HomeMy WebLinkAbout02-14-13
REGISTER OF WILLS OF CUMBERLAND COUNTY, PENNSYLVANIA
ESTATE OF WALTER ALBERT COX, Deceased File Number ' 13
L ~11 V'
PETITION FOR CITATION TO SHOW CAUSE WHY PETITIONER SHOULD NOT
BE APPOINTED ADMINISTRATRIX
And now comes the Petitioner, Catherine T. Cramer, by and through her attorney,
Elizabeth B. Place, Esquire, SkarlatosZonarich LLC, to file this Petition for Citation to Show
Cause why Petitioner should not be Appointed Administratrix of the Estate of Walter Albert
Cox, and, in support thereof, avers as follows:
1. Walter Albert Cox died intestate on June 18, 2012, a resident of Cumberland
County, Pennsylvania.
2. Decedent is survived by the following heirs at law:
a. Catherine T. Cramer, his daughter, residing at 7 Pine Road, Apt. 502, Mount
Holly Springs, PA 17015;
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, current address unknown; last known residence is
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Dillsburg, PA 17109.
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3. Jeffrey A. Cox and Alfred A. Cox have signed Renunciations requesting that
letter of administration in said estate be issued to Catherine T. Cramer. Copies of the
Renunciations are attached as Exhibits "A" and "B."
4. David L. Cox, address unknown, has not made application to this Court for letters
of administration of said estate.
5. Decedent had no significant assets at the time of his death. However, 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. Simultaneous with the filing of this Petition, Petitioner's attorney will be filing a
petition asking for the appointment of John B. Zonarich, Esq. as administrator pendente lite in
order to file a writ to toll the statute of limitations on the personal injury claim.
7. It is anticipated that the Register of Wills will grant the requested letters of
administration pendente elite for a limited period of time.
8. Petitioner, Catherine T. Cramer, is a resident of Cumberland County,
Pennsylvania, is familiar with the pending litigation, and is willing to serve as Administratrix of
her father's estate.
WHEREFORE, Petitioner requests that a Citation be issued to David L. Cox (mailed to
General Delivery, Dillsburg, PA) to show cause why Petitioner should not be granted letters of
administration.
Respectfully submitted,
SKARLATOSZONARICH LLC
Dated: Llzl By: v--
El' eth B. Place, Esq.
S preme Court No. 44682
Skarlatos & Zonarich Building
17 S. Second Street, 6`" Floor
Harrisburg, Pennsylvania 17101
(717) 233-1000
Attorney, for Petitioner
VERIFICATION
I, Catherine T. Cramer, the Petitioner in the foregoing matter., verify that I have read the
foregoing document and that the facts set forth therein are true and correct to the best of my
knowledge, information and belief, and that this verification is subject to the penalties of 18 Pa.
Cons. Stat. § 4904 related to unsworn falsification to authorities.
Dated:
atherine T. Cramer
RENUNCIATION
REGISTER OF WILLS
CUMBERLAND COUNTY, PENNSYLVANIA
Estate of Walter Albert Cox Deceased
1, Jeffrey A. Cox , in my capacity/relationship as
(Print Name)
child of the above Decedent, hereby renounce the right to
administer the Estate of the Decedent and respectfully request that Letters be issued to
Catherine T. Cramer
(Date) (Signature) j
31 D ( sT'~`r~y , l,Uf f ~
(Street Address)
(City, State, Zip)
Executed in Register's Office Executed out of Register's Office
Sworn to or affirmed and subscribed Before the undersigned personally appeared the
before me this day party executing this renunciation and certified
of that he or she executed the renunciation for the
purposes stated within on this I P day
of Febr~ar ?~13
Deputy for Register of Wills Notary Pu is
My Commission Expires: v(-j)6e( -,)7120 i~
(Signature and Seal of Notary or other official qualified to
administer oaths. Show date of expiration of Notary's Commission.)
COMMONWEALTH OF PENNSYLVANIA
Notarial Seal
Form Rw-n6 re,. in. i3.n6 Brian 1. Murmn, Notary Public
Gty of Harrisburg, Dauphin County
My Commission Expires Oct 27, 2016
MEMBER, PENNSYLVANIA ASSOCIATION OF NOTARIES
RENUNCIATION
REGISTER OF WILLS
CUMBERLAND COUNTY, PENNSYLVANIA
Estate of Walter Albert Cox , Deceased
C
1, Alfred A. Cox , in my capacity/relationship as
(Print Name)
child of the above Decedent, hereby renounce the right to
administer the Estate of the Decedent and respectfully request that Letters be issued to
Catherine T. Cramer
zi 13/3 ~ ' ~ r ~
Coe
(Date) (Signal ije)
3~l 5priny Ro,d /,,r
(Street Address) J!
(00'. State. Z P)
Executed in Register's Office Executed out of Register's Office
Sworn to or affirmed and subscribed Before the undersigned personally appeared the
before me this day party executing this renunciation and certified
of that he or she executed the renunciation for the
purposes stated within on this i rh day
of Febtuarq 2.6 13
Deputy for Register of Wills Notary Pd Vic
My Commission Expires: D lv6er 27~ Wpb
(Signature and Seal of Notary or other official qualified to
administer oaths. Show date ofexpiration of Notary's Commission)
COMMONWEALTH OF PENNSYLVANIA
Notarial Seal
Form RW-06 rev. 10. 13.06 Brian 1. Mullen, Notary Public
City of Harrisburg, Dauphin County
My Commission Ex Tres Oct 27, 2016
MEMBER, PENNSYLVANIA ASSOCIATION OF NOTARIES