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Home My WebLink About04-4194William P. Douglas, Esq. Supreme Court LD. #37926 Douglas Law Office 27 W. High St. Carlisle, PA 17013 Telephone (717) 243-1790 Jasmine Alsina and Carlos Alsina, Jr., individually and on behalf of all those entitled to share in the proceeds for the wrongful death of Carlos Alsina, Sr.; and Jasmine, in her capacity as administratrlx of the estate of Carlos Alsina, Sr., deceased PETITIONERS VS Werner Enterprises, Inc. RESPONDENT In The Court of Common Pleas of Cumberland County, Pennsylvania 04- q]~ CivilTerm Petition for Approval of Compromise Settlement and Distribution Praecipe to Issue a Writ of Summons Dear Mr. Long: Please issue a writ of summons against the defendant, Werner Enterprises, Inc. date: August 24, 2004 William P. Dou~s, Esq. Attorney for l~aintiff Commonwealth of Pennsylvania County of Cumberland Jasmine Alsina and Carlos Alsina, Jr., individually and on behalf of all those entitled to share in the proceeds for the wrongful death of Carlos Alsina, Sr.; and Jasmine, in her capacity as administratfix of the estate of Carlos Alsina, Sr., deceased PETITIONERS In The Court of Common Pleas of Cumberland County, Pennsylvania 04 - L~t~ Civil Te~ui VS Werner Enterprises, Inc. RESPONDENT Petition for Approval of Compromise Settlement and Distribution Writ of Summons To: Werner Enterprises, Inc. do John T. Pion, Esq. Dickie, McCamey & Chilcote, P.C. Two PPG Place, Suite 400 Pittsburgh, PA 15222-5402 You are hereby notified that Jasmine Alsina and Carlos Alsina, Jr., individually and on behalf of ail those entitled to share in the proceeds for the wrongful death of Carlos Alsina, Sr.; and Jasmine, in her capacity as admirfistratrix of the estate of Carlos Alsina, Sr., deceased have brought an action against you. date: ~,ttbt~ 1~, 20OM' William P. Douglas, Esq. Douglas Law Office 27 W. High St. Carlisle, PA 17013-0261 717-243-1790 Attorney for Plaintiff William P. Douglas, Esq. Supreme Ct. ID # 37926 Douglas Law Office 27W. High St. PO.B. 261 Carlisle, PA 1701343261 Telephone 717-243 - 1790 individually and on behalf of all Cumberland County, Pennsylvania those entitled to share in the proceeds for the wrongful death of Carlos Alsina, Sr.; and Jasmine, in her capadty as administratrix of the estate of Carlos Alsina, Sr., deceased 04- '-h'~iq C/vii Te~:-. PETITIONERS VS Petition for Approval of Compromise Settlement and Distribution Werner Enterprises, Inc. RESPONDENT Petition for Approval of Compromise Settlement and Distribution TO THE HONORABLE, THE JUDGES OF SAID COURT: 1. The petitioner, Jasmine Alsina, individually and in her capacity as Administratrix of the Estate of Carlos Asina, Sr., deceased, is an adult individual residing at 3593 Bainbridge Avenue, Apartment 2B, Bronx, New York, 10467 2. The petitioner, Carlos Alsina, Jr., is an adult individual residing at RR7 Box 7163, San Juan, Puerto Rico, 0092. 3. The respondent, Werner Enterprises, Inc., is a corporation doing business in the Commonwealth of Pennsylvania and is represented by John T. Pion, Esq., of Dickie, McCamey & Chilcote, P.C., Two PPG Place, Suite 400, Pittsburgh, Pennsylvania, 15222-5402. 4. Carlos Alsina, Sr., died intestate and was survived by his two adult children, Jasmine Alsina and Carlos Alsina, Jr. who are. the sole surviving heirs of Carlos Alsina, Sr. 5. Jasmine Alsina, was appointed administratrix of the Estate of Carlos Alsina, Jr., by Earl S. Keim, II, Register of Wills in and for Westmoreland County, Pennsylvania. 6. Jasmine Alsina and Carlos Alsina, Jr. are the natural children of Carlos Alsina, Sr., deceased. 7. On or about April 5, 2003, while traveling on the Pennsylvania Turnpike Carlos Alsina, Sr. was killed in a motor vehicle accident involving the respondent's vehicle. 8. Carlos Alsina, Sr., died intestate. 9. Costs advanced by Coale Cooley Leitz, P.C., in preparation of this matter, are in the amount of $4,314.68. 10. To settle any and all claims, the petitioners, in their individual capacity, are agreeable to accept a total of Three Hundred Thousand Dollars ($300,000.00) in full and final settlement for the wrongful death of their father Carlos Alsina, Sr. 11. To settle any and all claims, the petitioner, in her capacity as Administratrix of the aforementioned estate, is agreeable to accepting a total of Seven Hundred Thousand Dollars ($700,000.00) in full and final settlement for the death of her father Carlos Alsina, Sr. 12. The petitioner has agreed to pay a contingent fee of 33-1/3% of any recovery and advanced costs in this matter to the law firm of Coale Cooley Leitz, P.C. 13. The petitioners requests that the following distribution be made for the death of their father Carlos Alsina, Sr.: Jasmine Alsina, individually and Carlos Alsina, Jr., individually $198,705.60 Jasmine Alsina, in her capacity as Adrninistratrix of the Estate of Carlos Alsina, Sr., deceased $463,646.39 Coale Cooley Lietz, P.C. Coale Cooley Leitz, P.C. (advance costs) $333,333.33 $4,314.68 14. William P. Douglas, Esq., on behalf of the petitioners, has spoken with J. Paul Diebert of The Pennsylvania Department of Rew:nue, and Mr. Diebert has indicated that the Department is agreeable to the aforesaid allocation. WHEREFORE, it is prayed that the aforesaid settlement and the proposed distribution, be approved. Douglas Law Office August 24, 2004 By William P. Douglas, Esq.?~ ~ Attorney for the Petitiont~r~ Affidavit I HEREBY SWEAR OR AFFIRM THAT THE FOI~iEGOING IS TRUE AND CORRECT TO THE BEST OF MY KNOWLEDGE AND/OR INFORMATION AND BELIEF. THIS IS MADE SUBJECT TO THE PENALTIES OF 18 PA.C.S.§ 4904 RELATING TO UNSWORN FALSIFICATION TO AUTHORITIES. August 24, 2004 · ~ougm~Esq. ALfG 2 4 2004 individually and on behalf of all Cumberland County, Pennsylvania those entitled to share in the proceeds for the wrongful death of Carlos Als~na, Sr.; and Jasmine, ~n her capacity as administratrix of the estate of Carlos Alsina, Sr., deceased PETITIONERS 04 - ql cl~ Civil VS Petition for Approval of Compromise Settlement and Distribution ~ Wemer Enterprises, Inc. i RESPONDENT Order of Court AND NOW, this 24th day of August, 2004, in consideration of the attached petition, the proposed settlement is approved, and the following distribution is directed: Jasmine Alsina, individually and Carlos Alsina, Jr., individually Jasmine Alsina, in her capacity as Administratrix of the Estate of Carlos Alsina, Sr., deceased $198,705.60 $463,646.39 Coale Cooley Lietz, P.C. Coale Cooley Leitz, P.C. (advance costs) $333,333.33 $4,314.68 DOUGLAS LAW OFFICE 27 W. HIGH ST. lOB 261 CARLISLE PA 17013 TELEPHONE 71%243-1790 William P. Douglas, Esq. Supreme CL ID # 37926 individually and on behalf of all those entitled to share in the proceeds for the wrongful death of Carlos Alsina, Sr.; and Jasmine, in her capacity as administratrix of the estate of Carlos Alsina, Sr., deceased PETITIONERS VS Cumberland County, Pennsylvania 04 - q 'Ici0c Civil Term i Werner Enterprises, Inc. Petition for Approval of Compromise ' Settlement and Distribution i RESPONDENT Praecipe to Settle and Discontinue Dear Mr. Long, Please mark the above captioned matter settled and discontinued. August 26, 2004 William P. Doughs, Esq. Attorney for Pk~ntiffs