HomeMy WebLinkAbout12-12-12Johnson, Duffie, Stewart & Weidner
By: Mark C. Duffie
I.D. No. 75906
301 Market Street
P. O. Box 109
Lemoyne, Pennsylvania 17043-0109
(717) 761-4540
IN RE: JENNA C. COOK
Attorneys for Petitioner
IN THE COURT OF COMMON PLEAS OF
CUMBERLAND COUNTY, PENNSYLVANIA
ORPHANS' COURT DIVISION
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~~' ~~ `r~ ^~- ~`~" ~ Docket No. 21-12-1121
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~'-' '' ~ ~"~ -~ ~`~ ~~= PETITION FOR CITATION OR RULE ABSOLUTE
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TO T~PIOI~RABL JDGES OF THE ORPHANS' COURT DIVISION:
Petitio~ri~r, Jenna C. Cook, by and through her counsel, Johnson, Duffie, Stewart & Weidner,
respectfully states the following in support of her Petition for Citation or Rule Absolute
1. Petition filed a Petition for an Accounting Pursuant to PA.R.C.P. 5319 on October 17, 2012.
2. In response to said Petition, the Honorable Thomas A. Placey issued, by Order of Court, a
Citation upon Respondent, Karen J. Cook, to show cause why the relief requested in the underlying Petition
should not be granted.
3. Pursuant to the Order of Court issued on October 19, 2012 upon Respondent, Karen J. Cook,
to show cause why the relief requested in the Petition should not be granted, Petitioner effected service of
said Citation upon Respondent on October 24, 2012 by first class mail and certified mail, return receipt
request. A true and correct copy of said correspondence is attached hereto and incorporated herein as
Exhibit "A".
4. The certified mail with the return receipt requested was delivered on November 8, 2012 at
12:41 p.m. The copy of the letter and Citation that was sent via first class mail was never returned. See
Exhibit "A".
5. More than twenty (20) days has elapsed since the Citation was delivered via certified mail,
return receipt requested and Respondent has failed to plead or show cause why the relief requested in the
Petition should not be granted.
WHEREFORE, your Petitioner respectfully requests this Honorable Court to enter an Order directing
the Respondent to produce a full and complete accounting of the Uniform Gift to Minors Act or UGMA
Account to Petitioner within five (5) days from the date of said Order.
Respectfully submitted,
JOHNSON, DUFFI~, STI~,T & WEIDNER
Mark C.~ffie
Attorney I.D. No. 759 6
301 Market Street
P.O. Box 109
Lemoyne, PA 17043-0109
(717) 761-4540
Attorney for Petitioner
528692
unrir~vsr~rFs
~osr~c sERVKE_
Date: 12/05/2012
GAIL MAHONEY:
The following is in response to your 12/05/2012 request for delivery information on your
Certified Mail(TM) item number 7196 9009 3500 0583 2832. The delivery record shows that
this item was delivered on 11/08/2012 at 12:41 PM in MECHANICSBURG, PA 17055. The
scanned image of the recipient information is provided below.
Signature of Recipient:
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Address of Recipient: '~{ ~~
1\ P C`~ ~ 0. ~~,n ~V
Thank you for selecting the Postal Service for your mailing needs. If you require additional
assistance, please contact your local Post Office or postal representative.
Sincerely,
United States Postal Service
CERTIFICATE OF SERVICE
AND NOW, this day of December, 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
1277 Timber View Drive
Mechanicsburg, PA 17050
JOHNSON, C~UI~FIE, STEWART & WEIDNER
By:
ark C. Duffi