HomeMy WebLinkAbout04-06-09IN RE: 1N THE COURT OF COMMON PLEAS
CUMBERLAND COUNTY,
QTIP TRUST U/A PENNSYLVANIA
GEORGE F. DIXON, JR.
ORPHANS' COURT DIVISION
N0.21-1994-0754
REPLY OF MARSHALL L. DIXON,
INDIVIDUALLY, TO NEW MATTER
AND NOW, comes Objector, Marshall L. Dixon, in his individual capacity ("Marshall"),
through his attorneys, Saidis, Flower & Lindsay, and files the following Reply to New Matter:
15. Marshall hereby incorporates as his reply to paragraph 15 the averments set forth
in paragraphs 1 -14 of his Objections. To the extent any further response is required, all
responses of the Answer are denied to the extent inconsistent with the averments of Marshall's
Objections.
16. The averment of paragraph 16 is a legal conclusion to which no response is
required. In the event and to the extent that an answer is deemed to be required, the same is
denied.
WHEREFORE, Marshall L. Dixon respectfully requests relief as set forth in his
Objections.
Respectfully submitted,
SAIDIS, FLOWER & LINDSAY
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2009
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Daniel L. Sullivan, Esquire
Attorney I.D. 34548
2109 Market Street
Camp Hill, PA 17011
Phone (717) 737-3405
Attorney for Marshall L. Dixon,
in his individual capacity
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VERIFICATION
I, Marshall L. Dixon, hereby verify that the facts set forth in the foregoing
document are true and correct to the best of my information, knowledge and belief. I
understand that false statements herein are made subject to the penalties of 18 Pa. C.S.
Section 4904, relating to unsworn falsification to authorities.
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Dated: April ~ , 2009 ~ ;
Mar all L. Dixon
CERTIFICATE OF SERVICE
I certify that I am this date serving the foregoing document upon the person(s)
indicated below by U.S. Mail, postage prepaid, addressed to:
Stanley A. Smith, Esquire
Rhoads & Sinon LLP
1 South Market Street
Harrisburg, PA 17108-1146
No Otto, III, Esquire
Manson, Deardorff, Williams & Otto
10 East High Street
Carlisle, PA 17013-3015
Elizabeth Mullaugh, Esquire
McNees, Wallace & Nurick LLC
100 Pine Street
P. O. Box 1166
Harrisburg, PA 17108-1166
Date: ~ 3, ~~ c1
SAIDIS, FLOWER & LINDSAY
By: ~ti..~-~ i_ ~ ~""""_---
Daniel L. Sullivan, Esquire
Attorney I.D. 3454$
2109 Market Street
Camp Hill, PA 17011
Phone (717) 737-3405
Attorney for Marshall L. Dixon.,
in his individual capacity