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HomeMy WebLinkAbout11-20-13 go ZZ, rnrn m on U O m2 e_ e coX rte- v -•-I b c� C'� a a ca oar �i ) C3 c G) C!) O THE MATTER OF CUMBERLAND COUNTY THE ESTATE OF OFFICE OF REGISTER OF WILLS PATRICIA M. SHAW NO. 21-13-0815 MOTION TO MAKE CITATION ABSOLUTE AND NOW THIS i Q day of November, 2013, comes Theresa L. Shade Wix, Esquire, attorney for the Estate of Patricia M. Shaw and its Administrator, Vernon D. Edwards, Petitioner, and makes the following Motion. 1. On August 27, 2013, Petitioner filed a Petition for Approval of the Sale of Real Estate relating to the above-referenced matter. 2. On September 3, 2013, a Citation returnable twenty (20) days from service was issued by the Honorable Thomas A. Placey. 4. The Citation was issued upon all interested parties to show reason, if any, why Petitioner, Vernon D. Edwards, Administrator of the Estate of Patricia M. Shaw, should not be permitted to sell the property located at 1759 Sheepford Road, Mechanicsburg, Pennsylvania for the total purchase price of$8,500.00. 3. The Citation was served upon Vernon Edwards, Eugene Edwards and Bonnie VanGundy as per the attached Affidavit of Service, and copies of Certified Mail return receipt cards marked as Exhibit "A". 4. No Answer to the Citation has been filed within the applicable time period. WHEREFORE, Your Honorable Court is respectfully requested to grant the relief requested in the Petition for Approval of the Sale of Real Estate and to enter the attached Order. Respectfully submitted, By J�Ct�o�w J l/l/ G Theresa L. Shade Wix, Esq., ID #43089 4705 Duke Street Harrisburg, PA 17109 (717) 652-8455 Attorneys for the Estate of Patricia M. Shaw and its Administrator, Vernon D. Edwards 2 THE MATTER OF CUMBERLAND COUNTY .THE ESTATE OF OFFICE OF REGISTER OF WILLS PATRICIA M. SHAW NO. 21-13-0815 Affidavit of Service Personally appeared before me, Theresa L. Shade Wix, Esquire, who being duly sworn, deposes and says as follows: 1. I am the Counsel of Record for the Estate of Patricia M. Shaw. 2. On September 13, 2013, by U.S. Postal Service, Certified Mail/Return Receipt and by Regular Mail, I sent a copy of the Petition for Approval for the Sale of Real Estate and the Order of Court of September 3, 2013, executed by the Honorable Thomas A. Placey, to the following persons: Vernon Edwards Eugene Edwards Bonnie VanGundy. 12517 Kent Road " 2314 Riverview Ter 5431 Parson C*el f3d:1 King George, VA 22485 Alexandria; VA 22303 Alexande�ity, AL)35©'a0? v - M C� ,. r m Y c c And served the same by facsimile to: Robert C. Saidis, Esq. : -� � Saidis, Sullivan & Rogers ° o o 26 West High Street o c Carlisle, PA 17013 (717) 243-6510 (Fax)- n " o co o '*� Theresa L. Shade Wix, Esquire Sworn to or affirmed and acknowledged before me this I3'r' day of s 2013. Notary;P lic My Commission Expires: COMMONWEALTH OFPENNS'I VA i:. NOTARIAL SEAL GAYE CRIST,Notary PubBc Lower Paxton Twp.,Dauphin County My Commissar 18, Exhibit "A" CERTIFICATE OF SERVICE AND NOW, this 13th day of September, 2013, I, Gaye Crist, an employee of the firm of Wix, Wenger & Weidner, attorneys for the Estate of Patricia M. Shaw, hereby certify that I served the within Affidavit of Service this date by faxing a copy addressed as follows: Robert C. Saidis, Esq. Saidis, Sullivan & Rogers 26 West High Street Carlisle, PA 17013 (717) 243-6510 (Fax) WIX, WENGER & WEIDNER Gaye Cri SENDER:COMPLETE THIS SECTION COMPILET�THIS SECTION ON VERY I ■ Complete Items 1,2,and 3.Also complete a Sign re i item 41f Restricted Delivery is desired. ❑Agent I ■ Print your name and address on the reverse ❑Addressee so that We can return the card to you. I B. eWed by(Pd ed Name) C. Date of Delivery ■ Attach this card to the back of the mailplece, ,,;;. ! or on the front if-space perks, 1. Article Addressed to: D. Is deli � p from it 1?, ❑Ve If rter delivery h ovv-.. Ms. Bonnie VanGundy �y 5431 Pearson Chapel Rd. Alexander City, AL 35010 Q ° . Service Type Mail ❑ Mil Reg ❑ m R pt for Merchandise ured C.O.D 4. R rA. Fee) ❑Yes 2. Article Number (nansferfromsenviceratrep 7008 2810 0001 6233 9837 I Ps For 3811,February 2004 Domestic Return Receipt 102595-02+n-1s40 , i SENDER:I COMPLETE •N COMPLETE THIS SECTION ON DELIVERY ! ■ complete Items 1,2,and 3.Also complete A. tum ,GE I Item 4 if Restricted Delivery is desired. I ■ Print your name and address on the reverse Ad so that we can return the card to you. B, �r& �by( Name Y C. of De ■ Attach this card to the back of the maiipiece; V, '! 7 or on the front if space permits, lv .�.�, D. Is delivery address Oigerent 1? OI I 1. Ankle Addressed to: �,tf k YES enter delivery address 1 ( I ; Mr. Vernon Edwards 2248 12517 Kent Road ; King George, VA 22485 . 3. Service Type di Certified Mall ❑Express Mall - ❑Registered ❑Return Receipt for Merchandise j ❑Insured Mail ❑C.O.D. I 4. Restricted Delivery?(Extra Fee) ❑Yes I j2. Article Number 700$._2810 0001 6233 9844 . (Ransfertrom.servkelaW u- i ! I Ps Form 3811,February 2004 Domestic Return Receipt 102595ae44a547'1 SENDER: COMPLETE THIS SECTION COMPLETE THIS SECTION ON DELIVERY r I I ■ Complete items 1,2,and Also complete A Signature ! item 4 if Restricted Delivery Is desired. ❑Addre j ■ Print your name and address on the reverse - X ❑Addressee i ' so athl can return the card to you. try,(`n ) . Date of Delivery ■ Atts card to the back of the mallpiece, u ,A or M k space permits. D. Is delivery address dite 1? 11. Aril tip i ressed to: if YES,enter delivery ❑ M ugene Edwards l " S a j 1 231Q Riverview Ter i Q3f o I Alexandria, VA 22303 e ' 3. Service Type EXCertllled Mail ❑Express Mall ❑Registered ❑Return Receipt for Merchandise ❑Insured Mall ❑C.O.D. I 4. Restricted Delivery!(Extra Fee) ❑Yes THE MATTER OF CUMBERLAND COUNTY THE ESTATE OF OFFICE OF REGISTER OF WILLS PATRICIA M. SHAW NO. 21-13-0815 CERTIFICATE OF SERVICE AND NOW, this 1911 day of November, 2013, I, Gaye Crist, an employee of the firm of Wix, Wenger & Weidner, attorneys for the Estate of Patricia M. Shaw and its Administrator, Vernon D. Edwards, hereby certify that I served the within Motion to Make Citation Absolute this date by depositing a copy of same in the United States mail, postage prepaid, in Harrisburg, Pennsylvania, addressed as follows: Vernon Edwards Eugene Edwards Bonnie VanGundy 12517 Kent Road 2314 Riverview Ter 5431 Pearson Chapel Rd. King George, VA 22485 Alexandria,VA 22303 Alexander City, AL 35010 And served the same by facsimile to: Robert C. Saidis, Esq. Saidis, Sullivan & Rogers 26 West High Street Carlisle, PA 17013 (717) 243-6510 (Fax) WIX, WENGER &WEIDNER ,9� Gaye Cr19t