HomeMy WebLinkAbout05-6225
IN THE COURT OF COMMON PLEAS
OF CUMBERLAND COUNTY, PENNSYL VANIA
TREVOR HARNER a Minor by
JEFFREY HARNER, Parent and
Natural Guardian,
NO. O!;' - ~~S
C! t 0 ~L ';- &U-',\
Petitioners
CIVIL ACTION - LAW
v.
EAST PENNSBORO TOWNSHIP,
Respondents.
PETITION FOR MINOR'S SETTLEMENT
AND NOW, TO WIT, comes the Petitioner, Jeffrey Hamer, ("Petiti~ner") parent
and natural guardian of Trevor Hamer ("Minor") and files this Petition to cq/npromise
action for approval of settlement and avers the following in support thereof:
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I. Petitioner is an adult individual, residing at 612 Strites Road,',iHarrisburg,
Pennsylvania 17111.
2. Petitioner is the parent and natural guardian ofthe Minor, boI[n
June I, 1994, and who lives at the above-noted address with Petitioner.
3. Respondent is East Pennsboro Township with offices at 98 S<jluth Enola
Drive, Enola, Pennsylvania,
4. This Petition is filed as a result of injuries sustained by the M~or child,
,
Trevor Harner, while playing at his uncle's house located at 114 Front Stree~in Enola.
At that time, the Minor child sustained an 8 to 9 centimeter laceration acrossilhe anterior
part of his shin when his right leg went through a metal grate covering a SIOrju water
drain that was rusted with rungs broken off exposing a large gap. The Mino~ child has
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essentially recovered from said injuries and has reached maximum recovery. i A true and
correct copy ofthe June 25, 2003 office notes from Richard A. BoaI, M.D, attached
hereto and indicates that Trevor "will return to see me only as needed." Exhibit "A."
5. The Minor child was born on June I, 1994 and is currently 11 years
of age, The minor child's mother, Billy A. Smith, currently residing at 319South Tenth
Street, Lebanon, Pennsylvania 17042.
6. At the time of the incident the Minor child was under the ma~ority care
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and control of the Petitioner and continues so to be.
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7. Petitioners has incurred medical expenses in the caring and ~atrnent of
the Minor child. Said medical expenses have resulted in outstanding medic~1 expenses
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totaling $1,627.93. A true and correct copy of the medical expenses are att~ched hereto,
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incorporated herein by reference and marked Exhibit "B." There was no m~~ical
coverage available for these medical expenses.
8. East Pennsboro Township has agreed to pay and Petitioner w~nts to accept
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the payment of $17,500.00 to resolve the case against Respondent. A true a~d correct
copy of East Pennsboro Township's proposed Release and letter of the settl~ent offer is
attached hereto, incorporated herein by reference and marked Exhibits "C" ~d "D"
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,
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respectively,
9. Petitioner has made a careful and diligent inquiry and investi~ation into
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the facts surrounding the incident, the responsibility therefore, and the natur~ extent and
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seriousness of the Minor's injuries.
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10. Petitioner has a Contingent Fee Agreement with the undersi~ed. A true
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and correct copy of said Fee Agreement is attached hereto incorporated herel\1 by
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reference and marked Exhibit "E." ii
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II. Petitioner intends to fully invest the proceeds of this settlement and
maintain same for the care and use of the Minor child.
12. Petitioner proposes to distribute the gross settlement procee4s of
$17,500.00 as follows:
a.
Trevor Harner, a Minor, in a restricted
account not to be withdrawn before
majority or upon leave of Court
TOTAL
~ 9,940.77
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~i 5,832.75
~I, 1,515,93
~I 112,00
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Ji 98.55
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~f 7,500.00
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b,
To Menges, McLaughlin, Cunningham
& Kalasnik, P.C. Counsel fees (33.33%)
c.
Holy Spirit Hospital
d.
Orthopaedic Institute of P A
e.
To Menges, McLaughlin, Cunningham
& Kalasnik, P.C. reimbursement of costs
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WHEREFORE, Petitioner, Jeffrey Harner, prays this Honorable Cot enter an
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Order approving the Minor settlement and awarding the appropriate counsellifees as
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requested herein, '
IfJ~ Ie?
n P. McLaughlin,
Sup. Ct. LD. 62737
145 East Market Street
York PA 17401
717-243-8046
Attorney for Petitioners
"A"
ORTHOPEDIC INSTITUTE OF PENNSYLVANIA
(717) 761-5530
Patient: Trevor A. Harner
DOB: 06/01/94 SSN: 205 74 1350
Chart #: 21753006
Page # 1
----------------~-------------------------------------------------------------
6/16/2003 RICHARD J. BOAL, M.D.
OFFICE VISIT
Poplar Church Road Office
CHIEF COMPLAINT, Trevor is a 9 year old young man In generally good health
who was playing on 6-12-03 when he fell onto a sewer drain injuring his right
leg. He had a large laceration on the anterior aspect of the rlght leg. He
was treated at Holy Spirit Hospital with cleansing of the wound and su~ure of
the wound.
X-rays of his tibia were taken. I have reviewed those x-rays a~d they! are
essentially within normal limits.
REVIEW OF SYSTEMS, The patient's review of systems, past medical his~bry,
family history, and social history have been recorded and reviewed. !
PHYSIC~L EXAM, He lS a well developed, well nourished male in no acuce
distress. He is alert and oriented x 3.
On examination this young man's knee is normal. His ankle is normal. i He
does have about a six inch laceration on the anterior aspect of his l8~ which
has been sutured and appears to not be inflamed or infected.
DIAGNOSIS: Laceration of the anterior aspect of the left leg.
PLAN: I am going to have this young man slowly increase his activiti~~.
is not to do anything rough with the leg. He is going to retur~ to s~~
believe on the 24th or the 25th of June and we will remove his sutures:;.
He
me I
His dad told me they would like him to play in one more baseball game I am
not optimistic that this will occur but I will see how he is ge=ting a~ong
when he returns.
RJB/raf
LTR-DR BOAL CORRESPONDENCE
(Ref) COX, D.O., LAWRENCE
6/25/2003 RICHARD J. BOAL, M.D.
OFFICE VISIT
Powers Avenue Office
CHIEF COMPlJI..INT: Trevor returned for follow-up of the laceration to hILS
right leg.
REVIEW OF SYSTEMS: The patient's review of systems, past medical his~ory,
family history, and social history have been re-evaluated and reviewecl-
PHYSICAL EXAM: He is a well developed, well nourished male in no acu~e
distress. He is alert and oriented x 3. On examination today his wounds
look good. Stitches have been removed and steri-strips applied.
--------------------------------------------------------------,----------------
ORTHOPEDIC INSTITUTE OF PENNSYLVANIA
(717) 761-5530
Patient: Trevor A. Harner
DOB: 06/01/94 SSN: 205 74 1350
Chart #: 21753006
Page # 2
-------------------------------------------------------------------------------
6/25/2003
OFFICE VISIT
RICHARD J, BOAL, M.D.
-CONTINUED-
PLAN: He is going to increase his activities as tolerated. He is not to
swim for another week. He will return to see me only as needed.
RJB IJ ep
cc: Lawrence Cox, D.O., via fax
-------------------------------------------------------------+,----------------
"B"
Medical Expenses Summary
Incident of June 12, 2003
RE: Trevor Harner (minor)
No. Provider Datelsl
1 ' Holy Spirit Hospital 6112103
2. Orthopaedic Institute of PA, 6116103, 6125103
Treatment
Charoe
Total $
ERTreatment $1,515ir13
Orthopaedic Treatment $112,Ob
TOTAL MEDICAL EXPENSES THIS LIST .,.,...,..."....'......,..,.. .,."..",. $1,627,93
HeI #
TYPE OF
BILL
,;
. DATE OF BilL
DATE OF
PREVo BILL
':; r
OUTP,
P E PATIENT NAME
HARfoi.tcR ,TRlNOR p,
HOLY SPIRIT HOSPITAL
503 N 21ST 5T
CAMP HILL, PA
717 763-2141
FEI # 23-1512747
PATIENT NUMBER
SEX AGE
ADMISSION DATE
~~
17011
BIRTH-DATE
06/01/94
211595..\8 M 9
06/12/03
C.O.B. INSURANCE COMPANY NAME GAOUPNUMBER POLICY NUMBER
GUARANTOR
wIEFFRE', Ht~RNER
NAME 99 FRONT 5T
AND .JEST FAIRVIBJ P(~ 1"7025
ADDRESS DUB IN JON A
. :1
PLEASE RETURN THIS PORTION WITH YOUR PAYMENT, 7~ *,lUt ,! AMOUNT OF 1$
PAYMENT
-
DATE DESCRIPTION OF I SERVICE TOTAL EST. COVERAGE EST. COVERAGE EST. COY AGE EST. COVERAGE PATIENT
POSTED HQSPIT AL SERVICES CODE CHARGES INS. CO. NO.1 INS. CO. NO.2 INS. CO. 0.3 INS. CO. NO.4 AMOUNT
DETAr _ OF CURRENT CH(,RGES, PA', 1ENT5 AND AD,)l)STr1E rrs
)6/12 ~ur1P SET -;:'.. T'{POI16139313 48.00 48,00
~,
)6/12 3ECOND,~RY SET 0116139339 20,00 20,00
)6/12 :EFAZOLIN 50011GO 144080364 11.00 11,00
]6/12 _IDOCA 1/; 2~iL 0144720100 27.00 27.00
)6.1 12 TETMJUS/DIPT A 0144'790026 47,00 47,00
)6/12 BANDAGE p,CE 4.(\ 0114101372 2.18 2. ~8
)6/12 3UTl.IRE TRAY 0114120000 53.75 53.75
)6/12 ~DAPT DRESS 3:<80114124549 5,00 5.00
)6/12 BM,IDAGE 5TATITE0114125660 1,00 1. 00
)6/12 3TRIPS TEL FA 4:<0114127211 1,00 i 1.00
)6/12 '4ACL 0.9 500 011613064.; 11,00 11,00
)6/12 ',ACL 0.9/; :LOO 0116131278 13.00 13,00
)6/ 12 I'J CATH 0117207002 14,00 14,00
)6/12 TRANSpr,RENT DRE0117207028 1.00 1,00
)6/12 RIGHT LEG 013650165E 158,00 158,00
)6/12 LEVEL IV FG 011710575t" 447.00 447,00
)6! 12 ED I..EVEL IV PC 0117105834 235,00 235,00
)6/12 fEP LAG SP I N~\, T011730690J 421,00 421,00
BALA~ CE FORW\RD 0,00
SU1111I' RY OF CURRENT CHp,RGES
PHARt'IACY 250 153.00 153,00
11/5 SUPPLIES 270 101.93 101,93
DX X-RAY 320 158.00 158,00
Et1ERGENCY ROiJI1 450 1103.00 1103.00
5UB-l OTi~L OF CURRo CH?,RGES 1515.93 1515,93
:v I A-tf IV OS /..5 gCJj.D
'6'1; 0
FEOERAlIDENT. NO. 23-1512747
T 0 T A L S 1515,93 1515.93
PATIENT NUMBER I REFER ALL QUESTIONS TO THE PLEASE SEND PAYMENT TO: I PAY ,
BUSINESS OFFICE i
211595381 (717) 763-2138. HOLY SPIRIT HOSPITAL HIS Ar10UNT 1515.93
503 NORTH 21ST ST EET ADDITIONAL P TlENT BiLLING MAYBE NECESSARY FOR ANY
CHARGE NO OSlE
HOL Y SP I R IT HOSP IT (,L
CAt1P HILL., PA
R
CAMP Hill, PA, 17011,2288
S,P D WHEN THIS BILL WAS PREPARED
OR IF fNSURAI'JCE CARRIERS DO NOT PAY ANY PART OF
THE AMOUN1'$ SHOWN UNDER ESTIMATED INSURANCE
COVERAGE.
OSL DBR ORTH INSTITUTE OF PA
875 POPLAI~ CHURCI~ rO~~D
12: 7" -.- 1 L;. --- (j.3
CRMP HILL PA 17011
'f' ll--"/b 1'-~3~.5:j~::
TAX ID #: 23-1875547
PATIENT: 217530 l-iARNER i-REVOR A
Pi~'T BAL'
Ids BnL"
01i,H Bi=~iL ~
1. ]. 2. ~~;Zi
. ~l~o
.00
-------.-.-------------------------------------.----------------.--.---.--------------------
SEF:;;i) C
DA1-E INV RP S DR PROC DESC
IN", n
COMMEN1" co C#A PL
LINE INVOICE RUNNING
AMOUN~i BALANCE BALANCE
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.~.~_. - - __ __~_ - - .__ __. __.~____ ______.... __ _. ~_ ____ __.~~_ ___~___ - __ __ __ __ __'__' __ - ___. __~._ - ___ ..___ ~ ___ _1....__-- ... ._u ____ ________ _. __u
051603 1 5 1 55 CLATE CHGE LA1-ER 05 ~00 .00 .0Q!
RICHARD J BUAL MD DIAG:
0525(;3 C~ E.. 1 5~j CL.ATE CHGE L.~lTEP 02.. 00 . 1L1Q'1 .0.Q\
RICHARD J BOAL MD DIAG,
051603 ~ 5 i 55 99202 OFFICE OUT 05 70.00 70.00 70.0C
RICHARD J BOAL MD DrAG: 891.0 E84S.0 EB85.9
tZ.\bc:502:0 Lt b 1 5::'; r::Y:)~:::1~~~ OFFICE OUT Oi.~: L~2. 0:L'l L~c~. 00 l1e:. Ql~)
RICHRRD J BOAL MD DIAG: 891.0 E849.0 E885.9
--------------.----------- END OF' PQTIENT HISTORY --------------~------.-----.-----
*** TOTALS ***, CHRRGES: 112.00 PAY01ENTS: .00 ADJWSTS: .00
======================:==========~=============================~===============
"C"
GENERAL RELEASE OF ALL CLAIMS
FOR AND IN CONSIDERATION of Seventeen Thousand Five Hundred -----001100
($17,500,00) Dollars, receipt of which is hereby acknowledged, I, Jeffrey Harner as Legal Guardian for
Trevor Harner, a Minor, DO HEREBY RELEASE AND FOREVER DISCHARGE, East Penn.boro
Township, and any and all of its agencies, predecessor and successor agencies, and any anp all agents,
insurers, servants, employees, officers, officials and assigns (hereinafter referred to as the 'IEast Pennsboro
Township", from any and all actions, including any and all claims for contribution and/or ijIdemnification,
causes of action, claims, demands, damages, costs, consequential damage or any other thing whatsoever on
account of and in any way growing out of Bodily Injury and all known and unknown pers~na1 injuries,
unknown property damages or loss of any nature which I now have or may hereafter have, resulting or to
result from or rising out of an accident which occurred on or about June 12, 2003, in East lPennsboro
Township, Penusylvania,
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I hereby acknowledge and assume all risk, chance or hazard that the said damage~aY be or
become permanent, progressive, greater or more extensive than is now known, anticipated r expected. No
promise or inducement which is not herein expressed has been made to us, and in executin i this Release I
do not rely upon any statement or representation made by any of the above named East Pe ',nsboro
Township, or any person, firm, corporation or agent representing the East Pennsboro To :nship
concerning the nature, extent or duration of said damage or the legal liability therefore, I
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I understand that this settlement is the compromise of a doubtful and disputed clai~. and that the
payment is not to be construed as an admission of liability on the part of anyone, including e above
named East Pennsboro Township hereby released by whom liability is expressly denied,
This release contains the entire agreement between the parties hereto and the termlofthis Release
are contractual and not a mere recital. i
In further consideration of the above payment, I, the Releasor, for myself, my heir, next of kin,
executors, administrators, successors, successors in title, and assigns convenant and agree t indenmify and
hold hannless the said East Pennsboro Township and any and all predecessor and success r parties for
any and all claims, demands and suits for damages, costs, expenses or compensation which I or my heirs,
next of kin, executors, administrators, successors, successors in title or assigns have or may have on
account of or in any way growing out of said occurrence or its results.
I certify that I am over eighteen (18) years and I FURTHER STATE THAT I HA~ECAREFULY
READ THE FOREGOING RELEASE OF ALL CLAIMS AND KNOW THE CONTENT 'THEREOF
and I sign same as my own free act.
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WITNESS my hand and seal this day of ,2005, "
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WITNESS: I
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Jeffrey Hamer Legal Guardian of Trevor HaJ;or
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COMMONWEALTH OF PENNSYLVANIA
: s.s.
COUNTY OF YORK i
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Before me the undersigned official, personally appeared Jeffrey Hamer, Legal GUatdian of Trevor
Harner, Minor, who being by me fIrst duly sworn did depose and say that they had executed the foregoing
RELEASE as their own true act and deed and desires the same to be recorded as such,
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Notary Public
"D"
MENGES
MCLAUGHLIN
CUNNINGHAM
KALASNIK. PC
AITORNEYS AT LAW
N, CHRISTOPHER MENGES
SHA WN P. MCLAUGHLIN
DARRYL W. CUNNINGHAM
JOSEPH A KALASNIK
GUNNARL.ARMSTRONG
SYDNEY C. H. BENSON
OF COUNSEL:
FRED E, KILGORE
October 31, 2005
(Dictated on October 24, 2005)
FI~E COpy
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VIA FACSIMILE: (717) 671-7351 and first class mail
Michael A. Rolko, Claim Representative
St. Paul Travelers
6360 Flank Drive, Suite 1200
Harrisburg, P A 12112-2766
RE:
Tracking Number:
Our Client:
Insured:
Claim No:
Date of Loss:
Dear Mr. Rolko:
UW11324
Trevor Harner (a minor)
East Pennsboro Township
GP0931023509T003
June 12, 2003
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This letter is a follow-up to our telephone conversation of October 14,2 P5, Please be
advised that Mr. Harner has authorized me to accept a final settlement of $17,50 ,00 on behalf of his
son, Trevor. Therefore, please forward any release you may require, Of course, II will need to put
together a Minor Petition for presentation to the Court. If you have any comme ts or questions in
the meantime, please let me know, otherwise thank you for your work to date in 'esolving this claim,
II
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Thank you. I'
SPM/sms
CC: Jeffrey Harner
PLEASE REPLY To:
11145 EAST MARKET STREET
YORK,PA 17401
TELEPHONE (717) 843-8046
FAX (717) 854-4362
E-mail YorkfWYQurLawFinnForLife.com
Very truly yours,
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, McLaughlin
www.YoURLAWFIRMFORLlFE.COM
021! KENNEDVCOURT, SUITES
HANOVER, P A 17331
TELEPHONE (717) 632,1784
FAX (717) 632-2433
E-mail Hanover(wYourLawFimlForLife.com
o 18 E I 5T KING STREET, 21\D FLOOR
NCASTER, PA 17602
TEIEPHONE(717)560-5068
FAX (7 J 7) 735,7709
E~mail an aste a~ YourLawFirmFor ife.com
TOLL FREE 1-866-464-5297
"E"
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CLIENT REPRESENTATION OPTION
IIW e, the undersigned request that our file and all pertinent documentation and infomtation:
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Be transferred to Menges, McLaughlin, Cunningham & Kalasnik, LLf to assume
representation of me/us in this matter. IIW e understand that no additlbnal attorney fees
will be incurred as a result of this change, I,
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Be delivered to the law firm of at i
, P A and that all monies and costs due on m ',file for
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representation must be paid in full to Stambaugh, Rickards & Franke I prior to the file
being forwarded to my new attorney, '
-:5~~'1 A Hc,-c (\E::.{
Client Name, Printed
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C1ien i ~ I
Client Name, Printed
Client signature
(; I ~ ~y
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PLEASE REPLY To:
./
'" 145 EAST MARKET STREET
YORK,PA 17401
TELEPHONE (7 17) 843-8046
FAX (717) 854-4362
TOLL FREE 1,866-464-5297
E~majl mtlm@vorklawoffice.com
o 1157 E1CHELBERGER STREET
HANOVER, P A 17331
TELEPHONE (717) 632,1784
FAX (717) 632-2433
E-mail m~m@hanoverlaw.coro
o 18 EAST G STREET, 2ND FLOOR
LANC ~TER, P A 17602
TELEPH !<E (717) 560-5068
FAX rI7)735-7709
E-mail mlllncasterra2de"azzd.com
FRANKEL
CUNNINGHAM
STAMBAUGH
8: ASSOCIATES
ATTORNEYS AT LAW
l4WEST KING STREET
IRK. PENNSYLVANIA 17401
CONTINGENT FEE AGREEMENT
The Client employs the law firm of FRANKEL, CUNNINGHAM,
STAMBAUGH & ASSOCIATES, as my attorneys in the representation, trial, or
settlemw.e .1 a~, clail}' regar.d)ng: . I 'L
~~ 1\ r'r Ie - I 'i - 0, \ ,"" '3fnr........ ~ Cool '"
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with full power and authority to appear on my behalf.
For all services performed, the client agrees that the attorn~\ shall receive
. of any recovery, including all u I derinsurance,
insurance, and liability payments, as full payment of the profesi.ional services,
The employment is on a contingent basis and if no recovery i' received, no
attorneys' fees are due. ,i
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The contingent fee shall be calculated from the gross reco ~ry and before
any expenses are deducted. This fee is valid through proceedin S at trial. Any
fees for proceedings to a higher court will be negotiated separalely.
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The attorney shall be paid the same percentage as state ! above of any
oral or written settlement offer or award from any recovery plus II costs if this
contract is terminated by either party.
The client shall be responsible to pay for all costs incurre
be a recovery or no recovery. The costs may include, but are
medical reports, stenographic services, office expenses, com
fees, filing fees, Sheriff's costs, investigation costs, medical-p
and expert costs. These costs shall be paid in advance
arrangements are made.
should there
ot limited to,
'uter research
ralegal costs,
',unless other
This agreement has been signed on
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The Client acknowledges receipt of a copy of this
Agreement. OA H) (_l
WITNESS:
C~ntingent
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Fee
Jill
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Client
VERIFICATION
I verify that the statements made in this Petition for Minor's Settlemen~ are true and
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correct. I understand that false statements herein are made subject to the pen~ties of 18 Pa.
C.S, Section 4904, relating to unsworn falsification to authorities.
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v) It1Vv~
Dated:
(
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Jeffrey 'darner, atural Guardian for Trevor Harner, Minor
.... \] 11'
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(,.-"
IN THE COURT OF COMMON PLEAS
OF CUMBERLAND COUNTY, PENNSYLVANIA
DEe 0 5 2005
;:(J1f
TREVOR HARNER a Minor by
JEFFREY HARNER, Parent and
Natural Guardian,
NO. OS- -~J..4S c."utl ~8I...\
Petitioners
CIVIL ACTION - LAW
v,
EAST PENNSBORO TOWNSHIP
Respondents
ORDER
AND NOW, this (, ~ day of ~ ,2005, upon Petitioner, Shawn P.
McLaughlin, Esquire, and in consideration of the attached Petition For Minor's
Settlement is it hereby Ordered that a Hearing shall be held on (~).!( ,
2005 beginning at <'6jA.m., in Courtroom number 5 of the Cumberland County
Courthouse,
Judge
~ ,
t: '~
,..... \'!,
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r.-] ,'~j
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.
IN THE COURT OF COMMON PLEAS
OF CUMBERLAND COUNTY, PENNSYL VANIA
TREVOR HARNER a Minor by
JEFFREY HARNER, Parent and
Natural Guardian,
NO. 0 S - (PlZ S- (;01) 1 er IV)
Petitioners
CIVIL ACTION - LAW
v.
EAST PENNSBORO TOWNSHIP,
Respondents.
ORDER
AND NOW, this J&' ~ day of ~ 2005, upon Petition for Minor's
Settlement of Menges, McLaughlin, Cunningham and Kalasnik, P.C. and Shawn P.
McLaughlin, Esquire, and after hearing of the same, is hereby Ordered as follows:
1. The Minor settlement with East Pennsboro Township, Respondent is
hereby approved in the amount of$17,500.00. Attorney's fees and costs to the law firm
of Menges, McLaughlin, Cunningham and Kalasnik, P.C. are approved in the amount of
$5,931.30 ($5,832.75 fees + $98.55 costs).
2. Payment of the medical expenses to Holy Spirit Hospital and Orthopaedic
Institute ofP A totaling $1,627.93 is approved.
3, Petitioners are authorized to sign a general Release or other appropriate
Release with the East Pennsboro Township.
4. The remaining funds, totaling $9,940,77, are authorized to be placed with
assistance of counsel, in a federally-insured financial institution or savings bank in the
name of the Minor, with the provision that no withdrawals can be made from such
account until the Minor reaches his majority. Proof of the deposit shall promptly be filed
with the Court.
BY THE
Judge
!'J
Chl' dopher mellYS &JILU~
j Ihr~'&~ Cro
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. "''''''''J
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'is :5 [1'1 82 JJO SGllZ
"1\'1."\"".',..; """ 1""11":10
Nj\;c..Ll.-';~\_.<I:\;::'~(J =-11
3Ji:.<!'-O:nij
IN THE COURT OF COMMON PLEAS OF
CUMBERLAND COUNTY, PENNSYL VANIA
TREVOR HARNTER, A Minor by
JEFFREY HARNER, Parent and Natural:
Guardian
NO. 05-6225 Civil Term
Petitioner,
CIVIL ACTION - LAW
v.
EAST PENNSBORO TOWNSHIP
Respondent.
PRAECIPE TO SETTLE/WITHDRAW AND DISCONTINUE
TO THE PROTHONOTARY:
Please withdraw the above-captioned action and mark as settled, discontinued and
ended and/or dismissed.
MENGES, MCLAUGHLIN, CUNNINGHAM
& KALASNIK, P.C.
~/ ~ _-'7~(
Shawn p, McLaughlin, Esquire
Sup. Ct. LD. No. 62737
145 East Market Street
York, PA 17401
(717) 843-8046
Attorney for Plaintiff
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IN THE COURT OF COMMON PLEAS OF
CUMBERLAND COUNTY, PENNSYLVANIA
TREVOR HARNTER, A Minor by
JEFFREY HARNER, Parent and Natural:
Guardian
NO. 05-6225 Civil Term
Petitioner,
CIVIL ACTION - LAW
v.
EAST PENNSBORO TOWNSHIP
Respondent.
AFFIDAVIT OF DEPOSIT
Before me, a Notary Public, in and for said County and Commonwealth, personally
appeared Shawn P. McLaughlin, Esquire, who being duly sworn according to law deposes and
says that in accordance with the December 28,2005 Court Order, the amount of the minor
settlement has been deposited in a federally-insured til1ancial institution or saving bank in the
name of the minor, as shown by the Deposit Receipt hereto attached.
MENGES, MCLAUGHLIN, CUNNINGHAM
& KALASNIK, P,C.
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Date: '1 - d-I ,[i i
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Shawn-P:-MCLaughlin, Esquire
Sup. Crt. LD. No. 62737
Attorney for Petitioner
SWORN iln~UBSCRIBED to before
me this .fJJ..3!1 day of August, 2002
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Notarial S$el
Diana K. DoWdell, Notary Public
City of York, Yor1< County
My Commission Exp....s Sept. 11, 2007
Member, Pennsylvania Association of Notariea
WACHOVIA
TIME DEPOSIT
AUTOMATICALLY RENEWABLE
PERSONAL CD 12 UP TO 18 MONTHS
Opening Date
Account Number
Taxpayer 10 Number
APRIL 20, 2006
247402052579909
206741350
This Receipt Acknowledges That The Depositor Named
Below Has Deposited With This Bank The Sum Of $ ***"'*****10,000.00**;'**
Depositor
Name And
Address
TREVOR A HARNER
612 STRITES ROAD
HARRISBURG PA 17111
Term
Maturity Date
JUNE 20, 2007
Interest Rate Per Annum
04,74%
Annual Percentage Yield Interest Payment Frequency/Period
14 MONTHS
04,85%
1 MONTH(S)
Interest Payment Disposition
CAPITALIZE
Account to Credit
PROD-TYPE: 205
PROMO CD: CP00116
Issued by
WACHOVIA BANK, N.A.
NE CNTRL PA / UNION DEPOSIT
PA
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Authorized Signature
X
Date
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Member FDIC
NOT TRANSFERABLE
CUSTOMER RECEIPT
566591 (Rev 04 Page 1 of 3)
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