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McNEES WALLACE & NURICK LLC
Guy H. Brooks
I.D. No. 49672
James J. Franklin
I.D. No. 306458
100 Pine Street, P.O. Box 1166
Harrisburg, PA 17108-1166
(717) 237-5384
(717) 260-1764 facsimile
gbrooks(a�mwn.com
jranklin a(�mwn.com Attorneys for Petitioners
MUTHIAH SABARETHINAM and : IN THE COURT OF COMMON PLEAS
VIJAYALAKSHMI RAMANATHAN, : CUMBERLAND COUNTY, PENNSYLVANIA
Parents and Natural Guardians of
KIRTI MUTHAIAH, a minor,
Petitioners : ORPHANS' COURT DIVISION
v. : NO. /3 ea6'L'`
KEITH M. MASELLI and
•
LAURA MASELLI,
•
Respondents
PETITION FOR APPROVAL OF MINOR'S SETTLEMENT
AND NOW come Muthiah Sabarethinam and Vijayalakshmi Ramanathan,
parents and natural guardians of Kirti Muthaiah, and pursuant to Pa.R.C.P. 2039,
petition the Court for approval of the settlement of the personal injury claim for Kirti
Muthaiah, a minor, for the reasons set forth below.
/03. 75- 1
/ ' '
01.970
•
1. No action was commenced in this case, thus the Orphan's Court division
has jurisdiction to approve this settlement. See In re Schwartz'Estate, 10 A.2d 386,
388 (Pa. 1940); Bollinger v. Randall, 135 A.2d 802, 805 (Pa. Super. Ct. 1957).
2. Petitioner, Muthiah Sabarethinam, is the father of Kirti Muthaiah.
3. Petitioner, Vijayalakshmi Ramanathan, is the mother of Kirti Muthaiah.
4. Both Petitioners and Kirti Muthaiah reside at 5110 Mendenhall Drive
Mechanicsburg, PA 17050, Cumberland County, Pennsylvania.
5. Due to Kirti's young age, the parties request that she need not attend any
hearing that the Court may require to address this Petition.
6. Respondents are Keith M. Maselli and Laura Maselli.
7. On August 28, 2012, Kirti Muthaiah was at or near her residence in
Mechanicsburg, Pennsylvania.
8. On that date, Kirti Muthaiah was the subject of an incident involving two
dogs owned by Respondents. Respondents subsequently had the two dogs
euthanized.
9. Kirti Muthaiah suffered serious injuries to her left leg as a result of the
incident.
10. Kirti Muthaiah was transported to the Penn State Milton S. Hershey
Medical Center for treatment.
11. Kirti Muthaiah received definitive treatment over several days for the
injuries to her left leg, including operations and a skin graft. Kirti Muthaiah's medical
-2-
discharge summary from the Penn State Milton S. Hershey Medical Center is attached
hereto as Exhibit "A."
12. Kirti Muthaiah may have permanent scarring on her leg due to the injuries
and corresponding surgeries.
13. The hospital records do not indicate any other injuries. See Exhibit A.
14. At the time of the incident, Respondents possessed homeowners
insurance with a $300,000 policy limit.
15. Respondents have offered the limits of their homeowners insurance policy
as consideration for settlement and release from any potential civil action arising out of
the incident.
16. The parties have reached a settlement, subject to Court approval, in the
amount of$300,000.00, the limits of Respondents' homeowners insurance policy, paid
to Kirti Muthaiah.
17. The settlement and release do not apply to any separate criminal
prosecutions that may be brought by the District Attorney of Cumberland County, and
they do not limit any restitution that may be ordered by the Court of Common Pleas of
Cumberland County. True and correct copies of the Release and Addendum to
Release are attached collectively hereto as Exhibit "B."
18. Petitioners and the undersigned entered into a contingent fee agreement
for the undersigned's services to Petitioners in the above-referenced matter.
-3-
19. Pursuant to the terms of the contingent fee agreement, the undersigned is
entitled to a sum equal to 33 1/3 percent of the gross recovery as reasonable attorneys'
fees for the undersigned's services and representation.
20. The undersigned continues to represent Petitioners in the ongoing criminal
investigation into this incident.
21. According to the Penn State Milton S. Hershey Medical Center, there are
no current unpaid liens, claims or debts that relate to the medical treatment provided to
Kirti Muthaiah.
22. Petitioners hereby certify that a gross settlement in the amount of
$300,000.00 —the limits of Respondents' homeowners insurance policy— as
compensation for the injuries suffered by Kirti Muthaiah and in lieu of any litigation is
reasonable and in the best interests of the minor, Kirti Muthaiah.
23. Petitioners request that the Court approve of the Release and Addendum
to Release agreed to and executed between Petitioners and Respondents in the forms
attached collectively hereto as Exhibit B. See Exhibit B.
24. Upon information and belief, Petitioners did not incur any other fees or
costs in connection with this matter.
25. After taking into account the undersigned's 33 1/3 percent of the gross
recovery, Petitioners shall deposit the full net settlement sum into an interest bearing,
restricted, federally insured account for the benefit of Kirti Muthaiah, marked "No
withdrawals prior to age 18 without prior court approval."
-4-
26. Petitioners join in this request and hereby agree that approval of the
proposed settlement is in the best interests of the minor, Kirti Muthaiah.
WHEREFORE, Petitioners request the Court's approval of this settlement, and
the Court's approval of the Release and Addendum to Release attached collectively
hereto as Exhibit B as set forth above.
McNEES WALLACE & NURICK LLC
By
Guy H. Brooks
I.D. No. 49672
James J. Franklin
I.D. No. 306458
100 Pine Street
P.O. Box 1166
Harrisburg, PA 17108-1166
(717) 237-5384
Dated: May 17, 2013 Attorneys for Petitioner
-5-
PENNSTATE HERSHEY Penn State Hershey Tel: (717)531-8055
Milton
T, Milton S. Hershey Medical Center
Milton S. Hershey Health Information Services, HU24
1 8.7.5;5 Medical Center 500 University Drive
P.O. Box 850
Hershey, PA 17033-0850
Patient Name: MUTHAIAH, KIRTI Visit Number: 10512543
MRN: 1468799 Visit Type: Inpatient
Date of Birth: 2/17/2005 Patient Location: 7MBE; 7217; 01
Patient Gender: Female
Discharge Summary
RESULT STATUS: Final
DOCUMENT SUBJECT:
ELECTRONICALLY SIGNED BY: Ingraharn,John Michael (9/21/2012 17:20 EDT)
DISCHARGE SUMMARY
Name: MUTHAIAH, KIRTI
HMC Number: 1468799
DOB: 02/17/2005
Date of Admission: 08/28/2012
Date of Discharge: 09/19/2012
Physician: Ingraham, John Michael
Service: Plastic Surgery
Destination: Penn State Hershey Rehab Hospital
(717) 832-2600
Discharge Diagnosis: Left lower extremity dog bite with open wound, peroneal nerve transection, arterial disruption at
trifurcation with thrombosis of anterior tibial artery status post thrombectomy.
Dictation#349410
Surgical Procedures: 8/29/12
1. Left popliteal and anterior tibial artery embolectomy.
2. Bovine pericardial patch angioplasty of left popliteal artery.
3. Debridement of 50 sq cm of skin, muscle, and fascia with completion fasciotomy.
4. Excisional debridement of skin, subcutaneous tissue, muscle 30 cm2.
8/31/12
1. Debridement of 15 square cm of skin, subcutaneous tissue and fascia.
2. Washout and placement of wound VAC.
3. Exploration of peroneal nerve.
9/2/12
Excisional debridement of skin and subcutaneous tissue with washout and placement of VAC dressing.
Date/Time Printed: 10/5/2012 14:01 EDT Page 1 of 5
Printed By: White,Shayla M
PENNSTATE HERSHEY
• Milton S. Hershey
}
5 Medical Center
Patient Name: MUTHAIAH, KIRTI MRN 1468799
Discharge Summary
9/4/12
1. Open reduction and pin fixation of a proximal fibula fracture.
2. Debridement of 10 sq cm of skin, fascia, and nerve.
3. Placement of wound VAC.
9/7/12
1.VAC dressing change
9/11/12
1. Debridement of 15 sq cm of skin through fascia in a sharp excisional fashion.
2. Delayed layered primary closure measuring 12 cm.
3. Repair of peroneal nerve defect with two 6 mm x 3 cm NeuraGen nerve tubes and an interposing 5 mm x 7 cm Avance
nerve allograft.
4. Split-thickness skin graft with meshing 180 sq cm.
9/17/12
Dressing change under anesthesia.
Vaccinations Received This Hospital Stay:
No vaccinations were given this hospital stay.
Discharge Medications:
1.Acetaminophen-hydrocodone(Lortab Elixir)5 mL by mouth every 6 hours.
2.Aspirin (aspirin 81 mg oral tablet, chewable) 1 tab by mouth once daily.
3. Nonformulary MED(Flintstones Complete) 1 tab by mouth once daily.
4.Senna 8.8 mg by mouth 2 times daily.
5. Polyethylene glycol 3350(MiraLax) 17 g by mouth once daily, as needed for Constipation.
6.Bacitracin topical (bacitracin topical 500 units/g ointment) 1 appl topically once daily.
Brief History of Present illness:
A 7-year-old, otherwise healthy female who suffered injury to the left lower leg following attack by 2 dogs on the afternoon
of 8/28/12.Taken as a level 2 trauma to York Hospital, stabilized and transferred to HMC. Found to have circumferential,
degloving injury to the soft tissue, fibular head fracture, transection of the peroneal and sural nerves and extensive
vascular injury.
Hospital Course:
Admitted to PICU on the evening of 8/28/12 after wash out and debridement of her injuries in OR. Received 2 units of
pRBCs in OR. Evaluated by pediatric surgery, plastic& reconstructive surgery, orthopedic surgery and vascular surgery.
She was started on Unison and gentamicin for coverage of animal bite and open fracture, respectively. Pt was kept
intubated overnight and returned to OR on 8/29 for repeat I &D. She was successfully extubated after returning from the
OR and received 2 more units of pRBC's due to HGB 6.6. Hourly Doppler vascular checks continued to show good DP
and PT pulses. At that time, her pain was well controlled and she was mildly sedated with a basal rate of Fentanyl via
PCA. On 8/30/12 she was advanced to a diet of clear liquids. On this day, she was able to wiggle the toes on her left foot
on demand and had intact sensation on both the dorsal and plantar surfaces of the foot. Vascular checks were
decreased to q2h and she was moved to IMC status. Her antibiotic regimen was narrowed to include only Unasyn. She
was started on ECASA 81 mg per the vascular surgery team. On 8/30/12, she was taken back to the OR for wound
Date/Time Printed: 10/5/2012 14:01 EDT Page 2 of 5
Printed By: White,Shayla M
PENN STATE HERSHEY
PIM Milton S. Hershey
1 8 5"5
Medical Center
Patient Name: MUTHAIAH, KiRTI MRN 1468799
Discharge Summary
debridement and washout. Pieces of the peroneal nerve were tagged for future grafting. A wound VAC was placed and
the left leg was then placed in a CAM boot for dorsiflexion. Her Foley was discontinued. Two days later on 9/2/12, she
returned to the OR for further debridement,washout and replacement of the VAC. Due to blood loss during surgery and a
Hbg/Hct of 5.9/18, she was transfused with pRBCs. She tolerated this well and resumed a normal diet, although had
decreased appetite. She continued to have strong pulses via Doppler. PT/OT were enacted although she remained
non-weightbearing on the left leg per vascular/plastics. She was transitioned to PO pain medications with IV morphine
PRN. On 9/4/12 she returned to the OR for a possible skin graft, but it was decided to proceed only with washout and VAC
replacement at that time. Ortho percutaneously pinned the fibula at this time as well. As she remained stable from
vascular and ortho standpoints, on 9/5/12 a focus was placed on her PT/OT and nutritional needs. She was able to get
OOB to wheelchair and get out of her room. She was given samples of multiple dietary supplements to try to find one that
she might like due to decreased appetite and poor PO intake. She completed her course of Zosyn for her dog bite wound.
On the evening of 9/5/12 she began complaining of increased, burning-like pain in her leg and toes. She was given her
PRN morphine and was able to sleep through the night, but the pain was still present in the morning. Neurontin was
started for this neuropathic pain. She continued to have poor PO intake, and placing an NG tube for nutritional support
was discussed. This was not eventually needed. The patient returned to the OR on 9/7 for irrigation, debridement, and a
VAC dressing change. Postoperatively the patient did well and continued to increase her PO intake, not requiring an NG
tube. It was decided by the Plastic surgery team to complete nerve grafting and split thickness skin graft to cover the
wound. The patient was continued on aspirin as per Vascular surgery recommendations and her pain was managed
appropriately. On 9/11 the patient returned to the OR for definitive treatment of her wound. Plastic surgery performed the
following procedures:1. Debridement of 15 sq cm of skin through fascia in a sharp excisional fashion. 2. Delayed layered
primary closure measuring 12 cm. 3. Repair of peroneal nerve defect with two 6 mm x 3 cm NeuraGen nerve tubes and
an interposing 5 mm x 7 cm Avance nerve allograft 4. Split-thickness skin graft with meshing 180 sq cm. Post-operatively
the patient had no complications. She was instructed to remain on bedrest.A VAC dressing was applied as a bolster to
her reconstructed area. The patient did have trouble with pain, especially from the skin graft donor site on her left lower
back. Zosyn was re-started post-operatively. Any slight movement causes pain in her donor site. She continued to tolerate
PO and remained stable.The patient had difficulty moving her bowels and a bowel regimen was initiated with improved
her condition.On 9/16 the patient's IV infiltrated. Due to the patient's increased pain since the skin graft, the bolster was
removed on 9/17 during another operative procedure. The patient's dressing was changed to Xeroform, Kerlix, and ACE
wraps. The patient did well postoperatively. Her family was instructed these dressings will have to be changed twice daily
upon discharge until her follow up appointment. Orthopedics also cleared her to resume weight bearing as tolerated on
her left lower extremity. She was encouraged to continue her physical therapy and occupational therapy with active and
passive range of motion. Physical Therapy evaluated her and found her an appropriate candidate for inpatient rehab. She
was accepted at Penn State Rehab. The patient was discharged on 9/19 with a follow up with nurse visit in one week and
Dr. Ingraham in two weeks. VNA nursing will be arranged. Patient has a follow-up appointment with Vascular Surgery on
10/22.
Exam on Discharge:
Left Lower Extremity: Xeroform + bacitracin + Kerlix+Ace dressing in place-skin graft 90-95% intact
Motor: Dorsiflexion impaired, able to minimally flex/ext toes
Skin: Donor site-L lateral thigh/buttock demonstrates serosang o/p, Xeroform+ bacitracin +Ace
Less pain at graft site and able to accommodate lying flat
Care Instructions:
You will receive a phone call regarding your follow up appointment with Dr. Ingraham in 1 week.You will receive a call
within two business days. if you do not receive the call in 2 business days, please call 717-531-8952. Your appointment
will be in the UPC clinic at the Hershey Medical Center in Suite 3200.
Date/Time Printed: 10/5/2012 14:01 EDT Page 3 of 5
Printed By: White,Shayla M
PENNSTATE HERSHEY
Milton S. Hershey
$
. , Medical Center
Patient Name:ry'MUTHAIAH, KIRTI MRN 1468799
Discharge Summary
You also have a follow up appointment with Dr.Amy Reed in the Vascular Surgery clinic on 10/22/12 that is also located
in the UPC clinic.
Please follow up with Orthopaedic Surgery in 1-2 months to follow up on left pin placement.
Wound care:
Left lower extremity: After removing the dressing please place a thin layer of bacitracin on top of the skin graft, followed by
Xeroform(yellow gauze with ointment), and then wrap the area with Kerlix, followed by an ACE wrap.
Skin graft donor site: leave open to air. Let Xeroform dry and trim edges of Xeroform as it peels away from the skin.
Abdominal pads(ABD pads) may be used for comfort.
Sponge bathe only, must keep operative sites clean and dry.
Diet Guidelines:
regular diet, as tolerated. encourage plenty of liquids, fiber/protein intake.
Activity Guidelines:
No strenuous activity.Weight bearing as tolerated. Please keep leg elevated when sitting or lying down. Patient may be
bathed with a sponge bath, the left lower leg should not be submerged in water in any way.
Call your doctor if:
Please call your doctor if there are any additional questions or problems such as change in color of skin graft(white/blue),
fever, worsening swelling, change in sensation, unusual drainage or bleeding, increasing pain not responsive to
prescriptions.
During regular business hours please call 717-531-8952 for the Nurse line. After hours please call 717-531-8521, the
HMC operator, and ask for the plastic surgeon on call.
Follow-up with Nurse visit at UPC 3200 in one week.
Follow-up with Dr. Ingraham in two weeks at his Camp Hill office
Other Instructions:
Some patients and families experience increased emotional symptoms after injury, particularly after a head injury. It is
common and completely normal to have a gradual return to normal sleeping/eating/coping routines. Visit
aftertheinjury.org for interactive tools and information.
Follow-Up Appointments:
Scheduled Penn State-Hershey Appointments Within the Next 90 Days.
1. Follow-Up with PRS, UPC Nurse at Plastic Surgery- Univ Phys Ctr Suite 3200 on 09/26/2012 at 09:30 am
2. Follow-Up with Reed, Amy B at Nyes Road Suite E-Harrisburg on 10/22/2012 at 02:40 pm
Date/Time Printed: 10/5/2012 14:01 EDT Page 4 of 5
Printed By: White,Shayla M
PENI\STATE HERSHEY
Ti Milton S. Hershey
• 5 $ Medical Center
Patient Name: MUTHAIAH, KIRTI MRN 1468799
Discharge Summary
Electronic Signature on File
Electronically Reviewed/Signed by: Cathy R Henry, MD
Electronically Reviewed/Signed by: John Michael Ingraham, MDCosigner Signature Dt/Tm,: 09/21/2012 05:20 PM
CRH/JJR DD: 09/19/12 DT: 09/19/12 23:58
Date/Time Printed: 10/5/2012 14:01 EDT Page 5 of 5
Printed By: White,Shayla M
a
PARENTS/GUARDIAN RELEASE AND 114EMNITY AGREEMENT
United Services Member Name USAA Number LIR Number Date of Loss
Automobile Association Keith M. Meselli 018652617 4 08-28-2012
FOR AND IN CONSIDERATION of the payment to Muthiah Sabarethinam and
Vijayalakshmi Ramanathan, as parents and natural guardians of Kirti Muthiah, of the sum of
Three Hundred Thousand Dollars($300,000.00), thft receipt of which is hereby acknowledged,
we,the undersigned, father and mother of Kirti Muthiah, a minor, do forever release, acquit,
discharge and covenant to hold harmless Keith M. Maselli and Laura Maselli,theirs heirs,
successors,and assigns of and from any and all civil actions, causes of civil action, civil claims,
demands,civil damages, costs, loss of services,expenses and compensation, contribution,
indemnification, on account of,or in any way growing out sf, any and all personal injuries,which
we may now or hereafter have as the parents of Kirti Muthiah. This includes the civil claims or
rights of action for damages that Kirti MutllIah.has or may}iereafter have when she reaches the
age of majority. This release pertains to the accident that occurred on or about August 28,
2012,at or near her home in Mechanicsburg, PA. Tiffs release pertains only to any present or
future civil action that might be available to Kirti MuttNah or her parents and is not intended to
apply to any separate criminal prosecutions that may be brought by the District Attorney of
Cumberland County. This release i$not intended to limit any restitution that may be ordered by
the Court of Common Pleas of Cumberland County.
It is further understood and agreed that this settlement is the compromise of a doubtful
and disputed claim,and that this payment is not to be construed as an admission of liability on
the part of Keith M. Maselli and Laura Maselli, by whom liability is expressly denied.
We further state that we have read the foregoing release and know the contents thereof
and that we sign the same as our own free act.
PENNSYLVANIA statutes, 75-1822 states: "Any person who knowingly and with intent to injure
or defraud any insurer files an application or claim containing any false, incomplete or
misleading information shall, upon conviction, be subject to imprisonment for up to seven years
and payment of a fine up to$15,000."
Executed at o6 .ur f/ PA this 1 5- day of F , 2013.
City/State Day Month
WITNESSES: CAUTION: READ BEFORE SIGNING
Signature Legal Signature
Vijavalalcshrn'i afimanathan
11014
Si:r're Legal Signature
7 iEI Muthiah Sabarethinam
COMMONWEALTH OF PENNSYLVANIA
NOTARIAL SEAL
ROLAND L DOYLE,JR.,Notary Public
Mechanicsburg Boro.,Cumberland County
fluty Commission Expires December 31,2016
ADDENDUM TO PARENTS/GUARDIANS'RELEASE
AND INDEMNITY AGREEMENT SIGNED FEBRUARY 15,2013
ATTACHED HERETO AS EXHIBIT A
FOR AND IN CONSIDERATION of the payment to Muthiah Sabarethinam and
Vijayalakshmi Ramanathan, as Parents and Natural Guardians of Kirti Muthaiah, the sum of
Three Hundred Thousand Dollars and 00/100 ($300,000.00), the receipt of which is hereby
acknowledged, we, the undersigned father and mother of Kirti Muthaiah, a minor, do forever
release, acquit, discharge and covenant to hold harmless Keith M. Maselli and Laura Maselli,
their heirs,successors,and any and all other persons of and from any and all civil actions,causes
of civil action, civil claims, demands, civil damages, costs, loss of services, expenses and
compensation, contribution, indemnification on account of, or in any way growing out of any
and all personal injuries which we may now have or hereafter have as the parents of Kirti
Muthaiah.
It is further expressly understood and agreed that we will INDEMNIFY, DEFEND AND
HOLD HARMLESS the releasees named above from ANY LOSS, cost and expense and, any
and all claims against them for contribution or indemnity by any other person, firm or
corporation which arises from, or is related to the occun-ence set forth in the legal action above,
including any and all claims for medical expenses, liens asserted as a result of paid medical
expenses.
Executed at U$ Lt Sl."%s ij.),ythis q 'day of ) ,2013.
WITNESS:
MUTHIAH SABARETHINAM,as Parent
and Natural Guardian of Kirti Muthaiah,a Minor
�Y AKSI�✓II RAMANATHAN,as Parent
and Natural Guardian of Kirti Muthaiah,a Minor
VERIFICATION
Subject to the penalties of 18 Pa. C.S. §4904, relating to unsworn falsification to
authorities, I hereby certify that I have read the foregoing document and that the facts
set forth therein are true and correct to the best of my knowledge, information and
belief.
•
Muthiah Sabarethinam
Dated: t 7 May 6906
•
VERIFICATION
Subject to the penalties of 18 Pa. C.S. §4904, relating to unsworn falsification to
authorities, I hereby certify that I have read the foregoing document and that the facts
set forth therein are true and correct to the best of my knowledge, information and
belief.
M - -PA-
Vija Y alakslxfni am at n
Dated: ,'7 f c n90/3
-2-
MUTHIAH SABARETHINAM and
VIJAYALAKSHMI RAMANATHAN,
Parents and Natural Guardians of KIRTI
MUTHAIAH, a minor,
Petitioners IN THE COURT OF COMMON PLEAS
V. OF THE NINTH JUDICIAL DISTRICT
KEITH M. MASELLI and LAURA
MASELLI,
Respondents 2013-02813 CIVIL TERM
IN RE: PETITION FOR APPROVAL OF MINOR'S SETTLEMENT
ORDER OF COURT
AND NOW, this 291h day of May 2013, upon consideration of the Petition for
Approval of Minor's Settlement, a HEARING shall be held on 25 June 2013, at 2:30
p.m. in Courtroom Number Six of the Cumberland County Courthouse, One
Courthouse Square, Carlisle, Pennsylvania.
The minor child shall not be present for the above-scheduled hearing without
prior approval from this court.
BY THE COURT,
Thomas A. Placey C.P.J.
Distribution: .:
_may H. Brooks, Esq.
Keith M. Maselli
Laura Maselli ;
Y c ? -4r
S 3G//3
MUTHIAH SABARETHINAM and IN THE COURT OF COMMON PLEAS
VIJAYALAKSHMI RAMANATHAN, CUMBERLAND COUNTY, PENNSYLVANIA
Parents and Natural Guardians of,
KIRTI MUTHAIAH, a minor, .:
Petitioners : `CA'MS' COURT DIVISION
NO. 13 6Gvi1
V.
KEITH M. MASELLI and
LAURA MASELLI,
Respondents
ORDER
AND NOW, this 2S day of , 2013, upon consideration of the
Petition for Approval of Minor's Settlement, said Petition is GRANTED and the following
Order is entered:
1. The Court hereby approves of the settlement, Release, and Addendum to
Release agreed to and executed by Petitioners and Respondents, attached as Exhibit B
to the Petition;
2S
2. Petitioners' counsel shall receive -3--3 V9 ercent of the gross recovery —
the total sum of$ — as reasonable attorneys' fees; L4-p eta ,�
~e3. Petitioners are directed to deposit the net settlement proceeds — Ids
attorneys' fees — in an interest bearing, restricted, federally insured account for the
benefit of Kirti Muthaiah that provides that no withdrawals can be made from the
account without prior approval of this Court until Kirti Muthaiah attains 18 years of age;
and,
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4. Petitioners shall file with the Court proof of such deposit/ w Lk"v% "�Od-c.S
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TH IC U
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En,
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MUTHIAH SABARETHINAM and
VIJAYALAKSHMI RAMANATHAN,
Parents and Natural Guardians of,
KIRTI MUTHAIAH, a minor,
Petitioners
: IN THE COURT OF COMMON PLEAS
: CUMBERLAND COUNTY, PENNSYLVANIA
NO. 2013 -2813 -CIVIL
v. .b = ..t- -t
m
KEITH M. MASELLI and z"a r— `'*"
-Jr-,
LAURA MASELLI, - o
Respondents xo x�;
53-.5;:.:u-4,-,-;
,
AFFIDAVIT OF DEPOSIT OF MINOR'S FUNDS -`` c..„). -}
The undersigned, Muthiah Sabarethinam and Vijayalakshmi Ramanathan,
parents and natural guardians of Kirti Muthaiah, a minor, hereby certify that the net
settlement amount of $192,307.84 as set forth in this Court's Order dated June 25,
2013, was deposited by Muthiah Sabarethinam and Vijayalakshmi Ramanathan into an
interest bearing, restricted, federally insured account for the benefit of Kirti Muthaiah, a
minor. Proof of deposit is attached hereto as Exhibit "A."
By
Muthiah Sabarethinam
G
6 6
Vijayalaks mi Ramanathan
417 Mercury Drive
Mechanicsburg, PA 17050
Dated: June 27, 2014 Petitioners
ExhibA A
Discove74uf1, 26. 2014n 3:56PM 7179863370
DISCOVER'
https://www.disco•No. 069 9,mitP. 3:/achome/details
Walwrna, MUTHIA14 $A$ARETHINAM ,PING MUTHUgGMAIi.CCM
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1 of 1 6/26/2014 2:40 PM
6126/2(J u n, 26. 2014 3: 5 6 P M 717986337 0scover Bank' Account Title Beneficiary Non -Spouse
DISCOVER'
No. 0699 P. 2
213
Welcome, MLIHIAHSAIMARETI1 M,pING.lvllrr)ti GMAL.COM Last login 0e124114,07:43 PM ET
Account Profile Massages Customer Service
Account Summary Transfer Money Bill Pay View Statements
Accounts Summary DP MONEY MARKET Account Title
DP MONEY MARKET
)ODt-)Do(161i - Opened Jun 09, 2014
Account Title
Ownership Type
Custodial
ACustodial Account allows an adult to legally transfer ownership of funds to a Minor when the Minor
reaches the age of maturity. The account Is owned bye Mnor, but controlled by the DE UTMA
Custodian.
EeneAclary VIJAYALAKSHMI RAMANATHAN
A Baneflciaryla a beneficiary des Ignetlon, created by an account owner who names one or more
persona to recelve the proceeds upon the owners death. The POD/LTF beneficiary heti no ownership
Interest during the owners lifetime.
DEUTMACustodian MlUTHIAH SABARETHINAM
ACustodtsn Is a parent or other designated adult who holds an accountfor the benefit of a minor
chlld,The Custodian manages the account until the child reaches the age of mahirttyand mayteke
control of the accountThe Delaware Uniform Trenefers to Minora Act(DE UTMA) allows items other
than cash or securities to given to Mnors
Minor KIRTI MUTHAIAH
The Mnor is the account owner,but cannotesneact on the account until the ege of maturity.
Vlow:
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Sciod eh Acc0Uht
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Questions? Call customer sentice at
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TDD 1-800-347-7454 (Mon. through Fri.)
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