HomeMy WebLinkAbout08-06-13 (2) �
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TO: CLERK OF ORPHAN'S COURT
CUMBERLAND COUNTY, PENNSYLVANIA
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FROM: TERRY�. GEBHARD �~3 ��
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RESPONDENT TO CITATT�N REGARDII�G PETITION TO SELL ���: PR�P�RTY ;;;� �'
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IN RE: FIL.E NO. 2013-00765 �- �' ; �j �.� 4�
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IN RE: VELMA B. GEBHARD �
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(MOTHER OF THE PETITIONER AND THE RESPONDENT) � �� ��
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Enclosed piease find the response of the Respondent in the �case of the File number
2013-00765 as cited above.
Piease note, as explained in the response, that there is no difference of opinion
between the Petitioner and the Respondent about whether or not to sell the
Residential Real Property at 630 Devonshire Drive, Carlisle, Pennsylvania, which is
the home owned by Velma B. Gebhard, mother of the Petitioner and the Respondent.
The Petitioner and the Respondent agree that the property should be sold.
The fundamental issue has, therefore, been misstated in Item No. 11 of the Petition
to sell Real Property as submitted to the Court by David A. Bari�, attorney for the
Petitioner.
In actuat fact, the difference of opinion between the Petitioner and the Respondent
relates to the Terms and Conditions and the process by which the Real Property cited
above should be prepared for market and marketed and sold. In addition, the
Respondent disagrees that the Petitioner should be granted total control (to the
exctusion of fihe Respondent) of process to prepare for market, to market and to sell
the above cited Real Property.
The Respondent has been investing considerable time and effort toward achieving a
reasonable, rational process to maximize the net proceeds from the sale of the
property, which is ciearly in the best interest of Veima B. Gebhard, and, therefore,
aiso constitutes acting in compliance with the intent of the responsibilities of a POA
agent.
Therefore, please note that, as part of the enelosed response by the Respondent, is a
proposal for consideration for approval by the Court titied "TERMS AND CONDITIONS
FOR SALE OF REAL PROPERTY AT 630 DEVONSHIRE DRIVE, CARLISLE,
PENNSYLVANIA."
This proposal is intended to reptace and to be carried out in lieu of the Petition to Seit
Reai Praperty that has been proposed by David A. Baric, atfiorney for the Petitioner,
Velma G. Conway, who is the sister of the Respondent.
The Respondent was not provided a full copy of the Citation and Petition by David A.
BariC until August 1, 2013.
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Therefore, it has allowed a very limited time to prepare a response.
The Respondent, therefore, apologizes for any deviations from conventional form and
respectfully requests that the Court focus on the substance of the response which the
Respondent has made every effort to submit within the 15 day response period.
Thanks you far your consideration.
erry ]. Gebhard, Respondent
(P�A FOR VELMA B. GEBHARD)
402 Howell Road
Exton, PA 19341
610-363-5492