HomeMy WebLinkAbout06-0934IN THE COURT OF COMMON PLEAS
CUMBERLAND COUNTY, PENNSYLVANIA
No. 0(a - ?3 / ?[C>GC? ?„' I
Civil Action -
JURY TRIAL DEMANDED
MICHAEL CHEREWKA AND MICHELLE
CHEREWKA, INDIVIDUALLY AND
MEAGHAN CHEREWKA, A MINOR, BY
MICHAEL CHEREWKA AND MICHELLE
CHEREWKA, GUARDIANS
125 PHELAM ROAD
CAMP HILL, PENNSYLVANIA 17011
ERIC A. ULSH
Versus 2311 OAKWOOD ROAD
HARRISBURG, PENNSYLVANIA 17104
PRAECIPE FOR WRIT OF SUMMONS
TO THE PROTHONOTARY OF SAID COURT:
Please issue writ of summons in the above-captioned action.
X Writ of Summons shall be issued and forwarde
TIMOTHY A. SHOLLENBERGER. ESQ
Shollenberoer & Januzzi. LLP
2225 Millennium Way
Enola. Pennsylvania 17025
(717) 728-3200
Date:
WRIT OF SUMMONS
TO THE ABOVE NAMED DEFENDANT(S):
YOU ARE NOTIFIED THAT THE ABOVE-NAMED PLAINTIFF(S) HAS/HAVE COMMENCED
AGAINST YOU.
Date: :I h ill . a OUL
( ) Check here if reverse is issued for additional information
PROTHON. - 55
GIGLOBAL\WPDATAZOCS\TIM CASE FILES-OPEN\Chere ,Meghan\Pleadings\WRIT OF SUMMONS.doc
Supreme Court ID No. 34343
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SHERIFF'S RETURN - OUT OF COUNTY
CASE NO: 2006-00934 P
COMMONWEALTH OF PENNSYLVANIA:
COUNTY OF CUMBERLAND
CHEREWKA MICHAEL ET AL
VS
ULSH ERIC A
R. Thomas Kline ,
duly sworn according to law, say:
and inquiry for the within named
ULSH ERIC A _
but was unable to locate Him
deputized the sheriff of DAUPHIN
serve the within WRIT OF SUMMONS
Sheriff or Deputy Sheriff who being
that he made a diligent search and
DEFENDANT , to wit:
in his bailiwick. He therefore
County, Pennsylvania, to
On March 16th , 2006 , this office was in receipt of the
attached return from DAUPHIN
Sheriff's Costs: So answ
Docketing 18.00
Out of County 9.00
Surcharge 10.00 R. Thomas Klin
Dep Dauphin County 29.25 Sheriff of Cumberland County
Postage .78
67.03
03/16/2006
SHOLLENBERGER & JANUZZI
Sworn and subscribed to before me
this 2J,-h day of C ch
,2 ao(r A.D.
Pro tart'
In The Court of Common Pleas of Cumberland County, Pennsylvania
Michael Cherewka et al
vs.
Eric A. Ulsh No. 06-934 civil
Now, February 21, 2006 I SHERIFF OF CUMBERLAND COUNTY, PA, do
hereby deputize the Sheriff of Dauphin County to execute this Writ, this
deputation being made at the request and risk of the Plaintiff.
Sheriff of Cumberland County, PA
Affidavit of Service
Now,
within
upon
at
by handing to _
a
and made known to
copy of the original
So answers,
the contents thereof.
Sheriff of County, PA
COSTS
Sworn and subscribed before SERVICE $
me this _ day of 20_ MILEAGE
AFFIDAVIT
20,, at o'clock M. served the
(pil.tre of r o*4prif f
Mary Jane Snyder
Real Estate Deputy
William T. Tully
Solicitor
Dauphin County
Harrisburg, Pennsylvania 17101
ph: (717) 780-6590 fax: (717) 255-2889
Jack Lotwick
Sheriff
Commonwealth of Pennsylvania CHEREWKA MICHAEL ET AL
vs
County of Dauphin ULSH ERIC A
Sheriff's Return
Charles E. Sheaffer
Chief Deputy
Michael W. Rinehart
Assistant Chief Deputy
No. 0301-T - - -2006
OTHER COUNTY NO. 06-934
AND NOW:March 9, 2006 at 9:03AM served the within
WRIT OF SUMMONS upon
ULSH ERIC A by personally handing
to DORIS ULSH, MOTHER OF ERIC 1 true attested copy(ies)
of the original WRIT OF SUMMONS and making known
to him/her the contents thereof at 2311 OAKWOOD ROAD
HARRISBURG, PA 17104-0000
Sworn and subscribed to
before me this 10TH day of MARCH, 2006
ClGt/
NOTARIAL SEAL
MARY JANE SNYDER, Notary Public
Highspire, Dauphin County
My Commission Expires Sept. 1, 2006
So Answers,
'e°%
Sheriff of Dauphin County, Pa.
By
Deputy Sheriff
Sheriff's Costs:$29.25 PD 02/23/2006
RCPT NO 215116
WONG
r
MICHAEL CHEREWKA AND
MICHELLE CHEREWKA,
INDIVIDUALLY AND MEAGHAN
CHEREWKA, A MINOR, BY
MICHAEL CHEREWKA AND
MICHELLE CHEREWKA, GUARDIANS,:
Plaintiffs
IN THE COURT OF COMMON PLEAS
CUMBERLAND COUNTY, PENNSYLVANIA
vs. : NO. 06-934 Civil Term
ERIC A. ULSH, JURY TRIAL DEMANDED
Defendant CIVIL ACTION - LAW
PRAECIPE FOR ENTRY OF APPEARANCE
TO THE PROTHONOTARY:
Please enter the undersigned's appearance on behalf of the Defendant, ERIC A.
ULSH, with regard to the above-captioned matter.
Respectfully submitted,
NEALON GOVER & PERRY
Date: ? krlcy
By:
Michael S. Ferguson, Esquire
I.D. No. 83882
2411 North Front Street
Harrisburg, PA 17110
717/232-9900
CERTIFICATE OF SERVICE
AND NOW, this day of June, 2006, 1 hereby certify that I have served the
foregoing PRAECIPE FOR ENTRY OF APPEARANCE on the following by depositing a
true and correct copy of same in the United States mail, postage prepaid, addressed to:
Timothy A. Shollenberger, Esquire
SHOLLENBERGER & JANUZZI, LLP
2225 Millennium Way
Enola, PA 17025
UV`
Michael S. Ferguson, Esquire
.11?
f'
Jeffrey T. McGuire, Esquire
Attorney I. D. # 73617
Caldwell & Kearns, P.C.
3631 North Front Street
Harrisburg, PA 17110-1533
(717) 232-7661
Attorney for Defendant Eric A. Ulsh
MICHAEL CHEREWKA and
MICHELLE CEREWKA,
INDIVIDUALLY AND MEAGHAN
CHEREWKA, A MINOR, BY
MICHAEL CHEREWKA AND
MICHELLE CHEREWKA, GUARDIANS
Plaintiffs
vs.
ERIC A. ULSH
Defendant
IN THE COURT OF COMMON PLEAS
CUMBERLAND COUNTY, PENNSYLVANIA
NO. 2006-CV-934-CV
CIVIL ACTION - LAW
PRAECIPE TO ENTER APPEARANCE
TO THE PROTHONOTARY:
Please enter the undersigned's appearance on behalf of the Defendant, Eric
A. Ulsh, with regard to the above-captioned m
Date: October 24, 2006 By:
Fd Guire, Esquire
. D. # 73617
& Kearns, P. C.
3631 North Front Street
Harrisburg, PA 17110-1533
(717) 232-7661
Attorney for Defendant, Eric A. Ulsh
f
CERTIFICATE OF SERVICE
AND NOW, this 24th day of October 2006, 1 hereby certify that I have served a
copy of the within document on the following by depositing a true and correct copy of
the same in the U.S. Mail at Harrisburg, Pennsylvania, postage prepaid, addressed to:
Timothy A. Shollenberger, Esquire
2225 Millennium Way
Enola, Pa 17025
By:
ELL & KEARNS
1 J'-r
ShirlejA Erb, Secretary
06621-32/108160
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SHOLLENBERGER & JANUZZI, LLP
2225 Millennium Way
Enola, PA 17025
Telephone Number: (717) 728-3200
Fax Number: (717) 728-3400
Attorneys for Plaintiff
MICHAEL CHEREWKA and MICHELLE
CHEREWKA, INDIVIDUALLY and
MEAGHAN CHEREWKA, A MINOR, by
MICHAEL CHEREWKA and MICHELLE
CHEREWKA, GUARDIANS,
IN THE COURT OF COMMON PLEAS
CUMBERLAND COUNTY,
PENNSYLVANIA
NO. 06-934 CIVIL
Plaintiffs
V.
ERIC A. ULSH,
CIVIL ACTION - LAW
JURY TRIAL DEMANDED
Defendant
PETITION TO APPROVE COMPROMISE SETTLEMENT
AND DISTRIBUTION OF PROCEEDS
AND NOW come the Plaintiffs/Petitioners, MICHAEL CHEREWKA
and MICHELLE CHEREWKA, INDIVIDUALLY and MEAGHAN CHEREWKA, A
MINOR, by MICHAEL CHEREWKA and MICHELLE CHEREWKA, GUARDIANS,
by and through their attorneys SHOLLENBERGER & JANUZZI, and do
respectfully set forth the following:
1. The minor, Meaghan Cherewka, was born on October 17, 1995,
and currently resides with her parents, Plaintiffs/Petitioners, Michael and Michelle
Cherewka, at 125 Phelam Road, Camp Hill, Cumberland County, Pennsylvania.
2. The Defend ant/Respondent herein is Eric A. Ulsh, whose last
known address is 2311 Oakwood Road, Harrisburg, Pennsylvania 17104.
3. On or about April 30, 2004 Meaghan Cherewka was injured in an
automobile collision which occurred on Park Street, at or about its intersection
with South Sporting Hill Road, Hampden Township, Cumberland County,
Pennsylvania. See Police Report attached hereto as Exhibit "A."
4. As a result of the collision, Meaghan Cherewka, sustained a
contusion to her leg and adjustment disorder with anxiety. Meagan did not
require treatment for her leg, but from January 12, 2005 to July 13, 2005, did
receive treatment from a Licensed Professional Counselor with regard to the
adjustment disorder and anxiety. See May 17, 2006 and May 18, 2006 Reports
from Victoria A. Whitcomb, M.S., LPC, RPT-S attached hereto as Exhibit "B."
5. Michael and Michelle Cherewka, on behalf of Meagan, have
incurred various medical bills for the treatment rendered to Meagan, all of which
have been paid in full, with no outstanding liens. Michael and Michelle Cherewka
paid $1,070.00 out-of-pocket and $80.00 was paid by Meaghan's private Health
Insurer. See Medical Bills attached hereto as Exhibit "C."
6. The Defendant/Respondent, through his insurer, Progressive
Insurance Company, has offered the sum of $2,500.00 to settle this claim for in
exchange for the Release attached hereto as Exhibit "D."
7. The Plaintiffs/Petitioners believe this offer of settlement is fair and
reasonable.
8. The Petitioners have retained the services of the law firm of
Shollenberger & Januzzi, LLP, to represent them. Shollenberger & Januzzi, LLP
is representing the Plaintiffs/Petitioners on a pro bono basis and is not charging a
fee for their service.
9. The Plaintiffs/Petitioners have further agreed to pay out of their
share of the recovery the following costs incurred or advanced on behalf of
Meaghan:
A. Cumberland County Prothonotary (filing fee): $55.00
B. Cumberland County Sheriff (service fee): $67.03
C. Hampden Township (police report): $15.00
The amount of reimbursement for the above costs that were incurred and
advanced on Plaintiffs'/Petitioners' behalf total $137.03.
10. The Plaintiffs/Petitioners request the court approve the
compromised settlement in order to distribute the proceeds as follows:
Shollenberger & Januzzi, LLP
(reimbursement of costs advanced) $137.03
Michael and Michelle Cherewka
(reimbursement for medical bills paid) $1,070.00
Meaghan Cherewka, by Michael Cherewka and
Michelle Cherewka, her parents and natural guardians $1,292.97
11. The Plaintiffs/Petitioners request that the funds be distributed for
the benefit of the minor, Meaghan Cherewka, and should be deposited in one or
more savings accounts in the name of Meaghan Cherewka, in banks, building
and loan associations or savings and loan associations, deposits in which are
insured by a federal governmental agency, provided that the amount deposited in
any one savings institution should not exceed the amount to which accounts are
thus insured.
12. The Plaintiffs/Petitioners request that, upon approval of the
proposed compromised settlement and receipt of the proceeds thereof, they be
authorized to execute a good and sufficient release of any further liability and to
discontinue the above action against the Respondent named herein.
WHEREFORE, the Plaintiffs/Petitioners, MICHAEL CHEREWKA and
MICHELLE CHEREWKA, INDIVIDUALLY and MEAGHAN CHEREWKA, A
MINOR, by MICHAEL CHEREWKA and MICHELLE CHEREWKA, GUARDIANS,
request this Honorable Court to approve the Compromise Settlement and
Distribution of Proceeds or, in the alternative, schedule a hearing.
Respectfully submitted,
SHOLLEN ERGER AND JANUZZI, LLP
r
BY:
Adam T. Wolfe, Esquire
Attorney for Plaintiffs
Dated: August I.S , 2007
METRO THE HARRISBURG AREA POLICE INFORMATION RESOURCE SYSTEM (CRSIPINC)
PAGE: 1 CRASH REPORT 06/04/04 HKC1 HAM3
CRASH NUMBER: P0003815 OCIDENT NUMBER: 2004040037 CASE CLOSED: Y
----------------------------------------------------------- ------------------
AGENCY: 21103 HAMPDEN TWP
DISP-TM: 1355 ARRV-TM: 1405 PATROL-ZN: SW PRECINCT: 230 SOUTH SPORTING H
INV-DT: 04-30-2004 INVESTIGATOR: LUNDQUIST, DENNIS C BADG: 0197
APP-DT: 05-03-2004 REVIEWER: KOPKO, RICHARD J BADG: 1910
COUNTY: 21 CUMBERLAND MUNICIPALITY: 103 HAMPDEN TWP
CRS-DT: 04-30-2004 TM: 1350 #UNIT: 2 #PEOP: 3 #INJ: 1 #KILL:
REPORTABLE: Y NOTIF HIWY MAINT: N PENNDOT PROP: N
SCH BUS RELATED: N SCH ZON RELATED: N
FOLLOW UP: N CITY PROP DAM: Z
CRASH DESC: 6 REL TO RDWY: 1 ILLUM: 1 WEATHER: 1 RDWY SURF COND: 0
INTERS TYP: 02 SPEC LOC: 0 SPEC JURIS: RDWY SURF TYPE:
PRINC RD - CNTY:
STR NM:
INSEC RD - CNTY:
STR NM:
LANDMARKI - RT#:
STR NM:
LANDMARK2 - RT#:
STR NM:
21 RT#: SEG:
PARK ST EXT EX
21 RT#: SEG:
S SPORTING HILL RD
MILEPOST: 0000
MILEPOST: 0000
#LNS: 02 SPD LIM: 25
HOUSE#:
#LNS: 02 SPD LIM: 35
SEG MARKER:
DIST FR CRASH - FT:
SEG MARKER:
E
S
S
4
.0
ORIENT:
RT
ORIENT:
RT SIGN:
ORIENT:
MI:
ORIENT:
TRAF CONTROL DEVICE TYPE: 2 FUNCTIONING: 3
WORK ZONE - TYP: 0 LOC: SPEED LIM: WORKERS PRES:
LN CLOS: RD CL/DETOUR: SHLD/MED WK: MOVING WK: FLAGGER: OTHER:
LANE CLOSED DUE TO CRS: 0 DIRECT: TRAP DETOUR: EST TM CLOSE:
FIRST HARMFUL EV: 02 UN#: 01 MOST HARMFUL EV: 02 UN#: 01
ENV/RDWY FACTORS: 00 PRIME FACTOR: D 17 UN#: 01
EMERGENCY TRANSPORT - EMS AGENCY: HAMPDEN TOWNSHIP
MED FACILITY: DID NOT TRANSPORT
UNIT 2 WAS TRAVELING EAST ON PARK ST. EXTENDED. UNIT 2 SAID UNIT 1 CAME
BACKWARDS ON PARK ST. EXTENDED IN THE WEST BOUND LANE. UNIT 2 SAID THAT
UNIT 1 WAS TRAVELING AT A HIGH RATE OF SPEED AND WAS SWERVING BACK AND
FORTH. UNIT 2 OPERATOR SAID SHE BROUGHT HER VEHICLE TO A STOP AS SHE DID
NOT KNOW WHAT UNIT 1 WAS DOING. UNIT 2 OPERATOR SAID THAT UNIT 1 STARTED
TO PASS HER AND THE RIGHT REAR OF UNIT 1 STRUCK THE LEFT SIDE OF HER VEHICLE.
UNIT 1 OPERATOR SAID THAT HE WANTED TO TURN AROUND AND WAS BACKING UP TO DO
SO. UNIT 1 SAID HE WAS GOING FASTER THEN HE SHOULD HAVE BEEN AND HIS VEHICLE
DID STRIKE UNIT 2. THE ODOR OF ALCOHOL WAS PRESENT ON UNIT 1 DRIVERS BREATH.
UNIT 1 DRIVER WAS TAKEN INTO CUSTODY FOR D.U.I. AND TAKEN TO THE BOOKING
CENTER TO BE TESTED AND PROCESSED. UNIT 1 DRIVER DID VOLUNTEER TO TAKE A
BREATH TEST AFTER HE WAS GIVEN HIS IMPLIED CONSENT LAWS. THE RESULTS OF
THE BREATH TEST SHOWED UNIT 1 DRIVER HAD A .179% BAC.
POLICE INFORMATION RESOURCE SYSTEM (CRSIPINC)
METRO THE HARRISBURG ARF
A
PAM: '2 RASH REPORT • 06/04/04 HKC1 HAM3
I
CRASH NUMBER: F0003815 INCIDENT NUMBER: 200404003
--------------------------
-
73 HAM
-------------------------
-
-------------------------
UNIT NUMBER: 01 TYPE: 01 COMMERCIAL VEH: N
OWNR NAME: ULSH ROBERT A 7172380019
OWNR ADDR: 2311 OAKWOOD ROAD HARRISBURG PA 17104
VIN: 2B3HD46R3YH275973 YR: 2000 MAKE: 07
LIC PLATE: EPH5566 PA TRAV SPD: 999
INS CO,PO,PH: PROGRESSIVE 52328777-0 9999999999
TOW TO,BY,PH:
# TRL UNITS: 0 TYP UNIT: TAG NO,YR,ST:
TYP UNIT: TAG NO,YR,ST:
VEHICLE COL: 05 TYP: 01 SPEC USAGE: 00 ROLE: 1 POSITION: 01
INIT IMP PT: 05 DAMAGE: 1 DIR TRAV: W MOVEMENT: 14 GRAD: 1 ALIGNM: 1
ALCOH,DRG SUSP: 2 TEST TYP: 2 RESULT: 17 PHYSICAL COND: 1
OWNER/DVR CD: 02 DVR PRESENCE: 1 PEDESTRIAN SIGNAL: PED LOC:
VIOLATION CD: 75 3802 Al CHARGED: Y
VIOLATION CD: 75 3802 C CHARGED: Y
HARM EVENT l: 02 L/R: MHE: Y UTIL POLE#: DRIVER ACTION 1: 17
HARM EVENT 2: L/R: MHE: UTIL POLE#: DRIVER ACTION 2:
HARM EVENT 3: L/R: MHE: UTIL POLE#: DRIVER ACTION 3:
HARM EVENT 4: L/R: MHE: UTIL POLE#: DRIVER ACTION 4:
VEH FAILURES: 00 PEDEST ACTION
(45F1) DVR RESTRICTIONS COMPL: DVR ENDORSEMENT COMPL: DVR LICENSE COMPL:
AVOIDANCE MANEUVER: UNDER RIDE INDICATOR: EMERGENCY USE:
DRUG TEST TYPE: RESULTS: PRINCIPLE IMPACT PT:
-----------------------------------------------------
UNIT NUMBER: 02 TYPE: 01 COMMERCIAL VEH: N -------------------------
OWNR NAME: CHEREWKA MICHAEL 7177617202
OWNR ADDR: 125 PELHAM ROAD CAMP HILL PA 17011
VIN: JH4KA965530000512 YR: 2003 MAKE: 54
LIC PLATE: ESM4890 PA TRAV SPD: 000
INS CO,PO,PH: USAA 234 02 08 9999999999
TOW TO,BY,PH: EDMONDSONS SERV CENTER ROADSIDE AUTO RESCUE 7176976262
# TRL UNITS: 0 TYP UNIT: TAG NO,YR,ST:
TYP UNIT: TAG NO,YR,ST:
VEHICLE COL: 08 TYP: 01 SPEC USAGE: 00 ROLE: 2 POSITION: 01
INIT IMP PT: 04 DAMAGE: 2 DIR TRAY: E MOVEMENT: 03 GRAD: 1 ALIGNM: 1
ALCOH,DRG SUSP: 1 TEST TYP: 0 RESULT: PHYSICAL COND. 0
OWNER/DVR CD: 02 DVR PRESENCE: 1 PEDESTRIAN SIGNAL: PED LOC:
VIOLATION CD: CHARGED:
HARM EVENT 1: 11 L/R: MHE: Y UTIL POLE#: DRIVER ACTION 1: 00
HARM EVENT 2: L/R: MHE: UTIL POLE#: DRIVER ACTION 2:
HARM EVENT 3: L/R: MHE: UTIL POLE#: DRIVER ACTION 3:
HARM EVENT 4: L/R: MHE: UTIL POLE#: DRIVER ACTION 4:
VEH FAILURES: 00 PEDEST ACTION
(45F1) DVR RESTRICTIONS COMPL: DVR ENDORSEMENT COMPL: DVR LICENSE COMPL:
AVOIDANCE MANEUVER: UNDER RIDE INDICATOR: EMERGENCY USE:
DRUG TEST TYPE: RESULTS: PRINCIPLE IMPACT PT:
METRO THE HARRISBURG ARJPOLICE INFORMATION RESOURCE SYSTEM (CRSIPINC)
PAGE: '3 CRASH REPORT • 06/04/04 HKC1 HAM3
CRASH NUMBER: F0003815 INCIDENT NUMBER: 20040400373 HAM
------------------------------------------------------------------------------
* * * * * * * * * * * * PEOPLE INFORMATION * * *
PERSON TYPE: 1=DRIVER 2=PASSENGER 7=PEDESTRIAN 8=OTHER 9=UNKNOWN
INJ SEVERITY: 0=NONE 1=KILLED 2=MAJOR INJ 3=MODERATE 4=MINOR 9=UNK
UNIT NO: 01 PERSON NO: 01 TYP: 1 INJ SEVERITY: 0 DOB: 19830418 SEX: M
NAME (L,F,M,S): ULSH ERIC A
ADDRESS: 2311 OAKWOOD ROAD PHONE: 7172380019
HARRISBURG PA 17104
DRIVER LICENSE: PA 26423511
SEAT POSN: 01 SAFE-EQ1,2: 03 10 EJECT: 1 EJ-PATH: 0 EXTRIC: 1 TRANSP: N
UNIT NO: 02 PERSON NO: 01 TYP: 1 INJ SEVERITY: 0 DOB: 19570512 SEX: F
NAME (L,F,M,S): CHEREWKA MICHELE R
ADDRESS: 125 PELHAM ROAD PHONE: 7177617202
CAMP HILL PA 17011
DRIVER LICENSE: PA 17741610
SEAT POSN: 01 SAFE-EQ1,2: 03 10 EJECT: 1 EJ-PATH: 0 EXTRIC: 1 TRANSP: N
UNIT NO: 02 PERSON NO: 02 TYP: 2 INJ SEVERITY: 2 DOB: 19951017 SEX: F
NAME (L,F,M,S): CHEREWKA MEAGHAN K
ADDRESS: 125 PELHAM ROAD PHONE: 7177617202
CAMP HILL PA 17011
SEAT POSN: 05 SAFE-EQ1,2: 01 00 EJECT: 1 EJ-PATH: 0 EXTRIC: 1 TRANSP: N
• Hampden Township Polio
Police Crash... port Form . .
[S_ Incident f 4' iQdD373Agency Code -71101 _ Agency Name
Arrival Tune IMPS' I Om m s LUAJI?DmtttST
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FROM :STRICKLER &WHITCOMB MH ASSO FAX NO. :7175912797 May. 17 2006 03:03PM P2
LM Hau
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S'TR MIR & WHITCOMB MENTAL HEALTH ASSOCIA'T'ES, U C -
3901 Hautzdale Drive
suite 108
Camp WA PA 17011
May 17, 2006
Timothy A. Shollenberger
Shollenberger & Januzzi, LLP
2225 Millennium Way
Enola, PA 17025
Dear Mr. Sollenberger:
RE:
DOB:
BEGAN THERAPY:
DIAGNOSIS:
PRESENTING ISSUE:
GOALS:
SYMPTOMS:
Phonc717.909-9750
Fax: 717.909A752
Meghan Cherewka
October 17, 1975
January 12, 2005
309.24 (Adjustment Disorder with Anxiety)
The car she was riding in was hit by a drunk driver
To reduce symptoms of anxiety
1~ earful of sleeping in the dark, disruptive sleep pattern,
anxiety at bedtime, refusing to sleep in a bed alone
Meghan's initial visit was January 17, 2005. Meghan was extremely timid and fearful, little to
no play, was able to verbalize an account of the accident and revealed many other fears such as
robbers, breaking and entering her home and/or worried that she would be taken and killed.
Meghan was able to acknowledge she worries about those things. Her body posture was always
stiff and fearful except when she was showing off her gymnastic poses. Eventually Meghan was
able to do the sand tray therapy and appeared to be able to work out some of her anxieties.
Meghan's parents utilized a behavioral modification plan to get her back into her own bed Her
parents reported an improvement on the sleep issue. However, therapy was disrupted without
closure on July 13, 2005 due to conflicting schedules.
If you have any further questions, please feel free to contact me at (717) 909-9750.
Inc ly,
? a a
Victoria A. Whitcomb, M.S., LPC, RPT-S
Licensed Professional Counselor
Registered. Play'rherapist Supervisor
VAWAmt
May. 18 2006 04:14PM P2
FROM :STRIC4LER &WHITCOMB MH ASSO FAX NO, :7175912797
v
siUCKM & WH Cokm MENTAL HEA= AseoCUT% 1w
3901 Ebdx ate Drive Ph=ft717A04.9750
Suite 108
t m T17A09?4752
Camp ML PA 17011
I
May 18, 2006
Tinnothy A. Shollenbetrrger
Shollenbe;rger & Jan=4 LLP
2225 Millennium Way
Fula, PA 17025
Dear Mr. Shollenberger:
RE: Addendum to Meaghan Ctxecewka's letter of May 17, 2006
DOB: October 17.1975
It is my opinion; to a reasonable dogrce with psychological mtainty, that Meaghan's
anxiety symptoms, especially the fear of boing taken or being killed, are related to the
trauma of being bit by a do mken driver and witnessing the drunken behaviors edited
at the some of the accident.
if you have any further questions, please feel•free to oontact me at (717) 909-9750.
Simrrely,
I/A"- Q
Victoria A. Whitcomb, LPC, RPT-S
Licensed Professional Colmselor
Registered Play Therapist Supervisor
VAW/lmt
STRICKLER & WHITCOMB MH OC •
5267 SMPSN FRRY RD SUITE 2
MECHANICSBURG, PA 17050
(717) 697-5489
MEAGHAN CHEREWKA
125 PELHAM ROAD
CAMP HILL, PA 17011
BALANCE AS OF 07113/2005 $0.00
07/1312005 CHARGE INSUR. - IND PSYCH VWJS $90.00 $90.00
07/13/2005 PAYMENT PATIENT 3597 - CHECK #: 1611 VWJS ($10.00) $80.00
BALANCE AS OF 07/13/2005 VWJS $80.00
SUBTOTALS $90.00 ($10.00)
Procedure Code.
Federal Tax ID#: 43-2064703
Provider information:
Judith L. Strickler, M.S., NCC
Licensed Psychologist
License #: PS-007182-L
Diag 1: 309.9
Your next appointment is:
Day:
Date:
Victoria A. Whitcomb, M.S., NCC, LPC
Licensed Professional Counselor
License #:PC-001606
Time:
Will call to reschedule: z
You will be charged for any appointment missed or cancelled with less than 24 hours
STRICKLER & WHITCOMB MH C
5267 SMPSN FRRY RD SUITE 2
MECHANICSBURG, PA 17050
(717) 697-5489
MEAGHAN CHEREWKA
125 PELHAM ROAD
CAMP HILL, PA 17011
BALANCE AS OF 06/2712005
06/2712005 CHARGE PATIENT - IND PSYCH VWJS
06/27/2005 PAYMENT PATIENT 3385 - VISA VWJS
BALANCE AS OF 06/27/2005 VMS
$90.00
Procedure Code: a/ (O
Federal Tax ID#: 43-2064703
Provider information:
Judith L. Strickler, M.S., NCC
Licensed Psychologist
License #: PS-007182-L
Victoria A. Whitcomb, M.S., NCC, LPC
Licensed Professional Counselor
License #:PC-001606
U
$0.00
$0.00
Diag 1: 309.9
f7 /? -
0-f t 0
Your next appointment is: _
Day:
Date:
TimeO
Will call to reschedule:
You will be charged for any appointment missed or cancelled with less than 24 hours notice.
STRICKLER & WHITCOMB M OC
5267 SMPSN FRRY RD SUITE 2
MECHANICSBURG, PA 17050
(717) 697-5489
MEAGHAN CHEREWKA
125 PELHAM ROAD
CAMP HILL, PA 17011
BALANCE AS OF 06120/2005
CHARGE PATIENT - IND PSYCH VWJS
PAYMENT PATIENT 3256 - CHECK #: 1567 VWJS
BALANCE AS OF 06/20/2005 1VWjS
Procedure Code:
•
$0.00
$0.00
$90.00
Diag 1: 309.9
Federal Tax ID#: 43-2064703
Provider information:
Judith L. Strickler, M.S., NCC
Licensed Psychologist
License #: PS-007182-L -
Victoria A. Whitcomb, M.S., NCC, LPC
Licensed Professional Counselor
License #:PC-001606
Your next appointment is:
Day.
Date.
Time: eAO
Will call to reschedule:
You will be charged for any appointment missed or cancelled with less than 24 hours notice.
STRICKLER & WHITCOMB M SOC •
5267 SMPSN FRRY RD SUITE 1W
MECHANICSBURG, PA 17050
(717) 697-5489
MEAGHAN CHEREWKA
125 PELHAM ROAD
CAMP HILL, PA 17011
BALANCE AS OF 06113/2005
06113/2005 CHARGE PATIENT - IND PSYCH VWJS $90.00
06/13/2005 PAYMENT PATIENT 3191 - CHECK #: 1561 VWJS ($90.00)
BALANCE AS OF 06113/2005 VWJS
SUBTOTALS $90.00 ($90.00)
Procedure Code: Diag 1: 309.9
Federal Tax ID#: 43-2064703
Provider information:
Judith L. Strickler, M.S., NCC
Licensed Psychologist
License #: PS-007182-L
Victoria A. Whitcomb, M.S., NCC, LPC
Licensed Professional Counselor
License #:P"01606
Your next appointment is:
Day:
Date:
i
Time:
Will call to reschedule:
You will be charged for any appointment missed or cancelled with less than 24 hours notice.
STRICKLER & WHITCOMB M*OC .n
5267 SMPSN FRRY RD SUITE 2 Q?
MECHANICSBURG, PA 17050 co
(717) 697-5489
MEAGHAN CHEREWKA
125 PELHAM ROAD
CAMP HILL, PA 17011
BALANCE AS OF 0512612005 $0.00
05!28!2005 CHARGE PATIENT - IND PSYCH WVJS $90.00 $90.00
05/262005 PAYMENT PATIENT 2983 - CHECK #: 1541 vWJS ($90.00) $0.00
BALANCE AS OF 052612005 VWJS $0.00
SUBTOTALS $90.00 ($90.00)
Procedure Code:0
Federal Tax ID#: 43-2064703
Provider information:
Judith L. Strickler, M.S., NCC
Licensed Psychologist
License #: PS-007182-L
Victoria A. Whitcomb, M.S., NCC, LPC
Licensed Professional Counselor
License #:PC-001606
Diag 1: 309.9
Your next appointment is:
Day:
Dater
Time:
Will call to reschedule:
You will be charged for any appointment missed or cancelled with less than 24 hours notice.
STRICKLER & WHITCOMB MH OOC .
5267 SMPSN FRRY RD SUITE 2W
MECHANICSBURG, PA 17050
(717) 697-5489
MEAGHAN CHEREWKA
125 PELHAM ROAD
CAMP HILL, PA 17011
BALANCE AS OF 04/2012005 $0.00
04/20/2005 CHARGE PATIENT - IND PSYCH VWJS $90.00 $90.00
04/20/2005 PAYMENT PATIENT 2400 - CHECK #: 1467 VWJS ($90.00) $0.00
BALANCE AS OF 04120/2005 VWJS $0.00
SUBTOTALS $90.00 ($90.00)
Procedure Code: qMV51 Diag 1: 309.9
Federal Tax ID#: 43-2064703
/0L Provider information: Your next appoint nt is:
Judith L. Strickler, M.S., NCC
Licensed Psychologist Day:
License #: PS-007182-L
Date: qn Q? 'Gib
Time:
Victoria A. Whitcomb, M.S., NCC, LPC S ' ?-
Licensed Professional Counselor
License #:PC-001606 Will call to reschedule:
You will be charged for any appointment missed or cancelled with less than 24 hours notice.
STRICKLER & WHITCOMB MHOOC
5267 SMPSN FRRY RD SUITE 2W
MECHANICSBURG, PA 17050
(717) 697-5489
MEAGHAN CHEREWKA
125 PELHAM ROAD
CAMP HILL, PA 17011
BALANCE AS OF 03/31/2005 $040
03/31/2005 CHARGE PATIENT - IND PSYCH VWJS $90.00
7 $90.00
03/31/2005 PAYMENT PATIENT 2151 - CHECK #: 1446 VWJS ) $0.00
BALANCE AS OF 03/31/2005
VWJS $0.00
SUBTOTALS $90.00 ($90.00)
Procedure Code: 90846 Diag 1: 309.9
Federal Tax ID#: 43-2064703
Provider information:
Judith L. Strickler, M.S., NCC
Licensed Psychologist
License #: PS-007182-L
Victoria A. Whitcomb, M.S., NCC, LPC
Licensed Professional Counselor
License #:PC-001606
Your next appointment is:
Day:-2,-
Dater
Time:
Will call to reschedule:
You will be charged for any appointment missed or cancelled with less than 24 hours notice.
STRICKLER & WHITCOMB MH OC •
5267 SMPSN FRRY RD SUITE 2
MECHANICSBURG, PA 17050
(717) 697-5489
MEAGHAN CHEREWKA
125 PELHAM ROAD
CAMP HILL, PA 17011
BALANCE AS OF 03/21/2005
/2005 CHARGE PATIENT - IND PSYCH VWJS $90.00
/2005 PAYMENT PATIENT 1980 - CHECK #: 1438 VWJS ($90.00)
BALANCE AS OF 03121/2005 VWJS
SUBTOTALS $90.00 ($90.00)
Procedure Code: Diag 1: 309.9
Federal Tax ID#: 43-2064703
Provider information: Your next appointment is:
Judith L. Strickler, M.S., NCC
Licensed Psychologist Day: ?-hors.
License #: PS-007182-L
Date: 11 q j_
Victoria A. Whitcomb, M.S., NCC, LPC
Licensed Professional Counselor
License #:PC-001606
Time:
Wlll call to reschedule:
You will be charged for any appointment missed or cancelled with less than 24 hours notice.
•
STRICKLER & WHITCOMB M' 0C
5267 SMPSN FRRY RD SUITE 2
MECHANICSBURG, PA 17050
(717) 697-5489
MEAGHAN CHEREWKA
125 PELHAM ROAD
CAMP HILL, PA 17011
BALANCE AS OF 03121/2005 $0.00
03/2112005 CHARGE PATIENT - IND PSYCH VWJS $90.00 $90.00
03/21/2005 PAYMENT PATIENT 1977 - CHECK # 143,1 VWJS ($90.00) $0.00
BALANCE AS OF 03121/2005 VWJS $0.00
SUBTOTALS $90.00 ($90.00)
Procedure Code:
Federal Tax ID#: 43-2064703
Provider Information:
Judith L. Strickler, M.S., NCC
Licensed Psychologist
License* PS-007182-L
Victoria A. Whitcomb, M.S., NCC, LPC
Licensed Professional Counselor
License #:PC-001606
Diag 1: 309.9
Your ne,
Will call to reschedule:
You will be charged for any appointment missed or cancelled with less than 24 hours notice.
STRICKLER & WHITCOMB MFDSOC
5267 SMPSN FRRY RD SUITE 2W
MECHANICSBURG, PA 17050
(717) 697-5489
MEAGHAN CHEREWKA
125 PELHAM ROAD .
CAMP HILL, PA 17011
BALANCE AS OF 03/16/2005
03116/2005 CHARGE PATIENT - IND PSYCH VWJS $90.00
03116!2005 PAYMENT PATIENT 1952-CHECK#: 1413 VWJS
0311612005 PAYMENT PATIENT 1953 - CHECK #: 1413 VWJS
BALANCE AS OF 03/16/2005 VWJS
SUBTOTALS $90.00
Procedure Code:
?U6
Federal Tax ID#: 43-2064703
Provider information:
Judith L. Strickler, M.S., NCC
Licensed Psychologist
License #: PS-007182-L
Victoria A. Whitcomb, M.S., NCC, LPC
Licensed Professional Counselor
License #:PC-001606
E
($90.00)
($1
$0.00
Diag 1: 309.9
Your next
Time:
is:
WIII call to reschedule:
You will be charged for any appointment missed or cancelled with less than 24 hours notice.
STRICKLER & WHITCOMB MHGOC
5267 SMPSN FRRY RD SUITE 2W
MECHANICSBURG, PA 17050
(717) 697-5489
•
MEAGHAN CHEREWKA
125 PELHAM ROAD
CAMP HILL, PA 17011
BALANCE AS OF 03109/2005
CHARGE INSUR. - IND PSYCH
BALANCE AS OF 03/09/2005
SUBTOTALS
VMS $90.00
VWJS
Ind;
$0.00
$90.00
$90.00
$0.00
$90.00
Procedure Code:D D?
Federal Tax ID#: 43-2064703
Provider information:
Judith L. Strickler, M.S., NCC
Licensed Psychologist
License #: PS-007182-L
Victoria A. Whitcomb, M.S., NCC, LPC
Licensed Professional Counselor
License #:PC-001606
Diag 1: 309.9
Your next appointment is:
Day:
Date: ?yJ
Time:
Will call to reschedule:
You will be charged for any appointment missed or cancelled with less than 24 hours notice.
STRICKLER & WHITCOMB MH OC
5267 SMPSN FRRY RD SUITE 2
MECHANICSBURG, PA 17050
(717) 697-5489
MEAGHAN CHEREWKA
125 PELHAM ROAD
CAMP HILL, PA 17011
BALANCE AS OF 02/21/2005 $90.00
02121/2005 PAYMENT PATIENT 1511 - CHECK 1377 VWJS ($90.00) $0.00
02121/2005 CHARGE INSUR. - IND PSYCH VWJS $90.00 $90.00
02/21/2005 PAYMENT PATIENT 1512 - CHECK ,1377 VWJS ($90.00) $0.00
BALANCE AS OF 02/2112005 VWJS $0.00
SUBTOTALS $90.00 ($180.00)
Procedure Code: v N
Federal Tax ID#: 43-2064703
Provider information:
Judith L. Strickler, M.S., NCC
Licensed Psychologist
License #: PS-007182-L
Victoria A. Whitcomb, M.S., NCC, LPC
Licensed Professional Counselor
License #:PC-001606
Diag 1: 309.9
Your next appointment is:
Day:
Datetwf
TimeWIII call to reschedule:
You wi!I be charged for any appointment missed or cancelled with less than 24 hours notice.
STRICKLER & WHITCOMB MHOOC
5267 SMPSN FRRY RD SUITE 2W
MECHANICSBURG, PA 17050
(717) 697-5489
MEAGHAN CHEREWKA
125 PELHAM ROAD
CAMP HILL, PA 17011
IAU41111? 11
•
BALANCE AS OF 02/0112005 $0.00
02/02/2005 CHARGE INSUR. - IND PSYCH VWJS $90.00 $90.00
02/02/2005 PAYMENT CLIENT 1241 - DEDUCTIBLE CK#1343 VWJS ($90.00) $0.00
BALANCE AS OF 02/02/2005 VWJS $0.00
SUBTOTALS $90.00 ($90.00)
Procedure Code: Oy k04
Federal Tax ID#: 43-2064703
Provider information:
Judith L. Strickler, M.S., NCC
Licensed Psychologist
License #: PS-007182-L
Victoria A. Whitcomb, M.S., NCC, LPC
Licensed Professional Counselor
License #:PC-001606
Diag 1: 309.9
Your next appointment is:
Day: Mon
Calp ct( ate: a I 6s ??a
Time: y.e.2 :sc?P?
Will call to reschedule:
• •
Strickler & Whitcomb Mental Health Associates, LLC
5267 Simpson Ferry Road
West Entrance, Suite 2
Mechanicsburg, PA 17050
Statement #: Client name: Meaghan Cherewka
Date: 1/17/05 Address: 125 Pelham Road
Customer ID: Camp Hill PA 17o11
180-76-7362
Date Insurance code DSM IV-TR Description Amount Due Payment Balance
1/12/2005
90806
309.0
Individual Thera session
590.00 (check)
S90.W It1U
$0.00
1/172005 90806 309.0 Individual Thew session S90.00 $90.00 136 50.00
Total:
S0.00
REMITTANCE
Customer ID:
Statement
Date:
Thank you!
Provider Information:
Judith L. Strickler, M.S., NCC
LICENSE: PS-007182-L
FEDERAL TAX ID #: 43 2064703
Terms: 30 days
Please submit payment to:
Strickler & Whitcomb Mental Health Associates
5267 Simpson Ferry Road
Mechanicsburg, PA i7o5o
Victoria A. Whitcomb, M.S., NCC, LPC
LICENSE: P0001606
FEDERAL TAX ID #: 43 2064703
Phone: (717) 697-5489
Fax: (717) 591-2797
Your next appointment is:
DATE: .2 /A / O S?
TIME: d0
Will call to reschedule. I
Insurance DOES NOT nay for missed appointments.
After 30 days interest may be charged on the unpaid balance.
You will be charged for any appointment missed or cancelled
without 24 hour notice.
0 0
Strickler & Whitcomb Mental Health Associates, LLC
5267 Simpson Ferry Road
West Entrance, Suite 2
Mechanicsburg, PA 17050
Statement #: Client name: Meaghan Cherewka
Date: i/i2/o5 Address: 125 Pelham Road
Customer ID: Camp Hill PA 17011
180-76-7362
Date Insurance code DSM IV-TR Description Amount Due Payment Balance
l/IZ2005
90806
309.0
IndividualTherapy session
$90.00 (check)
$90.00 1310
$0.00
Total:
REMITTANCE
Customer ID:
Statement
Date:
Provider Information:
Judith L. Strickler, M.S., NCC
LICENSE: PS-007182-L
FEDERAL TAX ID #: 43 2064703
Terms: 30 days
Please submit payment to:
Strickler & Whitcomb Mental Health Associates
5267 Simpson Ferry Road
Mechanicsburg, PA 17050
Victoria A. Whitcomb, M.S., NCC, LPC
LICENSE: PC001606
FEDERAL TAX ID #: 43 2064703
Phone: (717) 697-5489
Fax: (717) 591-2797
Thank you!
Your next appointment is:
DATE: I //-7 / US
TIME:
Will call to reschedule. 17
You will be charged for any appointment missed or cancelled
without 24 hour notice.
Insurance DOES NOT Day for missed appointments.
After 30 days interest may be charged on the unpaid balance.
49/13/07 12:03 FAX 7175581606_. Progressive Cas Ins Co
PARENTS' RELEASE AND INDEMNITY AGREEMENT
Page 1 of 2
[a 002
KNOW ALL BY THESE PRESENTS: That the undersigned, individually and as legal parents
and guardians of Meagban Cherewka, a minor (hereinafter "Releasors"), for the sole
consideration of Two Thousand Five Hundred and 00/100 (52,500), receipt of which is hereby
aclmowledged, have remised, released, and forever discharged and covenant to hold harmless
Eric A. L1sh and Doris N. Ulsh, their heirs, administrators, executors, successors, agents,
employees, subsidiaries, affiliates and assigns (hereinafter collectively referred to as
"Releasees"), from any and all claims, demands, damages, costs, expenses, loss of services,
actions and causes of action, belonging to the said Releasors arising out of any act or occurrence
up to the present time, and particularly on account of personal injury, disability, property damage,
loss or damages of any kind sustained or that may hereafter be sustained by the said Releasers in
consequence of an accident that occurred on or about the 4/30/04, at or near Hamden, PA.
To procure the payment of the stated consideration, the Releasers hereby declare: that no
representations about the nature and extent of the said injuries, disabilities or damages made by
any physician, attorney or agent of Releasee, nor any representations regarding the nature and
extent of legal liability or financial responsibility of any of the parties released, have induced the
Releasors to make this Release & Indemnity Agreement; that this Release is entered into in
consideration of all known and unknown injuries, disabilities and damages, and also the
possibility that the injuries sustained may be permanent and progressive and recovery therefrom
uncertain and indefinite, so that consequences not now anticipated may result from the said
accident.
The payment made to the undersigned is upon Releasors warrant that no consideration
has been received heretofore from any person, firm or corporation, nor has Releasors released
heretofore any person, firm or corporation from any claim or liability for the said accident.
Releasors agree to indemnify and hold harmless said Releasee from any additional sum of money
that Releasee may hereafter be compelled to pay on account of the injuries to said minor because
of said accident.
The Releasers understand that the Releasees admit no liability of any sort by reason of
said accident and that said payment in compromise is made to terminate further expense and
controversy respecting all claims for damages that Releasors have heretofore asserted or might
personally or through personal representatives hereafter assert because of said accident.
I have read this release and understand it.
Signed:
Witness
Michael Cherewka, father date
Witness Michelle Cherewka, mother date
+ 08/15/07 12:04 FAX 7175581606 Progressive Cas Ins Co 10003
PARENTS' RELEASE AND INDEMNITY AGREEMENT
Page 2 of 2
STATE OF
COUNTY OF
On this day of , 2 before me personally appeared
, to me known to be the person (s) who executed the foregoing
insftmment, and aclmowledged this as a free act and deed.
My commission expires
NotaryPublic
Claim No.: 042783353
I • • 1
SHOLLENBERGER & JANUZZI, LLP
2225 Millennium Way
Enola, PA 17025
Telephone Number: (717) 728-3200
Fax Number: (717) 728-3400
Attornevs for Plaintiff
MICHAEL CHEREWKA and MICHELLE
CHEREWKA, INDIVIDUALLY and
MEAGHAN CHEREWKA, A MINOR, by
MICHAEL CHEREWKA and MICHELLE
CHEREWKA, GUARDIANS,
IN THE COURT OF COMMON PLEAS
CUMBERLAND COUNTY,
PENNSYLVANIA
NO. 06-934 CIVIL
Plaintiffs
ERIC A. ULSH,
JURY TRIAL DEMANDED
Defendant
V.
CIVIL ACTION - LAW
CERTIFICATE OF SERVIVE
And now, this it S4"' day of August, 2007, 1 hereby certify that a true and
correct copy of the foregoing Petition to Approve Compromise Settlement has
been served upon the following, Attorney for Defendant, via U.S. Mail:
Jeffrey T. McGuire
Caldwell & Kearns, P.C.
3631 North Front Street
Harrisburg, PA 17110
SHOLLEN RGER & JANUZZI, LLP
By:
Adam T. Wolfe, Es
>? n
G'y f
? m
-' C 1
i
SHOLLENBERGER & JANUZZI, LLP
2225 Millennium Way
Enola, PA 17025
Telephone Number: (717) 728-3200
Fax Number: (717) 728-3400
Attorneys for Plaintiff
MICHAEL CHEREWKA and MICHELLE
CHEREWKA, INDIVIDUALLY and
MEAGHAN CHEREWKA, A MINOR, by
MICHAEL CHEREWKA and MICHELLE
CHEREWKA, GUARDIANS,
IN THE COURT OF COMMON PLEAS
CUMBERLAND COUNTY,
PENNSYLVANIA
NO. 06-934 CIVIL
Plaintiffs
V.
ERIC A. ULSH,
Defendant
CIVIL ACTION - LAW
JURY TRIAL DEMANDED
DISTRIBUTION OF F
AND NOW come the Plaintiffs/Petitioners, MICHAEL CHEREWKA and
MICHELLE CHEREWKA, INDIVIDUALLY and MEAGHAN CHEREWKA, A
MINOR, by MICHAEL CHEREWKA and MICHELLE CHEREWKA, GUARDIANS,
by and through their attorneys SHOLLENBERGER & JANUZZI, and do
respectfully file this Amendment to Petition to Approve Compromise Settlement
and Distribution of Proceeds:
No Judge has ruled upon any other issue in the same or related matter.
Counsel for the Plaintiff/Petitioners contacted, Jeffery T. McGuire, Esquire,
Counsel for the Defendant/Respondent and he concurs in the filing of this
Petition.
Respectfully submitted,
SHOLL BERGER JANUZZI, LLP
r
Timothy A. Shollenberger, Esquire
PA ID No. 34343
Adam T. Wolfe, Esquire
PA ID No. 201057
s
SHOLLENBERGER & JANUZZI, LLP
2225 Millennium Way
Enola, PA 17025
Telephone Number: (717) 728-3200
Fax Number: (717) 728-3400
Attorneys for Plaintiff
MICHAEL CHEREWKA and MICHELLE
CHEREWKA, INDIVIDUALLY and
MEAGHAN CHEREWKA, A MINOR, by
MICHAEL CHEREWKA and MICHELLE
CHEREWKA, GUARDIANS,
Plaintiffs
V.
ERIC A. ULSH,
Defendant
IN THE COURT OF COMMON PLEAS
CUMBERLAND COUNTY,
PENNSYLVANIA
NO. 06-934 CIVIL
CIVIL ACTION - LAW
JURY TRIAL DEMANDED
AND NOW this 30" _ day of August, 2007, 1 hereby certify that I have served
the following Amendment to Petition to Approve Compromise Settlement and
Distribution of Proceeds to the following by depositing a true and correct copy of
same in the United States mail, postage prepaid, addressed to:
Jeffrey T. McGuire, Esquire
Caldwell & Kearns, P.C.
3631 North Front Street
Harrisburg, PA 17110
Respectfully submitted,
SHOLL NBERGER & JANUZZI, LLP
Adam T. Wolfe, Esquire
PA ID No. 201057
ra
°
O
C
73 G,
S
rn
--a 73
?
"
-• r' fj) --1
SHOLLENBERGER & JANUZZI, LLP
2225 Millennium Way
Enola, PA 17025
Telephone Number: (717) 728-3200
Fax Number: (717) 728-3400
Attorneys for Plaintiff
MICHAEL CHEREWKA and MICHELLE
CHEREWKA, INDIVIDUALLY and
MEAGHAN CHEREWKA, A MINOR, by
MICHAEL CHEREWKA and MICHELLE
CHEREWKA, GUARDIANS,
AUG 8 42007
ff*?
IN THE COURT OF COMMON PLEAS
CUMBERLAND COUNTY,
PENNSYLVANIA
NO. 06-934 CIVIL
Plaintiffs
V.
ERIC A. ULSH,
CIVIL ACTION - LAW
JURY TRIAL DEMANDED
Defendant
AND NOW this day of ?S? , 2007, upon
consideration of the within Petition, Plaintiffs' request for approval of a
Compromise Settlement in the above captioned matter is approved. Plaintiffs'
counsel shall be permitted to collect costs and expenses in the amount of
$137.03, to be paid from the proceeds of this settlement. It is further ordered that
Plaintiffs/Petitioners, Michael and Michelle Cherewka shall collect $1,070.00 for
reimbursement of out-of-pocket payment of medical bills on behalf of Meaghan
Cherewka. The balance of the proceeds shall be deposited in the name of
Meaghan Cherewka in one or more savings accounts, banks, building and loan
associations or savings and loan associations, deposits of which are insured by a
Federal governmental agency provided that the amount deposited in any one
savings institution shall not exceed the amount to which accounts are thus
insured.
No withdrawal shall be made from any such account until Meaghan
Cherewka shall attain her majority, except as authorized by further Order of this
Court.
Proof of the deposit, along with a signature card for each account, shall be
promptly filed of record with the Court.
Lo
ZS
SHOLLENBERGER & JANUZZI, LLP
2225 Millennium Way
Enola, PA 17025
Telephone Number: (717) 728-3200
Fax Number: (717) 728-3400
Attornevs for Plaintiff
MICHAEL CHEREWKA and MICHELLE
CHEREWKA, INDIVIDUALLY and
MEAGHAN CHEREWKA, A MINOR, by
MICHAEL CHEREWKA and MICHELLE
CHEREWKA, GUARDIANS,
Plaintiffs
V.
ERIC A. ULSH and ROBERT A. ULSH,
Defendants
PRAECIPE TO END, SETTLE AND DISCONTINUE
TO THE PROTHONOTARY:
Please mark the above-captioned action settled, ended, and discontinued
IN THE COURT OF COMMON PLEAS
CUMBERLAND COUNTY,
PENNSYLVANIA
NO. 06-934 CIVIL
CIVIL ACTION - LAW
JURY TRIAL DEMANDED
with prejudice.
Date: November 26, 2008
Respectfully submitted,
SHOLLENBERGER & J-ANUZZI, LLP
Attorneys for/Flaintiff
By:
Adam T. Wbife,W-squire
Attorney I.D. #201057 for
Timothy A. Shollenberger, Esq.
Attorney I.D. #34343
2225 Millennium Way
Enola, PA 17025
(717) 728-3200
(717) 728-3400 (fax)
SHOLLENBERGER & JANUZZI, LLP
2225 Millennium Way
Enola, PA 17025
Telephone Number: (717) 728-3200
Fax Number: (717) 728-3400
Attorneys for Plaintiff
MICHAEL CHEREWKA and MICHELLE
CHEREWKA, INDIVIDUALLY and
MEAGHAN CHEREWKA, A MINOR, by
MICHAEL CHEREWKA and MICHELLE
CHEREWKA, GUARDIANS,
IN THE COURT OF COMMON PLEAS
CUMBERLAND COUNTY,
PENNSYLVANIA
NO. 06-934 CIVIL
Plaintiffs
V. CIVIL ACTION - LAW
ERIC A. ULSH, JURY TRIAL DEMANDED
Defendant
CERTIFICATE OF SERVICE
AND NOW, this 26th day of November, 2008, 1 hereby certify that a true
and correct copy of the foregoing Praecipe to Discontinue has been served upon
the following, Attorney for Defendant, via U.S. Mail:
Jeffrey T. McGuire, Esquire
Caldwell & Kearns, P.C.
3631 North Front Street
Harrisburg, PA 17110
SHOLLENBER,GER & JANUZZI, LLP
i
By:
Adam T. Wolfe, Esq.
_,
;.
...?
.?, t--< .,..
.,,
SHOLLENBERGER & JANUZZI, LLP
2225 Millennium Way
Enola, PA 17025
Telephone Number: (717) 728-3200
Fax Number: (717) 728-3400
Attorneys for Plaintiff
MICHAEL CHEREWKA and MICHELLE
CHEREWKA, INDIVIDUALLY and
MEAGHAN CHEREWKA, A MINOR, by
MICHAEL CHEREWKA and MICHELLE
CHEREWKA, GUARDIANS,
FILED-OFFICE
OF THE PROTHONOTARY
2011 MAR 23 AM I1 : 18
CUM PBEERLAND COUNTY
IN THE COURT OF COMMON PLEAS
CUMBERLAND COUNTY,
PENNSYLVANIA
NO. 06-934 CIVIL
Plaintiffs
V.
ERIC A. ULSH and ROBERT A. ULSH,
CIVIL ACTION - LAW
JURY TRIAL DEMANDED
Defendants
PROOF OF DEPOSIT
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APC 102 -
InStavings Account Inquiry » Basic Account Data
Account number 77,804676361 1BA -
Short name CHI=iEWKA MEAGHAN K M
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Current balance
Avail balance
Avail tomorrow
Memo balance
Hold amount
Check CR balance
Interest due
Int pd this year
Int pd last year
Acct current rate
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Stat F
Statement code/cycle
Date opened
Processed thru
Prod type
Page 1 of 1
Next Display S/hoid inform
-Account Name/Address
MICHAEL CHEREWKA
CUSTODIAN FOR
MEAGHAN K CHEREWKA UTMA
125 PELHAM ROAD
CAMP HILL PA 17011
-Customer Activity
Stops/holds active
Date last contact
Date last active
Date last deposit
Amount lest deposit
-Previous Statement Date
Last stmt date
Last stmt balance 77
Checks/deposits since 00000
Service charge typelplan
Combined stmt/nbr copies;
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