HomeMy WebLinkAbout05-3993
II
INRE:
IN THE COURT OF COMMON PLEAS OF
CUMBERLAND COUNTY, PENNSYLVANIA
LYDIA HAMMAKER,
(minor) by her Guardian
MELINDA HAMMAKER
: NO. os---3993
: CIVIL ACTION - LAW
PRTTTTON TO SFTTLR MINOR'S CLAIM PTTRSTTANT TO P"R.20~9
AND NOW, comes counsel for the above-captioned Plaintiffs, Patrick F. Lauer, Jr.,
Esquire, ofthe Law Offices of Patrick F. Lauer, Jr., LLC and respectfully avers the following:
1. Keith and Melinda Hammaker are the parents of Lydia Hammaker and they reside at 415
North High Street, Duncannon, P A 17020.
2. Lydia Hammaker is 7 years of age.
3. Lydia Hammaker suffered minor injuries as a result of an automobile accident on April
8, 2000, while traveling with her parents on Route 34, Cumberland County,
Pennsylvania.
4. The injuries Lydia Hammaker suffered were minor bumps, scratches, abrasions,
contusions, facial lacerations and a concussion. Lydia suffered a minor scar from the
injuries.
5. Heather Weaver is insured through Allstate Insurance Company.
6. Allstate Insurance Company has offered $8000.00 to settle the claim for any and all
known and unknown injuries as a result of the automobile accident.
7. Lydia Hammaker has suffered no adverse repercussions from the automobile accident.
8. Medical bills totaled $7829.15 and have been paid. A majority of the medical bills were
for x-rays, examinations and transportation via helicopter to Hershey Medical Center.
9. Keith and Melinda Hammaker, parents of Lydia Hammaker, are satisfied that $8000.00
is a just and reasonable settlement for any and all injuries to Lydia Hammaker.
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10. The attorney's fees in this case are 30%, or a total of $2400.00. Expenses advanced in
the case for medical records are $115.59.
11. Keith and Melinda Hammaker shall open a trust account in the name of their child and
said proceeds shall not be distributed until Lydia Hammaker reaches the age of 18,
unless the court authorizes said distribution.
WHEREFORE, the plaintiffs respectfully request your honorable court to authorize the
settlement and distribution of the proceeds as follows:
Attorney's Fees, Including Expenses: $2515.59
Keith and Melinda Hammaker: $5484.41
Date: cgJf/kJ-
Respectfully submitted,
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~atrick F. Lauer, Jr., Esquire
Law Offices of Patrick F. Lauer, Jr., LLC
2108 Market Street, Aztec Building
Camp Hill, Permsylvania 17011-4706
ID#46430 Te1.(717)763-1800
I'
INRE:
LYDIA HAMMAKER,
(minor) by her Guardian
MELINDA HAMMAKER
: IN THE COURT OF COMMON PLEAS OF
: CUMBERLAND COUNTY, PENNSYLVANIA
: NO.
: CIVIL ACTION - LAW
VERIFICATION
I verify that the statements made in this Petition are true and correct. I understand that false
! statements herein are made subject to the penalties of 18 Pa. C.S. S 4904, relating to unsworn
falsification to authorities.
Date: c;Jct/C?J-
Date: ~) 1/0)'--
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Signatur~0~.' . '7-r~
KEITH HAMMAKER
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jECEIVED AUG 052005;
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INRE:
: IN THE COURT OF COMMON PLEAS OF
: CUMBERLAND COUNTY, PENNSYLVANIA
LYDIA HAMMAKER,
(minor) by her Guardian
MELINDA HAMMAKER
: NO. 0')- ?/193
: CIVIL ACTION - LAW
OROFR OF rOITRT
AND NOW, this -----1.t:L.-- day of _'A u O"!> t
2005, and based on the
within petition, the requested relief is hereby GRANTED and authorization is given to settle the
minor's claim pursuant to Pa.R. 2039. .l\. h""Ul~U5 .Yhai1'JnaU 116t 15"" l.LdJ UH
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'Jon" 1" tl,,,,, Cu.GlberJana Ce~n.:)~' C8.......t1.Luu.~"".
BY THE COURT,
Distributi~
;,ft"atrick F. Lauer, Jr., Esq., 2108 Market Street, Camp Hill, PA 17011
~ey G. Shore, Esquire, 2411 No Front Street, Harrisburg, PA 17110
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