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HomeMy WebLinkAbout04-21-06 IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA ORPHANS' COURT DIVISION IN RE: THE ESTATE of CARRIE A. SHIVELY, deceased No. 2005 - 00519 C') Co ~-xJ co=u tn-,-o :0::;:::,-- r--:- Z rn ,~ uS ;n ""~:- ?' CJoo C)O." oC: ......,. c::;:) c:::t C1" )> -0 ::::0 N ,-:.'CJ r'; I C') ~~5 CJ r':" C:J ~:~:~ ~r~ ':!J <:-) ._._ rn C/:l I;:~; Late of Newville Borough PETITION OF BETTY J. STOUFFER FOR RULE TO SHOW CAUSE EXECUTOR SHOULD NOT BE REMOVED~ SUBJECTED TO SURCH- COMPELLED TO FILE AN ACCOUNT -0 :x: THE 7:'" GE an~ TO THE HONORABLE JUDGES OF THE SAID COURT: NOW COMES, Betty J. Stouffer ("the petitioner"), by and through her attorneys undersigned, and respectfully states the following in support of her petition: 1. By Order of this Court dated March 2,2006 (copy attached hereto), John McCrea, the executor of the Estate of Carrie A. Shively, was directed to present an informal account of his administration of the estate to the petitioner no latrr than March 21, 2006. I As of the date of this petition, one month later, the executor has n~t done so, and he 2. i has not explained his failure to do so. ! I The petitioner's attorney wrote to the executor on April 7, 2006, Ireminding him of 3. this Court's Order and suggesting that even the most informal ac ounting might be acceptable to the petitioner. 4. The executor has not responded, and the petitioner's attorney has een unsuccessful in his attempts to reach the executor by telephone. I WHEREFORE, the petitioner prays this Honorable Court issue upon the 1xecutor a Rule to Show Cause why the Letters appointing him should not be revoked, whyl he should not be I Ordered to file a First and Partial Account, and why he should not be +rcharged for any losses to the estate, as well as the full amount of the petitioner's attorney fets. ~ . -- ~ Dated: fiLl , 2006. Respectfully submitted, i SAID IS, FLOWER & LI~SA Y i I I ~L By: Thomas E. Flower, Esq. Id. No. 83993 II 2109 Market Street Camp Hill, PA 17011 717-737-3405 '- IN RE: THE ESTATE OF CARRIE A. SHIVELY, deceased IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA ORPHANS' COURT DIVISION Late of Newville Borough NO. 2005-0519 ORDER OF COURT AND NOW, this 2nd day of March, 2006, this matter having been called this date, and the parties having reached an agreement for relief that is acceptable to them at this point, it is ordered that an inheritance tax return shall be filed not later than Friday, March 10, 2006, and an informal accounting not later than March 21, 2006. - /' By thE;_/C'o~r '7 ./' ~ (Y Edgar B. ~. Thomas E. Flower, Esquire For Petitioner John McCrae c/o Sally J. Winder, Esquire 9947 Molly Pitcher Highway Shippensburg, PA 17257 Sheriff prs (::J -_:_-~ ~...,.,) E:':l !~ CT" I ()-) t,C,; (11 "" IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA ORPHANS' COURT DIVISION INRE: THE ESTATE of CARRIE A. SHIVELY, deceased No. 2005 - 00519 Late of Newville Borough VERIFICATION I, Betty J. Stouffer, Petitioner, hereby verify that the statements made in the foregoing petition are true and correct to the best of my information, knowledge and belief. 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: April 21, 2006 By: . ,--p IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA ORPHANS' COURT DIVISION IN RE: THE ESTATE of CARRIE A. SHIVELY, deceased No. 2005 - 00519 Late of Newville Borough CERTIFICATE OF SERVICE AND NOW, this 21st day of April, 2005, I, Thomas E. Flower, Esquire, of the firm of Saidis, Flower and Lindsay, hereby certify that I this day served a true and correct copy of the foregoing Petition for Rule to Show Cause upon the party listed below via United States Mail, postage prepaid, addressed as follows: John McCrae c/o Sally J. Winder, Esquire 9947 Molly Pitcher Hwy. Shippensburg, P A 17257 Respectfully submitted, SAIDIS, FLOWER & LINDSAY By: Du~S1~ Thomas E. Flower, Esquire Supreme Court ill #83993 2109 Market Street Camp Hill, PA 17011 (717) 737-3405 Attorney for Petitioner