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HomeMy WebLinkAbout11-10-08~ ~-[~, ` c LAW OFFICES STEPHEN C. NUDEL, PC Stephen C. Nudel, Esquire Attorney ID #41703 Bret Keisling, Esquire Attorney ID #201352 219 Pine Street Harrisburg, PA 17101 (717) 236-5000 In Re: ESTATE OF HOWARD C. GALE 208 ~0~ ! Q PM :' 3S rr~~ C~nn.~C~t, rJ~ ,~;.?uR ~ IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA ORPHAN'S COURT DIVISION NO. 1998-629 PETITION FOR DECLARATORY JUDGMENT CONCISE STATEMENT OF ERRORS COMPLAINED OF ON APPEAL PURSUANT TO Pa.R.A.P. 1925(b) AND NOW, comes Petitioners Michael J. Gale, Howard C. Gale, III, Ellen Michelle Gale, and Melissa G. Gale Lindeman, by and through their attorneys, Law Offices Stephen C. Nudel, PC, and respectfully files this Concise Statement of Errors Complained of on Appeal Pursuant to Pa.R.A.P. 1925(b): 1. Whether the trial court committed an error of law or abused its discretion when it denied Appellants' Petition for Declaratory Judgment? 2. Whether the trial court committed an error of law or abused its discretion when it denied Appellants' Petition for Declaratory Judgment because it determined that decedent's will did not contain a latent ambiguity? 3. Whether the trial court committed an error of law or abused its discretion when it failed to consider extrinsic evidence that supported Appellants' Petition? 4. Whether the trial court committed an error of law or abused its discretion when it denied Appellants' Petition for Declaratory Judgment even though decedent was sole shareholder in two corporations and he consistently treated disputed properties as if they were titled to one corporation although the properties were deeded to another corporation? Whether the trial court committed an error of law or abused its discretion when it denied Appellants' Petition for Declaratory Judgment even though decedent's estate and his widow consistently treated disputed properties as if they were titled to one corporation although the properties were deeded to another corporation? Respectfully submitted, Date:lJ~~w~~ t b I ?r~o ~ LAW OFFICES STEPHEN C. NUDEL, PC Stephen C. Nudel, Esquire Attorney ID #41703 Bret Keisling, Esquire Attorney ID #201352 219 Pine Street Harrisburg, PA 17101 (717) 236-5000 Attorneys for Petitioners 2 CERTIFICATE OF SERVICE I hereby certify that a copy of the foregoing has been duly served upon the osta e following, by depositing a copy of the same in the United States Mail, first-class, p g prepaid, at Harrisburg, Pennsylvania, as follows: Adam L. Seiferth, Esquire Cipriani & Werner 1011 Mumma Rd., Suite 201 Lemoyne, PA 17043-1145 Mr. Anthony Rossognoli 138 Kathleen Lane Wyomissing, PA 19610 Date: ~wtw~~ (~ .z©c~ ~ eislmg, Esquire