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Home My WebLink About02-21-14 r nr,nl , , r;IC OF E. FF is LAW OFFICES OF PETER J. RUSSO, P.C. BY: Paul D. Edger, Esquire E3 2 1 hC1 C 7 PA Supreme Court ID: 312713 Peter J. Russo, Esquire PA Supreme Court ID: 72897 OF,IFI.::; 5 „_i,:, 5006 East Trindle Road, Suite 203 CUIJEPfitJ'',ND CO., PA Mechanicsburg, PA 17050 (717) 591-1755 Attorneys for Estate IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA In re: ESTATE OF : IN THE COURT OF COMMON PLEAS CHARLES E. STEEVER : CUMBERLAND COUNTY, PENNSYLVANIA No. 2012-1291 PETITION TO REVOKE LETTERS OF ADMINISTRATION AND NOW, comes the Estate of Charles E. Steever, by and through the attorney of record, and Administrator, Paul D. Edger, Esquire, and the Law Offices of Peter J. Russo, P.C. (hereinafter "Petitioner"), and avers the following in support of the Petition to Revoke Letters of Administration: 1. The decedent, Charles E. Steever, passed away on November 7, 2011. 2. The Estate of Charles E. Steever was opened with the Cumberland County Register of Wills on December 10, 2012, due to filing a Petition for Grant of Letters by Petitioner, after the renunciation by the decedent's closest living relative. 3. The Petition for Grant of Letters exhibited that the decedent passed away without a will. 4. Petitioner, after an extensive genealogical search, located an heir to the decedent, Marilyn Klinger, a first cousin, who resides in Lancaster, Pennsylvania. LP 5. Letters of Administration were granted to Paul D. Edger, Esquire on February 26, 2013, by then Register of Wills, Glenda Famer Strasbaugh. 6. At all times since filing the Petition for Grant of Letters, Attorney Edger has been employed as an associate attorney with the Law Offices of Peter J. Russo, P.C., located at 5006 East Trindle Road, Suite 203, Mechanicsburg, Pennsylvania 17050. 7. Due to recently discovered information, additional filings are required for the Estate, including an amended Revenue 1500, due to additional debts located of the Estate. 8. On February 14, 2014, Attorney Edger will no longer be an associate with the Law Offices of Peter J. Russo, P.C., and has accepted a position with MidPenn Legal Services, in the Carlisle Office. 9. Due to the restrictions imposed on MidPenn Legal Services, Attorney Edger is unable to handle the Estate, nor transfer the Estate with Attorney Edger to his new practice. 10. Due to Attorney Edger's transfer, he is no longer able to administer the Estate and provide the necessary responsibilities and candor on behalf of the Estate to this Honorable Court. 11. Attorney Peter Russo has indicated that he will accept, if approved by the Register of Wills, Letters of Administration naming Attorney Russo as Administrator of the Estate. A copy of the Petition for Grant of Letters, which Attorney Russo will submit to the Register of Wills upon approval by this Court, is attached hereto as Exhibit "A." 12. Marilyn Klinger, only known relative of the decedent, was notified of this Petition, and stated that she does not object. WHEREFORE, the Petitioner, Paul D. Edger, Esquire, respectfully requests this Honorable Court to grant the within Petition, and to revoke the Letters of Administration appointed to Paul D. Edger, Esquire on February 26, 2013, permit Attorney Peter J. Russo, Esquire to file for Letters of Administration of the Estate, and be listed as the attorney of record. Respectfully submitted, LAW OFFICES OF PETER J. RUSSO, P.C. By: Peter J. Russo, squire PA Supreme Court ID: 72897 Paul D. Edger, Esquire PA Supreme Court ID: 312713 5006 East Trindle Road, Suite 203 Mechanicsburg, PA 17050 Telephone: (717) 591-1755 Facsimile: (717) 591-1756 Attorneys for Estate Date: February 14, 2014 VERIFICATION I, Paul D. Edger, Esquire, attorney for the Plaintiff, verify that the statements made in the foregoing document(s) are true and correct. I understand that false statements made herein are subject to the penalties of 18 Pa.C.S. § 4904 relating to unsworn falsification to authorities. Date: J) / P D. Edge , quire EXHIBIT "A" • Reset PETITION FOR GRANT OF LETTERS REGISTER OF WILLS OF CUMBERLAND COUNTY, PENNSYLVANIA Petitioner(s) named below, who is/are 18 years of age or older, apply(ies) for Letters as specified below, and in support thereof aver(s)the following and respectfully request(s)the grant of Letters in the appropriate form: Decedent's Information Name: Charles Eugene Steever Fite No: a/kfa: (Assigned by Register) a/k/a: a/k/a: Social Security No: 208-42-4397 Dale of Death: November 7 2011 Age at death: 55 Decedent was domiciled at death in Cumberland County, Pennsylvania (state)with his/her last principal residence at 3448 Walnut Street Camp Hill Borough Cumberland Street address,Post Office and Zip Code City,'Township or Borough County Decedent died at Holy Spirit Hositak 503 N 21st Street: 17011 Canto Hill Cumberland PA Street address,Post Office and Zip Code City,Township or Borough County State Estimate of value of decedent's property at death: If domiciled in Pennsyl vania- .. . . . . .... . . ..... .... . .. All personal property $ 75 000.00 If not domiciled in Pennsylvania. —.——.—........... Personal property in Pennsylvania $ If not domiciled in Pennsy lvania. . ..... ....... . ..... .... Personal property in County $ Value of real estate in Pennsylvania.. . .. . . . . .... . . ... . . ... . . . .... . . .. . . ..... .. .... . . ..... . $_ 'TOTAL ESTIMATED VALUE. .. . $ 75 000.0(i Real estate in Pennsylvania situated at: None _ Mauch additionat sheets,ifhecessary.) Street address,Post OftiCe and Zip Code City,Township or Borough County A. Petition for Probate and Grant of Letters Testamentary Petitioner(s)averts)he/she/they islam the Executor(s)named in the last Will of the Decedent,dated and Codicil(s) thereto dated State relevant circumstances(e.g.renunriation,death of executor,etc) Except as follows: after the execution orthe instrument(s)offered for probate Decedent did not marry,was not divorced,was not a party to a pending divorce proceeding wherein the grounds for divorce had been established as defined in 23 Pa. C.S. §3323(g),and did not have a child born or adopted;and Decedent was neither the victim eta killing nor ever adjudicated an incapacitated person. 0 NO EXCEPTION'S V EXCEPTIONS ✓� B. Petition for Grant of Letters of Administration (If applicable) e.fa.,d.b_n.,dbn.e.t.a.,pendente life,durante absentia,darante mtnorkate If Administration,c.ta. or d.b.n.c.P.a.,enter date of Will in Section A above and complete list of heirs. Except as follows: Decedent was not a party to a pending divorce proceeding wherein the grounds for divorce had been established as defined in 23 Pa.C.S.§3323($)and was neither the victim of a killing nor ever adjudicated an incapacitated person. Q NO EXCEPTIONS 0 EXCEPTIONS Petitioner($),after a proper search has/have ascertained that Decedent left no W ill and was survived by the following spouse(if any)and heirs(attach additional sheets,if necessary): Name Relationship Address Marilyn B. Klinger First Cousin 201 White Oak Drive Lancaster.PA 17601 rannRFV-o2 rev. loatnoll Page I oft Oath of Personal Representative Official Use only COMMONWEALTH OF PENNSYLVANIA } } SS: COUNTY OF CUMBERLAND } Petitioner(s)Printed Name Petitioner(s)Printed Address Peter J.Russo Esquire 5006 E.Trindle Road Suite 203 Mechanicsburg, PA 17050 The Petitioner(s)above-named swear(s)or affirm(s)the statements in the foregoing Petition are true and correct to the best of the knowledge and belief of Petitioners)and that,as Personal Represcntative(s)of the Decedent,the Petitioner(s)will well and truly administer the estate according to law. Sworn to or affirmed and subscribed before Date me this—day of Date By: Date P'or the Register Dale BOND Required: Q YES Q NO To the Register of Wilts: FEES: Please enter my appearance by my signature below: Letters. . . . . . . . . . . . . . . .. .. . . . S Attorney Signature: { 2)Short Ccrtificatc(s).. . . . . ( 2 ) Renunciation(s;).. . . . . . . . ( )Codicil(s). . .. .. .... . . . ( )Affidavit(s).. . . ..._ . .. . Bond.. . . . . . . . . . . . . . . . . . . . . . Printed Name: Peter J. Russo, Esquire _ Commission. . . . . . . . . . . . . . . . . . Supreme Court Other . . . . . . . . ID Number: 72597 . . . . . . Firm Name: Law Offices of Peter J. Russo,P.C. . . . . . . . . Address: 5006 F. Trindle Road - Suite 203 . . . . . . . . Mechanicsburg PA 17050 . .. . . . Phone: 717-591-1755 Automation Fee. .. .. ... ... .. . Fax: 717-591-1756 JCS Fee. . . . . . . . . . . . . . . . . . . . . �. Email: nmcco(°n��law r_.rrin TOTAL. . . . . . . . . . . . . . . . . . . . . $ 0.00 DECREE OF THE REGISTER Estate of Charles Eueene Steever File No: alk/a: AND NOW, in consideration of the foregoing Petition, satisfactory proof having been presented before me, IT IS DECREED that Letters of Administration are hereby granted to Peter J. Russo,Esquire of The Law Offices of Peter J. Russo P.C. in the above estate and (if applicable) that the instrument(s)dated described in the Petition be admitted to probate and filed of record as the last Will(and Codicil(s))of Decedent. Register of Wilts FormNFKO2 re«, rariu2air Page 2 of LAW OFFICES OF PETER J. RUSSO, P.C. BY: Paul D. Edger, Esquire PA Supreme Court 1D: 312713 Peter J. Russo, Esquire PA Supreme Court ID: 72897 5006 E. Trindle Road, Suite 203 Mechanicsburg, PA 17050 (717) 591-1755 Attorneys for Estate IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA In re: ESTATE OF : IN THE COURT OF COMMON PLEAS CHARLES E. STEEVER : CUMBERLAND COUNTY, PENNSYLVANIA No. 2012-1291 CERTIFICATE OF SERVICE I, Derek M. Strouphauer, Paralegal, hereby certify that I have served a true and correct copy of the foregoing document upon the following persons, in the manner indicated: Via Hand Delivery Peter J. Russo, Esquire Law Offices of Peter J. Russo, P.C. 5006 East Trindle Road, Suite 203 Mechanicsburg, PA 17050 IHE LAW OFFICES OF PETER J. RUSSO, P.C. BY: D roup ra Date: /��/ �/C-�