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HomeMy WebLinkAbout06-04-101 ~ IN ~~ IN THE COURT OF COMMON PLEAS OF WILLIAM E. JONES, :CUMBERLAND COUNTY, PENNSYLVANIA ORPHANS COURT 21- 09 - 1132 PETITION FOR APPROVAL OF A SETTLEMENT REGARDING THE PROBATE OF THE WILL OF WILLIAM E. JONES AND NOW, this day of June 2010, comes Barbara Spraglin, the Executrix of the Estate of William E. Jones, by her attorneys, Irwin & McKnight, P.C., and requests the approval of the settlement reached with the heirs at law of the Estate of William E. Jones. 1. The deceased is William E. Jones, who died on December 3, 2009. He had been the subject of litigation regarding a Power of Attorney at Orphans Court 2009-940. His death made that litigation moot and the outstanding petitions were dismissed. 2. The Last Will and Testament of William E. Jones was presented for probate to the Office of Register of Wills of Cumberland County and letters were granted to the Executrix, Barbara Spraglin. 3. On or about December 16, 2009, an Appeal of Probate was filed by Petitioner, Gwendolyn Mosley, who is represented by L. Rex Bickley, Esquire, of Harrisburg, which alsw sought certain relief from the Orphan's Court. ° ~-~:.: x .l ~.~;r.'! ~ 4~Y ' ~ ---" . . r'"~'~c -~-~s 3 ~ ~,»-~ -i `~'~ _ ~~ ~ ~~~ rn ~. 2 s ? 4. On or about December 17, 2009, President Judge Edgar B. Bayley, entered an Order of Court which gave the Estate of William E. Jones 20 days to Answer the Petition and Appeal of Probate. A copy of the Order is marked as Exhibit "A" and made a part of this Petition. 5. The Estate of William E. Jones, filed an Answer on January 20, 2010, a copy of which is marked as Exhibit "B" and made a part of this Petition. 6. Following the filing of the Answer by the Estate of William E. Jones, various settlement negotiations have occurred and the parties have reached a settlement of all the outstanding issues. No other pleadings have been filed. 7. The terms of the settlement are as follows: A. The Appeal of the Probate of the Will dated May 5, 2009, of William E. Jones is withdrawn and deemed to be dismissed. B. Within thirty (30) days of the Court Order approving the compromise of this matter, the Estate of William E. Jones will pay the sum of One Hundred Seventy- Five Thousand and no/100 ($175,000.00) Dollars and upon the sale and settlement of the real estate situate in North Middleton Township, Cumberland County, pay an additional sum of Twenty-Five Thousand and no/ 100 ($25,000.00) Dollars to Christine Young on behalf of herself and other relatives of William E. Jones. C. Christine Young together with the other heirs of William E. Jones does release, quit claim and discharge the Estate of William E. Jones and its counsel, Irwin & McKnight, P.C. D. Each party will pay its own counsel fees and expenses. 3 [ t 8. A copy of the release signed by Christine Young and the other heirs of William E. Jones A copy of the release is marked as Exhibit "C" and made a part of this Petition. WHEREFORE, the Estate of William E. Jones hereby requests that the Court set a hearing to approve this settlement and that the Estate of William E. Jones be permitted to pay expenses related to the maintenance of the real estate and take the steps necessary to obtain the funds required to pay this settlement. sy: Date: June ~ ~ 2010 Respectfully submitted, IRWIN & Mc~NIGHT, P.C. Marcus A. Mc i , uire 60 West Pomfret eet Carlisle, Pennsylvania 17013 (717} 249-2353 Supreme Court I.D. No. 25476 4 ~ -s . ~ r CITATION Office of the Register of Wills Cumberland County, Pennsylvania IN RE: Estate of William E. Jones, Deceased 21-09-1132 COMMONWEALTH OF PENNSYLVANIA ; SS. COUNTY OF CUMBERLAND . TO: L. Rex Bickley Marcus A. McKnight, III GREETINGS: AND NOW this 18`u day of December, 2009, the Clerk of Orphans' Court of Cumberland County issues this citation upon all parties of interest, whether beneficiaries under the will or heirs at law, to show cause why the appeal should not be sustained. The respondents shall have twenty (20) days after service of the citation in which to file an answer and then petitioner shall have twenty (20) days in which to file a reply. r ~~ ~~ Glenda Farner Strasbaugh Clerk of Orphans' Court C7 :.a c~ ' ! ~~ !~ ~... _3 : _ •~ ,, . , ~. ., ~~ ~ ao ` ~ et''' b' ~ } IN RE: WILLIAM E. JONES IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA 21-09-1132 ORPHANS' COURT ORDER OF COURT AND NOW, this j l day of December, 2009, Gwendolyn Mosley having filed an appeal from the grant of letters in the above-captioned case to Barbara Spraglin, fT IS ORDERED that the Register~shall cite all parties in interest, whether beneficiaries under the will yr heirs at law, to show cause why the appeal should not be sustained. The respondents shall have twenty (20) days after service of the citation in which to file an answer and then petitioner shall have twenty (20) days in which to file a reply. When the case is at issue, petitioner shall seek a hearing before a judge. In the interim Barbara Spraglin is enjoined from exercising any powers granted to her. By the Cou~rl~ Edgar B. Bayley, ~1. L. Rex Bickley, Esquire Marcus A. McKnight, III, Esquire :sal ~. ..1 ._ s~. ~., -,~~ ~ r ~ _J ', ice ~ . ~~ ~ ~ `` •.y` .•~ i `.w.ry . tt ~. G7~ ~ s~ lie: `.l oi' ~ fa ~i~' I ~~~~ ~ ~ ~~~~ I ~NWIi~ ~: 4vlc~(I~~IGh~~ i_AW OFFi0~5~ I I i ~ ~ IN RE: : IN THE COURT OF COMMON PLEAS OF WILLIAM E. JONES :CUMBERLAND COUNTY, PENNSYLVANIA ORPHAN'S COURT -LAW N0.21- 2009 - 01132 NOTICE TO PLEAD ~ ~:~-:=~ ~ C - ~, ~.- TO: Gwendolyn Mosley -=_' ~' ~' ~ -~ , ~~- . ~' L. Rex Bickley, Esq. .~ ;--=-;"' ~ , - ~ ~ ' <~-~'. 114 South Street o ~~> r ~"' ~ =-' - : ~-> Harrisburg, PA 17101 - _._, • • ~ .; ~ ; ~ ~ ~t _i ~.-} YOU AR,E HEREBY NOTIFIED TO FILE A WRITTEN RESPONSE TO THE ENCLOSED NEW MATTER WITHIN TWENTY (20) DAYS FROM SERVICE HEREOF OR A JUDGMENT MAY BE ENTERED AGAINST YOU. IRWIN & McKNIGHT, P.C. By: Marcu A. McKn t, III, Esquire 60 West Pomfret Street Carlisle, Pennsylvania 17013-3222 (717) 249-2353 Supreme Court ID. No. 25476 Date: January 25, 2010 - ~ IN RE: : IN THE COURT OF COMMON PLEAS OF WILLIAM E. JONES :CUMBERLAND COUNTY, PENNSYLVANIA ORPHAN'S COURT - LAC' V `~ ,s N0.21- 2009 - 01132 ~=' ~ _ ~ ~= ~ - -` ANSWER TO APPEAL OF PROBATE `~ ;-~-~ - `- ~ `- . ; , PETITION TO INTERVENE. AND `~- ~~ `' -`' t. ~;_ ~ =~ , _.r. _: -- --~ ~ ~ ~ ~ ~ PETITION FOR INJUNCTIVE RELIEF ' ~ ~" ' _ WITH NEW MATTER ~~ ,~, _ ~~'~' AND NOW, this 25th day of January 2010, comes the Respondent, Barbara Spraglin, Executrix of the Estate of William E. Jones, by her attorneys, Irwin & McKnight, P.C., and makes the following Answer to the Appeal of Probate, Petition to Intervene, and Petition for Injunctive Relief with New Matter: 1. The averments of fact contained in paragraph one (1) of the Petition are admitted. 2. The averments of fact contained in paragraph two (2) of the Petition are admitted. 3 The averments of fact contained in paragraph three (3) of the Petition are admitted. 4. The averments of fact contained in paragraph four (4) of the Petition are admitted. 5. The averments of fact contained in paragraph five (5) of the Petition are admitted. 6. The averments of fact contained in paragraph six (6) of the Petition are admitted. 2 ~ t 7. The averments of fact contained in pazagraph seven (7) of the Petition are admitted. 8. The averments of fact contained in pazagraph eight (8) of the Petition are admitted in part and denied in part. A. It is admitted that a hearing was held on November 12, 2009, at 1:30 p.m. before Judge M. L. Ebert, Jr. regarding a Petition to challenge the validity and the use of a Power of Attorney dated July 3, 2009, by Christine Young. Testimony was offered regarding the capacity of William E. Jones to understand and sign documents in July of 2009 by Douglas 3. Bower, M.D., the physician of William E. Jones. Dr. Bowers was not, however, asked for his opinion as to whether William E. Jones had testimony capacity and interest to execute a will on May 5, 2009. Dr. Bowers did testify that the abilities of William E. Jones declined significantly after the death of his beloved wife, Delores Jones, on June 10, 2009. On June 25, 2009, William E. Jones was admitted to the Carlisle Regional Medical Center and discharged to the Claremont Nursing and Rehabilitation facility. B. At the time William E. Jones signed his will, there was no pressure from the church members or officers to sign the will. On the contrary, the will was the result of long discussions between Delores Jones and William Jones concerning the disposition of the assets in the event that either of them died. The church was one of many beneficiaries named by William E. Jones in his last will dated May 5, 2009. The church exerted no influence over Reverend William E. Jones. Its members were primarily occupied with the care of Reverend Jones whose wife was dying of cancer. 3 ~ ~ ~ 9. The averments of fact contained in paragraph nine (9) of the Petition are specifically denied. On the contrary, they are secure in an estate escrow account at M&T Bank, in annuities with Met Life and real estate located on Spring Road in North Middleton Township. 10. The averments of fact contained in paragraph ten (10) of the Petition are specifically denied. On the contrary, there are ongoing expenses for the real estate which should be paid in order to protect the asset. WHEREFORE, the Petition of Gwendolyn Mosley should be dismissed and the Estate of William E. Jones be permitted to proceed. NEW MATTER AND NOW, comes the Respondent, Barbara Spraglin, Executrix of the Estate of William E. Jones, by her attorneys, Irwin & McKnight, P.C., and makes the following New Matter to the Petition of Gwendolyn Mosley: 11. The averments of fact contained in the Answers to the Petition of Gwendolyn Mosley are hereby incorporated by reference and are made a part of this New Matter. 12. The Petitioner, Gwendolyn Mosley, has no staadin~ to bring the Petition which appeals the Probate of the will or seek injunctive relief. She states that she is a second cousin of the deceased but has no standing since she is not an heir at law of William E. Jones. There are more than one first cousin who are the heirs at law of the will of William E. Jones who died leaving no parents, spouse, or children as his heirs at law. 4 ~ ~ ~ 13. The Petition does not expressly state how Gwendolyn Mosley is representing any interest of Christine Young. 14. Christine Young does not have "clean hands" since she mishandled the assets of William E. Jones while serving as his Power of Attorney. She is subject to surcharge by the Estate of William E. Jones for funds spent on her behalf or on behalf of her family. She does not have clean hands in challenging the validity of the will of William E. Jones. 15. Christine Young attempted to cash annuities with MetLife which would not have benefited William E. Jones. It nearly cost William E. Jones a loss of Fifty Thousand and no/100 ($50,000.00) Dollars in income taxes. 16. At the time William E. Jones signed his will on May 5, 2009, he possessed the necessary testamentary interest capacity to sign his will which was the product of considerable planning and thought by William E. Jones and his wife, Delores Jones. 17. The health of William E. Jones sustained a serious decline after the death of Delores Jones on June 10, 2009. He was hospitalized on June 25, 2009, and placed in the Claremont Nursing and Rehabilitation facility in Cumberland County. His health continued to decline and when a hearing was held before Judge Ebert on November 12, 2009, he was hospitalized when under the care of Christine Young in the Pinnacle Health System of Harrisburg. He died on December 3, 2009, having never recovered his health. At no time after the death of Delores 5 • ~ ~. Jones on June 10, 2009, did William E. Jones possess the necessary testamentary interest to formulate and knowingly sign another will or understand the actions of those who had taken custody of him. 18. At the time William E. Jones executed the will dated May 5, 2009, William E. Jones had no contact from the Petitioner or from Christine Young who is motivated by greed and seeks only to defeat the plans and hopes of both Delores Jones who gave her assets to care for William E. Jones, and William E. Jones who sought to benefit lifelong friends and projects he had supported during his life. WHEREFORE, the appeal and the Petition of Gwendolyn Mosley, should be dismissed with costs to the Respondent. Respectfully submitted, IRWIN &~IcKNIC~IT, P.C. sy: Mar s A. Mc i t, III, Esquire 60 est Pomfret Street Carlisle, Pennsylvania 17013 (717) 249-2353 Supreme Court I.D. No. 25476 Date: January 25, 2010 6 ~ ~ " VERIFICATION The foregoing document is based upon information which has been gathered by my counsel and myself in the preparation of this action. I have read the statements made in this document and they are true and correct to the best of my knowledge, information and belief. I understand that false statements herein made are subject to the penalties of 18 Pa.C.S.A. Section 4904, relating to unsworn falsification to authorities. h t~ BARBARA SPRAGLIN Date: January 25, 2010 ~ ~ ~ i IN RE: : IN THE COURT OF COMMON PLEAS OF WILLIAM E. JONES :CUMBERLAND COUNTY, PENNSYLVANIA ORPHAN'S COURT -LAW N0.21- 2009 - 01132 CERTIFICATE OF SERVICE I, Marcus A. McKnight, III, Esquire, hereby certify that a copy of attached document was served upon the following by depositing a true and correct copy of the same in the United States mail, First Class, postage prepaid in Carlisle, Pennsylvania, on the date referenced below and addressed as follows: L. Rex Bickley, Esq. 114 South Street Harrisburg, PA 17101 By: Date: January 25, 2010 IRWIN & McKNIGHT, P.C. ~1 ~ i~/ 60 West Pomfret eet Carlisle, PA 17013 (717) 249-2353 Supreme Court I.D. No. 25476 7 1 f ~ ~~ IN THE COURT OF COMMON PLEAS WILLIAM E. JONES CUMBERLAND COUNTY, PENNSYLVANIA ORPHAN'S COURT -LAW NO. 21-2009-01132 RELEASE This release is made and executed by the following individuals: Mr. Thomas Mosley 975 Fort Hill Street Macon, GA 31217-6403 Mr. Robert Clarence Mosley 690 Penn Street Bressler, PA 17113 Mrs. Christine Young 767 High Street Bressler, PA 17113 Mrs. Agnes Davis 1167 S. Harrisburg Street Oberlin, PA 17113 Mrs. Beatrice Harrison 97 Saint Andrews Blvd. Limerick, PA 19468-4300 (Hereinafter referred to as "Claimants"). Mrs. Gloria Daniels 4606 Hillside Rd. Harrisburg, PA 17109 Mary Thompson 1127 S. Harrisburg Street Oberlin, PA 17113 Mrs. Betty Goodrich 600 Altavista Ave. Harrisburg, PA 17109 WHEREAS, William E. Jones died on December 3, 2009; and WHEREAS, a Will executed by William E. Jones was presented for Probate and accepted into Probate on December 7, 2009, in the Court of Common Pleas of Cumberland County, Pennsylvania; and WHEREAS, Barbara Spraglin was appointed the Executrix of the Estate of William E. Jones; and WHEREAS, the Claimants filed an Appeal of Probate on December 14, 2009; and WHEREAS, the Claimants and the Executrix of the Will which was probated, Barbara Spraglin, and the heirs under that Will wish to compromise and settle all claims and causes of action which they may now have and may have in the future arising out of the Probate of the Will of William E. Jones; and WHEREAS, the Claimants wish to release the Executrix and Heirs of the Last Will and Testament of William E. Jones upon terms set forth below; and WHEREAS, the Claimants have agreed to execute this Release. KNOW ALL MEN BY THESE PRESENCE, the Claimants, in consideration for the payment of $175,000.00, within thirty (30) days from the date of the Court approval of this Agreement and $25,000.00 when certain real estate owned by the late William E. Jones is sold or 180 days of the Court approval of this Release and Agreement, whichever first occurs hereby remiss, release, quit claim and forever discharge Barbara Spraglin; the Executrix of the Last Will and Testament of William E. Jones and any heirs provided for in said Will from all claims, demands, actions, causes of actions, suits, debts ar~d contracts which they may have against Barbara Spraglin and the heirs under the probated Will of William E. Janes, each may have or ..now has from the beginning of the Will to the date of these presences. The $175,000.00 and the $25,000.00 shall be paid to Christine Young, who in turn will make distribution to the other heirs in accordance with the Agreement with the Claimants. AND THEREFORE, WE, do hereby remise, release quit claim, and forever discharge the said Executrix and Irwin & McKnight, P.C., legal counsel and their heirs, executors, administrators, successors and assigns, of and from the said share and of and from all actions, suits, payments, accounts, reckonings, claims and demands whatsoever, related to the Last Will and Testament of William E. Jones dated May 5, 2009, and the administration of his estate. I hereby consent and agree that the Orphan's Court of Cumberland County may discharge the said Executrix and Irwin & McKnight, P.C. legal counsel upon application, without further notice to me. . F the arties hereto do execute this Release this "day of IN WITNESS WHEREO p , 2010. ~` tness Witness Witness ~~ Mr. Thomas Mosley Mr. Robert larence Mosley Mrs. Christie Young ,J ~ V Witness Mrs. Gloria Daniels rv v~ Witness Mrs. Agnes Davis /" , ~~. Witness ~ Ms. Mary Thompson IL Witness Mrs. Beatrice ' arrison YV Witness Mrs. Betty Goodrich - ~ STATE OF GEORGIA : ~~-~)~~ COUNTY OF ~ f~ij~ , t On this, the ~ ~ day of /~~c ~ , 2010, before me the undersi ned /" g officer, personally a peared Thomas Mosley, known to be (or satisfactorily prove) to be the person whose names I subscribed to the within instrument, and acknowledged that he executed the same for the purposes therein contained. IN WITNESS WHEREOF I set m hand and official seal ~_.:..,..,,,,,,,,~,r.. Y KECfA fi COOPER ,f Nohni t?ubik % Bibb C~un1y %~ f en~sion l' Ot My ommission Expires: ~~~ ljo. ~~ WHEREAS, the Claimants wish to release the Executrix and Heirs of the Last Will and Testament of William E. Jones upon terms set forth below; and WHEREAS, the Claimants have agreed to execute this Release. KNOW ALL MEN BY THESE PRESENCE, the Claimants, in consideration for the payment of $175,000.00, within thirty (30) days from the date of the Court approval of this Agreement and $25,000.00 when certain real estate owned by the late William E. Jones is sold or 180 days of the Court approval of this Release and Agreement, whichever first occurs hereby remiss, release, quit claim and forever discharge Barbara Spraglin; the Executrix of the Last Will and Testament of William E. Jones and any heirs provided for in said Will from all claims, demands, actions, causes of actions, suits, debts ar~d contracts which they may lave against Barbara Spraglin and the heirs under the probated Will of William E. Jones, each may have or now has from the beginning of the Will to the date of these presences. The $175,000.00 and the $25,000.00 shall be paid to Christine Young, who in turn will make distribution to the other heirs in accordance with the Agreement with the Claimants. AND THEREFORE, WE, do hereby remise, release quit claim, and forever discharge the said Executrix and Irwin & McKnight, P.C., legal counsel and their heirs, executors, administrators, successors and assigns, of and from the said share and of and from all actions, suits, payments, accounts, reckonings, claims and demands whatsoever, related to the Last Will and Testament of William E. Jones dated May 5, 2009, and the administration of his estate. I hereby consent and agree that the Orphan's Court of Cumberland County may discharge the said Executrix and Irwin & McKnight, P.C. legal counsel upon application, without further notice to me. IN WITNESS WHEREOF, the parties hereto, do execute this Release this ~ day of ~(''1 a , 2010. Witness Witness tea,!` ~ ~~ `~~~ ~~ Witness Mr. Thomas Mosley ~I / ~ .s` ` Mr. Robert larence Mosle / '~~~i Y Mrs. Christine Young STATE OF PENNSYLVANIA SS: COUNTY OF DAUPHIN On this, the ~ day of ~ ~ , 2010, before me, the undersi ed officer, personally appeared Robert Clarence Mos y, known to be (or satisfactorily proved to be the person whose names I subscribed to the within instrument, and acknowledged that he executed the same for the purposes therein contained. ~- IN WITNESS WHEREOF, I set my hand anal official seal N6t~ary -~% ~ My Commission Expires: i ~ WHEREAS, the Claimants wish to release the Executrix and Heirs of the Last Will and Testament of William E. Jones upon terms set forth below; and WHEREAS, the Claimants have agreed to execute this Release. KNOW ALL MEN BY THESE PRESENCE, the Claimants, in consideration for the payment of $175,000.00, within thirty (30) days from the date of the Court approval of this Agreement and $25,000.00 when certain real estate owned by the late William E. Jones is sold or 180 days of the Court approval of this Release and Agreement, whichever first occurs hereby remiss, release, quit claim and forever discharge Barbara Spraglin; the Executrix of the Last Will and Testament of William E. Jones and any heirs provided for in said Will from all claims, demands, actions, causes of actions, suits, debts and contracts which they may Dave against Barbara Spraglin and the heirs under the probated Will of William E. Jones, each may have or now has from the beginning of the Will to the date of these presences. The $175,000.00 and the $25,000.00 shall be paid to Christine Young, who in turn will make distribution to the other heirs in accordance with the Agreement with the Claimants. AND THEREFORE, WE, do hereby remise, release quit claim, and forever discharge the said Executrix and Irwin & McKnight, P.C., legal counsel and their heirs, executors, administrators, successors and assigns, of and from the said share and of and from all actions, suits, payments, accounts, reckonings, claims and demands whatsoever, related to the Last Will and Testament of William E. Jones dated May 5, 2009, and the administration of his estate. I hereby consent and agree that the Orphan's Court of Cumberland County may discharge the said Executrix and Irwin & McKnight, P.C. legal counsel upon application, without further notice to me. IN WITNESS WHEREOF, the parties hereto, do execute this Release this ~ day of __ ~~r ,2010. Witness Witness ~.. Witness Mr. Thomas Mosley Mr. Robert Clarence Mosley ,S3_~v Mrs. Christine Young ~ ~ COUNTY OF DAUPHIN STATE OF PENNSYLVANIA SS: On this, the ~~d- day of f ~ t Q , 2010, before me the undersigned officer, personally appeared Christine Young, known to be Eor satisfactorily prove) to be the person whose names I subscribed to the within instrument, and acknowledged that she executed the same for the purposes therein contained. IN WITNESS WHEREOF, I set my hand and official seal NOTARtAI SEAL pEBRA L GOGGtN Notary Publlc HtGHSPIRE 8080., DAUPHIN COUNTY My Commission Expires Apr 5, 2Q13 NdtP(ry " - " ~ - d My Commission Expires i3 ~. + .~ Witness Mrs. Gloria Daniels Witness Mrs. A e avis (~a~~~~ Y'o~~ y ~~ Witness Ms. Mary Thompso Witness Mrs. Beatrice Harrison Witness Mrs. Betty Goodrich _J k ~ ~ STATE OF PENNSYLVANIA SS: COUNTY OF DAUPHIN . On this, the ~'~ day of ~ ~, , 2010, before me, the undersigned officer, personally appeared Gloria Daniels, kn to be (or satisfactorily prove) to be the person whose names I subscribed to the within instrument, and acknowledged that she executed the same for the purposes therein contained. IN WITNESS WHEREOF, I set my hand an official seal - ~ - NOTARIAL SEAL DEBRA L GOGGIN tary Notary Public My Commission Expires: '~ HiGHSPIRE BORO., DAUPHIN COUNTY S My Commission Expires Apr 5, 2013 ~(/ ~ ~ ~ STATE OF PENNSYLVANIA SS: COUNTY OF DAUPHIN t `~ s' ed On this, the ~ day of ~ ~{ , 2010, before me the under ~gn officer, personally appeared Agnes Davis, kno to be (or satisfactorily prove) to be the person whose names I subscribed to the within instrument, and acknowledged that she executed the same for the purposes therein contained. IN WITNESS WHEREOF, I set my hand and official seal NOTARIAL SEAL OESRA L GOGGIN Notary Publlc l ~y HIGHSPIRE BdRO., DAUPHIN COUNTY My Commission Expires: ~n f My Commission Expires Apr 5, 2013 v r ~ ~ • STATE OF PENNSYLVANIA SS: COUNTY OF DAUPHIN . On this, the ~~ da of /~ 2010 before me the undersi ed Y U1, gn officer, personally appeared Mary Thompson, kno to be (or satisfactorily prove) to be the person whose names I subscribed to the within instrument, and acknowledged that she executed the same for the purposes therein contained. IN WITNESS WHEREOF, I set my hand and o NosARIAI. s~Al. OEBRA L GOGGIN Notary Public HIGHSPIRE 6080., DAUPHIN COUN?1f My Commission Expires Apr 5, 20i 3 seal + "~ ~G Notar My Commission Expires: v~15-~or3 • Witness Witness Witness / •. i/ fitness Witness COMMONWEALTH OF PENNSYLVANIA NOri'AItIAI, SEAL Sarah Barnshaw, Notary Public S Coventry 1'wp, Chester County M cawm~ssion ires~Ma 06, 2013 Mrs. Gloria Daniels Mrs. Agrees Davis Ms. Mary Thompson w .. ~, Mrs. Beatrice Harrison Mrs. Betty Goodrich •~ <; ~ STATE OF PENNSYLVANIA SS: COUNTY OF MC~1-h~OM2~ On this, the o~' n. day of .~- pt-~, ( , 2010, before me the undersigned officer, personally appeared Beatrice Harrison, known to be (or satisfactorily prove) to be the person whose names I subscribed to the within instrument, and acknowledged that she executed the same for the purposes therein contained. IN WITNESS WHEREOF, I set my hand and official seal Notary My Commission Expires: col~orfwBAl.~x o l~xsnv~ NOrfARiAL SEAL. Sarah Bamshaw, Notary Public S Coventry Twp, Chester County commission ' ~ Ma 06, 2013 Y N ~ Witness Witness Witness Witness ,~yy~ o Witness fY1 a~ 1; ~ Y~ ~'1~ Mrs. Gloria Daniels Mrs. Agnes Davis Ms. Mary Thompson Mrs. Beatrice Harrison Mrs. Betty Goodrich ._~ ,~ « STATE OF PENNSYLVANIA SS: COUNTY OF DAUPHIN ; rd On this, the ~ day of ~ ~, ~ , 2010, before me, the undersigned. officer, personally appeared Betty Goodrich, own to be (or satisfactorily prove) to be the person whose names I subscribed to the within instrument, and acknowledged that she executed the same for the purposes therein contained. IN WITNESS WHEREOF, I set my hand andofficial seal NOTARIAL SEAL DEBRA L GOGGIN NO Notary Public .- HiGHSPIRE BORO., DAUPHIN COUNTY My Commission Expires: ~ ~ ~ ~ ~~ f My Commission Expires Apr 5, 2013 - l~ I VERIFICATION The foregoing document is based upon information, which has been gathered by my counsel and myself in the preparation of this action. I have read the statements made in this document and they are true and correct to the best of my knowledge, information and belief. I understand that false statements herein made are subject to the penalties of 18 Pa.C.S.A. Section 4904 relating to unsworn falsification to authorities. ~~ BARBARA SPRAGLIN Date: June 3, 2010 .~ a + ~~ IN ~; IN THE COURT OF COMMON PLEAS OF WILLIAM E. JONES, :CUMBERLAND COUNTY, PENNSYLVANIA ORPHANS COURT :21-09-1132 CERTIFICATE OF SERVICE I, Marcus A. McKnight, III, Esquire, hereby certify that a copy of attached document was served upon the following by depositing a true and correct copy of the same in the United States mail, First Class, postage prepaid in Carlisle, Pennsylvania, on the date referenced below and addressed as follows: L. Rex Bickley, Esq. 114 South Street Harrisburg, PA 17101 IRWIN & McKNIGHT, P.C. By: Marcus ~. McKni , ;Esquire 60 West Pomfret St Carlisle, PA 17013 (717) 249-2353 Supreme Court I.D. No. 25476 Date: June _4 , 2010