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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: Layout Template: Requested by: Finished: Date Range: Matters: Clients: Major Clients: Responsible Lawyer: Introducing Lawyer: Assigned Lawyer: Type of Law: Sort by Resp Lawyer: New Page for Each Lawyer: New Page for Each Matter: Totals Only: Consolidate Payments: No Activity Date: 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