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HomeMy WebLinkAbout02-1126PETITION FOR PROBATE and GRANT OF LETTERS Estate of ~ ~i2°~ - c9 ~ ~~ 2i-~~-ilal. also known as No. To: Register of Wills for the _ ~ Decea ed. County of CUDIBERLAND Social Security No. ~ - b=oa in the Commonwealth of Pennsylvania The petition of the undersigned respectfully represents that: Your petitioner(s), who is/are 18 years of age or older an the execut~~ -`' ;/ in the last will of the above decedent, dated i ~i ~.,_, ~ c~sL named and codicil(s) dated , -u}_ (state relevant circumstances, e.g. renunciation, death of executor, etc.) Decendent was domiciled at death in Cu ~_ 1~ t famil or principal residence at 7_S-- ~ CO~tptY, Pe nsYly nia, with at ~ ' u~i-L l,~ 1 (list street, number and muncipality) -~. r ~~~ ,~ _ _ y , Except as follows, decedent after execution oft will o fe incompetent: of age, tot marry, was not divorced and did not have a child born or adopted or probate; was not the victim of a killing and was never adjudicated Decendent at death owned property with estimated values as follows: (If domiciled in Pa.) All personal property `' (If not domiciled in Pa.) Personal property in Pennsylvania $ ~ ~ ~ G"-9 V (If not domiciled in Pa.) Personal property in County $ Value of real estate in Pennsylv. nia .- $ -<, sit~~ted ~ follows: ~~~ '~- ~ . n ~ cr ~ ~ ~.. -z-- ~ ~ ~~ ~ ~>r WHEREFORE, petitioner(s) respectfully req est(s) he probate f the last presented herewith and the grant of letters - nd codicil(s) theion. (testamentary; administration c.t.a.; administration d.b.n.c.t.a.) U G '~ ~ N t. ~. C -cy O C '« ~ 'i ~a N ~.. ~ O cC G bq OATH OF PERSONAL REPRESENTATIVE COMMONWEALTH OF PENNSYLVANIA 1 COUNTY OF CUMBERLAND r S3 The petitioner(s) above-named swear(s) or affirm(s) that the statements in the foregoing petition are true and correct to the best of the knowledge and belief of petitioner(s) nd that as personal represen- tative(s) of the above decedent petitioner(s) will well and truly min' ter the es rdin to law. Sworn to or affirmed and subscribed before me this ~ ~ th day of ~ IIECEMBFR ~ ~, ~, t ,~ ~• ~ ~ ) x9~ ~nn2 a Re 'ter No. 2.1-Oo1-11 alv Estate of R. CREE FnT7. AKA R(~RF.RT rR,~~ ~'~J~~'g ,Deceased DECREE OF PROBATE AND GRANT OF LETTERS AND NOW DEf'~MBER 11, 2002 19 , in consideration of the petition on the reverse side hereof, satisfactory proof having been presented before me, 1T 1S DECREED that the instrument(s) dated ~ - 2 - 2 0 01 described therein be admitted to probate and filed of record as the last will of R. CREE FOTZ AKA ROBERT CREE FOtiTZ and Letters TESTAMENTARY are hereby granted to ROBERT C FO~TZ .TR e FEES Probate, Letters, Etc. ......... X 3 7 5. 0 0 Short Certificates( ) .......... $ 15 . 0 l~I~ii~~ .~~ra..pag~.s. $ 3.00 jcp ~ 10.00 TOTAL ~ 403.00 Filed .~ .12-11-2002 ma~Yec~~ ~to ~atty ~ 12-11~-2002 Register of Wills d~~~' V // / _ i ATTORNEY (Sup. Ct. LD./No.) ADDRESS PHONE ~[ hls is to ct?~tift~ rirat the inforn.larion here given is correctly copied ~(:~n) <~)~ original ccrtiEicatL o~ dcaT c?~ri~ ~ 11.^c ~~)t~) ~r~~ :_> Local Rtgistrtr. Tile original cc~.r:~uare will be.!o~rwarded ro the JCC)~: 1'trai Records Office tol pe-n~a1.,t ~ `ii (s,. WARNI~6G: !t is illegal to duplicate this Copy Tay photostat or photograph. P 8704063___ H1OS.I V Rav. 2187 nNT EMT NK a• ~cw..cS~.~lt~s' ~_(>~at ~z~~~~~,r~~~r ~QY_~~_2(1Q2____-- >.(' COMMONWEALTH OF PENNSYLVANIA • DEPARTMENT OF HEALTH • VITAL RECORDS CERTIFICATE OF DEATH NAME OF DECEDENT If vn. MWda, ual SEX SOCIAL SECURITY NUMBER DATE OF DEATN,MOM. Day.'Aw) 11/22/2002 5804 03 M 181 ,. Robert Cree Foltz .. - ,. - ,. AGE (Lan B+IMay) UNDfR t YEM UNDER f DAY DATE OF &RTH BIRTMPI.ACE 1CM ane PUCE OF DEATH ICnecw Dray nne -see iMlrucworra on aMr noel Mdana r D•H Hears r M'vwlw !Mpnln. Oay.'tnl Salad Faegn CMlNfyl 9/30/1911 andisburg, PA HO$pITAL: OTHER: nroat.naf7 ENOIApN4d ^ DDA C N,w„U0"'9e ^ RwdarKe ^ ;~ yl ^ 91 Yn. r 6. 7. M. COUNTY OF DERH CffY, BORO. TWP OF DEATH FACKf (Y NAME In rrq mnlulgn. give enM all numbwi VMS~~Ot7ECEDEM OF HISPANIC ORIGIN? ~ EN1 meson M6an. 844. Wni.. eN. ecM CWen No [1n Ise ^ n w e I Carlisle Boro. a Cumberland , y . p rlisle Regional Medical Center WaifJln.Prwbfllon,MC. „White k w DECEDEM'9 USUAL OCCUPQION KINOOF BUSINESS/INWSTRY VMS DECEDENT EVER IN DECEDENT'S EDUCATION MARITAL STATUS•MerMe SURVWpnG SPOUSE U.S. ARMED fORCEST n doe com Naver~ In mN. 4•. rtrnoanrwNl (Give wrW d.ak One our mcw d `M0"'kr4w'; m rrw vea re~rca.l E4mwuvylSewneary Cortege ^ ® rvice salesman E~ocon Corp. S vw No j°'zj 4 "'""' Married Annie C. Bisht~-lyn~ VC e 110. • l,a ,,. /,. 11. ,!. . DECEDEM'S MAKING ADDRESS ryrM.CM~T n. S1a4. ZOCooe1 DECEDENT'S West ennS rO PA lMAl 7 b 1' ) ~ ra n , 1e 0ece Dla ~. e i ACTUAL 17a. SMIe 2175 Newville Road RESIDENCE eve n. ,. Carlisle PA 17013 ~e,,,p„~,pn, °"°"'°rIIOe' ,,,. Cumberland '°"'""'°' ,7e.^ ~! nd fRMER'S NAME 1Fvn, Mode. Lan) MOTHEfl'S NAME IFwn. M~eele. Magwr Swnams) Annie - Swisher ,!- Robert C. Foltz „- ' aeFORMANT'S NAk1E (TrpegrM I S MMtINO ADDRESS (Street CM/Te•'n. 544. Zp CQdel NFORMANT 2175 Newville Road, Carlisle, PA 17013 Annie C. Bis Foltz „ ,,,• a• METHOD OF DISPOSIT ORE OF DISPOSITION n4,4n ^ Rnnovw kom SIMe ^ P,wn+. Ow, rant l~ cr e PLACE OF DISPOSRgN- Name d Cwlwery, Gamaay LOCA7gN • CilylTww, gape. Zb Woe a an« Pl.c. Per County ~ wr e ~^ ~«~1+ ^ 11/27/2002 sburg, PA Land Landisburg Cemetery ,,,• .:,~ „ „e. f Y ' SIGNRURE OFF RVICE LICENSE PE TINO AS SUCH LICENSE NUMBER NAME AND ADDRESS OF FACN.f FD 012633 L ~kaing Brothers Funeral Hone, Carlisle, PA 17013 a~ %.~ ,,, Wmplwe eema „as aey wren unMtrq b,M pen d row4egs, seals occurcW at IM tmie, a to and qau nateo. LICENSE NUMBER 2 , " DQE SM,NEO Z~I (/ MorMl. DM lrrl aMeiarn s nw milapN n,trw n Ham 4 rypwure and Tine) , / p , / ~ ~ S 3 ' Q J ) S (,~ 2 Z O Z nuw o, ann •L • mone / 1V , - ( / F y . w xac. . x,.. ~- Menu 2a•26 map W COmp4IW trY TMAE OF DEATH DATE PRONOUNCED DEAD IMOnm. Dey, Year) VMS CASE REFERRED TO MEDICAL EXAMINEFUCORONER7 ,/ {J ° N ` o person more prdqunew ewm. ~ I I ~ Z I O z n. a• I u : 5v t' M n . . :.. aT. PART I: EMM IM eeeaws, wrjuriee a COTpnta,grrt r,niCn ulnae tM eea,n. W nd wler IM moll el eyirrq, sacs ae grdac a respiralery amen, slreck or Marl hiWre. i Appn):MM4 PART B: Olnn fiOniM1CeM OerldYpM OdWipYlerQ b eNm• D1R linens penreen nO, reMleilrq trr Bra lareennrq oww pven4 PAM 1. LW OMy Orre Cnne On ea4 nM. I arp arse own ERIEd11TE GIRE(Fwr ~n ~. /~. v I ,.p.n, e, Deem)--- TOR ASA OUENCE OFT. ~~, ` i DVE J r ' , ` J / ^~ C Sepww,aF, aw rnrmuorre D. II any, 4prry b arvrreeiale DUE 70108 AS A CONSEQUENCE OFT: I awe. Eller UNDERLYNq , DAVSE 10i,eer or vyuy c. sr erred e.+rw DUE TO 108 AS A CONSEQUENCE OFT rasu4npneeawl WT e. y11e.4 AN AUTOPSY WERE AU70PSY FINdNG3 MANNER OF DEATH DATE OF IW URY TIME OF INJURY INJURY QVJORKT DESCRIBE MOW IWURY OCCURRED. PERFORME% Ma4LABLE PRgR 10 F CA E ~ (Maven. OM. Yawl COMPLE,1011 O US 7( HdnieiEe ^ Na1wn ~ OF DEATHT / I) Vw ^ No ^ AACnwa ^ Paneirp NHesllge,igl ^ ]ee ,e0. M• Y ^ N ~ Yw ^ Ne 1 1 , 7 [ S"IC7ee ^ CouM ml ee dnemunea ^ . PUCE OF IW URY -,4 nome.4rm, reran. 4day. olM1Ca LOCATgN (Strew. CMlbwn. S4,a) o w 1 7 E - DuaMrq. Me. ISpeNv) ,~, 3!0. h. ]pe. ,01. CERfIF1ER ICnsck oNyrfrw - 'eERrvYINO PHYSICIAN IPnyecan cdnlymg vr,e. d deem wren anann Onvscan Ms prgquntea seam arq conpnee nem Z,1 TO Yle peel el my knew40ga, deem oecunw ew b m. eau+e(el arts manner w gnae ..................................................... ~ SIGNATURE AND TI EOF CEiLTIFIE L „p, - ml d LICENSE NU R DATE NED IMmn, ,tMrl ~ ~ J ~Z ~3 eea •/IgIgUNCNNi AND CERTIFYIND PHYSICIAN(Pnyscan pqn prorrourrevrq ceam ane<Mdyvg locausa arts Rue le IM eeuse(el arts manner ee wnW ........................ ^ leee arts t e ,I e 4 .. ~ ~ O ,te. „e „ ' P , re nre, e , ~ Ta,I,e pM n my krowNegn, seem Pecw.w a NAME AND ADDRESS OF R50~ ~O COMP).ETED ~lJ~ ~H~'/~ ~Q (nem 271 Type or Prin, ~~ PY N ~ Cy/tJL p - •MEDN;AL EXAMINER/CORONER On Metleeis o, eaaminatbn andlo, Inves,lga,ion,in my opinion,dee,l, octanes a„M,Ime,da,e,aM Place, arM eue,o me uuse(s)and ^ ................................................. ..... ..... . s wa,W Q J~( ~ ~ 70 ~j ~ q ~ ........................... ,nrlner a „a. ~_ , : ~ ~ REGISTRAR'S SGNATURE AND NU ~ ~ I~~ n. A w- ° DATE FILEDIMWrm. Day. 1 ,,. ~ , as ac~oa~ LAST WILL AND TESTAMENT R CREE FOLTZ d2 /-0~-` 11,1.(0 I, R. CREE FOLTZ of 2175 Newville Road, Carlisle, Cumberland County, Pennsylvania, being of sound and disposing mind, memory and understanding do hereby make publish and declare this my Last Will and Testament, hereby expressly revoking all other writings in nature testamentary by me at any time heretofore made. FIRST: I direct that all my debts and funeral expenses be paid as soon after my decease as may be practicable. SECOND: I direct that inheritance tax on property disposed of herein shall be paid from my residuary estate. THIRD: I give, devise and bequeath the sum of Fifty Thousand Dollars together with my residence in West Pennsboro Township, Cumberland County, Pennsylvania to my wife, Anna C. Foltz. FOURTH: I give and bequeath One Hundred shares of Exxon Mobile stock to each of my grandchildren living at the time of my death. FIFTH: I hereby give, bequeath and devise all the rest and residue of my estate and property, real, personal and mixed, of whatsoever nature and wheresoever situated of which I may own at the time of my death, or to which I may be entitled or of which I may have the right to dispose at the time of my death, to my son, Robert C. Foltz, Jr.. -~ - (SEAL) R. CREE FOLTZ Page one of two SIXTH: I hereby appoint my son, Robert C. Foltz, Jr., as Executor of this, my Last Will and Testament, but in the event he is unable or unwilling to serve, I then appoint my granddaughter, Lisa Beattie, as Executor of this, my Last Will and Testament. I further direct that they shall not be required to give bond or other security in any jurisdiction wherein proceedings may be held in connection with my estate. IN WITNESS WHEREOF, I have hereunto set my hand and seal this 2nd day of July, 2001. ~.. --~', l -r ~ __. -+~ .rl (SEAL) R. CREE FOLTZ °~"~ J ;J Page two of two i ( s ; REGISTER OF WILLS OF ~~ ~^ ~~ COUNTY OATH OF SUBSCRIBING WITNESS a ~ - ~a- I la.to _{eae#) a subscribing witness to the law, depose(s) and say(s) that ~etl- will presented herewith, (each) being duly qualified according to ,p c~~ present and saw the testate, sign the same and that , signed as a witness at t>he request of testate in h ~ S Presence and (in the presence of each other) (in the presence of the other subscribing witness(es)). Sworn to or affirmed and subscribed before j ~ y`'}' day of me this ~ aoo~- ~. ~.,.~' gister (Address) (Name) (Address) ~~~UNTY REGISTER OF WILLS OF OATH OF NON-SUBSCRIBING WITNESS ~ t - oa.-- - t ~.co t~~ ~, (eac) subscriber hereto, (each) being duly qualified according to"Iaw, _familiar with the signature of J testat of (one of the subscribing witnesses to) the will ,. ~-, that to the best of believes the signature on the a ~ ~ ~- depose(s) and presented herewith and codicil will is in the handwriting of knowledge and belief. ~ ~ ,~- Sworn to or affirmed and subscribed before p~'h day of e this __,__- - r ~ 1t,5~' ~ ,~p~~ Regis er 1_ _ _ ~ . (~C.~~ oC~ _ 1 /Na e %~---- (Addy ss) ~ ` _ ~ ~ ~~ j ~ ~ ~ ~ /d7 (Name c. ,~ ~"? ,. (Addy ~ ` ,~ .~/ ~~~ / ~ D ~ rF ~~ ~`;, CERTIFICATION OF NOTICE UNDER RULE 5.6(a) Name of Decedent; R ree Foltz Date of Death: 11/22/2002 Will No. Admin No. 2002-01126 To the Register: I certify that notice of beneficial interest required by Rule 5.6(a) of the Orphan's Court Rules was served on or mailed to the following beneficiaries of the above-captioned estate on Janu____a_rv ? 1.~ 2003 Name A r Anna C. Foltz of 2175 Newville Road Carlisle PA 17013 Lisa F Beattie of 240 ShadtiLane_ Carlisle PA 17013 Jennifer G Nailor of 340 Pleasant Hall Road C'arhsle PA 17013 Jac.~ueline R Dommel of 336 Toll Gate Road York. PA 17403 Notice has now been given to all persons entitled thereto under Rule5.6(a)except Date: January 22, 2003 ~~' ~~~~' - Signature Name Gerald K Morrison, Esquire Address Center Square New Bloomfield, PA 17068 Telephone(717L5 82-2300 Capacity Personal Representative X Counsel for personal Representative COMMONWEALTH OF PENNSYLVANIA DEPARTMENT OF REVENUE BUREAU OF INDIVIDUAL TAXES DEPT. 280601 HARRISBURG, PA 1 7 1 28-0601 RECEIVED FROM: FOLTZ ROBERT C JR 238 SHADY LANE CARLISLE, PA 17013 fold PENNSYLVANIA INHERITANCE AND ESTATE TAX OFFICIAL RECEIPT ESTATE INFORMATION: ssrv: ia1-o3-5so4 FILE NUMBER: 2102-1 126 DECEDENT NAME: FOLTZ R. CREE DATE OF PAYMENT: 08/15/2003 POSTMARK DATE: 08/14/2003 couNTY: CUMBERLAND DATE OF DEATH: 1 1 /22/2002 ACN ASSESSMENT CONTROL NUMBER AMOUNT 101 ~ 59,000.00 TOTAL AMOUNT PAID: REMARKS: C/O GERALK K MORRISON, ESQ CHECK# E-7 SEAL INITIALS: AC RECEIVED BY: DONNA M. OTTO 59,000.00 DEPUTY REGISTER OF WILLS REV-1162 EX(11-96) NO. CD 002907 REGISTER OF WILLS IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYI,VANIA ORPHANS COURT DIVISION IN RE: ESTATE OF R. CREE FOLTZ, : An Incapacitated Person : : NO. ORPHANS CT. : : Petition for Citation to Show Cause Why the Executor Should Not Be Removed in Accordance with 20 Pa. Cons. Stat. §§ 3182 and 3182 or in the Alternative, Directing the Executor to promptly Administer The Estate And Distribute the Specific Bequests Thereon TO THE HONORABLE, THE JUDGES OF THE COURT: -~ The petition of Anna Foltz respectfully states that: 1. She is the widow of R. Cree Foltz late of Cumberland County, Pennsylvania with a current residence of 2175 Newville Road, Carlisle, Pennsylvania. 2. R. Cree Foltz ("testator") died November 22, 2002, leaving a will dated July 2, 2001, a copy of which is attached hereto and marked as Exhibit "A." 3. Letters testamentary were granted to the testator's son, Robert C. Foltz, Jr., (executor") of Carlisle, PA by the Register of Wills of Cumberland County, Pennsylvania. 4. After directing the payment of her debts and specifically bequeathing certain paintings, the testator made the following disposition of his estate: THIRD: I give, devise and bequeath the sum of Fifty Thousand Dollars together with my residence in West Pennsboro Township, Cumberland County, Pennsylvania to my wife, Anna C. Foltz. 5. As a pecuniary legatee, petitioner has an interest in the efficient administration of this estate. 6. Since qualifying to serve, the Executor has both taken actions and failed to take other actions, which have extended this estate administration for a period of more than sixteen (16) months into its second year. 7. The Executor has sought to obtain personal property which Petitioner, the widow, has claimed as property by the entireties but has taken no legal action to determine ownership thereof. 8. The Executor has refused and failed to distribute the pecuniary bequest of $50,000.00 or deliver the deed to the petitioner's residence as required by the Last Will & Testament of the decedent as provided in paragraph 3 above. 9. The refusal and failure of the Executor is the result of his demonstrated personal animus toward Petitioner. 10. The Petitioner is currently ~'l years of age and further delay in the administration of the Estate and distribution of the specific bequests made to her in the Last Will & Testament will cause her substantial anguish. 11. For these reasons, petitioner further believes that the interests of the estate are likely to be jeopardized by the Executor's continuance in office and intervention is necessary to protect the property of the estate. 12. The history of this estate administration and the personal animus of Executor toward Petitioner mandates the drastic measure of removal of the Executor, or in the alternative an Order mandating prompt distribution of the pecuniary bequests Estate assets to which Petitioner is entitled. WHEREFORE, petitioner requests that a citation be awarded, directed to R. C. Foltz, Jr., to show cause why he should not be removed as executor of the will of R. Cree Foltz, Deceased, within twenty (20) days. Anna Foltz Petitioner VERIFICATION I, ANNA FOLTZ, Petitioner, in this action hereby state that the statements of fact made in the foregoing Petition are true and correct to the best of my information and belief. The undersigned understands that the statements herein are made subject to the penalties of 18 Pa.C.S.A. §4904 related to unsworn falsification to authorities. ANNA FOLTZ CERTIFICATE OF SERVICE I hereby certify that a copy of the within Petition has been mailed by the undersigned, by U.S. Mail, first-class, postage prepaid, on the. (~ day of. 'fi~vrl 1 2004, addressed to: Robert C. Foltz, Jr. 238 Shady Lane Carlisle, PA 17013 Date: %C$~o~c Steven J. Fishman, Esquire Attorney I.D. No. 16269 Salzmann, Hughes & Fishman, P.C. 95 Alexander Spring Road, Suite 3 Carlisle, PA 17013 (717) 249-6333 Attorney for Petitioner MOI~RISON LAW 1717S822~00 12/1~./02 0~:08pm P. 002 LAST WILL AND TESTAMENT OF I, R. CREE FOLTZ of 2175 Newville Road, Carlisle, Cumberland County, Pennsylvania, being of sound and disposing mind, memory and understanding do hereby make publish and declare this my Last Will and Testament, hereby expressly revoking all other writings in nature testamentary by me at any time heretofore made. FIRST: I direct that all my debts and funeral expenses be paid as soon after my decease as may be practicable. SECOND: I direct that inheritance tax on property disposed of herein shall be paid from my residuary estate. THIRD: I give, devise and bequeath the sum of Fifl-y Thousand Dollars together with my residence in West Pennsboro Township, Cumberland County, Pennsylvania to my wife, Anna C. Foltz. FOURTH: I give and bequeath One Hundred shares of Exxon Mobile stock to each of my grandchildren living at the time of my death. FIFTH: I hereby give, bequeath and devise all the rest and residue of my estate and property, real, personal and mixed, of whatsoever nature and wheresoever situated of which I may own at the time of my death, or to which I may be entitled or of which I may have the right to dispose at the time of my death, to my son, Robert C. Foltz, Jr.. 4...Q ~". ~,..e~ '": · R. c~E F~L;i'Z " .~ - - Page one of two HORRI~ON LAW 1717S822~0~ 12/11/~2 0~:08pm P. 00~ i' SIXTH: I hereby appoint my son, Robert C. Foltz, Jr., as Executor of this, ray Last Will and Testament, but in the event he is unable or unwilling to serve, I then appoint my granddaughter, Lisa Beattie, as Executor of this, my Last Will and Testament. I further direct that they shall not be required to give bond or other security in any jurisdiction wherein proceedings may be held in connection with my estate. IN WITNESS WHEREOF, I have hereunto set my hand and seal this 2nd day of July, 2001. ~ W~SSS: Page two of two COMMONWEALTH OF PENNSYLVANIA REV-1162 EX(11 96) DEPARTMENT OF REVENUE BUREAU OF INDIWDUAL TAXES DEPT 280601 HARRIS~3U RG, PA 17128 O601 PENNSYLVANIA RECEIVED FROM: INHERITANCE AND ESTATE TAX OFFICIAL RECEIPT NO. CD 004462 MORRISON GERALD K ESQ CENTER SQUARE P.O. BOX 232 NEW BLOOMFIELD, PA 17068 ACN ASSESSMENT AMOUNT CONTROL NUMBER ........ fold .......... 1 01 $1,680.44 ESTATE INFORMATION: SSN'. 181-03-5804 FILE NUMBER: 2102- 11 26 DECEDENT NAME: FOLTZ R. CREE DATE OF PAYMENT: 1 0/04/2004 POSTMARK DATE: 1 0/01/2004 COUNTY: CUMBERLAND DATE OF DEATH: 11/22/2002 TOTAL AMOUNT PAID: $1,680.44 REMARKS: CHECK# E-18 INITIALS: JA SEAL RECEIVED BY: GLENDA FARNER STRASBAUGH REGISTER OF WILLS REGISTER OF WILLS COM.ONWEALTHOF REV'1500 o.,e, es, oNLY PENNSYLVANIA DEPARTMENTOE.EVENUE INHERITANCE TAX RETURN "'E.UMSE. DEPT. 280601 "A""ISBURO, Al,126-0601 RESIDENT DECEDENT 2 - 0 2 12 8 DECEDEN]~S NAME (LAST, FIRST, AND MIDDLE INITIAL ~ SOCIAL SECURITY NUMBER z Foltz, R. Cree 1 8 1-0 3-5 8 0 4 LU DATE OF DEATH (MM-DD-Year) DATE OF BIRTH (MM-DD-Year) THIS RETURN MUST BE FILED IN DUPLICATE WITH THE 14.1 0 11/22/2002 0913011911 REGISTER OF WILLS M.I (IF APPLICABLE) SURVIVING SPOUSE'S NAME (LAST, FIRST, AND MIDDLE INITIAL) t't SOCIAL SECURITY NUMBER AnnaC. Foltz 1 7 4 - 0 5- 3 7 O 9 ~ [] l. OdginalRetum [] 2. SuppiementalReturs [] 3. RersainderReturs (d~ofdea~p,or~12-13-82) ~ [] 4. LimitedEsteta [] 4a. FuturelnterestComprorsise(d~dde~aSer12.12.82) [] 5, Federal Estate Tax Ret~Jm Raquired := ~ o, [] 6. Decedent Died Testate (Attach copy of W~II) [] 7. Decedent Maintained a Living Trust p.~ach cc, py of Trus~ ~ 8. Total Nursber of Safe Deposit Boxes < [] 9. Litiga~n Proceeds Received [] 10, Spousal Poverly Credit (dm ofde~ bet~e, 12-31-~1 a~d 1-1-95) [] 11. Election to tax under Sec. 9113{A) (A~ch SeE z Gerald K. Morrison, Esquire ~ P.O. Box 232 o TELEPHONE NUMBER ~ (717)582-2300 New Bloomfield PA 17068 1.R.,Estate(schedu,a^) (1) 1770 2. Stocks and Bonds (Schedule B) (2) 191;~32.00 3. Closely Held Corpora~on, Pa~emhip or Sole-Propdetership (3) , 4. Mortgages & Notes Receivable (Schedule D) (4) 5. Cash, Bank Deposits & Miscellaneous Personal Probe~ (5) 124,985 54 (Schedule E) ~ 6. JointJy Owned Property (Schedule F) (6)  [] Separate Billing Requested "'t 7. Inter-Vivos Transfem & Miscellaneous Non-Probate Property (7) I.- (Schedule G or L) ~ 8. Total Gross Assets (total Lines %7) (.,1 (8) 421,617.54 ILl 9. Funeral Expe~es & Adrsinistrative Costs (Schedule H) (9) 23,797.20 10. Debts of Decedent, Mortgage Liabilities, & Liens (Schedule I) (10) 7,269.85 11. Total Deductions (total Lines 9 & 10) (11) 31,067.05 12. Net Value of Estate (Line 8 rsinus Line 11) (12) 390,550.49 13. Charitable and Governrsental Bequeste/Sec 9113 Trusts for which an eieotion to tax has not been (13) rsede (Schedule J) 14. Net Value Subject to Tax (Line 12 rsines Line 13) (14) 390,550.49 ~ rate, ortmnsfersunderSes. 9116(a)(1.2) 155,000.00 X 0 (15) 0.00 ~ 16. AmountofLine14taxabieatlinealrate 235,550.49 X .045 (16) 10,599.77 ::3 ~ X .12 (17) t.3 X .15 (18) ~ 19. Tax Due (19) 10,599.77 I-- Decedent's Complete Address: STREET ADDRESS 21 75 Newville Road CITY Carlisle I STATE PA I ZIP 17013 Tax Payments and Credits: 1. Tax Due (Page 1 Line 19) (1) 10,599.77 2. Credits/Payments A. Spousal Poverty Credit B. Prior Payments 9~000.00 C. Discount Total Credits (A + B +C) (2) 9,000.00 3. Interest/Penalty if applicable D. Interest E. Penalty Total Interest/Penalty ( D + E ) (3) 4. If Line 2 is greater than Une 1 + Line 3, enter the difference. This is the OVERPAYMENT. Check box on Page I LiRe 20 to r~luest a refund (4) 5. If Line 1 + Line 3 is greater than Line 2, enter the difference. This is the TAX DUE. (5) 1,599.77 A. Enter the interest on the tax due. (SA) 80.67 B. Enter the total of Line 5 + 5A. This is the BALANCE DUE. (SB) 1,680.44 Make Check Payable to: REGISTER OF WILLS, AGENT PLEASE ANSWER THE FOLLOWING QUESTIONS BY PLACING AN "X" IN THE APPROPRIATE BLOCKS 1. Did decedent make a transfer and: Yes No a. retain the use or income of the property transferred; ........................................................................... [] [] b. retain the right to designate who shall use the property transferred or its income; ........................................ [] [] c. retain a reversionary interest; or ...................................................................................................... [] [] d. receive the promise for life of either payments, benefits or care? ............................................................. [] [] 2. If death occurred after December 12, 1982, did decedent transfer proper~Y within one year of death without receiving adequate consideration? ............................. [] [] 3. Did decedent own an "in trust for' or payable upon death bank account or security at his or her death? ................. [] [] 4. Did decedent own an Individual Refirement Account, annuity, or other non-probate property which contains a beneficiary designation? ....................................................................................................... [] [] IF THE ANSWER TO ANY OF THE ABOVE QUESTIONS IS YES, YOU MUST COMPLETE SCHEDULE G AND FiLE IT AS PART OF THE RETURN. Under [ decla'e th and to the best of my knowledge e~d belief, it is fide, correct ade complete. DATE ;,< 09/30/2004 PA 17013 DATE 09/30/2004 ADDRESS P.O. Box 232 New Bloomfiel PA 17068 For dates of death on or after July 1, 1994 and before January 1, 1995, the tax rate imposed on the net value of transfers to or for the use of the surviving spouse is 3% [72 P.S. §9116 (a) (1.1) (i)]. For dates of death on or afer January 1, 1995, the tax rate imposed on the net value of transfers to or for the use of the surviving spouse is 0% The statute does not exemot a transfer to a surviving spouse from tax, and the statutory requirements for disclosure of assets and filing a tax return are still applicable even if the surviving spouse is the only beneficiary. For dates of death on or after July 1, 2000: The tax rate imposed on the net value of transfers from a deceased child twenty-one years of age or younger at death to or for the use of a natural parent, an adoptive parent, or a stepparent of the child is 0% F2 P.S. §9116(a)(1.2)J. The tax rate imposed on the net value of transfers to or for the use of the decedent's lineal beneficiaries is 4.5%, except as noted in 72 P.S. §9116(1.2) [72 P.S. §9116(a)(1 )]. The tax rate imposed on the net value of transfers to or for the use of the decedent's siblings is 12% [72 P.S. §9116(a)(1.3)]. A sibling is defined, under Section 9102, as an individual who has at least one parent in common with the decedent whether by blood or adoption. SCHEDULE A CO.MONW LTR OFPENNSYLVA.,^ REAL ESTATE RESIDENT OECEDENT ESTATE OF FILE NUMBER Foltz. R. Cree 21 02 1126 All mai pF~ity o~ so~ or as a (e,,aiit in common must be mpoA~ at fair markM value. Fair manet value is defin~ as ~e pd~ at whi~ pmpe~ would ~ ~changed be~een a willi~ buyer and a ~lli~ sel~r, nei~er being ~m~lled ~ buy or sell, ~ having reasonable knowledge of the relevant fa~. Real pmpe~ ~ich is ~intly-o~ed ~th right of suw~omhip must ~ disclosed on Schedule F, ITEM VALUE AT DATE NUMBER DESCRIPTION OF DEATH 1. Brick ranch dwelling situate in West Pennsboro Township, Cumberland County, 105,000.00 Pennsylvania - See Cumberland Coun~ Deed Book "A", Volume 20, Page 884 - Appraised by Diversified Appraisal Se~ices TOTAL (Also enter on line 1, Recapituration) $ 105,000.01) (If more space is needed, insert additional sheets of the same size) SCHEDULE B COMMONWEALTH OF PENNSYLVANIA STOCKS & BONDS INHERITANCE TAX RETURN RESIDENT DECEDENT ESTATE OF FILE NUMBER Foltz. R. Cree 21 02 112~ All property jointly-owned with right of sun,'ivorshlp must be disclosed on Schedule F. ITEM NUUBER DESCRIPTION VALUE AT DATE 1. 5,600 shares of ExxonMobil @ 34.22 per share OF DEATH 191,632.00 TOTAL (Also enter on line 2, Recapitulation) $ 191,632.01'~ (If mere space is needed, inserl additional sheets of the same size) SCHEDULE E COMMO"W~LT'OFPENNSYLVA.,^ CASH, BANK DEPOSITS, & MISC, INHERITANCE TAX RETURN RES,OENT OECE~E.T PERSONAL PROPERTY ESTATE OF FiLE NUMBER Foltz. R. Cree 21 02 1121~ Include the )roceeds of litigation and the date the proceeds were received by the estate. All property jointly-owned wffh the right of survivomhi ~ muet be a!~,c!o_~ed on Schedule F. ITEM NUMBER DESCRIPTrON VALUE AT DATE 1. 1996 Buick Sedan - sold to Lisa F. Beattie OF DEATH 3,000.00 2. Personal property of Decedent - Appraised by IBIS Appraisal Services 5,631.00 3. The Bank of Landisburg CD#061057761 20,039.18 4. The Bank of Landisburg CD#061057762 10,081.12 5. The Bank of Landisburg CD#700008824 30,088.77 6. The Bank of Landisburg CD#700009325 25,203.42 7. The Bank of Landisburg CD#7000010310 666.05 8. The Bank of Landisburg CD#700011565 30,276.00 TOTAL (Also enter on line 5, Recapitulation $ 124,985.54 (if more space is needed, insert additional sheets of the same size) SCHEDULE H COMMONWEALTH OF PENNSYLVANIA FUNERAL EXPENSES & INHERITANCE TAX RETURN RESIDENT DECEDENT ADMINISTRATIVECOSTS ESTATE OF FILE NUMBER Foltz. R. Cree 21 02 112~ Debts of decedent muet be reported on Schedule I. ITEM NUMBER DESCRIPTION AMOUNT A. FUNERAL EXPENSES: 1. Ewing Funeral Home 7,002.50 B. ADMINISTRATIVE COSTS: 1. Personal Representative's Commissions Name of Personal Representative (s) Social Secudty Number(s) / EIN Number of Personal RepresentalJve(s) Street Address C~ State Z~p Year(s) Commission Paid: 2. AttomeyFees Gerald K. Morrison 12,864.70 3. Family Exemption: (if decedent's address is not the same as claimant's, attach explanation) 3,500.00 Claimant Anna C. Foltz StreetAddresa 2175 Newville Road ci~/Carlisle State PA Zip 17013 Relationship of Claimant to Decedent wife 4. PmbateFees Mary C. Lewis 430.00 5. Accountant's Fees 6. Tax Return Preparer's Fees 7. TOTAL (Also enter on line 9, Recapitulation) $ 23,797.20 (If more space is needed, insert additional sheets of the same size) SCHEDULE I cO..O.W~LT. OFPE..SY.V^Ni^ DEBTS OF DECEDENT, ~S,DE.T~C~D~.T MORTGAGE LIABILITIES~ & LIENS ESTATE OF FILE NUMBER FoItz. R. Cree 21 02 1126 Include unreimbursed medical expenses. ITEM NUMBER DESCRIPTION AMOUNT 1. Dale F. Shughart, Jr. - legal account 4,000.00 2. The Sentinel - estate advertising 102.11 3. Cumberland Law Journal - estate advertising 75.00 4. IBIS Appraisal Service - appraisal fee 120.00 5. Diversified Appraisal - appraisal fee 275.00 6. U.S. Treasury - 2002 and 2003 income taxes 2,079.42 7. PA Department of Revenue - 2002 and 2003 income taxes 523.32 8. Rice Memorial Works - gravestone lettering 95.00 TOTAL (Also enter on line 10, Recapitulation $ 7,269.8~, (If more space is needed, insert additional sheets of the same size) REV-1513 EX + COMMONWEALTH OF PENNSYLVANIA BENEFICIARIES INHERITANCE TAX RETURN RESIDENT DECEDENT ESTATE OF FILE NUMBER Foltz. R. 3tee 21 02 1126 RELATIONSHIP TO DECEDENT AMOUNT OR SHARE NUMBER NAME AND ADDRESS OF PERSON(S) RECEIVING PROPERTY Do Not List Trustee(s) OF ESTATE I. TAXABLE DISTRIBUTIONS [include ou~ght spousal distributions and transfem under Sec. 9116 (a) (1.2) 1. Anna C. Foltz Wife $50,000.00 and 2175 Newville Road Carlisle, PA 17013 residence 2. Lisa F. Beattie Granddaughter 100 shares of 240 Shady Lane Carlisle, PA 17013 ExxonMobil 3. Jennifer G. Nailor Sranddaughter 100 shares of 340 Pleasant Hall Road Carlisle, PA 17013 ExxonMobil 4. Jacqueline R. Dommel Granddaughter 100 shares of 336 Toll Gate Road York, PA 17403 ExxonMobil 5. Robert C. Foltz, Jr. Son rest and residue 238 Shady Lane Carlisle, PA 17013 ENTER DOLLAR AMOUNTS FOR DISTRIBUTIONS SHOWN ABOVE ON LINES 15 THROUGH 18, AS APPROPRIATE, ON REV-1500 COVER SHEET ][][. NON-TAXABLE DISTRIBUTIONS: 1. A. SPOUSAL DISTRIBUTIONS UNDER SECTION 9113 FOR WHICH AN ELECTION TO TAX IS NOT BEING MADE B. CHARITABLE AND GOVERNMENTAL DISTRIBUTIONS 1. TOTAL OF PART II - ENTER TOTAL NON-TAXABLE DISTRIBUTIONS ON LINE 13 OF REV-1500 COVER SHEET $ (If more space is oeeded, inset1 additional sheets of the same size) December 30, 2002 GERALD K MORRISON ESQUIRE POST OFFICE BOX 232 CE/F~ER SQUARE NEW BLOOMFIELD PA 17068 Re: E CREE FOLTZ $SN: 181-03-2804 Dear Attorney Morrison: Pursuant to your letter dated December 23, 2002, the Department of Public Welfare (DPW), Estate Recovery Program, has reviewed the information you provided regarding the above-referenced individual. It has been determined that this individual did not receive any type of assistance during the questioned period. Therefore, according to the information you provided, the Department's Estate Recovery Program will not seek any recovery from this estate. If you have any questions please feel free to contact me. Sincerely, Ronald D. Hill, Manager' TPL - Casualty Unit (717)772-6604 (717)772-6553 FDD{ 1N RE: ESTATE OF : IN THE COURT OF COMMON PLEAS OF R. CREE. FOLTZ : CUMBERLAND COUNTY, PENNSYLVANIA DECEASED : : ORPHAN'S COURT D1VISION : NO. 21-02-1126 PETITION FOR EXEMPTION To Whom It May Concern: The Petition of Anna C. Foltz respectfully represents: 1. That your petitioner is the widow ofR. Cree Foltz, who died November 22, 2002, a resident of Cumberland County. 2. That decedent and petitioner were married at the time of the death of the said R. Cree Foltz, and the petitioner was a member of the decedent's household at the time of his death. 3. That letters testamentary were granted to Robert C. Foltz, Jr., by the Register of Wills of Cumberland County. 4. That petitioner claims $3,500.00 as her widow's exemption under Section 3121 of 20 Pa.C.S.A. WHEREFORE, petitioner prays that said sum of $3,500.00 be set apart to her as aforesaid. A~qN'A (2. POLTZ 1N RE: ESTATE OF : IN THE COURT OF COMMON PLEAS OF R. CREE. FOLTZ : CUMBERLAND COUNTY, PENNSYLVANIA DECEASED : : : ORPHAN'S COURT DIVISION : NO. 21-02-1126 ELECTION TO TAKE LTNDER WII,I, To Whom it May Concern: I, Anna C. Foltz, widow of the above decedent, who died on the 22''a day of November, 2002, having first made, published and declared his last will and testament, dated July 2, 2001, duly probated in the office of the Register of Wills of Cumberland County, on December I 1, 2002, and recorded under Estate No. 21-02-1126 hereby elect to take under the terms of the said will. IN WITNESS WHEREOF, I have hereunto set my hand and seal this ~ O/''' day of March, 2003. ~ (SEAL) ANNA ~. FOLTZ COMMONWEALTH OF PENNSYLVANIA : : SS: COUNTY OF ~'~-rm~'~r~(~ : On this 2-o ~ day of March, 2003, before me, the subscriber, a notary public in and for the Commonwealth of Pennsylvania, residing in the County of ~'a~,,mb~,~d , personally appeared Anna C. Foltz, and acknowledged the foregoing election to be her act and deed and desired that the same might be recorded as such. WITNESS my hand and notarial% NOTARY PUBLIC SF~ 'EVEN J. FISHMAN, Notary Public d s · Bom, cumberlandCounty Ce, ' COHHONgEALTH OF PENNSYLVANIA DEPARTHENT OF REVENUE BUREAU OF INDIVIDUAL TAXES INHERITANCE TAX DIVISION NOTICE OF INHERITANCE TAX po BOX 28060! APPRAXSENENT, ALLONANCE OR DZSALLONANCE HARRXSBURG, PA 17X28-0601 OF DEDUCTIONS AND ASSESSNENT OF TAX REV-lsd? EX AFP (09-0~) DATE 11-29-2004 ESTATE OF FOLTZ R C DATE OF DEATH 11-22-2002 FILE NUNBER 21 02-1126 COUNTY CUHBERLAND ·" ' ~* i: iTM"~ F~ ? ~'::~ ? 6ERALD K HORRISON ESQ [~ .... '.: ........ ACN 101 PO BOX 2~2 Aaoun~ Remi~ed I NEN BLOOHFIELD PA 1~7068 I HAKE CHECK PAYABLE AND REHZT PAYHENT TO: REGISTER OF N~LLS CUHeERLAND CO COURT HOUSE CARLISLE, PA 17015 CUT ALONG THIS LINE ~ RETAIN LONER PORTXON FOR YOUR RECORDS DZSALLONANCE OF DEDUCTIONS AND ASSESSHENT OF TAX ESTATE OF FOLTZ R C FILE NO. 21 02-1126 ACN 101 DATE 11-29-2004 TAX RETURN NAS: (X) ACCEPTED AS FILED ( ) CHANGED RESERVATION CONCERNING FUTURE INTEREST - SEE REVERSE APPRAISED VALUE OF RETURN ~ASED ON: ORIGINAL RETURN 1. Real Es~e~e (Schedule A) (1) 105~000.00 NOTE: To insure proper 2. S~ocks and Bonds (Schedule B) (2) 191;6~2.00 credi~ ~o your account, $. Closely Held S~ock/Par~nership In~eres~ (Schedule C) ($) .00 submi~ ~he upper portion ~. Hor~geges/No~es Receivable (Schedule D) (~) .00 of ~his form ~i~h your 6. Cash/Bank Deposi~s/Nisc. Personal Proper~y (Schedule E) (5) 124~985.54 ~ax payment. 6. Jointly O~ned Proper~y (Schedule F) (6) .00 7. Transfers (Schedule G) (7) .00 8. To~el Asse~s (8) 421,617.54 APPROVED DEDUCTIONS AND EXENPTZONS: 25,797.20 9. Funeral Expenses/Adm. Cos~s/Nisc. Expenses (Schedule H) (9) ZO. Debts/Hot,gage Liabilities/Liens (Schedule I) (10) 7.269.85 11. To,al Deductions (11) ~].0~7.0~ 12. Ne~ Value of Tax Re~urn (12) $90,550.49 15. Charitable/Governmental Bequests; Non-elected 9115 Trusts (Schedule J) (15) .00 1~. Ne~ Value of Es~a~e Subjec~ ~o Tax (1~) $90,550.49 NOTE: Zf an assessment ~as issued previously, lines 1~, 15 and/or 16, 17, 18 and 19 ~111 reflect figures that include the total of ALL returns assessed to date. ASSESSHENT OF TAX: 15. Aeoun~ of Line lq a~ Spousal ra~e (1S) 155,000.00 X O0 = .00 16. Aeoun~ of Line 1~ ~axable a~ Lineal/Class A ra~e (16) 235,550.49 X 045 = 10,599.77 17. Aeoun~ of Line 1~ a~ Sibling re~e (17) .00 X 12 = .00 18. Aaoun~ of Line 1~ ~axable a~ Collateral/Class B ra~e (18) .00 X 15 = .00 19. Principal Tax Due (19)= 10,599.77 TAX CREDITS: PAYH~NT RECEIPT DISCOUNT AHOUNT PAID DATE NUNBER INTEREST/PEN PAID (-) 08-14-2005 CD002907 .00 9,000.00 10-01-2004 CD004462 77.10- 1,680.44 TOTAL TAX CREDIT I 10,603.34 BALANCE OF TAX DUEl 3.57CR INTEREST AND PEN. .00 TOTAL DUE $. 57CR TF PA/D AFTER DATE INDICATED, SEE REVERSE ( ZF TOTAL DUE IS LESS THAN $1, NO PAYNENT IS REQUIRED. ~ ~ FOR CALCULATION OF ADDITIONAL INTEREST. ZF TOTAL DUE ZS REFLECTED AS A "CREDIT" (CR), YOU NAY DE DUE~-~-~/~ A REFUND. SEE REVERSE SIDE OF THIS FORN FOR INSTRUCTIONS.) ~' * Cumberland County - Register Of Wills One Courthouse Square Carlisle, PA 17013 Phone: (717) 240-6345 Date: 12/01/2004 MORRISON GEP~ALD K ESQ CENTER SQUARE P.O. BOX 232 NEW BLOOMFIELD, PA 17068 RE: Estate of FOLTZ R. CREE File Number: 2002-01126 Dear Sir/Madam: It has come to my attention that you have not filed the Status Report by Personal Representative (Rule 6.12) in the above captioned estate. As per the AMENDMENTS TO SUPREME COURT ORPHANS' COURT RULES, NO. 103 SUPREME COURT RULES DOCKET NO. 1, for decedents dying on or after July 1, 1992, the personal representative or his counsel, within two (2) years of the decedent's death, shall file with the Register of Wills a Status Report of completed or uncompleted administration. This filing will become delinquent on: 11/22/2004 Your prompt attention to this matter will be appreciated. Thank You. Sincerely, GLENDA FARNER STRASBAUGH REGISTER OF WILLS cc: File Personal Representative(s) Judge Cumberland County - Register Of Wills One Courthouse Square Carlisle, PA 17013 Phone: (717) 240-6345 Date: 10/11/2005 MORRISON GERALD K ESQ CENTER SQUARE P.O. BOX 232 NEW BLOOMFIELD, PA 17068 RE: Estate of FOLTZ R. CREE File Number: 2002-01126 Dear Sir/Madam: It has come to my attention that you have not filed the Status Report by Personal Representative (Rule 6.12) in the above captioned estate. As per the AMENDMENTS TO SUPREME COURT ORPHANS' COURT RULES, NO. 103 SUPREME COURT RULES DOCKET NO.1, for decedents dying on or after July 1, 1992, the personal representative or his counsel, within two (2) years of the decedent's death, shall file with the Register of Wills a Status Report of completed or uncompleted administration. This filing is due by: 11/22/2005 Your prompt attention to this matter will be appreciated. Thank You. Sincerely, ~~~ GLENDA FARNER STRASBAUGH REGISTER OF WILLS cc: File Personal Representative(s) Judge .1:6 I.- . Register of Wills of Cumberland County STATUS REPORT UNDER RULE 6.12 Name of Decedent: R. Cree Foltz Date of Death: 11/22/2002 E N 21-02-1126 state 0.: pursuant to Rule 6.12 of the Supreme Court Orphans' Court Rules, I report the following with respect to completion of the administration of the above-captioned estate: 1. State whether administration of the estate is complete: Yes rn No 0 2. If the answer is No, state when the personal representative reasonably believes that the administration will be complete: 3. If the answer to No. 1 is Yes, state the following: a. Did the personal representative file a final account with the Court? Yes 0 No ill b. The separate Orphans' Court No. (if any) for the personal representative's account is: c. Did the personal representative state an account informally to the parties in interest? Yes [3 No 0 '_L. C_:.", LU -- "-.)0 u.:- :~ C5 ~_ C:J '::-b-~' 1-._.., cc c. (:5 LLj c_-= c. Copies of receipts, releases, joinders and approval of formal or informal accounts may be filed with the Cl k of the Orphans' Court and may be attached to this report. Date:#'J- tn Gerald Ka Morri~nn- 'Rc::.qn;Y~ Name . ",,':::,t; P.O. Box 232, New Bloomfield, PA 17068 Address O~ 1-..- C) c~, (717) 582-2300 Telephone No. l.r~ Cd:' = '" '.. Capacity: 0 Personal Representative o Counsel for personal representative f IN RE: ESTATE OF R. CREE FOLTZ, DECEASED : IN THE COURT OF COMMON PLEAS : CUMBERLAND COUNTY, PENNSYLVANIA : ORPHANS' COURT DIVISION : NO. 02-1126 ANSWER TO PETITION TO SHOW CAUSE WHY EXECUTOR SHOULD NOT BE REMOVED OR ALTERNATIVELY DIRECTING EXECUTOR TO PROMPTLY ADMINISTER THE ESTATE AND DISTRIBUTE THE SPECIFIC BEQUESTS TO THE HONORABLE, THE JUDGES OF SAID COURT: AND NOW, comes the Respondent, Robert C. Foltz, Jr., Executor of the Estate of R. Cree Foltz, deceased, by his Special Counsel, Dale F. Shughart, Jr., Esquire, and makes the following Answer to the Petition of Anna Foltz: ANSWER 1 · ~ctmzc'cect. 2. Admitted. 3. Admitted. 4. Admitted in part. Denied in part. The 'Deced~ did 'not bequeath "certain paintings,, The document speaks for itself. The remaining averments are admitted. 5. Admitted. 6. Denied. On the contrary, the undersigned Executor has acted reasonably and responsibly in an effort to resolve numerous issues which have arisen between the Petitioner and him and has acted consistent with the advice of Gerald K. Morrison, Esquire, Attorney for the Estate, attempting to resolve issues through negotiation, which has resulted in a reasonable delay in the administration of the Estate. 7. Admitted in part. Denied in part. It is admitted that the Executor has taken no legal action to determine ownership of disputed items. The remaining averments are denied. On the contrary, although the Petitioner has claimed items owned by the decedent were gifted to her after their marriage, she has failed to provide any evidence of such gifting. Further, Petition has failed to allow the Executor reasonable access to the real property at 2175 Newville Road to enable an inventory of the tangible personal property or an appraisal of the value of the real estate to be made. By way of further Answer the averments of Executor's New Matter are incorporated herein by reference. 8. Admitted with a qualification. Although the Executor has refused to distribute the Petitioner's cash bequest or the real estate, he has done so consistent with the advice of the attorney for the Estate. By way of further answer, the averments of the Executor's New Matter are incorporated herein by reference. 9. Denied. While the Executor admits to considerable frustration and anxiety over this matter, he has no ill feelings toward the Petitioner. 10. Denied. The Executor is without specific knowledge or information sufficient to form a belief as to the degree of "anguish', being suffered by the Petitioner. By way of further answer, it is the Executor's sincere goal to resolve the current impasse, complete administration of the Estate and distribute Petitioner's cash bequest and real estate to her in the near future. 2 11. This averment states an opinion, not a fact and no answer is required. If an answer is required, the averments of Paragraph 11 are denied. On the contrary, the Executor intends to move forward to resolve the issues promptly, fairly and efficiently as set forth in the Executor's New Matter, the averments of which are incorporated herein by reference thereto. 12. The averments of Paragraph 12 state a conclusion of law and no answer is required. If an answer is required, the averments of Paragraph 12 are denied. On the contrary, the Executor intends to move forward to resolve the issues promptly, fairly and efficiently as set forth in the Executor's New Matter, the averments of which are incorporated herein by reference thereto. WHEREFORE, the Respondent, Robert C. Foltz, Jr., Executor of the Estate of R. Cree Foltz, deceased, prays Your Honorable Court to dismiss the Petition of Anna C. Foltz. NEW MATTER 13. The averments of Executor's Answers to averments of the Petition Paragraphs 1 through 12, inclusive, are incorporated herein by reference thereto. 14. The decedent was the owner, at his death, of the real property known as 2175 Newville Road, Carlisle, PA, in which the Decedent and Petitioner resided at his death. The Petitioner continues to reside there, and the real property will be distributed to her pursuant to the Will. 15. The Petitioner has refused to allow the Executor and/or -3- his representatives to have any access to the real property. 16. Although the Executor has paid estimated Pennsylvania Inheritance Taxes, he cannot prepare and file the Pennsylvania Inheritance Tax Return until the value of the real property has been determined by appraisal. 17. The discovery rules of the Pennsylvania Rules of Civil Procedure are applicable to proceedings in the Orphans' Court pursuant to Section 774 of the PEF Code, 20 Pa.C.S. 774, Pa. O.C. Rule 3.6 and C.C.O.C.R. 3.6-1. 18. Contemporaneously with the filing of this Answer, the Executor is serving separately upon the Petitioner, by and through her attorney, a Request For Entry Upon The Real Property Belonging To The Estate, pursuant to Pa.R.C.P. 4009.32, a true and correct copy of which is attached hereto, made a part hereof, and marked Exhibit "A". 19. The request serves two purposes, the first of which will be to allow a qualified real estate appraiser to establish the fair market value of the premises on the decedent's date of death. 20. By virtue of various exchanges of correspondence and telephone communications, the Petitioner's attorney and the attorney for the Estate, Gerald K. Morrison, Esquire, have exchanged various lists of the items of tangible personal property which the Executor claims were owned by the decedent prior to his marriage to the Petitioner and prior to his death. Executor contends these items were at the decedent's home at the time of his -4- death. Being denied access to the premises your Petitioner has been unable to identify these items specifically, nor to have them appraised. 21. By letter dated August 13, 2003, the Petitioner, by her attorney, Steven J. Fishman, Esquire, advised the Executor's attorney that "as I indicated in my letter of May 21, 2003 (copy enclosed) Mrs. Foltz has already begun to give away or sell items from her house and unless Mr. Foltz acts reasonably quickly there will be few items left for him to receive,,. 22. The Executor has prepared a list of items which, to his knowledge, were at the decedent's house on his date of death and which were owned by the decedent prior to his marriage to the Petitioner. Many of these items are family heirlooms. Many items are firearms, and related paraphernalia supplies, tools, etc., are items which the Petitioner cannot reasonably claim to have used in conjunction with the decedent during his lifetime; nor has she presented any evidence that the items were gifted into entireties property. 23. The Executor's Request For Entry Upon The Estate Real Estate, referred to above, Exhibit "A", obtains the specific request that the inspection of the tangible personal property enable a licensed auctioneer to identify and appraise items of tangible personal property at the home which the Executor contends were owned solely by the Decedent. 24. To the extent that the Petitioner has sold or gifted --5-- items of tangible personal property which were owned by the decedent prior to his marriage to her, knowing that the ownership of these items was in dispute, she is accountable to the Estate for the value of items sold at market value, and the Estate may recover items transferred for less than fair market value. 25. The Executor believes and therefore avers that Your Honorable Court has authority to order and direct the Petitioner to account for missing items by providing an itemized list of all items identified by the Executor in Exhibit "B" as being Estate assets owned by the Decedent, together with their current whereabouts, including an attachment of receipts for items sold. 26. The Executor declines to depose the Petitioner standing instead upon protection of the Dead Man's Statute in regard to the legal requirements for proving an alleged transfer of ownership of separate property into entireties property. 27. As soon as the Executor has obtained access to the Estate real property for purposes of identifying and valuing the real estate and tangible personal property which he contends were owned by the decedent, Petitioner will file an Inventory and Pennsylvania Inheritance Tax Return. As soon as the Pennsylvania Inheritance Tax Return has been approved, the Executor will file an Account and Schedule of Proposed Distribution. 28. The proper method of attacking the Executor's contentions regarding the ownership of tangible personal property in the decedent's home at his date of death will be for the Petitioner to -6- file Objections thereto. See, Remick's Pennsylvania Orphans' Court. Practice, Revised, Volume 3, Chapter XXV, Page 261 et seq. 29. The Petitioner is in possession of the real property, and therefore is not being prejudiced by the failure to distribute it, pending resolution of disputes. Further, to the extent that the Petitioner has dissipated tangible personal property of the Estate, which is not recoverable, the value of such items may be offset against her $50,000 specific bequest. 30. Under the circumstances, the Executor is not in a position to make a distribution of specific bequests. He will, however, promptly distribute the $3,500 family exemption to the Petitioner to demonstrate his willingness to move forward with all matters which can be resolved prior to confirmation of an Account. 31. The Executor believes and therefore avers that both he and the Petitioner bear equal responsibility for the impasse which has resulted in a delay in completing the Estate. However, the Executor believes and therefore avers that it has been reasonable for him, consistent with the advice of his attorney, to endeavor to resolve these matters without resort to formalized proceedings in the Orphans' Court. 32. The undersigned special counsel appears in this matter on behalf of the Executor with the approval of Gerald K. Morrison, Esquire, attorney for the Estate, because of the distinct possibility that if these proceedings move forward to a hearing, Attorney Morrison will be required to testify on behalf of the --7-- Executor in such proceedings. WHEREFORE, Robert C. Foltz, Jr., Executor of the Estate of R. Cree Foltz, deceased, prays Your Honorable Court to order and direct as follows: 1. That the Petitioner, Anna C. Foltz, allow Robert C. Foltz, Jr. and his representatives upon the Estate real property specifically devised to Anna C. Foltz for purposes of appraising the value of the real estate and the tangible personal property which the Executor claims to have been owned by the decedent at his date of death. 2. That Anna C. Foltz provide a documented inventory identifying all items identified by the Executor as belonging to the Decedent which she has sold or gifted, identifying as to each such item, the value received for such item and items present whereabouts. o Such other relief as shall be just and proper. Respectfully sub ' ted, Dale F. Shugha[t/,! j$. Supreme Court l~.q. ~93~3 35 East High StreW, Suite Carlisle, PA 17013 (717) 241-4311 203 Special Counsel for Robert C. Foltz, Jr., Executor, Estate of R. Cree Foltz, deceased -8- VERIFICATION Robert C. Foltz, Jr. hereby verifies that the facts set forth in the foregoing Answer and New Matter are true and correct to the best of his knowledge, information and belief, and understands that false statements herein are made subject to the penalties of 18 Pa. C.S. §4904 relating to unsworn falsifications. DATE Ob---o -9- IN RE: ESTATE OF R. CREE FOLTZ, DECEASED : IN THE COURT OF COMMON PLEAS : CUMBERLAND COUNTY, PENNSYLVANIA : ORPHANS' COURT DIVISION : NO. 02-1126 REQUEST FOR ENTRY UPON REAL PROPERTY BELONGING TO ESTATE PURSUANT TO PA.R.C.p. 4009.32 TO: ANNA C. FOLTZ, C/O STEVEN J. FISHMAN, ESQUIRE You are directed to allow Robert C. Foltz, Jr., Executor of the Estate of R. Cree Foltz, deceased, upon the Estate Real Property situate at 2175 Newville Road, Carlisle, PA and into the dwelling'house to enable Robert C. Foltz, Jr., a qualified real estate appraiser, and a licensed auctioneer to inspect and photograph the premises and the contents of the home which are claimed to be property owned by R. Cree Foltz, individually, and which are therefore contended to be assets passing under the Last Will and Testament of the decedent. The undersigned Special Counsel for Robert C. Foltz, Jr., will contact Steven J. Fishman, Esquire to arrange a time for Mr. Foltz, the appraiser, the auctioneer, and the undersigned attorney for the Executor, to enter onto the real property and into the dwelling house to inspect and appraise the real property and the contents. If you fail to cooperate, you may be subject to sanctions of the Pennsylvania Rules of Civil 35 East High Street, Suite 203 Carlisle, PA 17013 (717) 241-4311 authorized by Rule 4019(c) Procedure. Special Counsel for Robert C. Foltz, Jr., Executor, Estate of R. Cree Foltz, deceased Following is a list of Firearms owned by R. Cree Foltz (Deceased) Prices Established from Standard Catalog of Firearms Price and Reference Guide 12th Edition Published by Krause Publications 700 E. State Street, Iola, WI.-54990-0001 Telephone 715-445-2214. 1. H. Standard Sentinel Revolver-22 Caliber with Lawrence Leather Holster-Value $110.00. 2. Ithica 12 Gauge Pump Shot Gun (model 37)--$175.00 3. Remington Pump 22 Caliber (Field Master) with telescope with l"tube --$180.00 4. Winchester Pump Shot Gun (model 12) Given to Cree Foltz by L. Dana Rice to be passed to Robert Foltz Jr. upon Cree's Death (Standard Grade)--S300.00 5. Savage Lever Action Rifle (300 Caliber Model 99) with sling-custom safety and B+L scope bases --$475.00 6. Savage over and under (222 Rifle over 3'20 gauge shot gun) (Model 24V) with Waver Vari Power Scope with 1" Tube --$200.00 7. Sake~Forrester-Bolt Action Rifle (243 Caliber) with B+L Balvar 8 scope and mounts plus sling. -- $1300.00 8. Evinrude outboard motor, fuel tank and motor stand ($550.00 Quote from Bigbee Boats, Marysville Pa.) R. Cree Foltz (Personal Items) Not Received by Robert C. Foltz Jr. 1. 2 Plank Bottom Chairs (had been Cree's mothers) 2. Oak Dry sink (Gayle Foltz had customer built and finished.) 3. Plank Bottom Chairs--2 captains and 4 side chairs (Sophia Foltz had these hand made) 4. Antique Drop leaf gate leg Table. 5. Antique mahogany Slant top desk and chair. 6. 2 end tables. 7. Oil painting of Rice's covered bridge Perry Co. 8. Oil painting of ~.~ IRice Blacksmith shop (Artist - Mary Egolf (deceased)) 9. Large glass hand painted table light. 10. Anniversary Clock - glass dome 11. Antique mahogany Bed Room Set - Bed and 2 (Belonged to Sophia Foltz) dressers. 12. Custom made walnut Gun Cabinet. 13. Fishing Gear (misc) 14. Book Shelf filled with Zane Grey and Louis L'more Books 15. Wrist Watch 16. Cree Foltz's College year Book. 17. Haines History of Perry County, Pa (purchased by Sophia Foltz for Robert Foltz.) Collector's Item. 18. Cree Foltz's Aviator's Leather cap from 1931 (Priceless to his Son). 19. All remaining family Photos (Foltz + Guyler Family) 20. Exxon Award Pins with Diamond Chips 21. Work/reloading loading bench and reloading equipment+supplies (A) Bench (B) Press (C) Powder measure (D) Powder scales (E) Case Trimmer (F) Case gauge (G) Case Lubber (H) Bullets (I) Primers (J) Gun Powder (K) RCBS reloading Dies--30-06 300 Savage 243-222-7mm Remington mag. 22. Pearson 60lb Pull fiberglass Bow and Arrows. 23. Antique Knife and Sheath. 24. Folding Hunting Knife. 25. Pear Handle Pocket Knife. 26. Hand Tools A. Socket wrench set B. Open and box end wrenches C. Regular slot and Phillips screw drivers D. Metal punches and metal chisels E. 8lb hammer F. Ball Peen hammer G. Hacksaw H. Set of easy outs I. Set adjustable wrenches J. Set pliers K. Stencil set (used to imprim soft) L. ¼ inch Electric drill + metal drill bits. M. 2 carpenters Hand saws (for wood) N. 5 ton Blue Hydraulic Jack. O. Set of car ramps. P. Bench Grinder 27. Antique wash stand painted white. (Belonged to Great Grandmother Guyler) IN RE: ESTATE OF R. CREE FOLTZ, DECEASED : IN THE COURT OF COMMON PLEAS : CUMBERLAND COUNTY, PENNSYLVANIA : ORPHANS' COURT DIVISION : NO. 02-1126 CERTIFICATE OF SERVICE AND NOW, this 4th day of May, 2004, I, Dale F. Shughart, Jr., attorney for Robert C. Foltz, Jr., Executor, of the Estate of R. Cree Foltz, deceased, hereby certify that I have served a true and correct copy of the Answer and New Matter, pursuant to Pa.R.C.P. 1023.2, by mailing a copy of the same by United States mail, postage prepaid, addressed as follows: Steven J. Fishman, Esquire Salzmann, Hughes & Fishman, P.C. 95 Alexander Spring Road, Suite 3 Carlisle, PA 17013 v ~Dale F.~ ~P~ae~ H~ u7~3 ts Carlisle, PA 17013 (717) 241-4311 203