IN THE UNITED STATES DISTRICT COURT 

FOR THE EASTERN DISTRICT OF PENNSYLVANIA 

ROSEN SCHAFER & DIMEO, LLP

BY: ILENE SCHAFER, ESQUIRE 

IDENTIFICATION NO.: 34418 

121 S. BROAD STREET 

SUITE 800 

PHILADELPHIA, PA 19107 

(215) 864-9440 

 

ATTORNEY FOR PLAINTIFF

JAMES REEVES, III, a minor by his p/n/g

ALTHEA JACOBS 

v. 

VANESSA CARTER-MORAGNE, et al.

:

: 

: 

: 

: 

: 

: 

: 

: 

:

CIVIL ACTION 

NO. 02-4428

To the Honorable, the Judges of the Said Court: 

 The Petition of Althea Jacobs parent and natural guardian of James Reeves, III by their 

attorney Ilene Schafer, Esquire respectfully represents as follows: 

 1. That she is the parent and natural guardian of James Reeves, III who resides at 

1934 Dalkeith Street, Philadelphia, Pa 19140. He is currently 16 years old, having been born on 

1 and his SSN is 

 2. On February 6, 2002, said minor was struck by a bullet in Imani Education Circle 

Charter School at 5612 Greene Street in the City and County of Philadelphia fired accidentally 

by defendant, Vanessa Carter-Moragne. 

 3. Thereafter, litigation commenced under the above civil 

action number and on April 21, 2003, Judge Dalzell signed an Order approving Plaintiff’s 

Motion for Approval of Minor’s Compromise and ordering that the net sum payable to James 

Reeves, III, a minor, be deposited in a Federally Insured Savings Account or Federally Insured 

Savings Certificate to be marked “Not to be withdrawn until minor reaches the age of eighteen or 

without an Order from a Court of competent Jurisdiction”. 

 4. Thereafter, a Certificate of Deposit was opened up at Citizens Bank under 

Case 2:02-cv-04428-SD Document 24 Filed 06/11/2008 Page 1 of 3
Account No. 6241-498415. To date, that Certificate has accrued interest and has a balance of 

over $14,000.00 currently. 

 5. Attached hereto is a letter from Althea Jacobs regarding her request 

for release of $2,545.00 for her son to attend Camp Emagination for computers. 

 6. Petitioner asserts in her letter that she is unable to afford said Camp and, 

James is an exceptional student who lives in a high crime area and she would like to help him 

advance his love of computers and allow him a safe summer and improve his chances for a 

successful future. 

 Wherefore, Petitioner respectfully requests this Court approve an Order allowing 

Petitioner to withdraw $2,545.00 from the above described Certificate of Deposit for use in the 

purchase of a computer and printer for the minor plaintiff. 

 ROSEN, SCHAFER & DIMEO, LLP 

 BY: __________________________ 

 ILENE SCHAFER, ESQUIRE 

Case 2:02-cv-04428-SD Document 24 Filed 06/11/2008 Page 2 of 3
IN THE UNITED STATES DISTRICT COURT 

FOR THE EASTERN DISTRICT OF PENNSYLVANIA 

ROSEN SCHAFER & DIMEO, P.C.

BY: ILENE SCHAFER, ESQUIRE 

IDENTIFICATION NO.: 34418 

121 S. BROAD STREET 

SUITE 800 

PHILADELPHIA, PA 19107 

(215) 864-9440 

 

ATTORNEY FOR PLAINTIFF

JAMES REEVES, III, a minor by his p/n/g

ALTHEA JACOBS 

v. 

VANESSA CARTER-MORAGNE, et al.

:

: 

: 

: 

: 

: 

: 

: 

: 

:

CIVIL ACTION 

NO. 02-4428

DECREE

 AND NOW, this day of , 2008, upon consideration of the foregoing 

Petition for Release of Minor’s Funds, it is hereby ORDRED and DECREED that Althea Jacobs 

is permitted to withdraw the sum of $2,545.00 from the Citizens Bank Certificate of Deposit 

under Account No. 6241-498415 for the registration and attendance at Camp Emagination. 

 BY THE COURT: 

 __________________________ 

 J. 

Case 2:02-cv-04428-SD Document 24 Filed 06/11/2008 Page 3 of 3