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Home My WebLink About95-04524 . .' 2, Payment of expenses incurred in the resolution of these cases is authorized as reasonable and necessary, a, Filing Fee - Prothonotary (2 Actions) $ 91.00 b, Sheriff - Cumberland County $ 67,36 c, Sheriff. Lancaster County $ 61.00 d. Sheriff. Dauphin County $ 55,25 e, Police Report $ 8,00 f. Overnight mail and express services $ 130,00 g, Investigation services. Bruce Miller $1.635,08 TOTAL $2,047.69 3. The legal fees of Irwin, McKnight & Hughes in the following amounts are approved as follows: Estate of Ross D, Purdy......,..... $60,000,00 Estate of Valerie P,], Spurdon .. $60,000,00 TOTAL .........................,.......5120,000.00 c, From the Underinsured coverage provided by Nationwide Insurance, a copy of said releases Is attached hereto and Is marked as ExhibitlF", Ross Purdy Valerie P,J, Spurdon $200,000,00 $200,000.00 Each settlement represents the policy limits and together provide each Estate with: TOlnl Settlement Ross Purdy $500,000,00 Totnt Settlement Vnlerle P.J. Spurdon $500,000,00 10, The Inw firm hns In the course of settlemel1t of these cases incurred expenses which are reasonable nnd necessary nnd hnve been reimbursed by the Estates of Ross Purdy and Valerie P.J. Spurdon, n, Filing Fee. Prothonotary (2 Actions) $ 91.00 b, Sherin'. Cumberland County $ 67,36 c, Sherin'. Lancaster County $ 61.00 d, Sherin'. Dlluphln County $ 55.25 e, I'ollce Report $ 8.00 f, Overnight mnll nnd express services $ 130.00 g, Investlgntlon services. Bruce Miller $1.635,08 TOTAL 52,047.69 RELEA...~ AND SETTLEMENT OF CLA. · 71'1 AL 19915 ' , FOR THE SOLE CONSIDERATION oc..""..,..TWO"IlUNDRED"FIFTY",IUOUSI\ND"DOT.LARS.."",..,..,"'""....",..,..".. Dollars ($ ........250000......, ........,). ...........................................................................................0..................,."......".............,.....,',....," l/we"..,......,..ESWE. ,.EOB...R.OSS.. PURD'l......" ..,.. ......'".. ..,..',.., ,....,........",......,..," ......' ,....,..",.."""".."""""","",..,""""',.., ....'" ...... r".jding at,..........2..,SI:I1I:1o\1. ..Rond,.. ,Newville,.. ,PA., ~7241""....""..,.."""'" ",..",.., '....,..,..,.." ..,.. ,......"""".."..""..,",..,"',...... do hereby release, acquit and lorever discharge"....",touise..F..,tr.l.tt.",..,IV.illiLlm..,T,r,i.t,t..,..........,........"............,..,...... ,The ..Hart.f oJ:d..lns.urance.. Group.. and... the il:" res pec,tl. ve "agents,.."..,..,",...., ......", ....""....,..",..,....",.."..,..,..".., ...... Irom any and all actions, causes 01 action. claims and demands. damages, costs. loss 01 services. expenses and compensa- tion on account 01 or In any way growing out 01 any and all known and unknown personal injuries and property damage resulting or to result Irom an accident which occurred on or about,........",....AugU&t..25",..19,94......,..............,..,..,19........... and do hereby agree to indemnily and save harmle!s the said....,..,touise..P..,tdtt'j..,IH-ll-i,llm..,Tri,t't..................... Ihe,.1lart.ford..Insurl1nce..CI:oup..and",their..,t:espoo tiVe",I1Bllnts...............,............,...."......,'" ,..........,....".."..,........ Irom alllurther claims or demands, cost or e.~pense arising out 01 the injuries or damage sustained by me/us, It is lurther agreed that in the event other parties are responsible to me/us lor damages as a result 01 this accident. the e.~ecution 01 this agreement shall operate as a satislaction 01 my/our claim against such other parties to the extent 01 the pro rata share 01 the parties herein released, It 15 expressly warranted by me/us that no promise or Inducement has been o!fered e.~cept as herein set lorth; that this release Is executed without reliance upon any statement or representation 01 the person or parties released, or their representatives, concerning the nature and e.~tellt 01 the injuries, damages and/or legal liability therelor; that accept- ance 01 the consideration set lorth herein 15 in lull accord and satislaction 01 a disputed claim lor which liability is expressly denied. Signed and' sealed thls........,/./... .z:L...........,....day 01......... .................,.. ........h),l.llllll,l;....,.........., ................ ................,19, ,'), ?".., Address <00 '^' est ~,,{r~t sj., ,~~.!~~,!~..,..e.A..,..,\?.q,!.:;;, ESTATE OF ROSS DAV~~ ~Y B1;",..,'!IJ((;(,g:./;:~~,(!,................,........, DAVID L. PURDY, Adm strntor . ................................................ ..............................................................,............................." .....................,..........,..................,......................."................. STATE of..~,~,!\,?.l~,~,!!,)'~~......,....,..,} 'I'd' ss, COUNTY OF....,.."I,,!L,!..I;\H,!:,..,........,....,.., On this.....,..........U..,M..""....",......,..,day 01.........,',......,....",~!ll.m'!,L...."",..,....19,n...., belore me personallY appeared ..,~~HI?..~,:..,!:',~~,'!.,!,..f':,~,~,~.~~!1,~~,~,~~,~..,~,L..~,!!!!,..!~!!,~,~~,~..~.L,I\,~!!!1,',n.~,Y.~,d.,'~:,'!.!:~'J..,..,..,""",,',' .."" ........',' """,..""..,..".... to me known to be the person described herein. and who e.,ecuted the loregoing instrument. .lnci........!!!;!,...... acl<nowledged that....,\1!l........",voluntarily e.~ecuted the same, 'I. D Is.... Nr< . ~ '-(-:-' \.,J '-:"LiNoA'!:. CE~TRES. t\'.,';;~i';;~b'li~"N "~y'p~'bjiC"" Indlan..1. IndiBr\1 Counl"l M CemmlMIM E.rl'es Mnrr:h 23. 1I)Jft (R) AWF (Ol92u) FOnD LCoJ1J7 Ru. Prihttd III U. S. A. RELEA.....:: AND SETTLEMENT OF CLA..,. 717 AL 19914 ;.oOR THE SOLE CONSIDERATION of.."..,....XWO..lIUNOR.EO..,FIF,'I'i'..,TIIOUSANll"DOLLMS,..............,..............,...., Dollars ($, ..,..,250000....,.. ,....,..,), .............................................................................................,............................,........,..................., I/we....,........ EST.A:rE..FOR. ..VALER.IE.., E PiJ1DON,.., ........'.. ,..".... ..,..,..""..,..,......",...."...... ....,..,..........""..,",',....".... ,..','..,..,..,.. ..,...., residing at....,....,2"Station"aoad, ..Ncwvil1e,.,,,PA..17,241..,..........,,,..,,,,,,....,..,,,,..,,..,,..,..".."......"....,,,,..,,....,..,....,..,,,,....,,,.., do hereby release, acquit and forever discharge..".."Louisc..,F.. 'l'llI':i.'T..t.. ~1i,H,i,am..,Tr,Ht........".."....,....,..............,..,.., The...llart.ford..lnsurance...Grou(1..snd..,thoir,..respacti,vo..a!lcmts............,........,..,..,........"""....".... ........,..,..,............ from any and all actions, causes of action, claims and demands, damages. costs, loss of services, e~penses and compensa- tion on account of or in any way growing out of any and all known and unknown personal injuries and property damage resulting or to result from an acddent which occurred on or about"..,..,....,..August..25 ,..,19,94 ".."",,,,........,,....,,!9,........, , and do hereby agree to indemnify and save harmless the said..,....,Loul.so"F..:td tt"i..,\/H,H,arn..Td,H,.."'..".......... The..Hsl: tf.ord"Insursl1Co...G roup.. 4 nd" eheir..,rospec,tive.. age nt s. ,........,.. ........,............,.. ,....'.. ..,......,.. ......'..' ....,...... from all further claims or demands, cost or expense arising out of the injuries or damage sustained by me/us. It is further agreed that in the event other parties are responsible to me/us for damages as a result of this accident. the execution of this agreement shall operate as a satisfaction of my/our claim against such other parties to the e~tent of the pro rata share of the parties herein released, It is expressly warranted by me/us that no promise or inducement has been offered e.xcept as herein set forth; that this release is executed without reliance upon any statement or representation of the person or parties released. or their representatives, concerning the nature and e.xtent of the injuries, damages and/or legal liability therefor: that accept- ance of the consideration set forth herein is in full accord and satisfaction of a disputed claim for which liability Is expressly denied, Signed and' sealed this"..........,.........~,~......,......,day of..........,...., ...... ......,~,~~~,~,~....,.. ..............,.., ........,............,......,.., 19 ,?,~.... Address (00 ..,...,t ~lf ~ Sw..... " C"'~..,r.b'="...!.2q,!,2.. I ESTATE OF VALERIE P. SPURDON IlY: ('//Lo.1 '3 cL ~-.:.. Ittmlm:"II';..'~'~';"'f!ii'ijii'i'r;;';"''Jiaiiifiil'iitr'iito'r'" ......,,,...................."................. .......................................................,...............,.....................' ,..................................................................,..........'............... STATE OF......,....l!ENII,SYLVANIA,..,........} 55, COUNTY OF,......,~,IDI!l,l\Jl.~P.........,...."" On this......,..,..1:.::......................,....day or..........,......,'^~Il11.~,~..,......,....,..,....,..!9..~,~..,,' before me personally appeared ,!!9.9,\\R..,\l"..J,!\!tJ.!j,."J~'.\!I11Jr.,l!,...Mml,111'.\~r,'.\~m:..,9.L,!;!),l!..J~l!Ji!~,!1,..9.L~"!.!!r,!,!1...!~, ..,~m!r~!!.'.1..,................,....,........, to me known to be the person described herein, and who e.xecuted the foregoing Instrument, and..,J),\L....",..acknowledged that,...."f,l,..........vo!untarily e.xecuted the same, (R) AIIP (0192u) U:t.l~ s.~aJ O"I~A. "'''''~,o, t<,~1f'/ f't:t:<: C.Y'l-m (k'10, Currbl.lJrd C't1JN/ My (""lrrl1'\lri~1 E,lf=JdS [}:-;. I!:, 1tv:' ,hmICCr, ,~~~'\;~..'CnCJIttlt.tI\VJ B.Q.t.:i",k,TOQJ1h.J~,........,..,....",.. V Notary Public 'onD LCoDU R." PriIlttd GI'MlRl\L REtBIISB For the consideration of fifty thousand dollars ($50.000.00), receipt of which is hereby acknowledged, 1/we release lII1d discha1'ge, lII1d for myself/ourselves lII1d for my/our heirs, representatives, executors, administrntors, successors IlI1d assigns, do hereby remise, release IlI1d forever discha1'ge William H. Tritt. Jr. lII1d Erie Insurance GroUO hereinafter referred to as the releasee(s), his/her/their/its heirs, execUtors, administrators, insurers, successors IlI1d assigns, lII1d any lII1d all other persons, firms, corporations, associations, of IlI1d fran any IlI1d all causes of action, suits, rights, judgments, claims and demands of whatsoever kind, in law or in equity, known IlI1d unknown, which 1/we now have or may hereafter have, especially the claimed legal liability of releasea(s), arising fran or I:Jy reason of any IlI1d all bodily or personal injuries lII1d/or property damage known lII1d unknown, foreseen IlI1d unforeseen which heretofore has/have been or which hereafter may be sustained I:Jy fIlS/US arising out of the accident on or about l\uqust 25, 19~, at or near .!Llh 0233, in the county of cumbedlll1d, in the state of pennsvlvania, which liability releasee(s) expressly deny(ies). 1fWe agree that in consideration set forth above is specificallY applicable to and paid to fIlS/US with respect to any lII1d all damage to any property, either real or perr...onal, of mine/ours and with respect to any IlI1d all personal or bodily injury of mine/ours, whether presently Icnawn or unknown, foreseen or unforeseen or which may subsequently develop lII1d the consequences thereof, all as arising out of the aforementioned accident. 1fWe further agree that the consideration set forth above is specifically applicable to and paid to fIlS/US with respect to any right of contribution that 1/we may have against the releasee(s), his/her/their/its heirs, execUtors, administrators, insurers, successors lII1d assigns relative to claims of others that may be brought against fIlS/US I:Jy reason of said accident. 1fWe further a9J:ee that the consideration set forth above is specifically applicable to my/our a9J:eement that I/we will not join nor attempt to join the releasee(s), his/her/their/its executors, administrators, insurers, successors lII1d assigns in any capacity, in any action that may be brought against fIlS/US arising out of said accident. 1fWe warrant for myself/ourselves lII1d my/our heirs, 1:epresentatives, executors, administrators, successors and assigns that I/we have received no money or other valuable consideration fran any other person or persons I:Jy reason of any causes of action, suits, covenants, agreements, judgments, claims and demands of whatsoever kind, which 1/we now have or may hereafter have, for injuries to my/our person or property or for the other matters for which this release is given. Intending to be legally bound thereby, WI'l'NFSS my/our hand(s) lII1d seal(s) this /~ I- day of October , 19 95 IIY: VALERIE P. J. SPURDON ESTATE /! ' ('7/f.~ /21 cl~~ ROGER II ,IRWIN, Administrator \ (Seal) (Seal) NOTlCEl pennsylvania ACT 6 of 1990, Section 1627. requires us to Inform you thot IIAny person ...ho knowingly and with Intent to Injure Dr defraud any Insurer fllcn on application or clolm containing any folse, Ir~Dnplcte or mts\codln9 InfonmGtlcn shalt, \4=Ion convict ton, be sublect to Inprhonncnt for l.p to seven years and p.l-,ment of a fine of up to $15,000.11 010170174720 I(J(JI I 111'1' "y." 1 REL2 GIlIlIlRlIL JlBtEl\SB For the consideration ot tifty thousand dollars ($50.000.00), receipt ot which is hereby acla1awledged, I/we release llI1d discharge, llI1d tor myself/ourselves and tor my/our heirs, representatives, executors, administrators, successors and assigns, do hereby remise, release and toraver discharge william H. Tritt. Jr. and Erie Insurance GrouP hereinafter reterred to as the releasee(s), his/her/their/its heirs, executors, administrators, insurers, lroCCOSsors llI1d assigns, and any and all other persons, firms, coIpOrations, associations, ot llI1d tran MY and all causes ot action, suits, rights, judgments, claims and demands ot whatsoever kind, in law or in equity, known and unknown, which I/we now have or may hereafter have, especially the claimed legal liability of releasee(s), arising fran or by reason ot any and all bodily or personal injuries and/or property damage known and unknown, toreseen llI1d unforeseen which heretofore has/have been or which hereafter may be sustained by ma/us arising out of the accident on or about l\UClUSt 25, 1994, at or near !Wh 0233, in the COlUlty ot CUmberland, in the state of pennsylvania, which liability releasee(s) expressly deny(ies). I/We agree that in consideration set torth a!xlve is specifically applicable to and paid to malus with respect to any and all d.al::age to any property, either real or personal, ot mine/ours and with respect to MY and all personal or bodily injury of mine/ours, whether presently Jcnown or unknown, foreseen or unforeseen or which may subsequently develop and the consequences thereof, all as arising out of the aforementioned accident. I/We further agree that the consideration set forth a!xlve is specifically applicable to and paid to ma/us with respect to any right of contribution that I/we may have against the releasee(s), hls/her/their/its heirs, executors, administrators, insurers, successors and assigns relative to claims ot others that may be brought against malus by reason ot said accident. I/We further agree that the consideration set forth above is specifically applicable to my/our agreement that I/we will not join nor atteu;1t to join the releasee(s), his/her/their/its executors, administrators, insurers, successors and assigns in any capacity, in any action that may be brought against me/us arising out ot said accident. I/We warrant for myself/ourselves and my/our heirs, representatives, executors, administrators, successors and assigns that I/we have received no money or other valuable consideration fran any other person or persons by reason of any causes of action, suits, covenants, agreements, judgments, claims and demands of whatsoever kind, which I/we now have or may hereafter have, tor injuries to my/our person or property or for the other matters tor which this release is given. Intending' to bc3 legally bound thereby, WITNESS r:t'f/our hand(s) arA seal(s) this day ot October , 19 95 . / Cf ;zA Jtki )'$i" BY: (Seal) (Seal) NOIICE. pennsylvanIa ACT 6 of 1990, Section 1827, requIre. u. to Inform you that "Any pe"on ....0 knowingly ond with Intent to Injure or dcfrat.d anv Insurer files on application Dr claim contolnlng any folso, Incarplcte or mls'eodlng Infarmacton shall. \4lon corwtctlon, be subject to lrrprlsonnent for t.p to seven years and p3yment of a #tne of up to '15.000," 010170174720 I!XIIJIlI'1' "p," REL2 1 RELEASE AND TRUST ^GREEHh~T - 81Ul Know all men by these presents: That, for the sole consideration of the sum of Two Hundred Thollsand and 00/100------ Dollars (POO,OOO.Op, the receipt of which from the Nationwide Insurance Company, designated below, (hereinafter called "Nationwide") is hereby acknowl- edged, the undersigned in her/his capacity as an insured, or parent (guardian) of , a minor insllred, q'li hWi'l1.and &~ife) of , a deceased insured or executor (administrator) of '(Jll~eruap~J. Spurdon, a deceased insured, as de- signated below, hereby releases, discharges, and for herself/himself, her/his, executors, administrators, successors and assigns does forever release and discharge Nationwide of and from all claims of whatsoever kind and nature prior to and including the date hereof growing out of the UNDERINSURED Motorist Coverage of an Automobile Insurance Policy number 58C613734 issued by Nationwide to Ross D. Purdy , and resulting or to result from an accident which occurred on August 25 ,191i-at or near State Route 233 and State Route 174, Penn Township, Cumberland County, PA And further: In consideration of such payment, the undersigned, for herself/himself personslly and in her/his capacity, as designated below, agrees to take through any representative designed by Nationwide, such action as may be necessary or appropriate to recover the dam_ges suffered by the undersigned and said minor or estate from any person or persons, organization, association or corporation other than Nationwide who or which may be legally liable therefor and to hold any monies recovered from such person or persons, organization, association or corporation as a result of judgment or as .a result of settlement with or without litigation in trust for Nationwide to be paid to Nationwide immediately upon recover, thereof; provided, however, that any sum recovered in excess of the amount paid to the undersigned by Nationwide as consideration for this Release and Trust Agreement plus all expenses, court costs and attorney fees in connection therewith shall be retained by the undersigned and said minor or estate, as their interests may appear, for her/his own use and benefit and the undersigned hereby agrees to reimburse, indemnify and save harmless said Nationwide against any further claims under said policy resulting from the above accident, by or on behalf of any minor or deceased named above, her/his representatives, heirs or assignees, hereby waiving any and all rights of exemption, both as to real and personal property, to which the undersigned may be entitled by the laws of any state as against such claims for reimbursement or indemnity ,/' 0. cL: x Roger 8. Individually and V.at'<Hl t Gttlt'I"dian S l>6tl1rC AS Administrator Ex~u:.ut:or of: Tht! Estatt! of Valt!rie P.J. Spurdon Accepted: Nationwide Insurance Company By Witnesses Dated at: Carlls!t!. I'ellnsy!vllllln 17013 Il.'eelllbur 12th , 19 q~ PENNRO E 1244 4/92 EXlIIlIlT "1'" RELEASE AND TRUST hGREEKENT - BIUI . , Know all men by these presents: That, for the sole consideration of the sum of Two Hundred Thousand and (\(\/100 __,..__ Dollars (QOO,ooo.r.), the receipt of which from the Nationwide Insurance Company, designated below, (hereinafter called "Nationwide") is hereby acknowl- edged, the undersigned in her/his capacity as an insured, or parent (guardian) of , a minor insured, <ltlilehup.~e!lee (101 if e) of ' a deceased insured or executor (administrator) of Ross-D. l'urdV ' a deceased insured, os de- signated below, hereby releases, discharges, and for herself/himself, her/his, executors, administrators, sllccessors and assigns does forever release and discharge Nationwide of and from all claims of whatsoever kind and nature prior to and including the date hereof growing out of the UNDERINSURED Motorist Coverage of an Automobile Insurance Policy number 58C613734 issued by Nationwide to Ross D. \'urdy , and resulting or to result from on accident which occurred on August 2:' ,19 94 at or near State Route 233 and State Route 174 Penn Townshi , Cumberland Count T>A. r ! And further: In consideration of such payment, the undersigned, for herself/himself personally i and in her/hiS capacity, as designated beloW, agrees to take through any representative \' designed by Nationwide, such action aB muy be necessary or appropriate to recover thc damages suffered by the undersigned and said minur or estate from any person or persons, organization, I association or corporation othcr than Nationwide who or which may be legally liable therefor I and to hold any monies recovered from such person or persons, organization, association : or corporation as a result of judgment or as a result of settlement with or without litigation,! in trust for Nationwide to be paid to Nationwide immediately upon recover, thereof; provided, i however, that any sum recovered in excess of the amount paid to the undersigned by Nationwide \ os consideration for this Release and Trust Agreement plus all expenses, court costS and I attorney fees in connection therewith shall be retained by the lIndersigned and said minor ; , or estate, as their interests may appear, for her/his own use and benefit and the undersigned i hereby agrees to reimburse, indemnify and save harmless said Nationwide sgainst any further ! claims under said policy resulting from the above sccident, by or on behalf of any minor I or deceased named above, her/hiS representatives, heirs or assignees, hereby waiving any I' and all rights of exemption, both aa to real and personal property, to which the undersigned may be entitled by the lawS of any state as against such claims for reimbursement or indemnity.\ X . 1;?a \ /j, Y; y In ividual Faient- ctual"c.P "g,. 3puuse Administrator of: The Estate of RosS D. purdy AS YV(tr."tnr Accepted: Nationwide Insurance Company :"..,,~;U<l 171. ;;,t;-jr- Nume ~/lA nf r/ls,Oa.t/.k/l!':lJ.Mf/ Name r (,0 WEST \'OMFRE'r !IT.. CAllT.l!l1.F., AddresS PA 17:~ I'A 17011 60 WEST \'OHFRF.T ST.. CAllT.l!l1 v., AddresB llated at I CARUSt.F., l'ENNIWt.vANIA IlECI<MIIF.R 2(,. , 199~ PENNRO E 1244 4/92