HomeMy WebLinkAbout10-22-09r•
IN RE:
WILLIAM E. JONES
IN THE COURT OF COMMON PLEAS
CUMBERLAND COUNTY, PENNSYLVANIA
ORPHAN'S COURT -LAW
NO. 2009-940
ANSWER TO PETITION FOR INJUNCTIVE RELIEF
AND PETITION TO SET ASIDE FOWER OF
ATTORNEY OF WILLIAM E. JONES
AND NOW, comes Christine Young, who answers the above-captioned Petition as
follows:
1. Admitted in part. It is admitted that the Petitioner is Reverend Fred D. Johnson.
Respondent does not know where the Petition resides.
2. Neither admitted nor denied. The Respondent admits that Exhibit "A" is a Power
of Attorney purportedly and allegedly executed by William E. Jones.
3. Admitted.
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4. Adnutted. _ -r~ c ~ ~~~
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7. Admitted. ~ .
8. Admitted in part and denied in part. It is admitted that William Jones executed a
Power of Attorney appointing the Respondent as his Attorney. The implication or suggestion
that it was not done properly is denied. By way of further answer, William E. Jones approached
the Respondent for her assistance.
9. Denied. Mr. Jones on July 3, 2009, had the mental capacity to execute a power
attorney and has the mental capacity to execute a Power of Attarney today. The Power of
Attorney executed by William E. Jones on July 3, 2009 and the signatures executed in that Power
aze his signatures. Respondent is unable to respond to the initial statement in paragraph 9
because it is uncleaz what that statement states or suggests.
10. Denied. The Respondent, Christine Young has diverted no funds into any of her
accounts. The checking account and the savings account at M&T Bank, which Mr, Jones had
prior to her appointment as power of attorney, are the only two accounts that are involved in this
matter. There are no accounts with joint names with herself or any other person. By way of
further answer the Respondent has not diverted funds for her own use.
11. Admitted in part and denied in part. The Respondent had contact with
representatives of Met Life for the purpose of ascertaining what assets were owned by William
Jones. Additionally, she had discussions with the representative regarding cashing in the
annuities and regarding other issues with respect to his investments. It is denied that she was
attempting to transfer any funds into an account in which she was a joint owner. Such accounts
do not exist.
12. Neither admitted nor denied. This paragraph contains a conclusion of law to
which no response is necessary.
13. Neither admitted nor denied. This paragraph is a prayer for relief to which no
response is necessary.
WHEREFORE, Respondent respectfully requests that this Petition be dismissed.
Respectfully submitted,
Date: z ~ ` ~
---~
L. Rex Big
114 South
Esquire
Harrisb~g, Pennsylvania 17101
717/234-0577
Attorney I.D. # 23U95
VERIFICATIGN
I, CHRISTINE YOUNG, verify that the facts set forth in the documents are true and
correct to the best of my information, knowledge and belief. I understand that false statements
made herein are made subject to the penalties of Pa. C.S.A. §4904 relating to unsworn
falsification to authorities.
Date: f ~~1~ f ` ~
CERTIFICATE OF SERVICE
I, L. Rex Bickley, Esquire, attorney for Christine Young hereby certify that on this -~
day of October, 2009, I served a true and correct copy of the within Answer to Petition for
Infective Relief and Petition to Set Aside Power of Attorney of William E. Jones, by first class
mail, postage prepaid at Harrisburg, PA to the following:
Marcus A. McKnight, III, Esquire
IRWIN & McKNIGHT, P.C.
60 West Pomfret Street
Carlisle, Pennsylvania 17013
L. Rex Bickley
114 South St.
Harrisburg, P 17101
717-234-0 ?