HomeMy WebLinkAbout01-6808LISA E. MARTIN,
JOHN N. WALTERS and MARGARET
T. WALTERS, individually and as Parents and :CUMBERLAND COUNTY,
NaturalGuardians of DANIEL WALTERS, a Minor, :PENNSYLVANIA
Petitioners :
v. :NO. Ot --
:CIVIL ACTION - LAW
Respondent :
:IN THE COURT OF COMMON Pl ~EAS
PETITION FOR APPROVAL OF COMPROMISE SETTLEMENT
AND DISTRIBUTION OF PROCEEDS OF A MINOR'S COMPROMISE
AND NOW, come Petitioners, JOHN N. WALTERS. and MARGARET T. WALTERS,
individually and as parents and natural guardians of DANIEL WALTERS, a minor, and file this
Petition to Compromise Action and for approval and distribution of settlement proceeds and aver
the following in support thereof:
1. Petitioners JOHN N. WALTERS and MARGARET T. WALTERS (hereinafter
"Petitioners") are adult individuals who currently reside at 100 Byron Nelson
Circle, Etters, Pennsylvania, 17319.
2. Petitioners are the parents and natural guardians of DANIEL WALTERS, a
minor, (hereinafter "Minor") who currently resides with Petitioners at the above
address.
o
o
°
Minor's date of birth is May 1, 1986.
Respondent LISA E. MARTIN (hereinafter "Respondent") is an adult individual
who currently resides at 116 Bungalow Road, Enola, Pennsylvania, 17025.
This case arises from an automobile accident on November 15, 1998 wherein the
vehicle of Respondent collided with that in which the Minor was a passenger.
As a result of the accident, Minor was taken to Holy Spirit Hospital for evaluation
at which time he was diagnosed with a cervical strain. A copy of the Emergency
Room report is attached hereto as Exhibit "A".
Minor had conservative follow-up treatment consisting of pain medication and
rest.
Respondent was insured under an auto policy issued by Nationwide Insurance
Company (hereinafter "Nationwide"), an insurance company licensed to transact
business in the Commonwealth of Pennsylvania, with a principal place of
business at 1000 Nationwide Drive, Harrisburg, Pennsylvania, 17112.
To date, Minor's medical bills have been paid by USAA.
Petitioners have made a careful and diligent inquiry and investigation to ascertain
the facts surrounding the accident, the responsibility of therefore and the nature,
extent and seriousness of Minor's injuries.
11. As evidenced by that attached hereto as exhibit "B", the Minor's treating
physician has opined that the Minor has obtained maximum medical improvement
without the need for further treatment.
12. Nationwide has offered to compromise this claim for the mount of Five
Thousand Three Hundred Dollars ($5,300.00) of which One Thousand Fifty
Dollars ($1,050.00) is to be paid to Margaret T. Walters for out-of-pocket
expenses incurred.
13. Petitioners believe that this compromise with Nationwide is fair and in the best
interest of Minor.
14. Nationwide requests that Petitioners give a release in the form attached hereto as
Exhibit "C".
15. Said compromise is in accordance with Pa.R.C.P. 2039.
16. Petitioners intend to deposit said proceeds of Minor's settlement in a trust account
at Members First Federal Credit Union, a banking institution insured by the FDIC.
17. Proof of deposit shall be filed with the Court.
WHEREFORE, Petitioners request that this Honorable Court enter an Order authorizing
settlement in accordance with the aforementioned terms, and that Petitioners, individually and as
parents and natural guardians of Minor Petitioner, may execute a general release in favor of
Nationwide Insurance Company and its insured, LISA E. MARTIN.
Respectfully submitted,
JAMES, SMITH, DURKIN & CONNELLY LLP
/~~, ESQUIRE
Attorney I.D. ~29563
]AP, ED W. HANDLEMAN, ESQUIRE
Attorney I.D. #82629
P.O. Box 650
Hershey, PA 17033-0650
(717) 533-3280
Attorney for Petitioners
DATE
DATE
JOHN N. WALTERS, Individually and
as Parent and Natural Guardian of
DANIEL WALTERS, a minor
as Parent and Natural Guardian of
DANIEL WALTERS, a minor
VERIFICATION
The undersigned, JOHN N. WALTERS, Individually and as Parent and Natural Guardian of
DANIEL WALTERS, a minor, hereby verifies that the facts set forth in the Petition for Approval of
Compromise Settlement and Distribution of Proce2xts of a Minor's Compromise are tree and correct
to the best of his knowledge, information and belief and further states that false statements herein
are made subject to the penalties of 18 Pa.C.S. Section 4904 relating to unswom falsification to
authorities.
JOHN N. WALTERS
VERIFICATION
The undersigned, MARGARET T. WALTERS, Individually and as Parent and Natural
Guardian of DANIEL WALTERS, a minor, hereby verifies that the facts set forth in the Petition for
Approval of Compromise Settlement and Distribution of Proceeds of a Minor's Compromise are
tree and correct to the best of her knowledge, infom~ation and belief and further states that false
statements herein are made subject to the penalties of 18 Pa.C.S. Section 4904 relating to unswom
falsification to authorities.
Exhibit A
CC
HPI
PMH
AI.,LERGIES
SH/FH
ROS
CONSTITUIT1ONAL
EYES
ENT
NECK
LUNGS
CHEST
CARDIAC
Gl]ABDOMEN
SKIN
ADM, DATE: 11115/98
Thc patient ,s a 12-year-old white male who presents after a motor vehicle accident.
The patient wa~ a restrained passenger ,n the front seat, Complains of para in h,s
r,ght and left clawcle areas and right and left'dlac crest and lower cervical, upper
thoracic vertebrae, cervical area at about the level of TI, T2. Denies any other
specific complaints.
Nil,
Nil.
Negative.
The patient demes any head injury, loss of consciousness, blurred vision or vomiting
pHYSICAL EXAMINATION
The patient is a well,developed, well.nourished white male m no acute d~stress.
Temperature 98.2° Fahrenheit, pulse 69, resp~rations 18, blood pressure 130/68.
Conjunc~vae w~thoul discharge or mlect~on. Lids w~thout lesions. PERRL.
Ears - Tympanic membraneS without perforation, mjeet~on or bulging.
Mouth - Lips, teeth and gums normal
Throat - Oropharynx w~thout lesions or exudate. Airway patent.
Nose - Nasal mu¢~xsa normal.
SinuseS- No sinus tenderness.
The pataent ,~ tender on palpation over the level of about TI, T2, mostly parasp,mous
area, but also m the mldline.
Normal reSpiratory effort. Breath sounds equal No roles, rhonchl or wbeeze~.
Nonreader to palpation.
Regular rate and rhythm without murmurs, ectopy, rubs or gallops.
Soft, nontender, normal bowel sounds, no masses. No hepatosplenomegaly-
Normal color and ~urgoi'. The patient has paint on bis left forearm from something
unrelated to the accident.
Page 1
HOLY SPIRIT HOSPITAL
Camp Hill, PA
17011
NAME: WALTERS, DANIEL
MR#: 403383
ROOM #: ECU
DR.: Rudntck
EXTREt~TIES
NEUROLOGICAL
PSYCHIATRIC
LABORATORY ASSESSMENT
Symmetrical. Full range of motion. Equal tone and strength. No io~nt tenderness
or effusion. No clubbing or cyanos~s.
Alert and oriented to person, place and t~me. Cranml nerves intact. Sensory and
motor functmnz normal. Reflexes symmetrical.
Oriented to person, place and tame Mood and affect appruprmte.
A unnalysis was negative for blood. An x-ray of the patient's
cervical spine, lumbosacral spree and T-spree were w~thm normal
hm~z.
ASSESSMENT
PLAN
Muscle strain.
Ibuprofen or Tylenol for pain, warm soaks to 1he patient's tender areas on h~
back/neck for half hour every four hours for 72 hours. No gym for one week
Follow up w~th ins family doctor ~thm one week's t~me.
HR/ad
D: 11/15/1998
T 11/16/1998
2395
Page 2
HOLY SPIRIT HOSPITAL
Camp Hill,
17011
NAME. FF,4LTEILq, DANIEL
MR#: 403385
ROOM # ECU
DR: Rudtttek
EIVI~RGENCY CARE L"NIT FAMILY HEALTH CENTER DISCHARGE INSTRUCTIONS HOLY SPIRIT HOSPITAL
(717) 763-2316 (717) 763-2424
an effort to provide
The examination aad tream~ent you have received in the Emergency Care Unit (ECU) have been rendered on aa emergency basis only, and are not intunded t9 be a substitute for or
complete medical care, If you develop new problems or co~plicatlons .contact your physician or the Emergency Care Unit. FOLLOW THE INSTRUCTIONS CHECKED BELOW.
d,ati'~nnt Inform~on~ Patient Information sheets contain important information to review and keep.
~ ) ~,~[n ( ) Conjunctivitis { ) Fever/Pad. Fever ( ) Laceration ( ) Seizure
( ) Alcohol reaction ( ) COPD ( ) Flu ( ) Neck Strain !J Sore Throat
( ) Allergic reaction ( } Corneal abrasion/foreign body ( ) Fracture ( ) Nosebleed J~.Sprains and Strains
( ) Asthma ( ) Croup/bronchitis ( ) Headache ( ) Otit[s Media '( ~ Threatened Miscarriage
( ) Back pain ( ) Crutch walking ( ) Head injury ( ) Pediatric Head Injury ( ) Toothache
( ) Bites-Human/Animal/insect ( ) Diarrhea and Vomiting/Pad. Vomiting ( ) Hyper[ension ( ) Pediatric URI ( ) URI and Colds
( ) Burn ( ) Drug/Alcohol abuse/addiction ( ) Immunization/Tetanus ( ) PID/VD ( ) UTI and Pyelonephrit[s
( ) Chest Pain ( ) Febrite Convulsion ( ) Kidney Stones ( ) Rash ( } Other
WOUND CARE ~esent medications except:
( ) May gently wash over wound in 24 hours with soap snd water or
peroxide. Do not soak in water.
( ) Change dressing times daily. Redress with Bacitracin/Neosporln
and sterile dressing.
d:'/, cc'.'C,"d ~/Diptherie Booster given.
BRUISES, F~...R~
~'"'~"tEl~vate the injured part for days to reduce swe[l[ng.
) Apply ice packs intermittently for days to reduce swelling.
) Ace wrap for suppor~ for days.
) Wear splint ( ) At all times until folrow-up.
( ) For activity as needed.
) Use sling for support.
) Use crutches: ( )As needed, weight beating as tolerated.
( ) At all times. NO WEIGHT BEARING
for
t ~-vvear cervical collar support for days·
( ) Rest, avoid bending, lifting, strenuous activity for days.
(~bpply moist heat for '~0 m nutes ~ '-_~ times daily
/
ADDITIONAL INSTRUCTIONS
( ) Off work/school from. __ to
( ) Light Duty until:
Restrictions: t £ _
NO gym/sports until ] //'~ ~ / ~ ~
~Follow instructions on W(~rk/me~'s Co~np~nsation Form.
( ) Wear eye patch for hours.
( ) if nose bleed recurs, pinch nose firmly for 5 minutes
continuously, return if bleeding not controlled.
( ) The prescribed antibiotic may reduce the effectiveness of
medication you ere currently taking. Check package
instructions or consult with Pharmacist,
)The interpretation of your X-Reys are preliminary reading.
Your films will be reviewed by a radiologist· You or your
physician will be contacted if there ia a change in the
diagnosis.
~,dditional Instructions:
/~oUSe Advil (Ibuprofen) or Tylenol as pain,
needed
for
fever
rding to package instructions for age, weight.
( ) Use the following medicines according to package
instructions:
1:
2:
3:
( ) The following medicines may cause drowsiness:
DO NOT DRIVE OR OPERATE MACHINERY WHILE TAKING:
This is our recommendation for follow-up, your
If
nsu~anca (HMO) requires a physician referral for specialty
consultation, IT IS YOUR RESPONSIBILITY TO OBTAIN THE
//~ESSARY APPROVAL.
ollow-up with: ( ) Return to hospital
,,Family Doctor
7//'--- ("~,) ( ) WorkN et
days for: ~Follow-up
in
· ~ ) Suture removal
( ) Call as soon as possible for appointment
) Pick up your X-Rays from the Radiology Department prior to
your follow-up appointment. Call 763-2696 to have films
ready.
) See your physician or specialist if not improved in
days.
) Return to ECU if you feel your condition is worsening,
especially if
) Your blood pressure wes elevated. Please have it
rechecked by your physician.
) Test results have been given to you. Take them with you to
the follow-up appointment.
Test results given: F~CBC []CPRO [] EKG [] X-RAY COPY
[] RENAL PRO. [] RECORDS COPY CHART [] GLUC.
i~horabTIENT VERBALIZES UNDERSTANDING
y acknowledge receipt of these instructions and
understand them. I understand that I have had emergency
treatment only and that I may be released before all of my
medical problems are known or treated. I will arrange for
follow up care as
SIGNATURF~f \ .~ ~,r- _ . !
SIGNATURE'/f~/
~;~ysieian - M.D. ] D.O~. Nu'r,
11/15/98
1546
HOLY SPZRIT HOSPITAL, C~(P HILL, PA 17011
DEI~ARTM~NT OF LABORATORY M~DICINE
STEpHENBON S.P. SWA~DOSS'M.D., DIRICTOR
LOCATION
PA~E 1
Ae~9~ 0000127B~128 ~/C$~ 403a83
Loo&~£on~ ECU ROb~T
Spec $' 1115:U00024S
Ordered: URIN
Coll: 11/15/98-!531
Recd' 11/15/98-1533
Status. COMP
sub Dr: ED GROUP
Req $' 00991856
COLOR
CLARITY
DH
GLUC.
BILI
PROTEIN
~ITE
LE~ EST
Result
Y~LLOW
7 0
NORMAL
I~GATIVE
NEGATIVE
NEGATIV~
NEGATIVE
NEGATIVE
NEGATIVE
AM, ST,YE
4 5-8 0
NORF~%L MG./DL
NEGATIVE M~,/DL.
~TI~
~TI~
~TIVE
HOLY SPIRIT HOSPITAL, ~ HILL, PA 170~1 PAgE I
DATE, 11/17/98
RUN TI~ 0909
D~ART~ OF LA~ORAT. ORY~DICI~q~
ST~PHENSON S.P. SWAM~DOSS M.D., DIR3CTOR
LOCATION
WAi~TE£$,DANIEL G
.A~C~s 0000127~7128 ~=~; 40~3fl3
98:B0O18603R COMP, Coll 11/15/98-1525 Recd
NOT ~ERFO~D - I ,OREENNEGATI%'E
11/1~/~8-1~7 (R~0099186¢) ED GROUP
MOLY SPIRIT ~K)SPITAL
DEPARTMENT OF RADIOLOGY AND DIAGNOSTIC IMAGING
CAMP MILL, PENNSYLVANIA 17011
(717) 763-2600
P~TIENT: WALTERS, DANIEL G
DICTATION DATE: 11/15/98 5:36pm .
MR= 403383
SOC SEC: 999-05-0186
ORD DR.~ ED GROUP,
PT TYPE:
ADM DATE4~98 02:37PM
LOCATION ECU
TRANSCRIPTION DATE 11/16/1998 07:55AM
SERVICE: ECU
EXAMINATION: cERVICAL sPINE
COMMENTS:
Alignment is normal and the disc interspaces are preserved. No bony
abnormalities are seen. There is no encroachment on the neural foramina.
The atlanto-axlal relationshzps appear normal.
CONCLUSION: Normal cervical spine.
DICTAcorD BY t
DATE O~ EXAM:
K.R. Haidet, M.D./lah
11/15/1998
HOLY SPIRIT HOSPITAL
DEPARTMENT OF RADIOLOGIf AND DIA$~OSTIC
~ HI~, p~S~V~IA 17011
(717) 76~-2600
PATIENT" WALTERS, DANIEL G
DICTATION DATE: 11/15/98 5:36pm ·
MR: 403383
SOC SEC: 999-05-0186
ORD DR.: ED GROUP,
LOCATION~E~
TRANSCRIPTION DATE 11/16/1998 07:56A~
ARI~IVAL DATE:
HOSP SERVICE{ ECU
EXAMINATION: THORACIC SPINE (3V
COMMENTS:
Alignment is normal and the dxsc interspaces are preserved. The
vertebral bodies are normal in height. The bony architecture is normal and
there is no abnormal widening of the paraspinal stripe.
CONCLUSION: Normal thoracic spme.
DIC~A~ BY:
DATE OF EX;IMz
K.R. Haidet, ~l.D./lah
11/15/1998
HOLY SPIRIT HOSPITAL
DEP~RTMENT OF RADIOLO~Y AND DIAGNOSTIC IMAGING
CAMP HILL, PENNSYLVANIA 17011
(7X7)
PATIENT~ WALTERS, DANIEL G
MR: 405383
S0C SEC~ 999-05-0186
ORD DR.: ED GROUP,
PT TYPE: E
ADM DATE_l,~5~:37PM
LOCATI0~--~
DICTATION DATE~ 11/15/98 5:36pm.
T~ANS~RIPTION DATE 11/16/1998 07~57AM
ARRIVAL DATE~
HOSP SER¥ICE~ ECU
EXA~INATION~ LUMBAR SPINE (6V)
COMMENTS:
Alignment is normal and the disc intez~paces are preserved. The bony
structures appear normal. The apophyseal and sacro-iliac Joints are
unremarkable.
CONCLUSION: Normal lumbar spine.
DICTATED BY:
DA~E OF EXAM:
K.R. Harder, M.D./lah
11/15/1998
Exhibit B
DAVID M. JOYNER, M.D., F.A.C.S.
RICHARD J. BOAL, M.D.
ROBERT IL DAHMUS, M.D,
STEPHEN W. DAILEY, M.D.
WILLIAM W. DEMUTH, M.D., F.A.C.S.
JOHN IL I~ 11, M.D., F31,C.S.
MARK IL GRUBB, M.D.
RICHARD H. HALLOCK, M.D.
ORTHOPEDIC INSTITUTE
OF PENNSYLVANIA
TELEPHONE: (717) 761-5530 ·
(800) 834-4020
FAX: (717) 737-7197
JAMES IL MAMSHER, M.D., F.A.C.S.
GREGORY A, HANI%5, M.D,
ALF~L~iDER IV~LENAK, M.D., F.A.C.S.
ROBERT IL KANEDA, D.O.
RONALD W. LIPI~, M.D., F.A.C.S,
JASON J. LrlTON, M.D.
STEVEN B. WOLF, M.D.
THOMAS J. YUCHA, M.D,
October 16, 2000
John McNalty, Esquire
James, Smith, Durkin & Connelly LLP
P.O. Box 650
Hershey, PA 17033
RE:
OCT 4 2000
Daniel G. walters
212 17 2461
Dear Mr. McNally:
The above patient was initially seen by me on December 16, 1998. He was a
12-year-old boy, who had no history of neck or low back pain and was seated
as a passenger in the front seat of a car on November 15, 1998. The car was
stopped and was rear-ended by another vehicle that he said might have been
going 40 miles an hour. He noted the onset of neck and low back pain and was
seen at Holy Spirit Hospital the day of injury where radiographs of his
cervical spine, thoracic spine and lumbosacral spine were taken. They
reportedly showed no abnormalities.
When I saw Daniel, he was taking Advil and was having intermittent neck and
Iow back pain. His orthopedic examination disclosed no objective findings of
neck or low back abnormalities. I felt that Dan had strained his neck and
low back in the vehicle accident and because of continued pain was unable to
wrestle at that time. I felt that it was appropriate for him to continue
taking Advil and sent him to the Keystone Spine Center for a program of back
exercises, which he was to continue to do on his own. At that point I felt
that no other investigative studies were indicated and expected his symptoms
to subside with the passage of time. I did not feel that surgery would be
necessary-
When I saw Daniel on December 16, 1998, he was still symptomatic and had not
z~ached maximum medical impzoveme~L. I do not know when he will do so. As
have stated I do not know if any additional medical treatment is needed or
prescribed because I have not seen him in nearly two years.
If I can be of other help to you, please call on me.
S incerel~:~
Jaso% J. Litt~In, M.D.
JJL/clv
ORThOPeDIC SURGEONS, LTD.
ADDRESS ALL CORRESPONDENCE TO: 875 POPLAR CHURCH ROAD, CAMP HILL, FA 17011
II~RRI$~I3RG OFFICE ~J~F IllLL OFFICE HERSHEY OFFICE
450 pOWERS AVE. 890 POPLAR CHURCH RD., STE. 108 10 WEST CHOCOLATE AVE., STE. 105
CAMP HILL OFFICE
CAMP filLL OFFICE. 875 pOPLAR CHURCH RD;
3916 TRINDLE RD.
Exhibit C
FULL AND FINAL RELEASE.
FOR AND IN CONSIDERATION of the sum of FIVE THOUSAND THREE HUNDRED
DOLLARS ($5,300.00) paid to the undersigned, JOHN N. WALTERS and MARGARET T.
WALTERS, individually and as Parents and Natural Guardians of DANIEL WALTERS, a Minor, the
receipt and sufficiency of which is hereby acknowledged, the undersigned agree to fully release,
discharge, hold harmless, and indemnify NATIONWIDE INSURANCE COM.PANY, LISA E.
MARTIN, and all other persons, associations and corporations, whether or not named herein, their
heirs, executors, administrators, successors, assigns and insurers, and their respective agents, servants,
employees and attorneys, from any or all causes of action, claims and demands of whatsoever kind on
account of all known, and unknown injuries, losses and damages allegedly sustained by DANIEL
WALTERS on November 15, 1998, and, specifically, from any claims, or joinders, for sole liability,
contribution, indemnity or otherwise as a result of, arising from, or in any way connected with injuries
sustah~ed by DANIEL WALTERS, and the defense and handling thereof from the inception of the
claim until the date of this Full and Final Release.
The undersigned understand and agree that the acceptance of said sum is not an admission of
liability by any party named herein. It is expressly understood and agreed that.this Release and
settlement is intended to cover and does cover not only all known injuries, losses, and damages, but any
further injuries, losses, and damages which arise from or are related to the occurrences set forth in the
Legal Action noted above and the handling and defense thereof. Nationwide Insurance Company will,
however, pay for all future treatment to the Minor which resulted from automobile accident of
November 15, 1998 to the extent not covered by other insurance, and such payments shall be made
directly to the Minor's healthcare providers.
It is further understood and agreed that this is the complete Release Agreement, and that there
are no written or oral understandings or agreements, dkectly or indirectly connected with this Release
and settlement that are not incorporated herein. This Agreement shall be binding upon and inure to the
successors, assigns, heks, executors, administrators, and legal representatives of the respective parties
hereto.
The undersigned hereby declare and warrant that they are of legal age, the terms of this
settlement have been completely read, and that they have discussed the terms of this settlement with
legal counsel of choice; and said terms are fully understood and voluntarily accepted for this purpose of
any and all claims on account of the injuries and damages above-mentioned, and for the express
purpose of precluding forever any further or additional suits arising out of the aforesaid claims.
WITNESS:
JOHN N. WALTERS, Individually and as
Parent and Natural Guardian of DANIEL
WALTERS, a Minor
DATE
WITNESS:
MARGARET T. WALTERS, Individually
and as parent and Natural Guardian of
DANIEL WALTERS, a Minor
DATE
TO
YOU ~RE¢"I,iEREBy NOTIFIED TO PLEAD TO
THE E NCLC/.~E D WITHIN
A DEFAULT J~D~NT MAY BE E~
LAW OFFICE
JAMES, SMITH, DURK~ & CONNELLY, LIJP
E O. BOX 650
HERSHEY, PENNSYLVANIA 17033-0650
WE HEREBy CE Ib"Y THAT THE WITHIN IS
A TRL!E ANDCEC~OI~EcT COPY OF THE
JOHN N. WALTERS and MARGARET
T. WALTERS, individually and as Parents and
Natural Guardians of DANIEL WALTERS, a Minor,
Petitioners
LISA E. MARTiN,
Respondent
: iN ~ COURT OF COMMON PI F. AS
: CUMBERLAND COUNTY,
: PENNSYLVANIA
:
CIVIL ACTION- LAW
ENTRY OF APPEARANCE
Dated: //~/~ !
TO THE PROTHONOTARY:
Kindly enter the appearance of the undersigned on behalf of the Petitioners, John N.
Walters and Margaret T. Walters, Individually and as Parents and Natural Guardians of Daniel
Walters, a Minor, with respect to the above-captioned matter.
Respectfully submitted,
JAMES, SMITlf, DURKIN & CONNELLY, LLP
-~U-RKIN; ESQLqlLE
/ Attorney I.D. ~29563
JARAD W. HANDELMAN, ESQUIRE
Attorney I.D. #82629
P.O. Box 650
Hershey, PA 17033-0650
(717) 533-3280
Attorneys for Defendant
JOHN N. WALTERS and MARGARET
T. WALTERS, individually and as Parents and :CUMBERLAND COUNTY,
NaturalGuardians of DANIEL WALTERS, a Minor, :PENNSYLVANIA
Petitioners :
v. :NO. Or-- 6,gO?
LISA E. MARTIN,
:IN THE COURT OF COMMON PLEAS
:CIVIL ACTION - LAW
Respondent :
ORDER
AND NOW, this~_~_~ day of~, 2001, upon presemation of a Petition
for Approval of Compromise Settlement and Distribution of Proceeds of a Minor's Compromise, it
is hereby directed that a hearing, on the merits take place on the ~.~ day of
~ ., 2001J[at ~_.._'.'_._._.'t~' o'clock in the ~.m.
JOHN N. WALTERS and MARGARET
T. WALTERS, individually and as Parents and
NaturalGuardians of DANIEL WALTERS, a Minor,
Petitioners
LISA E. MARTIN,
Respondent
:IN THE COURT OF COMMON PLEAS
:CUMBERLAND COUNTY,
:PENNSYLVANIA
.
:NO. O[- ~0~
:CIVIL ACTION - LAW
ORDER
AND NOW, this-~z'~ day ofII ._._A~ , 200~the Petition of JOHN N.
! .
WALTERS and MARGARET T. WALTERS, individually and as parents and natural guardians of
DANIEL WALTERS, a Minor, is hereby GRANTED, with Minor's proceeds to be issued as
follows:
Settlement of $5,300.00, to be distributed as follows:
$4,250.00 to DANIEL WALTERS in a guardianship account insured by a Federal
governmental agency.
$1,050.00 to MARGARET T. WALTERS for unreimbursed wage loss during the
Minor's convalescence.
3. No withdrawals can be made from such account without Court approval until the
minor reaches majority.
4. Proof of deposit shall be promptly filed of record.
Petitioners may execute a general release in favor of Nationwide Insurance Company and
LISA E. MARTIN.
By the Co~
coUrT oF c°~°~
JOHN N. WALTERS and MARGARET : IN THE COURT OF COMMON PLEAS
T. WALTERS, individually and as Parents and : CUMBERLAND COUNTY
NaturalGuardians of DANIEL WALTERS, a Minor,: PENNSYLVANIA Petitioners :
LISA.E. MARTIN,
NO. 01-6808
CIVIL ACTION - LAW
Respondent
PRAECIPE TO SETTLE AND DISCONTINUE
TO THE PROTHONOTARY OF YORK COUNTY:
Kindly mark the above docket as settled, satisfied and discontinued as to all parties in this
action.
JAMES, SMITH, DURKIN & CONNELLY, LLP
/ JARAD W. HANDELMAN, ESQUIRE
Attorney I.D.//82629
P.O. Box 650
Hershey, PA 17033-0650
(717) 533-3280
Attorneys for Petitioners
JOHN N. WALTERS and MARGARET
T. WALTERS, individually and as Parents and
NaturalGuardians of DANIEL WALTERS, a Minor,
Petitioners
LISA E. MARTIN,
Respondent
IN THE COURT OF COMMON PLEAS
CUMBERLAND COUNTY,
PENNSYLVANIA
NO. 01-6808
CIVIL ACTION - LAW
PRAECIPE TO FILE PROOF OF DEPOSIT
OF MINOR'S SETTLEMENT
TO THE PROTHONOTARY OF YORK COUNTY:
Please file, and make part of the record, the attached proof of deposit of Minor's
settlement proceeds in accordance with the Order of Court dated January 2, 2002.
Dated:
JAMES, SMITH, DURKIN & CONNELLY, LLP
J Attomey I.D. g29563
JARAD W. HANDELMAN, ESQUIRE
Attomey I.D. #82629
P.O. Box 650
Hershey, PA 17033-0650
(717) 533-3280
Attomeys for Petitioners
Members/ .
P.O. Box 40 · Mechanicsburg, PA 17055-0040
(717) 697-1161
TOLL FREE (800) 283-2328
www.membersl st.org
205175 WALTERS/DAN S
100 BYRON NELSON CIRCLE
ETTERS PA 17319-9435
CR RT: 0 FLAGS:R3,26
02/19/02 BR: 10wn:S BD:
Ref:C24/ATM Dept:BOOK-R PR: .00
Password: SSN:212-17-2461
Affinity Code: PH:(717)938.-0197
Household: 0 WK:(000)000-0000
Number Date Memo
000001001 02/19/08 FUNDS FROZEN IN ACCOUNT UNTIL 5/1/04 PER COURT ORDER IMT
Slx Desc Dt Open Balance Avail Rate YTD Div Lst Act Flags
00 RSA 051701 276.32 851 .0000 1.38 021908
40 ~ 30M 021908 4850.00 0 4.0300 .00 021902 22,40
Total Shares Pledged: 12775.00
Membersl
FEDERAL CREDIT UNION
February 19, 2002
Re: Daniel G Walters
Karen Durkin
PO Box 50
Hershey, PA 17033
Dear Karen;
Members 1st FCU has established an account for Daniel G Walters. The funds
in the account have been placed in a Certificate of Deposit and frozen until May
1, 2004 pursuant to the Order of the Court of Common Pleas of Cumberland
County. The enclosed document shows the account name and the restriction
placed on those funds.
Please contact us for any additional assistance. Any questions or further
communications should be directed to Gregory P Schank, AVP Branch
Operations at 717-795-6003 or 1-800-283-2328 ext 6003.
Respecfully,
Isodean M Wodey
Assistant Branch Manager
Enclosure
FEB 2 rl 2002
5000 Louise Drive · P.O. Box 40 ° Mechanicsburg, Pennsylvania 17055 ° (717) 697-1161 ° Fax (717) 795-6024
www. members 1 st.org
C) CZ~ CD