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REBECCA and MICHAEL KARNS,
Minors, by and through their
parents and natural guardians,
DAVID and TAMMY KARNS,
Plaintiffs
IN THE COURT OF COMMON PLEAS
CUMBERLAND COUNTY, PENNSYLVANIA
NO. 94-1858 CIVIL TERM
CIVIL ACTION - LAW
:
v.
JAMES L. TAYLOR, III,
Defendant
JURY TRIAL DEMANDED
NOTICE
TO: Rebecca and Michael Karns, Minors,
by and through their parents and natural
guardians, David and Tammy Karns, Plaintiffs;
and
David L. Lutz, Esquire
ANGINO AND ROVNER, P.C.
4503 North Front Street
Harrisburg, PA 17110
YOU ARE HEREBY NOTIFIED, that the New Matter set forth herein
contains averments against you to which you are required to respond
within twenty (20) days after service thereof. Failure by you to
do so may constitute an admission.
CALDWELL & KEARNS
By:
J
r, Esquire
Dated: ~~ l'lt"t"'l'\-
REBECCA and MICHAEL KARNS,
Minors, by and through their
parents and natural guardians,
DAVID and TAMMY KARNS,
Plaintiffs
IN THE COURT OF COMMON PLEAS
CUMBERLAND COUNTY, PENNSYLVANIA
NO. 94-1858 CIVIL TERM
CIVIL ACTION - LAW
v.
JAMES L. TAYLOR, III,
Defendant
JURY TRIAL DEMANDED
R
WITH NEW MAlTER PURSUANT TO Pa.R.C.P. 2252(d)
AND NOW, comes the Defendant, James L. Taylor, III, by his
attorneys, Caldwell & Kearns, and does respond to the Complaint of
Plaintiffs, stating in support thereof as follows:
1. Admitted.
2. Admitted.
3. Admitted.
4. Admitted. In further response, however, Defendant, James
L. Taylor, III, address is 831 Bosler Avenue, Lemoyne, CUmberland
County, Pennsylvania 17043.
5. Admitted.
6. Admitted.
7. Admitted.
8. Admitted.
9. Denied. After reasonable investigation, Defendant Taylor
is without knowledge or information sufficient to form a belief as
1
.
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to the truth of the averment as to whether Plaintiff, Tammy Karns,
was operating her vehicle in the proper lane of travel and proof
thereof is demanded, if relevant.
10. Admitted.
11. Denied as stated. In further response to the averments
of '11, it is admitted that the vehicles of Defendant Taylor and
that operated by Plaintiff, Tammy Karns, struck each other in
aforesaid intersection, which was uncontrolled by signal or other
traffic device. In further response it is denied that Defendant
Taylor's vehicle caused the Karn's vehicle to leave the roadway if,
in fact, such occurred, which is not admitted but denied, but any
such movement, if any, was due to, in whole or part, the operation
of same by Plaintiff, Tammy Karns.
12. The averments of '12 and its subparagraphs appear to set
forth conclusions of fact and/or law to which no further response
is required or appropriate. In the event and to the extent any or
all of the averments of '12 are not found to be conclusions of law
and/or fact, same are all denied. In further response, Defendant
Taylor avers that he committed no negligent, careless, wanton or
reckless actions or inactions which caused the injuries, if any be
proven, to Plaintiffs. In further response, Defendant Taylor
states as follows:
2
.
(a) Defendant Taylor did have his vehicle under proper
and safe control at all times, but by virtue of the operation of
the Karn's vehicle and/or hedges, shrubs, trees and other bushes
obstructing his view at this intersection, which was uncontrolled
by sign or light, he was unable to avoid the aforeidentified
collision.
(b) At all times, Defendant Taylor was alert and
maintained a proper watch for other vehicles on the highway, but by
virtue of the operation of the Karn's vehicle and/or hedges,
shrubs, trees and other bushes obstructing his view at this
intersection, which was uncontrolled by sign or light, he was
unable to avoid the aforeidentified collision.
(c) At all relevant times, Defendant Taylor stayed
within his lane of travel in properly approaching the intersection
and making a turn from Green on to 24th Street.
(d) At all relevant times, Defendant Taylor traveled at
a safe and appropriate speed of travel.
(e) Defendant Taylor did not disobey or fail to perform
any rights of the road for the proximate cause of this accident, to
include failure to yield the right-of-way and, in fact, if any such
failure was the proximate cause, that was the failure of Plaintiff,
Tammy Karns, as hereinafter more particularly set forth.
3
(f) Defendant Taylor incorporates its response to
Subparagraph 12(b) by reference thereto.
(g) Defendant Taylor incorporates its responses to
Subparagraphs 12(a) through 12(e) by reference thereto.
(h) Defendant Taylor incorporates its responses to
Subparagraphs 12(a) through 12(e) by reference thereto.
(i) At all relevant times, Defendant Taylor operated his
vehicle in a careful, non-reckless manner with proper and due
regard to the rights of all others using the highway and did not in
such operation violate the Motor Vehicle Code of the Commonwealth
of Pennsylvania.
CLAIM I
Michael Karns. A Minor. bv and throuah his narents
and natural auardians. David and T-mmv Karns.
Individuallv. Plaintiffs v. James L. Tavlor. III. Defendant
13. '13 but incorporates '1 through '12 of the Complaint and,
accordingly, Defendant Taylor incorporates its responses to '1
through '12 by reference thereto.
14. Denied. After reasonable investigation, Defendant Taylor
is without knowledge or information sufficient to form a belief as
to the averments of '14 and proof thereof is demanded, if relevant.
15. Denied. After reasonable investigation, Defendant Taylor
is without knowledge or information sufficient to form a belief as
to the averments of '15 and proof thereof is demanded, if relevant.
4
"
16. Denied. After reasonable investigation, Defendant Taylor
is without knowledge or information sufficient to form a belief as
to the averments of '16 and proof thereof is demanded, if relevant.
17. Denied. After reasonable investigation, Defendant Taylor
is without knowledge or information sufficient to form a belief as
to the averments of '17 and proof thereof is demanded, if relevant.
18. Denied. After reasonable investigation, Defendant Taylor
is without knowledge or information sufficient to form a belief as
to the averments of '18 and proof thereof is demanded, if relevant.
19. Denied. After reasonable investigation, Defendant Taylor
is without knowledge or information sufficient to form a belief as
to the averments of '19 and proof thereof is demanded, if relevant.
WHEREFORE, Defendant, James L. Taylor, III, respectfully
requests that the Complaint of Plaintiff, Michael Karns, by and
through his parents and natural guardians, David and Tammy Karns,
be dismissed.
CLAIM II
Rebecca Karns. A Minor. bv and throuah her Darents and
natural auardians. David and T-mmv Karns. Individuallv.
Plaintiffs v. James L. Tavlor. III. Defendant
20. '20 but incorporates '1 through '19 of the Complaint and,
accordingly, Defendant Taylor incorporates its responses to '1
through '19 by reference thereto.
5
21. Denied. After reasonable investigation, Defendant Taylor
is without knowledge or information sufficient to form a belief as
to the averments of '21 and proof thereof is demanded, if relevant.
22. Denied. After reasonable investigation, Defendant Taylor
is without knowledge or information sufficient to form a belief as
to the averments of '22 and proof thereof is demanded, if relevant.
23. Denied. After reasonable investigation, Defendant Taylor
is without knowledge or information sufficient to form a belief as
to the averments of '23 and proof thereof is demanded, if relevant.
24. Denied. After reasonable investigation, Defendant Taylor
is without knowledge or information sufficient to form a belief as
to the averments of '24 and proof thereof is demanded, if relevant.
25. Denied. After reasonable investigation, Defendant Taylor
is without knowledge or information sufficient to form a belief as
to the averments of '25 and proof thereof is demanded, if relevant.
26. Denied. After reasonable investigation, Defendant Taylor
is without knowledge or information sufficient to form a belief as
to the averments of '26 and proof thereof is demanded, if relevant.
WHEREFORE, Defendant, James L. Taylor, III, respectfully
requests that the Complaint of Plaintiff, Rebecca Karns, by and
through his parents and natural guardians, David and Tammy Karns,
be dismissed.
6
NEW MATTER
In further response to Plaintiffs' Complaint, Defendant Taylor
avers the following New Matter, to wit:
27. The injuries caused to minor Plaintiffs were caused by
negligent actions or omissions of individuals over whom Defendant
Taylor is not responsible.
28. The negligent actions or omissions of Tammy Karns
constitute an intervening and superseding cause of any injuries
alleged to have been sustained by minor Plaintiffs.
29. Defendant Taylor performed his responsibilities and
obligations to properly and safely operate his motor vehicle at all
relevant times in a proper, correct and safe manner.
30. Some or all of the claims asserted by minor Plaintiffs in
their Complaint are not recoverable items of damage and under the
laws of the Commonwealth of Pennsylvania and/or the Pennsylvania
Motor Vehicle Financial Responsibility Act.
31. There was no negligence on the part of Defendant Taylor
or, in the alternative, in the event it is judicially determined
that there was negligence on the part of said Defendant, said
negligence was not the proximate cause of the incident or injuries
as described in Plaintiffs' Complaint.
7
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32. Any act or acts of negligence on the part of Defendant
Taylor, which are specifically denied, were not the substantial
cause of any injuries sustained.
33. Plaintiff, Tammy Karns, was guilty of such contributory
and/or comparative negligence and the damages recoverable, if any,
should be diminished in proportion to the amount of negligence
attributable to said Tammy Karns.
34. Said accident was caused in full or part by virtue of
disability of the motor vehicle operators to clearly see other
vehicles entering the intersection by virtue of location, size and
height of shrubs, trees, bushes and other growth at or near the
said intersection.
WHEREFORE, Defendant Taylor respectfully requests that the
Plaintiffs' Complaint be dismissed.
NEW MATTER PURSUANT TO Pa.R.C.P. 2252(d)
35. The acts and injuries described in Plaintiffs' Complaint
were caused by negligent actions or omissions of Tammy Karns. Such
negligent actions or omissions included the following, to wit:
(a) failure of Tammy Karns to have her vehicle under
such control as to be able to stop within a short, fair distance
ahead;
(b) failure to keep alert and maintain a proper watch
for the presence of other motor vehicles on the highway;
8
.........
(c) failure to yield the right-of-way to Defendant
Taylor's vehicle;
(d) failure to keep a proper watch for traffic on the
highway;
(e) failure to travel at a safe speed;
(f) failure to keep proper and adequate control over her
vehicle;
(g) failure to drive her vehicle with due regard for the
highway and traffic conditions which were existing and which she
was, or should have been, aware.
36. As a result of the aforesaid actions, Plaintiff Tammy
Karns was the substantial and proximate cause of any injuries
sustained by minor Plaintiffs, if any be proven.
37. Injuries sustained by minor Plaintiffs, if any be proven,
were increased by Tammy Karns' failure to operate her vehicle as
aforesaid in a safe and careful manner.
38. In the event it is determined that minor Plaintiffs are
entitled to recover any or all of the damages alleged in their
Complaint against Defendant Taylor, which is specifically denied,
in that event, Plaintiff, Tammy Karns, is jointly and severally
liable to minor Plaintiffs, or liable over to Defendant Taylor for
contribution and/or indemnity.
9
39. Defendant Taylor, therefore, further joins Plaintiff,
Tammy Karns, by way of cross claim, to protect his right of
contribution and/or indemnity in the event that it is judicially
determined that Defendant Taylor and Plaintiff, Tammy Karns, are
jointly or severally liable to the minor Plaintiffs, the existence
of any liability on the part of Defendant Taylor being expressly
denied.
WHEREFORE, Defendant, James L. Taylor, III, respectfully
requests that Plaintiffs' Complaint be dismissed.
In the
alternative, Defendant avers that if he be found liable to minor
Plaintiffs upon any cause of action set forth, which liability is
denied, then in such event, that Plaintiff, Tammy Karns, be found
liable over to Defendant, James L. Taylor, III, or jointly or
severally liable for contribution and/or indemnity.
Respectfully submitted,
CALDWELL & KEARNS
Dated:
L \'1.,l~""'\4
\I
By:
J , Esquire
At ey I.D. #0 9
Attorney for Defendant
James L. Taylor, III
3631 North Front Street
Harrisburg, PA 17110
(717) 232-7661
10
VERIPICATION
I, JAMES R. CLIPPINGER, Attorney for Defendant, James L.
Taylor, III, verify that the averments made on behalf of said
Defendant are based upon knowledge, information and belief
provided to me by James L. Taylor, III, and/or Defendant's
retained expert. Based upon this information, the statements set
forth in the foregoing Answer With New Matter are to the best of
my information true and correct. I understand that false
statements herein are subject to the penalties of 18 Pa.C.S. S
4904 relating to unsworn falsification to authorities.
,~__J'_.-,_ >.'!~_'J;-~
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CERTIFICATE OF SERVICE
AND NOW, this 17th day of June, 1994, I 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:
David L. Lutz, Esquire
ANGINO AND ROVNER, P.C.
4503 North Front Street
Harrisburg, PA 17110
CALDWELL & KEARNS
/k;~~" R ~
'R (' e .. "dh~l'~~
Clippinget I Es 1. e (.UY
G,\DATA\JRC\DD335\94239\32316.1
11
REBECCA and MICHAEL KARNS,
Minors, by and through their :
parents and natural guardians,:
DAVID and TAMMY KARNS, :
Individually,
Plaintiffs
IN THE COURT OF COMMON PLEAS
CUMBERLAND COUNTY, PENNSYLVANIA
CIVIL ACTION - LAW
NO. 94 1858 civil
.
.
vs.
JAMES L. TAYLOR, III,
Defendant
JURY TRIAL DEMANDED
PLAINTIFFS' ANSWER TO DEFENDANT'S NEW MATTER
27. through 34.
Denied.
The Defendant's allegations set
forth in paragraphs 27 through 34 are hereby denied as said
paragraphs contain conclusions of law to which no response is
necessary. By way of further response, the factual allegations set
forth in Plaintiffs' Complaint are herein incorporated by
reference.
Respectfully submitted,
ROVNER, P.C.
ut , Esqu re
I.D. No. 359 6
4503 North Front Street
Harrisburg, Pennsylvania 17110
(717) 238-6791
Counsel for Plaintiffs
Dated:
\ L\}" \C\~
48006/HLS
REBECCA and MICHAEL KARNS,
Minors, by and through their
parents and natural guardians,
DAVID and TAMMY KARNS,
Individually,
Plaintiffs
IN THE COURT OF COMMON PLEAS
CUMBERLAND COUNTY, PENNSYLVANIA
.
.
CIVIL ACTION - LAW
NO. 94 1858 Civil
vs.
.
JAMES L. TAYLOR, III,
Defendant
.
.
.
.
JURY TRIAL DEMANDED
CERTIFICATE OF SERVICE
I, Melinda L. Spicher, an employee of the law firm of Angino
& Rovner, P.C., do hereby certify that I am this day serving a true
and correct copy of PLAINTIFFS' ANSWER TO NEW MATTER upon all
counsel of record via postage prepaid first class United States
mail addressed as follows:
Caldwell & Kearns
James Clippinger, Esquire
3631 North Front Street
Harrisburg, PA 17110
Dated:
\p \11 \c1~
45615/HLS
~~R ARE HEREBY NOTIFIED TO FILEE
A WRITTEN REBPON8E TO TH
ENCL08ED
WITHIN TWENTY (20) DAY8 FROM
8ERVICE HEREOF OR A JUOOEMENT
MAY BE ENTF,RED AGAINBT YOU
. .
BY
AnORNEY
POST & SCHELL, P.C.
^nORNlYS AT LAw
101 NORTH FRONT 51RIll
HARRISBURC, I'lNNSYLVANIA \7\0\
t71n 11l-591\
fAX
(7m lll.9l74
WE 00 HEREBY CERTIFY THAT
~~~TW\~~I~yI80~ \'ll'l ~?GfNO:':
FILtlIlN THl": ACTION
BY AnORNEY
Dated: l' f -rY
Counsel for Additional Defendant
Tammy Karns
RBBBCCA and HICHABL KARNS,
Hinors, by and through their
parents and natural guardians :
DAIVD and TAMMY KARNS,
Indi vidually,
.
.
IN THB COURT 01' CONNON PLBAS
CUMBBRLAND COUNTY, PBNNSYLVANIA
CIVIL ACTION - LAW
No. 1858 Civil 1994
.
.
.
.
.
.
.
.
Plaintiffs
.
.
.
.
v.
.
.
:
JAMBS L. TAYLOR, III,
.
.
:
Defendant
.
.
.
.
v.
.
.
.
.
TAMMY KARNS, :
Additional Defendant: JURY TRIAL DBHANDBD
BNTRY 01' APPBARANCB
TO THB PROTHONOTARY:
Please enter my appearance for Additional Defendant,
Tammy Karns, in the above-captioned case.
POST & SCHBLL, P.C.
P.u' t:~~
I.D. Number: 39701
101 North Front Street
Harrisburg, PA 17101
(717 232-5931
-
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CERTIFICATE OF SERVICE
I. Carol A. Landis, an employee ~or tbe law ~irm Post .I<
Schell, P.C., hereby state that a true and correct copy o~ the
Loregoing Bntry oL Appearance was served upon all cOWlsel oL record
by Lirst class United States mail, postage prepaid, addressed as
Lollows, on the date set Lort:l1 below:
Bv First Class U.S. Mail:
David L. Lutz, Esquire
ANGINO .I< ROVN8R, P.C.
4503 N. Front St.
Harrisburg, PA 17110
Jemes Clippinger, Bsquire
3631 N. Front St.
Harrisburg, PA 17110
POST .I< SCHELL, P.C.
[l~a ~1c40
Carol A. Landis
Dated: gjr l1i
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CCA and MICHAEL KARNS, :
Minors, by and through their :
parents and natural guardians,:
DAVID and TAMMY KARNS,
Individually,
plaintiffs
IN THE COURT OF COMMON PLEAS
CUMBERLAND COUNTY, PENNSYLVANIA
CIVIL ACTION - LAW
NO. 94 1858 civil
vs.
.
.
JAMES L. TAYLOR, III,
Defendant
.
.
.
.
JURY TRIAL DEMANDED
ORDER
AND NOW, this
rztl.
day of
t:>~u..l,c.r
S6t'Lg~uln::o.l. , 1994, upon
consideration of the Petition for Approval of Minor Plaintiff
Rebecca Karns' Compromise Settlement and Distribution of Proceeds,
it is hereby ordered and decreed that a hearing is scheduled for
Q.,n1.
the /6tk, day of #~ 1995; at '!:vO" o'clock in Courtroom
5.
BY THE COURT:
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5339B/MLS
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REBECCA and MICHAEL KARNS, :
Minors, by and through their :
parents and natural guardians,:
DAVID and TAMMY KARNS, :
Individually, :
Plaintiffs :
IN THE COURT OF COMMON PLEAS
CUMBERLAND COUNTY, PENNSYLVANIA
CIVIL ACTION - LAW
NO. 94 1858 civil
vs.
.
.
.
.
.
.
.
.
JURY TRIAL DEMANDED
JAMES L. TAYLOR, III,
Defendant
AND NOW, this
ORDER
day of
, 1994, upon
consideration of Petition for Approval of Minor Plaintiff Rebecca
Karns' Compromised Settlement and Distribution of Proceeds, it is
hereby ORDERED and DECREED that the Petition is granted and payment
of $8,050 made payable to Tammy and David Karns, as Parents and
Natural Guardians of Rebecca Karns, be deposited into the Farmers'
Trust Bank, a deposit which is insured by the Federal Government,
and no withdrawal will be made from such account until the Minor
Plaintiff attains majority, except as authorized by Order of Court.
BY THE COURT:
J.
53389/MLS
f'~."7'",!-
.
REBECCA and MICHAEL KARNS,
Minors, by and through their
parents and natural guardians,
DAVID and TAMMY KARNS,
Individually,
plaintiffs
IN THE COURT OF COMMON PLEAS
CUMBERLAND COUNTY, PENNSYLVANIA
.
.
CIVIL ACTION - LAW
NO. 94 1858 civil
vs.
JAMES L. TAYLOR, III,
Defendant
JURY TRIAL DEMANDED
PETITION ~OR APPROVAL OP MINOR PLAINTIPP REBECCA KARNS'
COMPROMISED SETTLEMENT AND DISTRIBUTION OP PROCEEDS
The petition of Rebecca Karns, a Minor, by David and Tammy
Karns, her parents and natural guardians, respectfully represent:
1. Rebecca Karns, the Minor Plaintiff, is the daughter of
David and Tammy Karns, Petitioners herein. Rebecca is 6 years old,
having been born on February 24, 1988.
2. On May 15, 1992, Rebecca sustained a medial fracture of
the right tibia. Enclosed as Exbibit A is Dr. Thomas Malin's March
15, 1993 orthopedic report and office records.
3. At the time of the accident, Rebecca was a passenger in
a vehicle driven by her mother, Tammy Karns.
4. Mrs. Karns' vehicle was travelling on south 34th Street
in Camp Hill when involved in a motor vehicle accident with
Defendant, James L. Taylor.
5. At a result of the accident, a claim was brought against
Defendant Taylor. Mr. Taylor's counsel joined Tammy Karns as an
Additional Defendant.
6. GEICO Insurance Company, on behalf of Defendant Taylor,
and Anthem Insurance Company, on behalf of Tammy Karns as an
53389/MLS
Additional Defendant, has agreed, subject to approval of your
Honorable Court, to compromise the claim of Rebecca for the sum of
$11,500 ($9,000 from GEICO and $2,500 from Anthem).
7. In view of the uncertainty of securing a verdict in
excess of $11,500, particularly given the fact that this is a
limited tort claim, your Petitioners believe it is in the best
interests of Rebecca that the proposed settlement be accepted and
approved.
8. Should the Court deem it necessary to schedule a hearing
to approve the settlement, and if a hearing is scheduled, Rebecca
and her parents, David and Tammy Karns, and Plaintiffs' counsel
will be present at the hearing.
9. Your Petitioner has retained the law firm of Angino &
Rovner, P. C. to prosecute this action and has entered into a
contingency fee agreement with said attorneys whereby said
attorneys are to receive, for professional services, 35% of any
amount recovered after filing suit. However, given the fact that
the settlement was achieved shortly after filing suit, Angino &
Rovner seeks attorneys' fees based on 30% of the gross amount
recovered.
10. Petitioners have agreed, subject to approval of your
Honorable Court, to pay Angino & Rovner, P.C. for out of pocket
expenses incurred in prosecuting this claim. Angino & Rovner, p.e.
has agreed to waive all expenses incurred.
11. Petitioners aver that the remainder of the settlement,
$8,050 is to be deposited into the Farmers' Trust Bank of Carlisle
in an account, provided that no withdrawal will be made therefrom
.
1~.;j,*r",'I'<tit~
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until Rebecca reaches majority, except as authorized by Court
Order.
WHEREFORE, Petitioner requests your Honorable Court to approve
the Minor's compromise settlement and authorize the payment of
attorney's fees from the fund due the minor and direct payment of
$8,050 due to Rebecca to be deposited in the Farmers' Trust Bank of
Carlisle.
Respectfully sUbmitted,
ANGINO & ROVNER, P.C.
v d L.
I.D. No. 359 6
4503 North Front street
Harrisburg, Pennsylvania 17110
(717) 238-6791
Counsel for Petitioners
Dated:
1~/:;lq~
VERIFICATION
I, TAMMY KARNS, AS PARENT AND NATURAL GUARDIAN OF REBECCA
KARNS, Petitioner, have read the foregoing PETITION FOR APPROVAL OF
MINOR PLAINTIFF REBECCA KARNS' COMPROMISED SETTLEMENT AND
DISTRIBUTION OF PROCEEDS and do hereby swear or affirm that the
facts set forth in the foregoing are true and correct to the best
of my knowledge, information and belief. I understand that this
Verification is made subject to the penalties of 18 Pa.C.S.A.
section 4904, relating to unsworn falsification to authorities.
WITNESS:
It) / ~/q-y
/
r7a-m/>"'7 l4-?/'IA:)
TAMMY KARNV
Dated:
VERIFICATION
I, DAVID KARNS, AS PARENT AND NATURAL GUARDIAN OF REBECCA
KARNS, Petitioner, have read the foregoing PETITION FOR APPROVAL OF
MINOR PLAINTIFF REBECCA KARNS' COMPROMISED SETTLEMENT AND
DISTRIBUTION OF PROCEEDS and do hereby swear or affirm that the
facts set forth in the foregoing are true and correct to the best
of my knowledge, information and belief. I understand that this
Verification is made subject to the penalties of 18 Pa.C.S.A.
section 4904, relating to unsworn falsification to authorities.
9/11 /11/
, I
Dlt D
WITNESS:
Dated:
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Cumberland Orthopaedic Associates, LTD.
99 November Drive, Camp HIli, PA 17011-5097 . Phone 717.761.8644
.:
Thomas H. Malin, M.D., F.A.C.S.
William J. Polacheck, Jr.. M.D.
Craig W. Fultz, M.D.
March 15, 1993
Michael J. Navltsky
ANGINO & ROVNER, P.C.
4503 North Front Street
Harrisburg, PA 17110
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RE: Rececca L. Karns
D/A: 5-15-92
Dear Mr. Navltsky:
Enclosed you will find copies of the medical records on Rebecca L. Karns
which I believe, for the most part, are self-explanatory In regard to the
Injury and progress of her care.
If there are additional questions you may have In regard to her status,
please do not hesitate to write to me.
M.D.
THM/dlh
Enclosures
PLAINTIFF'S
EXHIBIT
A
-
ERY
PRACTICE LIMIT
- '
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"...
~
CUMBERLAND ORTHOPAEDIC ASSOCIATES, LTD.
Thomas H. Malin, M.D. William J. Polacheck, Jr., M.D. Craig W. Fultz, M.D.
patlent'sName1?tJV{~('Jl U<'~,.,,:;' Blrthdate ,..9-o1L/- ??
Street or Road -1.S \ ~ \.. Co \-, I A ~ L Present Age ~
City or Town (A" i c; \R.. State ~ Zip J -, n 13
Telephone --k9 ,. '1 '3. ~ G Social Security /I 010 LJ - I, P- - .'3 I 3 9
Occupation or Job Title
Marital Status: Single _ Married _ Divorced/Separated _ Widowed -
Employer
Employer Address
Telephone
K 1'\ r"'~ ) )),qu ld k'.4 rn-S
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Spouse, Parent or Guardian Name --=' '" f'f\ 0\ ~
Address \ q \ ~\ ( '- \-.. L A ",Q..
Phone to 9 \ - 9"'3 ~ 9
'\)".)E~PIOyer _~ \ \ 'f-\ m Q r \ l A f"'\ ",,.. \.Ad '- ~ \ i'r (. 0, Telephone
~oc.<I':;
EmployerAddreS$ ,Q)~ \':\Art-'~ h",.~ \" \u..
Person to be Notified In Emergency (:,0 Id j t /.( nr' n-6
phone 7/;/p-: 970:2
~'-\"3-4~-S~
c..<.\C" \I"f> \-e .~ nu \"'S
Heillth InSUrAnce
Card Holder's Nilmll
Blue Shield 10 Number
Card Holder'a Employet
Blue Shield Group /I ".
Do You Have a PACE CARD?
10 Number LI- oot/I Irs - ;5 - Is,
Medicare Nurribllf
Other InSUrance ~'A ~J!. ~ ,till \ c. .q.... 6.
Is your visit today a WORK.RELATED InJUry or problem?
Is your vlsll toddy related to an AUTOMOBILE ACCIDENT?
DArE of InJUry or Accident: 'MA....' \ ~ " \ G CI "'L
Family Physician '\)r. ~\lAc..~
ReferrlngPhyslclan ~\...\ ~Y'f\L fY'V\er1e.t\t.l(
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Yes_ No ~
YeLX No_
FOR'" '-Rev. .....
THOMAS H.. MALIN, M.D.
.....,
.'
f4
.....,..........:........
~
WilliAM J. POLACHECK. JR.. M.D.
PAST MEDICAL HISTORY
CRAIG W. FULTZ. M.D.
PRESENT MEDICATIONS:
(Pleue Include D018ge)
FAMILY HISTORY:
Mother
Father
Brolher
Sister
Molher
Falher
Brother
Sisler
FORM 2.REV. 2/D\
YES NO
_-L
_-L
EYES
Eyeglasses
Contact Lenses
InlectlDns
NAME '\< t.htc~ A \< PI r,,!.
PREVIOUS HOSPITAL ADMISSIONS: (Plesse Indlcale Both Medical and Surgical Admissions)
MONTH/YEAR HOSPITAL
REVIEW OF SYSTEMS:
HEAD
Chronic Heedaches
Injury
LUNGS YES NO
Pneumonls V
- --;7
Asthma - ---r
Emphysema _ _
Exposure to fumes or dust _ -L..
STOMAcH YES NO
Ulcer Disease _ -5-
Gallbladder - ---r-
Hiatal Hernia .
- ---r
Polyps 01 Colon
Upper 131 or
Barium Enema
Irrlleble Bowel Syndrome
ColIlls
Diverticulitis
Yellow Jaundice
./
--y
--r
--y
--;
--
DIABETES
YES NO
./
=;;:
CANCER
YES NO
~/
=7
_-L-
HYPERTENSION HEART DISEASE
YES NO YES NO
v v
-~ -7
-~ -~
DATE oS! f1)~/ 9.;;1
REASON
ALLERGIES TO
FOOD AND MEDICATIONS
YES No
_ ---'C
_ ---L
_ ---L
EARS, NOSE,
AND THROAI
Hearing Loss
Ear Infections
Nose Bleeds
Dentures
YES NO
-~
,/
--;7
--;7
HEART
High Blood Pressure
Shortness 01 Breath
Chest Pains
Heart Murmurs
Rheumallc Fever
Swelling 01 Feet
Heart Procedures or Tesls
Medicine for Your Heart
Medicine lor Blood Pressure
YES NO
-~
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- '--;7
- --;7'
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.
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KIDNEYS AND BLADDER
Kidney/Bladder Infection
Frequenl Urination
Blood In Urine
Awaken Irom Sleep to Urinate
YES NO
_ --1L.
_-L
_ ----IC..
-~
YES NO
_ ......JL
Are you dlsbetlc?
Do you use Insulin? 0 pills? 0
Have you had blood transfusions?
Have you had hepatitis?
Do you smoke?
How many clgaretlaa per day?
Have you smoked In the pasl?
How many per day?
Do you drink alcohol?
How much per week?
Do you drink collee?
How many cups per dsy?
Do you drink tea?
How many cups or glasses per day?
00 you drink soda?
How manv cans Der dav? ___1______
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CUMBERLAND ORTHOPAEDIC ASSOCIATES, LTD.
99 November Drive
Cemp Hili, PA 17011.5097
Our primary concern Is the medical care and treatment ot our patients, not developing
lawsuits. It Is becoming Increasingly difficult for us to comply With the numerous requests
from patients and their attorneys. Consequently, please be advised that we will no longer
prepare written reports for a patient's attorney or others concerning a patient's condition,
treatment or prognosis. We will, however, upon wrltteri request, provide a patient with
copies of hls.or her medical records, upon payment of the costs of photocopying.
We reserve the right upon proper notice to terminate our services to any patient who Insists
that we provide reports or letters, or appear In person or by phone, In connection with a
patient's pursuit of legal remedies.
By signing below, the undsrslgned agrees to accept the services of Cumberland Ortho-
paedIc Associates, LTD. upon the terms and conditions set forth herein.
W:"'!:~AktYv~
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Y 2'2.~ 12
001!
FOAM 4-REV.1II1
~~~
PA IONATURE
l.a!;ecr.4- K.q rl1J
PAllENnJ NAME (Print) .
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~
CUMDERLAND ORTHOPAEDIC ASSOCIATES, LTD.
99 November Drive
Camp Hili, PA 17011.5097
PATIENT'S AGREEMENT TO PAY FOR SERVICES RENDERED
I, '\'"r................ I( qr"r
. ~~If.nl at guardian)
~.Q \oQ.C'C",",
(myooll. n.... 0' chlld.. mlnall
, hsreby agree to pay for the professional services to
rendered by CUMBERLAND ORTHOPAEDIC ASSOCIATES,
LTD., as they may be billed to ms from time to lime. I undsrstahd that bslng covered by msdlcal
Insurance or lllnedlcal payment or reimbursement plan does not eliminate or diminish my duty to
pay for services so rendsred; however, that amount I am requited to pay will be reduced by the
amount actually paid by my Insurer to CUMBERLAND ORTHOPAEDIC ASSOCIATES, LTD. The
annual deducllble and co-pay porllon of Medicare Is my rElsponslblllty as CUMBERLAND ORTHO-
PAEDIC ASSOCIATES, LTD. accepts the reasonable Medicare charge. Msdlcare usually pays 80%
of the "rellsonable charge" and you or your Insurer must pay ths remaining 20Dtb. I understand that
Interest at 1 \12% per month on ths unpaid balance after 45 days, regardless of Insurance carrier or
source of paymsnt, will be charged.
I permit and agree that CUMBERLAND ORTHOPAEDIC ASSOCIATES, LTD., may provide a copy of
my medical record to any Insurance carrier who so requests such documentallon of services
performed. for payment of those services on my behalf. Physicians are now required by law to
disclose financial Interests they have In health-related facllllles. The physicians of CUMBERLAND
ORTHOpAEDIC ASSOCIATES. LTD., mayor lTIay not have a financial Interest In the Csntral PA MRI
Centtlr.
I authorlzti Iny Insurance carrier to make payment of medical benefits dlreclly to CUMBERLAND
ORTHOPAEDIC ASSOCIATES, LTD. for services rendered.
With my signature below, I acknowledge receipt of a copy of this agreement.
OATE
~}$z,
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~~~ ~Cn%1
A! A(#ffIY
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DATE
.OIM '.IEV, .191
,-'."'..."'"....".;."."....._.,....'"...Oi:"".l1I
KARNS, Rebecca L.
\Davld Karns
191 BIrch Lane
Carlisle PA 17013
:YJ 71l
l~e/lIIs(I/I) fir"? (~/) l-/;? (IV)
May 22, 1992--FRIDAY AM
See LETTER to Donald Kovacs, M.D. Idh/sam
June 1, 1992--MONDA Y PM
This patIent Is have some feeling of looseness about the superIor aspect of
her cast. It Is not extremely loose. The cast Is not well maIntaIned.
The superIor portion of the calf was petalled wIth the stockInette to the
cast. She will be seen In 3 wks. for removal of her cast and X-ray of her
knee, AP and lateral, prIor to beIng seen.
THM/sam
RTO: 3 wks.
~.R).'"
'^,I(B~ lR. -.).l.g . '1 ';}.. R..... t."->--L (31 )
June 26, 1992--FRIDAY, A.M.
This patient's cast was removed from her right lower extremity.
EXAM: She has no tenderness about the proxImal tibia or distal femur. She
has some fullness passively. She has a range of motion of 4S degrees wIthout
pain.
X-RA YS: REview of her x-rays Indicate confirmation of a fracture to the
epiphysis of her right proximal tibia. There is callous formation In the
separation.
PLAN: WIth this diagnosis I advised the mother of progressive ambulatlon and
the use of one crutch. Range of motion without agresslve walking or activity
or running untl she can walk without pain or limp.
We are going to see her In two weeks. She Is going to continue on the one
crutch for support so she can walk without a limp. When we see her I will
re-evaluate her before making a decision for repeat x-ray.
THM/dlh
RTO: 2 weeks
l: 1'6-
h~J.:>
..--...-
,.
~~~:;,.:_,
'-Cumberland Orthopaedic Associates, LTD.
99 November Drive. Camp Hili. PA 17011.5097 . Phone 717.761.8644
Thomas H. Malin. M.D.. F.A.C.S.
William J. Polacheck, Jr" M.D.
Craig W. Fullz, M.D.
May 28, 1992
Donald J. Kovacs, M.D.
1358 Lutztown Road
Boiling Springs, PA 17007
Dear Dr. Kovacs:
RE: Rebecca L. Karns
191 Birch Lane
Carlisle, PA 17013
I saw your patient Rebecca L. Karns In my office on May 22, 1992.
This four-year-old white female apparently was Involved In an automobile
accident on Friday, May 15, 1992 where she was a passenger In the rear seat
wearing a seat belt. She was seated behind the driver. Apparently the car
was struck head on at 3ljth Street in Camp Hili, Pennsylvania. The patient
was apparently taken out of the car by her mother with no apparent history of
Injury reported at that time. However, she was seen at Holy Spirit Hospital
and had x-rays. Later that evening she began to show swelling and
progressive pain to her right knee and lower extremity. She was seen Monday
evening the 18th of May and with f'e-evaluatlon she was placed In a knee
Immobilizer and referred.
When seen today the patient had moderate swelling of her right knee and her
right calf with pain to examination of her calf and leg in the area of her
right knee. On examination she does not have evidence of Instability,
medially or laterally or anteriorly or posteriorly. She is tender over the
proximal knee however.
Review of her x-rays suggested she could have some widening of the epiphysis
of the proximal tibia when compared to the left knee. In order to evaluate
this comparative films were taken again today to compare to the films taken
on 5/15/92. These comparative films confirm that this patient has a Salter
II fracture of her proximal tibia.
The film taken In my office Indicates she has a fracture of the right tibia
medially. The fracture Is through the epiphysis and out this medial tibial
flare area.
PRACTICE liMITED TO ORTHOPAEDIC SURGERY
,f 'J
t ... ~(iLI tt.-L.,-""
Thomas H. Malin, M.D.
Rebecca L. Karns
May 28, 1992
Page Two
On this basis the patient was placed In a long leg fiberglass cast which she
will require for a minimum of four weeks. She will be on crutches and unable
to weight bear on this cast during this period of time.
She will be seen In four weeks for removal of her cast and x-ray out of,
fiberglass at that time. .
The origInal x-ray report, a copy of which Is enclosed, Indicated a normal
right leg. This could only be seen and evaluated by examination and
subsequent films today which confirm that which was not seen and was not
evident, In my opinion either, on the original x-rays.
This then Is a report on your patient.
THMfdlh
Enclosure
cc: Sal Alfano, M.D.
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KARNS, Rebecca L.
July 13, 1992--MONDAY PM
This patient Is walking with external rotation of the right leg and she walks
with a limp. She has no swelling to her knee. She has FROM of her right
knee. She has no pain or tenderness.
She will go about her activities and I believe with time and activity, she
will decrease external rotation. She will RTO In 6 wks.
THM/sam
RTO: 6 wks.
August 31, 1992--MONDAY PM
This patient Is walking well.
PE, She has no limp and there Is slight toe-In. There Is Internal tibial
torsion here, both on the right and left. There was full range of motion
without the limp that she had previously. She has full range of motion of
her knee.
PL: She, therefore, will go about her activity and be discharged.
THM/mka
DISCHARGED
11/12192 Prepayment received and records mailed to Federal Kemper Insurance
Company, Greefleld Corporate Center, 1811 OJde Homestead Lane, PO Box 10548
Lancaster, PA 17605-0548 Attention: Christine Hall/Claims
March 15, 1993 -- Copy of records mailed with letter to Michael J. Navltsky
JlNGINO & ROVNER, P.C., 4503 North Front Street, Harrisburg, PA 17110 '
!il>lljl~.~~,,~#~";,i"~
REBECCA and MICHAEL KARNS,
Minors, by and through their :
parents and natural guardians,:
DAVID and TAMMY KARNS, :
Individually, :
Plaintiffs :
IN THE COURT OF COMMON PLEAS
CUMBERLAND COUNTY, PENNSYLVANIA
CIVIL ACTION - LAW
NO. 94 1858 Civil
:
VB.
.
.
.
.
JAMES L. TAYLOR, III,
Defendant
:
.
.
JURY TRIAL DEMANDED
CERTIFICATE OF SERVICE
I, Melinda L. Spicher, an employee of the law firm of Angino
& Rovner, P.C., do hereby certify that I am this day serving a true
and correct copy of PETITION FOR APPROVAL OF MINOR PLAINTIFF
REBECCA KARNS' COMPROMISED SETTLEMENT AND DISTRIBUTION OF PROCEEDS
upon all counsel of record via postage prepaid first class United
states mail addressed as follows:
Caldwell & Kearns
James Clippinger, Esquire
3631 North Front Street
Harrisburg, PA 17110
Post & Schell
Paul Grego, Esquire
101 N Front st
Harrisburg, PA 17101
~Md~~.~CN-
Mel nda L. Spich r
Dated:
\?- \ b\C\1t
45615/I!LS
REBECCA and MICHAEL KARNS,
Minors, by and through their :
parents and natural guardians,:
DAVID and TAMMY KARNS, :
Individually,
Plaintiffs
IN THE COURT OF COMMON PLEAS
CUMBERLAND COUNTY, PENNSYLVANIA
.
.
CIVIL ACTION - LAW
NO. 94 1858 civil
vs.
.
.
JAMES L. TAYLOR, III,
Defendant
.
.
.
.
.
.
JURY TRIAL DEMANDED
ORDER
AND NOW, this
?~
L:>t;.c.c....1. J
day of -8epteeer, 1994, upon
consideration of the Petition for Approval of Minor plaintiff
Michael Karns' compromise Settlement and Distribution of Proceeds,
it is hereby ordered and decreed that a hearing is scheduled for
J_ /, a.,n.
day of '{-<'VUj 1994': at C}'",th)llo'clock in Courtroom
thejlG6t
5.
BY THE COURT:
J
~
~/7/~11'..v
S3389/MLS
. t-..,.,....
':-';J.",:!;",":~~;.j.:1,-,f' .~
"
fi~~i~i~"'40,jo",;4 ,
I.
,..
REBECCA and MICHAEL KARNS,
Minors, by and through their
parents and natural guardians,
DAVID and TAMMY KARNS,
Individually,
Plaintiffs
IN THE COURT OF COMMON PLEAS
CUMBERLAND COUNTY, PENNSYLVANIA
CIVIL ACTION - LAW
NO. 94 1858 civil
vs.
JAMES L. TAYLOR, III,
Defendant
.
.
JURY TRIAL DEMANDED
AND NOW, this
ORDER
day of
, 1994, upon
consideration of Petition for Approval of Minor Plaintiff Michael
Karns' Compromised Settlement and Distribution of Proceeds, it is
hereby ORDERED and DECREED that the Petition is granted and payment
of $12,600 made payable to Tammy and David Karns, as Parents and
Natural Guardians of Michael Karns, be deposited into the Farmers'
Trust Bank, a deposit which is insured by the Federal Government,
and no withdrawal will be made from such account until the Minor
Plaintiff attains majority, except as authorized by Order of Court.
BY THE COURT:
J.
53389/MLS
REBECCA and MICHAEL KARNS,
Minor., by and through their
parents and natural guardians,
DAVID and TAMMY KARNS,
Individually,
Plaintirrs
IN THE COURT OF COMMON PLEAS
CUMBERLAND COUNTY, PENNSYLVANIA
.
.
CIVIL ACTION - LAW
NO. 94 1858 civil
v..
.
.
:
JAMES L. TAYLOR, III,
Derendant
.
.
JURY TRIAL DEMANDED
PITITIOH POR APPROVAL OP MINOR PLAINTIPP MICHAEL KARNS'
COMPROMISBD SBTTLBMBNT AND DISTRIBUTION OP PROCEBDS
The Petition of Michael Karns, a Minor, by David and Tammy
Karns, his parents and natural guardians, respectfully represent:
1. Michael Karns, the Minor plaintiff, is the son of David
Michael is 9 years old,
and Tammy Karns, Petitioners herein.
having been born on June 3, 1985.
2. On May 15, 1992, Michael sustained a forehead laceration,
leaving a permanent scar as a result of being involved in an
automobile accident.
3. At the time of the accident, Michael was a passenger in
a vehicle driven by his mother, Tammy Karns.
4. Mrs. Karns' vehicle was travelling on South 34th Street
in Camp Hill when involved in a motor vehicle accident with
Defendant, James L. Taylor.
5. At a result of the accident, a claim was brought against
Defendant Taylor. Mr. Taylor'S counsel joined Tammy Karns as an
Additional Defendant.
6. GEICO Insurance company, on behalf of Defendant Taylor,
and Anthem Insurance Company, on behalf of Tammy Karns as an
53389/MLS
. "J.-'.
Additional Defendant, has agreed, subject to approval of your
Honorable Court, to compromise the claim of Michael for the sum of
$18,000 ($15,000 from GEICO and $3,000 from Anthem).
7. In view of the uncertainty of securing a verdict in
excess of $18,000, particularly given the fact that this is a
limited tort claim, your Petitioners believe it is in the best
interests of Michael that the proposed settlement be accepted and
approved.
8. Should the Court deem it necessary to schedule a hearing
to approve the settlement, and if a hearing is scheduled, Michael
and his parents, David and Tammy Karns, and Plaintiffs' counsel
will be present at the hearing.
9. Your Petitioner has retained the law firm of Angino &
Rovner, P. c. to prosecute this action and has entered into a
contingency fee agreement with said attorneys whereby said
attorneys are to receive, for professional services, 35% of any
amount recovered after filing suit. However, given the fact that
the settlement was achieved shortly after filing suit, Angino &
Rovner seeks attorneys' fees based on 30% of the gross amount
recovered.
10. Petitioners have agreed, subject to approval of your
Honorable Court, to pay Angino & Rovner, P.C. for out of pocket
expenses incurred in prosecuting this claim. Angino & Rovner, P.C.
has agreed to waive all expenses incurred.
11. Petitioners aver that the remainder of the settlement,
$12,600 is to be deposited into the Farmers' Trust Bank of Carlisle
in an account, provided that no withdrawal will be made therefrom
,.-...._,...-." .~,"""'''''
until Michael reaches majority, except as authorized by Court
Order.
WHEREFORE, Petitioner requests your Honorable Court to approve
the Minor's compromise settlement and authorize the payment of
attorney's fees from the fund due the minor and direct payment of
$12,600 due to Michael to be deposited in the Farmers' Trust Bank
of Carlisle.
Respectfully submitted,
ANGINO & ROVNER, P.C.
~.~Esquir.
I.D. No. 35956
4503 North Front street
Harrisburg, Pennsylvania 17110
(717) 238-6791
Counsel for Petitioners
Dated:
I ~I$l c,y
f'
. ,~"
.,-," ., '_~ ~~ _' ,v" .~: ",.., :'~'"
'.,.
co-,,,,:,','-'
"}~'::<:, -',' ,:,.'-:' "
VERIFICATION
I, DAVID KARNS, AS PARENT AND NATURAL GUARDIAN OF MICHAEL
KARNS, Petitioner, have read the foregoing PETITION FOR APPROVAL OF
MINOR PLAINTIFF MICHAEL KARNS' COMPROMISED SETTLEMENT AND
DISTRIBUTION OF PROCEEDS and do hereby swear or affirm that the
facts set forth in the foregoing are true and correct to the best
of my knowledge, information and belief. I understand that this
Verification is made subject to the penalties of 18 pa.C.S.A.
section 4904, relating to unsworn falsification to authorities.
WITNESS:
0/ ~/94
Dated:
/u/~/v</
I
(/'" ,'/'//>>/N---; ./fa~__,....
TAMMY KARN~
./
I'
VERIFICATION
I, TAMMY KARNS, AS PARENT AND NATURAL GUARDIAN OF MICHAEL
KARNS, Petitioner, have read the foregoing PETITION FOR APPROVAL OF
MINOR PLAINTIFF MICHAEL KARNS' COMPROMISED SETTLEMENT AND
DISTRIBUTION OF PROCEEDS and do hereby swear or affirm that the
facts set forth in the foregoing are true and correct to the best
of my knowledge, information and belief. I understand that this
Verification is made subject to the penalties of 18 Pa.C.S.A.
section 4904, relating to unsworn falsification to authorities.
WITNESS:
Dated:
JAMES L. TAYLOR, III,
Defendant
.
.
.
.
JURY TRIAL DEMANDED
. .
REBECCA and MICHAEL KARNS, :
Minors, by and through their :
parents and natural guardians,:
DAVID and TAMMY KARNS, :
Individually, :
Plaintiffs :
IN THE COURT OF COMMON PLEAS
CUMBERLAND COUNTY, PENNSYLVANIA
CIVIL ACTION - LAW
NO. 94 1858 civil
vs.
.
.
.
.
.
.
CERTIFICATE OF SERVICE
I, Melinda L. Spicher, an employee of the law firm of Angino
& Rovner, P.C., do hereby certify that I am this day serving a true
and correct copy of PETITION FOR APPROVAL OF MINOR PLAINTIFF
MICHAEL KARNS' COMPROMISED SETTLEMENT AND DISTRIBUTION OF PROCEEDS
upon all counsel of record via postage prepaid first class United
States mail addressed as follows:
Caldwell & Kearns
James Clippinger, Esquire
3631 North Front Street
Harrisburg, PA 17110
Post & Schell
Paul Grego, Esquire
101 N Front st
Harrisburg, PA 17101
Dated:
\d\~\C't\
1\ ;l~~
nda L. sp c
l~
45615/MLS
REBECCA and MICHAEL KARNS,
Minors, by and through their
parents and natural guardians,
DAVID and TAMMY KARNS,
Individually,
IN THE COURT OF COMMON PLEAS
CUMBERLAND COUNTY, PENNSYLVANIA
NO. 94-1858 CIVIL TERM
Plaintiffs
CIVIL ACTION - LAW
v.
JAMES L. TAYLOR, III,
Defendant
JURY TRIAL DEMANDED
v.
TAMMY KARNS,
Additional Defendant
PRAECIPE
-
TO THE PROTHONOTARY:
..I
PLEASE issue a Writ of Summons to join Tammy Karns, 191 Birch
Lane, Carlisle, CUmberland County, Pennsylvania, as an Additional
Defendant in the above referenced action.
Respectfully submitted,
CALDWELL & KEARNS
By:
. Cl ppi , ire
tt ney I.D. N . 07159
Attorneys for De endant
3631 North Front Street
Harrisburg, PA 17110
717-232-7661
Dated: May 13, 1994
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REBECCA and MICHAEL KARNS,
Minors, by and through their :
parents and natural guardians,:
DAVID and TAMMY KARNS, :
Individually,
Plaintiffs
IN THE COURT OF COMMON PLEAS
CUMBERLAND COUNTY, PENNSYLVANIA
.
.
CIVIL ACTION - LAW
NO. Cj!j - I J)"{ (] ~~L -;j f/vn-...
.
.
vs.
.
.
JAMES L. TAYLOR, III,
Defendant
:
JURY TRIAL DEMANDED
NOTICE TO DEFEND
You have been sued in court. If you wish to defend against
the claims set forth in the following pages, you must take action
within twenty (20) days after this complaint and Notice are served,
by entering a written appearance personally or by attorney and
filing in writing with the Court your defenses or objections to the
claims set forth against you. You are warned that if you fail to
do so the case may proceed without you and a judgment may be
entered against you by the Court without further notice for any
money claimed in the Complaint or for any other claim or relief
requested by the Plaintiff. You may lose money or property or
other rights important to you.
YOU SHOULD TAKE THIS PAPER TO YOUR LAWYER AT ONCE. IF YOU DO
NOT HAVE A LAWYER OR CANNOT AFFORD ONE, GO TO OR TELEPHONE THE
OFFICE SET FORTH BELOW TO FIND OUT WHERE YOU CAN GET LEGAL HELP.
COURT ADMINISTRATOR
4th Floor
Cumberland County Courthouse
Carlisle, PA 17013
(717) 240-6200
40407/JHD
,,:........,'._~......,""'-,.-.....-
REBECCA and MICHAEL KARNS, :
Minors, by and through their :
parents and natural guardians,:
DAVID and TAMMY KARNS, :
Individually, :
Plaintiffs :
IN THE COURT OF COMMON PLEAS
CUMBERLAND COUNTY, PENNSYLVANIA
CIVIL ACTION - LAW
NO.
vs.
:
.
.
JAMES L. TAYLOR, III,
Defendant
.
.
.
.
JURY TRIAL DEMANDED
NOTICIA
Le han demandado a usted en la corte. si usted quiere
defenderse de estas demandas expuestas en las paginas sugnuientes,
usted tiene viente (20) dias de plazo al partir de la fecha de la
demanda y la notificacion. Usted debe presentar una apariencia
escrita 0 en persona 0 por abogado y archivar en la corte en forma
escrita sus defensas 0 sus objeciones alas demandas en contra de
su persona. Sea avisado que si usted no se defiende, la corte
tomara medidas y puede entrar una orden contra usted sin previo
aviso 0 notificacion y por cualquier queja 0 alivio que es pedido
en la peticion de demanda. Usted puede perder dinero 0 sus
propiedades 0 otros derechos importantes para usted.
LLEVE ESTA DEMANDA A UN ABOGADO IMMEDIATEMENTE. SI NO TIENE
ABOGADO 0 SI NO TIENE EL DINERO SUFICIENTE DE PAGAR TAL SERVICIO,
VAYA EN PERSONA 0 LLAME POR TELEFONO A LA OFICINA CUYA DIRECCION SE
ENCUENTRA ESCRITA ABAJO PARA AVERIGUAR DONDE SE PUEDE CONSEGUIR
ASISTENCIA LEGAL.
COURT ADMINISTRATOR
4th Floor
Cumberland County Courthouse
Carlisle, PA 17013
(717) 240-6200
o,~,f~;,,~.;'~r:>>~
REBECCA and MICHAEL KARNS,
Minors, by and through their :
parents and natural guardians,:
DAVID and TAMMY KARNS, :
Individually,
Plaintiffs
IN THE COURT OF COMMON PLEAS
CUMBERLAND COUNTY, PENNSYLVANIA
CIVIL ACTION - LAW
NO.
vs.
JAMES L. TAYLOR, III,
Defendant
JURY TRIAL DEMANDED
COMPLAINT
1. Minor Plaintiff, Michael Karns, born on June 3, 1985,
resides with his parents, Plaintiffs, David and Tammy Karns, at 191
Birch Lane, Carlisle, Cumberland County, Pennsylvania.
2. Minor Plaintiff, Rebecca Karns, born on February 24,
1988, resides with her parents, Plaintiffs, David and Tammy Karns,
at 191 Birch Lane, Carlisle, Cumberland County, Pennsylvania.
3. Plaintiffs, David and Tammy Karns, ci tizens of the
Commonwealth of Pennsylvania, are husband and wife, adult
individuals who reside at 191 Birch Lane, Carlisle, Cumberland
County, Pennsylvania.
4. Defendant, James L. Taylor, III, is an adult individual
and citizen of the Commonwealth of Pennsylvania who resides at 220
R. Spring Lane, Enola, Cumberland County, Pennsylvania.
5. The facts and occurrences hereinafter related took place
on or about May 15, 1992 at approximately 6:35 p.m. at the
intersection of 34th street and Green street, Camp Hill, Cumberland
county, Pennsylvania.
6. Plaintiff Tammy Karns was operating her motor vehicle, a
1983 Chevrolet Malibu, in a northbound direction on South 34th
street.
"<;".1, .
.
7. Minor Plaintiff, Michael Karns, was a passenger in the
rear seat of the vehicle driven by Plaintiff Tammy Karns.
8. Minor Plaintiff, Rebecca Karns, was a passenger in the
rear seat of the vehicle driven by Plaintiff Tammy Karns.
9. Plaintiff Tammy Karns was driving her vehicle within the
proper lane of travel for northbound traffic on 34th street, Camp
Hill, Cumberland County, Pennsylvania.
10. At the same time, Defendant Taylor was operating a 1990
Pontiac LeMans in a westbound direction on Green street.
11. Defendant Taylor entered the intersection of 34th and
Green streets, struck Mrs. Karns' vehicle and pushed the vehicle
off of the roadway.
12. The foregoing accident and all of the injuries and
damages set forth hereinafter sustained by Minor Plaintiffs Michael
and Rebecca Karns, are the direct and proximate result of the
negligent, careless, wanton and reckless manner in which Defendant
Taylor operated his motor vehicle as follows:
a. failure to have his vehicle under such control as
to be able to stop within the assured clear
distance ahead;
b. failure to keep alert and maintain a proper watch
for the presence of other motor vehicles on the
highway;
c. failure to stay within his lane of travel;
d. failure to travel at a safe speed;
e. failure to yield the right-of-way to Plaintiff's
vehicle;
f. failure to keep a proper watch for traffic on the
highway;
g.
failure to drive his vehicle with due regard for
the highway and traffic conditions which were
existing and of which he was or should have been
aware;
L
failure to keep proper and adequate control over
his vehicle; and
driving his vehicle upon the highway in a manner
endangering persons and property and in a reckless
manner with careless disregard to the rights and
safety of others and in violation of the Motor
Vehicle Code of the Commonwealth of Pennsylvania.
h.
CLAIM I
MICHAEL KARNS. A MINOR.
BY AND THROUGH HIS PARENTS AND NATURAL GUARDIANS.
DAVID AND TAMMY KARNS. INDIVIDUALLY. Plaintiffs
YlL..
JAMES L. TAYLOR. III. Defendant
13. Paragraphs 1 through 12 of the Complaint are incorporated
herein by reference.
14. Minor Plaintiff Michael Karns sustained painful and
severe injuries which include but are not limited to contusions of
his forehead and a five (5) centimeter laceration to his forehead
which required stitches sutures, leaving a permanent scar.
15. By reason of the aforesaid injuries sustained by Minor
Plaintiff Michael Karns, Plaintiffs David and Tammy Karns were
forced to incur liability for medical treatment, medications, and
similar miscellaneous expenses in an effort to restore their son to
health, and claim is made therefor.
16. Because of the nature of Minor Plaintiff Michael Karns'
injuries, Plaintiffs David and Tammy Karns have been advised and,
CLAIM II
REBECCA KARNS. A MINOR.
BY AND THROUGH HER PARENTS AND NATURAL GUARDIANS.
DAVID AND TAMMY KARNS. INDIVIDUALLY. Plaintiffs
YL.
JAMES L. TAYLOR. III. Defendant
therefore, aver that they may be forced to incur similar expenses
in the future, and claim is made therefor.
17. As a result of the aforementioned injuries, Minor
Plaintiff Michael Karns has undergone and in the future will
undergo physical and mental suffering, inconvenience in carrying
out his daily activities, loss of life's pleasures and enjoyment,
and claim is made therefor.
18. As a result of the aforesaid injuries, Minor Plaintiff
Michael Karns has been and in the future will be subject to
humiliation and embarrassment, and claim is made therefor.
19. As a result of the aforesaid accident, Minor Plaintiff
Michael Karns has sustained permanent serious disfigurement and
claim is made therefor.
WHEREFORE, Minor Plaintiff Michael Karns, by and through his
parents and natural guardians David and Tammy Karns, demands
judgment against Defendant James L. Taylor, III, in an amount in
excess of Ten Thousand ($10,000.00) Dollars exclusive of interest
and costs and in excess of any jurisdictional amount requiring
compulsory arbitration.
20. Paragraphs 1 through 12 of the Complaint are incorporated
herein by reference.
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21. Minor Plaintiff Rebecca Karns sustained painful and
severe injuries which include but are not limited to a medial
fracture of the right tibia.
22. By reason of the aforesaid injuries sustained by Minor
Plaintiff Rebecca Karns, Plaintiffs David and Tammy Karns were
forced to incur liability for medical treatment, medications, and
similar miscellaneous expenses in an effort to restore their
daughter to health, and claim is made therefor.
23. Because of the n~ture of the injuries to Minor Plaintiff
Rebecca Karns, Plaintiffs David and Tammy Karns have been advised
and, therefore, aver that they may be forced to incur similar
expenses in the future, and claim is made therefor.
24. As a result of the aforementioned injuries, Minor
Plaintiff Rebecca Karns has undergone physical and mental
suffering, inconvenience in carrying out her daily activities, loss
of life's pleasures and enjoyment, and claim is made therefor.
25. As a result of the aforesaid injuries, Minor Plaintiff
Rebecca Karns has been subject to humiliation and embarrassment,
and claim is made therefor.
26. As a result of the aforesaid accident, Minor Plaintiff
Rebecca Karns has sustained serious impairment of her bodily
function.
, .~':"1'~~;'1'::,~:~~~"
WHEREFORE, Minor Plaintiff Rebecca Karns, by and through her
parents and natural guardians, David and Tammy Karns, demands
judgment against Defendant James L. Taylor, III, in an amount in
excess of Ten Thousand ($10,000.00) Dollars exclusive of interest
and costs and in excess of any jurisdictional amount requiring
compulsory arbitration.
Respectfully submitted,
ANGINO & ROVNER, P.C.
Dated: '-t ll\ \q L\-
17110
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REBECCA and MICHAEL KARNS, :
Minors, by and through their :
parents and natural guardians,:
DAVID and TAMMY KARNS, :
Individually, :
Plaintiffs
IN THE COURT OF COMMON PLEAS
CUMBERLAND COUNTY, PENNSYLVANIA
CIVIL ACTION - LAW
NO.
.
.
vs.
JAMES L. TAYLOR, III,
Defendant
.
.
JURY TRIAL DEMANDED
DIRECTIONS FOR SHERIFF
Please serve Defendant James L. Taylor, III, at his place of
residence at 220 R. Spring Lane, Enola, Cumberland County,
Pennsylvania, by leaving a copy of the enclosed Complaint with him/
or with an adult relative or with an adult/person in charge at that
time.
Respectfully submitted,
ANGINO & ROVNER, P.C.
Dated:
1-\ \ II I q4
Da J.d L.
I.D. No. 3595
4503 North Front Street
Harrisburg, Pennsylvania 17110
(717) 238-6791
Counsel for Plaintiffs
.
VERIFICATION
We, David and Tammy Karns, Individually, and as Parents and
Natural Guardians of Minor Plaintiffs, Rebecca and Michael Rarns,
Plaintiffs, have read the foregoing COMPLAINT and do hereby swear
or affirm that the facts set forth in the foregoing are true and
correct to the best of my knowledge, information and belief. I
understand that this Verification is made subject to the penalties
of 18 Pa.C.S.A. Section 4904, relating to unsworn falsification to
authorities.
WITNESS:
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David Rarns
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SHERIFF'S RETURN
CCMolONWEALnl OF PENNSYLVANIA: In The Court of Common Pleas of
COUNl'Y OF ClJolBERLAND Cumberland Coun ty, pennsy I van ia
No. 94-1858 Civil Term
Rebecca and Michael Karns, Minors, by Complaint in Civil Action Law
and through their parents and natural and Notice
guardians David and Tammy Karns, Individually
VS
James L. Taylor, III
Wesley Cook
. ~Il<RCl6f Deputy Sheriff of
CUnberland County, Pennsylvania, who being duly sworn according to law, says,
that he served the within
Complaint in Civil Action Law and Notice
upon James L. Taylor, III
, the defendant, at 6:30
o'clock
P
.M. !S~ / EDST, on the
26
day of Apr il
. 19~43t
831 Bosler Avenue, Lemoyne . CUnberland County,
Pennsylvania, by handing to James Tay lor, I II
a true and attested copy of the Complaint in Civil Action Law and Noticf!
and at the same time directing
his
attention to the contents thereof and
the "Notice to Plead" endorsed thereon.
Sheriff's Costs:
Docketing
Service
Affidavit
Surcharge
So answers:
r~r-~<~
R. Thomas Kline, Sheriff
14.00
9.52
2.00
25.52 Pd. by Atty.
4-27-94
by
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Deputy Sheriff
Sworn and subscribed to before Ire
this ..1.rL day of
19 Cfq-
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CBRTIFlCATB OF SBRVICB
I, JAMES R. CLIPPINGER, do hereby certify that I have this
date forwarded the foregoing document in the United States mail,
first class, postage prepaid thereon, to the following person(s) :
David L. Lutz, Esquire
ANGINO AND ROVNER PC
4503 North Front Street
Harrisburg, PA 17110
Attorneys for Plaintiffs
DATED::, May 13, 1994
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REBBCCA and MICHAEL JCARNS, I
Minors, by and through I
their parents and natural I
guardians, DAVID and TAMMY I
JCARNS, Individually,
Plaintiffs
IN THE COURT OP COMMON PLEAS OP
CUMBERLAND COUNTY, PENNSYLVANIA
v.
NO. 94-1858 CIVIL TBRM
CIVIL ACTION - LAW
JAMBS L. TAYLOR, III,
Defendant
v.
TAMMY JCARNS,
Additional Defendant
IN RE I MINOR'S SETTLEMENT
ORDER OP COURT
AND NOW, this 16th day of Pebruary, 1995, upon
consideration of the Petition for Approval of Minor Plaintiff
Rebecca Xarns' Compromised Settlement and Distribution of
Proceeds, and following a hearing, the proposed settlement and
distribution is approved, and it is hereby ordered and decreed
that the sum of $8,050.00 received by the parents and natural
guardians of Rebecca Xarns pursuant to the settlement be
deposited in the Parmers Trust Bank in a deposit account insured
by the federal government in the name of the minor. No
withdrawal may be made from any such account until the minor
attains her majority except as authorized by prior Order of
Court. Proof of the deposit shall be promptly filed of record.
The account shall be insured by the federal government.
A ...
By the Court,
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David L. Lutz, Esquire - c~ FlA<:ouLftj. ;I./II,/q".
Counsel for Plaintiffs 0 0 ..A. f.
James R. Clippinger, Esquire
Counsel for Defendant
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Paul W. Grego, Esquire _u
Counsel for Additional Defendan~
parmers Trust Bank - ~""d'd rC".....af, .:G- :b~ J.~, l'~.
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REBBCCA and MICHABL ltARNS,
Minors, by and through
their parents and natural
guardians, DAVID and TAMMY
ltARNS, Individually,
Plaintiffs
IN THE COURT 01' COMMON PLEAS 01'
CUMBBRLAND COUNTY, PBNNSYLVANIA
v.
NO. 94-1858 CIVIL TERM
JAMBS L. TAYLOR, III,
Defendant
CIVIL ACTION - LAW
v.
TAMMY ltARNS,
Additional Defendant
IN RE I MINOR'S SETTLEMENT
ORDER OP COURT
AND NOW, this 16th day of Pebruary, 1995, upon
consideration of the Petition for Approval of Minor Plaintiff
Michael Karns' Compromised Settlement and Distribution of
Proceeds, and following a hearing, the proposed settlement and
distribution is approved, and it is hereby ordered and decreed
that the sum of $12,600.00 received by the parents and natural
guardians of Michael Karns pursuant to the settlement be
deposited in the Parmers Trust Bank in a deposit account insured
by the federal government in the name of the minor. No
withdrawal may be made from any such account until the minor
attains his majority except as authorized by prior Order of
Court. Proof of the deposit shall be promptly filed of record.
The account shall be insured by the federal government.
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FE8 16 10 02 AH '95
.
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Of hl[ f ,rTHON~UhY
CUI46[{lLlliO C~,INlY
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By the Court,
David L. Lutz, Bsquire
Counsel for Plaintiffs
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James R. Clippinger, Bsquire
Counsel for Defendant
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b,@,
Paul W.
Counsel
Grego, Bsquire
for Additional Defendan
Trust Bank ~ C~~ f..A..........C.C.~ :t.,- ~l,.f ~, e~. .:J-Il..~qf.
Parmers
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REBECCA and MICHAEL KARNS,
Minors, by and through their :
parents and natural guardians,:
DAVID and TAMMY KARNS, :
Individually,
Plaintiffs
IN THE COURT OF COMMON PLEAS
CUMBERLAND COUNTY, PENNSYLVANIA
CIVIL ACTION - LAW
NO. 94 1858 civil
vs.
:
.
.
JAMES L. TAYLOR, III,
Defendant
JURY TRIAL DEMANDED
PRAECIPE TO DISCONTINUE
To the Prothonotary:
Please mark 'the above-captioned matter settled and
discontinued.
ANGINO & ROVNER, P.C.
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~<lvid L. Lutz
J.D. #36956
4503 N. Front Street
Harrisburg, PA 17110
(717) 238-6791
Counsel for Plaintiffs
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co Caldwell & Kearns
James Clippinger, Esquire
3631 North Front Street
Harrisburg, PA 17110
Post & Schell
Paul Grego, Esquire
101 N Front st
HarriSburg, PA 17101
62088/MTG
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