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David A. Mills, Esquire PA 37192 ~._.y
BLAKEY, YOST, BUPP & BAUSCH, LLP ~"'
17 East Market Street
York, PA 17401
(717) 845-3674
Attorneys for Petitioner Darlene J Skoloda
1N RE:
ESTATE OF
MARY ELEANOR JOHNS a/k/a
MARY E. JOHNS a/k/a
MARY JOHNS a/k/a
ELEANOR JOHNS a/k/a
ELEANOR M. JOHNS,
Late of Upper Allen Township,
Deceased
IN THE COURT OF COMMON PLEAS OF
:CUMBERLAND COUNTY, PENNSYLVANIA
ORPHANS' COURT DNISION
No. 21-11-0851
REPLY OF DARLENE J. SKOLODA TO NEW MATTER OF
BRINDA J. ALBRIGHT AND CASEY D. HAMILTON
AND NOW, this 12th day of July, 2012, comes Petitioner, Darlene J. Skoloda, by and through
counsel, Blakey, Yost, Bupp & Bausch, LLP, who files this Reply to the New Matter of Brinda J.
Albright and Casey D. Hamilton, as follows:
24. Denied. Eleanor Johns was not competent to execute a will at all times in March,
2011.
25. Denied. Eleanor Johns did not always know the names of the closest members of her
family in March, 2011 and she was persistently confused.
26. Denied. Petitioner, Darlene J. Skoloda, believes that her mother, Eleanor Johns, did
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not deal on equal terms with Brinda Albright, that her sister, Brinda Albright, influenced Eleanor
Johns, and that Eleanor Johns depended on Brinda Albright with whom she was residing when the
will was drawn for her to execute.
27. Denied. Petitioner, Darlene J. Skoloda, clear believes that her mother, Eleanor Johns,
was weakened, mentally, in 2011.
28. Denied. The allegation is a conclusion of law. To the extent facts are averred in this
paragraph, they are denied. Petitioner, Darlene J. Skoloda, clearly believes Brinda Albright unduly
influenced Eleanor Johns.
WHEREFORE, Petitioner, Darlene J. Skoloda, respectfully requests this Honorable Court to
sustain the Appeal from the Decree of the Register of Wills that admitted to probate the document,
dated March 9, 2011, and to open the Decree of the Register of Wills to permit the Register to
receive and act upon a Petition for probate of an earlier writing, dated May 23, 1986, as the will of
Mary Eleanor Johns, a/k/a Mary E. Johns, a/k/a Mary Johns, a/k/a Eleanor Johns, a/k/a Eleanor M.
Johns, deceased.
Respectfully,
Dated: /d~ ~
YOST, BUP & BAUSCH, LLP
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Dav~ A. Nl~lls, Esquii~A 37192
~TEast Market Street
York, PA 17401
(717) 845-3674
Attorneys for Petitioner, Darlene J. Skoloda
2
:, Dt~.P..LENE ,.. SKOLC;ll~,, state upon personal kno~,.~ledge; or i:;fo.~nutio:~ ihat I
believe to be true, that the facts in the REPLY OF DARLEN-E J. SKOLODA TO NEW
MATTER Or BRINDA J. ALBRIGHT AND CASEY D. HAMILTON are true.
I ~,.tnderstand that false statements herein are made subject to the criminal penalties of 18
Pa. C.S. Sec. 4904, relating to unsworn falsificaticn to authorities.
Dated:
A ` ~,_,
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~' DARLENE J.. OLODA
CERTIFICATE OF SERVICE
I, David A. Mills, Esquire, hereby certify that I have served a true and correct copy of the
foregoing REPLY OF DARLENE J. SKOLODA TO NEW MATTER OF BRINDA J.
ALBRIGHT AND CASEY D. HAMILTON by depositing a copy of same in the United States
Mail, regular delivery, postage prepaid as follows:
Daniel L. Sullivan, Esquire
Saidis, Sullivan & Rogers
26 West High Street
Carlisle, PA 17013
Dated: /~ ~ ~~~
BLAKEY, YOST, BUPP 8~ BAUSCH, LLP
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l~v_~A.'Mill~, Esquire x_37192
17 East Market Street
York, PA 17401
(717) 845-3674
Attorney for Petitioner, Darlene J. Skoloda