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WIlHam 1', lJ"u81.,. J!"I'
Supremo C"urt l.lHJ7<J26
Dougllll, l>uUgllll &. l>uuglul
27 W,I1I8h Sl,
1'011 261
Carll.lo I'. 1701J
Tolephono 717-24J.1790
Teresa E, Roberts, individually and as
Administratrix of the Estate of John J,
Roberts, deceased
In the Court of ommon Pleas 0
Cumberland County Pennsylvania
Orphans Court Division
PETITIONERS
VS
No. 1994- roLft1
tWJ TL-i1vv'
Penn State College of Medicine,
University Hospital, The Milton 5,
Hershey Medical Center
Petition lor Settlement Approval
Civil Action Law
RESPONDENT
Petition for Approval of
Compromise Settlement and Distribution
TO THE HONORABLE, THE JUDGES OF SAID COURT:
1. Your petitioner, Teresa E, Roberts, resides at 1466 Woods Rd" Lot 5,
Shippensburg, Cumberland County, Pennsylvania,
2, The petitioner was married to John J, Roberts, The decedent had no
children, Teresa E, Roberts is the sole surviving heir, At the time of his death, the
decedent was a resident of Cumberland County, Pennsylvania,
3. Your petitioner, Teresa E. Roberts, is the Administratrix of the Estate of
John J, Roberts, the petitioner's late husband, having been so appointed by the
Register of Wills of Cumberland County, Pennsylvania,
4. All debts incurred for the burial of John J, Roberts were paid personally
by Teresa E, Roberts, as well as all debts outstanding at the time of his death,
There are no outstanding debts owed by John J, Roberts and/or the Estate of
John Roberts. In the unlikely event any are discovered, the petitioner, Teresa E,
Roberts, hereby agrees to be personally responsible therefore,
5. John J, Roberts died fonowing gastric bypass surgery, which was
performed at the defendants institullon,
6, It was alleged that the decedent died, as a result of the negligence of the
agents of the defendant hospital, on September 8, 1990,
7, Negligence and liability for the death of John J, Roberts has been denied
by the defendant, and said defendant continues to deny liabillly therefore,
8, To sellle, what is a disputed claim, the plaintiff has agreed to accept
$500,000.00 in full and final settlement. $200,000.00 of which has been paid by the
defendant hospital and $300,000,00 of which wi\1 be paid by the Pennsylvania
Medical Catastrophic Loss Fund on or about December 31,1995,
9, Extensive preparations were made for the litigation of this matter which
was scheduled to occur on October 31st, 1994, in the Court of Common Pleas of
Dauphin County, Pennsylvania, Agreement to setlle was reached approximately
2 weeks before trial.
10, Teresa E, Roberts, has agreed upon a contingent fee of 33-1/3'70 of any
recovery in this mailer as wen as reimbursement of any costs advanced by the
Law Firm of Douglas, Douglas & Douglas,
11. Your petitioner, Teresa E, Roberts, requests that the fonowing distribution
be made for the wrongful death of her husband:
Teresa E, Roberts
$330,426,69
$166,666,66
$2,906,65
Douglas, Douglas & Douglas
Douglas, Douglas & Douglas
(Advanced costs)
WHEREFORE, it is prayed that the aforesaid settlement of $500,000,00, and the
proposed distribution, be approved,
DOUGLAS, DOUGLAS & DOUGLAS
By\"lJt~ Q~ P
William p, Douglas, Esq,
Attorney for the Petitioner
November 14, 1994
There are no outstanding debts owed by John J, Roberts and/or the Estate of
John Roberts. In the unlikely event any are discovered, the petitioner, Teresa E,
Roberts, hereby agrees to be personally responsible therefore,
5, John J, Roberts died following gastric bypass surgery, which was
performed at the defendants in~titution,
6, It was alleged that the decedent died, as a result of the negligence of the
agents of the defendant hospital, on September 8,1990,
7, Negligence and liability for the death of John J, Roberts has been denied
by the defendant, and said defendant continues to deny liability therefore,
8, To settle, what is a disputed claim, the plaintiff has agreed to accept
$500,000,00 in full and final settlement. $200,000,00 of which has been paid by the
defendant hospital and $300,000.00 of which will be paid by the Pennsylvania
Medical Catastrophic Loss Fund on or about December 31,1995,
9, Extensive preparations were made for the litigation of this matter which
was scheduled to occur on October 31st, 1994, in the Court of Common Pleas of
Dauphin County, Pennsylvania, Agre~ment to settle was reached approximately
2 weeks before trial.
10, Teresa E, Roberts, has agreed upon a contingent fee of 33-1/3% of any
recovery in this matter as well as reimbursement of any costs advanced by the
Law Firm of Douglas, Douglas & Douglas,
11. Your petitioner, Teresa E. Roberts, requests that the following distribution
be made for the wrongful death of her husband:
Teresa E, Roberts
$330,426.69
$166,666,66
$2,906.65
Douglas, Douglas & Douglas
Douglas, Douglas & Douglas
(Advanced costs)
WHEREFORE, it is prayed that the aforesaid settlement of $500,000,00, and the
proposed distribution, be approved,
DOUGLAS, DOUGLAS & DOUGLAS
By
~ -"
William p, Douglas, Esq, i
Attorney for the Petitione
November 14, 1994