HomeMy WebLinkAbout04-10-14 IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY
PENNSYLVANIA
� IN RE: ' ��`'`.
: Orphans Court Divis�on � � rn
ESTATE OF E. JEANNE (HOGUE) RECHT :
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DECEASED : No. 21-13-0154 � � � �., �
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PETITION FOR CITATION TO SHOW CAUSE WHY APPEAL FRON�'I� �"� ti.r".. rn
DECREE OF REGISTER OF WILLS, DATED FEBRUARY 7,2013 ADMI�I G � N -°w��
TO PROBATE THE PURPORTED WRITING OF E. JEANNE (HOGUE) I7;ECHT
SHOULD NOT BE SUSTAINED
AND NOW, comes Jan Recht Stogsdill, Petitioner herein, by and through her counsel
Kathleen Misturak-Gingrich, Esquire and the Law Offices of Peter J. Russo, P.C., and
hereby requests this Honorable Court issue a citation directed to Jennifer A. Margush,
Executrix and Sole Beneficiary of Decedent's estate, to show cause why the Appeal from
the Decree of the Register of Wills dated February 7, 2013, admitting to probate an
instrument dated August 3, 2011, as the Last Will and Testament of Decedent, should not
be sustained and the Decree of the Register of Wills be opened to permit the Register to
receive and act upon a Petition directing the Register of Wills to issue Letters of
Administration to Petitioner for an Intestate Estate. In support, Petitioner avers as
follows:
1. This is a will contest asking this Honorable Court in this proceeding to set aside
the February 7, 2013, Decree of the Register of Wills of this Court, declaring the
August 3, 2011, writing entered as the Last Will and Testament of E. Jeanne
(Hogue) Recht, and granting further relief, including removal of Jennifer A.
Margush, as Executrix. A copy of the February 7, 2013, Register's Decree is
attached as Exhibit "A" and incorporated by reference.
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2. This Court has jurisdiction and venue pursuant to 20 Pa. C.S. §711 (1) and 711
(18).
3. E. Jeanne (Hogue) Recht ("Decedent") was a resident of Cumberland County,
Pennsylvania at the time of her death on January 26, 2013, with a last principal
address of 117 Green Ridge Lane, Newville, Pennsylvania, 17241.
4. Petitioner herein is Jan Recht Stogsdill, an adult individual residing at 25 Country
Club Road, Shalimar, Florida, 32579.
5. Respondent, Jennifer A. Margush, is an adult individual residing at 5619
Waltersdorff Road, Spring Grove, Pennsylvania, 17362.
6. Petitioner is the natural daughter of Decedent, E. Jeanne (Hogue) Recht.
7. Respondent is the niece of Decedent.
8. Decedent has four (4) natural children in addition to Petitioner. Said natural
children of Decedent are listed below in Paragraph 9.
9. The names and addresses of Decedent's other natural children, who comprise all
other parties in interest, are as follows:
A. Joan R. Wolf, an adult individual, natural daughter of Decedent, who
resides at 411 Limestone Road, Carlisle, Pennsylvania, 17015.
B. John M. Recht, Jr., an adult individual, natural son of Decedent, who
resides at 5520 Dansby Place, Tallahassee, Florida, 32311.
C. Jane Recht, an adult individual, natural daughter of Decedent, who
resides at 37 Randal Avenue, West Hartford, Connecticut, 06110.
D. James Recht, an adult individual, natural son of Decedent, whose last
known address is P. O. Box 308, Roxbury, Connecticut, 06783.
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10. Decedent was a single divorcee at the time of her death.
11. On February 7, 2013, the Register of Wills admitted to probate as the Last Will
and Testament of Decedent a writing dated August 3, 2011 ("Instrument").
12. Petitioner believes, and therefore avers, that the Instrument admitted to probate is
not the Last Will and Testament of Decedent.
13. On September 14, 2004, Decedent executed a Power of Attorney, through
Attorneys Hartman and Yannetti, of Gettysburg,jointly naming Petitioner and
Decedent's niece, Cheryl Dee Lockman as attorneys-in-fact. A copy of said
Power of Attorney is attached as Exhibit"B"and incorporated by reference.
14. After Decedent's execution of the Power of Attorney, Petitioner, Jan Recht
Stogsdill, received the Power of Attorney and signed it, thereby accepting the
responsibilities of agent set forth in the Power of Attorney.
15. On information and belief, in December 2004, Attorney Thomas E. Flower,
Esquire prepared a Last Will and Testament for Decedent naming Petitioner and
her husband, Thomas Mark Stogsdill sole heirs. On information and belief, said
Will also named Jan Recht Stogsdill as Executrix.
16. On information and belief, at the time Decedent executed the Last Will and
Testament prepared by Attorney Flower("Prior Will"), Decedent had full mental
faculties and was of a clear, testamentary frame of mind, knowing the nature and
extent of her worldly possessions and how she wanted them disposed of after her
death.
17. Petitioner has been unable to locate an executed copy of the Prior Will.
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18. Starting in the 1980s and unti12011, Petitioner kept in contact with Decedent and
made periodic visits to Pennsylvania to check on her mother's welfare, at one
point interceding with Decedent's physician and a surgeon to make sure her
mother's severely diseased gallbladder was removed and her health restored.
19. Decedent suffered from mental illness most of her life, including full-blown
hoarding, manic depression, and paranoia. In fact, Decedent resisted getting her
gallbladder checked or removed for fear of the doctors discovering cancer when
they opened her up. She was convinced that an operation would reveal cancer,
despite having no medical reason for that suspicion.
20. On or about June, 2011, Petitioner was the point of contact for her mother and
was contacted by Green Ridge Assisted Living Facility in which Decedent lived
and was told that she (or someone under Petitioner's direction)needed to clean
out Decedent's apartment or Green Ridge would be forced to evict her because
of offensive odors, vermin, and bugs caused by Decedent's hoarding and lack of
sanitation, all of which created a health, safety and welfare risk to herself, as well
as to other residents in Green Ridge. Further, the extensive clutter in Decedent's
apartment caused a falling risk to the Decedent herself.
21. To avoid Decedent's eviction, Petitioner and her husband promptly traveled from
Florida to Pennsylvania and cleaned out Decedent's apartment where they
removed and washed soiled clothes piled halfway to the ceiling, five years of
hoarded mail, rotten food, clutter and even some furniture that inhibited
Decedent's path to the restroom. Further, the clutter had completely blocked the
intake to the air conditioner, causing the compressor to burn out. Petitioner's
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husband realized there had been no air conditioning for his 91-year-old mother-
in-law for an undetermined amount of time as Decedent complained that her
apartment had been hot"for a long time." Petitioner's husband worked with the
Green Ridge maintenance crew to replace the air conditioner as the temperature
was too high for an elderly woman to remain in the apartment without adequate
cooling and ventilation.
22. However, because of her mental state, Decedent resented that Petitioner and her
Husband had touched her possessions, rearranged the furniture to make a clear
path into the restroom, and removed an electric organ that did not work to make
sufficient room for Decedent to move without obstruction in her own apartment,
resulting in a limited period of time during which Decedent did not communicate
with Petitioner.
23. Petitioner was not overly concerned about Decedent's reaction because
Petitioner was well aware of Decedent's mental health issues and there had, in
the past, been periods of time when Decedent had distanced herself from
Petitioner because she was upset about something Petitioner had done or failed to
do, in Decedent's opinion.
24. Sometime subsequent to the trip to clean Decedent's apartment to prevent her
eviction, Decedent removed Petitioner as her point of contact at the Green Ridge
Assisted Living Facility.
25. Decedent's hoarding and unsanitary lifestyle had previously nearly destroyed two
other homes owned and/or occupied by Decedent. However, when Decedent's
living conditions became known to Decedent's niece, Dee Lockman and her
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family, they took action to protect and restore Decedent to a safer living
environment; however, Decedent had also distanced herself from these
individuals, despite that they, like Petitioner, had acted in her best interest. Dee
Lockman was a co-Power of Attorney with Petitioner, by way of the 2004 Power
of Attorney. During the extensive clean-up of Decedent's prior homes
(including the removal of years' worth of accumulation of boxed up excrement
due to no water from a water main break between one of the houses, which
Decedent had occupied and the street), and despite that such living conditions
threatened Decedent's health, safety and welfare, as well as the health, safety and
welfare of those living near Decedent, Respondent and her Father, Ken Hogue,
brother of the Decedent, opined that Decedent should be permitted to "live as she
desired", thereby appeasing Decedent and ratifying (if not encouraging)
Decedent's unhealthy living conditions.
26. During the time the Decedent was put out with Petitioner, Respondent and her
Father used that emotional distance as an opportunity to ingratiate themselves to
Decedent, as well as, Petitioner believes, encourage the rift between the
Decedent, Petitioner and Ms. Lockman.
27. In late July 2011, Petitioner and Decederit had made plans to get together to go
to dinner when Petitioner was coming to Pennsylvania for a class reunion;
however, when Petitioner did not find Decedent at home, she called her uncle
Ken Hogue's house and was told by him that Decedent was there, but that she
did not want to see or talk to Petitioner even though Petitioner had come to town
a day early to spend time with her mother as had been previously arranged
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between Petitioner and Decedent. This event occurred less than two weeks from
the date the Instrument was executed after Decedent had consulted with Attorney
Richard Reilly, Ken Hogue's attorney.
28. Starting on or about late July/early August 2011, Decedent's health deteriorated
and she had to have emergency surgery to implant a pacemaker. Petitioner only
found out about the surgery when she called Decedent, but was unable to reach
her at her apartment.
29. Petitioner then called Ken Hogue and was told that Decedent was recuperating at
the Ken Hogue residence.
30. Again, Petitioner was told that Decedent did not want to speak with her and she
was not able to speak with Decedent at that time.
31. On information and belief, during the period in which Decedent recovered from
the surgery, she was largely dependent upon her brother, Ken Hogue, and his
daughter, Respondent herein, for her care and maintenance.
32. On information and belief, in July 2011, Ken Hogue took Decedent to his
attorney, Richard R. Reilly, Esquire in York, Pennsylvania to have a new Power
of Attorney drafted for Decedent.
33. On information provided by Attorney Reilly, said Power of Attorney was dated
July 13, 2011 (which was less than two weeks after Petitioner had cleaned
Decedent's apartment to avoid Decedent's eviction) and Decedent had therein
named Ken Hogue as Decedent's first agent and Respondent as Decedent's
second agent in the event Mr. Hogue was unwilling or unable to serve.
Petitioner does not have a copy of said Power of Attorney, nor was she aware,
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until after Decedent's death, that Decedent had executed a new Power of
Attorney to supersede the Power of Attorney previously granted to Petitioner by
Decedent.
34. On information provided by Attorney Reilly, Ken Hogue returned Decedent to
Attorney Reilly's office on August 3, 2011, at which time Decedent allegedly
signed the Instrument that has been accepted for probate by the Register of Wills
of Cumberland County, naming Respondent the sole Beneficiary and Executrix
of Decedent's Estate.
35. However, Petitioner believes, and therefore avers, that the Instrument should not
have been admitted to probate for the following reasons:
(a) The August 3, 2011, Instrument was in a name that was not
Decedent's legal name. Indeed, the name on the Instrument referred to a name
that Decedent legally changed many years before, when she married at the age of
24,because she so despised her given name that she swore to secrecy anyone
who found out the name. She had consistently, throughout her life, refused to be
called by that name. A true and correct copy of the Decedent's driver's license,
showing her legal name, is attached hereto and incorporated by reference as
Exhibit"C".
(b) Petitioner believes, and therefore avers, that Decedent would never
have knowingly or voluntarily given the name appearing on the Instrument as her
legal name to be used on the Instrument and never would have voluntarily
supplied that name to be used on any legal document, as doing so would be
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contrary to Decedent's actions during the entirety of her adult life; however,
Decedent's brother, Ken Hogue, knew of her given name.
(c) Petitioner believes, and therefore avers,that the signature on the
Instrument has been in some way forced since there are irregularities in the
signature that Petitioner knows so well since she watched her mother practice
writing her signature, filling pages and pages and pages of paper,throughout
Petitioner's formative years. Decedent's signature was her bond and Decedent
was very particular about it. Throughout the many years of Mother and
Petitioner sitting by the fire or in front of the felevision,the same signature was
written over and over, without variation, and never once was Decedent's middle
name, "Hogue",written in parentheses or the letter"E"written at the beginning.
In fact, Petitioner was an adult before she ever knew her mother had ever had
another given name. Ken Hogue, being the Decedent's brother, is one of the few
people who know that Decedent's given name was Elda J. Hogue.
(d) On information and belief, Ken Hogue is the only one who would
have added the "E"to Decedent's name and placed(Hogue) in parenthesis, and
insisted that the name be shown on the Instrument as E. Jeanne (Hogue)Recht,
as confirmed by the funeral director who told Petitioner that Ken Hogue called
him and directed him to change the name on the death certificate to read: "E.
Jeanne Hogue Recht,"which is not Decedent's legal name and which name must
now be amended on the official death certificate to comport with Decedent's
legal name.
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(e) Attorney Reilly further supplied a handwritten directive dated July 31,
2012, purportedly of Decedent's that was not written by Decedent, but which
purports to be signed by Decedent. A copy of said handwritten directive, which
directs that Decedent wanted no service, no obituary, etc., is attached as Exhibit
"D" and incorporated by reference. Said handwritten directive effectively
preserved Decedent's estate for Respondent, by eliminating certain final
expenses.
(fl Petitioner believes, and therefore avers, that the directive was forced
upon Decedent to preserve the estate for Respondent because when Ken Hogue
called and told Petitioner that her mother had died, leaving everything to
Respondent, Petitioner had asked about a headstone for Decedent and Ken
Hogue replied, "Do you think she needs one, Jan? That's an awful expense."
(g) On information and belief, the handwritten directive was not written
by Decedent, but rather by Jean Hogue, mother of Respondent and wife of Ken
Hogue.
(h) Petitioner believes, and therefore avers, that Decedent would not have
voluntarily elected to forgo the formalities of a viewing and a service as such
formalities were h'istorically important to her. Moreover, if Decedent were
competent and capable of making the decisions in the handwritten directive,
there was no cause for said directive to have been written by someone else,
besides Decedent.
(i) Most compelling to the invalidation of the Instrument is that Petitioner
has subsequently learned that the notary seals on the Decedent's Instrument are
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invalid. Indeed, Disciplinary Complaints have been filed by the Prosecuting
Attorney for the Department of State against the two (2)notaries involved,
Pauline Gima and Cori Spisak, which complaints are docketed at 0079-19-13,
File No. 13-99-004952 and 0078-99-13, File No. 13-99-004953.
(j) Pauline Gima(a notary from a law firm other than Attorney Reilly's)
allegedly notarized Decedent's Instrument, but she never recorded the entry in
her notary log, contrary to section 15(a) of Pennsylvania's Notary Public Law.
(k) On the other hand, Cori Spisak, who at the time Decedent purportedly
executed the Instrument, worked as a paralegal for Attorney Reilly,permitted
Attorney Reilly to place entries in her log book, despite that she had not
witnessed the signatures being affixed to the referenced Instrument and despite
that Attorney Reilly is not a notary. Specifically, Attorney Reilly entered
notarization of Decedent's Instrument in Cori Spisak's notary log, despite that
Cori Spisak was not present at the time Decedent and the witnesses purportedly
executed the Instrument, nor did Ms. Spisak witness either Decedent's or the
witness's signatures. A copy of Cori Spisak's notary log is attached as Exhibit
"E"and incorporated in reference.
(1) Contrary to the Public Notary Law at Section 15(a), Pauline Gima also
refused multiple requests by Petitioner and the undersigned counsel for a copy of
her notary log.
36. The invalidation of the notary seals,the questions whether the Instrument was
signed by the Decedent and/or the witness,the timing of the Instrument's
preparation in close proximity to Decedent's emergency surgery, when she was
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dependent upon Respondent and Respondent's Father for care and maintenance,
the transport of Decedent by Respondent's father to his own attorney, located
miles away from Decedent's residence when Decedent historically had her legal
work prepared by counsel in closer proximity to her place of residence,
combined with the fact that Attorney Reilly, who drafted the Instrument in other
than Decedent's legal name and included a name that Decedent had lawfully
changed and historically refused to use, are collectively cause for invalidation of
the Instrument.
37. The only witnesses to Decedent's signature are Attorney Reilly, who participated
in the unlawful notaries being affixed to Decedent's Instrument and Tara
Chevron, another paralegal employed by Attorney Reilly, whose knowledge
about and/or participation in the unlawful notaries is currently unknown by
Petitioner.
38. On information and belief,Notaries Gima and Spisak are negotiating Consent
Decrees with the Department of State, but said Consent Decrees have not yet
been accepted by the Secretary of the Commonwealth and made into Orders,
which would then become public documents. As such, Petitioner is unaware at
this time what sanctioris will be suffered by Notaries Gima and Spisak.
39. Decedent suffered a stroke ten(10) days before her death and Respondent and
her Father notified none of Decedent's children, including Petitioner, about her
condition until after Decedent's death.
40. Respondent and her Father effectively precluded Petitioner and her siblings from
having time with their Mother to say good-bye and make certain she was well
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taken care of during her final days. However, Respondent and her Father, by
their own admissions to Petitioner, did completely clean out Decedent's
apartment,no mean feat due to her hoarding, and claimed all of her possessions
while Decedent lay dying in the nursing home portion of Green Ridge.
41. Once Decedent's physical and emotional health deteriorated, Respondent and her
Father isolated Decedent from her children.
42. A true and correct copy of the Instrument(containing the unlawful notarizations)
admitted to probate by the Register of Wills is attached hereto as Exhibit"F"and
incorporated by reference.
43. Petitioner is the natural child of Decedent,had maintained ongoing contact and
relations with Decedent, and had acted in Decedent's best interests and as
Decedent's Power of Attorney.
44. Petitioner was a natural object of Decedent's bounty.
45. Respondent was not a child of Decedent, but rather a child of Decedent's
Brother, who had arranged with his own attorney to have the Instrument drawn
up for his sister by his own—not independent-�ounsel, located in York,
Pennsylvania, despite that Decedent resided in Cumberland County and had her
own counsel there, at a time when Decedent's physical and mental health were
suspect.
46. The Instrument admitted to probate was not lawfully notarized and the credibility
and competency to testify of at least one of the witnesses (i.e., Attorney Reilly)
to the execution of the Instrument is subject to question as he actively
participated in the unlawful notarizations of the Instrument.
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47. Therefore, his competency to testify about Decedent's execution of the
Instrument is certainly at issue. Moreover, until such time as Tara Chevron's
knowledge of, and participation in,the unlawful notarizations is determined, Ms.
Chevron's competency to testify is also in question.
48. It should also be noted that in Notary Spisak's log, which was unlawfully
completed by Attorney Reilly,there is an annotation in what appears to be
Attorney Reilly's handwriting that Decedent was "93 years old"; however,
Decedent was 91 years old at the time she purportedly signed the Instrument, but
Decedent was 93 years old at the time of her death, which raises further
questions about the timing and the legitimacy of the notary log entries and the
signatures on the Instrument.
49. Petitioner believes that the signatures purporting to be that of Decedent on the
Instrument and in the notary logs are not Decedent's or were otherwise forced to
be entered onto the Instrument and/or the notary log.
50. Petitioner is a person entitled to inherit, as a child of the Decedent, under the
intestate laws of the Commonwealth of Pennsylvania, if the Instrument is not
admitted to Probate.
51. As Respondent and her Father cleaned out Decedent's apartment as she lay
dying, Petitioner fears that they intentionally or inadvertently destroyed the Prior
Will, which has not been located.
COUNTI
52. Paragraphs 1-51 above are incorporated by reference as if set forth in their
entirety.
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53. Petitioner believes, and therefore avers,that Decedent lacked testamentary
capacity at the time the Instrument in question was signed.
WHEREFORE, Petitioner respectfully requests that this Court issue a
citation to Respondent to show cause why this Appeal from the Decree of the Register of
Wills admitting to probate the Instrument dated August 3, 2011, should not be sustained
and the Decree of the Register of Wills be opened to permit the Register to receive and
act upon a Petition for Letters of Administration to be granted to Petitioner for an
intestate estate, as the Prior Will of Decedent has not been located.
COUNTII
54. Paragraphs 1-53 are incorporated by reference as if set forth in their entirety.
55. In light of Decedent's questionable mental health and her physical maladies at or
around the time that the Instrument was prepared and allegedly signed by
Decedent, Respondent and her Father had placed into motion a plan to gain
confidential positions of trust with Decedent and to care for and isolate Decedent
from other family members from July 2011 until Decedent's death.
56. For the reasons stated above, Respondent developed, maintained, and exercised
undue influence over Decedent, such that Respondent and her Father, exercised a
significant and predominant role in the formulation and execution of the
Instrument admitted to Probate, which may not have been executed as
Decedent's voluntary and knowing act.
WHEREFORE,Petitioner respectfully requests that this Court issue a
citation to Respondent to show cause and why this Appeal from the Decree of the
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_ _ _ _
Register of Wills, admitting to probate the Instrument dated August 3, 2011, should not
be sustained and the Decree of the Register of Wills be opened to permit the Register to
receive and act upon a Petition for Letters of Administration to be granted to Petitioner
for an Intestate Estate, as the Prior Will of Decedent has not been located.
COUNT III
57. Paragraphs 1 through 56, above are incorporated by reference as set forth in their
entirety.
58. The Instrument admitted to probate contains unlawful notarizations that
invalidate the notary seals, call into question the validity of the various
signatures, and at least one of the witnesses participated in the unlawful
notarizations,thereby undermining his creditability and competency to testify as
a witness to Decedent's signature. Whether the second witness had any
knowledge of or participated in the unlawful notaries is unknown by the
Petitioner at this time, but certainly Ms. Chevron's competency to testify is
subject to question.
59. As such, the validity of the Instrument admitted to probate is questionable and at
least one witness should be deemed incompetent to testify about Decedent's
� signature.
WHEREFORE, Petitioner respectfully requests that this Court issue a
Citation to Respondent to Show Cause why this Appeal from the Decree of the Register
of Wills, admitting to probate the Instrument dated August 3, 2011 should not be
sustained and the Decree of the Register of Wills be opened to permit the Register to
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receive and act upon a Petition for Letters of Administration to be granted to Petitioner
for an Intestate Estate, as the prior referenced Will has not been located.
Respectfully Submitted,
THE LAW OFFICES OF PETER J.RUSSO,P.C.
Date: April��, 2014 ����`"-
Kathleen Misturak Gingrich, Esquire
Attorney I.D. No. 41682
5006 E. Trindle Road, Suite 203
Mechanicsburg, PA 17050
(717) 591-1755
Attorneys for the Petitioner
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VERIFICATI4N
To the best of my personal knowledge, information and belief, I, Jan Stogsdill, do hereby
verify that the facts averred and statements made in the foregoing Petition are true and correct. I
understand that false statements or averments therein made will subject me to the criminal
penalties of 18 Pa. C.S. A. § 4904 relating to unsworn falsification to authorities.
Date: /�� fa,o�o2Q�'� By: G
J Stogsdill
PETITIQN FOR GR�4NT �F LETl'ERS
REGISTER OF N(ILLS OF CUMBERLAND COUNTY, PEAlidSYLVAi111q
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 requests the grant of Letters in the appropriate form:
Jennifer A.Mar ush
DecedenPs Information
Name: E.Jeanne(Hogue)Recht
Flle No: 21-13- �`.���
alWa: —
a/kla: (Assigned by Reglster)
a/kla:
Date of Death: 01/26/2013 . Social Security No:
Age at Death: g3
Decedent was domiciled at death in Cumberiand County,
PA (State)with his/her last
principal residence at 117 Green Ridge Lane,Newvllle 1T241
Slr¢el address,poat Office and Zip Coda West Pennsboro Cumberland
City.Township or goraugh Counly
Decedent died at 117 Green R(d e Lane,Newville 17241
West Pennsboro Cumberland PA
Streel address,Post Olfica and Zip Ccde City,Tovmship or Baough Counly SWta
Estimate of value of decedent's property at death:
!f domiciled in Pennsylvania...................... All persanal property � ���-j�>
Ifnot domiciled in Pennsylvanla................ Personal property in Pennsylvania 5
If not domlclled fn Pennsylvania................ Personal property in County �
Value otreal estate in Pennsylvania........................... .,,,,,,,,,,,, �
TOTAL ESTIMATED VALUE S
Real eslete in Pennsylvania situaletl at
(Affach add/tionaf Sheefs,i/neoessary.)
Street address,Posl O�ce antl Z;p Code City,Township or Borouph
Counly
�A. Petition for Probate and Grant of L tter�Teata.,,a.,r ;
Petit�oner(s)aver(s)that he/sne/they is/are the Executor(s)named in the Last Will of the Deceden:,dated � I
therato dated � and Codici!(s)
Stata relavant circumstances(e.g.,renunciafan,deafh of eracutai e�a)
Except as fallows:after the execution of the instrument(s)offered for probate,Decedent did not mar was not divorced,was not a party to a pending
divorcz 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 of a killing nor ever adjudicaied an incapacitated person.
�NO EXCEPTIONS � EXCEPTIONS
❑B. Petition for Grant of etterc of Admin(crr��t�� (If appiicable)
c.f.a.,d.b.n.,d.b.n.c.t.a.,pedente life,durante absentia.durante m/norila(e
If Administration,c.ta ord.b.n.c.t.a.,snter date of Will in Sectfon A above and comolete lisi nT ha:�s
Except as follows:Decedent was not a party lo pending divorce proceeding wherein the grounds tor divorce had been established as defined
in 23 Pa.C.S.§3323(g)and was neither the victim of a killing nor ever ad)udicated an inCapacltated person.
�NO EXCEPTIONS� EXCEPTIONS �
Petitioner(s),after a proper search has/have ascertained that Decedent left no Wili and was survived by the following�us��e(if any)�helr�ao h
additionalsheets,ifnecessary):
m -° c� °° v' �
Name Relationship Address D �
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a
z �'. � � oQ
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Form RW-02�ev.�a�r-2or f
Copyright(c)2011 tortn sofQvaro only Tho Leckner Group,Inc. P�Ba�o�2
. _ _ _ .
PETITIOPI FOR GRANT OF LETTERS
REGISTER OF WILLS OF CUMBERLAND COUIdTY, PENNSYLVAIVIA
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 requests the grant of letters in the appropriate form:
Jennifer A.Maruush
DecedenYs Information
Name: E.Jeanne(Hoguej Recht Flle No: 21-13- �`.�y
a/kla:
a/k/a: (Assigned by Register)
a/k/a:
Social Security No:
Date of Death: 01/26l2013 ' Age at Death: 93
Decedent was domiciled at death in Cumberland County, pp (Stafe)with hislher last
principal residence at 117 Green Rldge Lane,Newvllle 17241 West Pennsboro Cumberland
SVCeI address,Pwl Otfice and Zip Code City,Township or Borough Counly
Decedent died at 117 Green Rfdge Lane,Newville 17241 West Pennsboro Cumberfand PA
Slrael address Posl OK�ce and Zip Cetle Ciry.7ownstnp or Borough Counly Slate
Estimate of value of decedenPs property at death;
Ifdomlciled in Pennsy/vania...................... All personal property $ ���[j��
Ifno!domiciled in Pennsylvanla................ Personal property in Pennsyivania $
It not domlciled!n Pennsylvania................ Personal property in County $
Value of rea!estate in Pennsylvania..................................................... ....... $
TOTAL ESTIMATED VALUE S
Real ealale in Ponnsylvania situated at
(AttacA addi(ionat sheefs,il necessary.)
Streel addrass,Posl Office antl Zip Code Cily,Township or Borough Counly
�A. Petition for Probate and Grant of Letterc Te tament-r�
Petitioner(s)aver(s)that he/she/they is/are the Executor(s)�amed in the Last Will of the Decede�:,dated � � �_and Codicil(s)
thereto dated .
Slata relevant urcumstances(e.g.,renunoat'an,death o/execuloi efc.)
Except as follows:after the execution of the instrument(s)offered for probate,Decedent did not mar was not divorced,was not a party to a pending
divorce proceeding wherein the grounds for divorce had been estabiished as defined in 23 Pa.C.S.§�3323(g),and did not have a child born or
adopted;and Decedent was neither the victim of a killing nor ever adjudicated an incapacitated person.
�NO EXCEPTIONS� EXCEPTIONS
❑B. Petition for Grent of Letters of Admfni�treUon pf applicable)
c.t.a.,d.b.n.,d.b.n.c.f.a.,pedenfe life,durante absetnfia.duranfe mfnofifafe
ff Administration,c.La or d.b.n.c.t.a.,enter date of Will in Se.tion A abov �nd comolete li t of heirS,
Except as follows:Decedent was not a party to,pending divorce proceeding wherein the grounds for divorce had been established as defined
ln 23 Pa.C.S.§3323(g)and was neither the victim of a killing nor ever ad�udicated an incapacitated person.
❑NO EXCEPTIONS � EXCEPTtONS �
Petitioner(s),after a proper search has/have ascertained that Decedent left no Will and was survived by the following�ousbe(if any)'�heir�a h
additional sheets,if necessary): � � � � O
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�ath vf Personai Representative OKcialUseOnty
COMMONWEFILTH OF PENNSYLVANIA }
COUNTY OF ,� } SS:
}
Petitioner(s)Printe Name Petitioner(s)Printed Address
Jennffer A.Margush 6619 Waltersdorff Road
Spring Grove,PA 17362
717.578.3739
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The Petitioner(s)above-named swear(s)or aKrm(s)the statements in the fore oing Petition are true and correct to Ihe best of the kr�3,rledge and s � C
belief of Petitioner(s)and that,as Personal Representative(s)of the Deceden etitioner(s 'll well and tru administer the estate a�ordi t law� '7i
Sworn to or affirmed and subscribed betore oeie a ��
me this 'at' day of � , a v r 3 oato
By� Date
r �Sr S v K COUNTY oa�e
'�;Y COMM ION IRES
BO.N[�F�e�����+���016 To the Registerof Wills:
FEES: `, Please enter my appearance by my signature below:
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Letters.......................................... $ , � Attorne ' ure:
( .`j )Short Certificate(s)......... tj,(^�; J����
t )Renunciation(s).............. �
( )Codicil(s)........................
( )A�davit(s)...................... Pr(nted Name: Rlchard R.Reilly
Bond............................................
Commission.......�.............. Supreme Court
............ ID Number: 617T2
Other
Z•r,herlictn 'e �uc ���h����� ��..cC�
� Firm Name:
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��`!� �i C�C Address: 54 N.Duke Street ,
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York,PA 1T401
Phone: 717-843-5355
Automation Fee............................ 'j. ��1:
_ Fax: 717-845-6761
JCS Fee....................................... _ �?J.� •
TOTAL......................................... c� i��. 5�` E-mail: rlchardrelliy@verizon.net
DECREE OF THE REGISTER
Date of Death: 01126/2013
Social Security No:
Estate of _E.Jeanne(Hoquel Recht File No: y�.�3_/�y
alkla:
AND NOW, 7�i r� '� �i •L��lc.G.7_L.� r -
c�[� ,in consideration of the foregoing Petition,
satisfactory proof having b�en presented before me,� IS DECREED that Letters Testamentarv
are hereby granted to Jennifer A.Margush
in the above estate and(if applicable)that the inslrument(s)dated
described in the Petition be admitted to probate and filed of record as th@ I st Wili(and Codicil(g))of Decedent-
'.(�/ � / (.'�.G��I`(I•�C � /�
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POWER OF ATTORNEY
N�TICE
THE PURPOSE OF THIS POWER OF ATTORNEY IS TO GIVE THE PERSON(S)OR INSTITUTION
. YOU DESIGNATE(YOUR"AGENT(S)")BROAD POWERS TO HANDLE YOUR PROPERTY,u�iICH
MAY INCLUDE P.OWERS TO SELL OR OTHERWISE DISPOSE OF ANY REAL OR PERSONAL
PROPERTY WITHOUT ADVANCE NOTICE TO YOU OR APPROVAL BY YOU.
THIS POWER OF ATTORN�Y DOES NOT IMPOSE A DUTY ON YOUR AGENT(S)TO EXERCISE
GRANTED POWERS,BUT WHEN POW�RS ARE EXERCISED,YOUR AGENT(S)1VIUST USE DUE
CARE TO ACT FOR YOUR BENEFIT AND TN ACCORDANCE WITH THIS POWER OF ATTORNEY.
YOUR AGENT(S)MAY EXERCISE THE POWERS GNEN HERE THROUGHOUT YOUR LIFETIME,
EVEN AFTER YOU BECOME INCAPACITATED, UNLESS YOU EXPRESSLY LIMIT THE
DURATION OF THESE POWERS OR YOU REVOKE THESE POWERS OR A COURT ACTING ON
YOUR BEHALF TERMINATES THE AUTHORITY OF YOUR AGENT(S).
YOUR AGENT(S)iVIUST KEEP YOUR FUNDS SEPARATE FROM FIJNDS OF YOLJR AGENT(S).
A COURT CAN TAKE A��VAY THE POWERS OP' ANY AGENT IF IT FINDS AN AGENT IS NOT
ACTING PROPERLY.
THE POWERS AND DUTIES OF AN AGENT UNDER A POWER OF ATTORNEY ARE EXPLAINED
MORE FULLY IN 20 PA.C.S. CH. 56.
IF TH�RE IS ANYTHING ABOUT THIS FORM THAT YOU DO NOT UNDERSTAND,YOU SHOULD
ASK A LAWYER OF YOUR OWN CHOOSING TO EXPLAIN IT TO YOU.
I HAVE READ OR HAD EXPLAINED TO ME THIS NOTICE,AND I LINDERSTAND ITS CONTENTS.
-�
�
� �'` ` -- --
Jeanne H.Recht,Principal
� _ / y-v f
Date
_ __ _
POWER�F ATTORNEY � �
KNOW ALL MEN BY THESE PRESENTS, that I, JEANNE H.RECHT, of 147 Maple
Stxeet,Rear,Manchester,Pennsylvania 17345, York County, have made, constituted and
appoint�d and by these presents do make, constitute and appoint my daughter,JAN RECHT
STOGSDILL, of 829 Verdun Way S. W.,Marietta, Georgia 30064, and my niece, CHERYL
. DEE LOCKMAN of 900 White Oak Tree Road, Gardners,Pennsylvania 17324,my true and
lawfitl attorneys, acting together or separately. Tn addition, I direct that my cluldren, Joan Wolf,
John Recht,Jr.,Jane Recht and James Recht, are hereby excluded from serving as my true
and lawfiil attorney.
Said attorneys shall act for me and in my name,place and stead, and to my use,to do any or all of
the following:
(1) To inake limited gifts.
(Z) To create a trust for my benefit.
(3) To make additions to an existing trust for my benefit.
(4) To claim an elective share of the estate of my deceased spouse.
(5) To disclaim any interest in property.
(6) To renounce fiduciaiy positions.
(7) To withdraw and receive the income or principal of a trust.
(8) To authorize my admission to a medical,nursing, residential or similar
facility and to enter into agreements for my care.
(9) To authorize medical and surgical procedures.
(10) To engage in real property transactions.
(11) To engage in tangible personal property transactions.
(12) To engage in stock,bond and other securities transactions.
(13) To engage in commodity and option transactions.
(14) To engage in banking and financial transactions.
¢
(�15) To borrow money.
(16) To enter safe deposit boxes.
(17) To engage in insurance transactions.
(18) To engage in retiremeut plan transactions.
(19) To liandle interests in estates and trusts.
(20) To pursue claims and litigation.
(21) To receive government benefits.
(22) To pursue tax matters.
Aiid i furtlier constitute my true and lawfiil attorneys, far me and in my name and on my behalf
generally to refuse and/or accept medical and mental treatment,to have access to all my medical
records; to disclose those records to others;to employ and discharge physicians,psychologists
and psychiatrists; to consent to or refuse medical or mental treatment and procedures; and to
authorize admission to hospitals,rehabilitation centers,psycluatric treatmeilt facilities,
coiivalescent or iiursing homes and hospice, and to si�n the necessary and appropriate consents
and releases thereto.
This Power of Attorney shall not be affected by disability of the principal, either inentally or
physically.
IN WITNESS WHEREOF,I have hereunto set my hand and seal this � 7� � day of
S�� �+�-�� , 2004.
Wimesses:
� �B.J• c�,�� (SEAL)
Jea ne H.Recht
''Yl�-,
�;
�`
COMMONWEALTH OF PENNSYLVAI�IA :
�' . SS:
COUNTY OF ADAMS :
On this .�day of 5-c ,� w� <� , 2004,before me, a notary public, the tmdersigned
officer,personally appeared Jeanne H. Recht,laiown to me, or satisfactorily proven, to be the
person whose name is subscribed to the within instrument and acknowledged tl�at she executed
the same for the purposes therein contained.
IN WITNESS WHEREOF,I have hereunto set my hand and seal.
`Y►�
Notary Public
�3otariat��at �Q��,��c �
Irene M.Hartman,Nutary
Ge:tYsbv�g 6oro�A�June 4.2 5
{�I►y Commission ExP
- _ _
� M ��� � � � � �
ACKNOWLEDGMENT
��
�
I,JAN RECHT STOGSDILL,HAVE READ THE ATTACHED POWER OF ATTORNEY AND AM
ONE OF THE PERSONS IDENTIFIED AS AN AGENT FOR THE PRINCII'AL. I HEREBY
ACKNOWLEDGE THA.T,IN THE ABSENCE OF A SPECIFIC PROVISION TO THE CONTRARY IN
THE POWER OF ATTORNEY OR IN 20 PA.C.S. CH. 56 WHEN I ACT AS AGENT:
I SHALL EXERCISE THE POWERS FOR THE BENEFIT OF THE PRINCIPAL.
I SHALL KEEP THE ASSETS OF THE PRINCIPAL SEPARATE FROM MY ASSETS.
I SHALL EXERCISE REASONABLE CAUTION AND PRUDENCE.
I SHAI_L KEEP A FULL AND ACCURATE RECORD OF ALL ACTIONS,RECEIPTS AND
DISBURSEMENTS ON BEHALF OF THE PRiNCIPAL.
! — � .�
J Recht Stogsdill,Agent '
lt -J `����
Date
� . ACKNOWLEDGMENT
�
�
� � a
- ;'�
I, CFIERYL DEE LOCKMAN,HAVE READ THE ATTACHED POWER OF ATTORNEY AND AM ;
ONE OF THE PERSONS IDENTIFIED AS AN AGENT FOR THE PRINCII'AL. I HEREBY
ACKNOWLEDGE THAT,IN THE ABSENCE OF A SPECIFTC PROVISION TO THE CONTRARY IN
THE POWER OF ATTORNEY OR IN 20 PA.C.S. CH. 56 WHEN I ACT AS AGENT:
I SHALL EXERCISE THE POWERS FOR THE BENEFIT OF THE PRINCIPAL.
I SHAI.L KEEP THE ASSETS OF THE PRINCIPAL SEPARATE FROM MY ASSETS.
I SHALL EXERCISE REASONABLE CAUTION AND PRUDENCE.
I SHALL KEEP A FULL AND ACCURATE RECOR.D OF ALL ACTIONS,RECEIPTS AND
DISBURS�MENTS ON BEHALP OF THE PRINCIPAL.
� � j �-C'/G /
�,.
Cheryl Dee ockman,Agent
-�%�y�C�/G/
Date
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EXHIBIT "F"
LAST WILL & TESTAMENT of
E. Jeanne (Hogue) Recht
I, E. Jeanne (Hogue) Recht, of Cumberland County, Pennsylvania, residing at 117
Green Ridge Lane, Newville, PA 17241, declare this to be my will, hereby revoking all prior
wills and codicils made by me.
PAYMENT oF DEBTS, FUNERAL EXPENSES&DEATH TAXES .
FIRST: T direct the payment of my just debts and the expenses of my last illness and
funeral as soon as may be convenient after my death. I further direct that all inheritance,
estate and other death taxes, together with interest and penalties thereon, of whatever nature
and by whatever jurisdiction imposed, shall be paid as an administrative expense of my estate.
DISTRIBUTION oF ESTATB PROPEkTY
SECOND: I give the rest, residue and remainder of my property (real, personal and
mixed) to my niece, Jenni�er A. Margush, provided she survives me for a period of thirty
(30) days. In the event Jennifer fails to so survive me, her share sha11 go, in eqnal shares, to
her issue,
POWERS oF EXECUTOR
THIRD: In addition to and not in limitation of the powers conferred upon executor by
law, I authorize the exercise of the following: '• .
(a) To hold, or to sell at public or private sa(e, without ordar of court, or to lease and
exchange, any real or personal property composing my estate and to compromise claims;
� �_�
�•_.• :`.
�� , ...� .
( ) �
��� � ��1�rz�,�,c.�,t ����� �: / fl,�,��,�,�.,.�. -
. Jeanne(Hogue) Rech
_ _ _ .
� (b) To establish a trust and appoint a Trustee for the Uenefit of any beneficiary under 21 years
of age. The Trustee in his/her sole discretion may allow early payments for the purpose of
post-secondaiy education after considering all other available resources; and
{c) That my executor shall not be required to furnish security in any jurisdiction.
APPOINTMENT oF EXECUTIX
� FOURTH: I appoint my niece, Jennifer A: Margush, executrix of my will. If Jennifer
• predeceases me or is unable or unwilling to qualify, act or serve as my executrix, �r having
qualified dnd/or served is �anable cr un�vzlli:.g to continue to ser.vP, I 2p�oirt m� �arot;:Pr,
Kenneth E. Hogue, Sr., executor of my will. .:�,
C'�-1 � / �/�:,
DATED: AUgLiSt�_, ZO11. .-� ( ,: � t�y--d�_�-'aC.�J �1 'r' ���_...�._.._.
�. .Tea ne(Hogue) Recht (
Signec�by E. Jeanne (Hogase) Recht, the testatrix, as her will, iji the pr•esence of us, who, at
her•reqacest, in her presetace & in the presence of each other, iiave signe�l oacr•names c�s
witnesses.
�"��.��1
��� G.4 � �-���.�- `���`�
Witness � � � Address
� "�• .7 /n .J. �v�� ..��. /prJG
. Witrcess�� Address
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� ACKNOWLEDGMENI A1vD AFFIDAVIT
I
. ' COMMONWEALTH oF PENNSYLVANIA .
� COfINTY oF YORK ,
I
� E. Jean�ae (Hogue) Recht, the testatrix in and the undersi�ned yvitnesses to
( tlae vvill, the attachect or for•egoing instrurnent, who have signed the instrurnent,
ihaving been qccalifced accordirag to the law de�ose and say:
� (a) thc�t I, the testatf•ix, do her•eby acknowledge that I signed the instru�nent as
imy will, that 1 signed it willingly and as my fi•ee an�l voluntary act fof•the
� purposes therein expresse�; wnd
I
� (b) that we, the witnesses, were present and sativ the testatri.r sigra the instrument
� as her last will, that she signed it willingly and executed it as her free and
� voluntary act for the purposes therei�a expr•essed; that each of us in the
ihea�•ing and sight of the testatr�,C signed the will as a witness atad that to the
� best of our knowledge the testatrix was at that time 18 or more ye�rs of age,
iof soacn�l mind cend ccnder no constraint or undace influence.
I
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i /� � � •C9�Y, J C _._..
(: ��'�� .1�
� E. Jeanne (Hogue) Rec
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� Witness
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' `7�_ � ���.�
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I Witness
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jSworn or affirmed to, subscr•ibe�l a��acknowledged before me by the testatrix artd the
� afof�ernentionecl wititesses this�_day of Attgust, 2011.
RICHARD R.REILLY �
ATT012NEY AT LAW � <
(71'�843-5355 '
Offices�11he Cor»er of• � i� � � �(.���
Diuke&King Str•eets i Nota�y Public
5G SOUTH DUKE ST.
YORK PA 17401-I402 � CUhLbfaNWEALTH OF PENNSY(.VANi�1
� NOTAR[AL SEAL
Fax: � Pauline E.Gima,Notary Public
(717)845-G7G1 � Cir,�of York,York County
� Iv�Y ea�tut�ission expirtis Febn�aty 02,26(4
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