HomeMy WebLinkAbout11-19-07
BEFORE THE REGISTER OF WILLS OF
CUMBERLAND COUNTY, PENNSYLVANIA
Estate of Marci J. Seaman, Deceased
No. I05~
of 2007
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PETITION FOR CITATION TO'.~~
COMPEL ADMINISTRATION OF ESTATE~:~~~~
AND TO PRODUCE LAST WILL AND TESTAMENTo~
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The petition of Long Meadows Townehouses Association, Inc. ("Petitioner")
respectfully states that:
1. Marci Seaman Hollenback ("decedent") died intestate on an unknown
date, a resident of Cumberland County, Pennsylvania residing at 12 Campbell Place,
Camp Hill, PA 17011.
2. Decedent was survived by her spouse, Frank Hollenback, an adult
individual with a mailing address of 12 Campbell Place, Camp Hill, PA 17011.
Petitioner believes that decedent is also survived by two children of unknown names, a
man (believed to go by the name "Robert") and a woman (believed to go by the name
"Amy").
3. At the time of her death, Decedent owned real property located at 12
Campbell Place, Camp Hill, PA 17011, a condominium subject to the Declaration of
Long Meadows Townehouses Association, Inc. and the Rules and Regulations of such
Association.
4. Since her death, Decedent's spouse has resided at the property at 12
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Campbell Place but has failed to maintain such property and, as a result, such property
has deteriorated and has been subjected to various assessments by Petitioner for
failure to repair, failure to make payments of association dues, and various other
assessments. Consequently, Petitioner has become a creditor of decedent's estate in
the amount of $50,245.31 plus attorney's fees, interest and costs.
5. Petitioner, Long Meadows Townehouses Association, Inc. has an address
of 16 Campbell Place, Camp Hill, PA 17011 and, as noted above, is a creditor of
decedent's estate.
6. Neither decedent's spouse or her children have petitioned for the grant of
Letters Testamentary or of Administration on decedent's estate, and Petitioner believes
that making such a request to Decedent's spouse would be futile because Petitioner
has sent several Certified Mail letters to Petitioner, none of which have been picked up
by Decedent.
7. Upon information and belief, Petitioner believes that decedent may have
had a will and therefore petitions the Court to require Frank Hollenback to produce the
last will and testament of Marci Seaman Hollenback to the Register of Wills.
2
WHEREFORE, Petitioner respectfully requests that a citation be awarded,
directed to Frank Hollenback, to (1) show cause why he should not apply for Letters
Testamentary or of Administration on the Estate of Marci Seaman Hollenback,
deceased, or in the alternative, to show cause why such letters should not be granted to
Petitioner, and (2) require Frank Hollenback to produce the will of Marci Seaman
Hollenback to the Register of Wills of Cumberland County.
Edmund J. Berger
Attorney for Petitioner
Attorney \.0. # 53407
BERGER LAW FIRM, P.C.
2104 Market Street
Camp Hill, PA 17011
Phone: (717) 920-8900
Fax: (717) 920-8901
E-Mail: tberger@bergerlawfirm.net
Date: November 19, 2007
3
11/15/2007 09:53
71 77702400
ALPHA CONSULTING ENG
BERGER LAW fIRM PC 71?9209901
PAGE 01
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Nov 15 2007 lO:a3RM
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VERIFICA110N
I, JarMS $trupe. veI\fy that I am tile presidenl of Long Meec\lWlIS
TawnehO'" AsSOCiation. Inc.. and that the ~ rnede In this
PetiIion for CitatIOn to Compel AdministndiOn and To Produce l.8SI VV1II an
Testament are true and correct. I undel'8t8nd that f81se statements herein
are made subject to the penalties of 18 Pa.C.S. i49<l4 relatin9 to unllWO
fa\sification to authoritIes.
~\V(f~4L.l~1 2007
Date
CERTIFICATE OF SERVICE
I hereby certify that I have this day served a true and correct copy of the
foregoing document, Petition for Citation to Compel Administration of Estate and to
Produce Last Will and Testament, upon the following person, in the manner indicated:
VIA FIRST CLASS MAIL and CERTIFIED MAIL
Mr. Frank Hollenback
12 Campbell Place
Camp Hill, PA 17011
Date: November 19, 2007
Edmund J. Berger
Attorney for Petitioner
Attorney \.0. # 53407
BERGER LAW FIRM, P.C.
2104 Market Street
Camp Hill, PA 17011
Phone: (717) 920-8900
Fax: (717) 920-8901
E-Mail: tberger@bergerlawfirm.net