HomeMy WebLinkAbout11-16-10e..~
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IN THE COMMON PLEAS`COURURT CUMBERLAND COON ~ ~ ~ ~ ~
DIVISION ~-" o
ORPHAN S CO ,._~~, ,.,_ ~..i ; ,~
N0.21-10-0496 ~ «, ~ v-
ESTATE OF DOMINICK SABELLA r~o~ .~,, ~,~; -;~;
EQUEST AN EMERGENCY INJUNCTION AGE,"~'T -- •. ~=-
MOTION TOR a o ``' ~'
EXECUTRIX'S ATTEMPTS TO DISPOSSESS THE BENEFICIARY ~"~
AND SPOUSE FROM 5219 STUART DRIVE, AND ENJOIN THE
ADMINISTRATION OF THE ESTATE WITH ISSUES TO HEARD
IN ORPHAN'S COURT ON JANUARY 13, 2011
NOW comes the Beneficiary, Michael Sabella, with a Motion to Request an
er enc Injunction Against the Executrix's Attemp dminD'tration with IsBues to fbe
Em g Y
and Spouse from 5219 Stuart Drive, 13, 201°,l~n nd represents: ~ ick Sabella.
Heard in Orphan's Court on January
1.Marion Sabella is the lawful wife of the ba familamembereand egalDresident at 5219
At issue is Mrs. Sabella s status as a Sabe Y
uart Drive. Marion Sabella, the decedent's beloved°d someeBedland Breakfast'Inn, as
St since 2006, not as a guest
residence at the property has implied.
the Executrix, through her attorney, Civil
.At the heart of the matter, and the impetus for fili be f~'nd County Pr ho'notaryt o
2
Judgments in Default has beer~ntered with the Cum
2010, that basically throws hers^to
Division, Civil Docket No: 10-5285,-on~November 4,
the street, in spite of her status as 20 O at the Mag st rialDistrict Court 09-1-01, Mrs.
3.At a hearing held on Augusta, ,.,~ the machinations of the
Sabella tried to defend her position but was ovsabela ca not afford an attorney, nor is
Executrix's lawyers, the Butler Law Firm. Mrs
she eligible for free consultation with an experi{ shec ommi ed an earo~rof law in the
other kind of lawyer. Mrs. Sabella was told tha
an a eal, but not how to remedy the error, or whandt aseM chael was physc a ly
filing of PP handles all the legal woes, a
michael Sabella, Beneficiary, ;-, the matter of his very freedom, the
indisposed due to the interference the Executrix
case fell to default.
e of the reletivity of Civil Court Docket No.10-5285, a ~udencef tOhattaan's
4.Becaus
Court Docket no.21-10-049 S,et the amps gn of to or against the Sa ,g~la's will continue
Dockets be enjoind; otherw ~ has interpret~ied a clause in the tb punish and
unabated. Linda Zisman, Executrix,
rive Michael Sabella of his inheritance in accordan a troublesome fly w th a sledge
dep
HeyGse of the Butler Law Firm is a testament to killing
er. En'oinment is the fail/safe mechanism of the COOnic health issuesawho must
hamm 1
does not occur. Both Michael and his wife suffer from c r
fend for themselves as they were taught. Mic~asmanrs~st werdsh'p aseExecutilx.
declining as a result of his first cousin, Linda
5.An emergency injunction is necessary to thwao t t what she wlantsZTheae is nohey
will play any Court; district, civil, criminal, etc... , g
understanding where the hatred,of Ms. Zisman i ~ Mar onf t stayh nrres dente at t earm
suffered by allowing the Sabella s, Michael and/o
home while awaiting a ruling of the President Judge in the Orphan's Coh nhe nc~udin
relative to interpretation of the will. ThisC aela lans to keepthe house that he has g
engagement of conflicts of interests. ~VI~ P
known as home for the majority of his. i~o one evend d ITheoev dlencelof Domen ck'sas
a plan to keept ~ be o resented to Orphan'seCourt on January 13, 2011, where the truth
intentions are p
of everything shall come to light.
WHEREFORE, the Beneficiary, Michaelo thelExecutex and heaminionsawh ch
Emergency Injunction against the actions
amount to dastardly villainy, issue from this augdu n o n a I actions re ative to thehmatter
Sabella's, in residence at 5219 Stuart Drive an 1
under Orphan's Court Docket No.21-10-0496. Tnt s of Li da Z sman have no situation
has become critical, due to the fact that the aqe woman into the street, if the
compulsions about dragging a scared, sick, _ _ _
judgments of november 4, 2010 are left undisturbed.
IIhh Respectfully Submitted,
Dated: ~ 1~
Michael Sabella
VERIFI%i; i l::~a~i
Sabella, swear and affirm under the penaties provided { to the bes$ of my
I, Michael
Pa.C.S.A. Sec. 4904 that facts contamedherein are true and correc
knowledge and belief.
Respectfully Submitted:
Dated-./~~(6 ~~(~
Michael Sabella, pro se
PROOF OF SERVICE
Clerk of Courts (1 copy)
1 Court House Square
Carlisle PA 17013
Kevin Hess, P.J.
1 Court House Square
Carlisle PA 17013
Benjamin J. Butler, Esquire
500 N. 3~d Street, PO Box 1004 ~,,~
.%~1~~
Harrisburg PA 17108
Respectfully Submitted:
Dated:
d l / l / /~ Michael Sabella, pro se
I ~ (~ (I Bld . 22
128 E. Azalea Dr., 9
Harrisburg Pa 17110-3587