HomeMy WebLinkAbout06-27-08IN THE COURT OF COMMON PLEAS
CUMBERLAND COUNTY, PENNSYLVANIA
ORPHANS' COURT
IN RE: ROBERT G. TRAVER
and O.C. No. 21-2008-5~ "'
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LOIS J. TRAVER ' _ ~ =' ~"
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MOTION TO MAKE RULE ABSOLUTE :_ _' ~-
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AND NOW COMES, Petitioner, HCR ManorCare -Camp Hill ("Petitioner")n~'
and through its attorneys, ScxuTlEx BOGAR LLC, and files the within Motion To Make
Rule Absolute, and in support thereof respectfully avers that:
1. On June 13, 2008, Petitioner filed a Petition for Accounting with this
Honorable Court, requesting that the Court issue a citation directed to Anna Messimer
to show cause, if there be, why an Order should not be entered requiring her to file a
full and complete accounting of a1I transactions undertaken by her with respect to
Robert G. Traver's assets and income and Lois J. Traver's assets and income from
February 23, 2006, to present.
2. On June 17, 2008, the Court issued a Preliminary Decree to show cause
why an Order should not be entered requiring Anna Messimer to file a full and
complete accounting of all transactions undertaken by her on behalf of Robert G. Traver
and Lois J. Traver, from February 23, 2006, to the present.
3. The Citation was returnable June 20, 2008, at 3:00 p.m.
OR;GINAL
4. The Respondent has failed to submit any response to the aforementioned
citation or to show any cause why such an Order should not be entered by this
Honorable Court directing Ms. Messimer to file an accounting of her actions as the
Agent for both her father and mother.
WHEREFORE, Petitioner respectfully requests that the Court enter an Order
requiring Anna Messimer to file two separate full and complete accountings of aII
financial transactions or actions undertaken by her as the Agent for her father and
mother, Robert G. Traver and Lois J. Traver, from February 23, 2006, to the present.
Respectfully submitted,
Dated: ~ ~ `' ~ ~
SCHUTJER BOGAR LLC
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By.
Kirk S. Sohonage
Attorney L D. No. 77851
(717) 909-8160
Brandon S. Williams
Attorney I.D. No. 200713
(717) 909-5922
417 Walnut Street, 4~ Floor
Harrisburg, PA 17101
Attorneys for Petitioner
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CERTIFICATE OF SERVICE
I hereby certify that a true and correct copy of the foregoing Motion to Make Rule
Alasolute was served via first-class, United States mail, postage prepaid, upon the
fallowing:
Anna Messimer
Date: ` Z ,~ 0 ~
c/o Lowell R. Gates, Esquire
GATES, HALBRUNER & HATCH PC
1013 Mumma Road, Suite 100
Lemoyne, PA 17043
William Keslar, Paralegal