HomeMy WebLinkAbout03-0945SHOLLENBERGER & JANUZZl, LLP
1820 Linglestown Road
P.O. Box 60545
Harrisburg, Pennsylvania 17106-0545
Telephone Number: (717) 234-3700
Fax Number: (717) 234-8212
Attorneys for Plaintiff
IN RE: THOMAS MILES,
a minor,
IN THE COURT OF COMMON PLEAS
CUMBERLAND COUNTY,
PENNSYLVANIA
NO.
ORPHANS' COURT DIVISION
AND NOW come the Petitioner, THOMAS MILES, by and through his parent and
natural guardian, JOHN MILES, by and through their attorneys, SHOLLENBERGER &
JANUZZI, LLP, and respectfully represent the following:
1. Petitioner, Thomas Miles, is a minor, having been born on August 3, 1993,
and resides with his parents, John Miles and Julie Miles, at One North Pin Oak Drive,
Boiling Springs, Cumberland County, Pennsylvania 17007.
2. Petitioner John Miles is the father and natural guardian of Thomas Miles, and
is an adult individual residing at the above stated address.
3. The Respondent herein is Rain Drop Products, LLC, 211 Baney Road, P.O.
Box 781, Ashland, Ohio 44805, c/o Cincinnati Insurance Companies, P.O. Box 192,
Hughesville, Pennsylvania 17737. The Respondent is the manufacturer of the device
involved in the incident hereinafter described.
4. On or about June 28, 2002, Petitioner Thomas Miles was injured when he
was struck on the head from a falling metal bucket, known as a "Tumble Bucket" while
playing at the Hampden Township swimming pool.
5. The incident resulted in the Petitioner Thomas Miles suffering a laceration to
the top of his head.
6. As a result of the above referenced incident and the injuries sustained
therein, Petitioner Thomas Miles incurred medical bills totaling $1,880.00. Of this
amount, all but $45.00 was paid by private health insurance. No lien has been asserted
with regard to the medical bills.
7. The Petitioner last received medical treatment on July 8, 2002, at which time
his family physician at Carlisle Pediatrics indicated he had a well-healed laceration and
removed the sutures from his head. Attached hereto as Exhibit "A" is a copy of Carlisle
Pediatrics' office note.
8. The Respondent, while not admitting liability, has offered to settle this claim
for $2,500.00.
9. The Petitioners believe this offer of settlement is fair and reasonable.
10. The Petitioner, Thomas Miles, by John Miles, his parent and natural
guardian, has retained the services of the law firm of SHOLLENBERGER & JANUZZI,
LLP to represent him and has agreed to pay a twenty-five percent (25%) contingent fee
to said attorneys. A copy of the contingent fee agreement between the Petitioner and
his counsel is attached hereto, incorporated by reference herein and marked as Exhibit
Ilall"
11. The Petitioner has further agreed to pay out of his share of the recovery any
and all costs incurred or advanced on his behalf. The amount of the costs that were
incurred and advanced on Petitioner's behalf to date in this matter total $124.19. An
itemization of all costs is attached hereto, incorporated herein and marked as Exhibit
IICII'
12.
order to distribute the proceeds as follows:
Shollenberger & Januzzi, LLP
(reimbursement of costs advanced)
Shollenberger & Januzzi, LLP
(attorney's fee - Twenty Five [25%] Percent
The Petitioners request the court approve the compromised settlement in
$ 124.19
$ 625.00
Thomas Miles, by John Miles, his
his parent and natural guardian $ 1,750.81
13. The Petitioner, Thomas Miles, by John Miles, his parent and natural
guardian, requests that the funds to be distributed for the benefit of Thomas Miles be
deposited in one or more savings accounts in the name of Thomas Miles in banks,
building and loan associations or savings and loan associations, deposits in which are
insured by a federal governmental agency, provided that the amount deposited in any
one savings institution should not exceed the amount to which accounts are thus
insured.
14. The Petitioner, Thomas Miles, by John Miles, his parent and natural
guardian, requests that upon approval of the proposed compromised settlement and
receipt of the proceeds thereof, they be authorized to execute a good and sufficient
release of any further liability and to discontinue the above action against the
Respondent named herein.
15. The Petitioner's counsel continues to represent the Petitioners for the claims
against one or more potentially liable joint tortfeasors, and reserves the right to pursue
a separate action against one or more additional Defendants.
WHEREFORE, Thomas Miles, by John Miles, his parent and natural guardian,
requests this Honorable Court to approve the Compromise Settlement and Distribution
of Proceeds.
Respectfully submitted,
SHOLLENBERGER & JANUZZI, LLP
K~"rl J~'. Januzzi, Esquire
Attorney I.D. #65575
9yrs. Date:
Interval History
School q'~'~- t..~
Illness/injury/surgery
Health maintenance
Dentist
Vision C3
Hearing El
Concerns
/fl w: FT(,.~ B.P..~0~)(~ Allergies
Psychosocial PE. / Normal ~' Abnormal []
Family relationships
Peer relationships
Activities / interests
~5o~c<.r.
Mood
Appetite / Sleep
Television
Gen. App. Q'"f'eeth
Head . Q'Neck I~"Tanner stage
Eyes Q'Chest I:~Ext. la"
Ears
Nose ~r r~ea~l ~" ,..qKln ,_l-
Throat C~Abdomen C}--Back
..............Comments ...................................
~lmpression
Treatment
POWER OF ATTORNEY
AND
CONTINGENT FEE AGREEMENT
I, Thomas Miles, by his parent and natural guardian, John Miles, do hereby
retain the offices of Shollenberger & Januzzi, LLP of Harrisburg, Pennsylvania, as our
attorneys to negotiate for us a settlement or to institute for us in our name any legal
proceedings or actions that in their judgment are necessary in connection with our claim
for damages sustained on June 28, 2002 against Hampden Township Pool and any
other person, firm, corporation or entity who may be responsible for my claim, and/or to
obtain an amicable settlement.
We hereby give to our attorneys, a Power of Attorney to execute all documents
connected with the claim for the prosecution of which the attorney is retained, including
pleadings, contracts, commercial papers, settlement agreements, compromises and
releases, verifications, dismissals, orders, settlement checks and all other documents
that we could properly execute in connection with this lawsuit.
We agree not to settle or adjust the above claim or any proceedings arising from
said claim nor to discuss said claim with any other persons.
We agree to pay attorneys' fees from the total amount recovered from any
source on account of our bodily injury claim on the following basis:
Settlement of third party tort 25% of total
claim prior to filing of legal sum recovered
action.
Settlement of third party tort
claim on or after filing of
action.
33-1/3% of total sum
recovered
Costs: Costs are to be paid from my (client's) share of the total amount
recovered and include, but are not limited to: photocopies; fax charges; postage;
notaries; long distance telephone charges; mileage for attorneys and staff; investigation
charges; photographs; court costs; WEST LAW research charges; medical records
costs; deposition costs; expert witness fees; stenographer costs; and, video deposition
fees.
In the event that no recovery is obtained on this claim, the attorneys will make no
charges for their time or services. However, any costs or expenses which the attorneys
SHOLLE. NBERGER & JANUZZI, LLP
1820 LINGLESTO~N ROAD · P.O. BOX 60545 · HARRISBURG, PA 17106-0545
('/17) 234-3700 · FAX C'/I'~ 234-8212
may have advanced on behalf of the claim must be paid by me upon request by said
attorneys. In the event that no recovery is obtained on this claim, my attorneys agree
that they will only request repayment of costs, if I/we fail or refuse to follow their advice
regarding settlement of the claim.
As one possible settlement option, we authorize the said attorneys to explore the
possibility of a structured settlement through the use of deferred periodic payments.
We agree that if our claim is settled through such structure, the attorneys' fees may be
paid directly to said attorneys from the insurance company, either in one lump sum
payment at settlement, or, at the sole option of said attorneys and/or insurance
company, deferred into future payments. However, in any event, said attorneys' fees
shall be calculated in the percentage as set forth above based upon the cost of the
structured settlement or present value thereof in accordance with applicable law.
All medical bills for which I am legally responsible incurred as a result of the
injuries shall be paid from my share of the recovery, unless otherwise paid by
insurance.
The Contingent Fee Agreement applies to all proceedings up to and including
verdict or decision at trial. If, in the discretion of the attorneys, post-trial proceedings,
including appeals, are warranted, they will not be covered by this Contingent Fee
Agreement and a new fee agreement will be required by said attorneys.
IN WlT,~NESS WHEREOF, we have hereunto set my hand and seal this.
day of, / ~(D~ ,2001. ' '
(SEAL)t~..~/~j~//~'~ - ~""~ ' (SEAL)
(SEAL) ~':/" I/ (SEAL)
AND NOW, this l~ ~'' dayof
,2001,the above
Contingent Fee Agreement and Power of Attorney has been read, approved and
understood by me and the receipt of a copy thereof acknowledged. The terms set forth
(SEAL) . (SEAL)
are a~z~,,~
·
SHOLLEN'BERGER & JANUZZI, LIP
1820 LINGLESTOWN ROAD · P.O. BOX 60545 · HARRISBURG, PA 17106-0545
(717) 234-3700 · FAX (717) 234-8212
Oct 27/2003 Page 1
Shollenberger & Januzzi, LLP
Client Costs Journal
To Oct 27/2003
Date Paid To Source Matter Client Name
Entry# Explanation
Ref# G/L Acct Amount
Oct 31/2002 Expense Recovery CER 021503 Miles
58422 Postage - Oct
Oct 31~2i002 Expensei Reicove~y CER 021503 MiieSi
58563 PhOtOCOPies , Oct
Total for Oct 31/2002 : 0.82
Nov 7/2002 Carlisle Pediatric Associates GB 021503 Miles
58596 Medical Records Thomas Miles
Total for Nov 7/2002 :
17.33
CER
Nov 30~2002 E~ense RecOvery 021503
60070 postage ,NOv
Nov 30/2002 Expense Recovery CER 021503
60375 Photocopies - Nov
Total for Nov 30/2002 : 18.55
Dec 3/2002 ChartONE; Inc GB 021503 Miles
59080 Medical RecOrds . inv# 4020t02i~201552 Holy spirit H
Miles
Miles
31.96
CER 021503 Miles
0.37
CER 021503 Miles
CER 021503 Miles
4.06
CER O215O3
CER 021503 Miles
Miles
Miles
9.05
CER 021503
0.90
CER 021503
0.60
CER 021503
CER 021503
Miles
0.67
CER 021503 Miles
CER 021503 Miles
Total for Dec 3/2002
Dec 31/2002 Expense Recovery
60593 Postage - Dec
Total for Dec 31/2002
Feb 28/2003 Expense ReCovery
i 62797 Postage , Feb
Feb 28/2003 Expense Recovery
62932 Photocopies - Feb
Total for Feb 28/2003
Apr 30/2003iiiiExpenseRecovery
64852 Postage , April
Apr 30/2003 Expense Recovery
65196 Photocopies - April
Total for Apr 30/2003
JUn 30/2003 Expense ReCovery
67502 photocopies -june
Total for Jun 30/2003
Jul 15/2003 Expense Recovery
67326 Postage - June
Total for Jul 15/2003
Jui 31/2003 Expense Recovery
68176 iiP0stage JUlY
Jul 31/2003 Expense Recovery
68571 Photocopies July
Total for Jul 31/2003
Aug 31~2003 Expense RecOVery =
69460 postage ,Aug
Aug 31/2003 Expense Recovery
69655 Photocopies - Aug
Aug i 3ili/i2003 !i iExpense i Recovery
69927 Telephone ' Aug
Total for Aug 31/2003
Sep 30/2003 Expense Recovery
71270 Telephone Sept
CER 021503 Miles
18.88
CER 021503 Miles
Miles
Total for Sep 30/2003 : 6.00
OCti i27/2003 Cumberland county Clerk of theiOrphan'iGB 021503
71415 Fiting Fees 'iProth°nOtary ~ ii ThomasiMilesii
Total for Oct 27/2003 ~ 21.00
00609 5556 - Postage R 0.37
00611 5543- photOcopi 0~45
5464 5407 - Medical R 17.33
00621 5556 - pOStage R 15.85
00625 5543 Photocopi 2.70
5539 5407 - Medical R 31.96
00627 5556 - Postage R 0.37
00651 5556 ~ Postage R 1.06
00652 5543 - Photocopi 3.00
00669 5556 . postage R 3.50
00671 5543 - Photocopi 5.55
00682 5543 i PhotOCOpi 0,90
00681 5556 - Postage R 0.60
00694
00698
5556 ? postage R 0.37
5543 - Photocopi 0.30
00704
00705
00707
00722
5556
5543
':POstage R 4.38
i
- Photocopi 10.50
5861' Telephone 4100
5861 - Telephone 6.00
6855 5150 ~ COu~t COS 21 00
G/L Account
5010 - CLIENT DISB. EXPENS
5150 - Court Costs
5407 - Medical Records
5543 - Photocopies Recover
5556 - Postage Recovery
5861 - Telephone Recovery
Total:
*** Client Costs Journal - G/L Account Summary ***
Debit Credit
130.19
21.00
49.29
23.40
26.50
10.00
130.19 130.19
REPORT SELECTIONS
Report:
Layout Template:
Requested by:
Finished:
Date Range:
Matters:
G/L Account:
Ref#:
G/L Summary Only:
Client Costs Journal
Ail
csholley
Monday, October 27, 2003 at 02:52:23 PM
To Oct 27/2003
021503
All G/L Accounts Include Exp. Recoveries:
All Checks Include AP Entries:
No
Yes
Yes
Include General Check Allocations: Yes
SHOLLENBERGER & JANUZZl, LLP
1820 Linglestown Road
P.O. Box 60545
Harrisburg, Pennsylvania 17106-0545
Telephone Number: (717) 234-3700
Fax Number: (717) 234-8212
Attorneys for Plaintiff
IN RE: THOMAS MILES,
a minor,
IN THE COURT OF COMMON PLEAS
CUMBERLAND COUNTY,
PENNSYLVANIA
NO.
ORPHANS' COURT DIVISION
AND NOW this --- day of 2003 I hereby certify that I have
served a true and correct copy of the Petition to Approve Compromise Settlement by
United States mail, postage prepaid, addressed to:
Greg Cassimatis, Esquire
4999 Louise Drive, Suite 103
Mechanicsburg, PA 17055
Kar~Januzzi, Esquire
SHOLLENBERGER & JANUZZl, LLP
1820 Linglestown Road
P.O. Box 60545
Harrisburg, Pennsylvania 17106-0545
Telephone Number: (717) 234-3700
Fax Number: (717) 234-8212
Attorneys for Plaintiff
IN RE: THOMAS MILES,
a minor,
1 4 t003~
IN THE COURT OF COMMON PLEAS
CUMBERLAND COUNTY,
PENNSYLVANIA
ORPHANS' COURT DIVISION
AND NOW this ,'¢''~ day of z.,e~.......t.~,200_, upon
consideration of the within Petition, Plaintiffs request for approval of a Compromise
Settlement in the above captioned matter is approved. Plaintiffs contingent fee
agreement with counsel is approved and Plaintiffs counsel shall collect fees, costs and
expenses'set forth in Plaintiffs Petition and the exhibits attached thereto from the
proceeds of this settlement. The balance of the proceeds shall be deposited in the
name of Thomas Miles in more savings accounts in banks, building and loan
associations or savings and loan associations, deposits of which are insured by a
Federal governmental agency provided that the amount deposited in any one savings
institution shall not exceed the amount to which accounts are thus insured.
No withdrawal shall be made from any such account until Thomas Miles shall
attain his majority, except as authorized by further Order of this Court. Proof of the
deposit, along with a signature card for each account, shall be promptly filed of record
with the Court.
SHOLLENBERGER & JANUZZl, LLP
1820 Linglestown Road
P.O. Box 60545
Harrisburg, Pennsylvania 17106-0545
Telephone Number: (717) 234-3700
Fax Number: (717) 234-8212
Attorneys for Plaintiff
IN RE: THOMAS MILES,
a minor,
IN THE COURT OF
CUMBERLAND COU .~.,~,
PENNSYLVANIA
ORPHANS' COURT DIVISION
AND NOW come the Petitioner, THOMAS MILES, by and through his parent and
natural guardian, JOHN MILES, by and through their attorneys, SHOLLENBERGER &
JANUZZI, LLP, and respectfully represent the following:
1. Petitioner, Thomas Miles, is a minor, having been born on August 3, 1993,
and resides with his parents, John Miles and Julie Miles, at One North Pin Oak Drive,
Boiling Springs, Cumberland County, Pennsylvania 17007.
2. Petitioner John Miles is the father and natural guardian of Thomas Miles, and
is an adult individual residing at the above stated address.
3. The Respondent herein is Hampden Township, 230 South Sporting Hill Road,
Mechanicsburg, PA 17055, c/o Fireman's Fund Insurance Companies, 9690 Deereco
Road, Timonium, Maryland 21093.
4. On or about June 28, 2002, Petitioner Thomas Miles was injured when he
was struck on the head from a falling metal bucket, known as a "Tumble Bucket" while
playing at the Hampden Township swimming pool.
5. The incident resulted in the Petitioner Thomas Miles suffering a laceration to
the top of his head.
6. As a result of the above referenced incident and the injuries sustained
therein, Petitioner Thomas Miles incurred medical bills totaling $1,880.00. Of this
amount, all but $45.00 was paid by private health insurance. No lien has been asserted
with regard to the medical bills.
7. The Petitioner last received medical treatment on July 8, 2002, at which time
his family physician at Carlisle Pediatrics indicated he had a well-healed laceration and
removed the sutures from his head. Attached hereto as Exhibit "A" is a copy of Carlisle
Pediatrics' office note.
8. The Respondent, while not admitting liability, has offered to settle this claim
for $3,000.00.
9. The Petitioners believe this offer of settlement is fair and reasonable.
10. The Petitioner, Thomas Miles, by John Miles, his parent and natural
guardian, has retained the services of the law firm of SHOLLENBERGER & JANUZZI,
LLP to represent him and has agreed to pay a twenty-five percent (25%) contingent fee
to said attorneys. A copy of the contingent fee agreement between the Petitioner and
his counsel is attached hereto, incorporated by reference herein and marked as Exhibit
11. The Petitioner has further agreed to pay out of his share of the recovery any
and all costs incurred or advanced on his behalf. The amount of the costs that were
incurred and advanced on Petitioner's behalf to date in this matter total $30.55. An
itemization of all costs is attached hereto, incorporated herein and marked as Exhibit
12. The Petitioners request the court approve the compromised settlement in
order to distribute the proceeds as follows:
Shollenberger & Januzzi, LLP
(reimbursement of costs advanced) $ 30.55
Shollenberger & Januzzi, LLP
(attorney's fee - Twenty Five [25%] Percent $ 750.00
Thomas Miles, by John Miles, his
his parent and natural guardian $ 2,219.45
13. The Petitioner, Thomas Miles, by John Miles, his parent and natural
guardian, requests that the funds to be distributed for the benefit of Thomas Miles be
deposited in one or more savings accounts in the name of Thomas Miles in banks,
building and loan associations or savings and loan associations, deposits in which are
insured by a federal governmental agency, provided that the amount deposited in any
one savings institution should not exceed the amount to which accounts are thus
insured.
14. The Petitioner, Thomas Miles, by John Miles, his parent and natural
guardian, requests that upon approval of the proposed compromised settlement and
receipt of the proceeds thereof, they be authorized to execute a good and sufficient
release of any further liability and to discontinue the above action against the
Respondent named herein.
15. The Petitioner, Thomas Miles, by John Miles, his parent and natural
guardian, previously reached a settlement with the manufacturer of the device which
caused the injury. A copy of the Court's Order approving the compromised settlement
is attached hereto as Exhibit "D."
WHEREFORE, Thomas Miles, by John Miles, his parent and natural guardian,
requests this Honorable Court to approve the Compromise Settlement and Distribution
of Proceeds.
Respectfully submitted,
SHOLLE~R~ER & JANUZZI, LLP
'111.1/
By: .
Attorn~y I.D. #65575
I
Interval History
School
Illness/injury/surgery
Health maintenance
Dentist Gl--,
Vision E!
Hearing El
Concerns
Psychosocial
Family relationships
Peer relationships
Activities / interests
,5o~:c~'. ~-'~'~_,,,o,
Mood
Appetite / Sleep
Television
PE. / Normal ,/' Abnormal ·
Gen. App. Gi"Ceeth I~'G. U.
Head . Q'Neck C~q'anner stage
Eyes G~7_,hest Gl.l~xt.
Ears t~"Lunns I~"Neuro
~qose t.zi"r~ eal t
Throat U~Abdomen E~Back
...................................
impression
Treatment
Follow-u
POWER OF ATTORNEY
AND
CONTINGENT FEE AGREEMENT
I, Thomas Miles, by his parent and natural guardian, John Miles, do hereby
retain the offices of Shollenberger & Januzzi, LLP of Harrisburg, Pennsylvania, as our
attorneys to negotiate for us a settlement or to institute for us in our name any legal
proceedings or actions that in their judgment are necessary in connection with our claim
for damages sustained on June 28, 2002 against Hampden Township Pool and any
other person, firm, corporation or entity who may be responsible for my claim, and/or to
obtain an amicable settlement.
We hereby give to our attorneys, a Power of Attorney to execute all documents
connected with the claim for the prosecution of which the attorney is retained, including
pleadings, contracts, commercial papers, settlement agreements, compromises and
releases, verifications, dismissals, orders, settlement checks and all other documents
that we could properly execute in connection with this lawsuit.
We agree not to settle or adjust the above claim or any proceedings arising from
said claim nor to discuss said claim with any other persons.
We agree to pay attorneys' fees from the total amount recovered from any
source on account of our bodily injury claim on the following basis:
Settlement of third party tort 25% of total
claim prior to filing of legal sum recovered
action.
Settlement of third party tort
claim on or after filing of
action.
33-1/3% of total sum
recovered
Costs: Costs are to be paid from my (client's) share of the total amount
recovered and include, but are not limited to: photocopies; fax charges; postage;
notaries; long distance telephone charges; mileage for attorneys and staff; investigation
charges; photographs; court costs; WEST LAW research charges; medical records
costs; deposition costs; expert witness fees; stenographer costs; and, video deposition
fees.
In the event that no recovery is obtained on this claim, the attorneys will make no
charges for their time or services. However, any costs or expenses which the attorneys
SHOLLENBERGER & JANUZZI, LLp
1820 L1NGLESTOWN ROAD · P.O. BOX 60545 · HARR/SBURG, PA 17106-0545
(717) 234-3700 · FAX (717) 234-8212
may have advanced on behalf of the claim must be paid by me upon request by said
attorneys. In the event that no recovery is obtained on this claim, my attorneys agree
that they will only request repayment of costs, if I/we fail or refuse to follow their advice
regarding settlement of the claim.
As one possible settlement option, we authorize the said attorneys to explore the
possibility of a structured settlement through the use of deferred periodic payments.
We agree that if our claim is settled through such structure, the attorneys' fees may be
paid directly to said attorneys from the insurance company, either in one lump sum
payment at settlement, or, at the sole option of said attorneys and/or insurance
company, deferred into future payments. However, in any event, said attorneys' fees
shall be calculated in the percentage as set forth above based upon the cost of the
structured settlement or present value thereof in accordance with applicable law.
All medical bills for Which I am legally responsible incurred as a result of the
injuries shall be paid from my share of the recovery, unless otherwise paid by
insurance.
The Contingent Fee Agreement applies to all proceedings up to and including
verdict or decision at trial. If, in the discretion of the attorneys, post-trial proceedings,
including appeals, are warranted, they will not be covered by this Contingent Fee
Agreement and a new fee agreement will be required by said attorneys.
IN WlT,~NESS WHEREOF, we have hereunto set my hand and seal this
day of, / ¢~:~ , 2001.
(SEAL, ~" ~'~ i~~~'/'/¢/ (SEAL)
(SEAL) ~'"" '- ' (SEAL)
AND NOW, this l~ ~'' day of (~¢~
,2001, the above
Contingent Fee Agreement and Power of Attorney has been read,, approved and
understood by me and the receipt of a copy thereof acknowledged. The terms set forth
(SEAL) ~._,~/-/~// (SEAL)
(SEAL) o (SEAL)
are aT/~,~
·
SHOLLENBERGER & JANUZZI, LLP
1820 LINGLESTOWN ROAD · P.O. BOX 60545 · HARRISBURG, PA 17106-0:~45
~17) 234-3700 · FAX (717) 234-8212
Feb 24/2004 Page 1
Shollenberger & Januzzi, LLP
Client Ledger
ALL DATES
Date Received From/Paid To Che# General
Bld Trust
Entry# Explanation Rcpt# Rcpts Disbs Fees Inv# Acc Rcpts Disbs Balanc~
1278 Miles, Thomas
021503 Date of accident - 9/17/02 ( fee 25%, 33 1/3%, Father - John Thomas) 2 - Karl
Oct 31/2002 EXpenSe Recovery 00609 0!37 i813
58422 Postage - oct
oct 31/2002 Expense Recovery 00611 0.45 1813
58563 Photocopies Oct
Nov 7/2002 Carlisle pediatric ASsociates
5464 i7~33 1813
58596 Medical Records ~ Thomas MileS
Nov 30/2002 Expense Recovery 00621 15.85 1813
60070 Postage - Nov
NOV 30/2002 ExpenSe RecoVery 00625
60375 PhOtOcOpies _ N~V
Dec 3/2002 ChartONE, Inc 5539 31.96 1813
59080 Medical Records inv#
402010-1-201552 Holy Spirit Hosp
Dec 31/2002 EXPense ReCovery 00627 0.37 1813
60593 postage- ~%
Feb 28/2003 Expense Recovery 00651 1.06 1813
62797 Postage Feb
Feb 28/2003 EXpence Recovery 00652 3100 18i3
62932 Ph~t0C0Pi~s ' Feb
Apr 30/2003 Expense Recovery 00669 3.50 1813
64852 Postage April
Apr 30/2003 Expense Recovery 00671 5:55 181]
Jun 30/2003 Expense Recovery 00682 0.90 1813
67502 Photocopies - June
JUl 15/2003 ExpenSe Recovery 00681
67326 postage- June
Jul 31/2003 Expense Recovery 00694
68176 Postage July
Jul 31/2003 Expense Recovery 00698 0.30 18i3
68571 PhOtoCopies - July ::
Aug 31/2003 Expense Recovery 00704 4.38 1813
69460 Postage - Aug
Aug 31/2003 EXpense Recovery 00705 10.50 1813
69655 PhotOC0pies , Aug
Aug 31/2003 Expense Recovery 00707 4100 1813
69927 Telephone - Aug
sep 30/2003 Expense ReCOVery 00722
71270 Telephone - sept
Oct 27/2003 Cumberland County Clerk of the Orphan's 6855 21.00 1813
71415 Filing Fees - Prothonotary - Thomas
Miles
OCt 31/2003 Expense Recovery 00732 1285 1813
: 72150 POstage OCt
Nov 30/2003 Expense Recovery 00739 4.15 1813
73045 Postage - Nov
Nov 30/2003 EXpense ReCovery 00741 2~50 1813
73188 TelePhOne- Oct/NOV
Nov 30/2003 Expense Recovery 00742 4.05 1813
73401 Photocopies - Nov
jan 14/2004 Cincinnati Insurance COmpanies 00589
1813 1 2500.00 2500 00
74572 Settlement ' ck# 021659130 1/12;
Jan 27/2004 Fees To Lawyer 2 625.00 1813
74811 Fee - 25% of settlement with
Cincinnati Insurance Co per court order
jan 27/2004 Billing On InvOice 18t3
74812 FEES 625i00 DISBS 142!74
Jan 27/2004 Shotlenberger & Januzzi
74814 Costs recovered on settlement of Thomas
Miles #021503
0.37 1813
Jan 27/2004 Sh°llenberger & janUzzi 731i 1 625 00 1744 81
74816 Fee 2 0n se~tiement With cincinnati
Coi T Miles #021503
Jan 27/2004 John Miles, parent and natural guardian 7312 1 1744.81 0.00
74818 Settlement proceeds from Cincinnati Co,
Thomas Miles #021503
Jan 27/2004 Sh°llenberger & JanUZZi 00836 130.19
74820 PMT ' Client Paying Bill , costs
recovered on settlement of T Miles
#021503
Jan 27/2004 Sh°ilenberger & Januzzi 03366 625.00
74822 PMT - Client Paying Bill - fee on
0200
1813
7310
i 130.19 2369.81
Feb 24/2004 Page 2
Date
Received From/Paid To
Shollenberger & Januzzi, LLP
Client Ledger
ALL DATES
Che# General
Bld Trust
Entry# Explanation
Rcpt# Rcpts Disbs
settlement of Thomas Miles #021503
Feb 24~2004 Clerk of Orphans Court 7373
76067 Filing Fees ~ Proth0notary re:
Thomas Miles
Fees Inv# Acc Rcpts Disbs Balance
I UNBILLBD I t BILLED
TOTALS CHE+ RECOV FEES+ = TOTAL DISBS + FEES +
PERIOD 18.00 0.00 0.00 18.00 142.74 625.00
END DATE 18.00 0.00 0.00 18.00 142.74 625.00
-- BAL~CES --
TAX - RECEIPTS = A/R
0.00 755.19 12.55
0.00 755.19 12.55
TRUST
0.00
0.00
I/NBILLED BILLED
FIRM TOTALS CHE+ RECOV FEES+ = TOTAL DISBS + FEES +
PERIOD 18.00 0.00 0.00 18.00 142.74 625.00
END DATE 18.00 0.00 0.00 18.00 142.74 625.00
REPORT SELECTIONS
I I-- BALANCES --[
TAX - RECEIPTS : A/R TRUST
0.00 755.19 12.55 0.00
0.00 755.19 12.55 0.00
Report:
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Finished:
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Matters:
Clients:
Major Clients:
Responsible Lawyer:
Introducing Lawyer:
Assigned Lawyer:
Type of Law:
Sort by Resp Lawyer:
New Page for Each Lawyer:
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Ver:
Client Ledger
Ail
csholley
Tuesday, February 24, 2004 at 04:09:26 PM
kLL DATES
021503
Ail
All
All
All
All
All
No
No
No
No
No
Dec 31/2199
6.10b
Firm Totals Only: No
Entries Shown - Billed Only: No
Entries Shown - Disbursements: Yes
Entries Shown - Receipts: Yes
Entries Shown - Trust: Yes
Entries Shown - Time or Fees: Yes
Working Lawyer: No
Incl. Matters with Retainer Bal: No
Incl. Matters with Neg Unbld Disb: No
Show Interest: No
Trust Account: All
Show Client Address: No
SHOLLENBERGER & JANUZZI, LLP
1820 Linglestown Road
P.O. Box 60545
Harrisburg, Pennsylvania 17106-0545
Telephone Number: (717) 234-3700
Fax Number: (717) 234-8212
Attorneys for Plaintiff
IN RE: THOMAS MILES,
a minor,
IN THE COURT OF COMMON PLEAS
CUMBERLAND COUNTY,~.~';:
PENNSYLVANIA
NO.
ORPHANS' COURT DIVISION
AND NOw this I ~) TH- day of kl 0 ~ r-'Ty] 1~ F.L~ , 200_, upon
consideration of the within Petition, Plaintiff's request for approval of a Compromise
Settlement in the above captioned matter is approved. Plaintiff's contingent fee
agreement with counsel is approved and Plaintiffs counsel shall collect fees, costs and
expenses set forth in Plaintiffs Petition and the exhibits attached thereto from the
proceeds of this settlement. The balance of the proceeds shall be deposited in the
name of Thomas Miles in more savings accountS in banks, building and loan
associations or savings and loan associations, deposits of which are insured by a
Federal governmental agency provided that the' amount deposited in any one savings
institution shall not exceed the amount to which accounts are thus insured.
No withdrawal shall be made from any such account until Thomas Miles shall
attain his majority, except as authorized by further Order of this Court. Proof of the
deposit, along with a signature card for each account, shall be promptly filed of record
with the Court.
SHOLLENBERGER & JANUZZl, LLP
1820 Linglestown Road
P.O. Box 60545
Harrisburg, Pennsylvania 17106-0545
Telephone Number: (717) 234-3700
Fax Number: (717) 234-8212
Attorneys for Plaintiff
IN RE: THOMAS MILES,
a minor,
IN THE COURT OE_,GOMM~N p~.AS
CUMBERLAND C~NTY,...,-L':' .... ,~
PENNSYLVANIA
ORPHANS' COURT DIVISION
AND NOW this z.z~ day of r,",~ ,200_, upon
consideration of the within Petition, Plaintiff's request for approval of a Compromise
Settlement in the above captioned matter is approved. Plaintiff's contingent fee
agreement with counsel is approved and Plaintiff's counsel shall collect fees, costs and
expenses set forth in Plaintiff's Petition and the exhibits attached thereto from the
proceeds of this settlement. The balance of the proceeds shall be deposited in the
name of Thomas Miles in more savings accounts in banks, building and loan
associations or savings and loan associations, deposits of which are insured by a
Federal governmental agency provided that the amount deposited in any one savings
institution shall not exceed the amount to which accounts are thus insured.
No withdrawal shall be made from any such account until Thomas Miles shall
attain his majority, except as authorized by further Order of this Court. Proof of the
deposit, along with a signature card for each account, shall be promptly filed of record
with the Court. ~
$
TIMOTHY A. SHOLLENBERGER
KARL J. JANUZZl
SHOLLENBERGER & JANUZZI, LLP
2225 MILLENNIUM WAY
ENOLA, PA. 17025
WritAr's Din=!d ~-m8il kii@shollianlaw com
(717) 728-J200
FAX (7! 7) 728-J400
January 28, 2005
with offices in Elizabethville (717) 362-4472
Wilkes-Barre (570) 822-0711
Office of the Clerk of Orphan's Court
Cumberland County Courthouse
One Courthouse Square
Carlisle, PA 17013
RE: In Re: Thomas Miles. a minor
Dear Sir/Madam:
Pursuant to the order of Judge Kevin HEll'S, d.<!le.cLMa.rch 22, 2004 in the
above captioned case, enclosed please finctProof of dee.~ltjJ;lto the proper
account for Thomas Miles.
Very truly yours,
I.,i""
Karl J. Januzzi
KJJ:jjr
Enclosure
cc: John Miles
c=
-:-
'0
tv 1st
MEMBERS 1st
FEDERAL CREDIT l'NION
CERTIFICATE
APPLICATIO'IT A'lTD DISCLOSGRE
I/\\'e hereb,y apply for a :\'lembcrs 1'1 Certificate in the
amount and term listed below.
'\l\T1'RITY IH TE:
08/03/2011
240453
ACCOL:\T #:
SOCIAL
SHTRITY#
Please Print Thomas J Miles
\IE\lBER'S :'\'\\1E:
,""RESS: 1 N Pin Oak Drive
(717) 241-4981
591-35-1787
CITY:
Boilinq Sprinqs
SH TE: Pa ZlI' CODE: 17007
HO\l[ PIIO,,\;E :\L:\18ER:
WORK :'\T\mER:
.101:\1' OW,\'[R(S) :\A:\1I<::
o PLEASE DEPOSIT S 2,219.45
D PLEASE TR-\:\!SFER $
I~ THE FOLLOWI:"'(; \L\:\\TR
fRO" ACCT. :\0.
Sl~rflX
.. OFFICE USE ONLY
. .. ANNUAL
S A!'IIOl!'T DESC~ ._A<.T :PERCENTAGE ...
CERlHICA 1E TERI\I ($500 Minimum) ABBR;; CODE VIELD DIVIDEND RATE SUFFIX #
3 _\10"111 CtRTIFllATE 3\10 . 6
6 \1O"1II ('[RrIFle"lE 26\'.' 7
12 \lOYlll CERTIFICHF IVR 22/'X
18 \lO:\TH (EHTlFIC,\TE 18\1 9
30 .\fO'\TlI (FRTIf'ICATF 3thl 10
3 YEAR CERTlFlC-\'1 F 3YR I~
-t \T\R CERTIFlC-\TE 4'R 15
4 YEAR Ill'\'lP l'P CERTlnC\lT B~8 25
5 YEAR CERTIHC\TE $2.219.45 5YR II 4.40 4.31 41
-- --
9 .\IO:\"I'H '\0 PE....-' ITY (SS,1I00 ~lIl'.) 9_\10 26
CERTIFICATF
BR~l'CH, DlI'L()\ H
*Di\-'. Paid at !\-Iaturity 01 JSK
'\IETlIon (n- DI\'IUF:...n l)ISPOSITIO~
f'LEAS!':
CHOOSE
,ccor'\T
I n....v , ....F\IBER
V SA:\.lE ACCOl.':"'T
-- I
,
- DEPOSIT BACK TO CERTIFICATF: (I)
- DEPOSIT TO S,'\\T\GS AcnH''''T (2)
~ DEPOSIT TO CIIECKI:'\G ACCOL'\T (2)
- DEPOSIT TO IN\.'fST'\1E~T SA \1"'Gsh-II\L\ (2)
- DEPOSIT TO SLPPLD.1E."HAL S..\ Yl~GS (2)
- I\hlL \IE A CIIFTl( (3)
'---0--
('''')
M.I;\IBER'S. SIG:\'A TlRE:
.,
",-"J ,i':'
DATE:
'-.:- This is to certify that the above named person(s) is (are) the owner(s) of a Certificate account at
__:\-le":lbCts 1st Federal Credit l;nion. The Certificate is in accordance with the terms of the J\-lembcrship
C')andAcc,ount Agreement and the Credit lInion's current Truth-in-Savings Rate and Fee Schedule
::H":which--shal'l accompany the receipt of deposit for this Certificate and is incorpofllted by this reference.
--,
Re... 51113/114
'. ~
Share and Loan List
Account 0000240453
Account Typc: Court Ordered
\h'mht'r
THOMAS J MILES
r~ pl' Birthdatt'
Primary 08/03/1993
1 ',) PI',) OAK DRIVE
l30IU',)G SPRINGS. PA 17007
Shart'
S 00
S 40
S 41
Ikst'riptiol1
SA VINGS
60 MONTH CERT
60 MONTI! CER!
\Iaturitv Datt'
08/03/20] 1
08/03/2011
':::0
C"')
Page I of 1
Thomas J Miles
Rl'Iatiol1ship Codt' 00
SSl\ lIo!TIt' Phone
591-35-1787 717-241-4981
Availahle
- 79.79
- 3.880.84
- 4,938.90
Balance
25.21
1.778.89
2,219.45
tile)/C :\Program%20Fi les\Symitar\SFW\I-I!ML\llTtvlL View _ 373 883 5 .htm
1/18/2005