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Home My WebLink About05-13-15 services with Hetrick-Bitner Funeral Home. It is fudher admitted that Ms. Spreu directed the remains of her late husband ro be [ransferred from Pennsylvania to Arlington National Cemetery for inteanent and burial. 5. Admitted in part and denied in part. It is admitted that upon lhe icquest for the Decedent's family and with their assucance foc payment of thosc costs tha[iather than the immediate intcrment in Arlington Natio¢al Cemetery as coordinated with the U.S. Army, the DecedenYs remains were transpoited to Iowa for a memorial service. [t is denied that Ms. Spreu desired such a delay in laying her husband to final res[ and it was only upon Ihe assucanees of DecedenPs pazents, Marv and Bonnie Rohlena, that the all additional cos[s for the memorial services in Iowa would be paid by Marv and Bonnie Rohlena that decedenPs remains were x�iouted to Iowa for a memorial service. 6. Denied. Respondent is without information or belief concerning Brosh Chapel and their business entiTy sweture and bcation and same is therefore denied with strict proof demanded. 7. Denied. Respondent is without information or belief and same is denied with strict proof demanded. &. Denied. Respondent is without information or belief as to this vague averment and same is denied with strict proof demanded. 9. Admitted in par[ and Denied in part. lt is admi[[ed that a memorial service was held for the Decedent o� Aug�st 1 S, 2014 at the direction of the decedent's pazents. It is denied that Ms. Spreu entered i�to any communication or coordination for the memoria] service. It is denied lha[ the services performed in Iowa were funeral services. 10. and I 1. Admitted iu part and Denied in par[. It is admi[[ed that Brosh Chapel sent a bill. It is de�ied [he bill was in the amount of $8,450.60. It is denied that the services performed by elaiman[ were fune�al scrvices, but were in fac[ a memorial service contcacted and eoordinated directly with Brosh Chapel by Marv and Bonnie Rohlena and nol by Ms. Spreu individually or by the DecedenYs Estate. Purther, notice of the denial of the claim was timely provided to claimanYs local counseL (See, Exhibit "A") Despite multiple requests for copies of signed contrac[ for services, no m�ritten contrac[ has been forthcoming from either claimant or its counsel. Further, claimant failed to attach any written doc�ment o� bill or invoice to its Petition in support of its claim. 12. and 13. Admitted. 14. Denied. Respondent is without information or belief as [o attomey fees paid o� incurred and same is denied with strict proof demanded. W HEREFORE, Respondent requests that this claim be denied along with all requests foi attorney fees and interest and the Peti[ion be dismissed with projudice. OBJECTIONS: 15. Paragraphs 1 thru 14 are incorporated herein by refercnce. 16. Pe[itioner's claims appeazs to be based upon a written contractual claim however, no contract executed by Respondent is attached to Petition despite RespondenPs repeated requests for same to Petitioner's local counsel. 17. No fixneral services were performed in Iowa, only memorial services were performed in lowa at the request and coordination of Marv and Bonnie Rohlena. All funeral services and preparation of funeral services were performed in Pennsylvania or Virginia and havc been paid. 18. [t is believed that Claimant submitted its cequest for paymen[ directly to Marv a�d Bounie Rohlena, necessary parties to this dispute but who Petitioner failed to be named as a necessazy party in these pcoceedings. 19. This court lacks jui'isdietion to adjudica[e a eontractual dispute between an Iowa entiry for a contract that arose in Iowa and ente�ed into by Marv and Bonuie Rohlena in Iowa. 20. The Pctition lacks sufficient specificity as to claims made or conversations incurred to permit any response to be forthcoming by the Respondent. 21. The Petition is legally insufficient as i[ appeazs to assert a claim for memorial services supposedly made by Ms. Spreu in her individual capacity and not as legal representa[ive of the Estate. 22. Petitioner's claim is based upon an appazent contract however, Claimant failed to a[tach written documentation in suppod of its elaim. The Este[e nevec signed any documents with the claimant a�d nor did Ms. Spreu in her individual capaciry or in her representative capacity sign a contract for services with the Petitione[. 23. This dispu[ed Petition and undedying elaim should be filed as a Civil Action as it is an undcrlying contractual dispute. WHEREFORE, Respondent requests that Petition of Claimant be dismisscd with prejudiee. Respectfully Submitted: COYNE & COYNE, P.C. Date: �Z �i�'GI .U/5 By: �� V�—�� isa Ma�ie Coyne, �sq. a. Sup�eme Ct N . 53788 3901 Market Stceet Camp Hill, PA 17011-4227 (777) 737-0464 A�tarney for Respondent VERIFICAT[ON The Executrix of the Estate of S[even L. Rohlena, Decease is s[a[ioned ou[side the jurisdiction of the couR (Belgivat—N.A.T.O. Headquarters) and the verification of Executrix cannot be obtained wi[hin [he time allowed for filing[he pleading. Therefore this verifica[ion is made by [he Attomcy for [he Estate based upon sufficient knowledge or information and belief and from direc[eonversa[ion and communieation wi[h the Executrix. � � . DaleA: .4�4 i . y� Z� , I �:isa a�ie Coyne, Esq., [rorney for Estate i t � COYNE & COYNE, P.C. A PRJFESSION?.L CORPOR?-TION ATTORNEYS AT LAW Henry F. Coyne 3901 Mazke:Stree[ (517) 737-0464 Lisa Mane Coyne Caacp Hill, Pennsylvauia Facsimile(71'n 737-J161 � Ausan F. Gxogan ll011-4227 www.coyneandcoyne.com December 36. 2013 Mazk A Mateya, Esquire 59 W. Church Avenue CarGsle, PA 17013 Re: ESTATE OF STEVEN L. ROHL'cNA DECEASED Deaz Mazk: I rueived ttre Forice of Claim which you fiLed oo December 23, 20 L4 on behalf of your clien[, Brosh Chapel. 9s your client has pmbabiy advised you, the Estate disputes [his claun and no paymeu[ will be made. As I previously communicated to your client, yo� clien[ conhacted individuaLly with Mr. and Mrs. Marvin Rohleua of 6637 Ut°Avenue,Keystone, CA='-'-�9 for Brosh services. All funeral merchandise for COL Rohlena and funeral prepazaGon services were perfoaned in � Pennsylvania and have been paid in fiilL 'Vtr. and Mrs. Marv�n Rohlena, not ffie decedenYs legal i representative, survivine spouse, nor[he execuaix, requested any of the services purported performed by vour client. Should you 6ave auy documeats whieh my client executed and which is t6e legal bazis for your clieut's ela¢n, please forwazd those documents foc my �eview. Until that time, youc eGenYs claim is denied. Very truly yours, COYNE &C�P.C: � �{ v'/ �- � iLi MarieCoyne LMGcmc � Encls. Cc: � Clientw/encis. �� /��, f "/-� ' CF.RTIFICATE OF SERVICE I, Lisa Macie Coyne, Esquirc, of Coyne & Coyne, P.C., hereby certify [hat true copy of the foregoi�g Answer to Rule to Show Cause and Objection was served this date upon the below-referenced individuals at thc below listed address by way of first class mail, postage pre-paid: Mark A. Mateya, Esquire 55 W. Church Avenue Carlisle, PA 17013 �/i — ✓ Dated: /�Z �...i �� BY; /��(.' �i�— � ' L sa Marie Coyne, Es u�e �� a. Supreme Ct.No 788 3901 Market Street Camp HiIL, PA 17011-4227 (71� 737-0464 COYNE & COYNE, P.C. A PROFESSIONAL CORPORA'I ION ATTORNEYS AT LAW HenryF.Coyne 3901 Marke[Stree[ (717)737-0464 Lisa Marie Coyne Camp Hill,Pennrylvania Facsimile(717) 73�-5161 Austin F.Grogan 17011-4227 www.coyneandcoyne.com May l2, 2013 Via Ovemieht Mailine: Clerk of Orphaus' Court Cumberland County Courthouse Oce Courthouse Square Carlisle, PA 17013 Ae: Estate ojSteven L. Roh[ena.Deceased Na. 11-74-0770 Dear Madam: We repcesen[the Es[a[e of[he Late Steven L. Rohlena. EncloseA please find an original and Iwo (2) copies for[he Responden['s Answer and Objection to Petition and Rule [o Show Cause. Please docket the original Answer and Objec[ion a�d reNm to[his ollice one(1)cbcked-in wpy. Thank you for your assis[ance. If you have any questions, please contact me. Very fmly yonrs, COYNE&COYNE, P.C. �, �:1ti,� C�a Lis Marie Coyne LMGcmc Encl. Cc: Hoa Thomas A. Placcy,]udge, w/encls. Mark Ma[eya, Esq,w/encls. Ri[a Spreq 8xecutrix,w/encls.