HomeMy WebLinkAbout03-04-14 IN RE: ESTATE OF DOROTHY E. POMRANING : ORPHANS' COURT DIVISION
LATE OF THE BOROUGH OF CARLISLE : COURT OF COMMON PLEAS
: CUMBERLAND COUNTY
: PENNSYLVANIA
: NO. 21-13-0672
: Prior Judge: Christie L. Peck
PETITION TO MAKE RULE ABSOLUTE
AND NOW, comes Petitioner, Keith L. Pomraning, by and through his counsel,
Bradley L. Griffie, Esquire, and the law firm if Griffie & Associates, P.C., and
Petitions the Court as follows:
1. Your Petitioner, Keith L. Pomraning, is an adult individual currently residing at
298A McAlister Church Road, Carlisle, Cumberland County, Pennsylvania, and
is the Administrator of the estate of Dorothy E. Pomraning.
2. Petitioner filed a Petition for Settlement of a Small Estate in this matter on
January 2, 2014, a copy of said Petition being attached hereto and incorporated
herein by reference as Exhibit"A".
3. As a result of filing the Petition, the Court issued an Order of Court and Rule to
Show Cause dated January 8, 2014, which Rule was issued upon the
Commonwealth of Pennsylvania Department of Public Welfare to show cause, if
any they had, as to why their claim for Medicaid reimbursement should not be
discharged and otherwise why the requested distribution set forth therein by
Petitioner should not be approved, a copy of said Order of Court and Rule to
Show Cause being attached hereto and incorporated herein by reference ok,
Exhibit"B". V 5
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4. By certified mail, a true and attested copy of the Order of Court and Rule to
Show Cause and Petition were served upon the Department of Public Welfare
(DPW), with service being made on January 21, 2014, a proper Affidavit of
Service, which included the signed and dated certified mail card being attached
thereto,being filed of record in this matter.
5. More than thirty (30) days have passed since service upon the Commonwealth of
Pennsylvania Department of Public Welfare and no response has been filed.
6. It is appropriate to make the prior Rule absolute and enter an Order-finalizing the
settlement of this estate in all respects.
7. Petitioner is the natural son of the decedent, Dorothy E. Pomraning, and decedent
was also survived by one other child, namely, Mary L. Geisweit, of 50 East
Water Street,Middletown,Pennsylvania, 17057.
8. Mary L. Geisweit has been provided with a copy of the prior Petition and Order
of Court and Rule to Show Cause; in addition, Mary L. Geisweit has participated
with your Petitioner relative to reviewing all assets and debts of the estate and
concurs in the request made herein.
9. Since the filing of the prior Petition for Settlement of a Small Estate, no
additional assets have been made known to Petitioner, nor have any additional
claims been made known to Petition.
WHEREFORE, Petitioner requests your Honorable Court to enter an Order Ordering
and Decreeing that the Commonwealth of Pennsylvania Department of Public Welfare's
Estate Recovery Claim in the amount of $36,826.69 is discharged and the estate is
otherwise approved as settled with payment of administration costs and expenses outlined
in paragraph 7 of the original Petition and.with no additional disbursements being made
to additional claimants or heirs.
Respectfully submitted,
*ifoPetitioner quire
Supreme Court ID No. 34349
200 North Hanover Street
Carlisle, PA 17013
(717) 243-5551
(800) 347-5552
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 unworn falsification to aut'orities.
DATE:
i . Pomraning
IN RE: ESTATE OF DOROTHY E. POM ANING : ORPHANS' COURT DIVISION
LATE OF THE BOROUGH OF CARLISLE : COURT OF COMMaN PLEAS'
CUMBERLAND CCEJTsbTY r m m
:PENNSYLVANIA _ >
NO.21-13-0672 � n rc'- .r"q o
2 R7 N M M
c) :17 :.X/ rJ
O I O C
PETITION FOR SETTLEMENT;OF A,SMALL ESTA --3
AND NOW, comes Petitioner, Keith L. Pomraning, by and through his counsel c"n
co
Bradley L. Griffie, Esquire, and the law firm of Griffre & Associates, P.C., and petitions
the Court as follows:
1. Your Petitioner is Keith L. Pomraning, an adult individual currently resid ng at
298 A McCalister Church Road, Carlisle, Cumberland County, Pennsylvania.
2. Your Petitioner is the Executor of the estate of his mother, Dorothy E.
Pomraning,who passed away on March 21,2013.
3. Your Petitioner was appointed as Executor of the estate of Dorothy E.
Pomraning on March 21,2013.
4. Petitioner is the natural son of the decedent, Dorothy E. Pomraning, and
decedent was also survived by another child, Mary L. Geisweit, of 50 East Water
Street,Middletown,Pennsylvania, 17057,
5. The assets in decedent's possession at the time of her death was limited to an
F&M Trust checking account, number XXX7120, which was owned jointly with
Petitioner since April 13, 2009; as such, the F&M Trust checking account was
not a probate asset and only had a date of death value of$41.66.
6. The only assets received by the estate after decedent's death was as follows:
{A} Wells Fargo Checking Account $856.66
Account No. X00000=9781
XX9781
Exhibit "A"
(B) Public School Employees' Retirement System 81.51
(C) 10 Shares of Sysco Corporation Stocks 34.44
TOTAL $1,282.57
7. The estate incurred the following expenses that were funeral expenses or costs of
administration of the estate:
(A) Egger Funeral Home $3,590.98
(B) Prospect Hill Cemetery(Interment) 1,770.00
(C) Tim Barrick (Music) 50.00
(D) Blue Mountain Blooms (Flowers) 477.00
(E) Judi Crum (Music) 50.00
(F) Cathy Hartsock (Music) 50.00
(G) Big Spring Presbyterian Church 220.00
(Service/Wake)
(H) Bank Fees 35.00
(I) Probate Fees 173.50
(J) Executor's Commission 1,500.00
(K) Attorney's Fees 2.000.00
TOTAL $8,416.48
8. In addition,the decedent, at the time of her death,had the following indebtedness
due and owing to the named parties:
(A) Thomwald Home (Final Billing) $4,134.92
(B) Department of Public Welfare 42.961.61
(Medicaid Claim)
TOTAL $42,961.61
9. As a result of the costs associated with funeral expenses and administration of
the estate,and the debts of the decedent,this is an insolvent estate.
10. A Pennsylvania Inheritance Tax Return was filed and approved as an insolvent
estate, a copy of said Notice of Inheritance Tax Appraisement, Allowance or
Disallowance of Deductions and Assessment of Tax being attached hereto and
incorporated herein by reference as Exhibit"A".
11. By correspondence of June 19, 2013, your Petitioner and counsel corresponded
with the Third Party Liability Section of the Pennsylvania Department of Public
Welfare, Estate Recovery Program, requesting a statement as to any sums
claimed to be due by the Department for benefits provided to the decedent.
12. By correspondence of July 9, 2013, Petitioner's counsel received the Estate
Recovery Statement of Claim, claiming the sum of $36,826.69 due to the
Department of Public Welfare for repayment of Medicaid payments granted on
behalf of the decedent, a copy of said Estate Recovery Statement of Claim being
attached hereto and incorporated herein by reference as Exhibit"B".
13. By correspondence of September 3, 2013 to the Claims Investigation Agent with
the Department of Public Welfare, Division of Third Party Liability, Estate
Recovery Section, sent certified mail, all information relative to the assets and
debts of the estate, along with a copy of the filed Inheritance Tax Return, was
provided to the Department, and request was made for the Department to waive
its claim based upon the insolvency of the estate, a copy of said letter being
attached hereto and incorporated herein as Exhibit"C".
14. The correspondence of September 3, 2013 was received by the.Department on
September 5, 2013, as evidenced by the certified mail return receipt card, a copy
of which is attached hereto and incorporated herein by reference as Exhibit"D".
15. As no response was received to the correspondence of September 3, 2013,
correspondence was forwarded to the Claims Investigation Agent, Department of
Public Welfare, Division of Third Party Liability, Estate Recovery Section, on
November 27, 2013, again asking for the Department to waive its claims for
recovery against the estate as this estate was insolvent, a copy of correspondence
of November 27, 2013 being attached hereto and incorporated herein by
reference as Exhibit"E".
16. The correspondence of November 27, 2013 to the Department of Public Welfare
was sent by certified mail and received on December 5, 2013, as evidenced by
the certified mail return receipt card which is attached hereto and incorporated
herein by reference as Exhibit"F".
17. To date, all costs and fees paid associated with administration of the estate as
previously identified have been paid from the non-probate assets, being the
jointly held F&M Trust checking account, the limited refunds received by the
estate after the decedent's death, and Petitioner's and Petitioner's sister's
separate assets.
18. There are no probate assets available to compensate the Department of Public
Welfare relative to its Medicaid Reimbursement Claim.
19. Pursuant to 55 Pa. Code §258.8, your Petitioner, who is personal representative
of the estate, has met his obligation to secure a statement from the Pennsylvania
Department of Public Welfare, provide all necessary documentation for the
Department to evaluate their claim and the Department has failed to respond,
despite two letters sent by certified mail to the Department, which initial
correspondence has been in the Department's hands for over ninety (90) days.
20. Petitioner proposes that the estate be resolved with no additional distributions to
the Pennsylvania Department of Public Welfare relative to its Medicaid
Reimbursement Claim and no distributions to the heirs of the estate as this is an
insolvent estate.
21. As is his obligation,Petitioner has:
(A) Secured a Statement of Claim from the Department of Public Welfare;
(B) Provided a copy of the within Petition and proposed Order to the
Department of Public Welfare, prior to filing, giving notice of the intent
of Petitioner to secure a discharge of the Department of Public Welfare
liability; and
(C) Illustrated, by the within Petition, that there are insufficient assets to pay
the Department's claim.
22. Petitioner is unable to set forth the position of the Department of Public Welfare
due to their failure to respond to prior written correspondence to them as
previously referenced herein.
23. The other natural child of the decedent has been provided with a copy of the
within Petition prior to filing and concurs in the request made herein.
WHEREFORE, Petitioner requests your Honorable Court to enter an Order of Court
and Rule to Show Cause upon the Commonwealth of Pennsylvania,Department of Public
i
Welfare,to show cause, if any it has,.as to why the claim of the Department should not be
discharged due to the insolvency of this estate and why this estate should not be settled as
proposed.
Respectfully submitted,
e e,Esquire
A orney r Petitioner
Supreme Court ID No. 34349
200 North Hanover Street
Carlisle,PA 17013
(717)243-5551
(800) 347-5552
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 unworn falsification to auth 'ties.
DATE: �� 1 4xaw-v
Keith L.'Pomraning
IN RE: ESTATE OF DOROTHY E. POMRANING : ORPHANS' COURT DIVISION
LATE OF THE BOROUGH OF CARLISLE : COURT OF COMMON PLEAS
CUMBERLAND COUNTY
PENNSYLVANIA
N0. 21-13-0672
CERTIFICATE OF SERVICE
1, Bradley L. Griffie, Esquire hereby certify that I did, the 2nd day of January,
2014, cause a copy of the within Petition for Settlement of a Small Estate to be served
upon the Respondent, Department of Public Welfare, and upon the heir, Mary L.
Geisweit, by first class mail,postage prepaid, at the following addresses:
Department of Public Welfare
Division of Third Party Liability
Estate Recovery Section
PO Box 8486
Harrisburg, PA 17105
Mary L. Geisweit
50 East Water Street
Middletown,PA 17057
DATE:
. I I P V e�fie, E squire
etitioner
NOTICE OF INHERITANCE TAX +-.,. pennsylvania
BUREAU OF INDIVIDUAL TAXES APPRAISEMENT, ALLOWANCE OR DISALLOWANCE DEPARTMENT OF REVENUE
INHERITANCE TAX DIVISION OF DEDUCTIONS AND ASSESSMENT OF TAX REV-1547 EX AFP (08-13)
PO BOX 280601
HARRISBURG PA 17128-0601
DATE 11-19-2013
ESTATE OF POMRANING DOROTHY E
DATE OF DEATH 03-21-2013
F-ILE NUMBER 21 13-0672
COUNTY CUMBERLAND
GRIFF.IE BRADLEY L ACN .101
200 N HANOVER ST APPEAL .DATE: . 01-18-2014
CARLISLE PA 17013-2423 (See reverse side under Objections)
Amount Remitted
MAKE CHECK PAYABLE AND REMIT PAYMENT TO:
REGISTER OF WILLS
1 COURTHOUSE SQUARE
CARLISLE PA 17013
CUT ALONG THIS LINE RETAIN LOWER PORTION FOR YOUR RECORDS ,4--
REV--1547 EX AFP C08-1.3) NOTICE OF INHERITANCE TAX APPRAISEMENT, ALLOWANCE OR
-
DISALLOWANCE OF DEDUCTIONS AND ASSE'SSM2NT-•DF TAX ""'• -
ESTATE OF: POMRANING DOROTHY EFILE NO. :21 13-0672 ACN: 101 DATE: 11-19-2013
TAX RETURN WAS: C X) ACCEPTED AS FILED C 7 CHANGED
APPRAISED VALUE OF RETURN BASED ON: ORIGINAL RETURN
1. Real Estate (Schedule A7 Cl) • 00 NOTE: To ensure proper
2. Stocks and Bonds (Schedule B) (2) 344.40 credit to your account,
. '
3. Closely Held Stock/Partnership Interest (Schedule C) C3) DD submit the upper Portion
of this form with your
4. Mortgages/Notes Receivable (Schedule D) C4J. .00 tax payment.
5. Cash/Bank Deposits/Mist. Personal Property (Schedule E) C5) 938. 17
6. Jointly Owned Property (Schedule F) C0 20 :83
7. Transfers CSchadule G) C7) ..OD
B. ,Total Assets - (8) 1 .303.40
APPROVED .DEDUCTIONS AND EXEMPTIONS: - -
9. Funeral Expenses/Adm. Costs/Mist. Expenses (Schedule H) (9) 8.416.48
10. Debts/Mortgage Liabilities/Liens CSchadule I) 0107 42.961 . 61
11. Total Deductions C11) 51,378.09
12. Net Value of Tax Return C12) 50,074.69-
13. Charitable/Governmental Bequests; Non-elected 9113 Trusts CSchedule J) C13) , . 00
14. Net Value of Estate Subject to Tax C14) 50,074.69-
NOTE: - I-f an assessment was issued previously, Lines 14, 15, 16, 17, 18 and/or .19 will
reflect figures 'tha't include the total of all returns assessed 'to date.
ASSESSMENT OF TAX:
15. 'Amount of'Lirte'14- at spousal 'rate - - "- ""' (157- .'0'0 g -0'0 - = . 00
16. Amount of Line 14 taxable at lineal rate C161 - nn x 045 = . 00
17. Amount of Line 14 at sibling rate (17) . nn X 12 = .00
18. Amount of Line 14 taxable at collateral rate (18) . 00 X 15 = .00
19. Principal Tax Due C19)= . 00
TAX CREDITS:
PAYMENT RECEIPT DISCOUNT (+) AMOUNT PAID
DATE NUMBER INTEREST/PEN PAID C-)
TOTAL TAX PAYMENT . 00
BALANCE OF TAX DUE . 00
INTEREST AND PEN. . 00
R bit "A" TOTAL DUE 00
x IF PAID AFTER DATE INDICATED, SEE REVERSE IF TOTAL DUE IS REFLECTED AS A CREDIT (CR), YOU MAY BE 'DUE
• ,p�enni l;yaVia
� q'EP!lBTM�IfT �� hUb].LC WI%4rFti[L�
July 9, 2013
KEITH L POMRANING
298 A MCCALISTER CHURCH ROAD
CARLISTLE PA 17015
Re: Dorothy Pomraning
CIS #: 590219252
SSN: ###-##-2497
Date of Death: 03/21/2013
ESTATE RECOVERY STATEMENT OF CLAIM
Dear Mr. Pomraning:
Under State and Federal law, the Department of Public Welfare (the Department) is
required to recover medical assistance (MA) reimbursement from the probate estates of
deceased individuals who were over age 55 when such assistance was received. 42 U.S.C.
§1396p(b)(1). 62 P.S. § 1412. This letter sets forth the amount of the Department's claim
against the estate of the above referenced individual and explains the obligations of
executors, administrators, and persons receiving estate property.
Although the amount in the estate may be considerably less-than that which
is owed to the.Department, our claim is against-the estate, no one else.
.Statement of Claim Amount
i
The Department maintains a claim in the amount of $36.826.69 against the
above-mentioned estate. This claim is for repayment of MA granted on behalf of the
decedent. Enclosed is the Department's itemized statement of claim.
A portion of this medical expense, namely .00, was incurred during the last six
months of the decedent's life; therefore, it is a Class 3 claim pursuant to Section 3392 of the
Decedents, Estates, and Fiduciaries Code, .20 Pa. C.S.A. 3392(3). The balance of the claim,
namely•$36.826.69, is to be entered as a priority Class 5.1 claim against the estate. You
should refer to Section 3392 for a more complete explanation of the priority rules.
If-a lawsuit is filed-for injuries sustained-by-the decedent prior to.death, then the
Department may also have a lien against the personal injury action. A statement of claim
for that injury-related lien must be requested separately.
Bureau of Program Integrity I Division of Third Party Uablllty I Recovery Section „
PO Box 8486 1 Harrisburg, Pennsylvania 17185-8486 EXIIiblt B
R�PA B'TMIrNT OF PUl3 L.4C WBLPAIiF
Your Responsibility to Provide Information to the Department
Please acknowledge receipt of this letter and advise whether the Department's claim
is admitted and when payment may be expected. When the estate accounting is complete,
please provide a copy.
The Department audits all estate recovery claims and therefore we require
documentation to substantiate all deductions from the gross estate. The regulations
governing how the Department computes its estate recovery claim are found in 55 Pa. Code
Chapter 258. These regulations are readily available on the Internet, in addition to being
carried in most local law libraries.
In order to document computation of the amount due the Department, the following
Items should be submitted.to the address below:
1. For real estate:
a. Copy of the deed
b. Copy of the latest tax assessment
c. Copy of'a current appraisal, if available
2. Copy of the funeral bill
3. Copy of the statement of the burial account if one existed
4. Copy of the statement of the personal care account balance at date of death, if the
decedent was in a nursing home
5. Copies of original and updated life insurance policy forms naming beneficiaries
6. Copies of any and all stocks and bonds
7. Copies of bank statements showing balances on the date of death
8. Copies of signature cards or other proof of when accounts were made joint
9. A list of any gifts or other transfers for less than fair market value made by the
decedent (personally or under a power of attorney)
Your Responsibilities to the.Department
Under State law, executors or administrators may be personally liable to pay the
Department's estate recovery claim if they transfer estate property without the
Department's claim being paid. Persons who receive that property without paying valuable
and adequate consideration to the estate may also be personally liable. The responsibilities
of the primary next of kin/administrator/executor, is to advise the Department of any assets
in the estate and to ensure that the remaining money, after all funeral and administrative
costs are deducted, is sent to the Department. Accordingly, you must ensure the
Department's claim is satisfied before making distribution of assets to heirs.
I
Bureau of Program integrity I Division of Third Parry Liability I Recovery Sectlon
PO Box 8486 1 Harrisburg, Pennsylvanla 17105-8486
IF'rRA RT.FiI @NT ctP BUIS I.k]C I(LFxUPA`R,E
Insolvent.Estates and the Fiduciary Responsibility to Creditors
If there are not enough estate assets to pay the claims of all creditors in full, then
the executor or administrator has a duty to act in the best interest of creditors when
administering the estate. If you must spend the estate's money to administer it, you must
act prudently and make purchases as if the money were coming out of your own pocket.
The Department's approval is required if you expect the legal fees to exceed more than the
greater of 6% of the estate assets or $1,000. Contingent fees for estate administration will
generally not be approved. If you do not obtain approval, the Department may consider the
excessive fees to be a transfer for less than valuable and adequate consideration.
Sincerely,
Katie.J. East
TPL Program Investigator
7.17-772-6713
717-772-6553 FAX
Enclosure
I
Bureau of Program Integrity I Dlvlslon of Third Party Llability Recovery Section
PO Box 8486 1 Harrisburg, Pennsylvania 17105-8486
s �
Attorneys and Counselors at Lay,
200 North Hanover Street
Bradley,L. Griffie,Zsquire Carlisic,PA 17013
8annah Berman-Snyder,Esquire F° (717)243-5551
ac
100 Lincoln Way East,Suite 1)
Robin I Bassett $ Charnbersburg,PA 77201
Office Manager ""�`" (717)267-1350
Kelly L.Perez (800)347-5552
Legal Assistant Fax(717)243-5063
September 3, 2093
Reply to: Carttste
Katie J. East
TPL Program Investigator
Bureau of Program Integrity
Division of Third Party Liability
PO Box 8486
Harrisburg,PA 17105-8486
CERTIFIED MAIL
RE: Dorothy Pomrarling
CIS#: 590219252
SSN: XXX-XX-2497
Date of Death: 3/21/2013
Dear Ms.East:
Please be advised that I am attorney for the estate of Dorothy Pomraning. Based
upon correspondence dated July 9, 2013, forwarded to Mr. Keith L. Pomraning, who is
the Administrator of the estate, the Department has a claim for $36,826.69. 1 am
enclosing a copy of the three-page Estate Recovery Statement of Claim that you
t
forwarded to Mr.Pomraning.
This is a severely insolvent estate. I am enclosing a photocopy of the
Pennsylvania Inheritance Tax Return (REV-1500) that we are filing in this estate
evidencing the fact that the assets total $1,303.40 and the funeral bill alone was more
than twice this amount. Mr. Pomraming and his sister paid all of the fees referenced on
this Inheritance Tax Return from their own separate funds.
We ask that you review the Return and confirm for us that the Department will
waive its recovery claim in this matter based upon the insolvency of the estate.
If you need additional documentation or information from me, please feel free to
contact:me-and we-.will:see:.that:documentation.is.-prosided;
Exhibit nG,n
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W-TFIE & ASS 0 CIA TES
Attorneys and Counselors at Lam, 200 North Hanover Street
Carlisle,PA 17013
Bradley L. Griffie,Esquire A (717)243.5551
[annob Berman-Snyder,R squire
100 Lincoln Way Last,Suite D
Robin J.Bassett rt� Chandeersburg,RA 17201
(717)267-1350
Office Manager
KPerez ` (800)347-5552
Kelly L.
Legal Assistant Nove,4140 -712013 Fax(717)243-5063
Reply to: Carlisle
CERTIFIM MAIL
Katie J. East
TPL Program Investigator
Bureau of Program Integrity
Division of Third Party Liability
POB ox 8486
Harrisburg,PA 17105-8486
RE: Dorothy Pomraning
CIS-#: 590219252
SSN: XXX-XX-2497
Date of Death: 3/21/2013
Dear Ms.East:
Enclosed herein please find a copy of correspondence I forwarded to you on
September 3, 2013. We have not received a response to this correspondence. We have
received approval from the Department of Revenue on our Inheritance Tax Return, so we
are ready to move forward to finalize this estate. If we cannot receive a response from
you, we will file a Petition for Settlement of a Small Estate providing a Rule to Show
Cause to you.
Your immediate attention would be appreciated.
Very truly yours,
Bradley L. Griffie
BLG/rjb
Enclosure
Cc: Keith-L;Pomraning; Administrator
Mary L. Geisweit
Exhibit "Ell
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IN RE: ESTATE OF DOROTHY E.POIv1RANING : ORPHANS' COURT DIVISION
LATE OF THE BOROUGH OF CARLISLE : COURT OF COMMON PLEAS
: CUMBERLAND COUNTY
PENNSYLVANIA
NO.21-13-0672
ORDER OF COURT AND RULE TO SHOW CAUSE
AND NOW this .iiMl day of `'i"Lr ZC.i;C L�r 2011, upon
presentation and consideration of Petitioner's'Petition for Settlement of a Small Estate,
filed pursuant to 20 Pa. C.S. §3102,it is hereby ORDERED and DECREED that:
1. A. Rule is hereby issued upon the Respondent, Commonwealth of
Pennsylvania,Department of Public Welfare, to show cause, if any they have,
as-to why their claim for Medicaid Reimbursement should not be discharged
and otherwise why the requested distribution set forth herein by Petitioner
should not be approved.
2. Said Rule is returnable thirty (30) days after service by certified mail upon the
Commonwealth of Pennsylvania, Department of Public Welfare, Third Parry
Liability Division, Estate Recovery Section, P. 0. Box 8486, Harrisburg, PA,
17105.
3. Notice of entry of this Order shall be provided to all parties by Petitioner.
By the Court,
/ J.
o _ m
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A,TRULCOPYF,. _. �--i:: cry o
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set my hand and the seal
of .acid court at`C�arrNole,PA
This I day of
�66I�'4n�I I
Clark ot the 0 khans Cd.Irt . .
Cumberland County Exhibit "B"