HomeMy WebLinkAbout06-13-11 (2)~- s
IN RE ESTATE OF
PETER N. KUTULAKIS
IN THE COURT OF COMMON PLEAS
CUMBERLAND COUNTY, PENNSYLVANIA
Register of Wills No.: 1997-00716
ANSWER IN OPPOSITION TO PETITION TO OPEN ESTATE AND SET ASIDE
THE FINAL ACCOUNT AND DISTRIBUTION
OF THE ESTATE OF PETER N. KUTULAKIS
AND NOW this ~ ~ day of June, 2011, comes Respondent Mary D. Kutulakis by and
through her counsel Dean E. Reynosa and hereby avers as follows:
1. Admitted.
2. Admitted in part and denied in part. It is admitted that the Decedent was married to
Respondent at the time of his death. The Decedent had moved out of the home on several
occasions and established residence elsewhere including at a cabin that was once on land
presently owned by Respondent. Respondent does not believe that the Decedent was out of
the home for a consecutive fifteen year period.
3. Denied. The Decedent's will and the deeds are written documents that speak for
themselves. To the extent that Petitioner suggests that Decedent's wishes are different than
those expressed in his will and in the deed, Respondent asserts that such representations
violate the Dead Man's Act.
4. Admitted.
5. Admitted.
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6. Admitted.
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7. Admitted. .
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9. Admitted. ~ `'''~
10. Denied. Respondent asserts that the allegations of this paragraph violate the Dead
Man's Act. To the extent that a response is required, Decedent's last will and the deeds to the
property at issue are written documents that speak for themselves.
1 - 1
11. Denied. Respondent asserts that the allegations of this paragraph violate the Dead
Man's Act. To the extent that a response is required, Decedent's last will and the deeds to the
property at issue herein are written documents that speak for themselves.
12. Denied. After reasonable investigation, Respondent is without sufficient information
to determine the truth of the allegations of this averment.
13. Denied. After reasonable investigation, Respondent is without sufficient information
to determine the truth of the allegations of this averment.
14. Denied. Respondent had no reason to hide the fact that Decedent died with a will.
The will was probated at the Cumberland County Register of Wills and was available to
everyone for inspection. It is believed and therefore averred that Petitioner was an active
participant in the probate of Decedent's will. During the estate administration, Petitioner
directed that Decedent's personal property items be appraised. See letter from John T.
Emsminger dated May 5, 1998, attached hereto as Exhibit A. Decedent's will provided that
Petitioner would receive all of Decedent's personal property.
15. Admitted.
16. Admitted.
17. Denied as stated. Respondent engaged in mediation with Petitioner for three
reasons. Respondent sought to reestablish a relationship between herself and Petitioner, her
son. Second, Respondent sought to reestablish a relationship between herself and her
granddaughter. Finally, Respondent also sought to discuss her plans to sell her property.
18. Admitted.
19. Denied. After reasonable investigation, Respondent is without sufficient information
to determine the truth of the allegations of this averment.
20. Denied. Respondent incorporates her response at paragraph 14 as though if fully
set forth at length herein.
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21. Denied. After reasonable investigation, Respondent is without sufficient information
to determine the truth of the allegations of this averment. To the extent that a response is
required, Decedent's estate was probated at the Cumberland County Register of Wills and was
on file for all to inspect. Respondent further incorporates her response at paragraph 14 as
though if fully set forth at length herein.
22. Denied. The averments of this paragraph state legal conclusions to which no
response is required. To the extent that a response is required, Respondent denies any legal
significance Petitioner attributes to Respondent's failure to invoke a spousal election.
23. Denied. The averments of this paragraph state legal conclusions to which no
response is required.
24. Denied. Respondent incorporates her response at paragraph 22 as though if fully
set forth at length herein.
I. 505 BARNSTABLE ROAD
25. Respondent incorporates her responses at paragraph 1 -24 as though if fully set
forth at length herein.
26. Denied. The Agreement of Sale is a written document that speaks for itself.
27. Denied. After reasonable investigation, Respondent is without sufficient information
to determine the truth of the allegations of this averment. To the extent that a response is
required, it is noted that the Agreement of Sale was on file with the public record in this Estate.
28. Denied. The Agreement of Sale is a written document that speaks for itself.
29. Denied. The averments of this paragraph state legal conclusions to which no
response is required. To the extent that a response is required, Decedent did not finalize the
purchase of the property. Decedent did not pay the lump sum that was due on August 1, 1997.
Respondent purchased the property with her own proceeds by Deed dated May 12, 1998, and
recorded May 26, 1998. See Deed attached hereto as Exhibit B. Petitioner possesses no
equitable interest in 505 Barnstable Road.
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s stated. Respondent acquired sole ownership interest of 505 Barnstable
30. Denied a
Road by Deed recorded May 26, 2998. Id.
31. Denied. The averments of this paragraph state legal conclusions to which no
response is required. To the extent that a response is required, Petitioner does not possess
an equitable interest in property purchased individually by Respondent and deeded individually
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to Respondent.
11. 411 BARNSTABLE ROAD
32. Respondent incorporates her responses at paragraph 1 - 31 as though if fully set
forth at length herein.
33. Admitted with further explanation. Respondent and Decedent purchased the
property as husband and wife as tenants by the entireties. See Exhibit E to Petitioner's Petition
to Open.
34. Denied. Respondent incorporates her response at paragraph 33 as though if fully
set forth at length herein.
35. Admitted.
36. Denied. Respondent asserts that the allegations in this averment violate the Dead
Man's Act. To the extent that a response is required, the property remained deeded to
Decedent and Respondent as husband and wife as tenants by the entireties.
37. Denied. Respondent incorporates her response at paragraph 36 as though if fully
set forth at length herein. Additionally, Respondent made the decision herself to sell her
property after Decedent passed away.
38. Denied. Respondent incorporates her response at paragraph 36 as though if fully
set forth at length herein. Additionally, Respondent moved from the farmhouse when her
current home was completed in 1999.
39. Denied. Respondent incorporates her response at paragraph 36 as though if fully
set forth at length herein. Additionally, the deed was never changed and shows that at the time
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of Decedent's death, the property was held by Respondent and Decedent as tenants by the
entireties.
40. Admitted.
41. Denied. Respondent incorporates her response at paragraph 37 as though if fully
set forth at length herein.
42. Denied. The averments of this paragraph state legal conclusions to which no
response is required. To the extent that a response is required, it is acknowledged that
Petitioner acquired an ownership interest in a portion of 411 Barnstable Road (approximately
20.338 acres) as noted in a deed dated March 12, 1999, and recorded at Deed Book 195 Page
82. See Deed attached hereto as Exhibit C. It is denied that Petitioner possesses any
equitable interest in the remaining portion of the property formally known as 411 Barnstable
Road.
III. FRAUD
43. Respondent incorporates her responses at paragraph 1 - 42 as though if fully set
forth at length herein.
44. The docket speaks for itself.
45. Admitted.
46. Admitted.
47. The docket speaks for itself.
48. The docket speaks for itself.
49. Denied. The Affidavit of Service is a written document that speaks for itself. To the
extent that a response is required, Respondent notes that she signed for the certified return
receipt card addressed to Petitioner after the postal carrier delivered it to her at 505 Barnstable
Road. Respondent had no reason to conceal the filing of the final account in this matter from
Petitioner or fail to deliver to him the final account. It is believed and therefore averred that
Petitioner was aware of the fact that the estate was being probated in Cumberland County. In
~ - •
fact, an appraisal of the Decedent's personal property was undertaken at Petitioner's request.
See John T. Ensminger's letter dated May 5, 1998 attached hereto as Exhibit A.
50. Admitted with further explanation. At the times relevant hereto, mail was being
delivered to either address until the postal carrier understood who lived at which address.
51. The docket speaks for itself.
52. Admitted.
53. Denied. The averments of this paragraph state legal conclusions to which no
response is required. To the extent that a response is required, Respondent signed the card for
Petitioner since it was delivered to her address. Respondent had no reason to conceal the fact
that the final account had been filed in this estate or fail to deliver to him the final account. It is
believed and therefore averred that Petitioner was an active participant in the administration of
Decedent's estate.
54. Denied. Respondent incorporates her response at paragraph 53 as though if fully
set forth at length herein. Additionally, Respondent denies that she engaged in any fraud.
Respondent signed the receipt upon the request of the postal carrier and as a favor to her son.
55. Denied. Respondent incorporates her response at paragraph 53 as though if fully
set forth at length herein. Additionally, Respondent had no reason to conceal the fact that the
final account had been filed in this estate.
56. Denied. Respondent incorporates her response at paragraph 53 as though if fully
set forth at length herein.
57. The docket speaks for itself.
58. Denied. The averments of this paragraph state legal conclusions to which no
response is required. To the extent that a response is required, Respondent denies that she
engaged in any fraud. Respondent incorporates her response at paragraph 49 as though if fully
set forth at length herein.
1 ~ ~
59. Denied. The averments of this paragraph state legal conclusions to which no
response is required. To the extent that a response is required, Respondent denies that she
engaged in any fraud. Respondent had no reason to conceal the fact that the final account had
been filed in this estate. Respondent incorporates her response at paragraph 49 as though if
fully set forth at length herein.
60. Denied. Respondent did not conceal the fact that Decedent died with a will. The will
was probated in the Cumberland County Register of Wills for inspection by everyone. It is
believed and therefore averred that Petitioner was an active participant in the estate
administration. Decedent's will provided that Petitioner would inherit all of his personal property.
Petitioner directed that Decedent's personal property items be appraised.
61. Denied. Respondent had no reason to conceal the fact that the final account had
been filed in this estate.
IV. FAILURE TO PROVIDE NOTICE PURSUANT TO RULE 6.3
62. Respondent incorporates her responses at paragraph 1 - 61 as though if fully set
forth at length herein.
63. Denied. The averments of this paragraph state legal conclusions to which no
response is required.
64. Denied. The averments of this paragraph state legal conclusions to which no
response is required.
65. Denied. The averments of this paragraph state legal conclusions to which no
response is required.
66. Denied. It is believed and therefore averred that Petitioner was aware that
Decedent's will was being probated in Cumberland County. It is further believed and therefore
averred that Petitioner was an active participant in the estate administration. Petitioner directed
that Decedent's personal property items be appraised. Decedent's will provided that Petitioner
~ ~ }
would receive all of his personal property. Respondent incorporates her response at paragraph
49 as though if fully set forth at length herein.
67. Denied. The averments of this paragraph state legal conclusions to which no
response is required.
68. Denied. The averments of this paragraph state legal conclusions to which no
response is required.
Wherefore, Respondent respectfully requests that this Honorable Court deny Petition to
Open the Estate.
NEW MATTER
69. Respondent incorporates her responses at paragraph 1 - 68 as though if fully set
forth at length herein.
70. Petitioner was an adult at the time that Decedent passed away and his last will
probated.
71. Petitioner was a practicing attorney at the time that Decedent's will was probated.
72. Petitioner's claims are barred by the applicable statute of limitations.
73. Petitioner's claims are barred by the doctrine of laches.
74. Petitioner's claims are barred by the Statute of Frauds.
75. Petitioner's claims are barred by operation of the Dead Man's Act.
76. Petitioner seeks an equitable interest in real estate held solely by Respondent.
77. Real estate transfers pursuant to the terms of the individual deed.
78. With respect to the property at issue in Petitioner's Petition to Open Estate,
Decedent held neither individually.
79. With respect to 505 Barnstable Road, at the time of Decedent's death the property
was owned by and deeded to Thomas M. Place.
80. Decedent did not possess an ownership interest in 505 Barnstable Road at the time
of his death.
81. While an Agreement of Sale was executed between Decedent and Thomas M. Place
on July 26, 1996, the Agreement of Sale required Decedent to make monthly payments for one
year.
82. The Agreement of Sale further required that Decedent make a final lump sum
payment on August 1, 1977 [sic: 1997].
83. Decedent did not make the final lump sum payment.
84. Decedent's Estate did not make the final lump sum payment.
85. Since the final payment was not made in accordance with the Agreement of Sale, no
deed was ever created transferring title of the property from Thomas M. Place to Decedent.
86. Respondent purchased the property from Thomas M. Place and Grace E. D'Alo by
Deed dated May 12, 1998 and recorded on May 26, 1998. See Deed attached hereto as Exhibit
B.
87. Respondent purchased 505 Barnstable Road with her own funds and in her own
name.
88. Petitioner does not possess any equitable interest in property purchased by
Respondent in her own name.
89. With respect to 411 Barnstable Road, Decedent and Respondent purchased this
property as husband and wife as tenants by the entireties. See Exhibit E to Petitioner's Petition
to Open.
90. Upon Decedent's death, title to 411 Barnstable Road passed to Respondent
individually.
91. Petitioner acquired an ownership interest in a portion of 411 Barnstable Road
(approximately 20.338 acres) as noted in a deed dated March 12, 1999, and recorded at Deed
Book 195 Page 82.
92. Petitioner accepted his deed wherein it is noted that title to the whole 411 Barnstable
Road was vested in Respondent at the time of Decedent's death.
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93. Petitioner does not possess any equitable interest in the remaining portion of the
property formally known as 411 Barnstable Road.
94. The deed for 411 Barnstable Road never included Petitioner.
95. Petitioner's Petition to Open the Estate only alleges that he possesses an equitable
interest in the foregoing two pieces of real estate.
Wherefore, since Petitioner possesses no equitable interest in either property, his
Petition to Open should be denied.
Respectfully submitted,
SAIDIS, SULLIVAN & ROGERS
v,
De E. Reynosa, Esquire
A rney Id. 80440
26 West High Street
Carlisle, PA 17013
(717) 243-6222
Counsel for Respondent Mary D. Kutulakis
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.~CJHN T. ENSM ANGER
AUCTIONEER and APPRAISER
302 Fireside Drive, Camp Hill, PA 1 701 1-1 421
Phone (717) 763-9779 FAX (717) 541-9444
May 5, 1998
Steven J. Schiffman, Esquire
2080 Linglestown Road
Harrisburg, PA
Dear Sir:
Re : Estate of PetE~r M Kutul aki s
At the request of Jason Kutulakis, I have appraised the E~roperty of the
late Peter M. Kutu1akis. This property is located in a ~>torage shed
on the property at 411 Barnstable Road, Carlisle, Pennsylvania.
The values shown have been arrived at after careful inspection and I
believe that they reflect a fair market value as of this date.
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Fair market value is defined as being the most reasonable or probable
price in terms of money which real or personal property will bring in an open
and competitive market under all conditions necessary for' a fair sale, the
buyer and seller each acting in a prudent manner and assuming the price is
not affected by undue stimulus.
Taking into account the prices listed on the following page, it is the
opinion of the undersigned that the fairy market value of the property is
$2,860.00 tTwo Thousand Eight Hundred-Sixty Dollars).
Employment in and compensation for making this appraisal are in no manner
contingent upon the values reported and I certify that I have no financial
interest in the property appraised, present or contemplated.
Very truly yours,
. ~ ~~ ~ r
/ ~
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f John T. Ensminger
~~
Personal Property - Peter M. Kutulakis
Horse fair - lithograph
Fox Hunt
Trova print
3 framed 21x35 Monet repos
3 pc living room suite
Tea wagon
Microwave
Pair of~kitchen armchairs
l~lashstand
Oak rolltop desk
Wall cabinet
Oval mirror
Square mirror
Schoolmaster's desk
Pair of andirons
Magnavox TV
41i ng cha i r
Microwave stand
Pair antique rushbottom chairs
Bureau
Oak office chair
$125.00
75.00
25.00
300.00
100.00
150.00
40.00
40:00
175.00
650.00
75.00
20.00
20.00
300.00
2.00
25.00
50.00
30.00
300.00
300.00
40.00
Total 2,860.00
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GER
JOHN ~. ENSMiN
AUCTIONEER and APPRAISER
302 Fireside Drive, Camp Hill, PA 17011
Phone (717) 763-9779
.........................May.. 5,............198.........
To .............st~`!~.n. ,J,. „Sch i f fman,~ _ ,~squ i.re
............ ... .....
............2i18Q..1..tin9~.~~twn,Road .........................................................................................
.............l~arr..i.sbuC9 ~..P.A......................................,............................................................
Estate of......P.~ter..M.:. KU~yI aki 5 ..................................................:........................................
..............................................................................................................................
Appraisal Services
Real Estate @ $ .............:........ per parcel $..........................
Persona I Property 125: 00
Total x.12.5•.•00 ................
___
THIS DEED
~~~
MADE THE /o~ day of , in the year of ~~ne thousand nine
hundred ninety eight (1998).
BETWEEN THOMAS M. PLACE and GRACE E. D'ALO, husband and
wife, hereinafter referred to as:
Grantors,
and MARY D. KUTULAKIS, a widow, hereinafter referred to as:
Grantee.
WITNESSETH, that in consideration of THIRTY FOUR THOUSAND
($34,000.00) DOLLARS in hand paid, the receipt thereof is hereby
acknowledged, the said Grantors do hereby grant and convey to the said
Grantee, her heirs and assigns:
ALL that certain tract of land with the improvements thereon erected
situate in West Pennsboro Township, Cumberland County, Pennsylvania,
bounded and described as follows:
BEGINNING at a point in the center of a public road; at line of land now
or formerly of Herman M. Hurley, et ax; thence by the same, :North 74 degrees
West 137.5 feet more or less to an old fence at line of land now or formerly of
Peter N. Kutulakis, et ux; thence by the same in a Northeasterly direction along
said fence line, 375 feet more or less to a point at line of land now or formerly
of Ray M. Albright; thence by the same, South 20 degrees 52 minutes West, 100
feet more or less to a point in the center line of said road; thence by the same,
South 72 degrees 37 minutes West, 297 feet more or 1_ess to the place of
BEGINNING.
AND BEING the same premises which Peter N. I~utula~is, and Mary D.
Kutulakis, husband and wife, by their deed dated April 22, 1974, and recorded
in the Office of the Recorder of Deeds in and for Cumberland County,
Pennsylvania, in Deed Book "O", Volume 25, Page 888, granted and conveyed
unto Thomas M. Place, Grantor herein.
AND the said Grantors do hereby covenant and agree that they will
warrant specially the property hereby conveyed.
Grace E. D'Alo is included herein to convey any interest she may
acquired in the subject premises by virtue of marriage to Thomas M. P
have
IN WITNESS WHEREOF, said Grantors have hereunto set their hands
and seals the day and year first above written.
SIGNED, SEALED AND DELIVERED
IN THE PRESENCE
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` WITNESS THOMAS M. PLACE
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WITNESS CE E. D'ALO
COMMONWEALTH OF PENNSYLVANIA
. SS
COUNTY OF CUMBERLAND
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On this, the day o , A.D. 1998, before me appeared
THOMAS M. PLACE, known to me, o satisfactorily proven) to be the person
whose name is subscribed to the wit in instrument, and acknowledged that he
executed the same for the purposes therein contained.
IN WITNESS WHEREOF, I hereunto set my hand anti official seal.
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COMMONWEALTH OF PENNSYLVANIA
SS
COUNTY OF CUMBERLAND ,-- :
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On this, the /~~~ y'day `of ~~``~ , A.D. 1998, before me appeared
GRACE E. D'ALO, known to me, (or, atisfactorily proven) ~o be the person
whose name is subscribed to the within instrument, and acknowledged that she
executed the same for the purposes therein contained.
IN WITNESS WHEREOF, I hereunto set my hand and official seal.
~~
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~?OTARiAL SEAL
~' u(RGl~iEA tr'i. ~IASSEY, NOTARY PUBUiC
;{ C..:.Ri.,SLE Q,7r~c, CUb9BERLAND t:0.PA
t k?1' CO311l1115SlDN ~7. (PIAES NOVEN-BEq 1~ Z001
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I HEREBY CERTIFY, that the precise residence and complete post office
address of the within Grantee are:
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Attorney for Grantee
COMMONWEALTH OF PENNSYLVANIA
SS
COUNTY OF CUMBERLAND •
Recorded on this day of , A.D. 1998,
in the Recorder's Office of the said County in Deed Book ,Page
Given under my hand and the seal of the said Office, the date above
written.
Recorder
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BED
Parcel #; P/O 46-08-0583-065
MADE the j ~~ day of „x,_____,1999,
Ii1rTWBI:N MARY I7, KIITULAKIS, WIpQW, of West Pennsborc~ Townshtp,
Cumberland County, Pennsylvania, hereinafter referred to as
And
GRAN'I'PSES
~'"~ WITNESSBTIi, that In consideration of ONI3 ($1.00) DOLLAR, in hand paid, the
receipt whereof is hereby acknowledged, tits sold Grantor does heret~y 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, boi.inded and
described in accordance with a Final Subdivision Plan of Mary D. Kutulakis,
recorded in the Office of the Recorder of Deeds iii and for Cumberlan~:l County in
Plan Book 78, Page 53, as follows:
GRANTOR
JASON P. TCYJTULAKIS and JOANNE L. KU'I'ULAKIS, husband and wife, of
I-Yershey, Dauphin County, Pennsylvania, herelriafter referred to as
BEGINNING at an iron pin set on the dedicated right of way line of a public road
known as Earnstable Road ('I'-447), thence South O6 degrees 30 minutes 00
seconds East a distance of 100,00 feet to a nail; thence along (Ands now or
for~i~erly of Sylvia H. Rambo and passing tl-rougli Barnstable Roacl (T-447) South
06 degrees 45 minutes 14 seconds West a distance of 200.00 feet to a Hall; thence
along lands now or formerly of Sylvia H, Rambo North 78 degrees 30 minutes 00
seconds East a distance of 784,27 feet to a set Iron pin; thence along lands now or
formerly of Raymond I3. main South 15 degrees 15 minutes 00 secc-nds Fast a
distance of 418,b0 feet to a set iron pin; thence along lands now or formerly of
Mary D. Kutulakis South 77 degrees 23 minutes 05 seconds West to a set bolt;
thence Nortll 20 degrees 10 minutes 47 seconds West a distance of 52.65 feet;
t}ience North 15 degrees 07 minutes 33 seconds West a distance of 42,64 feet;
thence along lands now or formerly of Mary D, Kutulakis South 77 degrees 47
minutes 29 seconds West a distance of 219.80 feet to an iron pin; thence North 11
degrees 9G minutes 4~3 seconds West a distance of 49.33 feet to nn iron pin; thence
South 78 degrees 05 minutes 33 seconds West a distance of 538.48 feet to a set
iron pin; thence North 11 degrees 30 minutes 00 seconds West a distance of
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587.62 feet to a set iron pin; thence along lands now or formerly. oi' Sylvia 1=I.
Rambo North 7$ degrees 30 m(nutes 00 seconds IIast a distance of 99!).06 feet try
an iron pin, the place of BEGINNING.
CONTAINING 20.338 acres and being Lat 3-A of the aforementiortied
Subdivision PIan.
BEING part of the same premises which Robert R. Line, Jr., and Joan r'. Lin+~, his
wife, granted and conveyed unto Peter N. Kutulakis and Mary D. Kutulakis, his
wife, by deed dated October 2, 1965, and recorded in the Cumberland Caurity
Recorder of Deeds Office in Deed Baok 21-T~908. The said Peter N. Kutulakis
died August 5, 1997, thereby vesting title in the widow, Mary D. Kutulakis,
Grantor herein.
THIS iS A CONVIiYANCfi FROM MOTHER TO 5qN AND DAUGI-ITER-IN-
LAW AND TI-iER.EFORIr L~XEMPT PROM RIsALTY TRANSFER TAX.
UNDER AND SUBJECT, HOWEVER, TO RESTRICTIONS OF RECORD AND
AS SET' .ItORTH IN THE AI30VE-MBN'tIONI3D DfifiD.
AND the Grantor will warrant generally the property hereby conveyed.
IN WITNESS WI-IEItEOF, the said Grantor has set her hand and seal t11+, day and
year first above written.
SIGNED, S$ALPsD ANp DfiLIVEItED
I TI*IB PRL~SENCE OF:
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1~__ ~ ~ ~• ~ 1(SEAL)
a D utula s
COMMONWEALTI-i OF PENNSYLVANIA )
~S.
COUNTY Ol' CUMBERLAND )
On this, the 12--TW day of ('~~-R ,
]999 before me
the undersigned officer, personally appeared Mary D. Kutulakis, known to me or
satisfactorily proven to be the person whose Warne is subscrlbed to the wit. , •
instrument, and Acknowledged that she executed the same for the pu~pp ~"~,~,:~~`'`'
therein contained, •' ~ , •.~.:•'~ •=~
IN WI'1'N_ESS WI-iERBOP I hereunto set my hand and official seal '.t r ~ ' '`~~ '
NOIAI{IAL SEAL .--' ~'`~ r'~;{;~r~ ,
GEORGE F. DOUQUIS, III NOTARY PUBttC ~ ~-- ~'No~ ~ ~~~'~ .. ~:~^:j
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r~nl iStE HORO., CU~tBERUttD COUttTY ,,~a.~-n~cf'~h~~lrhix:.r
•~••~~-~e~mN ExP~RE5IUNE 26, 1999
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Certificate of Residence
7 hereby certify that the precise residence and complete post office address
of the within Grantees is:
~k(d ~ ~d- ...Carlisle, PA 17013
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Dated• 3 f Z• F'• ~
Attorney or Grantees
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VERIFICATION
I, Mary D. Kutulakis, hereby verify that the statements made in the
foregoing Answer in Opposition to Petition to Open Estate and Set Aside the
Final Account and Distribution of the Estate of Peter N. Kutulakis are true and
correct to the best of my information, knowledge and belief. 1 understand that
false statements herein are made subject to the penalties of 18 Pa. C.S.
Section 4904, relating to unsworn falsification to authorities.
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Dated: (~/Y~.~_ [ U, ~.D 1 1 ~~
Mary lakis
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CERTIFICATE OF SERVICE
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1 hereby certify that on this ~ day of June, 2011, 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:
Jason P. Kutulakis, Esquire
Two West High Street
Carlisle, PA 17013
SAIDIS, SULLIVAN & ROGERS
Dean . Re uire
Attorney Id. 80440 `
26 West High Street
Carlisle, PA 17013
717-243-6222