HomeMy WebLinkAbout06-23-15 Christopher E. Rice, Esquire
I.D. Number 90916
David W. Park, Esquire
I.D. No. 315905 ;
MARTSON LAW OFFICES c o �' r
10 East High Street .=3 �—
Carlisle, PA 17013
(717) 243-3341
Attorneys for Petitioner Autumn M. Jones, a minor cn -7 �� o
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C-0 F rn
IN THE COURT OF COMMON PLEAS
OF CUMBERLAND COUNTY, PENNSYLVANIA r%) �
ORPHAN'S COURT DIVISION
IN RE ESTATE OF AUTUMN M. JONES, a ; DOCKET NO. 2015 - +I O3
minor.
PETITION PURSUANT TO 20 PA C.S. 45101(3) OF AUTUMN M. JONES, a minor,
TO DIRECT PAYMENT OF INSURANCE BENEFITS OWED TO MINOR
1. Petitioner Autumn M. Jones is a minor over the age of fourteen who resides at 9
Mooredale Road, Carlisle, Pennsylvania 17015.
2. Petitioner is the daughter of Robin S. Jones.
3. Robin S. Jones, has three children: Petitioner Autumn M. Jones, Evelyn V. Jones,
and Jonathan M. Jones (collectively, the "Children").
4. The Children are beneficiaries under a certain life insurance policy on the life of
Decedent Mark Li Jones, their natural father(the"Policy").
5. The Policy is through Colonial Life and Accident Insurance Company ("Colonial
Life").
6. The Policy is in the amount of $50,000.00 and lists the Children each as equal
primary beneficiaries.
7. Each of the Children is entitled to one-third of$50,000.00 pursuant to the Policy.
8. Colonial Life will not issue the Children's benefits to Robin S. Jones without
Order of this Honorable Court.
9. Petitioner brings this Petition Pursuant to 20 PA C.S. §5101(3).
10. Pursuant to Decedent's Last Will and Testament, the Children are also
beneficiaries to a testamentary trust holding the residue of Decedent's estate (the "Trust").
11. The trustee of the Trust is Robert E. Golden-Jones.
12. The Trust and its assets are not subjects of this Petition.
13. Petitioner only seeks direct payment of the benefits owed to her under the Policy
to her mother, Robin S. Jones.
14. Petitioner knows of no adverse interest Robin S. Jones holds as to Petitioner's
interest in the benefits of the Policy.
15. Petitioner has not notified the United States Department of Veteran Affairs as the
Policy did not arise out of any military service.
16. Petitioner requests that her reasonable attorney's fees incurred in bringing this
Petition be paid from the subject insurance benefits.
WHEREFORE, Petitioner Autumn M. Jones, a minor over the age of fourteen, requests
that this Honorable Court issue an order directing Colonial Life & Accident Insurance Company
to make payment in accordance with the proposed order attached hereto.
Respectfully submitted,
MARTSON LAW OFFICES
BY�
Christopher E. Rice, Esquire
I.D. No. 90916
David W. Park, Esquire
I.D. No. 315905
10 East High Street
Carlisle, PA 17013
(717) 243-3341
Date: G l Zy0ovC Attorneys for Petitioner
VERIFICATION
The foregoing is based upon information which has been gathered by my counsel in the
preparation of this appeal. The language of the document is that of counsel and not my own. I
have read the document and to the extent that it is based upon information which I have given to
my counsel, it is true and correct to the best of my knowledge, information, and belief. To the
extent that the content of the document is that of counsel, I have relied upon counsel in making
this verification.
This statement and verification are made subject to the penalties of 18 Pa. C.S. Section
4904 relating to unsworn falsification to authorities, which provides that if I make knowingly
false averments, I may be subject to criminal penalties.
Autumn M. Jones
3
CERTIFICATE OF SERVICE
I, Mary M. Price, an authorized agent for Martson Law Offices, hereby certify that a copy
of the foregoing Petition for Direct Payment was served this date by depositing same in the Post
Office at Carlisle, PA, first class mail, postage prepaid, addressed as follows:
Colonial Life &Accident Insurance Company
Legal Department
P.O. Box 100194
Columbia, SC 29202-3194
MARTSON LAW OFFICES
BY ` �4, 0, �-
M. Price
1 ast High Street
Carlisle, PA 17013
(717) 243-3341
Dated: �P/�//sem