HomeMy WebLinkAbout11-15-104.
IN RE: Estate of Roberta S. Baldwin, IN THE COURT OF COMMON PLEAS
Deceased CUMBERLAND COUNTY, PENNSYLVANIA
ORPHANS COURT DNISION .v
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PETITION FOR PROBATE OF CONFORMED COPY OF a ~ ~ c ~ ~i
TYPED WILL AND HAND-WRITTEN LIST Q~ O = __
TO THE HONORABLE REGISTER OF WILLS OF CUMBERLAND COUNTY: ~~ r r r~-,
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AND NOW, come the Petitioners, John E. Slike and M & T Bank, by and through their attorneys,
Saidis Sullivan Law, and aver the following in support of this Petition:
1. Petitioners are the Executors in the above referenced Estate having been appointed by the
Register of Wills on August 31, 2010.
2. Decedent is Roberta S. Baldwin, who died on August 17, 2010.
3. The Will of the Decedent admitted to probate by the Register of Wills was ahand-written
Will executed by the Decedent on January 12, 1995 (the "hand-written will"). A copy of the hand-written
will is attached hereto as Exhibit "A."
4. Petitioners also offered for probate two additional documents: (a) a conformed copy of
the Decedent's typed will executed by her on January 19, 1995 (the "typed will"); and (b) a list of
tangible personal property with proposed distributees executed by Decedent on January 19, 1995 (the
"hand-written list"). These documents are attached to this petition as Exhibits "B" and "C," respectively.
The typed wifl and the hand-written list were not admitted to probate when first offered.
5. One of the Petitioners herein, John E. Slike, Esquire, was the scrivener of both the hand-
written will and the typed will, and personally witnessed Decedent's execution of each document.
6. The typed will executed by the Decedent on January 19, 1995 is almost identical to the
hand-written will admitted to probate, the only change being the addition of a paragraph relating to the
disposition of articles of tangible personal property not designated on the hand-written list.
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In both the hand-written will admitted to probate and the conformed copy of the typed
will executed by Roberta S. Baldwin on January 19, 1995, the bulk of her estate is given to seven named
charitable organizations: (a) Franklin and Marshall College, (b) Chatham College, (c) West Shore
Public Library, Camp Hill, PA, (d) Mount Calvary Episcopal Church, Camp Hill, PA, (e) Dickinson
College (f) Harrisburg Academy, (g) Mercersburg Academy
8. Decedent was a widow without children and her intestate heirs aze three first cousins who
are not named as beneficiaries in either the hand-written will or the typed will, although in the typed will
dated January 19, 1995, the children of one of the first cousins are permitted to choose undesignated items
of tangible personal property from her house.
Despite a diligent search by the Executors neither the typed will nor the original hand-
written list of tangible personal property has been located.
10. The search was complicated by the fact that Decedent retained at her house thousands of
documents throughout her two story house, including legally pertinent documents such as deeds, health
care directions and powers of attorney mixed in with decades old accumulated newspaper articles, cards,
notes, receipts, bank statements, greeting cards, civic club materials and other items which normally
would have been discarded years ago.
11. It is the firm belief of the Petitioners that the Decedent's original typed will and original
typewritten list of beneficiaries were not intentionally destroyed by Decedent but were misplaced.
12. The Decedent's Estate consists of tangible personal property, real estate, and intangible
property believed to be in excess of $600,000.00.
13. The persons or institutions having an interest in this Petition are the following:
Beneficiaries Under the Handwritten Will
Bonnie Baldwin Kress
2821 Combe Hill Trail
Raleigh, NC 27613
Anthony Arms (believed to be deceased)
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Adele Baldwin
10025 Glenn Street
Bakersfield, PA 93312-2769
Tatiana Reese (sic) (believed to be deceased)
F&M College
c/o Mary Ann M. Cooke, Associate Director of Gift Planning
P.O. Box 3003
Lancaster, PA 17604-3003
Chatham College
Woodland Road
Pittsburgh, PA 15232
Dickinson College
c/o Joe Martellaro, Gift Planning Officer
P.O. Box 1773
Carlisle, PA 17013-2896
Mercersburg Academy
300 East Seminary Street
Mercersburg, PA 17236
Harrisburg Academy
10 Erford Road
Lemoyne, PA 17043
Camp Hill Public Library (West Shore Library)
100 North 19~' Street
Camp Hill, PA ' 17011
Mt. Cavalry Episcopal Church
123 North 25"' Street
Camp Hill, PA 17011
Beneficiaries Under the Conformed Couv of the Tvoed Will
Tatiana C. Reed (believed to be deceased)
Bonnie Baldwin Kress
(same address as above)
Adele Baldwin
(same address as above)
Franklin & Marshall College
(same address as above)
Chatham College
(same address as above)
e
West Shore Public Library
(same address as above)
Calvary Episcopal Church
(same address as above)
Dickinson College
(same address as above)
Harrisburg Academy
(same address as above)
Mercersburg Academy
(same address as above)
Children of Barbara Tuttle
Lawrence Tuttle
27 Flynt Avenue
Monson, CA 01057
Colby Tuttle
38 Mechanic Street
Upton, MA 01057
Joyce Hams
206 Sugar Hill Road
Williamsburg, MA 01096
Joan Vargas
Department of Human Resources
10205 Channel Island Drive
Austin, TX 78747-2697
Kathleen Cota
P.O, Box 91
163 Montgomery Avenue Extension
Pittsfield, MA 01202-2633
Handwritten List
"Bonnie"
Fbelieved to be Bonnie Baldwin Kress, same address as above)
Stephen Kress
5104 Melbourne Road
Raleigh, NC 27606-1748
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Intestate Heirs
Barbara Swann Tuttle
20 Quaboag Heights drive
Monson, MA 01057
Peter Swann
5 Carlisle Court
Westport, CT 06880
Sherwood Swann
P.O. Box 217
Newport, NC 28570-0217
14. Petitioners believe and aver that of the persons identified in paragraph 13, above, Tatiana
C. Reed and Anthony Arms have predeceased Decedent. (Tatiana C. Reed was erroneously identified as
Tatiana Reese in the hand-written will.)
WHEREFORE, Petitioners respectfully request that the conformed copy of the typed will of
Decedent dated January 19, 1995 and the hand-written list of disposition of tangible personal property
bearing the same date be admitted to probate.
Respectfully submitted,
SAIDIS SULLIVAN LAW
Daniel L. Sullivan, Esquire
Supreme Court ID No. 34548
26 West High Street
Carlisle, PA 17013
(717)243-6222
Dated: 1~1 w • I S ,'1010
VERIFICATION
We, the undersigned Executors of the Estate of Roberta Baldwin, hereby verify and state
that the facts set forth in the foregoing Petition are true and correct to the best of our knowledge
or information and belief. We understand that false statements herein are made subject to the
penalties of 18 Pa. C.S.A.§4904 relating to unsworn falsification to authorities.
Jo ike
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M&T
By:
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LA6T WILL AND TESTAMENT
OF
ROBERTA S. BALDWIN
2, ROBERTA S. BALDWIN of the Borough of Camp Hill, Cumber-
land County, Pennsylvania, declare this to be my Last Will and
Testament, hereby revoking any will previously made by me.
I - I direct the payment of all my just debts out of my
estate as soon as may be practical after my death.
II - Z bequeath to my friend, Tatiana C. Reed of
Harrisburg, PA, my white gold diamond cluster ring, my yellow
gold ring with diamond cluster center with two side diamonds, my
yellow gold bracelet with three small diamonds, and my lapis
lazuli set comprised of a necklace, bracelet and earrings.
III - I bequeath my Taiwan desk, Chinese lacquer coffee
AIDIS, GUIDq
SHUFF &
MASLAND
2109 Mazket Stroet
Camp Hill, PA
table and pastel picture of her father to Bonnie Baldwin Kress.
Should she predecease me, these items shall be distributed to her
son, Stephen Kress.
IV - I bequeath my Atmos clock to Adele Baldwin,
laughter of my deceased husband.
V - I bequeath certain other items of my tangible
personal property, -not-including -cas-h -and -securities, . in -a.c-cor-.
dance with a written list made by me during my lifetime. In the
Page 1
absence of such a list or designation on said list, I direct that
my executor hereinafter named distribute the following items as
indicated and shall sell the remainder of said tangible personal
property and add the proceeds to the residue of my estate:.
A. I bequeath my pearl necklace with .filigree of
diamonds pendant, matching bracelet and earrings to Bonnie
Baldwin Kress, daughter of my deceased husband. Should she
predecease me, these items shall be distributed to her daughter,
Susan Kress.
B. I direct that my executor shall allow the
children (and their spouses) of my cousin, Barbara Tuttle, to
choose any articles of my tangible personal property notprevi-
ously mentioned in this will or a written list, and that the
balance of said tangible personal property be sold.
VS - I bequeath the sum of $10,000 to my friend,
Tatiana C. Reed.
VII - I devise and bequeath all the rest, residue and
AIDIS, GUIDO,
SHUFF &
MASLAND
L109 Market Street
Camp Hill, PA
remainder of my estate of whatever nature and wherever situate as
follows:
A. 20~ of said residue shall be paid to Franklin
& Marshall College, Lancaster, PA;
B. 20~ of said residue shall be paid to Chatham
College, Pittsburgh, PA;
C. 20~ of said residue shall be paid to the West
Shore Public Library, Camp Hill, PA;
D. 15~ of said residue shall be paid to Mt.
Calvary Episcopal Church, Camp Hill, PA;
E. 10~ of said residue shall be paid to Dickinson I
1ege,___Carlisle, PA; _
Page 2
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F. 10~ of said residue shall be paid to Harris-
burg Academy, Wormleysburg, PA;
G.. 5$ of said residue shall be paid to Mercers-
.burg Academy, Mercersburg, PA;
VIII - I appoint Dauphin Deposit Bank and Trust Company
~IDI5, GUIDO,
SNUFF &
MASLAND
;109 Markel Street
Camp Hill, PA
and John E. Slike, Esquire, Executors of this, my Last Will and
Testament. Neither of my personal representatives shall be
required to post bond in this or any jurisdiction.
IN WITNESS WHEREOF, I have hereunto set my hand and seal on
this, the ~ Cl. ~ day of ~; G~fi~c. , 1995 .
//.~//~cb[~~T"a~ S ~3a ~d~l~ (SEAL)
Roberta S. Baldwin
Signed, sealed, published and declared by ROBERTA S. BALDWIN,
Testatrix therein named, on this and two (2) other sheets of
paper as and for her Last Will and Testament, in our presence,
who, in her presence, at her request, and in the presence of each
other, have hereunto subscribed our names as attesting witnesses,
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Name
Name .----__ _ _ ._
Address
_ _ Address
Page 3
R
S
COMMONWEALTH OF PENNSYLVANIA)
SS.
COUNTY OF CUMBERLAND)
WE, the undersigned, the testatrix and the witnesses,
respectively, whose names are signed to the foregoing instru-
ment, being first duly sworn, do hereby declare to the under-
signed authority that the testatrix signed and executed the
instrument as her Last Will and Testament and that she signed
willingly (or willingly directed another to sign for her), and
that she executed it as her free will and voluntary act for the
purposes therein expressed, and that each of the witnesses, in
the presence and hearing of the testatrix signed the will as
witnesses and that to the best of their knowledge the testatrix
was at that time eighteen years of age or older, of sound mind,
and under no constraint or undue influence.
Testatrix
Witness
Witness
IDIS, GUIDO,
SHUFF &
MASLAND
109 Market Sweet
Camp Hill, PA
Subscribed, sworn
testatrix, and subscribed
nesses, this day of
to and acY,nowledged bef ore me by the
and sworn to before me by both wit-
1995.
Notary Public
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