HomeMy WebLinkAbout09-19-13 IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY,! PENNSYLVANIA
ORPHAN'S COURT DIVISION r
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In Re Estate of Donna J. Fritz, Deceased n/ /3 —
No. OL I
PETITION FOR CITATION TO PRODUCE THE WILL OF DONNA J. FRITZ
OR IN THE ALTERNATIVE TO SHOW CAUSE WHY
LETTERS OF ADMINISTRATION SHOULD NOT BE GRANTED
TO THE REGISTER OF WILLS OF CUMBERLAND COUNTY, PENNSYLVANIA:
Your Petitioner, Jodi A. Fritz, hereby files this Petition and respectfully represents that:
1. Your Petitioner is Jodi A. Fritz, an adult individual with a mailing address of JAF
Station, P.Q. Box 8067, New York, NY 10001.
2, Your Respondent is Robert L. Fritz, an adult individual residing at 105 Kings Highway,
Marysville, Perry County, PA 17053.
3. Petitioner is the daughter of Donna J. Fritz, ("Decedent"), a resident of Forest Park
Health Center, Carlisle, Pennsylvania, who died on June 19, 2013.
4. Respondent previously advised Petitionerthat Decedent had execute a Last Will and
Testament, the original of which was in his possession, designating the two of them
as the Decedent's sole beneficiaries and appointing them as co-executors of
Decedent's estate. Petitioner asked to be provided with a copy of that Will, which
request was ignored by Respondent. It is uncertain if such will exists or if Decedent
died intestate.
5. Decedent's sole heirs are Petitioner, Jodi A. Fritz, and Respondent, Robert L. Fritz,
who is an adult.
6. Decedent was divorced and had not remarried, and has no surviving spouse and no
surviving issue other than Petitioner and Respondent.
7. Respondent previously asked Petitioner to sign a renunciation form renouncing her
right to administer the Decedent's Estate, which Petitioner refused to do requesting
instead that Petitioner and Respondent be appointed as Co-Executors or
Co—Administrators of Decedent's Estate. Respondent also ignored that request and
has taken no action to move forward with the probate of the Decedent's alleged Will
or with the appointment of an administrator for the Decedent's Estate.
8. If there is no will, Petitioner, as Decedent's daughter, is Decedent's intestate heir,
Petitioner and is entitled to the grant of Letters of Administration pursuant to 20
Pa.C.S.A. § 3155(b).
9. Petitioner and Respondent are not able to communicate with each other.
10. Petitioner is represented in this matter by Diane G. Radcliff, Esquire, which attorney
was Decedent's Attorney-in Fact, and who managed all of Decedent's personal and
financial affairs since her appointment in January 2011.
11. Petitioner has developed a working relationship with Diane G. Radcliff, Esquire,which
will permit the orderly transition of financial information to Petitioner. No such working
relationship exists between Respondent and Diane G. Radcliff, Esquire.
WHEREFORE, Petitioner respectfully requests that a citation be awarded, directed to the
Respondent, Robert L. Fritz, to:
(a) Produce for probate the Last Will and Testament of Donna J. Fritz;
or, in the alternative
(b) Show cause why the Letters of Administration should not be granted to
Petitioner, Jodi A. Fritz by the Register of Wills of Cumberland County for the
Estate of Donna J. Fritz, deceased.
Dated: �o Respectfully submitted,
RA LI ESQUIRE
rindle Roa
Camp Hill, PA 17011
Telephone: (717) 737-0100
Supreme Court ID #32112
Attorney for Petitioner, Jodi A. Fritz
VERIFICATION
I verify that the statements made in the foregoing document are true and correct. I
understand that false statements herein are made subject to the penalties of 18 Pa.C.S.
Section 4904, relating to unsworn falsification to authorities.
Jodi A. Fntz
Date: C>W1