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NEALON.
GOVER, PC.
ATTORNEYS AT LAW
2411 NORTH FRONT STREET
HARRISBURG, PA 17110
TELEPHONE (717) 232-9900
FACSIMILE (717) 236-9119
JAMES G. NEALON, III
jnealon@nealon-gover.com
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May 27 200'1
DELIVERY VIA FAX
AND U. S. MAIL
Glenda F. Strausbaug
Cumberland County Register of Wills
One Courthouse Square
Carlisle, PA 17013-3387
RE: IN RE THE ESTATE OF DAVID GROSS
NO. 2103-1065
Dear Ms. Strausbaug:
I received the voice mail from your assistant inquiring as to whether we were
going to respond to the New Matter raised in the recent filing of Brian Gross. I do not
believe a response needs to be filed as the New Matter was not endorsed with a Notice
to Plead. However, in order to avoid any confusion, I am enclosing a Verification signed
by me for the Response of Elizabeth Barth to the Petition for Revocation of Letters and
Removal of Administratrix. I would ask that this attached to the Response.
I fully expect to substitute a Verification by Ms. Barth within the next several
days. I did not want this procedural problem be an impediment to resolving the case on
the merits.
Thank you for your attention to this matter.
, P.C.
James G. Nealon, III
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cc: Paula J. McDermott, Esquire (w/enc. via fax and U.S. Mail)
Elizabeth M. Barth (w/enc.)
VERIFICATION
I, ELIZABETH M. BARTH, verify that the statements made in the foregoing
RESPONSE OF ELIZABETH M. BARTH TO PETITION FOR REVOCATION OF
LETTERS AND REMOVAL OF ADMINISTRATRIX are true and correct. I understand
that false statements herein are made subject to the penalties of 18 Pa.C.S.A. ~4904
relating to unsworn falsification to authorities. The Verification of Elizabeth M. Barth
could not be obtained in the time prescribed by the Pennsylvania Rules of Civil
Procedure.
Date: 7 II/elf
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James G. Nealon, III
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