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HomeMy WebLinkAbout14-2837THE PROTHONOTARY RY 2O1aMAY -`9 WMM.57 CUMBERLAND COUNTY PENNSYLVANIA ANGINO & ROVNER, P.C. Richard C. Angino, Esquire Attorney 1D# : 07140 4503 North Front Street Harrisburg, PA 17110-1708 (717) 238-6791 FAX (717) 238-5610 Attorneys for Plaintiff(s) E-mail: rca@angino-rovner.com IN RE: BRIAN Q. YUEN AND JUDY X. CHUI-YUEN, INDIVIDUALLY AND AS PARENTS AND NATURAL GUARDIANS OF JUSTIN YUEN, a minor IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA NO. /K'g37 C/� 7e741 PETITION FOR COURT APPROVAL OF A COMPROMISED SETTLEMENT AND THE DISTRIBUTION OF PROCEEDS ON BEHALF OF MINOR PETITIONER JUSTIN YUEN, BY AND THROUGH HIS PARENTS AND NATURAL GUARDIANS, BRIAN Q. YUEN AND JUDY X. CHUI-YUEN, PURSUANT TO Pa.R.C.P. 2039 The Petitioners respectfully represent: 1. Justin Yuen is a minor having been born on August 26, 1999, is currently a freshman in high school, and resides with his parents at 15 Imperial Court, Carlisle, Cumberland County, PA 17013. 2. On November 28, 2012, Justin Yuen was burned when his science teacher, James Reddington, was conducting an experiment involving burning alcohol. See Carlisle Fire Department Report of Incident dated December 7, 2012, attached as Exhibit A. / 0 3 7 -5- /0°M./ -6f 549485 1 C / 9,290e A_3os-6 V7 3. As a result of being burned in the science experiment, Justin was taken by helicopter to Johns Hopkins Hospital in Baltimore, Maryland'. See Exhibit B Life Lion Flight Request printout. Thereafter, Justin came under the care of Bernard A. Cohen, M.D. See Report of January 8, 2014, attached as Exhibit C. 4. Justin's medical bills have been paid by a combination of insurance and out-of- pocket ut-ofpocket expenses paid by the Carlisle Area School District and the Blue Cross/Blue Shield of Illinois has a subrogation lien of $18,562.19 attached hereto as Exhibit D. Richard C. Angino, Esquire, of Angino & Rovner, P.C. (now Angino & Lutz, P.C.) was successful in obtaining a reduction in the $18,562.19 subrogation 'lien of Blue Cross/Blue Shield of Illinois to $13,000. Exhibit E. 5. A Mediation was conducted from 9:30 a.m. until 5:00 p.m. on March 13, 2014, before Mediator David Lehman. 6. As a result of the Mediation, all claims,were settled as follows: a. $130,000 to be paid by the Carlisle Area School District on behalf of Justin's claims; 7. The Carlisle Area School District agreed to pay an additional $2,000.00 to assist Mr. and Mrs. Yuenwith their out-of-pocket expenses that they anticipate will be incurred between the present time and when Justin reaches the age of 18. 8. Brian Q. Yuen and Judy X. Chui-Yuen, individually and as parents and natural guardians of Justin Yuen, a minor signed a Settlement Agreement and General Release which releases as per the Release, the CARLISLE AREA SCHOOL DISTRICT, ITS PRESENT AND PAST OFFICERS, DIRECTORS, STOCKHOLDERS, EMPLOYEES, TEACHERS, 549485 2 AGENTS, SERVANTS,.. ATTORNEYS, ASSIGNS, AFFILIATES, SUBSIDIARIES, INSURERS, SPECIFICALLY INDEMNITY INSURANCE COMPANY OF NORTH AMERICA AND SCHOOL CLAIMS SERVICE, AND ANY AND ALL OTHER PERSONS, FIRMS, AND/OR CORPORATIONS IN WHICH ANY OR ALL OF THEM MIGHT HAVE AN INTEREST. Exhibit F. 9. Justin has a permanent scar as shown by photographs attached hereto as Exhibit G. It is anticipated that future revisions and perhaps some plastic surgery after Justin reaches the age of 18 will improve the present appearance of the scar. 10. Since the case involves a municipality there are sovereign immunity issues that make any recovery problematic. 11. The settlement, therefore, is an excellent result considering the sovereign immunity issues. 12. Richard C. Angino, Esquire of Angino & Rovner, P.C. was retained by Justin's parents under a Power of Attorney which provides for a 30% fee plus expenses if the case is resolved before litigation. See Power of Attorney attached hereto as Exhibit H. 13. Considering the considerable time that was spent by the Angino & Rovner law firm, the fact that the case was on the verge of filing a Complaint, considering the difficulty in surmounting the sovereign immunity issues, and the excellent result, Plaintiffs' counsel Angino & Rovner, P.C. is requesting the approval of the 30% contracted fee plus expenses. 14. Under the Angino & Rovner, P.C. Power of Attorney, Angino & Rovner, P.C. is entitled to 30% of $130,000 or $39,000 as a fee. 15. Expenses incurred are $1,283.30. A breakdown of costs and expenses is attached as Exhibit I. 549485 16. Petitioners request approval of the settlement of the claims of Justin and his parents as follows: a. The form of the Release for the $130,000 settlement amount plus the $2,000 to assist Justin's parents, Brian Q. Yuen and Judy X. Chui-Yuen in their out-of-pocket expenses until Justin reaches the age of 18. b. $130,000 less 30% attorneys' fees of $39,000 less expenses of $1,283.30, less escrow reimbursement of Blue Cross/Blue Shield of Illinois subrogation lien of $13,000 or $76,716.70 to be invested in an approved trust investment, such as a Certificate of Deposit, savings account, etc: under the terms and conditions that the entire amount plus interest will be paid to Justin when he reaches the age of 18 years. c. Pursuant to local Rule 12.5-3(b): the Court directs that any cash be deposited in an interest bearing account in such depository in the name of Justin Yuen or the name of Brian Q. Yuen and Judy X. Chui-Yuen, as parents and natural guardians of Justin Yuen, subject to the express restriction, to be noted on the records of the depository, that no withdrawals may made from such account until the minor attains the age of majority, except as authorized by prior order of the Court, with the further requirement that evidence of the marking of such account to indicate the restriction be promptly filed of record. d. $2,000 will be paid to Brian Q. Yuen and Judy X. Chui- Yuen without paying any fee or expenses to assist them with their out-of-pocket expenses until Justin reaches the age of 18. e. Petitioners' counsel shall pay to Blue Cross/Blue Shield of Illinois $13,000. f. All monies shall be distributed in accordance with the Distribution Sheet attached as Exhibit J and K. WHEREFORE, the Petitioners request that the Court approve the settlement offer of $130,000 as described above. 549485 Dated: May , 2014 549485 ANG I►, •1& ROVNE chard C. A. f gino, Esquire PA I.D. ► o, 07140 4503 Fr o nt Street Harr' "bur_, PA 17110 (7 ) 238-6791 — phone 38-5610 — fax angino-rovner.com Attorney for Plaintiffs/Petitioners PETITIONERS' :;COUNSEL'S,CERTI.F, ICATE - I, Richard C. Angino, Esquire, Petitioners' counsel, do hereby affirm that the proposed settlement of $130,000 for Justin Yuen, in my professional opinion, is in the best interest of Justin. If Justin's case were presented to a jury, the attorney's fees and expenses would increase and the jury award could be less than the settlement offer made. ANGINO VNE 4gino, Es • I ire A I.D. N 07140 4503 N. ont Stre Harrisbfrg, P A . 7110 (717) 2 8 r7 ° 1 — phone (717) 238-5610 — fax rca@angino-rovner.com Attorney for Plaintiffs/Petitioners Date: May . , 2014 549485 VERIFICATION We, Brian Q. Yuen and Judy X. Chui-Yuen, father and mother and natural guardians of Justin Yuen, a minor, hereby verify that the facts set forth in the foregoing PETITION are true and correct to the best of our knowledge, information, and belief. We understand that any false statements therein are made subject to the penalties of 18 Pa.C.S.A. §4904, relating to unsworn falsification to authorities. al ---411. willilliri WitDetii Witness Date: �'� t 1 549485 CERTIFICATE OF SERVICE I, Gwen Baughman, an employee of the law firm of Angino & Rovner, P.C., do hereby certify that I am this day serving a true and correct copy of the PETITION FOR COURT APPROVAL OF A COMPROMISED SETTLEMENT AND THE DISTRIBUTION OF PROCEEDS ON BEHALF OF MINOR PETITIONER JUSTIN YUEN, BY AND THROUGH HIS PARENTS AND NATURAL GUARDIANS, BRIAN Q. YUEN AND JUDY X. CHUI- YUEN, PURSUANT TO Pa.R.C.P. 2039 upon all counsel of record via postage prepaid first class United States mail addressed as follows: L Roeg Williamson, JD, CCM Senior Litigation Analyst School Claims Service P.O. Box 814 New Cumberland, PA 17070-0814. Timothy J. McMahon, Esq. Marshall, Dennehey, Warner, Coleman & Goggin 100 Corporate Center Drive, Ste. 201 Camp Hill, PA 17011 Dated: May 9, 2014 549485 • EXHIBIT A EXHIBIT A Carlisle Fire Department From: John Heberlig Fire Chief: Carlisle Fire & Rescue Services 177 Carlisle Springs Road Carlisle, Pa 17013 Date of incident: November 28th 2012 December 7 2012 As I have stated in my first report on what we have thought took place and how the fire got started on December 4th 2012 this will be our final report of the investigation of the Wilson Middle School Incident. With some interviews with some Students, Principle, Photos, and the direction of the fire and other information we gathered that day at the school. On Wednesday December 5th 2012 at 2:15pm I went to the school to have a meeting with Mr. Redington (Teacher), Colleen Friend (Principle), Jim Flower (Solicitor) , and a representative from the teachers Union. I received a written statement from Mr. Reddington on what he did in the fourth period class and asked him a few questions and explain at this point what we thought took place and how the incident happened and why. Mr. Reddington could answer a few of my questions but some he was not sure of. Below I will state with talking to Mr. Reddington and the information we have on what we feel happen. We have confirmed that Mr. Reddington did do two demonstrations in Science Room 87. The first demonstration he poured Isopropyl Alcohol onto Desk 17 from my diagram and used a match to start the fire. Once the fire was lit and he showed the kids the fire was out. Some students asked if you poured the Alcohol in the beaker if it would explode. He then explain why it would not as you will see in his statement. At this point he then put some 99% Isopropyl Alcohol from the plastic bottle that you can see on picture 5-1 marked 91 % Isopropyl Alcohol into a beaker. He added very little to show the students that it would not explode the beaker. He then lit a fire in the beaker to show the students that the beaker would not explode and it DID NOT once he got it lit. A student then ask him what would happen if you poured more of the 99% Isopropyl Alcohol in the beaker with a flame. Mr. Reddington did not answer the student / students to me in his statement he said to himself (when I poured rubbing alcohol into the beaker I expected it to extinguish the flames by smothering the small surface area. instead, the fire followed the stream of rubbing alcohol up into the bottle, igniting the contents inside and propelling flames outward into the classroom.) He also stated (I did not intend for anything to happen other then extinguishing the flames and if I had thought there was any chance that it might do anything other than that, I would not have done it.) 0 With a few things he has said in his statement and with what I know and what I have printed off about and gave to the Solicitor about 99% Isopropyl Alcohol and what the flash points are and some other things to look out for. 99% Isopropyl Alcohol is a Flammable Liquid with a flash point of 12 degrees C (53 degrees F). With that and when Mr. Reddington poured more Alcohol that would cause a flash and not put the fire out like he thought it would do. There are a few things that will put out Alcohol fires and they are, Dry Chemical, which is what he used to put out the fire, and Alcohol- Resistant Foam. And as far as the fire following the stream of Alcohol up and into the bottle of Alcohol I do not think that is what happened if it did the plastic bottle would have either exploded or caught on fire and there was no damage to the bottle that he was using to pour from. Also there would have been a flash fire when it got to the bottle of alcohol and Mr. Redington should of got burnt as well. When I had a meeting with Mr. Redington he said the only injury he got was a small cut or burn on his one finger as he showed me the day we met. I just have a concern by the way he stated a few things and it sounded like he was saying it to himself. And with the alcohol he was using he should of known it was flammable and what the flash point was and know adding more alcohol would not put out the fire cause of the heat plus the flame that was still in the beaker. He also did not say if he has done this before and that is adding Alcohol to a beaker that has a flame or any heat in it if he has in the past I would think he would have stated that he did. I just feel that he was not sure what would happen before he did it. I feel with our statements we got from the three students, pictures, information we have printed off the Internet about the about 99% Isopropyl Alcohol and with Mr. Redington statement I feel we have taken our time with everything and did not rush to come up with the cause and what happen and how the students got burnt. I know Mr. Reddington did not mean to do any damage or hurt anyone while doing his demonstration but below is what we have come up with. Mr. Reddington was doing two demonstration and they took place in the back of the room on desk 17. Mr. Reddington poured some alcohol on the desk then used one the matches that was laying on the same desk to light it. Once he showed the students the fire was out. He then poured some alcohol into the beaker that is on the same desk (17) and then used another match to light it. Believed the second match that is on the desk is what he used to Tight the second demonstration with the Beaker. At that point he started to pour more alcohol into the beaker. When Mr. Reddington started to pour the alcohol in the beaker that is when it exploded and caught on fire along with the students. Mr. Reddington then put the fire out on the kids and then put the fire out in the beaker. When Mr. Reddington started to pour the alcohol in the beaker the second time and it exploded he threw his arm that had the container of alcohol in the air because of the flame that shot up out of the beaker and when he did the alcohol came out of the container and went towards all the students. The fire followed the path of the direction of the alcohol when Mr. Reddington threw his arm up. The Spots on some of the desks is from the alcohol falling down and landing on the desk this is why we feel he raised his arm to avoid the fire and the alcohol carne out. Plus with some of the books that were burnt on the sides shows us how the path the fire went. Below I did a diagram and pictures what we found after the incident. 1. The teacher did the demonstration on Desk 17 and Picture 1 2. We found 2 matches on Desk 17 of the diagram and Picture 1 3. Picture 2 is one of the matches that is on desk 17 of the diagram 4. Pictures 3 is the other match that is on desk 17 of the diagram 5. Picture 4 in a shot from the back of the class room in the angle of how the fire burst to the front of the room 6. Pictures 5-1 and 5-2 is the two alcohol containers we found in the back of the room on a counter 7. Picture 6 and desk 14 of the diagram is some books that took some heat from the fire. Also found some spots that is to believed to be alcohol. This desk was in the same row and in front of the desk 17 of the diagram. 8. Picture 7-1 & 7-2 is binders that is on desk 10 of the diagram that took some heat and fire. Picture 7-2 is stuff that dripped from the books on picture 7-1 9- Picture 8 and desk 13 of the diagram has some spots from signs of alcohol and a note pad that was on the desk but got knocked on the floor. 10. Picture 9 is another shot of Desk 17 of the diagram with the beaker. The picture also show spots from signs of alcohol that was thrown in the air and landed on the desk. Along with Dry Cern from the fire extinguisher that put the fire out. 11. Picture 10 is a shot from the front of the room. 12. Pictures 11 & 12 is a sweatshirt and a shirt that was found on the floor in the back of the room by where the alcohol was on the counter. 13. Picture 13 is a shot from the back of the room by the door. The fire extinguisher you see in the picture that is where it was when we went in the room. It was on desk 18 of the diagram. 14. Picture 14 is showing some spots and is signs of alcohol and is desk 14 of the diagram. This is the desk in front of desk 17 which was the desk they did the demonstrations on. 15. Picture 15 is desk 13 of the diagram it is showing spots and is signs of alcohol. And in the top right corner you will see a outline of a book that was there but it is laying on the floor in front of the desk. 16. Picture 16 is the number of the class room that the incident happen in. Carlisle Fire & Rescue Services Fire Chief John H Heberlig 'I T RE• PICTURE 4 1 I PICTURE 3 PICTURE 5-1 PICTURE 5-2 PICTURE 6 P]C ARE 7-1 PICTURE 7-2 PICTURE 8 21•Mglaaft PICTURE 11 PICTURE 12 PICTURE 13 P C"URE 14 S ( a EXHIBIT B Life.Lion Life Lion Division 500 University Drive Hershey, PA 17033 (717)-531-7777 FAX (717) 531-0861 Transport Request: Division: CCT Air- Carlisle Medical Record Number: Yuen, Justin Page lot 4 as Request #: 1211-1243-A Svc Date: 11/28/2012 Type: Helicopter Air- On -scene (Traum Priority: Emergent Dispo: Patient Transported Name: Yuen, Justin Addr: 15 Imperial Court Carlisle, PA 17013 Ph: 717-448-7016 DOB: 08/26/1999 Age: 13 yrs. Sex: M SS: - • Race: Asian / Pacific Islander Next of Kin: Reran -fag Agsvcy I Loszl a Name: Cumberland County Comm Carlisle, PA 17013 @ Scene: LZ 3 Location: Alternate Landing Zone Loc County: Cumberland PA Loc CSZ: CARUSLE, PA 17013 Eii,tTIflis Call Rcvd: 11:32:50 on Notify Pit: 11:33:08 on Wx Confirm:. 11:33:12 Respond: 11:40:33 Ar Liftoff: 11:45:38 Dp Arrive 1: 11:53:00 Depart 1: *12:13:34 Arrive 2: *12:44:00 Depart 2: 13:34:16 Arrive 3: 14:05:00 In Service: 14:05:47 Completed: 14:05:47 on 11/28/2012 11/28/2012 . Bedside: 11:54:00 Bedside: 12:09:00 ReceMnAgency Name: Johns Hopkins Hospital Baltimore, MD 21205 Unit: Emergency Department Rec MD: Personnel I : Crew 1: Wood, Clayton CHW Crew 2: Friel, Daniel DPF Crew 3: Crew 4: Pilot 1: Saida, Joseph Dispatcher: Gingrich, Timothy Elapsed nines (min) Dispatch: 0 Wx Check: 0 Liftoff: 5 Response: 13 Fly to Pt: 7 Fly with Pt: 30 Other Fit: 31 Tot Leg Time: 68 .• On Scene: 21 Bedside: 15 Total Crevv: 145 Aircraft I Went: N611LL Dauphin 65-N2) Mileages I Mock Times 1 , ) 11/28/2012 ., Loaded Miles: 71.1 sm(PtoP); Actual: 71.8 SM Total Miles: 142.3 smMax. Alt: 0 panefir Weight Category and Diagnosis Category: Burns Diagnosis: Burns: Partial Thickness Pt Weight: 35 kg Mechanism: Fire- Flame and Explosion Allergies: NKDA Yuen, Justin Page lot 4 Flight Request Printout - Request #: 1211-1243-A Chief Complaint: right hand pain Date & Time of Injury / Onset: 11/28/2012 11:20 History of Present illness: Initially on standby - subsequently dispatched as a STAT response to a nearby middle school for reported burn victims secondary to an unknown type of explosion/fire. Arrived on scene to be directed towards several EMS units (Cumberland/Goodwill) adjacent to the landing zone. Flight team split crew to triage patients. This trip report pertains to a 13 y.o. = 35 kg male encountered in the rear of an ambulance @ 1154 hrs - Medic 40 in attendance. Report was received from the Paramedics who advise that patient was involved in some type of chemical "flash fire" in the science classroom. Patient further elaborates that "rubbing alcohol" was one of the chemicals involved and that there was a minimal explosion but no flying debris. He denies loss of consciousness and only complains of mild to moderate discomfort from burns in the right hand and tower face. EMS exam was significant for partial thickness burns to the face, neck and right hand. Treatment PTA of flight team consisted of peripheral IV access, and dry dressing application to the right hand. Due to the nature and location of this patients burns, he will be rapidly transported via air medical to the closest regional pediatric burn center (Johns Hopkins). for further evaluation and care. Aid Prior to Arrival: EKG- 3-4 Lead Obtained, Access- Peripheral, Normal Saline Prior Aid performed by: EMS Provider Physical Exam: Assessment @ 11:54:00: ** Skin Assessment: Normal, warm and dry (bums to be described in detail below) total of partial thickness burns estimated © >10% ** Head/Face Assessment: airway is naturally maintained - respirations are regular and non -labored with no audible stridor, cough or harsh voice; visualization of the oropharynx is unremarkable for redness, charring or edema. there is no dysphagia; no fluid drainage is noted from the ears, nose or mouth; partial thickness burns are noted on lips, both ears and patients chin; eyebrows and hairline are singed - nasal hairs are intact; PERL @ 5mm *' Neck Assessment: a small region of partial thickness burns is noted across the anterior neck surface. The trachea is midline and there is no JVD ** Chest/Lungs Assessment: grossly atraumatic with equal chest excursion and clear/equal bilateral breath sounds. ** Heart Assessment: crisp S1/S2; ECG shows ST without ectopy ** Abdomen Left Upper Assessment: grossly atraumatic, soft and non-tender ** Abdomen Left Lower Assessment: grossly atraumatic, soft and non-tender ** Abdomen Right Upper Assessment: grossly atraumatic, soft and non-tender ** Abdomen Right Lower Assessment: grossly atraumatic, soft and non-tender ** GU Assessment: grossly atraumatic ** Back Cervical Assessment: no significant findings ** Back Thoracic Assessment: no significant findings ** Back Lumbar/Sacral Assessment: no significant findings ** Extremities -Right Upper Assessment: grossly atraumatic with exception of reported partial thickness burns to the fingers of the hand - hand Is dressed with gauze; radial pulse 2/3+, neuromotor function intact ** Extremities -Right Lower Assessment: grossly atraumatic; DP pulse 2/3+, neuromotor function intact ** Extremities -Left Upper Assessment: grossly atraumatic; radial pulse 2/3+, neuromotor function intact; patent IV access noted in the LAC via #18 gauge catheter with NSS Infusing @ TKO following a 250 ml bolus. ** Extremities -Left Lower Assessment: grossly atraumatic; DP pulse 2/3+, neuromotor function intact ** Eyes -Left Assessment: 5 -mm, Reactive ** Eyes -Right Assessment: 5 -mm, Reactive ** Mental Status Assessment: Normal - presents In no acute distress and Is resting quietly ** Neurological Assessment: no deficits noted on exam Yuen, Justin Page 2 of 4 Flight Request Printout - Request #:1211-1243-A Past Medical History: no PMH no MEDS Treatment: Introduced staff - report obtained from Medic 40, Obtained tx/transp consent(implied - patient is a minor), Assessed patient, Attached monitors, IVF continued @ TKO rate, Moved patient to litter, Patient covered with blankets/thermal wrap, Patient secured to litter in upright position of comfort, Hearing protection provided via headset, patient transferred to aircraft and secured for flight, transport initiated with continual monitoring . including pain assessment, PRN Morphine administered in flight for pain control with good effect, attempted contact with receiving hospital - unable to establish, patient report relayed via Lifelion dispatch center, arrived JH ECU without Incident. Report given to aimee RN by Wood, Clayton. Lab Values: Vital Signs Time N P R Effort 02 Pain Sedation Notes 1x;58 112t76 110 14 Normal 100% 4 NA 12:10 12:10 118/66 98 16 Normal. 99% 6 MA Sinha Tachycardia 12:25 119/69 100 16 Normal 998 4 NA 12:40 114/68 110 14 Normal 100% 3 NA EVMGCS Vital Assessment Time EKG Temp GCS Score AVP(! RTS Glu Notes 11:55 Since Tachycardia 2 4 5 6 15 A 12 ; Complications: None; Authorization: 12:10 Sinus Rhythm 4'5 6 15 A 12 12:30 Morphine 12:25 Sinha Tachycardia - 4 5 6 15 A 12 12:40 5 u Tachycardia 4 5 6 15 A 12 EVMGCS Time Access Method Who Fluid) Medication IV Fluids and Drip Medications Site Rate Dose Notes Infused Ga. Concentration 11:5 Cal! Access- Infusion Contin Normal Saline Antecubite 50.0 TRO 18.0 ml/hr Complications: None; Authorisation: Protocol (Standing Order) Total ntake (Pre -Transport) 250 (During Transport) 50 Total Output (Pre -Transport) 0 (During Transport) 0 Medications Time Medication Dose Units Route Who Notes 12:15 Morphine 2 auj IV CHH ; Complications: None; Authorization: Protocol (Standing Order) 12:30 Morphine 2 mg IV CHV • ; Complications: None; Authorization: Protocol (Standing Order) Yuen, Justin Page 3 of 4 . Flight Request Printout - Request #: 1211-1243-A "••••,, • Time 12:4 Medication ins Dose Units Medications (Continued) Route Who Notes 2 XV ; Complications: None; Authorization: Protocol (Standing Order) e Procedures and Supplies Qty Sill Who Procedures and Supplies Notes -4 Lead Obtained i S Coif 1 Place EKG Strip Here Electronically signed 11/2812012 18:48:05 SIGNATURES Clayton Wood Daniel P Friel EMT -P CFRN Yuen, Justin Page 4 of 4 EXHIBIT C EXHIBIT C Jan. 10. 2014 8:48AM Kate 13. Puttgen, M.D., Interim Director Bernard A. Cohen, M.D.. Professor, Dermatology & Pediotrics Anna L. qrossberg. Assistant Professor January 8, 2014 Richard C. Angino, squire 4503 North Front Street Harrisburg, PA 17110-1799 Dear Mr. Angino: Pediatric CI ermatalogy 200 N. Wolfe Street / Unit 2107 Baltimore, Maryland 21287 410-955-2043T 410.614-9308 F No. 3075 P. 2 JOH\ S HOPKINS MEDICINE 'Please find attached copies of Justin Yuen's records pertaining to his visits to pediatric dermatology for evaluation of hypertrohpic scars resulting from a burn sustained during a science experiment at school. I will also answer queries that you included in your letter dated November 13. For more specific information regarding visit charges I will have to refer you to Johns Hopkins University Dermatology Billing at 410-933-1200 and Johns Hopkins Hospital Billing at 443-997-0100. • I have seen him during 2 visits in Pediatric Dermatology at the Johns Hopkins Pediatric Outpatient • Center. The initial visit on April 25, 2013 was for evaluation of his burns, and the second visit was to Pediatric Dermatology Laser Clinic for intralesioinal steroids and pulsed dye laser of the scarred areas. Please note the findings related to the scar during his first visit. I will locate images from his first visit if this would help. I expect the scar will improve with treatment and would like to re-evaluate him later this year to assess his response to the first treatment. Further treatment recommendations will depend on his response to the initial treatment. I look forward to working with Justin and his family and will keep you up to date with his progress with , Justin and his parents consent. Sincerely, Ber rd A. Cohen, Professor, Dermatology & Pediatrics EXHIBIT 13 EXHIBIT D ;eptember 16, 2013 R1CHARDANG!NO 5,NG/NO&ROVNBR 4SU3NORTH FRONT STREET HARRISBURG PA 17110 Event ID: Subscriber Name: Patient Name: Subject: of Illinois 8126510 Group Number: 565691 BRIAN YUEN Date of Jnjury or Illness: 11/28/2012 JUSTIN YUEN ¥our Record Data: Important update regarding reimbursement provision for the above -referenced event Dear RICHARD ANGINO: BLUE CROSS BLUE SHIELD OF ILLINOIS is committed to sharing information with you regarding the event referenced above. Therefore, we want to notify you concerning our right of reimbursement and/or subrogation under the above named patient's health care plan. The health care p!an for this patient includes a reimbursement and/or suprovision. If JUSTIN YUEN and/or his or her. dependents has received or will receive an award or settlement for medical expenses resulting from the patlent's injuryur illness that occurred on 11/28/2012, then there is an obligation to reimburse the member's health care plan. That means BLUE CROSS BLUE SHIELD OF ILLINOIS is entitled to recovery of benefits provided to the patient that cover any injury- or illness -related medical expenses. This applies to any payment received, whether by action at law, settlement or otherwise. The total amount of benefits provided as of this date is $18,562.19. Please calI to verify the current amount of benefits prior to sending the total reimbursement payment to the foUowing address: BLUE CROSS 1BLUE SHIELD -OF ILLINOIS 3200 Robbins Road Springfield, IL 62704 Attention: Corporate Reimbursement/Subrogation Any partial payment sent to -t e above addr.ess or any other BLUE CROSS BLUE SHIELD OF ILLINOIS office does not constitute nei ent iyull ansiwill not release the lien. Please acknowledge receipt of this Ietter by s!gning below and retur ing o�cmonejebovaaddress. / .�' u~+"~��" ����/~�/"".�~"~ D If you shoul ave any questions, please contact me at(8OC)582'O418.extension 213O between the hours of 8 a.m. and 5 p.m. Centr -.8"tandard Time, Monday through Friday. Sincerely, ]r wuw�~ ''W._ Jennifer Moore Corporate Reimbursement/Subrogation Service Representative BLUE CROSS BLUE SHIELD OF ILLINOIS 3200 Robbins Road, Springfield, Illiriois 62704.nWW.BCBSILC0M A Division of Health Care Service Corporation, a Mutual Legal Reserve Company, an Independent Licensee ofthe Blue Cross and Blue Shield Association EXHIBIT E EXHIBIT E /'. Fax Server 4/23/2014 3:20:21 PM PAGE 2/005 Fax Server BlueCross B.lueShield of Illinois April 23, 2014 RICHARD ANGINO ANGINO & ROVNER 4503 NORTH FRONT STREET HARRISBURG PA 17110 Event ID: 8126510 Group Number: 555691 Subscriber Name: BRIAN YUEN Date of Injury or Illness: 11/28/2012 Patient Name: JUSTIN YUEN Your Record Data: Dear RICHARD ANGINO: This letter confirms our phone conversation on 04/23/2014 regarding the settlement amount for the above -referenced event number. Per our conversation, BLUE CROSS BLUE SHIELD OF ILLINOIS has agreed to accept $13,000.00 to fulfill the obligation of $18,562.19. Please be advised that we reserve the right to pursue the reimbursement of claims for treatment through this date which have not been submitted and/or included in the obligation. Thank you for your assistance in resolving this matter. If you should have any questions, please contact me at (800) 582-6418, extension 2205, between the hours of 8 a.m. and 5 p.m. Central Standard Time, Monday through Friday. We appreciate the opportunity to serve you. For verification purposes, we ask that you please attach a copy of the attached remittance form with your payment and return to: Health Care Service Corporation 25552 Network Place Chicago, IL 60673-1255 Sincerely, axge4C9'l& tL.. - Allison Suitts Corporate Reimbursement/Subrogation Service Representative BLUE CROSS BLUE SHIELD OF ILLINOIS Enclosure: Remittance Form 3200 Robbins Road, Springfield, Illinois 62704. WWW.BCBSIL.COM A Division of Health Care Service Corporation, a Mutual Legal Reserve Company, an Independent Licensee of the Blue Cross and Blue Shield Association EXHIBIT F EXHIBIT F SETTLEMENT AGREEMENT AND GENERAL RELEASE This Release and Settlement Agreement (hereinafter referred to as "Release") is made and entered into between BRIAN YUEN and JUDY CHUI-YUEN, on behalf of themselves and on behalf of their minor son, JUSTIN B. YUEN, their heirs, executors, administrators, assigns, insureds, and legal representatives (collectively, the "Releasors") and THE CARLISLE AREA SCHOOL DISTRICT, its present and past officers, directors, stockholders, employees, teachers, agents, servants, attorneys, assigns, affiliates, subsidiaries, insurers, specifically Indemnity Insurance Company of North America and School Claims Service, and any and all other persons, firms, and/or corporations in which any or all of them might have an interest (collectively, the "Releasees"). WHEREAS, Justin B. Yuen was involved in a personal injury incident that occurred on November 28, 2012 at the Wilson Middle School in Carlisle, Pennsylvania as a result of which Justin B. Yuen, through his parents, Brian Yuen and Judy Chui-Yuen, has asserted and/or could assert certain claims for damages arising from the November 28, 2012 incident at the Wilson Middle School in Carlisle, Pennsylvania; and WHEREAS, Brian Yuen and Judy Chui-Yuen, as parents of Justin B. Yuen, have asserted and/or could have asserted claims for money damages arising from the incident that occurred on November 28, 2012 at the Wilson Middle School in Carlisle, Pennsylvania; and WHEREAS, Releasors and Releasees desire to settle all claims that have and/or could have been asserted by Releasors individually, in their own behalf and with respect to Brian Yuen and Judy Chui-Yuen on behalf of their minor son, Justin B. Yuen, together with any and all other 05/1188048.v1 1 matters pertaining to Releasors' claims that have been raised, might have been raised, could be raised, could have been raised, or that might be raised in the future under theories of negligence, Constitutional and/or other statutory based claims and/or any and all other liability or damages claims or any kind or nature. Releasors and Releasees incorporate the foregoing into the following agreement. 1. Settlement and Release Releasors, for and in consideration of the sum of ONE HUNDRED THIRTY TWO THOUSAND AND 00/100 (5132,000.00) DOLLARS, the consideration for which is the release of Releasors' claims for personal physical injuries and/or attorney's fees, if and as applicable, payable by and/or behalf of Releasees hereby forever release and discharge Releasees of and from any and all past, present and future claims, demands, obligations, actions, causes of action, liens, rights, damages, costs, expenses, and compensation of any nature whatsoever, which Releasors now have, or which may hereafter accrue or otherwise be acquired, on account of, or in any way growing out of the November 28, 2012 incident at the Wilson Middle School in Carlisle, Pennsylvania, whether known or unknown, including any claims for interest, costs and fees including attorneys' fees. This Release shall be a fully binding and complete Settlement Agreement between the parties hereto and is a General Release. Releasors further agree to submit promptly a Petition for Court approval of the Compromise of a Minor's cause of action and/or claims and shall provide a copy of the Court Order approving that Minor's Compromise to appropriate representatives of the Carlisle Area School District. 05/1188048,v1 2 2, Full and Final Release It is fully understood and agreed that this Release covers all asserted and potential claims against Releasees, it being the intent of the undersigned Releasors to extinguish fully and forever every and all claims against the Releasees for injuries and/or damages incurred and/or which may be incurred and/or which have been incurred as a direct or indirect result of the incident that occurred on November 28, 2012 at the Wilson Middle School in Carlisle, Pennsylvania, 3. Further or Future Damages Releasors hereby acknowledge, agree, and understand that after the date of this Release, their injuries and/or damages may turn out to be different than they now believe them to be, and that by signing this Release they are accepting that risk and giving up any right to seek further money from, or otherwise to assert any and all claims or demands against the Releasees. 4. Warranty Releasors hereby represent and warrant that they will satisfy all claims and liens that can or may be asserted against the proceeds of this settlement. Releasors further represent, warrant and agree that if any lien or claim is asserted, they will satisfy such lien or claim as asserted, they will satisfy such lien or claim promptly and will indemnify, hold harmless and defend the Releasees from any and all such lien(s) or claim(s). It is expressly warranted by Releasors that any and all medical liens, health care liens, Medicare liens, and any other liens asserted or to be asserted by any person, firm, corporation, or government entity as a result of the provision of any medical care, treatment, or services to Releasors in their lifetimes, will be satisfied by the Releasors out of the settlement proceeds. In 05/1188048,v1 3 no event shall Releasees or any of them bear any responsibility or liability whatsoever for any liens. Additionally, Releasors shall indemnify, defend, and hold harmless, the Releasees from any claims, demands, or suits of any kind from any liens asserted in connection with the November 28, 2012 incident, which occurred at the Wilson Middle School in Carlisle, Pennsylvania. In accordance with the Medicare Secondary Payor Act, the interests of CMS (Centers for Medical Services) have been taken into account and in accordance with the SCHIP Law, no reporting is necessary with regard to this settlement. Further, Releasors agree to fully satisfy, indemnify, and hold Releasees harmless from any and all penalties, liens, conditional payments, fines, demands, and actions in law or in equity, or other payments that may be required if any of the Releasors' representations as to the entitlement or lack thereof of Medicare benefits are in any way misrepresented. S. Payment of Settlement Consideration Releasors hereby agree, acknowledge, instruct, permit and authorize the Releasees to make the aforementioned settlement payment of $132,000.00 through a check made payable to: "Brian Yuen and Judy Chui-Yuen as parents and natural guardians of the minor, Justin B, Yuen and Richard C. Angino, Esquire, their attorney" promptly upon Court approval of the Minor's Compromise. 05/1188048,v 1 4 6. Attorney's Fees Each party hereto shall bear all attorneys' fees and costs arising from the actions of their own counsel in connection with the Complaint, this Settlement Agreement and the matters and documents referred to herein, and all related matters, 7. Warranty of Capacity to Execute Agreement Releasors represent and warrant that no person or entity other than the Releasors have and/or have had any interest in the claims, demands, obligations, or causes of action referred to in this Settlement Agreement and Release, and that they have not sold, assigned, transferred, conveyed, or otherwise disposed of any of the claims, demands, obligations, or causes of action referred to in this Settlement Agreement and Release. S. No Admission of Liability It is understood and agreed by the Releasors and Releasees that this Release is not to be construed as an admission of liability on the part of the Releasees or any of them and that the Releasees expressly deny any liability for any negligence, breach of warranty, breach of contract, or other damage of any kind or nature whatsoever. 9. Informed Decision Releasors acknowledge that they have received the advice of independent counsel of their own choosing, specifically Richard C. Angino, Esquire, and execute this Release as their own free act and deed. 10. Non -Disclosure and Confidentiality Except to the extent required by applicable law, Court Order or subpoena and disclosure to legal tax advisers, Releasors and Releasees further understand and agree that neither they nor 05/1188048,v1 5 their attorneys, agents, servants or other representatives or individuals will in any way publicize or disclose or cause to be publicized or disclosed to any persons, or in any news or communications media, including, but not limited to, legal publications, newspapers, magazines, radio, television and internet pages and/or cites, the fact of and/or terms and/or conditions of this settlement or of the claims from which this settlement arises. Except to the extent required by applicable law, all parties to this Agreement expressly agree to decline comment on any aspect of this settlement, or the claims from which this settlement arises, to any and all individuals and/or members of the news media and/or refrain from engaging any individual or the news media in any such comment, The spirit and intention of this non -disclosure provision is to maintain confidentiality regarding the settlement itself and of the claims from which this settlement arises, This non -disclosure provision is intended to become part of the consideration to both Releasors and Releasees and is integral to the settlement reached between them concerning the claims that Releasors have or could have asserted as a result of and/or arising from the November 28, 2012 incident at the Wilson Middle School in Carlisle, Pennsylvania, Releasees and Releasors acknowledge that no portion of this settlement amount represents consideration for the mutual promise to maintain strict confidentiality of all of the terms of this Agreement. Rather, the Releasees and Releasors expressly have agreed that each other's reciprocal confidentiality covenant is the sole consideration given in exchange for that of the other, 11. Governing Law It is hereby agreed by the parties that this Agreement shall be governed by the Laws of the Commonwealth of Pennsylvania, regardless of any conflict of laws provision requiring reference to the Rules of, decision in and/or laws of another state or sovereign nature, osis 188048,vt 6 12, Entire Agreement and Successors In Interest The terms and conditions contained in this Agreement supersede all prior oral or written understandings between Releasors and Releasees and constitute the entire Agreement between them concerning the subject matter of this Agreement. This Agreement shall not be modified or amended except by a writing signed by all parties. Futher, this Agreement shall be binding upon the executors, administrators, personal representatives, heirs, successors and assigns of each. IN WITNESS WHEREOF, this Agreement has been signed by Releasors, Brian Yuen and Judy Chui-Yuen on behalf of themselves and on behalf of their minor son, Justin B. Yuen. COMMONWEALTH OF PENNSYLVANIA Nctani Seal Gwen, Baughman; Notary Public Susquehanna Twp.. Dauphin County My Commission Expires .34.ine 12, 2017 mEms€R. Pelorsiveaxa A.350:1ATICA OF NOTAiUS 05/1188048,0 7 EXHIBIT G EXHIBIT G H;XHIBIT H POWER OF ATTORNEY AND FEE AGREEMENT BY SIGNING THIS AGREEMENT, I (WE) ACKNOWLEDGE THAT I (WE) HAVE ENGAGED THE LAW FIRM OF ANGINO & ROVNER, P.C. (HEREINAFTER A & R), TO REPRESENT ME (US) UNDER THE FOLLOWING TERMS AND CONDITIONS: A & R may on my (our) behalf secure medical, work and other similar records, conduct an investigation, negotiate, and if necessary start suit against anyone responsible for my (our) injuries and losses with respect to with full power and authority to appear on behalf of the undersigned in any Court of record or in any administrative or other proceeding, to do and perfoi,n all and every act and thing whatsoever that may be requisite and necessary to be done in connection with the above claim as fully as the undersigned might or could do if personally present; hereby ratifying and confirming all that said attorneys shall lawfully do or cause to be done therein by. virtue of this power of attorney: I (we) understand that so long as the case -is handled by an A &R attorney, 'I (we) will riot be responsible for any fees and/or expenses unless a recovery or benefit is obtained. If my (our) case is handled to a successful completion by an A & R attorney, I (we) agree to pay A & R a fee calculated on the total recovery, for time expended, as outlined on the following chart. I (we) also agree to pay A & R all reasonable out-of-pocket expenses without the payment of interest. Once an attorney fee is established based upon work performed to achieve'a settlement or verdict, any additional settlements will be at the same percentage or possibly higher if additional work is performed to achieve the settlement or verdict. If my (our) case was forwarded/referred to A & R by another attorney or law firm, A & R may pay a portion of its fee to forwarding counsel. You will not pay a larger fee because of the fee splitting arrangement. 6. If for any reason I (we) take my (our) case to another attorney or law firm including a former A & R attorney or handle it myself (ourselves), I (we) recognize that A & R has, in good faith, expended money and time for my (our) benefit and I (we) therefore agree to pay, or have my (our) new attorney pay, immediately upon severing the A & R attorney/client relationship, all the out-of-pocket expenses incurred on my (our) case plus interest at the rate of 6% per annum from the date of each expenditure. In addition, when the case is successfully concluded, I (we) agree to pay or to direct my (our) new attorney to pay as a fee 20% of the gross recovery to A & R. 7. If I (we) decide not to pursue my.(our) case contrary to the recommendations of A & R, I (we) agree to pay all out-of-pocket expenses incurred in my (our) case, plus interest at the rate of 6% per annum from the date of each expenditure. 8. In the event that any settlement is made on a structured or deferred payment basis, A & R shall be entitled to receive their percentage based on the present value of the structured settlement, if paid as a lump sum at the time of settlement. 9. If by settlement or operation of law, benefits are to be paid periodically in the future, the attorneys' fee due to Angino & Rovner, P.C., on such benefits will be calculated by taking the present value of such future payments at the time of the award based upon the then existing federal funds discount rate and will be paid in a lump sum to the attorneys at the time of settlement or verdict. I (we) agree not to settle or discuss settlement of my (our) case without the written consent of A & R. 362178 (revised 8/10) 1 A&R ME(Us) a. SETTLEMENT PRIOR TO STARTING SUIT 30% 70% b. SETTLEMENT FOLLOWING SUIT BUT PRIOR TO PRETRIAL CONFERENCE OR APPOINTMENT OF ARBITRATORS FOR ARBITRATION 35% 65% c. SETTLEMENT AT OR AFTER A PRETRIAL CONFERENCE OR SETTLEMENT AFTER THE APPOINTMENT OF ARBITRATORS FOR ARBITRATION; SETTLEMENT OR VERDICT AT TRIAL OR ARBITRATION; SETTLEMENT AFTER TRIAL, ARBITRATION, OR APPEALS. 40% 60% d. [F NO-FAULT RECOVERY OR NON -MONETARY BENEFIT: RICHARD C. ANGINO ($750); NEIL J. ROVNER ($450); ASSOCIATES ($400) PER HOUR BUT NOT TO EXCEED 40% OF TOTAL RECOVERY OF VALUE OF BENEFIT e. OTHER CASES Once an attorney fee is established based upon work performed to achieve'a settlement or verdict, any additional settlements will be at the same percentage or possibly higher if additional work is performed to achieve the settlement or verdict. If my (our) case was forwarded/referred to A & R by another attorney or law firm, A & R may pay a portion of its fee to forwarding counsel. You will not pay a larger fee because of the fee splitting arrangement. 6. If for any reason I (we) take my (our) case to another attorney or law firm including a former A & R attorney or handle it myself (ourselves), I (we) recognize that A & R has, in good faith, expended money and time for my (our) benefit and I (we) therefore agree to pay, or have my (our) new attorney pay, immediately upon severing the A & R attorney/client relationship, all the out-of-pocket expenses incurred on my (our) case plus interest at the rate of 6% per annum from the date of each expenditure. In addition, when the case is successfully concluded, I (we) agree to pay or to direct my (our) new attorney to pay as a fee 20% of the gross recovery to A & R. 7. If I (we) decide not to pursue my.(our) case contrary to the recommendations of A & R, I (we) agree to pay all out-of-pocket expenses incurred in my (our) case, plus interest at the rate of 6% per annum from the date of each expenditure. 8. In the event that any settlement is made on a structured or deferred payment basis, A & R shall be entitled to receive their percentage based on the present value of the structured settlement, if paid as a lump sum at the time of settlement. 9. If by settlement or operation of law, benefits are to be paid periodically in the future, the attorneys' fee due to Angino & Rovner, P.C., on such benefits will be calculated by taking the present value of such future payments at the time of the award based upon the then existing federal funds discount rate and will be paid in a lump sum to the attorneys at the time of settlement or verdict. I (we) agree not to settle or discuss settlement of my (our) case without the written consent of A & R. 362178 (revised 8/10) 1 PLEASE COMPLETE PERSONAL INFORMATION BELOW Receiving Support from Dept of Welfare or Public Assistance (Including Cash) Yes 6)) (circle one) Receiving Medicare/Medicaid Yes(circle one) Medicare # Under child support order? Yes ► s, (circle one) Are you in arrearages with child support? Yes I. • (circle one) Are you currently in bankruptcy? Yes 466z (circle one) Are you currently registered with any on-line information page, such as Facebook, Twitter, My Space, Linked in, etc. 4S> Na (circle one) Do you agree to NOT post any information relative to6 your accident claim and our representation on such sites? No (circle one) (initial) Injured's. Name: -Tustin% , • ytt If Married, Spouse's Name: S1,>' )e- i3Jjt4 V - y/l4V Injured's Social Security Number: If Married, Spouse's Social Security Number: If Married, Spouse's Date of Birth: I U/ / 7 73 Injured's Date of Birth: Address: E -Mail Address: Telephone : Home 7/ 7 cA Sit CO C 2 Work 7/ 7 VIC. 'IC.C.c r Cellular 7/ 7 Se -Ye 7/d r BY SIGNING THIS AGREEMENT, THIS 022 DAY OF jti Y! , 20 13, I (WE) ACKNOWLEDGE THAT I (WE) HAVE READ, UNDERSTOOD, AND RECEIVED A COPY OF SAME AND AGREE WITH ITS TERMS AND CONDITIONS. WITNE (ES): i� (SEAL) I recognize that in order to investigate my claim, Angino & Rovner, P.C., will obtain my medical records and other personal medical information. i understand Angino i Rovner may -disclose my medical information to experts, insurance cairiers, defendants, oilier attorneys and/or other individuals necessary to pursue my case. I have been informed that I have the right to privacy in my medical records under the Health Insurance Portability and Accountability Act, 42 U.S.C. § 1320, et seq. If this Act would be deemed to apply to disclosures made by Angino & Rovner, I hereby waive any rights I may have under the aforementioned Act and hereby hold Angino & Rovner, P.C., harmless for any actions which may be affected by HIPAA or the regulations thereunder. (Client's initials) I understand that Angino & Rovner will retain my file for a period of five years after the conclusion of my case. I further acknowledge that Angino & Rovner will destroy my file at the end of the five year period (personal documents and pictures will be returned to the client). Exceptions to this policy may include cases involving minors, annuities/structured settlements, and worker's compensation cases settled by partial compromise and release. I have no expectation that my file will be retained permanently. (Client's Initials) I (We) acknowledge pursuant to Act 109 of 2006, which became law on July 7, 2006, that a statutory lien has been created by the Pennsylvania Legislature which requires me (us) to provide information concerning any Orders or Agreements to pay child support and any arrearages that may be due at the time of settlement or verdict. I (we) also recognize that the law requires the law firm of Angino and Rovner, P.C. toverify with the Pennsylvania Depai liuent of Public Welfare whether there are any arrearages in my (our) support obligation at the time of settlement. I (we) understand that the law requires my attorney pay the amount of the arrearages to the Pennsylvania State Disbursement Unit prior to distribution to me of the net proceeds of any settlement or award to me in any case where the net proceeds to client exceed $5000.00. I acknowledge that if there are child support arrearages owed at the time of settlement or verdict that it is statutory lien which Angino and Rovner, P.C. must confirm and honor. (Client's Initials) 62178 (revised 8/10) 2 EXHIBIT I EXHIBIT I Angina & Rovner, P.C. ** CASE/ACCOUNTING REGISTER ** PREPARED: 3/18/2014 FILE NUMBER • 13076 CLIENT • YUEN, BRIAN Q. FOR JUSTIN, DATE IN OFFICE • 6/22/2013 TYPE OF CASE M DEFENDANTS) CARLISLE AREA SCHOOL DISTRICT JAMES REDDINGTON ATTORNEY IN CHARGE • RCA FORWARDER REFERRAL SPECIAL NOTE(S) • W-9 BC/BS ILLINOIS LIEN $18,562.19 *** FILE EXPENSES *** PAGE: 1 DESCRIPTION DATE QUANTITY UNIT/PRICE AMOUNT -PERSON INVESTIGATION TIME EXPENSE 8/20/2013 .50 70.00 35.00 MAS INVESTIGATION TIME EXPENSE 8/22/2013 .50 70.00 35.00 MAS EXPENSE TYPE TOTAL: INVESTIGATION TIME EXPENSE 70.00 * DIGITAL C.D./DVD 8/22/2013 6.00 EXPENSE TYPE TOTAL: INVESTIGATION EXPENSE 6.00 * MILEAGE 8/20/2013 23.10 MILEAGE 8/26/2013 23.10 EXPENSE TYPE TOTAL: MILEAGE 46.20 * COLOR PRINTS 8/22/2013 38.00 .50 19.00 EXPENSE TYPE TOTAL: PHOTOCOPIES 19.00 UPS 8/22/2013 52.06 EXPENSE TYPE TOTAL: PUROLATOR 52.06 * SUB -TOTAL 193.26 ** DESCRIPTION CHECK EXPENSES *** DATE CHECK# AMOUNT SUB -TOTAL TOTAL EXPENSES .00 ** 193.26 *** RECEIPTS Angino & Rovner, P.C. ** CASE/ACCOUNTING REGISTER ** PREPARED: 3/18/2014 FILE NUMBER • 13076 PAGE: 2 CLIENT YUEN, BRIAN Q. FOR JUSTIN, RECEIPTS TOTAL .00 *** CUSTOMER NAME * OUTSTANDING INVOICES * INV# INV DATE $BILLED $PAID $DUE OUTSTANDING INVOICE TOTAL .00 *** TOTAL.., 193.26- ** END OF FILE ** 1:41 PM Angino & Rovner 03/18/14 Job Profit Detail January 1, 2013 through March 18, 2014 Type Date Name Account # Source Name Memo Amount Richard Angino Yuen, Brian Q. for Justin, minor Bill 7/11/2013 13076 Bill 9/18/2013 13076 Check 10/29/2013 13076 Bill 11/20/2013 13076 Check 3/7/2014 13076 Check 3/7/2014 13076 Check 3/10/2014 13076 Check 3/10/2014 13076 Bill 3/18/2014 13076 Check 3/18/2014 13076 Check 3/18/2014 13076 Check 3/18/2014 13076 Check 3/18/2014 13076 Check 3/18/2014 13076 Total Yuen, Brian Q. for Justin, minor Total Richard Angino TOTAL Schmidt Kramer, P.C. Healthport 1.0.D„ Inc. Proth of Cumberland County d 14 a cc tfirsi 193,26 f- 390-04 a8ls Lk/NtA.OrAliete4 7 00 - 0 744641 283u N reimb. costs 0.00 -26.82 Faxes - 10/29/2013 -3.00 Johns Hopkins Hosp. -31.03 Faxes -4.00 Inv. Exp. -21.25 Color Prints 9 @ .50 -4.50 Inv. Exp. -42.50 file pet. -103.75 Photocopies -94.75 Postage -16.44 Long Distance -10.00 Photocopies -30.00 Fax -2.00 -390.04 -390.04 -390.04 Page 1 EXHIBIT J EXHIBIT J ANGINO & LUTZ, P.C. RICHARD C. ANGINO RCA@ANGINOLUTZ.COM DAVID L. LUTZ. DLUTZ@Q ANGINOLUTZ.COM BRIAN Q. YUEN AND JUDY X. CHUI-YUEN, INDIVIDUALLY AND AS PARENTS AND NATURAL GUARDIANS OF JUSTIN YUEN, A MINOR v. CARLISLE AREA SCHOOL DISTRICT AND JAMES REDDINGTON DISTRIBUTION SHEET TOTAL AMOUNT OF SETTLEMENT $130,000.00 DEDUCTIONS: Attorney's Fee (30% of $130,000.00) $39,000.00 Balance $91,000.00 Reimbursement of proportionate share of expenses paid by attorneys to others for records, experts, etc. $1,283.30 Balance $89,716.70 Escrow for reimbursement of Blue Cross/Blue Shield of Illinois subrogation lien $13,000.00 BALANCE TO CLIENT PLUS ANY INTEREST EARNED WHILE HELD IN BANK ESCROW $76,716.70 FINAL DIVISION: Attorney's Fee $39,000.00 Client's Balance $76,716.70 Partial Reimbursement of Expenses $1,283.30 Escrow for Reimbursement of BC/BS subrogation $13,000.00 This settlement/verdict may be taxable. We recommend that you consult your accountant or tax attorney for the calculation of your tax liability and any deductions to which you may be entitled. WARRANTY AND NOW, this day of , 2014, we acknowledge that we have read, understood, approved and obtained a copy of this Distribution Sheet. We further acknowledge that the above balance constitutes my total reimbursement for medical expenses, wage losses, pain and suffering and any other losses sustained or claims resulting from our accident. We warrant that if there are any outstanding medical bills, child support arrearages or claims other than as set forth above, they will be our responsibility; we further warrant that we will pay any outstanding Blue Cross, Blue Shield, Public Assistance, Medicare/Medicaid, medical subrogation liens or any other liens and expenses not noted above. WITNESS Brian Q. Yuen WITNESS Judy X. Chui-Yuen 4503 NORTH FRONT STREET HARRISBURG, PA 17110-1799 PHONES (717) 238-6791 FAX. (717) 238-5610 W W W.ANGINOLUTZ.COM EXHIBIT K EXHIBIT K ANGINO & LUTZ, P.C. RICHARD C. ANGINO RCA@ANGINOLUTZ.COM DAVID L. LUTZ DLUTZ@ANGINOLUTZ.COM BRIAN Q. YUEN AND JUDY X. CHUI-YUEN, INDIVIDUALLY AND AS PARENTS AND NATURAL GUARDIANS OF JUSTIN YUEN, A MINOR v. CARLISLE AREA SCHOOL DISTRICT AND JAMES REDDINGTON DISTRIBUTION SHEET TOTAL AMOUNT OF SETTLEMENT $2,000.00 DEDUCTIONS: Attorney's Fee $0.00 Balance $2,000.00 Reimbursement of proportionate share of expenses paid by attorneys to others for records, experts, etc. $0.00 BALANCE TO CLIENT PLUS ANY INTEREST EARNED WHILE HELD IN BANK ESCROW $2,000.00 FINAL DIVISION: Attorney's Fee $0.00 Client's Balance $2,000.00 Partial Reimbursement of Expenses $0.00 This settlement/verdict may be taxable. We recommend that you consult your accountant or tax attorney for the calculation of your tax liability and any deductions to which you may be entitled. WARRANTY AND NOW, this day of , 2014, we acknowledge that we have read, understood, approved and obtained a copy of this Distribution Sheet. We further acknowledge that the above balance constitutes my total reimbursement for medical expenses, wage losses, pain and suffering and any other losses sustained or claims resulting from our accident. We warrant that if there are any outstanding medical bills, child support arrearages or claims other than as set forth above, they will be our responsibility; we further warrant that we will pay any outstanding Blue Cross, Blue Shield, Public Assistance, Medicare/Medicaid, medical subrogation liens or any other liens and expenses not noted above. WITNESS Brian Q. Yuen WITNESS Judy X. Chui-Yuen 4503 NORTH FRONT STREET HARRISBURG, PA 17110-1799 PHONE. (717) 238-6791 FAX. (717) 238-5610 W W W.ANGINOLUTZ.COM 551938 IN RE: BRIAN Q. YUEN AND JUDY X. CHUI-YUEN, INDIVIDUALLY AND AS PARENTS AND NATURAL GUARDIANS OF JUSTIN YUEN, a minor (tountp of pCumbertona IN THE COURT OF COMMON PLEAS OF THE NINTH JUDICIAL DISTRICT 2014-02837 CIVIL TERM IN RE: PETITION FOR COURT APPROVAL OF A COMPROMISED SETTLEMENT AND THE DISTRIBUTION OF PROCEEDS ON BEHALF OF MINOR PETITIONER JUSTIN YUEN, BY AND THROUGH HIS PARENTS AND NATURAL GUARDIANS, BRIAN Q. YUEN AND JUDY X. CHUI-YUEN, PURSUANT TO PA.R.C.P. 2039 ORDER OF COURT po AND NOW, this z2 day of May 2014, upon consideration of Petition for Court Approval of a Compromised Settlement and the Distribution of Proceeds on Behalf of Minor Petitioner Justin Yuen, by and through his father and mother and natural guardians, Brian Q. Yuen and Judy X. Chui-Yuen, and pursuant to Pa.R.C.P. 2039, it is hereby ORDERED that the Petition is GRANTED, subject to the reduction in attorneys' fees as noted below: 1) The form of the Release for the $130,000 settlement amount plus the $2,000 to assist Justin's parents, Brian Q. Yuen and Judy X. Chui-Yuen in their out- of-pocket until Justin reaches the age of eighteen (18); 2) $130,000 less 25% attorneys' fees of $32,500, less expenses of $1,283.30 less escrow reimbursement of Blue Cross/Blue Shield of Illinois subrogration lien of $13,000, or $83,216.70 to be invested in an approved trst investment, such as a Certificate of Deposit, savings account, etc. under the terms and conditions that the entire amount plus interest will be paid to Justin when he reaches the age of eighteen (18) years; 3) Pursuant to local Rule 12.5-3(b): the Court directs that any cash be deposited in an interested bearing account in such depository in the name of Justin Yuen or the name of Brian Q. Yuen and Judy X. Chui-Yuen, as parents and natural guardians of Justin Yuen, subject to the express restriction, to be noted on the records of the depository, that no withdrawals may be made from such account until the minor attains the age of majority, except as authorized by prior order of the Court, with the further requirement that evidence of the marking of such account to indiciate the restriction be promptly filed of record; 4) $2,000 will be paid to Brian Q. Yuen and Judy X. Chui-Yuen without paying any fee or expenses to assist them with their out-of-pocket expenses until Justin reaches the age of eighteen (18); 5) Petitioners' counsel shall pay to Blue Cross/Blue Shield of Illinois $13,000; and 6) All monies shall be distributed in accordance with this Order. B't�TFIE COURT, Thomas Distribution: Richard C. Angino, Esq. L. Roeg Williamson, JD, CCM Timothy J. McMahon, Esq. ' .4 ?ettSem .L(Y QIP $fZ3/'y acey 14V £Z AV�d'iiti F S �D q@� A ANGINO& LUTZ,P.C. Richard C.Angino, Esquire Attorney 1D# : 07140 4503 North Front Street Harrisburg,PA 17110-1708 (717)238-6791 FAX(717)238-5610 Attorney for Plaintiff(s) E-mail:rca@anginolutz.com IN RE: BRIAN Q. YUEN AND JUDY X. IN THE COURT OF COMMON PLEAS OF CHUI-YUEN, INDIVIDUALLY AND AS CUMBERLAND COUNTY, PENNSYLVANIA PARENTS AND NATURAL GUARDIANS OF JUSTIN YUEN, a NO. 2014-2837 minor PROOF OF DEPOSIT OF MINOR'S FUNDS In accordance with Pa. R.C.P. 2039 and this Court's Order of May 22, 2014, approving settlement, Plaintiffs/Petitioners now file proof of deposit. Attached as Exhibit A is a letter and document from Members 1st Federal Credit Union showing the account name of Minor Justin Yuen and the restriction placed on the funds. The savings account and certificate of deposit are frozen until 08/26/2017. ANGI1)0 LUT C. c r C. Angino, Esquire '. D. No. 07140 4503 N. Front Street Harrisburg, PA 17110 (717) 238-6791 —phone (717) 238-5610—fax rca@anginolutz.com Attorney for Plaintiffs/Petitioners Dated: Junes-5 , 2014 553482 1 CERTIFICATE OF SERVICE I, Lisa A. Giknis, an employee of the law firm of Angino & Rovner, P.C., do hereby certify that I am this day serving a true and correct copy of the PROOF OF DEPOSIT OF MINOR'S FUNDS upon all counsel of record via postage prepaid first class United States mail addressed as follows: L Roeg Williamson, JD, CCM Senior Litigation Analyst School Claims Service P.O. Box 814 New Cumberland, PA 17070-0814 Timothy J. McMahon, Esq. Marshall, Dermehey, Warner, Coleman& Goggin 100 Corporate Center Drive, Ste. 201 Camp Hill, PA 17011 Lis A. Giknis Dated: June,2014 549485 A MEMBERS 111 FEDERAL CREDIT UNION 6/11/14 ANGINO &ROVNER, P.C. 4503 NORTH FRONT STREET HARRISBURG, PA 17110 Dear RICHARD C. ANGINO: Re: JUSTIN YUEN Members 1St Federal Credit Union has established an account for Justin Yuen. The funds in the account have been placed in a savings account and certificate of deposit and frozen until 08/26/2017 based on the court order. The enclosed document shows the account name and the restriction placed on those funds. Please contact us for additional assistance. Any questions or further communications should be directed to Gregory P Schank, VP of Branch Operations at 1-800-283-2328, extension 6003. Respectfully, Meg Beaston MSR Walnut Bottom branch enclosure 5000 Louise Drive - P.O.Box O • Mechanicsburg,Pennsylvania 17055 • (800)283-2328 • www.membersIst.org Page 1 of 1 St MEMBERS 1St FEDERAL CREDIT UNION Share/Loan List For Account: 0000563848 JUSTIN YUEN Account Type: Coin Member Ordered Member Type SSN Home Number JUSTIN YUEN Primary *****-3172 717-241-6062 15 IMPERIAL COURT CARLISLE,PA 17013 Share Description Rate Maturity Date Available Balance S0000 REGULAR SAVINGS -$26,193.40 $13,221.70 S 0040 19 MONTH CERT 1.00% 01/0912016 -$140,500.00 $70,000.00 DEPOSIT TOTAL $83,221.70 LOAN TOTAL $0.00 6/11/2014