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HomeMy WebLinkAbout01-05-10 ~. I 4^w.1 . IN THE COURT OF COMMON PLEAS - - ~ 4-- ~ m ~-' ~-~ ~ CUMBERLAND COUNTY, PENNSYLVANIA ~ -, ~, _~ .__ c , ~. ~ ~ ctn .. ~~ «~i IN RE: ESTATE OF STEVEN G. DOLLINS c°, ~ -~, `-- No.: 2008-003 50 ~ `~' ~'~' ' r' c~ p cn n 1. Your Petitioner, Carolyn Dollins, is the personal representative for ~ Estate of Steven G. Dollins, who is the deceased father of the minors, Gage D 11 ns, Owen Dollins, and Taryn Dollins. ~'~~ 2. The minor children, Gage Dollins, was born on March 17, 2003, O e Dollins, was born on December 12, 2006, and Taryn Dollins was horn on F~bruary 8, 2008. 3. On Mazch 3, 2008, Steven G. Dollins was killed in a motor vehicle dident. At the time of his death he was single and had three minor children, Dollins, Owen Dollins, and Taryn Dollins. ~ '~ 4. Carolyn Dollins was appointed administratrix of the estate of Steve ~. Dollins on April 2, 2008, by .Glenda Fanner Strasbaugh, the Register f Wills of Cumberland County. ~~ 'i 5. All sums set forth above constitute damages on account f personal injury/wrongful death, arising from the occurrence, within the me g of § 104 (a) (2) of the Internal Revenue Code of 1986, as amended. 'i II 6. A $15,000.00 insurance payment from decedent's UIM carrier Progressive Insurance is to be divided pursuant to the fee agreement as follows: ~~ i, ',I III a. 25% to Rominger & Associates as an attorney fee, in the ~rnount of $3,750.00 (see attached fee agreement) '' '~ i b. 50% of the remaining $11,250.00 to the Estate, as the pro~e~ds of the survival action in the amount of $5,625.00. I II c. 50% of the remaining $11,250.00 to the Estate, as the pro~e~ds of the wrongful death action in the amount of $5,625.00, which will b~ placed in a federally insured bank or saving institution as permitted by th~ Rules of Civil Procedure for benefit of each of the minor children, in equal shares. 7. The Department of Revenue has agreed to an allocation of 50% of ~ awazd to i i the wrongful death action. (See attached letter) 8. Progressive has reviewed this matter and agrees to the content of this ~e~ition. WHEREFORE, your petitioner prays that the settlement afore referenced be approved. ~I 'III Respectfully submitted, ~I RONIINGER dic ASSOCIATE ~~ I! / ~- Date: January 5, 2011 Kaz~P~ominger, Esquire ~ ~I~ 155 South Hanover Street Cazlisle, PA 17013 I ' (717) 241-6070 Supreme Court ID # 81924 Attorney for Petitioner ', IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA IN RE: ESTATE OF STEVEN G. DOLLINS No.: 2008-00350 AFFIDAVIT I hereby swear or affirm that the Foregoing is true and correct to knowledge and/or information and belief. This is made subject to the Pa.C.S §4904 relating to unsworn falsification to authorities. hest of my Mies of 18 IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA IN RE: ESTATE OF STEVEN G. DOLLINS No.: 2008-00350 CERTIFICATE OF SERVICE !, The same has been provided sent, addressed to responding counsel, mail, as follows. Erica Conway, Claim Representative State Farm Insurance Companies Complex Claims unit P.O. Box 142 Concordville, Pennsylvania 19331 Respectfully submitted, ROMINGER & ASSOCIA' Date: January 5, 2011 v ~~ first class Karl E ominger, Esquire 155 outh Hanover Street Carlisle, PA 17013 ' (717) 241-6070 Supreme Court ID # 81924 ', Attorney for Petitioner ', I; I~ -_ _ - ~