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IN RE: ESTATE OF T. A.
MILLER, LATE OF THE BOROUGH
OF CARLISLE, CUMBERLAND COUNTY::
PENNSYLVANIA, DECEASED . .
IN THE COURT OF COMMON PLEAS
CUMBERLAND COUNTY, PENNSYLVANIA
ORPHANS' COURT DIVISION
NO. 21-78-314
ANSWER OF BEATRICE M. CLAUS, SURVIVING SPOUSE
TO THE HONORABLE, THE JUDGES OF SAID COURT:
Beatrice M. Claus, surviving spouse of T. A. Miller,
makes answer to the Petition of Shiloh Baptist Church, West
Street A.M.E. Zion Church, Bethel A.M.E. Zion Church, and
North Middleton Township, Cumberland County, Pennsylvania,
as follows:
The averments of paragraphs 1 through 3 are admitted.
4. It is averred that the consent of the parties in
interest is irrelevant and unnecessary.
5. Admitted.
6. Denied. On the contrary it 1S averred that for a
period of five years and upwards prior to his death, the
decedent, T. A. Miller, and the claimant, Beatrice M. Claus,
were known to their friends and acquaintances as husband and
wife, and that on May 19, 1978, the Reverend I. Ray Berrian
performed a ceremonial marriage at the Herndon Camp Grove,
uniting in marriage T. A. Miller and Beatrice M. Claus. It 1S
further averred that T. A. Miller made public announcement of
the said marriage by telephone to one or more newspapers on
May 20, 1978.
WHEREFORE, Beatrice M. Claus prays your Honorable Court
to dismiss the Petition to revoke, vacate or annul her election
to take against the will of T. A. Miller.
And she will ever pray, etc.
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J mes R. Humer, ttorney or
eatrice M. Claus
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.
. .
STATE OF PENNSYLVANIA
COUNTY OF CUMBERLAND
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Beatrice M. Claus, being duly sworn, according to law,
deposes and says that the facts set forth in the foregoing
Answer are true and correct to the best of her knowledge,
information and belief.
~fL~ ~ ePe~
Beatrice M. Claus ,: \ '
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Sworn to and subscribed
before me this J~tt day
of November, 1978.
",rJY PUBLiC
n flqm~5 July 14, 1981
Cllm~"r!ar.d Counly
I certify that I served copies of the within answer by
ordinary mail, U. S. Postal Service, postage prepaid at Carlisle,
Pennsylvania, addresse. as follows:
Harold S. Irwin, Jr., Esq.
Irwin, Irwin, & Irwin
44 S. Hanover St.
Carlisle, PA 17013
John H. Broujos, Esq.
4 N. Hanover St.
Carlisle,PA 17013
Attorneys for the three churches
James D. Bogar, Esq.
23 W. Main St.
Shiremanstown, PA 17011
Attorney for Township
Carlisle, PA
() ~ /~.)~
. ames R. Humer, Attorney _or
urviving Spouse
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November 27, 1978