HomeMy WebLinkAbout05-31-11In re: IN THE COURT OF COMMON PLEAS OF
AMBROSIA SNOW, minor, :CUMBERLAND COUNTY, PENNSYLVANIA
by her parents and guardians,
JAMES SNOW and PAMELA SNOW :ORPHANS' COURT DIVISION
PETITION FOR LEAVE TO COMPROMISE AND DISCONTINUE
TO THE HONORABLE, THE JUDGES OF SAID COURT:
The Petition of James Snow and Pamela Snow respectfully represents that:
1. Petitioners are James Snow and Pamela Snow, adult individuals, who
reside at 14 Heather Drive, Carlisle, Cumberland County, Pennsylvania, 17013.
2. Petitioners are the natural parents, natural guardians and shared legal
custodians of Ambrosia Snow (hereinafter "the Child"), born January 29, 2000.
3. The Child resides with Petitioners.
4. On February 1, 2008, a furnace at the home of Petitioners and the Child
released oil and fumes while being serviced by Larry Dowless, d/b/a Cumberland
Heating and Air Conditioning.
5. The oil and fumes damaged the home and certain personal property within
the home.
6. The Child lost birthday and Christmas presents valued at approximately
$500.
7. The Child sustained no serious physical injuries, only minor respiratory
trouble for a few days.
8. Petitioners have pursued psychological treatment for the Child, however
no doctor's opinion exists that causally relates the Child's condition to the incident of
February 1, 2008.
9. Petitioners and the Child filed a Complaint with this Honorable Court on
January 9, 2009, docketed at No. 09-6777.
10. The Defendant in the civil action has agreed to settle the case with the
Child for a lump sum payment of one thousand dollars ($1,000).
12. No liens exist related to the incident of February 1, 200-
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13. Your Petitioners, as natural parents and guardians of the Child, believe
that the proposed compromise and settlement of the cause of action is fair and
reasonable and in the best interest of the Child, and are willing to enter into a settlement
of the within action.
14. Undersigned counsel will assert no fees or costs for the Child's settlement.
15. The settlement consideration of One Thousand Dollars ($1,000) is
proposed to be distributed as follows:
The sum of One Thousand Dollars ($1,000.00) to be distributed to James
Snow and Pamela Snow, natural parents and guardians of Ambrosia Snow, to be
invested in an interest-bearing account at Orrstown Bank for the benefit of said
minor, Ambrosia Snow, which funds shall be distributed to said minor:
(1) when she attains the age of eighteen (18) years; or
(2) at an earlier date upon application to and approval of this Court.
WHEREFORE, Petitioners respectfully request your Honorable Court to approve
the settlement and distribution of the claim of the minor child, Ambrosia Snow, as
proposed herein.
Respectfully submitted,
TURD ROBIN
Q ~/3i/1Z
Date By: Lorin A rew Snyde ,Esq.
PA I D N .203199
129 S th Pitt Street
Carli e, P 13
717-245-9688
In re:
AMBROSIA SNOW, minor,
by her parents and guardians,
JAMES SNOW and PAMELA SNOW
IN THE COURT OF COMMON PLEAS OF
CUMBERLAND COUNTY, PENNSYLVANIA
ORPHANS' COURT DIVISION
NO. °;4 r ~ ~ " ~. tr ~.
VERIFICATION
I, James Snow, verify that the statements contained in the foregoing Petition For
Leave to Compromise and Discontinue are true and correct to the best of my
knowledge, information and belief. I understand that false statements therein are made
subject to the penalties of 18 Pa.C.S. §4904, relating to unsworn falsification to
authorities.
Date J mes Snow
In re:
AMBROSIA SNOW, minor,
by her parents and guardians,
JAMES SNOW and PAMELA SNOW
IN THE COURT OF COMMON PLEAS OF
CUMBERLAND COUNTY, PENNSYLVANIA
ORPHANS' COURT DIVISION
r,
NO. '_ i (~ ~ ~ ~ ~ _.
VERIFICATION
I, Pamela Snow, verify that the statements contained in the foregoing Petition For
Leave to Compromise and Discontinue are true and correct to the best of my
knowledge, information and belief. I understand that false statements therein are made
subject to the penalties of 18 Pa.C.S. §4904, relating to unsworn falsification to
authorities.
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Date Pamela Snow