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RECORDED OFFICE OF
FAFILES\Clients\15821 R Jones\15821.2 PUTMA\15821.2.Motion to Make Rule Absolute.Umpci REGISTER O'1 F WILLS '
Christopher E. Rice, Esquire 7015 JUL 28 FM 9 13
I.D.Number 90916
David W. Park, Esquire C LE IR v\ OF
I.D. No. 315905
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MARTSON LAW OFFICESC U l�B E R t_�;tI D �- : i'�''
10 East High Street
Carlisle, PA 17013
(717) 243-3341
Attorneys for Petitioner Robin S. Jones
IN THE COURT OF COMMON PLEAS
OF CUMBERLAND COUNTY, PENNSYLVANIA
ORPHAN'S COURT DIVISION
IN RE ESTATE OF JONATHAN M. JONES, a DOCKET NO. 21 - 2015 - 705
minor
MOTION TO MAKE RULE TO SHOW CAUSE ABSOLUTE
AND NOW, comes Petitioner, Robin S. Jones on behalf of Jonathan M. Jones, a minor
("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 23, 2015.
5. In her Petition, Petitioner requested that certain life insurance benefits owed to
Jonathan M. Jones be paid to Petitioner 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 Robin S.Jones on behalf of Jonathan M.Jones,a minor under 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: - z 7- z '0 Attorneys for Petitioner
A
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
By AOdA 0^-e�
ININY M. Price
10 East High Street
Carlisle, PA 17013
(717) 243-3341
Dated: / t�