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HomeMy WebLinkAbout03-05-13Andrew C. Sheely, Esquire 127 S. Market Street P.O. Box 95 Mechanicsburg, PA 17055 PA ID NO. 62469 717-697-7050 (Phone) 717-697-7065 (Fax) IN RE: THE ESTATE OF GLADYS M. OWENS, Deceased ~ r~ 4~1 C © ., f'tl ~ ~ ,:y ~ ~ ~ , C"' T,M tea.. _1 ~`~ C.I; C'`' . ° :. ,~;; u . r~ ,~ ~, c ..._ ~ r. J ~ .~. • IN THE COURT OF COMMON pLE~S O~ ";',~ °-~~`° CUMBERLAND COUNTY, PENNa,~LVANIA;~ '`'~ ~j ORPHANS COURT DIVISION NO. 21-11-1255 MOTION TO APPROVE SALE OF REAL ESTATE The Estate of Gladys M. Owens, by and through counsel of Andrew C. Sheely, Esquire, hereby files this Motion to approve the sale of real estate and respectfully states as follows: 1. On February 25, 2013, the Honorable Thomas A. Placey entered an Order of Court scheduling a hearing to consider approving a February 11, 2013 Agreement of Sale pertaining to the decedent's real estate located at 207 E. Locust Street, Mechanicsburg, Pennsylvania. hereto as Exhibit "A". A copy of the Order is attached 2. Subsequent to entry of the Order of Court, counsel for the Estate received written correspondence dated March 1, 2013 from counsel representing two beneficiaries confirming that they had no opposition to the proposed Agreement of Sale. A copy of the letter is attached hereto as Exhibit "B". 3. All beneficiaries consent to the terms and conditions of the February 11, 2013 Agreement of Sale pertaining to the decedent's residence. 4. The Honorable Thomas A. Placey has previously entered Orders of Court in this matter. 5. All beneficiaries and counsel representing beneficiaries Rose M. Neidig and Holly M. Owens concur with the relief requested herein. 6. The entry of the attached order of court is necessary to permit the sale of the decedent's real estate in accordance with prior orders entered in this action and the Agreement of Sale dated February 11, 2013. WHEREFORE, the Estate of Gladys M. Owens respectfully requests the entry of the Court Order attached hereto approving the sale of the decedent's residence in accordance with the Agreement of Sale dated February 11, 2013. Respectfully submitted, A drew C. Sheely, Esquire Attorney for Estate of Gladys M. Owens, Carmella Colban, Executrix c/ Date: March ~ 2013 2 Exhibit "A" 6 IN RE: THE ESTATE OF IN THE COURT OF COMMON PLEAS OF GLADYS M. OWENS, CUMBERLAND COUNTY, PENNSYLVANIA Deceased ORPHANS COURT DIVISION NO. 11-11-1255 ESTATE MOTION TO APPRO~ SALE OF REAL ESTATE ORDER OF COURT AND NOW, this 2S day of ~~ /~~~,,,~ 2013, upon consideration of the attached Motion, a hearing on the relief requested in the attached petition is scheduled for the~j ~ day of GG~ 2013,. at ~ ;~ ~•m., in Courtroom No . ~ ~~/' of the Cumberland Cou ~` r~ty Courthouse, Carlisle, Pennsylvania. ~~ Andrew C. Sheely, Esquire Attorney for Petitioner Anthony T. McBeth, Esquire, Attorney for Rose M. Neidig 407 North Front Street Harrisburg, PA 17101 co ~~ ~ ~' ~ D r ~~,, ~ rn ~ ~ _~ d ~ ~-> ~ c^: o c -, a, -; ro Y- -,-~ m -~ N t--^ N ~' ~rn ~ ~ ..._ o :n ~ _.,~ :~., 0 0 -r, -:~ ~..- -~ c~ r°' ~r P- CA O "~ Fin ambit «~ ~~ 03,101/2!'1, 'r ,s^ #1407 P.OO1,f002 LAW OFFICES OF ANTHONY T. MCBF'TH X107 North )?rout Street Harrisburg, PA 17101 tcl (717)138;36$6 fax (71718-3575 F~~ transmittal T0: Andrew C. Sheely, Esquire FAX #: (717} 697-70fi5 FRaM: Anthony T. McBeth DATE: March 1, 2013 RE: Estate of Gladys M. Owens PAGES: 2, including this cover sheet MESSAGE: This transmittal is intended only for the individual or entity named above. You are hereby notified that any use, dissemination, distribution, copying, use of or reliance upon the information contained in and transmitted with this facsimile by or to anyone other than the recipient designated above is unauthorized and is strictly prohibited. If you have received this transmission in error, please notify us immediately by telephone, copect if necessary. Any facsimile erroneously transmitted to you should be immediately returned to the sender by U_S_ Mail or, if authorization is granted by the sender, destroyed. n~1I1 I~l2111r, ~/~'1^ ANTHONY T. McBETH AT'I'OItNE'Y AT YAK 407 NQRTH FRONT STREEY CAMERON MANSION HARRISBX)'RG, AA 17101 E-mail: acmlawl[y?verizon.net March 1, 2t?13 Andrew C. Sheely, Esquire 127 South Market Street P.O. Box 95 Mechanicsburg, PA 17Q55 Re: Estate of Gladys M. Owens Dear Andy: tt1407 P. 002/002 AHONB (717) 238-3486 1-~dp0-227-6914 {For 717 eras) FAX (717) 2;8-3575 This is to confirm the telephone message that I left far you last evening. Our clients, Rose Neidig and Holly Owens, have no apposition to the sale of the Decedent's real estate as set forth in the Motion to ApprQVe the Sale. Please take whatever steps are necessary to eliminate the March 5 hearing_ As I mentioned to you yesterday, l have a Pennsylvania Supreme Court argument in Philadelphia on that day. Thanks very much. ATM:msm VIA TELEF'ACSIMILE ONLY cc: Rose M. Neidig (via regular mail) CERTIFICATE OF SERVICE I, Andrew C. Sheely, Esquire, hereby certify that I am this day serving the attached Motion upon the following named individuals this day by depositing same in the United States Mail, First Class, postage prepaid, at Mechanicsburg, Pennsylvania, addressed as follows: Anthony T. McBeth, Esquire, Attorney for Rose M. Neidig and Holly Owens 407 North Front Street Harrisburg, PA 17101 Phyllis A. Henneman 111 Fairway Drive Carlisle, PA 17015 Joseph C. Owens Jr. 13 Heathglen Road Middletown, PA 17057 Date: March ~ 2013 c:. Sneely, Attorney at Law Andrew C. Sheely, Esquire 127 S. Market Street P.O. Box 95 Mechanicsburg, PA 17055 PA ID NO. 62469 717-697-7050 (Phone) 717-697-7065 (Fax) IN RE: THE ESTATE OF GLADYS M. OWENS, Deceased IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA ORPHANS COURT DIVISION N0. 21-11-1255 CERTIFICATE OF CONCURRENCE OR NON-CONCURRENCE I, Andrew C. Sheely, Esquire, reviewed the contents of the attached motion with Anthony T. McBeth, Esquire, who provided a letter dated March 1, 2013 confirming his onsen to the relief requested in the attached motion prior to its filing on the date set forth below. A copy of the March 1, 2013 letter is attached to the Motion as Exhibit "B". Date: March ~ , 2013 Andr w C. Sheely, Esquire Attorney for Estate of Gladys M. Owens 127 South Market Street P.O. Box 95 Mechanicsburg, PA 17055 717-697-7050