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HomeMy WebLinkAbout14-2748.4 WILLIAM J. FERREN & ASSOCIATES Francis R. Gartner, Esquire Atty ID # 49436 10 Sentry Parkway, Suite 301 Blue Bell, PA 19422 (215) 274-1710 isy,�vA A IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA DIVISION IN RE: Estate of BABY -GIRL DULAM- : N)1KASIREDDY, Deceased NO. ' V UNCONTESTED PETITION TO SETTLE WRONGFUL DEATH AND SURVIVAL ACTION The petition of Bharath Kasireddy and Mrudula Dulam, Parents of Baby -Girl Dulam- Kasireddy, deceased respectfully represents: 1. Petitioners are Bharath Kasireddy and Mrudula Dulam who are the parents of Baby - Girl Dulam-Kasireddy, 2. The decedent, Baby -Girl Dulam-Kasireddy, a 6.5 month old fetus, died on September 29, 2013, as the result of injuries sustained in a motor vehicle accident which occurred on September 29, 2013. A true and correct copy of the Coroners Certificate of Death is attached hereto and marked as Exhibit A. 3. Petitioners are the only individuals entitled under Pennsylvania law to recover damages under the Wrongful Death Act and Survival Actions for the damages suffered as a result of the death of their daughter. 4. The motor vehicle accident occurred on September 29, 2013, on Braddock Road heading North on the Fairfax County Parkway in Fairfax, Virginia. A true and correct copy of the police incident report is attached hereto as Exhibit B. covd- s103., S�� Db4I 3�'/ 5. The decedent, Baby-Girl Dulam-Kasireddy, was a fetus in her mother's womb, while her mother was a restrained passenger in a vehicle which was struck by Abraham Aragon's vehicle. 6. Bharath Kasireddy was the driver and Mrudula Dulam was a passenger in the vehicle struck by Abraham Aragon. Both Mr. Kasireddy and Ms. Dulam suffered injuries. The force of the impact resulted in severe deceleration and force to the mother's abdomen which in turn caused extensive trauma and fetal distress necessitating an emergency C-Section, however the trauma was such that the baby did not survive. The cause of death was placental abruption. See Exhibit A. 7. Baby-Girl Dulam-Kasireddy died intestate and without any estate . 8. At the time of the September 29, 2013 motor vehicle accident, the 2002 Toyota Avalon was owned and operated by Bharath Kasireddy was insured by Travco Insurance Company. The insurance policy provides underinsured motorist benefits of $100,000 per person and $300,000 per accident. A true and correct copy of the Automobile Policy Continuation Declarations is attached hereto and marked as Exhibit C. 9. Travco Insurance Company has offered to resolve all claims for underinsured motorist benefits related to the death of Baby-Girl Dulam-Kasireddy for the sum of $100,000, the policy limits. 10. The petitioners have agreed to accept the tender of the available underinsured motorists policy limits in satisfaction of this claim for wrongful death and survival actions. 11. Petitioners are not represented by counsel but understand their right to counsel and are satisfied that they have a complete understanding of their claims and any potential future consequences, and elect to proceed pro se. 12. Travco Insurance Company retained the undersigned attorney to prepare and file this petition seeking for approval of the wrongful death and survival actions. 13. Petitioners seek the Court's approval of this settlement and the distribution of settlement proceeds as set forth herein and in the proposed Order attached hereto. . 14. The following settlement has been proposed: $100,000.00 for wrongful death and $0 for survival action. 15. The proposed settlement is reasonable for the following reasons: The available policy limits are being exhausted with this settlement. 16. Petitioners are of the opinion that the proposed settlement is reasonable given that the available automobile liability coverage is being paid to the petitioners. 17. Counsel has incurred the following expenses for which reimbursement is sought: $0 18. Counsel requests counsel fees in the amount of $0. 19. There are no unpaid medical expenses. 20. Petitioners requests allocation of the net proceeds of the settlement, Wrongful Death Action $100,000 or 100 % Survival Action $0 or 0 % 21. Petitioners believe that the net proceeds of the settlement should be allocated in their entirety to the wrongful death action and not to the survival action in view of the compromised amount of the settlement, the lack of conscious pain and suffering, and the general policy of the law in favor of the wrongful death claim to the extent of affording it full priority over the survival claim as set forth in Wringler Estate, 29 Fiduc. Rep. 499 (1979). See also, McElhiney v Lockett and Quisito, Court of Common Pleas of Bucks County indexed to No. 86-261-15-2. 22. Pursuant to 42 Pa.C.S. § 8301, the beneficiaries of the wrongful death action and their respective interests are as follows: Bharath Kasireddy and Mrudula Dulam, parents of the Decedent, Baby -Girl Dulam-Kasireddy. 23. There are no other liens or claims against the proceeds of these actions or against the decedent's estate. 24. Bharath Kasireddy and Mrudula Dulam, parents of the Decedent, Baby -Girl Dulam- Kasireddy. may pursue claims against Abraham Aragon and this settlement with Travco Insurance Company is not intended to in anyway release Abraham Aragon or his automobile insurance company from those claims. WHEREFORE, Petitioners requests that they be permitted to enter into the settlement recited above and that the Court approve the proposed allocation and distribution of the settlement proceeds. Respectfully submitted, WILLIAM J. FERREN & ASSOCIATES Gartne , ' squire VERIFICATION We, Bharath Kasireddy and Mrudula Dulam, parents of the Decedent, Baby -Girl Dulam- Kasireddy. hereby depose and state that we have reviewed the foregoing Uncontested Petition to Settle Wrongful Death and Survival Actions and the facts contained therein are true and correct to the best of our knowledge, information and belief. We understand that false statements herein made are subject to the penalties of 18 Pa. C.S. Section 4904, relating to unsworn falsification to authorities. Bharath Kasireddy Dated: 0q-.-($—2o(g-- Mrudula Dulam Dated: i EXHIBIT A COMMONWEALTH OF VIRGINIA - CERTIFICATE OF DEATH DEPARTMENT OF HEALTH DIVISION OF VITAL RECORDS - RICHMOND COMA FOR sus REGISTRATIONA BEA , Z,• C CERT)_ E.ATE6 �'`/ 1 MEDICAL EXAMINER'S CERTIFICATE tiuniatiIL4 •�•,� 2. SEX mak irnafe-� DECEDENT 1. FULL NAME 10011 (mWdb) Oast) Of DECEDENT Baby Girl Dulam-Kasireddy _ ■ MI 3. DATE OF DEATH Imo.) (day) (Year) 14. AGE IF UNDER 1 Y IF UNDER ,1 DAY Lit I 1 1 fours minutes September 29, 2013 roan, , , 5 1 5. DATE OF (mo.) (day) Ow) SRM ept. 29, 2013 6. EVtR 11 U'T 1w ARMED FORCCS2 ❑ i . • IL COUNTY OF DEATH gl independent 0414, maws Wark1 PLACE OF DEATH 7. NAME OF HOSPRAL OR 1NSTRUTION OF DEATH (if none. m state) 1 1X)11 EmmePaL MDallent lm I - 0 i INOVA Hospital Fairfax❑ Fairfax 8. CRY OR TOWN OF DEATH Inside cny or town limits? Falls Church ® 10. STREET ADDRESS OR RT. NO. OF PLACE OF DEATH 3300 Gallows Road USUAL RESIDENCE OF DECEDENT 11. STATE (OR FOREIGN COUNTRY) OF DECEDENTS RESIDENCE Virginia 12 COUNTY OF DECEDENT'S RESIDENCE pl Independent 0414, leets WsM3 Fairfax y 0r town Be 13. CITY OR TOWN OF RESIDENCE • Mf de Wns? Lorton p ® .ZPC�O1DE 14. STREET ADDRESS OR RT. NO. RESIDENCE l 22 V !�}:T 7339 Ardglass Drive PERSONAL DATA 15. NAME OF DECEDENTS FATHER Bharath Kasireddy / 16, MAIDEN NAME OF DECEDENTS MOTHER Mrudula Dulam 17. RACE OF DECEDENT 18. OF HISPANIC ()MINT If yes. 0Decly Cuban, Mexican, Pune Rican. ate ® ❑ 18. EDUCATION (Specify only highest pats c0mplated) 0 a e+) Asian 110 Yes Efementayu�twary (o-1 College 14 20. Lt Intal OF WHAT COUNTRY 21.811TMPLACE (state oe mufti, .® U.S.A. Virginia 22 NEVER MARRIED DIVORCED 1 MARRIED • WIDOWED • 2J. IF MARRIED OR WIDOWED, NAME OF SPOUSE (11 dNomed kava Wank) 24. SOCIAL SECURITY NUMBER 25. USUAL OR LAST OCCUPATION 27. INFORMANT • OR SOURCE OF INFORMATION Mrudula Dulam - Mother s&gig 111111P' 1;W . m a WB6� c MEDICAL CERTIFICATION 28. PART L Ender the dseases. krydes, or compilations that caused the death. Do no enter the made d dying, 0004190 cabled 07 resp tory West. shag or 0001 la...INTCI4 mat any arts on trash One. ILA-C�hi mfr. L• A, oil. U P'fi b - 'disease M.0 DEATPEW:UH cause li 0v r5 IMMEDIATE CAUSE (Foal a _-III. (l condition resuming In death) ' DUE TO (OR AS A CONSEQUENCE OF): • • SequentiallycnsryIadp IS) DUE TO (OR AS A CONSEQUENCE OFC mediate se. Er UNDERLYING CAUSE (Disease or h4Iry that Initiated ever0s repelled in death) LAST (0) PART 8. Other ak�Naant conwaats contributIng to death bbl r0ct mating k the undedyl/g cause given inn PML 260. AUTOPSY? 0, AUTHORIZED DY: la O 28b. IF FEMALE, WAS THERE A PREGNANCY W PAST3 MONTHS? yes ID no IFMA unknown El 28c. IF EXTERNAL CAUSE. IT WAS ,00wY atbMw6URWy0 TO Amato° DEATH 2811, DESCRIBE HOW INJURY RELATING TO DEATH OCCURRED {� �% / / emits MO TO a. e g I4 I l `. (.. mics N MO 28e. TIME OF INJURY (mo.) (day) (year) (DIWO 'tpig -1`I -►3 281. INJURY OCCURRED - . nr,t❑ not* 13 28g. PLACE OF INJURY (home, lam, 128h. (dy 0r torn) MOWN latah) Dasa, oMco 01049., ek.) t IVf vu a' 0.0 14-0 r rGt.r a.,c, 284.1 CERTIFY that I took chug° 04 the remains described above. viewed NATURAL CAUSES 0 ACCIDENT I ' SUICIDE 0 the body, made inquiry and In my opinion deem resulted nor 1000 fid 2 r (AM)AM inn: • UNDETERMINED 0 POINO ❑. NCeC Ct /14 U..44,t 4. j) rp hni MICIDE IDEN SIG Alf IRE ) . DATE SIGNIID: � _--)1.4if L. 1111 II-- 1. -• .• � ... � . , �J} A(p/pyRE�g/g OF)A€DICAC. EXAMINER `� 1� A NAME OF CA{{ ER (type open 0 AAO I 1 1V t2, I 0 at,-- A-A.L-, v,S 7 • �' /2, IA/sic( MF/ „Try FUNERAL DIRECTOR❑ DIRECTOR 29. BURIAL REMOVAL CREMATION • 7 "- 30 PLACE- (name el cemetery or aemaaryl (coy or termly) tate) OF BURIAL, -' REMOVAL ETC. Funeral Choices of Chantilly ' Chantilly • Virginia 31, yC•'*rg, i!ur al di person j6m�.� ) E p NEM. tuners o ccs o 1 irly ADOREss:14522L Lee Rd. ,Chantilly,VA 20151. REGISTRAR DATE RECD 32. ii (signature of r�gistrROR aq t LR: 111 RESERVED FOR - REGISTRAR'S USE This is to,.certiiy,,that this is a true and correct reproduction of the original record filed with the ,FAI"RVA , ,COUNTY HEALTH DEPARTMENT, FAIRFAX VIRGINIA. OCTABBR48'f.20.13 DATE -ISSUED 1 DEPUTY REGISTRRAAR VOID IF ALTERED OR DOES NOT BEAR IMPRESSED SEAL Generated by CamScanner from intsig.com EXHIBIT B Revised Report Ci) CRASH Crash tat. Date 09 Q City of CD Town of L,DmmDnwealln or 1/1rglnla• uepanmenf or nnDlDrvenitaes Police Crash Report 1111E111111 I DIHI Page 1 ^••y I Day of Week MILITARY Time (24 hr clock) 29 12013 SUN I 0140 City or Town Name 00.0000000000000 County of Crash FAIRFAX COUNTY Landmarks at Scene NONE H130UN (Hey 7107) of 5 GPS Lo g 00.0000000000000 Official DMV Use - Location of Crash (route/street) RT286 FAIRFAX COUNT PW N S EW Railroad Crossing ID no. (d within 15011.) Location of Crash (routelstreel) of RT620 BRADDOCK RD CD At intersection With or 500 ❑ Miles Il Feet ( CD Q C' -.DRIVER• Drivers Name (Last, First, Middle) ARAGON, ABRAHAM Address (Street and Number) 11227 SOLDIERS RIDGE CIR Apt. 304 City I State I ZIP MANASSAS Birth Dote 03 116 j1969 Safety Equip. Used At Bag Ejected 1 SVA X20109 Drivers License Number State DI. CDL A69647199 VA CIO O CCD. 4) Date of Death Injury Type I EMS Transport 091 29 _12013 1 I Cr7 CO) 2 3 Summons 1 Offenses Charged to Driver Issued As Result of Crash UEFIICLE.. Vehicle Owner's Name (Last, First, Middle) Same as Driver C Address (Street and Number) ' City Vehicle Year Vehicle Make 1 9 9 3 MAZDA Vehicle Model MX3 Vehicle Plate Number WUM1911 VIN J_M1 EC4326P0219038 Name of Insurance Company (not agent) NATIONWIDE INSURANCE Speed Before Crash Speed Limit Maximum Safe Speed 50 50 50 PASSENGER CMV Towed Q c ate Approxima e Repai Cost A 2,000 Q Oversize Q Cargo spill Under Q Override Q Underride ALL Passengers Age Count Over 18.17 116-21 Local Case Number 2013-2720025 Mile Marker Number Number of Vehicles 002 DRIVER Driver Fled Scene Q Driver's Name(Last, Fust, Middle) KASIREDDY, BHARATH Address (Street and Number) City [State I Gender CP Address (Street and Number) 416 MEADOW DR Vehicle Model AVALON Disabled CSD City CAMP HILL Birth d Date 08 117 11978 Drivers License Number 28755710 I State JPA State PA ZIP 17011 DLCDL OD CI I CD COD Safely Equip. Used 3 Air Bag�Ejected 1 I' Date of Deathni I_ 1 Driver Injury Type tory TypeEMS Transport 2 J 7 N Summons Issued As Result of Crash 2 Offenses Charged to VEHICLE Vehicle Owner's Name (Last, First, Middle) Same as Driver i Address (Street and Number) City [State I ZIP Vehicle Year Vehicle Make 2 0 0 2JTOYOTA Vehicle Model AVALON Disabled CSD CMV CD Towed COD Vehicle Plate Number GZS6039 State PA Approximate Repair Cost 10 000 VIN 4T1 BF28872U254854 Q Oversize Q Cargo spill Name of Insurance Company (not agent) TRAVELERS INSURANCE Q Override Q Underride Speed Before Crash Tpeed Limit Maximum Sale Speed Under ALL Passengers Count Age COver 50J 50 a 1 6-17J 18.21 J 21 01 (only if injured or killed; PASSENGER (only f injured or killed) Name of Injured (Last, First, Middle) I EMS Transport CD GO Date of Death 1 1 Name of Injured (Last, First, Middle) `;:DULAM, MRUDULA EMS Transport Date of Death Cwt (' 1 1 Position In/On Vehicle 1 Safety Equip Used AirbagEjected T Injury Type Birthdate I 1 Gender COQ Position In/On =''; Vehicle 3 Salety Equip I Used 3 Airbag 1 Ejected 1 Injury Type 2- Birthdate Gender 04 102119-8-41® W Name of Injured (Last, First, Middle) EMS Transport co c) Date of Death 1 1 a'; Name of Injured (Last, First, Middle) EMS Transport co c> Date of Death 1 I Position -1 IreOn Vehicle Safety Equip Used Airbag Ejected Injury Type Birthdate I I Gender M QF Position In/On Vehicle Safety Equip Used Airbag Ejected Injury Type Birthdate TGender I to Codes 8 1 I 2TII 3 8 416 7 8 POSITION INION VEHICLE 1. Driver 2.6. Passengers 7. Cargo Area 8. Riding/Hanging On Outside 9-98. All Other Passengers SAFETY EQUIPMENT USED 1. Lap Belt Only 2. Shoulder Belt Only 3. Lap and Shoulder Belt 4. Child Restraint 5. Helmet 6.Other 7. Booster Seat 8. No Restraint Used 9. Not Applicable AIRBAG 1. Deployed - Front 2. Not Deployed 3. Unavailable/Not Applicable 4. Keyed ON 5, Unknown 6. Deployed - Side 7. Deployed - Other (Knee, Air Belt, etc.) 8. Deployed - Combination EJECTED FROM VEHICLE 1. Not Ejected 2. Partially Ejected 3. Totally Ejected SUMMONS ISSUED AS A RESULT OF CRASH 1. Yes 2. No 3. Pending INJURY TYPE 1. Dead Before Report Made 2. Visible Signs of Injury, as Bleeding Wound or Distorted Member or Had to be Carried From Scene. 3. Other Visible Injury, as Bruises, Abrasions, Swelling, Limping, etc. 4. No Visible Injury, But Complaint of Pain, or Momentary Unconsciousness. 6. No Injury (drive only) Name (Last, First, Middle) Name of Injured (Lest, First, Middle) EMS Transport Date of Death C) C) I I Name of Injured (Last, First, Middle) EMS Transport Date of Death - I����I I I Report File Date Position Equip ISafety In/quip Vehicle Used Vehicle Used Airbag Elected Injury Type Birthdate Gender I I OD Ci " Position In/hn Vehicle" Safely Used Used Airbag Ejected Injury Type Birthdate l Gender _1 I 11 Q Codes 8 1 I 2TII 3 8 416 7 8 POSITION INION VEHICLE 1. Driver 2.6. Passengers 7. Cargo Area 8. Riding/Hanging On Outside 9-98. All Other Passengers SAFETY EQUIPMENT USED 1. Lap Belt Only 2. Shoulder Belt Only 3. Lap and Shoulder Belt 4. Child Restraint 5. Helmet 6.Other 7. Booster Seat 8. No Restraint Used 9. Not Applicable AIRBAG 1. Deployed - Front 2. Not Deployed 3. Unavailable/Not Applicable 4. Keyed ON 5, Unknown 6. Deployed - Side 7. Deployed - Other (Knee, Air Belt, etc.) 8. Deployed - Combination EJECTED FROM VEHICLE 1. Not Ejected 2. Partially Ejected 3. Totally Ejected SUMMONS ISSUED AS A RESULT OF CRASH 1. Yes 2. No 3. Pending INJURY TYPE 1. Dead Before Report Made 2. Visible Signs of Injury, as Bleeding Wound or Distorted Member or Had to be Carried From Scene. 3. Other Visible Injury, as Bruises, Abrasions, Swelling, Limping, etc. 4. No Visible Injury, But Complaint of Pain, or Momentary Unconsciousness. 6. No Injury (drive only) Name (Last, First, Middle) Badge or Code Number Agencyloepartmentffame and Code ewing Officer Report File Date 1ReviOfficers KEEVILL, E.300644 FAIRFAX COUNTY POLICE LONG, J. 01 ' 14 2014 Officer initials EIK Badge # 300644 Revised Report 4) CRASH Commonwealth of Virginia • Department o) Motor Vehicles I II II III II IItil I I III Police Crash Report Crash 1.11.1 DD YYYY MILITARY Time (24 hr clock) Date 09 129 201 0140 0 7 0 7 8 FR300P (Rev 7107) Page 2 of 5 FAIRFAX COCounty of Crash [CD City of COUNTY [CD Town of Local Case Number 2013-2720025 DRIVER INFORMATION 1 12W N ;trunk Driver's Action,. ' XPi I: I 0 )' 1.NoImproper Action 0(; 01 2. Exceeded Speed Limit Qf 0 3. Exceeded Safe Speed But Not Speed Limit 0) 0 4. Overtaking On Hill Oi Q, 5. Overtaking On Curve 8. Overtaking at Intersection is t D Q; 7. Improper Passing of School Bus c �0: 8. Cutting In a '0!9.01herImproper Passing (4)1 Q; 10. Wrong Side of Road - • Not Overtaking 0 :0 11. Did Not Have Right -of -Way O( 0; 12. Following Too Close 0 C), 13. Fail to Signal or Improper Signal Or C) 14. Improper Tum •WideRight Tum Qi !C7 15. Improper rum • 1 ; i Cut Comer on Left Tum 0) 10+ 16. Improper Turn From Wrong Lane .Q, 17. Other improper Tum QQ 18. Improper Backing C s(3 19. Improper Start From Parked • Position ! i 0 1�, 20. Disregarded Officer or nagger C) C' 21. Disregarded Traffic Signal ( '0, 22. Disregarded Stop or Yield Sign 0i 23. Driver Distraction Q! 24. Failed to Stop at Through High 1 way - No Sign 0 ;01 25. Drive Through Work Zone pO 26. Felled to Set Out Flares or Flags 27. Fail to Dim Headlights d ,O 28. DrivingWithoutLights t ;UE 29. improper Parking Location Q :O 30. Avoiding Pedestrian a) OI 31. Avoiding Other Vehicle L,1 a 32. Avoiding Animal c : (j 33. Crowded 06 Highway 0 34. Hit and Run 0 O 35. Car Ran Away - No Driver Q36.Blinded byHeadlights I [� i 0 37. Other Q i n 36. Avoiding Object in Roadway (� O 39. Eluding Police 0 40. Fall to Maintain Proper Control �1 ('"•� 41. Improper Passing C,,,) 42.1mproper or Unsele Lane Change :0 43. Over Correction Ve1tt iVe2Jh. 1 Ni' J. Driver Vision Obscured P3 i 01.9l ;iii 1. Not Obscured O, 01 2. Rain, Snow, eto. on Windshield Q ,Qi 3. Windshield Otherwise Obscured Q ;0j 4. Vision Obscured by Load on l Vehicle O a O O! 0 01 0 01 0 0I 0`2 0".O; C)C>j v:U; D Qi 14.811nd Spot (� '.Q; 15.SmokelDusl ( ;O; 16. Stopped Vehkle(s) 5. Trees, Crops, etc. 6. Building 7. Embankment 8. Sign or Signboard 9. Hi0crest 10. Parked Vehicle(s) 11. Moving Vehkle(s) 12. Sun or Headlight Glare 13. Other •• sit Type,of Driver Distractions s,i O Qj 1. Looking et Roadside Incident 0 :Qll 2. Driver Fatigue 0 '0; 3. Looking at Scenery i O 01 4. Passenger(s) 0 ;Q1 5. Radio/CD, etc. 0 :0i 6. Cell Phone 0 :QI 7. Eyes Beton Road 0 U! 8. Daydreaming Q O/ 9. Eating/Drinking 0 {O, 10. Adjusting Vehicle Controls 0 iQ 11. Other 0 C) . 12 Navigation Device i .1 NtA ; 'NIA' : • ,.�{ Drinking 0 4)1 1. Had Not Been Drinking (1)� ! )' 2. Drinking • Obviously Drunk Q}}> Q� 3. Drinking • Ability Impaired Of :O{ 4. Drinking - Ability Not Impaired 0! ?Oj 6. Drinking • Not Known Whether jImpaired O ,C)� 6. Unknown 1 1 i Condition di:kilter P2' -_ Contributing to the Crash!';= ((_i 6 ) 1. No Defects CD, :0 2. Eyesight Defective O .0 3. Hearing Defective a; 0 10: 4. Other Body Defects C i •U 5.Illness C`j ;(71 6. Fatigued C.I Q 7. Apparently Asleep C .• & Other Q 9. Unknown IIA i<�t Method of Aicoho1P6. a. Determination {by police) 411 `0; 1. ewe Qi .C7j 2. Breath (DI 0: 3. Refused (2)1 ;C>1 4. No Test 11 ! dt IIIA -:Drug Use 01 1. Yes C•' 012. No 0 013. Unknown I{ 7 VEHICLE INFORMATION 1 `Veh 2 tiflj f y./I :Vehicle Maneuver ( ) ;40' 1. Going Straight Ahead {� :0 2. Making Right Tum O ,01 3. Making Leh Tum 0 QI 4. Making U -Turn pi 6. Slowing or Stopping n (:) 6. Merging Into Traffic lane 0 01 7. Starting From Parked Position C) 0! 8. Stopped in Traffic Lane QI9.Ran Off Road -Right ,Q O: 19.RanOff Road -Left Q QI 11. Parked 0 '0l 12. Backing -Q 0 13. Passing Q O 14. Changing Lanes Q. Q 15. Other 0 'Q 16. Entering Street From Parking Lot r1i- ri) '; Skidding Tire%Maik ---' () 0 U (S) .11 'Q 1. Before Application of Brakes i ,Q 2. After Application of Brakes r •0 3. Before and After appiication o1 Brakes I ;C•101 4. No Visible Skid Mark/Tire Mark .1 ..r+1 "I ,Vehiae:Body Type ' (S) :lel 1. Passenger car 0 01 2. Truck - Pick•up/PassengerTruck i Q1 3. Van Q Oj 4. Truck - Single Unit Truck (2•Axles) 0 'O 7. Motor Home, Recreational Vehicle (D 0j 8. Special Vehicle - Oversized I Vehicle/EarthmoveeRoadEquipment 9. Bicycle 0 0 10. Moped C) 0 11. Motorcycle e7 ;Of 12. Emergency Vehicle 1 (Regardless of Vehicle Type) C.) '0; 13. Bus -School Bus 0 Oi 14. Bus- City Transit BuslPrivatety Owned Church Bus 0 0; 15. Bus - Commercial Bus 0 :01 16. Other (Scooter, Go-cart, Hearse, Bookmobile, Golf Carl, etc. O !• Q 18. Special Vehicle • Farm Machinery 0 al 19. Special Vehicle - ATV 'C) 1Q1 21. Special Vehicle - Low -Speed Vehicle (� !(J; 22 Truck • Sport Utility Vehicle (SUV) 0 ,O; 23. Truck • Single Unit Truck 1 (3 Axles or More) t O .Q, 25. Truck • Toles *Nacos (Bobtallo Indio) I -�V f 11121 rvfl/ r1lA'; Vehicle Damage } `';.v4 � (2)! ` 1. Unknown Q ;Qii 1• i 2. No damage t;)EIOi 3. Overturned Q Q, 4. Motor C Ci' 5. Undercarriage 6. Totaled l.... i Q Com: 7.Fire c- lei 8. Other (; 1 NlA Condition.-,,',.. I)� (1); 1. No Detects O'r OI 2 Lights Defective CJ' 3. Brakes Defective U' 4. Steering Defective .(D} 0! 5. Puncture/Blowout 01 0 6. Wom or Slick Tires Q! O; 7. Motor Trouble Cif ,Q• 8. Chains In Use c 0: 9. Other ( 3C) 10. Vehicle Altered Q` 11. Mirrors Defective Oi ,Q; 12. Power Train Defective O/ O; 13. Suspension Defective 0 .(71 14. WindowsAVtndshield Detective O; .C)1 15. Wipers Defective OF Q+ 16. Wheels Defective :O, CD; 17. Exhaust System l+{,r SpeciaiFolegn otor.Vehicle ��1); 1. No Special Function (J iQ; 2. Taxi ;0 3. School Bus (Public or Private) 'a .O; 4.TransitBus Y' ( ;01 5. Intercity Bus (D!Q; 6. Charter Bus (J ;a 7. Other Bus O O; 8. witary O 01 9. Pollee 0.1Q 10. Ambulance O `C); 11. Fire Truck 0 ;Q; 12. Tow Truck 01 13. Maintenance O 1 : 14.Unknown ;U, •', 0 EMV in servic ;QI t. Yes 012. No i • I 4,V 'NIM )NIA Truck Cover •Oy Ql i. Yes i pi 2. No • •i i Officer Initials EIK Badge # 300644 Revised Report Commonwealth of Virginia- Department of Motor Vehicles I II II 111111 111111 IIII Pae 3fR300PP(R57/07} Police Crash Re ort g 0 7 0 7 C CRASH Crash IATA DD YYYY MILITARY Time (24 hr clock) County of Crash Date 09 129 12013 0140 FAIRFAX COUNTY 0City of --- Local Case Number I Q Town of 2013-2720025 Location of First Harmful C1 Event Ira Relation to Roadway ciao i. On Roadway Q 2. Shoulder Q 3. Median Q 4. Roadside Q 5. Gore 0 6. Separator CD 7. In Parking Lane or Zone Q 8. off Roadway, Location Unknown Q 9. Outside Right -of -Way Weather Condition (•1) 1. No Adverse Condition (Clear/Cloudy) Q 3. Fog 0 4. Mist Q 5. Rain Q 6. Snow Q 7.SIeeUHe9 O 8.Smoke/Dust Q 9 Other Q 10. Blowing Sand, Soli Dirt, or Snow Q 11. Severe Crosswinds C2 Light Conditions C3: Q 1. Dawn Q 2. Daylight 0 3. Dusk Q 4. Darkness • Road Lighted 1) 5. Darkness - Road Not Lighted Q 6. Darkness • Unknown Road Lighting 0 7.Unknown Traffic Control Device C4 O 1.Yes -Working (7 2. Yes - Working and Obscured Q 3. Yes • Not Working Q 4. Yes - Not Working end Obscured Q 6. Yes • Missing Q 6. No Traffic Control Device Present CRASH INFORMATION Traffic Control Type C5 0 O 0 O 0 0 0 O 0 O O 0 0 0 0 O 1. No Trait lc Control 2. Officer or Flogger 3. Traffic Signal 4. Stop Sign 5. Slow or Warning Sign 6. Traffic Lanes Marked 7. No Passing Lines 8. Yield Sign 9. One Way Road or Street 10. Railroad Crossing With Markings and Signs 11. Railroad Crossing With Signals 12. Railroad Crossing W1h Gate and Signals 13. Other 14. Pedestrian Crosswalk 15. Reduced Speed - School Zone 16. Reduced Speed • Work Zone 17. Highway Safety Corridor 'Roadway Alignment C6 (♦) 0 O (ID O O 0 O 0 0 1. Straight - Level 2. Curve - Level 3. Grade - Straight 4. Grade - Curve 5. Hi9crest • Straight 6. Merest • Curve 7. Dip • Straight 8. Dip- Curve 9.Other 10.On/Off Ramp Roadway Surface Condition ap--) 1. Dry Q 2. Wet O 3. Snowy O 4.Icy Q 5. Muddy Q 6.Oil/Other fluids Q 7.Other Q 8. Natural Debris Q 9. Water(Standing, Moving) Q 10. Slush Q 11, Sand, blit, Gravel C7 Roadway Surface Type 0 1. Concrete 2. Blacktop, Asphalt, Bituminous Q 3. Brick orBieck (D 4. Slag, Gravel, Stone Q 5. Dirt 0 6.Other CB Roadway Description Q 1. Two -Way, Not Divided ( 2. Two -Way, Divided Unprotected Median Q 3. Two -Way, Divided, Positive Medan Border 0 4. One -Way, Not Divided Q 5. Unknown C9 Roadway Defects C10 t No Defects 2. Holes, Ruts, Bumps 3. Soft or Low Shoulder 4. Under Repair 5. Loose Material 6. Restricted Width 7. Slick Pavement 8. Roadway Obstructed 9. Other 10. Edge Pavement Drop Off Relation to Roadway C11 Interchange Area: 0 1. Main•Line Roadway Q 2. Acceleration/Deceleration Lanes Q 3. Gore Area (Between Ramp and . Highway Edgelines) Q 4. Collector/DIstrbutor Road 0 5.0n Entrance/Exit Ramp Q 6. Intersection at end of Ramp Q 7. Other location not listed above within en interchange area (median, shoulder and roadside) Intersection Area: (44) 8. Non -Intersection Q 9. Within Intersection 10. Intersection•Retated • Within 150' Q 11. Intersection -Related • Outside 150' Other Location: Q 12. Crossover Related Q 13. Driveway, Alley -Access • Related Q 14. Railway Grade Crossing Q 15. Other Crossing (Crossings for Bikes, School, etc.) Intersection Type n 1.1101 et Intersection Q 2.Two Approaches Q 3. Three Approaches Q 4. Four Approaches Q 5. Five -point, or more Q 6. Roundabout C12 Work Zone Q 1. Yes QV 2. No C13 Work Zone Workers Present Q 1. With Law Enforcement Q 2. With No Law Enforcement 0 3. No Workers Present C14 Work Zone Location Q 1. Advance Warning Area Q 2. Transition Area Q 3. Activity Area Q 4. Termination Area C15 Work Zone Type Q 1. Lane Closure Q 2. Lane ShifNCrossover Q 3. Work on Shoutder or Median Q 4.Intennittent or Moving Work Q 5. Other C16 School Zone C17 o 1. Yes Q 2. Yes -With School Activity 010 3.No Type ofCollision. C18 Q 1. Rear End Q 2. Angle ( 3. Head On Q 4. Sideswipe • Same Direction 0 6. Sideswipe - Opposite Direction 0 6. Fixed Object In Road Q 7. Train Q B. Non -Collision Q 9. Fixed object • OH road Q 10. Deer Q 11. Other Animal Q 12. Pedestrian Q 13. Bicyclist o 14. Motorcyclist Q 15. Backed Into Q 16. Other Officer Initials EIK Badge # 300644 Revised Report (OD Commonwealth of Virginia. Department of Motor Vehicles I II II III II 111 I II II Pae 4 300PPf(Rev 7/07) Police Crash Report g 0 7 0 7 0 CRASH Crash Litt DD YYVY MILITARY lime (24 hr clock) Date 09 12912013 0140 [11 ICS Fill In Impact Area(s). Initial Impact, [12_J 12 4D 11 10 9 Q 8 Q 70 0 6 01 0 2 Q 3 04 0 5 Veh Dir of Travel • N/S/E/W WNW Fill In Impact Area(s). Initial Impact. 12 11 Q 10 Q 90 60 7 Q 12 CibD 01 Q 2 0 3 0 4 05 Veh Dir of Travel - N/S/EIW County o Crash o City of FAIRFAX COUNTY Q Town of CRASH DIAGRAM t ROUTE 286 FAIRFAX COUNTY PKWY c»..u..So r 81 .w.estesw RT620 BRADDOCK ROAD SEE ATTACHED DIAGRAM ,Local Case Number 2013-2720025 Indicate North by Arrow Mg Fill In Impact Area(s). Initial Impact. f._J 12 0 0 11 C71 10 0 0 9 Q 13 Q 3 80 - (J 4 7Q l J Q 5 0 Veh Dir of Travel N/S/FJW 0 6 DAMAGE TO PROPERTY OTHER THAN VEHICLES Fill In Impact Area(s)._ Initial Impact 11 © io CDD C..) 80 70 12 O 0 6 0 1 02 03 O4 0 5 Veh Dir of Travel - N/S/EJW Approx. Repair Cost Object Struck (Tree, Fence, etc.) Property Owners Name (last, First, Middle) Address (Street and Number) VDOT Properly Seconii Ther FEven t e k^w �.9- ;�l s 2HaiW114y CY� lto' CRASH DESCRIPTION V2 WAS SOUTH BOUND IN THE LEFT LANE ON RT286 APPROACHING RT 620. TWO VEHICLES WERE SIDE BY SIDE IN FRONT OF V2, WITH 1 IN EACH OF THE 2 SOUTH BOUND LANES. V1 WAS NORTH BOUND IN THE LEFT LANE OF THE SOUTH BOUND LANES OF RT286 APPROACHING THE 3 VEHICLES. THE 2 SOUTHBOUND LEAD VEHICLES SWERVED TO AVOID V1. V1 PASSED IN BETWEEN THEM AND IMMEDIATELY CRASH EVENTS = er cie ' isl: ent Seconii Ther FEven t e k^w �.9- ;�l s 2HaiW114y 20 ,(i1 20 First Harmful Event of Entire Crash that Results in First Injury or Damage. 20 COLLISION WITH FIXED OBJECT 1. Bank Or Ledge 10. Other 2. Trees 11. Jersey Wall 3. Utility Pole 12. Building/Structure 4. Fence Or Post - 13. Curb 5. Guard Rail 14. Ditch 6. Parked Vehicle 15. Other Fixed Object 7. Tunnel, Bridge, Underpass, 10. Other Traff in Barrier Culvert, etc. 17. Traffic Sign Support B. Sign, Traffic Signal 18. Mailbox 9. Impact Cushioning Device Vehicle ll ,FirstEvent J Second Event ` Third Event Fotirth.Event . MostHarmful Event',.: r 1 I 1 Vehicle / First Event 1 Second Event :j Third Event I FourthEvent , Meat HarmfulEvent 1 COLLISION WITH PERSON, OR NON -FIXED OBJECT 19. Pedestrian 20. Motor Vehicle In Transport 21.Train 22. Bicycle 23. Animal MOTOR VEHICLE 24. Work Zone Maintenance Equipment 25. Other Movable Object 26. Unknown Movable Object 27. Other NON -COLLISION 28. Ran ON Road 29. Jack Knife 30. Overturn (Rollover) 31, Downhill Runaway 32. Cargo Loss or Shift 33. Explosion or Fire 34. Separation of Units 35. Cross Median 36. Cross Centerline 37. Equipment Failure(Tire, etc.) 38. Immersion 39. Fetl/Jumped From Vehicle 40. Thrown or Falling Object 41. Non -Collision Unknown 42. Other Non -Collision 'Revised Report 40 ommonweailn or virgmla• vepanmenr or motor venlcies Police Crash Report 1-1-13001-' (Hey 7/07) Page 5 of 5 CRASH GPS Lat. 00.0000000000000 GPS Long. 00.0000000000000 Crash 1.11.1 DD 'YYYY- ' "Day of Week ' Date 09 129 [2013 JSUN MILITARY Time (24 hr clock) 0140 County of Crash FAIRFAX COUNTY Official DMV Use C) City of City or Town Name CQ Town of Landmarks al Scene NONE Location of Crash (route/street) RT286 FAIRFAX COUNT PW Railroad Crossing ID no. (if within 15011.) Local Case Number 2013-2720025 N S E W Location of Crash (routelstreet) O At intersection With or 500 O Miles Ei Feet *)C,.� OC' of RT620 BRADDOCK RD Mile Marker Number , Number of Vehicles 002 Crash description (continued) STRUCK V2, WHICH HAD ATTEMPTED TO SWERVE TO AVOID IMPACT. THE DRIVER OF V1 DIED AT THE SCENE. //// JANUARY 2014 REVISION: THE TOXICOLOGY REPORT FROM THE MEDICAL EXAMINER'S OFFICE SHOWS DRIVER #1 WAS INTOXICATED. Fairfax County Police Fatal Crash Lncident Date: September 29, 2013 Location: Fairfax County Pw/ Braddock Rd Case Number 20132720025 Drawn By Date Drawn Scale Detective E. Keevill October 21 , 2013 1" = 24.24' • ROUTE 286 FAIRFAX COUNTY PKWY Grass Median --------)6 ..,- Vi (-.- :( V2 Paved Shoulder 6 RT620 BRADDOCK ROAD EXHIBIT C TRAVELERS J Automobile Policy Continuation Declarations 1. Named Insured BHARATH KASIREDDY AND MRUDULA DULAM 416 MEADOW DR CAMP HILL PA 170111227 Your Policy Number 990947004 101 1 Your Account Number 990947004 Your Service Center Address KNOXVILLE BUSINESS CENTER P 0 BOX 59059 KNOXVILLE TN 379509059 For Policy Service Call 1.800.842.5075 For Claim Service Call 1.800.CLAIM33 2. Premium Your Total Premium for the Policy Period is $452.00. The policy period is from May 21, 2013 to November 21, 2013. 3. Your Vehicles 1. 2002 TOYOT AVALON XL/ 2. 2013 HONDA ODYSSEY EX Identification Numbers 4T1BF28B72U254854 5FNRL5H67DB032875 4. Coverages, Limits of Liability and Premiums Insurance is provided only where a premium is shown for the coverage. *IF COLLISION COVERAGE IS PROVIDED UNDER THIS POLICY, COVERAGE EXTENDS TO VEHICLES WHICH YOU RENT FOR 30 DAYS UNDER A RENTAL CAR COVERAGE AGREEMENT. PLEASE REMEMBER THAT COLLISION COVERAGE DOES NOT PAY FOR LOSS OF USE. PLEASE CONTACT YOUR TRAVELERS AGENT OR REPRESENTATIVE IF YOU HAVE QUESTIONS. IF YOU DO NOT CARRY COLLISION INSURANCE, THIS POLICY DOES NOT PAY FOR DAMAGE TO RENTAL VEHICLES. A. Bodily Injury $100,000 each person $300,000 each accident VEHICLE 1 VEHICLE 2 02 TOYOT 13 HONDA AVALON XL/ ODYSSEY EX $ 32 $ 29 B. Property Damage $100,000 each accident $ 45 $ 50 Continued on next page 010/0M1994 PL -7782 Rev. 08-07 Page 1 of 5 000798/00084 F3115CHM 7857 04/22/13 TRAVELERS J 4. Coverages, Limits of Liability and Premiums (continued) 02 TOYOT 13 HONDA AVALON XL/ ODYSSEY EX D7. Uninsured Motorists (Bodily Injury) Non -Stacked $100,000 each person $ 4 $ 4 $300,000 each accident See Endorsement A37043 D9. Underinsured Motorists (Bodily Injury) Non -Stacked $100,000 each person $ 15 $ 15 $300,000 each accident See Endorsement A37043 E. Collision Actual Cash Value less $ 49 $ 80 $500 deductible Auto Loan/Lease Coverage $ 4 See Endorsement A00400 F. Comprehensive (Other than Collision) Actual Cash Value less $ 29 $ 50 $100 deductible Auto Loan/Lease Coverage $ 2 See Endorsement A00400 G. Extended Transportation Expense $30 per day/$900 maximum $ 10 $ 10 I. Towing and Labor Costs $200 per disablement $ 5 $ 5 QA. First Party Benefits Coverage Limited Tort Option $ 7 $ 7 See Endorsement A37021 Subtotals for your vehicles $ 196 $ 256 Continued on next page 010/0M1994 PL -7782 Rev. 08-07 Page 2 of 5 Named Insured Policy Number Policy Period Issued On Date BHARATH KASIREDDY AND MRUDULA DULAM 990947004 101 1 May 21, 2013 to November 21, 2013. April 22, 2013 TRAVELERS J 4. Coverages, Limits of Liability and Premiums (continued) Total Premium for This Policy: 452 5. Information Used to Rate Your Policy Discounts and Advantages Safe Driver Advantage. Early Quote Advantage Paid in Full Discount Travelers Renters Customer Multiple Cars on Policy New Car Discount Anti -Theft Discount Passive Restraint Discount Drivers 1. BHARATH 2. MRUDULA Vehicles 1. 02 TOYOT AVALON XL/ 2. 13 HONDA ODYSSEY EX 13 HONDA ODYSSEY EX 13 HONDA ODYSSEY EX 02 TOYOT AVALON XL/ DATE OF BIRTH 08-17-78 04-02-84 USE OF VEHICLE Commute Commute 13 HONDA ODYSSEY EX SEX MARITAL STATUS Male Married Female Married LOCATION OF VEHICLE CAMP HILL PA CAMP HILL PA Continued on next page 010/0M1994 PL -7782 Rev. 08-07 Page 3 of 5 000799/00084 F3115CHM 7857 04/22/13 TRAVELERS J 5. Information Used to Rate Your Policy (continued) It is important that the above information is correct to ensure that your policy is properly rated. If there are errors or changes to this information, please notify your Travelers representative immediately. 6. Other Information Accident Forgiveness helps keep your rates from going up just because of an accident. Your policy is not yet eligible for Accident Forgiveness. To qualify*, you must have Travelers auto insurance for 4 years and your policy must be free of accidents and violations for 5 years. * Eligibility and qualification may vary by state. Loss Payees 13 HONDA ODYSSEY EX VIN # 5FNRL5H67DB032875 AMERICAN HONDA FINANCE CORP PO BOX 650200 HUNT VALLEY,MD 210650200 Your Insurer TRAVCO Insurance Company 6081 East 82nd St, Indianapolis, Indiana 46250 One Tower Square, Hartford, CT 06183 Policy Endorsements A37013 Amendment of Policy Provisions - Pennsylvania A37021 First Party Benefits Coverage - Pennsylvania A37043 Uninsured/Underinsured Motorists Endorsement - Pennsylvania A00400 Auto Loan/Lease Coverage Policy Edition 8 Policy Form 101 Issued on 04/22/13 Thank you for insuring with Travelers. We appreciate your business. If you have any questions about your insurance, please contact your Travelers representative. Continued on next page 010/0M1994 PL -7782 Rev. 08-07 Page 4 of 5 ti Named Insured Policy Number Policy Period Issued On Date BHARATH KASIREDDY AND MRUDULA DULAM 990947004 101 1 May 21, 2013 to November 21, 2013. April 22, 2013 TRAVELERS J FOR YOUR INFORMATION Children & air bags. . . it's as easy as 1 - 2 - 3 1. Never put a child seat (those used with infants) in the front seat of a car with air bags. 2. Make sure all children are buckled up no matter where they sit. Unbuckled children can be hurt or killed by an air bag. 3. The rear seat (those with seat belts) is the safest place for children of any age to ride. For information about how Travelers compensates independent agents and brokers, please visit www.Travelers.com or call our toll free telephone number 1-866-904-8348. You may also request a written copy from Marketing at One Tower Square, 2GSA, Hartford, Connecticut 06183. YOU MAY PURCHASE UNINSURED AND/OR UNDERINSURED MOTORISTS COVERAGE AT ANY AVAILABLE LIMITS FROM $15,0001$30,000 UP TO YOUR BODILY INJURY LIABILITY LIMITS. YOU MAY REJECT THESE COVERAGES ENTIRELY. 010/0M1994 PL -7782 Rev. 08-07 Page 5 of 5 000800/00084 F3115CHM 7857 04/22/13 sf'7f v IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA DIVISION IN RE: Estate of BABY -GIRL DULAM- :,� KASIREDDY, Deceased Na: U AND NOW, this day of , 2014, upon consideration of the attached Uncontested Petition to Settle Wrongful Death and Survival Actions, it is hereby ORDERED and DECREED that Petitioners are authorized to enter into a settlement with Travco Insurance Company in the gross sum of $100,000 for Underinsured Motorist Benefits. It is further ORDERED AND DECREED and that the settlement proceeds shall be distributed as follows: GROSS SETTLEMENT: $ 100,000 Wrongful Death (100%) $ 100,000 Survival Action (0%) $ 0 The Wrongful Death Action shall be paid as follows: To: Bharath Kasireddy and Mrudula Dulam $ 100,000 Approval of this settlement does not affect Petitioners ability to pursue a claim against Abraham Aragon or any other person or entity responsible for the death of Baby Girl Dulam- Kasireddy. >- 0J 4- v.., r- a> --y 1120119L co • ▪ 13-1 sl AY c)... U -'1,3 BY THE Nomas A. Placey Common Pleas Judge J.