STATE OF MICHIGAN IN THE CIRCUIT COURT FOR THE COUNTY OF INGHAM

The Estate of Sean Michael Glarner, by Denise Glarner, Personal Representative, Plaintiff, v. Case No. 10-712-NO Honorable: Clinton Canady, III Circuit Court Judge

Okemos Public Schools, Carol Thorsen and Pat Hatcher all d/b/a Okemos Special Needs Day Camp, Defendants. Timothy A. O’Rourke (P32443) Hay & O’Rourke, P.C. Attorneys for Plaintiff 221 West Saginaw Lansing, MI 48933 (517) 372-2900 William Vogelzang, Jr. (P29231) Mark T. Ostrowski (P49761) Kara T Rozin (P72140) Kluczynski, Girtz & Vogelzang Attorneys for Defendants 648 Monroe Avenue, NW, Suite 400 Grand Rapids, MI 49503 (616) 459-0556

PLAINTIFF’S MOTION FOR AUTHORITY TO DISTRIBUTE PROCEEDS OF SETTLEMENT

NOW COMES Plaintiff Denise Glarner, as Personal Representative for the Estate of Sean Michael Glarner, Deceased, by and through his attorneys, Hay & O’Rourke, P.C. by Timothy A. O’Rourke, and hereby moves the Court pursuant to MCL for an Order Allowing Distribution of the net proceeds of the wrongful death settlement in the within matter, and in support states as follows:

1.

On December 18, 2012 an agreement was reached by all parties, as well as

all interested parties in settlement of the above entitled matter for the amount of $200,000.00. 2. Authority for the distribution is requested to include the following, together

with any additional costs not incurred at the time of this motion: 1. 2. 3. 5. 3. Settlement Amount Less Costs (to date) Less Attorney Fee Net Settlement $200,000.00 15,662.06 61,439.84 $122,898.10

After payment of fees and costs, the sum of $122,898.10 will be distributed

equally among the heirs and survivors entitled to participate under MCL 600.2922. At the time of his death, Sean Michael Glarner was survived by the following interested individuals: a) b) c) Denise Glarner, Mother Hans Glarner, Father Nicholas Glarner, Brother

These persons are all the persons known to the Personal Representative who may be entitled to damages under the provisions of MCL 600.2922. 4. The Personal Representative believes and states that all medical, hospital,

funeral and burial expenses of the Decedent for which the Estate may have been liable have been paid. There are no outstanding charges against the Estate. 5. A Notice of the Hearing to Distribute, as well as a copy of this Motion, was served

on all of the interested parties. Proof of Service has been filed with this motion. WHEREFORE, the Personal Representative requests this Court to enter its Order

Allowing Distribution of the Proceeds of the Settlement pursuant to the distribution. The Personal Representative further requests that the Order authorize him to execute any and all documents necessary, to take any and all actions or proceedings to implement and give full force and effect to the Distribution Settlement and closing of the Estate. Respectfully submitted, HAY & O’ROURKE, P.C.

_______________________________ Timothy A. O’Rourke, ( P32443) Attorney for Plaintiff Denise Glarner Administrator/Personal Representative Of the Estate Dated: February 1, 2013

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