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HomeMy WebLinkAbout03-02-11 +€!~r' KOPE & ASSOCIATES, LLC BY: HILARY P. VESELL, ESQUIRE ATTORNEY 1D ~ ST. JOHNS CHURCH ROAD, SUITE ~ o - CAM P HILL, PA x` } 4 ~ L~1,~ ~tT~ ~ `ii IN RE: ESTATE OF : IN THE COURT OF COMMCi~A~F - PETER YANDRIC, :CUMBERLAND COUNTY, F~~VSYL~4N1 DECEASED ~ ~t , :ORPHANS COURT DIVISION NO. ANSWER TO PETITION TO STAY TRANSFER OF ESTATE ASSETS AND TO DETERMINE OWNERSHIP OF TRANSFERRED FUNDS IN THE AMOUNT OF X179,853 PRIOR TO DECEDENT'S DEATH AND NEW MATTER Admitted. Admitted. Admitted. Admitted subject to a mistake in -the Respondent's legal name which is Alice Joan DiSante, instead of Joan L. DiSante. Admitted in part and denied in part. While it is admitted that a branch of Citizen's Bank exists at said location, it is specifically denied that Decedent banked at this location. To the contrary, Decedent banked regularly at the Dillsburg Branch of Citizen's Bank. Denied. After reasonable investigation, answering Respondent is without knowledge or information sufficient to form a belief as to the truth of these averments and, therefore, such allegations are deemed to be denied and strict proof thereof is demanded. Admitted. Admitted. Admitted. Admitted Admitted. Admitted in part and denied in part. While it is admitted that Decedent added Respondent's name to Decedent's checking account, it is specifically denied that it was solely for the purpose of assisting Decedent with his daily living expenses. To the contrary, although this money was used, inter alia, to assist Decedent with his daily living expenses, it was intended as a gift. The money was placed in a joint tenancy bank account with the right of survivorship he shared with his girlfriend, Respondent, after Decedent was advised by his attorney, Andrew C. Sheely. Admitted. Admitted in part and denied in part. While it is admitted that Decedent's physical health was deteriorating as a result of his diagnosis of anal cancer, it is specifically denied that Decedent's mental health was in any way deteriorating. To the contrary, Decedent's mental capacity remained undiminished until he was administered Morphine on October to help him with pain he was experiencing as a result of his cancer. Admitted in part and denied in part. While it is admitted that Respondent provided regular care to Decedent,. it is denied that this care was for any other reason but her love for him as his constant companion and girlfriend. See sympathy card to Respondent from David P. Yandrich and Norma Dieffenbach attached as Exhibit "A." It is further denied that David P. Yandrich and Norma Dieffenbach provided regular care, comfort, or companionship to the Decedent. To the contrary, David P. Yandrich and Norma Dieffenbach would normally visit the Decedent just long enough for Respondent to drive home and tend to her cats before returning to Decedent's home. Furthermore, before Decedent was diagnosed with cancer and became ill, David P. Yandrich did not visit Decedent at all and Norma Dieffenbach only visited Decedent occasionally with her children after they shopped at a nearby flea market. Admitted. By way of further response, Respondent had Decedent's mail held at the Post Office after a Bank Statement she needed to balance her joint account never arrived or went missing; neighbors and relatives would regularly pick up Decedent's mail and leave it outside of his front door. Admitted. By way of further response, Decedent gifted Respondent, his girlfriend and constant companion of over two years, said amount of money. It is clear that the money was gifted, as Decedent even went so far as to write "gift" in the memo section of the check in an effort to make his intentions clear. As further support, it is believed and averred that Decedent consulted his attorney at length regarding gifting said money to his girlfriend. Admitted. By way of further response, Decedent called and spoke at length to Candy L. Abram, Branch Manager/Bank Officer, to transfer said funds into a joint account with Respondent. The transfer of money was handled this way and transferred electronically at Ms. Abram's suggestion. Denied. To the contrary, the amount that Decedent gifted to his girlfriend compromises only a small part of his total Estate. Furthermore, these funds were specifically set up with the intention that they would pass outside of probate so that the Decedent's Estate Plan would not be disrupted. Admitted. Denied. To the contrary, a Power of Attorney restricts only the Agent of the Power of Attorney. See Decedent's last four Power of Attorneys attached as Exhibit Decedent himself would not be limited to gifting restrictions placed on his designated Agent or Power of Attorney. By way of further answer, Decedent never signed an instrument limiting his own gifting authority. Admitted. Denied. To the contrary, neither Decedent, who made said transfers, nor Respondent were under any obligation to inform David P. Yandrich of inter vivos gifts. Denied. After reasonable investigation, Respondent is without knowledge of information sufficient to form a belief as to the truth of these averments and, therefore, such allegations are deemed to be denied and strict proof thereof is demanded. Denied. After reasonable investigation, Respondent is without knowledge of information sufficient to form a belief as to the truth of these averments and., therefore, such allegations are deemed to be denied and strict proof thereof is demanded. Denied. After reasonable investigation, Respondent is without knowledge of information sufficient to form a belief as to the truth of these averments and, therefore, such allegations are deemed to be denied and strict proof thereof is demanded. k Denied. After reasonable investigation, Respondent is without knowledge of information sufficient to form a belief as to the truth of these averments and, therefore, such allegations are deemed to be denied and strict proof thereof is demanded. Admitted in part and denied in part. While it is admitted that David P. Yandrich attempted to remove these funds from their rightful owner without proper authorization, it is specifically denied that doing so would preserve or protect said funds as they were specifically intended to pass outside of probate. Admitted. By way of further response, Respondent is the owner of said funds. By operation of law, the jointly held bank account with right of survivorship passes outside of probate as Decedent's intent was to gift Respondent these said funds. Admitted. By way of further response, David P. Yandrich unlawfully appropriated, without Respondent's knowledge, approximately one-hundred and fifty thousand dollars from said account and left approximately five thousand dollars for Respondent. Decedent was then removed as a party to Respondent's joint checking account with right of survivorship after he passed away to keep David P. Yandrich from removing the rest of said funds from the account which rightfully belonged to Respondent. Denied. To the contrary, Decedent voluntarily, and with sound mind, authorized the transfers from his money market account into the checking account held in joint tenancy after discussing said transfer at length with his banker, Candy L. Abram, and his attorney, Andrew C. Sheely, who counseled him that all said transfers to a joint checking account would be considered a gift. Admitted. By way of further response, all transfers were made before he was prescribed Morphine. Admitted in part and denied in part. While it is admitted that Decedent's mental health may have deteriorated after being administered Morphine, it is specifically denied that this deterioration affected his decision to gift Respondent money, as the money had been gifted prior to Decedent receiving Morphine. Denied. To the contrary, all said transfers occurred while the Decedent's capacity was undiminished, again, before being administered Morphine for his sole medical infirmity, anal cancer. Furthermore, Decedent suffered from no disease or illness of the mind that would call into question his mental powers or capabilities, which remained undiminished before being administered Morphine. By way of further answer, Decedent was making end of life decisions and plans before being administered Morphine. including executing a new Will in September, before which David P. Yandrich, who is contesting the transfers at issue, was not named as a beneficiary in the Will. See the last four Last Will and Testaments of Decedent all written during the past eleven years attached as Exhibit "C". Denied. To the contrary, Decedent was competent to make end of life decisions and was not limited in making end of life decisions by any recently executed Wills or Power of Attorneys. See Exhibits "8"and "C." Denied. To the contrary, all beneficiaries of Decedent's probate and non-probate assets will be taxed at the same rate. Furthermore, the Estate has approximately one million dollars in which to payrall tax liabilities. Denied. To the contrary, it is believed and, therefore, averred that non-probate assets gifted to Respondent comprised less than twenty percent of the Estate. Furthermore, it is believed and, therefore, averred that Decedent had a net worth close to one million dollars so that his Estate will have ample funds in which to pay Estate expenses, tax liabilities, and funds to residual beneficiaries. Denied. After reasonable investigation, Respondent is without knowledge of information sufficient to form a belief as to the truth of these averments and, therefore, such allegations are deemed to be denied and strict proof thereof is demanded. By way of further answer, Decedent did not need his nephews, David P. Yandrich, consent or authorization to make inter vivos gifts. Admitted. Admitted in part and denied in part. While it is admitted that Counsel for the Estate has stayed said transfer of fund, it is specifically denied that Decedent intended said funds to be returned to the Estate. By way of further response, Decedent intended to gift Respondent these funds and even received consult from his attorney, Andrew C. Sheely, regarding said gift. Admitted. By way of further response, Respondent is the rightful owner of said funds that were specifically set up, and intended to pass outside of probate. Admitted in part and denied in part. While it is admitted that Respondent is the rightful owner of said funds, it is specifically denied that Decedent was mentally impaired when said funds were transferred. Denied. To the contrary, the funds were specifically gifted to Respondent by Decedent, who was of sound mind and in full authority to gift his own property through inter vivos transfers. Moreover, said transfers were specifically set up to pass outside of probate after consulting with his attorney, Andrew C. Sheely. Further, the Estate, which is believed to be worth approximately one million dollars has ample and adequate funds in which to pay all taxes and liabilities. Denied. After reasonable investigation, Respondent is without knowledge of information sufficient to form a belief as to the truth of these averments and, therefore, such allegations are deemed to be denied and strict proof thereof is demanded. Admitted. NEW MATTER Respondent had Decedent's mail held at the Post Office after a Bank Statement that Respondent needed to balance the joint account was found missing. The neighbors, Janet Cravener and Barbara Marvain, sometimes picked up the mail and may have gone through it, as well as Decedent's nieces and nephews, who would retrieve the mail and leave it outside of Decedent's front door. Decedent intended to gift Respondent the check for fifty thousand dollars in support thereof, as Decedent wrote "gift" in the memo section of the check. As further support of his intentions, it is believed, and therefore averred, that Decedent consulted his attorney, Andrew C. Sheely, regarding the legal effect of all said transfers. Decedent executed a new Will on September 2A10. It is believed, and therefore averred, that this Will was executed while Decedent was in the hospital being treated with anal cancer. Prior to the execution of Decedent's Will from September David P. Yandrich was not a beneficiary in Decedent's Estate. At that time, the majority of Decedent's Estate was left to charity. See Exhibit "C." It is believed, and therefore averred, that David P. Yandrich was taken out of Decedent's Will for many years due to their strained relationship and the fact that David P. Yandrich rarely visited Decedent before he was diagnosed with anal cancer. Respectfully Submitted, KOPE & ASSOCIATES, LLC Dated: ~ ~d~ l ( HILARY P. VES L, ESQUIRE VERIFICATION I, A. Joan DiSante, Respondent in this matter, have read the foregoing Answer to the Petition. I verify that my averments in this Answer to the Petition are true and correct and based upon my personal knowledge. I understand that any false statements herein are made subject to the penalties of Pa.C.S. § relating to unsworn falsifications to authorities. '`d _ _ , Dated: ~ _ ~ ~ , A. oa iSante o,v1 D,4 r Your lend eiCpression o~' sycnpa{hy ~,~1~~°i~," and friend s11ip vv11 ~ always rentatn to our memories TllanlLyou~or your {ltough~ful~ess r~ 1 ` r ti ~ C1"~ ~ ~`~?:~~p -'C"~a.~ ~ ~Y' ~C% Lam", Cc~',~. s ~C~~i ~ i~?C7~`l`C\ REVOCATION OF POWER OF ATTORNEY KNOW ALL MEN BY THESE PRESENTS, that I, PETER YANDRIC, of Park Place, Mechanicsburg, (Monroe Township), Cumberland County, Pennsylvania, hereby revoke in full the Power of Attorney dated January a copy of which is attached hereto. E IN WITNESS WHEREOF, and intending to be legally bound hereby, I have signed this Revocation of Power of Attorney, hereby revoking any and all other Power of Attorney documents heretofore made by me, this ~ day of September, WITNESS: J t~ ~ ~ (SEAL) PETER YANDRI r r ~ ~r j/pf - COMMONWEALTH OF PENNSYLVANIA SS. COUNTY OF CUMBERLAND : On this, the ~ } day of September, before me, a Notazy Public, personally appeared PETER YANDRIC, known to me or satisfactorily proven to be the person whose name is subscribed to the within instrument, and acknowledged that he executed the same for the purposes therein contained. IN WITNESS WHEREOF, I hereunto set my hand and official seal. ? j; Notar Public' ~ ~ ~ My Commission Expir.~s: - 8Ek'XY pubic M? Carrdwon East ~ r end 0 PETER YANDRIC POWER OF ATTORNEY NOTICE THE PURPOSE OF THIS POWER OF ATTORNEY IS TO GIVE THE PERSON YOU DESIGNATE (YOUR "AGENT") BROAD POWERS TO HANDLE YOUR PROPERTY, WHICH MAY INCLUDE POWERS TO SELL OR OTHERWISE DISPOSE OF ANY REAL OR PERSONAL PROPERTY WITHOUT ADVANCE NOTICE TO YOU OR APPROVAL, BY YOU. i~TS POWER OF ATTORNEY DOES NOT IlVIPOSE A DUTY ON YOUR AGENT TO EXERCISE GRANTED POWERS, BUT WIN POWERS ARE EXERCISED,. YOUR AGENT MUST USE DUE CARE TO ACT FOR YOUR BENEFIT AND IN ACCORDANCE WITH THIS POWER OF ATTORNEY. YOUR AGENT MAY EXERCISE THE POWERS GIVEN HERE THROUGHOUT YOUR LIFETIlVIE, EVEN AFTER YOU BECOME INCAPACITATED, UNLESS YOU EXPRESSLY LIMIT THE DURATION OF THESE POWERS OR YOU REVOKE THESE POWERS OR A COURT ACTING ON YOUR BEHALF TERMINATES YOUR AGENT' S AUTHORITY. YOUR AGENT MUST KEEP YOUR FUNDS SEPARATE FROM YOUR AGENT'S FUNDS. A COURT CAN TAKE THE POWERS OF YOUR AGENT IF IT FINDS YOUR AGENT IS NOT ACTING PROPERLY. THE POWERS AND DUTIES OF AN AGENT UNDER A POWER OF ATTORNEY ARE EXPLAINED MORE FULLY IN PA.C.S. CH. IF THERE IS G ABOUT THIS FORM THAT YOU DO NOT UNDERSTAND, YOU SHOULD ASK A LAWYER OF YOUR OWN CHOOSING TO EXPLAIN TT TO YOU. I HAVE READ OR HAD EXPLAINED TO ME THIS NOTICE AND I UNDERSTAND ITS CONTF~1'TS. ~ ~ ~'l-C-, SEPTEMBER , PETER Y DRIC PETER YANDRIC POWER OF ATTORNEY KNOW ALL MEN BY THESE PRESENTS, that I, PETER YANDRIC, of Park Place, Mechanicsburg, (Monroe Township), Cumberland County, Pennsylvania, have made, constituted and appointed and ~by these presents do make, a constitute and appoint my nephew, DAVID P. YANDRICH, of Candlewycke Drive, Middletown, Dauphin County, Pennsylvania, as my agent with the power to transact any business in my name as though I myself were acting. This Power of Attorney revokes any and all Power of Attorney appointments and Power of Attorney documents heretofore made by me. This power includes, but is not limited to, the following: To engage in bankinE and financial transactions, which means that my agent may: (a) Sign checks, drafts, orders, notes, bills of exchange and other instruments or otherwise make withdrawals from checking, savings, transaction, deposit, loan or other accounts in my name and endorse items payable to me and receive the proceeds in cash or otherwise. (b) Open and close such accounts in my name, purchase and redeem savings certificates, certificates of deposit or similar instruments in my name and execute and deliver receipts for any funds withdrawn or certificates redeemed. (c) Deposit any funds received for me in my accounts. (d) Do all acts regarding checking, savings, transaction, deposit, loan or other accounts, savings certificates, certificates of deposit or similar instruments, the same as if I could do if personally present. (e) Sign any tax information or reporting form required by Federal, State or local taxing authorities, including, but not limited to, any Form W-9 or similar form. (fj In general, transact any business with a banking or financial institution that I could if present; and To enter anv safe deposit boxes, which means that my agent may enter any safe deposit box in my name; add to or remove the contents of such box, open and close safe deposit boxes in my name; however, my agent shall not deposit or keep in my safe deposit box any property in which my agent has a personal interest; and i To pursue claims and litigation, which means that my agent may: (a) Institute, prosecute, defend, abandon, arbitrate, compromise, settle or otherwise dispose of, and appear for me in, any legal proceedings before any tribunal regarding any claim relating to me or to any of my property interests. (b) Collect and receive any claim or settlement proceeds; waive or release my rights; employ and discharge attorneys and others on such terms (including contingent fee anangements) as my agent deems appropriate. (c) In general, exercise all powers with respect to claims and litigation that I could if present and if 1 was competent; and To engage in tangible aersonal property transactions, which means that my agent may: (a) Buy, sell, lease, exchange, collect, possess and take title to tangible personal property in my name. (b) Move, store, ship, restore, maintain, repair, improve, manage, preserve and insure tangible personal properly in my name. (c) In general, exercise all powers with respect to tangible personal property that I could if present; and To engage in real property transactions concerning my real estate at Park Place, Mechanicsburg, (Monroe Township), Cumberland County, Pennsylvania, and any other real estate I may own or hereafter acquire, which means that my agent may: (a) Acquire or dispose of real property (including my current or fuhve residence) or any interest therein, including, but not limited to, the power to buy or sell at public or private sale for cash or credit or partly for each; .exchange, mortgage, encumber, lease for any period of time; give or acquire options for sales, purchases, exchanges or leases; buy at judicial sale any property on which I hold a mortgage. (b) Manage, repair, improve, maintain, restore, alter, build, protect ar insure real property; demolish structures or develop real estate or any interest in real estate. (c) Collect rent, sale proceeds and earnings from real estate; pay, contest, protest and compromise real estate taxes and assessments. (d) Release in whole or in part, assign the whole or a part of, satisfy in whole or in part and enforce any mortgage, encumbrance, lien or other claim to real property. (e) Grant easements, dedicate real estate, partition and subdivide real estate and file plans, applications or other documents in connection therewith. (f) In general, exercise all powers with respect to real properly that I could do if present and competent; and To handle interests in estates and trusts, which means that my agent may receive a bequest, devise, gift or other transfer of real or personal property to me in my own right or as a fiduciary for another and give full receipt and acquittance therefore or a refunding bond therefore; approve accounts of any estate, trust, partnership or other transaction in which I may have an interest; and enter into any compromise and release in regard thereto; and To make additions to an existing trust for my benefit, which means that my agent, at any time or times, may add any or all of the property owned by me to any trust in existence when the power was created, provided that the terms of such trust relating to the disposition of the income and corpus during my lifetime are the same as those set forth in paragraph below. My agent and the trust and its beneficiazies shall be answerable as equity and justice may require to the extent that an addition to a trust is inconsistent with prudent estate planning or financial management for me or with the known or my probable intent with respect to disposition of my estate. To engage in insurance transactions, which means that my agent may: (a) Purchase, continue, renew, convert or terminate any type of insurance (including, but not limited to, life, accident, health, disability or liability insurance) and pay premiums and collect benefits and proceeds under insurance policies. (b) Exercise nonforfeiture provisions under insurance policies. 2 (c) In general, exercise all powers with respect to insurance that I could if present and competent; however, my agent cannot designate himself beneficiary of a life insurance policy unless the agent is my spouse, child, grandchild, parent, brother or sister; and To borrow money, which means that my agent may bon•ow money and pledge or mortgage any properties that I may now or hereinafter own as a security therefore; and To pursue tax matters, which means that my agent may: (a) Prepaze, sign, verify and file any tax return on my behalf, including, but not limited to, joint returns and declarations of estimated tax, including examining and coping all of my tax returns and tax records. (b) Sign` an Internal Revenue Service power of attorney form. (c) Represent the principal before any taxing authority and protest and litigate tax assessments; claim, sue for and collect tax refunds; waive rights and sign all documents required to settle, pay and determine tax liabilities; sign waivers extending the period of time for the assessment of taxes or tax deficiencies; and To disclaim any interest in property, which means that my agent may release or disclaim any interest in property on my behalf, provided that any disclaimer under any statute shall be in accordance with ' applicable law in the event I have been adjudicated an incapacitated person at the time of the execution of the disclaimer; and To renounce fiduciary positions, which means that my agent may: (a) Renounce any fiduciary position to which I have been appointed; and (b) Resign any fiduciary position in which I am then serving, and either file an accounting with a court of competent jurisdiction or settle on receipt and release or other informal method as my agent deems advisable. (c) The terra "fiduciary" shall be deemed to include, without limitation, an executor, administrator, trustee, guazdian, attorney-in-fact or agent or officer or director of a corporation; and To authorize my admission to a medical, nursing. residential or similar facility and to enter into agreements for my care, which means that my agent may apply for my admission to a medical, nursing, residential or other similar facility, execute any consent or admission forms required by such facility which are consistent with this paragraph, and enter into agreements for my care by such facility or elsewhere during my lifetime or for such lesser period of time as my agent may designate, including the retention of nurses for my benefit; and To create a trust for my benefit, which means that my agent may execute a deed of trust, designating one or more persons including my agent, as original or successor trustees and transfer to the trust any or all property owned by me as my agent may decide, subject to the following conditions: (a) The income and corpus of the trust shall either be distributable to me or to the guardian of my estate, or ~ be applied for my benefit, and upon my death, any remaining balance of corpus and unexpended income of the trust shall be distributed to my estate. (b) The deed of trust may be amended or revoked at any time and from time to time, in whole or in part, by my principal or the agent, provided that any such amendment by my agent shall not include any provision which could not be included in the original deed; and 3 To withdraw and receive the income or corpus of a trust, which means that my agent may: (a) Demand, withdraw and receive the income or corpus of any trust over which I currently or in the future have power to make withdrawals; (b) Request and receive the income or corpus of any trust with respect to which the trustee thereof has the discretionary power to make distribution to me or on my behalf; and (c) Execute a receipt and release or similar document for the property received under paragraphs and and To make limited sifts, which means that my agent may make only gifts for or on behalf of me, which are limited as follows: (a) The class of permissible donees under this paragraph shall consist solely of my nephew, David P. Yandrich, my niece, Norma J. Dieffenbach, my friend, Joan DiSante, (including my agent if my agent is a member of any such class), a charitable organization, or any of them. (b) During each calendar year, the gifts made to each or any permissible donee, pursuant to such power, shall have an aggregate value not in excess of, and shall be made in such manner as to qualify in their entirety for, the principal's annual exclusion from the Federal gift tax permitted under section 2503(b) of the Internal Revenue Code, determined without regard to section 2513(a) thereof (or any successor provision to the code) of (Public Law U.S.C. 1 et sea.) for me and, if applicable, my spouse. (c) My agent shall be responsible as equity and justice may require to the extent that any gift made pursuant to a power "to make limited gifts" exceeds the limitations imposed by subparagraph (a) or (b). (d) A power to make gifts, whether or not limited as aforesaid, shall be construed to empower my agent to make gifts to each donee either outright or in trust; in the case of a gift to a minor, such gifts may be made in trust or in accordance with the relevant sections of the Pennsylvania Uniform Transfers to Minors Act or pursuant to an Order of Court. In the case of a gift made in trust, my agent may execute a deed of trust for such purpose, designating one or more persons (including my agent) as original or successor trustees, or may make additions to an existing trust. In making any gifts, my agent need not treat the donees equally or proportionately and may entirely exclude one or more permissible donees, and the pattern followed on the occasion of any gift or gifts need not be followed on the occasion of any other gift or gifts. (e) My agent and the donee of a gift shall be responsible as equity and justice may require to the extent that a gift made by my agent is inconsistent with prudent estate planning or financial management for me or with my 1 known or probable intent with respect to disposition of her estate. (f) No transfer agent, depository or other third party acting in good faith shall have any responsibility to see ~ to the proper discharge by my agent of her duties hereunder. (g) In addition to the gifts authorized by subparagraphs (b) and (c), my agent may make a gift pursuant to ~ such power for the tuition or medical Gaze of any permissible donee to the extent that the gift is excluded from the Federal gift tax under section 2503(e) of the Internal Revenue Code of as a qualified transfer. (h) My agent may consent, pursuant to section 2513(a) of the Internal Revenue Code of to the splitting of gifts made by my spouse, if applicable, to my issue or a spouse of my issue in any amount and to the splitting of gifts made by my spouse, if applicable, to any other person in amounts not exceeding the aggregate annual gift tax exclusions for both spouses under section 2503(b) of the Internal Revenue Code of and 4 To engase in retirement plan transactions, which means that my agent may contribute to, withdraw from and deposit funds in any type of retirement plan (including, but not limited to, any tax qualified or non-qualified pension, profit sharing, stock bonus, employee savings and retirement plan, deferred compensation plan or individual retirement account), select and change payment options for my benefit, make roll-over contributions from any retirement plan to other retirement plans and, in general, exercise all powers with respect to retirement plans that I could if present and competent; and To receive government benefits, which means that my agent may prepare, sign and file any claim or application for Social Security, unemployment, military service or other government benefits; collect and issue receipts for all government benefits or assistance; and, in general, exercise all powers with respect to government benefits that I could if present and competent; and To engage in commodity and option transactions, which means that my agent may: (a) Buy, sell, exchange, assign, convey, settle and exercise commodities, future contracts and call and put options on stocks and stock indices traded on a regulated options exchange and collect and receipt for all proceeds of any such transactions. (b) Establish or continue option accounts for the principal with any securities of a futures broker. (c) In general, exercise all powers with respect to commodity and option transactions that I could if present and competent; and To engage in stock. bond and other securities transactions which means that my agent may: (a) Buy or sell (including short sales) at public or private. sale for cash or credit or partly for cash all types of stocks, bonds and securities; exchange, transfer, hypothecate, pledge or otherwise dispose of any stock, bond or other security. (b) Collect dividends, interest and other distributions. (c) Vote in person or by proxy, with or without power of substitution, either discretionary, general or otherwise, at any meeting. (d) Join in any merger, reorganization, voting-trust plan or other concerted action of security holders and make payments in connection therewith. (e) Hold any evidence of the ownership of any stock, bond or other security belonging to me in the name of a nominee selected by my agent; (f) Deposit or arrange for the deposit of securities in a clearing corporation as defined by applicable law; ~ (g) Receive, hold or transfer securities in book-entry form. (h) In general, exercise all powers with respect to stocks, bonds and securities that I could if present and competent. Subject to the foregoing, I authorize my agent to appoint a substitute or successor to act as agent with the same powers as though named by me in this Power of Attorney. I do hereby ratify and confum all that my agent, and a substitute or successor shall lawfully do, or cause to be done, by virtue of this Power of Attorney. 5 Further, in the event that legal proceedings concerning my incapacity within the meaning of any applicable law or for the appointment of a guardian of my estate and/or person are commenced, I nominate and appoint my agent appointed by this Power of Attorney for consideration by the court having jurisdiction of those proceedings for appointment as the guardian of my estate and/or person, and I request the court to make its appointment in accordance with this nomination, except for good cause shown or disqualification. My agent shill be entitled to reasonable compensation for services performed hereunder. This Power of Attorney shall not be affected by my physical or mental disability or incapacity or by uncertainty as to whether I am dead or alive, and it may be accepted and relied upon by anyone to whom it is presented until such person either receives written notice of revocation by me or a guardian (or similar fiduciary) of my estate, or has actual knowledge of my death. IN WITNESS WHEREOF, and intending to be legally bound hereby; I have signed this Power of Attorney, hereby revoking any and all other Power of Attorney documents heretofore made by me, this ~ day of September, WITN SS: v (SEAL) PETER YAND C 7 r ~ ~ ~ - r~ ~ COMMONWEALTH OF PENNSYLVANIA SS. COUNTY OF CUMBERLAND On this, the ~jf day of September, before me, a Notary Public, personally appeared PETER YANDRIC, known to me or satisfactorily proven to be the person whose name is subscribed to the within instrument, and acknowledged that he executed the same for the purposes therein contained. IN WITNESS WHEREOF, I hereunto set my hand and official seal..., I Notary Publi ~"'s t .•Jt My Commissio, res: ~ NOf1~R1111. S1cAl. BOXY M. iq~LY, Not~? Pt~lk Murg Bao, ~~baia~d Co. _ 6 ~ Corron Mov.19, ACKNOWLEDGMENT EXECUTED BY AGENT I, DAVID P. YANDRICIi, have read the attached Power of Attorney and am the person identified as the agent for the principal, PETER YANDRIC. I hereby acknowledge that in the absence of a specific provision to the contrary in the Power of Attorney or in Pa.C.S.A. Section et. se when I act as agent:, I shall exercise the powers for the benefit of the principal. I shall keep the assets of the principal separate from my assets. I shall exercise reasonable caution and prudence. I shall keep a full and accurate record of all actions, receipts and disbursements on behalf of the rincipal. WITNESS DAVID P. ANDRI September ~ , PETER YANDRIC POWER OF ATTORNEY NOTICE THE PURPOSE OF THIS POWER OF ATTORNEY IS TO GIVE THE PERSON ~'OU DESIGNATE (YOUR "AGENT") BROAD POWERS TO HANDLE YOUR 4 PROPERTY, WHICH MAY INCLUDE POWERS TO SELL OR OTHERWISE DISPOSE OF ANY REAL OR PERSONAL PROPERTY WITHOUT ADVANCE NOTICE TO YOU OR APPROVAL BY YOU. THIS POWER OF ATTORNEY DOES NOT IMPOSE A DUTY ON YOUR AGENT TO EXERCISE GRANTED POWERS, BUT WHEN POWERS ARE EXERCISED, YOUR AGENT MUST USE DUE CARE TO ACT FOR YOUR BENEFIT AND IN ACCORDANCE WITH THIS POWER OF ATTORNEY. YOUR AGENT MAY EXERCISE THE POWERS GIVEN HERE THROUGHOUT YOUR LIFETIME, EVEN AFTER YOU BECOME INCAPACITATED, UNLESS YOU EXPRESSLY LIMIT THE DURATION OF THESE POWERS OR YOU REVOKE THESE POWERS OR A COURT ACTING ON YOUR BEHALF TERMINATES YOUR AGENT'S AUTHORITY. YOUR AGENT MUST DEEP YOUR FUNDS SEPARATE FROM YOUR AGENT'S FUNDS. A COURT CAN TAKE THE POWERS OF YOUR AGENT IF IT FINDS YOUR AGENT IS NOT ACTING PROPERLY. THE POWERS AND DUTIES OF AN AGENT UNDER A POWER OF t~_TTORNEY ARE EXPLAINED MORE FULLY IN PA. C.S. CH. IF THERE IS ANYTHING ABOUT THIS FORM THAT YOU DO NOT [ TNDERSTAND, YOU SHOULD ASK A LAWYER OF YOUR OWN CHOOSING TO EXPLAIN IT TO YOU. I HAVE READ OR HAD EXPLAINED TO ME THIS NOTICE AND I trIVDERSTAND ITS CONTENTS. ~ / ems? . =~ETER Y NDRIC JANUARY ~ , PETER YANDRIC POWER OF ATTORNEY KNOW ALL MEN BY THESE PRESENTS, that I, PETER YANDRIC, of Parlc Place, Mechanicsburg, (Monroe Township), Cumberland County, Pennsylvania, have made, +constituted and appointed and by these presents do make, constitute and appoint my neice, NORMA J. DIEFFENBACH, of High Street, Steelton, Dauphin County, Pennsylvania, as my agent with the power to transact any business in my name as though I myself were acting. This power includes, but is not limited to, the following; To engage in banking and financial transactions, which means that my agent mav: (a) Sign checks, drafts, ordexs, notes, bills of exchange and other instruments or otherwise make withdrawals from checking, savings, transaction, deposit, loan or other accounts in my name and endorse items payable to me and receive the proceeds in cash or otherwise. (b) Open and close such accounts in my name, purchase and redeem savings certificates, certificates of deposit or similar instruments in my name and execute and deliver xeceipts for any funds withdrawn or certificates redeemed. (c) Deposit any funds received for me in my accounts. (d) Do all acts regarding checking, savings, transaction, deposit, loan or other accounts, savings certificates, certificates of deposit or similar instruments, the same as if I could do if personally present. ~ (e) Sign any tax information or reporting form required by Federal, State or local taxing authorities, including, but not limited to, any Form W-9 or similar form. (f) In general, transact any business with a banking or financial institution that I could if present; C-, and To enter anv safe deposit boxes, which means that my agent may enter any safe deposit box in my name; add to or remove the contents of such box, open and close safe deposit boxes in my name; however, my agent shall not deposit or keep in my safe deposit box any property in which my C agent has a personal interest; and I ~ To Pursue claims and litigation, which means that my agent may: (a) Institute, prosecute, defend, abandon, azbitrate, compromise, settle or otherwise dispose of, anal appear for me in, any legal proceedings before any tribunal regazding any claim relating to me or to ' any of my property interests. (b) Collect and receive any claim or settlement proceeds; waive or release my rights; employ and dischazge attorneys and others on such terms (including contingent fee arrangements) as my agent deerns appropriate: ~ # (c) In general, exercise all powers with respect to claims and litigation that I could if present and if 1 was competent; and To engage in tangible personal jpro~ert~ transactions, which means that my agent may: (a) Buy, sell, lease, exchange, collect, possess and take title to tangible personal property in my name. (b) N1.ove, store, ship, restore, maintain, repair, improve, manage, preserve and insure tangible personal property in my name. (c) In general, exercise all powers with respect to tangible personal property that I cotild if present; and S. To engage in real ~ro;~erty transactions concerning any real estate at Parlc Place, Mechanicsburg, Monroe Township, Cumberland County, Pennsylvania and any other real estate I may own or hereafter acquire, which means that my agent may: (a) Acquire or dispose of real property (including my current or future residence) or any interest therein, including, but not limited to, the power to buy or sell at public or private sale for cash or credit or ~ partly for each; exchange, mortgage, encumber, lease for any period of time; give or acquire options for Bales, purchases, exchanges or leases; buy at judicial sale any.property on which I hold a mortgage. ~ (b) Manage, repair, improve, maintain, restore, alter, build, protect or insure real property; demolish structures or develop real estate or any interest in real estate. \ (c) Collect .rent, sale proceeds and earnings from real estate; pay, contest, protest and compromise V \ real estate taxes and assessments. (d) Release in whole or in part, assign the whole or a part of, satisfy in whole or in part. and enforce ~ any mortgage, encumbrance, lien or other claim to real property. (e) Grant easements, dedicate real estate, partition and subdivide real estate and file plans, applications or other documents in connection therewith. 2 (f) In general, exercise all powers with respect to real property that I could do if present and competent; and To handle interests in estates and trusts, which means that my agent may receive a bequest, devise, gift or other transfer of real or personal property to me in my own right or as a fiduciary.. for another and give full receipt and acquittance therefor or a refunding bond therefor; approve accounts + of any estate, trust, partnership or other transaction in which I may have an interest; and enter into any " compromise and release in regard thereto; and To make additions to an existing trust for my benefit, which means that my agent., at any time or times, may add any or all of the property owned by me to any trust in existence when the power was created, provided that the terms of such trust relating to the disposition of the income and corpus during my lifetime are the same as those set forth in paragraph below. My agent and the trust and its beneficiaries shall be answerable as equity and justice may require to the extent that an addition to a trust is inconsistent with prudent estate planning or financial management for me or with the known or my probable intent with respect to disposition of my estate. To engage in insurance transactions, which means that my agent may: (a} Purchase, continue, renew, convert or terminate any type of insurance (including, but not limited to, life, accident, health, disability or liability insurance) and pay premiums and collect benefits and proceeds under insurance policies. (b) Exercise nonforfeiture provisions under insurance policies. (c) hz general, exercise all powers with respect to insurance that I could if present and competent; 11o~vever, my agent cannot designate herself beneficiary of a life insurance policy unless the agent is my 1 ~ ~ spouse, child, grandchild, pazent, brother or sister; and , To borrow money which means that m a ent ma borrow move and led e or mort a e ~ Y g Y Y P g g g any properties that I may now or hereinafter own as a security therefore; and To pursue tax matters, which means that my agent may: (a) Prepare, sign, verify and file any tax return on my behalf, including, but not limited to, joint returns and declarations of estimated tax, including examining and coping all of my tax returns ~l anal tax records. ~ (b) Sign an Internal Revenue Service power of attorney form. C ~ (c) Represent the principal before any taxing authority and protest and litigate tax 3 assessments; claim, sue for and collect tax refunds; waive rights and sign all documents required to settle, pay and determine tax liabilities; sign waivers extending the period of time for the assessment oC taxes or tax deficiencies; and To disclaim any interest in ~ro~erty, which means that my agent may release or. dzsclaim any interest in property on my behalf, provided that any disclaimer under any statute shall be in accordance with applicable law in the event I have been adjudicated an incapacitated person at the t i.me of the execution of the disclaimer; anCl TO renounce flduCiary j~OS1t10nS, which means that my agent may: (a} renounce any fiduciary position to which I have been appointed; and (b) resign any fiduciary position in which I am then serving, and either file an accounting with a court of competent jurisdiction or settle on receipt and release or other informal method as my agent deems advisable. (c) The term "fiduciary" shall be deemed to include, without limitation, an executor, administrator, tntstee, guardian, attorney-in-fact or agent or officer or director of a corporation; and To authorize my admission to a medical, nursing residential or similar facility and to enter into agreements for my care, which means that my agent may apply Eor my admission to a medical, nursing, residential or other similar facility, execute any consent or admission forms required by such facility which are consistent with this paragraph, and enter into agreements for my care by such facility or elsewhere during my lifetime or for such lesser period of time as my agent may designate, including the retention of nurses for my benefit; and i ~ To create a trust for my benefit, which means that my agent may execute a deed of trust, designating one or more persons including my agent, as original or successoz trustees and transfer to the trust any or all property owned by me as my agent may decide, subject to the following v conditions: (a) The income and corpus of the trust shall either be distributable to me or to the guardian of my estate, or be applied for my benefit, and upon my death, any remaining balance of corpus and unexpended income of the trust shall be distributed to my estate. ~j ~ (b) The deed of trust maybe amended or revoked at any time and from time to time, in whole or in part, by my principal or the agent, provided that any such amendment by my agent shall not include C.~~ any provision which could not be included in the on final deed; and g 4 To withdraw and receive the income or corpus of a trust, which means that my agent may: (a) demand, withdraw and receive the income or corpus of any trust over which I currently or in the future have po~ver to make withdrawals; _ (b) .request and receive the income or corpus of anytrust with respect to which the trustee thereof has the discretionary power to make distribution to me or on my behalf;'and (c) execute a receipt and release or similar document for the property received under paragraphs and To make limited gifts, which means that my agent may make only gifts for or on l,ehalf of me which are limited as follows: (a) The class of permissible donees under this paragraph shall consist solely of my agent, my agent's daughter (including my agent if my agent is a member of any such class), a charitable organization, or any of them. (b) During each calendar year, the gifts made to each or any permissible donee, pursuant to such power, shall have an aggregate value not in excess of, and shall be made in such manner as to qualify in theix entirety for, the principal's annual exclusion from the Federal gift tax permitted under section 2503(b) of the Internal Revenue Code, determined without regard to section 2513(a) thereof (or any successor provision to the code) of (Public Law U.S.C. 1 et sere for me and, if applicable, my spouse. (c) My agent shall be responsible as equity and justice may require to the extent that any gift ~ made pursuant to a power "to make limited gifts" exceeds the limitations imposed by subparagraph (a) or (b)• (d) A power to make gifts, whether or not limited as aforesaid, shall be construed to empower my agent t.o make gifts to each donee either outright or in trust; in the case of a gift to a minor, such lifts may be made in trust or in accordance with the relevant sections of the Pennsylvania Uniform Transfers to Minors Act or pursuant to an Order of Court. In the case of a gift made in trust, my agent +?~ay execute a deed of trust for such purpose, designating one or more persons (including my agent) as original or successor trustees, or may make additions to an existing trust. In making any gifts, my agent C~, need not treat. the donees equally or proportionately and may entirely exclude one or more permissible ~ donnees, and the pattern followed on the occasion of any gift or gifts need not be followed on the occasion of any other gift or gifts. 5 (e) My agent and the donee of a gift shall be responsible as equity and justice may require to the extent that a gift made by my agent is inconsistent with prudent estate planning or financial management - for m.e or with my known or probable intent with respect to disposition of her estate. (f) No transfer agents, depository or other thixd party acting in good faith shall have any responsibility to see to the proper discharge by my agent of their duties hereunder. (g) In addition to the gifts authoxized by subparagraphs (,b) and (c), my agent may make a gift pursuant to such power for the tuition or medical care of any permissible donee to the extent that the gift is excluded from the Federal gift tax under section 2503(e) of the Internal Revenue Code of as a qualified transfer. (h) My agent may consent, pursuant to section 2513(a) of the Internal Revenue Code of to the splitting of gifts made by my spouse, if applicable, to my issue or a spouse of my issue in any amount and t.o the splitting of gifts made by my spouse, if applicable, to any other person in amounts not exceeding the aggregate annual .gift tax exclusions for both spouses under section 2503(b) of the Internal Revenue Code of and To engage in retirement flan transactions, which means that my agent may contribute to, withdraw from and deposit funds in any type of retirement plan (including, but not limited to, any tax qualified or non-qualified pension, profit sharing, stock bonus, employee savings and rPt.irement plan, deferred compensation plan or individual retirement account), select and change payment options for my benefit, make roll-over contributions from any retirement plan to other retirement plans and, in general, exercise all powexs with respect to retirement plans that I could if present and competent; and ~ ~ To receive government benefits, which means that my agent may prepare, sign and v file any claim or application for Social Security, unemployment, military service or other government eJ benefits; collect and issue receipts for all government benefits or assistance; and, in general, exercise all `v~' powers with. respect to government benefits that I could if present and competent; and To engage in commodity and ovtion transactions, which means that my agent may: (a) Buy, sell, exchange, assign, convey, settle and exercise commodities, fixture contracts and call N CJ and put options on stocks and stock indices traded on a regulated options exchange and collect and ~ ~ receipt for all proceeds of any such transactions. (b) Establish or continue option accounts for the principal with any securities of a futures 6 broker. (c) In general, exercise all powers with respect to commodity and option transactions that I could if present and competent; and To engage in stock, bond and other securities transactions, which means _ that my agent may: (a) Buy or sell (including short sales) at public or private sale for cash or credit or partly for cash all types of stocks, bonds and securities; exchange, transfer, hypothecate, pledge or otherwise dispose of any stock, bond or othez security. (b) Collect dividends, interest and other distributions. (c) Vote in person or by proxy, with or without power of substitution, either discretionary, general or otherwise, at any meeting. (d) Join in any merger, reorganization, voting-tzust plan or other concerted action of security holders and make payments in connection therewith. (e) Hold any evidence of the ownership of any stock, bond or other security belonging to me in the name of a nominee selected by my agent; (f) Deposit or arrange for the deposit of securities in a clearing corporation as defined by applicable la~v; (g) Receive, hold or transfer securities in book-entry form. (h) In general, exercise all powers with respect to stocks, bonds and securities that I could if present and competent; and To obtain and review my medical records and authorize medical and I surgical procedures, which means that my agent may: (a) Request, review and obtain full and unfettered access to any and all medical or similar records C` maintained by my treating physician, doctor or health card provider or any other medical personnel who provided or .is presently or in the future will be providing medical services to me on my behalf. This Power shall be full and absolute and shall include the power to execute or gzant any and all required releases for the dissemination oz release of such medical information to my agent or others designated by my agent. This power shall be exercisable and operable, notwithstanding any present or future Federal, RJ o~ State or local laws, rules or regulations which may limit access to my medical records; and (b) Arrange for and consent to medical, therapeutical, rehabilitative and surgical procedures for me, including the administration of drugs, subject to the limitations of my Declaration (Living Will); 7 and To make an anatomical gift of all or Part of m~ body, subject to the limitations of my Declaration (Living Will), if any. If my agent shall be or become unable or unwilling to serve or to continue to Y ` serve, then I appoint in her stead or as her successor, my second niece, JOSEPHINE M. DIEFFENBACH, of Steelton, Pennsylvania. Subject to the foregoing, I authorize my agent to appoint a substitute or successor to act as agent with the same powers as though named by me in this Power of Attorney. I do hereby ratify and confirm all that my agent, and a substitute or successor shall lawfully do, or cause to be done, by virtue of this Power of Attorney. Further, in the event that legal proceedings concerning my incapacity within the meaning of any applicable law or for the appointment of a guardian of my estate and/or person are commenced, I nominate and appoint my agent appointed by this Power of Attorney for consideration by the court having jurisdiction of those proceedings for appointment as the guardian of my estate and/or person., and I request the court to make its appointment in accordance with this nomination, except for good cause shown or disqualification. My agent shall be entitled to reasonable compensation for ~ ~ services performed hereunder. U This Power of Attorney shall not be affected by my physical or mental disability or incapacity or by uncertainty as to whether I am dead or alive, and it may be l~7 accepted and relied upon by anyone to whom it is presented until such person either receives varitten notice of revocation by me or a guardian (or similar fiduciary) of my estate, or has actual knowledge of my death. 8 IN WITNESS WHEREOF, and intending to be legally bound hereby, I t?ave signed this Power of Attorney this day of January, ~.'VIT~IES S: ~ f/./"' (SEAL) PETER YA RIC f. J/ ~ / COMMONW~LTH OF PE S~VA~A SS. COUNTY OF CUMBERLAND On this, theme ~ day of January, before me, a Notary Public, personally appeared PETER YANDRIC, known to me or satisfactorily proven to be the person whose name is subscribed to the within instrument, and acknowledged that he executed the same for the purposes therein contained. IN WITNESS WHEREOF, I hereunto set my hand and official seal s Notary Publi ' ~ /G~7 My Commission Expir MORARtALSEAIr' !l~XY M. IO~Y, Notttp hit Mir Ce 9 jI ~ ACKNOWLEDGMENT EXECUTED BY AGENT I, NORMA J. DIEFFENBACH, have read the attached Power of Attorney and am the person identified as the agent for the principal, PETER YANDRIC. I hereby aclcno~vledge that in the absence of a specific provision to the contrary in the Power of Attorney or in Pa. C.S.A. Section et. se when I act as agent: I shall exercise the powers for the benefit of the principal. I shall keep the assets of the principal separate from my assets. I shall exercise reasonable caution and prudence. I shall keep a full and accurate record of all actions, receipts and disbursements on behalf of the principal. ~ ~ J ~ , i WITNESS N(JRMA j. EFFENBACH January , 1 { 1 4 i : POWER OF ATTORNEY (DURABLE) NOTICE THE PURPOSE OF THIS POWER OF ATTORNEY IS TO GIVE THE PERSON YOU- DESIGNATE (YOUR "AGENT")BROAD POWERS TO HANDLE YOUR PROPERTY,,WHICH- MAYINCLUDE POWERS TO SELL OR OTHERWISE DISPOSE OF ANY REAL OR PERSONAL PROPERTY WITHOUT ADVANCE NOTICE TO YOU OR APPROVAL BY YOU.' " THIS POWER OF ATTORNEY DOES NOT II~IPOSE A DUTY ON YOUR AGENT TO EXERCISE GRANTED POWERS, BUT WHEN POWERS ARE EXERCISED, YOUR REGENT MUST USE DUE`CARE TO ACT FOR YOUR BENEFIT AND IN ACCORDANCE: WITH THIS POWER: OF :ATTORNEY. _ .YOUR AGENT MAY EXERCISE THE POWERS GIVEN HERE THROUGHOUT YOUR LIFETIME, EVEN AFTER YOU BECOME INCAPACITATED, UNLESS YOU EXPRESSLY LIMIT THE DURATION OF THESE POWERS OR YOU REVOKE THESE POWERS OR A COURT . ACTING ON YOUR BEHALF TERMINATES YOUR AGENT'S AUTHORITY. YOUR AGENT MUST KEEP YOUR FUNDS SEPARATE FROM YOUR AGENT'S FUNDS. A COURT CAN TAKEAWAY THE POWERS OF YOUR AGENT IF IT FINDS YOUR AGENTIS'NOT ACTING PROPERLY.. THE POWERS AND DUTIES OF AN AGENT UNDER A POWER OF ATTORNEY ARE EXPLAINED MORE FULLY IN Pa. C:S Ch. IF THERE IS ANYTHING ABOUT THIS FORM THAT YOU DO NOT UNDERSTAND, YOU SHOULD ASK A LAWYER OF YOUR OWN CHOOSING TO EXPLAINET TO YOU. I HAVE READ OR HAD EXPLAINED TO ME THIS NOTICE AND I UNDERSTAND ITS CONTENTS. DATE: PETER YANDRIC .KNOW ALL PERSONS BY THESE PRESENTS, that I, PETER YANDRIC, single man, currently of Park Place, Mechanicsburg, Monroe Township, Cumberland County; Pennsylvania, have made, constituted and appointed, and by these presents do make, constitute and appoint ANDREW C. SHEELY, ESQ.; currently of South Market Street, Mechanicsburg, Cumberland County, Pennsylvania, my true and lawful agent and surrogate to make health care and medical treatment decisions on my behalf for me and in my name and on my behalf generally, to do and perform all matters and things, transact all business, make, execute and acknowledge all. contracts, orders, writings, assurances; and instruments which may be requisite or proper to effectuate any matter or thing appertaining to or belonging to me. In the event that ANDREW C. SHEELY, ESQ., is unable or unwilling to act as such agent and surrogate, I appoint his wife, KATHLEEN A. SHEELY, currently of South Mazket Street, Mechanicsburg; Cumberland County, Pennsylvania, as my true and lawful agent and surrogate in his place and stead. In the event that KATHLEEN A. SHEELY, is unable or unwilling to act as such agent and surrogate, I appoint my niece; NORMA J. DIEFFENBACH, currently of Chambers Street, Steelton; Dauphin County, Pennsylvania, as my true and lawful agent and surrogate in her place and stead. Being of sound and disposing mind, memory and understanding, I hereby make, publish and declare this my Power of Attorney,. hereby revoking and making void any and all prior Powers of Attorney by me at any time heretofore made. For'purposes of reliance bythird parties, the presentation of his power by any Agent shall be deemed conclusive proof that the other Agent(s) has failed to act or ceased to serve. NOTICE TO THIRD PERSONS AND ENTITIES: FAILURE TO COMPLY WITH THE INSTRUCTIONS OF THE AGENT HEREIN WITHOUT REASONABLE CAUSE SHALL MAKE YOU SUBJECT TO CIVIL LIABILITY FOR ANY DAMAGES RESULTING FROM NONCOMPLIANCE. IN ACCORDANGE WITH THE PENNSYLVANIA PROBATE, ESTATE AND FIDUCIARIES CODE (PEF CODE) R'HICH READS IN PERTINENT PART AS FOLLOWS: 1 § Section Liability:. (a) ,Third party liability. -Anyperson who is given instructions by an agent in accordance with the terms of a-powerbf attorney shall comply with the instructions..--Any person who without reasonable cause fails to comply with those instructions shall be subject to civil liability for any damages resulting from 'noncompliance. Reasonable cause under this subsection shall include; but not be limited to, a good!faith report having been made by the third party to the local protective services agency regarding abuse, - neglect, exploitation. or abandonment purstratrtto section of the act ofNovember (P.L.381, No.79) known as the Older Adults Protective Services Act. ~ (b) Third party immunity: -Any person who acts in good faith reliance on a pdwer of attorney shall incur no liability as a resulf of acting in accordance with-the instructions of the agent. L SPECIFICPOWERS INCLUDED IN GENERAL POWER -Without limiting the general powers hereby already conferred, my agent and surrogate shall have the following specific powers which are included in the foregoing general powers: A. THERE. SHALL BE NO RIGHT TO MAKE GIFTS FOR ANY REASON OR PURPOSE... B. to create a trust. My agent may execute a deed of trust, designating one or more persons (including himself or herself) as original or successor trustees and transfer to the trust any or'all property owned by me as my agent may decide, subject to the following conditions: The: income and corpus of the trust shall either be distributable to me or to the guardian of my estate, or be applied for my benefit; and upon my death, any remaining balance of corpus and unexpended income ofthe trustshall be distributed to my estate. The deed of trust may be amended or revoked. at any time. and from time to time; in whole or in part, by me or my agent, provided that any such amendment by my agent shall not include any provision which could notbe intruded in the original deed. C, to make additions to an existing trust. A power "to make additions to an ezistu:g trust for my benefit" shall tnean that my agent, at "any time or times, may add sny or all of the property owned by the principal to any trust in existence when the power was created, provided that the terms of such trust relating to the disposition of the income and corpus during my lifetime are the same as those set forth in subsection (B). My agent and the trust and its beneftciaries shall be answerable as equity and justice may require to the extent that an addition to a trust is inconsistent with prudent estate planning or financial management for me or with my known or probable intent with respect to .disposition of my estate. D. in the event of my marriage, to claim an elective share ofthe estate of my deceased spouse. f1 power "to claim an elective share of the estate of my deceased spouse" shall mean that my agent may elect to take against the will and conveyances of my deceased spouse, disclaim any Interest in property which I am required to disclaim as a result of such election, retain any property which I have the right to elect to retain, file petitions pertaining to the election, including pettttons to extend the time for elecfing and petitions for orders, decrees and judgments in accordance with P.E.F. Code Section (e) and (d) (relating to determination of effect ojelection; enjoreement), and take all other actions which my agent deems appropriate in order to effectuate the election; provided, however, that the election shall be made only upon the approval of the court having jurisdiction of my estatein accordance wUh P.E.F. Code Section (relating to right of election personal to surviving spouse) in the case 1 am adjudicated an incapacitated person, or upon the- approval ojthe court having jurisdiction of the deceased spouse's estate in the case 7 have not been adjudicated an incapacitated person. E. to disclaim any interest in property. A power "to disclaim any interest in property" shall mean that my agent may release or disclaim any interest in property on, my behalf in accordance with P.E.F. Code Chapter (relating to disclaimers) br P.E.F. Cade Section (relating to release or disclaimer of powers or interests), provided that any. disclaimer under Chapter shall be in accordance with the provuians of P.E.F. Code SecSon (relating to disclaimers by fiduciaries or agents) in the case I shall have been adjudicated an Incapacitated person at the time of the execution of the. disclaimer..., F, to renounce fiduciary positions. 2 L A power "to reduce fiduciary positions" shall mean that my agent may: (a) renounce any fiduciaryposition to which I have been appointed; and. (b) resign any fiduciary position in which I am then serving, and either file an accounting with a court of competent jurisdiction or settle on receipt and release or other informal method. as the agent deems advisable. The term "fiduciary" shall be deemed to include, without limitation,'an executor, , administrator, trustee, guardian, agent or officer or director of a corporation. f G. to withdraw and receive the income or corpus of a trust. A power "to.withdraw and receive the income or carpus of a trust" shall mean that the agent may; demand, withdraw and receive the income or corpus of any trust over which I have the power to make withdrawals; request and receive the income or corpus of any trust with respect to which the. trustee thereof has the discretionary power to make distribution tome or on my behalf; and execute a receipt and release or similar document for the property received under paragraphs and H. [LEFT INTENTIONALLY BLANK] i. to engage. in real property transactions. A power to "engage in real property .transactions:-shall mean that my agent may: .Acquire or dispose of real property (including my residence) or any interest therein, including, but not limited to the power to buy or sell at public or private sale for cash or creditor partly for each; exchange, mortgage, encumber, lease for any period of time;. give or;acquire options for sales, purchases; exchanges or leases; buy, at judicial. sale anyproperty on which I hold a mortgage. .Manage, repair, improve, maintain, restore, alter; build, protect or.insure real property; demolish structures. or develop real estate. or any interest in real estate. Collect rent, sale proceeds and earnings from real estate; pay, contest, protest and compromise real estate taxes and assessments. Release in whole or in part, assign the whole or a part of, satisfy in whole or in part and enforce any mortgage, encumbrance, lien or other claim to real property. Grant easements, dedicate real estate, partition and subdivide real estate and file plans, applications or other documents in connection therewith: Imgeneral, exercise all powers with respect to real property that the principal could if present, including to sign, seal and deliver deeds and other instruments. L to engage in tangible personal property transactions... A power to "engage in tangible personal property transactions" shall mean that my agent may: Buy, sell, lease, exchange, collect, possess and take title to tangiblepersonal property.. Move, store, ship, restore, maintain, repair, improve, manage, preserve and insure tangible personal property. In general, exercise all powers with respect to tangible personal property that I could if present. ` K. to engage in stock, bond and other securities transactions. A power to "engage in stock, bond and other securities.transactions" shall mean that my agent mays 3 L Buy or sell (including short sales) at public or private sale for cash or credit or partly for cash all types of stocks, bonds and securities; exchange, transfer, hypothecate, pledge or otherwise dispose of any stock,. bond or other security. Collect dividends, interest and other distributions. Vote' in person or by proxy, with or without power of substitution, either discretionary, general or otherwise, at'any meeting. Join in any merger, reorganization, voting-trust plan or other concerted action of security holders and make payments in connection therewith. ~ r ~ Hold any evidence of the ownership of any stock,. bond or other security belonging to me in the name of a nominee selected by my agent. Deposit or arrange for the deposit of securities in a clearing corporation as defined in Division 8 of Title of the Pennsylvania Commercial Code,(relating to investment securities). Receive, hold ar transfei securities in book-entry form. In general, exercise all powers with respect to stocks, bonds and securitiesxhat I could if present. L. There shall be powerto engage in commodity and option" transactions. "M. to engage in banking and financial transactions. A power to "engage in banking and financial transactions" shall mean that my agent may: Sign checks, drafts, orders, notes, bills of exchange and other instruments ("items") or otherwise make withdrawals from checking„savings, transaction, deposit, loan or other accounts in my name and endorse items payable to me and receive the proceeds in cash or otherwise. Open and close such accounts in my name, purchase and redeem savings certificates, certificates of deposit or similar instruments in my name and execute and deliver receipts for any funds withdrawn or certificates redeemed. Deposit any funds received for me in my accounts. Do all acts regarding checking, savings, transaction, deposit, loan or other accounts, savings certificates, certificates of deposit or similar instruments,-the same as I "could do if personally present. Sign any tax information or reporting form required by .federal, state or local ` taxing authorities, including, but not limited to any Form W-9 or similar form. In general, transact any business with a banking or financial institution that I could if present.. N. to borrow money. A power to "borrow money" shall mean that my agent may borrow money and pledge: or mortgage any properties that I own as a security therefore. O. to enter safe deposit boxes I may own singly or jointly with others. A power to "enter safe deposit boxes"shall mean that my agent may enter any safe deposal box an my name; add to or remove the contents of such box, open and close safe deposit boxes to my name; however, my agent shall not deposit or keep in any safe deposal box of mine any property in which my agent has a personal interest. P. to engage in insurance transactions. A power to "engage an insurance transactions" shall mean that my agent may: Purchase, continue, renew, convert or terminate any type of insurance (including, .but not limited to life, accident, health, disability or liability insurance) and pay premiums and collect benefits and proceeds under insurance policies. 4 Exercisenonforfeiture.provisions under insurance policies. In general, exercise all powers with respect to insurance that I could if present; however, my :agent cannot designate himself or herself beneficiary of a life insurance policy unless my agent is my spouse, child, grandchild, parents,: brother or sister. Q. to engage in retirement plan transactions, Apower to "engage in retirement plan transactions" shall mean that my agent may contribute to, withdraw from and deposit funds in any type of retirement plan Cncluding, but not limited to any tax qualified or nonqualified pension, profu sharing, stock: bonus, employee savings and retirement plan, deferred compensation plan or individual retirement account), select and change payment options for me, make roll-over contributions from any retirement plan to other retirement plans and, in » general, exercise all powers with. respect to retirement plans that I could if present R. to handle interests in estates and trusts. Apower to "handle interests in estates and trusts" shall mean that my agent may receive a bequest, devise, gift or other transfer of real or personal property to me rn my own right or as a fuiuciary jor another and give full reeeipt`and acquittance therefore or a refunding bond therefore; approve accounts of any esiate, trust,. partnership or other transaction in which I may have an interest;. and enter Into any compromise and release,in regard thereto. S. to pursue claims and' litigation.: Apower to `pursue claims and litigation"shall mean that my agent may: Institute, prosecute, defend, abandon, arbitrate; compromise, settle or otherwise dispose of, and appear for mein, any legal proceedings before any tribunal regarding any ..claim relating to me or to any' property interest of mine. ; ' Collect and receipt-for any claim or settlement proceeds; waive or release rights of mine;:employ and discharge attorneys and others on such terms{including contingent fee arrangements) as my agent deems appropriate. In general, exercise all powers with respect to claims and litigation that I could if present. T. to receive government benefits. Apower to "receive government benefits" shall mean that my agent may prepare, sign and file any claim or application jor Social Security, unemployment, military service or other government benefits; collect and receipt for al! government benefits or assistance; and, in general; exercise all powers witk respect to government benefits that I could if present. U. to pursue tax matters. Apower to "pursue tax matters" shall mean that my agent ,may: Prepare, sign, verify and file any tax return on my behalf, including, but not limited to, joint retums and declarations of estimated tax; examine and copy al( of my tax retums and tax records. Sign an Internal Revenue Service power of attorney form. Represent mebefore any taxing authority; protest and litigate tax assessments; claim,. sue for and collect tax refunds; waive rights and sign all documents required to settle, pay and determine tax liabilities; sign waivers, extending the period of time for the assessment of taxes or tax deficiencies. In general, exercise all powers .with respect to tax matters thaC I could. if present. U.1 to enter my mailbox, to receive all my mail and to instruct the United States Postal Service to forward all my mail V. :powers generally. All.powers described in this section shall be exercisable with respect to any matter in which I am in any way interested at the giving of this power of attorney or 'thereafter and whether arising in this Commonwealth or elsewhere, with the same powers, and to all intents and purposes with the same validity as I could, if personally present; hereby ratifying and confirming whatsoever my agent shall and may do, by virtue hereof. ; 5 IL HEALTH CARE POWERS - In addition, my surrogate appointed by this Power of Attorney is hereby and shall be authorized to make health pare and medical'treatment decisions'for me which'shall include; but not be limited to the following: A. To have full. and unfettered access to and to review my medical and Simi ar records with any Doctor or other health care provider or similar care provider. This power shall be full and absolute, and shall include the power to grant releases for the dissemination of such information to others. This power shall be exercisable despite anything to.the contrary in any current privacy .acts or similar acts or regulations or such as may be passed or adopted from time to time in the ~ future. s ' B. To authorize my admission to a medical, nursing, residential or similar facility and to enter into agreements for my care at the expense of my estate; to execute any consent of admission. forms required by such facility which aze consistent with this paragraph, and enter into agreements for my care by such facility or elsewhere during mylifetime odor such lesser period of time as my Surrogate may designate, including the retention of nurses for me; C. To authorize medical and swgical procedures and to arrange for and consent to medical, therapeutical and surgical procedures forme, including the administration of drugs; D. To authorize the administration of pain relieving drugs or other medical or surgical procedwes calculated to relieve my pain even though their use may lead to permanent physical damage, addiction or even hastenae moment of (but not intentionally cause) my death and to authorize unconventional pain relief therapies which my surrogate believes may be helpful to me; E. To withhold consent o any medical care or treatment (including medicaland surgical proceduresp F. To revoke or change: any consent previously given or implied bylaw for any medical care or treatment(including medical and surgical procedures); G. To arrange for my removal from any medical or nursing facility; and H. To grant, in conjunction with any instructions given under this power, releases to hospital staff, physicians, nwses and other medical and hospital administration personnel who act in reliance on instructions given by my surrogate or who render writtenopinions to my surrogate in connection with; any matter described in this. power from all liability for damages suffered or to be suffered by me; to sign documents titled or purporting to be a "Refusal to Permit Treatment" and "Leaving Hospital Against. Medical Advice," as well as any necessary waivers of or releases. froFn - liability required by any hospital or physician to implement my wishes regarding medical treatment or non-treatment. III. DURABILITY -This Power of Attomey shall not be affected by any disability on my behalf, including the event that I become incapacitated and/or incompetent to handle my affairs. )v. PROCEEDINGS FOR APPOINTMENT OF A GUARDIAN - In the event that legal proceedings concerning my incapacity, within the meaning of P.E.F. Code Chapter or for the appointment of a guardian of my estate and/or person-are commenced, I nominate my agent appointed by .this Power of Attorney for consideration by the cowl having jurisdiction of those proceedings for. appointment as the guardian of my estate and/or person; and I request the court to make its appointment in accordance with this nomination, except for good cause or disqualification. V. DELEGATION OF POWERS - My agent may delegate any one or more powers granted herein.: to one or more persons and on such terms as my agent may designate and specify..,. 6 IN WITNESS WHEREOF, and intending to be legally bound hereby, I have hereunto set my ;hand and seal this day of WITNESSc (SEAL) PETER YANDRIC i - - 7 COMMONWEALTH OF PENNSYLVANIA ) SS: COUNTY OF ) On this, the day of , before me, the undersigned officer, personally appeared PETER YANDRIC, who being duly sworn according to law, deposes and says thatahe foregoing Power of Attorney is his act and deed and that he desires the same to be recorded as such: IN WITNESS WHEREOF, I have hereunto set my hand and notarial seal the day and year aforesaid. ~ r Notary Public . My Commission expires;.: (SEAL) 8 ACKNOWLEDGMENT (OF ACCEPTANCE OF APPOINTMENT) I, ANDREW' C. SHEELY, E5Q., have read the attached ]lower of Attorney and am the person identified as the agent. for the principal.. I hereby acknowledge that in the absence of a specific provision to the contrary in the Power of Attorney or in Pa. C.S. when I act as agent: L I shall exercise the powers for the benefit of the principal., I shall keep the assets offhe principal separate from my assets. 1 M I shall exercise reasonable caution and prudence. I shall keep a full and accurate record of all actions, receipts and disbursements on behalf of the principal. _ DATE: {SEAL) ? ANDREW C. SHEELY,,ESQ. , 9 'ACKNOWLEDGMENT (OF ACCEPTANCE OF APPOINTMENT) , I, KATHLEEN A. SHEELY, have read the attached Power of Attorney and am the person identified as the agent for the principal. I hereby acknowledge that in the absence of a specific provision to the contrary in the Power of Attomey or in Pa. C.S. when I act as agent: L I shall exercise the powers for the benefiYof the principal. I shall keep the assets of the principal separate from my assets. ~ r r I shall exercise reasonable caution and prudence. I shall keep a full and accurate record of all actions, receipts and disbursements on behalf of the principal. DATE: (SEAL) KATHLEEN A. $HEELY ACKNOWLEDGMENT (OF ACCEPTANCE OF APPOINTMENT) I, NORMA J. DIEFFENBACH, have read the'attached Power of Attorney and.am the person identified as the agent, for the principal. T hereby acknowledge that in the absence of a specific provision to the contrary in the Power of Attorney or in Fa. C.S. when I act_ as agent: I. I shall exercise the powers for the benefit of theprincipal. I shall keep the assets of the principal separate from my`assets. k t I-shall exercise reasonable caution and prudence.'. I shalLkeep a full and accurate record of all actions, receipts and disbursements on behalf of the principal. DATE: (SEAL) _ NORMA J DIEFFENBACH I<1VOW ALL 1~'[I,N If'`~l: 1'RI~SGNTS, that PETER YANL~121C, c>t~ I1)t)'i 1';+t l• I'Lt~ c•, lilc•c~l?~u?icsl,urt;, (i~lc~tt?„~• "l~owtlshi.p), Curttl~erlantl C'c,ttiny, 1'~•tttttivlu;ttti:?, i?:ave tttatlr~, c•ut?stittttr~l y , aru~ appointed aiul by thr•se• 1+rrtit•ttt~ cl,~ t?t;tl•r, ri+ttstitutc• :ttttl .?ppt?ittr ttty nt'pl?tw, 1)AVIll l'. Y~1N1)!t!c ~ 1 t ';tt?cllc~wyi~l.t.~ I )ri~~t~, iLti~lclletowi~, Uattpltin Cuuittti~, 1'c~u?t~,~•l~-:ttti:t, :t5 uty att.urttt•y-in-l~ac•t wiilt. tltt~ l~tnvc~r to tratttiac't att~• htt•,itt,~•:•, iii n+~- i?;+tttt• tltc+ttt;l? I itt~'~.c•II ~~-c•rc~ ~t't i tt4', This power inch+cl`•~~, t'. ??~?t l~ttti~c~c) tc?, thr 1c~11c~~~~it??~ l . To take all la~~~lttl ',t, l'`, t„ tc•,~„ti•,~t, t•iallt~t•t :titcl ?t•i•t~i~~t• any amounts of n~onc~y, now nr hc•rc•al~tt~t „1~•itt;; t,r payable ti> t?ti~, ;uttl tt, c•c~ut~rontise and c~xc•~•t?tc• rc•l~•;+s,c•~, ,~tlt,~t ~~ttl4?c•u•?tt clisc•h;?r~~c•~, 1,?t titrut; To c°?iti~r ~,:tic~ clc~}~c,~,tt t~„~ c?i ~~~lticl? 1 ~tttt rc•tttt•r in my ~ ~ own right. or jointly with c?thc•r~,, t„ „1u•tt itc•~~• ~;tCc• cl~pu:;it I+u~+•s, atttl to :?cltl tc? or rt~ntuvc• a?t~- tl+,• ; ~,ttt, tt~ . ,•I ,?tt~~ ~,tu It sale clc•1?c,tiit 1~„~c•~,, antl to rlc_>sc ouf arty ul• thc• buxc.•,, I,+tt tt~,t tc, 1,I;tc~c• :tny pt.•rsunal pru}~c~rty of tltt• ;tttt~rney-in-I;tt't it? :ttt~~ ~ ,~t+l~. .,,,~,I ,+i t„t+tc•~--itt-l:u~t i•, lititt•~1 ;ts a To tlcpu;,it lu+tcl~, ttt ~,ttlt,lt;t~~~ IuntiS tt?,t?t ;ttt~~ ac,++ttnt that 1 tuay have in al~.y baith, tttt~.t t „ttt},;tit~~, tttttttta( ~,;tvit?g, lt;tttl, t,t savings and loan ~lssctci~ttit?tt, ittt•Ittcltttt', ;t~~c~„ttttt~~ I utay ht?(tl ;ctitttly with c)tltc'r l)c~rsotls, c)r tc~ tlc•[u-,pit fi???tl~ it? :??itl will?tl?"t?~w fintds Crc,nt t?t?v trt•ruuttt. it? t?r?y f"iitt?t?t'it?1 it?~tir?rtit~r? ?~,I)r+ I? rt?, ',.tr{I ,ttt~~???t ttt:t~~ t )t•;)tt• il?,t? [)ttr[)u5r; To endorse t?++tt'~,, ? [t+ + tlr.ttt!, ,rtt(1 Lail[:, ul ~'~t~lttttt~;c, w[t_}ch tllay require my endur5c't?tt'rtt It,r tlt•l,c?tikt, I~ur cas[litt~ c,r Cur Tu scl[, tt.rt?~,It't .?',•,?',s,r? .tr?~~ l,t'r~+,ttal [?rt,l,t'rt~', ~,it•t'1., build or other s~c~urity ~r (witit't?t't' t+i tit~l+t t,l ~~•Itit'I1 1 ttttt ituw ~u+:;!;c's!;c'c[ car ilt w[ti~,11 [ tilay [taut' t?r Itt'rc•,,it+'r .r• +I+r?rc' ,?r? rt?ic•?t•tit trrttl tt, t'~t't'??tc' ;rtty tttlll till itlstrutttc'tttti tl(~c't'.a~,ar~' ~+t ?r?ah?' ti?r+'I? ti:rlt', tratlsFc'r (>r tt1tiit,t?ttt('i~t; rl~c, itu•ur anc~ l,a~, tu?~' t~`.l+t'??',c' c,l. ht'c~~)itt~t; ttty n'.?I t'.titatc' at ll~t)~~ [~~lt'[~ ['l:tt'c', (~~t't'11,??1?+ ^,lr???+' 4\1+sr+l~++' ~ ts?ti11`,1?Il+l, ( ~Ilrlll+s'1~~ills) 1 ~..UUllly, ht11I1Sy[V~1tU~1, titlt~ :?i?~' ++tl?+') lt'.?l t"~1,ilt' [ Il1ay (,bi'11 ++r l??'i"r',Iflt'C a('t[uirc~, itl food order and tt•l+,?tt, s++ l+.?~' ;?ll t,?~t•~ ;tlttl t)tl?t•r c•~l)c'tttirs necessary to keep and nlaint:?it? t??y ',a?tl rt'al t'titate; [c°as~' alt c?r ~,;trts of tier! rctlf estat.r; to [)urrc,w t,t~ tf?t' ~,?~t tr??t~,~ .=f '„??tl ?t•t?I t'!,tatt• ar?t) ~~,r~t' ,t llturt~a~e to serui~r 5u~•[? I+,;?t?; ttt ~,t•ll :r??~~ l+,ttt t+? of ?itv tiaitl tt•al t~~t:tt.(.• f'or such ~~rice atld to surl? [,?rtt l?a~t'r a•, tt?~• :?tittrt?t'y-itl-f~ttc•t ~I?t?ll tlt•t•i?1 c-~~~ tt(~~.tttt.t~;~utt5; ~ttt~i t~, ?tt;ttt,?~~;t•, trrtl+,i+~+ , t??,rt?tt,?irt, t•t'~t~)tt', [,?ti4ti +?t (jc~v~'IuE~ st"tc[t ~~ru[)t'rt y; r[~c, [~??rc-Itatic' c,? ~+tl?+•?~~r',~' :u+lr?irt' :utv itttt'rt'tit i?? :???tl alV,ititl' ~)1)ti1('sl,Ittr? ++f tr':t) qtr+}'++'rl ; 11is1 is w t"~+r clc't'tl', ,?r?ll +!Il?~ i ~t55ur~?ttc~s izl t[le l~tw 1c,r sri? I? [•r++l++ rt ~ ; ~hcl t'\t't'titt', tl1'11~+'{, l~t1u~~-lt•tlgt.: tlet'tlti, t.lt't•cis ttl~ trust, rt)v~~n:lnts, illcat.'uturt'y, :lgYeelilt'11t~,, nll+ll~;;ls+,t•~i, llvOotltecatic>n~, llill~ t>l~ laal{Ilt;, !)Ills, l)tlllt{`;, t1+?11",. +'ll>t',, 1 + ++I Ill'1?t I+'l+•;1',t", :Li `+:111`+l:lt.'l.l(;)!IS UJ llltlitg:lt;~', of it'itf`+ :illtl tllllt'1 tll'l)is, t), l~0 Wit~lClT'dW ~itlll It t t?t\ 1 i11+ t'tlll)Ilti Ittf51_; t 1Q. rho st.te and setilt' ~+tlil~; tll l~intl in my naulr car I~ur 11?y t)t•nt'l~it; "1't) si<<,I1, :1~,`,it~,n +'ll+l++l',1• `,1•+~llrlty itisllt'tl III' :Illy, cr7rl.toratiotl, Ranh <)r <)tllt't ++1ljinlir':lt ,Intl t1, t•~,t'rriu' :In~~ l it+,l?t~, ~,,~itl? 1"t'~;l)t'i't tllt'l~t'tt) tlt:lt l lu;l~' I?.1~1', `l'am Ix)rrtl~w III+111t•~` I++I IiI~ .I+ 1 ++111?i +iI? wlultt'~>t'r Ic'1111ti :111ci c't)ilclitic~ns as tt?:?_y t)c• tlt't'ttterl 1;i~'illt; ll~~ tir'c•uritti' tlit•It•I+)i ;i 111t)I~ll;~:igt', Ilt)lt', 1 + +~ll,ll+ ! .i'• + ti' I++1 i+~;iii'+ llt't't11t'll a~l)1~iJlJll:itt' :Intl, Itllllt+'1, i~1+'+11++' + ~111,11+'I:II it11 lilt' t)111C'r'ti at1l~ lu ~t~iarantee tltt° `+ilit I`~ l lf'illl`+ ..Intl ~1lntllllulis r:1~•~ntr~d a~~ro~riact.~, said }x)~~'t'I t+l 11+~I?+,~~' itlt~itltliltg tilt' right tt) l)1?trow 1111t1)l'~+ Oll :tlt~' 111`+tlr:lill't' II1~ ll~i' lllllll++'~t', ~lilll lu l)lc'ilg~, assign, :?itcl tlcli~'t'r '•tl1 ;i`~ 11Itt~'; To l)rc'l):1t-c', r'~;t'c•tllt• llll• :Ill t.lh ?t•turnti rt'titurt•tl I)t' . t1l:ult' lty tnr, to l):?~' tllr t.1~,t'•s +lll+', t;1 + f ~ f {t'luntlti, `,lt+,li will~~t'rs c'xtt'nclittg cite ltt'rit)tl Ct)r tll+' ,?`„t•',',1?It'tlt ,li `,t1t~11 t;1Xrti ur tit'lit•it'nt'it's in tllt't?1, tc~ sign cc)ttst•ltt~; tt~ tltt' i1111nt'111.1t+' •,',+•',~rll+•1tt c)I~ tlt•Iit'i1'nt•11"• ;Intl i11 t~i.'lltilllt't'~+ t,l Illlll iil`~t'll I.1 + f~i ! ',l l I11t~ l ,11`I1'i I11!`111'~, i llllll CC) l'll~a~l' )1)1?1l11 ,tilt,iltt'\", it+ Ic`ltli ',fill Ilit' ill t't?Illlt'l'111+11 1\'illl clll~' 1t1:1LtCt5 ;.IY1S111(~ 1)l'fO1"t' 11'tit^1,11, ',i;ltt' tll. 111t':1~ t:l\Ill~~ :Il~t'l11'~', "l~u tli5cl:?iul ilitt~lt•',1 ~111,In'rty; l "1'O_tt•Ilt?1111+ I I+I11+ I.t, 1+t ~',Il It +ll`,, l6. "l~o al?rall~e l~lr Illy c'llll:tllt't' tt, :?IIt1 t'arc~ at al?y llu~~lital, 1lC)Illt', 11t':I1111 t't'lltl'1, +t+ll;'.Il±"++ III IIt1111t', It'l?rt'illt'ill t,1 (ll,',t1C11tIt,11, .IItt1 It, ,111,ilIS~•t l+~I ++~u Itl ~\';It\t' 11'iliilil.Ii1' ant! :Ill nleclirll and sur~i1:11 l+liit t +11t1{ . i,ll 11?•E I,t'll:lll, il?t'llltllil?~. 1?tll?lillistrlltit)11 nf,(Irl.lgs, ~:uul 11t ~tll 1+111a I+.I t';tlt'; 1'O lill'~I f+11 ilt'fli :I11(~ IO ;It1l~illl?Ilti lt) t~Xl5llll~ Illy 1 r1'II+'! II , "l~c, ?ll:ll.t' t~ill~, 1111u11.11 t'lll~,. "l~c) t'ttt:lt',1' ill 11'lllt°n?1•I11 I,I,III (1:11?ti;?ctic,llti. '~O. '1'c~ r1•it'I\'t' t'++~'+'?II111+ 11t llt llt`~ "1'c~ j)1lrsue t:il il?~ilt1•?ti. ; i 1 I..,li + ~l 1~1,1~'t'1 il~~tlt~ ; lit' .1111'l'It'tl III\ ~ 11\"~it';1~ Illt'111~11 t11~:11,11111' 1.It \ ~ it I ~ti + ! i:iliti 1 ~ t~ l,+ 1 1 +1t ,1t1 ur ~1~1\'t', :llll~ ll Illay 1)l' :I1'la'1~1? t1 is II+,I 111~+~t1 I~\' \'t Itt le'llttitl it ~1Ct'Sl'iltl'~~ Ulltll titll'~1 ~eYSrJiI t'11111 I Is t t 1;t 1t'llitl'll Ilt,llt'~' 1,f It'\'1,t';1111?11 1)y . y, lilt' Or A guarcii,lll (c)r 5iillil:il Ilt~llt s i+l !II\' 1",1;1?t', l,l It:Iti :It'til:ll J 1 ~ l~llc~wll~d~e ol~ llly clt',?t I1. N1y :Itturllc'y-il?-I~It~t ~,il,lll I,t 1 1?Iltlt•1~ rl•:ttiut?:tl?It' CU111~~.'~LS.1t1011 f(11' tit'1~Vlt'1'~, It1'111,IIIli'tl I,t'It'1111111'1 1 IN WITNESS ~-1'l ll I~.I + , llli?'tllliit~; t~? It?• I~•t;:?Ily I~uttntl I?c°reL~y, I have si~nt.•rl this Pri~~'t•r t tl pit t+ it l?t•~~ t hip, .J~~ ~Iay of Allril, ''t)UU. ti~'ITNL,SS. ' F % .J Y Yw /'r L' . t't"i't'tt '>r'~~NI )tilt ; t'1 )hl~It)N1~ti'I'.;11 III 1 I'I I !t a';11 ~ of 1 (:'()l IN'1'Y CUlV1i31.IZ1r1I'~l{ > C)11 this, the J~fh tl,.l`~ ••I ;'UI?1?, lu•Ittrr n?c•, 1~+11)l;1ry ~~l1~lllt', l~t•1'tit111:111~' ~Ilil!{':tli'~I l+ i ~,It1llill I` II~+W11 I+~ ~+f ',;111'~l:I~ ltillly l11'OVt'il t0 LAC ll?r IICI'tiUll ~~'ll+~',+' I'. ,iil+~,+ 111~1'~I I+t till' S\'tlhlll III•,111111tt'tti, ;llltl tt~'l~llo>,vlCdgrt that h~• t.'~c1111,•+I II1, I~~I I11~ I.11i1~+~'.t•s lht•lt'ill tt~lll.lill~.I. IN Wf1~itil:Sti 1'ti'l I;i + ?f 11•+ulr~t ~,+•i 1?ty h:?I?tl ,u111 +ttll+ i;ll tir~ll. it .li I',1111i1~ ~ ~f~-/1.-~ ~ ; rf~I:1'~'Lfi ~l; 1 +~illllll',~•i~•11 l:xlti?'c•ti:L.c~Cturl T%~Lt'3 rror~R{~1~ sou AlyM W MlIN1tM, Nofiry Pubik Nk?+ Iw~1+~Mt;r~+++~ k~1ao, C.wMrtla~>'d CAwM A~}r (~I.NMN1[i~+ii? ~rt~M lfr~tl ~ ~ LAST WII.,L AND TESTAMENT OF PETER YANDRIC I, PETER YANDRIC, of Park Place, Mechanicsburg, (Monroe Township), Cumberland County, Pennsylvania, make; publish and declare this as and for my Last Will and Testament, hereby revoking all other Wills and Codicils heretofore made by me. FIRST: I direct that all inheritance, estate, transfer, succession and death taxes, as well as my just debts and funeral expenses, of any kind whatsoever, which may be payable by reason of my death, shall be paid out of the principal of my estate as the same can conveniently be done. SECOND: I specifically give and bequeath a sum of Five Thousand Dollars to my friend, JOAN DISANTE, of Camp Hill, Pennsylvania, per stirpes. THIRD: I give, devise and bequeath all the rest, residue and remainder of my estate of whatever nature and wherever situate, including any property over which I hold power of appointment and together with any insurance policies thereon, as follows: (a) Twenty-fve percent thereof unto my niece, NORMA J. ~ ~ DIEFFENBACH, of Steelton, Pennsylvania, provided that should NORMA J. ~ DIEFFENBACH predecease me, I give and bequeath her share unto my nephew, DAVID P. YANDRICH, of Middletown, Pennsylvania; and (b) Seventy-five percent thereof unto DAVID P. YANDRICH, provided that should DAVID P. YANDRICH predecease me, I give and bequeath his share unto NORMA J. DIEFFENBACH. r' FOURTH: In addition to all powers granted to them by law and by other provisions of this Will, I give the fiduciaries acting hereunder the following powers, applicable to all property, exercisable without court approval and effective until actual distribution of all property: (A) To sell at public or private sale, or to lease, for any period of time, any real or personal property and to give options for sales, exchanges or leases, for such prices and upon such terms (including credit, with or without security) or conditions as are deemed proper. This includes the power to give legally sufficient instruments for transfer of the property and to receive the proceeds of any disposition. (B) To partition, subdivide, or improve real estate and to enter into agreements concerning the partition, subdivision, improvement, zoning or management of real estate and to impose or extinguish restrictions on real estate. (C) To compromise any claim or controversy and to abandon any property which is of little or no value. (D) To invest in all forms of property, including stocks, common trust funds and mortgage investment funds, without restriction to investments authorized for Pennsylvania fiduciaries, as are deemed proper, without regard to any principle of diversification, risk or productivity. (E) To exercise any option, right or privilege granted in insurance policies or in other investments. (F) To exercise any election or privilege given by the Federal and other tax laws, including, but not necessarily being limited to, personal income, gift and estate or inheritance tax laws. (G) To make distributions to my herein named beneficiaries in cash or in kind or partly in each. ' l (H) To borrow money from themselves or others in order to pay debts, taxes, or estate or trust administration expenses, to protect or improve any property held under my will, and for investment purposes. 2 (I) To select a mode of payment under any qualified retirement plan (pension plan, profit sharing plan, employee stock ownership plan, or any other type of qualified plan) to the extent provided for by the plan or the law. FIFTH: I nominate and appoint DAVID P. YANDRICH, Executor, of this, my Last Will and Testament. I direct that my Executor or his successor shall not be required to post security or a bond for the performance of their duties in any jurisdiction. IN WITNESS WHEREOF~i, I have hereunto set my hand and seal to this, my Last Will and Testament, this l day of September, p ti ct/I~~~ ~ (SEAL) PETER Y RIC Signed, sealed, published and declared by the above-named Testator as and for his Last Will and Testament in our presence, who, at his request, in his presence and in the presence of each other, have hereunto subscribed our names as attesting witnesses. 1 ~~?n~ ~ ~ i2~2a~~G,f~ Address (Zv SY ame Address ~ ~ ~ , ~l r~ Name r 3 LAST WILL AND TESTAMENT i OF PETER YANDRIC I, PETER YANDRIC, of Park Place, Mechanicsburg, (Monroe Township) Cumberland County, Pennsylvania, make, publish and declare this as and for my Last Will and Testament, hereby revolting all other Wills and Codicils heretofore made by me. FIRST: I direct that all inheritance, .estate, transfer, succession and death taxes, as well as my just debts and funeral expenses, of any kind whatsoever, which may be payable by reason of my death, shall be paid out of the principal of my estate as the; same can conveniently be done. SECOND: I give, devise and bequeath all the rest, residue and remainder of my estate of whatever nature and wherever situate, including any property over which I hold power of appointment and together with any insurance policies thereon, as follows: a. Twenty-five percent thereof unto the AMERICAN RED ` ~ CROSS OF THE SUSQUEHANNA VALLEY, North Sixth Street, P.O. Box 5 Harrisburg, Pennsylvania, fox all lawful purposes; and b. Twenty-five percent thereof unto. the SALVATION ~ ARMY OF CENTRAL PENNSYLVANIA., Green Street, Harris- ~ burg, Pennsylvania, for all lawful purposes; and ~ c. Twenty-five percent thereof unto the HOSPICE OF CENTRAL PENNSYLVANIA, South Enola Drive, P.O. Box Enola, Pennsylvania, for all lawful purposes; and d. Twenty-five percent thereof unto my niece, NORMA J. DIEFFENBACH, of Steelton, Pennsylvania, provided that should NORMA J. DIEFFENBACH predecease me, I give and bequeath her share as provided for herein unto her daughter, JOSEPHINE M. DIEFFENBACH, of Steelton, Pennsylvania. THIRD: In addition to all powers .granted to them by law and by other provisions of this Will, I give the fiduciaries acting hereunder the following powers, applicable to all property, exercisable without court approval and effective until actual distribution of all. property: (A) To sell at public or private sale, or to lease, for any period of time, any real or personal property and to give options for sales, exchanges or leases, for such prices and upon such terms (including credit., with or without security) or conditions as are deemed proper. This includes the power to give legally sufficient instruments for transfer of the property and to receive the proceeds of any disposition. ' (B) To partition, subdivide, or improve real estate and to enter into agreements. concerning the partition, subdivision, improvement, zoning or management of real estate and to impose or extinguish restric- ~ tions on real estate. . ~ 2 (C) To compromise any claim or controversy and to abandon any property which is of little or no value. (D) To invest in all forms of property, including stocks, common trust funds and mortgage investment funds, without restriction to investments authorized for Pennsylvania fiduciaries, as are deemed t proper, without regard to any principle of diversification, risk or pro- ductivity. (E) To exercise any option, right or privilege granted in insurance policies or in other investments. (F) To exercise any election or privilege given by the Federal and othex tax laws, including, but not necessarily being limited to, per- sonal income, gift and estate or inheritance tax laws. (G) To make distributions to my herein named beneficiaries in cash or in kind or partly in each. (H) To borrow money from themselves or others in order to pay debts, taxes, or estate ox trust administration expenses, to protect or ~ ' improve any property held under my will, and for investment purposes. (I) To select a mode of payment under any qualified retire- ment plan (pension plan, profit sharing plan, employee stock ownership plan, or any other type of qualified plan) to the extent the plan or the law. ~ FOURTH: I nominate and appoint NORMA J. , DIEFFENBACH as Executrix, of this, my Last Will and Testament. In ~ 3 the event that NORMA J. DIEFFENBACH is unable or unwilling to serve as my Executrix, I nominate and appoint JOSEPHINE M. DIEFFENBACH, as my Executrix. I direct that my Executrix and her successors, shall not be required to post security or a bond for the performance of their duties in any jurisdiction. 1 IN WITNESS WHEREOF, I have hereunto set my hand and seal to this, my Last Will and Testament, this ~ ~ day of January, ~ I ~~~L (SEAL) PETER YANDRIC Signed, sealed, published and declared by the above-named Testator as and for his Last Will and Testament in our presence, who, at his request, in his presence and in the presence of each other, have here- unto subscribed-our names as attesting witnesses. ~c'~nc~ C~~ ;d - l Address ' Name Ad ess ~ ?c~s.~ e ~ 4 LAST WILL AND TESTAMENT OF PETER YANDRIC I, PETER YANDRIC, single man, currently of Pazk Place, Mechanicsburg, Monroe Township, Cumberland County, Pennsylvania, being of sound and disposing mind, memory and understanding, do make, publish and declaze this my Last Will and Testament, hereby revoking and making void any and all prior Wills by me at any time heretofore made. ~ t I direct the payment of all my just debts and funeral expenses as soon after my decease as the same can conveniently be done. I duect my Executor to sell all of my property, real, personal, and mixed, whatsoever and wheresoever situate, at public or private sales, or at a combination of both, as he deems most fitting in his sole and absolute discretion. The proceeds derived from such sale or sales, as the case may be, shall then first be applied to pay my debts and the costs of the settlement of my Estate, administrative expenses, fees, commissions, and the like. FOR PURPOSES OF CLARIFICATION AND EMPHASIS: I make it known hereby that I am also directing my Executor to pay all death taxes due on any specific gift or residuary shaze in my estate before division and distribution among my individual and charitable beneficiazies. After the payment of the above, I give, devise and bequeath the then remaining balance as follows: A) To my loyal and trusted friend and helper, BEULAH ATKINSON, currently of West Trindle Road, Mechanicsburg, Monroe Township, Cumberland County, Pennsylvania, the sum of five thousand and No/100ths dollazs. In the event she predeceases me, this gift shall lapse and shall be equally divided among the four chazities named hereinbelow. The then remaining balance is to be divided into lour equal shares and distributed among: B) HOSPICE OF CENTRAL PENNSYLVANIA, currently of PO Box Enola, Cumberland County, Pennsylvania. C) AMERICAN RED CROSS, PENNSYLVANIA CAPITAL REGION CHAPTER, currently of North Sixth Street, Hamsburg, Dauphin County, Pennsylvania. D) SALVATION ARMY, CITADEL OFFICE, currently of Green Street, Harrisburg, Dauphin County, Pennsylvania. 1 E) AIDAN SHEELY, son of ANDREW C. SHEELY, ESQ. In the event he is under age eighteen yeazs at the time of my death and the distribution of my Estate, I nominate, constitute, and appoint his parents, the said ANDREW C. SHEELY, and his wife, KATHLEEN A. SHEELY, as guazdians of his said share. In the event he has predeceased me, then to his said pazents, by the Entireties. In the event they have both also predeceased me, then this share shall lapse and shall be equally divided among the four charities named hereinabove. 1 I nominate, constitute and appoint ANDREW C. SHEELY, ESQ., to be the Executor of this my Last Mill aril Testament. In the event that he is unable or unwilling to act as Executor, I appoint KATHLEEN A. SHEELY, to be the Executrix in his' place and stead. In the event that she is unable or unwilling to act as Executrix, I appoint my niece, NORMA J. DIEFFEN$ACH, to so serve as the Executrix in her place and stead. I further direct that they shall not be required to file bond or other security in the Office of the Register of Wills for the purpose of administering my Estate. IN WITNESS WHEREOF, I have hereunto set my hand and seal this / day of ~1une , A.D. s~ ,PGfzr- ~ ndr~ ~ (SEAL) PETER YANDRIC Signed, sealed, published and declared by the above-named PETER YANDRIC, as and for his Last Will and Testament, in the presence of us, who at his request and in his presence, and in the presence of each other, have hereunto subscribed our names as witnesses. S~ (,y1QS, C ~'!i ~~G~a,~s !~l ~'~ielle ~ ?u ~,'~k z LAST WILL AND TESTAMENT OF PETER YANDRIC a I, PETER YANDRIC, of Park Place, Mechanicsburg, (Monroe Township), Cumberland County, Pennsylvania, make, publish and declare this as and for my Last Will and Testament, hereby revolting all other Wills and Codicils heretofore made by me. FIRST: I direct that all inheritance, estate, transfer, succession and death taxes, as well as my just debts and funeral expenses, of any kind whatsoever, which maybe payable by reason of my death; shall be paid out of the principal of my estate as the same can- conveniently be done. SECOND: I give, devise and bequeath all the rest, residue ~ and remainder of my estate of whatever nature and wherever situate, including any property over which I hold power of appointment and together with any insurance policies thereon, to my nephew, DAVID P. YANDRICH, of Candlewyclce Drive, Middletown, Dauphin County, Pennsylvania, provided that should DAVID P. YANDRICH predecease me, I give, devise and bequeath his share unto his issue, per stirpes. THIRD: In addition to all powers granted to them by law and by other provisions of this Will, I give the fiduciaries acting hereunder the following powers, applicable to all property, exercisable without coLtrt approval and effective until actual distribution of all property: (A) To sell at public or private sale, or to lease, for any period of time, any real or personal property and to give options for sales, exchanges or leases, for such prices and upon such terms (including credit, with or without security) or conditions as are deemed proper. This includes the power to give legally sufficient instruments for transfer of the property and to receive the proceeds of any disposition. (B) To partition, subdivide, or improve real estate and to enter into agreements concerning the partition, subdivision, improvement, zoning or management of real estate and to impose or extinguish restric- tions on real estate. (C) To compromise any claim or controversy and to abandon any property which is of little or no value. (D) To invest in all forms of property, including stocks, common trust funds and mortgage investment funds, without restriction to investments authorized for Pennsylvania fiduciaries, as are deemed proper, without regard to any principle of diversification, risk or pro- . ductivity. (E) To exercise any option, right or privilege granted in ~ insurance policies or in other investments. (F) To exercise any election or privilege given by the Federal and other tax laws, including, but not necessarily being limited to, per- q> sonal income, gift and estate or inheritance tax laws. (G) To make distributions to my herein named beneficiaries 2 in cash or in kind or partly in eacll. (H) To borrow money from themselves or others in order to pay debts, taxes, or estate or trust administration expenses, to pxotect or improve any property held under my will, and for investment purposes. ' (I) To select a mode of payment under any qualified retire- ment plan (pension plan, profit sharing plan, employee stock ownership plan, or any other type of qualified plan) to the extent the plan or the law. FOURTH: I nominate and appoint DAVID P. YANDRICH, Executor, of this, my Last Will and Testament. I direct that my Executor and his successors, shall not be required to post security or a bond for the performance of their duties in any jurisdiction. IN WITNESS WHEREOF, I have hereunto set my hand and seal to this, my Last Will and Testament, this day of April, (SEAL) PETER Y DRIC Signed, sealed, published and declared by the above-named Testator as and for his Last Will and Testament in our presence, who, at his request, in his presence and in the presence of each other, have here- unto subscribed our names as attesting witnesses. Address Name ~~,,nnYY 9y~ '~r ~ ~ - e i~IISGI,~tZ ~ 17~SS ..J ~ Address Name 3 KOPE ASSOCIATES, LLC BY: HILARY P. VESELL, ESQUIRE ATTORNEY ID ST. JOHNS CHURCH ROAD, SUITE ? CAMP HILL, PA IN RE: ESTATE OF : IN THE COURT OF COMMON PLEAS OF PETER YANDRIC, :CUMBERLAND COUNTY, PENNSYLVANIA DECEASED :ORPHANS COURT DIVISION NO. CERTIFICATE OF SERVICE I, Hilary P. Vesell, Esquire, hereby certify that on March / , I served a copy of the foregoing Answer to Petition by first class, United States mail to the following: Andrew C. Sheely, Esquire S. Market Street P.O. Box Mechanicsburg, PA Charles E. Shields, III, Esquire Attorney at Law 6 Clouser Road Mechanicsburg, PA Hilary P. Ves ,Esquire I D# St. Joh s Church Road, Ste. Camp Hill, PA KOPE & ASSOCIATES, LLC BY: HILARY P. VESELL, ESQUIRE ATTORNEY ID ST. JOHNS CHURCH ROAD, SUITE CAMP HILL, PA fi IN RE: ESTATE OF : IN THE COURT OF COMMON PLEAS OF PETER YANDRIC, :CUMBERLAND COUNTY, PENNSYLVANIA DECEASED :ORPHANS COURT DIVISION NO. NOTICE TO DEFEND AND CLAIM RIGHTS YOU HAVE BEEN SUED IN COURT. If you wish to defend against the claims set forth in the following pages, you must take action within. twenty days after this New Matter and Notice are served, by entering a written appearance personally or by attorney and filing in writing with the Court your defenses or objections to the claims set forth against you. You are warned that if you fail to do so the case may proceed without you and a judgment may be entered against you by the Court without further notice for any money claimed in the New Matter or for any other claim or relief requested by the Respondent. You may lose money or property or other rights important to you. YOU SHOULD TAKE THIS PAPER TO YOUR LAWYER AT ONCE. IF YOU DO NOT HAVE A LAWYER OR CANNOT AFFORD ONE, GO TO OR TELEPHONE THE OFFICE SET FORTH BELOW TO FIND OUT WHERE YOU CAN GET LEGAL HELP. CUMBERLAND COUNTY BAR ASSOCIATION SOUTH BEDFORD STREET CARLISLE, PA AVISO USTED HA SIDO DEMANDADO/A EN CORTE. Si usted desea defenderse de las demandas que se presentan mas adelante en las siguientes paginas, debe tomar accion dentro de los proximos veinte dias despues de la notification de esta Demanda y Aviso radicando personalmente o por medio de un abogado una comparecencia escrita y radicando en la Corte por escrito sus defensas de, y objecciones a, las demandas presentadas aqui en contra suya. Se la advierte de que si usted falla de tomar accion como se describe anteriormente, el caso puede proceder sin usted y un fallo por cualquier suma de dinero reclamada en la demanda o cualquier otra reclamation o remedio solicitado por el demandante puede ser dictado en contra suya por la Corte sin mas aviso adicional. Usted puede perder dinero o propiedad u otros derechos importantes para usted. USTED DEBE LLEVAR ESTE DOCUMENTO A SU ABOGADO INMEDIATAMENTE. SI USTED NO TIENE UN ABOGADO O NO PUEDE PAGARLE A UNO, LLAME O VAYA A LA SIGUIENTE OFICINA PARA AVERIGUAR DONDE PUEDE ENCONTRAR ASISTENCIA LEGAL. CUMBERLAND COUNTY BAR ASSOCIATION SOUTH BEDFORD STREET CARLISLE, PA TELEFONO: AMERICAN WITH DISABILITIES ACT OF The Court of Common Pleas of Cumberland .County is required by law to comply with the American with Disabilities Act of For more information about accessible facilities and reasonable accommodations available for disabled individuals having business before the Court, please contact the Court of Common Pleas of York County. All arrangements must be made at least hours prior to any hearing or business before the Court. You must attend the scheduled conference of hearing.