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IN THE COURT OF COMMON PLEAS
PENNSYLVANIA
CUMBERLAND COUNTY
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IN RE: ESTATE OF HARRY DULANY CATTS r?
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PETITION FOR APPROVAL OF SETTLEMENT
1. Your Petitioner, Nellie Catts, is the personal representative for the Estate of Harry
Dulany Catts, who is the deceased.
2. On April 26, 2009, Harry Dulany Catts was killed in a motor vehicle accident. At
the time of his death he was married to Nellie Catts.
3. Nellie Catts was appointed personal representative of the Estate of Harry Dulany
Catts on June 8, 2009, (see attached).
4. All sums set forth above constitute damages on account of personal
injury/wrongful death, arising from the occurrence, within the meaning of § 104
(a) (2) of the Internal Revenue Code of 1986, as amended.
5. There are two applicable insurance policies.
6. The alleged tortfeasor's policy, held by Infinity Insurance has a $50,000.00 limit
which has been tendered.
7. There is $50,000.00 in gap insurance / and or UIM coverage, available from
Nationwide Insurance which will pay an additional $50,000.00.
8. Medicare by way of CMS / MSPRC has asserted a lien, and is providing a final
figure, but it is believed to be less than $30,000.00
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9. The $100,000.00 in insurance payments from are to be divided pursuant to the fee
agreement as follows:
a. 25% of the first 50,000.00 and 5% of any amount thereafter to Rominger
& Associates as an attorney fee,
b. An unknown amount to Medicare for their lien interest, to be paid in full,
reduced by any deductions allowed by law, once the lien amount is known
and agreed upon.
c. The remainder of the net proceeds to be divided between decedent's wife
(his sole heir) as Wrongful Death proceeds and his estate as Survival
Action proceeds.
10. The Department of Revenue has no interest in this case, as the estate is a
Maryland Estate, and the funds will be paid into the estate and the wife, neither of
whom are in Pennsylvania.
WHEREFORE, your petitioner prays that the settlement afore referenced be
approved.
Respectfully submitted,
ROMINGER & ASSOCIATES
Date: March 2, 2011
Kar. Rominger, Esquire
155 South Hanover Street
Carlisle, PA 17013
(717) 241-6070
Supreme Court ID # 81924
Attorney for Petitioner
IN THE COURT OF COMMON PLEAS
CUMBERLAND COUNTY, PENNSYLVANIA
IN RE: ESTATE OF HARRY DULANY CATTS :
. No..
AFFIDAVIT
I hereby swear or affirm that the Foregoing is true and correct to the best of my
knowledge and/or information and belief. This is made subject to the penalties of 18
Pa.C.S §4904 relating to unworn falsification to authorities.
Date: &-111
Nellie Catts, Personal epresentative
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State of Maryland
LETTERS OF ADMINISTRATION
OF A SMALL ESTATE
Estate No. 64089
I certify that administration of the Estate of
HARRY DULANY CATTS JR
was granted on the 8th day of JUNE. 2009
to NELLIE IRENE CATTS
as personal representative(s) and the appointment is in effect
this 8th day of JUNE, 2009.
Q Will Probated June 08, 2009
(date)
11
Intestate estate.
Unprobated Will - Probate Not Required
Register of Wills for
RW 1107
VALID ONLY IF SEALED WITH THE SEAL OF THE COURT OR THE REGISTER
JOHN R. BLOYER
IN THE COURT OF COMMON PLEAS
CUMBERLAND COUNTY, PENNSYLVANIA
IN RE: ESTATE OF HARRY DULANY CATTS :
: No..
CERTIFICATE OF SERVICE
The same has been provided sent, addressed to responding counsel, by first class
mail, as follows.
Olive Fuller, Claims Representative
Nationwide Insurance
7125 Columbia Gateway Drive, Suite 350
Columbia, MD 21046
Amy Edwards, Claims Adjuster
Infinity Insurance Company
P.O. Box 830807
Birmingham, AL 35283-0807
Respectfully submitted,
ROMINGER & ASSOCIATES
Date: March 2, 2011
Karl Rominger, Esquire
15 South Hanover Street
Carlisle, PA 17013
(717) 241-6070
Supreme Court ID # 81924
Attorney for Petitioner