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03-01-13
c ~.: ~ rn © m ®~' ~ ~ rn ~ ~ ~ ~ ? c,, ~ ~~~ ~~ ~ . ;,~ ~ ~ ~~ IN THE COURT OF COMMON PLEAS OF CUMBERL,~ COL~1~T '~`~' PENNSYLVANIA `~' '~`` ; ~'~~ ~''' ~~ ORPHAN'S COURT DIVISION IN RE: ESTATE OF BERNITA E. HORVATH No. 21-07-0577 a/k/a BERNITA E. WARREN • deceased . ANSWER OF CO ADMINISTRATRIX BERNITA H. NYE TO PETITION FOR CITATION NOW COMES Bernita H. Nye, Co-Administratrix of the Estate of Bernita E. Horvath a/k/a Bernita E. Warren, deceased, by and through her attorneys, Pecht & Associates, P.C., and fides this Answer to Petition for Citation respectfully representing as follows: 1. Admitted. 2. Admitted. 3. Admitted. 4. Admitted. By way of further answer, Co-Administratrix Bernita H. Nye has frequently requested information from the other Co- Administratices in order for Pecht & Associates, PC to accurately complete the Inheritance Tax Return. The Co-Administratices have failed and refused to provide any of the expenses relating to the h~ r~ Estate to Ms. Nye or her attorneys, or to cooperate in any way in the ongoing administration of the estate. 5. Admitted. WHEREFORE, Respondent Nye respectfully requests this Honorable Court issue a Citation upon Melanie R. Horvath and Corrine R. Brandt only, and to either order them to provide all of the necessary information to Pecht & Associates, P.C. in order to complete the Inheritance Tax Return and have it signed by all Co-Administratrices for filing with the Register of Wills of Cumberland County, Pennsylvania, or to remove them as Co- Administratrices. Respectfully submitted, PECHT & ASSOCIA S PC March 1, 2013 By: Wayne M. Pecht, Esquire PA I.D. No. 38904 1205 Manor Drive, Suite 200 Mechanicsburg, PA 17055 (717) 691-9808 Attorneys for Co-Administratrix Bernita E. Nye •~ CERTIFICATE OF SERVICE I, Wayne M. Pecht, Esquire, hereby certify that I have served the foregoing Answer to Petition for Citation, by U.S. First Class Mail, postage prepaid, as follows: The Honorable Daniel Meuser Secretary of Revenue Commonwealth of Pennsylvania 1825 Stanley Drive Harrisburg, PA 17103-1256 Thomas O. Armstrong, Ph.D. Department Secretary for Taxation Commonwealth of Pennsylvania 1825 Stanley Drive Harrisburg, PA 17103-1256 Corinne R. Brandt 513 Penn Ayr Road Camp Hill, PA 17011 Melanie R. Horvath 603 Wingert Drive Mechanicsburg, PA 17050 March 1, 2013 PECHT & ASSOCI ES, PC Wayne M. Pecht, Esquire PA. I.D. No. 38904 1205 Manor Drive, Suite 200 Mechanicsburg, PA 17055 Phone: (717) 691-9808 Fax: (717) 691-2070 Attorneys for Co-Administratrix Bernita H. Nye