HomeMy WebLinkAbout03-05-12r
IN RE:
THE ZACHARY CRISWELL TRUST
Established under the
Last Will and Testament of
IN THE COURT OF COMMON PLEAS
OF THE 9T"JUDICIAL DISTRICT
OF PENNSYLVANIA
CUMBERLAND COUNTY
EDWARD N. NAYLOR, Deceased NO. 21-09-0055 ~
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MOTION TO `~ _~~
MAKE RULE TO SHOW CAUSE ABSOLUTES
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AND NOW COMES, Steven C. Daly, Trustee of the Zachary Criswell Trust and
Executor of the Estate of Edward N. Naylor, Deceased, by his attorney, William R. Bunt,
Esq., and respectfully moves this Court to make absolute the rule to show cause which
was issued in the above-captioned matter on February 2, 2012, and in support states
the following:
1. That Steven C. Daly, Trustee of the Zachary Criswell Trust and Executor of the
Estate of Edward N. Naylor, Deceased filed a Petition for Appointment of a Successor
Trustee on January 30, 2012.
2. On February 2, 2012, Your Honorable Court issued a rule on all interested
WILLIAM R. BUNT
CHRYSTAL L. PROSSER
ATTORNEYS AT LAW
109 S. Carlisle Street
New Bloomfield, Pa.
17068
parties to show cause why Juniata Valley Bank should not be named as Successor
Trustee, returnable within twenty (20) days of the date of said Order of Court.
3. That to the best of Movant's knowledge, information and belief, none of
the interested parties have responded to said Rule to Show Cause.
Tel. (717) 582-8195
FAX (717) 582-7521
WHEREFORE, Movant, Steven C. Daly, Trustee of the Zachary Criswell Trust
and Executor of the Estate of Edward N. Naylor, Deceased, respectfully requests that
this Court make the rule to show cause absolute and grant the petition to appoint
Juniata Valley Bank as Successor Trustee of the Zachary Criswell Trust; to discharge
Steven C. Daly from his office as Trustee of the Zachary Criswell Trust; to release the
said Steven C. Daly from future liability and to direct the said Steven C. Daly to
immediately transfer and delivery the assets of the Zachary Criswell Trust unto Juniata
Valley Bank.
RESPECTFULLY SUBMITTED,
William R. Bunt, Esq.
Supreme Court ID # 21529
109 S. Carlisle Street
P.O. Box 336
New Bloomfield, Pennsylvania 17068
(717) 582-8195
Attorney for Estate of Edward N. Naylor
WILLIAM R. BUNT
CHRYSTAL L. PROSSER
ATTORNEYS AT LAW
109 S. Carlisle Street
New Bloomfield, Pa.
17068
Tel. (717) 582-8195
FAX (717) 582-7521
DISTRIBUTION LIST
William R. Bunt, Esq.
P.O. Box 336
New Bloomfield, PA 17068
Attorney for Estate of Edward N. Naylor
Zachary Criswell
c/o Elmer &Shawna Criswell
P.O. Box 68
Duncannon,PA 17020
Trust Beneficiary
Joshua Criswell
c/o Elmer &Shawna Criswell
P.O. Box 68
Duncannon,PA 17020
Contingent Beneficiary
Juniata Valley Bank
Trust Services Office
Juniata Valley Bank Financial Services Building
1762 Butcher Shop Road
Mifflintown, PA 17059
Proposed Successor Trustee
WILLIAM R. BUNT
CHRYSTAL L. PROSSER
ATTORNEYS AT LAW
109 S. Carlisle Street
New Bloomfield, Pa.
17068
Tel. (717)582-8195
FAX (717) 582-7521