HomeMy WebLinkAbout11-5642Anthony W. Parker
PA ID 81251
Kelly, Parker & Cohen LLP
5425 Jonestown Road, Suite 103
Harrisburg, PA 17112
717-920-2220
FAX 717-920-2370
anarker-g,1kpc-law. corn
PRABHA JINDAL,
Administratrix of the ESTATE OF
RAMESH K. JINDAL, Deceased,
1750 Eliza Way
Mechanicsburg, PA 17050
Plaintiff
V.
FILED-OFFICE
,F i HE RROTNONOTAR Y
2011 JUL 14 AN 10: C*O
CUMBERLAND COUNTY
PENNSYLVANIA
IN THE COURT OF COMMON PLEAS
CUMBERLAND COUNTY,
PENNSYLVANIA
No. 11- S b g a CI Vi
KRISTEN A. CARPINELLO and CIVIL ACTION - LAW
MICHAEL V. CARPINELLO,
3806 Carriage House Drive :
Camp Hill, PA 17011
Defendants
PETITION FOR APPROVAL OF SETTLEMENT AND DISTRIBUTION OF FUNDS
Plaintiff Prabha Jindal, Administratrix of the Estate of Ramesh K. Jindal, deceased, by
and through counsel, Kelly Parker & Cohen, LLP, hereby petitions this Court for approval of the
settlement for wrongful death and survival action, pursuant to Pa. R. Civ. P. 2206, and avers in
support thereof as follows:
1. Plaintiff Prabha Jindal is an adult individual who resides at 1750 Eliza Way,
Mechanicsburg, Cumberland County, Pennsylvania.
2. Plaintiff was appointed Administratrix of the Estate of Ramesh K. Jindal,
deceased, on August 5, 2010, by the Register of Wills of Cumberland County. See Appendix A.
3. The names and addresses of all persons entitled by law to recover damages for
Ramesh K. Jindal's wrongful death and the relationship to the decedent are as follows:
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a. Prabha Jindal, Plaintiff herein, whose address is as identified in Paragraph 1
above, was the wife of the decedent;
b. Gaurav Jindal, M.D. is the son of the decedent and resides at 23 South 23rd
Street, Apt. 3R, Philadelphia, Pennsylvania;
c. Parul Kakaria, M.D. is the daughter of the decedent and resides at 1775
Adeline Way, Mechanicsburg, Pennsylvania;
d. Shivani Narasimhan, M.D. is the daughter of the decedent and resides at
14605 Corys Court, Glenelg, Maryland.
4. On March 13, 2010, Ramesh Jindal was involved in a motor vehicle accident at
the intersection of Goodhope and Creekview Roads, Mechanicsburg, Cumberland County,
Pennsylvania (the "Accident"). At the time of the Accident, Dr. Jindal was traveling north on
Goodhope Road and Kristen Carpinello was traveling east on Creekview Road. At the
intersection, the Jindal vehicle was struck broadside in the driver's side door by the vehicle
operated by Mrs. Carpinello. Ramesh Jindal was pronounced at the scene of the Accident. See
Police Accident Report and Coroner's Certificate of Death attached hereto as Appendices B and
C, respectively.
5. At the time of the Accident Mrs. Carpinello maintained a policy of insurance with
Erie Insurance Exchange ("Erie Insurance") with policy limits of $100,000 per person and
$300,000 per accident. Mrs. Carpinello did not maintain any additional insurance coverage,
whether it be an additional policy or umbrella policy. See Affidavit of No Additional Insurance
attached hereto as Appendix D.
6. While Erie Insurance and Mrs. Carpinello deny that Mrs. Carpinello has any
liability for the injuries to Ramesh Jindal, M.D., Erie Insurance is willing to pay its policy limit
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of $100,000 in exchange for a full and final settlement of all claims and appropriate releases
executed by Prabha Jindal, Administratrix of the Estate of Ramesh K. Jindal. A copy of the
General Release is attached hereto at Appendix E.
7. At the time of the Accident, Ramesh Jindal maintained an automobile policy with
Erie Insurance with underinsured benefits of $15,000 per person and $30,000 per accident. Erie
Insurance has tendered its $15,000 underinsured limits in satisfaction of its obligation under the
policy of insurance issued to Ramesh K. Jindal. A copy of the Release and Agreement is
attached hereto as Appendix F.
8. Under the circumstances, Plaintiff and undersigned counsel agree that the
settlement is fair and reasonable and seek approval of the negotiated settlement. Plaintiff
understands the terms of the settlement, agrees it is in the best interest of the Plaintiff and the
Estate, and freely and voluntarily accepts the same.
9. No litigation expenses have been incurred to date.
10. Pursuant to the contract for legal services with undersigned counsel, Plaintiff
requests that attorney fees in the amount of $38,329.50, representing 33 1/3 % of the gross
settlement, be paid to undersigned counsel. A copy of the contract for legal services is attached
as Appendix G.
11. After attorney's fees and expenses, the net sum of proceeds remaining is
$76,670.50.
12. There are no liens.
13. The Department of Revenue has approved a 90/10 allocation with 90% of the net
sum in proceeds to the wrongful death action and 10% of the net settlement proceeds allocated to
3
WHEREFORE, Plaintiff Prabha Jindal, Administratrix of the Estate of Ramesh K. Jindal,
deceased, respectfully requests that this Honorable Court issue an Order approving the settlement
and distribution in accordance with the terms of the foregoing Petition and attached Order.
Respectfully submitted,
thony . Parker
No. 81251
KELLY, PARKER & COHEN LLP
5425 Jonestown Road, Suite 103
Harrisburg, PA 17112
717-920-2220
FAX 717-920-2370
aparkergkpc-law.com
Dated: July 13, 2011
Counsel for Plaintiff Prabha Jindal,
Administratrix of the Estate of Ramesh Jindal,
deceased
g eH, %B I'kfor
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LAST 3Y IL AND TESTAMENT ?
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RAMESH K. JINDAL
O -6 t°
RAMESH K. JIND.A.L, of South Hanover Township, Dauphin 03i ,
1
,
Pennsylvania, do make, publish and declare this to be any Last Will and Testament, hereby
revoking all Wills and codicils by me at any tune made.
STEM 1. 1 direct that all inheritance and estate taxes becoming due by reason of
my death, whether such taxes may be payable by my estate or by any recipient of any property,
shall be paid by my Executrix out of the property passing under ITEM 5 of this Will, as an
expense and cost of administration of my estate. My Executrix shall have no duty or obligation
to obtain reimbursement for any such tax so paid, even though on proceeds or insurance or other
property not passing under this Will. In the absolute discretion of my Executrix, she may pay
such taxes immediately or may postpone the payment of taxes on future or remainder interests
until the time possession thereof accrues to the beneficiaries.
ITEM 2. 1 direct any Executrix to pay the expenses of my last illness and funeral
expenses from the property passing under this Will as an expense and cost of administration of
any estate.
ITS. In the event that my wife, PRAB A JINDAL, survives me,1 give and
bequeath to her absolutely and in fee simple all of my household f n-niui re and furnishings,
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books, pictures, jewelry, silverware, automobiles, wearing apparel and all other articles of
household or personal use or adornment. In the event that my wife, P HA JINDAL does not
survive me, I make said bequest to my cl-ildren living at the time of my death to be divided
among them as they shall agree.
= 4. In the event that my wife, PRABHA JINDAL, survives me, I give,
devise and bequeath to her the smallest amount of the assets of my estate that qualify for the
marital deduction as will be sufficient to result in the lowest federal estate tax being imposed
upon my estate, after allowing for the unified credit and any other allowable credits and
deductions. In determining such amount, the values for federal estate tax purposes shall control-
It is my intention that this bequest shall constitute a pecuniary bequest and that it shall not
participate in increases and decreases that may occur during the administration of my estate
(except such increases and decreases as may result from an election to use the alternate valuation
date).
My Executrix shall have full power and the sole discretion to satisfy this devise
and bequest, wholly or partly, in cash or kind and to select the assets that will be conveyed to my
wife. All assets so conveyed to my wife shall be valued at the value thereof as finally
determined for federal estate tax purposes; and provided further that my Executrix, in order to
implement this devise and bequest, shall distribute to my wife assets, including cash, having an
aggregate fair market value at the date or dates of distribution amounting to no less than the
amount of this devise acid bequest as finally determined for federal estate tax purposes; and
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provided further that there shall not be conveyed to nay wife any policy of insurance on the life
of my wife, or any asset, or the proceeds of any asset, which will not qualify for the mat ital
deduction. The exercise of the foregoing power and discretion by my Executrix shall not be
subject to question by or on behalf of any beneficiary.
In the event that my wife, PRABRA 7INDAL, predeceases me., I give, devise acrd
bequeath all my property as provided in the succeeding Item of this Will,
ITEM. . I give, devise and bequeath the residue of my estate, of every nature and
wherever situate, to my Trustees, IN TRUST, for the following uses and purposes:
(a) The Trustees shall pay to or expend and apply for the benefit of my
wife, PRABRA =AL, so much of the income and principal as they, in their sole discretion,
deems necessary for the proper support, maintenance and welfare of my wife, including medical,
surgical, hospital or other institutional care, having in mind both the standard of living to which
she has been accustomed and the income available to or for her from other sources. Any income
not distributed shall be added to principal.
(b) After the death of my wife, or if she predeceases me, then upon my
death, the Trustees shall continue the Trust for the following uses and purposes:
(i) The Trustees shall divide the trust corpus into separate parts
corresponding in number to the number of my children who shall survive me, and shall allocate
thirty-three (33%) percent to the part for my daughter, PA.RUL J. KAKARIA., thirty-three (33%)
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percent to the part for my daughter, SHIVANZ J. NARASEV RAN, and thirty-four (34%) percent
to the part.for my son, GAURAV JINDAL',.
(ii) The Trustees shall pay to or expend and apply for the benefit
of my children so much of the income and principal as they, in their sole discretion, deems
necessary for the proper support, maintenance, welfare and education of my children, and any
such distribution shall be made only from the part of the trust property designated as being for
the child benefited. Any income not distributed shall be added to principal.
(iii) The Trustee shall pay over to each such child one-half of the
principal balance of his or her part as it shall, exist at his or her attaining the age of twenty-five
(25) years. The Trustee shall pay over to each such child the entire remaining principal balance
of his or her part as it shall exist at his or her attaining the age of thirty (30) years.
(iv) In the event that one of my clOd.ren predeceases me or dies
prior to attaining the age of thirty (30) years, his or her part shall be added to the parts being held
for my surviving children in equal shares.
(c) No part of the income or principal of the property held under this
Trust shall be subject to attachment, levy or seizure by any creditor, spouse, assignee or trustee
or receiver 41 bankruptcy of any beneficiary prior to his or her actual receipt thereof The
Trustees shall pay over the net income and principal to the parties herein designated, as their
interests may appear, without regard to any attempted anticipation, pledging or assignment by
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any beneficiary under a trust, and without regard to any claium, thereto or attempted levy,
attachment, seizure or other process against said beneficiary.
X16. In addition to the powers conferred by law, the Trustees shall have the
following powers:
(a) To :retain in their absolute discretion and for such period as to them
shall seem advisable, any and all assets constituting the Trust Fund, without liability for any loss
incurred by reason of the retention of such assets.
(b) To change investments and properties, and to invest &ud reinvest all or
any part of the corpus of the Trust hereby established, in such securities, investments, or other
property as to them seems advisable and proper, irrespective of whether the same are authorized
for the investment of trust funds by the laws of the Commonwealth of Pennsylvania.
(c) To sell all or part of the property which at any time may constitute a
part of the Trust hereby established, at such times, upon such terms, for cash or on credit, with or
without security, in such manner and at such prices, either at public or private sale, as to them
shall seem advisable and proper, and to execute good and sufficient deeds and bills of sale
therefor.
(d) To lease auy property held by them, and fix the duration of the term,
irrespective of the provisions of any statute or of the termination of the trust; and to mortgage,
pledge, collect, convert, :redeem, exchange, or otherwise dispose of any securities or other
property at any time held by them.
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(e) To borrow money, whether to pay taxes, exercise subscriptions, rights,
and options pay assessments or to accomplish any other purpose of any nature incidental to the
administration of the Trust hereby established, and to pledge any securities or other property held
by them as security therefor.
(f) To enforce any bonds, mortgages, or other obligations or liens held
hereunder; to enter upon such contracts and agreements and to make such, compromises or
settlements of debts, claims, or controversies as they may deem necessary or advisable; to subalit
to arbitration any matter or difference; to vote personally or by proxy any shares of stock which
may at any time be held by them hereunder.
(g) To consent to the reorganization, consolidation, merger, liquidation,
readjustment of or other change in any corporation, company, or association, or to the sale or
lease of the property thereof or any part thereof, any of the securities or other property of which
may at the time, be held by them thereunder, and to do any act or exercise any power with
reference thereto that may be legally exercised by any person owning similar property in his own
right, including the exercise of conversion, subscription, purchase or other options, the deposit or
exchange of securities, the entrance into voting trusts, and the making of agreements or
subscriptions which they may deem necessary or advisable in connection therewith, all without
applying to w-iy court for permission so to do, and to hold, redeem, sell or otherwise dispose of
any securities or other property which they may so acquire, irrespective of whether the same be
authorized for the investment of trust funds by the laws of the Commonwealth of Pennsylvania-
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(h) To cause to be registered in their name as Trustees hereunder, or in the
names of their nominees without qualification or description, any securities at any time held in
the Trust hereby established.
(i) To determine the manner in which the expenses incidental to or
connected with the administration of the Trust hereby established shall be apportioned as
between income and principal.
0) To carry out agreements made by me during nay lifetime, including the
consummation of any agreements relating to the capital stock of corporations owned by ine at the
time of my death, and including the continuation of any partnership of which I may be a member
at the time of my death whenever the terms of the partnership agreement obligate my estate or
personal representative to continue my interest therein, and to enter into agreements for the
rearrangement or alteration of my interests or rights or obligations under any such agreements in
effect at the time of my death.
(k) To apportion extraordinary and stock dividends received by them
between income and principal in such manner as they may see fit; provided, however that all
rights to subscribe to new or additional stock or securities, and all liquidatiag dividends shall be
deemed to be principal.
The Trustees may freely act under all or any of the powers of this ,A.gxeement
given to them in all matters concerning the Trust hereby established, after forming their
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judgment based upon all the circumstances of any particular situation as to the wisest and best
course to pursue, without the necessity of obtaining the consent or approval of any court, and
notwithstanding that they may also be acting as an individual, or as trustee of other trusts, or as
an agent for other persons or corporations interested in the same ratters, or may be interested in
connection with the same matters as stockholders, directors or otherwise.
The powers herein granted to the Trustees may be exercised in whole or in part,
from time to time, and shall be deemed to be supplementary to and not exclusive of the general
powers of trustee pursuant to law, and shall include all powers necessary to carry the same into
effect- The enumeration of specific powers herein shall not be construed in any way to limit or
affect the general powers herein granted.
E 7. The Trustees of the foregoing 'bust shall be SMVANZ T.
NARASMIAN, PARUL J. KAKARTA and GAURA'V' =AL. In addition to other
provisions applicable to trustees generally, the following provisions shall apply to the Trustees:
(a) No bond or surety shall be required of the Trustees or of any successor
Trustee who shall serve hereunder
(b) The Trustees or any successor Trustee may resign by an instrlunent in
writing.
(c) The Trustees or any successor Trustee may appoint any person, firm
or corporation, other than the Testatrix or any firm or corporation in which the Testatrix has an
interest, as successor Trustee.
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MAY. ' 8. 2 0 1 ' 8 ; 03AN, 7172367777 N0. 179 P. 10
(d) Any successor Trustee shall have and may exercise all the rights,
powers, duties and discretions conferred or imposed on the Trustee.
(e) No one dealing with any Trustee need inquire concerzung the validity
of anything the Trustee purports to do, or see to the application of any money paid or property
transferred to or upon the order of the Trustee.
(f) No successor Trustee shall be obliged to examine the accounts and
actions of any previous Trustee.
(g) No successor Trustee shall be responsible in any -way for any acts or
omissions of any previous Trustee.
(h) No Trustee shall be liable for any act or omission unless the same be
due to that Trustee's own willful default.
(i) The compensations to be paid to any corporate trustee for its ordinary
services as Trustee shall be at the rates prescribed for similar trust services in its standard
compensation schedule in effect at the time of each charging of such compensation, unless it
agrees in writing to a different fee arrangement. Any corporate trustee shall receive reasonable
additional compensation for all requested or required extraordinary services. It may deduct the
compensation at such time or times and from such sources as it may reasonably determine.
Reasonable compensation shall be paid to any individual serving as Trustee, unless the
individual waives the right to receive compensation.
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MAY. 18. 2011 8: MAY 7172367777 NO, 179 P. 11
I ET NI 8. If my wife, PRABIiA TINDAL, anal I should die at the same time, or in
a common disaster, or under such circumstances that it is difficult or impossible to determine
who died first, she shall be deemed to have survived me.
ITEM 9. I hereby nominate, constitute and appoint my wife, PR.ABHA JINDA.L,
as Executlix of my estate. In the event that she is unable or unwilling to serve in this capacity, I
then nominate, constitute and appoint, my children, SPIIVAN7 J. NARASINfRAN, PARUL J.
KA.I A, and GALRAV TINDAL, as Co-Executors of my estate.
In addition to the powers conferred by law, my Executors shall have the same
powers granted to my Trustees in ITEM 6 above.
My Executors are specifically relieved from the duty or obligation of filing any
bond or bonds.
ITEM 1.0. For the convenience of my Executors, I note that this Will has been
prepared by Ronald D. Butler, Esquire and the Butler Law Finn.
IN WITNESS WIMREOF, I have hereunto set my hand and seal to this my Last
Will and Testament, this 1 day of ?, A.D., 2005.
N
(SEAL)
eslx . Tindal
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WI'T'NESS:
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NAY. ' 8. 20- 0 AN 7' 72367 777 NO. 79 P. 13
COMMONWEALTH OF PENNSYLVANIA
SS.
COUNTY OP DAUPHIN
We, RANMSH K. JINDAL, GAJ&Z t N- E and
N CV 4 - -S7 r-S-1 = , the Testator and the witnesses respectively, whose
names are signed to the attached or foregoing instrument, being first duly sworn, do hereby
declare to the undersigned authority that the Testator signed and executed the instrument as his
Last Will and that he had signed willingly (or willingly directed another to sign for him) goal that
he executed it as bas free and voluntary act for the purposes therein expressed, and that each of
the witnesses, in the presence and hearing of the Testator, signed the Will as witness and that to
the best of their knowledge, the Testator was at that time eighteen years of age or older, of sound
mind and under no constraint or undue influence.
amesli . Tindal
1
Witness
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iba?ess
Subscribed, sworn to and acknowledged before me by ASH K. JINDAL, the
Testator, and subscribed and sworn to before me by tZ . ,8
and ,q, the witnesses, this day
of /?'?,4? ? , 2005.
ary Public
My Commission Expires:
?+ Alr?uvY Ai."I"li OF PENNSYLVANIA
CHERYL L FERQUMN. Notary Public
(My of Hiwd5WM, DauptM Cowdy
OMMIssian F? i?as A?i18, 2QOB
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J COMMONWEALTH OF PENNSYLVANIA
POLICE CRASH REPORTING FORM
Case Closed Reportable Crash Page
AA 500 1 0 Yes Q No a Yes Q No
1111111111111111111111111 Crash Number
Incident Number Police Agency Patrol Zone
1 21103 400
HAM20100300353
®
e Agency Name Precinct Investigation Date (MM-DD-YYYY)
Hampden Township ?- 03 13 -12010
M Dispatch Time (mil) Arrival Time (mil) Investigator Badge Number
d F1523 1527 PATROLMAN JASON JULSETH 19-22?
Reviewer Badge Number Approval Date (MM-DD-YYYY)
JEFFREY A SNYDER F19_11 ?? 04 12 2010
County County Name Municipality Municipality Name Dav of !Meek
2] Cumberland 103 Hampden Township O Sun Q Thu
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Crash Date (MM-DD-YYYY) Crash Time (mil) No of Units People Injured Killed* "If > 00
= 2010 1520 complete
03 13
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O Tue a sat
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(If Yes, Complete
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School Bus
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Related
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Notify PENNDOTQ Yes No
Maintenance
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O North
03 30 2 O south House Number (if applicable)
Street Name Street Ending W East For Mid-block crashes only. Use
w 0 West
CREEKVIEW RD O O Unk
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Principal Roadway Street Name is
nown filled in if using this option
?8 O Interstate r-.) Turnpike O Turnpike O State O County - Local Road O Private O Other/
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L9 Degrees Minutes Seconds Degrees Minutes Seconds
Latitude: 40 15 e 59 000 Longitude: - 76 58 :F4 000
a Traffic Control Device Flashing O Yield Sign O Polite Officer or PCD Functioning ---
0 y
O Not Applicable Traffic Signal Flagman
O Active RR Crossing O Other Type TCD O No Controls O Device Improperly Functioning Emerenc
O Preemptive
Traffic Controls Signal
Signal O Stop Sign O Passive RR Q Unknown Q Device Not a Device Functioning O Unknown
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ISO
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e Cane Closed (if 'Not Applicable", skip rest of the Lane Closure section) Lane Closure O North Q East Q North and South Q All
Not Applicable O Partially Q Fully Q Unknown DInectio t Q South (N,S,E,W)
O West O East and West
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Q Traffic Yes O No O EAL T11M
Detoured Unknown Q a°Sed O< 30 Min. Q 30-60 Min. Q 1-3 hrs O 3-6 hrs Q 6-9 his Q> 9 hours
O Unknown
FORM M AA-500 (1=2)
PENNDOT COPY
http://"?,A,.dot6.state.pa.us/crsapp/Printlmages/XnilFiles/20100264162010042914310031... 4/29/2010
I COMMONWEALTH OF PERqWSVLVAK0A
POLICE CRASH REPORTING FORM Page:
AA 500 2 Police Use Only I LL-1
W0149866
Crash Number 7
Motor Vehicle in
0 Hit & Run Vehicle Q Illegally Parked O Legally Parked QNon -Motorized
?
Commercial Vehicle
e
a Transport
Type
Unit Pedestrian on Skates, Disabled From
Q Train Q Phantom Vehicle
Q Pedestrian O
0 O Yes ® No
g Previous Crash
in Wheelchair, etc (/f Yes, Complete Form C)
(if "Pedestrian" or "Pedestrian on Skates, in Wheelchair, etc", Complete Form M_, Section 28)
Unit No First Name MI Date of Birth (MM-DD-YYYY)
O1 RAMESH K? 09 13 1942
Last Name Telephone Number
Delete?
Q JINDAL
Address / City / State Zi
a 1750 ELIZA WAY MECHANICSBURG PA 17050
E Driver License Number State Class
PA ??
F20308890
6
Alcohol/Druas Suspected Driver or Pedestrian Physical Condition
No Q Illegal Drugs Q Medication NoPmalntiy O lUSeo ?y Fatigue Q Medication
Q Alcohol 0 Alcohol and Drugs O Unknown Had Been
O Sick Q Asleep Q Unknown
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Alcohol Test Type
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Primary Vehicle Code Violation Charged? -
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Q Blood 0 Urine O Te
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Driver Presence 1=Driver Operated 3=Driver Fled Scene
0 Test Given,
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Contaminated Results
" 2=No Driver 9=Unknown
Owner/Driver 00=Not Applicable 02=Private Vehicle Not 04=State Police Vehicle 07=Municipal Police Veh 09=Federal Gov Veh
01=Private Vehicle Owned/ Owned/Leased by Driver 05=PENNDOT Vehicle 08=Other Municipal 98=Other
02
Leased by Driver 03=Rented Vehicle 06=Other State Gov Veh Government Vehicle 99=Unknown
Same as Owner First Name Owner Last Name or Business Name (if Pedestrian, skip this Section)
Driver O 1RABHA JINDAL
Address / City / State / Zip Vehicle Make *Make Code
F1750 ELIZA WAY MECHANICSBURG PA 17050 Toyota 7 1 F49-71
VIN Model Year Vehicle Model (see overlay)
4T]BK36BX8U283648 2008 AVALON -?
License Plate Reg. State Est. Speed Vehicle Towed Towed By
I HDP2618 PA 035 0 Yes Q No ROADSIDE AUTO R
Insurance Insurance Company Policy No
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3=Towing Utility Trailer 6=Full Trailer 9=Unknown
Units:
Direction of
ravfi ee ^Vehicle Position 1 'Movement Q 1 °See Special Usage
Overlay
Vehicle Color Vehicle Type
05=Large Truck 20=Unicycle, Bicycle, 00 12=Commercial
06=Yellow
OS 01=Automobile 06=SUV Tricycle
O1 Passenger
Not
A
licable
00
=
07=Silver 02=Motorcycle 07=Van 21 =Other Pedalcycle o1
=Fire
V
=Taxi
13=Taxi
eh
08=Gold
01=Blue 09=Brown 03=Bus 10=Snowmobile 22=Horse & Buggy
04=Small Truck 11 =Farm Equip 23=Horse & Rider
02 Ambulance 21=Tractor Trailer
02=Red 10=Orange (!f "02", Complete Form 12=Construction Equip 24=Train 03=Police 22=Twin Trailer
08=Other Emergency 23=Triple Trailer
03=White 17=Purple
04=Green 12=Other M, Section 26) 13=ATV 25=Trolley
(if "20" or "21", Complete 18=Other Type Spec Veh 98=Other Vehicle 31=Modified Veh
11 =Pupil Transport 99=Unknown
05=81ack 99=1LInknown Form M, Section 27) 19=Unk. Type Spec Veh 99=Unknown
Initial Impact Point Damage Indicator Gradient 3=Downhill Road Alignment
00=Non-Collision 14=Undercarriage
] 01
T
it
12
Cl
i
t
15
d U
k P O=None 2=Functional
1=Minor 3=Disabling 4=Bottom of Hill
1=Level 5=To
of Hill 1=Straight
a 2=Curved
-
n
s
=
owe
n
=
oc
o n
9
k
U p
2=Uphill
13=Top 99=Unknown =
n
now 9=Unknown 9=Unknown
FORM P AA-500 (12/D2)
PENNDOT COPY
http://www.dot6. state.pa.uslcrsappIPrintlmageslXmIFiles/20100264162010042914310031... 4/29/2010
(C®OnfMfd®R1RE&LYN DIP PI'cRMS5YL@9eeaKE&
_j POLICIE CRASH RIEPORTING FORM Page:
AA 500 2 (vice use only
EHM
WO 149866
Crash Number
0 Motor Vehicle in
0 Hit & Run Vehicle Q Illegally Parked Q Legally Parked Q Nan -Motorized
Transport
T
Commercial Vehicle
a ype
Unit Q Pedestrian Q Pedestrian on Skates, Q Disabled From Q Train 0 Phantom Vehicle 0 Yes ® No
in Wheelchair, etc Previous Crash
'
"
' (If Yes, Complete Form C)
(If 'Pedestrian
or
Pedestrian on Skates, in Wheelchair, etc
, Complete Form M, Section 28)
Unit No First Name MI Date of Birth(MM-DD-YYYY)
I KRISTEN A? I1 18 1969
02
Last Name Tele hone Number
Delete?
Q CARPINELLO 7177371415
Address / Cit /State Zi
rt
3806 CARRLAGE HOUSE DR CAMP HILL PA 17011
Driver License Number State Class
21986813 PA
C
i AicohofiZ)rugs Suspected Driver or Pedestrian physical Condition
w
, Ille al Dru s Medication
No 0 9 9 0 Apparently Illegal Drug
Normal 0 Use Q Fatigue Q Medication
41 Q Alcohol Q Alcohol and Drugs Q Unknown Had Been
0 Sick Q Asleep Q Unknown
0
b Drinking
a Alcohol Test Type
Test Not Given Q Breath Q Other
Primary Vehicle Code Violation Charged?
v Q Blood 0 Urine 0
en if
G UNKNOWN Q Yes 0 No
v,
Test
Alcohol Test Results Q Test Refused Unknown
0 Results Driver Presence 1=Driver Operated 3=Driver Fled Scene
7o Q Test Given,
nt
mi
d Re
lts
C
t Vehicle 4=Hit and Run
o
a
na
e
su 2=No Driver 9=Unknown
Owner/Driver 00=Not Applicable 02=Private Vehicle Not 04=State Police Vehicle 07=Municipal Police Veh 09=Federal Gov Veh
01=Private Vehicle Owned/ Owned/Leased by Driver 05=PENNDOT Vehicle 08=Other Municipal 98=Other
O1
Leased by Driver 03=Rented Vehicle 06=Other State Gov Veh Government Vehicle 99=Unknown
I
Same as Owner First Name Owner Last Name or Business Name (If Pedestrian, skip this Section)
Driver Q f KRISTEN A & MIC CARPINELLO
Address / City / State / Zip Vehicle Make *Make Code
13806 CARRIAGE HOUSE DR CAMP HILL PA 17011 Honda 37
VIN Model Year Vehicle Model (see overlay)
5FNYF I 8505BO65298 2005 P1 LOT -?
License Plate Reg. State Est. Speed Vehicle Towed Towed By
ESP8016 PA 039 0 Yes Q No ROADSIDE AUTO R
Insurance Insurance Company Policy No
o ® Yes Q No Q un ERIE INSURANCE Q07 0806353 H
S.
ra . known
? -
E
2 p
Trailing Type 1=Towing Pass. Veh 4=Mobile/Modular Home 7=Semi-Trailer Tag No Tag Year Tag St
Unit No. of Unit 2=Towing Truck 5=Camper 8=Other
T
ili
? ra
ng
Units: 3=Towing Utility Trailer 6=Full Trailer 9=Unknown L.J
Direction of
Trave ] "Vehicle Position 0 ] 'Movement 0 ] *See Special Usage
Overlay
Vehicle Color Vehicle Type 05=Large Truck 20=Unicycle, Bicycle, OO 12=Commercial
06=Yellow
O ] 01=Automobile 06=SUV Tricycle
06 Passenger
00=Not Applicable Carrier
07=Silver 02=Motorcycle 07=Van 21 =Other Pedalcycle 01 =Fire Veh 13=Taxi
08=Gold
01=Blue 09=Brown 03=Bus 10=Snowmobile 22=Horse & Buggy
04=Small Truck 11 =Farm Equip 23=Horse & Rider
02=Ambulance 21 =Tractor Trailer
02=Red 10=Orange
03
Whi (If "02", Complete Form 12=Construction Equip 24=Train 03=Police 22=Twin Trailer
08=Other Emergency 23=Triple Trailer
=
te 1 7 =Purple
04=Green 12=Other M Section 26) 13=ATV 25=Troliey
,
(If "20" or "21", Complete 18=Other Type Spec Veh 98=Other
Vehicle 31 =Modified Veh
11=Pupil Transport 99=Unknown
05=Black 99=Unknown Form M, Section 27) 19=Unk. Type Spec Veh 99=Unknown
Initial Impact Point Damage Indicator gradient 3=Downhill Road Alignment
12 00=Non-Colli5ion 14=Undercarriage
01-12=Clock P
ints 15=Towed Unit 0=None 2=Functional
1=Minor 3=Disabling 4=Bottom of Hill
1=Level 5=To
of Hill 1=Straight
2=Curved
o 9=Unknown p
2=Uphill
13=Top 99=Unknown 9=Unknown 9=Unknown
FORM P AA-500 (12/02)
PENNDOT COPY
http://vA??r. dot6,state.pa. us/ersapp/Printlmages/XmIFi les/20100264162010042914310031... 4/29/2010
COMMONWEALTH OF PENNSYLVANIA
POLICE CRASH REPORTING FORM Page
AA 500 3 Police use Only 1
?IINWIIIVYIIA
W0149866
Crash Number
A 1 V
=Driver
D 00=NotJA Passenger/Occupant
2=Passenger 01=Driver - All Vehicles
7=Pedestrian 02=Front Seat Middle Position
8=0ther 03=Front Seat Right Side
9=Unknown 04=Second Row - Left Side Or
Motorcycle Passenger
05=Second Row - Middle Position
sex' 06=Second Row - Right Side
B F =Female 07=Third Row Or Greater -
M=Male Left Side
U =Unknown 08=Third Row Or Greater -
Middle Position
09=Third Row Or Greater -
Right Side
intua Severity: 10=Sleeper Section of Truckcab
C O=Not Injured 11=ln Other Enclosed
1=Killed Passenger Or Cargo Area
2=Major injury 12=ln Open Area
3=Moderate (Back Of Pickup, Etc.)
Injury 13=Trailing Unit
4=Minor Injury 14=Riding On Vehicle Exterior
8=Injury, Unk 15=Bus Passenger
Severity 98=Other
9=Unknown if 99=Unknown
Injury
01=Shoulder Belt Used
02=Lap Belt Used
03=Lap And Shoulder Belt Used
04=Child Safety Seat Used
05=Motorcycle Helmet Used
06=Bic cle Helmet Used
10=Safety Belt Used Improperly
11=Child Safety Seat Used improperly
12=Helmet Used Improperly
90=Restraint Used, Type Unknown
99=Unknown
Safety Equipment Two:
F 00=None Used / Not Applicable
01=front Air Bag Deployed (For This Seat)
02=Side Air Bag Deployed (For This Seat)
03=Other Type Air Bag Deployed
04=Multiple Air Bags Deployed
05=Motorcycle Eye Protection
06=Bicyclist Wearing Elbow/Knee/Pads
10=A.ir Bag Not Depioyed, Switch On
11=Air Bag Not Deployed, Switch Off
12=Air Bag Not Deployed,
Unk Switch Setting
13=Air Bag Removed (Prior To Crash)
19=Unknown it Air Bag Deployed
99=Unknown
G O=Not Applicable
1=Not Ejected
2=Totally Ejected
3=Partially Ejected
9=Unknown
H Ejection Path:
O=Not Ejected / Not Applicable
1=Through Side Door Opening
2=Through Side Window
3=Through Windshield
4=Through Back Door
5=Through Back Door Tailgate Opening
6=Through Roof Opening (Sunroof/
Convertible Top Down)
7=Through Roof Opening (Convertible
Top Up)
9=Unknown
I Extncarion:
i U=Not Applicable
1=Not Extricated
2=Extricated By Mechanical Means
3=freed By Non - Mechanical Means
8=Other
9=Unknown
L EMS Agency: HAMPDEN TOWNSHIP EMS Medical Facility: HERSHEY MEDICAL CENTER/HOLY SPIR
Unit No Person No De Date of Birth (MM-DD-YYYY) A B C D E F G H I
U 1 O l 0 e? 09 - 13 - 1942 M? 1? 01 03 O 1 E] OF F21
Name / Address / Phone
Same as EMS Transport
Operator JINDAL, RAMESH K 1750 ELIZA WAY MECHANICSBURG PA 17050 O Yes • No
Unit No Person No De Date of Birth (MM-DD-YYYY) A B C D E F G H I
O l 02 0 e? 06 - 25 - 1941 2 E] j 03 03 O 1 l? OF F
Name / Address / Phone
Same as EMS Transport
Operator PRABHA JINDAL 1750 ELIZA WAY MECHANICSBURG PA 17050 7176 Yes O No
Unit No Person No Delete? Date of Birth (MM-DD-YYYY) A B C D E F G H I
02 03 O 11 - 18 - 1969 1 F? 4? O] 03 O] T] q 1?
Name / Address / Phone
Same as EMS Transport
Operator CARPINELLO, KRISTEN A 3806 CARRIAGE HOUSE DR CAMP HILL P Yes O No
Unit No Person No Cate of Birth (MM-DD-YY1°y) A B C D E
U2 04 Delete7 D ' 06 - 30 -12001 ? IM 06 03 00 a
Name / Address / Phone
o Same as Operator DOMINIC ROBERT CARPINELLO 3806 CARRIAGE HOUSE DR. CAMP EMS Transport
H M Yes O No
Unit No Person No Date of Birth (MM-DD-YYYY) A B C D E F G H I
De0e7-?- ????????F]
Name / Address / Phone
EMS Transport
Same
Operatoasr O Yes O No
Unit No Person No Date of Birth (MM-DD-YYYY) v A B C D E F flH1
DelOete7 ?LLI Name / Address / Phone
Same as Operator . „„-... -- 1. uuw)
PENNDOT COPY
http : //wvk-r, dot6. state. pa. us/crsapp/Printlm ages/Xm IFi Ies/20100264162010042914310 031... 4/29/2010
COMMONWEALTH OF PENNSYLVANIA
POLICE CRASH REPORTING FORM
AA 500 4 police Use Only
o o Crash Description
10 4
Eli
` --
Relation to Roadway
o
c r
N n
A
V .r
Illumination
v
C ?
E Weather Conditions
-
G
y Road Surface Conditions
.2
16
E
c
w
N
c
0
`o
c
Cis
c
c
v
pII?IIIIIII?IA?
Page wa,v,o,
Crash Number 7
O=Non-Collision 2=Head On 4=Angle 6=Sideswipe B=Hil Pedestrian
1=Rear End 3=Rear to Rear 5=Sideswipe (Opposite Direction)
(Backing) (Same Direction) 7=Hit Fixed Object 9=01her/Unknown
1=0n Travel Lanes 3=Median 5=Outside Trafficway 7=Gore (Ramp Intersection)
2=Shoulder 4=Roadside 6=1n Parking Lane 9=Unknown
1=Daylight 3=Dark -Street 5=Dawn 8=Other
El 2=Dark - No Lights 6=Dark - Unknown
Street Lights
_. 4=Dusk Roadway Lighting
1=No Adverse
Conditions
3=Sleet (Hall)
5=Fog
7-Sleet & Fog
9=Unknown
2=Rain 4=S ow 6=Rain 8 Fog 8-Other
O=Dry 2=Sand, Mud, Din,
Oil 4=Slush 6=Ice Patches 8=01her
1=Wet _
3_=Snow Covered
5=Ice
r -Standing
7=WV
or oving
Most? Utility Pole fUurnber Harmful Events (hl
r
E
t _
)
Hi a
m
ven
30=
t Fence or wall
1 ] 7 F-1 a F 01=Hit Unit 1
02
i
Hi
U
2 31=Hit Building
32
Hi
l
C
Unit No n
=
t
t =
vert
t
u
0]
Z
27 f??
I U I O
r -
' 03=Hit Unit 3
04=Hit Unit 4 33=Hit Bridge Pier Or Abutment
34=Hit Parapet End
1
L 05=Hit Unit 5 35=Hit Bridge Rail
- 06=Hit Other Traffic Unit 36=Hit Boulder Or Obstacle
Please Put
3
0 07=Hit Deer
08=Hit Other Animal On Roadway
37=Hit Impact Attenuator
Events in
Sequential 09=Collision With Other Non 38=Hit Fire Hydrant
Order 4 O Fixed Object
11 =Struck B Unit 1 39=Hit Roadway Equipment
40=Hit Mail Box
12=Struck By Unit 2 41=Hit Traffic Island
13=Struck By Unit 3 42=Hit Snow Bank
Harm Event 1/R Most? Utility Pole Number 14=Struck By Unit 4 43=Hit Temporary Construction
y
0 ]
El 15=Struck By Unit 5
16=Struck By Other Traffic Unit
Hi
21
T
h
O
bb Barrier
48=Hit Other Fixed Object
49
Hit U
k
Fi
d
Unit No =
t
ree
r S
ru
ery =
n
nown
xe
Object
F
02
2 ? O 22=Hit Embankment
23=Hit Utility Pole 50=Overturn/Roll Over
51=Struck Struck By Thrown Or Falling
24=Hit Traffic Sign Object
25=Hit Guard Rail 52=Pot Holes Or Other
Please Put
Events in 3
? Q 26=Hit Guard Rail End
27=Hit Curb Pavement Irregularities
53=1acknife
Fi
Sequential 28=Hit Concrete Or 54=
re In Vehicle
Order
4 Longitudinal Barrier
29=Hit Ditch 58=Other Non-Collision
99=Unknown Harmful Event
First Unit No Harm Event Most Unit No Harm Event
77 -ent in ? fin
0 ] 12 Event rn 02 01
t tee rash t e rash
Do not repeat this mlormation m multiple pages
Environmental / Roadway
Potential Factors (EM) 1 99 2 3
00=None 11=Slippery Road Conditions (Ice/Snow)
01=Windy Conditions 12=Substance On Roadway
02=Sudden Weather Conditions 13=Potholes
03=0ther Weather Conditions 14=Broken Or Cracked Pavement
04=Deer in Roadway 15=TCD Obstructed
05=Obstacle On Roadway 16=Soft Shoulder Or Shoulder Drop Off
06=01her Animal in Roadway %8=0ther Roadway Factor
07=Glare 29=Other Environmental Factor
08=Work Zone Related 99=Unknown
Possible Vehicle Failures (V) 12=Wipers
00=None 06=Exhaust 13=Driver Seating/Control
01=Tires 07=Headlights 14=Body, Doors, Hood, Etc
02=Brake System 08=Signal Lights 15=Trailer Hitch
03=Steering System 09=Other Lights 16=Wheels
04=Suspension 10=Horn 17=Airbags
05=Power Train 11 =Mirrors 18=Trailer Overloaded
19=Unsecure/Shifted
Unit 0] 1 00 Z Trailer Load
No 20=Improper Towing
21=Obstructed Windshield
Unit 02 1 00 Z 99=Unknown
No
Indicated Prime Factor Unit No Factor Code
D not repeat ibis inrounalion un
multiple pages. 0 99
EIR V D P
0 Q Q Q If EIR is the Prime Factor
Type, leave Unit No blank
FORAM N AA-500 (1202)
00=No Contributing Action
01=Driver Was Distracted
02=Driving Using Hand Held Phone
03=Driving Using Hands Free Phone
04=Making Illegal U-Turn
05=Improper/Careless Turning
06=Turning From Wrong Lane
07=Proceeding W/O
Clearance After Stop
08=Running Stop Sign
0R
9=R
Red Light
10=Failure To Respond To
Other Traffic Controt Device
i 1=Tailgating
12=Sudden Slowing/Stopping
13=Illegally Stopped On Road
14=Careless Passing Or Lane
Change
15=Passing in No Passing Zone
16=Driving The Wrong Way on
1-Way Street
Noit 0 ] 1 99
17=Careless Or Illegal
Backing On Roadway
18=Driving On The Wrong
Side Of Road
19=Making Improper
Entrance To Highway
20=Making Improper Exit
From Highway
21=Careless Parking/Unparking
22=Over/Under
Compensation At Curve
23=Speeding
24=Driving Too Fast For Conditions
25=Failure To Maintain Proper Speed
26=Driver Fleeing Police (Pol Chase)
27=Driver Inexperienced
28=Failure To Use Specialized Equip
92=Affected By Physical Condition
98=Other Improper Driving Actions
99=Unknown
3= 4?
NorY 02 1 99 2 3 = 4
Pedestrian Action (P)
DO=None
01=Entering Or Crossing At
Specified Location
02=Walking, Running, Jogging.
Or Playing
03=Working
04=Pushing Vehicle
05=Approaching Or Leaving Vehicle
06=Working On Vehicle
07=Standing
98=Other
99=Unknown
Unit No 0 ] Unit No 02
PENINDOT COPY
http://www.dot6. state.pa.us/crsapp/PrintlnT ages/XmlFiles/20100264162010042914310031... 4/29/2010
I COMMONWEALTH OF PENNSYLVANIA
POLICE CRASH REPORTING FORM
AA 500 5 Police Use Only
?
tlII?NIYII11R11 Crash Number
Page
6 W0149866
.:..... ....... .... o
Witness Name Address Phone
I RANDALL GRAF 11 17 TUNBRIDGE LN MECHANICSBURG PA 1 7174185757
2 RANDALL GRAF CELL PHONE NUMBER 7177329744
Narrative and additional witnesses: Accident Investigation Notification Issued? i Property Damage 0
On 3/13/2010 @ 1523, 1 (Patrolman Jason Julseth) was working in my full capacity as a Hampden Township
Police Officer, wearing full police uniform and driving marked cruiser #1. At this date and time, Cumberland
County Control dispatched Hampden Police to the intersection of Creekview Rd. and Good Hope Rd. for a
report of an auto accident with possible injuries. At the time of dispatch I was on active patrol and driving
southbound on South Sporting Hill Rd. crossing Carlisle Pike. I initiated my lights and sirens and proceeded
north on Good Hope Rd. to the crash scene. While enroute, CCC advised that there may be two people
entrapped in one of the vehicles.
m
a
I approached the crash scene from the northbound lane of Good Hope Rd. Upon arrival, I noticed a
g Hampden Township Fire engine, along with Hampden EMS at the scene. I parked my cruiser in the northbound
lane of Good Hope Rd. just south of the Creekview intersection. I walked on the scene and saw two vehicles, a
C blue Honda Pilot, and a tan Toyota Avalon, which were the two vehicles involved in the crash. I initially passed
„ by the Honda Pilot but didn't see anybody in the vehicle; I did witness several people standing with umbrellas on
a the northbound corner of Creekview Rd. and Good Hope Rd. I noticed Fire personnel and Hampden EMS
tending to the tan Toyota vehicle. I briefly looked inside the passenger side of the vehicle; which was open, and
?U"rA A AA-500 (12/02)
PENNDOT COPY
http://Nv,A,w.dot6.state.pa.us/crsapp/Priiitlmages/XmIFiles/20100264162010042914310031... 4/29/2010
I rC®NNOR9tn911ALYN OF PER91' SYLVAR70A
fPOLOC.E CMASH REPORTONG ff®RfAfi1
AA cM N Police Use Only I
Narrative and additional witnesses:
Page CD New ?II (I III?IIIIII??I?I??IIII Crash Plumber
WO149866
O Change/
Continuation
saw the passenger (Prabha Jindal) laying across both seats in the front of the vehicle. I also briefly saw the
male driver (Ramesh Jindal) still located in the drivers side seat; I also saw what I believed was copious
amounts of blood inside the vehicle. Hampden Fire and EMS were tending to these individuals at this time.
I then turned my attention to the people standing on the corner. I spoke with the driver of the blue
Honda Pilot, Mrs. Kristen A. Carpinello. I immediately asked Carpinello if she was injured. Carpinello said
that her leg hurt and she had stains on her hands; preumably from her airbag deployment. Due to the rain
and wind conditions. I asked Carpinello what had happened. Carpinello initially told me that both her and
her son were heading southbound on Good Hope Rd. Carpinello said that they were struck by the other
vehicle when they entered the intersection. Carpinello told me that she couldn't remember what color the
light was on the traffic signal. I offered both Carpinello and her son, Dominic, who was a passenger in her
vehicle during the crash, to sit in my cruiser until EMS can assist them. Both Kristen and Dominic sat in the
rear of my cruiser. I then spoke with the Fire Co. who indicated that another ambulance would be enroute
to assist the Carpinello's; I advised the Carpinello's of this. I was then approached by Mr. Randy Graf, who
claimed to be an independent witness of the crash. Graf stated that he was travelling westound on
Creekview Rd. approaching the intersection of Creekview Rd. and Good Hope Rd. when he observed the
two vehicles crash. After asking Graf what he believes happened, Graf indicated that he only saw the crash
and didn't remember anything leading to the crash. Graf said that he didn't remember what color the traffic
control signal was displaying at the time of the crash. Graf then said he and his wife exited his vehicle to
tend to the involved crash parties. I collected Grafs information and released him from the scene.
0
9
Shortly after, Camp Hill EMS arrived on the scene and tended to the Carpinello's. After the Carpinello's
Q were escorted to the rear of Camp Hill Ambulance, Kristen's husband, Michael Carpinello, arrived on
scene. Michael went to speak with his wife and son in the Camp Hill Ambulance. Michael then approached
me and told me that Kristen had picked up Dominic from Twin Ponds on Lambs Gap, and were actually
heading eastbound on Creekview Rd. attempting to drive home. I then spoke with Kristen in the rear of the
ambulance who verified that she was, in fact, on Creekview Rd. travelling eastbound when the crash
3; occured. The Carpinello's live at 3806 Carriage House Dr., and, to me, were heading in the shortest
>x p
FMO a AA-sow tuw?
PENNDOT COPY
htip://www.dc)t6.state.pa. us/ersapp/Printlmages/XmIFiles/20100264162010042914310031... 4/29/2010
I C?®G51G?1®f?1C^J?[L4C,1 OF [PEEN NSSVIL@lAMA
PO LBCIE CPAS fl R2EEIOINUON G FORM
PA cM N Police Use Ony
Page 0 New lIiIIIIIINIIIIiIIUllIiIIN Gash Number
W0149866
O Change/
8e/
Continuation
Narrative and additional witnesses:
direction to travel home from Twin Ponds.
Kristen Carpinello:
As I spoke with Kristen, I did not notice any smell of an alcoholic beverage, nor did I suspect any
medication misuse or illegal drug use. Investigation shows that both Kristen and Dominic (who was sitting
in the passenger side rear seat) were both seatbelted. I found Kristen to be, in my opinion, in a slight state
of shock. When I spoke with Kristen initially, she was unable to remember any pertinent information
regarding the crash.
At this point, Cpl. Shaugnessy and Fire Police arrived at the scene. Cpl. Shaughnessy advised that the
Cumberland County Crash Team would be summoned to conduct an investigation. Cpl. Shaughnessy
indicated that the driver of the tan Toyota Avalon (Ramesh Jindal) was deceased. I gathered applicable
registration and license date from Carpinello before she was escorted to Holy Spirit Hospital by Camp Hill
EMS for her injuries. At this time, Sgt. Felty arrived on the scene. I spoke with Sgt. Felty and Cpl.
Shaughnessy, who directed me to travel to Holy Spirit Hospital to speak with Kristen Carpinello about the
crash.
I went to Holy Spirit to speak with Carpinello. Carpinello was being treated in a room when I spoke with
her. Carpinello again told me that she was going home with Dominic from Twin Ponds (eastbound) at the
time of the crash. Carpinello said that as she entered the intersection of Good Hope Rd., she saw, on her
right side, the other vehicle "zooming." Carpinello said that it happened so fast she didn't believe that she
had time to apply her brake pedal. Carpinello again said that she didn't remember what color the traffic
ro control signal was showing, but said she believed she didn't think she had to stop for the intersection.
u Carpinello had an apparent non-life threatening leg injury. I asked pertinent questions regarding Kristen.
c. Kristen's husband claimed she is not on medications. I asked if Kristen was distracted by Dominic or other
instances. Kristen said that she was not speaking with Dominic before or during the crash; the vehicle
a was "silent." Dominic was sitting in a chair in the room; apparently unharmed. I asked both Kristen and
Michael if I could speak with Dominic; they consented. I asked Dominic if he remembers seeing anything
ce' just before, or during the crash. Dominic said that there may have been a vehicle in front of their Pilot, but
couldn't remember. Dominic was unsure of the traffic control signal color. I advised the Carpinello's to call
5 me immediately should they have any more information regarding the crash. I also returned Kristen's
identification and vehicle info.
After speaking with the Carpinello's, I left Holy Spirit Hospital and
FORM B AA500y (ta??
PENNDOT COPY
http://www.dot6.state.pa.us/crsapp/Printlmages/XmlFiles/20100264162010042914310031... 4/29/2010
I BBL CRASH P3D6@1TORIG FORM f?lUGl O New 11111 IIIII I I IIIIIIIIIII III Crash wumber
Page W0149866
AA 500 N Pol ce use Ony O Change/
Continuation
Narrative and additional witnesses:
returned to the scene of the crash. Upon arrival to the crash, I noticed that the crash team was conducting
their investigation. I also saw the Coroner and the Coroner's assistants at the scene. I was informed by
various Hampden personnel that the passenger of the Toyota Avalon (Prabha Jindal) was being
transported by ambulance to the Hershey Medical Center for her injuries. At this point I called Graf on the
phone in order to determine if he remembered anything else about the crash. Graf was not able to
remember any specifics about the crash; rather, he just saw the vehicles strike each other. Graf unable to
remember what color the traffic signal was.
I called Michael Carpinello's cell phone (717) 443-0630 and told him that both vehicles would be towed
to the Hampden Police impound lot by way of Roadside Rescue; also, I indicated that he should call his
insurance company and to contact me directly should they have any questions or concerns.
While the Coroner's office and other Emergency workers, including the Cumberland County Crash Team
were conducting their investigations, I was conducting a preliminary crash report in my cruiser at the
scene. By way of my vehicles computer system I was able to retrieve pertinent information on vehicles and
the drivers/passengers of the vehicles involved with the crash.
At approximately 1850, 1 was informed that the Crash Team was finished with their investigation. At this
time, Roadside Rescue was notified to collect the two vehicles. Roadside arrived shortly thereafter and
collected the vehicles. Roadside Rescue towed the vehicles to the Hampden Police impound lot, where I
witnessed the placing of the vehicles. I retrieved the keys from the Honda Pilot, but the keys in the toyota
were jammed in the ignition and were unable to be retrieved. I placed the Honda keys in a brown paper
bag and noted when the vehicles were placed in the impound lot (at approximately 1915). 1 then headed to
station to continue the investigation.
On 4/11/2010 1 received the finalized report from Ofc. Claeys (CCART). The report includes estimated
a speeds for both V1 and V2. Claeys was able to pull V1's EDR (Event Data Recorder) and estimated V1's
speed to be between 35 and 42. The estimated speed of V2 is between 39 and 47 mph. Claeys
? concluded that neither speed or vehicle malfunction was a contributing factor in the crash; it's Claey's
conclusion that operator error was the primary contributing factor in the collision in either V1 or V2 failing to
stop for a steady red signal.
FORM B AA,14" (ram
PENNDOT COPY
http://wwvv.dot6.state.pa.us/ersapp/Printlmages/XmIFiles/20100264162010042914310031... 4/29/2010
1 OCCL't CUR&W POR40 G FORK (k10LJ Page CD New 111111111111111111111111111 CrashNumber
_J (CONDWOMWEALM OF AA 500 F P°lice Use Only O Q Change/
WO149866
Continuation
Road Surface Pupa Q Brick or Block Q Dirt Special Jurisdiction Q Military 0 Other Federal Sites
Q Concrete No Special Q Indian Reservation Other
Q Slag, Gravel or Q Other
Stone Jurisdiction
W Blacktop Q Unknown Q National Park C:) College/University CD Unknown
Campus
Please complete Unit information for each unit involved in a fatal crash. Do not repeat the information in the fields above on multiple pages.
Unit No P rinciple Impact Point 0
0 ] Q Non-Collision CD 11 12 010
1 2 0
Driver Restrictions Restrictions
Q
Complied With Not a Pennsylvania
Q
Driver Q Top
0 09
*
030
Compliance Restrictions Not
0 Unknown
0 Q Undercarriage
No Restrictions/ Complied With Compliance Q 0 4 Q
Not Applicable Compliance
Q Q Towed Unit _
07 0 ?
6 5
Unknown 0
0
o
°W ca Driver Endorsement Re quired -
0 Complied With Not a Pennsylvania
0 Driver Q Unknown Q
Compliance Required - Non
0 Unknown
0 Avoidance Maneuver
e
W None Required Compliance
Required -
0 Compliance No Avoidance
Q
Maneuver
Braking - Other Other Avoidance
0 Evidenc
i = Compliance Unknow n e Maneuver
«
Driver License
Q Not Required for
Q Unk if CDL or
Braking - Skid
0 Marks Evident
Steering - Evidence Inconclusive
or Driver Stated
Compliance Vehicle Class
No Valid License
Q CDL Required
Not a Pennsylvania
0
Braking - No Skid
Marks
Driver
Q
Steering and Braking W Unknown
O Not Licensed for Class
Valid License for Driver ,
Stated Evidence or Stated
-
Class Q Unknown
Under Ride Indicator
Drug Test Type
Q Blood
Q Other
- No Underride or Underride, No Override, Other
Q Compartment 0 Vehicle
None
Q Urine Unknown if Test
Q Override Intrusion
Given
Underride,
Underride, Unknown if
Drug Pest Results - (Up to Four Results)
Q Compartment ment 0 Underride or
0 Compart
Override
I
t
U
k
? Intrusion n
n
rusion
nown
0 = No Test Given 5 = Amphetamines
1 = No Drug Reported 6 = PCP
i
M D
Emergency Use Both Lights and
Q Lights Flashing Q
ar
juana 8 = Other
2 =
3 = Cocaine 9 = Unknown Test ? ? Not in Emergency Siren
4 = Opiates Results ® Use 0 Siren Sounding Q Unknown
Unit No
02
Driver Restrictions
m Q Restrictions
Complied With Q Not a Pennsylvania
Driver
mp ra Restrictions Not
0 Unknown
0
No Restrictions/ Complied With Compliance
Not Applicable Compliance
0
c Unknown
M Driver Endorsement
?B Q Required -
Complied With 0 Not a Pennsylvania
Drivet
Contp ran Q Required - Non Q Unknown
None Required Compliance Compliance
Q Required -
C Compliance Unknown
Driver License Not Required for
0
Vehicle Class
Q Unk if CDL or
omp rants CDL Required
No Valid License
0 for Class Not a Pennsylvania
0
Q Not Licensed
. Valid License for Driver
Q U
k
Class n
nown
Drug Test Type 0 Blood Q Other
None
0 Urine Unknown if Test
O Given
Drug Test Results - (Up to Four Results)
?
0 = No Test Given 5 = Amphetamines
1 = No Drug Reported 6 = PCP D
2 = Marijuana
3 =Cocaine 8 = Other
9 =Unknown Test ?
4 = Opiates Results
Principle Impact Point
O Non-Collision CD =
1 12 0 0
010 020
0 Top
Q 09 03 Q
O Undercarriage
04 Q
0 08
I Z_
O Towed Unit 07 06 05Q
Q Unknown 0 CD
Avoidance Maneuver
Q No Avoidance
Maneuver Braking -Other
0 Other Avoidance
0
Evidence Maneuver
Q Braking - Skid Q Steering - Evidence Q Inconclusive
Marks Evident or Driver Stated
Braking - No Skid
Q Marks
Driver Steering and Braking ® Unknown
0
,
Stated Evidence or Stated
Under Ride Indicator
No Underride or Underride, No
Q Compartment Override, Other
0 Vehicle
Override Intrusion
Underride,
Q Compartment Underride,
0 Compartment Unknown if
O Underride or
Intrusion Intrusion Unknown Override
Emergency Use Q Lights Flashing Q Both Lights and
Siren
- Not in Emergency
Use
Siren Sounding
Q Unknown
Pond a cw4CUF Omq
PENNDOT COPY
littp://www.dot6. state.pa.us/crsapp/Printlmages/Xml Files/20100264162010042914310031... 4/29/2010
Crash Number: W0149866
Incident Number: HAM20100300353
?J
wl
73?
d
it
http://www.dot6.state.pa. us/crsapp/Printlmages/XmlFiles/20l 0026416201004291431003 l ... 4/29/2010
j Print CloseWindow
Synopsis
Quality Assurance Synopsis Report
Crash Synopsis created 04/29/2010 for Crash Number W0149866 WebGroup: QA
Police Agency Data:
The crash report was recorded by police agency 21103-Hampden Township, patrol zone -400, under incident number HAM20100300353.
The dispatch date was 03/1312010, the dispatch time was 1523 hours, the investigation date was 03113/2010, the arrival time was 1527
hours. The investigator was PATROLMAN JASON JULSETH, badge number 19-22. The report was approved by JEFFREY A SNYDER,
badge number 19-11 on 04/12/2010.
Crash Data.
This is an angle crash occurred in Cumberland in the municipality of Hampden Township, on Saturday, 03/13/2010 at 1520 hours. The
illumination at the time of the crash was daylight. The 2 -unit crash involved 4 people with 2 injuries. There was 1 fatality as a result of this
crash. This is a reportable crash. Highway maintenance was not notified. The crash was not school bus related. The crash was not school
zone related. There was PennDOT property damaged. The crash did not occur in a work zone. The Blacktop roadway surface was wet.
Weather conditions included rain. A notification of an accident investigation was issued. Other environmental / roadway potential factors
included Unknown. The indicated prime factor for this crash was an environmental / roadway factor (Unknown). The first harmful event for
this crash was that unit 1 was struck by unit 2 and the most harmful event for this crash was that unit 2 Hit unit 01.
Type Location:
This was a a four way intersection crash, which occurred at no special location.
Principal Roadway:
Cumberland County, CREEKVIEW Road, the orientation of the roadway was East, there were 03 travel lane(s), the speed limit was 30 Mph,
with a local road or street route signing.
Intersecting Road:
Cumberland County, route 1013, the orientation of the roadway was North, there were 03 travel lane(s), the speed limit was 35 Mph, with a
state highway route signing.
GPS:
The police-entered Latitude was 40 15:59.000 and the police-entered Longitude was 76 58:47.000
TCD:
Traffic Control Device: a traffic signal, functioning properly.
Work zone:
Type of Work Zone: not a work zone.
Lane Closure:
Not applicable.
UNIT INFORMATION: 1
Unit Number 1 was a motor vehicle in transport. The unit was owned by JINDAL, PRABHA. Address: 1750 ELIZA WAY MECHANICSBURG
PA 17050. This 2008 Toyota identified by VIN: 4T1 BK36BX8U283648 was registered in PA with License HDP2618. Travel speed: 035. Unit
insured: vehicle has insurance, Insurance Company: ERIE INSURANCE EXCHANGE. The Unit was towed by ROADSIDE AUTO RESCUE.
This was not a commercial vehicle. This Unit was an automobile, Vehicle color: Gold, Special Usage: Not applicable. The initial impact point
was at 10 o'clock, Damage Indicator: Disabling (severe - not driveable), Vehicle role: was struck by unit 2 and hit a curb. Vehicle position: in
the curb lane right. Direction of travel: North, Movement: Going straight, Gradient: uphill, Alignment: Straight.
htip://www.dot6.state.pa.us/crsapp/generateSynopsis.do?method=executeGenerateSynopsis 4/29/2010
Driver Information
The driver of this unit was RAMESH K JINDAL. Address: 1750 ELIZA WAY MECHANICSBURG PA 17050. Drivers License #'. 20308890,
State: PA. DOB: 09113/1942. Age: 67. Sex: Male. Seat position: driver's seat. Primary safety equipment: lap and shoulder belt were used.
Secondary safety equipment: Front air bag deployed (for this seat). Injury severity: Killed. Ejection: Not ejected. Alcohol/Drugs Suspected
none suspected, Alcohol Test Type: Test not given, Alcohol Test Results: Result = 0.00. Driver's action(s), 1 unknown. The individual's
condition was apparently normal. Vehicle code UNKNOWN was violated. No citation was written.
Passanger Information
a passenger 02: PRABHA JINDAL, Address: 1750 ELIZA WAY MECHANICSBURG PA 17050. Telephone: 717-695-7328. DOB: 06/25/1941
Age: 68. Sex: Female. Seat position: Front seat right side. Primary safety equipment: lap and shoulder belt were used. Secondary safety
equipment: Front air bag deployed (for this seat). Injury severity: Injury, Unk Severity. Ejection: Not ejected.
UNIT INFORMATION: 2
Unit Number 2 was a motor vehicle in transport. The unit was owned by CARPINELLO, KRISTEN A & MICHAEL. Address: 3806 CARRIAGE
HOUSE DR CAMP HILL PA 17011. This 2005 Honda identified by VIN: 5FNYF18505BO65298 was registered in PA with License ESP8016.
Travel speed: 039. Unit insured: vehicle has insurance, Insurance Company: ERIE INSURANCE. The Unit was towed by ROADSIDE AUTO
RESCUE. This was nol a commercial vehicle. This Unit was an SUV, Vehicle color: Blue, Special Usage: Not applicable. The initial impact
point was at 12 o'clock, Damage Indicator: Disabling (severe - not driveable), Vehicle role: Hit unit 01. Vehicle position: in the curb lane right.
Direction of travel: East, Movement: Going straight, Gradient: on a level roadway, Alignment: Straight.
Driver Information:
The driver of this unit was KRISTEN A CARPINELLO. Address: 3806 CARRIAGE HOUSE DR CAMP HILL PA 17011. Telephone: 717-737-
1415, Drivers License #: 21986813, State: PA. DOB: 11/18/1969. Age: 40. Sex: Female. Seat position: driver's seat. Primary safety
equipment: lap and shoulder belt were used. Secondary safety equipment: Front air bag deployed (for this seat). Injury severity: Minor injury.
Ejection: Not ejected. Alcohol/Drugs Suspected: none suspected, Alcohol Test Type: Test not given, Alcohol Test Results: Result = 0.00.
Driver's action(s), 1 unknown. The individual's condition was apparently normal. Vehicle code UNKNOWN was violated. No citation was
written.
Passanger Information:
a passenger 04: DOMINIC ROBERT CARPINELLO, Address: 3806 CARRIAGE HOUSE DR. CAMP HILL PA 17011. Telephone: 717-737-
1415. DOB: 06/30/2001. Age: 08. Sex: Male. Seat position: Second row - right side. Primary safety equipment: lap and shoulder belt were
used. Secondary safety equipment: None used / Not applicable. Injury severity: Not injured. Ejection: Not ejected.
Print ' CloseWindow
http://www.dot6.state.pa.us/crsapp/generateSynopsis.do?method=executeGenerateSynopsis 4/29/2010
;moor
C
101.901 Kt\'.IIrlli
Tli? is to certify that this is a true copy of the record which is on file in the Pennsylvania Department of Health, in accordance with
,-e Vital Statistics Law of 1953, as amended.
WARNING: It is illegal to duplicate this copy by photostat or photograph.
6133993
No.
Marina O'Reilly Matthew
Acting State Registrar
MAR 3 1 2011
Date
6,144 REV 1112006 COMMONWEALTH OF PENNSYLVANIA • DEPARTMENT OF HEALTH a VITAL RECORDS IN 026907
PERMANENT CORONER'S CERTIFICATE OF DEATH
BLACK INK See instructions and examples on reverse
lk19_??/, I 1 STATE FILE NUMBER
1. Name d Decedent (First middle, last suffix) 2. Sex 3. Social Security Number 4. Date of Death (Month, day, year)
Ramesh K Jindal Male 178 -60 -2295 March 13, 2010
5. Age (Last Birthday) Under 1 year Under 1 day 6. Date of Birth (Month, day, year) 7. Birthplace (City and stale or loreign country) Sa. Place of Death (Check only one)
67 yrs hxams Days Hours Mmes
September 13,1942
Punjab, India Hospital:
[]Inpatient ?ERIOmpadent ?DDA Other:
[]Nursing Home []Residence []Other-Specify:
' 81b. County, d Death 8c City, Bon Twp. I Death 8d. Facility Name (If not institution, give street and number) 9. Was Decedent of Hispanic Origin? f] No ? Yes 10. Race: American Indian, BscK White, etc.
Cumberland Hampden pf yes, specify Cuban, (Speedy)
Good Hope Rd, at Creekview Road Mexican, Puerto Rican, etc.) sian-Indian
11. Decedent's Usual Occupation Kid of work done during most of working life. Do rot slate retired 12. Was Decedent ever in the 13. Decedents Education (Spedy only Nghest grade completed) 14. Marital Slaws: Married, Never Married, 15. Surviving Spouse (If rifle, give maiden name)
Kid of Work
Physician Kind d I Industry
Medica U.S. Awed Forces?
OYes g]No Elementary f Secondary (0.12) College (1-4 or S.j
5+ Wowed, Divorced (SpecrlA
married
rabha Jindal
• 16. Decedents Mang Address (Street, city I town, state, zip code) Decedents Did Decedent
v
e 7c
DecederrUveft Hampden Tw
oYes
PA
A
l R
id
17
St
t
1750 Eliza Way Li
ve
,
.
p.
ence
ctua
es
a
a
e
edwithi
17°'? tDece
Mechanicsburg, PA 17050
its of
17b Camty Cumberland Act
Aual Lids d City / Boro
18. Fader s Name (First, middle, last suffix)
Tulsi Ram Jindal 19. Mother's Name (First, middle, maiden surname)
Soria Gupta
20a. Informant's Name (Type I Print) 2Db. Inlonaa's Mal Address (Stree( city I fun, state, zip code)
Shivani Narasimhan 14605 Corys Court, Glen Elg, MD 21737
21a. Method of Disposition ® Cremndon ? Donation 21b. Date of Disposition (Months day, year) 21c. Place d Disposition (Name d camel". crematory or other place) 21d. Location (City I tam, slate, zip code)
•
0
Burrial p Re"""al from So W
?p or Donation
Ae"a'ea° March 22
2010 Hoover Funeral Homes Crematory Harrisburg, PA 17112
?
,
I
p???
r
Othe So.*. ,
22aSgnaWreof F nice ( such) 22b.LicenseNmteer 22c.NameandAddessdFadtity Hoover Funeral Homes & Crematory Inc.
FD 011921 L 6011 Linglestown Rd., Harrisburg, PA 17112
Cwo* Ilene only when darl 23a. To the best of my Imil, death occurred at the time, date and place stated. (Signature and dlle) 231b. License Number 23c. Date Signed (Month, day, year)
physician is not available at done of death to
car* cause of death.
Kenn 24.26 must be competed by person 24. Tone of Death 25. Date Pronounced Dead (Month, day, year) 26. Was Case Related to Medical Examiner I Coroner for a Reason Other than Cremation or Donal
who pronounces death, A rx. 3:20 P. M. March 13, 2010 Yes ?No
CAUSE OF DEATH (See Instructions and examples) i Approximate Interval Pan It: Eder other ' 28. Did Tobacco Use Conlrthda to Death?
hem 27. Pan I: Enter the chain - diseases, i furies, or mnplicafam -tat directly caused ga.dea i. DO NOT enter (Implied evens such as cardiac arrest t Onset to Death but not resuffing in the underlying cause given i Pan I. ? Yes ? Probably
respiratory armed, of ventricular ttht"on without stowing the ebft List ady one can on adl ine. '
h
? No ? UnNtawth
DIATE CAUSE i
disease or
aaAE'i4
Head and Neck Trauma Female.
29 ti
-30- a. El
n i
Seperttialydslwrdidas,iarty Due to 1a as a cosegtern oQ:
, b. Motor Vehicle Crash '
' Not pregnant within Past year
? Pr4yraaraalfneddath
kadala f case 6f0 on lire a
Erndr Bloc UN DERLYWG CAUSE Duero (a as a consequence ol): ' ? Not pregnant but pregnant vntlli 42 days
refined
evens c ' of death
•
Due to (a as a consequence oQ: ?
Not prepharll, bit pregnant 43 days to 1 year
belod death
• d.
Unggwn d
re
nant vhttm der
ast
ear
p
g
p
y
30a. Was an Autopsy
Performed? 30b. Were Autopsy Findings
AvdlablePrior aCortpietim 31. Manner of Death 32a. Dale d"(MDndv day, year) 32b. Descdbe How Intury Ocaxred
Belted operator, struck 32C. Piece of kyury: Now, Farm, Street Factory
OBI Sudmg,dc.(**)
dCause (A Death? ? Nafrd [] Homicide March 13 2010 broadside. Street
? Yes ?No ? Yes ? No 4ACcidem ? Pending Investigation 32d. Time ol iPry 32e. Injuryat Wark? 32f. If Trarsponabon Injury(Spedy) 32g. Location of Iniury (Street, city 1 town, state)
? suicide ? Could Not be Delemlied Aprx. ? Yes ;No ? Drivar 1 Operator ? Passenger ?Pedesfan
3:20 P.M' Oder•Spocil Good Hope Road, Mechanicsburg, Pa
33a. Certdar (deck only one) 33b. Sgrer ne and Titf of CaNfer
' Certifying Physician (Physical certifying cause d death when another physician has pronounced death and completed Item 23)
-Ex9?oner
To tlebesldmylmohMMge,dathoccwredduetotltecausas)andmemeaactate?-------------------------------- E]
' Pronouncing and certifying physioian (Physician both prorpuadng death and %A)* to cause d death)
ta
? 33c. License Number 33d. Des Signed (Month, day, Yon')
To the best of my gawledge, da
ocinmed at the On, date, and place, and due to the causei said manner as sbinL-----------------
Medical Examiner ICoroner March 15, 2010
On the basis of examination and f or inva0gation. In my opinion, death occurred it the time, daft and place, and due to to causl and manner a Stated_
34. Name and Address d Penton Who Corrpfted Cause d Dori glern 27) Type I Pill
;Registrar are s,naNaya?
2 a
a' L
year)
F
(S' Todd C. Eckenrode, Coroner
6375 Basehore Rd., Suite #1
'
° (
? 10
1
nAIA09
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ir+?•r+?
"""?,...wr?"
AFFIDAVIT OF NO ADDITIONAL INSURANCE
My name is Kristen Carpinello. On March 13, 2010 I was the driver of a 2005 Honda
Pilot EX, which my husband, Michael Carpinello, and I own. I was involved in an
accident at Creekview and Good Hope Roads in Hampden Township.
I understand
Mrs. Andai and the Estate of Mr. Andal are pursuing claims-against me for an amount
that may exceed the limits of my policy with ERIE INSURANCE EXCHANGE. This
bodily injury limit is $100,000 per person and a total of $300,000 per accident.
I certify that I do not have any other available insurance coverage to address the claims
being made by the Jindals, whether it is an additional policy or an excess or umbrella
policy.
1. further certify that at the time of the collision, I was not acting on behalf of any
employer.
I verify that the statements in this, affidavit are true and correct. I understand that false
statements herein are made subject to the penalties of 18 Pa. C.S.A. &. 4903, relating to
false swearing.
sten Carp' ello
Sworn to and Sub bed
Before me this0 day
of 0*z•-'' 2010
?S /' oor,
15000,
GENERAL RELEASE CLAIM #. 010171083221
For the consideration of ONE HUNDRED THOUSAND DOLLARS AND 001100-
dollars ($100.000.00
receipt of which is hereby acknowledged, 11we release and discharge, and for myself/ourselves and for my/our heirs,
representatives, executors, administrators, successors and assigns, do hereby remise, release and forever discharge
Kristen A. Carpinello and Michael V. Carpinello
hereinafter referred to as the releasee(s), his/her/their/its heirs, executors, administrators, insurers, successors and
assigns, and any and all other persons, (firms, corporations, associations, of and from any and all causes of action,
5}aits, rights, judgments, claims and demands of whatsoever kind, in law or in equity, known and unknown, which
Itwe now have or may hereafter have, especially th claimed legal liability of releasee(s) arising from or by
reason of any and all bodily or personal injuries and?or property damage known and unknown, foreseen and
unforeseen which heretofore has/have been or which hereafter may be sustained by melus arising out of the
accident on or about March 13 2010
YEAR
at or near Creekview and Good Hope Roads, Mechanicsburg, PA
in the county of Cumberland in the State of Pennsylvania
which liability releasee(s) expressly deny(ies).
Me agree that the consideration set forth above is specifically applicable to and paid to me/us with respect to
any and all damage to arrtly property, either real or personal, of mine/ours and with respect to any and all personal
or bodily injury of mine(ours, whether presently known or unknown, foreseen or unforeseen or which may
subsequently develop and the consequences thereof, all as arising out of the aforementioned accident.
I/We further agree that the consid ration set forth above is specifical y applicable to and paid to me/us with respect
to any right of contribution that Itwe may have against the releasees), hislher/theirhts heirs, exe utors, administrators,
insurers, successors and assigns relative to claims of others that may be brought against menus by reason of said
accident.
I/We further agree that the consideration set forth above i7 specifically applicable to my/our agreement that I/we
will not join nor attempt to join the r!eleasee(s , his/ herltheirlits heirs, a Tutors, administrators, insurers, successors and
assigns in any capacity, in any action that may be brought against melxus arising out of said accident.
I/We arrant for myselflourselves and my/our heirs, representatives, executors, administrators, successors and assigns
that Ilwe have received no money or other valuable consideration from any other person or persons by reason of any
causes of action, suits, covenants, agreement 7, judgments, claims and demands of whatsoever kind, which I/we now
have or may hereafter have, for injuries to my our person or property or for the other matters for which this release is
given.
I/We further understand and agree that this Release is inclusive of ny and all1 present and future liens or ci 'ms for
subrogation against the payments to be made in accordance with this Kele- s Uwe understand and agree that I/we are
responsible for the payment of any liens or charges against the payments to be made hereunder should an such liens,
subrogation, claims or claims for exp n es and charges be asserted. This includes, but is not limited to, medical expense
liens, workers compensation liens, 15A liens, liens asserted by any federal, state or local governmental entity or
agency gr an medical expense cla?im. hould any person or entity make claim for ayment o any liens or charges
against I he E 21 E or their counsel, I/we agree to indemnify and hold harmless the E RE and their counsel from any and
all such liens, charges, fees, claims, attorney fees, costs, interests and any other sum.
I/We understand that this settlement is the compromise of a disputed claim, and that the payment is not to be construed
as an admission of liability on the part of the persons, firms and corporations hereby released by whom liability is
expressly denied.
Intending to be legally bound thereby, WITNESS mylour hand(s) and seal(s) this
day of
_,---7UR -
NOTICE: Any person who knowingly and with intent to defraud any insurance company or other person tiles an application for insurance or
statement of claim containing any materially false information or conceals for the purpose of misleading, information concerning any
fact material thereto commits a fraudulent insurance act, which Is a crime and subjects the person to criminat and civil penalties.
WITNESS
(Seal)
(Seal)
C-41A-PA (R) 12104
?xN?$i?T
CLAIM #: 01 01 71 083270
RELEASE AND AGREEMENT
Under policy # Q071515283 issued by ERIE INSURANCE EXCHANGE/ERIE INSURANCE COMPANY, I/We, claiming coverage
for myself/ourselves or on behalf of Estate of Ramesh Jindal in consideration of Fifteen Thousand Dollars (515,000.00) dollars,
which 1/We have received, RELEASE AND DISCHARGE ERIE INSURANCE EXCHANGE/ERIE INSURANCE COMPANY from
any and all claims, causes of action or other rights which 1/We have, have had or could have under the Underinsured Motorists
coverage as set forth in said policy, which claims, causes of action or other rights arose or could have arisen as a result of a loss or
accident which happened on the 13`' day of March, 2010 at or near Good Hope Road and Creel(view Road in the county of
Cumberland in the State of Pennsylvania.
In consideration of such payment, 1/We agree as follows: 1) to assign Erie Insurance Exchange/Erie Insurance Company to my/our
rights of recovery against any person(s) or party(ies) legally liable to me/us, to the amount of and for the purpose of the payment noted
above; 2) that ]/We have not and will not make any separate settlement with nor give any separate release to any person(s) or
party(ies) who caused or are alleged to have caused the above mentioned loss or accident; 3) that suit may be instituted by Erie
Insurance Exchange/Erie Insurance Company in my/our name; 4) to execute all papers required to commence such suit; and 5) to
cooperate in prosecuting any or all actions which Erie Insurance Exchange/Erie Insurance Company may bring to recover from any
person(s) or party(ies) for the claims or causes of action which l/We have growing out of said loss or accident.
It is expressly understood and agreed that, out of any amount recovered, costs of collection, including by not limited to counsel fees,
shall be first paid to ERIE INSURANCE EXCHANGE/ERIE INSURANCE COMPANY. Except in states which apply comparative
negligence in determining legal liability, any recovery in excess of collection costs shall be paid to me/us, up to the full extent of
my/our loss. In states which apply comparative negligence, any recovery of my/our loss, in excess of collection costs, shall be
reduced by a factor equal to the percentage of my/our negligence which contributed to cause the above mentioned accident, before it is
paid to me/us.
I/We further understand and agree that this RELEASE AND AGREEMENT is inclusive of any and all present and future liens or
claims for subrogation against the payments to be made in accordance with this RELEASE AND AGREEMENT. i/We understand
and agree that I/we are responsible for the payment of any liens or charges against the payments to be made hereunder should any
such liens, subrogation, claims or claims for expenses and charges be asserted. This includes, but is not limited to, medical expense
liens, worker's compensation liens, ERISA liens, liens asserted by any federal, state or local governrnental cntity or agency or and,
medical expense claim. Should any person or entity make claim for payment of any liens or charges against ERIE INSURANCE
EXCHANGE/ERIE INSURANCE COMPANY or. their counsel, I/we agree to indemnify and hold harmless ERIE INSURANCE
EXCHANGE/ERIE INSURANCE COMPANY and their counsel from any and all such liens, charges, fees, claims, attorney fees,
costs, interests and any other sum.
1/We understand that this settlement is the compromise of a disputed claim, and that the payment is not to be construed as an
admission of liability on the part of the persons, firms and corporations hereby released by whom liability is expressly denied.
(CAUTION: READ BEFORE SIGNING)
Intending to be legally bound thereby, WITNESS my/our hand(s) and seal(s) this day of
W itnessesl-JBy:
(SEAL)
?x,* 18 r6
ATTORNEYS AT LAW
5425 JONESTOWN ROAD,
SUITE 103
HARRISBURG, PA 17112
TELEPHONE (717) 920-2220
FACSIMILE (717) 920-2370
Anthony W. Parker.
Extension 115
aparker@kpc-law.com
March 17, 2010
Prabha Jindal, M.D.
1750 Eliza Way
Mechanicsburg, PA 17050
Parul Kakaria, M.D.
1775 Adeline Way
Mechanicsburg, PA 17050
Gaurav Jindal, M.D.
23 South 23rd Street, Apt. 3R
Philadelphia, PA 19103
Shivani Narasimhan, M.D.
14605 Corys Court
Glenelg, MD 21737
Re: Engagement Letter
Dear Drs. Jindal, Jindal Kakaria and Narasimhan:
We are pleased that you have selected Kelly, Parker & Cohen LLP as legal counsel to
advise and represent you with regard to the auto accident that occurred on March 13, 2010. This
engagement letter and agreement includes services up to and including a final decision by a court
of common pleas, or by arbitration. Any and all appeals shall be covered by a separate
engagement agreement.
Our fees will be based on the recovery received from any individual, insurance company
or any entities through settlement or following trial. Our fee is thirty-three and one-third percent
(331/3%) of all amounts received. In the event that some or all consideration received is in a form
other than a monetary amount, then the fee will include the fair value of that compensation.
If you decide to terminate our representation before this matter has been resolved, either
through settlement or final decision by a court of common pleas, you agree to pay for our
services based on the time spent and the regular hourly rates of each attorney and paralegal
performing services on your behalf. The hourly rates vary from person to person and are
adjusted periodically (usually in January each year). We will be glad to provide you with a
schedule of rates presently in effect for the lawyers and paralegals who may be performing work
for you if you so desire. The work on these matters will mainly be handled by me at my hourly
rate of $190. 1 may be assisted by a paralegal whose rate is $95 per hour.
Ramesh K. Jindal, M.D.
Prabha Jindal, M.D.
March 17, 2010
Page 2
Upon your request, we will provide you with a statement reflecting work done in this
matter. We will include in our statements disbursements and out-of-pocket expenses made or
incurred on your behalf. These expenses typically include such items as obtaining medical and
nursing records, expert fees, document reproduction, travel expenses, long distance telephone
calls, mailing charges, necessary secretarial overtime, messenger services, filing fees, the cost of
depositions or other transcripts of testimony, and other expenses of litigation. You will be
required to reimburse us for these amounts from any recovery obtained. Should you decide to
terminate our representation before that time, you are required to reimburse us for these amounts
within thirty days of such action.
Our statements will also be accompanied by detailed reports including descriptions of the
services performed, the time incurred and the identity of the personnel performing the services.
Because this is a contingency case, our statements are only for your review and will identify the
amount owed to date if our services are terminated before the completion of this matter.
We are happy to discuss our statements at any time and will welcome the opportunity to
address any questions you may have.
If these arrangements are acceptable, please indicate your approval on the enclosed copy
of this letter and return it to us.
We very much appreciate the opportunity to serve you.
Very truly yours,
&
_.AnthonI W. Parker
Enclosure
The above billing procedure is acceptable.
Prabha Jindal, .D.
Dated:
Ramesh K. Jindal, M.D.
Prabha Jindal, M.D.
March 17, 2010
Page 3
GZ 311-7110
Shivani Narasimhan, M.D.
Dated:
Parul Ka aria, M.D.
Dated: :d ( A` I ID
??'fhB ??T
??: F: pennsylvania
U3 DEPARTMENT OF REVENUE
July 7, 2011
Anthony W. Parker, Esquire
Kelly, Parker & Cohen, LLP
5425 Johnstown Road, Suite 103
Harrisburg, PA 17112
Re: Estate of Ramesh K. Jindal
File Number 2110-0796
Court of Common Pleas Cumberland County
Dear Mr. Parker.
The Department of Revenue received the Petition for Approval of Settlement Claim to be filed on
behalf of the above-referenced Estate in regard to a wrongful death and survival action. It was forwarded
to this Bureau for the Commonwealth's approval of the allocation of the proceeds paid to settle the
actions.
Pursuant to the Petition, the 67 year old decedent died as a result of a motor vehicle accident.
The sole heir to decedent's estate is his spouse. Therefore, any proceeds paid to settle the survival action
would pass to decedent's spouse and would be subject to a zero percent inheritance tax rate. 72 P.S.
§9116(a)(1.1)(ii). Accordingly, regardless of the allocation of the subject proceeds, there would be no
inheritance tax consequences.
Please be advised that based upon these facts and for inheritance tax purposes only, this
Department has no objection to the proposed allocation of the net proceeds of this action, $69,003.45 to
the wrongful death claim and $7,667.05 to the survival claim. Proceeds of a survival action are an asset
included in the decedent's estate and, although subject to the imposition of a zero percent inheritance tax
rate in this instance, they must be reported on decedent's Pennsylvania inheritance tax return. 42
Pa.C.S.A. § 8302; 72 P.S. § 9106, 9107. Costs and fees must be deducted in the same percentages as the
proceeds are allocated. In re Estate of Merryman, 669 A.2d 1059 (Pa. Cmwlth. 1995).
I trust that this letter is a sufficient representation of the Department's position on this matter. As
the Department has no objections to the Petition, an attorney from the Department of Revenue will not be
attending the hearing regarding it. Please contact me if you or the Court has any questions or requires
anything additional from this Bureau.
i cerlel'fy,
annon E. Baker
Trust Valuation Specialist
Inheritance Tax Division
Bureau of Individual Taxes I PO Box 280601 1 Harrisburg, PA 17128 1 717.783.5824 shabaker@state.pa.us
Anthony W. Parker
PA ID 81251
Kelly, Parker & Cohen LLP
5425 Jonestown Road, Suite 103
Harrisburg, PA 17112
717-920-2220
FAX 717-920-2370
Marker 0akpc-law.corn
PRABHA JINDAL, IN THE COURT OF COMMON PLEAS
Administratrix of the ESTATE OF CUMBERLAND COUNTY,
RAMESH K. JINDAL, Deceased, PENNSYLVANIA
Plaintiff
V. No.
KRISTEN A. CARPINELLO and CIVIL ACTION - LAW
MICHAEL V. CARPINELLO,
Defendants
VERIFICATION
I, Prabha Jindal, M.D., Administratrix of the Estate of Ramesh K. Jindal, Deceased,
verify that I am the Plaintiff in the foregoing action and I, Prabha Jindal, M.D., verify that the
facts set forth in the foregoing Plaintiff's Petition for Approval of Settlement and Distribution of
Funds are true and correct to the best of my knowledge, information and belief. I acknowledge
that the Petition requests distribution of $38,329.05 to Kelly Parker & Cohen, LLP, for attorney's
fees. I approve, in all respects, this proposed distribution and approve of, and consent to, the
foregoing Petition in its entirety. I respectfully request this Honorable Court approve the
foregoing Petition.
I understand that I am subject to the penalties of 18 Pa.C.S.A. § 4904 relating to unsworn
falsifications to authorities for any false statement made in the foregoing Verification.
Dated: 1 I211-7w, ? I _c ?
Prabha Jind mlms ra rix of the
Estate of Ramesh K. Jindal, Deceased
Dated: I L? 1 1 ?1- c
Prabha Jin al
CERTIFICATE OF SERVICE
On this 13th day of July, 2011, I, Dana Y. Thompson, a paralegal with the law firm of
Kelly, Parker & Cohen LLP, hereby certify that I have, this day, served a true and correct copy
of the foregoing PETITION FOR APPROVAL OF SETTLEMENT AND DISTRIBUTION
OF FUNDS upon the person(s) and at the address(es) below named by United States First Class
Mail, postage prepaid in Harrisburg, PA:
Kristen and Michael Carpinello
3806 Carriage House Drive
Camp Hill, PA 17011
Don Bottini
Erie Insurance Group
P.O. Box 2013
Mechanicsburg, PA 17055
PRABHA JINDAL, IN THE COURT OF COMMON PLEAS
Administratrix of the ESTATE OF CUMBERLAND COUNTY,
RAMESH K. JINDAL, Deceased, PENNSYLVANIA
Plaintiff C
V. No.
KRISTEN A. CARPINELLO and CIVIL ACTION - LAW
MICHAEL V. CARPINELLO,
Defendants
ORDER
AND NOW, this 2,0 day of 2011, upon consideration of the
attached Petition for Approval of Settlement of wrongful death and survival action:
It is ORDERED that settlement of the above-captioned action for the gross sum of
$115,000 is approved, to be allocated ninety percent (90%) to the wrongful death action and ten
percent (10%) to the survival action.
It is also ORDERED that the settlement proceeds shall be distributed as follows:
TOTAL RECEIPTS: $115,000.00
SURVIVAL ACTION ($11,500.00)
To Kelly Parker & Cohen, LLP $ 3,832.95
Ten percent (10%) of counsel fees
To Estate of Ramesh Jindal, c/o Prabha Jindal, $ 7,667.05
Executrix of the Estate of Ramesh Jindal
C N-,
WRONGFUL DEATH ($103,500.00) _
---a r ,
r
To Kelly Parker & Cohen, LLP $34,496.55 F. __ q'
t:s
Ninety percent (90%) of counsel fees ` -1c;
To Prabha Jindal $49,501.74 ca ?
C-n
To Gaurav Jindal $ 6,500.57
To Parul Kakaria $ 6,500.57
To Shivam Narasimhan $ 6,500.57
IT IS FURTHER ORDERED upon receipt of the Survival Action proceeds, the personal
representative of the Estate of Ramesh K. Jindal shall promptly file a supplemental inventory and
inheritance tax return with the Register of Wills of Cumberland County.
DISTRIBUTION:;
? Kristen and Michael Carpinello, 3806 Carriage House Drive, Camp Hill, PA 17011
Don Bottini, Erie Insurance Group, P.O. Box 2013, Mechanicsburg, PA 17055.
Anthony W. Parker, Esquire, Kelly, Parker & Cohen LLP, 5425 Jonestown Road, Suite 103,
Harrisburg- PA 17112 -
n is M? cl
?P
,003
2
BY THE COURT: