The URL can be used to link to this page

Home My WebLink About02-14-13 (2) SKARLATOS ZONARICH LLC, Elizabeth B. Place, Esq. cl> M Skarlatos Zonarich Building 17 South Second St., 6th Floor rn --a C= Harrisburg, Pennsylvania 17101 (717) 233 -1000 r r*n ~ C" Email: ebp@skarlatoszonarich.com = o C) -n '71 Attorneys for Petitioner c a - Lt C-Tj C r- rn (n G> O REGISTER OF WILLS OF CUMBERLAND COUNTY, PENNSYLVANIA ESTATE OF WALTER ALBERT COX, Deceased : File Number EMERGENCY PETITION FOR GRANT OF LETTERS OF ADMINISTRATION PENDENTE LITE Elizabeth B. Place, Esq. files this Petition for Letters of Administration Pendente lite, and in support thereof, hereby avers as follows: 1. Petitioner after a proper search has ascertained that the Decedent, Walter Albert Cox, left no Will and was survived by the following heirs at law: a. Catherine T. Cramer, his daughter, residing at 7 Pine Road, Apt 502, Mount Holly Springs, PA 17065; b. Alfred C. Cox, his son, residing at 3101 Spring Road, Lot 14, Carlisle, PA 17015; C. Jeffrey A. Cox, his son, residing at 3101 Spring Road, Lot 14, Carlisle, PA 17015; d. David L. Cox, his son, address unknown. 2. The Decedent was domiciled at death in Cumberland County, Pennsylvania, with his last principal residence at 1000 Claremont Road, Carlisle, PA 17013. 3. The Decedent, then 80 years of age, died on June 18, 2012 at Claremont Nursing & Rehab, Middlesex Township, Cumberland County, Pennsylvania. 4. The Petitioner files this Petition for litigation purposes only. 5. The Petitioner believes, and therefore avers, that a cause of action exists in favor of the Estate of Walter Albert Cox and his next of kin for personal injuries arising out of the Decedent's care and treatment at a nursing home in which he resided prior to his death. 6. The statute of limitation for the personal injury action will expire on March 1, 2013, and litigation must be initiated prior to that date in order to preserve the rights of the Estate and the beneficiaries to a potential recovery for damages. 7. Simultaneously with the filing of the instant petition, Catherine T. Cramer is filing a Petition for Grant of Letters of Administration and a Petition for Citation to Show Cause Why Letters Should Not Be Issued (to her) directed to David L. Cox, the only child of Walter Albert Cox who has not filed a renunciation in favor of Catherine T. Cramer. 8. David L. Cox will have a period of time following the issuance of a Preliminary Decree awarding the Citation to respond by entering an appearance. 9. The process as described above will delay the issuance of Letters of Administration past the time when a law suit must be initiated. 10. It is imperative that Letters of Administration pendente lite be issued without delay so that litigation can be initiated before the expiration of the statute of limitations, and the rights of the Estate of Walter Albert Cox can be protected and preserved. 11. John B. Zonarich, Esq. is an attorney with the law firm of SkarlatosZonarich, LLC, of Harrisburg, Pennsylvania, is familiar with this case and is willing to serve as Administrator pendente lite until a permanent Administrator can be appointed; he is not counsel for the personal injury litigation. WHEREFORE, Petitioner respectfully requests that Letters of Administration pendente lite be granted to John B. Zonarich, Esq. in the above estate. date abeth B. Place, Esq. ttorney for Catherine Cramer Supreme Court No. 44682 SkarlatosZonarich, LLC 17S.2 d Street, 6c" Floor Harrisburg, PA 17101 Phone: 717-233-1000 VERIFICATION 1, Elizabeth B. Place, Esq. verify and state that: 1. I am the petitioner in the foregoing action. 2. The facts set forth in the foregoing pleading are true and correct to the best of my knowledge, information, and belief. 3. I understand that false statements herein are made subject to the penalties of 18 Pa.C.S. §4904, relating to falsification to authorities. E ' abeth B. Place, Esq. Date: -211y'Ly 3 ' Reset PETITION FOR GRANT OF LETTERS REGISTER OF WILLS OF CUMBERLAND COUNTY, PENNSYLVANIA Petitioner(s) named below, who is/are 18 years of age or older, apply(ies) for Letters as specified below, and in support thereof aver(s) the following and respectfully request(s) the grant of Letters in the appropriate form: Decedent's Information Name: Walter Albert Cox File No: a/k/a: (Assigned by Register) a/k/a: a/k/a: Social Security No: 194-24-9769 Date of Death: June 18, 2012 Age at death: 80 Decedent was domiciled at death in Cumberland County, PA (State) with his/her last principal residence at 1000 Claremont Road Carlisle 17013 Middlesex Township Cumberland Street address, Post Office and Zip Code City, Township or Borough County Decedent died at 1000 Claremont Road Carlisle 17013 Middlesex Township Cumberland PA Street address, Post Office and Zip Code City, Township or Borough County State Estimate of value of decedent's property at death: If domiciled in Pennsylvania All personal property $ If not domiciled in Pennsylvania Personal property in Pennsylvania $ If not domiciled in Pennsylvania Personal property in County $ Value of real estate in Pennsylvania $ TOTAL ESTIMATED VALUE.... $ 0.00 Real estate in Pennsylvania situated at: FOR LITIGATION PURPOSES ONLY (Attach additional sheets, if necessary.) Street address, Post Office and Zip Code City, Township or Borough County A. Petition for Probate and Grant of Letters Testamentary Petitioner(s) aver(s) he/she/they is/are the Executor(s) named in the last Will of the Decedent, dated and Codicil(s) thereto dated State relevant circumstances (e.g. renunciation, death of executor, etc.) Except as follows: after the execution of the instrument(s) offered for probate Decedent did not marry, was not divorced, was not a party to a pending divorce proceeding wherein the grounds for divorce had been established as defined in 23 Pa. C.S. § 3323(g), and did not have a child born or adopted; and Decedent was neither the victim of a killing nor ever adjudicated an incapacitated person. Q NO EXCEPTIONS 0 EXCEPTIONS B. Petition for Grant of Letters of Administration (If applicable) pendente lite c.t.a., d.b.n., d.b.n.c.t.a., pendente lite, durante absentia, durante minoritate If Administration, c.t.a. or d.b.n.c.t.a., enter date of Will in Section A above and complete list of heirs. Except as follows: Decedent was not a party to a pending divorce proceeding wherein the grounds for divorce had been established as defined in 23 Pa. C.S. § 3323(g) and was neither the victim of a killing nor ever adjudicated an incapacitated person. Q NO EXCEPTIONS 0 EXCEPTIONS Petitioner(s), afters proper search has/have ascertained that Decedent left no Will and was survived by the following spouse (ifany) and heirs (attach additional sheets, if necessary): Name Relationship Address Catherine Cramer Daughter 7 Pine Road, Apt. 502, Mount Holly Springs, PA 17065 Alfred C. Cox (see attached renunciation) Son 3101 Springs Road, Lot 14 Carlisle. PA 17013 Jeffrey A. Cox (see attached renunciation) Son 3101 Springs Road, Lot 14 Carlisle PA 17013 David L. Cox Son Whereabouts Unknown Farm RW-01 rev. 10/11/2011 Page 1 of 2 Official Use Only Oath of Personal Representative COMMONWEALTH OF PENNSYLVANIA SS: COUNTY OF CUMBERLAND } Petitioner(s) Printed Address Petitioner(s) Printed Name 17 South Second Street Floor 6,..H arrisbur PA 17101 Es . John B. Zonarich and correct to tstebest estthe ate knowledge and belief The P ner(s) above-named swear(s) or affirm(s) the statements in the foreg itng Petition) willre true of Petitioner(s) ioner(s) and that, as Personal Representative(s) of the Decedent, the Peioner(s well truly r the according to law. Date Sworn to or affirmed and subscribed before Date me this day of By: Date Date For the Register YES (F) NO To the Register of Wills: si nature below: BOND Required: Please enter my appearance by my g FEES: Attorney Si ature: $ Letters . ( 2) Short Certificate(s)..... . ( ) Renunciation(s)........ . ( ) Codicil(s) ( ) Affidavit(s)............ Printed Na : John B. Zonarich Bond Supreme Court Commission ID Number: 79989 Other " " " ' " ' ' ' . Firm Name: SkarlatosZonarich LLC Address: Harrisburg, PA 17101 . Phone: (717) 233-1000 Fax: 717 233-6740 Automation Fee Email: JCS Fee 0.00 TOTAL $ DECREE OF THE REGISTER File No: Estate of Walter Albert Cox a/k/a: in consideration of the foregoing Petition, AND NOW, satisfactory proof having been presented before me, IT IS DECREED EED that Letters of Administration Pendente Lite are hereby granted to John in the above estate and (if applicable) that the instrument(s) dated described in the Petition be admitted to probate and filed of record as the last Will (and Codicil(s)) of Decedent. Register of Wills Page 2 of 2 Form RW-Ol rev. 10/11/2011