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Home My WebLink About07-09-12 ~-. } L:-., ~7~ y'~- Q f V 4. -iJ i"~~ l ' , ~ J V •".. _ ~ r~9 ~r e ~ ~ ~ Ronald L. Finck, Esquire ~ ~ «" ~ ~ L~ ~~ Supreme Court ID No. 89985 ~ ~ Mette, Evans & Woodside 3401 North Front Street P.O. BOX 5950 Harrisburg, PA 17110-0950 717-232-5000 rlfinck@mette.com Attorneys for Petitioner Richard J. Maniglia 1N RE: AGREEMENT OF TRUST OF IN THE COURT OF COMMON PLEAS OF ROSARIO J. MANIGLIA, DECEASED CUMBERLAND COUNTY, PENNSYLVANIA, ORPHANS' COURT DIVISION N0.21-10-0568 MOTION SEEKING TO MAKE RULE ABSOLUTE AND THE ENTRY OF AN ORDER APPOINTING SUCCESSOR TRUSTEE The Petitioner, Richard J. Maniglia (the "Petitioner"), files this Motion Seeking to Make Rule Absolute and the Entry of an Order Appointing Successor Trustee, as follows: On May 22, 2012, Petitioner filed a Petition for Appointment of Successor Trustee and attached signed Consents from all remainder beneficiaries but for Drexel University School of Medicine ("Drexel") and the American Red Cross of the Susquehanna Valley ("Red Cross"). 2. On May 23, 2012, The Honorable M. L. Ebert, Jr., issued a Rule to Show Cause on Drexel and the Red Cross directing Drexel and the Red Cross to show cause why Petitioner should not be appointed Successor Trustee. 3. The Rule was returnable on or before June 14, 2012. 4. The Petitioner served the Rule of May 23, 2012 upon Drexel and the Red Cross by certified mail, return receipt requested on May 25, 2012. 5. Petitioner filed a Proof of Service with the Clerk of Orphan's Court on June 11, 2012. 6. Subsequent to the service of the May 23, 2012 Rule, Petitioner received a signed Consent from Drexel. 7. On June 11, 2012, Petitioner filed a Praecipe with the Clerk of Orphan's Court supplementing the record with Drexel's Consent attached. 8. To date, Petitioner has received no response from the Red Cross. WHEREFORE, Petitioner requests that the Rule be made Absolute and an Order be issued granting the Petitioner's Petition for Appointment of Successor Trustee. Respectfully submitted, METTE, EVANS & WOODSIDE Ronald L. Finck, Esquire Supreme Court ID No. 89985 3401 North Front Street P.O. Box 5950 Harrisburg, PA 17110-0950 (717) 232-5000 -Phone (717) 236-1816 -Fax Attorneys for Petitioner, Richard J. Maniglia Date: July 6, 2012 CERTIFICATE OF SERVICE I hereby certify that I am this day serving a copy of the foregoing document upon the person(s) and in the manner indicated below, which service satisfies the requirements of Permsylvania Rules of Civil Procedure by depositing a copy of same in the United States Mail at Harrisburg, Pennsylvania, with first-class postage, prepaid, as follows: The Estate of Dorothy M. Maniglia c/o Richard J. Maniglia, Executor 1514 Greenlawn Road Paoli, PA 19301 Holy Spirit Hospital 503 N. 21st Street Camp Hill, PA 17011 Drexel University School of Medicine Attn: David Toll 3141 Chestnut Street, Suite 310 Philadelphia, PA 19104 American Red Cross American Red Cross of Susquehanna Valley 430 West Orange Street Lancaster, PA 17603 Catholic Charities of the Diocese of Harrisburg 4800 Union Deposit Road Harrisburg, PA 17111 Edmund G. Myers, Esquire Johnson, Duffie, Stewart & Weidner 301 Market Street Lemoyne, PA 17043 Attorney for Christ United Presbyterian Church and Holy Spirit Hospital Christ United Presbyterian Church a/k/a Allendale Christ Presbyterians Church 421 Deerfield Road Camp Hill, PA 17011 Hospice of Central Pennsylvania 1320 Linglestown Rd. Harrisburg, PA 17110 Pennsylvania Office of Attorney General Charitable Trusts and Organizations Section 14th Floor, Strawberry Square Harrisburg, PA 17120 Respectfully submitted, METTE, EVANS & WOODSIDE Ronald L. Finck, Esquire Sup. Ct. I.D. No. 89985 3401 North Front Street P.O. Box 5950 Harrisburg, PA 17110-0950 (717) 232-5000 -Phone (717) 236-1816 -Fax Attorneys for Petitioner, Richard J. Maniglia Date: July 6, 2012