HomeMy WebLinkAbout12-16-05
J
IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA
ORPHANS' COURT DIVISION
INRE:
THE ESTATE of HERBERT L. HULL,
Deceased
No. 2002 - 00515
Late of Camp Hill Borough
MOTION OF TRACY HULL TO JOIN IN THE PETITION OF MARCIA HULL FOR
ENFORCEMENT OF THE TERMS OF THE FAMILY SETTLEMENT AGREEMENT
PURSUANT TO THIS COURT'S ORDER OF JUNE 14.2005
AND NOW COMES Tracy A. Hull, by and through his undersigned attorneys,
requesting to be heard at the hearing before this court scheduled for January 19, 2005, seeking
the same relief sought by Marcia Hull, that the terms of the Family Settlement Agreement be
enforced against Lawrence C. Hull, executor of the Estate of Herbert L. Hull, and states in
support the following:
1. Lawrence C. Hull, the executor of the Estate of Herbert L. Hull, has failed to comply with
subparagraphs 3.(iii) and (iv) of the said Agreement, as more fully set forth below;
2. The executor has failed to convey title to the Florida real estate properties to Tracy A.
Hull;
3. The executor has failed to pay all obligations of the estate, in that he has refused to pay
real estate taxes assessed against the estate's real estate in Florida, which should be prorated
through the date of eventual conveyance of the properties to Tracy A. Hull;
4. Movant also requests that reasonable attorney fees be assessed against the executor,
pursuant to subparagraph 3.(iii) of the said Family Settlement Agreement;
\ :
, '
WHEREFORE, Tracy A. Hull moves to be heard at the hearing before this court scheduled for
Jam~ 19, 20~.?, seeking the same relief sought by Marcia Hull, that the terms of the Family
. Settl~tpent A[l'eement be enforced against Lawrence C. Hull, executor of the Estate of Herbert
L. H~. (~
0- C)/
~~:,
C) U ::r:
t3 8::.
,,, o:::s _
C~ /A -/YI-o~
'-0
Respectfully submitted,
SAIDIS, SHUFF, FLOWER & LIND SA Y
By:
~~
Thomas E. Flower
S.Ct. #83993
2109 Market Street
Camp Hill, P A 17011
(717) -737 - 3405
Date~
,I
IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY,
PENNSYLVANIA
ORPHANS' COURT DIVISION
INRE:
THE ESTATE of HERBERT L. HULL,
Deceased
No. 2002 - 00515
CERTIFICATE OF SERVICE
AND NOW, this /6 day of December, 2005, I, Thomas E. Flower, of the firm of
Saidis, Shuff, Flower and Lindsay, hereby certify that I this day served a true and correct
copies of the foregoing Motion upon the parties listed below via United States Mail, postage
prepaid, addressed as follows:
Marcia M. Hull
c/o Paige Macdonald-Mathes, Esquire
SAUL EWING
2 North Second Street, ih Floor
Harrisburg, P A 17101-1604
Lawrence C. Hull
c/o Scott M. Dinner, Esquire
3117 Chestnut Street
Camp Hill, PA 17011
Respectfully submitted,
SAlDIS, SHUFF, FLOWER & LINDSAY
By: ~1~
Thomas E. Flower, Esquire \
Supreme Court ill #83993
2109 Market Street
Camp Hill, P A 17011
(717) 737-3405
Attorney for Petitioner