claim Central - Complex P.O. Box 142 Concordville, PA 19331-0142 GOLDBERG KATZMAN, P.C. ' jkl By: TEsquire Date: March 17, 2008 CIO 1 ' J Q l 3 CCi MAR 842008,yr(( `J Amy Cook and William Cook, IN THE COURT OF COMMON PLEAS Plaintiffs CUMBERLAND COUNTY, PENNSYLVANIA V. CIVIL ACTION - LAW 2w 3 3 Michael J. Bechtel NO: 073 Civil Defendant ORDER TO SHOW CAUSE AND NOW, this t?).ay of ??'Y1pf- , 2008, an Order to Show Cause why the Proposed Minor Settlement in the above-reference matter should not be approved. Order is returnable oZ C' days after service. A hearing on the Petition for Approval of the Minor Settlement is scheduled for the /XO-day of , 2008 at 3'30 M. in Courtroom S By the Court, Di tribution: homas J. Weber, Esquire, Goldberg Katzman, P.C., 324 Market Street, P.O. Box 1268, Harrisburg, PA 17108-1268 j.,Kichael Bechtel, c/o Cindy Belski, Claim Representative, State Farm Insurance Companies, Claim Central - Complex, P.O. Box 142, Concordville, PA 19331-0142 J r? 03? IIA t y?`t?$r`\V '?;?'s??`Y4 hJ ?4 f AMY COOK and WILLIAM COOK, IN THE COURT OF COMMON PLEAS OF Plaintiffs CUMBERLAND COUNTY, PENNSYLVANIA V. CIVIL ACTION - LAW MICHAEL J. BECHTEL, NO. 07-*@}-CIVIL Defendant OV33 IN RE: MINOR'S SETTLEMENT ORDER OF COURT AND NOW, this 12th day of June, 2008, upon consideration of the Petition for Approval of Minor's Settlement, and after hearing conducted on the petition, the settlement is approved. The proceeds shall be payable to the parents, William and Amy Cook, who shall deposit the funds in the child's Tuition Account Program account. With the approval of this settlement, any and all claims Ethan Cook has against Michael and Douglas Bechtel arising out of the motor vehicle accident that took place on or about April 14, 2005, are hereby extinguished. By the Court, M. L. Ebert, Jr., J. ZThomas J. Weber, Esquire For the Plaintiffs ./Michael Bechtel, c/o Cindy Belski, Claim Representative State Farm Insurance Companies, Claim Central - Complex P.O. Box 142 Concordville, Pa. 19331-0142 :mtf Car( ES /yta-l L CL L?14?o8 VIA VIVA ,NN3d r,t 61:01 WV 91 Nnf 001 301. O-031Y .R Thomas J. Weber, Esquire (#58853) GOLDBERG KATZMAN, P.C. 320 Market Street P.O. Box 1268 Harrisburg, PA 17108-1268 (717) 234-4161 Amy Cook and William Cook, Plaintiffs V. Michael J. Bechtel Defendant IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA CIVIL ACTION - LAW 0'1-'a 053 NO:-t7--2 3 Civil PRAECIPE TO DISCONTINUE TO THE PROTHONOTARY, Please mark the above-captioned action as discontinued with prejudice. GOLDBERG KATZMAN, P.C. 1ho By: Th J. Weber, 58853) 320 ket Street P.O. Box 1268 (717) 234-4161/Fax: 234-6808 tjw@goldbergkatzman.com Date: July 23, 2008 Attorney for Plaintiffs t CERTIFICATE OF SERVICE I hereby certify that I am this date serving a copy of the foregoing document upon the following via First Class Mail, which service satisfies the requirements of the Pennsylvania Rules of Civil Procedure: Michael J. Bechtel c/o Cindy Belski Claim Representative State Farm Insurance Companies Claim Central - Complex P.O. Box 142 Concordville, PA 13331-0142 GOLD G KATZMAN, P.C. By: Thomas eber, & ire Date: July 23, 2008 ? <: c"w ??"? -r? _ ?,, :. ?? iii - ,,, y ?, .?- ' '_ ? s r ?_ -?? = ??> p. ? ,? ??? .. !"?^ :LS `?° C-,? .'{