HomeMy WebLinkAbout03-24-09
SCHMIDT KRAMER PC o
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BY: SCOTT B. COOPER ESQUIRE ~o ~
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I.D. #70242 ~ z ~
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209 State Street ~ ~'~' ~ `
Harrisburg, PA 17101 ~;
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(717) 232-6300 - ~ -~, ,,;,
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Attorney for Petitioner -~ ~~ ~, , ;:
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IN RE: ESTATE OF IN THE COURT OF COMMON
KATHLEEN ANN CONN, : PLEAS CUMBERLAND COUNTY,
Deceased, by PENNSYLVANIA
KATHLEEN A. SMITH,
Administratrix,
Petitioner NO. 21-07-0108
ORPHAN'S COURT DIVISION
AFFIDAVIT OF COMPLIANCE
WITH COURT ORDER
AFFIDAVIT OF COMPLIANCE
WITH COURT ORDER
The undersigned, Scott B. Cooper, Esquire, who, being duly sworn
according to law deposes and states that:
1. The Honorable J. Wesley Oler, Jr., entered an Order on
February 2, 2009, directing that settlement funds in the amount of
$49,400.75 be deposited in compliance with Pa. R.C.P. 2039(b)(2), by
SCHMIDT KRAMER PC, in Certificates of Deposit with the remaining
balance, if any, in a savings account, insured by a federal governmental
agency, such account not to exceed the amount to which accounts are
insured by FDIC.
Each Certificate of Deposit and account shall be marked as follows:
"This money shall be held in trust, not to be redeemed,
except by Order of the Court before May 5, 2023."
2. In accordance with the terms of said Order, the undersigned
did, on March 11, 2009, set up the requested account, and proof of same
is attached hereto.
Respectfully submitted,
SCHMIDT KRAMER PC
By:
Scott B. Cooper, Esquire
Attorney I.D. #70242
209 State Street
Harrisburg, PA 17101
(717) 232-6300
Attorney for Petitioner
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IN RI'/.: ESTATE OF
I~i,~,TNLEEN ANN CONN,
Deceased, by
IATHLEEN A. SMITH,
AciministratriX,
Petitioner
IN THE COURT OF COMR~ION PLEBS
CUMBERLAND COUNTY,
PENNSYLVANIA
rJO. 08-3242
ORPI-IAN'S COURT DIVISION
SUPPLEI~~IEN'TAL PETITION FOR
APPROVAL OF MINOR'S SETTLEMENT
FOR WRONGFUL DEATH ACTION
(briar
AND NOW, this ~ day of ____, 2009, it is hereby
ORDERED and DECREED as follows:
(1) Pursuant to Pa. R.C.P. 2039 and 2206, and upon consideration of
the Supplemental Petition for Approval of Minor's Settlement for Wrongful
Death Action, Petitioner is authorized to enter into a settlement in the gross
sum of $100,000.00, and accept $7,500.00 in first party benefits proceeds.
(?J Petitioner, Kathleen A. Smith, Adrninistratrix of the Estate of
Kathleen Ann Conn, is given leave to sign the Release attached to the Petition
as Exhibit "M."
(3) It is approved that the settlement proceeds shall be distributed as
follows:
Schmidt Kramer PC,
Attorneys' fees at 25°./0 (1 J3 or
$8,325.00, of ~~rhich, is to be
paid to Michael Bangs, Esquire
as a referral fee) ...................................................................$25,000.00
Schn7idt Kramer PC,
Costs incurred to date ......... ............................. ........................ ~ 1 5.09
~Wron~fu7 De~:tlz A.ctscn:
ACS Reco~.~er~.~,
i'o satisfy >t-1edical Lien ................... ...........,.. ,~~~,000.00
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For unreil-nbLtrsed final e~.}~enses ................. ........ ... .............7,784. i6
Commerce I3anl•~, ]C~1 I~;orth =c~~~_md 5?r~c~t
1-1c~I-I-ISbLl!-~, ~'!'r1I"iS',i1V:-1ii1~-1 t0 ~_~~'_ 11E1)f)ti1~.E'~~ ][1
account numberec! U~27074.37. T11e accouni
shall be marked as follotivs
"This money shall be held in trust,
not to be redeemed, except by Order
of this Court, before Ma_y 5, 202." ...............................$49,4GO.i5
otal .............................................................$10?,500.00
The law firm of S~llniidt I~_ralner PC shall oversee the execution of the
preceding paragraph.
BY THE COURT:
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Commerce
Bank 1-888-937-0004
commercepc. com
Balance information reflects transactions through 6:00 PM on that business day. Some deposits may not 6e available for immediate withdrawal. Checks
and other items are received for deposit subject to the provisions of the Uniform Commercial Code or any applicable coNection agreement.
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CERTIFICATE OF SERVICE
AND NOW, I, Scott B. Cooper, Esquire, hereby certify that I have,
this day, served a copy of the Affidavit of Compliance With Court Order
by serving a copy of the same by hand delivery addressed to:
The Honorable J. Wesley Oler, Jr.
Cumberland County Courthouse
1 Courthouse Square, 1St Floor
Carlisle, PA 17013
Justin Self
5001 Seneca Drive
Mechanicsburg, PA 17050-2575
Kathleen Smith
425 South Main Street
Teleford, PA 18969
Douglas G. Kocher
Erie Insurance
4901 Louise Drive
Rossmoyne Business Center
P.O. Box 2013
Mechanicsburg, PA 17055-0710
Respectfully submitted,
SCHMIDT KRAMER PC
By:
Scott B. Cooper, Esquire
Attorney I.D. #70242
209 State Street
Harrisburg, PA 17101
(717) 232-6300
Attorneys for Petitioner
Date: ~ Z,~J~~