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HomeMy WebLinkAbout02-2979IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA No. Civil Action - (X) Law ( ) Equity TERENCE G. SMITH, SR. and PATRICIA SMITH, Parents and Natural Guardians of TERENCE G. SMITH, JR., a Minor, 3922 Emilfidge Drive Mechanicsburg, PA 17050 Plaintiffs : GEORGE E. ROBBINS and : BONITA L. ROBBINS : 914 Shiremont Drive : Mechanicsburg, PA 17050 : EUGENE WRONA : 1021 North 10~ Street : Whitehall, PA 18052 Defendants PRAECIPE FOR WRIT OF SUMMONS TO TNE PROTHONOTARY O'F CUMBERLAND COUNTY: Please issue a Writ of Summons in the above-captioned action. X Writ of Summons shall be issued and forwarded to (X)Attomey ( ) Sheriff John A. Statler, Esquire Goldber8~ Katzman & Shipman, P.C. 320 Market Stree{ P. O. Box 1268 Harrisburg, PA 17108-1268 Telephone: (717) 234-4161 Attorney I.D. No. 43812 Signatmn~f A~ o~0'm ey~ Date: ~_~ WRIT OF SUMMONS TO THE ABOVE-NAMED DEFENDANTS: YOU ARE NOTIFIED THAT THE ABOVE-NAMED PLAINTIFFS HAVE COMMENCED AN ACTION AGAINST YOU. Prothonotavj Deputy ( ) Cheek hare if reverse is used for additional information 80948.1 John A. Staffer, Esquire Attorney I. D. No. 431112 GOLDBERG, KATZMAN & SltlFMAN, P.C. 320 Market Street P.O. Box 1268 Iaatrrisburg, PA 17108-1268 Telephone: (717) 234-4161 Attorney for Plaintiffs TERENCE G. SMITH, SR. and PATRICIA SMITH, Parents and Natural Guardians of TERENCE G. SMITH, JR., a Minor, Plaintiffs V. GEORGE E ROBBINS, BONITA L. ROBBINS and EUGENE WRONA, Defendants : IN THE COURT OF COMMON PLEAS · CUMBERLAND COUNTY, PENNSYLVANIA CIVIL ACTION - LAW NO. 02-2979 CIVIL TERM PETmON FOR COURT APPROVAL OF MINOR'S SETTLEMENT AND NOW, come the Plaimiffs, Terence G. Smith, Sr. and Patricia Smith, parents and natural guardians of Terence G. Smith, Jr., a IVfmor, by their attorneys, Goldberg, Katzanan and Shipman, P.C., who petition this Honorable Court to approve a proposed minor's settlement in this case based on the following: 1. Terence G. Smith, Sr. and Patricia Smith are adult individuals and parents and natural guardians of Terence G. Smith, Jr. 2. Terence G. Smith, Jr. is currently 17 years old. His date of birth is December 14, 1984. 3. On June 2, 2001, Terence G. Smith, Jr. was attacked and bitten in the face by a German Shepherd dog owned by Defendants George E. Robbins _and Bonita L. Robbins. The dog was being walked by Defendant Eugene Wrona at the time of the incident. 4. At the time of the incident, George E. Robbins and Bonita L. Robbins were insured by Nationwide Insurance Company. Nationwide has offered $42,500.00 to settle this case. 5. At the time of the incident, Eugene Wrona was insured by Donegal Insurance Company. Donegal has offered $12,500.00 to settle this case. 6. Plaintiffs believe that the combined settlement offers of $55,000.00 is fair and reasonable under the circumstances. 7. Terence G. Smith, Jr. received medical and surgical treatment from Richard A. deRamon, M.D., a local plastic surgeon. A copy of Dr. deRamon's report of October 31, 2001 is attached hereto as Exhibit "A." 8. Terence G. Smith, Jr. achieved an excellent result from his medical treatment and is not expected to require any treatment in the future. 9. From the gross settlement proceeds of $55,000.00, Plaintiffs request this Honorable Court to approve payment orS11,000.00 to Goldberg, Katzman andShipman, P.C. in accordance with the Contingent Fee Agreement attached hereto as Exhibit "B." 10. Plaintiffs also request approval of reimbursement of costs advanced by Goldberg, Katzman and Shipman, P.C. in the amount of $462.87. An itemization of these advanced costs is attached hereto as Exhibit "C." 11. After payment of attorneys fees and costs the net settlement proceeds payable to Terence G. Smith, Jr. amount to $43,537.13. 12. Plaintiffs request this Honorable Court to approve the purchase of a structured settlement annuity for Terence G. Smith, Jr. through Hartford Life Insurance Company for $40,000.00. This company is rated by A. M. Best as A+ (superior), Class Size XV. A copy of the proposed structured settlement quote is attached hereto as Exhibit "D." That annuity will guarantee the following payments to Terence G. Smith, Jr. on the following dates: December 14, 2002 December 14, 2003 December 14, 2004 December 14, 2005 (Age 18) $10,548.00 (Age 19) $10,548.00 (Age 20) $10,548.00 (Age 21) $10,548.00 Total $42,192.00 13. The remaining $3,537.13 will be placed in a restricted bank account in the name of Terence G. Smith, Jr. with an appropriate notation on the account that no_withdrawal may be made of principal or interest until Terence G. Smith, Jr. reaches age 18 or unless by other order of this Court. WItEREFORE, Plaintiffs request this Honorable Court to approve this minors settlement in accordance with the terms outlined in this Petition. DATE: 80944.1 By: Respectfully submitted, GOLDBERG, KATZMAN & SI~IPMAN, P.C. Attorney I. D. No. 43812 320 Market Street P. O. Box 1268 Harrisburg, PA 17108-1268 Telephone: (717) 234-4161 Attorneys for Plaintiffs 4 VERIFICATION AND CONCURRENCE WE, TERENCE G. SMITH, SR. and PATRICIA SMITH, hereby verify that we have read the foregoing Petition for Court Approval of Minor's Settlement and concur in the terms outlined in the Petition. DATE: TERENCE G. SMITH, SR. DATE: PATRICIA SMITH m PLASTIC SURGERY CENTER, LTD The Center for Cosmetic Surgery Grandview Corporate Place 205 Grandview Avenue Camp Hill, Pennsylvania 17011 October 31, 2001 *JAMES A. YATES, M.D., F.A.C.S. RICHARD A. DE RAMON, M.D. John A. Statler Goldberg, Katzman & Shipman, P.C. 320 Market Street P.O.' Box 1268 Harrisburg, PA 17108-1268 RE: Terence G. Smith, Jr. Dear Mr. Statler: The following is a narrative medical summary regarding Mr. Smith. Mr. Smith was attacked by a dog on June 2, 2001, where he suffered multiple complex injuries to the upper and lower lip. He suffered a i cm. dorsal nasal laceration and extensive upper and lower lip lacerations involving both the red portion of the lips and the outer skin-bearing lip. His obicularis oris was transected in both the upper and lower lips. The laceration crossed the vermilion borders on both upper and lower lip and extended superiorly up into the left nasal sill. He had a second upper lip laceration which involved only the red portion of the lip. The lower lip had also two lacerations; the second extending obliquely and partially transecting the obicularis oris to about a third of its thickness. This required a 7.5 cm. complex closure and a I cm. simple closure. During this repair, the obicularis oris muscle had to be re-approximated; and wound edges had to be primarily debrided to obtain optimal results and minimize the need for future revision. Mr. Smith had a good result fro'm his repair. Plastic and Reconstructive Surgery Cosmetic Surgery Maxillo-Facial Surgery Hand Surgery Certified by the American Board of Plastic Surgery Phone (717) 763-7814 FAJ((717) 763-4918- WEB PAGE: http://www, plasticsurgery, org/MD/JAY5PLAS.htm Terence Smith Jr. Page 2 He was seen on June 8, 2001, at which time his sutures were removed. At that time, the obicularis muscle function was weak in the left upper lip, but present, and was predicted to improve with time. He was started on scar massage at two weeks post-op. He was seen again on July 9th, at which time he complained of tingling of the upper lip of an intermittent nature. At that time, his lip muscle function appeared to be normal. He was seen again on October 24, 2001; his complaint of numbness of the lip had improved, but he did not have normal sensation in the left upper or lower lip. Hi-s scars had faded nicely. There was no problems with vermillion border step-off and has had an excellent outcome. He does continue to have numbness. This is related to the sensory nerves which were severed at the time of the incident. This is likely to be permanent. His sensation may improve with time, and it may take six to twelve months to fully appreciate the extent of, and/or permanence of, this numbness. His scars will continue to mature. They also will take a year to a year and a half to fully mature. The lumpiness he feels in his lips is related to scar thickness. This should improve with time but may also be permanent. At this time, I cannot tell how much improvement he will have over the next year. He will continue on scar massage and will follow up on a PRN basis. If Terence is unhappy with the results of his lip repair, he understands he needs to wait at least a year and a half from the time of injury to consider scar revision because the scar maturation process is dynamic, and he will likely continue to have improvement over the next year. It is my impression that he will not Kequire scar revision and has had excellent results from his primary repair.' If I can be of any further assistance, please do not hesitate to call or write. Sincerely, /~ Richard de Ramon, M.D. POWER OF ATTORNEY AND FEE ARRANGEMENT THIS AGREEMENT, made this i~ttl day of ,3 t~t~¢ ,2001, by and between TERENCE G. SMITH, SR. and PATRICIA SMITH, of Mechanicsburg, Pennsylvania, individually and as parents and natural guardians of Terence G. Smith, Jr.~-.a min~r, hereinafter referred to as "client," and GOLDBERG, KATZMAN & SHIPMAN, P.C., of Harrisburg, Pennsylvania, hereinafter referred to as "attorneys," WITNESSETH: Client hereby retains attorneys to represent, appear and act for client as attorneys for the purpose of bringing such proceedings as may be necessary to prosecute the causes of action involved in regard to a dog bite incident that occurred on or about June 2, 2001 on Willcliff Drive, Mechanicsburg, Pennsylvania, involving Terence G. Smith, Jr., a Minor. Client empowers attorneys to file such legal action as may be advisable in their judgment. Client shall pay attorneys, as attorneys' fees for such representation, a sum equal to 20 percent of whatever may be recovered whether the claim is settled without suit; or to pay attorneys a sum equal to 20 percent of whatever may be recovered from settlement after suit has been commenced or arbitration demanded but before trial or arbitration; or to pay attorneys a sum equal to 20 percent of whatever may be recovered following the initiation of trial or arbitration or resulting fi'om a trial verdict or arbitration award before any preparation for appeal resulting from a trial verdict or before retrial of such cause, or to pay said attorneys a sum equal to 20 percent of whatever may be recovered at a time thereafter on appeal or retrial. If settlement of this case is made by a structured settlement, attorney's fees will be figured on the basis of respective percentage charged for legal fee of the present cash value of the settlement as determined by actuarial experts. Further, the attorney's fees may be paid out of the initial cash lump sum. ~/ ~ '~' ~lease initial here] Client further agrees that, in addition to the attorneys' fees, all costs and expenses, including expert witness' fees, filing fees, depositions costs, etc., incurred in investigation, preparing or litigating these claims be made from the gross proceeds of recovery, if any. It is understood that the attorney's fees shall be calculated and paid from the gross proceeds of recovery prior to calculation and payment of all costs and expenses. All disputes regarding attorney's services or fees shall be submitted to arbitration in accordance with the Pennsylvania Unifo,m Arbitration Act of 1980. Attorneys shall not receive any fee for their services in the event there is no recovery of any sums by settlement or verdict, excepting the above-mentioned costs and expenses which shall then be paid to attorneys by the client. Client empowers attorneys with full power to make any inquiries, to negotiate, bring, conduct, prosecute, sue or compromise and settle with client's approval, any action or suit, and to exercise and endorse any papers, checks, or orders on client's behalf in connection therewith. Attorneys shall be entitled to their full contingent share of any settlement offer, verdict or judgment on the claim for which they are hereby retained, even though client discharges them or obtains a substitute attorney before the claim is finally resolved or concluded. Client agrees that she shall not settle or compromise the claim without the written consent of attorneys. It is understood and agreed that if, at any time, in the sole judgment of Goldberg, Katzman & Shipman, P.C. the Defendant shall become execution proof, or if there is no likelihood of recovery on any verdict which can be obtained, Goldberg, Katzman & Shipman, P.C. shall have the right to withdraw from the case without making any charge for services rendered up to that time upon ten (10) days written notice by certified mail, to the undersigned. In the event of such withdraw, client agrees to promptly pay to attorneys all costs and:expens-~s which have been paid or advanced by said attorneys. If the client shall elect not to continue to pursue the claims for which attorneys have been retained and/or should the client fail to fully cooperate with the attorney's efforts in any and all matters concerning such claims, or otherwise terminate the services of the attorneys, the attorneys shall be entitled to immediately receive the greater of the following amounts: A. A sum equal to the number of hours spent on behalf of client's interests in such civil action times the hourly rate of $150.00 per hour, plus any and all costs which were advanced or otherwise outstanding; or, B. The contingent fee percentage which would be applicable to any offer of settlement, compromise of claim, or judgment obtained, as per the above contingent fee provisions. IN WITNESS WHEREOF, attorneys and client have set their hands and seals the day and year aforesaid. GOLDBERG, KATZMAN & SHIPMAN, P.C. DATE: ~ / Icl / t~ / DATE: 64354.1 I TERENCE G. SMITH, SR. P~TR~CIA SMITI~- ' ' 60LDBER6, KATZHAN & SHIPIIAN, P.C. ~20 HARKET STREET P.O. BOX 1268 HARRISBURG, PA 1710B-126B 717-234-4161 Fed lO No: 25-2179953 June 19, 2002 Billed through 06/19/02 Bill nuaber 77113-00001-003 JAS Terry Seith $922 Eeilridge Drive Hechanicsburg~ PR 17050 (Robbins~ EdNard & Bonnie) D/L: 6-2-01 S/L: &-1-03 DISBURSEItENTS 06/14/0! Copy Expense 07/24/01 Hedica] Reports/Records 07/26/0! Copy Expense 08/03/01 Copy Expense 11/06/01 Hedical Reports/Records 01/15102 Hedical Reports/Records 06/19/02 Filin9 Fees Total disburselents for this latter S[LLINS SUHHARY TOTAL OISSURSEHENTS TOTAL CHAR6ES FOR THIS BILL 2.12 36.05 2.00 2.20 250.00 125.00 45.50 $ 462.87 $ 462.87 $ 462.87 billing tieekeeper John A. Statler date of last bill date of last reiinder last bill through date bill type code C-Ol action to be taken O=hold entire bill l=a/r reNinder 2=bill exps, hold fees current 50 days 60 days 90 days 120 days hilling frequency ~-12 last payient hilling realization 732-6660 matter 00001 721 061t4/01 807 07/24/01 721 07/26/0t 721 08/03/01 807 11/06/01 807 01/15102 804 06/19/02 721 807 3:SUllary fees and exp 4=bill fees and exp 5=sueeary fees/detail e ,00 .00 .00 .00 .00 O% 2.12 2.00 2.20 250.00 125.00 462.87 6.32 45.50 411.05 462.87 462.87 Financial Settlement Services June 19, 2002 TO: RE: John Statler, Esq. Terrance Smith, Jr. 5837 MP 206227 0{}/02/01 01 The following plans are effective until 06/26/2002. These plans are from Hartford Life Insurance Company. This Company is rated by A.M. Best as A+ (Superior), Class Size XV. This Hartford case would include a Qualified Assignment to Hartford Comprehensive Employee Benefit Service Company (Hartford - CEBSCO), which will be the owner of the policy. Financial Settlement Services will request an Evidence of Guarantee from Hartford Life Insurance Company, guaranteeing the obligations assigned to Harfford-CEBSCO. This guarantee is issued with the policy and is not part of the Release and Qualified Assignment. . If you need fine tuning of these plans, or I can help in any way, plea;e call. Thank You / Today's Date: Name: Date of Birth: June 19, 2002 Terrance Smith, Jr. December 14, 1984 Plan #1 Annual Benefits: $10,548 per year. First payment is 12/14/2002 (age 18). Last payment is 12/14/2005 (age 21). This is 4 guaranteed annual payments, and then payments stop. TOTAL STRUCTURE AMOUNT: Cash At Time Of Settlement: TOTAL PLAN AMOUNT: Guaranteed Amount: $42,192 Male 'FIT Age: 17 Cost: $40,000 $42 19.2 $40,000 $2,500 $2,500 $44,692 .... $42,500 'I This proposal is effective through JUNE 26, 2002. This is the date that the funds for } the structure must be at the annuity company or this proposal will expire. This is an illustration, not a contract. Financial Settlement Services a di~h'i.~ of Natlor,~ld~ F'm~d~l I~rfitutlo. Diro'i~u~or~ A~e~cy, l~c, a~d ~ affiliatez. DATE: As of May 2002 TO: Financial Settlement Services (FSS) Clients SUBJECT: Hartford Ratings The following is a summary of the current ratings for Hartford Life Insurance Company. Hartford is a highly rated company by the vadous rating organizations. This Hartford case would include a Qualified Assignment to Hartford Comprehensive Employee Benefit Service Company (Hartford - CEBSCO). Financial Settlement Services will request an Evidence of Guarantee from Hartford Life Insurance Company, guaranteeing the obligations assigned to Hartford - CEBSCO. This guarantee is issued with the policy and is not part of the Release and Qualified Assignment. Hartford Life Insurance Company ratings are as follows: ,Rating Organization A.M. Best Rating & Size Moody's Standard & Poor's Fitch Hartford Life (provider and guarantor) A+ (XV) . Aa3 AA+ Should you need any additional information, please call FSS (800) 993-9931. FINANC~,L ~a,j. ~ ~-tM~A'T ~ga1~cF, s 400 WEb"I'WO~I~ DlU'V~* WAURAU. WI $4401.1T. O5 PRONE (~00) gg3-9931 - PAX (~J0)*16~Ji67 CERTIFICATE OF SERVICE I HEREBY CERTIFY that I served a true and correct copy of the foregoing document upon all parties or counsel of record by depositing a copy of same in the United States Mail at Harrisburg, Pennsylvania, with first-class postage prepaid on the ~ ~---~x day of 4~o~ ,2002, addressed to the following: George E. and Bonita L. Robbins 914 Shiremont Drive Mechanicsburg, PA 17050 Mr. Eugene Wrona 1021 North 10~ Street Whitehall, PA 18052 By Respectfully submitted, GOLDBERG, KATZMAN & SHIPMAN, P.C. Attorney I. D. No. 43812 320 Market Street P.O. Box 1268 Harrisburg, PA 17108-1268 Telephone: (717) 234-4161 Attorneys for Plaintiffs TERENCE G. SMITH, SR. and PATRICIA SMITH, Parents and Natural Guardians of TERENCE G. SMITH, JR., a Minor, Plaimiffs GEORGE E ROBBINS, BONITA L. ROBBINS and EUGENE WRONA, Defendants : IN THE COURT OF COMMON PLEAS · CLrMBERLAND COUNTY, PENNSYLVANIA : CIVIL ACTION - LAW · NO. 02-2979 CIVIL TERM ORDER AND NOW, this ___~_~ day of_~ ,2002, upon consideration of the Petition for Court Approval ofl~finor's Settlement in this case, it is hereby ORDERED that the proposed Minors Settlement is APPROVED in accordance with the terms outlined in the Petition. 0 t :q !44 ~- "i,ql~ ~:[) ~/.-!¥/rrr '; ' _ ,"' TERENCE G. SMITH, SR. and PATRICIA SMITH, Parents and Natural Guardians of TERENCE G. SMITH, JR., a Minor, Plaintiffs GEORGE E ROBBINS, BONITA L. ROBBINS and EUGENE WRONA, Defendants · IN THE COURT OF COMMON PLEAS · CUMBERLAND COUNTY, PENNSYLVANIA CIVIL ACTION - LAW · NO. 02-2979 CIVIL TERM ORDER AND NOW, this / ~ day of ~ ,2002, the Order of July 2, 2002 is amended to permit Terence G. Smith, Jr. to use the $3,537.13 in settlement proceeds as partial payment for his tuition, room and board and fees at Shippensburg University for the Fall 2002 semester. Revenue Accounting Office Old Main Room 100 Shippensburg University 1871 Old Main Drive Shippensburg, Pa. 17257-2299 (717) 477-1211 TERENCE SMITH 3922 EMILRIDGE DRIVE MECHANICSBURG PA 17050 I IIIIII IIIII IIIII IIIII IIIII IIIII IIIII IIIII III!1 IIII IIII *620186745* *200260 U * *04108.00* Coat, fete Enclosed Correction Form If This Address Is WronE 07/18/2002 FALL 2002 -COP. qECT INFOR~TION FOUND TO BE IN ERROR -REI'INUI THIS STATE][IlTEV[II IF MOB/~_AJICE ISDDE '-:-FEE'S-~'UB.1EC'r-TO~CHANGE' WITHOU1-NO/[c~ -REFER TO UNIVERSITY CATALOGS FOR WITHDRAWAL AND REFUND PROCEDURES -THE COfe4ONWEALTH OF PENNSYLVANIA PROVIDES APPROXIMATELY $5,262 PER FULL-TIHE EQUIVALENT RESIDENT STUDENT TO THE STATE SYSTEH OF HIGHER EDUCATION IN SUPPORT OF YOUR EDUCATION -ANY FINANCIAL AID SHOWN IS TENTATIVE -STUDEN1S WHO HAVE APPLIED FOR STAFFORD LOANS OR PLUS LOANS HAY TAKE CREDIT FOR 50 PERCENT OF THE LOAN SUBJECT TO VERIFICATION -Financial Aid Questions? CALL (717) 477-1131 -Other Billing Questions? CALL (717) 477-1211 ITEM DESCRIPTION DUE DATE: 08/07/2002 CHARGES/CREDITS BEGINNING BALANCE IN STATE TUITION EDUCATIONAL SERVICE FEE 218 HEALTH SERVICE FEE 72 STUDENT UNION FEE 102 ACTIVITY FEE ROOM FEE 15 MEAL PLAN COMMON DAMAGE FEE RECREATIONAL FEE SiCO: SICO Foundation Schola~ FOX: Shirley Fry Fox Apply Advance Reg. Payment )UE TO SMIPP~mSBURG UNIv~;~qSITF PLEASE DETACH AND R~TUP~N DEDUCTIONS (EXPLAIN AMOUNT ENCLOSE[ TOP PORTION WITH REMITTANC~ 0.00 2,189.00 .00 .00 .00 100.00 1,455.00 974.00 3.00 20.00 500.00CR 500.00CR 75.00CR 4,108.00 CHEDULES WILL BE AVAILABLE DURING ORIENTATION WHEN YOU ARRIVE IN AUGUST 320 MARKET STREET · STRAWBERRY SQUARE P.O. Box 1268 · HARRISBURG, PENNSYLVANIA 17108-1268 717.234.4161 · 717.234.6808 (FAX) www.gkslaw.com jas~gkslaw.com (Direct e-mail) GOLDBERG, KATZMAN ~ SHIPMAN, P.C. ATTORNEYS AT LAW August 12, 2002 OF COUNSEL F. LEE SHIPMAN COUNSEL JOSHUA D. LOCK ARNOLD B. KOGAN ARTHUR L. GOLDBERG (1951-2000) HARRY B. GOLDBERG (1961-1998) RONALD M. KATZMAN PAUL J. ESPOSlTO NEIL HENDERSHOT J. JAY COOPER THOMAS E. BRENNER JOHN A. STATLER APRIL L. STRANG-KUTAY GuY H. BROOKS JEFFERSON J. SHIPMAN JERRY J. Russ· MICHAEL J. CROCENZI THOMAS J. WEBER STEVEN E. GRUBB JOHN DELORENZO JOHN R. N1NOSKY ROYCE L. MORRIS DAVID M. STECKEL HEATHER L. FERNSLER Honorable Edward E. Guido Court of Common Pleas of Cumberland County Cumberland County Courthouse One Courthouse Square Fourth Floor Carlisle, PA 17013 Re: Terence G. Smith, a Minor Civil Action No. 02-2979 Civil Term Dear Judge Guido: On July 2, 2002 Your Honor approved our Petition for Court Approval of the Minor's Settlement in this case. As part of the settlement, the sum of $3,537.13 was to be placed in a restricted bank account in the name of Terence G. Smith, Jr. with an appropriate notation on the account that no withdrawal may be made of principal or interest until Terence G. Smith, Jr. reaches age 18 or unless by other order of this Court. We have received the settlement funds from the Defendants' insurance companies but have not yet established the restricted account. Terence G. Smith, Jr. will be enrolled as a Freshman at Shippensburg University this Fall. I enclose an invoice from Shippensburg University for Terence's Fall tuition, room and board and costs in the amount of $4,108.00. We are requesting that Your Honor permit Terence to use the $3,537.13 toward his Fall tuition. Accordingly, I am enclosing a proposed Order for Your Honor's consideration. JAS/ch Enclosure Very truly yours, cc: Mr. and Mrs. Terence G. Smith, Sr. (w/enclosure) GAHI~-~E OFPICE: 717.245.0597 · YORK OFFICE: 717.843.7912