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BEFORE THE REGISTER OF WILLS OF CUMBERLAND COUNTY, PENNSYLVANIA
IN THE MATTER OF THE ESTATE OF
JOSEPH A. HURLEY, deceased
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~ ORP~ANS, 197
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NO.
PETITION TO COMPEL ADMINISTRATION
TO THE HONORABLE RICHARD E. ANDERSON, REGISTER OF WILLS OF
CUMBERLAND COUNTY:
The petition of FRANCES MARIE BROvffi respectfully represents:
1. That Joseph A. Hurley died intestate, a resident
lof the Township of East Pennsboro, Cumberland County, on October
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123, 1977.
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2. Said decedent was survived by John R. Hurley,
his father and next of kin, who is of full age and sui juris.
3. Said decedent owned sundry personal property at
the time of his death, the value of which is unknown.
4. Your petitioner is Frances Marie Brown, adminis-
tratrix of the Estate of Robert W. Grab, Jr., deceased, and is a
principal creditor of the Estate of Joseph A. Hurley by reason of
rights of action arising from the death of petitioner's decedent
due to the negligence of the late Joseph A. Hurley.
5. The said John R. Hurley has not taken out letters
of administration on the estate of the said decedent.
WHEREFORE, your petitioner prays that a citation issue
directed to the said John R. Hurley, 840 Hillside Drive, Camp
Hill, Pennsylvania, 17011, father and next of kin of Joseph A.
Hurley, deceased, to show cause why he should not apply for, and
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take out letters of administration on the estate of the said
Joseph A. Hurley, or failing this, to show cause why he sould not
nominate another to take out letters in their place and stead.
RESPECTFULLY SUBMITTED:
KOLLAS AND COSTOPOULOS
By
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David J. Fost r, Esquire
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COMMONWEALTH OF PENNSYLVANIA
SS
COUNTY OF CUMBERLAND
Personally appeared before me, a notary public ln and
for said Commonwealth and County, FRANCES M. BROWN, who, being
duly sworn according to law, deposes and says that the facts set
forth in the foregoing PETITION TO COMPEL ADMINISTRATION are true
and correct, to the best of her knowledge, information and belief
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,/;:1?"ibc:.c_e-?-/.?;fI!~{ ~:;AH <?U
. FRANCES M. BROWN
Sworn and subscribed to before me
..' " ':''''~llis <5A day of May, 1978.
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LElviOYi,jE BOi:~}f CU:\~BfR!AND COUNTY
expires: I ClJ,\;,!JiSSiur. EXPIRES JL'NE 13, 1979
--Member, Pell"'Y lv.Y.TIQft.~sOI,laIl6n Of Notaries
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U'~.C~mmission
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IN THE MATTER OF THE ESTATE OF
JOSEPH A. HURLEY, deceased
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COUNTY OF CUMBERLAND
COMMONWEALTH OF PENNSYLVANIA:
SS:
CITATION
To John R. Hurley, (father and next of kin of Joseph
A. Hurley, deceased), Greeting:
At the instance of Frances Marie Brown, Administratrix
of the Estate of Robert W. Grab, Jr., creditor of the Estate of
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I Joseph A. Hurley, deceased, you are hereby cited to be and appear
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Ibefore the Register of Wills for the County of Cumberland,
ICumberland County Court House, Carlisle, Pennsylvania, on the
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J. day of j_i< /l,~ , 1978, at.::j'"':.-; o'clock) .m., and to show
cause, if any you have, why you should not apply for, and take
out letters of administration on the estate of Joseph A. Hurley,
deceased, or, failing this, to show cause why you should not
nominate another to take out letters in your place and stead, and
jgenerallY to do and abide all orders of the said Register of
Wills in the premises. And fail not at your peril.
IN WITNESS WHEREOF, I have hereunto set my hand and cause
the seal of said office to be hereunto affixed, dated at Carlisle,
aforesaid, the ,~~cJ.ciay of
'/no ' 1978.
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