HomeMy WebLinkAbout06-01-12~OM ~'
LITLILAKIS
Jason P. Kutulakis, Esquire
rlttomey I.D. #: 80411
2 West High Street
Carlisle, Pr117013
(717) 249-0900
IN RE: THE ESTATE OF
MARLIN L. MARSH
a/k/a MARLIN LEROY MARSH
late of South Middleton Township
Cumberland County, Pennsylvania
deceased
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IN THE COURT OF COMMON PLEAS
CUMBERLAND COUNTY, PENNSYLVANIA
NO.: 21-11-68
ORPHANS' COURT DIVISION
AND NOW, comes the Respondent, Susan Ann Kuhn, by and through her attorney,
Jason P. Kutulakis, Esquire, of ABOM & KUTULAKIS, L.L.P., and respectfully petitions for a
removal of Judy Ann Estill as Co-Administrator of the estate of Marlin L. Marsh, and in
support thereof avers the following:
PROCEDURAL HISTORY
1. Petitioner is Judy Ann Estill, (hereinafter referred to as "Ms. Estill"), who currently
resides at 2829 South Queen Street, Dallastown, Pennsylvania 17313 and is
represented by Marc Roberts, Esquire, of The Law Office of Marc Roberts.
2. Respondent is Susan Ann Kuhn, (hereinafter referred to as "Ms. Kuhn', who
currently resides at 151 South East Street, Carlisle, Pennsylvania 17013 and is
represented by Jason Kutulakis, Esquire, of Abom & Kutulakis, L.L.P.
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3. A third interested part in this matter is Brenda Sue Slaybaugh, (hereinafter referred
to as "Ms. Slaybaugh"), who currently resides at 8 Thornhill Court, Carlisle,
Pennsylvania 17015.
4. The decedent, Marlin Leroy Marsh, (hereinafter referred to as "Marlin" or
"Decedent"), died intestate on November 27, 2010. See, Petition for Probate and
Grant of Letters attached hereto as "Exhibit A."
5. Marlin is survived by three (3) daughters, identified above as Ms. Estill, Ms. Kuhn,
and Ms. Slaybaugh.
6. The Register of Wills of Cumberland County, Pennsylvania granted Letters of
Administration to Ms. Estill and Ms. Kuhn on January 14, 2011. See, "Exhibit A."
7. Ms. Slaybaugh has renounced her right to administer in favor of Ms. Kuhn and Ms.
Estill. See, "Exhibit A"
8. During the initial administration of this estate, Ms. Kuhn and Ms. Estill cooperated
with one another regarding estate matters with Ms. Kuhn assuming the
responsibility of cleaning the estate property for sale and Ms. Estill managing the
estate account. See the correspondence attached hereto as "Exhibit B." At some
point prior to May 30, 2011, cooperation between the aforementioned parties
ceased and progress with the estate slowed.
9. On April 18, 2011, Ms. Estill agreed to only act with the complete concurrence of
Ms. Kuhn. See, correspondence attached hereto as "Exhibit C."
10. Beginning May 30, 2011, Ms. Kuhn began writing a-mail letters to Ms. Estill urging
Ms. Estill to cooperate in order to settle the estate; suggesting methods tb prepare
the estate for sale; and requesting that Ms. Estill pay the estate taxes, as Ms. Estill
was in control of the estate checking account and in possession of the checks
registered to said account. See, correspondence attached hereto as "Exhibit D."
11. Ms. Estill does not address any of the concerns mentioned in Ms. Kuhn's
correspondence, but modifies the original agreement regarding estate activity. On
June 3, 2011 Ms. Estill requests that no improvements/changes be made to the
estate without written consent from all three (3) heirs. See, correspondence
attached hereto as "Exhibit E."
12. Ms. Kuhn agreed to and complied with Ms. Estill's request.
13. On June 4, 2011 Ms. Kuhn responds to Ms. Estill. See, correspondence attached
hereto as "Exhibit F." Ms. Kuhn notes several items concerning the estate:
a. Ms. Kuhn is cleaning brush and other "fire hazards" around the estate in
order to protect the interests of all three (3) heirs without the help of Ms.
Estill or Ms. Slaybaugh.
b. Ms. Kuhn asks for Ms. Estill and Ms. Slaybaugh's help to prepare the
estate [for sale/distribution among the heirs].
c. Ms. Kuhn mentions that the estate needs to be settled in a timely fashion.
d. Ms. Kuhn asks Ms. Estill to forward appraisals for all estate items sold to
date.
e. Ms. Kuhn asks Ms. Estill to forward any letters [to Ms. Kuhn] via a-mail
in order to receive a quicker response.
f. Ms. Kuhn reminds Ms. Estill of the condition that was previously agreed
to by all three (3) heirs, requiring items to be sold only after written
approval from all heirs.
g. Ms. Kuhn asks if anyone was hired to care for the lawn at the estate, and
asks to be notified, in compliance with the previous agreement, if
someone is hired.
h. Ms. Kuhn asks for a response to her previous communications, including
but not limited to, an a-mail and a letter previously sent to Ms. Estill
without response.
i. Ms. Kuhn asks when Ms. Estill will be available to sign the car title (part
of the estate) over to the purchaser and mentions that she has been
"texting" Ms. Estill regarding the car title since May 18, with no response.
14. On June 19, 2011, Ms. Kuhn contacts the office of Marc Roberts, Attorney
representing the estate, requesting a private meeting with all parties to discuss the
progress of the estate. Ms. Kuhn mentions that there have been delays in
communication for three (3) months. Ms. Kuhn also asks Marc Roberts, Esq. for
some estate account checks in order for her to pay the estate taxes before penalties
are assessed. See, "Exhibit G."
15. Ms. Kuhn never received estate account checks.
16. On June 21, 2011, Ms. Kuhn asked fox an account of Attorney Roberts' fees for
over-seeing the estate administration. Ms. Kuhn also requested copies of financial
records, receipts, and appraisals. Ms. Kuhn consented to an estate auction and,
once again, requested a meeting for all parties to discuss the details of the estate, as
other communication methods have proven ineffective. See, "Exhibit H."
17. Ms. Kuhn never received an accounting of the fees, receipts, or professional
appraisals relating to the estate.
18. On July 5, 2011, Ms. Kuhn obtained David Baric, Esq. to represent her interest in
the estate. See, correspondence attached hereto as "Exhibit I."
19. Through the joint efforts of all parties to the estate, a meeting was scheduled for
October 11, 2011. Ms. Kuhn was represented by Attorney Baric and Ms. Estill was
represented by Marc Roberts at the meeting. At the meeting, an agreement to
conduct an estate auction on November 26, 2011 was reached.
20. The estate auction proceeded as scheduled on November 26, 2011, with the
principle real estate being sold to Charles Yana, Dorothy Yana, and Ms. Kuhn for a
sum of $155,000.00. See, Auction of Real Estate of Estate of Marlin L. Marsh
Conditions of Sale attached hereto as "Exhibit J."
21. On November 28, 2011, two (2) days after estate auction and twenty-eight (28)
days prior to settlement of the real estate sale, Ms. Estill elected to terminate the
electricity to the estate without consent of the other heirs, despite their June 3=d
agreement See, correspondence attached hereto as "Exhibit R"
22. On December 17, 2011, Ms. Kuhn contacted Marc Roberts, Esq. with several
concerns, See, "Exhibit I~':
a. Ms. Kuhn expressed concern that no action has been taken to address
damages incurred by the lack of electricity to the estate in winter months,
i.e. moisture in the home.
b. The estate was not in the condition it was in on the day of sale due to Ms.
Estill's "unilateral actions." As a result, the buyers (Ms. Kuhn, Charles,
and Dorothy Yana) have decided to ternnate their purchase of the estate.
c. Ms. Kuhn mentions that the Conditions of Sale stated that buyers would
not assume control or become responsible for the property until thirty
(30) days after the sale.
d. Ms. Kuhn mentions that she cleaned up the debris from the estate sale
and removed more fire hazards post-sale, as was necessary, as Co-
Administrator of the estate.
e. Ms. Kuhn states that she has not heard from either Marc Roberts, Esq. or
Ms. Estill since the electric service was terminated and is concerned with
the unnecessary deterioration of the property.
f. Ms. Kuhn informs Marc Roberts, Esq. that her Attorney, David Baric, has
withdrawn as counsel due to a conflict of interest and she will be
obtaining new counsel.
g. Ms. Kuhn asks, once again, for a statement of Marc Roberts' fees for the
estate.
23. Ms. Kuhn received no response to her Dec. 17Tk' inquiries from Ms. Estill or Marc
Roberts, Esq.
PETITION TO REMOVE MS. ESTILL ANN ESTILL AS;CO-
ADMINISTRATOR OF THE MARLIN L. MARSH ESTAITE
24. Prior paragraphs are incorporated herein by reference.
25. This Court has statutory authority under 20 Pa.C.S.A. ~ 3182 to remove a personal
representative.
26. The Court may remove a personal representative when [s]he is wasting or
mismanaging the estate...or has failed to perform any duty imposed by law; or
when, for any other reason, the interests of the estate are likely to be jeopardized by
[her] continuance in office. 20 Pa.C.S.A. § 3182.
27. The Administrator of an estate can be removed for failure to make an inventory of
estate assets and pay estate debts from a separately maintained checking account.
Matter of Estate of Frey, 693 A.2d 1352-53 (Pa. Super. 1997)
28. An Administrator can be removed for commingling personal funds with estate
funds and keeping haphazard records which make it difficult to ascertain an
accurate accounting of estate funds. Matter of Estate of Frey, 693 A.2d 1352-53
(Pa. Super. 1997)
29. Ms. Estill has failed to make an inventory of estate assets with appraisals of the fair
value of said items at the date of decedent's death. In particular, Ms. Estill removed
gold coins and military items from the estate without obtaining an appraisal and
directly against the request of Ms. Kuhn. Ms. Estill has failed to respond to Ms.
Kuhn's requests for copies of receipts, appraisals, and account records in order for
both co-administrators to approve of sales and account for all estate transactions.
See "Exhibits F, G, H, and L."
30. Ms. Estill has commingled estate funds with personal funds, often paying estate
expenses out of her personal account and expecting reimbursement from estate
funds, despite the existence of an estate checking account, which has remained in
her sole possession. See, Estate Checking Account Register and Ms. Estill's Estate
"Records" attached hereto as "Exhibit M" and "Exhibit N" respectively.
31. Ms. Kuhn has taken every step necessary to contact Ms. Estill, requesting
information and cooperation throughout the entire estate administration process,
See, "Exhibits D, F, G, and H."
32. Due to the strained relationship between co-administrators, communication is
inefficient and ineffective. As a result, serious delays have been created in the
administration of the estate.
33. The correspondence between Ms. Kuhn, Ms. Estill, and their respective attorneys
indicates that Ms. Estill is frequently out of town, resulting in delays in meetings,
hearings, and progress of the administration of the estate. See, "Exhibits G and H"
as well as the correspondence attached hereto as "Exhibits O and P."
34. Ms. Estill's termination of the estate's electric service in Nov. 2011 put the estate in
jeopardy of deterioration, and caused the termination of the sale of the estate,
resulting in further delays and a need for the estate to be placed back on the
market. See, "Exhibit K"
35. Ms. Estill refused to assist Ms. Kuhn in preparing the estate for distribution and
sale, jeopardizing the interests of all beneficiaries of the estate and possibly
decreasing value of the real property of the estate as a result of significant delays.
36. Ms. Estill has failed, despite Ms. Kuhn's best efforts, to transfer the estate car title
to the purchaser William Marlin, potentially resulting in the loss of funds to the
estate. See, "Exhibit F." Mr. Marlin is currently threatening a lawsuit in order to
recover the vehicle.
37. Ms. Kuhn has regularly suggested an expedient settlement in recognition of the
timeframe for filing the Estate Inheritance Tax, without response or cooperation
on behalf of Ms. Estill. See, "Exhibits D and G."
38. The correspondence entered as exhibits to this Petition establish Ms. Kuhn's
efforts to communicate with her Co-Administrator and manage the Estate of
Marlin L. Marsh in a prompt and effectual manner. As such, it is in the best
interests of the Estate to allow Ms. Kuhn to continue as sole Administrator of the
Estate.
39. The exhibits attached to this Petition further demonstrate Ms. Estill's lack of
cooperation and mismanagement of the Estate, necessitating a prompt removal of
Ms. Estill from hex position as Co-Administrator.
[THEREFORE, the Petitioner requests that this Court remove Judy Ann Estill
from hex capacity as a Co-Administrator, and permit Susan Ann Kuhn to serve as the sole
Executor of the Estate of Marlin L. Marsh to its ultimate completion.
Respectfully submitted,
AsoM d~ %UTULAKIS, L.L.P.
DATE D
Jason P. Kutulakis, E e ~
Supreme Court ID 8 1
2 West High Street
Carlisle, Pennsylvania 17013
(717) 249-0900
A#orney for Susan Kuhn
verify that the statements made in the foregoing Petition to Remove Judy Ann Estill as Co-
Administrator of the Marlin Mazsh Estate ate true and correct I understand that false statements
herein are made subject to the penalties of Pa.C.S.A. §4904, relating to unsworn falsification to
authorities.
Date: ~ I ~Ol ~.
S an Ann Kuhn
IN THS COURT OF COMMON PLFsAS OF CUMBERLAND COUNTY, PSNNSYLVANIA
ORPHANS' COURT DIVISION
In re: Estate of MARLIN L. MARSH, No. 21-11-68
late of South Middletown Township,
Cumberland County, Pennsylvania
CSRTIFICATS OF NOTICS UNDSR RULS 5.6(a)
TO THE REGISTER:
I certify that the notice of estate administration required by
Rule 5.6(a) of the Orphans' Court Rules was served on or mailed to
the following beneficiaries of the above captioned estate on or
about April 5, 2011:
Name
Address
Judy Ann Estill 2829 South Queen Street, Dallastown, PA 17313
Susan Ann Kuhn 151 South East Street, Carlisle, PA 17013
Brenda Sue Slaybaugh 8 Thornhill Court, Carlisle, PA 17015
Notice has now been given to all persons entitled thereto under
Rule 5.6(a) except: none
Date: April 5, 2011
Marc`RoSerts, E9e~uire
149 East Market Street
York, PA 17401
(717) 843-1639
ID No. 34355
Capacity: Counsel for
Personal Representatives
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IN THE COURT OF COMMON PLEAS OF CUMBERLAND C
REGISTER OF WII.LS
PETITION FOR PROBATE AND GRANT OF
Estate of MARLIN L. MARSH ,Deceased ESTATE
a/k/a: MARLIN LERQY MARSH
a/k/a:
a/k/a: SS NO:_
Petitioner(s) who is/are 18 yrs of age or older, apply(ies) for: COMPLETE SECT
applicable:
^ A. Probate and Grant of Letters Testamentary or O Administration c.t.a., or d.
and aver that Petitioner(s) is/are entitled to the aforementioned Letters
the last Will of the above-named Decedent, dated and cod
(State relevant circumstances, e.g. renunciation, death of executor, i
Except as follows, Decedent did not marry, was not divorced, and did not have a child bom or
instruments offered for probate; was not the victim of a killing, was never adjudicated an Inca
party to a pending divorce proceeding st the time of death wherein grounds for divorce t
23 Ps. C.S.A. § 3323(8):
49 B. Grant of Letters of Administration
ea/er
C. Petitioner(s), after a proper search, haslhave ascertained that Decedent left no Will and was s
following spouse (if any) and heirs (If Administration c.t.a. or d.b.n.c.t.a., enter date of Will in S
heirs); was not the victim of a killing; was never adjudicated an incapacitated person; and was t
proceeding wherein grounds for divorce had 6eeo established as provided in 23 Ps. C.S.A.
Y, PENNSYLVANIA
ERS
;21- 11- (J~, U~
3-26-4583
`A' or `B' AND "C" as
.t.a. (complete PaK C also)
under
I dated
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pted after!~io~tion of tFle Z:~ ; ~
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fated petstit~,~a~'t'as Itat a ~'= -:: n
seen establLtilftB'~s defined inr', . ,=
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duraotem date) -• r-'~'
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vived by the
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lion A and complete list of
s party to a pending divorce
3323(8), except as follows:-
USE ADDI770NAL SHEETS IF NECESSARY 17 O 15
THIS SECTION MUST BE COMPLETED: ^ to renounce
Decedent was domiciled at death in Cumberland County, Pennsylvania, with his/her last
At '3Lf1 flvfnrrt R.i~a !'e+~rt ,+e+. ~. DA 17'37/.
address with Post Office and Zip Code', Municipality: Township, Borough, City)
Decedent, then 7 9 years of age, died 11 / 2 7/ 2 0 :~ 0 at his r e s i
(Month, nay, Year of death) (City and Sate
Estimated value of decedent's property at death:
If domiciled in PA
If not domiciled in PA
If not domiciled in PA
Value of Real Esate in Pennsylvania
All personal property
Personal property in Pennsylvania
Personal property in County
Total Estimated Value
Location of Real Estate in Pennsylvania: (Provide full address if possible.)
~t nature(s) ~
or principal residence
death occurred)
s6,000.00
S
a
S
5 1 ~Q r>n o.000
340 Oxford Roar
Name(s) & Mailing
1, Gardners, PA 17324
_ Judy Ann Estill, 2829 South Queen
/ ~ ., t
,~~~ Susan Ann Kuhn, S1 South East St.
3224
Interim Fann RW-02 revised 12.26.10 by Cumberland County pending action by [he Court "a i 11 ~ 12 YA I 1 / U 1.$ Page I of 2
j 717/243-837 ~~
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OATH OF PERSONAL REPRESENTATIVE
Commonwealth of Pennsylvania SS
County of Cumberland
The Petitioner(s) herein named swear or affirm that the statements in the f
coaect to the best of the knowledge and belief of Petitioner(s) and that, as
Decedent, Petitioner(s) will well and truly administer the estate according
Swom to or affirmed and subscribed
before me this ~ ~ day of
January ,2011
For the Register
Judy Ann Ens t
s
Petition are true and
representative(s) of the
DECREE OF PROBATE AND GRANT OF LE TERS n
c-
Estate of MARLIN L. MARSH ,Deceased FileNurnber:21- 011 -
AND NOW, this day of January 2011, in con ideration ~~
the reverse side hereon, satisfactory proof having been presented before me, IT I DECREk~
-Testamentary ~ of Administration are h by gnutte3_•a
(Ifappaubk, ever et.a., ab.a., 0.6.o.c.6a., e1c.)
Jud Ann E till
the above estate and that instruments(s) dated n/a de cribed in the
admitted to probate and filed of record as the last Will and Codicil(s) of Deced t.
Glenda Farner Strasbaugh,
Register of Wills
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FEES:
Letters ....................$ t~ULO ~CiU
Will ........................
Co Icll(s) .................
( Short Certificates ~
(~ )Renunciations....... ~
Bond .............................
Other .............................
.................................
.................................
Automation FEE......... 5.00
JCS FEE ................... 23.50
Signature of Coueael Req¢ired to
Atty's Signature
PRINTED Name: Marc Roberts, Esqui~e
Supreme Court ID No.: 3 4 3 5 5
Address:
Phone:
Fax:
Interim Forth RW-02 revised 12.26.10 by Cumberland County pending action by the Court
149~East Market Stree
Yorl~, PA 17401
717 843-1639
Page 2 of 2
sue kuhn <suzzie38@gmail.com>
:~
1 message
Sue Kuhn <suzzie38(ci~gmail.com>
To: judyestill~comcast.net
Fri, Jan 21, 2011 at 2:01 AM
hi,
i wanted to tell you how much it meant to me to hear you say that you're glad to have me back in your life. it
was wonderful to hear that!!! .. i want you to know that I'm not really worried about the house issue. a house is
just a place to keep your possessions, a place to call 'base' .. as i aged i learned the true meaning of happiness
is not in material things. if i can't afford the house at the final appraisal my work) will not collapse. the house i
have now is actually realy decent. i just hate living in town. i get sick of having neighbors sitting on top of me
and lack of parking is enough to drive a person nuts..but..i could honestly be content living in a cardboard box as
long as i had a computer and room for rriy happy pets.:) what would upset me is if you and i bst contact again.
i don't ever want that to happen. even when this estate is settled i am still going to call you for no reason .. just
because you are my sister and i love you. I'm really sorry for anything i have ever done or said to upset you in
the past. i wish i could take back all the wasted years we spent not speaking. i would love to be fable to
celebrate holidays as a family. i know that would mean the world to mom, daddy, and to myseff ..
as for the Brenda issue, i really am sick of her taking advantage of me. she has used my love fort her children to
manipulate me. she has used me far too many times. i prorrised myself when i let her move in with me and she
didn't care about me, my house, my iryury, mom 8~ daddy or anything other than herself that i wa& done letting
her take advanrtage of me. i did help daddy redo the interior at thornttill but i didn't do that for brdnda, i did it so
daddy didn't have to do it alone, to try to repay his kindness and to help the kids. judy, i could wrhte a million
words about how bad she treated daddy during that time but no words Gould possibly tell you the disrespect she
showed him. you know for daddy to tell her face to face that she is a nothir~q and would NEVER'be anything that
she was acting insane and was horrible to him. i have done really bad things in my past but daddy has never
said anything remotely like this to me » so you know how awful she was acting. i know in rriy past i have been
"*horrible** but i have apologized to daddy (and MANY others) for my behavior and i feel such regret and
sadness about what i have done .. Brenda on the other hand does not feel any regret, just an EVER
INCREASING SENSE OF ENTITLEMENT. you can ony do for a person for so long and then it's their
responsibility to step up and do for themselves .. i am done doing for her. i don't feel we are obligated to share
with her what she has not earned. while she naps it's you and i who stress .. when i talked to daddy tonight he
completely understood my feelings/thoughts and supports/agrees with us in giving her 26k and sCndirxl her on
her way .. she will contribute nothing, not financially, not emotionally and not physically .. SHE IS A PARASITE
AND WE ARE HER HOST.
i made a conscience choice to change in many ways .. it was a struggle. i took a cold hard look at myself and
my multitude of flaws. i searched my soul for the reasons of why i became that way. many of my issues were
related to childhood but as an adult i should have known better, i can't blame arty of my mistakes, as an adult,
on anyone but myself. i worked hard to right the wrongs „especially with daddy. earning his love and respect
mattered to me and i had to literally EARN his trust. it took years and years to build the trust he gives me now
.. it was all very worth it .. now, i have a dad. I'm not perfect and will never be but i know he respects me for
who i am as a person and completely trusts rrie. that is priceless .. but on the flip side of changing my ways »
i refuse to back down and let anyone (including our sister) use me. that is exactly what she is doing to ~. she
knows you are supplying the money to make repairs, you supplied the trucks to move things, arranged for
george to remove the steel .. she knows i arranged for rriy friends to work and save money by not hiring
professionals (altho their work is just as good.) she knows I'm over there working with a back injury, she knows i
I of 2 ' I 4/26/2012 9:56 AM
have a house full of animals to take care of and I'm at the estate so much that my house is a freakin fur ball
because I'm not here to clean as usual, she knows I'm busy there and still trying to take care of daddy (she
hasn't offered once to help him or mom thru this or any other illness) =parasite.
?oft 4/26/2012 9:56 AM
LAW OFFICE OF MARC ROBERTS
149 East Market Street
York, Pennsy/vania 17401
April 18, 2011
David A. Baric, Esquire
BARK SCHERER
19 West South Street
Carlisle, PA 17013
Re: Estate of Marlin L. Marsh
Dear Mr. Baric:
Marc Roberts, Esquire
Sarah E. Buhite, Esquire
Te%phmne (7171 843-1639
Facsimi/e (7171 845-8700
Thank you for your letter of March 29, 2011. First, let me clarify
what I understand Judy Estill's position to be on any interest she
has in the real estate. Judy has informed me that, as of this
time, she has never specified any amount that she would be'willing
to pay for the real property, although she has stated that if she
were to buy it, she would offer significantly higher than the
$84,000 that was offered by Charles, Dorothy, and Susan. Although
she may be willing to present an offer, Judy also acknowledges that
a member of the public may be willing to pay more than family
members, and she feels that it is in the best interests of all
parties involved, and particularly Brenda Slaybaugh, if the
property is presented for public auction. Doing this would avoid
the conflicts that are apparently present when a fiduciary seeks to
purchase estate real estate privately, and would eliminate the
difficulties of presenting competing contracts between Judy and
Charles, Dorothy and Susan.
I am providing an accounting that has been supplied to me by Judy
of the financial activity of the estate. .With regard to your
particular concern about antique coins, I can tell you that the
coins that have been sold were disposed of with the assistance of
John Freet, a retired certified public accountant, and
knowledgeable coin collector. His separate accounting for the
coins is also provided. A second sheet references some other
military items that were sold. To my knowledge, Judy has done
nothing in her activities as a co-executor that she did not believe
in good faith was satisfactory to Susan. She will, however, take
note of your concern in your letter of March 29, and will only act
from this point forward with complete concurrence with Susan or by
order of court.
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sue kuhn <suzzie38@gmail.com>
Letter of intent
1 message
Sue Kuhn <suaie38~gmail.com> Mon, May 30, 2011 at 11:10 PM
To: jtxiyestill@comcast.net
Judy,
The estate needs settled and I'm sending you this letter to inform you of what i would like to do about this
situation.
I'd like to hire Daddy, Freddy and Rich at a rate of $10/per hour to get the contents of the estate ready for
public auction. Since we can not come to an agreement, I feel the property should also be sold at this auction.
The 2011 taxes need paid. Since you have taken all the checks to the estates account are you planning on
paying these? If not, please let me know and I will pay them.
I of 1
4/26/2012 9:45 AM
sue kuhn <suaie38~gmail,com>
Cease and desist ,
4 messages
Judy Estill <judyestill~comcast.net> Fri, Jun 3, 2011 at 9:38 PM
To: Sue Kuhn <suaie38(i~gmail.com>, rtslaybaugh@gmail.com, marc Roberts <Marc@marcrobertslaw.com>
Susan,
RE: Cease and desist
It has been brought to the attention of Brenda and myself that you and and/or someone under your direction has
been at the estate doing landscaping/brush removal and other events.
We are not performing any additional improvements or rehabiliation to this estate without the written elusive
agreement of Brenda, myself and you.
Several days ago, a letter was mailed to your attention with several outstanding issues and subsequently no
further improvement and/or changes should be made to this estate until the items in that correspondence are
answered and addressed by Brenda and myself.
This includes but is not limited to the friring of any people.
Judy
EXHIBIT
____. _. __... ___.. _. -__1
Sue Kuhn <suzrre38(dl9mail.com> Sat, Jun 4, 2011 at 12:31 AM
To: Judy Estill <judyesti0@comcast.net>
Why yes Judy, there is clean up happening at the estate. Daddy is doing it for FREE because it is a FIRE
HAZARD and it increases the value of the estate when it is sold. The debris/leaves/brush located against the
house is an extreme fire hazard and the removal of this brush benefited the estate due to safety AND increases
the value... Do you have a problem with work being done for FREE that benefds the value of the estate and
removes a fire hazard? .. if so, why?? The FREE work done to the yours and
1 of 3
4/26/2012 9:24 AM
_ _ ~_
my own interests in this property, it benefded all of us. Were you planning on removing this fire hazard? Other
than the free clean up what specifically do you mean when you write 'other events'? For there haven't been any
'other events'.
I also need to inform you for safety reasons that while you, Brenda, or any other persons are at the estate are
with you „ do NOT drink the water. It's highly contaminated and has high levels of lead. Also, you may have
noted that I vented the basement via the well casing. Under the vent is wire to prevent animals etc. from
entering. This also is due to safety reasons. The radon in the basement is at EXTREME levels and venting it
allows it's release out of the basement, this prevents it from being breathed by persons while in the basement. I
wouldn't want anyone getting sick.
If you have objections to the hiring of people to prepare the estate for sale, do you and Brenda have plans on
helping to do the work so we don't have to hire people? Hence, the estate needs settled and we are running out
of time. If you have objections to the hiring of people I'd love to hear your thoughts on a *cheaper* way to
achieve this.
I got the notice today there is a letter to pick up. I won't be able to get it until Monday due to previous plans but
I would appreciate it ff you could forward it to me asap via my gmail account and we can resolve this issue via
the computer with less waste of time. Time is of the essence. Could you also forvvard me the appraisals for all
items you have have sold? Why wasn't 1 consulted/noted of the appraisals before items were sold without my
consent? I have consulted you regarding even minor details regarding the estate and I would have appreciated if
you would have had the courtesy to do the same as these items were 113 mine.
Did you hire persons to cut the grass? If so, why wasn't I notified of this? If so, at what cost is this service being
performed? Could you also send me copies of the estimates from the corr~anies you consulted to do this work?
In previous lawyer correspondence I was told I WOULD definitely be consuRed before things were done at the
estate. I held to this agreement and haven't hired anyone. I sent you a letter and an identical email.(see below)
and 1 did nothing because I haven't heard from you until this point in time. 1 have held to that agreement and
nothing has been done on my part without your knowledge/approval.:) If you hired persons to do this why was I
not contacted as agreed? If this work was done without cost to the estate then thank you.
Billy has paid for the vehicle that bebrged to Short. I'd like to know when you are available to sign the title over
to him? As stated in my previous email to you, I'd like to sign the bond at the same time. I sent you a text
regarding this issue March 18, 2011 but have got no response until this time. I would like to be able to finally
git~ Billy a date and time we can sign this over to him. Please let me know when you are available to meet Biiy
and I at Sollenbergers Messenger Service. I think Sollenbergers is a good choice because it's located in
Cumberland County where the estate is located. Evenings would work best due to BAlys work schedule.
As a reminder, not only was the garage uNocked but a light is currently on in the basement. When I was at the
estate and discovered the unlocked garage it was during the day and I did not go into the basement. Since it
was daytime I did not see the light was on. Daddy did not have a key to the home and could not turn off the light
off today. Would you like to tum the light off tomorrow or would you prefer I turn it off? Could you please also
inform Brenda to lock doors and make sure all lights are off before leaving the property? ..
Thanks and I'll be checking my email waiting to hear back from you. Have a nice night.:)
[Quoted text hidden]
Sue Kuhn <suzzie38t~gmail.com>
To: suzzie38~yahoo.com
Sat, Jun 4, 2011 at 12:57 AM
[Quoted text hidden]
Sue Kuhn <suaie38~gmail.com>
To: Judy Estill <judyestiil@comcast.net>
Sun, Jun 5, 2011 at 11:50 PM
'. of 3 4/26/2012 9:24 AM
__ _ _ _
Are you planning to cooperate at all? I try to contact you and every time I get MO response from you. This
estate needs settled (we are running out of time) and it is your obligation to assist in this matter. Is there a
reason you are making this so difficult? .. I would absolutely appreciate your assistance. I'm willing to work with
you. I try to communicate but you ignore me and I get no response back from you. Can you please respond
back so we can make a plan on settling this estate? I have been trying since March to get a response from you.
[Quoted text hidden]
3 of 3 4/26/2012 9:24 AM
- _ ,
-----L ri Q! na I`9 C ssa ~=----
. From: sue Kuhn ~mailtc~:
Sent: Sunday, June 19, ZOli 10:03 PM
To: Linda Parrish
Subject: Re: Meeting Marsh Lsta,e
I expect a PRIVATE conversation that is held 'in person' between myself, Marc and Judy. This estate
needs to be a PRIORITY. I have stated over and over that time is of the essence. From my
understanding Judy does not leave for Florida until Monday 6/20 so why was this meeting not held last
week? I was available to attend any day at any time. What do I have to do to get results? I am frustrated with
her noncompliance and total lack of communication. If this meeting is not held this week IN PERSON I will be
forced to take further action for there is no more time to waste. I would like this settled amicably, in a time
efficient manner, but unfortunately, that is not happening. I have spent hundreds of hours at the estate breathing
in extreme levels of radon, drinking contaminated water, aril giving 100% trying to get this estate settled as she
continualy goes to Flordia. I have went above and beyond to save this estate money. I expect Judy being
co--executrix to do the same. Her continual delays in communication have been happening for three months and
her actions have cost the estate money. This needs addressed now. I would like to speak with Marc via phone. I
will be available to speak with him tomorrow. My home phone is 717 243 2837 or cell
As far as the lawn > ARhough I asked, I was never given any answers. First, I'd like to see the estimates ftom
the companies Judy consulted to mow the lawn. I STILL do not know who she Fred or at what cost to the
estate? Did she sign a contract with this unknown company? Knowing the financial cost to the estate will
determine whether or not my father will take on the responsibility. If he does choose to take on this responsibility
I will not allow him to buy the gas for the mower That cost should come out of estate funds. Additionally, I'd like
Judy to send me checks so I can pay the taxes BEFORE they go into penalty value. Penalty value will cost the
estate addRional money which is UNNECESSARY.
IQuaed text Hidden]
Man; Roberts <Marc~marcrobertslaw.com> Tue, Jun 21, 2011 at 9:59 AM
To: Sue Kuhn <suaie38@gmail.com>
Cc: Linda Parrish <Linda~marcrobertslaw.com>
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i of 5
12 9:26 AM
.. .
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-----Original Message-----
~ram: Sue Kuhn [maiito:
Sent: Monday, June 20, 20118:49 PM
To: Marc Roberts
Subject: Re: f=W: Meeting Marsh Estate
Anon-private phone call is not satisfactory. I'm still waiting for the information about the lawn
and taxes.
4 of 5
lo~ea ~ -~denl
Sue Kuhn <suaie38(~gmail.com>
To: Marc Roberts <Marc~marcrobertslaw.com>
Tue, Jun 21, 2011 at 9:45 PM
judy wrote me another one of her letters .. the issues she brought up in previous emails i was going to address
in person via the meeting at yore office. i was e~eding the meeting to be held quickly, without delay, and wasn't
informed she was planning on going out of town again. it would be nice if things could be worked out but judy
dcesn't want to corrmumcate and discuss issues, instead she would like to dictate with no compromise or not
inform me at all.
judy and i worked well together when we first started settling the estate and she repeated stated what a good
job i did at the estate. it wasn't until she was in the room when my parents changed their wills that she became
so utterly impossible and completely stopped communicating with n>e. after the wills were changed, she caused
so much drama and conflict in the family due to her knowledge of the changes in the wills (which she shared with
ALL family members) and my parents were shown such hatred and utter disrespect that mom and daddy made
a choice to disown and disinherit both judy and Brenda. I'm afraid she's letting her personal issues with our
parents affect settling the estate. she needs to real¢e that i do not ~ntrol my parents finances, thoughts or
choices and to be angry at me for their decisions makes no sense. the marsh estate is so small and should be
super easy to settle. i wish with all my heart that she would commurrcate with me so we could settle this with
ease.
marc, I'd like to know exactly what you are charging to represent the estate. i haven't even been given that
information and i asked her months ago about your fee. I'm not sure why she feels she doesn't have to inform
me of these details. i would also like to see all financial records, receipts, and appraisals if you could get judy to
please send me a copy of those.
i choose to meet privately due to the interference of third parties=from persons who have no interest in this
EXHIBIT
4/26/2012 9:26 AM
_.. _ _ _ -r
estate adding their opinions and causing further conflict .. hence, that is why i would like a private 'in person'
meeting. I'm available at any time to meet when she returns to PA. please give me a 2 day notice of the date
and time.
i have no problem with the estate and remaining property, at the residence, being auctioned BUT I'd like to know
the specks such as but no limited to: is the auction company going to box the items in the garage and° house or
is that something we must do? if it is our responsibility to box these things please let me know. additionally, is
the auction company going to be moving the heavy things down from the second story of the garage?
i will make you a complete list of questions i have and will send it to you in the next few days.
have a nice day :)
lo~oced tea niddeni
Sue Kuhn <suaie38t~gmail.com>
To: Marc Roberts <Marc(c~marcrobertslaw.com>
Tue, Dec 6, 2011 at 4:23 PM
Mark, Did Judy shut off the electric at the estate? All the neighbors lights are on but the estate has NO electric
and there is a yellow tag on the box? .. I need to know immediately due to pipes freezing etc. And IF she did
were you aware of this?
lo~aea text ni~en]
i of 5 4/26/2012 9:26 AM
Judy
,~
TQ:
Sent: Friday, July 1, 2011 10:34:50 PM
Subject: Re: Meeting
[Quoted text hidden]
[Quoted text hidden]
Sue Kuhn <st~ie38 c~Dgmail.com> Tue, Jul 5, 2011 at 11:06 AM
To: judyestill@comcast.aet
I will be forwarding all information to Baric. I don't knowrf a meeting will be necessary, that will tie up to him. I'm
sure you'll hear from him shortly. Have a nice day.
[Quoted mad hidden]
3 of 3
4/26/2012 9:54 AM
AUCTION OF REAL ESTATE
OF
ESTATE OF MARLIN L. MARSH
November. 26, 2011
CONDITIONS OF SALE ,,
«.
1. This sale is made by Judy Ann Estill and Susan Ann Kuhn, Co-
Administrators of the ESTATE OF MARLIN L. MARSH.
2. The real estate being sold is known as 340 Oxford Road, South
Middleton Township, Cumberland County, Gardners, Pennsylvania
13324 (L'Pi i,Jo. 4G-40-2654-021} and is described as ap~~sears in
Appendix "A." The Seller's deed of conveyance shall be based
upon. this legal description. Any survey of the property
required by the Buyer shall be solely at the Buyer's expense.
3. This sale is made with reserve. Unless it is announced by the
auctioneer that the property will be sold absolutely on this
date, the Seller reserves the right to reject any and all
bids. The Seller also reserves the right to specify the
incremental amount of each successive bid. Upon the
auctioneer's announcement that the reserve has been removed,
at the conclusion of bidding, the highest bidder shall be
deemed to have purchased the property.
4. Seller warrants that the title shall be free and clear of all
liens and encumbrances and that title is good and marketable,
excepting only existing ;building restrictions, easements, and
other like matters of record:
5. The following expenses of the property shall be prorated as of
the'date of settlement: ,.
County and Township/calendar year basis;
School taxes/fiscal year basis;
Municipal Refuse charges, if any, as billed.
6. The cost of State and Local Transfer Taxes shall be divided
equally, 1~ to Seller and 1~ to Buyer.
7. Ten (10~) percent of the purchase price shall be paid in the
form of cash or approved check on this date. in the event of
a def cult by the Buyer in the performance of the contract to
buy the property, this down payment shall be non-refundable.
e. Seller agrees to execute and deliver a special warranty deed
to the property upon payment of the balance of the sales price
on the date of settlement.
' ~ .,
IT IS HEREBY AGREED BY AND BETWEEN Judy Ann Estill and Susan
Ann Kuhn, Co-Administrators of the ESTATE OF MARLIN L. MARSH,
er referred to as "Seller", and
Telephone
hereinafter referred to as "Buyer," that the Buyer has agreed to
buv and Seller has agreed to sell the property described in
_ ~
Appendix "A" for the sum of:
Dollars ($ ~~Oc~1
The attached "Conditions of Sale" shall be the tern~s.of this
agreement, to be cbserved and fulfilled. by the parties in all
respects.
On this. date, ten (10~) pereenb of~that sumo
-~- / G ~'-„'`,.~ l~~'`"~ Dollars ($~S~J~"~ ,
has been paid to £he Seller in partial payment of this. purchase,
INTENDING TO BE LEGALLY BOUND HEREBY, we have hereunto set our
hands and seals on November 26, 2011.
f ~ ~ ~~ ~- ~
pia
ESTILL, Co-Administrator„ BUYER
SAN ANN KUHN, Co-Administrator,
SELLER
<--eJ `~~...~-,
BUYER
BUYER'S ATTORNEY:
Name(s) ~/as desi#ed on deed)
n ~ r
Apvendix "A"
ALL that certain tract of land situate in SOUTH MIDDLETON TOWNSHIP,
County of Cumberland and State of Pennsylvania, bounded and
described as follows:
BEGINNING at a point in a public road which point is also a corner
of land now or formerly of Eugene Marsh; thence along land now or
formerly of the said Eugene Marsh South 69 degrees East, a distance
of 217..7 feet to an iron pin; thence along land now or formerly of
Calvin. G. Cook and Alice K. Cook, husband and wife, South 22
degrees 45 minutes East, a distance of 123.0 feet to an iron pin;
thence by the same South"23 degrees 15 minutes West, a distance of
347.0 feet to an iron pin; thence by the same and lard now or
formerly of William J'. McCartney and Alice McCartney,"~:u'~band and
wife, North 69 degrees West, a distance of 310.4 feet to a point in
the center of the said public road; thence along the center of said
public road North 23 degrees 15 minutes East, a distance of 430.0
feet to a point, the place of BEGINNING.
BEING improved with a one-story detached single family dwelling
known and numbered as 340 Oxford Road, Gardners, Pennsylvania.
IT BEING the same premises which Ronald E. Marsh, Executor of the
Kathleen N:. Brandt Estate, deceased, and Ronald E. Marsh and Robert'
V. Marst:, residuary beneficiaries of the Estate of Kathleen M.
Brandt, by their deed dated May 17, 2005, and recorded in the
Office of the Recorder of Deeds of Cumberland County, Pennsylvania,
in Record Book 268, passe 4585, granted and conveyed unto Marlin L.
Marsh, single man, who died seized thereof.
,.
__ _
marlin marsh estate
1 message
Sue Kuhn <suaie38~gmail.com>
To: Marc Roberts <marc@marcrobertslaw.com>
sue kuhn <suzzie38@gmail.com>
Sat, Dec 17, 2011 at 1:07 PM
Judy confirmed the electriGheat is on with no damage but there is no mention of her correcting her previous
actions. No actions were taken to air out the house to reduce the extreme excess moisture. No actions were
taken to reduce the extreme humidity with a dehumidifier. Hence, where has any damage control or remedy
actions been taken? Her examination of the property and so called repair have been very incomplete. Due to her
unilateral actions (intentional?) the property is not of the condition the day of the sale. Due to this situation,
caused solely by Judy, the buyers have chosen to terminate the purchase the real property, of the estate.
The day of sale the ony agreement signed was settlement in 30 days. There was no responsibility given to the
buyers to take over the electric or be responsible for the property. As co-administrator, I took it upon myself to
see that debris from the sale and FIRE HAZARDS were cleaned up. I have solely and consistently been
monitoring the estate to eliminate fire hazards since Mr. Marsh's death in 2010. It was due to my routine
inspections of the property that I noticed the electric was shut-off. Immediatey, I sent Judy and you both
text/email regarding this situation..) heard back from neither of you! Hence, the decision of shutting off the
electric was a decision made solely, with NO notification, by Judy and provisrons to provide damage control are
solely Judy's responsibility. 1 will take NO responsibility for her independent rogue actions. Was Judy was taking
adverse positions against the property? As co-administrator, I am hghly concerned with this unnecessary
deterioration of the property. I am bringing it to your attention because you are also to be my representative to
settle and protect this estate.
In the mean time, the property is sustaining additional deterioration due to no action being taken to correct
Judy's decision to shut off the electric with NO notification to myself, the Yana's or Attorney Banc. May I remind
you, In Judy's email from June 21 Judy clearly states there was NOTHING to be done to the property without
the written consent of herself, Brenda and I. It seems she chooses for her policies only apply to me, and not to
herself, as she blatantly continues to act disrespectfully and chooses NOT to notify me of her actions/intentions.
When does Judy become accountable and held to her own words(That nothing be done without the written
consent of myself, her and Brenda?) When does Judy become responsible for her own actions? Judy has
chosen to act in rogue manner and has put the estate in jeopardy! I am bringing this to your attention because
you are also to be my representatnre to settle and protect this estate.
Judy wants me removed as co-administrator? LoL My question is who is at fault in this situation? I was not
notified, as usual. Why should I be punished for Judy's actions? I have never done anything to put the estate in
jeopardy, nor would 1. I HAVE CLEARLY AND REPEATEDLY DONE ALL I CAN TO PRESERVE AND
PROTECT THE ESTATE AND ITS VALUE! This, Sir, I can easily prove thru photos and eyewitness accounts=all
I have done to consistently take care of this property, which benefitted not only myself but also benefitted Judy
and Brenda.
Due to conflict of interest Mr. Baric has declined to represent me. I have sought council and would appreciate
your cooperation, on my behalf, to allow my new attorney time to familiarize himseff with the Marlin Marsh
Estate. I will proceed further on the advice on my newly acquired council.
Mr Roberts, let me close by asking you questions that I have previousty asked you and you have chosen NOT to
answer. Sir, I feel I have every right to have a answer to these questions. I feel you are obligated to respond!
1 • I have asked you what you are charging to represent this estate and was never given an answer by you. I
l of 2
4/26/2012 9:32 AM
__
__
have asked you verbally and thru email.
So, I'm asking you again for the third time. What are you charging to represent the estate? Additionally, I'd
like to inquire about what you have charged the estate to date?
2'Additionally, while I'm asking you pertinent questions, I'd like to ask you AGAIN if you were aware that Judy
was shutting off the electric, on Nov 28,
2011 (d19am, WITHOUT not'rfyirg myself, the Yana's or Mr. Baric? °
of 2 4/26/2012 9:32 AM
~ • P
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Attorneys-at-Law
SCHERER
David A. Baric
Michael A. Scherer
Tricia D. Naylor
Bret P. Shaffer
Marc Roberts, Esquire
149 East Market Street
York, Pennsylvania 17401
RE: Estate of Mazlin L. Mazsh
Dear Mr. Roberts:
19 West South Street
Carlisle, Peiulsylvania 17013
(717) 249-6873
(717) 249-5755 -Fax
dbaricQbaricscherer.com
Mazch 29, 2011
I have received and reviewed your correspondence of March 18, 2011 regarding the
above matter.
It is my understanding that subsequent to your correspondence, Ms. Estill represented that
she was willing to purchase the real property of the estate for the sum of $160,000.00 in its
present condition. Please confirm that representation to me in writing. Susan Kuhn has
authorized me to accept such an offer from Ms. Estill for the estate real property.
I would ask that you instruct Ms. Estill to cease and desist from any further actions
relating to the administration of this estate absent the involvement and concurrence in each and
every act of administration by Ms. Kuhn. It is my understanding your client has collected and,
apparently, sold various items of personalty of the estate to include, but not be limited to, antique
coins. Please provide me with an accounting of all transactions undertaken by Ms. Estill
involving any property, real, personal or mixed of the estate.
Please be advised Ms. Kuhn objects to having any auctioneer remove personalty from the
real property of the estate to conduct an auction. Such action would result in an auction fee of
approximately thirty-five (35%) percent. An auction held at the real property would, conversely,
result in a fee of less than ten (10%) percent.
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NUM6ER Oft
CODE
DATE
TRANSACTION DESCRIPTION PAYMENt, FEE.
WNHpRAWAL (-I
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Judv $ Funded to Estate
Amount paitl Amount
from Jutly's Deposltetl
Personal funds to Jutly's
Personal funds
57 034 00 01/0511 t Check #189 hom Judy personal account ~ Ron gave me 56090 in cash (see below)
remaming funeral expanses
86,090.00 01/05111 Cash receivetl tram Ron Marsh - ne fauntl at estate
81.000.00 01/08!11 Cash to Susan for supPhesrwork pedormed by her fnends
850.72 01/08!11 Cleaning supplies
5675.00 01/10/11 Riehartl Nestor - Fumaee repair check #190
5138.76 Otl1 I/11 Eiectnc bill check #191
534.45 Ot/t 1111 Cumbertantl Valley Pam Managemem check #t 93
8425.00 Ot/11/1 t Dumpsler from RT Carey Trucking check #194
Ray 25&1400 two week rental delrveretl on 1-10-11
51,000.00 01!30/11 Poppy -check #201 from Judy peroonal account to reimburse Charles Yana for rash gwen to Suzzy
while Jutly was m Flontla
51.000.00 O7/31/11 Checc #201 from Jutly personal account to Susan for suppkes/work peAOrtnetl oy Susan's fnends
5700.00 01/25/11 Ricky Slonebreaker Check #196
53.542.21 02/0211 t Check from estate (o Judy to reunburse for funtlmg
830.51 02/23/11 Keys far estate for Brenda
$6,028.58 03/09/11 deposdetl check to my personal aeeoum for silver toms - needetl to pay (or lomhstone
E400.00 03/14!11 military items soltl
82.383.00 03/09/11 Silbaugh menwnal for tombstone check 71210
St 207.16 03/11/11 Charles Yana rhedc from my personal account to reimburse for tax lean
8548.00 02!26!11 Cash retumetl to Jutly hom Susan at estate meeting
561 ~ 70 04/12/11 Deposited by Jutly to estate as balance due from Judy
53! 9 45 06/09/11 Remaining baWnce paid to estate to complete the final personal funtling/reimbursemenl by Jutly
815 678 fi0 815.678.60
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LAW OFFICE OF MARC ROBERTS Marc Roberts, Esquire
Sarah E. Buhife, Esquire
Kathryn Nonas-Hunter, Esquire
149 East Market Sveet
York, Pennsy/vania 17407
December 16, 2011
Office of the Register of Wills
Cumberland County Court House
One Court House Square
Carlisle, PA 17013
Re: Estate of Marlin L. Marsh
Dear Ladies:
Te%phone (777) 843-7639
Facsimr7e (777) 845-8700
`~ ~~,
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~~~
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Please file the enclosed Petition for Removal of Susan Ann Kuhn as
Co-Administrator. Also enclosed is the $15 filing fee.
By this letter, I wish to advise the Court that my client, Judy Ann
Estill, will be out of state from December 16, 2011, through
January 2, 2012, January 18 through January 30, 2012, and February
10 through February 21, 2012. I would appreciate your noting these
times when my client will not be available for a hearing. Your
cooperation in this regard is greatly appreciated.
Should you require anything further, please feel free to give me a
call.
Sincerely,
Marc Roberts
dasl
Encls.
cc: Susan Ann Kuhn w/encl.
Brenda Sue Slaybaugh w/encl.
~ .
`~
sue kuhn <suzzie38~gmail.corr~
Meeting Marsh Estate
6 messages
Linda Parrish <Linda(c~marcrobertslaw.com>
To: Suaie38@gmail.com
Susan:
Thu, Jun 16, 2011 at 4:29 PM
I called Judy after I left you a voice mail message and tried to establish a date and time for a meeting. She is
out of town and will not be available until July 5 or July 6. She would prefer a morning appointment. I would
suggest 1rtednesday, Jury 6~' at 9:00 a.m. Will that suit your schedule? Marc would like the two of you to
submit a list of points for discussion to him a day or two prior to the meeting and that will be the agenda for the
meeting. Please let me know if this date and time will work for you. Thanks.
Linda Parrish
Law Office of Marc Roberts
149 East Market Street
York, PA 17401
Phone
Fax
_ _
_ _ ..
_ _
..._ ............................... .
Linda Parrish <Linda@marcrobertslaw.com> Fri, Jun 17, 2011 at 9:56 AM
To: Sue Kuhn <suaie38~gmail.com>
Cc: Marc Roberts <Marc~marcrobertslaw.com>
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l of 5
4/26/2012 9:26 AM
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AND NOW, this lst day of June, 2012, I, Shannon Freeman, of Abom & Kutulakis,
L.L.P., hereby certify that I did serve a true and correct copy of the foregoing Petition To
Remove Judy Ann Estill as Co-Administrator by depositing, or causing to be deposited,
same in the United States Mail, postage prepaid addressed to the following:
Marc Roberts, Esquire
149 East Market Street
York, PA 17401
Attorney for Judy Ann Ertill
AND
Brenda Sue Slaybaugh
8 Thornhill Court
Carlisle, PA 17015
,`
neon Freema
_.
ABOM ~"
TLILAKIS
Jason P. Kutulakis, Esquire
Attorney I.D. #: 80411
2 West High Street
Carlisle, Pr1 17013
(717) 249-0900
IN RE ESTATE OF
IN THE COURT OF COMMON PLEAS
CUMBERLAND COUNTY, PENNSYLVANIA
MARLIN L. MARSH
a/k/a MARLIN LEROY MARSH : NO. 21-11-68
late of South Middleton Township
Cumberland County, Pennsylvania
deceased
ORPHANS' COURT DIVISION
TO: Judy Ann Estill
c/o Mazc Roberts, Esquire
149 East Mazket Street
York, PA 17401
YOU HAVE BEEN SUED IN COURT. If you wish to defend against the claims set forth
in the following pages, you must take action within twenty (20) days after this Petition and Notice
are served, by entering a written appearance personally or by attorney and filing in writing with the
Court your defenses or objections to the claims set forth against you. You are warned that if you fail
to do so the case may proceed without you and a judgment may be entered against you by the Court
without further notice for any money claimed in the Complaint or for any other claim or relief
requested by the Plaintiff. You may lose money or property or other rights important to you.
YOU SHOULD TAKE THIS PAPER TO YOUR LAWYER AT ONCE. IF YOU DO
NOT HAVE A LAWYER, GO TO OR TELEPHONE THE OFFICE SET FORTH BELOW.
THIS OFFICE CAN PROVIDE YOU WITH INFORMATION ABOUT HIRING A LAWYER
IF YOU CANNOT AFFORD TO HIRE A LAWYER, THIS OFFICE MAYBE ABLE TO
_ _ __ _
__
PROVIDE YOU WITH INFORMATION ABOUT AGENCIES THAT MAY OFFER LEGAL
SERVICES TO ELIGIBLE PERSONS AT A REDUCED FEE OR NO FEE.
Pennsylvania Bar Association
Lawyer Referral Service
1-800-692-7375 (PA ONLY)
or 717-238-6715
Respectfully Submitted,
Date: June 1, 2012
ABOM & %UTULASIS, LLP
GC~
Jason P. Kutulakis, s
Attorney ID # 80411
2 West High Street
Carlisle, PA 17013
(717) 249-0900
Attorney for Sucan Kuhn