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Home My WebLink About05-3177 , William P. Douglas, Esq. Suprwe Court J.D. #37926 Douglas Law Office 27 W. High St. Carlisle, P A 17013 Telephone (717) 243-1790 Laure Giantomenico, guardian ad litem of Joseph Ehman, a minor Petitioners/Plaintiffs IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA vs 05 - 1'71 Civil Term Lisa Ehman Respondent/Defendant OVIL ACTION LAW Praecipe for Writ of Summons Dear Mr. Long: Please issue a writ of summons against the above captioned defendant. Date: June 21, 2005 ~ William P. Dougla , Attorney for pI . ~~ ~ 8:', Y It:' ~, ~d .J;:., ~ " \ ~ ~ 0 ~ -.' (- ~ai N - ~ -(:' - ~,.) C.Jl C["> . , Commonwealth of Pennsylvania County of Cumberland Laure Giantomenico, guardian ad litem of Joseph Elunan, a minor PetitWners/Plaintiffs IN TIlE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA vs 05 - ~ (11 CivilTerm Lisa Elunan Respondent/Defendant CML ACTION LAW Writ of Summons To: Lisa Ehman 304 Gorham Ave. N. Cape May NJ You are hereby notified t hat Laure Giantomenico, guardian ad litem of Joseph Elunan, a minor, has brought an action against you. (J Date: June 21, 2005 For information concerning this writ contact: William P. Douglas, Esq. Douglas Law Office 27 W. High St. Carlisle, P A 17013 (717) 243-1790 LEONARD 1. BOVEY and MURIEL E. BOVEY, Husband and Wife, Plaintiffs : IN THE COURT OF COMMON PLEAS OF : CUMBERLAND COUNTY, PENNSYL VANIA CIVIL ACTION - LAW v. NO. 2003-3177 CIVIL TERM CRAIG BROWN and DAVID CARMINES, : Defendants : JURY TRIAL DEMANDED PRAECIPE TO THE PROTHONOTARY: Please mark the captioned action as discontinued with prejudice. ~- / ate .;, I 'm 5 / ~ <;(. <2 ~ ~~ ~ ~ ,f\\~ il1~,','.. G'> :9.1 'i:tb \ 5 ';Zt.., .p ~~ 'fbt ~ <;i~ L.'J ~ 9>. >1:C, .p "'- ~"'- .' ?> r~ '-" ;:.<. :i. .p - Willimrr P. Dougk13, Esq. 5upreme Courl I.D. #37926 DOugk13 Law Offia 27 W. High 51. Carlisle, PA 17013 Telephone (717) 243-1790 Laure Giantomenico, guardian ad litem of Joseph Ehman, a minor Petitioners/Plaintiffs IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA vs 05 - :3177 Civil Term Lisa Ehman Respondent/Defendant CIVIL ACTION LAW Approval of Minor Settlement Petition for Approval of Minor's Settlement 1. Your Petitioner, Laure Giantomenico, is the natural grandmother and guardian ad litem of Joseph Ehman, a minor, currently residing at 377-7 Kettle Creek Rd., Toms River, New Jersey. 2. The respondent, Lisa Ehman, is an adult individual residing with her son Joseph at 304 Gorham Ave, North Cape May, New Jersey. 4. On January 17, 2004, the minor plaintiff was injured as the result of a one vehicle accident while a passenger in a vehicle being operated by his mother which was covered by a limited tort liability policy issued by Progressive Insurance Company. 5. As a result of the accident which occurred on the aforesaid date the minor child suffered contusions and lacerations and received medical treatment, all of which has been paid for by insurance less an ambulance bill which will be paid from the proceeds hereof. Said ambulance bill is in the amount of $670.00. 6. The minor plaintiff has healed from his injuries and has received no medical treatment since the weeks following the accident. 7. The parties are desirous to conclude this matter and have agreed upon a settlement, as follows: THE PARTIES AGREE AS FOLLOWS: Insurer for Defendant, Progressive Insurance Company, will pay the total sum of $20,670.00, to resolve this matter. 8. All sums set forth above constitute damages on account of personal injuries, arising from the occurrence, within the meaning of S 104(a)(2) of the Internal Revenue Code of 1986, as amended. 9. Counsel for the petitioners have agreed to a reduced fee of twenty-five percent of the recovery in the amount of $5,000.00. WHEREFORE, Petitioners pray that the settlements be ~- ~ William P. Douglas, Esq Attorney for petitioners . . William P. Douglas, Esq. Surmme Court 7.D. #37926 Douglas lJzw 0jJU;e 27 W. High St. Carlisle, P A 17013 Telephone (717) 243-1790 Laure Giantomenico, Gu;rrdian Ad Utem of Joseph Ehman, a minor Petitioners/Plaintiffs IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLV ANlA vs 05 - 3177 Civil Term Usa Ehman Respondent/Defendont OVIL ACTION LAW Approval of Minor Settlement AFFIDAVIT I hereby swear or affirm that the Foregoing is true and correct to the best of my knowledge and/ or information and belief. This is made subject to the penalties of 18 Pa.C.S. 94904 relating to unsworn falsification to authorities. ~ William P. Douglas coo Petitioners Date: September 19,2005 () ..., '= ~ c = -':;-~ cro :"'" en ~~ -',' 6<(: ,..., -0' -0 "'.-. .' "/'1' :B'~ 0~ ~!~' \.D ,-.) r:: i~. ~~ ':t;' -0 '.';;'C; ::l:: !.:::-(~\ )..""C ~ ~ .s::- ~ (.oJ Laure Giantomenico, guardian ad litem of Joseph Elunan, a minor Petitioners/Plaintiffs IN TIlE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA vs RECE!VED S;::P 19 ]OS 05 - 3177 Civil Term r Lisa Ehman Respondent/Defendant CMLACTION LAW Approval of Minor Settlement ORDER AND NO\v, to wit this the /f"day of September, 2005, it is hereby ordered that the minor settlement is approved. The proceeds of the settlement are to be distributed as follows: Laure Giantomenico, guardian ad litem of Joseph Ehman, a minor Douglas Law Office for payment to Duncanon EMS Douglas Law Office $15,000.00 670.00 $5,000.00 The proceeds of the settlement for the minor child are to be deposited in a federally insured savings account and/ or certificate of deposit, marked "Not to be withdrawn until age 18 or further Order of a Court". Joseph Ehman was born on 05-07-98. All sums set forth above constitute damages on account of personal injuries, arising from the occurrence, within the meaning of S 104(a)(2) of the Internal Revenue Code of 1986, as amended. IT IS FURTHER ORDERED that the institution in which said funds are deposited is hereby granted permission to use such income from said funds that is necessary to pay income tax which may become due and payable as a result of the said funds being on deposit in their institution. THE GUARDIANS shall provide a certificate to the Prothonotary setting forth the place of deposit, account number, in compliance with the above provision. By the Court, , / . /II*- J. Ci'~(l!i-o)- ~ ~ J6 William P. Douglas, Esq. Supreme Court 1.D. #37926 Douglas Law Office 27 W. High St. Carlisle, P A 17013 Telephone (717) 243-1790 Laure Giantomenico, guardian ad litem of Joseph Ehman, a minor Petitioners/Plaintiffs IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA vs 05 - 3177 Civil Term Lisa Ehman Respondent/Defendant CIVIL ACTION LAW Approval of Minor Settlement Praecipe to Mark Docket Settled and Discontinued Dear Mr. Long: Please mark the above captioned matter settled and discontinued. \'J~Q William P. Dougla Counsel for PI date: September 20, 2005 '.J(j.-' ~):' ~;~.:~ r: .<- "'-;-;' ~~'{~~ ):"'"c ~~~ ..< (") ~ ,..., = = en (/) 01 -U N o ~ -I X,:!J n,..- "om -uc? ,:)(~ :"t-ri ''1:0 ~.:;.o 01""11 -, 55 =< :l:~ :x Sl ~ <:D