HomeMy WebLinkAbout12-05-07
In Re:
DEe 0 52007;r1
IN THE COURT OF COMMON PLEAS
CUMBERLAND COUNTY, PENNSYL VANIA
CLAIR BEINHOWER,
ORPHANS' COURT DIVISION
Deceased
No. 21-07-0388
DEFENDANT TERRI CASSEL'S ANSWER TO
COMPLAINT FOR EQUITABLE INTERPLEADER
AND NOW, comes Defendant Terri Cassel, in her capacity as Executrix and as
Power of Attorney for Nancy Beinhower, by and through her counsel, Jacqueline M. Welby,
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Esquire, and responds to Plaintiffs Complaint as follows: 0 ~
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1. Admitted. ~i,-~ p 8
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2. Admitted. ~ 7' :P-
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3. Admitted. =-~ \D
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4. Admitted in part. Denied in part. It is admitted that Courtney Meyer'f
resides at 555 Hillcrest Road, York, York County, Pennsylvania 17011. It is denied that
Courtney Meyers is an adult. By way of further answer, Courtney Meyers is a minor of six (6)
years of age.
5. Denied. Nancy Beinhower resides at 4831 East Trindle Road,
Mechanicsburg, Pennsylvania 17055. By way of further answer; Mrs. Beinhower's children
Terri Cassel and Jeffrey Arnold serve as co-agents pursuant to a power of attorney.
6. Admitted. By way of further answer, Terri Cassel serves as co-agent for
her mother, Nancy Beinhower.
7. Admitted.
8. Admitted.
9. Admitted.
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10. Admitted.
11. Admitted.
12. Admitted.
13. Admitted.
14. Admitted.
15. Admitted.
16. Admitted.
17. Admitted.
18. Admitted.
19. Admitted.
20. Admitted.
21. Admitted.
22. Admitted.
23. Denied. After reasonable investigation, Defendant is without sufficient
information to determine the accuracy of the averments of this paragraph and such averments are
therefore denied. By way of further answer, the averments of this paragraph are denied as a
conclusion oflaw to which no response is required.
Respectfully submitted,
Lfej!'L( {L1/ )JJ. /12[1"1' dk
J cqu . ne M. Welby, Esquire
THE YORK LEGAL GROUP, LLC
3511 North Front Street
Harrisburg, P A 17110
Tel: 717.236.9675
Fax: 717.236.6919
Email: lwelby@yorklegalgroup.com
Dated: December 5,2007
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VERIFICATION
I, Douglas P. France, Esquire, do hereby verify that I am the attorney of record for
the pleading party herein, and that the facts set forth in the foregoing Complaint are true to the
best of my knowledge, information and belief, upon information supplied by Plaintiff. The
verification of Defendant, Terri Cassel, could not be obtained in time for this filing.
I understand that false statements made herein are made subject to the penalties of
18 Pa.C.S.A. S4904 relating to unsworn falsification to authorities.
Dated: November 5, 2007
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CERTIFICATE OF SERVICE
I, Jacqueline M. Welby, Counsel for Petitioner ofthe Estate of Clair Beinhower,
deceased, hereby certify that on this 5th day of December, 2007, I served Defendant Terri
Cassel's Answer to Complaint for Equitable Interpleader, via U. S. Mail, postage prepaid, upon
the following:
Stephen K. Portko, Esquire
Bratic & Portko
101 South U.S. Route 15
Dillsburg, P A 17019
Douglas P. France, Esquire
Kagen, Macdonald & France, P.C.
2675 Eastern Boulevard
York, PA 17402
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