HomeMy WebLinkAbout06-0888
CASEY L. KRESGE,
Respondent
MINOR'S COMPROMISE
F:\WP Directories\BWS\Minor's Compromisc\l.ynch.wpd
SAVANNAH LYNCH, by and
through her natural parent
and guardian, CAROL BEAL,
Petitioner
IN THE COURT OF COMMON PLEAS
CUMBERLAND COUNTY, PENNSYLVANIA
No. 2006 - FN? CIVIL TERM
v.
CIVIL ACTION - LAW
PETITION FOR LEAVE TO
COMPROMISE MINOR'S ACTION
Pursuant to Pennsylvania Rule of Civil Procedure No, 2039, Carol Beal, the natural
parent and legal guardian of the minor, Savannah Lynch, by her attorneys, HANDLER,
HENNING & ROSENBERG, LLP, by Matthew S, Crosby, Esq" petitions this Honorable
Court to enter an Order permitting settlement and compromise of this action and,
in support thereof, avers:
1, Savannah Lynch was born on December 12, 1989, and is, therefore, 16 years old
and a minor. She currently resides at 402 Boxwood Court, Mechanicsburg,
Cumberland County, PA 17050,
2, Petitioner, Carol Beal, is an adult individual and said minor's natural parent and
legal guardian, She currently resides with Savannah at 402 Boxwood Court,
Mechanicsburg, Cumberland County, PA 17050,
3, Respondent, Casey L, Kresge, is a competent adult individual currently residing at
17 Koser Road, Shippensburg, PA 17257,
4, On or about June 30, 2003, at approximately 3:42 p,m" the minor, Savannah
Lynch, was a passenger in a vehicle operated by Carol Beal (hereinafter
"Petitioner's vehicle"), which was traveling northbound on South College Street
approaching the intersection with West Willow Street in Carlisle, Cumberland
County, Pennsylvania,
5, On or about June 30, 2003, at approximately the same time and place, Respondent,
Casey L. Kresge, was the operator of a 1998 Plymouth (hereinafter referred to as
"Respondent's vehicle"), which was traveling westbound on West Willow Street,
approaching the intersection with South College Street. This intersection is
controlled by a Stop sign on West Willow Street.
6. Suddenly and without warning, Respondent's vehicle continued through the
intersection of South College Street and West Willow Street without stopping for the
posted Stop sign and pulled in front of Petitioner's lawfully proceeding vehicle,
causing a violent collision.
7. As a direct and proximate result of the negligence of the Respondent, the minor,
Savannah Lynch, suffered multiple injuries including, but not limited to, a contusion
to her right shoulder.
8, The minor, Savannah Lynch, was treated and released from Carlisle Hospital on the
date of the crash, Fortunately, she has not required any additional medical care at
all, Attached hereto, made a part hereof, and marked, "Exhibit A" are copies of the
minor's hospital records,
9. To date, all of said minor's collision-related medical bills have been paid,
10, Respondent's vehicle was insured under a policy of motor vehicle insurance issued
by Travelers Insurance Company that was in effect at the time of the accident.
11, Following negotiations, Travelers Insurance Company has offered to settle the
minor's claim against the Respondent, Casey L. Kresge, for a gross settlement of
$1,000,00. Attached hereto, made a part hereof, and marked "Exhibit B," is a copy
of the proposed settlement release.
12, Petitioner believes said settlement is in the best interests of the minor and proposes
to accept said settlement offer of $1,000,00, thereby releasing Respondent from
any and all claims, suits, and/or actions in the future,
13, Matthew S. Crosby, Esq., of HANDLER, HENNING & ROSENBERG, LLP, has
been the attorney for the minor in this action and he requests reasonable counsel
fees of $250,00 for services rendered plus costs and expenses of $111,04,
pursuant to a Contingent Fee Agreement signed by Petitioners, The 25% counsel
fees represent a reduction from the 33-1/3% fee agreement signed by the Petitioner
for Savannah Lynch, Thus, the total amount requested for attorney's fees and costs
is $361,04, Attached hereto, made a part hereof and marked, "Exhibit C," is the fee
agreement, and "Exhibit D", a true copy of the billing summary,
14, Petitioner requests this Honorable Court to order a payment of said balance of
$638,96 to be placed in an account investing only in securities guaranteed by the
United States government or a Federal governmental agency managed by
responsible financial institutions, bearing the name of the minor, Savannah Lynch,
that is marked "Not to be withdrawn until minor reaches the age of 18 or without the
Order of a Court of Competent jurisdiction."
15, Petitioner, Carol Beal, believes that this Compromise is in the best interests of her
minor daughter, Savannah Lynch,
WHEREFORE, Petitioner requests this Honorable Court to:
a, Approve the Compromise above-stated;
b. Authorize payment of the above-stated fees from funds
due the minor; and
c, Direct payment of the net funds due, in accordance with
the above-stated Compromise,
Respectfully submitted,
DATE: Z/13Iz.ca.
ROSENBERG, LLP
BY:
Matthew S, Crosby, Esq,
1.0, # 69367
1300 Linglestown Road
Harrisburg, PA 17110
(717) 238-2000
Attorneys for Petitioner
--
(.Xl'lb;t A
INITIAL ASSESSMENT FORM
4
Non-Urgent
Tlis/e Regional Medical Center
. Pt#: 9256584
Sex: F MR#: 0000609678
PRIORITY:
( .
Patient:
LYNCH, SAVANNAH T
12/12/1989 AGE: 13YRS
FRONKO, GERALD MD, PHD
. NON-STAFF, OUT OF TOWN PHY'
Worker's Camp:
Emp, Referred:
DOS:
EDP:
PCP:
DATE: 06/30/2003
Presentation Time: 16:12
Triage Time: 16:46
Arrival Mode: WALKED
Last T elanus:
Ace Sy: Step Fall1er
Vital SiQns
T: 99,6 PO
P: 87 Regular
R: 14 Un labored
SP: 133/086
02: % RA
Pain Intensity Scale: 0 /10
Pain Location: Denies Pain
Height:
Chief
Complaint:
" Weight: 130,0 Ibs, 59,1 kgs, LMP: AT PRESENT
MVA--MINOR INJURY
Brief restrained front seat passenger-her car t-boned by another. Denies injuries.
Assessment:
NIGHT SWEATS
WEIGHT LOSS
ANOREXIA
HEMOPTYSIS
FEVER
NO
NO
NO
NO
NO
SAFETY NO
RESTRAINED YES
DRIVER NO
AIRSAG DEPLOYED YES
Sudden
Onset:
Pre-Hospilal
Treatment:
Pediatric G&D App, for Age. NO, Immunization UTD. NO, Height ft, in" Head Circ, - Grade -, with Slep Fall1er
Assesment:
Past Medical none
History:
Allergies: nkda
Medicines: none
Additional Notes:
;
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/
Nurse Signature: SMK
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EXHIBIT
I A
:arlisJe Hospital -- Emerqency Department
46 Parker Sl Carlisle. PA 17013 -- (717~ ,-5500
Lvnch. Savannah
6/30/0 ,51 pm
ISPOSITION SUMMARY
Patient: Lvnch. Savannah
SS #:
CURRENT Address:
City:
Current Ph:
Zip:
Arrival: 6/30103 5:51 pm
Disch: 6/30103 5:53pm
MD ED: Gerald E, Fronko. MD
Res/PAlNP: Duane Stroup, PA-C
Ox #1: MVA (Unspecified)
ICD-9 #1: EB19,9
Ox #2: Contusion, Shoulder Reaion
ICD-9 #2: 923,00
~
PMD:
PMD Ph:
0609678
AqeIDOS: _
Medical Record: 0609678
Disposition:
#1 Ox Enql: MOTORVAESW
#2 Dx Enql: CONTUS,ESW
Follow-up: YOUR FAMILY DOCTOR
FlU MD Ph:
#1 Ox Span: MOTORVASSW
#2 Ox Span: CONTUS.SSW
FlU DIT: as needed
Other Instr: ice packs. rest Tvlenol or Motrin as needed for pain, return to the ER as needed
MY SIGNATURE BELOW INDICATES:
. I have received and understood the oral Instructions reqardinq my current
medical problem.
, I will arranqe follow-up care as instructed above,
I acknowledqe receipt of the written instructions as outlined
Patient (or Leqal Guardian) Siqnature
f:.x0' b,t 13
I
PLAINTIFF'S
EXHIBIT
f3
RELEASE IN FULL
FOR THE SOLE AND ONLY CONSIDERATION OF Oue Thousand Dollars and 001100 ($1,000.00) to
melus, paid receipt of which is hereby acknowledged, I1we hereby release and discharge David J. Mosser,
Denise M. Mosser, Colin J. Spirk and Casey L. Kresge and Travelers Property Casualty Insurance
Company of lllinois (Travelers) his or their successors and assigns, from all claims of any kind or
character which Ilwe have or might have against him or them, and especially because of all damages, losses
or injuries to persons or property, or both. whether developed or undeveloped, resulting or to result from
accident on or about July 30, 2003 atlnear West Willow Street and South College Street Carlisle, PA, and
I/we hereby acknowledge full settlement and satisfaction of all claims of whatever kind or character which
I1we may have against him or them by reason or the above mentioned damages, losses or injuries. I1we
hereby release him or them for all injuries and damages known, or unknown, suspected or unsuspected,
Ilwe have represented that the injuries sustained are pennanent and progressive, and that recovery
therefrom is uncertain and indefinite, and in making this Release and Agreement it is understood and
agreed that I1we rely wholly upon my/our own judgment, belief and knowledge of the nature, extent and
duration of said injuries and that no representations or statement regarding said injuries or regarding any
other matters made by the persons, firms or corporations who are hereby released. or any person or persons
representing him or them, or by any physician or surgeon by him or them employed has influenced me/us
to any extent whatever in making this Release,
1t is understood and agreed that the undersigned have entered into a separate agreement with Travelers
Property Casualty Insurance Company of lllinois (Travelers) whereby all subrogation liens have been
resolved, In further consideration of the payment made herein, the undersigned hereby agree to satisfy any
and all other subrogation interests, The undersigned further agree to indemnify, defend, save and hold
harmless David J. Mosser, Denise M. Mosser, Colin J. Spirt and Casey Kresge, and Travelers
Insurance Company of minois (Travelers) their respective heirs, executors, administrators, assigns and
insurers against loss from any and all further claims and demands made against them on account of the
injuries sustained in consequence of the aforesaid accident.
It is further understood and agreed that the payment of said amount is not to be construed as an admission
of liability upon the part of said persons. firms or corporations; liability being by him or them expressly
denied. All agreements and understandings between the parties hereto are embodied and expressed herein
and the terms of this release are contractual and not a mere recital,
This release does NOT ilpply to first-party automobile insurance benefits with Erie Insurance Group,
I/WE HAVE READ THE FOREGOING RELEASE AND FULLY UNDERSTAND IT
Signed, sealed and delivered this
2005 in presence of
day of
(Seal)
Carol A Beal, as parent and Natural guardian for
Savannah Lynch
(Seal)
Sworn to before me this _ day of
,2005
Notary Public
-
-
[' xtu b; f- C
-
CONTINGENT FEE AGREEMENT
I, Carol Beal, natural parent and guardian of SAVANNAH LYNCH, a minor, do hereby
retain HANDLER, HENNING & ROSENBERG, LLP" of Harrisburg, Pennsylvania, as my attorneys
in this matter to represent me and to process, negotiate, arbitrate a settlement or to institute in my
name, any legal proceedings or actions that, in their judgment are necessary, against CASEY
LYNN KRESGE, DENISE M, MOSSER, or anyone else, as a result of injuries and damages my
child sustained in an incident that occurred on June 30, 2003,
I agree not to settle, negotiate or adjust the above claim or any proceedings based thereon
without the written consent of my said attorneys,
In consideration of the services so to be rendered by Handler, Henning & Rosenberg, LLP,
I hereby covenant, promise and agree to pay them for their professional services rendered,
THIRTY-THREE AND ONE-THIRD PERCENT (33 %%) of whatever sum is recovered as a result
of settlement without lawsuit; or FORTY PERCENT (40%) of whatever sum is recovered after
lawsuit is filed or in the event of arbitration or mediation, I will reimburse Handler, Henning &
Rosenberg, LLP, for any necessary expenses advanced on my behalf in pursuing my claim,
Examples of typical expenses include Court filing fees, investigation, auto mileage, photocopies,
court reporters, medical records, expert witness fees, etc, If no money is obtained, client will
not owe a legal fee or expenses. I also agree to take possession of my medical files at the
conclusion of this case, My failure to take possession of these files within 60 days after the
conclusion of the case will authorize my lawyers to destroy said files,
I agree that HANDLER, HENNING & ROSENBERG, LLP, may associate additional lawyers
to assist with this case and I agree to the sharing of fees between lawyers, I understand the terms
herein apply to other lawyers associated on this case, I understand that the association of other
lawyers does not increase the amount of the attorney fees at the conclusion of the case,
Counsel reserves the right to withdraw if they desire to do so, for any reason(s) they deem
proper.
I acknowledge that I have read, approved and understood the above Contingent Fee
Agreement and I acknowledge having received a copy of the same, The terms set forth herein
are accepted,
- ( IN WITNESS WHEREOF, I have hereunto set my hand and seal this t~ay of _
) vJ ,2003,
( ~ .... ---- y; ~ (SEAL)
~ CAROL BEAL, natural pare t and
guardian of SAVANNAH L Y CH, a minor
j
PLAINTIFF'S
EXHIBIT
(,
Cl.hJb,+ J)
~ndlllr ,
Ilnningrr
I oSllnbllrg,LLP
ATTORNEYS AT LAW
1300 Linglestown Road, Harrisburg, PA 17110
Client No: 208524
Matter: 00000
Attorney: MSC
MV
Pre-Bill No: 17757
Bill Date:
February 06, 2006
Savannah Lynch
125 Heron Way
Carlisle, PA 17013
EXPENSES
07/29/2003
CASE
04/28/2005
AUTO
02/06/2006
CASE
02/28/2006
COpy
02/28/2006
ISI
02/28/2006
POS
INVOICE
PAYMENT DUE UPON RECEIPT
Vendor CHART ONE INC,; General Case Expense
07/29/2003
Auto Track Search
04l28/20lJ5
Vendor PROTH OF
28.49
18,00
55,50
Document
2.20
Document
,85
TOTAL EXPENSES
$111.04
Total due this invoice
$111.04
$111.04
TOTAL BALANCE DUE
EXHIBIT
I D
1
.~~
~A:'
natural parent and guardian of
SAVANNAH LYNCH, a minor
VERIFICATION
I, CAROL BEAL, natural parent and guardian of SAVANNAH LYNCH, a
minor, hereby verify that the statements made in the foregoing pleading are true and
correct to the best of my knowledge, information, and belief. I understand that false
statements herein are made subject to the penalties of 18 Pa, C,SA, Section 4904
relating to unsworn falsification to authorities.
DATE: :2J ij/ZbO ~
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RECEIVED FEB 15 ZOO~ ~
SAVANNAH LYNCH, by and
through her natural parent
and guardian, CAROL BEAL,
Petitioner
IN THE COURT OF COMMON PLEAS
CUMBERLAND COUNTY, PENNSYLVANIA
NO. 2006 -<fP~ CIVIL TERM
v.
CIVIL ACTION - LAW
CASEY L. KRESGE,
Respondent
MINOR'S COMPROMISE
ORDER
AND NOW, this nl" day of F~
consideration of the foregoing Petition,
, 2006, upon
IT IS HEREBY ORDERED that the disbursement of funds, as well as counsel fees
and expenses, are approved as set forth in said Petition and shall be disbursed in
accordance with the terms and conditions of the settlement agreement as follows:
A Direct payment of $361,04 to Matthew S, Crosby, Esq" representing
reasonable attorney's fees of $250.00 and $111,04, for reimbursement of costs;
B. Direct payment of $638,96 to be placed in an account investing only in
securities guaranteed by the United States government or a Federal governmental agency
managed by responsible financial institutions, bearing the name of the minor, Savannah
Lynch, that is marked "Not to be withdrawn until minor reaches the age of 18 or without the
Order of a Court of Competent jurisdiction"; and
-
//
C. Proof of deposit is to be filed with t
J,
,} 1- 00
C'rUJ .~
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ATTORNEYS AT LAW
Leslie B. Handler, Retired
W. Scott Henning
David H Rosenberg (PA. FLJ
Carolyn M. Anner (PA, NY, RN)
Matthew S. Crosby (PA, NJ)
Gregory M. Feather (PA. NJ)
Stephen G. Held
Jason C. Imler
HARRISBURG OFFICE
1300 linglestown Road
Harrisburg, PA 171 '0
717-238-2000
1-800-422-2224
717-233-3029 (fax)
April 3, 2006
LANCASTER OFFICE
140A E King Street
lancaster, PA 17602
717-431-4000
The Honorable Edward E. Guido, Judge
CUMBERLAND COUNTY COURTHOUSE
1 Courthouse Square
Carlisle, PA 17013-3387
DIRECT MAil TO:
P,O, Box 1177
Harrisburg, PA 17108
www.HHRLaw.com
Crosby@HHRLaw,com
Re: Savannah Lynch et al. Y. Casey L. Kresge
Cumberland Co. No, 2006-888 Civil
Minors'Compromise; Civil Action - Law
Dear Judge Guido:
In connection with the above-referenced matter and the Order you had executed on
February 17, 2006, approving settlement for this minor's compromise matter, enclosed
please find a courtesy copy of the Proof of Deposit regarding the deposit of the
settlement proceeds into a restricted account with Fulton Bank, for the minor, pursuant
to your aforementioned Order.
Should you have any questions whatsoever, please feel free to contact me at the
telephone number listed above, Thank you for your consideration in this matter.
Very truly yours,
HANDLER,~~NG ROSENBERG
"
BY:
Matthew S, Crosby
MSC/vf/enclosure
cc: Carol A. Beal
402 Boxwood Ct
Mechanicsburg, PA 17055
MAIN OFFICE
1300 Llnglestown Road
Harrisburg. PA '7J '0
7J 7-238-2000
J -800-422-2224
7J 7-233-30291Iax)
ATTORNEYS AT LAW
Leslie B. Handler, Retired
W. Scott Henning
David H Rosenberg WA.. FL)
Carolyn M. Anner {PA, NY, RN}
Matthew S. Crosby (PA, NJ)
Gregol}' M. Feather (FA, NJ)
Stephen G. Held
Jason C. Imler
LANCASTER OFFICE
7J 7-43' -4000
April 3, 2006
CARLISLE OFFICE
7J 7-241-2244
Office of the Prothonotary
CUMBERLAND COUNTY COURTHOUSE
1 Courthouse Square
Carlisle, PA 17013-3387
wvvw.HHRlaw.com
@HHRLaw,com
Re: Savannah Lvnch et al. v. Casey L. Kresae
Cumberland Co, No, 2006-888 Civil
Minors'Compromise; Civil Action - Law
Dear Sir or Madam:
In connection with the above-referenced matter, enclosed please find an original and two
copies of the Proof of Deposit, with regard to the February 17, 2006, Court Order, in this
minor's compromise matter. Please file and docket the same and return a clocked-in copy to
our office in the enclosed courtesy envelope,
Should you have any questions or require anything else, please do not hesitate to contact me,
Thank you for your assistance in this matter.
Very truly yours,
HANDLER, HENNING & ROSENBERG, LLP
Matthew S, crOSby
MSC/vff/enclosure
cc: Carol A Beal
402 Boxwood Ct
Mechanicsbur ,PA 17055
he Honorable
Edward E, Guido, Judge
i
....
SAVANNAH LYNCH, by and
through her natural parent
and guardian, CAROL BEAL,
Petitioner
IN THE COURT OF COMMON PLEAS
CUMBERLAND COUNTY, PENNSYLVANIA
No. 2006-888 CIVIL TERM
v.
CIVIL ACTION - LAW
CASEY L. KRESGE,
Respondent
MINOR'S COMPROMISE
PROOF OF DEPOSIT
AND NOW, comes the Petitioner, by and through her attorneys,
HANDLER, HENNING and ROSENBERG, LLP by Matthew S. Crosby, Esq" and
attaches the Proof of Deposit of the minor's settlement proceeds that were deposited
for the minor on March 16, 2006, into the Fulton Bank, as evidenced by Fulton Bank's
Certificate of Deposit Terms and Conditions - Summary, and pursuant to the February
17,2006, Court Order signed by The Honorable Edward E, Guido, Judge, both made a
part hereof and marked, "Exhibit A"
Respectfully submitted,
,HEN IN & ROSENBERG, LLP
BY:
Matthew S, Crosby, Esq,
Atty. ID No. 69367
1300 Unglestown Rd,
Harrisburg, PA 17108
717-238-2000
DATE: 4\1:)3, \~
Attorneys for Petitioner
.
andier.
enning rr
I osenberg
ATTORNEYS AT LAW
LeslJe B. Handler, Retired
W. Scott Henning
David H Rosenberg IPA. FLJ
Carolyn M. Anner [PAt NY, RNJ
Matthew S, Crosby fPA, NJj
Gregory M, Feather IPA, NJj
Stephen G. Held
Jason C Imler
, ",
March 13, 2006
--" .~, ..... .
Robin Strau6er
Fulton Bank
Third and Locu6t Street6
Harri6burg PA 17101
Dear Robin:
HARRISBURG OFFICE
1300 Linglestown Road
Harrisburg, PA 17110
717-23B-2000
l-BOO-422-2224
717-233-3029 (fax)
lANCASTER OFFICE
140A E f(ing Street
lancaster, PA 17602
717-431-4000
DIRECT MAIL TO:
P,O, Box 60337
Harrisburg, PA 17106
www.HHRlaw.com
LorieS@HHRlaw,com
Enclo6ed you will find a completed Retail Account Agreement to open a new account in the name
of:
i?avannah Lynch
Tax Identification # 160-72-3404
Thi6 depo6it in the amount of $638.96 6hall be placed in a College Saving6 Plan Account
marked not to be withdrawn without a court order until Savannah reache6 the age of 18. Her
date of birth i6 December 12, 1989 which mean6 the6e fund6 may not be relea6ed until December
12, 2007. Thank you for your immediate attention to thi6 matter.
Sincerely,
loi.L A 31'1-Ll~
Lorie A. Snyder
A66i6tant Admini6trator
BANK CERTIFICATION::
Term of CD: '] I ~M'{.IA
Type of Account Opened
CD
Intere6t Rate
~, Ci':l.
Account # () I '2- 0'). '-( 'il ':l. L-f D
Withdrawal Re6triction6 I A 1.l2j ') (';0 f
Amount of Depo6it
:j\ G~q , qc~
Qp 1.,,,, t\ P. (It(c-l.1 (
Date
slIG, IDe
Court Order Received ~
Account Opened By
EXHIBIT A
{
-
Fulton Bank
000-0248240
CMnM f)1\'1~'l'N . u."'<:.\~ltKlCmMtll P""511,1.~
l)"",..."~ UAN~ Ul\''""....' . (;"0.1" VAU.t.\ 01""''','
Downtown Harrisburg
CERTIFICATE OF DEPOSIT TERMS AND CONDITIONS - SUMMARY
Certificate of Deposit Type: 2 ( ,....",,"'j t l.-, C. [)
Renewed CO #:
(). "01: ,....k..(,<,<~
.f'-',....o::\s ,\.....t;l
12_fIZ.h(y;~
~' .
/J r Account No,; 0/2-0::1 y~ ~("(6
,"
'I
!Ill
G'
I
I
I
Issue Date: ":3,IIC,ID(...
Maturity Date: J-:l fl G>/O"J.
Principal Amount: ~G ~'J. c, Ii
Interest Rate: ~,q J.
Annual Percentage Yield: l-(. ot;)
Registered Holder Name{s) and Address:
SAVANNAH LYNCH, COURT ORDERED
CAROL BEAL, GUARDIAN
NO WD TILL MAJ 12/12/07
CASE>> 2006-88B
402 BOXWOOD COURT
MECHANICSBURG, PA
Interest Distribution Method:
Deposillo Account
Savings
)< Add to Principal
Issue Check
Checking
l'li
lj'
'iI:
II Tax ID Numb,,!,):
'I! SAVANNAH"
t. 1- Individual(s)
:l!""
""",...
17050
Frequency of Payment:
A ,1(\\)1'\ n ~ t;o~..... I ~501,.'<~ 11, {c.
160-72-3404
Sole Proprietor
CAROL
Partnership
" 186-60-6828
Corporation Lodge/Similar Org.
Bus. Tmst
lld. Uebili\y Co.
LJ Combined Stalement - Transaction Account Number
Fulton Bank acknowledges receipt of the above-described deposit, subject to collection of any portion thereof made in other than cash,
in accordance with the Rules and Regulations for Certificates of Deposit.
F~ ~t:~? /{A,Ji;1,
AulhorlzecJS,gnalure {K12..mx-'t..:.. p, rn;k~ll
'.'We have received a copy of the Rules and Regulations For Certificates of Deposit and agree,.on behalf of aU Registered Holders, 10 Ihe
terms and conditions of the certificate of deposit.
f.lv:
,!')diVi~O Sole Pfuprio:}
/0:."" 'm"y
Non-Individuals:
!'lama
Ime
:'lgnslUfe
"i,iJalUra\SeConaaryj
Name
Title
olgnalUre
!"f:iffiiLure{seconoary!
Name
Ti\le
'S@\B.ture
'.\r>der penalties of perjury, \ certify that:
1. The number shown on ~his form is my conec\ laxpayer identlficalion number (or I am waiting for a number to be issued 10 me),
and
2. \ ~m not sllbjed to bacKupwi\hholding because: (a) 1 am exempt from bacKUp withholding, of (b) I have nol been notified by
the Inlernal Revenue Service that I am subject to backup withholding as a result of a failure to report all interest or dividends, or
(c) the IRS has notified me that I am no longer subjecllo baCKUp withholding.
. . QU must cross out ilem 2 above jf you have been notified by lhe IRS that you aTe currently subject to backup withholdlng because of
',:nderreporting interest or dividends on your tax ratum,
Tille {if Non-Individualj
Dol.
'7
.
RECEIVED FE8 151006 1
y
SAVANNAH LYNCH, by and
through her natural parent
and guardian, CAROL BEAL,
Petitioner
IN THE COURT OF COMMON PLEAS
CUMBERLAND COUNTY, PENNSYLVANIA
NO.2006 -cfPcP CIVIL TERM
v.
CIVIL ACTION - LAW
CASEY L. KRESGE,
Respondent
MINOR'S COMPROMISE
ORDER
AND NOW, this 17" day of Pet- r
consideration of the foregoing Petition,
, 2006, upon
IT IS HEREBY ORDERED that the disbursement of funds, as well as counsel fees
and expenses, are approved as set forth in said Petition and shall be disbursed in
accordance with the terms and conditions of the settlement agreement as follows:
A. Direct payment of $361,04 to Matthew S, Crosby, Esq., representing
reasonable attorney's fees of $250,00 and $111,04, for reimbursement of costs;
B. Direct payment of $638.96 to be placed in an account investing only in
securities guaranteed by the United States government or a Federal governmental agency
managed by responsible financial institutions, bearing the name of the minor, Savannah
Lynch, that is marked "Not to be withdrawn until minor reaches the age of 18 or without the
Order of a Court of Competent jurisdiction"; and
,,~
C. Proof of deposit is to be filed with tbifCourt,
~G'_
J,
I', ~~~~~.f:,.C:PY FROM ReCORD
h......h.l~'-.:n~. t;/!-rC"'!~':'-'f I rll"I-~ <'l
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-',I W~, C" '"...Jrl ai Cailis!!), Pa
I.., - .CCi'j of r:- h" i,.;r'
SAVANNAH LYNCH, by and
through her natural parent
and guardian, CAROL BEAL,
Petitioner
IN THE COURT OF COMMON PLEAS
CUMBERLAND COUNTY, PENNSYLVANIA
No. 2006-888 CIVIL TERM
v.
CIVIL ACTION - LAW
CASEY L. KRESGE,
Respondent
MINOR'S COMPROMISE
PROOF OF DEPOSIT
AND NOW, comes the Petitioner, by and through her attorneys,
HANDLER, HENNING and ROSENBERG, LLP by Matthew S, Crosby, Esq" and
attaches the Proof of Deposit of the minor's settlement proceeds that were deposited
for the minor on March 16,2006, into the Fulton Bank, as evidenced by Fulton Bank's
Certificate of Deposit Terms and Conditions - Summary, and pursuant to the February
17,2006, Court Order signed by The Honorable Edward E, Guido, Judge, both made a
part hereof and marked, "Exhibit A"
Respectfully submitted,
~
,HEN IN & ROSENBERG, LLP
BY:
Matthew S. Crosby, Esq,
Atty, ID No, 69367
1300 Linglestown Rd,
Harrisburg, PA 17108
717-238-2000
DATE: 4\17' \~
Attorneys for Petitioner
;; xh) h I f A-
HARRISBURG OFFICE
1300 Unglestown Road
Harrisburg, PA 1711 0
717-238-2000
1-800-422-2224
717-233-3029 (lax)
Leslie B. Handler, Retired
W. Scott Henning
David H Rosenberg IPA, FL}
Carolyn M, Anner fPA, NY, RNI
Matthew S. Crosby IPA, NJI
Gregory M. Feather (PA, NJ}
Stephen G. Held
Jason C. Imler
LANCASTER OFFICE
140A E King Street
Lancaster, PA 17602
717-431-4000
ATTORNEYS AT LAW
March 13, 2006
DIRECT MAIL TO:
P,O, Box 60337
Harrisburg, PA 17106
www.HHRLaw.com
lorieS@HHRLaw,com
'""',~ "... tf/III'"
Robin Strauser
Fulton Bank
Ihird and Locust Streets
Harrisburg PA 17101
Dear Robin:
Enclosed you will find a completed Retail Account Agreement to open a new account in the name
of:
Savannah Lynch
lax Identification # 160-72-3404
Ihis deposit in the amount of $638,96 shall be placed in a College Savings Plan Account
marked not to be withdrawn without a court order until Savannah reaches the age of 18, Her
date of birth is December 12, 1989 which means these funds may not be released until December
12, 2007. Ihank you for your immediate attention to this matter.
Sincerely,
',(YiL A ~)}LjCll)~
Lorie A. Snyder
Assistant Administrator
BANK CERIIFICATION::
lerm of CD: '} \ ,M<\(' CIA
Iype of Account Opened
co
Interest Rate
7"Ci'J.
Account # CJ I '1- 0'). '-( 'if '). '--I C>
Withdrawal Restrictions I J..lu..1 ') (';O-=t
Amount of Deposit $ Gss; . '1(, Court Order Received ~
Account Opened By Qpb.,rcr. P. {r\,{,cJr'" l ( Date ~ I i G I DC
EXHIBIT A
Fulton Bank
000-0248240
C.""HI. [J"'1~'11" . t"w"".<luVl:m'Hu \)'H'ltlS
D~<l"'_K~ UA"~ 1)1\'"""" . GM'''''' V~ll.'" U'V,,"'_~
Certificate of Deposit Type;
Renewed CD #:
~ )H;'
I;; Account No.: () i:2.- oJ Y'3 :A46
,~ ,~
Ii
ii
I !,. Registered Holder Name(s) and Address:
SAVANNAH LYNCH, COURT ORDERED
CAROL BEAL. GUARDIAN
NO WD TILL MAJ 12/12/07
~: CASE # 2006-888
rl 402 BOXWOOD COURT
I;'
',' MECHANICS BURG, PA 17050
II Tax 10 Numberls):
,r SAVANNAH I 160-72-3404 CAROL
r~' )( Individual(s} Sole Proprietor Partnership
j~"
Downtown Harrisburg
CERTIFICATE OF DEPOSIT TERMS AND CONDITIONS - SUMMARY
2 f .....H.,,'~.... cD
D.. "01: ,-I'.L--'n,>(~
..;...,.....(h L:,..,t":(
1?I,z.hCY,"l
Issue Oate:51 \~lDC.
Maturity Date: 0 II &Io'-l-
Principal Amounl: ~C 3>'J. cl Co:
Interest Rate: ~,cl:J..
Annual Percentage Yield; L-{. DC;
Interest Distribution Method:
Deposillo Account
Savings
y. Add to Principal
Issue Check
Checking
Frequency of Payment:
A'~Av"dtj '+':0.'"1 :r: ~.sue.. D", (c.
I 186-60-6828
Corporation lodgeJSimilar Org,
Bus. Trust
LId. liability Co
:'] Combined Statement - Transaction Account Number
Fulton Bank acknowledges receipt of the above-described deposit, subject 10 collection of any portion thereof made in other than cash,
in accordance with the Rules and Regulations for Certificales of Deposit.
F~nt~~? ~,--ji/l
/ --V \
Authonzec!S'gnalure {R~~:.ct^ p. {il;b;;-4l\
,liVe have received a copy of the Rules and Regulalions For Certificates of Deposit and agree, on behalf of all Regislered Holders, \0 the
lerms and conditions of the certificate of deposit.
,ly'
,"")diVi~ci Soie P.-()prie'
/),;,"," ,m,y
Non.lndivlduals:
Name
line
--sigi1a1ure
,,-c,ilaIUre\SeconQaryl
Name
Tille
;'ignalure
'-'{;snalure (seconoarYI
Name
Tille
Sigffiiture
'.I"der penalties of perjury, 1 certify that:
1. The number shown on this form is my correct taxpayer identification number (Dr 1 am waiting for a number to be issued 10 me),
and
2. \ am not subject to backup withholding because: (a) 1 am exempt from backup will1holding, of {b) 1 have not been notified by
the Internal Revenue Service that' am subject to backup wilhholding as a result of a failure to report all interest or dividends, or
(c) the IRS has notified me that I am no longer subject 10 backup wilhholding.
')u must cross out item 2 above if you have been notified by the IRS Ihat you are currently SUbject to backup withholding because of
.tf1derrcportir.g interest or di~'idends on l'our tax re~urn.
-----
nallJre(Primary ndividual}
Title (i(Nan-lndividlJ8l)
Dale
Ui;\nIMioorCIFIDeIKl.il<>r
Page 1 of3
'7
RECEIVED FES 152006 1
,:<0'
SAVANNAH LYNCH, by and
through her natural parent
and guardian, CAROL BEAL,
Petitioner
IN THE COURT OF COMMON PLEAS
CUMBERLAND COUNTY, PENNSYLVANIA
NO. 2006 -cfcPcP CIVIL TERM
v.
CIVIL ACTION - LAW
CASEY L KRESGE,
Respondent
MINOR'S COMPROMISE
ORDER
AND NOW, this 01" day of Fdr--r
consideration of the foregoing Petition,
, 2006, upon
IT IS HEREBY ORDERED that the disbursement of funds, as well as counsel fees
and expenses, are approved as set forth in said Petition and shall be disbursed in
accordance with the terms and conditions of the settlement agreement as follows:
A. Direct payment of $361,04 to Matthew S, Crosby, Esq., representing
reasonable attorney's fees of $250,00 and $111,04, for reimbursement of costs;
B, Direct payment of $638,96 to be placed in an account investing only in
securities guaranteed by the United States government or a Federal governmental agency
managed by responsible financial institutions, bearing the name of the minor, Savannah
Lynch, that is marked "Not to be withdrawn until minor reaches the age of 18 or without the
Order of a Court of Competent jurisdiction"; and
C, Proof of deposit is to be filed wit~e'/c~~
,
BYT .',
~'
J,
I . i!:'~.:..~~OPY F~O~.~ RECORD
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