Loading...
HomeMy WebLinkAbout01-06-06 . . IN RE: ESTATE OF THE AARON J. SIODLOWSKI IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA 2005-00698 ORPHANS' COURT DNISION PETITION FOR SETTLEMENT AND NOW, comes your Petitioner, Robert J. Siodlowski, by and through his attorneys, Mancke, Wagner & Spreha, and files the following Petition for Settlement: 1. Your Petitioner, Robert J. Siodlowski, is the Administrator of the Estate of the Late Aaron J. Siodlowski. 2. The Late Aaron J. Siodlowski died June 18, 2005 as a result of an automobile accident in which he was fatally injured. 3. The Administrator of the estate engaged the services ofMancke, Wagner & Spreha, for purposes of administering the estate, as well as asserting a claim on behalf of the decedent as a result of the automobile accident. 4. The operator ofthe motor vehicle in which the decedent was fatally injured was insured through Allstate, the insured being Robert Weeks. 5. Allstate as tendered policy limits as set forth in Exhibit A attached hereto as full satisfaction of the claim against the operator of the motor vehicle in which the decedent was ,.,~ '.') .,.. ,1 ) fatally injured. :"-:' I ^'...::~ 6. The insured's carrier, Allstate, requires Court approval of the settlement, but does not require a hearing for Court approval, as evidenced by the letter from Allstate, a copy of which is attached hereto, incorporated herein by reference and marked as Exhibit B. 7. A copy of the Contingency Fee Agreement executed between the estate and counsel for the estate is attached hereto and marked as Exhibit C. 8. Counsel on behalf of the estate has opened the estate, intends to administer the estate as part of the overall fee structure at no extra charge, will pay costs on behalf of the estate without seeking reimbursement, has investigated the automobile accident, has interviewed witnesses, has asserted a claim to the insurance company, has gathered medical records, and has further advanced the claim on behalf of the estate. 9. Counsel for the estate respectfully requests the Court to approve the settlement subject to distribution in accordance with the Fee Agreement. 10. Counsel for the estate further confIrms that costs of administering the estate, and costs the assert the claim, are all part of the fee to be received by counsel for the estate. -2- VERIFICATION I verify that the statements made in the foregoing document are true and correct. I understand that false statements herein are made subject to the penalties of 18 Pa.C.S. Section 4904, relating to unsworn falsification to authorities. DATE: /;?--02:? .-() S ~.-tI ~ HARRISBURG ~ I LJllstate 6345 FLANK DRIVE, SUITE 1000 ~ ~HARRISBURG PA 17112-2765 You're in good hands, I,ll 111111/ r 11/1111/111111111/1/111111 11111111111. 11,111111,/1 LAW OFFICES MANCKE WAGNER & SPREHA 2233 N FRONT ST HARRISBURG PA 17110-1027 October 11, 2005 INSURED: ROBERT WEEKS DATE OF LOSS: June 16,2005 CLAIM NUMBER: 1555151784 B32 Your Client: Estate of Aaron Siodlowski PHONE NUMBER: 800-726-8890 FAX NUMBER: 717-540-7540 OFFICE HOURS: Mon - Fri 8:00am - 5:30pm Dear ML Wagner, Thank you for your recent demand package dated October 3, 2005, Please be advised that we agree to tender our bodily injury liability limits of $1 00,000,00, I have enclosed proof of the policy limits, I have enclosed some structured settlement proposals for the Estate's consideration, If any would be of interest, please let me know, Ifnot, I have also enclosed a release, Upon receipt of the executed release and a copy of the judge's order, I will promptly issue payment. If you have any questions, feel free to caIl me, Sincerely, 7(jm6erCy 'l(p{{y Kimberly KeIly 800-726-8890 Ext7562 Allstate Insurance Company -A - GENJOOl 1555151784 B32 ID~C ~2 "OO~ 1"40AM ~ . I ,L ~ " ALLSTATE !NS. Hog, Pa, 17112 ~ . HARRISBUR.G AII.state 6345 F:LANX DRIVlii, Sr.lX'I'E 1000 eHARRIBBr.lR~ FA 171l2-276S You're In ~ood Mnds. 11111111111,111111 Ii 1111111111111 r " 111.111111111 tll.1 " 111111 LAW OFFICES MANCKE WAGNER & SPREHA 2233 N FRONT ST HARRISBURG PA 17110-1027 December 12, 2005 INSURED: ROBERT WEEKS DATE OF LOSS: JW1e 16,2005 CLAIMNUMBER: 1555151784B32 Your Client: Estate of Aaron Siodlowski Dear Mr. Wagner, NO, 684 P 2 PHONE NUMBER: 800-726-8890 FAXNUMBBR: 717-540-7540 OFFICE HOURS: Mon. Fri 8:00am - 5:30pm Sincerely, As we discussed, once we havc a copy of the order from the court we will be glad to promptly finalize this claim. 7(jm6erCy 7(J{{y Kimberly Kelly 800.726-8890 Ext.7562 Allstate Insmance Company GENIOO 1 -B - 1555151784 B32 POWER OF ATTORNEY arul CONTINGENT FEE AGREEMENT OW ALL MEN BY THESE PRESENTS, THAT Uwe, '(a?-4~ (.) ~~Atlv;t"), lod L-C>.......~).<-: ' , do hereby retain MANCKE, WAGNER and SPREHA, of arrisburg, Pennsylvania, as my/our attorneys to negotiate for an adjustment or to institute for me/us in my/our name any legal actions or proceedings that in their judgment are ?ecessary, in connection with mY/9~r claim tor ?amages agamst 'D"':;)I-W"P-r-=--, (,c;.\L..r..- ~a_\1.., '"J\r ~-()J ~~l<.s or anyone else as a result of inju~!es or damages sustained by me/us on the I ~ day of ~,-,,--,"- \ \... 20 () ') . I/we agree not to settle or adjust the above claim or any proceedings based thereon without the written consent of my/our said attorneys. NOW, THEREFORE, in consideration of the services so to be rendered by my/our said attorneys, Uwe hereby covenant, promise and agree to pay to my/our said attorneys for their professional services rendered THIRTY-THREE AND ONE-THIRD (33 -1 /3 %) percent of whatever sum is recovered as a result of settlement without suit plus necessary expenses incurred in the event of any recovery, or-FQR~{4o.%}-percent..in-th~./-) suit-is.-iiled-ef-t.riaJ is hel~ plus~~xpenses-itlCuu:ed in the e~enLoEany...sucn.recoYery. (;j-;;;;?( ....-.-~> AND NOW, this 2 t/- day of JL~ , 20oS:the above Contingent Fee Agreement and Power of Attorney has been read, approved and understood by Ius and the rece~' pt of c py thereof acknowledged. The terms set forth are agreeable. /'/' / / -, /' ~ '------ I C (SEAL) f Ii /1 .' -t/,Q~2 ~_: (SEAL) (SEAL ) -c-