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Home My WebLink About10-17-12Johnson, Duffle, Stewart & Weidner By: Mark C. Duffle I.D. No. 75906 301 Market Street P. O. Box 109 Lemoyne, Pennsylvania 17043-0109 (717) 761-4540 Attorneys for Petitioner IN RE: JENNA C. COOK IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA ORPHANS' COURT DIVISION Docket No, ~~ ~~~ ' /~02-~ TO: Karen J. Cook 1431 Timber Brook Drive Mechanicsburg, PA 17050 NOTICE TO PLEAD AND NOW, this ~ day of October, 2012, you are hereby notified to plead responsively within twenty (20) days of the date of service hereof, or judgment may be entered against you. JOHNSON, DUFFIE, STEWART & WEIDNER Date: ~~ '' ~y«- :518997 . ,,,,/1 By. Mark C. Duffs squire Attorney I.D. No. 75906 301 Market Street P.O. Box 109 Lemoyne, PA 17043-0109 Telephone (717) 761-4540 Counsel for Defendant, Tyson Woods :~~ O ~ ~ ~? o ~, : i m h ~ c- • ry ~ ~ ~~ ut ~ c, Johnson, Duffle, Stewart & Weidner By: Mazk C. Duffie I.D. No. 75906 301 Mazket Street P. O. BOX 109 Lemoyne, Pennsylvania 17043-0109 (717)761-4540 IN RE: JENNA C. COOK Attorneys for Petitioner ~, ~ ~ ~ q rnt "3 ~ --~ -- f - } i'k°~ . , ~ .. -- .--~ . ~ VV c~ ~-~=- ---y ca _ ~ `/~ ''~7 O"1 IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA ORPHANS' COURT DIVISION Docket No. o~ - / ~ ' /~~ PETITION FOR AN ACCOUNTING PURSUANT TO PA. R.C.P. 5319 TO THE HONORABLE JUDGES OF THE ORPHANS' COURT DIVISION: Petitioner, Jenna C. Cook, through her counsel, Johnson, Duffle, Stewart & Weidner, respectfully states the following in support of her Petition for an Accounting pursuant to Pa. R.C.P. 5319: 1. Petitioner is Jenna C. Cook, an adult individual, who resides at 3803 Chippenham Road, Mechanicsburg, Pennsylvania 17050. She is nineteen (19) years old. 2. Respondent is Karen J. Cook, an adult individual, who resides at 1431 Timber Brook Drive, Mechanicsburg, Pennsylvania 17050. 3. The Respondent is the biological mother of the Petitioner. 4. When the Petitioner was bom, her maternal grandparents established a Uniform Gift to Minors Act ("UGMA°) Account (now Uniform Transfers to Minors Act or UTMA Account) for the benefit of Petitioner and nominated the Respondent as custodian of said account. 5. The Petitioner attends Savannah College of Art and Design in Savannah Georgia and had formerly been receiving payment of $878.33 a month from the UGMA Account to assist her in paying for her tuition at Savannah College of Art and Design. ~- 6. The Petitioner has requested of Respondent both orally and in writing since October of 2011 an accounting of the UGMA Account, the balance, the transaction history and any other facts or data pertaining to said account. 7. Respondent has refused to date to provide any said accounting and has failed to make regular distributions from the UGMA Account for Petitioner's benefit. Respondent now indicates that there is only Two Hundred Seventy-Eight ($278.00) Dollars in said Account. 8. Pursuant to Section 5319 of the Uniform Transfer to Minors Act,' Petitioner is entitled to an accounting by the custodian of the UGMA Account. WHEREFORE, your Petitioner respectfully requests this Honorable Court to enter a Decree directing respondent to provide a full accounting of the UGMA Account pursuant to Section 5319 of the Uniform Transfers to Minors Act. Respectfully submitted, JOHNSON, DUFF E, ST RT & WEIDNER By: Mark C. Duffle Attomey I.D. No. 75906 301 Market Street P.O. Box 109 Lemoyne, PA 17043-0109 (717) 761-4540 Attomey for Petitioner 517600 VERIFICATION I, Mark C. Duffle, attorney for Jenna C. Cook, hereby certify that the matters asserted herein constitute matters of record, legal arguments and matters within the direct knowledge of counsel. The statements contained herein are true and correct to the best of the knowledge of the undersigned. This verification is made pursuant to the provisions of 18 Pa.C.S.A. §4904. Vi , Mark C. Duffle ~ Date: ' c ' ~'~" I ~" CERTIFICATE OF SERVICE AND NOW, this 1 ~ day of October, 2012, the undersigned does hereby certify that he did this date serve a copy of the foregoing upon the Respondent by causing same to be deposited in the United States Mail, first class postage prepaid, at Lemoyne, Pennsylvania, addressed as follows: Karen J. Cook 1431 Timber Chase Drive Mechanicsburg, PA 17050 JOHNSON, DUFFIE,~STEWART 8~ WEIDNER By: