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Home My WebLink About11-28-11 r~ r~-~ In Re: IN THE COURT OF COMMON PLE~ r: , CUMBERLAND COUNTY, PENNSY~NIA ~_ ~-~ ~ , ~' SEIDEL ~ ; = MATTHEW J r= ~ ~== ~ -- - ' . _ A Minor : ~ ~ ~ ~ n' ~ GJ .7 ' i, `= .~ :ORPHANS' COURT DIVISION ~~ ~; ~ ~ '_ ? _ 1 .~ _- T+ - -~, JOINT PETITION TO DEPOSIT MINOR'S ESTATE INTO A SEQUESTERED INVESTMENT ACCOUNT PURSUANT TO 20 Pa. C.S. § 5103 TO THE HONORABLE, THE JUDGES OF THE SAID COURT: The Joint Petition of Ann M. Seidel (hereinafter referred to as "Mother") and Susan K. Sherk (hereinafter referred to as "Aunt"), by and through their undersigned attorney, respectfully represents: 1. Mother resides at 4003 Glenfinnan Place, Mechanicsburg, Cumberland County, Pennsylvania 17055, and is the mother and natural guardian of Matthew J. Seidel (hereinafter referred to as the "Minor"), age thirteen (13) having been born on June 5, 1998. 2. Aunt resides at 28 Joseph Drive, Boiling Springs, Cumberland County, Pennsylvania 17007 and is the biological sister of Mother and the biological Aunt of the Minor. 3. Mother is the daughter of Gary M. Glasgow (hereinafter referred to as "Decedent"), who died on September 21, 2011, and was a resident of 300 East Meadow Drive, Mechanicsburg, Cumberland County, Pennsylvania. 4. Decedent was the biological grandfather of the Minor. 5. As a result of the death of Decedent, the Minor is entitled, pursuant to the last beneficiary designation executed by Decedent, to one seventh (1/7) of the proceeds of a variable annuity contract issued by Prudential as The Prudential Premier X Series Annuity , bearing contract No. E1055642 (hereinafter referred to as the "Contract") and having a current value of $26,797.04 for the minor's interest. A true and correct copy of a letter from Prudential is attached hereto as Exhibit "A" and incorporated herein by reference. 6. Prudential requires a certified copy of a court order granting guardianship prior to distributing the proceeds of the Contract to the Minor. 7. Petitioners are not aware that the Minor has any other interest in the Estate of Gary M. Glasgow or any other estate or trust. WHEREFORE, Petitioners respectfully request that this Honorable Court authorize the distribution of the proceeds of the Contract due the Minor because of the maturity of the contract at the death of Decedent to Petitioners, without the appointment of a guardian of the Estate of the Minor or the entry of any security, such proceeds, to be deposited into an investment account of their choosing in the name of the Minor, which account shall bear the express restriction that there shall be no withdrawals from the account prior to June 5, 2016, except for payment of state yr federal income taxes or upon Order of the Court. Respectfully submitted, Dated: November z.3 , 2011 RADCLIFF LAW OFFICE, P.C. B : ~ ~ ' ~~ y David H. Radcliff, Esquire Attorney for Petitioners 1011 Mumma Road, Suite 201 Lemoyne, PA 17043 Supreme Court ID No. 25483 Telephone (717) 236-9318 11-22-2011 12:31 THOMAS W RDWAN 7177309010 Ptadelttial Thomas W ROWan 150 Corporate s;:cnter Drive Suite 104 Camp Hill, PA 17011 Dear Mr. Rowan: Thank you far the opportunity to be of setvice tv you. PAGE2 P~de~tial Aaaugipt A $nafnsa or Prodpidal Finangai, inc. P.O. Box 7980 Phlltdeipbia. PA 19178 (800) 5130805 Contract Numbtr: E1055642 November 18, 2011 Utt the above refereaoed contract, three out of seven beneficiaries have outstanding claims to be paid: Julia Seidel Matthew Seidel Katherine Seidel The above 1Lsted beneficiaries are entitled to equal shares of the rr°tnaining death benefit. The death benefit value as of November l7, ZOtI was 5.391.14 Your satisFaction is important to us. If you have questions, please contact your internal wholesaler or our Annuities Service Center at (800) 513-0805. Representatives are available to assist you Moray through 'Thursday between 8 a.m. and 7 p.m., and Friday between 8 a.m. and 6 p.m. Eastern time. 't'hank yon For choosing to do business wfth PrndenHal Annuities. Sincerely. Annuities Service Center Ammutfp areazsued by 7be Prudential Iama~xr Compllpy of An~ejica and P+uco life la~ran[t Company to New York, by Pruco 1,16e lannswce Company of New JeracY} ali lo~aled In Newark. NI, or by Pnideotia! Mnuilux Ufe 1laaaaaea C Shdron, C'C. AgMdli~ re diatribmed by PrudmtW Aanaitles I)iarlb~uora, lac., shdton, C'C. All ane Prudeptial Plntncncl companies and ~ Is solely re:pomble for itx o~vn 0nancia) c7orlditian and arnitractaal obligatiam. L'FR.CCFra 9E009 VERIFICATION I, Ann M. Seidel, verify that I am a Petitioner in the within petition, and that the facts contained therein are true and correct to the best of my knowledge, information and belief, and that this verification is subject to the penalties of 18 Pa.C.S. § 4904, relating to unsworn falsification to authorities. Date: ~ Z ~ ' ~ ~ ~,~ ~'~ 1 ~--r , Ann Seidel VERIFICATION I, Susan K. Sherk, verify that I am a Petitioner in the within petition, and that the facts contained therein are true and correct to the best of my knowledge, information and belief, and that this verification is subject to the penalties of 18 Pa.C.S. § 4904, relating to unsworn falsification to authorities. Date: ~/~ ~,~ Susan K. Sherk In Re: IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA MATTHEW J. SEIDEL A Minor ORPHANS' COURT DIVISION No. CERTIFICATE OF SERVICE I, DAVID H. RADCLIFF, ESQUIRE, hereby certify that on this, the r y of z~ ~ da November, 2011, copies of the foregoing Joint Petition to Deposit Minor's Estate into a Sequestered Deposit Pursuant to 20 Pa.C.5. § 5103 were caused to be served upon the following by first class mail, postage prepaid: Matthew J. Seidel 4003 Glenfinnan Place Mechanicsburg, PA 17055 ~~ e ~~ David H. Radcliff, Es re