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ESTATE OF BILLY JACK GLOVER,
Deceased
: IN THE COURT OF COMMON PLeAS
: CUMBERLAND COUNTY, PENNSYLVANIA
: ORPHANS' COURT DIVISION ~.
No. 21-05-0055
PETITION FOR THE APPROVAL OF THE SETTLEMENT OF THE CLAIM
OF THE ESTATE OF BILLY JACK GLOVER. DECEASED
Angela L. Marino, Administratrix of the Estate of Billy Jack Glover, Deceased,
petitions this Honorable Court for approval of the settlement of the Estate's claim for motor
vehicle insurance benefits, and in support thereof avers as follows:
1. Petitioner, Angela L. Marino, is the sister of the decedent and the
Administratrix of his estate under Letters of Administrations issued by the Orphans Court
division of the Cumberland County Court of Common Pleas on January 20, 2005. A true
and correct copy of the letters are attached hereto as Exhibit A.
2. Billy Jack Glover died in an automobile accident on January 6,2005.
3. At the time of his death, Billy Jack Glover did not have a Will and, thus, his
estate will be distributed according to the intestate laws of the Commonwealth of
Pennsylvania.
4. At the time of his death, Billy Jack Glover was insured under a policy of motor
vehicle insurance issued by State Farm Mutual Automobile Insurance Company.
5. Petitioner Marino has applied for Underinsurance Motorist Benefits pursuant
to the provisions of the aforementioned insurance policy.
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6. State Farm has tendered an offer in the amount of Fifteen Thousand
($15,000.00) Dollars, representing the total UIM limits available under the aforementioned
policy. A copy of a letter confirming the extension of the offer and the available limits is
attached as Exhibit B. The Police Accident Report is attached as Exhibit c.
7. At the time of his death, Billy Jack Glover was survived by four adult (4) half-
siblings: Angela L. Marino (DaB 9/5/66); Marc Marino (DaB 4/8/65); Paul Marino (DaB
9/25/63); and Andrew Eitreim (DaB 12/12/80). The decedent was unmarried and had no
children at the time of his death; his parents had predeceased him.
8. The UIM settlement proceeds will pass outside the Estate and be distributed
equally among the four half-siblings identified in Paragraph 7, above.
9. Petitioner has not engaged the services of counsel in this matter.
10. This Petition has been drafted by counsel for State Farm Insurance
Companies, the UIM carrier in this matter, and State Farm concurs in the same.
11. Petitioner respectfully requests this Court to approve the settlement of the
UIM claim as set forth above.
Respectfully submitted,
~,,')~~
Angel . Marino, Ad inistratrix
of the Estate of Billy Jack Glover,
Deceased
and
BOSWEll, TINTNER, PICCOLA & ALFORD
Date: ~/.z.o 105
Brigid a. Alfo ,Esquire
Attorneys for State Farm In rance Companies
STATE OF PENNSYLVANIA
COUNTY OF CUMBERLAND
SHORT CERTIFICATE
I,
GLENDA FARNER STRASBAUGH
Register for the Probate of wills and Granting
Letters of Administration in and for
CUMBERLAND County, do hereby certify that on
the 20th day of January, Two Thousand and Five,
Letters of ADMINISTRA nON
in common form were granted by the Register of
said County, on the
estate of BILL Y JACK GLOVER , late of MIDDLESEX TOWNSHIP
(First, Middle, Last)
in said county, deceased, to ANGELA L MARINO
(First Middle, Last)
and that same has not since been revoked.
IN TESTIMONY WHEREOF, I have hereunto set my hand and affixed the
seal of said office at CARLISLE, PENNSYLVANIA, this 20th day of January
Two Thousand and Five.
File No. 2005-00055
PA File No. 21-05-0055
Date of Death 1/06/2005
S.S. # 504-92-3212
I. Hhnr\JJt<U."-'-f,,~~\-J
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Deputy
EXHIBIT
I-A
NOT VALID WITHOUT ORIGINAL SIGNATURE AND IMPRESSED SEAL
STATI 'ARM
&
State Farm Insurance Companies
June 10, 2005
INSURANCE
e
State Farm Insurance
115 Limekiln Road
New Cumberland PA 17070-0257
Angela Marino
124 Amy Drive
Carlisle, PA 17013-8887
RE: Claim Number:
Date of Loss:
Our Insured:
Dear Ms. Marino:
38-K580-623
December 18, 2004
Billy J Glover
This letter serves to confirm our telephone discussion of May 6,
2005.
We are In a position to offer the $15,000.00 Underinsured
Motorist limits in this matter. We will hire counsel to prepare
the Court Approval.
Sincerely,
Nadine Alviani
Claim Representative
(717) 774-9052
State Farm Mutual Automobile Insurance Company
EXHIBIT
I~
HOME OFFICES: BLOOMINGTON. ILLINOIS 61710-0001
State Farm Insurance Companies
STATE FARM
A
I NSU RANC E
'"
CERTIFICATE OF COVERAGE
State Farm Insurance
11 5 Limekiln Road
New Cumberland PA 17070-0257
Claim Number: 38-K580-623
The undersigned is a Claim Team Manager for:
State Farm County Mutual Insurance Company of Texas
State Farm Lloyds, Inc.
State Farm Indemnity Company
-v'State Farm Mutual Automobile Insurance Company
Z:=State Farm Fire and Casualty Company
This certifies that policy number 0754-201-38 Car 001, covering a
1989 Ford Bronco II, was issued to Billy J Glover and was in
effect on the accident date of December 18, 2004. The coverages
and limits of liability for this policy on that date were:
A 15/30/5, C2 5,000, U-BI 15/30, F 1500, Y 5000, W 15/30
This policy provides Limited tort.
Karen
Claim
State of Pa
) ss.
County of York
Subscribed and sworn to before me this ltrh- day of \\....r(\...S2 ,
(Year) ~
COMMONWEALTH OF PENNSYLVANIA
Notarial Seal
JiB Thompson, Notary PltlIlc
Spring Garden Twp.. YOlk CoI.Ilty
Conimission E' . 2
~~
Notar P tric ~
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My
State Farm Mutual Automobile Insurance Company
HOME OFFICES: BLOOMINGTON, ILLINOIS 61710-0001
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METRO THE P~ISBUR~ AREA POLICE INFO~~TION RESOURCE SYSTEM (CRSIPINC}
PAGS; 1 CRASH REPORT 04/20/05 r<lZCl HD21
CRASH NUMBER: F0004657
INCIDENT NUMBER; 20041207870 HBG
CASE CLOSED: Y
-------------------------------~--------~-------------------------------------
AGENCY:
DISP-TM:
INV-DT:
t1.? P - DT :
COUNTY:
22301 HARRISBURG CITY
0316 ARRV-TM; 0353 PATROL-ZN: 04 PRECINCT:
12-18-2004 INVESTIGATOR: NORDSTROM, MATTHEW A
12-28-2004 REVIEWER: KARLSEN, CLIFFORD A
22 DAUPHIN MUNICIPALITY: 301 HARRISBURG
123 WALNUT ST
BADG: 0041
BADG: 0510
CITY
CRS-DT: 12-18-2004 TM: 0302 #UNIT:
REPORTABLE: Y NOTIF HIWY MAINT: N
SCH BUS RELATED: N
FOLLOW UP: N CITY PROP DAM~ Z
2 #PEOP: 2 #INJ;
PENNDOT PROP; N
SCH ZON RELATED; N
1
#KILL:
1
CRASH DESC: 2
INTERS TYP: 01
REI, TO RDWY: 1 ILLUM: 3 WEATHER: 1 RDWY SURF COND: 0
SPEC LOC: 0 SPEC JURIS: 0 RDWY SURF' TYPE: 2
22 RT#: SEG: #LNS: 05 SPD LIM: 35 ORIENT: W
ELMERTON AV HOUSE#: RT S
22 RT#: . SEG: #LNS; 07 SPD LIM: 35 ORIENT: S
N CAMERON ST RT SIGN: 4
~IILEPOST ; OODG SEG MARKER: OEIENT:
DIST FR CRASH - FT: MI; . 0
MILEPOST: 0000 SEG MARKER: ORIENT:
P;?INC RD - CNTY:
STR NM:
INSEC RD - CNTY:
STR NM:
LAND!'<t'\RKl - RT#:
STR t./"M:
LANDMARK2 - RT#:
S'I'R NM:
TRAF CONTROL DEVICE TYPE: 2
WORK ZONE - 'I'YP: 0 LOC:
LN CLOS: RD CL/DETOUR:
LANE CLOSED DUE TO CRS: 1
FUNCTIONING: 3
SPEED LIM;
SHLD/MED WK:
DIRECT: 7
WORKERS PRES:
MOVING WK: FLAGGER: OTHER:
TRAP DETOUR: Y EST TM CLOSE: 3
FIRST F~FUL EV: 02 UN#: 01
EWI/RDWY FACTORS: 00
MOST HARMFUL EV: 02 UN#: 01
PRIME FACTOR: D 98 UN#: 01
EMERGENCY TRANSPORT - EMS AGENCY: COMMUNITY LIFE TEAM EMS
MEn FACILITY: PENN STATE HERSHEY MEDICAL CENTER
WITNESS: RICHARD E RENNER PH: 7178343125
ADDR: 212 DELLVILLE RD, DONCANNON, PA 17020
)N 18 DEC 04 AT 0305HRS, POLICE UNITS WERE DISPATCHED TO THE AREA OF
I CAMERON ST AT ELMERTON AVE. FOR A REPORTED CRASH. UNITS RESPONDED
illD DETERMINED THE PARTIES INVOLVED HAD SEVERE INJURIES, AND WERE
~NTRAPPED. COMMUNITY LIFE TEAM EMS AND THE HARRISEURG FIRE BUREAU
)ESPONDED TO THE SCENE. UPON EXTRIC,Z\.TION OF THE INJ11RED PARTIES,
'HEY WERE TRANSPORTED TO THE HERSHEY MEDICAL CENTER FOR EVALUATION
-lID TREATMEN'T. DUE TO THE SEVERITY OF THE CRASH, THE TRAFFIC SAFETY
NIT WAS CALLED INTO SERVICE.
HE CRASH SCENE WAS SURVEYED AND MEASUREMENTS WERE TAKEN. IT WAS
ETERMINED THAT UNIT #1 WAS TRAVELLING WEST-BOUND ON ELMBRTON AVE,
OSSIBLY INITIATING A TURN SOUTH ONTO N CAMERON ST. UNIT #2 WAS
RAv~LLING EAST-BOUND ON INDUSTRIAL RD, POSSIBLY INTENDING TO
URN NORTH ONTO N CAMERON ST. THE UNITS COLLIDED IN THE CENTER OF
HE INTERSECTION. THE CONTACT WAS BETWEEN THE FRONT PASSENGER CORNER
F EACH VEHICLE. EACH VEHICLE HAD A SOLE OCCUPANT. THE OPERATOR
F UNIT #1 RECEIVED INJURIES TO HER LEFT ANKLE, NECK, AND RIGHT SIDE
.
IL-
U~ ~~ t)J r~l ~~;J~ r~~
rrQgress~ve ~as lllS ~Q
46J UUJ
"
METRO THE ~~~ISBURG AREA POLICE INFORK~TION RESOURCE SYSTEM {CRSIPINC}
PAGE: 2 CRASH REPORT 04/20/05 MZCl HD21
CRASH NUMBER: F0004657
INCIDENT ~BER: 2004120?870 HBG
._----~----------------------------~-------------------------------------------
RIBS, THE OPERATOR OF UNIT #2 RECEIVED INJURIES TO HIS RIGHT SIDE RIBS,
LOWER BACK, RIGHT LUNG, LEFT FRONTAL LOBE CONTUSION, AND RIGHT SIDE
INTER-CRANIAL HEMMORAGE. A LEGAL BLOOD SPECIMEN WAS DRAWN FROl\'1
THE OPBRATOR OF UNIT #1, AND A MEDICAL BLOOD SPECIMEN WAS FROM
DRAWN FROM THE OPERATOR OF UNIT #2.
EXAMINATION OF THE VEHICLES REVEALED THAT THE OPERATOR OF UNIT #2 WAS
NOT RESTRAINED AT THE TIME OF THE CRASH. THERE WERE ALSO NUMEROUS
BEER Cr.....~S LOCATED IN AND AROUND UNIT #2.
ON 18 DEC 04, I APPLIED FOR AND RECEIVED SEARCH WARRANTS FOR THE BLOOD
TOXICOLOGY RESULTS. THE WA~~TS WERE EXECUTED AT THE PENN STATE
HERSHEY MEDICAL CE~ITER AT 2241HRS. THE TOXICOLOGY RESULTS SHOWED
96 MG/DL {MEDICAL} FOR THE OPERATOR OF UNIT #1 AND ~11 MG/DL ~MBDICAL)
FOR THE OPERATOR OF UNIT #2.
ON XX J~~ 05, THE OPERATOR OF u~IT #2 SUCCUMBED TO HIS INJURIES.
THE CAUSE OF DEATH TJISTED WAS BRAD TRALTJ't1"A.
THE DAUPHIN COUNTY DISTRICT ATTORNEY'S OFFICE WAS CONSULTED AND
ADVISED THAT THERE WOULD EE NO CRIMINAL CHARGES FILED IN REFERENCE
TO THIS CR:1\.3H.
.------------------------------------------------------------------------------
VEHICLE COL;
INIT IMP PT:
ALCOH,DRG SUSP;
OWNER/DVR CD:
VIOLATION CD:
HARM EVENT 1:
HARM EVENT 2:
HARM EVENT 3:
HARM EVENT 4:
VEH FAILURES: 00
(45Fl) DVR RESTRICTIONS COMPL:
AVOIDANCE MANEUVER:
DRUG TEST TYPE:
u~IT WlMBER: 01 TYPE: 01 COMMERCIAL VEH: N
OWNR NAME: TIDWELL CATHY
OWNR ADDR: 717 NEWPORT RD DUNCANNON
VIN: 1FMDU34X1PUE05118 YR: 1993 MAKE: 12
LIC PLATE: DTA3792 PA TRAV SPD: 999
INS CO,FO,PH; PROGRESSIv~ 55640734-4
TOW TO,BY,PH: 1128 JONES TOWN RD, HBG 17 DON'S fu~ SON'S
# TRL UNITS: 0 TYP UNIT: TAG NO,YR,ST;
TYP UNIT: TAG NO, YR, ST:
03 TYP: 01 SPEC USAGE: 00
12 DAMAGE: 3 DIR TRAV: W MOVEMENT:
1 TEST TYP: 0 RESULT:
01 DVR PRESENCE: 1 PEDESTRIAN
75 3802 Al CHARGED: Y
02 L/R: WrlE; Y UTIL POLE#:
L/R: MHE: UTIL POLE#:
L/R: MHE: UTIL POLE#:
L/R: MHE: UTIL POLE#:
L
PA 17020
TONING
8007764737
7172342188
ROLE: 1 POSITION: 07
01 GRAD: 3 ALIGNM: 1
PHYSICAL COND: 1
SIGNAL: PED LOC:
DRIVER ACTION
DRIVER ACTION
DRIVER ACTION
DRIVER ACTION
PEDEST ACTION
1 DVR ENDORSEMENT COMPL: 0 DVR LICENSE COMPL; 3
o UNDER RIDE INDICATOR: 0 EMERGENCY USE; 0
1 RESULTS: 1 PRINCIPLE IMPACT PT; 01
1: 98
2:
3:
4 :
"
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'.
METRO THE HARRISBURG AREA POLICE INFORMATION RESOURCE SYSTEM (CRSIPINC)
PAGE: 3 CRASH REPORT 04/20/05 MZCl HD21
CRASH NUMBER; F0004657
INCIDENT NUMBER: 20041207870 HBG
VEHICLE eOL; 01
INIT IMP PT: 12
ALCOH,DRG SUSP; 1
OWNER/DVR CD~ 01
VIOLATION CD:
HARM EVENT 1:
HARM EVENT 2:
HARM EVENT 3:
P..APJ.1 EVENT 4:
VEH FAILURES; 00
(45Fl) DVR RESTRICTIONS COMPL:
AVOIDAlJCE ~mNEUVER:
DRUG TEST TYPE:
UNIT NUMBER: 02 TYPE~ 01 COMMERCIAL VEH: N
OWNR NAME: GLOVER BILLY
OWNR ADDR: 39 COUNTRY CLUB RD CARLISLE
VIN: IFMBU14T6KUA17903 YR; 1989 MAKE: 12
LIC PLATE: PHM4751 PA TRAV SPD: 999
INS CO, PO, PH: STATE FARM 754201D1638
TOW TO,BY,PH: 1128 JONESTOWN RD, HBG 17 DON'S AND SON'S
# TRL UNITS: 0 TYP UNIT: TAG NO,YR,ST:
TYP UNIT: TAG NO, YR,ST:
TYP~ 01 SPEC USAGE: 00
DAM..A.GE; 3 DIR TF3\.V: E MOVEMENT:
TEST TYP: 0 RESULT:
DVR PRESENCE: 1 PEDESTRIAN
CHARGED;
UTIL"POLE#:
UTIL POLE#:
UTIL POLE#":
UTIL POLE#;
J
PA 17013
TOWING
7179398918
7172342188
ROLE; 2 POSITION: 06
01 GRAD: 1 ALIGNM: 1
PHYSICAL CONn: 1
SIGNAL: PED LOC:
11 L/R:
L/R:
L/R:
L!R:
MHE: Y
MIlE:
MHE:
MHE~
DRIVER ACTION 1: 00
DRIVER ACTION 2:
DRIVER ACTIOxJ 3 =
DRIVER ACTION 4:
PEDEST ACTION ;
1 DVR ENDORSEMENT COMPL: 1 DVR LICENSE COMPL: 3
o UN~ER RIDE INDICATOR: 0 EMERGENCY USE: 0
1 RESULTS: 1 PRINCIPLE IMPACT PT: 01
.
6.~~~_~__._ __~ 4~_ ~~
- - . ...- - - . -.-.... ... .--
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MET~O THE aARRISBURG AREA POLICE INFORMATION RESOURCE SYSTEM (CRSIPINC)
PAGE: 4 CRASH REPORT 04/20/05 MZCl HD21
CRASH NUMBER: F0004657
INCIDENT NUMBER: 20041207870 HBG
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* * * * * * * * * * * * PEOPLE INFORMATION * * * * * * * * * * * * *
PERSON TYPE: l=DRIVER 2=PASSENGER 7=PEDESTRIAN 8~OTHER 9=UNKNOWN
INJ SEVERITY: O=NONE l=KILLEP 2=MAJOR INJ 3~MODERATE 4=MINOR 9=UNK
UNIT NO: 01 PERSON NO: 01 TYP: 1 INJ SEVERITY: 3 DOB: 19551212
NAME (L,F,M,S) : TIDWELL CATHY
ADDRESS: 717 NEWPORT RD PHONE:
DUN CANNON PA 17020
DRIVER LICENSE: FA 17887457
SEAT POSN: 01 SAFE-BQ1,2: 03 00 EJECT: 1 EJ-PATH: 0 EXTRIC: 1
SEX: F
L
TRA.:.'J S P: y
UNIT NO: 02 PERSON NO: 01 TYP: 1 INJ SEVERITY: 1 DOB: 19730611 SEX: M
NAME (L,F,M,S): GLOVER BILLY J
ADDRESS: 39 COUNTRY CLUB RD PHONE:
CARLISLE PA 17013
DRIVER LICENSE: FA 28341707
SEAT POSN: 01 SAFE-EQ1,2: 00 00 EJECT: 1 BJ-PATH: 0 EXTRIC: 2 TRANSP: Y
..