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HomeMy WebLinkAbout01-06-11IN 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 NO. 21-2009-1082 ANSWER TO AMENDED OBJECTIONS OF W. PETER WICKWIRE, JR., BENEFICIARY, TO FIRST AND FINAL ACCOUNT AND STATEMENT OF PROPOSED DISTRIBUTION t~~~ n ~~ ~. l __ .wL ,J - T ~ _ ~` ~ ~Gf~ i ~` _ _ .", .~ ~~~ x _ -; r~ •~ v ~ ~- AND NOW, COMES PAULA SYLVESTER, INDIVIDUALLY and as EXECUTRIX of the Estate of Warren P. Wickwire, Deceased (hereinafter, "Executrix"), by and through her attorneys, Lauren E. Bogar, Esquire and James D. Bogar, Esquire, and files this Answer to Amended 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 4 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 Amended Objections are legal conclusions to which no response is required. To the extent that a response is required, the remaining averments are denied. WHEREFORE, Paula Sylvester, individually and as Executrix, respectfully requests that the Amended 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, absolutely, and, further, grant to Paula Sylvester, individually, the costs of this action, attorneys' fees, court costs and, further, any and all other relief deemed just and reasonable. Date: January 6, 2011 ~L. Lauren B r, Esquire Supreme Court I.D. No. 205966 One West Main Street Shiremanstown, PA 17011 Telephone: (717) 737-8761 James D. og r, Esquire Supreme Co I.D. No. 19475 One West Main Street Shiremanstown, PA 17011 Telephone: (717) 737-8761 Attorneys for Paula Sylvester, Executrix Estate of Warren P. Wickwire, Deceased -2- VSRTFICATION I verify that the statements made in this Answer to Amended 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 : January 6 , 2 011 ~~- .. ~_ - . _~ ~ --_.___ Paula Sylvest ,.` dividually and as Executrix of t Estate of Warren P. Wickwire, Deceased -3- CERTIFICATE OF SERVICE I hereby certify that I am on this date serving a copy of the Answer to Amended 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 persons and in the manner indicated below: Service by first-class mail and facsimile transmission as follows: William L. Grubb, Esquire, Jr. Attorney for W. Peter Wickwire, Jr. 3803 Gettysburg Road Camp Hill, PA 17011 Fax: (717)763-6848 the January 6, 2011 By: Lauren E. B a Esquire Pa. I.D. No. 05966 One West Main Street Shiremanstown, PA 17011 (717) 737-8761 January 6, 2011 By: Jan(~es D. Bo ar Esquire Pa. I.D. No 1 475 One West Mai treet Shiremanstown, PA 17011 (717) 737-8761 Executrix Estate of Warren P. Wickwire, Deceased Attorneys for Paula Sylvester, -4-