HomeMy WebLinkAbout10-28-14 REC0R717-� ^j7;SCE 0E
Heather J. Vance-Rittman LSPa. Id. No. 82705 ` " '
Senior Deputy Attorney General 2014 UST 28 nM 3 00
Office of Attorney General
14`x' Floor, Strawberry Square C! `7 ::4 C r
Harrisburg, PA 17120 O;�p ii
(717) 705-1611
Hvance_rittman@attorneygeneral.gov C u la 3 {
IN RE: ESTATE OF WILLIAM COURT OF COMMON PLEAS OF
PURNELL PAYNE, CUMBERLAND COUNTY,
Deceased. PENNSYLVANIA
ORPHANS' COURT DIVISION
No. 21-10-0282
COMMONWEALTH'S ANSWER TO MARIANNE RUDEBUSCH'S PETITION
TO WITHDRAW AS COUNSEL FOR THE ETATE OF W. PURNELL PAYNE
TO THE HONORABLE JUDGES OF SAID COURT:
The Commonwealth of Pennsylvania, acting as parens patriae through its
Attorney General, Kathleen G. Kane, respectfully Answers the Petition as follows:
1. Admitted.
2. Admitted, in part, and Denied, in part. It is Admitted that the Executrix
retained the Law Offices of Susan Lederer. The remaining averments are Denied, in that,
after reasonable investigation, the Commonwealth is without sufficient information to
form a belief as to their truth.
3. Denied. The Praecipe is a document, which being in writing, speaks for
itself and any attempt to misconstrue or misinterpret same is specifically, Denied.
4. Admitted, in part and Denied, in part. It is Admitted that Ms. Rudebusch is
a licensed attorney. The remaining averments .are Denied, in that, after reasonable
investigation, the Commonwealth is without sufficient information to form a belief as to
their truth.
5. Denied, in that, the Commonwealth's Motion is a document, which being
in writing, speaks for itself and any attempt to misconstrue or misinterpret same is
specifically, Denied.
6. Denied. The Praecipe is a document, which being in writing, speaks for
itself and any attempt to misconstrue or misinterpret same is specifically, Denied. The
remaining averments are Denied, in that, after reasonable investigation, the
Commonwealth is without sufficient information to form a belief as to their truth. By way
of further answer, Ms. Rudebusch accepted her position as executrix and assumed
responsibility for administering the estate in her capacity as a fiduciary.
7. Denied, in that, after reasonable investigation, the Commonwealth is
without sufficient information to form a belief as to the truth of the averments.
WHEREFORE, the Commonwealth respectfully does not object to Marianne
Rudebush's request to withdraw as Counsel of Record with the understanding that Ms.
Rudebush has not asked to be relieved of her fiduciary duties as executrix, including, but,
not limited to her duty to account for her administration of the Estate.
Respectfully submitted:
KATHLEEN G. KANE
Attorney General q/
By: (/ 0r
HEATHER J. ANCE-RITTMAN
Senior Deputy Attorney General
Pa. Attorney ID 82705
Office of Attorney General
Charitable Trusts & Organizations Section MARK A. PACELLA
14th Floor— Strawberry Square Chief Deputy Attorney General
Harrisburg, Pennsylvania 17120
October 27, 2014
IN RE: ESTATE OF WILLIAM COURT OF COMMON PLEAS OF
PURNELL PAYNE, CUMBERLAND COUNTY,
Deceased. PENNSYLVANIA
ORPHANS' COURT DIVISION
No. 21-10-0282
VERIFICATION
1, Heather J. Vance-Rittman, Senior Deputy Attorney General, being duly
sworn according to law, hereby state that I am a Senior Deputy Attorney General with the
Office of Attorney General, Charitable Trusts and Organizations Section, that I am
authorized to make this verification on behalf of the Office of Attorney General, and the
facts in the Attorney General's Answer are true and correct to the best of my knowledge,
information and belief.
ell,
HEATHER J. V CE-RITTMAN
Senior Deputy Attorney General
Pa. Atty Id. No. 82705
IN RE: ESTATE OF WILLIAM COURT OF COMMON PLEAS OF
PURNELL PAYNE, CUMBERLAND COUNTY,
Deceased. PENNSYLVANIA
ORPHANS' COURT DIVISION
No. 21-10-0282
CERTIFICATE OF SERVICE
NOW, this 27th day of October, 2014, 1, Heather J. Vance-Rittman, Senior
Deputy Attorney General, caused to be served a true and correct copy of the Attorney
General's Answer in the above-captioned action by placing a true and correct copy of
same in the United States First Class Mail, postage prepaid, to the following persons:
Marianne E. Rudebusch, Esquire
1711 Locust Lane
Harrisburg, PA 17109
HEATHER J. ANCE-RITTMAN
Deputy Attorney General
PA. Atty Id. No. 82705