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HomeMy WebLinkAbout11-01-10IN RE: FIRST AND FINAL ACCOUNT . OF PAULA SYLVESTER, . EXECUTRIX FOR THE ESTATE OF WARREN P. WICKWIRE, LATE OF UPPER ALLEN . TOWNSHIP, CUMBERLAND COUNTY, PENNSYLVANIA, . DECEASED _ IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA ORPHANS' COURT DIVISION N0. 21-2009-1082 ANSWER TO OBJECTIONS OF W. PETER WICKWIRE, JR., BENEFICIARY TO FIRST AND FINAL ACCOUNT AND STATEMENT OF PROPOSED DISTRIBUTION ra ~ w~ o -,- ~l ~ ~ ~ ~ < s.~ ~rn ~ ~ ~ ~ ~ ' _,cn~ . f- _, ~ ~~ ~ `~ ~ _ - ~~ ~~ ~ - , : N _ '3 tv AND NOW, COMES PAULA SYLVESTER, EXECUTRIX of the Estate of Warren P. Wickwire, Deceased (hereinafter, "Executrix"), by and through her attorneys, James D. Bogar, Esquire, Jennifer B. Hipp, Esquire and Lauren E. Bogar, Esquire, and files this Answer to Objections of W. Peter Wickwire, Jr., Beneficiary, to First and Final Account and Statement of Proposed Distribution and sets forth as follows: 1. Admitted in part and denied in part. It is admitted only that the First and Final Account and Statement of Distribution, as filed, proposes to pay a Commission to the Executrix in the amount of $30,000.00, which is reasonable and just pursuant to 20 Pa.C.S. § 3537. By way of further answer, the proposed Commission is reasonable and just given the amount of work undertaken by the Executrix in the administration of the Estate and the size of the Estate. It is specifically denied that the administration of the Estate, as to "Schedule A" or otherwise, "required minimal duties on the part of the Executrix." The remaining averments in Paragraph 1 of the Objections are legal conclusions to which no response is required. To the extent that a response is required, the remaining averments are denied. 2. Denied. To the extent that Paragraph 2 of the Objections contains averments, they are conclusions of law to which no response is required. To the extent that a response is required, the averments are denied. WHEREFORE, Paula Sylvester, Executrix, respectfully requests that the Objections of W. Peter Wickwire, Jr., Beneficiary, to First and Final Account and Statement of Proposed Distribution, in their entirety, be dismissed with prejudice and that this Honorable Court confirm the First and Final Account and Statement of Distribution and, further, grant to Paula Sylvester, Executrix, the costs of this action, attorneys' fees and any and all other relief deemed just and reasonable. -2- Date: October 2010 J es D. Bo a Esquire Supreme Cou I.D. No. 19475 One West Main Street Shiremanstown, PA 17011 Telephone: (717) 737-8761 Lauren Bo r, Esquire Supreme Court I.D. No. 205966 One West Main Street Shiremanstown, PA 17011 Telephone: (717) 737-8761 Jenne er B. Hipp Supreme Court I.D. No. 86556 One West Main Street Shiremanstown, PA 17011 Telephone: (717) 737-8761 Attorneys for Paula Sylvester, Executrix Estate of Warren P. Wickwire, Deceased -3- VERIFICATION I verify that the statements made in this Answer to Objections of W. Peter Wickwire, Jr., Beneficiary, to First and Final Account and Statement of Proposed Distribution are true and correct. I understand that unsworn statements herein are made subject to the penalties of 18. Pa. C.S.A. Section 4904, relating to unsworn falsification to authorities. DATE: October ,~~, 2010 Paula Sylve r Executrix Estate of Warren P. Wickwire, Deceased -4- CERTIFICATE OF SERVICE I hereby certify that I am on this date serving a copy of the Answer to Objections of W. Peter Wickwire, Jr., Beneficiary, to First and Final Account and Statement of Proposed Distribution as filed this date with the Orphans' Court Division of Cumberland County, by sending the same upon the persons and in the manner indicated below: Service by first-class mail addressed as follows: William L Grubb, Esquire, Jr. Attorney for W. Peter Wickwire, Jr. 3803 Gettysburg Road Camp Hill, PA 17011 October ~, 2010 By: ~~ Ja es D. Bo r, Esquire Pa. I.D. N 9475 One West Mai Street Shiremanstown, PA 17011 (717) 737-8761 October Z,y- , 2010 By: Jenni r B. Hipp, Esquire Pa. I.D. No. 86556 One West Main Street Shiremanstown, PA 17011 (717) 737-8761 October ~ 2010 By: G Gtr' La ren E. B ar, Esquire Pa. I.D. No. 205966 One West Main Street Shiremanstown, PA 17011 (717) 737-8761 Attorneys for Paula Sylvester, Executrix Estate of Warren P. Wickwire, Deceased -5-