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Home My WebLink About09-23-14 (2) IN RE: Estate of Bonnie A. Bishop : IN THE COURT OF COMMON PLEAS Deceased : CUMBERLAND COUNTY. PENNSYLVANIA : ORPHANS COURT DIVISION ' q0� � : IVO. �,�- (�'- � � � o � , � e.�,�. � ;r� ,.:r, � � � <:,� � r7 _ �t� �= � :� .�n •� �` 1^ C;�J � r::� �,.,� � C P PETITION FOR PROBATE OF COPY OF LAST WILL'a �� -� AND GRANT OF LETTERS : � � `�' ,t ,� TO THE HONORABLE REGISTER OF WILLS DF CUMBERLAND COUIVfiY: `�`' �., rn � � cn o AND NOW, comes the petitioner, Michelle M. Bishop, by and through her � �' counsel, Paul Bcadford Orr, Esquire, and avers the following in support of her petition: 1. Petitioner, Michelle M. Bishop, is an adult individual residing at 47 East Penn St. Carlisle, Cumberland County, Pennsylvania, 17013. 2. Petitioner is the Executrix named in the Decedent's Last Will dated July 19, 2001. 3. At the time of her death, Decedent, Bonnie A. Bishop, was domiciled at 47 East Penn St, Carlisle, Cumberland County, Pennsylvania, 17013. 4. The Decedent died on July 23, 2014, at the Carlisle Hospital; Carlisle, Cumberland County, Pennsylvania. 5. The Decedent/Testatrix executed her last Will and Testament on July 19, 2001, and Amended on March 22, 2012, and Petitioner is the named Executrix in Decedents Will so dated; a copy of said Last Will and Testament is being attached hereto and incorporated herein by referenced as Exhibit "A." � � 6. Decedent in her Last Will and Testament specifically provided for the distribution of the entire rest, residue and remainder of her Estate, after the payment of obligated debts, to the Executrix herein fore named. 7. At the time the Decedent/Testator executed her Last Will and Testament, she was of Testamentary Capacity. 8. A due diligent search has been made since the Testator's death and the original Will has not been found. However, a copy of the Last Will and Testament has been located in the records of the Decedent/Testator's legal counsel. 9. Both M&T Bank safety deposit boxes and decedent's domicile was searched thoroughly by counsel and Petitioner. 10.The contents of the Last Will and Testament are as stated and a copy which has been located is attached hereto and incorporated herein by referenced as Exhibit «A „ 11.The Last Will and Testament executed by the Decedent/Testator on July 19, 2001, was never revoked by the Testator, but was amended on Monday 22, 2012, in Counsel for Petitioner's Law office. 12.To the best of Executrix knowledge, the Decedent's Estate includes funds located with M&T Bank totaling less than $15,000. _ . 13.To the best of the Executrix knowledge, Decedent/Testator was the owner of real estate in Pennsylvania, but left to her daughter by sole right of survivorship. See attached and marked as Exhibit "B." 14.As additional evidence of Decedent's intent see attached Power of Attorney documents marked as Petitioner's Exhibit "C" and Petitioner's Exhibit "D". WHEREFORE, Petitioners respectfully request the Probate of the copy of the Last Will and Testament dated July 19, 2001, presented with this petition, and the Grant of Letters in appropriate form to Michelle M. Bishop. p c II S b itte , Dated: � �� b � Paul Bradford Orr Attorney for Petitioner 50 E High Street Carlisle, PA 17013 717-258-8558 Supreme Court ID. 71786 �� .� <�. �� LAST WILL AND TESTAMENT ,,:-�`� -.� � � OF , r� ;�� BONNIE A. BISHQP ��`� I, Bonnie A. Bishop, of 47 East Penn Street, Carlisle, Cumberland County, Pennsylvania, being of sound and disposing mind, memory and understanding, do hereby rnake, publish and declare this as and for my Last Will and Testament, hereby revoking all other wills and codicils heretofore made by me. w a FIRST: I direct that all my just debts and funeral expenses, including ° my grave marker, shall be paid from the assets of my estate as soon as practicable after � my decease. ; c�a ; / ; �:, °�' , � �lh�� ¢;�,�� G"�r�' �'��,�� &��e�i� �, SECOND: I give, devise and bequeatl�the sidue of my estate, of ,�� . ,� '� every nature and wherever situate, to my children, my so , . ;-of __�_ 6 ��J` � ��o Carlisle, Pennsylvania and, my daughter, Michelle M.;Bishop, equally, provided that �� r.��., �� the share of either child who predeceases me or dies on or before the thirtieth day following my death, shall be distributed to his or her issue, per stirpes, living on the �, thirty-first day followin m death, and in default of such then-livin issue, such share `� �_''"� g Y g � :.. shall be added to the share for my other child. ��w�.y� THIRD: I direct that all taxes that may be assessed in consequence of my death, of whatever nature and by whatever jurisd�ction imposed, shall be paid from my residuary estate as a part of the expense of the administration of my estate. FOURTH: I nominate, constitute and appoint my Daughter, Michelle W. Bishop, Executrix of this my Last Will and Testament. Should my Daughter, Michelle W. Bishop, fail to qualify or cease to act as Executrix, I appoint my sister Darlene M. Laughman, of Carlisle, Pennsylvania, Executrix of this my Last Will and Testament. ' FIFTH: I direct my Executrix and her successors shall not be required to give bond for the faithful performance of their duties in this or any other jurisdiction. �� !I� �� IN WITNESS WHEREOF, I have hereunto set my hand and seal to this, my Last Will and Testament, consisting of two (2) typewritten pages, each identified by my signature, this /9�k.. day of 2001. , � � _ _�. � L) Bonnie A. Bishop Signed, sealed, published and declared by the above-named Testatrix, Bonnie A. Bishop and for her Last Will and Testament, in the presence of us, who, at her request, in her sight and presence, and in the sight and presence of each other, have hereunto cribed our nam witnesses. ' ' ,� '; , ---� �� _ �: � COMMONWEALTH OF PENNSYLVANIA ) . SS. COUNTY OF CUMBERLAND ) - I, Bonnie A. Bishop, Testatrix, whose name is signed to the attached or foregoing instrument, having been duly qualified according to law, do hereby acknowledge that I signed and executed the instrument as my Last Will and Testament; that I signed it willingly; and that I signed it as my free and voluntary act for the purposes therein expressed. Sworn or affirmed to and acknowledged before me by Bonnie A. Bishop, the Testatrix, this ��fh, day of _, 2001. . ► : EAL) Bonnie A. Bishop, Testatrix Notarial seal Heather L.Smith,Notary Public Carlisle Boro,Cumberland County ��A,�, �/� � My Commission Expires Apr.7,20b3 ��'/ �-��J Member, ennsylvania Association ot No ar es Notary Public i .i"'^.�.J��. _�,` y� � \\ �� ( � \ COMMONWEALTH OF PENNSYLVANIA ) -j `�-j� : SS. � r� ._. COUNTY OF CUMBERLAND ) - We, PAUL BRADFORD ORR and APRIL DEATRICK, the witnesses whose names are signed to the attached or foregoing instrument, being duly qualified according to law, do depose and say that we were present and saw Testatrix sign and execute the instrument as her Last Will and Testamenfi; that BONNIE A. BISHOP signed willingly and that she executed it as her free and voluntary act for the purpose therein expressed; that each of us in the hearing and sight of the Testatrix signed the Will as witnesses; and that to the best of our knowledge the Testatrix was at that time 18 or more years of age, of sound mind and under no constraint or undue influence. Sworn or affirmed to and subscribed to before me by PAUL BRAD ORD ORR and �P�L ,OF�-T2ZCK ' e s, thi `�'��.-day of 2001. J . (SEAL) Paul Bradford Orr,'>Witness _�_ Notariai Seal (SEAL� Heather L.Smith,Notary public car��s�e eoro,Cumberland Counry April eatrick, Witness MY�mmission Expires Apr.7,2003 M�� Yw��a Associa ion of Notaries G�iV V 1��-+�� Notary Public . . / aS'3�'(ja('� Tax ID No. � DEED MADC THE I ��, day of S� in t6e year of our Lord hvo thousand(2000) BGTWEEN BONIYIE A.BISHOP,MICHELLE MAE BISHOP,and MICHAEL W. BISHOP,being all of the HEIItS OF CLLYOL L.BISHOP,deceaxd,of the Borougli of Carliak,Cumberland Covnty,Pennsylvania GRANTOItS aud MICHELLE MAE BI3HOP and BONNIE A.BISHOP,of the borough of Carlislq Cumberland County,Pennsylvutia,as joint tenants with the right of o � survivorship o ��;., r�. m�'`e; GRANTEES � �� r Sv- � v�:! �- WITNESSETH,that in consideration of Ona Dollar(S 1.00),in hand pald,the receipt wheceof is �o�, lureby acknowledged,the said Granton do hereby grant aad convey to the said Grantees,their � �o i.; heirs and assigns as joint tenants with the right of survivorship: rv z rn,`: tJ7 "'��u ALL THAT CERTAIN lot of land with dweliing thereon situate on East Penn Street,in the "� � N, v Borough of Cazlisic,Cumberland County,Pennsylvania,bounded and described as follows: A OPI the north by QuaQy Ailey;on the�ast by lots of Lloyd 9.Homer end Ciertrude and Etlul Fair;on the south by East Penn Street;end on the west by lot now or fornrcrly of Hury Lightner. Containing 2l feet,mon or less,on Eaet Penn Street,and extending in depth a distance of 120 feet,moro or less,to Quazry Alley. Heving erected thereon a two snd one-half story frame dweilin�and garage,the dwelling being kaown as No.47 East Penn Street. BE1NC the same premises which Louetta B.Heckman,et al,by their dxd deted April 30,t 954, and recorded in the Oftice of the Recorder of Deeds in and for Cumbedand County ln Dad Book T,Volume 15,Page 60,granied and conveyed unto Alfred M,Bishop,Jr.and Cleyol L. Bishop,as joint teusnts with the right of sarvivorship..Alfred M.Bishop,]r.,died Au�ust 1, 1986 having never been married az�d having no children,thus vesting full fee simpte interest in the premises conveyed heroin in Cleyol L.Bishop the surviving joint tenent. Cleyol L.Bishop died Apri124,2000 survived by his wife Bonnie A.Bishop and two children,nemely,Michelte Mae Bishop and Michael W.Bishop in whom seid property beceme vested ur�der the intestate laws of the Commonwealth of Pennsylvania. T'his is a�on-taxable transfer for Pennsylvenia Transfer Tax purposes from mother and children to mother and daaghter. `�.._- , Uaur, �:�'� r„c� 232 _ � � �� • . -__-._ ;- -�- ---�----�-__ _._.__ 07/03/2012 12:58:09 PM CUMBERLAND COUNTY inst.#200025387-Page 1 of 5 • . .. ... _, , ..... , ! And the said Grantors hereby covenant and agree that they will warrant specially the property hereby conveyed. IN WITNESS WIiE�REOF,the ssid Granwrs have hereunro set their hande and seala the day and year first above written. SIGNED,SEALED AND DELIVERED IN TI�PRESENCS OF c EAL) . �BONNffi A.BTSH �Ot_��_�_�.-`n , �t�-�e.� 1_' 1�'�'lC�� • IJ�}'��(SEAL) MICHELLH MA8 BISHpP �o_,.��.,,,,n _ . �-1 p Q�n _ ` (gFAi.� �•' MICHAHL W.BISHO COMMONWEALTH OF PENNSYLVAIVIA ) :5S. COUNTY OF CUMBERLAND ) ON THIS,the l/�, day oi ,2000,bePoro me,the undcrsigned officer,peraonally appeared BO IE A.BISHOP,luwwn to au(or satisfactorily proven)to be the person whoae name ia subscrlbed to the within in:ocuuient,and ' acknowled�ed that ahe executed the aame[or the purposp thereln conta9cxd. TN WITNFSS WHEREOF,I hereunto set my hand and official seal. Noww swl FM�wL 8ni�NoWY A+bb ��w� /';�'�a�La�✓Ol.,-I�ha.s.-�-Q (SHAL) ��IM�Wr.:�:�:n.� t ! �� p� •i�• p !y=�t�l x•. • ♦^'�''`� �,V.r. � ~%`..F.` Y�'. 's��' yi.�y�� DOOK `,�w9 PACi 2� ;�..�.::.: ::,•.� ��'!��.;7�.:;;;t�`. . ._ __.�.-�.,.,._._._ .. __._�_r..—�,__ 07/03/2012 12:58:09 PM CUMBERLAND COUNTY Inst.#200025387-Page 2 of 5 COMMONWEALTH pg pENNSYLVANIA ) , COUNTY OF CUMBERLAND �SS. ) ON THIS,the �li'-�t. �y pf Ir-�J Z000,beforo me,the undersigned officer.personally appeared MICF[ELLg MqE BISHOP,Imovvn tp ttu(or satisfactorily proven)to be tlu person whose name is subacribai co the within instrument.and acknowledged that ahe executed tho same for the purpoae�thenin contained. IN WITNESS WHEREOF,I hereunco set my hand and official aeal. �oio,�Qw��Wld�pq�O� __L"�""'�'��d/IK�CJCI Coim*�lonlf b��r.f 000/ (SBAL) .,'„, ', s••' COMMONWEALTH OF PENNSYLVAN1p j r• � COUNTY OF CUMBERLAND �� • ) ��a�.,''.:G -�� ON THIS,the�day of 2000,before me,the undersigned oft3cer,Per�onally appared MI W. satisfactoril B�OP,�W'�►�me(or Y Pmven)to be the person whose name is subscribed to tbe within instcurtKnt,and ackrrowiedged tt�ut he executed the same for the purposes therein contained, IN'WiTNgSS WHEREpF,I hereunto set my hand and offic9a�s�al. arMNeoiqq�,d�0 �L�.� A 1�/1T'lYL1�j(� �on F� Iw�Ap.7,�p V ff�lCO�✓ . , ($�.� �,.,. ��+'��! �� ♦ 'a. f� +�y" ��. ^��1h :T�i? x'.+G!. 1 i � � nouK 229 r�tc� 234 . .. - � • � i �w� i..�� 07/03/2012 12:58:09 PM CUMBERLAND COUNTY Inst.#200025387-Page 3 of 5 , , , . , .. ... .... -- - - -_ • I do hereby certify that the precise residernx and compjete poat ot�ice address of the within- named Grantx(s)ia: 3r7 M,�►.,�.t, P'�� , r�a ��0�3 De�: 9�„/o o pa�.� g„� r� Attorney for fc�7ln.ii A•�N� COMMONWEALTH pF PEIVNSYLVANIA ) :SS. COUN1'X OP CUMBERLAND ) RECORDED on this__�day of S 4(� ,A.D. '}��Q,in the Recorder'a Offke of the eaid County,in Deed Book a aa ,Page�_, Given under my hand and tbe se�a� lfice,the date above . ��,,: y��,p,�t� written. :��;b. ,,;,., r��,. ",'. �'""'�'� • " '' ,Rxorder :y;.;�, � �OU:; '.t��:,ti��w�J.�k �� tl oa�K c29 r,sc�, 2�.5 . .....__.._..,_,,_._.,._--_ . F I—T.__ . _.. 07/03/2012 12:58:09 PM CUMBERLAND COUNTY Inst.#200025387-Page 4 of 5 ^��4 DURABLE HEALTHCARE POWER'OF ATTORNEY `�l1 '' AND HEALTHCARE TREATMENT INSTRUCTIONS �=�� '� �� (LIVING WILL) ,—� �.,�,\�;�� PART I - DURABLE HEALTHCARE POWER OF ATTORN Y ,-, ` -�� ' �,_,, I, BONNIE A. BISHOP, of 47 East Penn Street, Carlisle, Cumberland County, Pennsylvania, appoint the person named below to be my agent to make health and personal care decisions for me when and only when I lack sufficient capacity to make or communicate a choice regarding a health or personal care decision as verified by my attending physician. My agent may not delegate the authority to make decisions. MY AGENT HAS ALL OF THE FOLLOWING POWERS (SUBJECT TO THE HEALTHCARE TREATMENT INSTRUCTIONS THAT FOLLOW IN PART II): 1. To authorize, withhold or withdraw medical care and surgical procedures; 2. To authorize,withhold or withdraw nutrition (food) or hydration (water�medically supplied by tube through my nose,stomach, iptestines or veins; 3. To authorize my admission to or discharge from'medical, nursing, residential or similar facility and to make agreements for my care, including hospice care; 4. To have full access to my medical and hospital records and all information regarding my physical or mental health; 5. To hire and fire medica(, social service and other support personnel responsible for my care; APPOINTMENT OF AGENT I appoint the following agent: Agent: Michelle M. Bishop, daughter Address: Carlisle, Cumberland County, Pennsylvania Telephone Number: Home 1-800-654-5988 Work(717)249-3999 You are not required to appoint an agent. If you don't wish to appoint an agent, write "None" in the above space. If you don't name an agent, health care providers will ask your family for h��n determining your wishes for treatment. I my agent is not available or if my agent is my spouse and becomes divorced from me after the date of this document, I appoint the person or persons named below in the order pamed. (It is helpful, but not required, to name alternative agents.) �� ' , � �� First Alternative Agent: Second Alternative Agent: _��`'�,� =';' �� ,.�,�,.- Darlene M. Laughman, sister Michael W. Bishop, son ;� � �� , � ��_, � � Address: Carlisle, Cumberland County, Address: Carlisle, Cumberland ��u��,�� Pennsylvania Pennsylvania �-�"� Tel. No.: Home(717)243-3014 Tel. No.: Home(717) 258-4521 PART II - HEALTHCARE TREATMENT INSTRUCTIONS (LIVING WILL) The following healthcare treatment instructions exercise my xight to make decisions concerning my healthcare. These instructions are intended to provide clear and convincing evidene�e-of my wishes to be followed when I lack the capacity to make or communicate my treatment decisions: TERMINAL ILLNESS OR PERMANENT UNCONSCIOUSNESS If I suffer from a terminal condition or a state of permanent unconsciousness such as a permanent coma or persistent vegetative state and there is no realistic hope of signiticant recovery,all of the following apply: 1. I clirect that I be given healthcare treatment to relieve pain or provide comfort even if such treatment might shorten my life,suppress my appetite or my breathing,or be habit forming;; 2. I direct that all life prolonging procedures be withheld or withdrawn; 3. I specificalty do not want any of the foltowing as life prolonging procedures: heart-lung resuscitation (CPR), mechanical ventilator(breathing machine), dialysis (kidney machine),surgery, chemotherapy, radiation treatment, antibiotics. Please indicate w/iether you want nutrition (foorl) or/:ydration'(water) metlically supplied by a tube into your nose, stomacJi, intestine or veins if you suffer from a terminal condition or a state of permanent unconsciousness and tl:ere is no realistic Irope of significant recovery. (Initial only one stc�tement.) ' TUBE FEEDINGS " I want tube feedings to be given. OR ,� I do not want tube feedings to be given. OTHER EXTREME CONDITIONS If I should suffer from irreversible brain damage or brain disease with no realistic hope of significant recovery, I would consider such a condition intolerable and I want my healthcare providers and agent to treat any intervening life-threatening conditions just as they would a terminal condition or state of permanent unconsciousness as I have indicated a ove. Initials I agree ��. Initials I disagree - � ''+. �� I ii ° . ' �%� :�; 1� � ��j 1 � °� ' �� _� ��;; �-=%� �--' � 1 GOALS (OPTIONAL) My goals in making medical decisions if I suffer from a terminal illness or other extreme irreversible medical condition are as follows (insert yoarr personal priorities such as comfort care,preservation of mental functions, etc.): AGENT'S USE OF INSTRUCTIONS (Initia!one option only.) �i��My agent must follow these instructions. OR These instructions are only guidance. My agent shall have final say,and may override any of my instructions. If I did not appoint an agent,these instructions shall be followed. LEGAL PROTECTION On behalf of myself, my executors and heirs I hold my agents and my healthcare providers harmless, and release and indemnify them against any claim for recognizing my agents' authority or for following my treatment instructions in good faith. ; SIGNATURE Having carefully read this document, I have signed it this �f k-day of �� 2001, revoking all previous healthcare powers of attorney and medical treatment instructia�s. �/ .. f . 7 , � / BONNIE A. BISHOP WITNESS: � WITNESS: � - Two witnesses at least!8 years of age are required in Pennsylvania and should witness y ur signature in each other's pi�esence. (It is preferable if the witnesses are not your heirs nor yoz�r creditors, or employed by any ofyour healthcare providers.) NOTARIZATION ' On this !9�day of _, 2001, before me personal(y appeared the aforesaid declarant,to me know to the p rson described in and who executed the foregoing instrument and acknowledged that he/she fee act and deed. WITNESS WHEREOF, I have reunto set my hand and affixed my official seal in the County of�Ur►z�a�q�/ , State of � � , the day and year first above written. y��-� 7, .�� Notary Public ---e 'ssion expires Notarial Seal Heather L.Smith,Notary Public Carlisle Boro,Cumberyand Counry My Commission�xpires Ap�,7,2003 Member,PennsyNar,is A•;�,�i�t;Qn�t Notaries L��1FtA8L� P+01�V�R O�' P�TT0�2N�"Y I, �o�nie �#. �i�h�p, of 47 '�as# Penn Stres#, Carlisle, C�mb�rland �;ounty, Pennsylvania, do hereby appoint ��i��elle Nl, Bi�hop, curren#ly of 47 Ea�t Penn �tre�t, Carlisle, Cumberiar�d County, ��nnsylvar�ia, as my true and layvful attorney�in�fact (hereinafter referred to a� "my agent") with full powsr of substitution fior m� �nd i� my �ame, to transact a!! my business and to manage all my prop�rty and aff�ir� as I might do if personally present, i�cluding but not lirnited to the following povaers, ths implementation of vvhich shail be in accordance with 20 Pa. Cons. Stat. § 5503: 1. To make gifts (or to malcs limited gifts). 2. To create a trust for my benefiit. 3. To make additions to an existing trust for my benefit. 4. To claim an elsctiv� share of the sstats of my deceased spouse. 5. To disclaim any interest in property. 6. To renounce fiduciary positions. 7. To withdraw and receive the income or corpus 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 au#horize m�dical and surgical procedures. 10. To engage in real property transactions. 11. To engage i�n t�ngible personal property transactions. 12. To engage in stock, bond, and other securities transaction�. 13. To engage in commodity and option transactions. 14. To engage in bankiny and financial transactions. 15. To borrow money. 16. To enter saf� deposit boxes. 17. To sngage in insur�nce transactions. 18. To �ngag� in retirement plan transactions. 19. To i�andl� interests in sstate and trusts. 20. To �urs�e clai�ns and iitigation. 21. To receiv� government benefits. �X�z��' 4t � �� 22. To pursue #ax matt�rs. 23. To do ail other things which my �gent shall desm nece�sary and �ro�er in order to c�rry o�k �he fioregoing �owers. Any person who i� giv�� instructions by my agent in �ccordance +�vith t�is �o�,ver of attorney, shall com�ly ��ith the i��tructions, �ubject to the provisions of 20 �a. �ans. Stat. � 5608(a). Any person who acts in good faith relianc� on this power of attorney shall incur no liability as a r�sult of acti�g i� accordance with khe instructions of my agen#, Questions pertaining to the validity, construction and povvers created unde� thi� instrument shall be detsrmin�d in accordance with the laws of the Commonwealth ofi Pennsylvania. I have signed khis Power ofi Attorney this 22"d day of March 2012. ,- ,._.� �" ?�'�� WI��TNE S�� j" t � � � ., � � �,. i; y 6��4: � °' } i$� � I � � '� y , ; x „,� �: �� ' -,7 ' �� .- �/��1�� A'! �/ ��.:�f �l �'�..J '..,�' � �� f � ...N / ' �� , d�t.��'�l��C.y'�i�'� � ` :i� �f YC`', f'�� / � � � � �,. �� ` �i � � �� P�ul B. Orr, Esquir� Bonnie A. Bishop �M COMMONWEALTH OF PENNSYLVANIA ) COUNTY OF CUMBERLAND ) On this, the 22"d day of June, 2012, before me, a Notary �Pubiic in and for the aforesaid Commonwealth and County, per�onally appeared the above named, lcnovvn to me (or satisfactorily proven) to �e the person whose name is subscribed to #he foregoing Power of Attorney, and acknowledged that he execut�d the sam� ofi his o��vn volition and fre� v�rill, and fior the purpos�s th�rein contained. V1/1T�l��S my hand an�l official seal the day and year afor�said. C�id1�1�E+0+1.�,�!��i1� `�3 c,� <<� �.�t.Y�i ��..��" ,� <r 1��'„'��e� Heather l�Orr,7��ry dubiic c�ao�o,�►�+�d c«,�cr Heathsr Lyne fl r, Notary Pu�lic hN Corr�r�lon�cplres�r�l z�,�013 MEM�ER,PEMtISY�4/�Ml�ASSt3fJ�l7ICN QF H0T,�3tiE5 ATTORNEY VERIFICATION 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 unsworn falsifications to authorities. As counsel for the Petitioner I can verify statements applicable to statements made herein. Date: � ��" �� Paul Bradford Orr, squire Attorney for Petitiner