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April L. StranQ-Kutay, I.quire
ID # 4672S
ClOI.DIIUO, ~IIIIUI I ..IPIUUI, P.C.
3201 Market Street
P.O. Box 126B
Harri.burQ, PA 17108-1268
(717) 234-4161
'ax (717) 234-6810
Attorney for Plaintiff
JOHN TAYLOR AND MARY BREHM
individually and as parents
and Natural Guardians of
DOUGLAS TAYLOR, a minor,
Plaintiffs
IN THE COURT OF COMMON PLEAS
CUMBERLAND COUNTY, PA.
NO. 1':/- .33 d J- (i' L~~( \ -) lA-,r--
vs.
CIVIL ACTION - LAW
WAYNE SOUDER,
Defendant J
AND NOW, this~day of
.
.
, 1995, in consideration of
the facts set forth in the within Petition for Minor Settlement
and Distribution of Proceeds, it is hereby ordered and decreed
that the settlement in the amount of $100,000 is approved and
distribution is authorized as set forth below:
Settlement
$100,000.00
30,000.00
less counsel fees of 30t
Costs incurred:
1,132.80
$20,262.00 (present dollars
$20,000)
Annuity Payment (3/2/96)
Annuity Payment (3/2/2003)
$77,654.00 (present dollars
$48,922.70)
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April L. 8tran;-Kutay, .aquira
ID , 46728
GOLDIIIIRG, IM!IIIIIJI II IIIPKaII, ..C.
3201 Markat Street
P.O. lox 1268
Harriabur;. PA 17108-1268
(717) 234-4161
Fax (717) 234-6810
Attornay for Plaintiff
JOHN TAYLOR AND MARY BREHM
individually and as parents
and Natural Guardians of
DOUGLAS TAYLOR, a minor,
Plaintiffs
IN THE COURT OF COMMON PLEAS
CUMBERLAND COUNTY, PA.
NO.
vs.
CIVIL ACTION - LAW
WAYNE SOUDER,
Defendant
PETITION ~OR APPROVAL O. MINOR SETTLBMBNT
AND NOW, come the petitioners, Mary Brehm and John Taylor,
by their attorneys, Goldberq, J<atzman & Shipman, P.C., and
respectfully represent as follows:
1. That the petitioners are adult individuals who were
formerly married and who are parents and natural guardians of
Douqlas Taylor. Mrs. Brehm currently resides at 430 Nealy Road,
Newville, PA and Mr. Taylor currently resides at 20 Stamy Road,
Newville, PA.
2. That on January 2, 1994, Douqlas Taylor (D.O. B.: March
2, 1978) was ridinq his bicycle when he was injured in a
collision with an automobile operated by Wayne Souder.
3. Mr. Souder's insurance company, Nationwide Insurance,
has offered the limits of Mr. Souder's automobile insurance
policy in the amount of $100,000 to settle this claim.
8.00
52.25
7.50
6.60
1.50
29.00
23.26
9.00
9.45
25.00
315 . 00
21.25
200.00
15.00
354.49
55.50
4. The underinsurance carrier, Astna Insurance company,
has qiven consent to settle the case with Nationwide.
5. The petitioners, atter consultation with counsel,
considers the otter ot settlement to be tair and reasonable and
in the child'S best interest.
6. The petitioners request the Court to approve
settlement and distributions as tollows:
less counsel fees of 30'
Costs incurred:
$100,000.00
30,000.00
1,132.80
Settlement
Accident Report
Medical Reports/Records
Medical Reports/Records
copy costs/enc. w/corres.
copy costs/pOlice report
Mileaqe/parkinq attendinq hearinq
Photoqraphs
overniqht Mail
Copy costs/police report/bills
Filinq fees
Expert fees/report
Medical Reports/Records
Expert Fees/Report
Travel expense
wm. sullivan Investiqation
Filinq Fee for Petition for
Minor Settlement
Annuity payment (costinq
$20,000 to be made on minor's 18th
birthday (3/2/96)
2/24/94
2/28/94
3/8/94
3/17/94
3/18/94
3/21/94
4/6/94
4/12/94
4/14/94
4/14/94
5/13/94
9/26/94
2/17/95
1/94
1/94
6/16/95
$20,262.00
Annuity Payment (costinq
$48,922.70 to be made on minor's 25th
birthday (3/2/2003)
$77,654.00
BY:~"';I' ~ J'~,~-y
Ap 1 L. st ang-Kutay,' Esquire
320E Market street
P.O. Box 1268
Harrisburg, PA 17108
ID# 46728
(717) 234-4161
Attorney for Plaintiffs
7. That petitioners request a decision from the Court
within the next 10 day period as Annuity rates as quoted above
are only guaranteed until June 23, 1995.
Respectfully submitted,
GOLDBERG, KATZMAN' SHIPMAN, P.C.
JOHN TAYLOR AND MARY BREHM
individually and as parents
and Natural Guardians of
DOUGLAS TAYLOR, a minor,
Plaintiffs
vs.
WAYNE SOUDER,
Defendant
~
AND NOW, this flday
JUri li;/gqCjd",
IN THE COURT OF COMMON PLEAS
CUMBERLAND COUNTY, PA.
NO. c,'J'j" 3 3 D 2.. (1;;J 'J./U.A~
CIVIL ACTION - LAW
ORDER
the facts set forth in the within petition for Minor Settlement
of June,
1995, in consideration of
and Distribution of Proceeds, it is hereby ordered and decreed
that a Hearing is scheduled for a'Jtid d , 1995.
/I tV f ;)d a. lit,
BY THE COURT:
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