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HomeMy WebLinkAbout06-09-08RE: ESTATE OF RAY A .WIRES, IN THE COURT OF COMMON PLEAS OF DECEASED :CUMBERLAND COUNTY, PENNSYLVANIA ORPHANS' COURT tV ~ 21-06-0653 c o ESTATE NO ` -_ ~ ' '? . ' -~_- c-7 MOTION TO MAKE RULE ABSOLUTE ~ ~ - ' ~ _. ~ _ } . -1 r--, Patti L. Wires, Administratrix of the Estate of Ray A. Wires, Deceas=~ry hettort~ey~y _~ ~ _ _. - - r~ - ~I Snelbaker & Brenneman, P. C., submits this Motion to Make Rule Absoluteand in sulaport `~ tv ` thereof states the following: 1. On May 14, 2008 the Administratrix filed a Motion For Order To Release Administratrix From the Requirement Of Posting Bond with respect to the above Estate. A true and correct copy of the foregoing Motion is attached hereto and incorporated by reference herein as "Exhibit A". 2. On May 21, 2008 this Court issued a Rule upon Renita Nojehl to show cause, if any she should have why the relief requested in the above Motion should not be granted. A true and correct copy of the Court's Order of May 21, 2008 is attached hereto and incorporated by reference herein as "Exhibit B". 3. On May 27, 2008 Counsel for Administratrix Patti L. Wires served upon Patti L. Wires and Renita Nojehl a certified copy of this Court's Order of May 21, 2008 made reference to in Paragraph 2, above. A true and correct copy of the letter transmitting the certified copy of the Order is attached herein and incorporated by reference herein as "Exhibit C" 4. Ten days have elapsed from the service of the Court's Order of May 21, 2008 upon Ms. Nojehl and no response has been received by the attorney for the Administratrix or filed with the Office of the Register of Wills of Cumberland County. LAW OFFICES SNELBAKER SC BRENNEMAN, P.C. WHEREFORE, Patti Wires, Administratrix requests this Court to issue an Order making is Rule absolute and to release the Administratrix from the requirement of posting a bond with Register of Wills with respect to the above Estate. SNELBAKER & BRENNEMAN, P. C. BY: Keith O. Brenneman, Esquire 44 W. Main Street Mechanicsburg, PA 17055 (717) 697-8528 Date: June 9, 2008 Attorneys for Administratrix Patti L. Wires -2- LAW OFFICES SNELBAKER EC BRENNEMAN, P.~C. -~, .r ;, ~Q~ ~' l ~- ~~~ 19 = 30 IN RE: ESTATE OF RAY A. WIRES, DECEASED h ('S ~ A AMY ~,J ~'Rf11 ~~ ~ L>~rl L~ l ' J ~ IN THE COUR~'~E~CONII~T~~AT ~r~,EAS OF CUMBERLAND COUNTY, PEI~TNSYLVANIA ORPHANS' COURT ESTATE NO. 21-06-0653 MOTION FOR ORDER TO RELEASE ADMINISTRATRIX FROM THE REQUIREMENT OF POSTING BOND Patti L. Wires, Administratrix of the Estate of Ray A, Wires, Deceased.. by her attoi7leys, Snelbalcer & Brenneman, P. C., submits this Motion and in support thereof states the following: 1. Ray A. Wires died June 2, 2006 intestate in Cumberland County, Pennsylvania. 2. On July 21, 2006 Letters of Administration were issued to Patti L. Wires, Decedent's sister, who resides in Tontogany, Ohio. 3. As a condition of Patti L. Wires serving as Adminstratrix of the Estate of Ray A. Wires, Patti L. Wires was reduired to post bond, which bond was filed in the Office of the Register of Wills of Cumberland County, 4. Administration of the Estate of Ray A. Wires has been completed with the sole beneficiaries thereof, being the Administratrix, Patti L. Wires, and her sister, Renita M. Nohejl, entering into an agreement dated December 19, 2007. ~. On April 1, 2008 a Status Report under Rule 6.12 was filed with. the Office of th° Register of Wills in Cumberland County indicating that the administration of the Estate is complete. 6. All distribution to the two beneficiaries has been completed. LAw oFFicEs SNELBAKER He BRENNEMAN, P.C. EXHIBIT A 7. The surety that issued the bond posted by Patti L. Wires with the Office of the Register of Wills of Cumberland County, Pennsylvania, being Ohio Casualty Insurance Co., will ~ continue to maintain the bond unless a Court Order is provided indicating that the I Administratria' Bond can be released. WHEREFORE, Patti L. Wires requests this Court to issue an Order directing that she can be can be released from the obligation to post a bond in her capacity as Administratrix of the ~ Estate of Ray A. Wires. Respectfully Submitted, SNELBAKER & BRENNEMAN, P. C. 1 ~~'~~-~ BZ': Keith 0. Breruleman, Esquire 44 W. Mails Street Mechanicsburg, PA 170~~ (717) 697-5528 Date: May 12 , 2008 Attorneys for Administratri~ Patti L. Wires -~- LAw o~icEs SNELBAKER BC BRENNEMAN, P.C. VERIFICATION I verify that the statements made in the foregoing Mation are true and correct. I I understand that false statements herein are made subject to the penalties of 18 Pa.C.S. Section 4904 relating to unsworn falsification to authorities. Keith O. Brenneman Date: May 12, 2008 LAW OFFICES SNELBAKER & BRENNEMAN, P.C. CERTIFICATE OF SERVICE I, KEITH O. BRENNEMAN, ESQUIRE, hereby certify that I have, on the below date, caused a true and correct copy of the foregoing Motion to be served upon the persons and in the manner indicated below: FIRST CLASS MAIL. POSTAGE PREPAID. ADDRESSED AS FOLLOWS: Patti L. Wires 18725 Washington Street Tontogany, OH 4365 ~~ I~ Date: May ~, 2008 Renita M. Nohejl 4716 Fairway Drive Brooklyn, OH 44144 SNELBAKER & BRENNEMAN, P.C. 1j By: Keith O. Brenneman, Esquire 44 W. Main Street P, O. Box 318 Mechanicsburg, PA 170» (717) 697-8528 Attorneys for Administratrix Patti L. Wires LAW OFFICES SNELBAKER BC BRENNEMAN, P.C. LAW O~ICES SNELBAKER & BR ENNEMAN, F.C. MAY ~ 5 2DO~i IN RE: ESTATE OF RAY A. WIRES, DECEASED IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA ORPHANS' COURT ESTATE NO. ? 1-06-0653 ORDER AND NOW, this (~ day of , ?008, upon consideration of the Motion For Order To Release Administratrix From The Requirement Of Posting Bond, it is hereby ORDERED that a Rule is issued upon Renita M. Nojehl to show cause, if any she should have, why the relief requested in the foregoing Motion should not be granted. RULE RETURNABLE within ten (10 j days of the date of service of this Order upon Renita M. Nojehl. v~ .;; ,~, ~7 [` ~. t J ~' ~~ ~,' ~c ,~ r~~t ~~)L I ._. ~i ~_, _, I J. _ EXHIBIT B ks~ ~'~stimc~~y wharc~t, ~ h~reunt~ yet my hand and a~~ ~aa8 ~t s~~au~~ a ~~~ciws6~, F~ ~, , t~,rp'9a'"irim C:fIUrE riz.rrd ;:caunt~' ~' i SNELBAKER F3 BRENNFMA.N, P.C. A PROFESSIONAL CORPORATION ATTORNEYS AT LAW 44 WEST MAIN STREET MECHANICSBURG, PENNSYLVANIA 17055 RICHARD C. SNELBAKER KEITH O. BRENNEMAN Patti L. Wires 18725 Washington Street Tontogany, OH 43565 Re: Estate of Rav A. Wires Dear Ms. Wires and. Nojehl: 7l7-697-8528 P. O.. BOX 3t8 FACSIMILE (717) 69J-7681 May 27, 2008 Renita Nojehl 4716 Fairway Drive Brooklyn, OH 44144 Enclosed please find a certified copy of the Order issued May 21, 2008 to show cause wh}~ the relief that I requested in the Motion to excuse Patti from posting a bond. should not be granted. Yours truly, ItOB~sm Enclosure Keith O. Brenneman E%HIBIT C CERTIFICATE OF SERVICE I, KEITH O. BRENNEMAN, ESQUIRE, hereby certify that I have, on the below date, caused a true and correct copy of the foregoing Motion to be served upon the persons and in the manner indicated below: FIRST CLASS MAIL POSTAGE PREPAID ADDRESSED AS FOLLOWS: Patti L. Wires 18725 Washington Street Tontogany, OH 43565 Renita M. Nojehl 4716 Fairway Drive Brooklyn, OH 44144 By: Date: June 9, 2008 SNELBAKER & BRENNEMAN, P.C. i~ Keith O. Brenneman, Esquire 44 W. Main Street P. O. Box 318 Mechanicsburg, PA 17055 (717) 697-8528 Attorneys for Administratrix Patti L. Wires LAW OFFICES SNELBAKER FjC BRENNEMAN, P.C.