HomeMy WebLinkAbout07-20-06
IN RE:
IN THE COURT OF COMMON PLEAS OF
CUMBERLAND COUNTY, PENNSYLVANIA
ORPHANS' COURT
ESTATE OF MICHAEL R. BROWN
No.i~I~C0. ~
PETITION FOR DISTRIBUTION UNDER I 3102
OF THE PROBATE ESTATES AND FIDUCIARIES CODE
TO THE HONORABLE, THE JUDGES OF SAID COURT:
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The Petition of Mickey C. Shuler respectfully represents:
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1. Your Petitioner, Mickey C. Shuler, is an adult individual residing at '332 'Selle
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Vista Drive, East Pennsboro Township, Marysville, Cumberland County, Pennsylvania.
2. Your Petitioner is the owner of Shuler's Mobile Home Park located atc:g50
Orchard Avenue, Lower Allen Township, Camp Hill, Pennsylvania.
3. The Decedent, Michael R. Brown, died on January 31, 2006 as a resident of the
aforesaid Shuler's Mobile Home Park.
4. To the best of your Petitioner's knowledge, the Decedent was survived by two
daughters, Michelle Siefken, 515 Grand Avenue, Thiensville, Wisconsin and Angela Brown, 202
27 Dale Street, Medfield, Massachusetts.
5. At the time of the Decedent's death, the Decedent was the owner of a 1964
Richardson Mobile Home, Serial No. 14055XC15179. A copy of the certificate of title is
attached hereto as Exhibit A.
6. The Decedent leased space for the aforesaid mobile home in the Petitioner's
mobile home park for a monthly rental of $265.00 pursuant to a Lease Agreement.
7. No rent has been paid to the Petitioner since January of 2006, and there is now
due and owing the sum of $1,855.00.
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$2,250.00.
The cost of removing the aforesaid mobile home from the park will be at least
9. The mobile home has no value because of the cost of removal. Attached hereto
is a proposal for removal and an opinion of value. The aforesaid Harvey M. Shuler is not related
to the Petitioner.
10. The Decedent was also the owner of 1995 Lincoln Mark VIII, Serial No.
1 LNLM91VOSY620847, which automobile has been parked in the Petitioner's mobile home park
since the time of the Decedent's death. A copy of the certificate of title is attached hereto as
Exhibit B.
11. To the best of the Petitioner's knowledge and belief, the cost of the Decedent's
cremation and funeral has been paid by the Decedent's daughters.
12. To the best of the Petitioner's knowledge and belief, the Decedent left a Will
purporting to leave all of his estate to his daughters, but the Decedent's daughters have not
probated the Will and have no desire to administer the estate.
13. The Petitioner knows of no other assets of the Decedent other than the mobile
home and the car.
14. In order to be able to remove the mobile home and the automobile from the
Petitioner's park, Petitioner needs to have the title to the Decedent's mobile home and title to
the Decedent's automobile transferred to the Petitioner.
15. The value of the mobile home and the automobile will not cover your Petitioner's
costs for past due rent and removal of the mobile home.
16. The consents of the Decedent's daughters are attached hereto.
WHEREFORE, Petitioner prays that Your Honorable Court enter an Order authorizing
distribution of the aforesaid mobile home and automobile to the Petitioner and directing the
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Department of Transportation, Bureau of Motor Vehicles for the Commonwealth of Pennsylvania
to transfer title of the aforesaid mobile home and automobile to your Petitioner.
Respectfully submitted,
JOHNSON, DUFFIE, STEWART & WEIDNER
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Richard W. Stewart
Attorney I. D. No. 18039
301 Market Street
P.O. Box 109
Lemoyne, PA 17043-0109
Telephone (717) 761-4540
Attorneys for Petitioner
By:
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VERIFICATION
I, Mickey C. Shuler, the Petitioner named in the foregoing Petition, make this Affidavit
and have knowledge of the facts set forth in the foregoing and that said facts are true and
correct to the best of my knowledge, information and belief. I understand that false statements
made herein are subject to the penalties of 18 Pa.C.S. 94904 relating to unsworn falsification
authorities.
Dated 7/11 0 ~
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