HomeMy WebLinkAbout02-12-14 � �
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STACY B.WOLF,ESQUIRE � Y, rn �
10 WEST HIGH STREET
CARLISLE,PA 17013-2922 C � ^n � �
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(717)241-4436 � "�.-7 G � '�
SUPREME COURT I.D.No.88732 � '�- � �� Cy5
ATTORNEY FOR PATRICIA A.BOWSER '� 7'' r' ~ +''•� c�."y
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IN RE: ESTATE OF : IN THE COURT OF COM11��T �'-�.E OF°' ,-��a
ERNEST H. BLAKE : CUMBERLAND COUNTY,�F�TIVSY�AI�I1�.>
: ORPHANS' COURT DIVISI.rb1�7; �' �-- '''
: NO. 21-2012-0088 CIVIL TEI�I � �-' `'� "��
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OBjECTIONS TO FIRST AND FINAL ACCOUNT AND
PROPOSED SCHEDULE OF DISTRIBUTION
AND NOW, comes Patricia A. Bowser, heir,by and through her counsel, Stacy B.Wolf,
Esquire, and presents these objections to the First and Final Account and Proposed Schedule of
Distribution filed on December 13, 2013 by the executrix,Pamela Vazquez, for the Estate of Ernest
H. Blake as follows:
I. OBJECTIONS
1. Patricia A. Bowser, daughter of the decedent, Ernest H. Blake, filed a Notice of
Claim in the amount of$2,212.31 on or about July 8, 2013 and a Notice of Claim in the amount of
$4,495.98 on or about September 13,2013.
2. Patricia A. Bowser has made the following payments on behalf of the Estate to
which she seeks reimbursement:
a. $2,961.48 to Parthemore Funeral Home consisting of$2,320.00 for direct cremation,
$750.00 for the storage fee, $415.00 for the transfer fee to Hershey Medical Center, $41.48 for the
Death Norice in the Patriot News, $60.00 for death certificates, and $25.00 for the County Coroner
fee (with a $650.00 courtesy discount);
b. $294.00 to Dugan Funeral Home for the urn;
c. $2,566.50 in attorney's fees;
d. $350.00 to O'Sullivan's Irish Pub & Restaurant for catering for the Wake;
e. $575.20 to Lancaster Homebrew for wine for the Wake;
£ $1,200.00 to Charlie Zahm and Tad Marks for music services for the Wake;
g. $300.00 to Reverand Craig A. Loewen for the funeral service;
h. $104.65 to Penrac,LLC for a vehicle rental from January 13-16, 2012 to transport Ms.
Bowser's father to medical appointments shortly before his death on January 17, 2012; and
i. $922.92 to Penrac, LLC for a vehicle rental from January 18-February 16, 2012 to provide
transportation to Ms. Bowser to make funeral and other arrangements following decedent's death.
3. As decedent's daughter and because decedent's Will did not otherwise provide,
Patricia Bowser was statutorily authorized by 20 Pa.C.S. � 305 to direct the disposition of her
father's remains in a manner she deemed fit.
4. Contrary to 20 Pa.C.S. � 305, the executrix has frustrated Patricia Bowser's efforts to
obtain her father's bodily remains and other autopsy materials from Hershey Medical Center.
5. Property of Patricia A. Bowser remained at the decedent's home at the time of his
death which has not been returned to Ms. Bowser despite repeated requests.
6. Patricia Bowser's property that remained at the decedent's home for which she seeks
either the return of or payment for the value of includes the following:
a. rear seat,grocery bin, and three electronic keys to her 2006 Saturn valued at$1,186.06;
and
b. printer,monitor, speakers, and cables of her computer valued at approxixnately $450.00.
7. On December 13,2013, the executrix,Pamela Vazquez, filed a First and Final
Account and Petition for Adjudication/Statement of Proposed Distribution.
8. The First and Final Account and Petition for Adjudication/Statement of Proposed
Distribution deny any disbursements to Patricia Bowser for any of the expenses she has paid on
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behalf of the Estate nor do they allow for the return of any of her property that still remained in the
decedent's home.
WHEREFORE, Patricia A. Bowser prays this Honorable Court grants her objections and
order relief as follows:
(1) Order that the Estate reimburse Patricia A. Bowser in the amount of$8,274.75 and order
the return of all items of her property.
(2) In the alternative, that the Court Order that he Estate reimburse Patricia A. Bowser in
the amount of$9,910.81.
(3) Order that the executrix Pamela Vazquez cooperate in any request Patricia Bowser makes
regarding the disposirion of the bodily remains of the decedent.
(4) Grant such additional relief that the Court deems appropriate and just.
Respectfully submitted,
WOLF &WOLF
February /a , 2014 By:
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STACY OLF, ESQ E
10 West High Street
Carlisle, PA 17013
717-241-4436
SUPREME COURT ID #88732
Attorney for Patricia A. Bowser
IN RE: ESTATE OF : IN THE COURT OF COMMON PLEAS OF
ERNEST H. BLAKE : CUMBERLAND COUNTY, PENNSYLVANIA
: ORPHANS' COURT DIVISION
: NO. 21-2012-0088 CIVIL TERM
CERTIFICATE OF SERVICE
I, Stacy B. Wolf,Esquire, attorney for Patricia A. Bowser, do hereby certify this day that I
served a copy of the foregoing Objections upon the following by U.S. mail addressed as follows:
Seth Mosebey, Esquire
Martson Law Offices
10 E. High Street
Carlisle, PA 17013
Date: February�o'Z, 2014 �
Stacy B. f,Esquire
Attorney for Patricia Bowser