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HomeMy WebLinkAbout03-21-12 (2)IN RE ESTATE OF IN THE COURT OF COMMON PLEAS PETER N. KUTULAKIS CUMBERLAND COUNTY, PENNSYLVANIA Register of Wills No.: 1997-00716 NOTICE TO PLEAD To: Jason P. Kutulakis, Esquire Two West High Street Carlisle, PA 17013 You are hereby notified to plead to this Motion for Summary Judgment within thirty (30) days from service hereof. SAIDIS, SULLIVAN & ROGERS -ZI - Z,s~~ De~S E~R~ep~sa, Esquire A rney Id. 80440 26 West High Street Carlisle, PA 17013 (717) 243-6222 Counsel for Respondent Mary D. Kutulakis ~_., . ~~ ~ ~~_. a- . ~Tn .;, x--.- rn r~~ ,-, ~=-: '~ `r~ ~ L 'Tl ~~ IN RE ESTATE OF PETER N. KUTULAKIS IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA Register of Wills No.: 1997-00716 RESPONDENT MARY D. KUTULAKIS MOTION FOR SUMMARY JUDGMENT AND NOW this~~day of March, 2012, comes Respondent Mary D. Kutulakis by and through her attorney and hereby states as follows: 1. Petitioner Jason P. Kutulakis filed a Petition to Open the Estate and set aside the final account distribution of the Estate of Peter N. Kutulakis. 2. The Honorable Joseph H. Kleinfelter directed that Respondent Mary D. Kutulakis file a response to the Petition. 3. Respondent filed her Answer in Opposition to Petition to Open Estate and Set Aside the Final Account and Distribution of the Estate of Peter N. Kut ulakis on June 13, 2011. 4. The Honorable Eugene E. Fike, II, directed that discovery be completed prior to March 16, 2012. 5. Pretrial dispositive motions are due to be filed not later than March 21, 2011. ._, ~ .. >> MOTION FOR SUMMARY JUDGMENT !: ~ ~ ,, - - _ _ 6. Respondent incorporates the foregoing paragraphs as thoug~x.if~ey uD~re "' . fully set forth at length herein. ~~`~',~' ~ T_ ~ -~ . _Z C J --i _ _ _ ;-r7 -~ 1 33 ~,•'~ Q Lt~ _ ~..3 7. Section 3521 of the Decedents, Estates and Fiduciaries Code provides that any party in interest may file a petition to review a decedent's account within five years of the final confirmation. 20 Pa.C.S.A. § 3521. 8. The final account was confirmed in this matter on October 12, 1999. 9. In an effort to circumvent the statute of limitations in this matter, Petitioner has alleged that Respondent engaged in fraud when she signed for a certified return receipt card dated September 3, 1999. Petition at ¶ 54. 10. Petitioner's claim continues by suggesting that Respondent engaged in fraud in failing to deliver the First and Final Accounting that was enclosed with the September 3, 1999, mailing. Id. at ¶ 55. 11. Petitioner's claim also suggests that Respondent concealed the fact that his father died with a will. Id. at ¶ 60. 12. Petitioner's father passed away in 1997 and his Estate was probated at the Cumberland County Register of Wills. 13. Petitioner alleges that he was told by his father that he would leave a will. Id. at ¶ 12. 14. Although it is disputed, Petitioner alleges that he was told by his mother, the Respondent, that his father died without a will. Id. at ¶ 14. 15. Peter N. Kutulakis' holographic will was filed at the Cumberland County Register of Wills and Letters Testamentary were issued on August 27, 1997. See Exhibit A. 16. The Estate file with the will has been available for Petitioner's inspection at the Register of Wills Office since 1997. 17. Accepting the allegations of the Petition as true, despite the apparent disagreement as to the existence of a will, Petitioner did nothing to investigate whether a will was probated for his father's estate. 18. Petitioner did nothing to confirm whether a will existed until almost eleven years after the confirmation of the account and final distribution. 19. The Estate of Peter N. Kutulakis was represented by Attorney Steven J. Schiffman throughout the estate administration process. Id. at 47. 20. The status report stating that the administration of the estate was completed was filed on or about April 28, 2000. 21. On or about April 27, 2000, upon the conclusion of the estate administration process, Attorney Schiffman forwarded to Petitioner a letter advising him that the estate administration had been completed. See affidavit of Attorney Schiffman attached hereto as Exhibit B. 22. The letter was sent to Petitioner's address of 411 Barnstable Rd., Carlisle, Pennsylvania. Id. 23. Petitioner acquired 411 Barnstable Rd., from Respondent by deed dated March 12, 1999. See Exhibit C (This deed was a stipulated exhibit at the hearing concerning Respondent's Petition to Strike Lis Pendens). 24. The April 27th letter was not returned to Attorney Schiffman. Id. 25. It was. not until sometime after March 2010, that Petitioner sought to investigate his father's estate file at the Register of Wills. Petition at ¶¶ 17 - 20. 26. Petitioner obtained a copy of his father's will by reviewing the documents on file at the Cumberland County Register of Wills Office. Id. 27. Petitioner has failed to allege or explain why he waited until 2010 to search the Register of Wills' file. 28. It is not until May of 2011 that Petitioner filed this Petition to Open his father's estate. 29. There are no disputed issues of material fact. 30. A petitioner who alleges fraud in the context of 20 Pa.C.S.A. § 3521 "is not only chargeable with what he knew but also with what he could have discovered by reasonable diligence." In re Thorne's Estate, 344 Pa. 503, 511, 25 A.2d 811, 815-16 (1942). 31. As a matter of law, Petitioner is chargeable for knowledge of the existence of his father's will and estate documents since they could have been discovered with reasonable diligence in the Cumberland County Register of Wills Office. Id. 32. Petitioner has failed to establish fraud under 20 Pa.C.S.A. § 3521 and therefore, he is not able to circumvent the statute of limitations. 33. Petitioner's claim to open the estate is based upon documents that were readily available to him as early as August of 1997 if he had acted diligently in confirming whether his father died with or without a will. 34. Petitioner has also failed to present sufficient evidence to overcome the doctrine of laches as he waited over eleven years to review the documents that were filed by his father's estate at the Register of Wills. See generally Kinter v. Com. Trust Co., 274 Pa. 436, 118 A. 392 (1922). 35. Respondent would be prejudiced in that Petitioner seeks to upset the ownership interest in two parcels of land owned individually by Respondent for more than a decade. Wherefore, it is respectfully suggested that there are no disputed issues of material fact and that the Respondent is entitled to judgment as a matter of law. Should this Honorable Court grant this Motion for Summary Judgment, Petitioner further requests that the lis pendens filed at 2011-4543 in the Cumberland County Prothonotary's Office be stricken with prejudice. Respectfully submitted, SAIDIS, ~ULLIVAN & ROGERS ~- Zl - lru~1., Dean E. Reynosa, Esquire Attorney Id. 80440 26 West High Street Carlisle, PA 17013 (717) 243-6222 Counsel for Respondent Mary D. Kutulakis '. bath of Personal Representative Commonweatttr n3 Pennaylvanla County o4 C~unberland The Potitioner(s) above-nemod swear(s) or affirm(s) that the statoments In the loregoing Potition ere truo and correct to the bust of ttx~ know{edgo and belie( of Petitioners} and that, as personal reprosontativo(s) of tho Decedent, Potltioner(s) wll! well and truly administer the ostato acc ding to law. ~_~-~ Sworn to or afiirrnod and subscrlbod betoro r»3 this 26TH day of AIJGU~? ,q 97 .~ 1 ~ ~~ For tiro Register MAR`! ~ ~~k"~ No. 21 - 9 7 - 716 Estateot Peter N. Kutulakis Deceased Social5ecurityNO: 208-26-3096 DatoofDeath: 08/05/97 AND NOW, AUGUST 76 , 19 cam, in consideration of the Petition on the reverse sido hereon, satisfactory proof having been presented before me, IT IS DECREED that Letters ~ Testamentary ~ Ot Administration aze hereby grantod to Thomas Place (c.t.a.; d.b.n.c.t.a.; pondente liter durante absentia; durante minorKate) in the above estate and that the instrument(s) dated 11/09/92 i--- -- -...___- ------.. . I described in tiro Petition bo admitted to probate and filed of record as the last V'lill of Decedent. FEES l Letters . $ - - ~ , , , ~ ~ ~/ ~ ~ ~ c. -~ . /, t R~jister of Wills Shot Certificate(s) . $ '<! ~ ' ~~ ~ ~ MARY C ~ W I S ~- ~ ~U •1 ' Renunciation. $ Attorney/ Steven"J , hiffman Affidavits ( ). $ I.D. No: 25488 Extra Pages ( ) . $ Address: 2080 Linglestown Rd, Suite 201 Codicu..... . .... . $ Harrisburg, PA 17110 JCP Fee . .. .. $ Telephone: 717/540- 9170 Inventory. $ Other $ TOTAL. $ i ;, ~, Pr~par~d Dy th• P~nneylwnu Bay Aiencufinn Cop Y~~Dht Ic) 1998 rn~m so~twere only CPSyf lnma, Inc. Letters and order given to Exar~ut~r ;;,, n ., -: ~.,..~ ~..;r~rF... ..- . _ . _ Form RW-t (1DD1) ---~--:i r IN RE ESTATE OF IN THE COURT OF COMMON PLEAS PETER N. KUTULAKIS : CUMBERLAND COUNTY, PENNSYLVANIA Register of Wi11s No.: 1997-00716 AFFIDAVIT OF STEVEN J. SCHIFFMAN, ESQUIRE I, Steven J. Schiffman, Esquire, being duly sworn according to law, hereby depose and state as follows: 1. I, Steven J. Schiffman, Esquire, was retained by the Estate of Peter N. Kutulakis to represent the estate through the probate process. 2. The Executor of the Estate of Peter N. Kutulakis was Thomas M. Place. 3. I concluded my representation of the Estate of Peter N. Kutulakis on or about April 27, 2000. 4. Upon the conclusion of my representation, Isent aletter to Thomas M. Place on or about April 27, 2000, detailing the estate administration and notifying Mr. Place that the estate administration was now complete. 5. I verify that the letter attached hereto as Exhibit A is a true and correct copy of the letter sent to Thomas M. Place on or about April 27, 2000. 6. Upon the conclusion of my representation, (also sent letters to Mary D. Kutulakis and Jason P. Kutulakis on or about April 27, 2000, detailing the estate administration and notifying each that the estate administration was now complete. 7. I verify that the letter attached hereto as Exhibit B is a true and correct copy of the letter sent to each Mary D. Kutulakis and Jason P. Kutulakis on or about Aprii 27, 2000. 1 8. Jason P. Kutulakis' letter was sent the address that I had on file for him which was 411 Barnstable Road, Carlisle, PA 17013. 9. I did not receive the letter addressed to Jason P. Kutulakis back from the postal service. 10. Additionally, the letter addressed to Mary D. Kutulakis and Jason P. Kutulakis noted that income tax schedules were included with the April 27~' letter since there were tax consequences to each beneficiary. 11. I verify that the letters attached hereto are true and accurate copies of the letters in my file concerning the Estate of Peter N. Kutulakis. 12. The above statements are true and correct based upon my personal knowledge. Date:: 3 2~ ~ 2 ,/ 1~,-? fF Steven J. ~S>~iiffman, Esq. .` 1-' COMMONWEALTH OF PENNSYLVANIA ' ss COUNTY OF ~ ~-~'-~'''~' :. On this, the ~~'' day of ~~~ 2012, before me, the undersigned officer personally appeared Steven J. Schiffman, Esquire, known to me (or satisfactorily proven) to be the person whose name is subscribed to the within instrument, and acknowledged that he executed the same for the purposes therein contained. In Witness Whereof, I have hereunto set my hand and official seal. 4~ c . (SEAL) Title of Officer ~~ caNw~i~~ ae P~vsnvu 2 ~Tz.s~. Aa6u~ A. l;~vangclisti, Notary public Sttagieo6anna Trnraaiup, Dauphin County commission ex ` A9sy 07, 2012 Apri127, 2000 LORI K. $ERRATELLI STEVEN J. SCHIFFMAN Thomas M. Place, Esq. MICHAEL F. BROWN The Dickinson School of Law 1 SO South College Street RONALD L. CALHOON CarllSle, PA 17013 ANDREW J. OSTROWSKI Re: Estate of Peter N. Kutulakis DEBORAH L. PACKER Dear Tom: $TEVEN O. SPAHR Enclosed please find copies of the final fiduciary returns; final status MALIRA B. MUNDY report and letter to the beneficiaries. The Estate administration is now complete. MELANIE L. ERB If you wish to obtain any original documents from the file, please let me know within the next thirty days; otherwise, the file will be placed in storage. GARTH A.STEPHENSON ar Co~~,:ei If you have any questions, do not hesitate to contact me. Thank you. tMD & DC Bars Unh i JOHN D. SHERIDAN Very truly yours, Ur Counsel ............. SERRATELLI, SCHIFFMAN, P.C. SJS/dae sJ~r~ zo; Enclosures 2080 L~.~C~.esro~,•r•: Ra,o r':,~,rti;se:,ac:, i~ ~ ) ; 110-yr,?~~ (717) 540-9170 FA$ is 1 : 1 S=Iii-dti? Apri127, 2000 LORI K. SERRATELLI STEVEN ). $CHIFF-v{AN MICHAEL F. BROWN Register of Wills Cumberland County Courthouse RONALD L. CALHOON One Courthouse Square Carlisle, PA 17013 ANDREW ~. OSTROWSKI Re: Estate of Peter N. Kutulakis DEBORAH L. PACKER No. 1997-00716 STEVEN O. SPAHR Dear Sir/Madame: MAURA B. MUNDY Enclosed for filing, please find the original and one copy of the final status MEUNIE L. ERB report with regard to the above captioned matter. \JARTH A..~iTEPHENSON please time and date stamp the extra copy and return it to our office in the yr Coun,~l enclosed envelope. tMD & UC Baes C)nlvi IOHN D. SHERIDAN Thank You, in advance, for your assistance in this matter. Of Counsel Very truly yours, SERRATELLI, SCHIFFMAN, BROWN & CALHOON, P.C. Debra A. Evangelisti, Paralegal SuiTe zoi /dae zoeo Linc~esTO++. Ro .o Enclosure HAHRISBI.'RC;, F,~, cc: Thomas M. Place, Executor 7 i I n-9~7o (717) 540-9170 STATUS REPORT UNDER RULE 6.12 Name of Decedent: Peter N. Kutulakis Date of Death: August 5, 1997 Will No, 1997-00716 Admin. No. Pursuant to Rule 6.12 of the Supreme Court Orphans' Court Rules, I report the following with respect to completion of the administration of the above-captioned estate: 1. State whether administration of the estate is complete: Yes x No 2. If the answer is No, state when the personal representative reasonably believes that the administration will be complete: 3. If the answer to No. 1 is Yes, state the following: a. Did the personal representative file a final account with the Court? Yes x No b. The separate Orphans' Court No. (if any) for the personal representative's account is: c. Did the personal representative state an account informally to the parties in interest? Yes No x d. Copies of receipts, releases, joinders and approvals of formal or informal accounts may be filed with the Clerk of the Orphans' Court and may b' atta" d o this report. Dated : y ,~ l-,~oaz1 __-- ~~ `"~ Name (Please type or print) 2080 Linglestown Rd., Suite 201 Harrisburg, PA 17110-9445 Address (717) 540-9170 Telephone Number Capacity: Personal Representative x Counsel for Personal Representative April 27, 2000 LORI K. SERRATELII STEVEN f . SCHIFFMAN MICHAEL F. BROWN Mary D. Kutulakis Jason P. Kutulakis 505 Barnstable Road 411 Barnstable Road RONALD L.. CALHOON Caz11Sle, PA 17013 Cazltsle, PA 17013 ANDREW J. OSTROWSKI Re: Estate of Peter M. Kutulakis DEBORAH L. PACKER Dear Mrs & Mr. Kutulakis: STEVEN ~. SPAHR Please be advised that the administration of the Estate of Peter N. MAURA B. MUNDY Kutulakis is now complete. MELANIE L. ER8 The final fiduciary tax returns have now been filed. During the final year of the Estate any income/losses are passed through to the beneficiaries of the GARTH A. STEPHENSON Estate. In that regazd, I have enclosed a Schedule K-1 and Schedule L for each of or c~„~,,:e! you which should be provided to your tax prepazer for use in preparing your IMU c ~c B ~~, o.,!` personal income taxes for the 2000 tax year. JOHN D. SHERIDAN or c;,~~„<E.! Also enclosed is a short accounting which details the distribution of the Estate funds from the date of the formal court accounting to the present. Thank you for your attention. Very truly yours, SERRATELLI, SCHIFFMAN, BROWN ~ CA~I3OON, P.C. 5117E 2J i //[,/'~J. Steven 'J~3~J LI~GlfST{?U~ h,:,x.o H 4RF~S6l,HG. P~ SJS/dae ~ ~ I ~ a-~r~,-o Enclosure (7 1 7) 5 4 0 - 91 ~ o cc: Thomas M. Place, Executor f:::~ I > I ( ... . FINAL SHORT ACCO JNTING Balance Remaining - 10-18-99 $229.61 11-13-99 Interest Deposit 4.72 Add-In Penn Credit Corp. Uncashed Check #163 .21 Add-In Chex Systems Uncashed Check #172 11.84 246.38 Balance Due to Serratelli, Schiffman, Brown & Calhoon: 675.00 Write-Off: 428.62 Balance: _0_ COMMONWEALTH o~ PENNSYW~ County of CUMBERt.AI~ ~ ~ I Robert P Ziegler Recorder;, do CertHy that the foregoing ~ a tnattt end" N-y oernn~eelori Jan. 20, 2014 ~` _~_.~ `~ / 3~ ~,~._~. ~_>r~~ D~LED BETWEEN MARY D. KIITULAKIS, WIDOW, of West Pennsboro Township, Cumberland County, Pennsylvania, hereinafter referred to ns MADE the ~ ~~ do}~ of f~o,~,~c~ D~ , 1999, Ancl GRA1V'I'PS)S ~' WITNESSETIi, that in considerntlon of ONL ($1.00) DOLLAR, in hand paid, the receipt whereof is hereb}~ acknowledged, the said Grantor does hereby grant and convey to the said Grantees, their heirs and assigns: ALL that certain tract of land with improvements thereon situate in West Pennsboro Township, Cumberland County, Pennsylvania, bounded and described in accordance x~ith a Pinal Subdivision Plan of ivfary D. Kutulakis, recorded in the Office of the Recorder of Deeds in and for Cumberland County in Plan Hook 78, Pnge 53, na follows: ~1 f Parcel H; P/0 46-OS-0583-065 GRANTOR JASON P. I:UTULAKIS and )oA>`INE E. f:Lt:1'ULAKIS, husband and wife, of f-Iershey, Dauphin County, Pennsylvania, hereinafter referred to as BEGINNING at an iron pin set on the dedicated right of way lute of a public road known ns Barnstable Road ('I'-447), thence South O6 degrees 30 minutes UO seconds Bast a d19ta11CL' of 100.00 feet to a nail; thence along lands now or formerly of Sylvia H, Rambo and passing through Barnstable Road (T-497) South 06 degrees 45 minutes 14 seconds West a distance of 200.00 feet to a Hall; thence along Innds now or formerly of Sylvia H, Rambo North 7A degrees 30 minutes 00 seconds East a distance of 7114.27 feet fo a set iron pin; thence along lands nox~ or formerly of Raymond II. Blain South 15 degrees 15 minutes OD seconda Ensl a distance of 418.60 feet to a set iron pin; thence along Innds now or forrrter]y of Mary D, l:utulakis South 77 degrees 23 minutes 05 seconds West to n sef bolt; thence North 20 degrees 10 minutes 47 seconds West n distance of 52.65 feet; thence North 15 degrees 07 minutes 33 seconds Weat n distance of 42,69 feet; thence along lands now or formerly of Mary D, I<utulakls South 77 degrees 47 minutes 29 seconds West n distance of 219.130 feet to an iron pin; ihence North l1 degrees 3G minutes 43 seconds West n distance o(99.33 feet to on iron pin; thence South 7t? degrees 05 minutes 33 seconds West n distance of 538.46 feet to ~ set iron pin; thence North 17 degrees 30 minutes 00 seconds YVesf n distance of J(,'tif .~~Jr ~,ii;r ~71 587.62 feet fo n set iron pin; thence along lands now or formerly of Sylvia 1-f, Rambo North 78 degrees 30 minutes UO seconds Enst a distance of 990.06 feet to an iron pin, the place of BEGINNING. CONTAINING 20.33f3 ncres and being Lot 3~A of the aforementioned Subdivision Plan, BEING part of the eatne premises whic}i Robert R. Line, Jr., and Joart P. Litre, his wife, granted and conveyed unto Peter N, Ktttulakia and Mary D. Y.utulakis, Iris wife, by deed dated October 2, 1965, and recorded in the Cumberland County Recorder of Deeds Office In Deed Baok 21-T~408, Ttte said Peter N. Kutulakis died August 5, 1997, thereb}~ vesting title in the widow, Mary D. Kutulakls, Grantor herein. THIS IS A CONVIiYANCE FROM MOTI-IER TO SUN AND DAUGI-ITER-IN- LAW AND THEREFORE 13XEMJ'TPROMRRALTYTRAIVSPLtR'fAX. UNDER A1JD 5U13JECT, HOV>>EVER, TO RESTRiCT10N5 OP RECORD AND AS SI/T FORTH IiJ THE ABOVE-MBNTIONT3D DEED. AND the Grantor will warrant genernli}~ the property hereby conveyed. IN WITNESS WHIs1ZEOP, tite said Grantor has set her hand and seal the day and yenr first above written. 51GNED, S11ALTsD ANp DISLIl'EIZED I TI-iE PRL'SENCIi OP: ~9 [~ ~ _ (SEAL) n D <utuln s CONfMOJJ1hrEALTId OP I'EIJNSYLVAI~IA ) COUNTY OP CUMBERLAND ) SS. Tl_I On this, the ~~- dny of r~~-~-~~- 1999, before me the undersigned officer, personally appenred Mnry D. Y.utulakls, known to me or satisfnctorlty proven to be the person whose name is subscribed to the wit ~,i,i, instrument, turd ttcknowled ed that she executed the snore for the tY' ~p ~""'i~~ ~`' therein contained, "' ' ' - ~. IN WITNESS WHhREOP, I hereunto set my hand and official seal, ;~.~,.;t ,..;,Lt,;;,~,ygt;~l;,?.1;; .t w,,..~.:: r. NOIAHUL SEAL ~~ t ~ p~./-- ~'NOC~Y',~P'~"u- ;~+-~~:~',1~1;~' ., GEORGE F. DOUQUtS, Ili HOiARY PUBLIC ~. L. I ~,,;;,r f ~.ni ISLC fIDRO., CUMf3ERUND COUNTY -~A,y,MU~}~t.+,~x.;.l "'"neclnN E.zPIFlES 1181E 2G, 1999 UilUt; L~~7 ?SIGi l~:cr~ "; I.'~ . Certificate of Residence ]hereby certify that the precise residence and complete post office nddress of the within Grantees is: ?`I'f l ~~r~~.~r~ P d. Carlisle, PA 17013 Dated: 31 (~-(`~ `~ ~A9r~Q~. F' ~~/~4.i1- ~ Aftomey~or Grantees ~,,, „ i n; rn ~ ~ _ , ui ~_ '" N ,. ~ ,;, :J '~:~ U ~ ~ r,1 ' '~ ' r--{ !~! C.. f i CS Iir ~.: ~,.r <U F. 1.: - Cn =~~ cn ;~1-'sr at PrnnsyPrnnlo ' in Ilrr. u41ro for Iho recording o! Uoads l ~ ~ ;~,,~ trr rlenJ Counyr, is l:i . C.L'_(~"s~o?: Vol. ~ Page ~'~ ~ ~ ; ; my hand nn canl of ofli / ' :;rli<:l~:, t!'1 IIIIS~ ~jpY p 1d FRB Idef ~rr,,~~/~~,~jl Fj~~ h ~#CNi>;~P a_ , yr,f:%~~~~ flh~a ~J.+s`~flY'~F A ~li:.'jry,l~ ~-^- BOOR ~.~J (~;i;f ~.c;u ~...... CERTIFICATE OF SERVICE I hereby certify that on this ~ ~ day of March, 2012, a true and correct copy of the foregoing document was served upon the party listed below, via First Class Mail, postage prepaid, addressed as follows: The Honorable Eugene E. Fike Somerset County Courthouse 111 E. Union Street Somerset, PA 15501 Jason P. Kutulakis, Esquire Two West High Street Carlisle, PA 17013 SAIDIS, SULLIVAN & ROGERS Den eyno Esquire Attorney Id. 80440 26 West High Street Carlisle, PA 17013 717-243-6222