HomeMy WebLinkAbout01-07-13 G'~ _-
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Shelly J. Kunkel, Esquire ~.~~ `
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Supreme Court ID No. 64485 . {
Wion, Zulli & Seibert }~~~ ~"~ '``
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109 Locust Street
Harrisburg, PA 17101
(717) 236-9301
IN THE MATTER OF IN THE REGISTER OF WILLS
ESTATE OF SHAWN M. MISHKIN, CUMBERLAND COUNTY, PENNSYLVANIA
Deceased ESTATE NO. 2012-01211
MOTION TO MAKE CITATION FOR RULE ABSOLUTE
AND, NOW COMES Shelly J. Kunkel, Esquire, counsel for the Petitioner, Holly
A. Mishkin, Administratrix of the Estate of Shawn M. Mishkin, deceased, who
respectfully represents the following:
1. On November 28, 2012 the Petitioner, Holly A. Mishkin, Administratrix of
the Estate of Shawn M. Mishkin, deceased, filed a Petition for Leave to Continue
Decedent's Business pursuant to Section 3314 of the Probate Estates and Fiduciaries
Code in the Orphans' Court of Cumberland County to the above term and number.
2. On December 5, 2012 the Court of Common Pleas of Cumberland County,
Orphans' Court Division, by the Honorable Thomas A. Placey, issued a Preliminary
Order and Citation directing that the Citation was returnable within twenty (20) days of
service.
3. Notice of the Preliminary Order and Citation and a copy of the Petition
were personally served by counsel for the Petitioner upon all of the interested parties on
December 7, 2012.
4. Attached hereto is an Affidavit of Service indicating that all of the
Respondents were duly served with a copy of the Petition and Preliminary Order and
Citation.
5. The twenty (20) day period for responding to the Citation has now expired
and none of the recipients have filed an objection or answer to the Citation nor filed an
appearance in this matter.
WHEREFORE, it is respectfully requested that the Citation and Rule be made
absolute and that an Order be issued granting Holly A. Mishkin, Administratrix of the
Estate of Shawn M. Mishkin, leave and authority to continue the operation of Decedent's
business, The Plum Sport, until the business and its parent Pennsylvania Subchapter "S"
Corporation, Plum Sport, Limited, can be wound down and terminated.
Respectfully submitted,
WIO ULLI & SEIBERT
Shelly .Kunkel, Esquire
Supreme Ct. ID# 64485
109 Locust Street
Harrisburg, PA 17101
Phone: (717) 236-9301
IN THE MATTER OF : IN THE REGISTER OF WILLS
:CUMBERLAND COUNTY, PENNSYLVANIA
ESTATE OF SHAWN M. MISHKIN :ESTATE NO. 2012-01211
AFFIDAVIT OF SERVICE
Commonwealth of Pennsylvania
SS
County of Dauphin
Shelly J. Kunkel, Esquire, the attorney for the Petitioner, being duly sworn according
to law, says that she served in person to Isaac L. Mishkin at his business address of 210
Walnut Street, Harrisburg, Pennsylvania 17101 and to Holly A. Mishkin at the law offices
of Wion, Zulli & Seibert, 109 Locust Street, Harrisburg, Pennsylvania 17101, a true and
correct copy of the Petition for Leave to Continue Decedent's Business Pursuant to 20 Pa.
C.S. §3314 and the Preliminary Order and Citation in this matter, as evidenced by the two
Acceptances of Service, attached hereto as Exhibits "A" and "B".
Shelly J. Ku 1, Esquire
Sworn to and subscribed before
met this ~j'~~~ day of
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Notary Public
My Commission Expires: ~~ ~~ u
IN THE MATTER OF IN THE REGISTER OF WILLS
ESTATE OF SHAWN M. MISHKIN, CUMBERLAND COUNTY, PENNSYLVANIA
Deceased ESTATE N0.2012-01211
ACCEPTANCE OF SERVICE
I acknowledge receipt of personal service of the Petition and Citation in the matter of a
Petition for Leave to Continue Decedent's Business Pursuant to 20 PA. Cons. Stat. § 3314 and
do accept service of same from Counsel.
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Date: lZ~ 7 lZ ~~~' ~~h~~ , ~i~J~r~.
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Holly A. Mishkin, Administratrix
Estate of Shawn M. Mishkin
816 Sycamore Circle
Camp Hill, PA 17011
IN THE MATTER OF IN THE REGISTER OF WILLS
ESTATE OF SHAWN M. MISHKIN, CUMBERLAND COUNTY, PENNSYLVANIA
Deceased ESTATE NO. 2012-01211
ACCEPTANCE OF SERVICE
I acknowledge receipt of personal service of the Petition and Citation in the matter of a
Petition for Leave to Continue Decedent's Business Pursuant to 20 PA. Cons. Stat. § 3314 and
do accept service of same from Counsel.
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Date: ~. ; =, --~ 1 ~-'" 4..//~--~.-~-. ~ ; ~-
'~ Is ac L. Mishkin
210 Walnut Street
Harrisburg, PA 17101