HomeMy WebLinkAbout10-17-11 (3)SKARLATOS ZONARICH LLC
Bridget M. Whitley, Esq.
Skarlatos & Zonarich Building
17 South Second St., 6th Floor
Harrisburg, Pennsylvania 17101
(717) 233 - 1000
Email: bmw@skarlatoszonarich.com
Attorneys for Petitioner
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REGISTER OF WILLS OF CUMBERLAND COUNTY, PENNSYLVANIA
ESTATE OF GEORGE S. CORBIN, II, Deceased File Number ~ I - I ~ - I ~~~~ 1
EMERGENCY PETITION FOR GRANT OF
LETTERS OF ADMINISTRATION PENDENTE LITE
Bridget M. Whitley, Esq.. files this Petition for Letters of Administration Pendente lite,
and in support thereof, hereby avers as follows:
1. Petitioner after a proper search has ascertained that the Decedent left no Will and
was 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
f. David Corbin, his brother, who has no fixed address.
2. The Decedent was domiciled at death in Cumberland County, Pennsylvania, with
his last principal residence at 940 Walnut Bottom Rd., Carlisle, PA 17013.
3. The Decedent, then 62 years of age, died on March 9, 2011 at Manor Care
Nursing & Rehab, South Middleton Township, Cumberland County, Pennsylvania.
4. The Petitioner files this Petition for litigation purposes only.
5. The 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.
6. The statute of limitation for the personal injury action will expire on November 1,
2011, and litigation must be initiated prior to that date in order to preserve the rights of the Estate
and the beneficiaries to a potential recovery for damages.
7. Simultaneously with the filing of the instant petition, Mari D. Jones is filing a
Petition for Grant of Letters of Administration and a Petition for Citation to Show Cause Why
Letters Should Not Be Issued (to her) directed to the brothers and sisters of George S. Corbin, II.
8. The sisters and brothers of George S. Corbin, III will have a period of time
following the issuance of a Preliminary Decree awarding the Citation to respond by entering an
appearance.
9. The process as described above will delay the issuance of Letters of
Administration past the time when a law suit must be initiated.
10. It is imperative that Letters of Administration pendente lite be issued without
delay so that litigation can be initiated before the expiration of the statute of limitations, and the
rights of the Estate of George S. Corbin, II can be protected and preserved.
11. John R. Zonarich, Esq. is an attorney with the law firm of SkarlatosZonarich,
LLC, of Harrisburg, Pennsylvania, is familiar with this case and is willing to serve as
Administrator pendente lite until a permanent Administrator can be appointed.
WHEREFORE, Petitioner respectfully requests that Letters of Administration pendente
lite be granted to John R. Zonarich, Esq. in the above estate.
Bridget M. hitley, Esq.
Attorney for the Estate of
George S. Corbin, II
Supreme Court No. 33580
/ ~~f'f' SkarlatosZonarich, LLC
l~ 17 S. 2°d Street, 6th Floor
Harrisburg, PA 17101
Phone: 717-233-1000
VERIFICATION
I, Bridget M. Whitley, Esq. verify and state that:
1. I am the petitioner in the foregoing action.
2. The facts set forth in the foregoing pleading are true and correct to the best of my
knowledge, information, and belief.
3. I understand that false statements herein are made subject to the penalties of 18
Pa.C.S. §4904, relating to falsification to authorities.
Date: ~
. ~~
ridget Whitley, Esq.