HomeMy WebLinkAbout08-23-13 : IN THE COURT OF COMMON PLEAS
: CUMBE�tLAND COUNTY,PENNSYLVANIA
In re: Estate of Robert W. Kraly : ORPHANS' COURT DIVISION
: No. 2012—00754
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OBJECTIONS OF ARLENE J. NEUMYER TO�- � - �
ACCOUNT OF MURREL R. WALTERS, III, EXECUT(��:AND ., .
TO THE PROPOSED STATEMENT OF DISTRIBUTIQ�N aF f�_� .
THE ESTATE RESIDUE OF ROBERT W. KRALEY, DE�FA�ED '"�'
_.. - • ---, �
Pursuant to Orphans Court Rule 6.10, Arlene J. Neumyer, beneficia�i�of the atiove
f�:
captioned estate,by her undersigned attorneys, objects to the First and Final`Account d�Murrel-�.
Walters, III, Executor of the Estate of Robert W. Kraly, Deceased, and to the proposed
distribution, averring the following:
1. Robert W. Kraley died testate on June 25, 2012.
2. Objector Arlene J.Neumyer is the step-daughter of Robert W. Kraly,
deceased, as well as a specific beneficiary named in decedent's will and a named
beneficiary of the Robert W. Kraly Trust. Mrs. Neumyer resides at 119 North Market
Street, Mechanicsburg, Cumberland County, Pennsylvania 17055.
3. Executor Murrel R. Walters, III, is an attorney with a business address of
54 East Main Street, Mechanicsburg, Cumberland County, Pennsylvania 17055.
4. Attorney Murrel R. Walters, III, was the scrivener of decedent's will
executed on April 18, 2012.
5. The Register of Wills granted Letters Testamentary to Attorney Murrel R.
Walters, III, on July 11, 2012.
6. Attorney Walters was the decedent's Attorney-in-Fact and, as such, had
1
unfettered access to decedent's finances.
7. Attorney Walters was named as the trustee of a testamentary trust in
decedent's will. (See Section X of will dated April 18, 2012).
8. On July 17, 2013,Attorney Walters,through attorney David R. Galloway,
filed a Notice of Filing Account with a Schedule of Proposed Distribution By Murrel R.
Walters, Executor. The Notice required exceptions or objections to the Account to be
presented to the Court on Tuesday, August 27, 2013 at 9:00 a.m.
9. The First and Final Account of Attorney Murrel R. Walters, III, Executor,
filed with the Court on July 17, 2013, lists a beginning balance of accounts that Mrs.
Neumyer believes to be severely lacking. For example,the sale of the real estate located at
1802 McCabe Road, Landisburg, Tyrone Township, Perry County, Pennsylvania on or
about Apri12, 2010,the proceeds of which was $180,000.00, none of which appears to be
accounted for in the accounting.A true and correct copy of the recorded deed for the Perry
County property is attached as E�ibit A.
10. Decedent had life insurance which has not been paid out,to the best of
Objector's knowledge. Attorney Walters has been unwilling to share any information
with Mrs. Neumyer concerning this or most other pieces of financial information
concerning the decedent.
11. Objector requests that this Court order an accounting by Attorney-in-Fact
Walters of all of the assets he disbursed, directly or indirectly, and of the work he
performed, and all actions he performed, including all fees which he was paid for his work
as the Attorney-in-Fact, from three years prior to the decedent's passing to his date of
2
death.
12. As the trustee of a testamentary trust in decedent's will,Attorney Walters
will be paid as the Trustee of the testamentary trust.
13. It is believed that Attorney Walters, III, as the scrivener of the decedent's
will,was paid by decedent for his services rendered.
14. The Accounting calls for Attorney Walters to be paid $10,950 as the
executor of decedent's estate.
15. The Accounting calls for Attorney Galloway, who shares the same office,
has the same physical address and shares the same phone number with Attorney Walters,to
be paid the same amount as the executor for legal work in the administration of the
decedent's estate - $10,950. A true and correct copy of the business listings for Attorneys
Walters and Galloway is attached as Exhibit B.
16. Objector believes that Attorney Walters is `double dipping' fees,having the
attorney with whom he shares an office collect these fees.
17. Objector requests this Court reduce the fees to one-half the amount listed on
the Accounting for both Attorneys Walters and Galloway.
18. The Accounting lists proceeds from the sale of the house at 109 Skyline
Drive, Mechanicsburg, Cumberland County, Pennsylvania, in the amount of$140,000.
The value of the house was approximately $100,000 more than the selling price. The
house was not sold for fair market value. It is not known whether the house was listed
with a licensed realtor or what efforts were made to secure the best price possible and
thereby maximize the esta.te, according to the Probate and Estates Code. A true and
3
correct copy of the Deed for the above mentioned property as well as the real estate
assessment information is attached as Exhibit C.
19. Objector requests this Court surcharge Attorney Walters the difference
between a Fair Market Value price for the sale of the house at the date of the sale,as arrived
at by a licensed appraiser, and the selling price, and that those proceeds be added to the
residue of decedent's estate.
20. On March 18, 2013, Mrs. Neumyer wrote to Attorney Walters seeking
information about the administration of the estate. While Attorney Walters did send a
response on March 20, 2013,most of Mrs.Neumyer questions were left unanswered. A
true and correct copy of the March 18, 2013 and March 20, 2013, correspondence is
attached as Exhibit D.
21. One item that Mrs. Neumyer has inquired about, but to which she has not
been able to receive a response, is when she can pick up the jewelry that belonged to her
mother.
22. Decedent had given to Attorney Walters jewelry that belonged to
decedent's late wife for Mr. Walters to safe guard.
23. Attorney Walters has refused to show Mrs.Neumyer the jewelry or provide
any information about its worth.
24. Attorney Walters has refused to release the jewelry to Mrs. Newmeyer.
See Exhibit D.
25. The Accounting does not list the jewelry.
4
26. The Accounting does not list other personal items belonging to decedent,
including but not limited to coins.
27. In addition to the matters described above,the Accounting has various
questionable transactions, including but not limited to the following items:
a. Under Disbursements,the payment of$16,886.00 to Myer-Buhrig
Funeral Home. While Objector was consulted by Attorney Walters to plan the
funeral and select items, she has not seen an itemized bill for the funeral and
believes the price to be excessive.
b. Under Disbursements, a total of$2,860.00 was paid to Chuck E.
Bricker,Auctioneer, for appraising and selling personal property that had a gross
sale receipt of$5,919.25. Objector believes the commission of the auctioneer to
be excessive. Additionally, Objector has not seen an itemized list of the personal
items that were sold at auction by Chuck Bricker.
c. Under Disbursements, $2,016.58 was paid to an unknown entity or
person for"expenses of sale of residence." Obj ector does not know to whom these
funds were given and for what specific purposes.
d. Under Disbursements, $170.00 were charged by M&T Bank for"Fees
and Service Charges"for Account XXX-2919,which is listed as having$4,210.12.
Objector does not know what these fees and service charges are and why they are so
high.
e. Under Partial Distributions to Beneficiaries, it is listed"Specific
Bequests—Trust Disbursements: TO: ROBERT W. KRALY TRUST�Arlene J.
5
Neumyer, Beneficiary" with 11 payments of cash beginning 8/20/2012 and ending
06/25/2013.
WHEREFORE, Objector Arlene J.Neumyer requests this Court to:
A. Order an accounting by Attorney-in-Fact Walters of all of the assets he
disbursed, directly or indirectly, and of the work he performed, and all actions he
performed, including all fees which he was paid for his work as the Attorney in
Fact, from three years prior to the decedent's passing to his date of death;
B. Reduce the fees to one-half the amount listed on the Accounting for
both Attorneys Walters and Galloway;
C. Surcharge Attorney Walters the difference between a Fair Market
Value price for the sale of the house located at 109 Skyline Drive, Mechanicsburg,
PA, at the date of the sa1e, as arrived at by a licensed appraiser, and the selling
price, and that those proceeds be added to the residue of the decedent's estate;
D. Order Attorney Walters to turn over the jewelry of Mrs. Neumyer's
mother to Arlene J. Neumyer;
E. Appoint an auditor to pass upon the remaining Objections; and
F. Provide any further relief the Court deems just and proper.
Respectfully submitted,
Dated: g z3 �3 '""""`� '
Mark A. Mateya(P 78931)
Alexandra Makosky (PA 80267)
Mateya Law Firm, P.C.
5 West Church Avenue
Carlisle, PA 17013
(717) 241-6500 (Office)
(717) 241-3099 (Fax)
Attorneys for Objector
Arlene J.Neumyer
6
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WENDY M.WELFLEY -- ��:,
PERRY CUUNTY RECORDER OF DEEDS
2 East Main Street __ _�
New Bloamfield,Penosylvania 17068 _ "�� ,
(717)SSZ 2131 ���.; ." -�
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Recorded On 4/5l2010 At 9:49:50 AM �'=--�_--`'�-=-�� ��- -
� an.a.n�awr wo�t�n.us�nu
*Inatrument T�pe-DEED
Invoice Nnmber-88107
*Grnntor-KRALY,ROBERT W
*Grantee-PLACE,ROGER A JR
�Customer-ABSTRACT AMERICA REAL ESTATE
*FEES *Total Pages-4
STATE TRAN$SER TAX $1,800.00
STATE �PRIT TAX $0.50
JCS/ACCSS3 TO 3LJSTICE $23.5�
RECORDING FEES - �is.oo This is a certification page
RECORDBR OF DBEDS
2►rrFOr��T.F HOIISING s�o.oo DO NUT DETACH
conrrrY �xcsnr�s �� $2.o0
RECORDBR'8 ARCHIVES FEE $0.50
- To covx�ry This page is now part
x�coRn�x n�ROV�rrr �2.50 of this tegal document.
FUND – TO OFFICE
�ST PERRY SCHOOL $9�0.00
DI$TRICT REALT7C TAX
T3[RONE TO�iNSHIP $900.00 *RETURN DOCUMENT TO:
TOTAL PAID $3,6S2.00 ABSTRACT AMERICA REAL ESTATE
65 KEN MAR DR1VE
SHERMANS DALE,PA 17090
I hereby CERTIF'Y that this document is
recorded in the Recorder of Deeds Offfce
of Perry County,Pennsylvania.
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the veri5cation process aad may oot be reflected on t6is page.
Instrument Number:201042468 oo�oos
EXHIBIT IfIIIIIIIIIIIIIIIIiM�IIINI
�
Prepared by�
Murrel R.Walters III,Esq.
54 East Main Street
Mechanicsburg, PA 17055
Paroel No. 270,194.00-002.000
Property Addreas�
1802 McCabe Road
L�n.disburg,PA 17040
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MADE THIS 2nd day of April, in the year of our Lord two thousand ten (2010).
BETWEEN ROBERT W. KRALY, a single man,
Grantor,
and, ROGER A. PLACE, JR. and CYNTHIA K. PLACE, �
husband and wife,
Grantees,
WIfiNE3SETH, that in consideration of ONE HUNDRED EIGHTY THOUSAND- - - •
- ($180,000.00} D4LI.AR, in hand paid, the receipt whereof is hereby acknowledged,
the said grantor does hereby grant and convey to the said granteea, their heire and
assigns,
ALL THOSE CERTAIN lots or parcels of land, situate in Tyrane Township,
Perry County, Pennsylvania, as set forth on a Final Subdivieion Plan for Robert W.
Kraly and Mildred C. Kraly, husband and wife, dated January 8, 2002 as prepared
by ACT 1 Consultants and more particularly described as fvllows�
Tract No. 1
BEGINNING at a point in McCabe Road (ExtendecU� thence along McCabe
Road {Extended) South 61 degrees 9 minutes 18 seconds West, a distance of 378.80
feet to a point� thence continuing along McCabe Road {Extendec� South 5,0 degreea 21
minutes 13 eeconds West, a distance of 300.Q0 to a point� thence continuing along
McCabe Road (ExtendecU South 57 degrees 45 minutes 46 secands West, a distance of
222.75 feet to a point� thence North 34 degrees 54 min.utes 35 seconds West, a
diatance of 1,259.32 feet to a point� thence North 54 degrees 30 minutes East, a
distance of 222.7� feet to a Roint� thence North 31 degrees 30 minutee 00 seconds
East, a distance of 891.00 feet to a point� thence North 46 degrees 15 minutes East, a
distance of 132.Q0 feet to a point� thence North 36 degrees 15 minutes East, a
distance of 137.70 feet to a point at Corman Road; thence South 23 degrees 7 minutes
00 seconda Eaet, a distance of 299.10 feet to a point� thence South 20 degrees 29
minutes 12 aeconds East, a distance of 306.86 feet to a point� thence South 2U degrees
35 minutes 45 seconds East, � distance af 4C9.28 feet to a point� thence South 20
degrees 42 minutes 11 seconds East, a distance of 39.09 feet to a point� thence South
22 degrees 5 minutes 52 seconds East, a distance of 293.78 feet to a point; thence
South 22 degrees 41 minutes 17 seconds East, a distance of 347.4� feet to the point
and place of BEGINIVING.
BEING Tract No. 1 on the aforementioned plan and containing 35.638 acres
more ar less.
Tract No. 2
BEGINrTING at a point in McCabe Road (ExtendecU� thence South 22 degrees
41 minutes 17 seconds East along a Log Road, a distance of 421.80 feet to a point�
thence South 65 degrees 12 minutes 54 seconds East, a distance of 628.43 feet to a
point� thence North 29 degrees 5 minutes 49 seconds West, a distance of 318.66 to a
point; thence along MeCabe Road {Extended) Narth 50 degrees 21 minutes 13 seconds
East, a distance of 300.00 feet to a point; thence continuing along McCabe Road
(ExtendecU North fil degrees 9 minutes 18 seconds Ea�t, a distance of 378.80 feet to
the point and place of BEGINrTING.
BEING Tract No. 2 on the aforementioned plan and containing �.749 acres
more or less and improved with a two-story frame dwelling.
BEING Tract No. 1 and Tract No. 2 on the deed which R,obert W. Kraly and
Mildred C. Kraly, husband and wife, and Elizabeth Fleieher, formerly Elizabeth Jane
Flickinger, and Ronald S. Fleisher, wife and husband, by their deed dated August 1$,
1992 and recorded in Perry Caunty Deed Book 0693, Page 123, granted and conveyed
unto Robert W. Kraly and Mildred C. Kraly, husband and wife.
Mildred C. Kra�y died March 27, 2004, whereupon sole title became vested in
Robert VV. Kraly by virtue of the doctrine af survivorship incident to tenanciea by
the entireties.
The said grantor hereby covenants and agrees that he will warrant specially
the property hereby conveyed.
M 9 y p
IN WITIVES3 WHEXE�F, said grantor has hereunto set his hand and seal the
day and year first above written.
,Si"gnea�Sealed and IJelive�d'
Jn the Pt�sence of
�
) BERT W. KRALY
Cammonwealth of Pennsylvania )
ss.
County of Cumberland )
On this, the �N� day of , 2010, before me, the undersigned
o�'icer, personally appeared ROBER W. KRALY, known to me (or satisfactorily
prover� to be the person whose name is subscribed to the within inatrument, and
acknowledged that he executed same for the purposes therein contained.
IN WITNESS WHEREOF, I hereunto set my hand and official seal.
�
.
,
,
Notary Pub � �JQ�pRfAl SEAL
D1ANE M SMITH
Nolary publlc
MECFi/WICSBUR6 80R0,CUNieERIaWD CNIY
lV1y Commiaalon Ezpires 3un 22, 20T2
I do hereby certify that the precise residence and complete post office address
of the within named grantee is� � � (��,¢������� ,�j.�C�
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__ _ _ _ _ __ _ _ _ _ _ _ _
VTACT 54 E Main St
�RMATI{�(� Mechanicsburg,PA 17t?55
Office:717-697-4650
QView map � Edit this addre�s
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03A,11.
Prepared by and return to=
Murrel R.Walters III, Esq.
54 East Main Street
Mechanicsburg, PA 170b5
717-697-4650
Tax Parael No.� 38-18-1336-019
Property Address=
109 Skyline Drive
Mechanicsburg, PA 17050
���� �����
MADE THIS �`� day of ��uv��� , in the year two thousand thirteen(2013).
BETWEEN
MURREL R. WALTERS, III, ESQUIRE, Executor of the
ESTATE OF ROBERT W. KRALY,
Grantor,
anr�
SHARON K. FOLTZ,
Grantee,
WHEREAS, Robert W. Kraly was vested in his lifetime with premises
hereinafter described, situate in Cumberland County, Pennsylvania� and
WHEREAS, the said Robert W. Kxaly died June 25, 2012� and
WHEREAS, Murrel R. Walters, iII, Esquire, qualified as Executor of the
Estate of Robert W. Kraly and the Cumberland County Register of Wills assigned the
Estate No. 21-12-0754.
EXHIBIT
�
__. ni u�nrn� nnin r�ni i��TV Inet it 7MAf1717F,_Pa�o 1 nf F
NOW T�iIS INF?ENTURE WITNESSETH, that the said Grantar, for and in.
consideration of the sum of ONE HLTNDRED AIVD FORTY TH4U�AND - - - - -
{$140,OQQ.00} DQLLARS, lawful mcsney of the United 5tates, tc� him in hand paid by
the said Grantee, at and befare the sealing and deliver hereof, the receipt whereaf is
hereby acknowledged, has granted, bargained, sold, aliened, released and corifirmed,
and by these presents, and does grant, baxgain, �ell, aiien, release and confirm unto
the said Grantee, his heirs and assigns,
ALL THAT CERTAIN lc�t of land situated in Silver Spring TQwnship,
Cumberland County, Pennsylvania, bounded and described, as follows�
BEGINNII�TG at a point at the Sautheast corner of the a�.ntersection of
Township R,�ad 581 and Christina Street� thence North fi0 degrees 27 minutes 40
seconds East along the Southerly line of Township Road 581, one hundred eighty-
nine and eighty-six ane-hundretiths (1$9.86) feet t4 a pointr the�ce by land naw or
formerly of Nesbit H. Banga, South 40 degrees 15 minutes 2{} seeands East, two
hundred three and ninety-six one-hundredths {203,96} feet to a point� thence by
lands now ar formerly of Fred B, Dapp, Jr. and now or formerly of Harry S. Hodge,
South. 6Q degress 27 minutes 4Q seconds West, two hundred twenty-nine and
eighty-three one-hundredths (229.83) feet to a point on the Easterly line of
Ghristina Street� thence by the latter line �rl'orth 29 degrees 32 minutes 20 seconds
West, two hunclred (2�}0} feet ta the place of BEGINN�ING.
BEING Lots Nas. 19 and 20 on a Plan af Sectian .A, Ridge Hills, said Plan
being recorded in Plan Book 14, Fage 29, Cumberland County Records.
HAVING THEI�EON ERECTED a dwelling house and numbered as 109
Skyline Drive.
BEING the same premises which Alice J. Ftrltz, widow, by Deed dated May 2,
1990 and recorded in Cumberland County in Deed Book 34N, Page 94Q, granted
and conveyed unta Robert W. F�raly and M�.dred C. Kraly, husband and wife.
l��il.dred C, I�raly died Mareh 27, 2004 whereupt�n sole title became vested in
Robert W. Kraly by virtue of the doctra.ne of survivorship incident to tenancies by the
e�tireties.
__...,_..._ ._„. .,,R.. rr tnaocpr nn�n rn��ni�rv inet#9t793iS:i17.5-Paae 2 af 5
TOGETHER, with all and singular the building and improvements, ways,
waters, water•c�urses, rights, liberties, privileges, hereditaments and appurtenances
whatsoever thereunto belonging, ar in anywise appertaining, and the reversions and
remaindere, rents, issuea and profita thereo� and also, all the estate, right, title,
interest, use, trust, property, passession, claim and demand whatsoever, in law,
�{�Ul��OP Ot�1G'2'W1S£� �1flWSt}�VB�, of, in, to or out af the same�
T4 HAVE AND �O HOLL?, the said hereditaments and premises hereby
granted and relea�ed, or mentioned and intended sa ta be, with the appurtenances,
uuto the said Grantee, her heirs and asszgns, ta and for the vnly praper use and
behoof af the said Grantee, her hei�rs and assigns, forever.
And the said Grantor does covenant, prflmise and agree to and with the said
Grantee, her heirs and assigns, by these presents, that �he said Gxantor has not dane,
committed, or knowingly or willingly suffered to be done or committed, any act,
matter or thing whatsoever whersby the prennises hereby granted, or any part
thereof, i9, are, shall ar may be impeached, charged or eneumbered, in titie, charge,
estate, ar otherwise hawsoever.
- --- nr�r�ocnt nn�n tnn��n�TV Inct i!^f11'�t1z17F-Pana:�nf 5
_ _
. ,
�
IN WITNESS WHEREOF, said grantor has hereunto set his hand and seal the
day and year first above written.
Signed,Sealed and Delivened
it1 the PnesenCe of
� •
}
�
�
) MURREL R. WALTERS, III, ESQUIRE
) Executor of the Estate of Robert W. Kraly
Commonwealth of Pennsylvania )
ss.
County of Cumberland )
On this, the ��� day of J_l,�,�U-lCc� , 2013, before me, the undersigned
officer, personally appeared MLTRREL R. W�TERS, iII, Executor of the Estate of
Robert W. Kraly, known to me (or satisfactorily proven) to be the person whose name
is subscribed to the within instrument, and acknowledged that he executed same for
the purposes therei.n contained.
IN WITNESS WHEREOF, I hereunto set my hand and official seal.
caKMONwFU ���snvrwu
��.��� !e � ,� • �/
�p eaa a�noi�a 2�xr �,G`l I'`t'U u C-G�-
��a��u ���� tary Public
I do hereby certify that the precise address of the within named grantees is�
286 Ridge Hill R.oad, Mechanics g, PA 17050
�_
Attarney for Grantees
..��..nrn� n�in rn�iniTV incr�e�n�ana���-Paaa a nf 5
. .
.
ROBERT P. ZIEGLER
REC�RDER tJF DEEDS
CUMBERLAND COUNTY
,�
1 COURTI�OUSE SQI3ARE ' `�. - -~;� '
..-r.
CARLISLE, PA 17013 � '�
71'7-24tF-6370 = �
;
:� '� ' �
.,.,�,:,.�,�: ..
Instrumeat Number-ZU1303175
Recarded C?n 1/30/2013 At 10:1�:16 AM *Tata!Pages-5
*Instrnment Type-DEED
Invoice Number-12$OSS User II3-MSW
*Grantor-KRALY,ROBERT W
*Grantee-FOLTZ,SHARON K
*Customer-WAIITERS
*�'EE5
STAT� TRAN3FER TAX �r,�oo.00 +Certification Page
3TATE WRZT TAX $0.50
STA'TE JCSjACCESS �.'{} $23.SE? DtJ Nt3T DETA�H
JUSTICE
RECORDING FL88 — $11.50
RECdRDER OF DEEDS Tbis page is now part
PAACEL CERTISZCAT20N $io.o0 of this legal document.
FEEB
AE'E'ORDABLE HC?USING $11.54
COUNTY ARC�iIVE3 FEE $2.00
ROD ARCHIVES FEE $3.00
CI7t�ERLRl�`D VAI.LEY $7 CI0.0 0
SCHOCJL DI3TRZCT
SILVER SPRING TC?I�'SHIP $?00.00
TOTAI� PAIA $2,862.00
I Certify this to be recorded
in +�umberiaad County PA
�-,�',r'"`r'`'"`TI .
RECORD�R O�
,r�ao
*-Infarmation denoted by�a asterisk may c6inge daring
the veri�cstion procesa and may not be reflected oo t6is page.
003AJL
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MURREL R.WALTERS, III
Attorney at Law
54 East Main Street
Mechanicsburg,Pennsylvania 17055-3851
(717) 697-4650 (717) 697-9395 Fax
March 20, 2013
Arlene J.Neumyer
119 N.Market Street
Mechanicsburg,PA 17055
Dear Arlene:
I am responding to your recent letter and enclosing the March$2,000 payment to you.
The sale of the house permitted us to finalize the Inheritance T� Return. The return was
filed in February. Normally the Department of Revenue takes three months to audit an account.
There is no assurance with that schedule but my guess is that we will receive confirmation in June.
At that point we will be in a position to file a Formal Account with the Court. After the
account has been confitmed I will make distribution to all beneficiaries.
I will contact you to review the items,I have retained. ,� �
..,,::,.
r;�
Very truly�ours,
;^ .�� �,'`
` a'
;
�
_� �
Murrel R.Walt rs, III
MRW/rs
enclosures
_ _ , ,.� s_. . .�, ., .._ . ..�. >r, ,. ,� .,� .�. � � . ���
VERIFICATION
I, ARLENE J.NEUMYER, verify that the facts set forth in the foregoing Objections are
true and correct to the best of my knowledge, information, and belief. I further verify that I am a
beneficiary of the last will and testament of Robert W. Kraly, deceased;that the objections above
set forth are not filed for the purpose of delay,but because it is believed that they raise a proper
question regarding the assets and liabilities of Decedent's estate and the balance available for
distribution to the parties fairly entitled thereto, and to prevent injustice in the administration and
distribution of Decedent's estate. I understand that false statements are subject to the penalties of
18 Pa. C.S. § 4904 relating to unsworn falsification to authorities.
� .�'`.�
ARLENE J. MYER
CERTIFICATE OF SERVICE
I, Mark A. Mateya, Esquire,hereby certify that on the date listed below, I have served a
copy of the foregoing document on the following person by depositing a true and correct copy of
the same in the United States Mail, by way of United States Mail,first class,postage prepaid,
addressed as follows:
David Galloway, Esquire
54 East Main Street
Mechanicsburg, PA 17055
� _ �
,�j J 3 Mark A. Mateya, quire
Dated: g