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IN THE MATTER OF THE ESTATE OF * IN THE COURT OF COMMON PLEAS OF
MARY F. WERTZ, A1K1A MARY FAY * CUMBERLAND COUNTY, PENNSYLVANIA
WERTZ, DECEASED, LATE OF THE * ORPHANS' COURT DIVISION
TOWNSHIP OF UPPER ALLEN, *
COUNTY OF CUMBERLAND AND * FILE NO. 21-07-0431 r-
STATE OF PENNSYLVANIA *
PETITION FOR LEAVE TO PURCHASE REAL
ESTATE BY CO-EXECUTOR
TO THE HONORABLE, THE JUDGES OF THE ABOVE NAMED COURT:
-, ...
The Petition of Thomas F. Wertz and Joseph V. Wertz, by their attorney, Gerald L',
P. Neugebauer, Jr., Esquire, respectfully represents that:
1. Mary F. Wertz, also known as Mary Fay Wertz, hereinafter referred to as
Decedent, died testate on April 20, 2007.
2. Glenda Farner Strasbaugh, Register of Wills of Cumberland County,
Pennsylvania, acting in accordance with ITEM III of the Last Will and Testament of
Decedent, appointed your Petitioners, Thomas F. Wertz and Joseph V. Wertz, as
Co-Executors of the Estate of Decedent on May 4, 2007.
3. Said Last Will and Testament of Decedent provides, inter alia, as follows,
verbatim:
ITEM II. I give, devise and bequeath all the rest, residue and
remainder of my property, real, personal or mixed, tangible and in-
tangible, of whatsoever nature and wheresoever located and all
property to which I may be entitled or over which I may have any
power of disposition or appointment and whether acquired during or
after my lifetime unto my husband, EDWIN G. WERTZ, absolutely
and in fee simple, provided that he survives me by sixty (60) days of
my death; if EDWIN G. WERTZ should predecease me or shall die
within sixty (60) days of my death, then I give, devise and bequest the
said rest, residue and remainder of my property as follows:
(a) All the rest, residue and remainder of my property shall
go equally to children, namely: MARIAN FAY BUMANN, ANNA MAY
HATCH, EDWIN WERTZ, JR., CAROL ANN TEMOFONTE, MARY
LINDA WILLOUGHBY, ELIZABETH ANN GUY, PATRICK DENNY
~
WERTZ, THOMAS F. WERTZ, JOSEPH V. WERTZ and SISTER
LUCILLA WERTZ, share and share alike.
The Decedent's husband, Edwin G. Wertz, predeceased her, having died on February 9,
1991.
4. Decedent died seized of, inter alia, all of the following described real estate:
ALL that certain lot of ground situate in the Township of Upper Allen,
County of Cumberland, and State of Pennsylvania, bounded and
described as follows, to wit:
BEGINNING at a point in the western line of Orchard Lane (40 feet
wide) which said point is the division line between Lots Nos. 64 and
65 on the hereinafter mentioned Plan of Lots; thence along the
division line between Lots Nos. 64 and 65, South 84 degrees 11
minutes West, one hundred twenty-eight and seventeen (128.17)
feet to a point in the division line between Lots Nos. 65 and 91 on
said Plan; thence along the division line between Lots Nos. 65 and
91 and Lots Nos. 65 and 90, North 07 degrees 18 minutes West,
ninety and three one-hundredths (90.03) feet to a point in the
division line between Lots Nos. 65 and 66 on said Plan; thence
along the division line between Lots Nos. 65 and 66 on said Plan,
North 84 degrees 11 minutes East, one hundred thirty and fifty
one-hundredths (130.50) feet to a point in the western line of
Orchard Lane, aforementioned; thence along the western line of
Orchard Lane, South 05 degrees 49 minutes East, ninety (90) feet
to a point in the division line between Lots No. 64 and 65, afore-
mentioned, at the point and place of beginning.
BEING Lot No. 65, Section "F" in the Plan of Lots of Paul T.
Shearer and I. S. Eberly, known as RESERVOIR HILL, which said
Plan is recorded in the Cumberland County Recorder's Office in
Plan Book 14, at page 44.
HAVING thereon erected a single dwelling house.
UNDER AND SUBJECT to all exceptions, reservations,
restrictions and conditions contained in prior deeds of
conveyance.
BEING the same premises the title to which became vested in
Edwin G. Wertz and Mary F. Wertz (also known as Mary Fay
Wertz), his wife, by Deed from Jack E. Bertolette and Edna M.
Bertolette, his wife, dated November 29, 1967, and recorded
November 30,1967, in the office for the recording of deeds, etc.,
in and for Cumberland County in Deed Book P, Volume 22, page
122. The said Edwin G. Wertz died on February 9, 1991, thereby
vesting title solely in his wife, the said Mary F. Wertz (also known
as Mary Fay Wertz), the Decedent herein, as the surviving tenant
by the entirety.
Said certain lot of ground is hereinafter referred to as the Estate real estate.
5. The names and addresses of all of the heirs at law of Decedent, as per the
said ITEM II (fully detailed at paragraph 3 above), are as follows:
A. Marian Fay Bumann
6655 Corte Maria
Carlsbad, CA 92009
B. Anna May Hatch
12133 Green Beaver Road
Salem, OH 44460
E. Mary Linda Willoughby
430 Jennifer Drive
New Cumberland, PA 17070
D. Carol Ann Temofonte
3921 Murry Hill Court
Murrysville, PA 15668
F. Elizabeth Ann Guy
830 Old Mill Drive
Loveland, OH 45140
C. Edwin Wertz, Jr.
621 Hollen Road
Baltimore, MD 21212
G. Patrick Denny Wertz
320 E. Main Street
Mechanicsburg, PA 17055
H. Sister Mary Lucilla Wertz
Saints Peter & Paul Convent
1947 East Adams
Tucson, AZ 85719
I. Thomas F. Wertz (one of
your Petitioners)
25 Stone Tower Lane
Wilmington, DE 19803
J. Joseph V. Wertz (one of
your Petitioners)
410 Orchard Lane
Mechanicsburg, PA 17055
6. All of the testate heirs of the Estate of Decedent have agreed to the sale the Estate
real estate to Joseph V. Wertz, one of your Petitioners, in his individual capacity, for a gross
consideration of $145,500.00, which agreement is evidenced by the signatures of your
Petitioners hereafter and is also evidenced by signed consents attached hereto and
made a part hereof and marked as Exhibits A through H, respectively. The consent of one of
the testate heirs, Carol Ann Temofonte (marked as Exhibit D), was conditioned upon a proper
appraisal, which was obtained. All other consents were unconditional.
7. So that the aforementioned sale may be effectuated, your Petitioners request
that one of your Petitioners, Joseph V. Wertz, be authorized to purchase, in his
individual capacity, the Estate real estate for a gross consideration of $145,500.00, and
that your Petitioner, Thomas F. Wertz, be authorized to execute and deliver to Joseph V.
Wertz a Deed conveying the Estate real estate to him, in his individual capacity, for a
gross consideration of $145,500.00.
WHEREFORE, your Petitioners respectfully request your Honorable Court,
pursuant to Section 3356 and Section 5101 (2) of the Pennsylvania Probate, Estates and
Fiduciaries Code of 1972, P.L. 508, as amended, 20 Pa.C.S.A. 3356 and 5101(2), to
enter an ORDER:
A. Authorizing Joseph V. Wertz, one of the Co-Executors of the
Estate of Mary F. Wertz, also known as Mary Fay Wertz, to
purchase, in his individual capacity, the Estate real estate
from Decedent's Estate for a gross consideration of
$145,500.00, and
B. Authorizing and directing Thomas F. Wertz, one of the Co-
Executors of the Estate of Mary F. Wertz, also known as Mary
Fay Wertz, to execute and deliver to Joseph V. Wertz a Deed
conveying the Estate real estate to him, in his individual
capacity, for a gross consideration of $145,500.00.
And they will ever pray, etc.
GaUgebaUer, Jr., Esquire
Attorney for Co-Executors
STATE OF PENNSYLVANIA
*
* SS:
COUNTY OF CAMBRIA
*
THOMAS F. WERTZ and JOSEPH V. VVERTZ, being duly sworn according to
deposes and says
law, depose and say1hat the facts set forth in the foregoing PETITION FOR LEAVE TO
PURCHASE REAL ESTATE BY CO-EXECUTOR are true and correct to the best of
his
their4mowledge, information and belief.
T~{:Jp
Joseph V. Wertz
Sworn to and subscribed before me
this 10th day of October ,2007.
~(2J1.
Notary Public
NOTARIAL SEAL
CA'THrntNE M. KENT, NOTARY PUBliC
EBENSBURG BORO., CAMBRIA COUNlY
MY COMMISSION EXPIRES SEPT. 5, 2009
STATE OF PENNSYLVANIA
*
* SS:
COUNTY OF CAMBRIA
*
THOMAS F. VVERTZ and JOSEPH V. WERTZ, being duly sworn according to
deposes and says
law, depose' and say that the facts set forth in the foregoing PETITION FOR LEAVE TO
PURCHASE REAL ESTATE BY CO-EXECUTOR are true and correct to the best of
his
.ti:lQu:lknowledge, information and belief.
Thomas F. 'Nertz
Sworn to and subscribed before me
this 12th day of October ,2007.
~% '
~ Notary PUbli~
NOTARIAL SEAL
CATHERINE M. KENT, NOTARY PUBLIC
EBENSBURG BORO., CAMBRIA COUNlY
MY COMMISSION EXPIRES SEPT. 5. 2009
GERALD P. NEUGEBAUER, JR.
ATTORNEY AT LAW
GERALD P. NEUGEBAUER, JR.
12M WEST SECOND STREET
CRESSON. PENNSYLVANIA 16630
.lAMBS H. CONNELL..nt..
C19a9 - 1981)
(814) 886-2352
FACSIMILE (814) 886-2363
August 29,2007
Marian Fay Bumann
6655 Corte Maria
Carlsbad, CA 92009
Mary Linda Willoughby
430 Jennifer Drive
New Cumberland, PA 17070
Anna May Hatch
12133 Green Beaver Road
Salem,OH 44460
Elizabeth Ann Guy
830 Old Mill Drive
Loveland,OH 45140
Edwin Wertz, Jr.
621 Hollen Road
Baltimore, MD 21212
Patrick Denny Wertz
320 E. Main Street
Mechanicsburg, PA 17055
Carol Ann Temofonte
3921 Murry Hill Court
Murrysville, PA 15668
Sister Mary Lucilla Wertz
Saints Peter & Paul Convent
1947 East Adams
Tucson, AZ 85719
Re: Estate of Mary F. Wertz, also known as
Mary Fay Wertz
Dear Heir:
Enclosed herewith please find copies of both of the following relative to
the above-referenced Estate:
1. A market research opinion prepared by Cal Williams of
Straub & Associates Real Estate Group Inc., dated June
19, 2007, and
2. A Uniform Residential Appraisal Report prepared by
Chris H. Davis, Certified Residential Appraiser, of Fairway
Appraisals, dated July 29, 2007.
Exhibit A
August29,2007
Page 2
The first document values the Estate real estate at $150,000.00 - $154,000.00
presumably as of June 19, 2007 and the second document values the Estate real
estate at $176,000.00 as of July 24,2007. The latter was obtained because of
limitations stated in the former.
Additionally, please be advised that your brother, Joe, one of the Co-
Executors of your mother's Estate, has offered to purchase the Estate real estate
for a net consideration of $145,500.00, this being a gross consideration of
$155,000.00 less $1,000.00 for painting, less $1,000.00 to replace the wooden
windows and less a $7,500.00 savings of a real estate agent's commission. He
would be a true purchaser and his share of the Estate would not otherwise be
affected. Your brother and other Co-Executor, Tom, has no recommendation as
to the acceptability, or otherwise, of this offer. Rather, the three of us have
decided to request the input of each of the heirs of the Estate - hence the
purpose of this letter.
Accordingly, please accept this letter as my request, on behalf of the
Estate of Mary F. Wertz, also known as Mary Fay Wertz, that you consider Joe's
offer and thereafter complete the bottom portion of one copy of this letter, where
indicated, and return it to me in the envelope I have provided, all at your earliest
convenience, but, if you will, by not later than September 15, 2007. The other
copy of this letter is for your files. After I have received all responses, I will
collaborate with both Joe and Tom and, hopefully, a decision can be made as to
the acceptability or unacceptability of Joe's offer. I will, of course, let you know
the results or perhaps ask for further input.
I trust that you feel this is the most fair method of handling the disposition
of the Estate real Estate. Thank you for your time and consideration.
Very truly yours,
Gerald P. Neugebauer, Jr., Esquire
GPNjr: biz
Enclosures
cc: Thomas F. Wertz, Co-Executor
Joseph V. Wertz, Co-Executor
Exhibit A
August 29, 2007
Page 3
~. I hereby consent to the purchase of the Estate real estate from
the Estate of Mary F. Wertz, also known as Mary Fay Wertz, by my
brother, Joseph V. Wertz, for a net consideration of $145,500.00.
~141
Da e '
I do not consent to the purchase of the Estate real estate from the
Estate of Mary F. Wertz, also known as Mary Fay Wertz, by my
brother, Joseph V. Wertz, for a net consideration of $145,500.00 for
the following reason or reasons:
~~J~~~
51 ature
Exhibit A
.
August 29, 2007
Page 3
/
I hereby consent to the purchase of the Estate real estate from
the Estate of Mary F. Wertz, also known as Mary Fay Wertz, by my
brother, Joseph V. Wertz, for a net consideration of $145,500.00.
I do not consent to the purchase of the Estate real estate from the
Estate of Mary F. Wertz, also known as Mary Fay Wertz, by my
brother, Joseph V. Wertz, for a net consideration of $145,500.00 for
the following reason or reasons:
9 - ~- 07
Date
iL--<)~d!~
Signature
Exhibit B
August 29, 2007
Page 3
v
I hereby consent to the purchase of the Estate real estate from
the Estate of Mary F. Wertz, also known as Mary Fay Wertz, by my
brother, Joseph V. Wertz, for a net consideration of $145,500.00.
I do not consent to the purchase of the Estate real estate from the
Estate of Mary F. Wertz, also known as Mary Fay Wertz, by my
brother, Joseph V. Wertz, for a net consideration of $145,500.00 for
the following reason or reasons:
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Dat l
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Exhibit C
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Exhibit D
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August 29,2007
Page 3
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I hereby consent to the purchase of the Estate real estate from
the Estate of Mary F. Wertz, also known as Mary Fay Wertz, by my
brother, Joseph V. Wertz, for a net consideration of $145,500.00.
I do not consent to the purchase of the Estate real estate from the
Estate of Mary F. \Nertz, also known as Mary Fay Wertz, by my
brother, Joseph V. Wertz, for a net consideration of $145,500.00 for
the following reason or reasons:
~L \J illouj .f:J
Exhibit E
~,-' ..
August 29, 2007
Page 3
/
I hereby consent to the purchase of the Estate real estate from
the Estate of Mary F. Wertz, also known as Mary Fay Wertz, by my
brother, Joseph V. Wertz, for a net consideration of $145,500.00.
I do not consent to the purchase of the Estate real estate from the
Estate of Mary F. Wertz, also known as Mary Fay Wertz, by my
brother, Joseph V. Wertz, for a net consideration of $145,500.00 for
the following reason or reasons:
1a:5 ~o 1
ate
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-igna-. ~
Exhibit F
.
August 29, 2007
Page 3
/ I hereby consent to the purchase of the Estate real estate from
the Estate of Mary F. Wertz, also known as Mary Fay Wertz, by my
brother, Joseph V. Wertz, for a net consideration of $145,500.00.
I do not consent to the purchase of the Estate real estate from the
Estate of Mary F. Wertz, also known as Mary Fay Wertz, by my
brother, Joseph V. Wertz, for a net consideration of $145,500.00 for
the following reason or reasons:
J. - J..-~ - 0 "l
Date
p~-,~
Signature
Exhibit G
I . .. j' ~
August 29,2007
Page 3
~ I hereby consent to the purchase of the Estate real estate from
the Estate of Mary F. Wertz, also known as Mary Fay Wertz, by my
brother, Joseph V. Wertz, for a net consideration of $145,500.00.
I do not consent to the purchase of the Estate real estate from the
Estate of Mary F. Wertz, also known as Mary Fay Wertz, by my
brother, Joseph V. Wertz, for a net consideration of $145,500.00 for
the following reason or reasons:
tf"i i: fto7
Dat I
Juh)J1)prk~d~~a14
Signature
Exhibit H