HomeMy WebLinkAbout09-3066Mark Thomas Sophocles (PA ID #74998)
MARK THOMAS SOPHOCLES, LLC
21 Industrial Blvd., Suite 201
Paoli, PA 19301 H Nl&
Tel: (610) 651-0105
Fax: (610) 651-0106
IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY
PENNSYLVANIA- CIVIL DIVISION
IN RE: JERMAYNE M. WEBBER A/K/A JERMAYNE WEBBER
PETITION TO TRANSFER STRUCTURED SETTLEMENT PAYMENT RIGHTS
CIVIL DOCKET # 2009-
PETITION FOR APPROVAL OF TRANSFER OF
STRUCTURED SETTLEMENT PAYMENT RIGHTS
1. This Petition is brought pursuant to the provisions of the Pennsylvania Structured
Settlement Protection Act, 40 P.S. §4001 et seq. and Pa. R.C.P. 229.2.
2. Petitioner and Transferee is Settlement Funding, LLC, 3301 Quantum Boulevard,
Boynton Beach, FL 33426.
3. The Payee, Jermayne M. Webber a/k/a Jermayne Webber (hereinafter "Payee") is
an adult individual of full age and who resides at 211 Academic Way,
Shippensburg, PA 17257- 2168 in Cumberland County, Commonwealth of
Pennsylvania.
4. This Court has venue pursuant to the Structured Settlement Protection Act,
because the Payee is domiciled in Cumberland County, Pennsylvania.
5. Jermayne M. Webber a/k/a Jermayne Webber suffered personal injuries and, as a
result, he receives annuity payments as follows:
48 monthly payments each in the amount of $434.00 commencing on May 3,
2011 through and including April 3, 2015; 120 monthly payments each in the
amount of $850.00 commencing on May 3, 2015 through and including April
3, 2025; and 120 monthly payments each in the amount of $2,000.00
commencing on May 3, 2025 through and including April 3, 2035 (the
"Periodic Payments")
6. The Annuity Owner is Metlife Insurance Company of CT, Legal Department, One
Metlife Plaza, 27-01 Queens Plaza North, Long Island City, NY 11101.
7. The Annuity Issuer is Metlife Insurance Company of CT, Legal Department, One
Metlife Plaza, 27-01 Queens Plaza North, Long Island City, NY 111018.
8. On May 10, 2009, Jermayne M. Webber a/k/a Jermayne Webber executed an
Absolute Assignment Agreement (the "Transfer Agreement") a true and correct
copy is attached and incorporated herein as Exhibit "B" that provides for the
assignment of the payments as follows:
120 monthly payments each in the amount of $850.00 commencing on May
3, 2015 through and including April 3, 2025 (the Assigned Payments).
9. The Petitioner has provided to the Payee a Disclosure Statement, a true and
correct copy of which is attached hereto as Exhibit C, setting forth, inter alia, the
amounts and due dates of the Structured Settlement Payments to be transferred as
set forth in paragraph 8 herein above and in paragraph A of Exhibit C.
10. The net amount payable to the Payee after deduction of all commissions, fees,
costs, expenses, and charges is $13,244.08 minus any advances made to Payee
against the amount payable to Payee.
11. Based on the net amount that the payee will receive from this transaction
$13,244.08, the amounts and timing of the structured settlement payments
that would be assigned, the payee is, in effect, paying interest at a rate of
21.94% per year.
12. After due consideration, the Payee is satisfied that the transfer is in his best
interests for the reasons set forth in the Affidavit attached hereto as Exhibit D and
incorporated herein by reference.
13. The Payee has received the notice required by 40 P.S. §4003(b) as evidenced by
Exhibit F hereto.
14. The Payee has given the notice required by 40 P.S. §4003(a)(6) as evidenced by
Exhibit G hereto.
15. Attached hereto as Exhibit H is the certification required by Pa. R.C.P.
229.2(d)(3)(iii).
16. Payee has executed a statement confirming that he has waived independent legal
advice including considerations of any tax ramifications of the transfer.
WHEREFORE, the Petitioner prays this Honorable Court to enter its Initial Order scheduling a
hearing on this Petition.
Respectfully submitted,
Date: May 12, 2009
Attorney I.D. No. 74998
MARK THOMAS SOPHOCLEs, LLC
21 Industrial Boulevard, Suite 201
Paoli, PA 19301
Counsel for Settlement Funding, LLC
MARK T. SOPHOCLES, ESQUIRE
PA SUPREME COURT ID #74998
MARK THOMAS SOPHOCLES, LLC
21 Industrial Blvd., Suite 201
Paoli, PA 19301
Tel: (610) 651-0105
Fax: (610) 651-0106
IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY
PENNSYLVANIA- CIVIL DIVISION
IN RE: JERMAYNE M. WEBBER A/K/A JERMAYNE WEBBER
PETITION TO TRANSFER STRUCTURED SETTLEMENT PAYMENT RIGHTS
No. 09-
NOTICE OF PROPOSED TRANSFER OF STRUCTURED
SETTLEMENT PAYMENT RIGHTS
TO: Metlife Insurance Company of CT
Legal Department, One Metlife Plaza
27-01 Queens Plaza North
Long Island City, NY 11101
(Settlement Obligor)
Metlife Insurance Company of CT
Legal Department, One Metlife Plaza
27-01 Queens Plaza North
Long Island City, NY 11101
(Annuity Issuer)
Settlement Funding, LLC
3301 Quantum Boulevard
Boynton Beach, FL 33426
Attn: Court Order Group
(Transferee)
Jermayne M. Webber
211 Academic Way
Shippensburg, PA 17257-2168
(Petitioner)
You are hereby given notice that a petition to transfer structured settlement payment
rights has been filed in the Court of Common Pleas of Cumberland County, Pennsylvania. An
Order has been issued by the court requiring that responses or objections of the transferee,
structured settlement obligor or the annuity issuer, be brought before the court either in writing
or in person at a hearing set (on or after June 5, 2009) for , at
AM/PM in Courtroom , before the Honorable
. (A copy of the Scheduling Order dated
2009, is included with this notice). You are entitled to support,
oppose or otherwise respond to the payee's petition, either in person or by counsel, by filing
written comments with the court prior to the hearing or by attending the hearing.
Provided with this notice is a copy of the Petition to Transfer Structured Settlement
Payment Rights, including as attachments thereto a copy of the Transfer Agreement, and a copy
of the Transfer Disclosure Statement required by 40 P.S. § 4003 (2). Pursuant to 40 P.S. § 4003
(6), notice of the transferee's name, address and taxpayer identification number are as follows:
Settlement Funding, LLC
3301 Quantum Boulevard
Boynton Beach, FL 33426
(TIN: 58-2292928)
Date: May 12, 2009
Mark Thomas SoliMcles, Esquire
Attorney I.D. No. 74998
MARK THOMAS SOPHOCLES, LLC
21 Industrial Boulevard, Suite 201
Paoli, PA 19301
Counsel for Settlement Funding, LLC
Mark Thomas Sophocles, Esquire
PA SUPREME COURT ID #74998
MARK THOMAS SOPHOCLES, LLC
21 Industrial Blvd., Suite 201
Paoli, PA 19301
Tel: (610) 651-0105
Fax: (610) 651-0106
Counsel for Settlement Funding, LLC
IN RE: JERMAYNE M. WEBBER : IN THE COURT OF COMMON PLEAS
A/K/A JERMAYNE WEBBER : CUMBERLAND COUNTY,
: PENNSYLVANIA
: DOCKET# 09-
PRAECIPE FOR HEARING
TO THE PROTHONOTARY:
Kindly schedule the hearing on the petition filed in the above-captioned matter.
Respectfully submitted,
Date: Mav 12, 2009
Mark Thomas SopYocles, Esquire
Attorney I.D. No. 74998
MARK THOMAS SOPHOCLES, LLC
21 Industrial Boulevard, Suite 201
Paoli, PA 19301
Counsel for Settlement Funding, LLC
CERTIFICATE OF SERVICE
I, Mark T. Sophocles, hereby certify that a true and correct copy of this Petition to Transfer
Structured Settlement Payment Rights and Exhibits via Certified Mail Return Receipt Requested
and Federal Express upon the persons and entities, and at the addresses listed above, this 12th day
of May 2009.
TO: Metlife Insurance Company of CT
Legal Department, One Metlife Plaza
27-01 Queens Plaza North
Long Island City, NY 11101
(Settlement Obligor)
Metlife Insurance Company of CT
Legal Department, One Metlife Plaza
27-01 Queens Plaza North
Long Island City, NY 11101
(Annuity Issuer)
Settlement Funding, LLC
3301 Quantum Boulevard
Boynton Beach, FL 33426
Attn: Court Order Group
(Transferee)
Date: May 12, 2009
Jermayne M. Webber
211 Academic Way
Shippensburg, PA 17257-2168
(Petitioner)
Attorney I.D. No. 74998
MARK THOMAS SOPHOCLEs, LLC
21 Industrial Boulevard, Suite 201
Paoli, PA 19301
Counsel for Settlement Funding, LLC
VERIFICATION
I, KURT MOODY, In-House Counsel of Settlement Funding, LLC d/b/a Peachtree
Settlement Funding, have read the foregoing Petition to Transfer Structured Settlement Payment
Rights, and hereby aver that the statements therein are correct to the best of my personal
knowledge, information and belief.
This statement and verification is made subject to the penalties of 18 Pa. C.S.A. §4904
relating to unsworn falsification to authorities.
f?
DATE: May ?Z, 2009
RT MOODY
VERIFICATION AND CERTIFICATION
I, Mark Sophocles, Esquire as authorized outside counsel for Settlement Funding, LLC
verify that the statements made in this Petition are true and correct and to the best of my
knowledge, information and belief, formed after reasonable inquiry, that the transfer will comply
with the requirements of the Act and will not contravene any other applicable federal or state
statute or regulation or the order of any court or administrative authority. I understand that false
statements herein are made subject to the penalties of 18 Pa. C.S. §4904, relating to unsworn
falsification to authorities.
Date: May 12, 2009
Paoli, PA 19301
Counsel for Settlement Funding, LLC
Attorney I.D. No. 74998
MARK THOMAS SOPHOCLEs, LLC
21 Industrial Boulevard, Suite 201
Mark Thomas Sophocles, Esquire
PA SUPREME COURT ID #74998
MARK THOMAS SOPHOCLES, LLC
21 Industrial Blvd., Suite 201
Paoli, PA 19301
Tel: (610) 651-0105
Fax: (610) 651-0106
Counsel for Settlement Funding, LLC
IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY
PENNSYLVANIA- CIVIL DIVISION
IN RE: JERMAYNE M. WEBBER A/K/A JERMAYNE WEBBER
PETITION TO TRANSFER STRUCTURED SETTLEMENT PAYMENT RIGHTS
CIVIL DOCKET: 2009-
FINAL ORDER OF COURT
On this day of , 2009, it is ordered that the Petition to Transfer
Structured Settlement Payment Rights is granted. The court specifically finds that:
(1)The payee, Jermayne M. Webber a/k/a Jermayne Webber, has established that the transfer is
in the best interests of the payee or his dependents, taking into account the welfare and support of
his dependents, if any;
(2) Based on the certification by an attorney for the transferee, Settlement Funding, LLC, and the
court having not been made aware of any statute, regulation or order that would be incompatible
with the proposed transfer, the transfer will not contravene any applicable federal or state statute
or regulation, or the order of any court or administrative authority;
(3) The transfer complies with the remaining requirements of the Structured Settlement
Protection Act, including Sections 3(a)(2), 3(a)(4), 3(a)(5) and 3(a)(6);
(4) The payments that are to be transferred are designated as follows:
120 monthly payments each in the amount of $850.00 commencing on May 3, 2015
through and including April 3, 2025 (the Assigned Payments).
(5) The terms of this order shall survive the death of the payee and shall be binding on the
payee's heirs, beneficiaries and assigns;
(6) The payee shall receive from the transferee the gross amount of $13,244.08
(7) The Annuity Owner is Metlife Insurance Company of CT and the Annuity Issuer is Metlife
Insurance Company of CT, Legal Department, One Metlife Plaza 27-01 Queens Plaza North
Long Island City, NY 11101. The Annuity Owner and Annuity Issuer shall send the Assigned
Payments, when due, to Settlement Funding, LLC at P.O. Box 116476, Atlanta, GA 30368-6476
or to such other address as designated by Settlement Funding, LLC.
BY THE COURT:
J.
Background on Structured Settlements Generally:
Contrary to popular misconception, structured settlements typically result from a voluntary
settlement of an underlying tort claim. While many believe that structured settlements are
typically court approved, court ordered or otherwise mandated by the court as a form of
spendthrift trust, this is simply not true. Structured settlements are a convenient and cost
effective way to settle personal injury claims, particularly where there is disagreement over the
size of the settlement as the perceived value of future payments is generally higher than their true
value. Simply put, structured settlements are a cost effective way for insurance carriers to settle
personal injury claims on favorable terms and are often used for garden variety cases. In the vast
majority of cases they are simply the result of a negotiated settlement between plaintiff and
defendant with no substantive court involvement.
Anti-assignment provisions are often included in structured settlement agreements under the
mistaken belief that they are required to prevent the application of the "constructive receipt" tax
doctrine. These anti-assignment provisions were not included as a form of spendthrift trust nor
were they intended as a restriction on alienation of the right to receive structure settlement
payments. Rather they are a result of an overly cautious reading of several private letter rulings
from the early 1980's and a misunderstanding of the constructive receipt tax doctrine. Any
lingering doubts as to whether an anti-assignment provision is required to prevent constructive
receipt were dispelled in 2002 with the passage of 26 USC Section 5891, et seq. which made it
clear - by way of a clarification of existing law - that a sale or transfer of structure payments
rights would not alter the tax treatment applicable to the annuitant or annuity issuers.
Notwithstanding this, anti-assignment clauses remain a vestige of common practice and are
hence present in many settlement agreements.
The one common failing of structured settlements is that they are relatively inflexible. Once
established they cannot be altered. As a consequence, a secondary market for structured
settlements evolved in the 1990's. Because of the significant demand from structured settlement
recipients to restructure/refinance how and when they receive these payments, a secondary
market flourished. In 2002, the US Congress, after hearings before the Ways and Means
committee, passed 26 USC Section 5891, et seq. making it clear that structured settlements could
be transferred and that no adverse tax consequence would attach. As part of providing this
clarification, the Congress required that a transfer of structured settlement payment rights be
pursuant to a state transfer statute finding that the transfer was in the best interest of the selling
annuitant. Employees and officers of the petitioner, Settlement Funding, appeared at the
congressional hearing referenced above and worked tirelessly in the late 90's and early 2000's to
obtain the passage of 26 USC Section 5891 and to pass state transfer laws around the country.
Almost every state now has a structured settlement statute which provides for unprecedented
levels of consumer safeguards prior to an individual being permitted to sell a structured
settlement. This is so notwithstanding the fact that the decision to accept the structured
settlement, as outlined above, is typically the result of a simple negotiation between plaintiff and
defendant and not as consequence of the independent judgment that the recipient is unable to
manage their financial affairs. The structure settlement transfer statutes and the provisions of 26
USC Section 5891, et seq. make it clear that both federal and state legislators recognized the
need for liquidity in the secondary market for structured settlement payments. Provided that the
transfer statute is adhered to, the court should permit the transfer of the structured settlement
payments provided that such transfer is in the best interest of the payee.
MAY-10-2009 11:15 FROM:WILLIAM TAYLOR 7177899955 TO:18006007161
Veriflcadon
I verify that the statements made in this affidavit are true and donut. I understand that
false statements herein are made subject to the penalties of 18 Pa.C.S. §4904, relating to Mworn
falsification to authorities.
P.8
n?rE:QS'";1U ?C?
ermayne M. Webber a/k/a Jemayne Webber
MAY-10-2809 11:13 FROM:WILLIAM TAYLOR 7177899955 TO: 18006W7161 P.2
ABSOLUTE AS9lG msw AGRBB SNT
(TH "AGRE@aIENV I
May 10, 2000
I, .lenmayns M. Webber, (111", "lute" or "Assignor") residing at 211 Academia Way $Nppend urg, PA 17257-2168 am
entitled to 46 nhonthly payments each In the amount of $434.00 commencing on May 3, 2011 through and including
April 3, 2015; 120 monthly payments each In the amount of $850.00 commencing on May 3, 2015 through and
including April 3. 2025 and 120 monthly payments each In the amount of $2,000.00 corhmenc i g on May 3, 2025
through and Including April 3, 2035 (the "Periodic Payments") on account of the settlement of a can personal
ir4ury claim, the settlement of which is memorialized in that certain settlement agreement dated $eptember 24,
2001(1 he "Settlement Agreement'). The Periodic Payments are due to me from Madife Insurance Company at CT
(the "Settlement Obligor") under the terms of the Saitlement Agreement and are being funded by an annuity Issued
by W E% Insurance Company of CT (the "Annuity Issuer") bearing annuity contract number
344308AGS"100000026178.
A. I hereby sell, assign and convey to Settlement Funding, L.L.C. (the "Assignee") and its assigns through an
assignment all of my rights to and interest In and to the following payments due or to become due under the
Settlement Agreement:
120 mordhly payments each In the amount of $8S0.00 commencing on May 3, 2015 through
and including April 3, 202.6 (the "Assigned Payments"); and
In consideration for this assignment, Assignee shall pay to me the sum of: $15,444~08 (the "Assignment Prime").
B. 1 hereby make the following unconditional representations, warranties and promises:
1 No one other than me has any interest or claim of any kind or nature in, to or under the Assigned
Payments I am assigning hereunder.
2. 1 am not indebted to anyone that woad effect in any way either the assignment of the Assigned
Payments referenced above or Assignee's absolute rights to receive same.
3_ 1 agree to conduct my affairs so as to ensure that Assignee obtains all of the benefits of the
assignment contemplated hereby.
C. I agree that the following shah be considered an event of default by me under this Absolute Assignment
Agreement:
1. The representations set forth In Paragraphs 51 and B 2 above are at any time not true.
2. i=allure by me to perform the promise set forth in Paragraph 0 3 above.
3. Failure by the Settlement Obligor or the Annuity Issuer to make any one or more of the Assigned
Payments as a result of any act by me, my estate or any of my heirs.
4. Failure by the Settlement Obligor or Annuity Issuer to forward one or more Assigned Payments to
Assignee as a result of any act by me, my estate or any of my heirs.
5. Failure by me to forward promptly to Assignee any Assigned Payment received by me from the
Settlement Obligor or the Annuity Issuer.
6. Failure by me to AM any other obligation of mine under this Agreement.
D. The following are conditions precedent to Assignee's obligation to pay me the Assignment Price:
1. Assignee shall be whistled, In its sole discretion, that there are no claims or interests of any kind or
nature whatsoever that do or may aifed Assignee's rights to or interest in the A signed Payments
and Assignee's ability actually to receive same on the dates and in the amounts set forth herein.
2. Assignee shall have received a final non-appealable court order, or a signed acknowledgment from
Settlement Obligor and the Annulty Issuer satisfactory to Assignee M its sole discretion (such court
order or admawledgement together are hereinafter referred to as the "Order"), authorizing the
transfer by assignment of the Assigned Payments (which may continue to be made out to my name)
to Assignee, and directing that the Periodic Payments due on or after the day of the Order be
forwarded, or authorizing the forwarding of the Periodic Payments, directly to Assignee.
3. Assignee shall have received final financing approval from applicable funding source(s).
MAY-10-2009 11:13 FROM:WILLIA11 TAYLOR 7177999955 T0:18006007161 P.3
E. Under this Agreement and only to the extent permitted by law Assignee and I Intend to create a SscaxRY
interest under Art io 9 of the Uniform Commercial Code of the gists designated in Paragraph F below, In my rights
to and interest in the Assigned Payments, which rights have been assigned to Assignee as General Intangibles
under Article 9 of the Uniform Commercial Code of the state designated In Paregraph F below. This Agreement
shalt also function as a security agreement. This security Interest secures payment of the rights assigned and
performance of my obligations under Paragraph 8 above. Assignee may direct any eocount debtor, obligor on an
Instrument, including, without Imitation, the Settlement Obligor or Annuity Issuer, to make periodic payments directly
to Assignee as contemplated by the Uniform Commercial Code. Assignee may go a UCC-f financing statement to
perfect Its rights hereunder.
Interpreted inn accordanncee With the el low o by applicable state resid statutory low, this Agemnt shelf be governed by and
Any and all controversies, claims, disputes. rights, interests, suits or causes of action arising out of or relating to this
Agreement and the negotiations related thereto, or the breach thereof, shelf be settled by binding arbitration
administered by the American Arbitration Assocatiom The demand for arbitration shall be flied in writing with the
other party to this Agreement and with the American Arbitration Association offices in your state of residence. The
8rbitratton shall be held in the largest city in your state of residence. The arbitration shall be held before a single
arbitrator selected in accordance with the Commercial Arbitration Rules of the American Arbltrattion Association in
effect at the time that the demand for arbitration is filed- Discovery, specitieihr including Interrogatories. production
of documents and depositions shall be at the discretion of the arbitrator and to the extent permitted she# be
conducted in accordance with, and governed by the Federal Rules of Civil Procedure.
A demand for arbitration shall be made within a reasonable time after the claim, dispute or other matter in question
has arisen. In no event, shall the demand for arbitration be made after the date when inNitution of lsgai or equitable
proceedings based on such dakn, dispute or other matter in question, would be barred by the applicable statute of
limitations.
No arbitration arising out of or relating to this Agreement shall include, by consolidation or joinder or in any other
manner, an additional person or entity not a party to this Agreement, except by written consent of the parties hereto,
containing a speoMo reference to this Agreement and signed by the entity sought to be joined. Consent to
arbitration Involving an addtlfOral person or entity shall not constitute consent to arbitration of any deim, dispute or
other matter in question not described in the written consent or with a person or an* not named or described
therein. The foregoing agreement to arbitrate and other agreements to arbitrate with an additional person or entity
duly consented to by parties to this Agreement, shall be specifically enforceable in accordance with applicable taw In
any court having jurisdiction thereof:
The award rendered by the arbitrator shall to foal, and judgment may be entered upon it in accordance with
applicable law in any court having jurisdiction thereof. Such arbitrator shelf identify the substantially prevailing party
and shall include legal fees and expenses for the substantially prevailing party.
This provision does not apply to the extent inconsistent with applicable state law regarding the transfer of structured
settlement payments. In such case any disputes between the parties will be governed In accordance with the laws
of the domicile state of the payee and the domicile state of the payee is the proper venue to brim any cause of
action arising out of a breach of the agreement.
G. I hereby grant to Assignee an Irrevocable Power of Attorney with full powers of substitution to do all acts and
things that t might do regarding the Assigned Payments and any and all rights I have under the Settlement
Agreement with respect to the Assigned Payments, Including, Without Imitation, the power to endorse chedts, draft
or other Instruments, the power to after, edit and change payment Instructlorm and/or beneftlery designations and
any other act which, in the sole discretion of Assignee as my Attorney-fn-Fact is necessary or expedient for it to
obtain all of the benefits of the bargain contemplated by this transaction. This power of attorney Is coupled with an
interest and shall survive my death or disability.
H. In the event that prior to the consummation of the transaction contemplated hereby I receive any of the
Assigned Payments, or any portion thereof, the Assignment Price shall be reduced In like amount and the terms of
Na Agreement regarding the payments to be assigned shall be deemed to be adjusted accordingly. In the event
MAY-10-2009 11:13 FROM:WILLIAM TAYLOR 7177899955 TO: 18096007161 P.4
Assignee receives or otherwise comes into possession of any of the Periodic Payment(s) or portldrn(s) thereof which
are not hx*xled In the payments being absolutely assigned to Assignee hereunder, Assignee shag kwmrd such
amount(s) to me at the address set forth above within seven (7) days of receipt of such amount(s).
1. Assignee shall be entitled to discharge any adverse daims against Assignor or any of the Assigned
Payments whether or not such adverse dsime are disclosed. Assignee may, provided Assignee furnishes prior
written notice to Assignor, pay any and all amounts necessary or. It the Assignment Prim hoe been deposited into
an escrow account, instruct the escrow agent to pay any and all amourits necessary to discharge such brrs or other
adverse claims, end the Assignment Price shag be reduced by the amount of any such psyme L Adverse claims
may include disclosed ernounts to be deducted by Assignee from the Assignment Price to pay Assignee, as servkxr
for Peachtree Finance Company, LLC, to enable Assignor to obtain Peachtree Finance Company, LLVs release of
its encumbrance on a portion of the Assigned Payments, which portion of Assigned Pats relate to prior transfer
transaotion(s) consummated prior to the effective date of the applicable transfer act(s) which encumbrance must be
released for the transaction contemplated herein to be consummated.
J. I know that it will take some time for the Settlement Obligor and the Annuity Issuer to receive and process
the court order once it Is granted. I would like to receive the Assignment Price or a portion thereof as soon as
possible thereafter. Accordingly, t hereby request Assignee to pay me a portion of the Assignment Prim as soon as
possible after the court order is granted and authorize Assignee to hold in escrow an amount It deems necessary or
advisable h m the Assignment Price (the "Esorow Amount"} until all oondHions precedent have been satisfied,
Including, without limitation, the receipt by Assignee of the Settlement 0b%or and ft Annuity issuer's
acknowledgment of the terms of the court order in writing and their agreement to honor and comply with same. At
such time or earlier as Assignee may detwolne, I understand that Assignee will send the Escrow Amount to me
minus any Assigned Payments that the Annuity Issuer and/or Settlement Obligor sent to me while the Settlement
Obligor and the Annuity Issuer were processing the court order.
K. This Agreement shall take effect on the date it is signed by me (the Assignor) or on such later date
prescribed by applicable statutory law.
L. All disclosure statements are a materiel part of this Agreement and shall be read In pars materla herewith.
In witness whereof 1 hereunto set my hand. I „r,,,,_.,/
STATE OF Mmayne M. Webber
COUNTY OR CITY OF ,(f!9 ??'?
On the ?D day of,_ _,,. ,_• In the year before me, the undersigned, personally
appeared Jennayne M. Webber, personally known to me or proved to me on the basis of satiafectory evidence to
be the Individual(s) whose nrxne(s) Is (are) subscribed to the within instrument, and acknowledged to me that
tWshe/thay executed the some in hislherltheir cape ty(les), and that by hisfierNtal signature(s) on the Instrument,
the Individual(s), or the person upon behalf of which the Individual(s) acted, executed the instrument.
•e%
My Commission expires on
Accepted:
air
Set ment F d ! l .L.C.
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Dace
PT;,iiaA E DO NOT SIGN TKIS
DOCUMEN'T' UNTIL, 05110/2M
Nar4
wru.raM R TAYLOR
NOW PLM
SPRING Twp MRr eouNh
My c=Mk ion rut **$ don 27.201 o
MAY--10-2099 11:14 FROM:WILLIAM TAYLOR 7177899355 TO:18006007161 P.5
IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA
PE'1'1TI014 OF SETTLEMENT
FUNDING LLC A& PEACHTREE )
sETrLEMENT FUNDING TO ) No•
TRANSFER STRUCTURED }
SETTLEMENT PAYMENT RIC3KS )
Payee's Affidavit in Support of
Petition to Transfer Structured Settlement Rights
I, Jermayne M. Webber elide Jeamyne Webber, the payees, verify that the statements
below are true and correct:
1. Payee's name, address and age: Jermayne M. Webber aWa Ja myne Webber,
residing at 211 Academia Way, Shippmsburg, PA 17257.2168 and I am 19 years old
2. Marital Status:
X NeverMarried; Married; separated; Divorced
if married or separated, name of spouse:
3. Minor children and other dependents: No cWdren.
Names, ages, and places of residence:
4. Income:
(a) Payee's monthly income and sources: I am currently employed at Red Robbins
Restaurant where I earn $900.00 a month. In addition, I will begin to receive
structured settlement payments of $2,000.00 per month starting on May 3, 2025
through April 3, 2035.
MAY-10-2009 11:14 FROM:WILLIAM TAYLOR 7177899955 TO, 18006007161 P.6
(b) If presently married, spouse's monthly income and sow"' N/A-
Child support, alimony or alimony pendants lits:
Obligation to pay: _ Yes - &-No
if yes, state the amount of the obligation, to whom payable, and whether there are
arraarages:
6. Previous transfers:
Have you previously filed a petition to transfer payment rights under the structured
settlement that is the subject of this petition? „Lyes...._ No
if yes, far each petition that you filed,
(a) if the transfer was submitted for court approval, list the court, the case caption and
case number, and state whether the court approved or disapproved the transfer:
in the court of Cominon Pleas of Cumberland County, Pennsylvania, IN RE:
dermayne M. Webber, Petition to Transfer 3truchued Settlement Payment Rights,
Civil Docket # 2008-7477.
The transfer was approved.
(b) If the transfer was approved,
(1) State the name of the transferee and Identify (listing due dates and
payment amount(s), the payments involved in the transfer: The transferee was
Settlement Funding, LLC, and the payments involved were 48 monthly payments
each in the amount of $434.00 commencing May 3, 2011 through mid including
Apr113, 201 5.
MAY-10-2009 11:14 FROM:WILLIAM TAYLOR 7177899955 TO: 18006007161 P.7
(li) State the amount of money and the manner in which the money was used:
I received approximately $7,000.00, which I used to lease an apartment.
(c) Have you ever Ww&rred payments without court approval? NO. If so, please
explain:
7.
Reasons for transfer.
Describe in detail your reasons for the proposed transfer, including an explanation as to
why a sale of a lesser amount of the structured settlement will not better serve your
interests: I plan to use the entire proceeds of approximately $13,000.00 to retain a lawyer
for a legal matter in which I am involved. A sale of a lesser amount will not allow me to
afford this expense.
Payment of debts:
If you seek the transfer in order to pair debts, list each debt, including the name of the
creditor and the amount presently owed: N/A.
Debt
Creditor
Amount owed
$
MAY-10-2009 11:18 FROM:WILLIAM TAYLOR 7177899955 TO:18006007161 P.23
PENNSYI..VANIA TRANSFER DISCLOSURE
Payee: Jermayne M. Webber; resident of: PA
A. Amounts and due dates of the structured settlement payments to be
transferred: 120 monthly payments each in the amount of $850.00
commencing on May % 2015 through and including April 3, 2025.
B. Aggregate amount of such payments: $102,000.00
C. (1) Discounted present value of such payments: $78,548.87
(2) The discount rate used In determining such discounted present
value: 2.40 percent as of May 4, 2008.
D. Gross amount payable to the Payee in exchange for such payments:
$15,444.08
E. Itemized listing of all brokers' commissions, service charges,
application or processing fees, closing costs, filing or administrative
charges, legal fees, notary fees and other commissions, fees, costs,
expenses and charges payable by the Payee or deductible from the
gross amount otherwise payable to the Payee: Legal Fees: $2,000.00;
Processing Fee: $200.00.
F. Net amount payable to Payee after deduction of all commissions,
fees, costs, expenses and charges described above: $13,244.03
minus any advances made to Payee against the amount payable to
Payee.
G. The quotient, expressed as a percentage, obtained by dividing the
net payment amount by the discounted present value of the
payments: 10.86%.
N. Amount of any penalty and the aggregate amount of any liquidated
damages, Inclusive of penalties, payable by the Payee In the event of
any breach of the transfer agreement by the Payee: NONE
MAY-10-2009 11:18 FROM:WILLIAM TAYLOR 7177899955 70:18006007161 P.24
1. Payee acknowledges receipt of, and acknowledges to have read and
understood, the above disclosure statement and information required
to be d d by Payee's applicable state statute(s).
Initla
By signing below you are confirming that you received a copy of this
disclosure at least 10 days prior to executing your transfer agreement.
rmay a M. Webber
Date
MRY-10-2009 11:19 FROM:WILLIAM TAYLOR 7177899955 M:18096507161 P.25
NOTICE (PAl
Payee: Jermayne M. Webber
IMPORTANT NOTICE: You are strongly urged to consult with an
attorney who can advise you of the potential tax consequences of this
transaction.
I acknowledge receipt of the above notice.
By signing below you are confirming that you received a copy of this
notice at least 10 days prior to executing your transfer agreement.
Jermayne M. Webber
os/ 0-m
Date
MAY-10-2009 11:19 FROM:WILLIAM TAYLOR 7177899955 70:18006007161 P.26
ACKNOWLEDGEMENT (PA)
Payee: Jermayne M. Webber
(Please initial the following statement)
I expressly waive Independent legal advice regarding the implications of
the transfer, Including considerations of the tax ramiticagone of the
transfer.
dais)
Jermayne M. Webber
Date
MAY-10-2009 11:19 FROM:WILLIA31 TAYLOR 7177899955 M:1800600716l P.27
CONNECTICUT TRANSFER DISCLOSURE
Payee: Jennayne M. Webber; resident of: PA
A. Amount and due dates of the structured settlement payments to be
transferred: 120 monthly payments each in the amount of $850.00
commencing on May 3, 2015 through and Including April 3, 2025.
B. Aggregate amount of the payments: $102,000.00
C. Discounted present value of the payments: $78,548.87; the
calculation of current value of the transferred structured settlement
payments under federal standards for valuing annuities and is
determined by applying a (discount) rate of 2.40% as of May 4, 2009.
D. Gross advance amount: $15,444.08
E. itemized listing of all applicable transfer expenses, other than
attorney's fees and related disbursements payable in connection with
the transferee's application for approval of the transfer, and the
transferee's beat estimate of the amount of any of those fees and
disbursements: Processing Fee: $200.00.
F. Estimate of the amount of attorney's fees: $2,000.00
C. Net advance amount: $13,244.08
H. Amount of any penalties or any liquidated damages payable by the
Payee in the event of any breach of the transfer agreement by the
Payee: NONE
1. You have the right to cancel the transfer agreement, without penalty
or further obligation, not later than the third business day after the
date the agreement is signed by you.
J. You are advised to seek independent professional advice regarding
the transfer.
MAY-10-2009 11:19 FROM:WILLIAM TAYLOR 7177899955 TO., 18006007161 P.28
K. Payee acknowledges receipt of, and acknowledges to have read and
understood, the above disclosure statement and information required
to be sed by Payee's applicable state statute(s).
Initiats•
By signing below you are confirming that you received a copy of this
disclosure at least 3 days prior to executing your transfer agreement.
Jermayne M. Webber
10-57 /0&:R Date
MAY-10-2009 11:16 FROM:WILLIAM TAYLOR 7177899955 TO: 18096007161 P.12
DISCLOSURE AFFIDAVIT
I, Jermayne M. Webber, being of full age and duly sworn according to taw, upon my oath
depose and say:
1- I currently reside at 211 Academic Way, Shippensburg, PA 17267-2168.
2. 1 am over the age of (18) years old and am I make this affidavit upon my own
personal knowledge.
3. 1 received all of the statutorily required Disclosures on 0510112009, by E-mail, at
the following e-mail address: lermeynewebber@hotmall.com
Further, the affldevit sayeth not.
ermayne M. Webber
, 0-02
Date
STATE OF ?1,I/SyLL_ A?fJ//Qr
COUNTY OR CITY OF
On the day of in the yeepW? before me, the
undersigned, personally appeared Jertnayne M. Webber, personally known to me or proved
to me on the basis of satisfactory evidence to be the individual(s) whose name(s) is (are)
subscribed to the within instrument, and acknowledged to me that he/shelthey executed the
same in Father/their capacky(les), and that by hie/her/their signature(s) on the Instrument,
the Individuaks), or the person upon behaff of which the Individual(s) acted, executed the
Novi M
WK" R TAYLOR
?N PubMc
Von TWR MARY Comm
my ca nmwm expw ion 27, 2010 Not ?-
My Commission expires on
IN THE COURT OF COMMON PLEAS OF THE 39TH
JUDICIAL DISTRICT, PENNSYLVANIA-FRANKLIN COUNTY BRANCP
Jermayne Mollo Webber, CIVIL ACTION
by his parents and natural
guardians, Kevin G. Webber s
and Tammy L. Webber, No. 2001-2986
Plaintiff Judge: ----w
VS.
Donald F. Pratt, a
a:
Defendant
v
.D
The Petition of Kevin G. Webber and Tammy L. Webber, his wife,
parents and natural guardians of Jermayne Mollo Webber,
respectfully represents:
1.
Kevin G. Webber and Tammy L. Webber, his wife, are the parents
and natural guardians of Jermayne Mollo Webber, a minor, having a
date of bir_h of May 3, 1990.
2.
The minor plaintiff resides with petitioners in the Borough n°.
Shippensbuzg, Franklin County, Pennsylvania, his post office
address being 400 Lurgan Avenue, in said Houough.
3.
On January 19, 1997, the minor plaintiff was involved in an
accident in which he sustained a fracture of his right femur,
abrasions of his forehead, a hematoma on his upper lip, bilateral
lamina pacyracea fractures, fracture of the right frontal bo;e of
his nose, bilateral, orbital roof fractures and bilateral cribiforrr.
plate fractures.
4.
At the time of the accident, the minor plaintiff was
attempting to cross Pennsylvania Route 11 when he was struck by a
vehicle operated by the defendant.
3
5.
Following the happening of the incident referred to above,
Petitioners retained, as counsel, the law firm of Black and Davison
to investigate the incident, prepare the damage aspects of T-119
claim, and present the claim to defendant's insurance carrier.
Marked as Exhibit "A", and attached hereto, is a true and cortect
copy of the contingent fee agreement with the law firm of Stack ano
Davison.
6.
After retention, the law firm of Black and Davison obtained
and analyzed the appropriate incident reports, medical and hospitat
reports, and consulted with an accident reconstruction expert who,
along with counsel, conducted an on-sight inspection of the
accident scene and interviewed witnesses to the accident. Counsel
for petitioners also investigated the availability of liability end
underinsured motorist coverage to determine whether there was
applicable insurance against which a claim could be made by
petitioners on behalf of their son.
7.
As a result of the aforementioned i.nvestigat.ion, counsel
determined that petitioners had a viable claim against the
defendant in the above-captioned matter and entered into
negotiations with Nationwide Insurance Company, defendant's
insurance carrier, for the purpose of obtaining fair and reasonable
compensation fox the minor plaintiff.
8.
As a result of said negotiations, Nationwide insurance Companv
offered the sum of fifty thousand ($50,000.00) dollars in
settlement of petitioners' claim against the defendant, said su:n
representing the full liability policy limits of defendant's
policy.
9.
On September 24, 2001, your Honorable Court entered an order
approving the settlement of the liability claims. Marked as
Exhibit "B" and attached hereto is a true and correct copy o_ said
Ordex of Court.
10.
Concurrently with the negotiations with Nationwide Insurance
Company, counsel for petitioners entered into negotiations Witt,
Travelers Property and Casualty Company which provided underinsured
motorists covexage for Patricia Cashill, the mtzor platnt.ff's
former foster parent.
11.
At the time of the accident, Patricia Cashill maintaLned
underinsured motorist coverage pursuant to her automobile insurance
policy no. OJK748-032677175-3x1 issued by Travelers, which policy
had split underinsured motorist benefits of $100,000/$300,00n.
Marked as Exhi.b?t "C" is a true and correct copy of the coverages
provided to Patricia Cashill by Travelers.
12.
As a result of the aforementioned negotiations, Travelers has
offered the sun of one hundred thousand ($100,000.00) dollars in
settlement of petitioners' underinsured motorist clam, said amoure
representing the full underinsured motorist policy limits of the
American policy.
l3.
Travelers has certified that Patricia Cashill has no other
automobile or umbrella coverage th-wough Travelers which might
provide a source of underinsured motorists benefits to the minor
ulaintiif. Marked as Exhibit "Dn is a true and correct copy cf
correspondence, dated October 31, 2001, containing said
certification.
14.
Counsel for petitioners has conducted an invest2gation !n an
effort to locate other coverage, which search has failed to reveal
the existence of any other UIM coverage as evidenced by Exhibit "E"
attached hereto.
15.
Counsel for petitioners is of the opinion that the proposed
settlement is fair and reasonable in light of the fact the:
Travelers has offered its underinsured motorists policy limits and
no other underinsured motorist coverage is available.
16.
All debts and obligations arising out of the acc=den:,
including, but not necessarily limited to reimbursement of cash and
medical assistance have been paid or provided for, and there are no
liens against the settlement proceeds.
'7,
11.
Subject to your Honorable Court's approval, B:atk and Devisor
has agreed to counsel fees of twenty-five thousand ($25,000.00)
dollars for the prosecution of the above-referenced underinsured
motorist claim, said amount representing 25% of the gross recovery.
16.
Counsel for petitioners has incurred expenses wh»ch a m
itemized on Exhibit "F", attached hereto, for which reimbursement
is sought.
19.
From the proposed one hundred thousand ($100,00o.00) dol:.ars
settlement, it is proposed that the following deductions be made:
Counsel Fees (25%) $ 25,000.00
Out-of-Pocket Expenses 300.00
Reimbursement of Pa Dept of
Public Welfare Lien S 963.21
Total $ 26,263.23
20.
Petitioners aver that this settlement, after payment of
counsel fees, expanses, and reimbursement to the Commonwealth, -a
to be used for the purchase of a Structured Settlement Annuity.
Marked as Exhibit "G", and attached hereto is a schedule o!
periodic payments provided for under said structured settlement
annuity to be issued by Travelers Life Insurance Company, a 1:,;:o
insurance company having an "AW credit rating by A.M. seat.
Marked as Exhibit "H" is a Best's Rating Report on Travelers Life
Insurance Company.
21. '
The cost of the structured settlement annuity referred to
above is one hundred and two thousand, seven hundred and eighty I
_.,
($102,780-00) dollars. Marked as Exhibit ..,. and attached here to
is an evaluation of the proposed structured settlement pezfotmed by
Legal Economic Evaluations, Inc. attesting to the cost of the
proposed structured settlement annuity.
WHEREFORE, petitioners request that:
(1) That they be permitted to enter into tre
settlement recited above;
J
l
(2) That the net settlement proceeds be
invested 3n a structuged settlement
annuity as described in the attached
Exhibit "G".
(3) That they be authorized to execute an
underinsured motorist release ir favor of
rravelers, and
(4) That an order of distribution of the
proceeds from the J,nstant settlement be
entered as follows:
TO: Black and Davison, attorneys' fees . . . . . . . S 25,300.03
TO: Black and Davison., reimbursement
of out-of-pocket expenses . . . . . . . . . . . $ 300.00
TO: Reimbursement of medical assistance . . . . . . S 963,21
TO: Purchase of structured settlement annuity .. . . $ 73,736.73
TOTAL . . . . . .
. $100,003.0c
Respectfully Submitted,
0,
peat eove, Esc.
een Street
13
C.hambersburg, PA 17201
(717) 264-5194
I.D. Ito. 09837
OF COUNSEL:
SLACK AND DAvISON
92 West Queen Street
Chambersburg, PA 17201
Date: November g,_, 2001
3
VI RIFICA7TI
I, Tammy L. Webber, have read the foregoing ?etition for
Approval of Minor Plaintiff's Compxomise and Settlement of
Jndexinsured Motorist Claim and Distxibution of Proceeds which has
been drafted by my counsel. The factual statements and/or denia:s
contained therein are true and correct to the best of my knowledge,
information and belief. T am authorized to make this Verificazion.
This Verification is made only as to the factual averments
contained therein and not to regal conclusions and averments
authorized by counsel in his capacity as attorney for the party or
parties hereto.
This Verification is made subject to the penalties of 18 pa.
C.3., Section 4904, relating to unsworn falsification to
authorities which provides that, if I knowingly made false
averments, I may be subject to criminal penalties.
. tLhi2 X LUL G-t. T
Tammy L. ebber
Date: November 2L_, 2001
J
IN THE COURT OF COMMON PLEAS OF THE 39TH
JUDICIAL DISTRICT, PENNSYLVANIA-FRANKLIN COUNTY BRANCH
CIVIL ACTION
No. 2001-2986
Judge:
VS. ?,
Donald F.. Pratt, ev
Mp
Defendant .gyp 1? -C-C
NOW, this _ day of Atwmu.,&? , 2001, upor,
consideration of the within Petition, it is hereby ORDERED,
Jermayre Mollo Webber,
by his parents and natural
guardians, Kevin G. Webber
and Tammy L. Webber,
Plaintiff
ADJUDGED AND DECREED that the settlement of the underinsured
motorist claims of Kevin G. Webber and Tammy L. Webber, as parents
and natural guardians of Jermayne Mollo Webber, a minor, against
Travelers Property and Casualty Company should be and the same are
hereby approved. Distribution of the gross proceeds of one hundred
thousand ($100,000.00) dollars shall be as follows:
TO: Black and Davison, attorneys' fees (25%) . . . . $ 25,000.00
TO: Black and Davison, reimbursement
of out-of-pocket expenses . . . . . . . . . . . $ 300.0;;
TO: Reimbursement of medical assistance . . . . . . $ 963."
TO: Purchase of structured settlement annuity . . . $ 73,236.29
TOTAL . . . . . . . . . . . . . . . . . . . . . $100,000-00
The sum of $73,736.79 referenced above shall be invested wi.kr
Travelers Life Insurance Company, an A++ rated life insurance
company, in a structured settlement annuity paying at 3east the
BLACK AND DAVISON
.., Attorneys-at-Lav
92 West Queen Street
P. 0. BOX 513
Chanbersburg, PA 17201-OS13
Robert G. Schollaert (717) 264-5194 Jan 0. Sulcove
Jermayne M. Webber BILLING DATE 08-31-02
400 Lurgan Avenue
Shippensburg, PA 17257 ACCFT NO. JaS16361.00
RE: B.I.
DATE EXPENSES
04-20-01 Carlisle Police Dept - accident report 015.00
05-03-01 Middlesex Township Police - report $15.00
05-17-01 Recordex - medical records $67.96
06-18-01 WIlmal's Photography - photos $79.50
07-26-01 Sollenberger's - registration info $19.00
09-30-01 Prothonotary - filing fee $50.50
TOTAL FOR THE ABOVE EXPENSES $246.96
TOTAL FOR CURRENT PERIOD $246.96
PREVIOUS BALANCE $0.00
TOTAL $246.96
TOTAL PAYMENTS $0.00
AMOUNT DUE $246.96
Please write the above account number on your chock and
make your check payable to black and Davison
**THM YOU**
s
IN THE COURT OF COMMON PLEAS Or THE 39TH
JUDICIAL DISTRICT, PENNSYLVANIA-FRANKLIN COUNT`; BRANCH
Jermayne Mollo Webber, CIVIL ACTION
by his parents and natural
guardians, Kevin G. Webber
and Tammy L. Webber, 2001-2996 v .n
Plaintiff Nudge: C ?-°r-
-< 91?= -o r'.
VS. N ~i
Donald F. Pratt,
Defendant
C,
a,
I
NOW, this 2 day of 2041, upon c;onsideraLior of
the within Petition, it is hereby ORDERED, ADJUDGED AVD DECREED
that the settlement of the claims of Kevin G. Webber and Tammy L,
Webber, as parents and natural guardians of ;ermayne Mollo Webber,
a minor, against Donald ?. Pratt, should be and the same are her b}
approved. Diatrtbution of the gross proceeds of fifty thousand
($50,000.00) dollars shall be as follows:
TO: Kevin G. Webber and Tammy L. $37,253.04
Webber, parents and natural
guardians of Jermayne Mollo
Webber
TO: Black and Davison - reimbursement $ 246.96
of out-of-pocket expenses
TO: Black and Davison - attorneys fees $12.500.00
(251)
Total $50,000.00
The foregoing sum of $37,253.04 shall be deposited in to
federally-insured separate account for the benefit of Jerrayne
Mollo Webber, and no withdrawal shall be made from said account
i
o
OrE coDR 11
_,
t
I
IN THE COURT OF COMMON PLEAS OF THE 39TH I
JGDrant DISTRICT, PENNSYLVANIA- FRAN_CLIN COUNTY BRANCH
Jexmayne Mollo Nebber, CIVIL ACTION
by his parents and natural
guardians, Kevin G. Webber
and Tammy L. Webber, 2001-2986
Plaintiff Judge:
vs.
Donald F. Pratt, ,
Defendant
until Je=mayne Mollo Webber attains majority, except as authorizes
by further Order of Court.
Petitioners are authorized to execute and deliver ali '
necessary documents to effectuate the said settlement as set forth
in the within Petition.
Petitioners are ordered and directed to submit to the Cour:
written verification of the establishment of a federal ly-insuzed
depository account for the benefit of Jermayne Mollo Webber.
BY THE COURT,
J gld L
J.
4, ene sS -'- i
T
IN THE COURT OF C0144ON PLEAS OF THE 39TH
JUMIAL DISTRICT, PUNiSYLVPrNIA-MMKLIN COWTY BRANCH'
Jermayne No?to Webber, CIVIL aCTrON
by ?_s parents and natural 1
t
guardians, Kevin G. Webber' 2Q01-
and Tammy 1. Webber,
Plaintiffs Judge:..
i
vs .
Donald P. Pratt,
Defendant j
ONNM or
NOW this 11 day of September, 2C01, the witz.in. Petition
having been aresentod read, considered, and ordered to be fi;-
the Z A-* day of PfFACe.E/ 2045, at 1--34 o'clock km. in =he
Courtroom designated by the Franklin County Court Admin.,strator
is hereby sett as the time and place for hear_ng art t:.he w trin
Petition.
?s r
7AV
MCI
> T
r j
i
I
I do hereby retains Black- um bavisoa, of Chambersburg,
Pennsylvania, as my attorneys to negotiate for me at settlement or
to institute for me in my name any legal proceedings or actions
that in their judgment are neces$Zry in conn tion with my claim
for damages et' statinad o the III day of gee ?-, 101117
against and any other person, firm, corporation or entity -w may-Bi
responsible for my claim, and/ox to obtain an amicable settlement.
I hereby give to my attorneys a °Powesr of Attorney to execute:
all documents connected with the claim for the proseenxtion of which
the attorneys are retained, including pleadings, contracts,
commercial paper, settlement agreements, Compromises sad raleame:s,
verifications, dismissals, orders, settlement checks and all others
domments that I could properly execute in, connection with this
lawsuit.
I agree not to settles or adjust the above claim or any
proceedings arising from said claim :nor to discuss said claim with
any other persons
I agree to pay attorneys, fees from the total amount recovered
from any source, except first party benefits (i.e. work ;loss and
medical benefits); on account of my claim, including my claim for
uninsured or underinsured motorist benefits, on the following
balsis
Settlement of third party tort
claim prior to filing of legal
action.
Settlement of third party tort
claim on or after filing of
legal action.
Settlement of uninsured or
underinsured motorist claims
prior to selection of my
arbitrator.
Settlement of uninsured or
underinsured-motorist claims
after selection of my
arbitrator.
2s%
-39 7`34 of total
sum recovered
33,13 q
-"4 of total sum
recovered
2S9.
a- #' of total
suin recovered
33')3%
-44D+ of total sum
recovered
Costs: Costs are to be paid from share of the total amount
recovered and includes, but are not limxteed toss
h?toeapiess, fax
charges, notaries, long distance telephone charge,s,
mileage for attorneys and staff, investigation chargee&$
photographs, court costs!, legal research, charges, medical records
costs, fees for police report, deposition coasts, expert witneae
fees, stenographer coets,and video deposition fees.
In the event that no recovery is obtained on this `claim, the
attorneys will make no charges for their time or services.
However, any costs or expenses which the attorneys may have
advanced on behalf of the claim must be paid by me: upon request by
said at tornetys .
As one possible settletttent option, I authorize the said
attorneys to explore the possibility of a structured settlement
through the use of deferred periodic payments. I agree that if m
claim ie settled through such structure, the attorneys' fees may be
paid directly to said attorneys from the insurance company, either
in one lump sure payment at settlement, or, at the sole option o
said attorneys and/oz' insurance company, deferred into future
payments. However, in any event, said attorneys, fees shall be
calculated in the percentage as met forth above based upon the: coat
of the structured settlement or present value thereof in accordance
with applicable: law.
The undersigned authorize the tape recording of telephone
conferences with ion G. sulcov?e or other employees of shack and
Davison for purposes of record keeping.,
IN HITMMS WHSWBOP, I have hereunto not toy hand and seal this
,. day of? 2041.
Witness:
,-.-
(SEAL)
ANL? NOW, this # day of 2001, the within
Agreement Is appravee
BLACK AND DAVISON
By._
LTAW . Su cave
page 2 of 2
Robert C. Schollaert
BLACK AND IMVISON
Attorneys-*tLast
83 West Queen Street
P. Q. DOX 513
Chanbersbrurq, PA 17201-0513
(717) 264-5194
jar""* x. Webber
400 LAtrgan Avenue
Shipponsburq, PA 17257
RE; B. Z.
DATE EXPENSES
Jan G. Sulcove?
BILLING MATS 09-31-01
ACCT 94. JGS36361.00
04-20--01 carlisis Police Dept - accident report $15.00
05-03-01 Middlesex Township Police - report $15.00
05-17-01 Recordsx - medical records $67.46
06-18--01 Wilm's Photography - photos $79.50
07-25-01 Solloobargex's - registration info $19.80
08-30-02 Prothonotary tiling gee $50.50
TOTAL POR Tug ABOVE v(MSES
TOTAL FOR CUMENT PJWOQ
P'REVIOUS' BALANCE
T'OT'AL
TotAL PAYMMS.
AMOUNT DUS
$246.96
$346.96
$0.00.
$246.96
$0.00
$246,.96.
VIO&Gs vrite o ab4vc acaoxutt llumbor on y+0ur check and
Make your check payable to black and Davison
•*THAM YOU**
11
IN THE COURT OF COWSON PLEAS OT THE 39TH
JUDICIAL DISTRICT, P9VKSYLVANIA-FPJWKLIN COMITY BRANCK
Jermayne Mono Webber,
by his parents and natural
guardians, Kevin .C. Webber
and Tammy L. Webber,
Plaintiff'
Vs.
IDonald F. pr'att
Defendant
CIVIL ACTION
t 2001-2386
Jraage
; ? '??
. ?,,
LS.
°
ems :
lid oa' ?e?s
NQW, this Y ,'day o: 2001, upor consWeration c_°.
then, within Petition, it is hereby ORDERED, ADJUDGED AND DECREED
.hat the settlement of the, claims of Kevin G. Webber and Tammy T.,
i
Webber, as parents and :natural guardians of Jeemaynea Vollo Webber.
a minor, against Donald F. Pratt, should be° 80d the esame are he.reht
approved. aistr;buttcn of the gross proceeds of fifty 'thousand
($50,000.00) dollars shall be as follows: r
TO; Kevin G. Webber and Tar.my $37,233.04
'
We3bber, parents and natural
guardians of Jermayne3 M611o
Webber
TO: 81ack and Davison reimblxsement $ 246.96.
of out-of-pocket expenses
TO': Black end Davisor. attorneys fees 512,500.00:
(25%)
Total $50,000,.00
The foregoing suit of $37,253.04 shall be deposited in y
fete'rally- insuured separate account for the benefit of Jermayn°
Mollo Webber, and no withdrawal shall be _rade from said account.
c
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IN THE COURT OF CO MOM MAS, Op' T;$8 39T4
JUDICIAL DISTRICT. PENUSYLVANIA- NKI19 COUNTY BRANCH
k
JGr Mayne Mo11Q Webber, CIVIL ACTION I
by his pa_ents and natural I
f guardians, Kevin G. Webber No. 2001-2986 r
and Tammy L. Webber, r
Judges-
Plaintiff
.; t
f, its
. I
i Oonald F Pratt,
r
Defendant
oil
NOW, thitC day of November, 2041, the within Egypt t -?r I?I
i
having been presented, read, considered, and ordered :,a he ` erg,
! the -M daffy of ^AA 2001, at 10 of clock, L;-M. ir. the 1
l Courtroom designated by the Franklin County Court Adw...tn?.str for i
hereby suet a:a the time and place for hearing r. they wit,;;.
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in. The Court of COMMON i of
39th Judioiai District - Pe wwyivania
Fra?kiln Countlt
Fite No2001
CIVIC. ACTION - LAW
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SOLD MOLL
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PRATT DONAW F ?' • ?+
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ORDER OF COUR1r
NOW. April 07..`2000 the above-csp*wwd matter having come before the
Prothonotary to determine the status. of the case by reason of inactivity that no statement of
Intention to proceed has been filed.
IT 19 ORDERED. that the case be terminated with prejudice for faiiurs to prosecute.
By THE COURT,
t ` e • - --r.r..
Unit L. Dowd;
AVVWXMWY
CC WOMA ?? LM PA 17201
Wig imp 01 rNE MOLLO
a
zN THE COURT OF COWON PLEAS OF THE 39TH
JUDICIAL DISTRICT, PENNSYLVANIA-FRANKLIN COUNTY BRANCH
JeMRaYn* M0110 Webber,
b,Y his parents and natural
guardians, Kevin G. Webber
and Tammy I. Webber,
Plaintiff
vs .
.
Donald F. Pratt,
Defendant
CIVIL ACTION
No. 2001-2'966
Judge:
annuitp benefits specified or. 'Exhibit` "G", attached to the within
Petition.
Petitioners are authorized ti o: and deliver a:.'
necessary instrutaenta to effefctusite the said compromise as ,se*_
forth in the, within Petition.
Counsel for 'Petitioners is directed to transmit to the coor:
fo. thwith a fully executed, true and correct copy of the Structured
Settlement Agreement evidencing the above terins.
BY THE CoUaT
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2009 MAY 1 4 101' 3 0
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Mark Th mas Sophocles (PA ID #74998)
MARK OMAS SOPHOCLES, LLC
21 Indus 'al Blvd., Suite 201
Paoli, PA 19301
Tel: (610) 651-0105
Fax: (610 651-0106
THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY
. PENNSYLVANIA- CIVIL DIVISION
IN RE: JERMAYNE M. WEBBER A/K/A JERMAYNE WEBBER
PETITIO TO TRANSFER STRUCTURED SETTLEMENT PAYMENT RIGHTS
CIVIL D CKET # 2009-
INITIAL ORDER OF COURT
On s Ah& day of 2009, it is ordered that a hearing on this
Petition to ransfer Structured Settlement Payment Rights will be held on ,
2009 in co oomj?_ at/,.26'clock Aft/PM. The payee shall bring income tax returns for
the prior two (2) years to the hearing.
Within seven (7) days, the transferee shall give notice of the hearing date to the payee,
the structured settlement obligor, the annuity issuer, the payee's spouse and any person receiving
child support, alimony, or alimony pendente lite. The transferee shall attach a certificate of
service to the notice of hearing date. A copy of the notice with the certificate of service shall be
filed with the court prior to the hearing.
W. 18 209t
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BY THE COURT:
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Mark T. Sophocles (PA ID #74998)
MARK THOMAS SOPHOCLES, LLC
21 Industrial Blvd., Suite 201
Paoli, PA 19301
Tel: (610) 651-0105
Fax: (610) 651-0106
IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY
PENNSYLVANIA- CIVIL DIVISION
IN RE: JERMAYNE M. WEBBER
PETITION TO TRANSFER STRUCTURED SETTLEMENT PAYMENT RIGHTS
CIVIL DOCKET # 2009-03066
FINAL ORDER
On this 4 day of June, 2009, it is ordered that the Petition to Transfer of Structured Settlement
Payment Rights is granted.
The court specifically fords that:
(1) The payee, Jermayne M. Webber, has established that the transfer is in the best interests
of the payee or his dependents, taking into account the welfare and support of his dependents, if
any;
(2) Based on the certification by an attorney for the transferee, Settlement Funding, LLC, and
the court having not been made aware of any statute, regulation or order that would be
incompatible with the proposed transfer, the transfer will not contravene any applicable federal
or state statute or regulation, or the order of any court or administrative authority;
(3) The transfer complies with the remaining requirements of the Structured Settlement
Protection Act, including Sections 3(a)(2), 3(a)(4), 3(a)(5) and 3(a)(6);
(4) The payments that are to be transferred are designated as follows:
monthly payments each in the amount of $850.00 commencing on May 3, 2015 through and
including April 3, 2025 (the "Assigned Payments").
,t
(5) the terms of this order shall survive the death of the payee and shall be binding on the
payee's heirs, beneficiaries and assigns;
(6) the payee shall receive from the transferee the gross amount of $15,444.08
(7) Metlife Insurance Company of CT is both the Annuity Owner and the Annuity Issuer.
Metlife Insurance Company of CT shall send the Assigned Payments, as each becomes due, to
Settlement Funding, LLC at P.O. Box 116476, Atlanta, GA 30368-6476 or to such other address
as designated by Settlement Funding, LLC.
BY THE COURT:
FILED-of ACE
OF 7HE PI^?O NOTAPY
2009 JU-11-9 PPS 1: 56
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