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Home My WebLink About05-02-11 ~ ~., , e:-:~ ..°_' `~ -C7 ~ t.,~s k ~ ESQ. CHARLES E. PETRIE .._ ~ ~ ~~~.y ~ , 3528 Brisban Street ( ~T ~ t ry ~ ~ t ~''`' k.... ! ' ' -_,' Harrisburg, PA 17111 ~; ~ ~,--' ~ ~ ~ :_. (717) 561-1939 _ ~ =- (717) 561-4121 (FAX) _a ~' .:~, ~-~ o Sup. Ct. ID 29029 ~i. ATTORNEY FOR PETITIONER IN RE: : IN THE COURT OF COMMON PLEAS OF :CUMBERLAND COUNTY, PENNSYLVANIA ESTATE OF ELI CEKOVIC Deceased NUMBER : 21-09-981 PETITION FOR MODIFICATION OF ORDER NOW COMES Your Petitioner, ELLEN MARY MESSINGER CEKOVIC, Executrix of the Estate of ELI CEKOVIC, Deceased, by and through her Attorney, Charles E. Petrie, and respectfully represents as follows: 1. That Your Petitioner is ELLEN MARY MESSINGER CEKOVIC, the surviving spouse of Eli Cekovic (hereinafter referred to as "Decedent,") and the Executrix of his Estate. 2. That the Order signed by the Honorable J. Wesley Oler on April 29, 2011, has an error. The amount of the settlement is $250,000.00, not X300,000.00. Please see the attached Settlement Agreement for verification of the settlement amount. WHEREFORE, Your Petitioner respectfully requests that Your Honorable Court enter an Amended Order amending the settlement amount. Respectfully submitted, ~~ .,~ r~~ CHARLES E. PETRIE 3528 Brisban Street Harrisburg, PA 17111 SUP. CT ID NO. 29029 (717) 561-1939 Voice (717) 561-4121 Fax PetrieLawn,AOL. com -. _ i-• '; _. _ _ -~ .. :- _ ~..J 4 -._~ CHARLES E. PETRIE, ESQ. - ~ __ =;=, ~- : _ 3528 Brisban Street _ - ~ , ~ ~ ~ . ~ ~; ~ ~'~ ~__~ '~s Harrisburg, PA 17111 ~ ~ --~ ~, =, (717) 561-1939 (717) 561-4121 (FAX) Sup. Ct. ID 29029 ATTORNEY FOR PETITIONER ' IN RE: : IN THE COURT OF COMMON PLEAS OF :CUMBERLAND COUNTY, PENNSYLVANIA ESTATE OF ELI CEKtUVIC Deceased NUMBER : -~~ ~ ~'~~<< ~ ~ ~ ~' 1 ORDER AND NOW, th~s ~ ~ 1~ day of l~~~reh, 2011, upon consideration of the within Petition, it is hereby Ordere~ as follows: 1. The settlement set forth in the above-described manner is approved. Travelers Insurance Company shall pay the settlement proceeds in the above case in the amount of $300,000.00 to Attorney Charles E. Petrie. 2. From said proceeds, Attorney Petrie will distribute the proceeds as follows: a. He will expend such sums as are necessary to pay all of Decedent's medical expenses in full, including the lienholder. b) The sum of $50,000.00 shall be paid to Attorney Petrie, which sum represents his commission for representation of r Petitioner and the Estate of Eli Cekovic in this matter. ry 0~ ~~ ~~0~ ~~t~0`~~ ~y ~~ HUrrt~, ~i`i ~T~B5ilfilu-t~~ ~"1~'1~a~~~ i ;~t my harry j. `~r_ ~.Y~' +1~h ~~ j Cou ` o~ said •,~;~ 20 ,~ r. --i t f ~~ k ~~,~ ~ ~ .-~~ ~.. i ~ ~ aC15 UI't. L=~ the ~h , Clerk of rarrt~a r ,~,rnhArl~+~d .C c) All remaining sums shall be payable to the Estate of Eli Cekovic. BY THE COURT: ~'~~ ~/ ~/~~ ~ - , r _ ~ J. Distribution: Charles E. Petrie, Esquire, 3528 Brisban Street, Harrisburg, PA 17111, Attorney for Petitioner Mary Ellen Messinger Cekovic, Petitioner, 6050 Wertzville Road, Enola, PA 17025 GENERAL RELEASETHESE PRESENT KNOW ALL MEN BY ,- , Messin er Cekovic as Executrix of the Estate of Eli Cekovic, bF:!ny '~' rat we. Ellen Mary g $250,OOO.OC11 rc; ,~i~ :~, ,:~ :,,T~,, :~c~ti:~ for the sole consideration of Two Hundred Fifty Thousand Dollars, released, and forcvcr ~7~sr;~;~jca~=~~ _.~... . ~~.,a~~~, ;;~;~ receipt thereof is hereby acknowledged, have remise elers and for our heirs. exec,~a~ors i;aber~t A. t3anks, The Standard Fire Insurance Company (Trav i char e Robert A. Bank. The ~-~~~; ~~:.~:~to~s and assigns do hereby remise, release, and forever d s g '~ ~ Travelers and their successors and assigns. hers. executors Standard l=ire Insurance Company ( ) ~~ ~ tors. onl ,from any and all claims, demands, rights, and causes of action of whatsoe e r ;~;,c ac~m~n~stra Y nature, including claims of liens from MEDICARE, any other health care provid'I kr~owi~ a~ ~~i cu aria . . .;;, ~;~;{ an-~ ~~-orkrr~en's Cos~pensatien insurer. arrsrng from and by reason of any an~ a ._ ,c. ~ :~ ~~ foreseen and unforeseen bodily and persona! injuries. damage to 'Pro{vP~e Y,;.~'~t' :.,,}k~,oN~ . ~~- ~~ ~~~ uences thereof. resulting from an incident which occurred on July 9, X009. er~~ alp ,~.~,;t_. ;_;-,;,~~,~,r;t~ ~ ownsi}ip: Pennsylvania for which we have claimed Robert A. Ban s to oe g y _ , ~,~ ;~~.~~;r~t~ viability ~s hereby expressly denied. t ,~: =4f<~o ex ressly understood between the parties that Ellen Mary Messinger Cekovic asp ~.a p - e Estate of Eli Cekovic shat! be solely responsible for the repayment of any an d, ).c~ Executrix of th health care provider: health care insurer ac ;E;r;;. ir~Ciudrrlg Medicare; workmen's compensation, Ilen Ma Messinger Cekovic as Executrix of the Estate of Eli Gekavic ar~y other Dens. and E rY r nil .defend and hold harmless Robert A. Banks and The Standard Fire Insurance: agree., .o ~ndem y, man Travelers) from any and all claims or actions on account of any such I-er~. Co p y ~~;~:~~; ;f;r~ify that there are no outstanding liens against Us for child support ~E' ,`s Rabe ~, ,.: `,. ,,~y(,,:~-1ia o~ any other jurisdiction. vVe agree to indemnify, defend and hold narrnles~ =~: , ~ The Standard Fire Insurance Company (Travelers] from any and al{ clarets ar actrl~n~. ,..,~~~.ks attd .. -rcL:~~,~t of any child support liens. :L - ~ ~~TNESS WHEREOF, •vve have i7ereunto set our hand aria seal ties _ ~' ~!r ~- uaY of IN VVl ~- ~~..: __ in the year Two Thousand en. Sealed and delivered in the presence of: _.... Ellen Mary Messinger Cekovic as Executrix of th~-. Estate of Eli Cekovic /jam ~ j~„ ; ! / l ) _ : •~,,:~r,,;~,~•~.,~.~r~`E_,'~i__-f H ~F PEN/NSYLVANIA EXHIBIT "C"