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Home My WebLink About02-3247Patricia Cugini, Plaintiff vs. Mark Reisinger, Heidi Reisinger, Defendants IN THE COURT OF COMMON PLEAS CU~5~ERLAND COUNTY, PENNSYLVANIA CIVIL ACTION PERSONAL INJURY JURY TRIAL DEMANDED PRAECIPE FOR WRIT OF SU~ONS TO THE PROTHONOTARY: Please issue a Writ of Summons on the above named Defendants. Defendants, Mark Reisinger and Heidi Reisinger, have the following addresses: Mark & Heidi Reisinger 1266 High Street Boiling Springs, PA 17007 Date: 7' Respectfully submitted, a lin/L~. M~rkley, Esquire 219~/4~arket Street, Aztec Building Ca~p Hill, Pennsylvania 17011-4706 ID# 84745 Tel. (717) 763-1800 SHERIFF'S RETURN - NOT FOUND CASE NO: 2002-03247 P COMMONWEALTH OF PENNSYLVANIA COUNTY OF CI/MBERLAiqD CUGINI PATRICIA VS REISINGER MARK ET AL R. duly sworn according to law, says, that inquiry for the within named defendant, REISINGER MARK Thomas Kline ,Sheriff or Deputy Sheriff, who being he made a diligent search and DEFENDANT but was unable to locate Him in his bailiwick. He therefore returns the WRIT OF SUMMONS , , NOT FOUND , as to the within named DEFENDANT REISINGER MARK 1266 HIGH STREET BOILING SPRINGS IS VACANT. Sheriff's Costs: Docketing 18.00 Service 4.83 Not Found 5.00 Surcharge 10.00 .00 37,83 SO answe~r~: JJ ~ ~. Thomas Klin~~~ Sheriff of Cumberland County PATRICK LAUER JR 07/11/2002 Sworn and subscribed to before me this ~{ day of ~ ~b A.D. ProlYS~Sn6tar~ SHERIFF'S RETURN CASE NO: 2002-03247 P COMMONWEALTH OF PENNSYLVANIA COUNTY OF CUMBERLAND - NOT FOUND CUGINI PATRICIA VS REISINGER MARK ET AL R. Thomas Kline duly sworn according to law, inquiry for the within named defendant, DEFENDANT REISINGER HEIDI unable to locate Her WRIT OF SUMMONS ,Sheriff or Deputy Sheriff, who being says, that he made a diligent search and in his bailiwick. He therefore returns but was the the within named DEFENDANT , NOT FOUND , as to REISINGER HEIDI 1266 HIGH STREET BOILING SPRINGS IS VACANT. Sheriff's Costs: Docketing 6.00 Service .00 Not Found 5.00 Surcharge 10.00 .00 21.00 So answers: ~/ ..... ~ ~. Thomas Kll~e~ Sheriff of Cumberland County PATRICK LAUER JR 07/11/2002 Sworn and subscribed to before me this ~ day of ~ A.D. ary Commonwealth of Pennsylvania County of Cumberland WRIT OF SUMMONS PATRICIA CUGINI Plaintiff Vs. MARK REISINGER HEIDI REISINGER 1266 HIGH STREET BOILING SPRINGS, PA 17007 Defendant Court of Common Pleas No. 02-3247 CIVIL TERM In CivilAction-Law To MARK REISINGER AND HEIDI REISINGER You are hereby notified that PATRICIA CUGINI, the Plaintiff has / have commenced an action in Civil Action-Law against you which you are required to defend or a default judgment may be entered against you. (SEAL) Date JULY 9, 2002 CURTIS R. LONG Prothonotary Deputy Attorney: Name: MARLIN L. MARKLEY, ESQUIRE Address: 2108 MARKET STREET AZTEC BUILDING CAMP HILL, PA 17011-4706 Attorney for: Plaintiff Telephone: 717-763-1800 Supreme Court ID No. 84745 TRUE COPY FROM RECORD Im Tim~mony wP, m'8oL i h,m'e unto s~ my hand Commonwealth of Pennsylvania County of Cumberland WRIT OF SUMMONS PATRICIA CUGINI Plaintiff Vs. MARK REISINGER HEIDI REISINGER 1266 HIGH STREET BOILING SPRINGS, PA 17007 Defendant Court of Common Pleas No. 02-3247 CIVIL TERM In CivilAction-Law To MARK REISINGER AND HEIDI REISINGER You are hereby notified that PATRICIA CUGINI, the Plaintiff has / have commenced an action in Civil Action-Law against you which you are required to defend or a default judgment may be entered against you. (SEAL) Date JULY 9, 2002 CURTIS R. LONG Prothonotary c.~By _ Z~_~_r2.~ ~_. ~.C~~ Deputy Attorney: Name: MARLIN L. MARKLEY, ESQUIRE Address: 2108 MARKET STREET AZTEC BUILDING CAMP HILL, PA 17011-4706 Attorney for: Plaintiff Telephone: 717-763-1800 Supreme Court ID No. 84745 TRUE COPY FROM RECORD la Toeti, medly whB,~'aof, I h~'e unto sat my hafld Commonwealth of Pennsylvania County of Cumberland WRIT OF SUMMONS PATRICIA CUGINI Plaintiff Vs. MARK REISINGER HEIDI REISINGER 1266 HIGH STREET BOILING SPRINGS, PA 17007 Defendant Court of Common Pleas No. 02-3247 CIVIL TERM In CivilAction-Law To MARK REISINGER AND HEIDI REISINGER You are hereby notified that PATRICIA CUGINI, the Plaintiffhas / have commenced an action in Civil Action-Law against you which you are required to defend or a default judgment may be entered against you. (SEAL) Date JULY 9, 2002 CURTIS R. LONG Prothonotary Deputy Attorney: Name: MARLIN L. MARKLEY, ESQUIRE Address: 2108 MARKET STREET AZTEC BUILDING CAMP HILL, PA 17011-4706 Attorney for: Plaintiff Telephone: 71%763-1800 Supreme Court ID No. 84745 Patricia Cugini, Plaintiff vs. Mark Reisinger, Heidi Reisinger, Defendants IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA NO. 02-3247 CIVIL ACTION - LAW PERSONAL INJURY JURY TRIAL DEMANDED PRAECIPE TO AN~.ND_ WRIT OF SL~NR TO THE PROTHONOTARY: Please amend the caption on the above-mentioned action to read as follows: Samantha Cugini, a Minor, by Patricia Cugini, Guardian Plaintiff, vs. Michael Regel, and, Heidi Regel, Defendants IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA NO. 02-3247 CIVIL ACTION - LAW PERSONAL INJURY JURY TRIAL DEMANDED The Defendants amended address' are: Michael Regel 1267 High Street Boiling Springs, PA 17007 Heidi Regel 1267 High Street Boiling Springs, PA 17007 A corrected Praecipe For Writ of Summons is attached and included herein. Respectfully submitted, Marlin L. - · Markley, Esquire 2108 Market Street, Aztec Building Camp Hill, Pennsylvania 17011-4706 ID# 84745 Tel. (717) 763-1800 Samantha Cugini, a Minor, by Patricia Cugini, Guardian Plaintiff, VS. Michael Regel, and, Heidi Regel, Defendants IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA NO. 02-3247 CIVIL ACTION - LAW PERSONAL INJURY JURY TRIAL DEMANDED AMENDED PRAECIPE FOR WRIT OF S~MON~; TO THE PROTHONOTARY: Please issue a Writ of Summons on the above named Defendants. Defendants, Michael Regel, and Heidi Regel, have the following addresses: Michael Regel 1267 High Street Boiling Springs, PA 17007 Date: Heidi Regel 1267 High Street Boiling Springs, PA 17007 'Respectfully submitted, r~fn ~. Ma~kley, Esquire 2108 Market Street, Aztec Building Camp Hill, Pennsylvania 17011-4706 ID# 84745 Tel. (717) 763-1800 Commonwealth of Pennsylvania County of Cumberland WRIT OF SUMMONS Samantha Cugini, a minor by Patricia Cugini, guardian Plaintiff Vs. Michael Regel and Heidi Regel 1267 High Street Boiling Springs, PA 17007 Defendant Court of Common Pleas No. 02-3247 In CivilAction-Law To Michael Regel and Heidi Regel You are hereby notified that Samantha Cugini a minor, by Patricia Cugini, Guardian the Plaintiffhas / have commenced an action in Civil Action-Law against you which you are required to defend or a default judgment may be entered against you. (SEA[) Date August 20, 2002 Deputy Attorney: Name: Marlin L. Markley, Esq. Address: 2108 Market Street, Aztec Building Camp Hill PA 17011-4706 Attorney for: Plaintiff Telephone: 7177631800 Supreme Court ID No. 84745 ]'RUE COPy FROM RECORD m Testimony w~,oreof, I ~ere unto seI my and the .~sea/.of said C a hand rh~ ' .day o ! ts~e,..~ rothnnmarv~'T'- SHERIFF'S RETURN - REGULAR CASE NO: 2002-03247 P COMMONWEALTH OF PENNSYLVANIA COI/NTY OF CUMBERLAND CUGINI PATRICIA VS REISINGER MARK ET AL ROBERT BITNER , Sheriff or Deputy Sheriff of Cumberland County, Pennsylvania, who being duly sworn according to law, says, the within WRIT OF SUMMONS was served upon REGEL MICHAEL the DEFENDANT at 1730:00 HOURS, at 1267 HIGH STREET BOILING SPRINGS, PA 17007 HEIDI REGEL, WIFE on the 21st day of August 2002 by handing to a true and attested copy of WRIT OF SUMMONS together with and at the same time directing Her attention to the contents thereof. Sheriff's Costs: Docketing Service Affidavit Surcharge 18 00 4 83 00 10 00 00 32 83 Sworn and Subscribed to before me this 3-~ day of ,~2~, ~t'7-~,f.t.~ ~ ~/-~d~ A.D. ~rbthonotary So Answers: R. Thomas Kline 08/22/2002 PATRICK LAUER JR SHERIFF'S RETURN CASE NO: 2002-03247 P COMMONWEALTH OF PENNSYLVANIA: COUNTY OF CUMBERLAND CUGINI PATRICIA VS REISINGER MARK ET AL - REGULAR ROBERT BITNER , Sheriff or Deputy Sheriff of Cumberland County, Pennsylvania, who being duly sworn according to law, says, the within WRIT OF SUMMONS was served upon REGEL HEIDI the DEFENDANT , at 1730:00 HOURS, on the 21st day of August at 1267 HIGH STREET , 2002 BOILING SPRINGS, PA 17007 HEIDI REGEL by handing to a true and attested copy of WRIT OF SUMMONS together with and at the same time directing Her attention to the contents thereof. Sheriff,s Costs: Docketing 6.00 Service .00 Affidavit .00 Surcharge 10.00 .00 16.00 Sworn and Subscribed to before me this ~ day of ~,4~-~ ~2_~ A.D. / ~-ro~honotar~ So Answers: R. Thomas Kline 08/22/2002 PATRICK LAUER JR I D'e--puty Sider[fi 2 Samantha Cugini, a Minor Patricia Cugini, Guardia Plaintiff VS. Michael Regel, and, Heidi Regel, Defen& PETITION TO COl To the Judges of Your ] The Petition of natural guardians, resp¢ 1. Samantl herein. Samantha Cugi 2. This act when a dog, owned by i The in Pennsylvania; B. Samant multiple 1 cm lacerati¢ other lacerations on the and instmcted to see permanent scarring, m C. by IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA NO. 02-3247 CIVIL ACTION - LAW This ac~ ion was brought on July 9, 2002 against Marc and Heidi Reisinger and .a Cugini sustained injuries to her arm, including a 3 cm laceration, and ns/puncture wounds through her forearm including small wounds and two flexor surface of her forearm. She was placed in a splint for her arm to heal, plastic surgeon regarding permanent sc3rcing. Forttmately there was no need for additional medical attention; ts PERSONAL INJURY JURY TRIAL DiEMANDED ~PROMISE ACTION~ ALLOW COUNSEL FEES AND EXPENSES~ AND DIRECT DISTRIBUTION tonorable Court: Samantha Cugini, Minor, by Patdcia and Steven Cugini, her parents and ctfully represent: ta Cugini, the Minor Plaintiff, is the daughter of Patricia Cugini, Petitioner fi is twelve years old, having been bom orr September 20, 1991. [on was brought to recover damages front an injury sustained by Samantha dichael and Heidi Regel attacked her: ar3' occurred on August 20, 2002 at 1267 High Street, Boiling Springs, later amended to Mich Exhibit "A"); D. The pti recover for injuries ret dog was able to extem whether Samantha sho 3. The pm the following terms as ~ A. Heidi m Thousand dollars ($5,0. B. Samant] and Michael Regel an charged or chargeable successors and assigm services, actions and ca 4. In view your Petitioner believe accepted and approved. 5. Your Pe minor in this action an percent (33 1/3%) of th, in the Contingent Fee reasonable ael and Heidi Regel (See Praecipe for Writ of Summons attached hereto as aciple question of law to be decided is whether a trespassing minor can eived by an unprovoked dog; the principle question of fact is whether the beyond the Regel's property, whether the dog was properly restrained, or ald have known to stay away from the dog. :ies to this action are willing to enter into. a compromise of the action upon nore specifically laid out in the Release (a~tached hereto as Exhibit "B"): td Michael Regel, or their agents, pays to Samantha Cugini the sum of Five )o.oo); ia Cugini forever release, discharge, and covenant to hold harmless Heidi t Allstate Insurance Company and any other person, firm or corporation with responsibility or liability, their heirs, administrators, executors, from any and all claims, demands, damages, costs, expenses, loss of ses of action. >f the uncertainty of securing a verdict in excess of the amount of $5,000.00, it is in the best interests of said Minor that the proposed settlement be [tioner has retained The Law Offices of Patrick F. Lauer, Jr., L.L.C. for the ~ requests a counsel fee in the amount equal to thirty-three and one-third ~ amount described in the above paragraph, or $1666.67 for services detailed Agreement (attached hereto as Exhibit "C"), which in my opinion is a fee. 6. Expem incurred on behalf of~ this action. 7. Expen: incurred on behalf of 8. Expe~ Carlisle Regional Meal 9. Expens Geisswein Plastic Sur 10. The n~ and is maintained and 11. Should and if a hearing is sch Plaintiff's counsel will es totaling $242.20 detailed in Exhibit "D" attached hereto have been fid minor by The Law Offices of Patrick l.,uer, Jr., L.L.C. in connection with :s totaling $48.99, detailed in Exhibit "E" attached hereto, have been fid minor by Patricia Cugini, in connection with this action. :s totaling $1814.17, detailed in Exhibit "F" attached hereto, payable to the cal Center, have been incurred by said minor in connection with this action; ~s totaling $84.00, detailed in Exhibit "G" attached hereto, payable to :fy have been incurred by said minor in connection with this action. balance payable to Samantha Cugini is $1143.97. Samantha resides with upported by her parents, Patricia Cugini, and Steve Cugini. fie Court deem it necessary to schedule a hearing to approve the settlement, xtuled, Samantha Cugini, and her parents, Patricia and Steven Cugini, and >e present at the hearing. WHEREFOR~ compromised settleme fired due the minor an~ to be deposited in the choosing, and no wit except as authorized Petitioner requests your Honorable Court to approve the Minor's I and authorize the payment of the fees and expenses above stated from the l direct payment of the net fund due the minor to be made to her guardian, or name of the minor in a savings accotmt of the guardian of said minor's adraw therefrom can be made until Samantha Cugini reaches majority, · the court. Respectfully submitted, ID# 84745 Tel. (717) 763-1800 a Min~ Patricia Cugini, Guard Plaintil VS. Michael Regel, and, Heidi Regel, Defend I verify that Fees And Expenses, herein are made subjo authorities. Date: : IN THE COURT OF COMMON PLEAS r, by : CUMBERLAI<D COUNTY, PENNSYLVANIA : In : : NO. 02-3247 : : : : CIVIL ACTION - LAW : : PERSONAL INJURY : JURY TRIAL DEMANDED VERIFICATION * statements made in this Petition To Compromise Action, Allow Counsel ad Direct Distribution are tree and correct. I understand that false statements :t to the penalties of 18 Pa. C.S. § 4904, :relating to unswom falsification to Patricia Cu~ni Patricia VS. Mark Reis Heidi Rei~ ugini, Plaintiff nger, inger, Defendants IN THE COURT OF COMMON PLEAS CUMBERIi~gD COUNTY, PENNSYLVANIA 0, CIVIL ~iTION - LAW TO THE P~ Plea Defendants addresses Mark & He 1266 High Boiling St Date: PERSON~25 INJI/RY JURY TRIAL DEMANDED PRAECIPE FOR WRIT OF SU~AWONR THONOTARY: e issue a Writ of Summons on the above named Defendar Mark Reisinger and Heidi Reisinger, have the follc Respectfully submitted, arlin ..... ey, Esquire 219~w~arket Street, Aztec Buildi Ca{tip Hill, Pennsylvania 17011-47 ID# 84745 Tel. (717) 763-1800 ti Reisinger Street ,rings, PA 17007 ts. wing ~g ]6 Patricia C1 vs. Mark Reisil Heidi Reit TO THE PR( Plea~ !1 as follows Samantha C~ Patricia C~ vs. Michael Re, Heidi Rege The Defend~ Michael Re 1267 High Boiling Sp A correcte herein. Lgini, : Plaintiff : : : : Lger, : .nger, : Defendants : : : IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, ?ENNSYLVlLNIA NO. 02-3247 CIVIL ACTION - LAW PERSONAL INJURY JURY TRIAL DEMANDED PRAECIPE TO AMENDWRIT OF SL%94ONS ?HONOTARY: amend the caption on the above-mentioned action to 'ini, : ~ Minor, by : lgini, : 3uardian : Plaintiff, : : : : ~el, and, : Defendants : : : IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA NO. 02-3247 CIVIL ACTION - LAW PERSONAL INJURY JURY TRIAL DEMANDED ~nts amended address' are: ~el =treet rings, PA 17007 1267 H~h Street Boil~n~ Spr~n~s~ PA 17007 Praecipe For Writ of Summons is attached and incl~ Respectfully submitted, Marlin L. Markley, Esquire 2108 Market Street, Aztec Buildir Camp Hill, Pennsylvania 17011-47( ID# 84745 Tel. (717) 763-1800 ~ead ~ed Date:~-/~ ~oo?~ ~ Samantha ugini, a Minor, by Patricia ugini, ~ Guardian Plaintiff, VS. Michael R~gel, and, Heidi Regal, Defendants TO THE PR( Plea. Defendants addresses: Michael RE ~el 1267 High ~treet Boiling S~rings, Date: ~9. /~ ' 20~ Z IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA NO. 02-3247 CIVIL ACTION - LAW PERSONAL INJURY JURY TRIAL DEMANDED i~_MENDED PRAECIPE FORWRIT OF S~NS THONOTARY: e issue a Writ of Summons on the above named Defendan Michael Regel, and Heidi Regel, have the follo Heidi Regel 12,57 High Street PA 17007 Boiling Springs, PA 17007 'Respectfully submitted, Camp Hill, Pennsylvania 17011-47~ ID# 84745 Tel. (717) 763-1800 ~ing Lg ~6 PARENTS RELEASE AND INDEMNITY AGREEMENT CLAIM # $131801648B19 In consideration of the payment, to the undersigned, of the sum of $ 5,000.00 the receipt of which is hereby acknowledged, the undersigned parent s and guardian s of Samantha Cuqini, a minor, do __ forever release, discharge and coveqant to hold harmless Heidi & Michael Reoel & Allstate Insurance Company. and any other person, firm oricorporation charged or chargeable with responsibility or liability, their heirs, administrators, executors, sur~essors and assigns, from any and all claims, demands, damages, costs, expenses, loss of services, actions and causes of action, belonging to the said minor or to the undersigned arising out of any act or occurrence up to the present time, and particularly on account of ail personal injury, disability, property damage, loss or damages of any kind sustained or that may hereafter be sustained by the said minor or by the undeCsigned, in consequence of an accident that occurred on or about the 20th day of April, 2002 at or near 126~ Hiqh St, Boiling SprinRs, Pa. The undersigned do hereby bind ourselves and our heirs, administrators, executors, successors and assigns to repay to the said Heidi & Michael ReRel & Allstate InsUrance Company and to any other person, firm or corporation charged with responsibility or liability, their heirs, administrators, executors, successors and assigns, any additional sum of money that any of them may hereafter be compelled to pay on account of the injuries to said minor because of the said accident. To procure the payment of th~ said sum, we hereby declare: that no representations about the nature and extent of the said injuries, dis[abilities or damages made by any physician, attorney or agent of any party released, nor any representations regarding the nature and extent of legal liability or financial responsibility of any of the parties releasedl, have induced u~s to make this release and indemnity agreement; that in determining the amount of th~ said sum there has been taken into consideration not only the ascertained injuries, disabilities and damages, but also the possibility that the injudes sustained may be permanent and progressive and recovery therefrom uncertain and indefinite, so that consequences not now anticipated may result from the said accident. The undersigned agree agreement, that it shall apply resulting from the said accidE The undersigned understam __ of said accident and that sai claims for damages that said through personal represental , as a further consideration and inducement for this release and indemnity to all unknown and unanticipated injures and damages directly and indirectly nt, as well as to those now disclosed. that the parties hereby released admit no liability of any sort by reason payment in compromise is made to terminate further controversy respecting all minor or the undersigned have heretofore assertad or might personally or ves hereafter assert because of said accident. Signed and sealed this day of 20 In the presence of .(SEAL) STATE OF ~ COUNTY OF On this day ~f.__ foregoing instrument, and aci My commission expires , to me known to be the person :nowledged that __ executed the same as .__ (SEAL) , before me personally appeared who executed the free act and deed, NOTARY PUBLIC C106-4, Parents Release & Indemnity rev.08/16/01 CO~TIN~TFEE~EMENT J ~THIS AGREEMENT, entered into this ~ day of , ~ by and between The Law ~ffices of Patrick F. Lauer, Jr. (Attorney) and ~,~% ~(~ (Client) is entered into with the ~express understanding that Parties intend to be legally bound thereby and for the following considerations 1. Attorney agrees to represent client, with regards to a personal inju~ action against ~ Ju~ ~/~ ~f~_ arising out of ~n accident which took place on ~r about ~_~7_ 2. Attorney, for the consideration hereinafter stipulated, agrees to act as attorney in negotiation for settlement and, if a settlement is not effected, in bringing and prosecuting an action against the above named person or persons. In consideration for such services ~t i? agreed that attorneys shall reueiye ,a s~m of money equal t~th~rty-three and one/third percent (33 1/3%) of whatever amountlis recovered prior to the initiation of a law suit, and the sum ofI. forty percent (40%) of any amount recovered after the initiation ~f a law suit. A law suit is deemed to be initiated upon the filing of a Complaint or Writ of Summons or 'any other action which cgnstitutes the initiation of a legal action in the appropriate court holding jurisdiction over this particular action. 3. If after the trial of the case, an appeal should be taken to a higher cou~t, an additional four percent (4%) shall be payable on account of the appeal. 4. Said ifee shall be deducted from the gross settlement receipt after Which all expenses incurred by Attorney in the preparation ofl the law suit or in its prosecution shall be deducted, and t~e balance shall be paid to Client. 5. Ail e~penses incurred by Attorney, including, but not limited to, .1~ distance p~one charges, photocopying, medical records acquisition fees, medical expert fees, f~l~ng fees, court reporter services, etc., are the obligation of Client. Such obligations sh~ll adhere to the Client no matter if an offer of settlement ha~i been proffered or the amount of the recovery. Attorney may b~l for recovery of such expenses at any time after a recovery 1~ assured or termination of this contract. Accordingly, Attorney shall consult with Client prior to incurring any extraordinary or unusual expenses in the conduct of the case. Attorney does r~serve the right to require prel{m{nary expenses to be born by the Client such as expert report needed to access the possibility of claim. 6. If aft, the case lacks 1 from the case u a thorough investigation, Attorney believes that ~erit, Attorney reserves have the right to withdraw ~on written notification. 7. Should client terminate this contract with Attorney at ~'anytime prior to an offer of settlement, all expenses incurred by Attorney, including, but not limited to, long distance phone charges, photoc0pying, medical records acquisition fees, medical expert fees, filing fees, court reporter services, etc., will become due immediately and shall be paid by Client to Attorney within fifteen (15) days of the termination of the contract. 8. Should the Client terminate this contract with Attorney after an offer of settlement has been proposed, Attorney shall be entitled to twen of the case, eve retain other cot recovery if sai¢ of any offer ma( IN WITNESS this instrument written. ~y-five percent (25%) of said offer upon settlement ,n ~f Client retains other counsel. Should Client .nsel, Attorney shall be entitled to quantum merit L amount is greater than twenty-five percent (25%) Le while the contract with Attorney was in effect. ~HEREOF, the Parties hereto have set their hands to in execution thereof, the day and year first above Client LAW OFFICES OF PATRICK F. LAUER, JR. 2108 MARKET STREET CAMP HILL, PA 17011 PATRICIA CUGINI & SAMANTHA CUGINI 1301 W. TRINDLE ROAD CARLISLE, PA 17013 PF, R~ON~,I, TNJIIRY ~ETTT,EMENT OCTOBER 27, 20~ ~LSTATE ~S~CE CO~ ~C~L & ~I ~GEL $5,000.00 F.. ~ PF, N,~ i~,~q .. 33 1/3% CONTINGENT FEE MEDICAL RECORDS- CARLISLE HOSPITAL MEDICAL RECORDS- GIESSWEIN PLASTIC SURGERY FILING FEE - wRrr OF SUMMONS SHERIFF SERVICE OF wP, Ir OF SUMMONS, CUMBERLAND CTY. SUBPOENA PHOTOCOPYING - 94 COPIES ~ $.20 A COPY POSTAGE $1,666.67 $ 33.36 $ 25.O0 $ 50.5O $ 107.66 $ 2.00 $ 18.80 $ 4.88 TOTAL EXPENSES i TOTAL AMOUNT To CLIENT $1,908.87 $3,091.13 Rife AID It's not just a store. It's a solution.* RITE AIO #3613, 5260 SIHPSON FERRY RO HECHANI¢SBURG, PA 717 766-8732 Store # 136t3 WINOSOR PARK PLAZA S260 SI IPSON PERRY ROAO ¼ECHAHI :SBURG, PA 17055 (717) ~6-8732 Regist~ r jrJ. Transaction /~18046 Cashtm #36134667 4/24/02 2=36PN 1 SC~ NNEO pHARHAC'/ 10.00 . RX~! 296707 I Items Subtotal 10.00 Tax .00 To,al 10.00 CASH PAYNENT 10.00 Tendered 10.00 Cash C -',a~-.~e ,00 Inter'et Refills at R~tea~ :os ~ov~red by drugstore.com 1-800~RITEAIO for customer service RITE AID It's not just a store. It's a solution:' INTERNET~ REFILLS~'~ w w., md. om Store ~01074 1137 HAR~ET STREET LEHOYNE, PA 17043 (717) 737-3359 Register #1 Transaction #425080 Cashier //1.0746789 4/20/02 8:59P~ :~ 1 SCANHEO PMARHAC¥ 8.9S RX#531683 I Items Subtotsl 8.9~ Tsx .CC Total 8.9~ *PAID BY VISA* 8.9~ VISA card * ~YJ(XXXXXXXXXX2741 Exp 1/91/04 App # AVTO Ref # 020094 Card Present Tendered 8.~! Cash Change Internet Refills at RiteAid.oom powered by dru~store.com ~ 1-800-RITEAIO for customer service m f NOV-22-2002 FRI 03:18 PM P~T/ENT FIN~NOI~LS FRX NO, 7172188858 P, 04/05 11/22/02 PAGE 002 HEALTH MANAGEMENT ASSOCIATES DA17 COID: 858 CARLISLE REGIONAL MED CENTER AS OF 11/21/02 PATIENT= CUGINI, SAMANTHA J F/C: P P/T: E DSC CODE: 01 A/C: 9223406 ADMISSION: 04/20/02 DISCHARGE: 04/20/02 CHG DATE DPT REV BAT# HCPC NlM2 CHGCD DESCRIPTION QTY AMOUNT 04/20/02 480 450 6 04/20/02 412 250 5202 04/20/02 412 250 5~02 04/20/02 412 250 5~02 04/20/02 412 250 5~02 04/20/02 412 250 5202 04/20/02 428 320 8 73090 RT 97001 ER PROCED ZNTEP. M=D 28512 MYDROCODONE BIT 5-50 10286 LIDOCAINE HCL 1% MPF 01730 AUGMENTIN 500MG TAB 02850 BACITRACi]N OI~T 15GM 02850 ~ACITRACIN OINT 15GM 73090 FOREARM 2V 648.95 5.04 23i.30 16~.94 5.70 5.70 209,84 TOTAL CHARGES 1,604~33 TOTAL: CASH > 0.00 ADJUSTMENTS > 0.00 BALANCE > 1,604~33 SELECT: REV= * D~PT~ * CHGCD~ * DAT~/MDCY= * TO/MDCY~ * C~D:I~DAR,~=PAT 41-SUMMARY, 5-TO~,6~END, 7-RETURN, 8=BACKWARD ENTER=FORWARD ~ r NOV-22-2002 F~I 93:17 PN PRTIENT F]NRNO~RLS FR× NO, 7172188858 P, 05/05 11/22/02 PAGE 00~ HEALTH MANAGEMENT ASSOCIATES DA17 COID:~ 858 CARLISLE R~GIONAL MED CENTER AS OF 11/21/~2 PATIENT: CUGINI, SAMANTHA J F/C: P P/T: O DSC COD~: 01 A/C: 7190944 ADMISSION: 08/06/02 DISCHARGE: 08/0~/02 CHG DATE DPT REV BAT# HCPC M1M2 CHGCD DESCRIPTION QTY AMOUNT 08/0~/02 428 320 8 73140 ~5 73140 FINGER(S) MIN 2V i 209.84 TOTAL CHARGES 209 TOTAL: CASH ~ 0.00 ADJUSTMENTS > 0.00 BALANCZ > 209 SELECT: REV= * D~DT= * CHGOD- * DATE/MDCY= * TO/MDCY= * CMD:i=DA~2-PAT 4~SUMI6ARY,5=TOp, 6=END, 7-RETURN.,8-BACKWARD ENTER=FOR .84 ~ARD .~ledger] Giesswein Plastic Surgery PATIENT LEDGER PAGE: 1 GUARANTOR #:052835-00 PATIENT #:052835-00 ASSIGNMENT :yes-no LAST PAY DT:**/**/** ~ LAST PAY $ : 0.00i LeT PLN PAY:06/04/02 ~ LST PLAN $ : 139.05 AT COLLECTN: 30.00i INSURED #1 Cugini, Samantha J 1301 W Trindle Road Carlisle, PA 17013 PLAN 1 :Health Assurance POLICY #:17348464704 GROUP #:1005351001 Cugini, Samantha J Cugini, Samantha J 1301 W Trindle Road Carlisle, PA 17013 EMPLOYER NAME: REF DOCTOR:dru Unknown, PLAN 2 : FR:**/**/** POLICY #: TO:**/**/** GROUP #: Doctor INSURED #2 DATE BILL # DR. ~PT/PROCEDURE CHECK #:PLAN 04/22/02 154793 png 9243-Office Consultation - Level 3 06/04/02 AYMENT-THANK YOU 906737:Health America 06/04/02 riteoff:Health America 10/04/02 ove To Collection Bill Notes: cvd info today 5-15-02 Payment Notes: 5.00 copay First Form Printed for Health Assurance on 05/15/02 for Last Form Printed for Health Assurance on 05/15/02 for OFFICE: gps x:881.10-Complicated Forea 04/29/02 155340 png 9213-Office Visit - Level 3 06/04/02 AYMENT-THANK YOU 906737:Health America 06/04/02 riteoff:Health America 10/04/02 ove To Collection Bill Notes: cvd ins info today 5-15-02 Payment Notes: 5.00 copay First Form Printed for Health Assurance on 05/15/02 for Last Form Printed for Health Assurance on 05/15/02 for OFFICE: gps x:881.10-Complicated Forea Last statement printe~ on 10/01/02 for 30.00 Credit status: Collection set on 10/03/02 ! Balance for Cugini, Samantha J Balance for Plan CURRENT Patient 0.00 Plan 0.00 031-060 061-090 091-120 120+ 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 DATE :11/25/02 D.O.B:09/20/91 CHART: HOME :717-69~-1477 EMRG :717-79~-1843 EMPLY: | S S #: ~ CLASS:hmo D~:png FR: TO: POS CHARGE o 82.00 03.32- 63.68- 15.00- 182.0 E?n 182.00 E?n 0.00 ...... o 70.00 35.73- 19.27- 15.00- 70.0 E?n 70.00 E?n 0.00 ...... 0.00 0.00 ~[ledger] Giesswein Plastic Surgery PATIENT LEDGER PAGE: 1 GUARANTOR #:052835-00 PATIENT #:052835-00 ASSIGNMENT :yes-no LAST PAY DT:**/**/** LAST PAY $ : 0.00 LST PLN PAY:06/04/02 LST PLAN $ : 139.05 AT COLLECTN: 30.00 INSURED #1 Cugini, Samantha J 1301 W Trindle Road Carlisle, PA 17013 PLAN 1 :Health Assura POLICY #:17348464704 GROUP #:1005351001 DATE BILL # DR. 11/14/02 166308 png I Bill Notes: OFFICE: gps nee cugini, Samantha J Cugini, Samantha J 1301 W Trindle Road Carlisle, PA 17013 EMPLOYER NAME: REF DOCTOR:dru Unknown, ]Doctor ~NSURED #2 PLAN 2 : FR:**/**/** POLICY #: TO:**/**/** GROUP #: qPT/PROCEDURE CHECK #:PLAN 9213-office Visit - Level 3 t will send to.homeowners ins td 11-15-02 x:881.10-Compllcated Forea DATE :11/25/02 D.O.B:09/20/91 CHART: 717_69~_1477 HOME EMRG :717-795-1843 EMPLY: S S #: , CLASS:hmo D~:png Last statement printe¢ Credit status: Collect CURRENT Patient 70.00 Plan 0.00 on ~ion 10/01/02 for 30.00 set on 10/03/02 Balance for Cugini, Balance for Plan Samantha J 031-060 061-090 091-120 120+ 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 FR: TO: POS o 70.00 CHARGE 70.00 70.00 0.00 NOV 0 3 2003 Samantha Cugim, a Minor, by Patricia Cugini, Guardian Plaintiff, VS. Michael Regel, and, Heidi Regel, Defendants IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA NO. 02-3247 CIVIL ACTION - LAW PERSONAL INJURY JURY TRIAL DEMANDED APPROVAL OF COMPROMISE; ALLOWANCE OF COUNSEL FEES AND EXPENSES; DIRECTION OF DISTRIBUTION AND NOW, this ~ ° day of ~J0~.~r ,2003, it is so ordered that: 1. The pa~ies may compromise this action upon the terms of the proposed compromise set forth in the petition filed by Patricia Cugini on ~q.~_/t~ ~t~ . 2003. 2. Patricia Cugini, Guardian of Samantha Cugini, a minor, is authorized to pay the following counsel fees and expenses from the amount said minor is entitled to receive in this action: $1.~C~7 to The Law Offices of Patrick Lauer, Jr., L.L.C. for counsel fees; $242.20 to The Law Offices of Patrick Lauer, Jr., L.L.C. for expenses; $48.99 to Patricia Cugini to reimburse for medication purchases; $1814.17 to the Carlisle Regional Medical Center for payment for treatment; $84.00 to Geiswein Plastic Surgeon for payment for treatment. The balance of $ ! I ~ 2.97 remaining shall be paid either: A. __ to the guardian of said minor qualified to receive the same. Dpos -or- B. ited in the name of Samantha Cugini in a savings account of the guardian of said minor's choosing, and no withdraw therefrom can be made until Samantha Cugini reaches majority, except as authorized by the court. By The Court Distribution: 200, Bethlehem, PA 18017-2293 ,/fVlark and Heidi Regel 1267 High Street, Boiling Springs, PA 17007 Marlin L. Markley, Esquire ~ Law Offices of Patrick F. Lauer, Jr., L.L.C., 2108 Market Street, Camp Hill, /l~an Pennsylvania, 17011. a Phillips Allstate Insurance Company, Market Claim Office, 1655 Valley Center PKWY Suite Samantha Cugini, : a Minor, by : Patricia Cugini, : Guardian : Plaintiff, : VS. Michael Re~el, and, Heidi Re~el, : Defendants : IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTy, PENNSYLVANIA NO. 02-3247 CIVIL ACTION - LAW PERSONA~L INJURy JURY TRIAL DEM3~NDED PRAECIPE TO SETTLE, DISCONTINUe, TO THE PROTHONOTARY: Please mark the above captioned. discontinued, and ended AND ENM~ case and settled, Date: Respectfully submitted, ID# 84745 Tel. (717) 763-1800