HomeMy WebLinkAbout10-16-12BEFORE THE REGISTER OF WILLS OF
CUMBERLAND COUNTY, PENNSYLVANIA
IN RE: JAMES LESLIE GRIGGS, DECEASED No.: 21-12- ~ ~ ~ Z
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GUMBERt_AND CO., PA
PETITION FOR CITATION TO SHOW CAUSE WHY LETTERS
OF ADMINISTRATION SHOULD NOT BE ISSUED
AND NOW, this ~ d of October, 2012, comes the Petitioners, Lynn Veinotte and
Stuart Veinotte, husband and wife, by and through their attorney, Shawn P. McLaughlin, Esquire
and Menges & McLaughlin, PC and Petitions this Honorable Court as follows:
1. Petitioners are Lynn Veinotte and Stuart Veinotte, husband and wife, with a current
mailing address of 35 Field Circle, Chambersburg, Pennsylvania 17202.
2. Respondent is Josephine B. Griggs, an adult individual with a current mailing address of
239 Graham Street, Carlisle, Pennsylvania 17013-3718.
3. Upon information and belief, the decedent died Apri13, 2011.
4. Upon information and belief, Josephine B. Griggs, the Respondent, is the surviving
spouse of the decedent.
5. Petitioner was involved in an automobile collision with decedent on or about December
2, 2010.
6. Petitioner initiated a claim against decedent's automobile insurance policy for both
economic and non-economic damages.
7. To date, Petitioners have been unable to reach a settlement of their claims against
decedent with his insurance carrier.
8. Petitioners are creditors of decedent.
9. More than 30 days has lapsed since the decedent's death, and no estate has been opened.
10. The statute of limitations for Petitioners to bring their claim in the civil division runs on
December 2, 2012. Accordingly, time is of the essence in raising an estate for the
decedent.
11. Petitioners do not possess a certified copy of the decedent's death certificate, but are
taking the necessary steps to attempt to obtain a copy of same.
12. Petitioners' undersigned attorney has executed an affidavit of death, indicating the facts
upon which he relies in asserting that decedent is, in fact, deceased. The Affidavit of
Death is attached hereto, incorporated herein by reference, and marked Exhibit "1."
13. Petitioners have completed the standard Petition for Letters of Administration in a form
approved by the Pennsylvania Supreme Court, which is attached hereto, incorporated
herein by reference, and marked Exhibit " 2."
14. Petitioners seek to open an estate for decedent solely for the purposes of engaging in
litigation as described herein above.
WHEREFORE, the Petitioners, Lynn Veinotte and Stuart Veinotte, respectfully requests
this Honorable Court issue a citation directed to Josephine B. Griggs to show cause why
Petitioner should not be appointed Administrator of decedent's estate according to the attached
Petition for Letters of Administration.
Respectfully submitted,
/' MENGES & MCLAUGHLIN, P.C.
Date: ~~ . l t(~ ~ ~ ~--
Shawn P. McLaughlin, Esquire
Sup. Ct. I.D. No. 62737
145 East Market Street
York, PA 17401
Telephone No. (717) 843-8046
smclau~hlin(a?yourla~~~firnzlorlife.com
BEFORE THE REGISTER OF WILLS OF
CUMBERLAND COUNTY, PENNSYLVANIA
IN RE: JAMES LESLIE GRIGGS, DECEASED No.: 21-12-
ATTORNEY AFFIDAVIT
STATE OF PENNSYLVANIA )
SS.
COUNTY OF YORK )
I, Shawn P. McLaughlin, Esquire, being duly sworn according to law, deposes and says
that:
1. The undersigned is the attorney for the Petitioners, Lynn Veinotte and Stuart
Veinotte.
2. The Petitioners wish to pursue a legal claim against James Leslie Griggs, now
deceased, upon information and belief.
3. The decedent's automobile insurance carrier has advised the undersigned that
James Leslie Griggs died.
4. The undersigned undertook certain steps to verify the death of James Leslie
Griggs.
5. Attached hereto, is a copy of the Obituary confirming the death of James Leslie
Griggs, which death occurred on or about Apri13, 2011. See exhibit "A" attached hereto,
incorporated herein by reference.
6. The undersigned also confirmed the decedent's date of death on the Social
Security Administration's Death Index website.
Shawn P. McLaughlin, Esquire
Subscribed and sworn to before me_
this j~~~`' day of October, 2012
Not ~ Public
NOTARIAL SEAL
MICHELLE ORCHARD
Notary Public
YORK CITY, YORK COUNTY
My Commission Expires Jun 21, 2014
James 1•J. Griggs Obitu.a.ry: View Tames Griggs's Obituary 15y Th.e ~Vasb.in.gton. Post Page 1 of 2
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James L. Griggs
Death Notice Guest Book
GRIGGS JAMES LESLIE "LES" GRIGGS James Leslie 4 entries
Griggs, Colonel, United States Army (Retired), of Carlisle, PA 'My dee~asr condolences ro nil
passed away in Philadelphia on Sunday, April 3, 2011 in Les;(cunilyllknewLes...^
surrounded by family. Colonel Griggs was born on November _blichaeiPhetp.
14, 1937 in Bennettsville, SC to James Lonnie and Nannie
Gilliland Griggs. He graduated from Bennettsville High
School and Wofford College before entering the United Tne Guesr Book is expired.
States Army as a second lieutenant in November 1959.
Colonel Griggs spent most of his military career as a military {2estore the Guest Book
intelligence officer and foreign area specialist. During his
active duty service, Colonel Griggs received a Masters
degree in Slavic Studies from the University of Kansas, and
also graduated from the Armed Forces Staff College and the National War College. His
overseas service included several tours of duty in Europe and two years with US Army units in
Vietnam. Colonel Griggs commanded the 8th Psychological Operations Battalion at Fort Bragg,
survived three tours of duty on the Army Staff in the Pentagon, and also served with the
Defense Intelligence Agency. He closed out his active duty service by serving as the Director of
Soviet Studies at the US Army War College and, finally, as the United States Defense and
Army Attache in Poland in 1985 and 1986. Colonel Griggs retired from active duty on
September 1, 1986. Following his military retirement, Colonel Griggs accepted a position as a
military analyst in the Central Intelligence Agency's Directorate of Intelligence. He served with
the CIA in several analytical and management positions until his retirement in August 2000. His
final service with the CIA was as the Director of Central Intelligence Representative to the
United States Army War College in Carlisle, Pennsylvania. Following his retirement from the
CIA, Colonel Griggs received the Distinguished Career Intelligence Medal for his service to the
Agency. Colonel Griggs often recollected that the two highlights of his CIA career were his
tenure as chief of the military branch of the Balkans Task Force, which afforded him the
opportunity to work with and mentor some of the most lalen#ed young military analysts at the
CIA; and his work with Colonel Ryszard Kuklinski, a Polish General Staff officer who worked
covertly for the Central Intelligence Agency during the Cold War providing Soviet war plans and
other vital information that would have helped NATO defeat the Warsaw Pact if war were to
have broken out. Colonel Kuklinski and his wife Joanna became two of Colonel Griggs's
closest friends, and were godparents to his son Fred. Colonel Griggs received a heart
transplant at Hahnemann University Hospital in Philadelphia in February 2006 after another
transplant center had given up on him because his medical case was so complex, Everyone
who knew Colonel Griggs is grateful to the medical professionals at Hahnemann whose skill
and devotion gave us more time with him. Colonel Griygs is survived by his wife, Josephine
Bohan Griggs, their beloved children Fred and Annie (at home), and his children from his first
marriage to the former Sara Frances Cockfield: Jim and his wife Mary (Broad Run, VA),
Melynda and her daughter Emily (Fairfax, VA). Colonel Griggs was preceded in death by
Charlotte Anne, his daughter from his first marriage. The family has requested that donations
be made to the Gift of Life Donor Proqram, 401 North 3rd Street, Philadelphia, PA 19123-4101
in lieu of flowers. A reception and visitation will be held from 1 to 3 p.m., Saturday, April 9, 2011
at The Vault of Carlisle. 1 North Hanover Street, Carlisle. Parking will be available behind The
Vault and also at Hoffman-Roth Funeral Home & Crematory, Inc., 219 North Hanover Street,
Carlisle. Memorial services and burial with full military honors will be held at Ft. Myer Chapel,
Arlington National Cemetery, Arlington, VA to be announced at a later date. Hoffman-Roth
Funeral Home & Crematory, inc., 219 North Hanover Street, Carlisle is in charge of the funeral
arrangements. To sign the guest book visit www.hoffmanroth:com
Published in The Washington Post on April 6, 2011
Print I Vie•.v Guest Book
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.. A::^VE:<T:SEMENT .
_. _... _.. _------------__.-- AaChnicrs ~-.
PETITION FOR GRANT OF LETTERS
REGISTER OF WILLS OF CUMBERLAND COUNTY, PENNSYLVANIA
Petitioner(s) named below, who is/are 18 years of age or older, apply(ies) for Letters as specified below, and in
support thereof aver(s) the following and respectfully request(s) the grant of Letters in the appropriate form:
Decedent's Information
Name: JAMES LESLIE GRIGGS
a/k/a:
a/k/a:
a/k/a:
Date of Death: Anri13, 2011
File No:
(Assigned by Register)
Social Security No:
Age at death: 73
Decedent was domiciled at death in Cumberland County, Pennsylvania (State) with his/her last
principal residence at 239 Graham Street. Carlisle. Pennswlania -Cumberland County
Street address, Post Office and Zip Code City, Township or Borough County
Decedent died at Philadelphia. Pennsylvania
Street address, Post Office and Zip Code City, Township or Borough County State
Estimate of value of decedent's property at death:
If domiciled in Pennsylvania ............................All personal property
If not domiciled in Pennsylvania ........................Personal property in Pennsylvania
If not domiciled in Pennsylvania ........................Personal property in County
Value of real estate in Pennsylvania ........................................................ .
TOTAL ESTIMATED VALUE... .
$ 0.00
Real estate in Pennsylvania situated at: 239 Graham Street, Cazlisle Pennsylvania -Cumberland County
(Attach additional sheets, if necessary.) Street address, Post Office and Zip Code City, Township or Borough County
A. Petition for Probate and Grant of Letters Testamentary
Petitioner(s) aver(s) he/she/they is/aze the Executor(s) named in the last Will of the Decedent, dated
thereto dated
and Codicil(s)
State relevant circumstances (eg. renunciation, death of executor, etc)
Except as follows: after the execution of the instrument(s) offered for probate Decedent did not marry, was not divorced, was not a party to a pending
divorce proceeding wherein the grounds for divorce had been established as defined in 23 Pa. C.S. § 3323(g), and did not have a child bom or
adopted; and Decedent was neither the victim of a killing nor ever adjudicated an incapacitated person.
NO EXCEPTIONS ~ EXCEPTIONS
B. Petition for Grant of Letters of Administration (If applicable)
c.t.a., d.b.n., d.b.n.c.t.a., pendente lite, durante absentia, durante minoritate
If Administration, c.t.a. or db.n.c.~a., enter date of Will in Section A above and complete list of heirs.
Except as follows: Decedent was not a party to a pending divorce proceeding wherein the grounds for divorce had been established as defined
in 23 Pa. C.S. § 3323(g) and was neither the victim of a killing nor ever adjudicated an incapacitated person.
NO EXCEPTIONS ~ EXCEPTIONS
Petitioner(s), after a proper search has/have ascertained that Decedent left no Will and was survived by the following spouse (if any) and heirs (attach
additional sheets, if necessary):
Name Relationshi Address
Josephine Griggs Wife 239 Graham Street, Carlisle, PA 17013-3718
Form RW-02 rev. 10/11/2011 Page 1 of 2
Oatlh of Personal Representative
COMMONWEALTH OF PENNSYLVANIA
COUNTY OF CUMBERLAND
}
} SS:
}
Official Use Only
Petitioner(s) Printed Name Petitioner(s) Printed Address
The Petitioner(s) above-named swear(s) or affirm(s) the statements in the foregoing Petition are true and correct to the best of the knowledge and belief
of Petitioner(s) and that, as Personal Representative(s) of the Decedent, the Petitioner(s) will well and truly administer the estate according to law.
Sworn to or affirmed and subscribed before Date
me this day of Date
By' Date
For the Register Date
BOND Required: ~ YES Q NO To the Register ojWills:
FEES: Please enter my appearance by my signature below:
Letters ...................... $
( )Short Certificate(s)..... .
( )Renunciation(s)........ .
( )Codicil(s) ............ .
( )Affidavit(s)........... .
Bond ........................
Commission ................. .
Other
Automation Fee .............. .
JCS Fee . ....................
TOTAL ..................... $ 0.00
Attorney Signature: ~
Printed Name: Shawn P. McLaughlin, Esquire
Supreme Court
ID Number: 62737
Firm Name: Menges & McLaughlin, PC
Address: 145 Eact Market 4tre
York, PA 17401
Phone:
Fax:
Email:
DECREE OF THE REGISTER
Estate of JAMES LESLIE GRIGGS File No:
a/k/a:
AND NOW, , in consideration of the foregoing Petition,
satisfactory proof having been presented before me, IT IS DECREED that Letters
are hereby granted to
in the above estate and (if applicable) that
the instrument(s) dated
aescr>bed m the Petition be admitted to probate and filed of record as the last Will (and Codicil(s)) of Decedent.
Form RW-O~ rev. 10/11/?011
Register of Wills
Page 2 of 2