HomeMy WebLinkAbout04-16-09Irv RE:
IN THE COURT OF COMMON PLEAS
WILLIAM I. EVANS WILL :CUMBERLAND COUNTY, PENNSYLVANIA
: ORPHANS' COURT DIVISION
ESTATE NO. 21-08-979
RESPONDENT'S FIRST AMENDED RESPONSE TO CITATION SUR APPEAL
FROM DECREE OF PROBATE
NOW COMES Respondent Irma Davenport, by and through her counsel, Mark A.
Mateya, Esquire, and in response affirms the information presented in Respondent's Response to
Citation Sur Appeal From Decree of Probate, with the following exception:
61. Denied. Respondent exercised no control over Decedent in 2006 or at any other time
during Decedent's life.Decedent lived on his own until hid death, handled all of his own affairs
until his death.
62. Denied. Decedent managed his own affairs.
63. Denied. Respondent took no actions with regard to petitioner or petitioner's family
which could even remotely be interpreted as limiting contact between Decedent and anyone.
WHEREFORE, respondent respectfully requests this Honorable Court dismiss
petitioner's citation, with prejudice.
Respectfully submitted,
Date: ~~ ~~ ~~
Mark A. Mateya, Es ire ~ q
Attorney ID No. 78931 ~= p s; -,
P.O. Box 127 '~ ~ ~- ~~~
Boiling Springs, PA 1700 ~
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(717) 241-6500 _ ~~~~ a^ _~ =-
(717) 241-3099 Fax ,.",i~`- a `~ ~~
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Counsel for Respondent
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VERIFICATION
MARK A. MATEYA, ESQUIRE, verifies that he is the attorney and agent for the
Respondent herein, that the Respondent's verification cannot be obtained within the time allowed
:for the filing of this pleading, that as attorney for the Respondent, he has sufficient knowledge and
information concerning the contents of the within document and that the facts set forth in the
foregoing are true and correct to the best of his knowledge, information and belief. He understands
that false statements made therein are made subject to the penalties of 18 Pa. C.S. §4904, relating
to unsworn falsification to authorities.
V
MARK A. MATEYA, DIRE
Dated:
CERTIFICATE OF SERVICE
I, Mark A. Mateya, Esquire, hereby certify that I have served a copy of the foregoing
document on the following person(s) by depositing a true and correct copy of the same in the
United States Mail, by way of United States Mail, first class, postage prepaid, at Boiling Springs,
Cumberland County, Pennsylvania addressed to:
Ronald L Finck Esquire
Mette Evans & Woodside
PO Box 5950
Harrisburg PA 17110-0950
Dated: ~ ~~
~~ ~~~~
i~ Mark A. Mateya, Esquire
PO Box 127
Boiling Springs, PA 17007
(717) 241-6500
(717) 241-3099 Fax