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IN TIf1~: C'OUI~T OF COMMON PLEAS OF CtJMBF,RLAND C~;-UNTY, PENNSY"l,Vp~NIA
ORPHANS' LOURT DIVISION
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In re:
F,STA"1 1 ()l~~ (~IORGE R. LAKE
Deceased.
No. 2009-00717
PETITION FOR COURT ORllER 1'O
REVOKE LETTEKS TESTAMENTARY
AND APPOINT SUBSTITUTE ADMINISTRATRIX
~,'~~ D NOW, comes the Petitioner, Marie Lake, by and through her undersigned coumsel,
Barley Sn~~der I.LC, and respectfully represents as follows:
1 . Petitioner is Marie Lake to whom betters Testamentary were granted ~~n August
3, 2009. ha~~i~lg been named executrix in the Last Will and Testament of decedent dated October
20, 2oox.
2. Petitioner is the surviving spouse of decedent, who died testate on J~ine 1 ~4, 2009.
~"~t the time of decedent's death all of his assets were ,jointly owned by lhim and his
wife, Petitioner herein.
~. ~"~ll decedent's debts have been paid by Petitioner out of a jointly owned bank
account.
~;
.;~`~
Petitioner believes and therefore avers that neither an inventory nor an accounting
will be required to be tiled for this estate inasmuch as all assets were jointly owned by l~ner and
decedent.
6. Iz1 addition, Petitioner has obtained an extension of tune from the Penn~~~.ylvania
Department of Revenue within which to file a Pennsylvania inheritance tax return.
7. One of decedent's assets was a certificate of deposit issued on .Tune ?>, 200;x, by
Centric Bank, I~~.A., to Petitioner and decedent as joint owners with right of sur~~ivc-rship.
On March 30, 2009, a few months prior to his death, decedent withdrew the funds
from the certificate of deposit but failed to provide any of the proceeds to Petitioner. 1Zather, on
information and belief; decedent transferred the entire proceeds to an unrelated third party.
~). jiecause of the conversion of these funds, Petitioner has instituted shit to recover
her shard ol~the proceeds, and suit is presently pending in the Court of Common Pleas o:f
Cumberland County, Pennsylvania to No. 09-6276.
l U. Decedent's estate has been named a party to the liitigation, and therefo~r~c Petitioner
desires that the Letters Testamentary issued to her on August ~, 200'x, be revoked and that
decedent's cousin Suzanne I_,ake, of 1984 Camp Swatara Road, lvlyerstown, Pennsyl~~~a~~lia .17067,
be appointed in her stead.
l l . Petitioner believes and therefore avers that Suzanne Lake is ready and able to
serve in t he capacity as administratrix of the estate, and in addition., Suzanne Lake has consented
to serve. .~~~c~ (_'~:~nsent attached.
V~~'1 IFRF FORE, Petitioner, Marie Lake, respectfully request your I-Ionorable Court to
revoke the Letters Testamentary issued on August 3, 2009, and grant Letters of Administration to
Suzanne Lake.
Respectfully submitted.
BARLI~Y SN~'DER I,
~~
By ~ - ----------
Paul W. in
100 Fast Market Street
P.O. Box 15011
York, PA 17405-%012
717-846-8888
hax: 717-843-8492
E-Mail: pminni~~h<<r>barley.com
PA 74453
Attorneys for Petitioner
3160957
VERIFICATION
I, Marie Lake, the within Petitioner, hereby verify that th.e facts set forth in the fi~regoing
Petition are tr~~~e and correct to the best of my knowledge, information and belief. I u~nderst:and
that false statements herein are made subject to the penalties of l 8 Pa.C.S.A. ~490~ relating to
unsworn falsif~csation to authorities.
Dated:
.. ,-..
~ °> >
~-
--- ~~t.- i ~~_..r~ _ ~ ~( ~~
Mar ~ -- ---~==- --~t~~ _---~.. _~
le Lake
CONSENT
I. Suzanne Lake, hereby verify that I am over 18 years of age and do consent to my
appointment as Administratrix of the Estate of George R. Lake.
',,_~
~ f; ~ ., r
Dated.- --- - 1 ~ i ~ ~ ~. . ~ ~• ~.-r~ LC---~---- ~-
Suzanne ake
I ~ ' ~
100 East .tilarkct `.;tre~'t
P.O. I~ox 1;01
York, P,~ 1740-;~11
"Iel 717.~`~4(,.8~~t~ F ~~ ~~~ I -.~~ ~ ~.~49?
ww~ti~.l~arle~~.cr7m
March l 8, 201
Clerk oI~ the Orphans' Court
Courthouse
One Courthouse Square
Carlisle. I';1 1 ?0I3-3387
Iz ~ : h;state of George R. Lake, Deceased
No. 2009-00717
Dear S i r~.:
Paul V1`. 1~1iu~i~ichi, Esquire
f~ireet Dial Numbcr~ ? 17-K52-497(1
I:-snail: pminnich~u;barlev.con~~
On bellal f of Marie Lake we enclose a petition for court order to revoke letters
testamentary and to appoint a substitute administratri~. Would you please file this petition of
record and forward it to the Court for consideration. Our check in payment of the filing .tee of
$15.00 is enclosed.
I'lcase return a docketed copy of the petition to me in theenvelope enclosed. [ am also
providing envelopes for the return of the Order.
l~l~ank y~~~u for your help and attention to this matter. Please call ifyou have anw~
questions. .
Sincerely,
au innich
PWM/rnli»:~i~,i~~~~ i.rxx,
cc: ti l ~. Marie I.ahe
~1s. Suzanne Lake
Enclosure
fork • Lancaster • Reading • 13er"~~°n • Hanrner