HomeMy WebLinkAbout03-5923 IN THE ORPHANS COURT OF
CUMBERLAND COUNTY, PENNSYLVANIA
KATHY VANHART and KENNETH : NO. o.3 -
KAUFMANN, SR., as Parents and
Natural Guardians of KENNETH
JAMES KAUFMANN, JR., a Minor
V.
MICHAEL D. & CYNTHIA L. BLESSING : CIVIL ACTION - LAW
PETITION FOR SETTLEMENT AND DISTRIBUTION
OF PROCEEDS OF A MINOR'S CLAIM
Petitioners, Kathy VanHart and Kenneth Kaufmann, Sr., as Parents and Natural
Guardians of Kenneth James Kaufmann, Jr., a Minor, by and through their attorney,
Leah B. Graft, Esquire, respectfully represent the following:
1. Petitioners, Kathy VanHart and Kenneth Kaufmann, Sr., are adult individuals with
a mailing address of P.O. Box 164, Shippensburg, Cumberland County, Pennsylvania,
and are the Parents, Natural Guardians of Kenneth James Kaufmann, Jr., a Minor,
having the date of birth of November 9, 1992 (hereinafter referred to as Minor
Petitioner).
2. Respondents, Michael and Cynthia Blessing, are adult individuals residing at 9
Cherokee Drive, Shippensburg, PA 17257.
3. On February 2, 2001, Minor Petitioner, Kenneth James Kaufmann, Jr., was
visiting his neighbors, the Blessings, located at 9 Cherokee Drive, Shippensburg,
Pennsylvania. A black and white dog, named Shotzy, bit him in the mouth area.
4. As a result of this incident, Minor Petitioner suffered injuries, including but not
limited to: 1) stitches; and 2) scarring. Minor Petitioner was treated at Chambersburg
Hospital and by a plastic surgeon, and may undergo scar revision in the future.
5. Respondents, through their insurance carrier American Bankers Insurance, have
offered to compromise Minor Petitioner's claim for the sum of $10,000.
6. Petitioners are aware that accepting the offer of settlement will result in a waiver
of their right to a jury trial against Respondents, Michael and Cynthia Blessing.
7. Petitioners believe that this offer of settlement is fair and reasonable and in Minor
Petitioner's best interests. Petitioners have fully discussed this settlement with their
counsel, Leah B. Graft, Esquire.
8. Petitioners have a contingent fee agreement with their attorney in the amount of
25% of any award or recovery made.
9. If the compromise settlement is approved, Petitioners hereby request the
following distribution:
A. $2,500.00 would be paid to Leah B. Graft, Esquire pursuant to its Twenty-Five
Percent Fee Agreement.
B. $82.05 would be paid to The Law Offices of Dale E. Anstine, PC for costs
advanced.
C. $603.05 would be paid to Lawrence & Russell, LLP for the lien payable to
Blue Cross/Blue Shield of Illinois.
D. $6,814.90 would be paid to Kathy VanHart and Kenneth Kaufmann, Sr., as
Parents and Natural Guardians of the Minor Petitioner, Kenneth James
Kaufmann, Jr., which sum is to be placed in a savings account in a federally
insured bank or savings and loan association for the sole and exclusive use
of said Minor Petitioner and said account shall not be used for any reason
without court approval and shall be distributed to the Minor upon him
attaining the age of majority.
WHEREFORE, the Petitioners respectfully request that this Honorable Court
enter an order authorizing the compromise settlement and distribution of proceeds
in accordance with the Petition terms herein above.
LAW OFFICES OF DALE E. ANSTINE, P.C.
Respectfully submitted:
Leah B. Graft, Esquire ~
Attorney ID No. 29176
Two West Market Street
P.O. Box 952
York, PA 17405
(717) 846-0606
Attorney for the Petitioners
Aug 28/2003-
Date Received Fr,/Paid To
Entry! ~,xplanation
DALE E. ANSTINE, P.C.
Client LDdger
ALL DATES
Che! G~neral
Rcpt{ Rcpts Disbs
Bld {rust
Fees Inv! A¢¢ Rcpts Disbs
2203 Y~muXfmaa (a iium=)~ i(eaneth $-.me~
01~177 v. Ct~ ~ ~ke ~[~[~ D/~: 02/22/0[
~,: ['/~.,~,C.~'~:~=,:'{ U,%~':~' :"t
~y 16/200~ ~E I~
65423 l~ 1106101101697
38,53
I UNBILLED I [ BILLED
TOTALS CRD+ RECOV FEES+ - TOTAL DISBS + FEES +
PERIOD 82.05 0.00 0.00 82.05 0.00 0.00
END DATE 82.05 0.00 O.OO 82.05 0.00 0.00
TAX - ~EIPTS - A/R ~RUST
0.00 0.00 0.00 0.00
0.00 0.00 0.00 0.00
{ U~ILLED { I BILLED
FIPJ4 TOTALS C~E+ ~V FEES+ - TOTAL DISBB + FEES +
PERIOD 82.85 0.00 0.00 02.05 0,00 0.00
END DATE 82.05 0.00 O.00 82.05 0.00 0.00
T;<~ - ~CEIPTS - A/K TRUST
0.00 0.00 O.O0 0.00
0.00 0.O0 B.O0 0.00
REPORT SELECTIONS
Report:
Layout Template:
Requested by:
Finished=
Date Rsnge: ~L DATES
Matters: 01-177
Clients: Ail
Ma~or Clients: All
Responsible Lawyer: Ail
Iatzoducing Lawyer: Ail
Assigned Lawyer: All
Type of Law: Ail
Sort by Rasp Lawyer= No
New Page for Each Lawyer: No
New Page for Each Matter: No
Totals Only: No
Consolidate Payments: No
No Activity Date: Dec 31/2199
Client Ledger
All
Elizabeth
Tuesday, August 26, 2003 at 03:06:18 PM
Firm Totals Only: No
Entries Shown ~ Billed Only: No
Entries Eho',rn ~ Disbursements: Yes
Entries Shown - Receipts: Yes
Ent£ies Shown- Trust: Yes
Entries Shown- Time or Fees: Yes
Working Lawyer: No
Incl. Matters with Retainer 8al: No
Incl. Matters with Mag Unbld Dish: No
Show Interest: No
Trust Account: All
IN THE ORPHANS COURT OF
CUMBERLAND COUNTY, PENNSYLVANIA
KATHY VANHART and KENNETH
KAUFMANN, SR., as Parents and
Natural Guardians of KENNETH
JAMES KAUFMANN, JR., a Minor
:NO._
MICHAEL D. & CYNTHIA L. BLESSING CIVIL ACTION - LAW
PETITION FOR SETTLEMENT AND DISTRIBUTION
OF PROCEEDS OF A MINOR'S CLAIM
Petitioners, Kathy VanHart and Kenneth Kaufmann, Sr., as Parents and Natural
Guardians of Kenneth James Kaufmann, Jr., a Minor, by and through their attorney,
Leah B. Graft, Esquire, respectfully represent the following:
1. Petitioners, Kathy VanHart and Kenneth Kaufmann, Sr., are adult individuals with
a mailing address of P.O. Box 164, Shippensburg, Cumberland County, Pennsylvania,
and are the Parents, Natural Guardians of Kenneth James Kaufmann, Jr., a Minor,
having the date of birth of November 9, 1992 (hereinafter referred to as Minor
Petitioner).
2. Respondents, Michael and Cynthia Blessing, are adult individuals residing at 9
Cherokee Drive, Shippensburg, PA 17257.
3. On February 2, 2001, Minor Petitioner, Kenneth James Kaufmann, Jr., was
visiting his neighbors, the Blessings, located at 9 Cherokee Drive, Shippensburg,
Pennsylvania. A black and white dog, named Shotzy, bit him in the mouth area.
4. As a result of this incident, Minor Petitioner suffered injuries, including but not
limited to: 1) stitches; and 2) scarring. Minor Petitioner was treated at Chambersburg
Hospital and by a plastic surgeon, and may undergo scar revision in the future.
5. Respondents, through their insurance carrier American Bankers Insurance, have
offered to compromise Minor Petitioner's claim for the sum of $10,000.
6. Petitioners are aware that accepting the offer of settlement will result in a waiver
of their right to a jury trial against Respondents, Michael and Cynthia Blessing.
7. Petitioners believe that this offer of settlement is fair and reasonable and in Minor
Petitioner's best interests. Petitioners have fully discussed this settlement with their
counsel, Leah B. Graft; Esquire.
8. Petitioners have a contingent fee agreement with their attorney in the amount of
25% of any award or recovery made.
9. If the compromise settlement is approved, Petitioners hereby request the
following distribution:
A. $2,500.00 would be paid to Leah B. Graft, Esquire pursuant to its Twenty-Five
Percent Fee Agreement.
B. $82.05 would be paid to The Law Offices. of Dale E. Anstine, PC for costs
advanced.
C. $603.05 would be paid to Lawrence & Russell, LLP for the lien payable to
Blue Cress/Blue Shield of Illinois.
D. $6,814.90 would be paid to Kathy VanHart and Kenneth Kaufmann, Sr., as
Parents and Natural Guardians of the Minor Petitioner, Kenneth James
Kaufmann, Jr., which sum is to be placed in a savings account in a federally
insured bank or savings and loan association for the sole and exclusive use
of said Minor Petitioner and said account shall not be used for any mason
without court approval and shall be distributed to the Minor upon him
attaining the age of majority.
WHEREFORE, the Petitioners respectfully request that this Honorable Court
enter an order authorizing the compromise settlement and distribution of proceeds
~n accordance with the Petition terms herein above.
LAW OFFICES OF DALE E. ANSTINE, P.C.
Respectfully submitted:
Leah b. Graft, Esq '-~
Attorney ID No. 29176
Two West Market Street
P.O. Box 952
York, PA 17405
(717) 846-0606
Attorney for' the Petitioners
.26/2003, DALE E. ANSTINE, F.C. Page 1
Aug
Client Ledger
;iLL DATES
Date Received F£om/?aid To
Che# General Bld Trust
Entry! Explanation Rcpt{ Rcpts Dlshs Fees Invi Acc Rcpts Disbs Balance
2203 Ra.u.f.~tan (a mino~) ~ ~ ~es
01-1~7 v. ~ & ~e ~esJl~ D/A: 02/22/01 8 - ~ B. ~f
...... *.~; ...... . ~ ~:~:~ : :~.~:.: .~:: :, ~ ~ ~ ~ ~'.'~ ~*~.*~.¥~:. ~ :~ ~ ~ ~
I ~BILLED I I BILLED I I DA2~2;CES l--
FIRM T<F~ALS CHE+ ~COV FEES+ = TOTAL DISBS + FEES + T~ - ~EIPTS = A/R T~ST
PERIOD 82.05 0.00 0.00 82.05 0.00 0.00 0.00 0.00 0.00 0.00
END DATE 82.05 0.00 0.00 82.05 0.00 0.00 0.00 0.00 0.00 0.00
REPORT SELECTIONS
Report: Client Ledger
layout Template: All
Requested by: Elizabeth
Finished: Tuesday, August 26, 2003 at 03:06:18 PM
Date Range: ALL DATES
Matters: 01-177
Clients: Ail
Major Clients: All
Responsible Lawyer: All
Introducing Lawyer: All
Assigned Lawyer: All
Type of Law: All
Sort by Rasp Lawyer: No
New Page for Each Lawyer: No
New Page for Each Matter: No
Totals Only: No
Consolidate PaymeNts: No
No Activity Date: Dec 31/2199
Firm Totals Only: No
Entries Shown - Billed Only: No
Entries Shown - Disbursements: Yes
Entries Shown - Receipts: Yes
Entries Shown - Trust: Yes
Entries Shown - Time or Fees: Yes
Working Lawyer: No
Incl. Matters with Retainer Bal: No
Incl. Matters with Neg Dnbld Disb: No
Shew Interest: No
Trust Account: All
~8/29/2003 03:34 901-844-4435 P~GE 01/01
LAWR CE & RUSSELL
September 2, 2003
VIA FACSIMILE: (717'1 845-7431
Leah Graft, Esq.
2 W. Market St.
York, PA 17401
Attn: Elizabeth Simon
Re: Kenneth Kauffman
Dear Ms. Simon:
Thank you for speaking with me regarding this matter. /ks you know, this firm represents,
BlueCross BlueShield of Illinois with respect to $603.05 in benefits paid on behalf of Kenneth
Kauffraan.
This l~tt~ confirms your client's agreement to pay our client, BlueOross BlueShield Of
Illinois $603.05 to act as full and final settlement of our clienI's lien. Please make your check
payable to BlueCross BlueShield of Illinois and forward it to me at the address noted above.
Thank you for your assistance with this matter. Please ,all me if you have any questions.
Very truly yours,
LAWRENCE & RUSSELL, LLP
Trina R. Washington
IN THE ORPHANS COURT OF
CUMBERLAND COUNTY, PENNSYLVANIA
KATHY VANHART and KENNETH : NO.
KAUFMANN, SR., as Parents and
Natural Guardians of KENNETH
JAMES KAUFMANN, JR., a Minor
V.
MICHAEL D. & CYNTHIA L. BLESSING : CIVIL ACTION - LAW
PETITION FOR SETTLEMENT AND DISTRIBUTION
OF PROCEEDS OF A MINOR'S CLAIM
Petitioners, Kathy VanHart and Kenneth Kaufmann, Sr., as Parents and Natural
Guardians of Kenneth James Kaufmann, Jr., a Minor, by and through their attorney,
Leah B. Graft, Esquire, respectfully represent the following:
1. Petitioners, Kathy VanHart and Kenneth Kaufmann, Sr., are adult individuals wit;'
a mailing address of P.O. Box 164, Shippensburg, Cumberland County, Pennsylvania,
and are the Parents, Natural Guardians of Kenneth James Kaufmann, Jr., a Minor,
having the date of birth of November 9, 1992 (hereinafter referred to as Minor-
Petitioner).
2. Respondents, Michael and Cynthia Blessing, are adult individuals residing at 9
Cherokee Drive, Shippensburg, PA 17257.
3. On February 2, 2001, Minor Petitioner, Kenneth James Kaufmann, Jr., was
visiting his neighbors, the Blessings, located at 9 Cherokee Drive, Shippensburg,
Pennsylvania. A black and white dog, named Shotzy, bit him in the mouth area.
4. As a result of this incident, Minor Petitioner suffered injuries, including but not
limited to: 1) stitches; and 2) scarring. Minor Petitioner was treated at Chambersburg
Hospital and by a plastic surgeon, and may undergo scar revision in the future.
5. Respondents, through their insurance carrier American Bankers Insurance, have
offered to compromise Minor Petitioner's claim four the sum of $10,000.
6. Petitioners are aware that accepting the offer of settlement will result in a waiver
of their right to a jury trial against Respondents, Michael and Cynthia Blessing.
7. Petitioners believe that this offer of settlement is fair and reasonable and in Minor
Petitioner's best interests. Petitioners have fully discussed this settlement with their
counsel, Leah B. Graft; Esquire.
8. Petitioners have a contingent fee agreement with their attorney in the amount of
25% of any award or recovery made.
9. If the compromise settlement is approved, Petitioners hereby request the
following distribution:
A. $2,500.00 would be paid to Leah B. Graff, Esquire pursuant to its Twenty-Five
Percent Fee Agreement.
B. $82.05 would be paid to The Law Offices of Dale E. Anstine, PC for costs
advanced.
C. $603.05 would be paid to Lawrence & Russell, LLP for the lien payable to
Blue Cross/Blue Shield of Illinois.
D. $6,814.90 would be paid to Kathy VanHart and Kenneth Kaufmann, Sr., as
Parents and Natural Guardians of the Minor Petitioner, Kenneth James
Kaufmann, Jr., which sum is to be placed in a savings account in a federally
insured bank or savings and loan association for the sole and exclusive use
of said Minor Petitioner and said account shall not be used for any reason
without court approval and shall be distributed to the Minor upon him
attaining the age of majority.
WHEREFORE, the Petitioners respectfully request that this Honorable Court
enter an order authorizing the compromise settlement and distribution of proceeds
in accordance with the Petition terms herein above.
LAW OFFICES OF DALE E. ANSTINE, P.C.
Respectfully submitted:
Leah i3. Graft, EsquTe -~..___
Attorney ID No. 29176
Two West Market Street
P.O. Box 952
York, PA 17405
(717) 846-0606
Attorney for the Petitioners
Aug 26/2003 DALE E. ANSTINE, P.C. Page 1
Client Ledger
ALL DATES
Date Maceived From/Paid To
Entry! Explanation
Chef General Bid Trust
Rcpt# Rcpts Disbs Fees Invi Acc Rcpts Disbs
Balance
2203
01-177 v.
.......... .................................................................... ...........
J UNBILLED ] [ BILLED I ] DALA2:CES I--
TOTALS CHE+ RECOV FEES+ = TOTAL DISBS+ FEES + TAX - RECEIPTS - AIR TRUST
PERIOD 82.05 0.00 0.00 82.05 0.00 0.00 0.00 0.00 0.00 0.00
END DATE 82.05 0.00 0.00 82.05 0.00 0.00 0.00 0.00 0.00 0.00
J UNBILLDD I I BILLED I I DALA2:CES
FIRM TOTALS CHE+ RECOV FEES+ = TOTAL DISES+ FEES + TAX - RECEIPTS - A/R TRUST
PERIOD 82.05 0.00 0.00 82.05 0.00 0.00 0.00 0.00 0.00 0.00
END DATE 82.05 0.00 0.00 82.05 0.00 0,00 0.00 0.00 0.00 0.00
REPORT SELECTIONS
Report:
Layout Template:
Requested by:
Finished:
Date Range: ALL DATES
Matters: 01-177
Clients: All
Major Clients: All
Responsible l~awyer: All
Introdu¢ing Imwymr: All
Assigned ~awyer: All
T)~pe of Law: All
Sort by Reap ~awyer: No
New Page for Each Lawyer: No
New Page for Each Hatter: No
Totals Only: No
Consolidate Payments: No
No Activity Date: Dec 31/2199
Client Ledger
All
Elizabeth
Tuesday, August 26, 2003 at 03:06:18 PM
Firm Totals Only: No
Entries Shown - Billed Only: No
Entries Shown - Dl~lbursements: Yes
Entries Shown - Rec:eipts: Yes
Entries Shown - Trust: Yes
Entries Shown - Tin~ or Fees: Yes
Working Lawyer: No
Incl. Matters with Retainer EXl: No
Incl. Matters with Neg Unbld Dish: No
Show Interest: No
Trust Account: All
~8/29/2083 03:34 901-844-4435 PAGE 81/81
LAWRENCE & RUSSELL
, ATTOINEY$ '
1717 - IVl~'ti3h~. Tefll't~mme 36157 · P~ 901.644,4434 - P~x 60t.844.4436
September 2, 2003
VI__A~FACSIMILE: (7171 845-7431
Leah Graft, Esq.
2 W. Market St.
York, PA 17401
Attn: Elizabeth Simon
Re: Kenneth Kauffmma
Dear Ms. Simon:
Thank you for speaking with me regarding this matter. As you know, this firm represents.
BlueCross BlueShielfl of Illinois with respect to $603.05 in benefits paid on behalf of Kenneth
Kauf'fman.
This letter confirms your client's agreement to pay o~rr client, BlueCross BlueShield Of
Illinois $603.05 to act as full end final settlement of our client's lien. Please make your cheek
payable to BlueCross Blueghield of Illinois and forward it to me at the address noted above.
Thank you for your assistance with this matter. Please oall me if you have any questions.
Very truly yours,
LAWRENCE & RUSSELL, LLP
Trina R. Washington
IN THE ORPHANS COURT OF
CUMBERLAND COUNTY, PENNSYLVANIA
KATHY VANHART and KENNETH : NO.
KAUFMANN, SR., as Parents and
Natural Guardians of KENNETH
JAMES KAUFMANN, JR., a Minor
V.
MICHAEL D. & CYNTHIA L. BLESSING CIVIL ACTION - LAW
PETITION FOR SETTLEMENT AND DISTRIBUTION
OF PROCEEDS OF A MINOR'S CLAIM
Petitioners, Kathy VanHart and Kenneth Kaufmann, Sr., as Parents and Natural
Guardians of Kenneth James Kaufmann, Jr., a Minor, by and through their attorney,
Leah B. Graft, Esquire, respectfully represent the following:
1. Petitioners, Kathy VanHart and Kenneth Kaufmann, Sr., are adult individuals with
a mailing address of P.O. Box 164, Shippensburg, Cumberland County, Pennsylvania,
and are the Parents, Natural Guardians of Kenneth James Kaufmann, Jr., a Minor,
having the date of birth of November 9, 1992 (hereinafter referred to as Minor.
Petitioner).
2. Respondents, Michael and Cynthia Blessing, are adult individuals residing at 9
Cherokee Drive, Shippensburg, PA 17257.
3. On February 2, 2001, Minor Petitioner, Kenneth James Kaufmann, Jr., was
visiting his neighbors, the Blessings, located at 9 Cherokee Drive, Shippensburg,
Pennsylvania. A black and white dog, named Shotzy, bit him in the mouth area.
4. As a result of this incident, Minor Petitioner suffered injuries, including but not
limited to: 1) stitches; and 2) scarring. Minor Petitioner was treated at Chambersburg
Hospital and by a plastic surgeon, and may undergo scar revision in the future.
5. Respondents, through their insurance carrier American Bankers Insurance, have
offered to compromise Minor Petitioner's claim for' the sum of $10,000.
6. Petitioners are aware that accepting the offer of settlement will result in a waiver
of their right to a jury trial against Respondents, Michael and Cynthia Blessing.
7. Petitioners believe that this offer of settlement is fair and reasonable and in Minor
Petitioner's best interests. Petitioners have fully discussed this settlement with their
counsel, Leah B. Graft; Esquire.
8. Petitioners have a contingent fee agreement with their attorney in the amount of
25% of any award or recovery made.
9. If the compromise settlement is approved, Petitioners hereby request the
following distribution:
A. $2,500.00 would be paid to Leah B. Graft, Esquire pursuant to its Twenty-Five
Percent Fee Agreement.
B. $82.05 would be paid to The Law Offices of Dale E. Anstine, PC for costs
advanced.
C. $603.05 would be paid to Lawrence & Russell, LLP for the lien payable to
Blue Cross/Blue Shield of Illinois.
D. $6,814.90 would be paid to Kathy VanHart and Kenneth Kaufmann, Sr., as
Parents and Natural Guardians of the Minor Petitioner, Kenneth James
Kaufmann, Jr., which sum is to be placed in a savings account in a federally
insured bank or savings and loan association for the sole and exclusive use
of said Minor Petitioner and said account shall not be used for any reason
without court approval and shall be distributed to the Minor upon him
attaining the age of majority.
W_I"IEREFORE, the Petitioners respectfully request that this Honorable Court
enter an order authorizing the compromise settlement and distribution of proceeds
in accordance with the Petition terms herein above.
LAW OFFICES OF DALE E. ANSTINE, P.C.
Respectfully. submitted:
Leah I~. Graft, Esqu~e ~
Attorney ID No. 29176
Two West Market Street
P.O. Box 952
York, PA 17405
(717) 846-0606
Attorney for the Petitioners
Aug 26/2003 DALE E. ANSTINE, P.C.
Client Ledger
'' ALL DATES
Date Eeceived From/Paid To Chef Genezal
Bld Trust
Page 1
Entryf Explanation Rcptf Rcpts Disbs Fees Invf Acc Rcpts Disbs Balance
2203 Kauffman (i mtno=), l~th Jaael
01-177 v. Cln~i, & )(il:o ~.%esaLng D/A: 02/22/01 8 - ~eah n. Graff
May ~6/2001 ~NE I~ 3e.53
108534 Procesain~ of film
TOTALS CRE+ RECOV FEES+ = TOTAL DISBS + FEES + TAX - RECEIPTS ~ A/R TRUST
PERIOD 82.05 0.00 0.00 82.05 0.00 0.00 0.00 0.00 0.00 0.00
END DATE 82.05 0.00 0.00 82.05 0.00 0.00 0.00 0.00 0.00 0.00
FIRM TOTALS CHE+ RECO¥ FEES+ = TOTAL DISBE + FEES + TAX - RECEIPTS = A/R TRUST
PERIOD 82.05 0.00 0.00 82.05 0.00 0.00 0.00 0.00 0.00 0.00
END DATE 82.05 0.00 0.00 82.05 0.00 0.00 0.00 0.00 0.00 0.00
Report:
Layout Template:
Requested by:
Finished:
Date Range: ALL DATES
Matters: 01-177
Clients: All
Major Clients: All
Responsible Lawyer: All
Introducing Lawyer: All
Assigned Lawyer: All
Type of Law: All
Sort by Resp Lawyer: No
New Page for Each Lawyer: No
New Page for Each Matter: No
Totals Only: No
Consolidate Payments: No
No Activity Date: Dec 31/2198
Client Ledger
Ail
Elizabeth
Tuesday, August 26, 2003 at 03:06:18 PM
Firm Totals Only: No
Entries Shown - Billed Only: No
Entries Show - Diabursements: Yes
Entries Shown- Receipts: Yes
Entries Show~ - Trust: Yes
Entries Shown - Ti~ or Fees: Yes
Working Lawyer: No
Incl. Matters with Retainer Bal: No
Incl. Matters with Neg Unbld Disb: No
Show Interest: No
Trust Account: All
September 2, 2003
Leah Graft, Esq.
2 W. Market St,
York, PA 17401
Attn: Elizabeth Simon
Re: Kenneth Kauffrnma
Dear Ms. Simon
Thank you for speaking with me regarding th/s matter As you know
BlueCross BlueShield of Illinois with res ee ' , th/
Kauffman. p t to $603 05: .... 's firm r~rosen,~
· - m eenerit~ paid on behalf o -"A ~,~
f K~mexn
This l~tter confirms your client's
Illinois $603.05 to act as full and fin agreement to pay our client, Blueeros,~
payable to BlueCross li~ ue ~;-,~ -,,,,,~. se.t. tlement of our clbmt' ' _ BlueShield of
S-,..,u o~nnno~s and forw..a ,.. s hem P/ease make ...... · -
Thank you for your assistance with this matter t.~ ~uul~ss noted above.
· Please call nle if you have any questions.
Very tru/y yours,
LAWRENCE & RUSSELL LLP
IN THE OI~R"~/iRIlla~COURT OF
CUMBERLAND COUNTY, PENNSYLVANIA
KATHY VANHART and KENNETH
KAUFMANN, SR., as Parents and
Natural Guardians of KENNETH
JAMES KAUFMANN JR., a Minor
MICHAEL D. & CYNTHIA L. BLESSING · CIVIL ACTION - LAW
ORDER
AND NOW, this ~A/iday of "~/~/L_ , 2003, upon presentation of
the within Petition, the Court hereby directs that a hearing on the merits take place on
the /~dayof ~ ,2003, at ~-'(:~ o'clock~.m.
in J~e~s~-ehembel~ at the Cumberland County Court House, Carlisle, Pennsylvania.
KATHY VANHART and KENNETH
KAUFMANN, SR., as Parents and
Natural Guardians of KENNETH
JAMES KAUFMANN, JR., a minor,
PETITIONERS
MICHAEL D. & CYNTHIA L. BLESSING,:
RESPONDENTS
: IN THE COURT OF COMMON PLEAS OF
: CUMBERLAND COUNTY, PENNSYLVANIA
: 03-5923 CIVIL TERM
ORDER OF COURT
day of December, 2003, IT IS ORDERED:
AND NOW, this
(1) Approval of the settlement of this minor's claim for $10,000 for Kenneth J.
Kaufmann, Jr., born November 19, 2002, I$ GRANTED.
(2) From the settlement of $10,000, a counsel fee of $2,500 and costs of
$137.55, ARE APPROVED.
(3) From the settlement $603.05 shall be paid to satisfy a lien of Blue
Cross/Blue Shield of Illinois.
(4) The net proceeds of $6,759.40 shall be placed in a federally insured interest
bearing investment in the Provident Bank, Frederick, Maryland, in the name of
Kenneth J. Kaufmann, Jr., born November 19, 2002.
(5) The account shall contain the following notation: "NO WITHDRAWAL CAN
BE MADE PRIOR TO KENNETH J. KAUFMANN, JR., BORN NOVEMBER 19, 2002,
OBTAINING HIS MAJORITY EXCEPT BY AN ORDER OF A COURT OF
COMPETENT JURISDICTION."
(6) Kathy Vanhart and Kenneth Kaufmann, Sr., as parents and natural
guardians of Kenneth J. Kaufmann, Jr., are authorized to sign any release necessary to
effectuate this settlement, and to then settle and satisfy the docket. Counsel for
plaintiff, Leah B. Graft, Esquire, shall file with the Prothonotary, and forward a copy to
this chambers, proof of compliance with this order.
,,L~eah B. Graft, Esquire
For Petitioners
:sal '/~
KATHY VANHART and KENNETH
KAUFMANN, SR., as Parents and
Natural Guardians of KENNETH
JAMES KAUFMANN, JR., a minor,
PETITIONERS
: IN THE COURT OF COMMON PLEAS OF
: CUMBERLAND COUNTY, PENNSYLVANIA
MICHAEL D. & CYNTHIA L. BLESSING,:
RESPONDENTS : 03-5923 CIVIL TERM
AND NOW, this
ORDER OF COURT
day of February, 2004, this court's order of
December 10, 2003, is amended to change the date of birth of Kenneth J. Kaufmann,
Jr., from November 19, 2002 to November 9, 1992.
Edgar B. Bayley, J.
Leah B. Graft, Esquire
For Petitioners
IN THE COURT OF COMMON PLEAS OF
CUMBERLAND COUNTY, PENNSYLVANIA
KATHY VANHART and KENNETH :
KAUFMANN, SR., as Parents and :
Natural Guardians of KENNETH JAMES :
KAUFMANN, JR., a Minor, :
NO. 03-5923
Civil Term
viICHAEL D. & CYNTHIA L. BLESSING
PRAECIPE FOR FILING CERTIFICATE OF DEPOSIT
PURSUANT TO ORDER OF DEC, EMBER 10t 2003
I'o The Prothonotary:
Please file the attached Certificate of Deposit pursuant to Judge Bayley's Order of
}ecember 10, 2003 (copy attached for your convenience).
LAW OFFICES OF DALE E. ANSTINE, P.C.
Respectfully Submitted:
Leah B. Graft, Es~
Attorney ID No. 29176
Two West Market Street
P.O. Box 952
York, PA 17405
(717) 846 - 0606
Attorney for the Plaintiff
82/28/2884 89:21 301-662-7981 PROVZDENT E;ANK PAGE 01
· Pmvidanl
BANK
60 Mo Traditional CD
CERTIFICATE OF DEPOSIT
Depositor(s):
KENNETH J KAUFMAN JR
KATHLEEN F VANHART
Owner/No Access - Minor
Guardian (Gua~tlan Papers On File)
Account #:
Certificate Amount:
Opening Date:
Maturity Date:
APY: 3.00
Authorized Signature:
Non-Negotiable
100458896
$6,759.40
03/20/2004
03/20/2009
Interest Rate: 2.96
Member FDIC
KATHY VANHART and KENNETH
KAUFMANN, SR., as Parents and
Natural Guardians of KENNETH
JAMES KAUFMANN, JR., a minor,
PETITIONERS
MICHAEL D. & CYNTHIA L. BLESSING,:
RESPONDENTS
IN THE COURT OF COMMON PLEAS OF
CUMBERLAND COUNTY, PENNSYLVANIA
: 03-5923 CIVIL TERM
ORDER OF COURT
day of December, 20,03, IT IS ORDERED:
AND NOW, this /'O
(1) Approval of the settlement of this minor's claim for $10,000 for Kenneth J.
Kaufmann, Jr., born November 19, 2002, IS GRANTED.
(2) From the settlement of $10,000, a counsel fee of $2,500 and costs of
$137.55, ARE APPROVED.
(3) From the settlement $603.05 shall be paid to satisfy a lien of Blue
Cross/Blue Shield of Illinois.
(4) The net proceeds of $6,759.40 shall be placed in a federally insured interest
bearing investment in the Provident Bank, Frederick, Maryland, in the name of
Kenneth J. Kaufmann.. Jr., born November '19, 2002.
(5) The account shall contain the following notatiion: "NO WITHDRAWAL CAN
BE MADE PRIOR TO KENNETH J. KAUFMANN, JR., BORN NOVEMBER 19, 2002,
OBTAINING HIS MAJORITY EXCEPT BY AN ORDER OF A COURT OF
COMPETENT JURISDICTION."
(6) Kathy Vanhart and Kenneth Kaufmann, Sr., as parents and natural
guardians of Kenneth J. Kaufmann, Jr., are authorized to sign any release necessary to
effectuate this settlement, and to then settle and satisfy the docket. Counsel for
plaintiff, Leah B. Graft, Esquire, shall file with the'Prothor~°tary, and forward a copy to
''order.
this chambers, proof of compliance w~th th~s
~dgar B.. Bayley, J.
Leah B. Graft, Esquire /
For Petitioners
:sal