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SHOLLENBERGER & JANUZZI, LLP
2225 Millennium Way
Enola, PA 17025
Telephone Number: (717) 728-3200
Fax Number: (717) 728-3400
Attorne s for Plaintiffs
IN RE: BROOKLYN ALBRIGHT, a minor, by
JILL YAN ALBRIGHT and DENNIS JACK
O'DONNELL, guardians,
Petitioners
IN THE COURT OF COMMON PLEAS
CUMBERLAND COUNTY,
PENNSYLVANIA
NO. 0 (g - d.-,;L 7"'S CJ.I.I -fN-""
CIVIL DIVISION
PETITION TO APPROVE COMPROMISE, SETTLEMENT, AND DISTRIBUTION OF
PROCEEDS
AND NOW, come the Petitioners, BROOKLYN ALBRIGHT, a
minor, by JILL YAN ALBRIGHT and DENNIS JACK O'DONNELL, her parents
and natural guardians, by and through their attorneys, Shollenberger and
Januzzi, LLP, and do respectfully represent the following:
1. Petitioner, Brooklyn Albright, is a minor, having been born on April 5, 2000
and currently resides with her mother, Jillyan Albright, 6 Hilltop Drive,
Shippensburg, Cumberland County, Pennsylvania, 17257.
2. Petitioner, Jillyan Albright, is the mother and natural guardian of Brooklyn
Albright and is an adult individual currently residing at the aforementioned
address.
3. Petitioner, Dennis JACK O'DONNELL is the father and natural guardian of
Brooklyn Albright and is an adult individual currently residing at 95
Hershey Road, Shippensburg, Cumberland County, Pennsylvania, 17257.
4. Respondent is the United States of America.
5. Petitioner, Brooklyn Albright was born on April 5. 2000. During the birth a
shoulder dystocia was encountered. Delivery was effected with a vacuum
extractor and by use of the McRobert's Maneuver, the application of
suprapubic pressure, and delivery of the posterior shoulder.
6. Petitioner, Brooklyn Albright's birth occurred at Chambersburg Hospital
and the delivery was performed by Dr. Kathleen Ann Garde, an employee
of Keystone Rural Health Center. Valerie Fuller Fulton and Kristine Lively
Helman are registered nurses who assisted in the delivery.
7. Petitioners aver that the delivery deviated from the appropriate obstetrical
standard of care and that the nurses were improperly trained by
Chambersburg Hospital and failed to properly handle the shoulder
dystocia.
8. The Petitioner, Brooklyn Albright, alleged that she suffered injuries
including, but not limited to profound right brachial plexus injury with
multiple nerve root avulsions from the cervical spine.
9. As a result of the above and the injuries sustained therein, Petitioner,
Brooklyn Albright, incurred medical bills totaling $5,145.10. Of this
amount, all but $94.00 was paid. A copy of a Medical Bills Summary is
attached hereto as Exhibit "A". The Commonwealth of Pennsylvania
Department of Public Welfare has asserted the right of subrogation and
reimbursement with regard to the medical bills. As of December 7,2005,
the requested lien amount is $295.24.
10. Petitioner, Brooklyn Albright, last received medical treatment on January
18,2006 from Dr. Scott H. Kozin, MD at Shriners Hospitals for Children, at
which time Dr Kozin instructed that Brooklyn should continue with home
exercises and should return for an annual visit in one year.
11. Petitioners believe and therefore aver that Brooklyn Albright sustained the
injuries stated above as a result of the negligence of Dr. Kathleen Ann
Garde, Keystone Rural Health Center, Chambersburg Hospital, Valerie
Fuller Fulton, and Kristine Lively Hellman.
12. Suit was originally filed on March 25, 2004 in Franklin County,
Pennsylvania, but was removed to the United States District Court for the
Middle District of Pennsylvania.
13. The United States of America has assumed the Defense for Keystone
Rural Health Center and Dr. Kathleen Ann Garde.
14. With respect to Defendants Chambersburg Hospital, Valerie Fuller Fulton
and Kristine Lively Helman, the parties have not reached a settlement and
the litigation is ongoing.
15. The United States has offered $125,000.00 in settlement of Brooklyn
Albright's claim. In exchange for the aforementioned amount, the United
States of America seeks the signing of "AGREEMENT FOR
COMPROMISE SETTLEMENT AND RELEASE OF FEDERAL TORT
CLAIMS ACT CLAIMS PURSUANT TO 28 U.S.C. S 2677." A copy of the
proposed release is attached hereto and incorporated by reference herein
as Exhibit "B".
16. Petitioners believe that the above-referenced offer of settlement is fair and
reasonable.
17. The Petitioners have retained the services of the law offices of
Shollenberger and Januzzi, L.P. to represent them and had agreed to pay
a twenty-five (25%) percent contingent fee to said attorneys.
Shollenberger and Januzzi, L.P. has associated with Ralph Mazer, Esq.
and David Perkins, Esq. in the handling of this claim. A copy of the
Contingent Fee Agreement between the Petitioners and their counsel is
attached hereto, incorporated by reference herein and marked as Exhibit
"C".
18. The Petitioners have further agreed to payout of their share of the
recovery any and all costs incurred or advanced on their behalf. The
amount of the costs that were incurred and advanced on Petitioner's
behalf to date in this matter total $20,974.35. An itemization of all costs is
attached hereto, incorporated by reference herein and marked as Exhibit
"0".
19. Petitioners request that the Court approve the compromise settlement set
forth above and order that the proceeds be distributed as follows:
Attorneys Fees (25%)
Costs Reimbursement to Shollenberger and Januzzi, LLP
Department of Public Welfare Lien
$31,250.00
$ 20,974.35
$ 295.24
Balance to Brooklyn Albright
$ 72,480.41
20. Petitioner, Brooklyn Albright, by Jillyan Albright and Dennis 0' Donnell her
parents and natural guardians, requests that the funds to be distributed for
the benefit of Brooklyn Albright be deposited in one or more savings
accounts in the name of Brooklyn Albright 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 anyone savings institution should not exceed the amount to
which accounts are thus insured.
21. Petitioner, Brooklyn Albright, by Jillyan Albright and Dennis 0' Donnell her
parents and natural guardians, requests that upon approval of the
proposed compromised settlement and receipt of the proceeds thereof,
they be authorized to execute the Release attached to this Petition.
WHEREFORE, the Petitioners Brooklyn Albright, Jillyan Albright and Dennis 0'
Donnell her parents and natural guardians, request this Honorable Court approve
the Compromise Settlement and Distribution of the Proceeds or in the alternative
to schedule a hearing on this Petition.
Respectfully submitted,
SHOLLENBERGER AND JANUZZI, LLP
SHOLLENBERGER & JANUZZI, LLP
2225 Millennium Way
Enola, Pennsylvania 17025
Telephone Number: (717) 728-3200
Fax Number: (717) 728-3400
Attorne s for Plaintiff
IN RE: BROOKLYN ALBRIGHT, a minor,
by JILL YAN ALBRIGHT and DENNIS
JACK O'DONNELL, guardians,
Petitioners
IN THE COURT OF COMMON PLEAS
CUMBERLAND COUNTY,
PENNSYLVANIA
NO.
CIVIL DIVISION
CERTIFICATE OF SERVICE
And now, this .a.tday of April, 2006, I hereby certify that a true and
correct copy of the foregoing Petition to Approve Compromise, Settlement, and
Distribution of Proceeds has been served upon the following via U.S. Mail;
Kevin Osborne, Esquire
Hartman, Osborne & Rettig
126-128 Walnut Street
Harrisburg, PA 17101
G. Michael Thiel, Esquire
Assistant U. S. Attorney
William J. Nealon Federal Building
Suite 311
P. O. Box 309
Scranton, PA 18501
SHOLLEN ERGER & JANUZZI, LLP
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ACJREEMENT FOR COMPROMISE SETTLEMENT AND RELEASE OF
. .
FEDERAL TORT CLAIMS ACT CLAIMS PURSUANT TO 28 U.s.C, ~ 2677
It is hereby agreed by and between the Plaintiffs, JILL VAN ALBRIGHT,
DENNIS O'DONNELL and BROOKLYN D, ALBRIGHT, a minor, and the
Defendant, UNITED STATES OF AMERICA, by and through their respective
attorneys, as follows:
1, The parties do hereby agree to settle and compromise each and every claim
of any kind, whether known or unknown, arising directly or indirectly from the
treatment and care provided to Jillyan and Brooklyn Albright at the Keystone Rural
Health Center and/or the Chambers burg Hospital, which treatment and care began
on or about August 17, 1999, and continued on and through the labor and delivery of
Brooklyn Albright, a minor, which is alleged to have resulted injuries to Jillyan and
Brooklyn Albright.
2, The United States of America agrees to pay the sum of ONE HUNDRED
AND TWENTY-FrVE THOUSAND DOLLARS ($ 125,000,00), which sum shall be
in full settlement and satisfaction of any and all claims, demands, rights, and causes
of action of whatsoever kind and nature, arising from, and by reason of any and all
known and unknown, foreseen and unforeseen bodily and personal injuries, damage
to property and the consequences thereot~ resulting, and to result, from the subject
matter of this settlement, including any claims for wrongful death, for which
PlaintJ1Ts or their guardians, heirs, executors, administrators, or assigns, and each of
them, now have or may hereafter acquire against the United States of America, its
agents, servants, and employees,
3, Plaintiffs and their guardians, heirs, exeeutors, administrators, and assigns
agree to and do accept this settlement in full settlement and satisfaction and release
of any and all elaims, demands, rights, and causes of action of any kind, whether
known or unknown, including without limitation any claims for fees, costs, expenses,
survival or wrongful death, arising ti-om any and all known or unknown, foreseen or
unforeseen bodily injuries, personal injuries, death, or damage to property, which they
may have or hereafter acquire against the United States of America, its agents,
servants, or employees on account of the subject matter of this claim, or that relate
or pcrtain to or arisc from, directly or indirectly, the subject matter of this claim.
Plaintiff and their guardians, heirs, executors, administrators, and assigns further
agree to reimburse, indemnify, and hold harmless the United States of America, its
agents, servants, and employees from and against any and all claims, demands, right:;:,
and causes of action of any kind, whether known or unknown, including without
limitation claims for subrogation, indemnity, eontribution, or lien of any kind, or for
fees, costs, expenses, survival or wrongful death that relate or pertain to or arise from,
directly or indirectly, any act or omission that relates to the subject matter of this
claim,
4, This agreement for compromise settlement is not, is in no way intended to
be, and should not be construed as, an admission of liability or fault on the part of the
United States, its agents, servants, or employees, and it is speci fieally denied that they
are liable to the plaintiffs, This settlement is entered into by all parties for the
purpose of compromising disputed claims under the Federal Tort Claims Act.
5, It is also agreed, by and among the parties, that the respective parties will
each bcar their own costs, fees, and cxpenses and that any attorney's fees owed by the
Plaintiff~s will be paid out of the settlement amount and not in addition thereto,
6, It is also understood by and among the parties that pursuant to Title 28,
United States Code, Section 2678, attorney's fees for services rendered in connection
with this matter shall not excced 25 per centum of the amount of the compromise
settlement.
7, The persons signing this Settlement Agreement warrant and represent that
they possess full authority to bind the persons on whose behalf they arc signing to the
terms of the settlement. In the event any Plaintiff is a minor or legally incompetent
adult, the PlaintitTs must obtain State Court approval of the settlement at their
expense, Plaintiffs agree to obtain such approval in a timely manner: time being of
the esscnce, Plaintiffs further agree that the United States may void this settlement
at its option in the event such approval is not obtained in a timely manner. In the
event Plaintiff fails to obtain such State Court approval, the entire Stipulation For
Compromise Settlement And Release and the compromise settlement are null and
void,
8, The parties agree that this Agreement for Compromise Settlement and
Release, including all the terms and conditions ofthis compromise settlement and any
additional agreements relating thereto, may be made public in their entirety, and the
Plainti iT expressly consents to such release and dIsclosure pursuant to 5 U ,S,c:. ~
552a(b ),
9, It is contemplated that this agreement may be cxecuted in scvcral
counterparts, with a separate signature pagc for each party, All such counterparts and
signature pages, together, shall be deemed to be one document.
10. Plaintiffs reservc thc right to makc claim against any and every other
person or cntity, and reserve also the right to makc claim that they, and not the United
States of America are solely or Jointly liable to thc Plainti iTs for their injuries, losses
and damages,
II, In the event that other tortfeasors are found to be responsible to Plaintiffs
for damages as a result of bodily injury sustained by them as a result of this incident,
the execution of this Release shall operate as a satisfaction of that claim against such
other tortfeasors to the cxtent of the relative pro rata share of common liability of the
Unitcd States of America as herein releascd,
.
12, If it should appear or be adjudicated in any suit, action or proceeding that
the United States of America and others Jointly caused injuries, losses and damages
set forth in the claim currently pending, thcn in order to save the United States of
America harmless as further consideration for the aforesaid payment, Plaintiffs will
satisfy any decree,Judgment or award in whieh thcre is such a finding or adjudication
involving the United States of America on its behalf to the extent of its pro rata share
of I iabi I ity for contribution and/or indemnity,
13, This release is expressly intended and shall be construed to release and
protect the United States of America li'om all claims of contribution and all claims of
indemnity or otherwise, Plainti ITs will furthn indemnify and save forever harmlcss
the United States of Amcrica against loss or damage because or any and all further
claims, demands or actions made by others on account of or in any manner resulting
ii'Oll1 said injuries, losses or damages,
14, It is thc intention ofthc parties that this Pro-Rata Joint Tortfeasor Release
be construed, interpreted and in compliance with the 191\7 Pennsylvania Supreme
Court case of Charles v, Giantl,'agle Markets v. Stanley ivlagic Door, Inc" 513 Pa,
474,522 i\.2d I (I 987), No matter how this Relcase is titled or worded, the intention
of'bolh partics is that it shall be construcd as to have exactly the same legal clTect as
the release mentioncd on page five of the Ciant Eaglc decision and given the same
legal effect on all parties, including preclusion of the non-settling parties to rights
against the Unitcd States or America for contribution and/or indcmnity under a
verdict orjudgment or otherwise,
Wc further state that we have carefully rcad the foregoing Relcase and know
the contents thereo( and sign thc same of our own li'ce act.
Executed this 2'L,Joday of MA-f(,G/r
,20oe.,
c.-/U~/
,
G, Michael Thiel
Attorney for United States of America
Executed this
day of
,2
Timothy i\, Shollenberger, Esq,
Attorncys fOl' Plaintiff
Executed this
day of
,2
Jillyan Albright, individually and as guardian
of Brooklyn Albright
Plaintiff
Exccuted this
day of
,2
Dennis 0' Donnell, individually and as guardian
of Brooklyn Albright
Plainti ff
Power of Attorney
and
Contingent Fee Agreement
We, Jillyan Albright, Jeffrey Albright and Dennis Jack O'Donnell on behalf of
Brooklyn Albright, do hereby retain Shollenberger & Januzzi, LLP of Harrisburg,
Pennsylvania, as my attorneys to negotiate for me a settlement or to institute for me in
my name any legal proceedings or actions that in their judgment are necessary in
connection with my claim for damages sustained on the 5th day of April, 2001, against:
Kathleen A. Garde, MD" Chambersburg Hospital and Keystone Rural Health Center
and any other person, firm, corporation or entity who may be responsible for my claim,
and/or to obtain an amicable settlement.
I hereby give to my attorneys a Power of Attorney to execute all documents
connected with the claim for the prosecution of which the attorney is retained, including
pleadings, contracts, commercial papers, settlement, agreements, compromises and
releases, verifications, dismissals, orders, settlement checks and all other documents
that I could properly execute in connection with this lawsuit.
I agree not to settle or adjust the above claim or any proceedings arising from
said claim nor to discuss said claim with any other persons,
I agree to fully cooperate with my said attorneys in the prosecution of the claim
that comprises the subject matter of this Agreement. This includes, but is not limited to,
making myself available for legal proceedings and consultations with my said attorneys;
keeping my said attorneys informed as to my current mailing address, phone number
and the current status of my medical condition,
I warrant that the information which I have supplied and will supply during the
course of these legal proceedings is true and accurate, and has not been and will not
be obtained through fraud or illegal activities,
I agree to pay attorneys' fees from the total amount recovered from any source,
except first party benefits (i. e,. work loss and medical benefits), on account of my
bodily injury claim, including my claim for uninsured or underinsured motorist benefits,
on the following basis:
Settlement of third party tort
total claim prior to filing of
legal action,
33-1/3% of
total sum
recovered
Settlement of third party tort
claim on or after filing of legal
action,
40% of
total sum
recovered
SHOLLENBERGER. & JANUlZI, LLP
:320 L1NGLESTOWN ROAD. po. BOX 6llS45. HAHRISHURG, PA 17106-0;;'45
[717) 234-3700. FAX 1717) 234-8212
Costs: Costs are to be paid from my (the client's) share of the total amount
recovered and include, but are not limited to: photocopies; fax charges; postage;
notaries; long distance telephone charges; mileage for attorneys and staff; investigation
charges; photographs; court costs; WEST LAW research charges; medical records
costs; fee for police report; deposition costs; expert witness fees; stenographer costs;
and, video deposition fees,
In the event that no recovery is obtained on this claim, the attorneys will make no
charges for their time or services, However, any costs or expenses which the attorneys
may have advanced on behalf of the claim must be paid by me from my share of the
recovery settlement or verdict or if no recovery, settlement or verdict is obtained or the
settlement, recovery or verdict is less than the costs and I do not follow my attorney's
recommendation to accept an offer of settlement.
As one possible settlement option, I authorize the said attorneys to explore the
possibility of a structured settlement through the use of deferred periodic payments, I
agree that if my claim is settled through such structure, the attorneys' fees may be paid
directly to said attorneys from the insurance company, either in one lump sum payment
at settlement, or, at the sole option of said attorneys and/or insurance company,
deferred into future payments, However, in any event, said attorneys' fees shall be
calculated in the percentage as set forth above based upon the cost of the structured
settlement or present value thereof in accordance with applicable law,
All medicaL bills for which I am legally responsible incurred as a result of my
injuries shall be paid from my share of the recovery, unless otherwise paid by
insurance,
The Contingent Fee Agreement applies to all proceedings up to and including
verdict or decision at trial or arbitration, except proceedings which are or may be
required to collect first party benefits, If, in the discretion of the attorneys, post-trial
proceedings, including appeals, are warranted, they will not be covered by this
Contingent Fee Agreement and a new fee agreement will be required by said attorneys,
This Contingent Fee Agreement and Power of Attorney shall not apply to any
right, claim or cause of action that we may have for collection of first party benefits, (i,e"
work loss benefits and medical bills),
SHOUENBERGER & ,IANUZZI, UP
1820 UNGLE5TOWN ROAD. PO BOX 6OS45 . HARRISBURG, PA 17106-0545
(7171234-3700. FAX (7171234-8212
. ..
In Witness Whereof, I have hereunto set my hand(s) and seal(s) this 2~ day
A~I'I ,2000,
~I) ()<r~lU{\n ~,s:tl tw 1'\Yl\ (Seal)
Seal)(yv); ~ I) A' (Seal)
/ d/ / //:.:.>!~ /'
eal)(.rJ '. ,~,;;//, >i /::x::;~:?;, (Seal)
And Now, this 23rd day of AIJR,'L ,'2000, the above Contingent Fee
Agreement and Power of Attorney has been read, approved, and understood by me
and the receiR cop thereof acknowledged, The terms set forth are agreeable,
t' '\ v\;
't J' , (Seal)
,
1. (Seal)
,/ ,'/;/ .".- ",/";'
/'0/ / ..-<" /:::;/~ ~7'
/</.j '" .,'~ < <:,</ (Seal)
/'~7'-,./~ " /,'
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SllOllENBERGER & JANlJZZI. UP
1820 L1NGtESTOWN ROAD. 1'0_ BOX 60545 . HARRISBURG, PA ] 7l06-11Y15
(717) 234-3700. fAX 17171 234-8212
".or l-l/20CE
Date Received From/Paid To
Entry~ Explanation
1066 Albright, c/o Jillyan Albright, Brooklyn
011289 Medical Malpractice - referred by David Perki
May 9/2001 Chart One Inc 3426
44076 Medical Records - inv#106101107537,
Chambersburg Hasp
Milton S Hershey Medical Center
Medical Records Brooklyn Albright
Expense Recovery
Facsimilies - May
Expense Recovery
Postage - May
Expense Recovery
Photocopies - May
Keystone Health Center
Medical Records - Brooklyn Albright
FYI Heal thserve
Medical Records - l-8Q-32157 HMC
Expense Recovery
Postage - June
Expense Recovery
Photocopies - June
ChartONE,Inc
Medical Records - inv# l061C1108181
Chambersburg Hasp
Shriners Hospitals for Children
Medical Records - 8 Albright
Expense Recovery
Lexis, West law - July
Expense Recovery
Postage - Nov
l\.TLA LR
May
15/2001
44208
31/2001
44760
31/2001
44868
31/2001
44936
4/2001
44555
11/2001
44693
30/2001
45454
30/2001
45650
9/2001
45352
May
May
May
Jur.
Jun
Jun
Jun
Jd
Jul
11/2001
45452
16/2001
46454
31/2001
48922
13/2001
48811
Aug
Oct
Nov
Feb
28/2002
52131
28/2002
52224
6/2002
54471
Feb
Jun
Jul
31/2002
57065
31/2002
57076
2/20C3
59741
Aug
Jan
Jan
9/2003
60287
Feb
25/2003
62374
28/2003
62741
28/2003
62882
31/2003
63736
31/2003
63784
31/2003
64280
1/2003
63654
Feb
Fab
Mar
Mar
Mar
Apt
Apr
30/2003
64737
30/2003
65081
30/2003
65320
21/2003
65804
27 /2003
65885
27/2003
65887
Apr
Apr
May
May
May
iigation resources - Herides v. Phys.
Ins Co #3727
Expense Recovery
Postage - Feb
Expense Recovery
Photocopies - Feb
Suneet P Chauhan, MD
Outside Professional - re: Brooklyn
Albright
~xpense Recovery
Lexis, Westlaw - July
Expense Recovery
Lexis, Westlaw
Shanna Dishong
Outside Professional
records re: B Albright
Sandy Spade
Mileage/Parking - 1/8 Chambersburg
Hosp
Pa Instant Case Service
inv# 013127, Pics acct# 50419
Expense Recovery
Postage - Feb
Expense Recovery
Photocopies - Feb
Expense Recovery
Facsimilies - March
Expense Recovery
Postage - March
Expense Recovery
Telephone - March
ChartONE, Ine
Medical Records inv#
:06101-1-117478 Chambersburg Hosp
Expense Recovery
Postage - April
Expense Recove~y
Photocopies - April
Expense Recovery
Telephone - April
Expense Recovery
Lexis, West law April
Franklin County Prothonotary
Filing Fees - Prothonotary B Albright
Franklin County Sher:ff
Sheriff Fees B Albright
- August
review of
S~ollen~erger & Januzz:, ~~?
Client ~ecger
ALL DATES
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7],51
3456
83,00
00373
1. 50
00375
1. 36
00377
1.95
3515
40,00
3541
30,79
00387
0.34
00391
1.50
3619
::"41. 61
3634
77 ,14
00412
25,00
00465
9,29
4081
95,00
00518
0,34
00520
0,15
4866
700,00
00591
7,25
00592
11,85
5643
300,00
5687
38,69
5856
25,94
00651
0,74
00652
0,45
00662
2,00
00663
0,74
00667
1. 00
6018
92.77
00669
16,75
00671
70,95
00672
1.50
00674
3,75
6231
80,50
6232
150,00
Page -=-
BId Trust
Fees Inv# Ace Rcpts Disbs
Balance
Resp Lawyer: TAS
Ap~ 1112006 S~8llen8erger ~ 2anuzz:, ~1? Page 2
Clie:".t Lecger
AL~ Df\.~ES
Date Received From/Paid To Che# General 31d Trust
Entry# Explanation l\Cpt# ~ts__ Disbs Fees I:w# Ace Rcpts Disbs Bala:;ce
May 31/2003 Expense Recovery 00676 3,50
66026 Facsimilies - May
May 3:/2003 Expense Recovery OJ677 9,81
66064 Postage - May
May 31/2003 Expense Recovery 00678 31. 20
66231 Photocopies - May
Jun 30/2G83 Expense Recovery 00681 0.74
67259 Postage ~ June
Jul 31/2003 Expense Recovery 00694 20,03
68110 Postage - July
Aug 7/2003 Franklin County Sheriff 00735 71. 55
68332 RET - Refund - Sheriff fees - ck#
10395, 8/4, refund for Jillian Albright
Aug 31/2003 Expense Recovery 00704 4,79
69389 Postage - Aug
Sep 11/2003 Dr Gary Magram 6643 500.00
69760 Outside Professional re: Broklyn
Albright
Sep 30/2003 Expense Recovery 00711 10,50
70442 Facsimilies - Sept
Sep 30/2003 Expense Recovery 00713 4,99
70522 Postage - Sept
Sep 30/2003 Expense Recovery 00715 93,15
70750 Photocopies - Sept
Oct 2/2003 American Quick Print 6752 95,40
70371 inv # 6871, re: B Albright
Oct 23/2003 Expense Recovery 00723 414,00
71388 Lexis, Westlaw - Sept
Oct 28/2003 Jnishippers 6881 21. 85
71496 cust# BK0417, inv# 00058884
Oct 31/2003 Expense Recovery 00728 2,00
71862 Facsimilies - Oct
Jan 21/2004 Shanna E Dishong 7234 125,00
74695 Outside Professional - re: Brooklyn
Albright
Jan 31/2004 Expense Recovery 00753 1.50
75088 Facsimilies - Jan
Jan 31/2004 Expense Recovery 00754 1.85
75152 Postage ~ Jan
Jan 31/2004 Expense Recovery 00756 0,60
75348 Photocopies - Jan
Feb 25/2004 Dept of State 5898M 39,00
76178 records re: Broklyn Albright
Feb 28/2004 Expense Recovery 00762 3,70
76357 Postage - Feb
Feb 29/2004 Expense Recovery 00767 23,00
76541 Lexis, Westlaw - Jan
Mar 22/2004 Shanna Dishong 7504 100,00
77281 Outside Professional - re: B Albright
Mar 24/2004 Franklin County Prothonotary 7511 80,50
77317 Filing Fees - Prothonotary B Albright
Mar 24/2004 Franklin County Sheriff 7512 150,00
77319 Sheriff Fees - B Albright
Mar 24/2004 Expense Recovery 00773 287,00
77336 Lexis, Westlaw - Feb
Mar 26/2004 Expense Recovery 00774 2,00
77398 Notary
Mar 31/2004 Expense Recovery 00775 9,50
77720 Facsimilies - March
Mar 31/2004 Expense Recovery 00776 2,31
77766 Postage - March
Mar 31/2004 Expense Recovery 00779 1. 65
78038 Photocopies - March
Apr 5/2004 Franklin County Sheriff 00900 79,10
77617 RET - Refund - Sheriff fees - ck#
11767, 3/31, credit for B Albright
1011289
Apr 27 /2084 Expense Recovery 00787 235,00
78456 West~aw - March
Apr 30/2004 Expense Recovery 00790 13,61
78891 Postage - April
Apr 30/2004 Expense Recovery 00797 100,00
80123 Lexis, Westlaw - April
May 17/2004 Shrager Spivey & Sachs 7724 51.24
78818 trial transcripts - re: B Albright
May 31/2004 Expense Recovery 00795 3,69
79847 Postage - May
Apr ~~/2::;6 Sto~~enberger & :an~==~, ~~? Page 3
Clied ~ec.ger
.r\.L~ DA'I'ES
"Date Received From/Paid To C:JeiI' Ge:1eral BId Trust
En':ry# Explanation Rcptir: ?.cpts Jisbs Fees I:w# Ace Rcpts Disbs Ba:'ance
May 31/2004 Expense Recovery 00796 9,00
80002 Photocopies - May
Jd 31/2004 Expense Recovery 00812 0.74
81518 Postage - July
Jul 31/2004 Expense Recovery 00815 0,60
81700 Photocopies - July
Aug 10/2004 Cu~berland Valley Medical Services 7984 23.22
81397 Medical Records - Brooklyn Albright
Aug 12/2004 Expense Recovery 00814 237,00
81686 Lexis, Westlaw - July
A"Jg 16/2004 Joseph Marino, DO 8012 1300,00
8:854 Outside Professiona: - re: Brooklyn
Albright
Aug 18/2004 Richard P Bonfiglio, MD 8034 3000,00
82069 Outside Professional - re: Brooklyn
Albright
Aug 3:120:)4 Expense Recovery 008:9 ],33
82351 Postage - Aug
Aug 31/2004 Expense Recovery 00821 103,05
82667 Photocopies - Aug
Aug 3'j20D4 Expense Recovery 00824 1. 00
83012 Telephone - Aug
Sep 9/2004 James D Rogers, PhD 8119 1000,00
82647 Outside Professional - retainer re: B
Albright
Sep 2:/2004 David Griffin, MO 8:59 500,00
82972 Outside Professional retainer re:
Brooklyn Albright
Sep 22/2004 James A Greenberg, MD 8167 1000,00
83082 Outside Professional - re: Brooklyn
Albright
Sep 28/2004 Unishippers 8193 23,58
83209 ir.v# 1000529437, cust# UM4 7152.
Sep 30/2004 Expense Recovery 00835 5,50
84691 Facsimilies - Sept
Sep 30/2004 Expense Recovery 00849 5,00
85919 Lexis, Westlaw Sept
Oct 11/2004 Unishippers 8264 17 ,08
83532 invl 1000576214, cust# UM471523
Oct 18/2004 Geoffrey Schnider, MD 8302 350,00
83673 Outside Professional - re: Brooklyn
Albright
Oct 18/2004 Shanna Dishong 8313 200,00
83724 Outside Professional - report re: B
Albright
Oct 27/2004 Shriners Hospitals for Children 8354 32,10
83918 Medical Records Brooklyn Albright
Oct 27/2004 Robert L Irvin 8363 315,00
83953 Court Reporter Fees & Transcripts inv#
1694, re: B Albright
Oct 30/2004 Expense Recovery 00849 300,00
85936 Lexis, WesLaw Sept
Oct 31/2004 Expense Recovery 00833 21.28
84293 Postage - Sept/Oct
Oct 31/2004 Expense Recovery 00834 241. 65
84504 Photocopies - Sept/Oct
Nov 9/2004 HaroIs V Kulman Associates 8044 1500,00
84180 Outside Professional - re: Brooklyn
Albright
Nov 17/2004 James D Rogers, Pr.D 8067 2400,00
84690 Outside Pro:essiocal report re:
Brooklyn Albright
Nov 17/2004 Unishippers 8069 50,60
84751 inv# 1000651392, cust# UM471523
Nov 22/2004 Hughes Albr:ght Foltz & Natale Report 8078 264,20
84879 Court Reporter Fees & Transcripts
inv# 23-2345714, 10/21 depo
Nov 30/2004 Expense Recovery 00844 6,82
85215 Postage - Nov
Nov 30/2004 Expense Recovery 00845 144,00
85476 Photocopies - Nov
Nov 30/2004 Expense Recovery 00846 1.50
85615 Telephone - Nov
Nov 30/2004 Expense Recovery C0850 8,00
86163 Lexis, West::'aw - Nov
Dee 9/2004 Unishippers 8140 32,96
85390 cust# UM471523, inv# 1000726444
Ape ',:/2006
Shc::e~be~ger & J2~~zzi, L~P
Cient Ledger
ALL DATES
--'-------.--- Received From/Paid Che#
Ja.te To General
Entry# Explanation Rcpt# Rcpts Disbs
Jee 21/2004 Geoffrey Schnider, MD 8190 575,00
85897 Outside Professional re: Brooklyn
Albright
Dee 31/2004 Expense Recovery 00851 15,50
86251 Facsimilies - Dee
Jec 31/2004 Expense Recovery J0852 7,49
86427 Postage - Dee
Dee 31/2004 Expense Recovery 00853 5,85
86688 Photocopies - Dee
Dee 31/2004 Expense Recovery 00856 2,50
86945 Telephone - Dec
Dee 31/2004 Expense Recovery 00857 60,00
87084 Lexis, Westlaw - Dee
Jan 11/2005 The UPS Store 5720 10,65
86375 Dee shipping
Jan 31/2005 Expense Recovery 00861 6,36
88022 Postage - Jan
Jan 3l/2COS Expense Recovery 00862 6,45
88156 Photocopies - Jan
Jan 31/2005 Expense Recovery 00872 7,00
89135 Lexis, Westlaw - Jan
Feb 28/2005 Expense Recovery 00869 9,00
88755 Postage - Feb
Feb 28/2005 Expense Recovery 00871 8,40
88955 Photocopies - Feb
Feb 28/2005 Expense Recovery 00875 1. 50
89701 Telephone - Feb
Mar 23/2005 Richard Paul Bonfiglio, MD 8567 1050,00
89547 Outside Professional - re: Brooklyn
Albright
Mar 31/2005 Expense Recovery 00877 0,37
89902 Postage - March
Apr 30/2005 Expense Recovery 00881 15,00
90831 Facsimilies - April
Apr 30/2005 Expense Recovery 00885 0,30
91272 Photocopies - April
May 31/2005 00890 1. 06
91764 Postage - May
May 31/2005 Expense Recovery 00893 5,85
919J9 Photocopies - May
Jun 30/2005 Expense Recovery 00899 2,00
92697 Facsimilies - June
Jun 30/2005 Expense Recovery 00900 3,60
92732 Postage - June
Jun 30/2005 Expense Recovery 00902 1. 80
92957 Photocopies - June
Jul 20/2005 Expense Recovery 00905 190,00
93182 Lexis, Westlaw - June
Jul 31/2005 Expense Recovery 00907 0,45
93599 Photocopies - July
Sep 30/2005 Expense Recovery 00925 4. 69
95330 Postage - Sept
Sep 30/2005 Expense Recovery 00926 15,30
95440 Photocopies - Sept
Sep 30/2005 Expense Reccvery 00927 :,00
95569 Telephone - Sept
Oct 31/2005 Expense Recovery 00932 2,40
96496 Postage - Oct
Oct 31/2005 Sxpense Recovery 00933 5,40
96644 Pho~ocop.:.es - Oct
Nov 30/2005 Shanna Dishong 9514 50,00
97180 Outside Professional - re: B Albright
Dec 6/20C5 Hughes Albright Fo:tz & Natale Report 9537 331. 50
97359 Court Reporter Fees & ~ranscripts
inv# 28450, B Albright 11/22
Dec 6/2005 Expense Recovery 00939 1.50
97362 Facsimilies - Nav
Dee 12/2005 ~enise Cote-Arsenault 9561 500.08
97592 Outside Professional - medical report
letter re: B Albright
Dec 14/2005 Expense Recovery 00943 0,30
97878 Photocopies - Nav
Oee 29/20C5 Fed Ex 9643 33,80
98349 acc:# 1696-1867-4, inv# 3-257-88449
Dec 31/2005 Expense Recovery 00947 21. 00
98607 Faesimilies - Dee
Dec 31/2C05 Expense Recovery 00949 2,22
?age 4
BId Trust
Fees Inv# Acc Rcpts Disbs
Balance
Ap~ :U200E
S~ollenjerge~ & ~anezz:, ~~?
C:e:'.t Ledger
A::":' DfI.TES
Page 5
Jete Received From/Paid To
Entrv#__ Explanation
98760 Postage - Dee
Dec 31/2005 Expense Recovery
98919 Photocopies - Dec
Jec 31/2005 Expense Recovery
99095 Telephone - Dec
Jan 9/2006 Unishippers
98511 inv# 1001785294, cust# UM471523
Feb 2/2006 Expense Recovery
99445 Facsimilies - Jan
Feb 7/2006 Expense Recovery
99545 Postage - Jan
Feb 8/2006 Expense Recovery
99732 Photocopies - Jan
Feb 20/2006 Shriners Hospitals for Children
100312 Medical Records - Brooklyn Albright
Mar 29/2006 Expense Recovery
101254 Postage - Feb
Mar 30/2006 Expense Recovery
101382 Photocopies - Feb
Che# Gene::-al 31d Trust
Rcpt# Rcpts Disbs Fees Inv# Ace Rcpts Disbs
00951 364,20
::953 1.0:
9678 30,26
OJ954 23,00
00955 36,86
00956 53,85
9849 31. 83
00963 0.78
00965 0,30
Bala:'.ce
UNBILLED BILLED I 1- BALANCES ~I
TOTALS CHE + RECOV FEES == TOTA~ DISBS FEES + TAX - RECE:PTS ~ AIR TRUS':'
PERIOD 17713,72 3411,28 0,00 21125.00 0,00 0,00 0,00 o.oc 0,00 0,00
END DATE 17713,72 3411,28 0,00 21125.00 0,00 0,00 0,00 0,00 0,00 0,00
General. Retainer 150,65
UNBILLED I BILLED I 1------ BALANCES ------I
FIRM TOTALS CHE + RECOV FEES TOTAL DISBS + FEES + TAX RECEIPTS ~ AIR TRUST
PERIOD 1771],72 3411,28 0,00 21125,00 0,00 0,00 0,00 0,00 0,00 0,00
END DATE 17713,72 3411,28 0,00 21125,00 8.00 C,OO 0,00 0,00 0,00 0,00
General Retainer 150.65
REPORT SELECTIONS
Report:
Layout Template:
Requested by:
Finished:
Date Range:
Matters:
Clients:
Major Clients:
Responsible Lawyer:
Client Intra Lawyer:
Assigned Lawyer:
Type of Law:
Matters Sort By::
New Page for Each Lawyer:
New Page for Each Matter:
Totals Only:
Consolidate Payments:
No Activity Date:
Select From:
Include Corrected Entries:
Show Check # on Paid Payables:
Ver:
Client Ledger
All
Adam Wolfe
Tuesday, April 11, 2006 at 03:58:42 PM
ALL DATES
011289
All
All
All
All
All
All
Default
No
No
No
No
Dee 31/2199
Active, Inactive Matters
'0
No
7.22a
Firm Totals Only:
Entries Shown - Billed Only:
Entries Shown - Disburse;":'\ents:
Entr:es Shown - Receipts:
Entries Shown - Trust:
Entries Shown Time or Fees:
Working ~awyer:
Incl. Matters with
Incl. Matters with
Show Interest:
Trust Account:
No
No
Yes
Yes
Yes
Yes
No
Retainer Bal: No
Neg Unbld Disb: No
No
All
S~ow Client Address:
No
Show Trus: Summary by AC':OUf.t:
No
-
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~ ~ \.j.
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SHOLLENBERGER & JANUZZI, LLP
2225 Millennium Way
Enola, PA 17025
Telephone Number: (717) 728-3200
Fax Number: (717) 728-3400
Attorne s for Plaintiffs
IN RE: BROOKLYN ALBRIGHT, a minor, by
JILL YAN ALBRIGHT and DENNIS JACK
O'DONNELL, guardians,
Petitioners
IN THE COURT OF COMMON PLEAS
CUMBERLAND COUNTY,
PENNSYLVANIA
NO. 06-2273
CIVIL DIVISION
AMENDED PETITIO
AND NOW, come the Petitioners, BROOKLYN ALBRIGHT, a
minor, by JILL Y AN ALBRIGHT and DENNIS JACK O'DONNELL, her parents
and natural guardians, by and through their attorneys, Shollenberger and
Januzzi, LLP, and do respectfully represent the following:
1. Petitioner, Brooklyn Albright, is a minor, having been born on April 5, 2000
and currently resides with her mother, Jillyan Albright, 6 Hilltop Drive,
Shippensburg, Cumberland County, Pennsylvania, 17257.
2. Petitioner, Jillyan Albright, is the mother and natural guardian of Brooklyn
Albright and is an adult individual currently residing at the aforementioned
address.
3. Petitioner, Dennis JACK O'DONNELL is the father and natural guardian of
Brooklyn Albright and is an adult individual currently residing at 95
Hershey Road, Shippensburg, Cumberland County, Pennsylvania, 17257.
4. Respondent is the United States of America.
5. Petitioner, Brooklyn Albright was born on April 5, 2000. During the birth a
shoulder dystocia was encountered. Delivery was effected with a vacuum
extractor and by use of the McRobert's Maneuver, the application of
suprapubic pressure, and delivery of the posterior shoulder.
6. Petitioner, Brooklyn Albright's birth occurred at Chambersburg Hospital
and the delivery was performed by Dr. Kathleen Ann Garde, an employee
of Keystone Rural Health Center. Valerie Fuller Fulton and Kristine Lively
Helman are registered nurses who assisted in the delivery.
7. Petitioners aver that the delivery deviated from the appropriate obstetrical
standard of care and that the nurses were improperly trained by
Chambersburg Hospital and failed to properly handle the shoulder
dystocia.
8. The Petitioner, Brooklyn Albright, alleged that she suffered injuries
including, but not limited to profound right brachial plexus injury with
multiple nerve root avulsions from the cervical spine.
9. As a result of the above and the injuries sustained therein, Petitioner,
Brooklyn Albright, incurred medical bills totaling $5,145.10. There are no
outstanding medical bills. A copy of a Medical Bills Summary is attached
hereto as Exhibit "A". The Commonwealth of Pennsylvania Department of
Public Welfare has asserted the right of subrogation and reimbursement
with regard to the medical bills. As of December 7,2005, the requested
lien amount is $295.24.
..-
10. Petitioner, Brooklyn Albright, last received medical treatment on January
18,2006 from Dr. Scott H. Kozin, MD at Shriners Hospitals for Children, at
which time Dr Kozin instructed that Brooklyn should continue with home
exercises and should return for an annual visit in one year.
11. Petitioners believe and therefore aver that Brooklyn Albright sustained the
injuries stated above as a result of the negligence of Dr. Kathleen Ann
Garde, Keystone Rural Health Center, Chambersburg Hospital, Valerie
Fuller Fulton, and Kristine Lively Hellman.
12. Suit was originally filed on March 25, 2004 in Franklin County,
Pennsylvania, but was removed to the United States District Court for the
Middle District of Pennsylvania.
13. The United States of America has assumed the Defense for Keystone
Rural Health Center and Dr. Kathleen Ann Garde.
14. With respect to Defendants Chambersburg Hospital, Valerie Fuller Fulton
and Kristine Lively Helman, the parties have not reached a settlement and
the litigation is ongoing.
15. The United States has offered $125,000.00 in settlement of Brooklyn
Albright's claim. In exchange for the aforementioned amount, the United
States of America seeks the signing of "AGREEMENT FOR
COMPROMISE SETTLEMENT AND RELEASE OF FEDERAL TORT
CLAIMS ACT CLAIMS PURSUANT TO 28 U.S.C. 92677." A copy of the
proposed release is attached hereto and incorporated by reference herein
as Exhibit "B".
... ~,
16. Petitioners believe that the above-referenced offer of settlement is fair and
reasonable.
17. The Petitioners have retained the services of the law offices of
Shollenberger and Januzzi, L.P. to represent them and had agreed to pay
a twenty-five (25%) percent contingent fee to said attorneys.
Shollenberger and Januzzi, L.P. has associated with Ralph Mazer, Esq.
and David Perkins, Esq. in the handling of this claim. A copy of the
Contingent Fee Agreement between the Petitioners and their counsel is
attached hereto, incorporated by reference herein and marked as Exhibit
"CU.
18. The Petitioners have further agreed to payout of their share of the
recovery any and all costs incurred or advanced on their behalf. The
amount of the costs that were incurred and advanced on Petitioner's
behalf to date in this matter total $20,974.35. Upon request of this
Honorable Court the costs have been reduced by $3835.10 and the law
firm of Shollenberger & Januzzi will be reimbursed $17,139.25 of the
forwarded costs. An itemization of all costs is attached hereto,
incorporated by reference herein and marked as Exhibit "D".
19. Petitioners request that the Court approve the compromise settlement set
forth above and order that the proceeds be distributed as follows:
Attorneys Fees (25%)
Costs Reimbursement to Shollenberger and Januzzi, LLP
$31,250.00
$ 17,139.25
. .
Department of Public Welfare Lien
$ 295.24
Balance to Brooklyn Albright
$ 76,315.51
20. Petitioner, Brooklyn Albright, by Jillyan Albright and Dennis 0' Donnell her
parents and natural guardians, requests that the funds to be distributed for
the benefit of Brooklyn Albright be deposited in one or more savings
accounts in the name of Brooklyn Albright 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 anyone savings institution should not exceed the amount to
which accounts are thus insured.
21. Petitioner, Brooklyn Albright, by Jillyan Albright and Dennis 0' Donnell her
parents and natural guardians, requests that upon approval of the
proposed compromised settlement and receipt of the proceeds thereof,
they be authorized to execute the Release attached to this Petition.
WHEREFORE, the Petitioners Brooklyn Albright, Jillyan Albright and Dennis 0'
Donnell her parents and natural guardians, request this Honorable Court approve
the Compromise Settlement and Distribution of the Proceeds or in the alternative
to schedule a hearing on this Petition.
Respectfully submitted,
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IN RE: Brooklyn Albright, a minor,
By Jillyan Albright and
Dennis Jack O'Donnell, guardians,
IN THE COURT OF COMMON PLEAS OF
CUMBERLAND COUNTY, PENNSYLVANIA
: 06-2273 Civil
ORDER OF COURT
1\..
AND NOW, this 1.5 day of May, 2006, upon consideration of the within Petition,
Plaintiffs' request for approval of a Compromise Settlement in the above captioned
matter is approved,
Petitioners are permitted to execute the Release attached to this Petition as
"Exhibit B",
Plaintiffs' contingent fee agreement with counsel is approved and Plaintiffs'
counsel shall collect fees, costs and expenses set forth in Plaintiffs' Petition and the
exhibits attached thereto from the proceeds of this settlement. The recovery of costs
shall be limited to $17,139,25 as indicated in the Plaintiff's Amended Petition,
The Plaintiff shall place in escrow $295,24 to pay the outstanding lien asserted
by the Commonwealth of Pennsylvania Department of Public Welfare,
The balance of the proceeds shall be deposited in the name of Brooklyn Albright
in one or more savings accounts in 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 anyone savings institution shall not exceed the
amount to which accounts are thus insured,
'1-.. .
No withdrawal shall be made from any such account until Brooklyn Albright shall
attain her majority, except as authorized by further Order of the Court, Proof of the
deposit, along with a signature card for each account, shall be promptly filed of record
with the Court,
By the Court,
~-L
M, L. Ebert, Jr"
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