HomeMy WebLinkAbout07-28-15 F:\F1LES\Clients\15821 R Jones\]5821.2 PUTMA\15821.2.Motion to Make Rule Absolute.AJ.wpd
Christopher E. Rice, Esquire
I.D. Number 90916
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David W. Park, Esquire 3-- C> e._ rn C_>I.D. No. 315905 � C-, r`_`— en
MARTSON LAW OFFICES ? '- N r M
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10 East High Street �? an X
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Carlisle, PA 17013 )
(717) 243-3341
Attorneys for Petitioner Autumn M. Jones, a minor A_. ca r— rn
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IN THE COURT OF COMMON PLEAS
OF CUMBERLAND COUNTY, PENNSYLVANIA
ORPHAN'S COURT DIVISION
IN RE ESTATE OF AUTUMN M. JONES, a DOCKET NO. 21-2015-703
minor.
MOTION TO MAKE RULE TO SHOW CAUSE ABSOLUTE
AND NOW,comes Petitioner,Autumn M.Jones("Petitioner"),by and through her attorneys,
MARTSON LAW OFFICES, and moves this Honorable Court as follows:
1. On or about June 23,2015,Petitioner filed a Petition to Direct Payment of Insurance
Benefits Owed to a Minor in the above-captioned matter.
2. On June 25,2015,this Honorable Court issued a Rule upon Colonial Life&Accident
Insurance Company("Respondent")to show cause within 20 days of the date of the Order,why the
Petition should not be granted.
3. On or about July 14, 2015, Petitioner filed an Affidavit of Service certifying that
Respondent was served and signed for the Petition on July 2, 2015.
4. Therefore,twenty days from service of the Order expired on July 22, 2015.
5. In her Petition,Petitioner requested that certain life insurance benefits be paid directly
to her mother,Robin S.Jones and that Petitioner's reasonable cost for attorney's fees associated with
the Petition be payable from the subject insurance benefits.
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6. Respondent has not filed a response to the Petition.
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: -Z7 Z o l," Attorneys for Petitioner
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CERTIFICATE OF SERVICE
I,Mary M. Price,an authorized agent for Martson Law Offices,hereby certify that a copy of
the foregoing Motion to Make Rule Absolute 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
By4AIJ)
M. Price
1 East High Street
Carlisle, PA 17013
(717) 243-3341
Dated: �,r