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IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY,
PENNSYLVANIA
ORPHANS COURT DIVISION -
IN RE:
NO. 21-11-1051
ESTATE OF HELEN LOUISE MANN
Deceased
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ANSWER TO PETITION TO SHOW CAUSE
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AND NOW, comes Holly L. Ritchey, ("Respondent'), by and through her attorney,
Aaron C. Jackson and the law firm of Tucker Arensberg, P.C., and files the within ANSWER TO
PETITION TO SHOW CAUSE WHY ADMINISTRATOR SHOULD NOT BE APPOINTED filed by
Gregory E. Mann and states as follows:
1. Admitted.
2. Admitted.
3. Admitted.
4. Respondent is without information as to what Petitioner knew about the existence
or non existence of a will at the time of filing of the petition.
5. It is specifically denied that Respondent has refused to provide information
regarding the existence of a will. By way of further answer Respondent had discussions with
Petitioner related to this subject.
6. Admitted in part and denied in part. While Petitioner did inform Respondent of
his willingness to help out with their parents affairs Petitioner did not inform Respondent of his
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willingness to serve as executor or administrator and therefore it is specifically denied that
Respondent opposed such action.
7. Admit in part and denied in part. As further explanation Respondent believes
there to be assets of the estate. Respondent denies that such assets are significant until further
investigation can be made.
8. Admitted with further explanation. Respondent believes there to be assets of real
property; bank accounts; household possession and insurance in the estate as is consistent
with most estates.
9. Specifically denied that Respondent has flagrantly disregarded her fiduciary duty
to the estate until proof to the contrary is provided.
10. Admitted in part and denied in part. Admitted in part that if Respondent was
named as executor then she should have fulfilled the terms of the will. Denied upon the basis
that Respondent is not named as sole executor in the purported will.
11. Admitted with further explanation that Respondent was unaware of the existence
of a will at the time of the filing of the petition but Respondent believes that a will has been
found and has communicated this information to the Petitioner through counsel.
12. Denied. With further explanation that Respondent believes that a will has been
found and therefore denies that Petitioner should be appointed as sole administrator of the
estate under the Pennsylvania laws of intestacy.
13. Denied in part and admitted in part. Respondent is without sufficient information
to determine whether Petitioner was aware of their brother's position regarding this matter at the
time of filing of the petition. With further explanation, Respondent is aware of her brother Bany
Mann's position that the estate be administered according to the terms of the purported will and
all three persons named serve as co-executors for the estate.
Wherefore, Respondent requests that the court order that the purported will be probated
and the terms of the will be enforced.
Respectfully submitted,
TUCKER ARENSBERG, P.C.
By:
Aaron C. Jackson, squi e
Pa. I.D. No. 200490
2 Lemoyne Drive, Suite 200
Lemoyne, PA 17043
(717) 234-4121
Date: ( Counsel for the Respondent
Holly L. Ritchey
.,
VERIFICATION
I, Holly L. Ritchey, verify that the statements made in this Answer are true and correct to
the best of my knowledge, information and belief. I understand that false statements herein are
made subject to the penalties of 18 Pa.C.S.A. Section 4904 relating to unswom falsification to
authorities.
Date:
Holly L. ' c ey, R s ndent
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CERTIFICATE OF SERVICE
AND NOW, this ~ day of November 2011, I Aaron C Jackson, for the law firm of
Tucker Arensberg, P.C., attorneys for the Respondent, Holly L. Ritchey, hereby certify that I
have this day served the within document upon the following, in the manner indicated below:
Via First Class Mail addressed to:
Barry A. Mann
P O Box 63894
Philadelphia, PA 19147
Gregory Elliott Mann
C/O Craig A. Diehl, Esquire
Attorney for the Petitioner
3464 Trindle Road
Camp Hill, PA 17011
Aaron C. Jackson