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ESTATE OF : IN THE COURT OF COMMON PLEAS
ISABEL M. MORGAN : CUMBERLAND COUNTY, PENNSYLVANIA
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ORPHANS' COURT DIVISI(* ,7 rn
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AMENDED °' c° '
PETITION UNDER SECTION 3102 OF THE PROBATE,t'
ESTATES AND FIDUCIARIES CODE FOR `J
SETTLEMENT OF SMALL ESTATE
TO THE HONORABLE JUDGES OF SAID COURT: r,
Roger B. Irwin, Esquire, your Petitioner, files this Petition for Settlement of a Small
Estate under the provisions of Section 3102 of the Probate, Estates and Fiduciaries Code and in
support thereof avers that:
(1) Your Petitioner, Roger B. Irwin is a competent adult residing at 233 Avon Drive,
Carlisle, Pennsylvania 17013, and is the attorney of the above decedent.
(2) Isabel M. Morgan, died on December 16, 2008 at the age of 98 years, but prior
thereto was last domiciled at Green Ridge Village, 210 Big Spring Road,
Newville, Pennsylvania, Cumberland County, Pennsylvania. A copy of
Decedent's Death Certificate is attached hereto as Exhibit"A."
(3) Isabel M. Morgan died without a Will.
(4) Isabel M. Morgan had no probate estate when she died other than the following:
Annuity Policy IOGA333992 with Aviva Life and Annuity
Company with a value of$9,829.18. Correspondence from Aviva
Life and Annuity Company is attached hereto as Exhibit`B."
Checking account with ACNB Bank with a value of $225.79.
Correspondence from ACNB Bank is attached hereto as Exhibit
11C.11
Unclaimed Property with an approximate value of$600.00. A list
of assets with Unclaimed Property is attached hereto as Exhibit
"D
(5) The sole heirs and relationship to the Decedent are as follows:
The Decedent has no living family members.
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(6) The Pennsylvania Department of Public Welfare maintains a claim against the
Decedent in the amount of$313,064.59. A copy of the Pennsylvania Department
of Public Welfare Claim is attached hereto as Exhibit"E."
(7) Attorney fees in the amount of$750.00 will be charged to the estate.
(8) All assets in the name of the Decedent will be closed and the funds, less estate
aministration costs, will be forwarded to the Pennsylvania Department of Public
Welfare.
WHEREFORE, your Petitioner respectfully requests that an Order be made authorizing
Roger B. Irwin, Esquire to act as Fiduciary and claim the proceeds with Aviva Life and Annuity
Company, ACNB Bank and Unclaimed Property and pay to the Pennsylvania Department of
Public Welfare Claim,pursuant to Section 3102 of the Probate, Estates and Fiduciaries Code.
By /3. ,�
Roger 4g. Irwin, Esquire
Supreme Court I.D. No. 6282
IRWIN & McKNICHT, P.C.
60 West Pomfret Street
Carlisle, PA 17013
(717)249-2353
COMMONWEALTH OF PENNSYLVANIA
COUNTY OF CUMBERLAND
Roger B. Irwin, Esquire, being duly sworn according to law, deposes and says that the
facts contained in the foregoing Petition are true and correct to the best of his knowledge,
information and belief,
Swo nd subscribed before me CQMMQNMAI Or PMN
thi day of June, 2013. roam seep
Karen S.nom,Notary Public
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