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Home My WebLink About06-3977 Johnson, Duffie, Stewart & Weidner By: Jefferson J. Shipman, Esquire LD. No. 51785 30 I Market Street P. O. Box 109 Lemoyne, Pennsylvania 17043-0109 (717) 761-4540 SEAN D. TAYLOR and KATHRYN B. : IN THE COURT OF COMMO PLEAS OF TAYLOR, as parents and natural guardians: CUMBERLAND COUNTY, PE NSYLVANIA of NATHANIEL TAYLOR, a minor, 4228 East Tether Trail Phoenix, AZ. 85050 CIVIL ACTION - LAW I d(.)~tT~ Plaintiffs v. NO. OL - j tJ71 A. CHRISTIAN LAFFERTY and ALICIA M. MCPOYLE 27 West Simpson Street Mechanicsburg, PA 17055 Defendants i : AMICABLE ACTION IN TRES~ASS I ! PETITION FOR APPROVAL OF MINOR'S SETTLEMENT AGRE MENT AND NOW, comes A. Christian Lafferty and Alicia M. McPoyle who fil this Petition for Court Approval of Minors' Settlement Agreement, by respectfully stating the f 1I0wing: 1. A. Christian Lafferty and Alicia M. Mcpoyle reside at the addre s on 27 West Simpson Street, Mechanicsburg, PA 17055. 2. Sean D. Taylor and Kathryn B. Taylor are the parents and natujal guardians of Nathaniel Taylor, a minor, and formerly resided at 7 South George Street, Me hanicsburg, PA , 17055. 3. Sean D. Taylor and Kathryn B. Taylor, the parents and natural guardians of Nathaniel Taylor, a minor, currently reside at 4228 East Tether Trail, Phoeni~, AZ. 85050. I 4. Nathaniel Taylor is currently age 8. I I 5. On June 6, 2005, Nathaniel Taylor was on the property of A. dhristian Lafferty and Alicia N. Mcpoyle visiting with their son, when the property owners' dog it Nathaniel Taylor. 6. This bite required medical attention to include seventeen stitc es to Nathaniel 7. Currently, a total of $353.84 has been paid by A. Christian La erty's insurance Taylor's arm. company, the Erie Insurance Group, for medical expenses incurred by Natha iel Taylor. 8. Nathaniel Taylor's medical treatment is now complete. 9. Kathryn B. Taylor has negotiated a settlement of her child's cl 1m with the Erie 10. It has been agreed that Nathaniel Taylor will receive a payme t of $10,000.00, Insurance Group. which his parents have requested be placed in an already existing account fo the minor with Solomon, Smith & Barney. However, if the Court prefers this amount can be laced in a federally insured account for the minor. 11. It is believed that the proposed settlement is in the best interes s of the child, Nathaniel Taylor. WHEREFORE, it is respectfully requested that this Honorable Court ~pprove the settlement stated in this Petition. i i Respectfully submitted, I JOHNSON, DUFFIE, STEWART[ & WEIDNER ! DATE: 7/11 Ie>'- Je erson J. Shipman, Es ire I.D. #: 51785 301 Market Street Lemoyne, PA 17043-01 9 Attorneys for Erie Insura ce Group VERIFICATION We, Sean D. Taylor and Kathryn B. Taylor, as parents and natlilral guardians of Nathaniel Taylor, a minor, verify that all of the foregoing in the Petition for A~proval of Minor's Settlement Agreement are true and accurate to the best of our knowledge. Furthermore, we verify that this Settlement Agreement is in the best interests of our son, Nathal1iel Taylor. t.~ ~.~ ~;;L~ ~fv;0 :277797 CERTIFICATE OF SERVICE I HEREBY CERTIFY that I served a true and correct copy of the foregoing Petition to Approve the Minors' Settleme Agreement upon all parties or counsel of record by depositing a copy of same in tl)f; Unite ates Mail at Lemoyne, Pennsylvania, with fiirst-class postage prepaid on the II ~ay 0 , 2006, addressed to the following: Sean D. Taylor and Kathryn B. Taylor 4228 East Tether Trail Phoenix, AZ 85050 DATE: JOHNSON, DUFFIE, STEWART & WEIDNER Jeff rson J. Shipman, Esq ire 1.0. #: 51785 301 Market Street Lemoyne, PA 17043-01091 Attorneys for Erie Insuran~ Group , ~ 4g. r--."" 7J ~ lrt (', ,((;j \l. U1 \ . - CI1 ..0 --- - w () i<" ~ V'\ -J ~ ~ ~ - - I" "..0 ~ r - ~. -.l... { Johnson, Duffie, Stewart & Weidner By: Jefferson J. Shipman, Esquire I.D. No. 51785 301 Market Street P. O. Box 109 Lemoyne, Pennsylvania 17043-0109 (717) 761-4540 SEAN D. TAYLOR and KATHRYN B. : IN THE COURT OF COMMON PLEAS OF TAYLOR, as parents and natural guardians: CUMBERLAND COUNTY, PENNSYLVANIA of NATHANIEL TAYLOR, a minor, 4228 East Tether Trail Phoenix, AZ 85050 : CIVIL ACTION - LAW Plaintiffs v. A. CHRISTIAN LAFFERTY and ALICIA M. MCPOYLE 27 West Simpson Street Mechanicsburg, PA 17055 Defendants NO. Ot.. - J977 (!toiL 7-~ : AMICABLE ACTION IN TRESPASS ORDER AND NOW, thisd ~y Of~006, upon consideration of the Petition to Approve the Minors' Settlement Agreement, it is hereby ordered that a hearing is scheduled for 71iJ tA '/ "'U~. t/- ,2006,at .3:00 /'M., in Courtroom No..!..toconsiderthePetition. J :277670 J. '. .':::\~n8 ~" "I i )['1 I:::, I -'.,[",1" Ij"",[I] ~'" :~, . I \. 'j _ '" ~ ~:r\ -~ - > . . Johnson, Duffie, Stewart & Weidner By: Jefferson J. Shipman, Esquire 1.0. No. 51785 301 Mar1<et Street P. O. Box 109 Lemoyne, Pennsylvania 17043-0109 (717) 761-4540 IN THE COURT OF OMMON PLEAS OF CUMBERLAND COU TY, PENNSYLVANIA SEAN D. TAYLOR and KATHRYN B. TAYLOR, as parents and natural guardians: of NATHANIEL TAYLOR, a Minor, Plaintiffs v. NO. 06-3977 CIVIL T RM A. CHRISTIAN LAFFERTY and ALICIA M. McPOYLE, Defendants : AMICABLE ACTION N TRESPASS ORDER AND NOW, this I 0 ~ day of ~ ,2 06, upon consideration of the Petition to Approve the Minor Settlement Agreement, and after onducting a hearing on August 4, 2006 and in finding that the proposed settlement is in the est interest of the minor child, it is hereby ORDERED that the Petition is GRANTED. Findin that payment for medical expenses has been made by Erie Insurance Company, insurer of th Defendants, the settlement proceeds shall be distributed as follows: a. The Minor, Nathaniel Taylor, will receive a lump sum payment of $10,000.00, which will be placed on his behalf by his parents an natural guardians in an account in the name of the Minor in a bank, loan ass ciation, credit union, or etc. which is insured by a Federal governmental age cy. . , . . b. No withdrawal can be made from this account until th Minor attains majority, except as authorized by an Order of this court. c. Proof of deposit in a federally insured account shall promptly filed of record. :280964 22740-2104 cj- //-0(, ~ EDWARD E. GUIDO, . ~ ~ VINV/\lASNN3d I ",If)ry\ ('1~.['-,(::.(:;OI^'no I\J.J' '...),,' . I., ".-,'~l~i 80 :Z Wd II 5ilVSOOZ llil/10NOHIOCld 3Hl :10 3ClI:!:l(}{Bll:l Johnson, Duffie, Stewart & Weidner By: Jefferson J. Shipman, Esquire I.D. No. 51785 301 Marl<et Street P. O. Box 109 Lemoyne, Pennsylvania 17043-0109 (717) 761-4540 Attorneys for Defendants SEAN D. TAYLOR and KATHRYN B. : IN THE COURT OF COMMON PLEAS OF TAYLOR, as parents and natural guardians: CUMBERLAND COUNTY, PENNSYLVANIA of NATHANIEL TAYLOR, a Minor, Plaintiffs : CIVIL ACTION - LAW v. : NO. 06-3977 CIVIL TERM A. CHRISTIAN LAFFERTY and ALICIA M. McPOYLE, Defendants : AMICABLE ACTION IN TRESPASS PRAECIPE TO THE PROTHONOTARY OF CUMBERLAND COUNTY: Kindly marl< the docket settled and discontinued with prejudice in the above-captioned matter. , DUFFIE, STEWART & WEIDNER B: Sean D. Taylor, as pare and natural guardian of Nathaniel Taylor, a minor fferson J. Shipman, Esquire ttorney I.D. No. 51785 01 Market Street P.O. Box 109 Lemoyne, PA 17043-0109 Telephone (717) 761-4540 Attorneys for Defendants DATE f/ad()@ ('") ~,tf rnr' ~i:;r (Jj',: -< C:2"{:- ::';::, 2::_, $~~~: ~ "" = co;) "" :>-~ c:: ~ N \.0 -0 ::R:: w o -.J o -.., :t n1:D r- Clm :00 ()(l ~'i-j je:"; f5:I) ''''wC) Om -I $ -< , Johnson, Duffie, Stewart & Weidner By: Jefferson J. Shipman, Esquire I.D. No. 51785 301 Market Street P. O. Box 109 Lemoyne, Pennsylvania 17043-0109 (717) 761-4540 Attorneys for Defendants SEAN D. TAYLOR and KATHRYN B. : IN THE COURT OF COMMON PLEAS OF TAYLOR, as parents and natural guardians: CUMBERLAND COUNTY, PENNSYLVANIA of NATHANIEL TAYLOR, a Minor, Plaintiffs : CIVIL ACTION - LAW v. NO. 06-3977 CIVIL TERM A. CHRISTIAN LAFFERTY and ALICIA M. McPOYLE, Defendants : AMICABLE ACTION IN TRESPASS PROOF OF DEPOSIT IN MINOR'S SETTLEMENT Per Judge Guido's Order dated August 10, 2006 in the above referenced matter, please file the enclosed as proof of that the settlement proceeds have been deposited in the minor's trust account with Smith Barney. JOHNSON, DUFFIE, STEWART & WEIDNER By: ~~d ~ ~er, EsqUIre Attorney I.D. No. 200997 301 Market Street P.O. Box 109 Lemoyne, PA 17043-0109 Telephone (717) 761-4540 Attorneys for Defendants DATE:Se~ember20,2006 ~D-OOC.17 -L Your Broker/Dealer is Confirmation ~ cltlgroUpJ SMITHR\RNEY CITIGROUP GLOBAL MKTS INC. P.O. BOX 12057 11 N 3RD ST-2ND FL HARRISBURG PA 17101 Account Number: 724-12902-1-7 -035 Financial Advisor: FRED PEGGS 717-780-1778 Page 1 of 1 1111I111111111111I1I1111I11111II111II111I11I11111111111I111I11 SEAN D. TAYLOR ACF #610 NATHANIEL J. TAYLOR U1PA/UTMA 7 SOUTH GEORGE STREET MECHANICSBURG PA 17055-3714 Summary For Settlement Date 09/06/2006 Total Purchases $ 10,000.00 Net Amount $ 10,000.00 Debit You Bought 10,000 at a price of 100 BANK HAPOALlM B.M. . NY .CERTIFICATE OF DEPOSIT DTD 09/06/06 INT: MATURITY 5.1000% DUE 03/0612007 PRINCIPAL AMT $10000.00 FDIC. INSURANCE COVERS $100,000 ($250,000 FOR CERTAIN ~ETIREMENT ACCOUNTS) PRINCIPAL & INTEREST COMBINED, PER DEPOSITOR, PER INSTITUTION, FOR ALL DEPOSITS HELD IN THE SAME INSURABLE CAPACITY. FULL PRICE IS 100.00000000 Trade Date: 08/28/2006 Market: Over-The-Counter Gross Amount Amount Settlement Date $ 10,000.00 $ 10,000.00 09/06/2006 CUSIP#: 083997-5Z-5 Security#: 5408293 Solicited Order Cash Acct. Ref #: 325045 HOLD SECURITIES We acted as principal in this transaction. Citigroup Global Markets Inc., member NYSE, NASDAQ and other principal exchanges. Smith Barney is a division and service mark of Citigroup Global Markets Inc. and its affiliates and is used and registered throughout the world. CITIGROUP and the Umbrella Device are trademarks and service marks of Citicorp or its affiliates and are used and registered throughout the world. Citigroup Global Markets Inc. is a member of the Securities Investor Protection Corporation (SIPC). As a reminder, payment for securities purchased or delivery of securities sold must be deposited with us by the Settlement Date. See reverse for further details. Keep this document for your records. Thank you for doing business with us. 08/2812006 BD-000717-L -"" -0 ~ c..,.) ., ~ ~~ --aq ~q :t.:D ~t~ ~ ~ - c.J' <a "'i> -00;) f")\.{.1..\, <--:-/<J<_ 'Z.~ ~].: ::<: '.<:c r:~ c \t~- z- :2 ~ ~ ~ """0 r-> -