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HomeMy WebLinkAbout05-4922 WENDY LORENZ, parent and natural guardian of LINDSAY LORENZ, Plaintiffs IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA v. United Services Automobile Association, Defendant NO. OS" -,t/C?().~ (lL~~L~~ PETITION FOR LEAVE TO COMPROMISE A MINOR'S ACTION Wendy Lorenz, Parent and Natural Guardian of Lindsay Lorenz, a minor, hereby files this Petition for court approval through counsel for United Services Automobile Association (hereinafter "USAA") and in support thereof state the following: L Petitioner Wendy Lorenz is an adult individual residing at 449 Woodcrest Drive, Mechanicsburg, Cumberland County, Pennsylvania. 2, Minor Petitioner Lindsay Lorenz, who resides with Wendy Lorenz, is sixteen years of age, having been born on November 11,1988, 3. Lindsay Lorenz and Wendy Lorenz were involved in a single vehicle motor vehicle accident on February 3, 2004. 4. The vehicle was owned by Wendy Lorenz who had a policy with USAA number 006282636C, effective December 18, 2003 through May 9,2004, and provides for bodily injury coverage limits of$25,000.00 per person. (Declarations page ofUSAA insurance policy provided to Wendy Lorenz attached hereto as Exhibit "A"), (USAA insurance policy provided to Wendy Lorenz attached hereto as Exhibit "B", p. 15.) 5, As a result of the accident Minor Petitioner Lindsay Lorenz was injured and suffered a concussion, cut above her right eye, fractured pelvis and fracture of her sacrum. 14. The remaining $12,500.00 will be used to purchase an annuity which will pay on November 11, 2009, Lindsay Lorenz's 21 st Birthday, a guaranteed amount of$2,500.00, and on November 11, 2013, Lindsay Lorenz's 25th Birthday, a guaranteed amount of$12,800.00. 15, Upon filing the proof of deposit of the initial $12,500.00 payment with the Court, the Petitioners agree to refrain from bringing any action against USAA regarding the February 3, 2004 motor vehicle accident. 16. The USAA policy applicable to this matter does not provide for underinsured motorist benefits as the policy specifically excludes from the definition ofunderinsured motor vehicles any vehicle "owned by or furnished or available for the regular use of you or any family member if the named insured on this policy is the named insured on the liability bond or policy applicable to the underinsured motor vehicle." 17, All parties to this action concur with the filing of the Petition and seek approval of the minor compromise settlement under the terms set forth herein. WHEREFORE, the Petitioner respectfully requests that this Honorable Court approve the Minor Petitioners compromise settlement and enter the attached Order. Respectfully submitted, MARSHALL, DENNEHEY, WARNER, COLEMAN & GOGGIN DATE: 9/~/)/OO BY:~.~ J-~ ANDA L. STOMBA , ESQU LD. No, 94011 4200 Crums Mill Road, Suite B Harrisburg, PA 17112 (717) 651-3531 3 .~"j. .L'"..,._ .;:""~~., "'. :'l'i!~ .~:!" ~..~,'il ";'" ,~ JUL-15-ZDD5 11 :SIAM FROM-TRIPLE-R RANCH -11-lw~I'jS31 757-4Z 1-4179 T-Bla P.DDZ/DDZ F-SII WE:NDY LORENz, parent and na'.Unl Guardian ofIlNDSA Y LoRENZ. Plaintiffs : IN Tl:IE COURT OF COMMON' PLJO.AS : CUMBERLAND COUNTY, PENNSYLVANIA : v, USAA CASUALTY .mSURANCE CO,. Defendant . : NO. YERIFICATION , The undersigned herebYVf'rifies that the statements in the foregoing Petition for : , ApprovaJ of Minor's Compromise are based upon information wbich has been tUrnished [tCl , counsel by me and information wlcich has been gathered by COUIl6e1 in the preparation of till: ' ;,..',".,.: -', ..',',' , settle:tt11:'llt oftlris claim, The language of the Petitio~fDr .APP~ofMinor's Comprou:ii:;e is . . .' ",,' ',' '. - that counsel and not my own. I have read the Petition for Approval ofMmer's Co.tnpronlise and , to the e1d:ent tiult it is based Upon information which r have gi\'en to counsel. it is true and correct , , to the best of my knowledge, info'l11ation ami belief. To the e"tent; that the contents of~c Petition for Approval oiMinor's Compromise are that of counsel, I have relied upon my cOWlsel in making this Veri:fication. The llndersiiJ].ed also understands that. the statements therein are made subject to thepenallies ofl~ Pa. C.B,.~ 4904 rel~to unsworn falsification to authorities. .'.....,... DATE::::t/ IYID~ l)Jtt~~ ~ r .c. . ...... :5 )~ WENDYL.. '. - 1'1:1'..1 ""t1Jil!'nn"J ",. I I MRR,14 2005 10:50 FR USRR 8005310767 4980181 TO 917176519630 P.04/22 (4 SInk II'Slfrllllll Cutplnv} 9800 Fl1Idericki~urg ROld - SIn Antonio. TexIS 78Z88 PENNSYLVANIA AUTO POLICY AMENDED DECLARATIONS AT REVI POL Namad Insured and Address PAGE 3 ADDL INFO ON NEXT PAGE MAIL M:H-M-I lIMENDMENT TO f.. POLICY HUM8ER To. 00628 26 36C 7101 7 POLICY PERIOO: 112:0 I A.M. standlrd ~mel EFFECTIVE DEe 18 2003 TO ~ 09 004 o ERATORS 01 WENDY A LORENZ 03 RYAN J RICH ~ USAAo . USAA CASUAL TV INSURANCE COMPANY WENDY A LORENZ 135 SIMMONS RD MECHANICSBURG PA 17055-9723 MDDEL BODY TYPE vtH USE'- ....IJStIlQDl MillS t...~s. 1=' Ii.:, ie alsl 04 98 FORD EXPEDITION 4X4 4DR 05 04 MERCEDES C230 KOM SPT SED 4D 10 5 15 5 The Vehicle!sl described. herein iSlrinciPl"'L9.lflJ/ed It tile Iboye Iddress un lIS olhlrwiu slated, ."'0."/1,' ." . ....... ,.ro VEH 02 MECHANICSBURG PA lIU50-9723 VEH 05 MECHANICSB G PA _ VEH04 MECHANICSBURG PA 17055-9723 IS polley provide. osa OOverllses W ara a I!ramium is sllown II ow. a limits Bllown mill( Da radllcad by policy provisions and may not ba oOmbinlld regardlass of tha nllmber Of valirclu for which 8 r8mlllm is listed IInlns . 80lfic811 authorizad als.wher.. in litis olic. VEH YEH VEH VEH COVERAGES LIMITS OF LIABILITY 02 6-MONTH 04 6-MONTH 05 6-MONTH (- ACV. MEANS ACTUAL CASH VALUE) D=DED PREMIUM II=OED PREMIUM II-IIEII PREMIUM o~oeo PREMIUM OUN ~ MOUN S MOUN S OUN & . . BODILY INJURY EA PER $ 25,00 EA ACC $ 50,00 PROPERTY DAMAGE EA ACC $ 25,00 PART B - FIRST PARTY BENEFITS MEDICAL EXPENSE $ 5rOOO PART C - UNINSURED MOTORISTS . STACKED BODILY INJURY EA PER $ 25,00 EA ACC $ 50,00 PART C - UNDERINSURED MOTORISTS STACKED BODILY INJURY EA PER $ 25rOO EA ACC $ 50,00 PART D - PHYSICAL DAMAGE COVERAGE COMPREHENSIVE LOSS ACV LESS COLLISION LOSS ACV LESS INCREASED RENTAL REIMBURSEMENT TOWING AND LABOR 40.0 46.97 13.64 51.20 61.7 13.30 95.7 120.8 25.2 13.31 13.31 13.3 4.43 4.4 500 27.52 500 120.5 21. 60 6.0 4.4 500 74.3 50 327.2 6.00 TOTAL PREMIUM - SEE FOLLOWING PAGE(S) LOSS PAYEE H 05 CHASE AUTO FINANCE, PHOENIX AZ DORSEMENTS: ADDED 12-18-03 - NONE IN IN EFFECT (REFER TO PREVIOUS POLICY)- A400CW(01) A089(04) 5100PA(01) A132 (02) 5000 C ~ J~c~IA,'~ Menry. V.Go,Uio Jr. Prlsiitent -- -- ..... ....-'nM , ,. (PART C Confd,) UNDER/NSURED MOTOl'lISlS COVERAGE /STACKED! DEFINITIONS A Covel'Cld pemon as und In this Part means: 1. You or IlIIY &mily member, 2, Any othf;lr person ClOvel'Cld auto. Olll:Upylng yol,V' 3. Any person for damages that, P!lf$on Is entillecl to rec:gYer because of 81 to which thls c;overage appRes Sll8tl1lnecl by a Plll"llQn deseribed in A 1. or A2, move, However, the definition of ClOVIIl'Cld persgn d~ not inclUde the Government of the United States of America B, UndwinSlUlld mgtor vehicle means a land nnotor vehicle or trailer of eny type to whlllh a liabiRty bond, policy or self-insurance applies at the time gf the a=ident, but its ava.ilable limits for 81 liability are insufficlenf'tl:i pay losses and damages, However, 1he definition of an undClrinsu"'. motor vuhilll.. does not include; 1, An uninsl/l'ed motor vahie/e; or 2, Any vehicle or equipment a Owned by or furnished or ",ailable, ft;)/' the regular use of you or any f....ily member if: (1) The named insured On thi. policy; or (2) The eOVllf1ld person, mal;iqg: a claim under this policy, . '''', ';:,:,J'iI ; "'...' Is the named insured CI!l:;thelilll:!II1ty bond or policy app/~~le to the underinsUl'1lcl motor vehicle. , , - , ~; ~ However, 1his provision shannotlip~(Y if such veIlillle Qr equipment Is covered by a policy of IiIj)i1ity Insur~ separate lII1cl distinct from'; ,itiQ p,olk:Y under whioh UIM beneflta are qla/mel1, I5mOPA/Ov 7-00 8005310767 4980181' TO 917176Sf9630 P,07/18 '.",. b. ,Owned or operated by' II ..,f-Insurer under any appl/cable motor vehicle law, c, Owned. by any governmental unit or agency. ;l:; d. Operaled on rails gr.' cr<lwter !readll, except for II snowmObile. e. Oa,lqned mllinly for use gff public road~ willie not C!I'I public roads, f, While located for use lI$ a raldence or prefl:1illes. INSURING AGR~l;NjENT UNDERINSURSl) MoToRISTS COVERAGE .,; ,.,.. , A We' WUlpay, comp_atory dw!1ages which a ClOverad Pilrson .is legelly entitled to rlX:QVGr frQIT! the,. ., !:,WI1er or Operator of an un.rlll8\ll1ld'motor ",vehiole becwse of 81 sustained bY'a eOllarad pill'aol'l lII'ld Caused by an auto a=ldilnt , B. The 'O~ll., OL,Operator'$ liability for 1h_ damages must. arise out of the ownership, maintenanc$:," Or' use of,. the underlnsured 1Il0lOr """'tiJa~ C. Damages forSI"payable under UIM Coverage will be red!l~ by: " 1. Jlle S/'Iiilbility limits of the owners and ~per8tOr. " t:if 'the undar;l1ll1ll1ld motor \l8hiClJa;and, " >: ,',1;:~;~, L::t't,< 2, Amounts paid by or Qn behalf'of ."y other ' I:j....~. 'OI'''o1'9llnlzatiClns 'Who may be le!Jallv.f~ponSlble. ' ;' t O. NOJilclgmEllif'iOrdilrill/ge~ arising out of a suIt brouShtc..g~st; 1he o_t''' or operator of an undlirlnslll1Jii'rJotor nhlClle ,Is binding on lIS unlelis _:' '. , ,l. ,:j'~ 1 ;,,.. Rec.ive"~~Ofuil:jie' notice of the Pendency "of th.'~It'rNUlfIltg In. fhe JucI""""t: and :: 'l':';\~ 1'].'; , :;' , . ;'>1: 2, Have a ri!asonable Opportunity to protect OUr fnteIihts ill the !lUlt 4 ';:,':',::ii1i, I" ,,'I ""e 15 of 25 I ,it RELEASE AND SETTLEMENT AGREEMENT I. RELEASE AND SETTLEMENT A. THE UNDERSIGNED, Lindsay Lorenz, a minor, by and through Wendy Lorenz, parent and natural guardian of Lindsay Lorenz, a minor, and Wendy Lorenz, individually, ("CLAIMANTS") on this fJ S day of}Q "..kQ U , 20~or and in consideration of the sum of $12,500.00, representing ( upfront cash, piid to us by United Services Automobile Association _ Casualty Insurance Company (USAA-CIC) ("INSURER") and the sum of $12,500.00, to fund the periodic payments as provided for in Section 104, Subsection (a) (2) of the Internal Revenue Code of 1986, as amended, specified in Section II, paragraph F of this AGREEMENT, which INSURER contracts and agrees to payor cause to be paid to the persons or entities named in Section II, paragraph G, the receipt and legal sufficiency of all of which are expressly acknowledged, does hereby forever RELEASE, ACQUIT AND DISCHARGE Wendy Lorenz ("RESPONDENT"), INSURER and their servants, agents, officers, attorneys, claim adjusters, successors, heirs, assigns and all other persons, firms or corporations, from any and all claims, actions, causes of action, damages, liens of every kind and character, and/or other obligations of every kind and character, including all expenses incurred or to be incurred, on account or arising out of or in any way related to any and all injuries or damages to us, as a result of all occurrences involving CLAIMANTS and RESPONDENT on or about the 3rd day of February 2004, in or near Monroe Township, Pennsylvania, B. THIS RELEASE IS INTENDED TO AND DOES COVER ALL CLAIMS FOR INJURIES AND/OR DAMAGES, WHETHER OR NOT KNOWN TO THE PARTIES AT THE TIME THIS SETTLEMENT AGREEMENT IS EXECUTED, WHICH HAVE RESULTED, MAY HEREAFTER RESULT FROM, MAY HAVE BEEN, OR MAYBE CLAIMED TO HAVE BEEN CAUSED BY OR RESULTED FROM THE DESCRIBED OCCURRENCES. C, As additional consideration for the described payments, CLAIMANTS, for themselves, their heirs, executors or administrators, and assigns, agrees to and does indemnify and hold harmless RESPONDENT, INSURER and all others released by this AGREEMENT from any and all claims, demands and causes of action or any nature or character which have been made, or which may in the future be made by any person, firm or corporation claiming by, through or under them, including, but not limited to, all hospital, medical or other expenses or liens which are or could be asserted. II. PERIODIC PAYMENTS A. Notwithstanding any other provision of this AGREEMENT, INSURER IS and will remain contractually responsible for all periodic payments under this AGREEMENT. B, RESPONDENT and INSURER agree that CLAIMANTS (to whom, or upon whose behalf, the periodic payments contracted for in the AGREEMENT are to be made) made claim against RESPONDENT for damages arising from or involving physical injuries or physical sickness. Those claims, among others, are being released and settled by this AGREEMENT. C, The Parties further agree that all periodic payments specified in Section II, paragraph F, of this AGREEMENT are being funded by the purchase of a "Qualified Funding Asset," as defined in Section ,~ 130(d) of the Internal Revenue Code of 1986, from USAA Life Insurance Company, which will provide for payment of the periodic payments, INSURER will be the sole owner of the "Qualified Funding Asset." INSURER guarantees that the periodic payments will be made as specified in the PERIODIC PAYMENT SCHEDULE. CLAIMANTS acknowledge that USAA Life Insurance Company is an affiliate of INSURER and that, because of this affiliation, an indeterminate profit might eventually inure to the benefit of the INSURER. D. CLAIMANTS agree: (I) that INSURER is not required to set aside specific assets to secure the periodic payments; (2) that the periodic payments cannot be accelerated, deferred, increased or decreased by CLAIMANTS; and (3) that the periodic payment(s) shall not be, and cannot be, subjected in any manner to sale, transfer, assignment, pledge, mortgage, encumbrance, lien, collateral, or any similar transaction. Any attempted sale, transfer, assignment, pledge, mortgage, encumbrance, lien, collateral, or similar transaction is void. E. CLAIMANTS shall have no legal, equitable, vested, or contingent interest in the "Qualified Funding Asset" and their rights against INSURER, the company from whom the "Qualified Funding Asset" is purchased, or against the "Qualified Funding Asset" will be solely those of a general creditor. F. PERIODIC PAYMENT SCHEDULE: $2,500.00 guaranteed lump sum, payable on November I I, 2009 $12,800.00 guaranteed lump sum, payable on November I 1,2013 G. THE PERIODIC P A YMENT(S) WILL BE MADE PAYABLE TO: Lindsay Lorenz H. Any periodic payments to be made after the death of CLAIMANT, Lindsay Lorenz, under this SETTLEMENT AGREEMENT will be made to the Estate of Lindsay Lorenz, as designated at the time of settlement (or in writing from time to time thereafter by the guardian of said CLAIMANT with Court Approval) by said CLAIMANT, upon attaining the age of majority, and delivered to INSURER. If no person or entity is designated by said CLAIMANT, or if the person or entity designated is not living at the time of said CLAIMANT'S death, the payment will be made to the Estate of said CLAIMANT. I. AIl sums set forth herein constitute damages on account of personal physical injuries or physical sickness, within the meaning of Section 104 (a)(2) of the Internal Revenue Code of 1986, as amended. J. Discharge of Obligation: The obligation of the RESPONDENT and the INSURER to make each Periodic Payment shall be discharged upon the mailing of a valid check in the amount of such payment to the designated address of each Payee named in Section II of this Release, or by deposit by electronic funds transfer in the amount of such payment to an account designated by each Payee identified in Section II. III. GENERAL PROVISIONS A. It is expressly understood and agreed that this settlement is a compromise of a disputed claim, that the payments provided for may not be construed as an admission of liability by RESPONDENT or INSURER, and that RESPONDENT and INSURER expressly deny any liability to CLAIMANTS. B. CLAIMANTS covenant that no representations or promises other than those expressed in this SETTLEMENT AGREEMENT have been made to them in regard to this settlement, that they have 2 carefully read and fully understand this SETTLEMENT AGREEMENT, and that they understand that upon execution of this SETTLEMENT AGREEMENT, all rights, claims or demands CLAIMANTS may have against RESPONDENT and INSURER, except the contract to make periodic payments included in this SETTLEMENT AGREEMENT, are completely extinguished. C. SETTLEMENT AGREEMENT is to be construed and interpreted under the laws of the Commonwealth of Pennsylvania. Any person who, with intent to defraud or knowing that he/she is facilitating a fraud against an insurer, submits an application or files a claim containing a false or deceptive statement is guilty of insurance fraud. EXECUTED BY ALL PARTIES as of the date first stated above. CLAIMANT: Lindsay Lorenz, a minor I~ r WendyLLorenz, indivi Iy, an as parent and natural guardian of Lindsay Lorenz, a minor a minor WITNESS: f / ' tfiy ~2fY!cA- '; /:J /0S- , INSURER: United Ser\-ices Automobile Association- Casualty Insurance Company (USAA-CIC) Name Title EXECUTED at , this day of ,20_. 3 . . . r carefurly read and fully understand this SETTLEMENT AGREEMENT, and that they understand that upon execution of this SETTLEMENT AGREEMENT, all rights, claims or demands CLAIMANTS may have against RESPONDENT and INSURER, except the contract to make periodic payments included in this SETTLEMENT AGREEMENT, are completely extinguished. C. SETTLEMENT AGREEMENT is to be construed and interpreted under the laws of the Commonwealth of Pennsylvania. Any person who, with intent to defraud or knowing that he/she is facilitating a fraud against an insurer, submits an application or files a claim containing a false or deceptive statement is guilty of insurance fraud. EXECUTED BY ALL PARTIES as of the date first stated above. CLAIMANT: Lindsay Lorenz, a minor r Wendy Lorenz, indiVidually, and as parent and natural guardian of Lindsay Lorenz, a minor a minor WITNESS: f INSURER: United Seruces Automobile Association _ Casualty Insurance Company (USAA-CIC) {~(}.~dh Name . ~ 11J,M\- f~ Oij~ Title EXECUTED at h~ 1r: sf- thi c2/ , s day of ~ / ,200'.7. 3 WENDY LORENZ, Parent and Natural Guardian of LINDSAY LORENZ Plaintiffs IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA v. USAA CASUALTY INSURANCE CO., Defendant CERTIFICATE OF SERVICE I, Angela Zilla, an employee of Marshall, Dennehey, Wamer, Coleman & Goggin, do hereby certify that on this ;)O/4Jiay of September, 2005, I served a copy of the foregoing document via First Class United States mail, postage prepaid as follows: Wendy A. Lorenz 449 Woodcrest Drive Mechanicsburg, P A 17050 td~d 2d~ Angela Ila r-> -kl. 8 If) ...., 0 ~ t 0 = C? " U( c. OJ' -t " ., v' X-n .-.. r" rnr.::: , ...... ) -c -O~.~ - .J::: 1') ~_:J'y r- ~ ::1 ~~~ '\> ~ V ~ ~~~~ --a --. , , :J>: ~5rn 1::J p=- '.. <:? ~:..j .- -P- -,." P /~" !::) ~ -- i: =< Ul tJ 'f---- ...c:: '----Z -..() WENDY LORENZ, parent and natural Guardian of L1NSDAY LORENZ, PLAINTIFFS IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA V. USAA CASUAL TV INSURANCE CO., DEFENDANT 05-4922 CIVIL TERM ORDER OF COURT AND NOW, this --z...A.... day of September, 2005, a hearing on the petition to approve a minor's compromise settlement shall commence at 8:45 a,m., Tuesday, November 1, 2005, in Courtroom Number 2, Cumberland County Courthouse, Carlisle, Pennsylvania. By lhe~,."'" # .' "/ ' .' . .' .,', Amanda L. Stombaugh, Esquire For Petitioners ~ ~ :sal {j1, YU~' /, C~ FILE[~O:=fiCE OF THE rn01HONOTARY 2005 SEP 29 Pi: I: 35 C,,,,, viv.~~.. ~- - . WENDY LORENZ, parent and natural guardian of LINDSAY LORENZ, PLAINTIFFS IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA V, USAA CASUALTY INSURANCE CO., DEFENDANT 05-4922 CIVIL TERM ORDER OF COURT AND NOW, this r-r- day of November, 2005, following a hearing, IT IS ORDERED: (1) Approval of the settlement of this minor's claim in the amount of $25,000 for Lindsay Lorenz, born November 11, 1988, IS GRANTED. (2) From the settlement, $12,500, shall be used to purchase an annuity from National Settlement Consultants providing guarantee payments to Lindsay Lorenz of $2,500 on November 11, 2009, and $12,800 on November 11, 2013, (3) The amount of $12,500 shall be placed in a federally insured interest bearing investment in Members 1st Federal Credit Union, in the name of Linsday Lorenz, born November 11,1988. (4) The account shall contain the following notation: "NO WITHDRAWAL CAN BE MADE PRIOR TO LINDSAY LORENZ, BORN NOVEMBER 11, 1988, OBTAINING HER MAJORITY EXCEPT BY AN ORDER OF A COURT OF COMPETENT JURISDICTION." (5) Wendy Lorenz, the mother of Lindsay Lorenz, is authorized to sign any release necessary to effectuate this settlement. (6) Amanda L. Stombaugh, Esquire, shall file with the Prothonotary, and forward f2 'i:~~1 , ."~~ . 'f.~ ~~.~~_ :-I,o., ~UJ C1-:c, l- 0" -::1' - :C 0- U" C'l r- \ :7 S - en = "'" c.... "..... f:; <- '., ~! -.") C'j o ..-.--' ------- - ~ a copy to this chambers, proof of compliance with this order. By the Court, . /;~:,/ ,/,.;/ ,/ ,," /f' ,'//'/' " ../ /' / iii' _-,. WENDY LORENZ, parent and natural guardian of LINDSAY LORENZ, PLAINTIFFS V, IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA USAA CASUALTY INSURANCE CO" DEFENDANT 05-4922 CIVIL TERM CITATION FOR CONTEMPT A citation is issued to Wendy Lorenz to show cause why she should not be adjudicated in contempt for failing to deposit insurance proceeds of $12,500 in an account as required by Paragraphs 3 and 4 of an order entered on November 7,2005, approving a minor's claim for Lindsay Lorenz, born November 11, 1988. A Rule to show cause shall be heard IN COURTROOM NUMBER 2, CUMBERLAND COUNTY COURTHOUSE, AT 11 :30 A.M., MONDAY, APRIL 10, 2006, AT WHICH TIME WENDY LORENZ IS ORDERED TO APPEAR. Failure to appear will result in process being issued, / vG'eoffrey S, Mcinroy, Esquire For Wendy Lorenz ~Wendy Lorenz I c.op Y (Y\O-\ \ ed R.e~ t 449WoodcrestDrive leopy ty\Q.\{stc ceR . Mechanicsburg, PA 17055 I ) ' ./ ,-1/ , Il... '- "- :sal --l 1 ,,~O ,-', .)" &__Art/J.c.;, , UvJY . ,,,,,--v 0" - , ~o ,~~, ~~~+ r/'1Ji. /u~rRt( ,(,2)."'- ( d~~) ~ .j c ' J1u2;uM ,j/UJ'-'tt'-- "~ c)/. F1Lr '_' ,',_ ThE /;;'1..~~.~"',:,~\?.':~ Ol!;[!y L"flnr , ~'~/f..l tj,::p ") "., oJ I r': ~" /;,/J f(): 30 '1\ U.S. Postal Service CERTIFIED MAil RECEIPT '. (DG.i',~sflc Ma,1 Only; No Insurance Coverage Provided) ~ l___ .---.------,-- - 1------- !'(lSJnYf.]$ f.------------- (;'wtlfl'x.!10e! ,.." '" C"- '" "I:' ,.." o o o Return Hccclpt f(~e (f::ndorterne'1tRequired1 '_L_", --1 Restrk;ted DeliVery Fee IEndorsernent Requiredl 1.-- :2 Total PQstage & f:ees UP__.__ __ /) 5. .if 99:) ~ !;iC;r;;---- --~ n ;;4- -., az:.,../ o ",a/e,,~, ,'.' ':iB ~;~!}lJOd~~~n)~ ( 7 a<;~ WENDY LORENZ, parent and natural guardian of LINDSAY LORENZ, PLAINTIFFS IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA V, USAA CASUALTY INSURANCE CO" DEFENDANT : 05-4922 CIVIL TERM ORDER OF COURT AND NOW, this 10th day of April, 2006, Wendy Lorenz having filed proof of compliance with this court's order of November 7,2005, the petition to hold her in civil contempt, IS DISMISSED. ,)Nendy Lorenz , 449 Wood crest Dnve Mechanicsburg, PA 17055 ~ By the Court, \" // / vGeoffrey S. Mcinroy, Esquire :sal ty\o ,~~ t> ,,' \ ' ...... ,",. '. " ..... '3 ~) " WENDY LORENZ, parent and natural guardian of LINDSAY LORENZ, PLAINTIFFS IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYL~NIA V. USAA CASUALTY INSURANCE CO., DEFENDANT 05-4922 CIVIL TERM CITATION FOR CONTEMPT A citation is issued to Wendy Lorenz to show cause why she should not be adjudicated in contempt for failing to deposit insurance proceeds of $12,500 in an account as required by Paragraphs 3 and 4 of an order entered on November 7, 2005, , approving a minor's claim for Lindsay Lorenz, born November 11, 1988. A Rule to show cause shall be heard IN COURTROOM NUMBER 2, CUMBERLAND COUNTY COURTHOUSE, AT 11:30 A.M., MONDAY, APRIL 10, 2006, AT WHICH TIME WENDY LORENZ IS ORDERED TO APPEAR. Failure to appear will result in process being issued. f;ii;,=" l\ 1\11" 1\\1\\\I\lI\ 1\\1 I. ~ "~ _;l1b1n nnn1 "" "" I \)~~ ~ f I '\~'),} i \~Y\)6 . i I I I By the/C-ourt, . - . . I · -, ()~ -t/ 7;L:L Wendy Lorenz .... ~, 449 Wood crest Drive 1S ~ tJ.I.J". (,;'- n^ <4~,.,.rr - Mechanicsbl'.- A 0 INSUFFICIENl ADDRESS t01KER Oc 0 All~~~JE:u~mm~~El s g nSl DELIVERABLE AS AD DR ED . UNABLE 10 FORWARD \ \1\\ C . _.-..l ~..l..--::.~?":4,..A.e.~ - I!' 1...1 II" .111......"..' I ...11.. .11.. \1.1.. '''I \1. .1.1, .1.1..' " ~ WENDY LORENZ, parent and natural guardian of LINDSAY LORENZ, PLAINTIFFS : IN THE COURT OF COMMON PLEAS OF : CUMBERLAND COUNTY, PENNSYLVANIA V. USAA CASUALTY INSURANCE CO., DEFENDANT : 05-4922 CIVIL TERM ORDER OF COURT AND NOW, this ~ day of June, 2006, IT IS ORDERED: (1) Paragraph 4 of the order entered on November 7,2005, IS VACATED. Lindsay Lorenz, born November 11, 1988, shall have immediate access to the funds in that account. (2) All other provisions in the order of November 7, 2005, shall remain in full force and effect. ~dY Lorenz ./L;;~~ay E. Lorenz 250 Reeser Road Camp Hill, PA 17011 " f}:.DV, ~\ o :sal ... "';! Zll:S lid Zl L, ~iOQZ i' U\./!i', \OI.L\-"