HomeMy WebLinkAbout06-06-14 RECORDED OFFICE OF
REGISTER OF WILLS
BAYLEY & MANGAN 2014 JUN 6 °11 2 33
Mark F.Bayley,Esquire
Attorney I.D. #: 87663
17 West South Street CLEKK OF
Carlisle,PA 17013 ORPHANS' COURT
(717)241-2446 CUMBERLAND CO., PA
IN RE: IN THE COURT OF COMMON PLEAS OF
Estate of Judith A. Godfrey CUMBERLAND COUNTY, PENNSYLVANIA
NO. 21-13-0710
ORPHANS' COURT DIVISON
MOTION FOR CONTINUANCE
AND NOW, comes Richard Godfrey by and through his attorney, Mark F. Bayley, and in
support of the within motion avers as follows:
1. The Honorable Thomas A. Placey is assigned to the within matter.
2. On May 13, 2014 the movant filed his Petition to Compel Inventory and
Accounting.
3. On May 16, 2014 the Court issued a Citation upon Executrix Debra Maugans to
show cause why she should not be compelled to file an inventory and accounting as well as why
she should not be enjoined from distributing/encumbering estate assets; the Citation was made to
be returnable in court on June 9, 2014.
4. On or around June 3, 2014 Attorney Tricia D. Naylor became involved with
representing Ms. Maugans.
5. The Movant is now hopeful that the matter can be resolved informally.
6. The Movant requests to continue the proceeding scheduled for June 9, 2014 for
approximately two months to give Attorney Naylor ample time to get organized.
7. The parties agree that in the meantime Debra Maugans shall be prohibited from
making distributions associated with the assets of the Estate to herself or any other party without
written agreement between both beneficiaries or further Order of Court and that she shall be
prohibited from using the real estate associated with the Estate to secure any loan or otherwise
encumber the real estate with any lean and/or contract pending written agreement between both
beneficiaries or further Order of Court; these provisions are not intended to prevent Ms. Maugans
from utilizing estate assets for the payment of debt and administration costs (with exception to an
administrator's fee at this time) associated with the Estate.
8. Attorney Naylor has reviewed the within motion on behalf of Ms. Maugans and
has no objection to the entry of the attached order.
WHEREFORE, the Movant requests entry of the attached order.
Respectfully submitted,
BAYLEY& MANGAN
Mark F. Bayle , Esquire
Bayley&Mangan
17 West South Street
Carlisle,PA 17013
(717)241-2446
Supreme Court I.D. #87663
VERIFICATION
Mark F. Bayley, states that he is the attorney in relation to the within matter; that he
makes this affidavit as attorney because he has sufficient knowledge or information and belief,
based upon his investigation of the matters averred or denied in the foregoing document; and that
this statement is made subject to the penalties of 18 Pa. C.S. §4904, relating to unsworn
falsification to authorities.
Date:
Mark F. Bayley, Esquire
IN RE: IN THE COURT OF COMMON PLEAS OF
Estate of Judith A. Godfrey CUMBERLAND COUNTY, PENNSYLVANIA
NO. 21-13-0710
ORPHANS' COURT DIVISON
CERTIFICATE OF SERVICE
I, Mark F. Bayley, Esquire, do hereby certify that I this day served a copy of the forgoing
document upon the following by hand-delivery:
Tricia D. Naylor, Esquire
19 West South Street
Carlisle, PA 17013
C–,'2—
Mark F. Bayley, Esquire