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HomeMy WebLinkAbout11-28-05 . ~ Gerard C. Kramer J.D. No. 44715 SCHMIDT, RONCA & KRAMER, P.C. 209 State Street Harrisburg, PA 17101 (717) 232-6300 Attorney for Petitioner \:..:J In re: ESTATE OF LOUISE DONMOYER, COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA Deceased : No. 21-05-0400 BY Gary Donmoyer and Debra Donmoyer McClain, Executors, : ORPHAN'S COURT DIVISION Petitioners PETITION FOR APPROVAL OF UNDERINSURED MOTORIST SETTLEMENT AND NOW comes the Petitioners, Gary Donmoyer and Debra Donmoyer McClain, as Executors of the Estate of Louise Donmoyer, deceased, pursuant to 20 Pa.C.S.A. ~ 3323 approval of a Compromise Settlement in the above matter and further sets forth as follows: 1. The Petitioners, Gary Donmoyer and Debra Donmoyer McClain, are adult individuals, the children and beneficiaries of the Estate of their mother, Louise Donmoyer. 2. The Petitioner Gary Donmoyer and Debra Donmoyer McClain are Executors of the Decedent's Estate by virtue of Letters Testamentary which were granted to her by the Register of Wills of Cumberland County, on April 28, \..D -. 2005 at File No. 21-05-0400. (See Exhibit "A" of Plaintiff's Petition for Approval of Settlement). 3. Ms. Louise Donmoyer was injured In a motor vehicle accident which occurred on October 30,2004. 4. A petition for approval of the third party settlement was filed on October 31, 2005. An order approving that settlement was signed by Judge Edgar B. Bayley on October 31, 2005. Plaintiffs are now seeking approval of the settlement of the first level of underinsured motorist coverage. 5. Ms. Louise Donmoyer was the passenger of a vehicle traveling south on Orrs Bridge Road in Hampden Township in Cumberland County. 6. Another vehicle driven by Marcia Reynolds, which was driving northbound on Orrs Bridge Road, crossed the center line of the road. 7. A head-on collusion occurred between the two vehicles. The driver of the vehicle in which Ms. Louise Donmoyer was a passenger was killed instantly. (See Exhibit "B" of Plaintiff's Petition for Approval of Settlement). 8. As a result of the accident, Ms. Donmoyer was hospitalized at Hershey Medical Center for multiple fractures. While hospitalized she developed complications. Her initial stay at Hershey Medical Center lasted 19 days before she was transferred to HealthSouth. 9. At HealthSouth it was determined that Ms. Louise Donmoyer had suffered from significant losses in her cognitive ability and that she was becoming depressed from the accident. ... , 10. After experiencing respiratory distress Ms. Louise Donmoyer was transferred to Hershey Medical Center. 11. She was subsequently released to Select Long Term Acute Care. She returned to Holy Spirit Hospital for gastrointestinal bleeding after she vomited almost a cup of bright red blood on February 24, 2005. 12. After surgery in March 2005, Ms. Donmoyer was discharged to her home for home-care. 13. Ms. Louise Donmoyer passed away on April 22, 2005 from cardiac arrest at physical therapy. (See Exhibit "C" of Plaintiff's Petition for Approval of Settlement) . 14. Executors retained Schmidt, Ronca and Kramer, P.C. to investigate and pursue a personal injury claim against Ms. Marcia Reynolds, on a contingency fee agreement permitting 25% attorney's fee and agreeing to reimburse Schmidt, Ronca & Kramer, P.C. all costs and expenses as incurred on the his behalf to make the claim. (See Exhibit "D" of Plaintiff's Petition for Approval of Settlement). 15. The claim against the third party liable for the accident was settled for $249,000.00 (See Farmer's Insurance Company release attached as Exhibit " 1"). 16. The first level if underinsured motorist coverage is with Travelers Insurance. (See Travelers Insurance Declaration Sheet attached as Exhibit "2"). . r 17. Travelers Insurance has offered the policy limits of $100,000.00 for settlement. (See fax coversheet from Traveler's Insurance dated November 2, 2005 attached as Exhibit "3"). 18. Petitioners consider the settlement amount of One Hundred Thousand Dollars ($100,000.00) to be a fair and reasonable. (See Verifications attached as Exhibit "4"). 19. There is another level of underinsured motorist coverage available under Ms. Donmoyer's policy with AllState Insurance. 20. We have been given consent to settle from AllState. (See Letter from AllState attached as Exhibit "5"). 21. The Petitioners, Gary Donmoyer and Debra Donmoyer McClain are the only beneficiaries to the Estate. No minors are involved. 22. The Pennsylvania Department of Revenue has approved an apportionment of 50% to wrongful death and 50% to Survivor Action. (See PA Dept. of Revenue letter attached as Exhibit "6"). 23. Having retained the law firm of Schmidt, Ronca & Kramer, P.C. because of their expertise in these types of cases and signed a contingent fee allowing a 25% fee, Petitioners consider this to be reasonable for the work, expertise, and effort of the law firm. 24. To accomplish the Settlement, Schmidt Ronca and Kramer, P.C. incurred expenses including fees for filing, copying, postage, telephone & fax charges, resulting in a total cost of $615.00. ... 25. The Medicare lien of $78,858.43 was satisfied under the settlement with the liable third party. 26. The Petitioners requests that the following distribution be approved: Wrongful Death Action (50%) $ 100,000.00 $ 50,000.00 TOTAL SETTLEMENT Schmidt, Ronca & Kramer, PC Attorneys' Fees (25% of $50,000.00) $ 12,500.00 Schmidt, Ronca & Kramer, PC Attorneys' Costs $ 315.00 TOTAL PAYABLE in wrongful death action to Gary Donmoyer and De bra Donmoyer McClain $ 37,185.00 Survival Action (50%) $ 50,000.00 Schmidt, Ronca & Kramer, PC Attorneys' Fees (25% of $50,000.00) $ 12,500.00 Schmidt, Ronca & Kramer, PC Attorney Costs $ 315.00 TOTAL PAYABLE to estate in Survivor Action $ 37,185.00 27. Petitioners also request the Court grant permission to execute the Release attached hereto as Exhibit "7." WHEREFORE, the Petitioners requests that this Honorable Court enter the Order attached to this Petition approving the compromise settlement, , f directing the distribution of the proceeds as set forth herein, and authorizing him to sign a general release. Respectfully submitted, SCHMIDT, RONCA & KRAMER P.C. ~/~ Gerard C. Kramer, Esquire I.D. # 44715 209 State Street Harrisburg, PA 17101 (717) 232-6300 Attorney for Plaintiffs ~ fARM ERS Release in Full of All Claims and Righc''i Clilim #; 1005682408 FOR AND IN CONSIDERATION OF THE SUM OF TWO HUNDRED FORTY-NINE THOUSAND AND NOll no ($149,Ooo,om. rcn:ipr of which is acknowledged, I tdtaSl' and [orev.:-r dischargt the irlsun:r. FJ.rmt:rs New Century I nmranc:c r:omp;iny, Ronald Reynolds,.J r. ~ .t-.larcia Reynolds, their princilJats, agencs and rcprtstllt:l.tivcs fWIll allY Ol.nJ all rights, (,:h1ims, demands and damagel of any kino, known or unknown, existing or arisiug in rhl' {ucutt:, n:sulrial; from or rdated to injuries aud propf.:rry damage arising from an a(;cidt:nt that ()ccurred on or abl:at (he 30'. day of Occober, 2004, at or near Camp Hill, Pennsylvilnia.. This release shall/wr destroy or otherwise iLffe<:t the ri,qhrs of persons On whose' behalf this payment is malle, or persons who may claim tt1I.JC: damagt:d by reason Df the an.:idcnt orher rhan rhe unclersignecl ro pursue any legal remedies (hey may have a.ga.ilISt the 11l1dcrsi}{/Icd or ,my ocher pnson. I undersc3.!ld chat this is a compromise settlement of all my c1ilims iuisinR Ollr of rhe accidc:m referred ro above, and chere is 110 aumissioll of liability. I understalld thac chis is all the money nr considera.tion r will rec.eive from the ;inove descrihed parties for any anll all oC my claims as a resole of this lllCidcut. Further, 1 agree [0 reimburse and indemnify all rclt:ascd polrties for any a.mounrs whkh ;my inS\lrjlO(:C (euricfs, govcrnmcnr entities, hospitals ur olher iktsqllS of ur l1rgallizatiol\s may recover from rhem in reimbursemellt for amouncs paid to lIIe oc Oil my bchalf-.1s a result of chis ,ll;cideoc by way of contributioll, suhro1f.\tiDn, ind~ml1jry, or (ltherwis~, I have rcad this release and L11ll1crstal1J it. Signed a.nd (hted chis ~ day of )./{/ L/ ,20Qi:;;; :JVcl Sfy"k S.I- H~ tc. r of rhe E:mHe of Louise Donmoyer j)/.u-/ & (lYV'('ylffi, f?/1 J1lr' CiZ71,;~v DEBRA DONMOYER MCC IN, As Co.Executor of the E~cate of l,ouise Donmoyer /4 L/~/Cft- . /.:L L. l~r4'/v\ t/ V-V-WG :J. 0 (l .s ~ \-(. S i/'n~ L-i \/tvr1 flt/7/~i I,-,-,,rr,' U ~- AUTOMOBILE POLICY CONTINUATION DECLARATIONS 1. Named Insured Your Agency's Name and Address VIRGINIA A FETROW 4711-A CHARLES RD MECHANICSBURG PA 17050 AAA INSURANCE AGENCY 2301 PAXTON CHURCH ROAD HARRISBURG, PA 17110 Your policy NUmber : 947535705 101 1 Your Account Number: 947535705 For Policy Service Call 1-800-842-5075 For Claim Service Call 1-800-CLAIM-33 2. Your Total Premium for the Policy Period ,is $539.00. The policy period is from October 8, 2004 to October 8, 2005. 3. Your Vehicles Identification Numbers 1 2002 CHRYS PT CRSR TE 3C4FY58B421270131 4. Coverages, Limits of Liability and Premiums Insurance is provided only where a premium is shown for the coverage. 1 02 CHRYS PT CRSR TE A - Bodily Injury $100,000 each person $300,000 each accident 65 $ B - Property Damage $100,000 each accident 84 D7 - uni~sured Motorists (Bodily Injury) Non-Stacked $100,000 each person . $300,000 each, accident See 'Endorsement A37043 9 D9 underinsured Motorists (Bodily Injury) Non-Stacked $100,000 each person $300,000 each accident See Endorsement A37043 26 E - Collision Repair or Replacement less $500 deductible See Endorsement A37270 229 F' - comprehensive (Other than Collision) Actual Cash Value 87 ('f'"'\T'\...."',....,,...o.A n-n 'n~Kt 'O&Of! T"t_ __ , -- &: " 4. Coverages, Limits of Liability and Premiums (continued) I. 02 CHRYS PT CRSR TE QA - Pirst Party Benefits Coverage Limdted Tort Option See Endorsement A37021 16 R - Added First Party Benefits A7-Increased Medical Expenses $100,000 D6-Accidental Death $5,000 See Endorsement A37G21 23 Subtotal for your vehicle: $539 Total Premium for This Policy: $539 5. Information Used to Rate Your Policy Discounts Included in Your Premium Anti Theft Device 02 CHRYS PT CRSR TE Passive Restraint 02 CHRYS P'l' CRSR TE Drivers Date of Birth Sex Marital Status VIRGINIA 12-22-30 Female Single Vehicles Use of vehicle Location of Vehicle 02 CHRYS P'l' CRSR TE Pleasure MECHAN:ICSBURG PA It is important that the above information is correct to ensure that your policy is properly rated. If there are errors or changes to this information, please notify your Travelers representative immediately. 6. Other Information Your Insurer Travelers Personal Security Insurance Company One of The Travelers Insurance Companies One Tower Square, Hartford, CT 06183 Continued on next page Page 2 of 4 PL.77825.94 6701010\6553 ~- Named Insured: Policy Number: Policy Period: Issued On: VIRGINIA A FETROW 947535705 101 1 October 8, 2004 to October 8, 2005. September 10, 2004 6. Other Information (continued) Policy Endorsements A370l3 Amendment of Policy provisions - pennsylvania A3702l First party B~nefits Coverage - pennsylvania A37043 Uninsured/Underinsured Motorists Endorsement - Pennsylvania A37270 Repair or Replacement Collision Coverage - Pennsylvania Policy Edition 8 'Policy Form 101 Issued on 09/10/04 'l'ha.nk you ;for insuring with The Travelers. We appreciate your business. If you have any questions about your insurance, please contact your Travelers representative. FOR YOUR INFORMATION *IF COLLISXON COVERAGE IS PROVIDED UNDER THIS POLICY, COVERAGE EXTENDS TO VEHICLES WHICH YOU RENT FOR 30 DAYS UNDER A RENTAL CAR COVERAGE AGREEMENT. PLEASE REMEMBER THAT COLLISION COVERAGE DOES NOT PAY FOR LOS,S OF USE. PLEASE CON'l'ACT YOUR TRAVELERS AGENT OR REPRESENTATIVE IF YOU HAVE QUESTIONS. IF YOU DO NOT CARRY COLLISION INSURANCE, THIS POLICY DOES NOT PAY FOR DAMAGE TO RENTAL VEHICLES. * Children & -air bags. . . it's as easy as 1 - 2 - 3 1. Never put a child seat (those used with infants) in the front seat of a car with air bags. 2. Make sure all children are buckled up no matter where they sit. Unbuckled children can be hurt or killed by an air bag. 3. The rear seat (those with seat belts) is the safest place for children of any age to ride. The laws of the CommQDwealth of Pennsylvania, as enacted by the General Assembly, only require that you purchase:Liabliity and First Party Medical Benefits coverages. -Any additional coverages, or coverages in excess of the l~ts required by law, are provided only at your request as enhancements to basic coverages. The premium for the mandatory coverages at the limits required by law and the tort option you previously elected are as ~ollows: Coverage Veh 1 Bodily xnjury $15,000 each personl $30,000 each accident Property Damage $5,000 each accident First Party Medical $37.00 $73 . 00 $16.00 Subtotal $126.00 Total Amount $126.00 "........._.....:_..._..:1 ___ __~..... ____ _ _ __ "') -. C A FOR YOUR INFORMATION (continued) You may purchase Uninsured and/or Underinsured Motorists Coverage at &ny available limits from $15,000/$30,000 up to your Bodily Injury Liability limits. You may reject these coverages entirely. ACCIDENT FORGIVENESS: (Insuring with TRAVELERS can save you money) If you've been a TRAVELERS auto pOlicyholder for at least 5 years and haven't had an at fault accident in the last 5 years, TRAVELERS will forgive your next at fault accident; no points will be charged. This is to certify that this is a reproduction, from the company's records, of ~he insuranc~ po~c~ between the insured and the insuring company as describe~ in the De~laratlons Page. It IS a U I true and complete reproduction of the insurance policy. No Insurance IS afforded hereunder. Signature: f:jnU-",i-ho /3Jyn 0 -<--f) 0 Dab>: /!J -/5 tYi Page 4 of 4 PL-77625-94 67010M6553 .---- - NUV kJd dtakJ::> Ib=::>b I-/-< J/-<VL/-<~ l,UIYIIYI/-<l,L LINt:.:J blld '(-:)b d444 IU '::ll'(l'(d,jdb4b'( ,...,. i<:l1/tad ~) ."1 j ) ~ /,,/ ...-/' Facsimile Cover Sheet To: Gerard C. Kramer Company: SRK Law Phone: 717-232-6300 Fax: 717-232-6467 From: Bob Hotchkiss Company: Travelers Phone: 610-736-2430 Fax: 610-736-2444 Date: 11/2/05 Pages including this 2 cover page: Comments: Re: Insured: Virginia Fetrow Claim: L4M3972 Your Client: Estate of Louise Donmoyer Mr. Kramer: I acknowledge receipt of your fax today with attached Certificate Of Grant Of Letters. In follow up to our phone discussion today, based on review of the documentation you have submitted, Travelel'5 agrees to payment of its $100,000 UIM policy limit, on behalf of your cHent. with the understanding that any and all liens including Medicare will be satisfied out of these proceed,s. As noted. you will be obtaining the necessary court approval. Please send copy of the proposed court approval paperwork, plus a copy of tile Signed paperwork when appropriate, Additionally, I have enclosed release reflecting the above settlement. Please review same and have it signed and returned, if in order. Thank YOll for your co-operation and assistance in this matter. VERIFICATION I, the Petitioner, Gary Donmoyer, an Executor of the Estate of Louise Donmoyer, hereby verify that the statements set forth herein are true and correct to the best of my knowledge, information and belief. I am satisfied that the offer of structured settlement, referred to in this Petition, for Ms. Donmoyer's injuries is just and reasonable and I am willing to accept that offer. I have reviewed the contents of the Petition for Approval of Survival Settlement and concur with all the facts and statements. I understand that intentional false statements herein are made subject to the penalties of 18 Pa. C.S. 94904 relating to unsworn falsification to authorities. Date: / II ~,3/0S- !1 1/\ y. '\) Ga~;"o;~::';;;.~~for of the Estate of Louise Donmoyer VERIFICATION I, the Petitioner, Debra Donmoyer McClain, an Executrix of the Estate of Louise Donmoyer, hereby verify that the statements set forth herein are true and correct to the best of my knowledge, information and belief. I am satisfied that the offer of structured settlement, referred to in this Petition, for Ms. Donmoyer's injuries is just and reasonable and I am willing to accept that offer. I have reviewed the contents of the Petition for Approval of Survival Settlement and concur with all the facts and statements. I understand that intentional false statements herein are made subject to the penalties of 18 Pa. C.S. 94904 relating to unsworn falsification to authorities. Date: 11/2.3/0r- ; '\ ,1 ! (1 /Y1 J l' ! "Q,J!;i/I.s~ \Jj)(J{'tAru1h'?/L 'I} I . / Iv-JiG Debra Donmoyer MClain, as Executrix of the Estate of Louise Donmoyer ------ ~ ~ HARRISBURG Allstate 6345 FLANK DRIVE, SUITE 1000 .HARRISBURG PA 17112-2765 You're In good hands. '11""11,',"11"""1111111""1111111.111..1.1111.1..11..11 GERARD C. KRAMER, ESQUIRE SCHMIDT, RONCA & KRAMER P.C. 209 STATE ST HARRISBURG PA 17101-1130 November 07, 2005 INSURED: LOUISE E DONMOYER DATE OF LOSS: October 30, 2004 CLAIM NUMBER: 1554999430 B27 Reference: Estate of Louise Donmoyer Dear Mr. Kramer: PHONE NUMBER: 800-726-88YO FAX NUMBER: 717-540-7540 OFFICE HOURS: Mon - Fri 8:00am - 5:30pm As always, thank you for your cooperation with this matter. Thank you for your November 3, 2005 conesponcc. We do consent to the VIM settlement with Travelers Insurance. Sincerely, fJim Shaffer Tim Shaffer 717-540-7555 Allstate Insurance Company GENIOOI 1554999430 B27 1001 H'S I~OBlI1051IU702TtlOWI.tU to 1001\005 l// t. ~ ~ ) Bureau of Individual Taxes PO Box 280601 Harrisburg, PA 17128-0601 COMMONWEALTH OF PENNSYLVANIA DEPARTMENT OF REVENUE " I .' .\ "./ / ! \. /1.(...,':) ~ " / V v" // . ~ Telephone: 717-787-1794 Fax: 717-783-3467 Email: hmcclintoc@state.pa.us November 16,2005 Gerard C. Kramer, Esq. SRK Law 209 State St. Harrisburg, PAl 71 0 1 Re: Estate of Louise Donmoyer File Number: 2105-0400 Dear Mr. Kramer: The Department of Revenue has received a letter concerning the Petition for Approval of Settlement Claim to be filed on behalfofthe above-referenced Estate in regard to a wrongful death and survival action. It has been forwarded to this Bureau for the Commonwealth's approval of the allocation of the proceeds paid to settle the actions. Pursuant to the letter, the 74-year-old-decedent died as a result of complications from a motor vehicle accident. Decedent is survived by her two adult children. Please be advised that, based upon these facts and for inheritance tax purposes only, this Department has no objection to the proposed allocation of the gross proceeds of this action, $ 50,000 to the wrongful death claim and $ 50,000 to the survival claim. Proceeds ofa survival action are an asset included in the decedent's estate and are subject to the imposition of Pennsylvania inheritance tax. 42 Pa.C.S.A ~8302; 72 P.S. ~~9106, 9107. Costs and fees must be deducted in the same percentages as the proceeds are allocated. In re Estate of Merryman, 669 A.2d 1059 (Pa. Cmwlth. 1995). I trust that this letter is a sufficient representation of the Department's position on this matter. As the Department has no objections to the Petition, an attorney from the Department of Revenue will not be attending any hearing regarding it. Please contact me if you or the Court has any questions or requires anything additional from this Bureau. Finally, the approval of this allocation is limited to this estate and does not reflect the position that the Department may take in any other proposed distribution of proceeds ofa wrongful death! survival action. Sincer,ly, -s;\ ~ .{\;~t,~~'(\lbO ~ Holly A. McClintock Trust Valuation Specialist Inheritance Tax Division Bureau of Individual Taxes j, . NUV k:l'::: ':::k:lI:::J~ Ib; ~b I-t'< I t'<VU<~ LUITII'It'<LL LJ Nl:.~ blla "(,jb ~444 I U ':H"(l"(d,jdb4b"( ""'.~d/I::1'::: UNDERINSURED MOTORIST RELEASE KNOW ALL MEN BY THESE PRESENTS, that We, Debra Donmoyer McClain and Gary DenniS Donmoyer, as Executors of the Estate of Louise E. Donmoyer acknowledge receipt of the sum of One Hundred Thousand and 00/100 DoUars ($100,000.00), and paid by Travelers Personal Security Insurance Company (Travelers) , in full settlement of all claims submitted to Travelers Personal Security Insurance Company (Travelers), for Underinsured Motorist Benefits, asserted against policy number 9475357051011 for bodily injury, sickness, or disease, resulting and to result from a certain accident which happened on the 30th day of October, 2004 on or near Orrs Bridge Road, Hampden Township, PA for which we have claimed the owner, operator or person or organization responsible for the operation of an underinsured automobile to be liable. It is specifically understood and agreed upon by and between the parties that any Medicare lien existing in connection with this claim shall be satisfied by Debra Donmoyer McClain and Gary Dennis Donmoyer from the proceeds of this settlement. Moreover, Debra Donmoyer McClain and Gary Dennis Donmoyer agree to indemnify and save harmless Travelers Personal Security Insurance Company (Travelers) on account of any such Medicare lien. IN WITNESS WHEREOF, We have hereunto set our hands and seals the day of , in the year Two Thousand Five. Signed, seal and delivered in the presence of: WITNESS: Debra Donmoyer McClain ADDRESS: Gary Dennis Donmoyer STATE OF PENNSYLVANIA ; 55 COUNTY OF Sworn to and subscribed before me this day of , 2005. Notary Public ** TOTAL PRGE.02 ** . VERIFICATION I, the Petitioner, Gary Donmoyer, an Executor of the Estate of Louise Donmoyer, hereby verify that the statements set forth herein are true and correct to the best of my knowledge, information and belief. I am satisfied that the offer of structured settlement, referred to in this Petition, for Ms. Donmoyer's injuries is just and reasonable and I am willing to accept that offer. I have reviewed the contents of the Petition for Approval of Survival Settlement and concur with all the facts and statements. I understand that intentional false statements herein are made subject to the penalties of 18 Pa. C.S. ~4904 relating to unsworn falsification to authorities. Date: 111~3Io5- ~~- ~,~ Gary D moyer, as E cutor of the Estate of Louise Donmoyer . . VERIFICATION I, the Petitioner, Debra Donmoyer McClain, an Executrix of the Estate of Louise Donmoyer, hereby verify that the statements set forth herein are true and correct to the best of my knowledge, information and belief. I am satisfied that the offer of structured settlement, referred to in this Petition, for Ms. Donmoyer's injuries is just and reasonable and I am willing to accept that offer. I have reviewed the contents of the Petition for Approval of Survival Settlement and concur with all the facts and statements. I understand that intentional false statements herein are made subject to the penalties of 18 Pa. C.S. 94904 relating to unsworn falsification to authorities. Date: 11/23/0r- Jj (}k JfJ(/'(I/'fW'leIL- 7iI r t?I~ Debra Donmoyer MClain, as Executrix of the Estate of Louise Donmoyer ~ CERTIFICATE OF SERVICE rd AND NOW, this c:< 3 day of Mv.ernh2r< . , 2005, I, Gerard C. Kramer, Esquire, hereby certify that I have this day served the foregoing Plaintiffs Petition for Approval of Survival Settlement and proposed Order by depositing a copy of the same in the United States Mail, postage prepaid, at Harrisburg, Pennsylvania, addressed to: Robert Hotchkiss Travelers Insurance Company P.O. Box 13426 Reading, Pa 19612 Gary Donmoyer 1074 Lancaster Blvd., Apt. 3 Mechanicsburg, Pa 17055 Debra Donmoyer McClain 2 Wheatfield Drive Carlisle, Pa 17013 SCHMIDT, RONCA & KRAMER, P.C. /~ erard C. Kramer Attorney at Law Attorney I.D.# 44715 209 State Street Harrisburg, PA 17101 (717) 232-6300 Attorney for Plaintiffs