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HomeMy WebLinkAbout07-22-09 . BEFORE THE REGISTER OF WILLS In Re: CUMBERLAND COUNTY, PENNSYLVANIA ESTATE OF BENJAMIN S. LYONS, Deceased File No. 21-09 II617 RESPONDENT'S REPLY TO PETTI'ION FOR LETTERS OF ADMIlVISTRATION AND NOW comes Michael Lyons (herea$er the "Respondent") by and through his counsel Cra1g M. Kellerman, Esquire, and replies to the Petition for Letters of Adnvnistration for the Estate of Benjamin S. Lyons, deceased thereafter the "Decedent's Estate") and in support thereafter avers the following: 1. Admitted. c-~ ~ -~ 2. Admitted ~~ ~~ ~; ~ c _,_~~~ ~~-; * ^' 3. . Admitted , ~ -h. ~-- .,, m ' cv , ~ -, ~ ~a -~ . s. .. ~. ~~ ~ N ._ i r_ : J 4. Adanitxed. r.~~,,%-'-`, c~ _: ~ _ ~~ •LiiiivK+~i ~ N ' ~~r ~ . dm~tted ~ . f i . ~ ~ 7. Adnntteci. i~. Aclin~tted. 9. Denied. To the contrary, on July 6, 2009 counsel for Respondent provided counsel for Petitioner a letter indicating that he would not sign a renunciation (Exhibit "A" . ~ 10. Admitted. 11. No reply required. 12. Respondent desires to co-administer with petitioner his deceased son's estate. WHEREFORE, it is respectfiully requested that this Honorable Court deny the Petition of Judith I. Scholl for Letters of Administration. 1te11e" Connelly, P.C. By: C g M. Kellerman, Esquire Attorney .D. No. 47119 31 East Marshal Street Norristown, Pennsylvania 19401 (610) 275-6400 e-mail: V~~~I~AITON I, MICHEAL LYONS, petitioner in this matter; verify that, the facts set forth in the foregoing are true are true and correct to the best of my knowledge, information and belief. I understand that false statements herein are made subject to the penalties of 18 Pa.C.S.§4904, pertaining to unsworn falsification to authorities. Date MICHAEL LYONS . ~. KELLEP~MAN & CONNELLY, P.C. ATTORNEYS AT LAW 31 EAST MARSHALL STREET NORRISTOWN, PENNSYLVANIA 19401 (610)275-6400 Fax: (610) 275-0787 Craig M. Kellerman E-Mail: ck@.kellconnlaw.com Richard M. Connelly www.kellconnlaw.com July 6, 2009 Mark E. Halbruner 1013 Monona Road Suite 100 Lemoyne, PA 17043 VIA FACSIMILE (717) 731-9627 1tE: Estate of Benjamin S. Lyons Dear Mr. Halbruner: Kindly note that we represent Michael Lyons and are in the receipt of your letter dated June 18, 2009. Mr. Lyons desires to co-administrate his deceased. son's estate along with his ex-wife. Accordingly, he will not be signing a renunciation. Thank you for your attention to this matter. CC:Michael Lyons (Via Mail)