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HomeMy WebLinkAbout11-08-06 I IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYL VANIA ORPHANS' COURT DIVISION MICHELLE ANGELA FOGLE, Movant Estate No. 21-05-0488 vs. MAGDA FOGLE, DECEASED MARK ANDREAS FOGLE, CO- ADMINISTRATOR, and TERRY WILLIAM FOGLE, CO-ADMINISTRA- : TOR, and EDWARD LEE FOGLE, CO- ADMINISTRATOR, ESTATE OF MAGDA FOGLE, DECEASED, Respondents r-~ ~ ................< or" o ::n :::~o -'-- )~~ ~n , "'-:::D ,CI):^ -,:'.""" F.'l!"._ c.) <: I en .!,:8~~J: ',t1__ .. ':1.) -j -0 .-1h w o w MOTION FOR ADJUDICATION OF CONTEMPT AND SANCTIONS FOR WILLFUL DISOBEY ANCE OF A COURT ORDER Movant, Michelle Angela Fogle (hereinafter "Movant"), hereby files this Motion for Adjudication of Contempt and Sanctions respectfully stating in support thereof the following: 1. Movant in the above captioned proceeding is the legally adopted daughter of Magda Fogle, Deceased. See Certificate of Adoption attached hereto as Exhibit "A." 2. Respondents are the biological sons of the Decedent and are the duly appointed Co-Administrators of the Estate of Magda Fogle, deceased. A copy of the Decree of Probate and Grant of Letters is attached hereto as Exhibit "B. " 3. The Decedent, Magda Fogle, died testate on May 8, 2005. A copy of the Decedent's Last Will and Testament is attached hereto as Exhibit "c." .' 4. Upon written demand of the Cumberland County Register of Wills dated August 15, 2005, Respondents filed a Certification of Notice Under Rule 5.6(a) on September 2, 2005. Copies of said correspondence and Certificate of Notice Under Rule 5.6(a) are attached hereto as Exhibits "D" and "E" respectively. 5. Movant never received a Notification of Beneficial Interest from Respondents as required under Orphans' Court Rule 5.6(a). 6. It is believed and therefore averred that no advertisements of the Estate of Magda Fogle have been undertaken by the Respondents as required by 20 Pa. C.S.A. 9 3162. 7. No inventory has been filed for the Estate of Magda Fogle. 8. It is further believed and therefore averred that real estate belonging to the Decedent was sold by Respondents on or about September 14, 2005 for a gross sale price of One Hundred Seventy-One Thousand Nine Hundred ($171,900.00) Dollars. A copy of the recorded Administrator's Deed is attached hereto as Exhibit "F." 9. It is believed and therefore averred that Respondents' failure to notify Movant of a potential beneficial interest in Decedent's estate coupled with Respondents' failure to respond to Movant's written demands for status reports on the administration of Decedent's estate indicates Respondents' intent to exclude Movant from an equal distribution of the estate of Decedent. 10. When multiple attempts to contact Respondents by written correspondence and certified mailings yielded no response, Plaintiff initiated this action by 2 filing a Petition for Citation to Show Cause Why an Account Should Not Be Filed in Accordance with 20 Pa.C.S.A. ~ 3501.1 with the Cumberland County Court of Common Pleas, Orphans' Court Divisions on May 9, 2006. 11. Respondents failed to provide any responsive pleading, and thereafter on June 28, 2006, this honorable Court, in response to Plaintiff's Petition for Order to File an Account in Accordance with 20 Pa. CSA ~ 3501.1, issued an Order compelling the Respondents to file an accounting within thirty (30) days after personal service of the order upon them. 12. Personal service upon Respondents Mark Andreas Fogle and Edward Lee Fogle could not be achieved by certified mail insofar as all certified mail deliveries were refused. See attached copies of unclaimed certified mailings and unexecuted return receipts attached hereto as Exhibit "G." 13. At the direction of this honorable Court, on or about July 19, 2006, the Cumberland County Register of Wills re-mailed copies of the June 28, 2006 Order to Respondents Mark Andreas Fogle and Edward Lee Fogle by fi.rst class mail to establish service upon them. 14. Upon the allowance of three business days for delivery of the first class mailing, the date of August 22, 2006 was established as the deadline for Respondents to comply with this Court's Order to file and accounting in the matter of the Estate of Magda Fogle. 15. Respondents, by willful conduct, have shown a wanton disregard for the Order of Judge Oler dated June 28,2006, by failing and/or refusing to file any accounting of their administration of the Estate of Magda Fogle. 3 16. Respondent's vexatious conduct has been in total disregard for the Court's authority and similar conduct has taken place previously in this proceeding as Respondents disregarded this Court's Citation To Show Cause Why an Account Should Not Be Filed in Accordance with 20 Pa. C.S.A. 9 3501.1. 17. Under Pa.C.S.A. S 4132, entitled "Attachment and Summary Punishment for Contempts", Movant moves this Court for the relief set forth infra due to Respondents' repeated failure to accept service of this honorable Courts' Decrees and Respondents' willful disobeyance of this Court's Order dated June 28, 2006. 18. Pa. R.C.P. 4132 permits the Court, when acting under subdivision (2) of the rule, to enter an order imposing punishment for contempt. 19. Respondents' conduct has frustrated Movant's efforts to proceed m this action. 20. Respondents' continued egregious conduct has left Movant no alternative but to file this Motion for Adjudication of Contempt. 21. Due to Respondents' willful conduct in complete disregard for the authority of this Court, Movant now seeks to have this Court find Respondents in contempt of its Order; requests that this Court impose punishment upon Defendant for contempt to the greatest extent permissible under the law; schedule a hearing on the instant matter requiring the attendance of Respondents; order Respondents to pay Movant's costs, expenses, reasonable attorney's fees in preparing and presenting this Motion amounting to Five Hundred and Fifteen and 00/100 ($515.00) Dollars; order Respondents to pay 4 Movant's prior attorney fees expended to date in acquiring an accounting of Respondents' administration of the Estate of Magda Fogle in the amount of Nineteen Hundred and Eighty-Two 00/100 ($1,982.00) Dollars; and grant such other relief as this Court deems just and proper. 5 WHEREFORE, Movant, Michelle Angela Fogle respectfully requests that this Honorable Court find Respondents in contempt; impose punishment upon Respondents for contempt to the greatest extent permissible under the law; order Respondents to pay Plaintiffs costs, expenses, reasonable attorney's fees amounting to Five Hundred and Fifteen and 00/100 ($515.00) in preparing and presenting this Motion and prior attorney's fees amounting to Nineteen Hundred and Eighty-Two and 00/100 ($1,982.00) Dollars expended by Movant in pursuit of an accounting of Respondent's administration of the Estate of Magda Fogle; and grant such relief as this Court deems just and proper. Respectfully submitted, LA W OFFICES OF CRAIG A. DIEHL Dated: J 1- g () & By: ~ ~~ Shelly . Ku el, Esquire Supreme Court ID No. 64485 3464 Trindle Road Camp Hill, PA 17011-4436 Craig A. Diehl, Esquire Supreme Court ID No. 58201 3464 Trindle Road Camp Hill, PA 17011-4436 (717) 763-7613 Counsel for Movant 6 (') o c. '" ... -< Vl <> e.. Cl ~ <> o -, - '" ~ <> t ro ~ lTI o -n ." 1> 11 lTI Z ~ cr -< - . t ~ ~ 0 lTIOI{ o t-' "'f\ (\) "'ll 1> 11 1I1 Z j (') ~ g \~ ~ p.. <> n ... " '" p.. ;- '" ; Vl - Vl ...J, o fA ~ - '"T1 ..<. ~. ... ;:r <> 9 ~ .<. o "'ll ~ % ~ o -, ;- '" n o ~ n~ 1'\0 :11% -\\i 1;1'1 S t~t - . ~:r. o 00 o ~ ~ ~"\l ..; )011\ cT \ O%. ..... 0% '-" -QUI 1-" -\ -< 4 _... 1-" 0 <. UJ %.)0 1-" % o _ ';:S )0 o H1 o ::l oz. o 4 <1l ~ <1l 11 b \} No. 1J-D5-01t~ Estate of OF PROBATE AND GRANT OF LETTE AND NOW A'1.31 p05 . in consideration of tJe petition on the reverse side hereof, atisractory proof having been preseuted before me, I IT is DECREED that t e instruroent(s) date' - 23 - I 1 described therein be a tted to probate and filed of record as the last will of ffiA[; ~ F D f4:rW ARb l.f;!; Yo LE: . R~ster of Willi Pf1V rn FES Probate, Letters, Etc. ......... $ 'luO.au Short Certificates( (Q) . . . . . . . . .. $ 24 ,(TO 'Re:a l:l.aeiati~ :~'lIl,...h. ....... $ ~ 5, 00 A .....JCP sib. 00 TO L _ $ 314.(fV Filed .. RJ~ .I.Q5... ................... ATTORNEY (Su-p. Ct. 1.1 No.) I ADDRESS I PHONE .~) 1 WILL OF MAGDA FOGLE I I . cumb~~land I : rJ UJ I, MAG A FOGLE, of Upper Allen Township, Pennsylvania~ de lare the following to be my will: County, FIRST: I revoke all wills and codicils heretofore made by I me. of my estate, re he shall survive me. I direct that my just debts and fune~al expenses I I I I I I devise, bequeath and appoint all ofl the residue personal, to my husband, LUTHER ~. FOGLE, if I I I If he shall not survive me, I devise~ bequeath f said residuary estate, real and persrnal, in he children, namely, TERRY WILLIAM, EDWARD LEE and s practicable after my decease. SECOND be paid as soon THIRD: FOURTH and appoint all equal shares to I MARK ANDREAS, in addition to any children of mine herearter born. FIFTH: The share of any distributee hereunder who shall be a minor shall be held in trust for such minor by thel Trustee hereinafter name , to manage, invest, reinvest and to p~y to or apply for the us of such minor from time to time such ortions or all of the incom and principal as the Trustee shall co sider nec- essary for the rn intenance in health and education (ine' uding college or techn~cal training as appropriate) of the mihor, and to distribute to SU1h minor when the minor attains majority, the re- maining assets 01 the trust, if any. \ I MAE E. RUDY, Ex1cutors. serve or qUalif~ as such, I I I I I appoint the said I. RUSSELL RUDY rnd MAE E. RUDY, Trustees of the trusts herein created. Should ei~her of them cease or fail tOt I serve or qualify as such Trustees, the other shall be or continue a sole Trustee. I IN WI~ESS WHEREOF, I, the said MAGDA FOGLE, ~erewith set my hand and seallto this my last will, typewritten on t~o (2) sheets of paper (inCIUdlng the attestation clause and signatur~ of wit- nesses) upon one of which I have also written my nhme this 7-;;~ dayof', Nineteen Hundr+ and Sixty- Four. I ,110 tp:(-I Fe - 1 MAGDA ~~ as such, I apPoiht I. RUSSELL RUDY and Should either orrthem cease or fail to I appoint the other sole Executor. I SEVENTk: (SEAL) i On the . , 196~, MAGDA FOGLE declared t I us, the undersig ed, that the foregoing instru- ment was her las will, and she requested us to act as o/itnesses to the same and to er signature thereon. She thereupon stgned said will in our pres nee, we being present at the same time~ And we now, at her requ st, in her presence, and in the presen~e of each other do hereunt subscribe our names as witnesses. Ani we and each of us decla.e that we believe this testatrix to be of sound mind and memory. residing at residing at 1."-...---...-----. Cumberland County - Register Of Wills One Courthouse Square Carlisle, PA 17013 phone: (717)240-6345 Date: 08/15/2005 FOGLE MARK ANDREAS 77 YELLOW WOOD DRIVE DOWNINGTOWN, PA 19335 RE: Estate of FOGLE MAGDA File Number: 2005-00488 Dear Sir/Madam: It has come to my attention that you have not filed the Certification of Notice Under Rule 5.6 (a) in the above captioned estate. As per the AMENDMENTS TO SUPREME COURT ORPHANS' COURT RULES, NO. 103 SUPREME COURT RULES DOCKET NO. I, for decedents dying on or after July 1, 1992, the personal representative or his counsel, within ten (10) days after giving proper notice to the beneficiaries and intestate heirs as required by subdivision (a) of Rule 5.7, shall file with the Register of Wills or Clerk of the Orphans' Court his/her Certification of Notice. This filing is due by: 09/10/2005 Your prompt attention to this matter will be appreciated. Thank You. Sincerely, ~.~M~~~ GLENDA FAR~;~~t~~UGH Clerk of the Orphans' Court cc: File Counsel Judge CERTIFICATION OF NOTICE UNDER RULE 5.6(a) Date of Death: ~ M f\<OOt:\ U~ z..ooS ~O(nll-? Name of Decedent: ~ Will No. 'L 0 05 ~ ()() t{ "t <is Admin. No. To the Register: 1 certify that notice of (beneficial interest) ~state administration required by Rule 5.6(a) of the Orphans' Court Rules was served on or mailed to the following beneficiaries of the above-captioned estate on Name Address m Arul Po cd ~ L(pNl[) rfY/t0 ;r;-D{Q t j'?; 17--L{0101~"oO Df2.. lhll)((Olo"1(vJ,fl) ~, '(133$ 110 TO/J~-'<\) bll', ~om: ~ ll'fo'L '7 ~ <8-Mma t-'i 7-TIltk~ rU\ I (j tdlD~ ~ ;~a,1 ..---- ( ~R v{ Notice has now been given to all persons entitled thereto under Rule 5.6(a) except Date: Signatu,e (V -LlufJ /)-, ~ /t-;;v? R1 ( tD CO(pU:. '3 ~B llll nofLli: :nP2t~ NI(LUf2S()~A- ll6~J /pO[ L - 338y -- vUCr'2..Jt. Telephone ( 11 )( -!:t 4 ~ .- Ll510 5 --r- kLL Name Address o " U'-:. l. . c.,,' I' Capacity: V'Personal Representative I. I ('~J _Counsel for personal representative '"-- ' L '" . I' " t:-, ,:;:....; (.) ;;--- . '3 51 j I IV ~ ReBEI1T P. ZIEGLER :::~C;C;\D[i~. OF DEEDS .,.... '.1 ',:," GO',P.!TY-F' Parcel No: 42-29-2454-017 -- ('-P 20 UJ l..ll RfTlll 30 ADMINISTRATORS' DEED THIS INDENTURE is made this 15 bh day of September, 2005. BETWEEN MARK ANDREAS FOGLE, Co-A.llRiniatrator of the Estate of Magda Fogle alkJa Magdalene Fogle; TERRY WILLIAM FOGLE, Co-Administrator of the Estate of Magtla Fogle alkJa Magdalene Fogle; and EDWARD LEE FOGLE, Co.Administrator of the Estate of Magda Fogle aJkJa Magdalene Fogle; herein designated as the Grantors, AND JON J. BRENNEMAN and PAULA L. BRENNEMAN, his wife, herein designated as the Grantees WHEREAS, Jack E. Bertolette and Edna M. Bertolette, his wife, by Deed dated April 2, 1962, and recorded April 2, 1962, in the Office of the Recorder of Deeds in and for Cumberland County, Pennsylvania in Deed Book Volume M-20, Page 78, granted and conveyed the land herein described unto Luther A. Fogle and Magda Fogle afkfa Magdalene Fogle; WHEREAS, Luther A. Fogle died on September 24, 1978; and WHEREAS, Magda Fogle aIkIa Magdalene Fogle died on May 8, 2005; and WHEREAS, the Register of Wills of Cumberland County, Pennsylvania, duly granted Letters of Administration to Mark Andreas Fogle, Terry William Fogle and Edward Lee Fogle, the Grantors herein, on May 31, 2005, thereby granting them authority to grant and convey said premises pursuant to Section 3351 of the Pennsylvania Probate, Estate and Fiduciary Code (20 Pa. C.S.A. Section 3351). aoci 271 PACE 1 '7.9 !ili i .- -,..........-......- NOW THIS INDENTURE WITNESSE1H, that the said Grantors, for and in consideration of the sum of One Hundred Seventy.One Thousand Nine Hundred and 00/100 ('171,900.00) DoUIll'8 lawful money of the United States of America, unto them, well and truly paid by the said Grantees at and before the sealing and delivery hereof, the receipt whereof is hereby acknowledged, granted, bargained, sold, aliened, released and confIrmed, and by these presents do grant, bargain, sell, alien, release and confirm unto the said Grantees, their heirs and assigns, ALL THAT CERTAIN piece or parcel of land, situate in the Township of Upper Allen, County of Cumberland and State of Pennsylvania, bounded and described as follows: BEGINNING at the point of intersection of the southern line of Andes Drive and the western line of Cascade Road, as shown on the hereinafter mentioned Plan of Lots; thence along the western line of Cascade Road South three (3) degrees twenty-three (23) minutes West one hundred twenty-nine and forty-two one-hundredths (129.42) feet to a point; thence along other lands now or formerly ofMt. Allen Corporation, South eighty-four (84) degrees fifty-three (53) minutes West ninety and eighty-seven one-hundredths (90.87) feet to a point; thence along the eastern line of Lot No. 38 on said Plan North five (5) degrees seven (7) minutes West one hundred twenty-eight (128) feet to Andes Drive; thence along the southern line of Andes Drive North eighty-four (84) degrees fifty-three (53) minutes East one hundred ten (110) feet to the Place of BEGINNING. BEING Lot No. 37 on Plan of Section 2, Mt. Allen Heights, said Plan being recorded in the Recorder of Deeds Office of Cumberland County in Plan Book 12, Page 16. HAVING THEREON EREcrED a brick, split level dwelling house known as No. 508 Cascade Road, Mt. Allen Heights. UNDER AND SUBJECl' to covenants, easements, and restrictions of record. TOGETHER with all and singular improvements, buildings, ways, waters, water courses, rights, liberties, privileges, hereditaments and appurtenances whatsoever thereunto belonging, or in any way appertaining and the reversions and remainders, rents, issues and profits thereof; and also all the estate, right, title, interest, use, trust, property, possession, claim and demand whatsoever, of her, the said Magda Fogle alkJa Magdalene Fogle, as and immediately before the time of her decease, in law, equity, or otherwise howsoever, of, in, to, or out of the same. TO HAVE AND TO HOLD the said parcel above-described with improvements thereon, hereditaments and premises hereby granted and released, or mentioned and intended so to be, with the appurtenances, unto the said Grantees, their heirs and assigns, to and for the only proper use and behoof of the said Grantees, their heirs and assigns forever, AND the said Grantors, for themselves, their heirs, executors and administrators, do covenant, promise and agree, to and with the said Grantees, their heirs and assigns, that they have not done, committed, or knowingly or unwillingly suffered to be done or committed, any act, matter or thing whatsoever whereby the premises hereby granted, or any part thereof, is, are, shall or may be impeached, charged or encumbered, in title, charge, estate, or otherwise howsoever. BOOK 271 tACE 18!) . i~~ .--- .~ ;I~_ I ..... _._--,..". IN WITNESS WHEREOF, the said Grantors have hereunto set their hands and seals the day and year fIrst above written. SIGNED, sealed and delivered in the presence of: WITNESS WITNESS WITNESS EDWX. EE G E, Co- Administrator 0 the Estate of Magda Fogle alkJa Magdalene Fogle COMMONWEALTH OF PENNSYLVANIA COUNTY OF L\..l,fn b ifl CAn cL 55. On this 15 ch day of September, 2005, before me, a Notary Public, personally appeared MARK ANDREAS FOGLE, Co-Adllliniatrator of the EAtale of Mapa Fogle aIkIa Magdalene Fogle, known to me (or satisfactorily proven) to be the person whose name is subscribed to the within Deed and acknowledged that he executed the same for the purposes therein contained. Witneu my hand and seal the day and year aforesaid. 0}11~ if}Y)-~~ Notary Public NOTARIAL SEAL MILDRED M. O'DONNELL, Notary Public City of Harrisburg, Dauphin Co. PA My Commission expIres Aug. 26: 2006 BOOK 271 PACf is! illT COMMONWEALTH OF PENNSYLVANIA COUNTY OF tlAMb erJ WI&. SS. On this IS bh day of September, 2005, before me, a Notary Public, personally appeared TERRY WILLIAM FOGLE, Co-AdminUtrator 01 the Eatate 01 Mqda FQ8Ie alkJa ~De Fogle, known to me (or satisfactorily proven) to be the person whose name is subscribed to the within Deed and acknowledged that he executed the same for the purposes therein contained. Witness my hand and seal the day and year aforesaid. NOTARIAL SEAL MILDRED M. O'OONNELL, Notary Public City of Harrisburg, Dauphin Co., PA rlrj Commission Expires Aug. 26. 2006 ~ OJJ7-~~ Notary Public COMMONWEALTH OF PENNSYLVANIA COUNTY OF t.urnberlc...()~ SS. On this IS \:h day of September, 2005, before me, a Notary Public, personally appeared EDWARD LEE FOGLE, Co-Administrator of the Estate ofMasda Fogle alkJa ~daleDe Fogle, known to me (or satisfactorily proven) to be the person whose name is subscribed to the within Deed and acknowledged that he executed the same for the purposes therein contained. Witne88 my hand and seal the day and year aforesaid. MILpRED ~P6~~~~l SEAL M CIty of HarriSburg ~~~h~o~ry Public Y Commission Expires A In 0., PA u(J. 26, 2D06 ~O'h-r>rD~ Notary Public adaK zn .~ 182 ~ .J.L ___--:-'-~.1 . , The undersigned certifies that the precise residence and complete post office address of the Grantees is: 5 68 C(),,)e.u.d~ D(;)uJ.--. f\1 ~JiCt.n'L..-~l>>rb fR ) 7055 p;~ Attorney/Agent for Grantees '.'n I' ; h IS to be rey;_:cJ ;:,';"['r;~llld ("()un;'/ PA f.",J"..I......... v "./ . . ".0.' ...f.....,,:r...l <.'.: :',;;;.!<.- >..-, -.p 7 ~> p'. ,) , Recorder of Deeds f/IIf?~~~M f .... n =' ... ~ 41 ~ ... ... :J<:' .., ... ... .. ,'" ..... iif~f ~! 8 ~ ;;ta c... ,.., I -n ,. .. . !!1 i!?; a All ~5 .i i/" ~ ,... CJJ ... XJ .- ('". c..A I'D ... .... -:I -. Ii ! J ~ - o"T .-. . -c 0 ...... <JI .,., .... !?S -> :::.li- t.o.l -. '" ........, ~ <> :::lI .- '" C2 8 ..... 0 ::B ~ g~:;'" ..... Q.. ..... 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