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HomeMy WebLinkAbout06-28-13 RECOIRRF,',�„ n,r�tnr nr IN RE: ESTATE OF : IN THE COURT OF COMMON PLEAS NATASHA HAULIYI �I?J�I 2 1 3 :CUMBERLAND COUNTY, PENNSYLVANIA C,L ,:'k r : ORPHAN'S COURT DIVISION IV,[:a173) �doul�. 1 CURiE'E2L ,!:L' C0JQ'., 'A : NO. 2013 - �51 PETITION TO RAISE AN ESTATE AND APPOINT A PERSONAL REPRESENTATIVE AND NOW, comes PETITIONER, Robert A. Smyser, by and through his attorneys, Costopoulos, Foster& Fields, and petitions this Honorable Court to compel the raising of an Estate and the appointment of a personal representative for the Estate of NATASHA HAULMAN, for the following reasons: 1. Petitioner, Robert A. Smyser, is an adult individual who currently resides at 58 Irish Gap Road,Newville, Pennsylvania 17241. 2. On September 21, 2011, Petitioner was a backseat passenger in a vehicle operated by Natasha Haulman. Other passengers included the front seat passenger and owner of the vehicle, Benjamin Bloser, and another back seat passenger, Sadie McKeehan, when the vehicle was traveling on West Pine Street, South Middleton Township and impacted a tree. 3. As a result of the impact,Natasha Haulman and Benjamin Bloser were killed. 4. The backseat passengers, both of whom sustained injuries, were mechanically extricated from the vehicle by emergency personnel. A copy of the police report is attached as Exhibit A. 5. As a result of injuries sustained in the crash, Petitioner has a cause of action against the Estate of Natasha Haulman and has been trying to negotiate with the insurer, but to date, no settlement has been reached. 6. It is believed that at the time of her death,Natasha Haulman resided with her mother, Laura Bailey at 102 Seavers Road,Newville, Pennsylvnia 17241. 7, Petitioner,through his counsel, confirmed with the Register of Wills for Cumberland County, Pennsylvania,that no Last Will and Testament has been filed nor has an Estate been opened on behalf of Decedent,Natasha Haulman, to date. 8. Petitioner, through his counsel, contacted Laura L. Bailey and Mr. Jason G. Haulman, parents of decedent,Natasha Haulman, in an attempt to ascertain their intentions on raising their late daughter's Estate. See correspondence dated June 6, 2013 attached hereto as Exhibit`B". No estate has been opened and the time period indicated in the letter has passed. 9. Given the fact that Petitioner was involved in an accident resulting in injuries, Petitioner is required to file suit in the Cumberland County Court of Common Pleas naming the Administrator of the Estate of Natasha Haulman as a Defendant. 10. 20 Pa. C.S.A. § 3155(b)(5) allows the Plaintiff in an action for damages to apply for Letters of Administration and to raise the Estate of a deceased Defendant, if no Estate exists. 11. 10 Pa. C.S.A. §(b)(5) allows the Register of Wills in his or her discretion to issue Letters of Administration to any "fit person" in an action for damages against the Estate of a deceased Defendant. 12. Petitioner requests the Court to appoint, Richard W. Stewart, Esquire, as a personal representative to serve for the purposes of opening an Estate so that Petitioner can proceed forward with suit. 13. Richard W. Stewart, Esquire is a lawfully licensed attorney in Pennsylvania, has experience in estate matters and has been practicing law for approximately 30 years. 14. Richard W. Stewart, Esquire practices law at Johnson, Duffie, Stewart& Weidner located at 301 Market Street, P.O. Box 109, Lemoyne, Pennsylvania 17043-0109. 15. Ricahrd W. Stewart, Esquire has no objection to and will immediately renounce the appointment as personal representative if Decedent's parents Laura L. Bailey or Jason G.. Haulman, or another family member would like to be appointed as personal representative at a later date. 16. In the alternative, undersigned counsel has no objection to the appointment of Laura L. Bailey or Jason Haulman as a personal representative at this time if this Court and/or the Register of Wills deems necessary.. 17. Counsel has submitted alternate,proposed Orders for review and consideration. 18. Name and residence of persons to whom letters are requested to be granted are Richard W. Stewart, Esquire, 301 Market Street, P.O. Box 109, Lemoyne, Pennsylvania 17043 or in the alternative, Laura L. Bailey, 102 Seavers Road.Newville, PA 17241. 19. Petitioners have provided a copy of this instant Emergency Petition to Decedent's mother, Laura L. Bailey and her father, Jason G. Haulman, at the above listed address. WHEREFORE, Petitioner, Robert A. Smyser requests this Honorable Court to compel the opening and raising of an Estate and the appointment of a personal representative for the Estate of Natasha Haulman. Respectfully submitted: COSTOPOULOS, FOSTER& FIELDS eslie . Fields, Es wire I.D. 0. 29411 VERIFICATION The undersigned hereby certifies that she is the attorney for Petitioner and that the facts in the foregoing Emergency Petition to Raise an Estate and Appoint a Personal Representative are true and correct to the best of her knowledge, information, and belief, and that said matters relating to the Petitioner, are as known to the undersigned as to the client, Petitioner, Robert A. Smyser, said knowledge being based upon information contained in attorney's file in this matter, and further states that false statements herein are made subject to the penalties of 18 Pa.C.S.A. § 4904 relating to unsworn falsification to authorities. eslie M. ields, Esquire. Dated: 4;12-c- Lai j VERIFICATION The undersigned hereby certifies that he has reviewed the foregoing Petition to Raise an Estate and Appoint a Personal Representative and attests to same. The undersigned also agrees to be named as Personal Representative and agrees to withdraw as Personal Representative if/when another proper party comes forward and requests to be substituted. The undersigned further states that false statements herein are made subject to the penalties of 18 Pa.C.S.A. § 4904 relating to unworn falsification to authorities. Richard W. Stewart, Esquire Dated: 146 '0 AA-500 TX Iricfdenl Number: 1402-2062453 C01111)T0r1WCalth of Pennsylvania • Crash Involves: PAGE I Police Crash Report REPORTABLE cRASH 0 DUI QQ Falelily O HR and Run 0 Commoicinl vehlcls State Pelicu Vohleio Q Local Police Vehicle O NIA Work Zone Q AN U Snov+mabllo 0 Commonwoallh Vehicle O I ocal Gov Vehicle � Agency Name _—, t, PA STAYE POLICE-CARLISLE Case Closed Palrol2one llnveSligidon Dale Dispatch Tim Arrival Tines - YES or 06:04 Inve RNS.r _ 20_ I 09!21/2011 < hrs. OG:16 nra. _ BURNS,MICHgC'L W Badge Numbar Approval Oale 08366 3 09/2312011 RQUINN —'--'— -- Reviewer ead9e Number __ QUINN,LINETTEG Date of Crash - Time of Crash '� _-- ------ 07470 0 9121/2 011 IDay orthe W.K Crash Desc;lplion -------- __ 06:02 hra. _ I WEDNESDAY HI FIXED OBJECT County CUMBERLAND Weather Conditions - - SOUTH MIDDLETON TWP o NO ADVERSE CONDITIONS Relation to Roadway NIllumination ----.—_ OUTSIDE TRAFFICWAY- O DAWN Road Sudace Conditions —_ DRY N of Units Aor Peopla #ol Injured >7 Killed EMS Agency _-- _ 001 004 002 002 WEST SHORE EMS Medical Fadliy ---- School Bus Reiff led School Zone Related PennDOT Noltged i MILTON S HERSHEY MEDICAL CENTER NO NO NO YPe or Inlarseceo^ Spedal Location _ MIDBLOCK NOT APPLICABLE Work Zone Work Zone Type —'— --- -- o° NO Where n Wmk zone --- N �.__—___.— Spend Limit Workers Present Otrr-er Present Nbrs Zana Charederisgs Road Closed Vvbn on Shoulder Intermittent or Flagger ❑Lane Closure Cf vNth Dolour u or Median Ig Route Signing --�--- U Moving RUfir Control � other r COUNTY ROAD Rome Number Segmonl Number Travel Lanes TSpaad Limit Odenizlion -- Y476 �- �.�2 —1 36 MtF a- House Number .----�JJ�-LL���. EST '9 Street flame —,—_- WE$(PINE Ending 7REEY of Route Signing aegmonl Number Travel Lano$ SUsed in rPae�d ntapoIntersection --Crashes Street Name Ening E D Route Numbar Or IAil P Or Segment Marker Ramp Use On;Y ---Slreel En fn�c p — - E r Tenths o H Route Numbs, r---- �0�Mile Posl TenUS Or Segmonl MarKer Ramp Use Onij above entry Is the Is SlreaI Name ance fro n the Crash ne to Landmark 1 rees Minutes Seconds Decimal. Degrees M�nuj¢s ds Decimal 40 07 06 424 Lonpitud0: a � 77 ---- TraKic Codfol Device -- 77 12 675 FNOT APPLICABLE Trahlc Control nuno..ioning ----- NO CONTROLS m Lane Closed Lane Closure Dlredion FULLY F1LST AND WEST 7YES Detoured Esgmated Time Closed -- 3.6 HRS F Environmental,Roadvyay Potentla Fa l ctors NO i NONE Fodor 3 g First Harmful Event In the Crash ------ Most Harmful Event in the Crash Unit Number Harmful Event ---- - -_- 333 001 IT TREE OR SHRUBBERY U idrJUniber Harmrul Event a01 HIT TREE OR SHRUBBERY I DRIVtl Prime ION Unit Number Frime Fodor Driver Action DRIVERAC7tON 1001 1 SPEEDING w UR Prime Factor EnvlromenlaOadway _ Prime Fodor Vehlde Failure Prime Factor Pedeslri -------- an Action Road Surface Type —"-- - BLACKTOP Spacial Junsdk9on --------_.- _ NO SPECIAL JURISDICTION Printed At:PA State police.Cndialo 09,29,2011011:42 PM Pago i form q:H02• EXHIBIT —A AA-000 TX PAGE 2 Incident Number: M02.2062463 �Commonvilealth of Pennsylvania Crash Involves: r Police Crash Report REP TABLE CRASH ODtn Fataliv 0 Hit amlRU. O Commercial Vehicle O State PollcOVehicle O Local Police Vehicle O NIA O Work 20n0 O ATV O Snowmobile O Commomyealih Whic o O Local 0av Vehicie Unit Number Type Unit Vehicle �- 001 Motor Vehicle In Transport No Flnl Name MI bast Name �A SuPa 0p$ Telephone Number NATASHA R HAULMAN 03/06/1991 (717)386.39)6 Sheol Address City _ Slate 210 Code 102 SEAVERS ROAD NEWVILLE _ PA 17241 Gender Licenso Number Uecnse State Class Expire on Gate Ownorlodver c FEMALE 29288461 PA C 03Po8/2012 PRIVATE VEHICLE NOT OYVNFDILFASEO BY DRIVER Driver Presence P'nysrwi Cori Primary Vehido Codee Violallon Person Charged DRIVER OPERATED VEHICLE HAD BEEN ORIN! VC 3362 MAXIMUM SPEED LIMITS NO _v S AlocholiDnags Suspected hot test Type Alcohol Test Resutfs w ALCOHOL URINE UNKNOWN RESULTS Driver Action AFFECTED BY PHYSICAL CONDITION,DRIVING TOO FAST FOR CONDITIONS,OVER(UNDE COMPENSATION AT CURVE, SPEEDING `s Padasldanaction Pedestrian Signals Pedestrian Cloning Pedestrian Location ISl Harmful Event Lehu Right Side 11,1,ost Manful julifity Pate Number HIT TREE OR SHRUBBERY RIGHT YES 2nd Harmful Event Left or Right Side Most Hanmul wiy Pole Number 3rd Harmful Event 1411 or Rghi Side I1.osi Harmful Utility Polo Number �J 4th Harmful Event Len or Right Side Most Harmful Utility Pole Number Owner First No" �� Owner MIM1 Owner Last Name of Business Name u6z E MARTINA J BLOSER Street Address ---- City ��•— State 21p Code 160 BARNSTABLE ROAD CARLISLE, PA 17016 Vehicle Type SDecial Usage —•--" Govemmpnt Egalpmenl Number AUTOMOBILE NOT APPLICABLE Model Year Ivehlicle Make ivetude Model ehicle Color VIN 2006 IVOLKSWAdEN I GTI BLACK DOWDEOIJ654030929 License Plate Reg.Slate Est Speed Vehicle Tooted Taxed By OSY0262 PA 116 YES K A MULLEN'S TOWING •`EY nswence inaarance Compam• Paiky Number -'~-��'----�.—" plrolion Date YES 1ST CHOICE AUTO INSURANCE CO PAP204001 0611212012 c Direction of Travel Vehicle Position VehY n to Movement �� Initial impact Point a° WEST RIGHT OF TRAFFICWAY NEGOTIATING CURVE-LEFT 3 O'CLOCK Damegolndicatur Gradient Road Arigmnent PosSib%Vehicle Failures - DISABLING DOWNHILL CURVED NONE ° Ar of Units Type Unit! Tag Number Tag Y ear lap Stale -��- ° 9 � = �__.� .P Unit Make Unh Owner� c Type Unit 2 Tag Number ^1'ag Year Tag Stole W�.� Unit Make Unit tT•mer Engine Size Passenger? a$ ddle earrwnk? '- Troller? Oliver Eauwtlon? o � Driver Helmet Type Neimai Stayed On? DOT/Snall Designation? Eye Protection? Long Sleeves? long Parini? Over Ankle Boots? 0 E Passenger Helmet type Hatmal Stayed On? 007lSne0 Designation? Eye PratcsY!an7 Long Sleexas? tcrtg Pants? Over Ankle Seats? o Passenger? Helmet? u Head Ughts7 _ ---.�--' -_ Rear Raapctua? Printed At:PA State Poiioo-Carlisle 09129120111101:42 PIA Page 2 Farm e:UO2.2062463 AA-500 TX Incident Number: H02-2062463 Commonwealth of Pennsylvania PAGE 3 Crash Involves: police Crash Report REPORTAOLECRASIJ 0OUI Q Fotattty O Hat and Run C) Commercial VohlClo O $Into Police Vehicle `) Local Police Vehicle O NIA 0 W0f8 Zone O ATV O Snowmobile Q Cammanwomth Vahtolo 0 Local Gov Vehicle Unit Driver Reshtdions Compliance Driver Endorsement Compliance Driver tloense Compliance 01 NO RESTRIGTIONSINOT APPLICABLE NONE REQUIRED _ VALID LICENSE FOR CLASS &Principal Impact Point Voidance Maneuver —~� Under Rtd¢i :cator i 3 O'CLOCK NO AVOIDANCE MANEUVER NO UNbERR 1 OE OR OVERRIDE _�m LL Emergency Use Drug Test Typa Drug Test Results I NOT IN EMERGENCY USE URINE UNKNOWN TEST RESULTS ItUnkD Parson NO. First Name MI taxi Neme Suffix 006 001 001 NATASHA R HAULMAN 0310611991 Street Address City --� Slate Zip Code 102 BEAVERS ROAD NEWVILLE PA 17241 Phone Number EMS Transport Person Type Gander injury Sovetity (717)386.3096 NO DRIVER �FEMALE KILLED Seat Position Safety Equipment) o DRIVER•ALL VEHICLES LAP AND SHOULDER BELT USED n n Safety Equipment y' Exlricallon �� FRONT AIR BAG DEPLOYED(FOR THIS SEAT) EXTRICATED BY MECHANICAL MEANS Eadbn Election Path NOT EJECTED NOT EJECTEDtNOT APPLICABLE Unit a Person No. Flret Name fAl Lest Noma Suffix 006 001 002 BENJAMIN P BLOSER 06122!1990 beet Address City State Zip GOIs c 160 BARNSTABLE ROAD CARLISLE PA 17015 a° Phone Number Ellis Transport Person Type Gondar Injury Sovedty v� (717)246-0864 NO PASSENGER MALKILLED c Seat Position Safer,Equipment 1 �T u FRONT SEAT RIGHT SIDE NONE USED I NOT APPLICABLE 6 so"Equipment 2 Extrication FRONT AIR BAG DEPLOYED IFOR THIS SEAT) EXTRICATED BY MECHANICAL MEANS Election Election Path NOT EJECTED NOT EJECTEDINOT APPLICABLE Unit It person No. Ftrsi Name V tAi Lest Name �TSutfiz DOB 001 O03 SADIE L MCKEEHAN 09114111992 Street Address City State Zip Code 61 BROAD STREET APT 1 NEWVILLE PA 17241 Phone Number EA1S Transport frcradn 7ypp �•--• Gander Injury Severity ^� YES PASSENGEf: _.._ _ FEMALE INJURY,UNKNOWN SEVERITY e Seat Position Solely Equipment m SECOND ROW-LEFT SIDE OR MOTORCYCLE PASSENGER NONE USED!NOT APPLICABLE 5 —__• �$ Safety Equipment 2 - ^ExUirslion NONE USED I NOT APPLICABLE EXTRICATED BY` ISCHANICAL MEANS Electron EJecdon Path - -i -i NOT EJECTED NOT EJEC7EDtNOT APPLICABLE Unit a Perspn No. Fl s{Name MI last Name f -�—• 3�ltiY 006- •` 001 004 ROBERT � A �SMYSERR 07124/1991 ueel Address City State Zip Code 4 WEST MAIN STREET NEWVILLE' PA 17241 Phone Number EMS Traosporl Person Typo —•� Geller tn{ury Strefity 'gET YE5 PASSENGER 4MALE INJURY,UNKNOWN SEVERITY E Seat Position ssloty Equipment I . 3 SECOND ROW-RIGHT SIDE NONE USED f NOT APPLICABLE n Safety Equipment 2 Exukation NONE USED l NOT APPLICABLE EXTRICATED BY MECHANICAL MEANS Election jejection path NOT EJECTED NOT EJECTEOINOT APPLICABLE Printed At:PA Stets Police-Carlisle 00129/201101:42 PM Pogo 3 Forme 1102.2062463 AA-500 TX -Incident NUmbor: H02-2462463 commonwealth of P6nnsyivaniai PAGE 4 Crash Involves: Police Crash Report RCPORVABLF CRASH Q D rr^^i�UI Q fatality v Hit and Ran C Cmman:tVohtMO � StarPbitea Vohkte V Local PaitCO Vehicle O N7A Work ZOAD Q ATV J Snowmobile C Commonwaullh Vehlclo L0001 Gee Vehicle Personl8usinass Notified —�—••--"" phono__Number E STEVEN LEE BLOSCR Dela Noti led Time 401111 d (717)246.0684 09727/2011 08:46 his Reason tar Notification DEATH OF SON Pem0mausiness Notified phono Number c GARY LEE BAILEY Date Notified Time Notated P717}369.3395 _ 0912112017 09:20 = Reason tot Notification „_,__„•,,,_ his DEATH OF GRANDDAUGHTER H SpootOSto ' 4O31A4o npaclwin Tree SjrOa/ dSbrnH E \ 0 Ik mC S A aOw �f,.asautr �� 5PS:nfOS15 NARRATIVE Crash Unit#01 was traveling west on West Paine Street at an extremely high rate of speed, Unit#01 entered a left curve In the roadway. Operator#01 failed to negotiate this curve causing unit#01 to exit the north edge of the roadway. Unit#01 struck a tree. 009rator#01 and the front seat passenger were killed on impact. Two{2} rear seat passengers were injured and entrapped In the vehicle. Responding Fire and EMS personnel extricated the rear seat passengers. They were both transported to Milton S. Hershey Medical Center for treatment. This colllslon occurred on Wednesday,21 September 2011 at approximately y Printed At:PA Stoto Pollee•Cadteto 001261241101:42 PM Page 4 Form A:M02.2062463 AA�500 TX Incident Number: 1402-2062463 011 colttmonwealth of PerinsylvanilD PAGE u Crash Involves: Police CrastiReport HFPOWASLECRASH O Oil' - O° Fatality O Hit and Run O O Local Police Vehicle O NIA O Work Yen. O AW 0 Snowmobile O C.nlmonwealtb V0100 O Local Gov Vehicle 0602hrs on West Pine Street in South Middleton Township, Cumberland County. West Pine Street has a posted speed limit of 35miles per hour. The collision occurred at dawn on a roadway with no street lighting. The roadway surface is well worn asphalt with a slight descending grade and slight super-elevation. The road surface was dry with an overcast sky and an ambient temperature of approximately 64 degrees Fahrenheit. This collision occurred as unit#o1 was traveling west on West Pine Street at an extremely high rate of speed. As unit#01 entered a left curve In the roadway,operator#01 failed to react to the curving roadway. Unit#01 began to rotate counter-clock-wise,entering into an unrecoverable critical speed yaw. UnI #01 exited the north edge of the roadway where the right side of tmit#01 impacted a tree. The force of the impact caused an intrusion of approximately 40 inches Into the passenger compartment. The right font seat passenger and operator#01 both sustained fatal Injuries due to impact with the tree. Unit#01 came to uncontrolled rest facing southwest while still In contact with the struck tree approximately 20 feet north of the roadway. The occupants of unit#01 were identified as the following: Operator; Natasha Rebecca HAULMAN(PA 29308461) Right Front Passenger(pass#01); Benjamin Pash BLOSER (PA 29026040) Left Rear Passenger(pass#02): Sadie Lynn MCKEEHAN (PA 29856043) Right rear Passenger(pass#03): Robert Anthony SMYSER(PA 29628009) Upon my arrival, untt#01 was observed at uncontrolled rest, The roof of unit#01 had been out at the rear of the vehicle and folded forward by emergency services personnel to extricate the rear seat passengers. HAULMAN and BLOSER were deceased and still entrapped their respective seat positions. MCKEEHAN and SMYSER had been mechanically extricated and were being evaluated by EMS personnel. Physical evidence related to the collision Included but was not limited to tire marks attributed to unit#01 beginning in the westbound lane of West Pine Street, The tire marks traverse the westbound lane and exit the north edge of the roadway. Marks in the soft earth beginning at the north edge of the roadway and leading up to the point of Impact are also attributed to untt#01, Unit#01 sustained extensive impact damage nearly bisecting the vehicle directly across the front seating area. A partially empty bottle of Pucker Sour Apple Vodka was found lying alongside unit#01 at uncontrolled rest. Based on measurements of physical evidence observed at the scene,a speed calculation was completed. Results of the calculation determined unit#01 to be traveling at a speed in excess of 100 miles per hour. The scene was documented with a digital canters by the Investigating Officer. Digital photographs have been saved to a Compact Disc and forwarded to the Troop H, Forensic Services Unit for retention in accordance with AR 9-2T. West Shore Advanced Life Support Paramedic Douglas Lloyd HERMAN,was one of the first emergency services personnel on scene. HERMAN stated the ferrate passenger In the roar seat(MCKEEHAN)was panicking and attempting to crawl out of the vehicle. HERMAN assisted In the extrication of both MCKEEHAN and SMYSER. During HERMAN's evaluation of SMYSER, SMYSER stated that "they had been out drinking". SMYSER could not state how the collision had occurred. On 09121/2011 at approximately 0617hrs, pass#02,MCKEEHAN was interviewed at the scene by Trooper Rodney G. FINK. MCKEEHAN identified the other occupants of the vehicle as "Ben BLOSER, Rob SMYSER,and Natasha HAULMAN". MCKEEHAN could not Primed Al:PA Stata Polko-Carlisle 091201201101:42 PM Page 6 Fonne:H02-2062469 AA.5o0YX • Incident Number: H02.2002463 Commonwealth of Pennsylvania PAGE 6 Crash Involves: Police Crash Report RiA9Ll CRASH ©Out Fatality O Hit and Run 0 Commerclel Vahlelo O Stato Polio Vohlcle C Local Police Vohiclo , d NIA 0Work 2ono 0 ATV 0 Snowmotillo O C01nm0MVaalal Voh(cle O Local Gov Vehicle state how the collision had occurred, but stated they(all four occupants)tied been drinking alcohol that night. MCKEEHAN was then transported from the scene by Yellow Breeches EMS to the Milton S. Hershey Medical Center for evaluation and treatment. On 09/21/2011 at approximately 0620hrs,poss#03,SMYSER,was interviewed at the scene by Trooper Roger E. HALL. SMYSER had sustained head trauma but was conscious and responsive. SMYSER stated that they (occupants) had "been out drinking around and chilling with friends". SMYSER related lie did not know how the collision had occurred. SMYSER was then transported from the scone by Cumberland Goodwill Ambulance to the Milton S. Hershey Medical Center for evaluation and treatment. On 09/2112011 at approximately 0624hrs,Take Marie SLOAN of 618 West Pine Street In Mt.Holly Springs,Pa 17066 (pg#717486.7683)was Interviewed at the scene by Trooper Kevin HOLFORD. SLOAN did not witness the collision but had heard It and ran to the scene afterwards. SLOAN stated she heard unit#01 "flying down the road" prior to the collision. After hearing the unit#01 strike the tree, SLOAN ran to the scene. SLOAN stated she spoke with rear seat passenger MCKEEHAN. SLOAN claimed MCKEHHAN admitted they "were all drinking" and"under 21". On 0912112011 at approximately 0720hrs, i spoke with Robert Lee SLOAN of 618 West Pine Street in Mt. Holly Springs, PA 17065(ph#717483-7683) in the driveway of his residence. SLOAN had been in his residence at the time of the collision. SLOAN did not witness the collision but heard it. SLOAN stated,"i heard them coming down the road,"and"they were flying". SLOAN stated as the car passed his first thought was,"My God, if they make that turn it'll be a miracle". SLOAN then heard the vehicle Impact the tree. Cumberland County Coroner Todd ECKENRODE and Deputy Coroner Richard MIDDLEKAUFE responded to the scone. On 09121/2031 at 0645hrs,Coroner ECKENRODE pronounced both HAULMAN and BLOSER dead. The bodies of HAULMAN and BLOSER were then mechanically extricated from the vehicle. The bodies were then removed from the scene. Toxicology tests have been ordered for both HAULMAN and BLOSER; however,no autopsies will be performed. Coroner ECKENRODE took custody of and retained the Pennsylvania operator's licenses of both HAULMAN and BLOSER. On 09121/2011 at approximately 0846hrs,Trooper Scott E. MASCI notified Steven Leo SLOSER(father of Benjamin Pash BLOSER)of the death at the family residence. On 09/21/2011 at approximately 0920hrs, Trooper Scott E. MASCi notified Gary Lee BAILEY(grandfather of Natasha Rebecca HAULMAN)of the death at the family residence. Unit#01 was removed from the scone by K A Mullen's Towing &Recovery of Carlisle, PA, Responding Emergency Services Departments Included Mt. Holly Springs Citizens Fire Company, Union Fire Company,West Shore EMS, Yellow Breeches EMS, Cumberland Goodwill Ambulance,and Newvllle Community Ambulance. West Pine Street was closed between tan Drive and Maurice Road. Traffic control was conducted by members of the Mt. Holly Springs Citizen Fire Company Fire Police. i Printed At:PA Sinto Polito-Ca61910 09120120111 01:42 PM Pogo Form it:H02-202463 ,t AA-500 TX •Incident Number: n02-2002469 Commonwealth of Pennsyivani PAGE T Crash Involves: Police Crash Report I tTABLO CRASH 0 our ©Fatality 0 Ha and Run O Commorctal Voh(elo Q State Poll co WhOo C) 1-001 POlko VOhlele O NIA ©work Zone 0 ATV O Srmwmohllo O Commorlwool0,Vohkta O Local eov Vehlele I am a Technical Collision investigator(TCI)within the Ponnsylvania State Police. State Police members responding to and assisting at the scene included Corporal Todd J. RUDY,'rroopei- Rodney G. FINK,Trooper William D.HOTHAM,Trooper Roger E. HALL,and Trooper Kevin HOLFORD. Troop H Public Information Officer Trooper Michele DAVIS responded to the scene and spoke with media persons. In accordance with FR 64, Pennsylvania State Police,Troop H,Collision Analysis and Reconstruction Specialist (CARS)Corporal Christopher T. PUSHART was notified on 09/2112011 at approximately 0666hre. CARS did not respond due to a lack of prosecution based on the death of operator HAULMAN. Due to the likelyhood of alcohol Involvement In this collision and Injuries sustaijuld by the surviving passengers, VictimlWitness Assistance Guides were provided to SMYSER and MCKEEHAN. A Public information release was completed and disseminated by Trooper DAVIS, A copy has been printed and placed in the crash attachment fits. The Fatal Crash System entry was completed In accordance with FR 6-4 on 0912112011. Based on a tack of prosecution,this Investigation Is tenriinated. The toxicological results for operator#01, HAULMAN,will be supplemented to this report upon receipt for documentation purposes. Printed At:PA State Polito•CaAieto 00/26 MI 01:42 PM Page 7 Form 0:K02.2002463 COSTOPOULOS, FOSTER & FIELDS ATTORNEYS AND COUNSELORS AT LAW 831 MARKET STREET P.O. BOX 222 WILLIAM C.COSTOPOULOS LEMOYNE,PENNSYLVANIA 17043-0222 TELEPHONE(717)761-2121 DAVID J.FOSTER FAX(717)761-4031 LESLIE M.FIELDS ) VWVV.COSTOPOULOS.COM GEORGE Ii.MATANGOS HEIDI F.EAKIN June 6, 2013 VIA CERTIFIED AND REGULAR MAIL Ms. Laura L. Bailey Mr. Jason G. Haulman 102 Seavers Road Newville, PA 17241-8952 Re: Motor Vehicle Accident - September 21, 2011 Dear Ms. Bailey and Mr. Haulman: Please be advised that our firm represents Robert A. Smyser pertaining to a motor vehicle collision that occurred on September 21, 2011, in which your daughter, Natasha Haulman was also involved. We are sorry to hear of her passing. Regrettably we must contact you under these circumstances. Presently, we have been communicating with the automobile insurance company and are trying to negotiate a settlement. However, we have been unable to reach an agreement, and the other passenger in this matter is also in the same situation. There is a Statute of Limitations in Pennsylvania in which a person must file a claim for injuries they sustained in a motor vehicle accident. Mr. Smyser must file his -e aim-with-the-Gumberland-County-Geur1?of-Gommon-?teas-t"r--eser+re his4tght-to—-- � pursue his claim for injuries. Because your daughter has passed away, Mr. Smyser's claims have to be filed against your daughter's estate. The Cumberland County Register of Wills has no record of an Estate being opened in her name. We are respectfully asking that you take the needed steps to open your daughter's Estate and request that the Register of Wills appoint you as a representative of your daughter's Estate, or in the alternative that one of you be appointed and one of you renounce your right to be appointed. Because of the time limitations involved, if you are unable or do not open the estate for Ms. Haulman within the next 10 days, we will be filing a Petition with the Court seeking to raise an Estate in your daughter's name and in the petition, we will request that the court appoint a disinterested third party as EXHIBIT ! Ms. Laura L. Bailey Mr. Jason G. Haulman June 6, 2013 Page Two i representative of the Estate. This party would remain as representative until such time as you or another appropriate relative or party per your family's choice requests to be substituted. If you choose to open the estate yourself and be swom in as the representative, please contact the Cumberland County Register of Wills, One Courthouse Square, Carlisle, Pennsylvania, 17013, 717-240-6345, and they will assist you in doing so. I would also suggest that you immediately contact an attorney about raising an estate for your daughter as well. Thank you for your attention to this matter and again, please accept our condolences. Sincerely, Lesli M. Fields LMF:jmk CERTIFICATE OF SERVICE I, Leslie M. Fields, Esquire, hereby certify that on this 2 th day of June 2013, a true and correct copy of the foregoing document was served upon all parties by: Hand Delivery X First Class Mail, Postage Pre-Paid Certified Mail, Return Receipt Requested Fax Transmission Overnight Mail at the following address(es) and/or number(s): Ms. Laura L. Bailey Mr. Jason G. Haulman 102 Seavers Road Newville, PA 17241-8952 Richard W. Stewart, Esquire JOHNSON, DUFFIE, STEWART& WEIDNER, P.C. 301 Market Street Lemoyne, PA 17043 COSTOPOULOS, FOSTER& FIELDS Leslie . Fields, Esquire