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HomeMy WebLinkAbout01-16-13 w M William C. Dissinger, Esquire y' ~ 1~ C,? Attorney for Betty J. Gingrich Court I.D. # 27737 - ter. Dissinger & Dissinger 400 South State Road ~b Marysville, PA 17053 (717) 957-3474 - Phone (717) 957-2316 - Fax IN RE :IN THE COURT OF COMMON PLEAS ESTATE OF ARTHUR H. :OF CUMBERLAND COUNTY, LENTZ, DECEASED :PENNSYLVANIA :ORPHAN'S COURT :DIVISION :NO. 21-11-0422 ANSWER TO MOTION AND NOW, comes Betty J. Gingrich, by and through her counsel, William C. Dissinger, Esquire, and files this Answer to the Motion to Compel Betty J. Gingrich to return value of assets to Estate: 1. Admitted. 2. Admitted. 3. Admitted. 4. Admitted. 5. Admitted in part and denied in part. It is admitted that the Shivvers County Clipper was listed as covered equipment on Decedent's Tradesman insurance policy for Pete's Lawn Care with Mutual Casualty Company, dated March 28, 2011 and valued at $6,566.00. It is denied that this establishes ownership of the Shivvers County Clipper. 6. Admitted. 7. Admitted. 8. Admitted. 9. Admitted. 10. Admitted. 11. Admitted. 12. Admitted. 13. Denied. The Order of October 16, 2012, requires Betty S. Gingrich to "produce or provide information to the Executor as to the location and person(s) in possession of" the Shivvers County Clipper. 14. Admitted in part and denied in part. It is admitted that the Shivvers County Clipper was entered on Decedent's business insurance policy at a value of $6,566.00. It is denied that it was purchased by Decedent. To the contrary, the mower was purchased by Betty J. Gingrich. A copy of the check written by Betty J. Gingrich to Central Hardware in the amount of $6,566.70 for the purchase of the mower is attached hereto, marked as Exhibit "A" and made a part hereof by reference thereto. 15. Admitted in part and denied in part. It is admitted that Betty J. Gingrich had the mower repaired and paid for that repair with a check in the amount of $356.29. A copy of that check dated April 9, 2011, is attached hereto, marked as Exhibit "B" and made a part hereof by reference thereto. It is denied that this payment represents payment for servicing the mower. The Decedent had rolled the mower, bending the frame and damaging the deck. Betty J. Gingrich caused to be made partial repairs only. 16. Admitted. 17. Admitted in part and denied in part. It is admitted that Betty J. Gingrich sold the mower on May 9, 2011. It is denied that this was done to prevent the Executor from taking possession of said mower. Ms. Gingrich sold the mower because she believed she owned the mower and wished to sell it. 18. Denied. The value of the mower on May 9, 2011, was $3,500.00. The mower had been rolled by Decedent and had only been partially repaired. The frame was bent. 19. Admitted. WHEREFORE, Betty J. Gingrich, requests that the Court dismiss the Motion of Executor, Douglas C. Young. RESPECTFULLY SUBMITTED Dissinger & Dissinger William Cr' Dissinger, esquire Attorney for Betty J. Gingrich Court I.D. # 27737 400 South State Road Marysville, PA 17053 VERIFICATION I, Betty J. Gingrich, verify that the statements made in the foregoing document are true and correct. I understand that false statements herein are made subject to the penalties of 18 Pa. C.S. §4904 relating to unsworn falsification. ,'r1 Date: ' Betty" Girich Air fi k r Posting Date '`L Y#r.,,< x.__.._ • . 2010 Apr 09 - Research Seq # BETTY 1 GINGRICH iYA 514 5133009135 Sete ETY3w RS. PA PO / Account # _ ERS. PA 173ty ~ 15004213015420 Trust A J~- P - - • I -rr- Check/More # rsion 514 ~.e j /tG~:,~~sttLZ' sYv'_ j1f11L r~ tUX~l~lsC 8 _ 1 DB/CR ,f y, „ MOBank oB Dollar Amount omit :O~i3Q295S~:i5OO42~3OL542Oe'Q~R r'(7pUt76561s~O~' Bank # - - _ - _ - _ -j' - - 096 _ Branch 06108 f x d 1 " ; r - - Deposit Acct # 7^ 3740127240 r5 } c Record Type # = ~ r'3 Tom.- T - 01 xHint ; C• ?~'•"~i -P itment, i multi . t& i. , ~ }Z t ~ 13.7 Oa nelua s' ~ _ y t a Pat A: 2 _j eP1an . ^ ~RNWlh•i ~ y EXHIBIT A ,r v 0, 0 L nj °'F o N J n ~ o ~ O .ti -co) ' rr, e 1 ~ i 1 ~ ~ ° n ~ o In m I o- o \ r ~ \ e V 1 co ~ .ter s -^1 c0 ~m ®~3 rrw oil 11 E r N nom, cr ~ v' lJl f ^ " (Ci m .r - . ~ D m W n. " 10 `1•~© of ^ !11 o ( z `.'r`te ® \ O ~ ° ao 'a ~ ~ ~ ! f ! % 43 0 to 69 Q LI 1 n Q 4 w 44 k v e1 .r ! t a co \m o ~ I rp ~ a ` 'r 'd 1 ~r I 0. c J = I g V d EXHIBIT ~'I a t b p f 8 to A g i Ln d lu in T a ..sr. F.r ~ • r 4n r~ 1 ~ & IN RE :IN THE COURT OF COMMON PLEAS ESTATE OF ARTHUR H. :OF CUMBERLAND COUNTY, LENTZ, DECEASED :PENNSYLVANIA :ORPHAN'S COURT :DIVISION :NO. 21-11-0422 CERTIFICATE OF SERVICE I, William C. Dissinger, Esquire, hereby certify that a true and correct copy of the foregoing document was served on the following individual on the date and by the method as indicated below: Service by 13t Class Mail Susan J. Smith, Esquire 3009 Market Street Camp Hill, PA 17011 Date: William C. Dissing , Esquire