HomeMy WebLinkAbout08-09-12~ ~~ IN THE COURT OF COMMON PLEAS OF
Estate of Sherman R. Hinkley CUMBERLAND COUNTY, PENNSYLVANIA
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PETITION TO COMPEL ~
INVENTORY AND ACCOUNTING -,
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NOW, comes Petitioner, HCR ManorCaze, Ina ("ManorCaze"), by and through its
attorneys,~BARIC SCHERER LLC, and files the within Petition to Compel Accounting and, in
support thereof, sets forth the following:
1. HCR ManorCaze, Inc. is an Ohio corporation duly authorized to conduct business
in the Corpmonwealth of Pennsylvania with a business address of 1700 Market Street, Camp
Hill, Cumberland County, Pennsylvania 17011.
2. ' The Decedent, Sherman R. Hinkley, was a resident of the skilled care facility
operated bjy ManorCaze for a period of time prior to his death.
3. During the stay of Decedent at the facility, charges were levied by ManorCaze for
the care provided to Decedent.
4. Despite demand therefore, the Decedent failed and refused to pay for the costs of
his care.
5. ManorCaze has made a demand upon the estate to pay for the costs of care
provided ajnd ManorCaze remains unpaid.
6. ' A personal representative may be cited to file an account at any time by the Court.
20 Pa.C.S.A. §3501.1.
7. More than three (3) months have elapsed since appointment of Monica
Demaziniatio as Executrix and she has not filed an inventory as required by §3301(a) of the
Probate, E3tates and Fiduciaries Code.
WHEREFORE, Petitioner prays this Court issue a citation upon the Respondent requiring
her to file an accounting for the Estate of Sherman R. Hinkley within a date certain.
Respectfully submitted,
BARIC SCHERER L
David A. Baric, Esquire
I.D. 44853
19 West South Street
Carlisle, Pennsylvania 17013
(717)249-6873
VERI ION
I verify that the statements made in the foregoing Petition To Compel Inventory and
Accounting are true and correct to the best of my knowledge, information and belief. I
understand that false statements herein are made subject to the penalties of 18 Pa. C.S. § 4904,
relating to unsworn falsification to authorities.
I
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David A. Baric, Esquire
DATED: August 8, 2012
CERTIFICATE OF SERVICE
I hereby certify that on August q , 2012, I, David A. Baric, Esquire of Baric Scherer
LLC, did serve a copy of the Petition To Compel Inventory and Accounting, by first class U.S.
mail, postage prepaid, to the party listed below, as follows:
Debra Wallet, Esquire
24 North 32nd Street
Camp Hill, Pennsylvania 17 1
David A. Baric, Esquire