HomeMy WebLinkAbout10-21-04 (3) PRAECIPE FOR LISTING CASE FOR ARGUMENT
(Must be typewritten and submitted Jn duplicate)
TO THE PROTHONOTARY OF CUMBERLAND COUNTY:
Please list the within matter for the next Argument Court.
IN RE! ELEANOR U. ' IN THE COURT OF COMMON PLEAS OF
COOLIDGE, ' CUMBERLAND COUNTY, PENNSYLVANIA
- DECEASED. · ORPHANS' COURT DIVISION
· NO. 21-03-936
· JURY TRIAL DEMANDED
1. State matter to be argued (i.e., plaintiff's motion for new trial, defendant's demurrer to
complaint, etc.): Respondents' Motion for Summary Judgment.
2. Identify counsel who will argue case:
(a) for Petitioner: R. Mark Thomas, Esquire
Address: 101 South Market Street, Mechanicsburg, PA 17055
(b) for Respondents: James D. Flower, Jr., Esquire
Address: 26 West High Street, Carlisle, PA 17013
(c) for Estate of
Eleanor U. Robert G. Frey, Esquire
Coolidge: 5 South Hanover Street, Carlisle, PA 17013
3. I will notif~ all parties in writing within two days that this case bas been listed for argument.
4. Argument Court Date: November 10, 2004.
SAIDIS, SHUFF. FLOWER & LINDSAY
Attorneys for Respondents
October 21,2004 B,~~ ~? ~,,~i
',, / James D. Flower, Jr., E~q/CJif'e
~ I.D. #27742
26 West High Street
Carlisle, PA 17013
717-143-6222
AFFIDAVIT
The undersigned does hereby certify as follows:
1. I am an attorney licensed to practice in the Commonwealth of
Pennsylvania, since December, 1986. Since admission to the Bar, I have practiced law
at 5 South Hanover Street, Carlisle, Pennsylvania, at the law office formerly known as
the Law Office of Robert M. F'rey, and now known as Frey and Tiley Law Offices.
2. I am a partner in the law firm of Frey and Tiley.
3. Since the summer of 1989, our office represented Warren F. Coolidge and
Eleanor U. Coolidge in various matters, primarily related to estate planning.
4. On or about October 25, 1991, Mr. and Mrs. Coolidge executed
substantially similar Wills, which Wills left the residue of the estate in Trust, the income
to be paid to the surviving spouse during the spouse's lifetime, and on death, the Trust
was to be divided into three equal shares, one share for each of the Coolidge's children,
the shares to be held in Trust distributing income to the ool dge s ch Idren until such
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time as each child's oldest child attained 18 years of age. At such time, the income
interest of the Coolidge's child would terminate in favor of his or her children.
5. On several occasions both Mr. and Mrs. Coolidge executed new Wills
making certain changes in their testamentary plan since the Wills of 1991. Eleanor U.
Coolidge also executed new Wills making certain changes in her testamentary plan
subsequent to the death of her husband. None of the subsequently executed Wills
provided for any of three (3) children to receive a share of the residue of the estate
outright.
I do hereby swear that the information contained in this Affidavit is true and
correct to the best of my knowledge based on personal recollection and based on my
review of our office files pertaining to Warren F. Coolidge and Eleanor U. Coolidge.
R6bert G. Frey
Sworn and subscribed before me on the ...~% /''~ -day of October, 2004.
Notary public
jB N~]TAR~A L SEAL
TRfS~A A llESS, NOTARY PUBL~
BOROUGH OF CARLISLE, CUMBERLAND CO, PA