HomeMy WebLinkAbout08-0597I
07HB-00030
LAW OFFICE OF SNYDER & DORER
214 SENATE AVENUE, SUITE 503
CAMP HILL, PA 17011
TELEPHONE NUMBER: (717) 731-0988
IN THE COURT OF COMMON PLEAS
CUMBERLAND COUNTY, PENNSYLVANIA
IN RE: SETTLEMENT OF
PERSONAL INJURY CLAIM OF
NATHAN WENDLING, A MINOR
PETITION FOR LEAVE TO COMPROMISE MINOR'S CLAIM
Pursuant to Pa.R.C.P. 2039, Nationwide Insurance Company, by and through its
attorneys, Snyder and Dorer, hereby petitions this Court to enter an Order permitting
I settlement in compromise of this action, and in support thereof, avers the following:
1. Petitioners, Frederic Wendling and Lauretta Wendling, are adult individuals
residing at 150 Yellow Breach, Camp Hill, Pennsylvania 17011. They are the parents and
natural guardians of Nathan Wendling, a minor, who was born on October 1, 1994.
2. Petitioner, Nationwide Mutual Insurance Company (hereinafter "Nationwide"),
is a corporation organized and existing under the laws of the State of Ohio and having its
principal place of business in Columbus, Ohio, being duly authorized to conduct business in
the Commonwealth of Pennsylvania at 1000 Nationwide Drive, Harrisburg, Pennsylvania.
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3. Respondents, Patricia Klinger and Daniel Klinger, are adult individuals residing
at 22 Cedar Cliff Drive, Camp Hill, Pennsylvania 17011.
4. On August 3, 2006, Petitioners' son, Nathan Wendling, who was eleven years
old at the time, was involved in an accident at the home of Respondents.
5. The accident occurred when Patricia Klinger was backing her vehicle out of the
driveway and struck Petitioner Wendling' s parked vehicle as they were preparing to leave
Respondents' home. At the time, Nathan Wendling was holding a hand-crafted boat made of
tree branches, one of which is believed to have struck the minor' s forehead upon the impact
of Respondent' s vehicle into Petitioners' vehicle.
6. As a result of the collision, Nathan Wendling was evaluated on August 3, 2006
and August 8, 2006 by his pediatrician at Darowish and Associates at 895 South Arlington
Avenue, Harrisburg, Pennsylvania 17109. He had a small laceration midway between his
eyebrows which has gone on to healing (See medical records and photo attached as Exhibit
GL AN
7. Nathan Wendling has now returned to all normal activities.
8. No medical expenses were incurred by Frederic Wendling and Lauretta
Wendling on behalf of Nathan Wendling as a result of the injuries sustained in the August 3,
2006 accident.
9. No known unpaid or out-of-pocket medical expenses exist.
10. No additional medical treatment is anticipated for Nathan Wendling as a result
of injuries sustained in the August 3, 2006 accident.
11. At the time of the accident, Patricia and Daniel Klinger had automobile
insurance coverage through Nationwide.
12. The parties have negotiated a settlement of the bodily injury claim in the amount
of five thousand nine-hundred forty-three dollars and 86/100 ($5,943.86) to be paid in a
guaranteed lump sum payment in accordance with Paragraph III A. of the Release and
Settlement Agreement attached hereto as Exhibit B.
13. Frederic Wendling and Lauretta Wendling, as parents and natural guardians of
Nathan Wendling, believe that their son has made a complete and full recovery from any and
all injuries sustained in this incident, and will not require any additional medical treatment.
(See Affidavit attached as Exhibit " C".)
14. Frederic Wendling and Lauretta Wendling join the Petition and approve of the
proposed settlement because, under the circumstances, they consider it fair and reasonable
compensation for minor Nathan Wendling and the injuries he sustained as a result of this
incident. (See Exhibit " D".)
15. Under the proposed settlement, Nathan Wendling will receive the sum of
$5,943.86 on or about October 1, 2012, at which time he reaches his majority.
WHEREFORE, Petitioner requests that this Honorable Court enter an Order approving
the settlement in compromise and ordering distribution as set forth in the attached Order.
SNYDER & DORER
By:
JoAnne nzel, Esquire
Attorney Nationwide Mutual Insurance Company
and Patricia and Daniel Klinger
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RELEASE AND SETTLEMENT AGREEMENT
This Release and Settlement Agreement ("Agreement") is made and entered into among
Nathan Wendling, a minor, by his parents and natural guardians, Frederic Wendling and Lauretta
Wendling, Frederic Wendling and Lauretta Wendling, individually; Daniel E. Klinger and Patricia
Klinger, individually and as husband and wife; and Nationwide Mutual Insurance Company ("the
Parties"). The "Claimant" shall collectively mean Nathan Wendling, a minor, by his parents and
natural guardians, Frederic Wendling and Lauretta Wendling, Frederic Wendling and Lauretta
Wendling, individually, their respective heirs, executors, administrators, personal representatives,
successors and assigns; the "Insured" shall collectively mean Daniel E. Klinger and Patricia
Klinger, individually and as husband and wife; and the "Insurance Company" shall mean
Nationwide Mutual Insurance Company.
1. RECITALS
A. On or about August 3, 2006, at or near 22 Cedar Cliff Drive, Camp Hill, Cumberland
County, Pennsylvania, Nathan Wendling claims to have sustained physical injuries as a result of
the alleged conduct of the Insured (the "Incident"). In connection with the Incident, the Claimant
has asserted a claim against the Insured based upon tort or tort type claims.
B. The Insurance Company and the Insured have entered into a liability insurance contract
which provides that the Insurance Company shall defend the Insured against any claim or suit for
damages arising from the Incident, has authority to settle any such claim or suit on behalf of and as
agent for the Insured, and shall insure the Insured for such liability subject to the limits set forth in
the contract.
C. The Parties desire to enter into this Agreement to provide, among other things, for
considerations in full settlement and discharge of all claims and actions of the Claimant for
damages which allegedly arose out of or due to the Incident, on the terms and conditions set forth
in this Agreement.
NOW, THEREFORE, it is agreed as follows:
II. RELEASE
A. Release and Discharge. In consideration of the promise to make the periodic payment
referred to in Paragraph III.A. ("Periodic Payment"), the Claimant hereby completely releases and
forever discharges the Insured, the Insurance Company, and any and all other persons, firms, or
corporations from any and all past, present, or future claims, demands, actions, damages, costs,
expenses, loss of services, and causes of action of any kind or character, whether based on tort,
contract, or other theory of recovery, whether known or unknown, which have arisen in the past or
which may arise in the future, whether directly or indirectly, caused by, connected with or resulting
from the Incident. This release and discharge shall be a fully binding and complete settlement
among all Parties to this Agreement, and their heirs, assigns, and successors.
The Claimant acknowledges and agrees that this release and discharge is a general
release. The Claimant expressly waives and assumes the risk of any and all claims for damages
and expenses which exist as of this date, but of which the Claimant does not know or suspect to
exist, whether through ignorance, oversight, error, negligence, or otherwise, and which, if known,
would materially affect the Claimant's decision to enter into this Agreement. The Claimant further
agrees that the Claimant has accepted the considerations set forth in Paragraphs III. A. as a
complete compromise of matters involving disputed issues of law and fact. The Claimant assumes
the risk that the facts or law may be other than the Claimant believes. It is understood and agreed
to by the Parties that this settlement is a compromise of a doubtful and disputed claim, and the
payment is not to be construed as an admission of liability on the part of the Insured, by whom
liability is expressly denied.
B. Inluries Known and Unknown. The Claimant fully understands that the Claimant may
have suffered personal injuries that are unknown to the Claimant at present and that unknown
complications of present known injuries may arise, develop or be discovered in the future,
including, but not limited to, subsequent death or disability. The Claimant acknowledges that the
consideration received under this Agreement is intended to and does release and discharge the
Insured and the Insurance Company from any claims for, or consequences arising from, the
injuries which allegedly arose from the Incident; and the Claimant hereby waives any rights to
assert in the future any claims not now known or suspected even though, if such claims were
known, such knowledge would materially affect the terms of this Agreement.
C. Parties Released. This release and discharge shall also apply to the Insured's and the
Insurance Company's past, present, and future officers, directors, stockholders, attorneys, agents,
servants, representatives, employees, subsidiaries, affiliates, reinsurers, partners, predecessors
and successors in interest, heirs, executors, personal representatives, and assigns and all other
persons, firms or corporations with whom any of the former have been, are now, or may hereafter
be affiliated.
Ill. PAYMENT TO CLAIMANT PAYEE AND/OR BENEFICIARY
A. Periodic Payment. The Insurance Company, on behalf of the Insured, agrees to pay
or cause to be paid the following Periodic Payment:
(1) To Nathan Wendling ("Payee"), the following guaranteed lump sum payment:
Five Thousand Nine Hundred Forty Three and 86/100 ($5,943.86) on or about
October 1, 2012.
(2) Should Nathan Wendling die before October 1, 2012, then any remaining guaranteed
Periodic Payment set forth in Subparagraph III.A.(1) shall instead be paid, subject to the
provisions of Subparagraph III.A.(3) below, as they become due, to the estate of Nathan
Wendling ('Beneficiary"), with the last Periodic Payment to be made on or about
October 1, 2012.
(3) The Payee shall have the right, after reaching the age of majority, to submit a request
to change the Beneficiary by filing a written request with the owner of the Annuity Contract.
The change will be effective when approved by both the owner of the Annuity Contract and
the Annuity Issuer. Any change in the Beneficiary shall not in any way affect or alter any of
the provisions of this Agreement.
IV. ASSIGNMENT AND FUNDING OF PERIODIC PAYMENT OBLIGATION
A. Assignment of Obligation. The Parties understand and agree that the Insurance
Company may assign its duties and obligations to make such future Periodic Payment to Hartford
Comprehensive Employee Benefit Service Company ("Assignee") pursuant to a "Qualified
Assignment and Release," within the meaning of Section 130(c) of the Internal Revenue Code of
1986, as amended, attached as Exhibit A. When the Periodic Payment obligation is assigned to
Hartford Comprehensive Employee Benefit Service Company, Hartford Life Insurance Company
and Hartford Life, Inc. have represented that they will provide written guarantees of such obligation.
Such assignment is accepted by the Claimant without right of rejection and in full discharge and
release of the duties and obligations of the Insurance Company and all Parties released by this
Agreement with respect to such Periodic Payment. Upon such assignment, it is understood and
agreed by and between the Parties that the Assignee shall make said Periodic Payment directly to
the respective Payee and/or Beneficiary designated in Subparagraphs III.A.(1) and (2), and that the
Payee shall submit any request to change the Beneficiary directly to the Assignee.
The Parties expressly understand and agree that, with the Insurance Company's assignment
of the duties and obligations to make such Periodic Payment to Hartford Comprehensive Employee
Benefit Service Company pursuant to this Agreement, all of the duties and responsibilities
otherwise imposed upon the Insurance Company by this Agreement with respect to such Periodic
Payment shall cease, and instead such obligation shall be binding solely upon Hartford
Comprehensive Employee Benefit Service Company. The Parties further understand and agree
that when the assignment is made, the Insurance Company shall be released from all obligations
to make such Periodic Payment and Hartford Comprehensive Employee Benefit Service Company
shall at all times be directly and solely responsible for, and shall receive credit for, the Periodic
Payment, and that when the assignment is made, Hartford Comprehensive Employee Benefit
Service Company assumes the duties and responsibilities of the Insurance Company with respect
to such Periodic Payment.
B. Annuity Funding The Parties understand and agree that the Assignee may fund its
obligation to make the Periodic Payment by purchasing an annuity contract (the "Annuity Contract")
from Hartford Life Insurance Company (the "Annuity Issuer"). If such Annuity Contract is
purchased, the Assignee shall be the owner of the Annuity Contract and shall have and retain all
rights of ownership in the Annuity Contract.
For its own convenience, the Assignee may direct the Annuity Issuer to make the Periodic
Payment directly to the respective Payees and/or Beneficiaries designated in Paragraph III.A.
Each Payee and Beneficiary designated in Paragraph III.A. shall be responsible for maintaining
his/her current mailing address with the Annuity Issuer.
The obligation assumed by the Assignee to make each Periodic Payment shall be fully
discharged upon the mailing of a valid check or electronic funds transfer in the amount of such
payment on or before the due date to the last address on record for the Payee or Beneficiary with
the Annuity Issuer. If the Payee or Beneficiary notifies the Assignee that any check or electronic
funds transfer was not received, the Assignee shall direct the Annuity Issuer to initiate a stop
payment action and, upon confirmation that such check was not previously negotiated or electronic
funds transfer deposited, shall have the Annuity Issuer process a replacement payment.
C. Status of Claimant Payees and Beneficiaries. The Claimant, each Payee and each
Beneficiary, as applicable, shall at all times remain a general creditor of the Assignee and shall
have no rights in the Annuity Contract nor in any other assets of the Assignee. The Assignee shall
not be required to set aside sufficient assets or secure its obligation to the Claimant, each Payee,
or each Beneficiary, in any manner whatsoever.
V. NO CHANGES IN PERIODIC PAYMENT
The Claimant acknowledges and agrees that all, some, or any part of the Periodic Payment
cannot be, and may otherwise be prohibited or restricted under applicable law from being
accelerated, commuted, transferred, deferred, increased or decreased by the Claimant or by any
Payee or Beneficiary and that the Claimant or any Payee or Beneficiary shall not have the power to
sell, mortgage, encumber, or otherwise anticipate all, some, or any part of the Periodic Payment by
assignment or otherwise. Any transfer of the Periodic Payment by the Claimant may subject the
Claimant to serious adverse tax consequences.
VI. ENTIRE AGREEMENT
This Agreement contains the entire agreement between the Claimant, the Insured, and the
Insurance Company with regard to the matters set forth in it. There are no other understandings or
agreements, verbal or otherwise, in relation to the Agreement, between the Parties except as
expressly set forth in it.
This Agreement is intended to conform with the requirements of Internal Revenue Code
Sections 104(a)(2) and 130. All provisions of this Agreement should be construed in a manner so
as to effectuate that intent.
VII. READING OF AGREEMENT
In entering into this Agreement, the Claimant represents that the Claimant has completely
read all of its terms and that such terms are fully understood and voluntarily accepted by the
Claimant.
VIII. FUTURE COOPERATION
All Parties agree to cooperate fully, to execute any and all supplementary documents, and to
take all additional actions that may be necessary or appropriate to give full force and effect to the
terms and intent of this Agreement which are not inconsistent with its terms.
IX. DRAFTING OF DOCUMENT AND RELIANCE BY CLAIMANT
This Agreement has been negotiated by the respective Parties. The Parties to this
Agreement contemplate and intend that the payment set forth in Section III constitute damages
received on account of personal injuries or sickness, arising from the Incident, within the meaning
of Section 104(a)(2) of the Internal Revenue Code of 1986, as amended. However, the Claimant
warrants, represents, and agrees that the Claimant is not relying on the advice of the Insured, the
Insurance Company, anyone associated with them, including their attorneys and the insurance
broker placing the Annuity Contract, as to the legal and income tax or other consequences of any
kind arising out of this Agreement. Accordingly, the Claimant hereby releases and holds harmless
the Insured, the Insurance Company, and any and all counsel or consultants for the Insured and
the Insurance Company from any claim, cause of action, or other rights of any kind which the
Claimant may assert because the legal, income tax or other consequences of this Agreement are
other than those anticipated by the Claimant.
The Parties signing this Agreement, and each of them, warrant and represent that no
promise, inducement or agreement not expressed in this Agreement has been made to them and
that this Agreement constitutes the entire agreement between the Parties and that the terms of this
Agreement are contractual and not mere recitals.
The Claimant represents and agrees that the Claimant has read the Agreement and fully
understands it, and is aware of the propriety and legal effect of executing it, and neither the
Agreement nor the compromise and settlement recited in it were induced by fraud, coercion,
compulsion or mistake, nor is this Agreement nor the compromise and settlement made in reliance
upon any statement or representation of any of the Parties released by this Agreement, or their
representatives, agents or attorneys.
X. WARRANTY OF CAPACITY TO EXECUTE AGREEMENT
The Claimant represents and warrants that no other person or entity has, or has had, any
interest in the claims, demands, obligations, or causes of action referred to in this Agreement, and
that the Claimant has the sole right and exclusive authority to execute this Agreement and receive
the sums specified in it and that the Claimant has not sold, assigned, transferred, conveyed or
otherwise disposed of any of the claims, demands, obligations or causes of action referred to in this
Agreement.
XI. COURT APPROVAL
The Parties agree that the Claimant will file petitions for all necessary court approvals, that all
such petitions and orders shall be in a form satisfactory to all Parties, and that this Agreement will
not be effective until such approvals have been obtained.
XII. CONTROLLING LAW
This Agreement shall be construed and interpreted in accordance with the laws of the
Commonwealth of Pennsylvania.
XIII. SIGNATURES
This Agreement may be executed in counterparts, each of which shall be deemed to be an
original and all of which shall be deemed to constitute one and the same document.
Dated: /"-3-Gt
e ericeric Wendling, individually, and as parent and
natural guardian of Nathan Wendling, a minor, Claimant
Dated: d
Lauretta Wendling, indiv' Ily, and as parent and natural
guardian of Nathan Wending, a minor, Claimant
Dated:
Duly Authorized Representative for
Nationwide Mutual Insurance Company
APPLICABLE TO PENNSYLVANIA ONLY:
For your protection, Pennsylvania requires the following to appear on this form: Any person who
knowingly and with intent to defraud any insurance company or other person files an application for
insurance or statement of claim containing any materially false information or conceals for the
purpose of misleading, information concerning any fact material thereto commits a fraudulent
insurance act, which is a crime and subjects such person to criminal and civil penalties.
Exhibit A
Uniform Qualified Assignment and Release
"Claimant" Nathan Wendling, a minor, by his parents and natural guardians, Frederic Wendling and Lauretta
Wendling
"Assignor" Nationwide Mutual Insurance Company
"Assignee" Hartford Comprehensive Employee Benefit Service Company
"Annuity Issuer" Hartford Life Insurance Company
"Effective Date"
This Agreement is made and entered into by and
between the parties hereto as of the Effective Date
with reference to the following facts:
A. Claimant has executed a settlement agreement or
release dated , 2007 (the
"Settlement Agreement") that provides for the
Assignor to make certain periodic payments to or
for the benefit of the Claimant as stated in
Addendum No. 1 (the "Periodic Payments"); and
B. The parties desire to effect a "qualified
assignment" within the meaning and subject to
the conditions of Section 130(c) of the Internal
Revenue Code of 1986 (the "Code").
NOW, THEREFORE, in consideration of the foregoing
and other good and valuable consideration, the
parties agree as follows:
1. The Assignor hereby assigns and the Assignee
hereby assumes all of the Assignor's liability to
make the Periodic Payments. The Assignee
assumes no liability to make any payment not
specified in Addendum No. 1.
2. The Periodic Payments constitute damages on
account of personal injury or sickness in a case
involving physical injury or physical sickness
within the meaning of Sections 104(a)(2) and
130(c) of the Code.
4. The obligation assumed by Assignee with respect
to any required payment shall be discharged
upon the mailing on or before the due date of a
valid check in the amount specified to the
address of record.
5. This Agreement shall be governed by and
interpreted in accordance with the laws of the
Commonwealth of Pennsylvania.
6. The Assignee may fund the Periodic Payments by
purchasing a "qualified funding asset" within the
meaning of Section 130(d) of the Code in the form
of an annuity contract issued by the Annuity
Issuer. All rights of ownership and control of
such annuity contract shall be and remain vested
in the Assignee exclusively.
7. The Assignee may have the Annuity Issuer send
payments under any "qualified funding asset"
purchased hereunder directly to the payee(s)
specified in Addendum No. 1. Such direction of
payments shall be solely for the Assignee's
convenience and shall not provide the Claimant
or any payee with any rights of ownership or
control over the "qualified funding asset" or
against the Annuity Issuer.
8. Assignee's liability to make the Periodic
Payments shall continue without diminution
regardless of any bankruptcy or insolvency of the
Assignor.
3. The Assignee's liability to make the Periodic
Payments is no greater than that of the Assignor
immediately preceding this Agreement. Assignee
is not required to set aside specific assets to
secure the Periodic Payments. The Claimant has
no rights against the Assignee greater than a
general creditor. None of the Periodic Payments
may be accelerated, deferred, increased or
decreased and may not be anticipated, sold,
assigned or encumbered.
9. In the event the Settlement Agreement is declared
terminated by a court of law or in the event that
Section 130(c) of the Code has not been satisfied,
this Agreement shall terminate. The Assignee
shall then assign ownership of any "qualified
funding asset" purchased hereunder to Assignor,
and Assignee's liability for the Periodic Payments
shall terminate.
10. This Agreement shall be binding upon the 11. The Claimant hereby accepts Assignee's
respective representatives, heirs, successors assumption of all liability for the Periodic
and assigns of the Claimant, the Assignor and Payments and hereby releases the Assignor
the Assignee and upon any person or entity that from all liability for the Periodic Payments.
may assert any right hereunder or to any of the
Periodic Payments.
Assignor: Nationwide Mutual Insurance Company
By:
Authorized Representative
Title
Claimant:
Frederic ndling, as parent and natural guardian of
Nathan Wendling, a minor
Approved as to Form and Content:
Assignee: Hartford Comprehensive Employee Benefit
Service Company
By:
Authorized Representative
Title
Claimant
Lauretta endling, as parent an atural guardian of
Nathan Wendling, a minor
By: N/A
Claimant's Attorney
Addendum No.1
Description of Periodic Payments
The following Periodic Payment:
(1) To Nathan Wendling ("Payee"), the following guaranteed lump sum payment:
Five Thousand Nine Hundred Forty Three and 86/100 (;5,943.86) on or about October 1, 2012.
(2) Should Nathan Wendling die before October 1, 2012, then any remaining guaranteed Periodic Payment
set forth in paragraph (1) shall Instead be paid, subject to the provisions of paragraph (3) below, as they
become due, to the estate of Nathan Wendling ("Beneficiary'), with the last Periodic Payment to be made
on or about October 1, 2012.
(3) The Payee shall have the right, after reaching the age of majority, to submit a request to change the
Beneficiary by filing a written request with the owner of the Annuity Contract. The change will be effective
when approved by both the owner of the Annuity Contract and the Annuity Issuer. Any change In the
Beneficiary shall not in any way affect or alter any of the provisions of this Agreement.
Initials
Claimant:
Frederic WeLO"K91--
Assianor:
Nationwide
Assignee:
Hartford
Claimant: % u-)
Lauretta Wendftg
Fxb?b? F C
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M s
VIT
COMMONWEALTH OF PENNSYLVANIA
SS
COUNTY OF CUMBERLAND
Frederic Wendling and Lauretta Wendling, parents and natural guardians
of Nathan Wendling, a minor, are over twenty-one (21) years of age, and being
duly sworn according to law depose and say:
1. We hereby understand and agree that Nathan Wendling has
recovered from his injuries sustained in the accident of August 3, 2006.
2. That we read all of the foregoing and fully understand same and
affix our signatures hereto under oath as a free, voluntary, and uncoerced act and
deed.
3. We approve of the proposed settlement because, under the
circumstances, we consider it fair and reasonable compensation for our son,
Nathan Wendling.
4. It is further understood and agreed that, once the Court has
approved the settlement as outlined in this petition, no further claim can be made
against Nationwide Insurance Company or Patricia Klinger or Daniel Klinger for
any of the injuries sustained by minor, Nathan Wendling, whether now known or
unknown, including any and all claim for past and/or future medical expenses.
j
VIT
10 - .
Frederic Wendling, parent and natural guardian of minor plaintiff, Nathan
Wendling
Date:
Lauretta Wendling, pared and natural guardian of minor plaintiff, Nathan
Wendling
Date: VtIOC(
Sworn to and Su
Before me this-4
Notarial Seal
Stan ey S. Snyder, Notary Public
Londonderry Twp., Dauphin County 2
My Commission Expires Sept. 30, 2010
Member, Pennsylvania Association of Notaries
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1 07HB-00030
LAW OFFICE OF SNYDER & DORER
214 SENATE AVENUE, SUITE 503
CAMP HILL, PA 17011
TELEPHONE NUMBER: (717) 731-0988
IN THE COURT OF COMMON PLEAS
CUMBERLAND COUNTY, PENNSYLVANIA
IN RE: SETTLEMENT OF
PERSONAL INJURY CLAIM OF
NATHAN WENDLING
OINDER IN
JAN - ? 2001
We, Frederic Wendling and Lauretta Wendling, parents and natural
guardians of Nathan Wendling, a minor, do hereby join in the Petition of
Nationwide Insurance Company for Court Approval of Minor's
Settlement/Compromise.
Free c endling, parent and natural guardian of minor plaintiff, Nathan
Wendling
Sate: / 3?-O??j
Lauretta Wendling,
Wendling
and natural guardian of minor plaintiff, Nathan
E)ate: ! ?Vd
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r 11 P
TION
We, Frederic Wendling and Lauretta Wendling, verify that we are the
parents and natural guardians of the minor, Nathan Wendling, and we are the
Joint Petitioners in this action. We hereby verify that the statements made in the
foregoing Petition for Leave to Compromise Minor's Action are true and correct
to the best of our knowledge, information and belief. We understand that false
statements herein are made subject to the penalties of 18 Pa. C.S. Section 4904
relating to unsworn falsification to authorities.
rederic Wendling
DATE: J-?Q Q?
Lauretta Wendling
DATE:- -
-4Z?
IN RE:
SETTLEMENT OF
PERSONAL INJURY CLAIM OF
NATHAN WENDLING
IN THE COURT OF COMMON PLEAS OF
CUMBERLAND COUNTY, PENNSYLVANIA
08-0597 CIVIL
IN RE: PRELIMINARY DECREE - HEARING SET FOR MINORS COMPROMISE
ORDER OF COURT
AND NOW, this 1St day of February, 2008, upon consideration of the Petition for
Minor's Compromise of Nathan Wendling, by and through his parents and natural guardians,
Frederic Wendling and Lauretta Wendling, a hearing is hereby set for Friday, April 11, 2008 at
10:00 a.m. in Courtroom No. 5 of the Cumberland County Courthouse, Carlisle, Pennsylvania
at which time testimony in support of the minor's compromise shall be produced.
IT IS FURTHER ORDERED AND DIRECTED that the minor, Nathan Wendling, shall be
present for this hearing.
By the Court, -? ?A
'v`
M. L. Ebert, Jr., J.
Anne E. Kinzel, Esquire
Attorney for Nationwide Mutual Insurance Company
?`rederic and Lauretta Wendling
[/Parents
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07HB-00030
LAW OFFICE OF SNYDER & DORER
214 SENATE AVENUE, SUITE 503
CAMP HILL, PA 17011
TELEPHONE NUMBER: (717) 731-0988
IN THE COURT OF COMMON PLEAS
CUMBERLAND COUNTY, PENNSYLVANIA
IN RE: SETTLEMENT OF
PERSONAL INJURY CLAIM OF
NATHAN WENDLING
of-547
AND NOW, this it day of ADc?? , 2008 upon
consideration of the Petition for Leave to Compromise Minor's Action and after hearing,
it is hereby ORDERED and DECREED that the proposed settlement in the total amount
of Five Thousand Nine Hundred Forty-Three Dollars and .86/100 ($5,943.86) is
approved and distribution is to be made as follows:
Total Settlement: $5,943.86
TO: Nathan Wendling, a minor, to be paid to him on or about October
1, 2012 upon reaching his majority and in accordance with the
terms and conditions of the Release and Settlement Agreement
attached hereto and incorporated herein by reference.
$5,943.86
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BY THE COURT:
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