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HomeMy WebLinkAbout03-05-12 (3) IN RE; THE JOSHUA CRISWELL TRUST Established under the Last Will and Testament of EDWARD N. NAYLOR, Deceased IN THE COURT OF COMMON PLEAS OF THE 9T"JUDICIAL DISTRICT OF PENNSYLVANIA CUMBERLAND COUNTY -..:r ' NO. 21-09-0055 "a ~ .T~ ~~ v~ -~ - c~ . ~~s ; ~' ; r, ~ a ~~ r MOTION TO °'' MAKE RULE TO SHOW CAUSE ABSOLUTE AND NOW COMES, Steven C. Daly, Trustee of the Joshua 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 Joshua 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 Tel. (717)582-8195 FAX (717) 582-7521 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. WHEREFORE, Movant, Steven C. Daly, Trustee of the Joshua 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 Joshua Criswell Trust; to discharge Steven C. Daly from his office as Trustee of the Joshua 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 Joshua Criswell Trust unto Juniata Valley Bank. RESPECTFULLYJSUBMITTED, 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 Joshua Criswell c/o Elmer &Shawna Criswell P.O. Box 68 Duncannon, PA 17020 Trust Beneficiary Zachary 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 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