HomeMy WebLinkAbout02-0878
IN RE:
IN THE COURT OF COMMON PLEAS
CUMBERLAND CO., PENNSYLVANIA
ORPHANS' COURT DIVISION
TYLER ROBERT MOWRY,
A MINOR
NO. a J-O~. 371
PETITION PURSUANT TO 20 P.S. &5101
AND NOW, comes Petitioner, Jann Jones, the parent and natural guardian of the minor, Tyler
Robert Mowry and avers as follows:
1. Petitioner is Jann Jones, an adult individual with a current address of 5008 Pheasant
Hollow Road, Mechanicsburg, Pennsylvania 17050.
2. Petitioner is the parent and naturai guardian of Tyler Robert Mowry, a minor born April
16, 1992, who resides with Petitioner at 5008 Pheasant Hollow Road, Mechanicsburg, Pennsylvania
17050.
3. The minor's Father, Terry R. Mowry, Jr. is deceased, having died intestate and insolvent
on February 9, 2002.
4. Through his employer, United Parcel Systems, Terry R. Mowry, Jr. had a Group Life
Insurance Policy with Prudential Financial.
5. Tyler Robert Mowry, along with his minor sister, Autumn Nicole Mowry, have been
named as equal beneficiaries under the Group Life Insurance Policy of their Father, Terry R. Mowry, Jr.
(A separate, identicai Petition on behalf of Autumn Nicoie Mowry is being filed simultaneously with this
Petition).
6. The minor is to receive $6,250.00 in insurance proceeds from Prudential Financial.
Attached hereto and marked Exhibit "A" are letters dated May 22, 2002 from Prudential
Financial/Prudential Investments Annuity Services, confirming in writing that the minor is to receive
$6,250.00 as part of the life insurance settlement, (which amount has accumulated to $6,301.84 as of
May 22, 2002), and that the funds have been placed in an interest bearing Claim Settiement Certificate
CS000005032 until the minor reaches the age of majority or until a custodian or guardian is appointed.
7. Pursuant to Section 5101 of the Probates, Estates and Fiduciaries Code, because the
personal Estate of the minor has a net value of $25,000.00 or less, the proceeds of the life insurance may
be held or disposed of by the parent maintaining the minor, as directed by the Orphans' Court of
Cumberland County, the county where the minor presently resides.
8. Pursuant to Section 5102 of the Probates, Estates and Fiduciaries Code, this Court may
authorize or direct Petitioner, as the parent and natural guardian, to execute the necessary instruments
needed to carry out a Court Order regarding acceptance of the life insurance proceeds and deposit of
same in a savings account on behalf of the minor.
9. Petitioner's intention is to utilize the minor's proceeds to pay any attorney's fees and
costs reiated to this Petition; to pay one-quarter of the outstanding minor child's Father's funeral
expenses in the amount of $1,477.50; and to deposit the remaining life insurance proceeds and any
interest earned in an interest bearing Savings Account at Commerce Bank in the minor child's name and
Social Security Number, which funds would be sequestered until the minor attains the age of majority or
otherwise as authorized by Court Order. Attached hereto and marked Exhibit "B" is a copy of the
outstanding Hetrick Funeral Home, Inc. bill, showing a balance owed of $5,910.00. The minor's paternai
Grandfather is financiaily responsible for half of the balance.
WHEREFORE, Petitioner, Jann Jones respectfuily requests this Honorable Court to issue an
Order directing her, as the parent and natural guardian of the minor, Tyler Robert Mowry, to execute the
necessary documents to have the life insurance proceeds in the amount of $6,250.00, and any interest
earned, released from Prudential Financial. From the proceeds, Petitioner is seeking Court permission to
pay any attorney's fees and costs related to this Petition and to pay $1,477.50 to the Hetrick Funeral
Home, Inc. The remaining proceeds wouid be deposited into an interest bearing Savings Account at
Commerce Bank in the name and Social Security Number of the minor, and the funds would be
sequestered until the minor attains the age of majority or as authorized by Court Order. Proof of the
sequestered account would be filed of record.
Respectfuily submitted,
Dated: 9/2- u I ()L
Jill
At rney ID# 58802
Purcell, Krug & Hailer
1719 North Front Street
Harrisbur9, PA 17102
(717) 234-4178
Attorney for Petitioner,
Jann Jones
(misc. ~ones\petjtion)
2
-
Prudential t$ Financial
Prudential Investments
Annuity Services
PO Box 13379
Philadelphia, PA 19101
(888) 778-2888
www.prudential.com
TYLER ROBERT MOWRY
5008 PHEASANT HOLLOW RO
MECHANICSBURG P A 17050
Owner: TYLER ROBERT MOWRY
Annuitant: TYLER ROBERT MOWRY
Certificate Number: CSC000005032
May 22, 2002
Dear TYLER ROBERT MOWRY:
.
Please accept this letter as coufirmation that we have processed your claim for benefits. I appreciate the
opportunity to assist you with this settlement. I encourage you to keep this letter and refer to it if you
should need any further assistance.
Claim Settlement Certificate CSC000005032 is enclosed. This certificate reflects the $6,250.00 retained
on your behalf while the claim is being settled. Our Periodic Payment Center will retain this money until
you reach the legal age of majority or until a custodian or legal guardian has been appointed. Interest will
be credited annually while the funds remain in the account.
This decision is based on our policy records. According to these records, you are a minor and no custodian
or legal guardian has been appointed to you.
Enclosed is Form W-9 which should be completed by your parent or guardian on your behalf. Please be
sure to return the form to this office within 30 days from the date of this letter. It is important to note that
if we do not receive your completed Form W-9 within 30 days, we are required to withhold federal income
taxes from you payments. A reply envelope is enclosed for your convenience.
If you have any questions or need further assistance, please contact your representative or the Prudential
Annuity Service Center. You can reach us at (888) 778-2888, between the hours of 8:00 a.m. to 8:00 p.m.
Eastern time, Monday through Friday. If you are using a telecommunications device for the hearing
impaired (TOO), please call (800) 654-7637, between the hours of8:00 a.m. to 8:00 p.m. One of our
customer service representatives will be happy to assist you.
SinCe,'r ely" '
lit, ;Z )>t1;z<J{~J
Peter L Johnson :'
Registered Representative
Annuity Payment Services
Enclosures: Contract
W-9
ORD 86076 - Change in the Manner of Payment
Business Reply Envelope
A Prudential business
EXHIBit ,4
Registered Representative
Prudential Investment Management Services LLC
A Prudential company
Gateway Center Three.. 14th Floor
Newark, New Jersey 07102-4077
(973) 802.8624
-
Prudential ~ Financial
CLAIM SETTLEMENT CERTIFICATE NO. CSC000005032-A
is the result of settlement of a contract issued by:
The Prudential Insurance Company of America
Original Insured
Settlement Amount
Group Number
Certificate Number
TERRY R MOWRY JR
$6,250.00
76536
189589306
Annuitant
Annuitant Date of Birth
Certificate Date
TYLER ROBERT MOWRY
Date of First Interest Accumulation
APRIL 16, 1992
FEBRUARY 9, 2002
Frequency of Accumulation
FEBRUARY 9, 2003
Beneficiary: CLASS 1 : ESTATE OF TYLER ROBERT MOWRY
ANNUAL
Settlement of the above numbered contract(s) will be made as stated below:
The settlement amount will be held at interest. While the Annuitant is living, interest will be accumulated
effective on FEBRUARY 9, 2003 and at intervals of 12 months after that date.
The Annuitant may withdraw the balance.
Subject to our approval and to such conditions as may be agreed upon, the Annuitant may designate or
change a Beneficiary.
At the Annuitant's death, any balance will, without further accrual of interest, be payable in one sum as
described in the Beneficiary section of this certificate.
A Beneficiary receiving payments may withdraw the balance of his or her share.
Signed for the Company
By
..1.--
S-.'?..-o
*
Secretary
Date: February 9, 2002
CSC3
---
Definitions We define here some of the words and phrases that may be used in this certificate.
We, Our and Us - The company that issued the original contract(s).
You and Your - The Annuitant under this certificate.
Contract(s) - The original contract(s) that provided the settlement amount for this certificate.
Insured - The word Annuitant means Insured.
Balance On any date the balance is any unpaid amount with interest to that date.
Claim Settlement This supplementary contract, including the special provisions, if any, and any endorsements
Certificate attached, form the whole certificate. This certificate is evidence that contract proceeds have
been placed under an annuity settlement. It is assumed that all statements made when
making claim were made to the best of the knowledge and belief of the person(s) who made
them.
Change of Address To be sure your payments and important notices reach you without delay, you should notify
your Service Office as far in advance as possible of any changes in your mailing address.
Proof of Survival or Before we make a payment, we have the right to require proof that the Annuitant was living on
Death the date the payment was due. If we ask for such proof, that payment and any later ones will
not be due or payable unless and until we receive such proof in a form that meets our needs.
If we do not receive such proof within 36 months of the date we first ask for it, we will cancel
this settlement as of the date of our request. We will pay any death benefit that would have
then been payable as if the Annuitant had died on the date of our request.
Misstatement of Age If the Annuitant's stated date of birth is not correct, the amount of any payments already made
will be adjusted. The adjustment will be made as follows: (1) Any overpayments, with interest
at 5% a year, will be deducted from any payment(s) due then or later; (2) Any underpayments,
with interest at 5% a year, will be added to the next payment we make after receiving proof of
the correct date of birth.
Withdrawal If you have this right and would like to make a withdrawal, send your certificate to your Service
Office along with your signed request that includes your certificate number.
Ownership and Control Unless we endorse this contract to say otherwise: (1) the owner of the contract is the
Annuitant; and (2) while the Annuitant is living the owner alone is entitled to (a) any contract
benefit, and (b) the exercise of any right and privilege granted by the contract or by us.
Beneficiary(ies) You may be able to name or change a beneficiary. This is explained in the special provisions
attached to this certificate. Any request must be in writing and in a form that meets our needs.
It will take effect only when we file it at your Service Office. The interest of anyone who is
being removed will end as of the date of the request, even if you are not living when we file it.
When a beneficiary is designated, any relationship shown is to the Annuitant unless otherwise
stated. To show priority, we may use numbered classes, so that the class with first priority is
called class 1, the class with next priority is called class 2, and so on. When we use numbered
classes, these statements apply to beneficiaries unless otherwise stated.
1. One who survives the Annuitant will have the right to be paid only if no
one in the prior class survives the Annuitant.
2. One who has the right to be paid will be the only one paid if no one else
in the same class survives the Annuitant.
3. Two or more in the same class who have the right to be paid will be paid
in equal shares.
-----
Prudential ~ Financial
The Prudential Insurance Company of America
Pruco Life Insurance Company
Pruco Life Insurance Company of New Jersey
All are Prudential companies
Annuitant: TYLER ROBERT MOWRY
Claim Settlement Certificate Number: CSC000005032-A
CHANGE IN THE MANNER OF PAYMENT
1. This Certificate is amended to provide that (a) if the interest frequency is not annual, it is changed to annual; and (b)
each annual interest payment due after the date of this endorsement will be added to the principle and not paid out.
Any interest amounts that we add to the principle are subject to the same provisions and conditions that apply to the
principle.
2. But:
(a) if a life income settlement starts at a later date, we will use the life income rates in Ordinary contracts that we
issue on the due date of the first payment to compute that part of the life income payment that comes from the
interest that has accumulated under this certificate.
(b) We or the Annuitant may choose that the interest be paid periodically as of the next annual payment due date
on or after the date that choice is made.
3. All provisions of this Certificate that do not conflict with this rider still apply.
Endorsed or acknowledged for the Company
B',,"
llo--
S-.~a.
*
::::8cr8181i,i
Date: FEBRUARY 9, 2002
ORD 86076
---
4. If none survive the Annuitant, we will pay in one sum to the Annuitant's
estate.
Example: Suppose the class 1 beneficiary is Jane and the class 2 beneficiaries are
Paul and John. We owe Jane the balance if she is living at the Annuitant's death. We
owe Paul and John the balance if they are living then but Jane is not. But if only one
of them is living, we owe him the balance. If none of them is living we owe the
Annuitant's estate.
Before we make a payment, we have the right to decide what proof we need of the
identity, age or any other facts about any persons designated as beneficiary. If
beneficiaries are not designated by name and we make payment(s) based on that
proof, we will not have to make the payment(s) again.
Service Office This is the office we designate to service your certificate. Your Service Office is the Periodic
Payment Center whose mailing address is POBox 13379,Philadelphia, PA191 01. We will
notify you of any changes.
----
ENDORSEMENTS
(Only we can endorse this contract.)
Annuity Contract.
Prudential ~ Financial
Prudential Investments
Annuity Services
PO Box 13379
Philadelphia, PA 19101
(888) 778-2888
www.prudential.com
PURCELL DRUG AND HALLER
A TIN JILL WINEKA
1719N FRONT ST
HARRISBURG PAl 7102
Contract #: CSC000005032
CSC000005835
Client: TYLER ROBER MOWRY
AUTUMN NICOLE MOWRY
May 22, 2002
Dear Ms. Wineka:
Your recent request for information on the above-mentioned contracts has been referred to me for
a reply. I hope the following information proves helpful.
The value of contract CSC000005032 as of May 22, 2002, amounts to $6,301.84.
The value of contract CSC000005835 as of May 22,2002, amounts to $6,301.84.
If you have any questions, please call the Prudential Annuity Service Center at (888) 778-2888. You can
obtain contract values, request forms and duplicate statements, and conduct certain financial transactions
24 hours a day 7 days a week with our automated phone system. The Service Center is open Monday
through Friday between 8:00 a.m. and 8:00 p.m. Eastern time. If you are using a telecommunications
device for the hearing impaired, you may call (800) 654-7637, Monday through Friday between 8:00 a.m.
and 8:00 p.m. Eastern time.
Thank you for choosing Prudential for your insurance and financial services.
Sincerely,
~.itLLttL"~>0C(
~Lotetta Orce
Customer Service Associate
A Division of
Prudential Insurance Company of America
HETRICK FUNERAL HOME, Inc.
3125 Walnut Street, Harrisburg, PA 17109
(717) 545.3774 Fax (717) 545.2325
Graham S. Herrick, licensed director, Stephen G. Herrick, supervisor
Nathan A. Bitner, licensed director
Funeral Expense Agreement
This is an explanation of charges as well as a sales agreement
presented in accordance with the regulations of the Pa. Slate
Board of Funeral Directors.
STATEMENT OF FUNERAL GOODS AND SERVICES SELECTED
Charges are only for those items that you Selected or are required. If we are required by law or by a cemetery or crematory fa use any items, we
will explain the reasons in writing below. If you selected a funeral which may require embalming, such as a funeral with a viewing, you may have
lO pay [or embalming. You do nO! have to pay for embalming you did nOl approve If you selected arrangements such as direCl cremation or immediate
burial. If we charge for embalming we will explain why below.
Legal, cemetery, crematory or other requirements com elling the purchase of any ilems lisled below:
Reason for Embalming: -r; Q-.
Funeral Services for f? hi ( 'Date of Death ~_ '1- a;L Dare of Service
GOODS AND SERVICES SELECTED
TYPE OF SERVICE AUTHORIZED TO BE PROVIDED
&Traditional Full Service 8.,.Viewing day of Service
o Graveside service only 0 No Viewing
o Cremation c-:: Immediate Disposition
C Public Viewing U Anatomical Gift
o Private Family Viewing [] Memorial Service
C Evening Viewing 0 Shipping Service
o Receiving Service
Package Arrangement
1!l4Cf.:.,.......1 h-iA.H...-II(S......,f._ I...NI~ ~';c......,l.~
J h", fe'd>f .-/ fVNe~1 4,,,,,,,... $ ;'735
Charge for Services Selected: 1Af1'. ki _:3 0 b
I. PROFESSIONAL SERVICES 1)",,",,\' i~?'
Basic Services Fee ......,... $~
Embalming .......AJ.hf:>~...... $~
Cremation .."..,........\J",.... $_
Other Preparation of Body
$~
Transfer of Remains to Funeral Home.. $~
Sub-Total of Professional Services (BI) """.. $~
2. A~i~::fo~NA~ S{1~~I~~;~\~ON~_~t~I~~~;~
Funeral Service . $~
Memorial Service $_
Graveside Service .. ..... ...... $~
Sub-Total of Additional
Services and Facilities (B2). . _
3. AUTOMOTIVE EQUIPMENT
FuneralCoach......................... $ ~."~
Lead/Clergy Car....... _............... $_
Flower Car..... ....................... $~
Family Car............................ $
Other than local 20 mile Transponation. .. $_
Sub~Tota1 of Automotive Equipment (B3)....... $ ~
Total of Professional Services. Additional Service
And Facilities, and Automotive Equipment (B). . . '11 $~
C. CHARGE FOR MERCHANDISE SELECTED ~:71. '!> <;"
~~~'" Sk",\'''G ~. $ J~7<'
Othe.r ~ceptacle ~ l"'\ \7\1.)( I Sprvl.l...13llL.
Descnpuon $-=-----
Oute.r ~urial COJltainer\ t. "0"0
DcscnptJOD &-r~_ _IIIJ<'/.. $~
URN
Description $
Acknowledgement Cards.. ....... .......... $~
Me;;:~ ~1::,~(lii6)"'"'''''' $ -~ l
CASH ADVANCES Ml!ST BE REIMBURSED PRIOR TO SERVICE DAY
AGREEMENT; I aVec' that I have inspected lhe goods and savites ill:lected above and found them to be accurate and according 10 lhe arrangements I have selected., I acknowledge receipt
of a
CQpy _of thi~ Slalemenl of Goods and Service-< Selected. It i_s understood that the total charges shown above may be estimaled a~d ~f1ect only that agreed upon at the ume of lhis agreement.
Any
additIonal Items of SCrvlCe or merchandiill: ordered Or requlI'ed after the time of lhis arrangement shall be considered part of lhls "ireemen! and the Cost w,lI be reflected on your
Final Statement
which we provide.
TERMS: This is a ca.h tran.oction due in lull in 30 days. and in all evem. becomes past due and delinquem after the 30 day. date. A penalty of ] 5% pet annum (I .25% momhly) will be
charged
for unamicipated lale payment effective on the Hstday. , ,_ , .
WARRANTIES: The only warranty of the merchandisc sold m connection wnh t111~ agreement i. the e~prcss written warranty (,f any), provtded by lhe manufacturer. The funeral director makes
no wllfranty (cxpres""d or implied) with telpect 10 any funeral merchandi"".
AUTHORIZATION: I or We authorize and ratify prior conscot 10 the funeral director 10 take pClS""ssion of the body. give care to and carry out the arran,emenll hereto specified and allr~d
10.
I or We represent our""lvt'!! as lite perron(.) having the legal rillhtto auanlle for lhe final dispo.ition or lhe above named decedent, and do hereby IIflUl! aurhority to the funeral
director to supply
lhe services and merchand"e as listed aoove, I or We guarantee lhe paymem of Ih.. Conlact accordtng to the above terms. and also iIIree to pay any anorney f~ or legal iudgement imposed
upon
WcoUl'Ctionof{hecO$lofthis~erviceagreemenl.
Oral Permission To Embalm: The above named decedem ~ Was gramed 0 W'as refused by
J'ltD{r. d . on ;J I 'j I ( approx.
. Relation.hlP
FINAL ACCEPTANCE: I or We accept and approve, the above selections and terms, and acknowledge that the ge
effe.s:(~el I I IO~ andouter burial contamer price list effectlve ( I, ,I.;)~.were made available prior t" e!;tion
). 1!UA. A"/)I.(/ :JIlt!''''
~i, 'i Siln.lurcofl'urch..e, IDa
/ j ~~Th:
' /~~"'Y'""~"""""
Accepted By /~7:a-~
A.
B.
$~
Register Book........................... $~
Prayer Cards...................... (~';' :.:~ $
CrucifIx. . . . . . . . ; ;'.f1lT---
Temporary Grave Marker. . . . . . . . .. $_
Memorial Board Rental....... .'.... $_
Casket Rental.................. $_
Clothing..... ............. $_
Flag Case... ....................... $_
Other $_
Total of Merchandise Selected (C). ...$ P)..:'-7-<'-
D. Special Charges
Forwarding Remains to
$-
Receiving of Remains from
$-
$-
$-
....$-
Immediate Burial. . . . . . . . . .
Direct Cremation
Total of Special Charges(D)..
E. Cash Advances
Opening of Grave. . . .
Cemetery Equipment. .
Clergy/Mass Offering ...
~~~~~~ 'c~~i;s' ~f D~~~h C~r~ifi~~t~' n.'Q):
Newspaper Notice. . . . . , . . . , . . . . . . . . . . . . .
Cemetery Lot and Deed.......... '.......
Pallbearers............... ,
Airfare .........................
Vault Service Charge. . . ,
Honor Guard ....................
Organist............................... .
Other
$~
$...Mi9D
~ F;,~.
$~
$-
$-
$-
$-
$
$ .,,0
$-
$-
For YOllr convenience, we will advance the cost of the foregoing items; however, any
error made by any supplier of services shall be the sole responsibility of that supplier
and our funeral home is relieved of liability therefore by acting as your agent.
.... $ 900
$ %3>
$-
$~
D. SPECIAL CHARGES.............. $_
Total of Funeral Home Charges.............. $~
E. Cash Advances........................ $~
Total of Funeral Home Charges and
Cash Advan,:es ..<....................
Total of Cash Advances (E) . . . . . . . . . . . . . . . . .
A. PACKAGE ARRANGEMENTS. . . . . . . . . . .
B. ADDITIONAL SERVICESIFACILlTIES . .
C. MERCHANDISE .................
. $69.ID
~~. ~~)r/.I"~
Tule
aHIBI'I' ..
VERIFICATION
I verify that the statements made in the Petition Pursuant to 20 P.S. S5101 are true and
correct.
I understand that false statements herein are made subject to the penalties of 18 Pa.C.S.
Section 4904, relating to unsworn falsification to authorities.
Date: q Iz. s'l v L
,
"
()['i 0 1 ZOO?
IN RE:
IN THE COURT OF COMMON PLEAS
CUMBERLAND CO., PENNSYLVANIA
ORPHANS' COURT DIVISION
TYLER ROBERT MOWRY,
A MINOR
NO. 21.0.2- 878'
~ ,j O~
AND NOW, this 1/ '" day of a
, 2002, based on the
Petition of Jann Jones, the parent and natural guardian of the minor, Tyler Robert Mowry, this Court
hereby GRANTS the Petition and authorizes Jann Jones to execute all necessary documents in order for
the life insurance proceeds, and any interest earned, being held at Prudentiai Financial on behalf of the
minor be released to Jann Jones. It is further ordered that upon receipt of the life insurance proceeds
and any earned interest, Jann Jones is directed to:
1) Pay $1 ,477.50 of the proceeds to Hetrick Funeral Home, Inc.;
2) Pay any attorney's fees and costs related to this Petition;
3) Place the remaining monies in an interest bearing Savings Account at Commerce Bank
under the name and Social Security Number of the minor, Tyler Robert Mowry, with a
notation on the records of the Commerce Bank Savings Account that no withdrawals may
be made until the minor attains the age of majority, except as otherwise authorized by
Court Order;
4) File of record evidence of the marking of the restrictions on the Commerce Bank Savings
Account within ten days of the Account being opened.
BY THE COURT:
Distribution:
Jill M. Wineka, Esq., 1719 North Front Street, Harrisburg, PA 17102
I