HomeMy WebLinkAbout01-0133ROBERT H. HARNER, as : IN THE COURT OF COMMON PLEAS OF
parent and natural guardian : CUMBERLAND COUNTY, PENNSYLVANIA
of ELIZABETH HARNER and :
KATIE HARNER, :
852 Wynnewood Road :
Camp Hill, PA 17011 :
Plaintiff : CIVIL ACTION - LAW
VS. :
JESSE G. HEREDA, : NO.: {?/~ Z3-~ ~ ~P
112 North 26~h Street :
Camp Bill., PA 17011 :
Defendant :
TO:
JOINT PETITION FOR APPROVAL OF A
COMPROMISE SETTLEMENT, A MINORS' ACTION
THE HONORABLE JUDGES OF THE COURT OF COMMON PLEAS
FOR CUMBERLAND COUNTY, PENNSYLVANIA:
AND NOW, come the Petitioners, Elizabeth Namer and Katie
Hamer, Minors, by and through their parent and natural guardian,
Robert H. Hamer, and Jesse R. Hereda, by and through his
counsel, Goldberg, Katzman & Shipman, P.C., who files this
Petition by respectfully stating the following:
1. Elizabeth Hamer is
her father, Robert H. Hamer,
Cumberland County,
a minor who currently resides with
at 852 Wynnewood Road, Camp Hill,
Pennsylvania.
father, Robert H.
Cumberland County,
Katie Hamer is a minor who currently resides with her
Hamer, at 852 Wynnewood Road, Camp Hill,
Pennsylvania.
3. By Order of Court issued October 8, 1998, Robert H.
Hamer has primary physical custody of Elizabeth Hamer and Katie
Hamer, as well as shared legal custody of those children. A
of Court is attached hereto as Exhibit "A".
copy of the Order
4. Jesse G.
of 112 North 26TM Street,
Pennsylvania, 17011.
5. On or about January 31,
were passengers in an automobile
Hereda is an adult individual with an address
Camp Hill, Cumberland County,
1998, the minor Petitioners
operated by Jesse G. Hereda.
The Hereda vehicle was
Township, York County,
control, after hitting
another vehicle in the
6.
resides
7.
traveling along Mt.
Pennsylvania, when
a patch of gravel,
Airy Road, Carroll
the vehicle lost
and collided with
other lane of travel.
This Court has jurisdiction in that the Defendant
in Cumberland County.
As a result of this accident, Elizabeth Hamer
allegedly suffered a 3 ½ centimeter laceration of her forehead.
She also suffered a contusion upon her face.
Ail of Elizabeth Harner's medical bills have been paid
sacrum.
10. Ail of Katie Harner's medical bills have be paid which
she was rendered for her alleged
accident, Katie Hamer claims to
a fractured pelvis as well as a fracture of her
she allegedly incurred as a result of this accident.
11. Defendant, while denying liability for any of the
alleged injuries to the minor Plaintiffs, has offered to
compromise these claims.
12. Defendant's insurance carrier has offered a payment of
$7,500 to Elizabeth Hamer, made payable upon approval of this
settlement by This Honorable Court.
13. Defendant's insurance carrier has offered a payment of
$32,000 to Katie Hamer, made payable upon approval of this
settlement by This Honorable Court.
14. The Petitioners have reviewed the proposed settlement
and believe the settlement to be fair, just and equitable, as
well as in the best interests of both Elizabeth and Katie Hamer.
15. Mr. Hamer has not been represented by counsel, thus,
there will be no attorney's fees or costs removed from the
settlement amount.
concerning the treaYment
injuries.
9. As a result of the
have suffered
agencies and not to be
competent
paid over
WHEREFORE,
Honorable Court
compromise settlements.
16. Mr. Harrier recognizes that the monies received in these
settlements are monies for the minor children and that the funds
must be deposited into interest bearing, restricted bank
accounts, insured by the Federal Government or one of its
removed, without prior Order of Court of
jurisdiction, with the balance of said monies to be
to the children upon reaching the age of majority.
Petitioness respectfully requests that This
enter and Order approving the foregoing
Respectfully submitted,
natural guardian of Elizabeth
and Katie Hamer
GOLDBERG, KATZMAN & SHIP~L~N, P.C.
Attorney I.D.No.: 78000
320 Market Street
P.O. Box 1268
Harrisburg, PA 17108-1268
(717) 234-4161
Attorneys for Jesse Hereda
ROBERT H. HARNER, as
parent and natural guardian
of ELIZABETH HARNER and
KATIE HARNER,
852 Wynnewood Road
Camp Hill, PA 17011
Plaintiff
JESSE G. HEREDA,
112 North 26th Street
Camp Hill, PA 17011
Defendant
: IN THE COURT OF COi~R~ON PLEAS OF
CUMBERLAND COUNTY, PENNSYLVANIA
CIVIL ACTION - LAW
NO.:
ORDER
AND NOW, this I~ ° day of ~.~.~ , 2001, upon
consideration of the parties Joint Petition for Approval of
Minors'
GRANTED.
detailed
Settlement, it is hereby ordered that the Petition is
The settlement proceeds are to be distributed as
in the Petition.
57041.1
BY THE COURT:
ROBERT H. HARNER, as :
parent and natural guardian :
of ELIZABETH HARNER and :
KATIE HARNER, :
852 Wynnewood Road :
Camp Hill, PA 17011 :
Plaintiff :
JESSE G. HEREDA, :
112 North 26th Street :
Camp Hill, PA 17011 :
Defendant :
IN THE COURT OF COMMON PLEAS OF
CUMBERLAND COUNTY, PENNSYLVANIA
CIVIL ACTION - LAW
NO.: 01-133 Civil Term
PRA~CIPE
TO THE PROTHONOTARY:
Kindly mark the docket in the above referenced matter
settled and discontinued with prejudice.
Respectfully submitted,