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ESTATE OF JEFFREY O. SEES
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IN THE COURT OF COMMON PLEAS OF
CUMBERLAND COUNTY, PENNSYLVANIA
ORPHAN'S COURT DIVISION
~`~ PETITION FOR GRANT OF LETTERS
The petition of BONITA S. HEISEY, Co-Administrator and beneficiary of the Estate of
Jei~rey O. Sees, by and through her attorneys, Irwin & McKnight, P.C., respextfully represents as
follows:
1. Jeffrey O. Sees ("Decedent") died February 16, 2010, and Letters of
Administration were granted on or about March 4, 2010, to the Decedent's sister, .Bonita S.
Heisey, Petitioner herein, and to the Decedent's half-brother, Stephen P. Brudowsky.
2. Decedent was also survived by two half-sisters, Patti M. Buxton and Kimberly D.
Schardt, who along with the Co-Administrators and the Decedent were the children of Marian L.
Brudowsky.
3. Marian L. Brudowsky, passed away on July 24, 2009, but her safe deposit box
located at a branch of PNC Bank was not opened until Apri15, 2011.
4. As part of the inventory of the safe deposit of Marian L. Brudowsky on April 5,
2011, an original Last Will and Testament for her son, the Decedent herein, was located.
5. The original Last Will and Testament attached hereto is dated July 8, 2002, was
prepared by the Honorable Kathy A. Morrow of New Bloomfield, Pennsylvania, and is
witnessed by Glenda G. Dillman and Fred E. Morrow, the legal secretary and father-in-law of
Attorney Morrow.
6. Under Paragraph 5 of the original Last Will and Testament, Petitioner is
nonunated and appointed by the Decedent to be the Executrix of his Last Will and Testament.
7. Under 20 Pa.C.S.A. § 3133(a), "A will may be offered for probate at any time."
8. When letters of administration have been issued and a Will is subsequently
discovered, the Will may be offered directly to the Register of wills who "may amend or revoke
letters testamentary or of administration granted by him not in conformity with the provisions of
a will admitted to probate" 20 Pa.C.S.A. § 3181(b). See also Law of Wills in Pennsylvania, 2"d
Edition, § 9.20.
9. The Decedent's Co-Administrators have not yet completed distribution and
administration of Decedent's estate.
10. Petitioner therefore requests that the subsequently discovered Last Will and
Testament of the Decedent be admitted to probate, and that the previously issued Letters of
Administration be revoked.
11. Petitioner further requests that she be appointed Executrix of the Dec~ent's
estate.
WHEREFORE, Petitioner, Bonita S. Heisey, requests that the subsequently discovered
Last Will and Testament of Jeffrey O. Sees dated July 8, 2002, be admitted to probate, that
Letters Testamentary be issued to Petitioner, and that the previously issues Letters of
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Administration to Bonita S. Heisey and Stephen P. Brudowsky be revoked, along with such other
and further relief as may be deemed necessary.
Respectfully Submitted,
IRWIN & McI~TIGHT, P.C.
By:
Dou G er, ~ squire
Supreme ourt ID No. 83776
West Pomfret Professional Building
60 West Pomfret Street
Carlisle, Pennsylvania 17013
(717) 249-2353
Dated: February 1, 2012 Attorney for Petitioner
VERIFICATION
The foregoing document is based upon information which has been gathered by my
counsel and myself in the preparation of this action. I have read the statements made in this
document and they aze true and correct to the best of my knowledge, information and belief. I
understand that false statements herein made are subject to the penalties of 18 Pa.C.S.A. Section
4904, relating to unsworn falsification to authorities.
BONITA S. HEISEY
Date: ~ ~ ~O~
ESTATE OF JEFFREY O. SEES : IN THE COURT OF COMMON PLEAS OF
:CUMBERLAND COUNTY, PENNSYLVANIA
ORPHAN`S COURT DIVISION
. NO.
CERTIFICATE OF SERVICE
I, Douglas G. Miller, Esquire, do hereby certify that I have served a true and correct copy
of the foregoing document upon the persons indicated below both via facsimile and by first class
United States mail, postage paid in Carlisle, Pennsylvania 17013, on the date set forth below:
Scott W. Morrison
Center Square, PO Box 232
New Bloomfield, PA 17068
Date: February 1, 2012 IRWIN & McI~iIGHT, P.C.
Douglas G.~Mitler, Enquire
Supreme Court I.D. No. 83776
West Pomfret Professional Building
60 West Pomfret Street
Carlisle, Pennsylvania 17013-3222
(717) 249-2353
Attorney for Petitioner