HomeMy WebLinkAbout11-15-12~_
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BEFORE THE REGISTER OF WILLS OF `- ~ ~ --~~ ~~ --~
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CUMBERLAND COUNTY, PENNSYLVANIA _ -i ~ ~~ t=
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In Re: JAMES LESLIE GRIGGS, `-~' `- ~ t~ - ~. `~'
Deceased No. 21-12-1112 r ~ .~ `~`'
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RESPONSE OF JOSEPHINE B. GRIGGS
SHOWING CAUSE WHY LETTERS OF ADMINISTRATION
SHOULD NOT BE ISSUED TO
LYNN VEINOTTE AND STUART VEINOTTE
AND NOW, Respondent Josephine B. Griggs, by and through her
undersigned counsel, files this Response to the Register of Wills' Citation
dated November 1, 2012 and received by her on November 5, 2012, and
states the following:
1. Respondent Josephine B. Griggs is the widow of James Leslie
Griggs, who died on April 3, 2011.
2. Respondent understands that Petitioners Lynn and Stuart
Veinotte are trying to open an Estate for Mr. Griggs, for purposes of filing a
personal injury suit against the Estate, in relation to a motor vehicle accident
that allegedly occurred on December 2, 2010.
3. If Petitioners were to be appointed as Administrators of Mr.
Griggs' Estate, then Petitioners would end up being the Plaintiffs and
representing the Defendant in the law suit relating to the December 2, 2010
motor vehicle accident.
4. Because of the conflict of interest that would be posed by the
Petitioners representing both sides of the personal injury law suit for
example, because of the direct and unsupervised access the T~einottes would
have to the Griggs families' financial and other privileged information
Petitioners would not fall under the category of "other fit persons" entitled to
serve as personal representatives of the Estate, pursuant to 20 Pa.C.S.
§ 3155(b)(5).
WI~REFORE, Respondent Josephine B. Griggs objects to
Petitioners Lynn and Stuart Veinottes' request that Letters of Administration
be issued to them in connection with the death of James Leslie Griggs.
Respectfully Submitted,
Thomas, Thomas & Hafer, LLP
Date: ~s Ivov Z°~ ~'
Todd B. Narvol, Esquire
PA Attorney ID 42136
P.O. Box 999
Harrisburg, PA 17108-0999
717-237-7133
Attorneys for Respondent
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ATTORNEY VERIFICATION
I, Todd B. Narvol, of the law firm of Thomas, Thomas & Hafer, LLP,
am serving in the capacity as attorney for respondent Josephine B. Griggs in
this matter. The matters set forth herein are true and correct to the best of
my knowledge, information and belief. A follow-up verification made by
Mrs. Griggs will be filed.
Thomas, Thomas & Hafer, LLP
BY:
Date: ~ S I~nv~ ~~ Z Todd B. Narvol
Attorney for Respondent
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CERTIFICATE OF SERVICE
I do hereby certify that on this day I served a true and correct copy of
the foregoing document by first class mail, postage prepaid, addressed to the
following and via facsimile:
Shawn P. McLaughlin, Esquire
Menges & McLaughlin, P.C.
145 East Market Street
York, PA 17401
Respectfully submitted,
Thomas, Thomas & Hafer, LLP
BY:
Date: i~ /~o v- Zo ~ 2- Todd B. Narvol, Esquire
PA Attorney ID 4213 6
P.O. Box 999
Harrisburg, PA 17108-0999
717-237-7133
Attorneys for Respondent
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