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IN THE COURT OF COMMON PLEAS FOB{;+(j~ ~~~d ~ ~ ~~~ ~~; ~ ~
CUMBERLAND COUNTY PENNSYLVANIA
ORPHANS COURT DIVISION CLE~i{ Gr
IN RE: ~~f~N,~,h~'~ ~~~}~?
The Estate of Joseph P. Beil, :
Movant File no. 21-07-0753
MOTION TO MAKE RULE ABSOLUTE
AND NOW COMES, the Estate of Joseph P. Beil by and through its Executrix LeAnne
E. Beil and undersigned counsel, Gates Halbruner & Hatch, PC and files this Motion to Make
Rule Absolute and avers as follows:
On May 7, 2008, the Petitioner, LeAnne E. Beil, filed a Petition for Rule to Show
Cause Why Insurance Proceeds of the Decedent's Life Insurance Policy With Genworth Life and
Annuity Insurance Company Should not be Payable to the Policy Beneficiary LeAnne E. Beil.
2. This Court issued a Rule dated May 12, 2008 and served on May 13, 2008 upon
the known creditors of the Estate of Joseph P. Beil which Rule was returnable within 20 days of
service or June 2, 2008.
3. An Answer to the Rule was filed by Pramco III, LLC on June 2, 2008.
4. A Response to the Rule was filed by Genworth Life on June 3, 2008.
5. The returnable date of June 2, 2008 has passed and to Petitioner's knowledge no
other creditors or parties have filed an Answer or Response.
6. The following creditors were served and did not respond: Becket & Lee LLP,
Bank of America, Chase, Sovereign Bank, eCast Settlement Corporation, Capital One Services,
Commonwealth of Pennsylvania, Chase Auto Finance, Fulton Bank, HSBC Mortgage Services,
IRS Insolvency Unit, MBNA, and Discover Financial Services.
7. Petitioner requests that the Rule be made absolute with respect to the creditors
who did not file a timely response to the Rule to Show Cause.
WHEREFORE, Petitioner respectfully requests that this Honorable Court enter an order
making absolute the Rule issued in this matter on May 12, 2008.
June 10, 2008
Lowe R. Gates, Esq.
Supr e Court I.D. No. 46779
Gate , Halbruner & Hatch, P.C.
101 Mumma Road, Suite 100
Lemoyne, PA 17043
(717) 731-9600
Attorneys for Petitioner
2
IN THE COURT OF COMMON PLEAS FOR
CUMBERLAND COUNTY PENNSYLVANIA
ORPHANS COURT DIVISION
In RE:
The Estate of Joseph P. Beil,
Movant
AND NOW, on this day of
upon consideration of the Motion of
the Joseph P. Beil Estate, this Court finds that the requested relief is appropriate.
The Court therefore Orders that the Rule of May 12, 2008 is absolute as to all creditors
and parties interest who did not file a timely response to the Rule to Show Cause
BY THE COURT,
File no. 21-07-0753
ORDER OF COURT
J.
IN THE COURT OF COMMON PLEAS FOR
CUMBERLAND COUNTY PENNSYLVANIA
ORPHANS COURT DIVISION
In re:
Estate of Joseph P. Beil,
Petitioner File No. 21-07-0753
CERTIFICATE OF SERVICE
I, Sarah E. McCarroll, hereby certify that on this day I served a true and correct copy of
the foregoing Motion to Make the Rule Absolute upon the attached list of potential creditors and
parties-in-interest in the Estate of Joseph P. Beil.
Respectfully Submitted,
June 11, 2008 ~~O_,y~~y ---
Sarah E. McCarron
PA ID 91102
Gates, Halbruner & Hatch, PC
1013 Mumma Road, Suite 100
Lemoyne, PA 17043
717.731.9600
717.731.9627
s.mccan'oll(a~~ateslawfirm.com
ANDREW BEIL
4 SRIARGATE RD
MECHANICSBURG, PA 17050-3178
Bank of America/FIA Card Services formerly M
by eCAST Settlement Corporation
as its agent
POB 35486
Newark NJ 07193-5486
Becket ~ Lee LLP LeAnne E Bei1
PO Box 3001 Pramco III LLC 22 Royal Palm Drive
Malvern, PA 19355-0701 230 CrossKeys Office Park Mechanicsburg, PA 17050-7905
Fairport, NY 14450-3510
I CAPITAL ONE SERVICES
PO BO% 30285
SALT LAKE CITY, TIT 84130-0285
eCAST Settlement Corporation
POB 35480
Newark, NJ 07193-5480
CHASB
900 STEWART AVB
GARDEN CITY, NY 11530-4891
COMM OF PA DEPT OF RBVENUE
BUREAU OF COMPLIANCE
PO BO% 280946
HARRISBURG, PA 17121-0001
Chase Auto Finance
201 N Central Ave
Phoneix az 85004-0073
Az1-1191
FULTON HANR
P 0 HO% 432
EAST PETERSBURG, PA 17520-0432
HSBC Mortgage Services, Inc.
P.O. BO% 21188
EAGAN, MN 55121-0188
IRS INSOLVENCY UNIT #7
WILLIAM GREEN FED BLDG
PO BO% 12051
PHILADELPHIA, PA 19105-2051
William J Levant
Raplin Stewart
Post Office Bax 3037
Blue Be11, PA 19422-0765
SOVEREIGN BANK
601 PENN STRBET
READING, PA 19601-3544
William E. Craig
John R. Morton, Jr.
110 Marter Avenue, Suite 301
Morrestown, NJ 06057-3124
Discover Financial Services
POB 3025
New Albany, OH 43054-3025
HSBC MORTGAGE CORP USA
PO BO% 2393
BRANDON, FL 33509-2393
HSBC as Servicer for Household Financial Ser
c/o Udren Law Office, PC
Woodcrest Corporate Center
111 Woodcrest Road
Cherry Hill, NJ 08003-3620
MBNA
PO BO% 15026
WILMINGTON, DE 19850-5026
David W Carickhoff
Blank Rome LLP
1201 Market Street, Suite 800
Wilmington, DE 19801-1807
Dorothy L Mott
125 State Street
Harrisburg, PA 11101-1025
JPMorgan Chase Bank, N.A./Bank One
201 N. Central Avenue Floor 11
Phoenix, AZ 85004-0073