HomeMy WebLinkAbout10-17-11 (2)IN RE:
ESTATE OF GEORGE S. CORBIN, II
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IN THE REGISTER OF WILLS ~~ c.~ =~~ =~ ; ~ ~.=_ _~
CUMBERLAND COUNTY, PENl'yAN~~ -
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PETITION FOR CITATION TO SHOW CAUSE WHY PETITIONER SHOULD NOT
BE APPOINTED ADMINISTRATRIX
And now comes the Petitioner, Mari D. Jones, by and through her attorney, Bridget M.
Whitley, Esquire, SkarlatosZonarich LLC, to file this Petition for Citation to Show Cause why
Petitioner should not be Appointed Administratrix of the Estate of George S. Corbin, II, and, in
support thereof, avers as follows:
1. George S. Corbin, II died intestate on March 9, 2011, a resident of Cumberland
County, Pennsylvania.
2. Decedent is survived by the following heirs at law:
a. Mari D. Jones, claiming entitlement to the estate as the spouse of the
decedent, pursuant to a common law marriage entered into prior to
September 17, 2003, residing at 173 E. Penn Street, Carlisle, PA 17013;
b. Karen Reid, his sister, residing at 500 E. Prospect Street, Apt.. #1, York, PA
17403;
c. Jerry Corbin, his brother, residing at 3831 Wilcox Blvd., Chattanooga, TN;
d. Vivian Coleman, his half-sister, residing at 521 S. West St., Carlisle, PA;
e. Jack Corbin, his brother, currently incarcerated at SCI Huntingdon, 1100
Pike Street, Huntingdon, PA; and
£ David Corbin, his brother, who has no fixed address.
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3. Karen Reid, Jerry Corbin, Vivian Coleman, Jack Corbin and David Corbin, the
brothers and sisters of the decedent have not made application to this Court for letters of
administration in said estate.
4. Decedent had no significant assets at the time of his death. However, Petitioner
believes, and therefore avers, that a cause of action exists in favor of the Estate of George S.
Corbin, II and his next of kin, for personal injuries arising out of the Decedent's care and
treatment at the nursing home where he resided at the time of his death.
5. Simultaneous with the filing of this Petition, Petitioner's attorney will be filing a
petition asking for the appointment of John R. Zonarich, Esq. as administrator pendente lite in
order to file a writ to toll the statute of limitations on the personal injury claim.
6. It is anticipated that the Register of Wills will grant the requested letters of
administration pendent elite for a limited period of time.
7. Petitioner, Mari D. Jones, is a resident of Cumberland County, Pennsylvania, is
familiar with the pending litigation, and is willing to serve as Administratrix of her putative
common law husband's estate.
WHEREFORE, Petitioner requests that a Citation be issued to each of Karen Reid, Jerry
Corbin, Vivian Coleman, Jack A. Corbin, and David Corbin (mailed to General Delivery, York,
PA) to show cause why Petitioner should not be granted letters of administration.
Respectfully submitted,
Dated: C~Z:~~u-~w `~
SKARLATOSZONARICH LLc
By: ~
Bridget .Whitley, Esq.
Sup. Ct. No. 33580
Skarlatos & Zonarich Building
17 S. Second Street, 6th Floor
Harrisburg, Pennsylvania 17101
(717) 233-1000
Attorneys for Petitioner
VERIFICATION
Pursuant to Pennsylvania Rule of Civil Procedure 1024(c) and subject to the penalties of
18 Pa.C.S.A. Sec. 4904 relating to unsworn falsification to authorities, I, John R Zonarich,
Esquire, declare that I am the attorney for Petitioner Mari D. Jones; that I am authorized to make
this verification on her behalf; and that the facts set forth in the foregoing document are based
upon my own knowledge and information which I believe to be true and correct.
Dated: /D ~7- ~