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OC1971-0060 - ESTATE OF MOFFITT
f T"""""{_'----,...- -,# ./ • IN THE COURT OF COMMON PLEAS OF WASHINGTON COUNTY,PENNA • ORPHA~S'COURT DIVISION NO •.!r>C>t IN RE::ESTATE OF ,.MANIE MOFFITT, an alleged incompetent. 'I "-" ...--..•.... .\) PETITION-FOR APPOINTMENT OF GUARDIAN,ORDER AND DECREE ,rP J}\"~,;/iErl-:-,''0:..1 --1\-~/i!'J.\'\,y 2)(::::i ,'.~\)...'.,.v,\~.'.-.: (l \.~-- ~(J",-.Ii .,_,- v ,~,'~~:,'-:~';_. ~t·_~-;~.'V"--,,J .'~ ~"'''c,,,',\l'--'J 't rt~ I ~"J'\l;Y~)/~~2.J~:T~~ ~#/n.d~U""belk.~~ ~i/,,~~ ~~}/-)Y~'7 "). /h Lf-115\~~~(!J!;;:f .Jhz~-e~~~}:.3..-JL;1-7! 'O;l )'-,~'~ BFC/ma 1 -lOp 1/15/18/71 IN THE COURT OF COMMON PLEAS OF WASHINGTON COUNTY,PENNSYLVANIA. ORPHANS'COURT DIVISION IN RE:ESTATE OF MANIE MOFFITT, an alleged incompetent. (NO. PETITION FOR APPOINTMENT OF GUARDIAN TO THE HONORABLE P.V.MARINO,JUDGE OF SAID COURT: The Petition of Harold G.Moffitt respectfully represents: 1.That he is the nephew of Manie Moffitt,and is a resident of the City of Hagerstown,Maryland. 2.That the said Manie Moffitt,is a spinster,aged 82, and is a citizen of this state and resides in the Borough of Charleroi,Washington County,Pennsylvania,where she has resided continuously for more than seventy (70)years,and is a patient in the Brownsville Golden Age Nursing Home,5th &Church Streets, Brownsville,Pennsylvania. 3.That the said Manie Moffitt,the alleged incompetent, has real property located in Charleroi,Washington County,Penn- sylvania,amounting to approximately Ten Thousand ($10,000.00) Dollars. 4.That the said Manie Moffitt has personal property consisting of a checking account in the Charleroi Office of Mellon National Bank and Trust Company in the sum of approximatel~ Ten Thousand ($10,000.00)Dollars;two Social Security Adminis- tration Checks,dated December 3,1970,and January 3,1971, each in the sum of $40.20;a large,but undeteimiriednuwber 'of U.S.Government Bonds;miscellaneous clothing and furniture; and other,as yet undetermined personalty. 5.That the following is a list of all persons residing without the Commonwealth,who are sui juris,and would be en- titled to share in the estate of Manie Moffitt,if she would die intestate,there being none residing within Pennsylvania: a.Delphia Moffitt,wife of deceased brother, Edgar Moffitt,344 Townsend Road,Baltimore,Maryland,21221. b.Thomas E.Moffitt,nephew,2706 Rocks Road, Forest Hill,Maryland,21050. c.Madaline Litzan,niece,5013 Greenhill Avenue, Baltimore,Maryland,21206. d.Fred Moffitt,nephew,974 Martin Road,Baltimore, Maryland,21221. e.James W.Moffitt,nephew,Route 10,Box 524 A, Baltimore,Maryland,21219. f.Kenneth K.Moffitt,nephew,Route 1,Box 418, Frostburg,Maryland,21532. g.Mary Hoye,niece,344 Townsend Road,Baltimore, Maryland,21221. h.Harold G.Moffitt,nephew,136 Nottingham Road, Hagerstown,Maryland,21740. 6.That the alleged incompetent has no Guardian of her estate and no court has ever assumed jurisdiction in any proceeding to determine her competency. -2- 7.That the said Manie Moffitt,because of mental infirmities of old age,is unable to manage her property,and is liable to dissipate it or become the victim of designing persons. 8.That it is respectfully suggested that Mellon National Bank and Trust Company,be appointed Guardian of the Estate of the said Manie Moffitt,should she be adjudicated to be an incompetent person;and that the said suggested Guardian has no interest adverse or hostile to the alleged incompetent. 9.That there is attached hereto,made part of and!' marked Exhibit "A"the affidavit of Dr.W.L.iCunningham, stating that he is a physician and is well aC9uainted with Manie Moffitt,and that in his opinion she is'likely to become the victim of unscrupulous or designing persons,and that she cou!d not come to Court without risk of injury to herself or others. WHEREFORE,your petitioner respectfully prays your Honorable Court to adjudicate and find that Manie Moffitt is an incompetent,and to appoint Mellon National Bank and Trust Company,as Guardian of her Estate. And your petitioner will ever pray,etc. Harold G.Moffitt Howard F.Carson,Esquire, Attorney for Petitioner -3- COMMONWEALTI-I OF PENNSYLVANIA ) COUNTY OF WASHINGTON ) SS: Before me,the undersigned authority in and for said County and Commonwealth,personally appeared HAROLD G. MOFFITT,who,being duly sworn according to law,deposes and says that he is the petitioner in the foregoing petiton for appointment of guardian,and that the facts stated therein are true and correct to the best of his knowledge,information and belief. Sworn to and subscribed before me this __.~/~~~-__~day of January,1971. Notary Public My Commission Expires: COMMONWEALTH OF PENNSYLVANIA) COUNTY OF WASHINGTON ) SS: Before me,the undersigned authority in and for said County and Commonwealth,personally appeared Dr.W.L.Cunn- ingham,a legally licensed physician in the Commonwealth of Penn- sylvania,who,being duly sworn according to law,deposes and says that he is well acquainted with Manie Moffitt,and that in his opinion she is likely to become the victim of unscrupulous or designing persons,and that she could not come to Court without risk of injury to herself or others,and therefore ex- presses his belief that the within petition for appointment of guardian would be to the best Sworn to and subscribed before me this 15th day of January,1971. ~+'t!.2:"L/u! of her advantage.~ /~~.~ Dr.W.L.Cunningham "';"4- ACCEPTANCE BY CORPORATE GUARDIAN Mellon National Bank and Trust Company agrees to accept the appointment as Guardian of the Estate of Manie Moffitt. That the Mellon National Bank and Trust Company is not the fiduciary of an estate in which the incompetent,Manie Moffitt,has an interest,nor the surety of such a fiduciary, and has no interest adverse to that of said incompetent. MELLON NATIONAL BANK AND TRUST COMPANY ~,I By_----II...../7~=_M~·~_'---.a.:;W..;;;......;·~(}c~__--1 l/'Trus t Officer -5- ~"~.,...~~ NO.60 of 1971 .M'='......,.--- .£STATE OF IN liZ: Jlu IDQr Q!nurt nf Q!nnttttnu 'ltall nf lIullQiugtnu Q!nuuty.Jtuullyluuuia (@rp11uttl1'aIotirt iHUl1110U (( )) ~(1J il&ttou ~ ¥,llNI?_M.QI,PJTT.,_(( an alleged inCo~p8tent.))Ql,nltttltn1t1U~ultl1 nf.Jl'llUnylttulliU Inn: QInUttty of iIunlliugtott ) . t Sur Petition of:__-,-p...;..t<-:..1:?.w..O......T'·J.LO--'G.................;..1'.....·m.Li..1"....:.Ti'......I-'7......rr _ that,laying aside all business and excuses whatsoever,you do file in'the office of th,e Clerk of our Orphans'Court of \Vashington County,a full and com- plete answer,under oath,to each and every of the averments of the said petition,on or before r:ruGsday ,the.16th day of F_e_b_r_u_ar--,;,,--l__ 19~,at 2 :00.o'clock~.M.,and show cause why tt.9 said [,fanie Hoffi tt should r:.ot be adjudged an incon:petent and 8.guardi.s.n of her estate m:mointed; and further abide the order of our said Court in the premIses, If you fail hereof,the petition may be taken PRO CONFESSO and a decree made against you. WITNESS the Honorable P.Vincent Marino,Judge of our said Court, at Washington,Penna.,the 18th day of_-/-_~_:t--)n_u_a_r~'.I_.....:-_,19 "{I _~~??;c<~, Clerk of the Orphans'Court _..J..JH-,-,O-""H...o./lll.R.u.D_"'..:-.'..........."r....:...I.[e>....\'D....,,\::'.....IO.u.;Ny,'--Esq. Attorney for Petitioner. (Seal) IN'"RE: .iESTATE OF Qrol1tntntt1l11~ultl~nf Jru1t!lyhtUttiU .Olnuuiy nf iiiU!l11ittgtnu 3Jn m~r QIoud of QIommon.JUra.a of lJa.a~in!lton atouuly,Jrnn.ayluania ((@rpquuli'Qronti mi11i9iou ().) (( MANIEMOFFITT , )11Ii'..t t..·)NO.60 of 1971 an alleged incompetent'~t a.lOU ( ,)) ( \55: To:MANIE MOFFITT an alleged incompetent Sur Petition of:HAROLD Go HOFFITT ~rt.rtiug: lUr Qrnt1tnttttt~inu,--J.':J.Mj:UAN"'-JI'-L:.E........Ml:.UO./.£FF~IT.I.....lTL...____, that,laying aside all business and excuses whatsoever,you do file III the office of the Clerk of our Orphans'Court of \Vashington County,a full and com- plete answer,under oath,to each and every of the averments of.the ~aid petition,on or before_~M~o~n=da~yJ---__,the'8th day of__---=--=M_ar=--c.:..;h~_ 19-11,at 10 :oO-.-o'clodcA--..M.,and show cause why the said Nanie Moffitt shoUld not b~~djudged an incompetent and a guardian of . her estate aupointed; and further abide the order of our said Court in the premIses, If you fail hereof,the petition may be taken PRO CONFESSO and a decree made against you. \VITNESS the Honorable P.Vincent Marino,Judge of our said Court, at Washington,Penna.,the 1st day of__---'F"--'.=eb=r~u=a=r__J.y ,19 71. ~?o~:g Clerk of the Orphans'Court HOWARD F.CARSON,E_______________sq. '.' I.',~'.~ Attorney for Petitioner. (Seal) Charleroi, Penna. 15022 .. IN THE COURT OF COMMON PLEAS OF WASHINGTON COUNTY,PENNSYLVANIA. ORPHANS'COURT DIVISION IN RE:ESTATE OF MANIE MOFFITT, an alleged incompetent. o R D E R AND NOW,this AND DEC R E E--------- f~ /day of January,1971,uponI this petition;and it is dir- present~~_Of the a citationl:;s~2~rrded.\and the t~y of ~t!~~~~ii~~,1971,at ~'C£<?o 'clock, ~M.,is fixed for a hearing 0 ected that twenty (20)days'written notice thereof ,be given to Manie Moffitt,by personal service of a copy of the Petition~~ and -&rde~of Court;and it 1S further directed that twenty (20) days'written notice thereof be given to Delphia Moffitt,344 Townsend Road,Baltimore,Maryland,21221;Thomas E.Moffitt, 2706 Rocks Road,Forest Hill,Maryland,21050;Madaline Litzan, 5013 Greenhill Avenue,Baltimore,Maryland,21206;Fred Moffitt"'. , .c., 974 Martin Road,Baltimore,Maryland,21221;James W.Moffitt, Route 10,Box 524 A,Baltimore,Maryland,21219;Kenneth 'K. Moffitt,Route 1,Box 418,Frostburg,Maryland,21532;Mary Hoye, 344 Townsend Road,Baltimore,Maryland,21221;and Harold G." Moffitt,136 Nottingham Road,Hagerstown,Maryland,21740,by Certified Mail,Return Receipt Requested,to their respective '" IN THE COURT OF COMMON PLEAS OF WASHINGTON COUNTY,PA ORPHANS COURT DIVISION #60 of 1971 IN RE: ESTATE OF MANIE MOFFITT, an a11edged incompetent ANSWER OF: MADALINE LITZAU ! j "> l' lJ~it(/ /~ r-.J -~ r-.. c L~ L-. {- ,- -J CL -('""') ,~---:~~.';~-L? .,.,....L '.. J.MAYER WILLEN ATTORNEY AT LAW SUITE 709-10 AURORA FEDERAL BLDG. 301 N.CHARLES STREET BALTIMORE.MD.21201 .' IN RE: ESTATE OF MANIE MOFFITT, an alleged incompetent..• -, IN THE CDURT OF COMMON PLEAS OF WASHINGTON COUNTY,PA. ORPHANS COURT DIVISION ................'..No.60 of 1971 ANSWER OF MADALINE LITZAU TO THE HONORABLE,THE JUDGE OF SAID COuRT: The Answer of Madaline Litzau,erroneously called Madaline Litzan,to the Petition for Appointment of Guardian and the Order of Court thereon dated January 18,1971,respectfully shows:- 1.That she admits the matters and facts set forth in the first,second and f'dtth paragraphs of the said Petition. 2.That she is without personal knowledge of the matters and facts set forth in remaining paragraphs of said Petition,and therefore is unable to admit or deny the allegations thereof. 3.That answering_further the said Petition,shQ~bm.1ts her rights to the protection of this Honorable Court and for the passage of such decree herein as may be right and proper. And as in duty bound,etc.#~~ ~~~lhermark)MadalineLitza - Respondent I hereby certify that on this I bday of February,1971,a copy of the aforegoing Answer was mailed to Howard F.Carson,Esq., Charleroi,Pennsylvania,Solicitor for Petitioner./, '.~' jrnw/zs I~ LAW OFFICES-J.MAYER WILLEN SUITE 709·10 AURORA FEDERAL BUILDING 301 N.CHARLES STREET BALTIMORE.MARYLAND 21201 February 16,1971 Court of Common Pleas of Washington County) Orphans'Court Division Pennsylvania Attn:Russell Manino,Clerk Re:In Re:Estate of Manie Moffitt No.60 of 1971 Gentlemen: I am enclosing herewith Answer of ~~daline Litzau for fiming in the aboye case. Thanking you for your attention to the same,I am Yours very truly, cJ::J;!lw7fi1:J encl. cc:Howard F.Carson,Esq. TELEPHONE 752.5698 , " '-- , .. ,~----,-'--~ In the Court of Common Pleas of Washington County,Pennsylvania Orphans I Court Division No.600f1971 IN RE: ESTATE OF MA NIE MOFFITT, an alleged incompetent. DEC R E E . J(Marlno,J.)I -c.)I) :)./ "?\~" 1(r,"..'l"~'"~f l.:'J""'"\,,"'-.:;J ~ N '1 \,)~\".":~.;l ~C'.\"~,,~"~•~<~A.<>...~'-~e.-",_.<-..)4 ORPHANS'COURT DIVISION (COURT OF COMMON PLEAS) WASHINGTON,PA, /1.4'I 9 t -t ~2 '....':0 :u:u:w ","'""",,,~ .~. '.. IN THE COURT OF COMMON PLEAS OF WASHINGTON COUNTY,PENNA. ORPHANS I COURT DIVISION IN RE: ESTATE OF MANIE MOFFITT, an alleged incompetent. ) ) ) ) ) ) ) No.60 of 1971 A ND NOW"March DEC R E E f ,1971,upon consideratim of the annexed petition and after a hearing held following due notice,it is ORDERED AND DECREED tha t Manie Moffitt is adjudged an incompetent. Mellon National Bank and Trust Company is appointed Guardian of the Estate of MANIE MOFFITT,an incompetent. The said Guardian is directed to file an inventory in accordance with the provisions of Section 4,02 of the Incompetents'Estates Act of 1955, as amended. STATE OF PENNSYLVANIA,f SS: COUNTY OF WASHINGTON, Personally appeared before me the undersigned authority,Arlie W.Ott,T rust Office r , Mellon National Bank and Trust Company guardian of the estate of ~.~~~..MQ.~~~.~.:£.,~.~..~E:~.9..~P..~.!.~.;?;!.. ~,who being duly sworn,deposes and says that the following is a true and correct Inventory and State- ment of the personal and real property which are of the estate of the above named minor _~..t.d..~____.Sworn and subscribed before me this ) I 0 June -:#71........................day of ,19 , ...._...~~~....\Trust Officer I PRINCIPA~-PERSONALTY Dollars Cents 2-$1,000 USA Series H Bonds dated 5/1/66 2,000 00 5-$1 000 USA Series H Bonds dated 6/1/66 5.000 00 I 1-$1.000 USA Series H Bonds dated 7/1/66 1.000 00 I Mellon Bank.CharMroi Office -5%Savinl!s Certificate No. E 30917 dated 9/5/67 22,000 00 Checking-Account No.294=8874 at Mellon Bank.Charleroi I , Office registered Manie Moffitt 10,948 69 Cash at residence 1,231 00 Proceeds sale of household l!oods and trading stamps 902 63 Refund on cancellation of Utica Mutual Policy No.234728LP, Personal liability 6 50 Treasurer of USA check dated 12/1/70.6 mo.interest H Bonds 113 00 Treasurer of USA check dated 1/1/71.6 mo.intere st H Bonds 22 60 Garage rent thru February 1971 20 00 Monthly entitlement 'from S.S.cu~rently in amount of $40.20 I ..b- M~tropolitan Life Insurance Company Policy No.8688600, endowment at age 85,in face amount of $1,000 ...c- Prudential Insurance Co ••Hospital Expense Pol.No.HI-133-3~1 -c .. Deed to Lot No.72 Section A ••Tavlor Cemetery -c - One Lot of Ladies i ewelrv undete~mined PRINCIP ~L-REALTY House and lot situate in the Borough of Charleroi,Washington I County,Pennsylvania,known as 613 Crest Avenue,Charleroi, Pa.,recorded at Deed Book 583,page 585 undete rmined NOTE-If real estate,give street and number,Ward of City,Borough or Township,and 'County,and reference to Deed,Mortgage,Volume and Page. If cash in ibank,give name of same.$43,244 42 I I'No :QQ Qf 19..7.1.;,~.. J 1~;ReEstate I, " " ..,~ .J o,f ,, ~,' -," J: , 'J, ---I v" MANIE M0FFITT,, u '. an Incompetent............................................................................................................. 'J "':Minors. ,} I ;GU~R[)IAN'S ' },'o~U)-i -< , INVENl"ORY-~ND:- )---.I -,>.0';,STtATEMENT,--) ::'-.'c .'-.:5 ~ J' ..., J' }. , ,, ):i, , !-"- s-::, "-... ._.:f.~~.;;J; d)_L .J"0Cl:lr.1c.:: ,,;..-""-.......-~. 1J') -<!~ ,Fee $...!:i...a...4....p~4 ) Filed ·::..,I 19 I- Howard Carson ~·..·;-..·;..:;..·~·~..·>JI:..·~tt·..·~·..·.. .. IN THE COURT OF COMMON PLEAS OF WASHINGTON COUNTY,PENNA. ORPHANS'COURT DIVISION No.60 of 1971 IN RE: Estate of MANIE MOFFITT, an incompetent. PETITION FOR PRIVATE SALE OF REAL ESTATE UNDER SECTION 443 of the INCOMPETENT'S ESTATES ACT of 1955...._. '-.•~~r"J"0-.. '0 '!i.~~J~~~ ,-----~----;-~,-';...rrl -::!.~ _.~f'~ -,""--.~--.....) 0::.:; ..:-..-......-0;-'0l>(f) c:..... ~-=: n "--,-"-,.. I"'V . e:. •~Ylb~.unv ~~/M.d-(f'~~~ ~f%rl/n~lv~ 15022 I /-:;..J-j-//14 (I t£')L.,-1 7 1/ \ IN THE COURT OF COMMON PLEAS OF WASHINGTON COUNTY,PENNSYLVANIA. ORPHANS'COURT DIVISION IN RE: Estate of MANIE MOFFITT, AN INCOMPETENT. ) )No.60 of 1971 ) PETITION FOR PRIVATE SALE OF REAL ESTATE TO THE HONORABLE P.V.MARINO,PRESIDENT JUDGE OF SAID DIVISION: The Petition of MELLON NATIONAL BANK AND TRUST COMPANY respectfully represents: 1.That on the 8th day of March ,1971,at the above number and term,your petitioner was appointed guardian of the estate of MANIE MOFFITT,an incompetent. 2.That at the present time,the only assets of the said incompetent in the possession or control of your petitioner as said guardian as per Inventory filed is as follows: Personalty $43,244.42 Realty as per Agreement of Sale $14,500.00 3.That to date all the obligations and debts are kept on a current basis. 4.That as your petitioner is reliably informed and as appears in the record of the hearing for,the appointment of guardian,the prognosis for the recovery of the said incompetent is very poor,and she will,in all likelihood,require special nursing care for the remainder of he life. 5.That the dwelling house on the real estate hereinafter referred to will need normal maintenance and repairs and will be " a burden on the estate of said incompetent,and its sale would be for the best interests of said incompetent. 6.That as appears by Article of Agreement attached hereto, made a part hereof,and marked Exhibit A,your petitioner has agreed to sell said real estate,subject to the approval"of your Honorable Court,to Collins-Hall Agency,Inc.,CharlerQi,Pa.,as principal or agent,for the sum of $14,500.00. market value of said real estate,and that this is more than coul appraisers and brokers,that the sum of $14,500.00 is the fair marked Exhibits Band C,Affidavits of That there is attached hereto,made a part hereof,and Itwoindependentrealestate I i 1 I I 7. be obtained at public sale. WHEREFORE,your petitioner prays your Honorable Court,under the authority of Section 443 of the Incompetent's Estates Act of 1955,to approve the sale as aforesaid. 'MELLON NATIONAL BANK AND ,TRUST COMPAN COMMONWEALTH OF PENNSYLVANIA) SS: COUNTY OF WASHINGTON ) Before me,the underlign~a~thority,personally appeared ~',Z~~~~2?zci~,'TIust .QUiee-r of Mellon National Bank and Trust Company,who,being duly sworn according to law,deposes -and says that the statements contained in the foregoing Petition are true and correct to the best of his information,knowledge and belief. Sworn to and subscribed before me this /.-.n:<4:day of June,1971. "'. -2- Notary Public DOLORES P.MEREDITH,NotIIY publi.a WUhington,Washington ~ounty.Plt~ My Commission ExpiI. January 28,1915 FORM NO.17 (1966) REAL PROPERTY AGREEMENT (SHORT FORM) W~t5 1\gftrwrul WASHINGTON COUNTY BAR ASSOCIATION WASHINGTON,PA. 14thMadethe day of June 19 71, (hereinafter called "Seller")and Between MELLON NATIONAL BANK AND TRUST COMPANY,Guardian of the Estate of Manie Moffitt,an incompetent, COLLINS -HALL AGENCY,INC.,(hereinafter called "Buyer"), as principal or as agent, WITNESSETH,that for the consideration her~inafter set forth and intending to be legally bound the Seller and Buyer mutually agree as follows: 1.Seller agrees to sell and convey to buyer cM){)}(~M~upon approval of the Court by spec ia1 warranty deed in fee simple absolute,clear of all mortgages,judgment liens and tax liens and other encumberances affecting its marketability (except as hereinafter set forth)all the real property described in Paragraph 7 hereof. 2.Buyer agrees to purchase said real property and to pay Seller therefor the sum of Fourteen Thousand Five Hundred ($14,500.00 )Dollars as follows:Three Hundred ($300.00)Dollars at the signing of this Agreement and the balance of Fourteen Thousand Two Hundred ($14,200.00)Dollars upon delivery of Deed. 3.Possession shall be given~K at de 1i very of deed XWX ,and settlement shall be made at the office of Seller's attorney on that date.l:2xxxxxmxas)(~ 4.At settlement Seller shall pay for or be charged with the cost of all~documentary taxes and state and local realty transfer taxes payable upon this transaction,but real estate taxes for year of settlement,sewer charges and rents and royalties shall be prorated on a calendar year basis between Seller and Buyer as of date of delivery of possession of the premises;except as hereinafter set forth:Buyer shall pay one-half of the documentary taxes. 5.From and after the date of this agreement,insurance shall be provided and paid for as follows:by the Seller up to the date of possession. 6.Time is of the essence of this Agreement. 7.The real property which is the subject of this Agreement is described as follows: ALL that certain piece or parcel of ground situate in the Borough of CHARLEROI,Washington County,Pennsylvania,described as follows:,. BEING LOT NO.263 in Section 1'A"fronting on the western side of Crest Avenue,a distance of 40 feet between Sixth Street and Seventh Street and running back with uniform width a distance of 120 feet to a 20 foot alley.ALSO the right and privilege of using the sidewalk space between Lot No.261 adjacent to said Lot No.263 for the purpose of ingress,egr~ss and regress to and from said Lot No.263 above described,but said right- of-way shall be held for the corresponding use thereof by the present and future owners or tenants 'of said Lot No.261. BEING the same premises conveyed to Manie Moffitt by deed of Mary E. Mo:(fi tt,widow,dated March 25"1932,and recorded In 'tne Recorder's Office in and for Washington County,Pennsylvania,in Deed Book,Vol. "'.583 Page 585. ,., ...J'" .',> EXHIBIT A • 8.If Buyer defaults in payment or performance for 30 days,Seller may,at Seller's election use Qi1i en WOte Q"the following reme~in addition to or instead of any other remedies provided by law: (a)rescind this agreement :md retain all sums paid on aCCOll11t hereof as liquidated damages,in which case Seller shall retain title to the real estate free and clear of uny obligation or duty to Buyer and Buyer shall surrender this Agreement for cancellation; hereby waivi ,for which purpose Buye hereb authorizes any attorney icable action of ejectment, for damages,to include att e commission of % .n,exemption and inq sition,'"1 release of all errors; 9.The Buyer agrees not to record this Agreement and recording by the Ruyer shall constitute a breach thereof. 10.This Agreement shall extend to and benefit and bind the heirs,executors,administrators,successors and assigns of the parties.Whenever used herein,the singular number shall include the plural, the plural the singular and the use of any gender shall include all g·enders. NOTICE -THIS DOCUMENT MAY NOT SELL,CONVEY,TRANSFEn,INCLUDE on INSURE THE TITLE TO THE COAL AND RIGHT OF SUPPORT UNDERNEATH THE SURFACE LAND DESCRIBE.D OR HEFERRED TO HEREIN,AND THE OWNER OR OWNERS OF SUCH COAL 1VIAY HAVE THE.COMPLETE LEGAL HIGHT TO REMOVE ALL OF SUCH COAL AND,IN THAT CONNECTION,DAMAGE MAY RESULT TO THE SUHFACE OF THE LAND AND ANY HOUSE,BUILD- ING OR OTHER STRUCTUHE ON OR IN SUCH LAND.THE INCLUSION OF TIllS NOTICE DOES NOT ENLARGE,RE- STRICT OR MODIFY ANY LEGAL HIGHTS on ESTATES OTHERWISE CREATED,TRANSFERRED,EXCEPTED OR RESERVED BY THIS INSTRUMENT.(This notice is set forth pursuant to Act No.255,approved September 10,1965.) WITNESS the due execution hereof the day and year fIrst above written. MELLON NATIONAL BANK AND CKM'MV\TRUS"T 6M"I'ANY,iii';.. (~H~~'F;:~~.f!,EAL) ~t GfE C i hi I~r t//(!<2.5'f Jet .AJr ....................................................................................................(SEAL) ~IN~-HALL AGENCY,INC •..;(SEAL) ..:Ct.&...AL) ....................................................................................................(SEAL) WITNESSED BY:;t.,~~ ••••••••••••~~'~•••••••••••••••••••••••••••••••••••••m ••••••••••••••••••••••• ..~G'1 ~.t6:::~r.L?.. I., J.\;: Ci . I~4 ~ I=:U )1'. <C n:l oJ.Z ," ~'M 'n +.l H ~~'0 Q I=:!i Z ~H n:l1 OJ ~I;. n:l ~+.l >-<"en ;:l OJ u R·~C)'H 0.1]'"...)q s~<C n 0 ()..B>-<G.!u ,-<<C ,CxJ z ~I=:':;:; H <C n:l1 'M ::-...)8f-;0..~..-...)u.~<C ~Vi I=:;§/,:- CG z 0 ~n:l ~I:; U J r ',~ 0 Z ai n (f)~j~ §f-;..G +.l Z ;!:-<(f)1 +.l H tt;: ::J OM ...)~r,~;' W 0:;,'+-1 ...)~t'"H ~f-;'+-1 0 :t~( U f":l~t~·~~4'" !:~r Personally appeared before me,the undersigned authority, f'.. AFFIDAVIT COMMONWEALTH OF PENNSYLVANIA ) SS: COUNTY OF WASHINGTON I DEAN MORI,who being duly sworn according to law,deposes and I says that he is a Real Estate Broker,doing business in Rostravlr, Township,Westmoreland County,Pennsylvania;that he is well acquainted with the real estate situate at and -known as 613 Crest Avenue,Charleroi,Pennsylvania,which is more fully des- cribed in the copy of Agreement attached hereto;said property being sold to Collins-Hall Agency,Inc.,as principal or agent; that he is well acquainted with the market value of real estate ln the immediate vicinity of the aforesaid real estate;that he is not personally interested ln the proposed sale;and that the fair market value thereof is $14,500.00,and more than coul; be secured at public sale,and further deponent sayeth not. oear;Mori Sworn to and subscribed before me this 14th day of June,1971. (!(dA~~tZ/t<-'L~ Notary Public CLARA ALLISON NOTARY PU8L1C .MY Commission Expires Feb.23.1975 Cbarleroi,Pa;-Washington CountY', Exhibit B AFFIDAVIT COMMONWEALTH OF PENNSYLVANIA) SS: COUNTY OF WASHINGTON ) Personally appeared before me,the undersigned authority, Martin Wehousie,who being duly sworn according to law,deposes and f says that he is a licensed Real Estate Broker,doing business in Charleroi,washington County,Pennsylvania;that he is well ac- quainted with the real estate situate at and known as 613 Crest Avenue,Charleroi,Pennsylvania,which is more fully des- cribed in the copy of Agreement attached hereto;said property being sold to Collins-Hall Agency,Inc.,as principal or agent; that he is well acquainted with the market value of real estate in the immediate vicinity of the aforesaid real estate;that he is not personally interested in the proposed sale;and that the proposed consideration of $14,500.00 is more than could be secur- ed at a public sale,and further deponent sayeth not. Martin Wehousie Sworn to and subscribed before me this 14th day of June,1971. Exhibit C HFC/ma 1 -4.J 6/14/71 IN THE COURT OF COMMON PLEAS OF WASHINGTON COUNTY,PENNSYLVANIA. ORPHANS'COURT DIVISION IN RE:) ESTATE OF MANIE MOFFITT,)No.60 of 1971 an incompetent.) PRELIMINARY ORDER Court hereby fixes the on the within Petition;at said -~:!:::S~=::::I5:£:-'1971,at ftG.,.~0 'c 1ock ,.t!l......M., AND NOW,June ~/£aay of as the time return date,the Court will entertain higher bids;and adver- tisement to be made in accordance with the Court Rules. IN RE:ESTATE OF MANIE MOFFITT, an alleged incompe~nt J ~ -·....1 .'J, )," ~;:I ...} (r)Y':'", ~ DEC R E E CONFIRMING PRIVATE SALE OF REAL ESTATE IN THE COURT OF COMMON PLEAS OF WASHINGTON COUNTY,PENNA. ORPHANS'COURT DIVISION NO.60 of 1971 ~a_ N -::..J I. I .' I"""_~~--_~_.- ~'.~J "I," 0_ r--~._~ -0 r-~---,».c.. -.., -"'":;.1: 0: ~!T~~ S'Id~~£~~~ -t'~~ 15022 V I ~J-/.-I g-5'-'\/\ J~""I .. HFC/llr h.3cc 7/2/71 IN THE COURT OF COMMON PLEAS OF WASHING~N COUNTY,PENNSYLVANIA ORPHANS'COURT DIVISION IN RE: ESTATE OF MANIE MOFFITT, an incompetent. ) ) ) ) ) No.60 of 1971 AND NOW,this DEC R E E ~I~~ay of July,1971,upon consider- .,ation of the Petition for Private Sale of Real Estate,filed June 15,1971,the Court finding the proposed sale is for the testj I interests of the incompetent,under the provisions of Section 443 of the Incompetents'Estates Act of 1955;that all parties in interest have received notice of the presentation of the annexed Petition;and that the sale price of $14,500.00 is better than can be obtained at public sale;Mellon National Bank and Trust Company,Guardian of the Estate of Manie Moffitt,an incompetent, upon receipt of the balance of the purchase price,to wit, $14,200.00,as provided in the Agreement of Sale,annexed to the Petition,is authorized and directed to convey the premises identified as Lot 263 in Section "All in the Borough of Charleroi, Washington County,Pennsylvania,including the improvements ttereto and thereon to Collins-Hall Agency,Inc.,as principal or as agent,or to the principal of such Agency.The said Guardian 1S hereby authorized and directed to pay the cost of one-half (1/2) of the documentary taxes,to wit,$145.00..The premises are more: fully bounded and described as follows: ALL that certain piece or parcel of ground situate in the Borough of CHARLEROI,Washington County,Pennsylvania, described as follows: BEING LOT NO.263 in Section "A"fronting on the western side of Crest Avenue,a distance of 40 feet between Sixth Street and Seventh Street and running back with uniform"". i 'i '.' width a distance of 120 feet to a 20 foot alley.ALSO the right and privilege of using the sidewalk space between Lot No.261 adjacent to said Lot No.263 for the purpose of ingress,egress and regress to and from said Lot No.263 above described,but said right-of-way shall be held for the corresponding use thereof by the present and future owners or tenants of said Lot No.261. 1r BEING the same premises conveyed to Manie Moffitt by deed of Mary E.Moffitt,widow,dated March25,1932,and recorded in the Recorder's Office in and for Washington County, Pennsylvania,in Deed Book Vol.583,Page 585. ,0' IN THE COURT OF COMMON PLEAS OF WASHINGTON COUNTY,PENNA. ORPHANS'COURT DIVISIONNo.60 of 1971 IN RE:ESTATE OF MANIE MOFFITT, an alleged incompetent ~ AFFIDAVIT OF SERVICE and AFFIDAVIT OF MAILING \I II u---...J-.;::::.1 ->-Pl ;::D ..~ I .II en ,,-,,--r')-"---r-, :::::(fJ ~~.:.--;r- -;:---.rJ ,~~,-'-.<---"I:J'J .-<>..:~CJ :.E ~:r=.;VJ:::or-a......(f)-U'1 ~Yl!~r:wn/ ~Affub-~-n4e//or~~ -G'~~~ 15022 <-- '. IN THE COURT OF COMMON PLEAS OF WASHINGTON COUNTY,PENNSYLVANIA. ORPHANS'COURT DIVISION IN RE:ESTATE OF MANIE MOFFITT,)No.60 of 1971 an alleged incompetant.) AFFIDAVIT OF SERVICE COMMONWEALTH OF PENNSYLVANIA ) SS: COUNTY OF WASHINGTON Before me,the undersigned authority,personally appear- ed JOHN J.STASKO,Constable in and for the Borough of Coal Center, Washington County,Pennsylvania,who being duly sworn according to· I I law,deposes and says that he served the Petition,Order and\ Decree,and Citation in the above captioned matter,upon Manie Moffitt,at the Charleroi-Monessen Hospital,North Charleroi, Pennsylvania,by handing the same to the said Manie Moffitt in the presence of Charles Sungala,Administrative Assistant of said Hospital,on February 3,1971,at 10:20 a.m.;that Manie Moffitt identified herself to the affiant and accepted such Petition; that Charles Sungala receipted for said Petition in writing;and that such receipt is Sworn to and subscribed before me this ~~day of February,1971:..,~__.~~ ~~ r ~~.~ ..' ---.,..-------------------,-------.-,~.----- -. ..~-_._-..-..---_.....,.--.-"" ,",. :I~.~h'·1 ----,._--+----~~--_........---..._.._.--'-------.......... Constable CHARLEROI-,MONESSEN HOSPITAL NORTH CHARLEROI,PENNSYLVANIA February 3,1971 TO WHOM IT MAY CONCERN: A Petition For Appointment of Guardian was delivered to MANIE MOFFITT on the ~bove written date a t the above address at /6:do}JM;0'clock a.m. Charles Sungala, Administrative Assistant l ----'-----------.....:...------:---II II EXHIBIT "A" IN THE COURT OF COMMON PLEAS OF WASHINGTON COUNTY,PENNSYLVANIA. ORPHANS'COURT DIVISION IN RE:ESTATE OF MANIE MOFFITT, ( (No.60 of 1971 an alleged incompetant.( AFFIDAVIT OF MAILING COMMONWEALTH OF PENNSYLVANIA ) COUNTY OF WASHINGTON ) SS: Before me,the undersigned authority in and for said County and State,personally appeared HOWARD F.CARSON,ESQUIRE,who being duly sworn according to law,deposes and says that he did cause copies of the Petition,Order and Decree,and Citation, in the above captioned case to bemailedtoDelphiaMoffitt.by Certified Mail No.608419,at 344 Townsend Road,Baltimore, Maryland,21221;Thomas E.Moffitt,by Certified Mail No. 608418,at 2706 Rocks Road,Forest Hill,Maryland,21050; Madaline Litzan,by Certified Mail No.608420,at 5013 Greenhill Avenue,Baltimore,Maryland,21206;Fred Moffitt,by Certified Mail No.608421,at 974 Martin Road,Baltimore,Maryland,21221; James W.Moffitt,by Certified Mail No.532520,at Route 10, Box 524 A,Baltimore,Maryland,21219;Kenneth K.Moffitt, by Certified Mail No.608417,at Route 1,Box 418,Frostburg, Maryland,21532;Mary Hoye,by Certified Mail No.608416, at 344 Townsend Road,Baltimore,Maryland,21221;Harold G. Moffitt,by Certified Mail No.608415,at 136 Nottingham Road, Hagerstown,Maryland,21740.Each envelope was sent '~efurn_ Receipt Requested".Service was accepted by each of said in- dividuals as will appear by the Return Receipts attached hereto. Howard F.Carson Sworn to and subscribed before me this CATHY JEAN ROSENTHAl.!NOTARY PUBllQ CHARLEROI BORO WASHINGTON COUNTY, MY COMMISSION EXPIRES MARCH 12,1n~ Member Pennsylvania Assn.of Nolariell PLEASE r''qNISH SERVICE(S)INDICATED BY CHECKED BLOCK(S). REQUIRED FEE(S)PAID. r _dOW to whom,date and address D Deliver ONLY where delivered to addressee RECEIPT Received the numbered article described below. RtGISTERED NO. CeRTIFIED NO.£ot~/r INSURED NO. DATE DELIVERED /-'/..7/ SIGNATURE OR NAME OF OORESSEE (Must a/ways be jitted in).r.,.,, I /11 I '(/ '>!,-.//(,. ADDRESSEE'S AGENT.IF ANY PLEAS...."'URNISH SERVICE(S)INDICATED BY CHECKED BLOCK(S). REQUIRED FEE(S)PAID. Show to whom,date and address D Deliver ONLY..J where delivered to addressee RECEIPT Received the numbered article described below. REGISTERED NO. CERTIfiED NO.~/c? 6:>d?--ilo INSURED NO. DATE DELIVERED /-d~-// SIGNATURE OR NAME OF ADDRESSEE (Must a/ways be fitted in) ~JI~~6: SIGNATURE OF ADDRESSEE'S AGENT.IF ANY 1':' ---------- c5i-16-115Q-ll 3H-19i GPO c6i-16-1l5Q-ll 3H-19i GPO, DATE DELIVERED INSUREO NO. PLEASE FURNISH SERVICE(S)INDICATED BY CHECKED BLOCK(S). REQUIRED FEE(S)PAID. JW to whom,date and address 0 Deliver ONLY where delivered to addressee CERTIFIED NO..-c'/60 cf''T 'L~ REGISTERED NO. ------------ PLEASE FURNISH SERVICE(S)INDICATED BY CHECKED BLOCK(S). REQUIRED FEE(S)PAID. r "how to whom,date and address D Deliver ONLY _J where delivered to addressee RECEIPT Received the numbered article described below. REGISTERED NO.SIGNATURE OR NAMEOF ADDRESSEE (Must a/ways be fitted in) INSURED NO. DATE DELIVERED c5i-16-1l00-1l 341-lVi GPO ----------- O Deliver ONLY to addressee PLEASE FURNISH SERVICE(S)INDICATED BY CHECKED BLOCK(S). REQUIRED FEE(S)PAID. r Show to whom,date and address~-.J where deiivered RECEIPT Received the numbered article described below. REGISTERED NO.SIGNATURE OR NAME OF ADDRESSEE (MUSf always !e filted in) CE:SS3~'5 ~O INSURED NO. DATE DELIVERED c55-16-71M8-11 347-198 GPO r--------.---~~~o:_:_~~~__.....__~-__--._, PLl::ASE ;-URNISH SERVICE(S)INDICATED BY CHECKED BLOCK(S). REQUIRED FEE(S)PAID• ...how to whom,date and address 0 Deliver ONLY where delivered to addressee RECEIPT Received the numbered article described below. REGiSTERED NO. INSURED NO. DATE DELIVERED JAN i'j 1 ,197 SIGV:E OR NAME OF ADDRESSEE (MUSf alw?:.!:e filted in) CD c55-16-71MS-ll 347-198 GPO ,~,-~-------------------- ,-- PLEASE FURNISH SERVICE(S)INDICATED BY CHECKED BLOCK(S). REQUIRED FEE(S)PAID. Show to whom,date and address 0 Deliver ONLYJwheredeliveredtoaddressee REGISTERED NO. CERTIFIED NO./~-I' 60 iT/fa INSURED NO. DATE DELIVERED c65-16-715!8-11 347-198 GPO PLEASE FURNISH SERVICE(S)INDICATED BY CHECKED BLOCK(S). REQUIRED FEE(S)PAID• .~}.~how to whom,date and address 0 Deliver ONLY_ J where delivered to addressee RECEIPT Received the numbered article described below. c55-16-Tl648-1l 347-198 GPO SIGNATURE OR NAME OF ADDRESSEE (Musf always be filted in) /1~.'".--;::;/--- .EGISTEREO NO. CERTI FI ED NO.of~/~ I~"j"{.---_---::_~--~------ J IN THE COURT OF GOMMON PLEAS OF WASHINGTON COUNTY,PENNSYLVANIA ORPHANS'COURT DIVISION IN RE:) ) ESTATE OF )No.60 of 1971-MANIE MOFFIT,~ ) an incompetent.) fortthe holding of a hearing on the Petition for Private i~re:the estate of Manie Moffit,this is the time set in the estate of Manie Moffitt,an incompetent,Number THE HONORABLE P.VINCENT MARINO,Judge of the said Court. Monday,July 12,1971,at 11:00 o'clock A.M.,EDST. Mr.Carson,we are ready for the proceecing HOWARD F.CARSON,ESQ.,of Charleroi,Pi::., represe~ting the Petitio~er•. Yes,Your Honor.May it please the Caur , 60 of '1971. ~z<>.I>-III Z ZIIIII. i~BEFORE:Clz :J:III<~ ..:APPEARANCE S:uitI-III D .I <TIME:u D:J.., J:j:; N THE COURT:vi0: IIII-0:oII.III0: I-0::J8 MR.CARSON: .J<Uii:I&.o ] " Sale of Real Estate which was pre sente d to the COlITt on June 15,and this is the time set for the return date.First of all,I have the Affidavit of Mailing executed by myself, whereby copies of the Petition and Notice and soforth were--- I beg your pardon,it wasn't copies of the Petition,but Notice of the proceeding today W'qS mailed to each of the t eirs 2 ~ho initially we liswd in the Petition for Appointment 0 a Guardian for Mrs.Moffit and they were all sent by cert fied on June 17,June 24 and July 1st.At this tj.me I wculd pr sent ve your examination as proof of the The Affidavit of Mailing and the Proofs service. these to the Court for \.lProofofPublicationintheWashingtonCountyReportson mail,return receipt requested,and I have attached to th Affidavit of Mailing the usual return receipt cards.We ve one omission 'in this respect.The envelope to Mary Hoye was returned marked Deceased.Now I had information of th t fact,but here is a verification of it from the Post Department.And under those circumstances,I believe complied with the notices of mailing requirement. Also,under the same cover I have the .June 17,24,and July 1st;and in the Valley Independent ~z0(>..J>UIZ Z 1&1n. zg l.!lZiUI 0( ~ ~ii:l-UI C ..J0( § C :l.., :J:5 THE COURT: ../ ui~of Publication are ordered filed;they having complied wi h II:o~the Interlocutory Order of this Court made on June 15,19 1. l-~MR.CARSON:It would be appropria te at this time,Y ur o ~Honor,I believe,for the Cmlrt crier or yourself,as the ii:~case may be,to inquire if anyone in Court is intereste d in submitting a further bid on thi~property.I happen to know personally the four people on the bench over there.And they are interestrl in "the purchase but not at a higher pr ce. Collins Hall Agency was acting on their behalf. TI-IE COUR T:The Court will inquire at this time whe her there is anyone in Court presently who wishe s to be heard :,1' .. , \, , I 3 ::Ln me estate of this incompetent,'and more particularly, whether there ~s anyone in Court at this time who desires to offer more than the agreed price for the sa Ie of the real estate described in this Petition.The price being $14,50 . Is there anyone in Court who desires to offer more sum of $14,500 for the property described in this Petitio? ~MR.CARSON:,Might I add,Your Honor,that,of course is 0(>.I~the sum that is net to the estate.zz~THE COURT:Oh,yes.Is there anyone who desires to so z,~~bid?z i~(NO RESPONSE )~ entertain a Decree drawn by counsel. that the proceeding is proper in all respects and we will .,:THE COURT:,UitI-UI C .I0:( U o::l.., J:..""I There being no response,the Court feel (Proceedings Closed), and that this copy is a correct transcript of the same. I hereby certify that the proceedings and evidence are contained full •..;' iii.a::~ll:oII.~and accurately in the notes taken by Ire on the hearing of the above cause, l-ll: :JoU .I0<Uii:11.,o The foregoing record of the proceedings upon the hearing of the above cause is hereby approved and directe .....t· '. ... '. .. it... '..' ", '. (. ,., ",.... l ..t",.... " ...'.-..~-J--)--t ;1 -,r/), if·C)(."1, t If.:-:.i:..~",'."~".;;1 ,.),.,_.... .::;:.0 .."1:.:c -n ....,..- :-"") 0 ".t.N t.I -.-: --0 r (.:>-J:-"'"(.1)V"1 " •" f",t_.:\:"'1'..1 ".....("'."t.l ",:C.j \.- .llJ •h.'.......t.:. " ",....,'1 '1".,.,., /- j -J J.j.0..-!:-> ~~j JI;T~~; ). "1 i......J '.'.11..S It .~,j ."f]~,''jl£J t j __or;l.{t ..II r v tt ..."1.-1...j ,'J.!~-'I I ,CT-.'<"-- J i 1.'.:0 \,~j .ll 'J .·lf~>lJ : I ...'v H.q.J C~"~ej j In )'./t},. .1 .',J v IN THE COURT OF COMMON PLEAS OF WASHINGTON COUNTY,PENNA. ORPHANS I COURT DIVISION NO.60 of 1971 £ IN RE: ESTATE OF MANIE MOFFITT, an incompetent. , PETITION FOR ALLOWANCE AND CONFIRMATION OF PRIOR DISTR- IBUTIONS. ~,-' r ..... ~) -, :J r-.> Coo, '_V _.J _... C>=-_ ;'::::-o'C>J;>-(fl 'u"7~"~d/ur~~ ~/~r/,'~/rlff~ 15022~J-1.~J tj 3(/ZL .. <-- Hfc/ma 1 -.3 p. " 8/27/71 IN THE COURT OF COMMON PLEAS OF WASHINGTON COUNTY,PENNSYLVANIA. ORPHANS'COURT DIVISION IN RE: ESTATE OF MANIE MOFFITT, an incompetent. ) )No.60 of 1971 ) PETITION FOR ALLOWANCE AND CONFIRMATION OF PRIOR DIS- TRIBUTIONS. TO THE HONORABLE P.V.MARINO,PRESIDENT JUDGE OF SAID DIVISION: The petition of Mellon National Bank and Trust Company, I Guardian of the Estate of Manie Moffitt,an incompetent,respect- fully states: 1.The Mellon National Bank and Trust Company was app- ointed Guardian of the Estate of Manie Moffitt,an incompetent, by Decree of this Court,dated March 8,1971. 2.A Guardian's Inventory and Statement was filed on the lath day of June,1971,showing U.S.savings Bonds,a 5%Savings Certificate of the Mellon Bank,a checking account at the Charleroi Office of the Mellon Bank,cash found at the incompetent's residence,miscellaneous smaller items,and a house and lot situate at 613 Crest Avenue,Charleroi,Pennsylvania. The total of the items was $43,244.42,without a value being placed on "one lot of ladies jewelry"and on the real estate. The real estate was later sold for $14 1 500 i 00 6 3.The incompetent is presently a patient at Haven Crest Convalescent Home,situate in Car~oll Township,Washington County,Pennsylvania. 4.The incompetent has no dependents. 5.The following creditors of the incompetent have the claims indicated below:- a.Haven Crest,Inc.,balance due $2327.60 which includes room,board and miscellaneous incidentals,and medical expenses through Sept- ember,1971.As of the date of your petitioner's appointment,the balance due was $944.05,and as shown in Paragraph 6 below,$2000.00 has been paid on account. b.Charleroi-Monessen Hospital -Care 640 •.36 6.Your petitioner has paid the following indicated claims and administrative expenses: ~i'-U""" ! I I II 1I Columbia Gas:Service to 3/11/71 Service to 4/12/71 Service to 5/11/71 West Penn Power Co: Service to 2/24/71 Service to 3/25/71 Service to 4/26/71 Bell Telephone Co.: Billing 2/16/71 Final service Authority of Borough of Charleroi, Service to 3/10/71' $47.83 32.35 21.90 1.40 4.48 .88 3.35 .85 $102.08 6.76 4.20 20.50 I John M.Young,M.D.Professional Services per statement of 2/19/71 30.00 W.L.Cunningham,M.D.Balance of charges owing per assigned Medicare claim processed 2/19/71 62.88 Carlo Sirri,M.D.Examination of Manie Moffitt and Court testimony 100.00 .2. C.S.Bateman Agency Register of Wills Haven Crest,Inc. Malcolm L.Morgan, Co.Treas Collins-Hall Evelyn Kinnaird Appraisal of Residence Charges on Decree $2.50 Three certified copies of Order of Court 4.50 Payments on account 1971 County taxes IncreaS?fire coverage at residence Caretaking of residence, May and April $25.00 7.00 2000.001 I !I54.55 . 25.00 40.00 Howard F.Carson, Esq. West Penn Power Co. Columbia Gas West Penn Power Co. Auth.of Borough of Charleroi Auth.of Borough of. Charleroi Larry Yowan Legal fees Reimbursement- Costs advanced Service to 5/25/71 Service to 6/10/71 Service to 6/24/71 Service to 5/19/71 Sewag~ Grass cutting $300.00 41.04 341.04 3.71 8.53 .11 5.50 1 15.00 12.00 W.Ross Allen,Tax Collector West Penn Power Co. Howard F.Carson, Esq. Valley Independent Auth.of Borough of Charleroi Borough taxes-197l -$59~6l School taxes-197l 187.99 Final bill Attorney fees -250.00 Costs advanced 70.74 Advertising Final bill Total 247.60 .73 320.74 35.25 9.12 $3477.30 7.All of the disbursements listed in paragraph 6 immed- iately above as having been paid,were made conditioned upon the subsequent approval of this Court,for in the discretion of your 3. petitioner and its counsel,they were proper,necessary and reasonable. 8.After investigating the physical and mental condition of the incompetent,who is 82 years of age,your petitioner be- lieves that her condition will not improve,and that it will be necessary for her to remain a patient at the Haven Crest Conval- escent Home for the balance of her life,therefore,your pet- itioner requests authorization to continue making payments to Haven Crest,Inc.for care and maintenance,including needed medications,and to pay the incompetent's physicians for such care as they may find to be necessary. WHEREFORE,your petitioner prays this Court for confirmation and approval of the prior disbursements which were made and list- ed in paragraph 6 above,for the payment of reasonable counsel fees for the preparation and presentation of this petition,for the payment or reimbursement of the costs of thE petition,and for authorization to continue making payments to Haven Crest,Inc. at its regular scheduled rates and to the incompetent's physician, all as authorizeq by the provisions ~nder Section 644 of the In- competent's Estates Act of 1955,as amended. ::~~L:Jar;TRUST CUMPANY AieW:Ott,Trust Officer 4. " COMMONWEALTH OF PENNSYLVANIA ) SS: COUNTY OF WASHINGTON ) Before me,the undersigned authority,personally appeared Arlie W.Ott,Trust Officer of Mellon National Bank and Trust Company,who,being duly sworn according to law,deposes and says that the statements contained in the foregoing Petition are true and correct to the best of his information,knowledge, and belief. Sworn to and subscribed before mE~'rt~:(sZ3aday of September,1971. 5. IN THE COURT OF COMMON PLEAS .OF WASHINGTON COUNTY,PENNSYLVANIA ORPHANS'COURT DIV IS ION IN RE:Estate of MANIE MOFFITT, ) )No.60 of 1971 an incompetent.) ORDER AND DECREE ~ AND NOW,this ;I~--aay of September,1971,upon consider-• ation of the within Petition,it is ORDERED AND DECREED that the prior disbursements made by the petitioner and listed in Para- graph 6 of the Petition are approved;the petitioner shall pay a reasonable counsel fee for the preparation and presentation of the within Petition,together with the record costs o'r'said within Petition;and the Mellon National Bank and Trust Company, Guardian,is authorized to continue making payments to Haven Crest,Inc.,and to the incompetent's physicians,so long as those charges are in accordance with the regular scheduled rates and charges of said Haven Crest,Inc.,and of said physicians. <-- { \ .. \ IN THE COURT OF COMMON PLEAS OF WASHINGTON COUNTY,PENNA. ORPHANS'COURT DIVISION No.60 of 1971 IN RE:ESTATE OF MANIE MOFFITT, an alleged incompetent. AFFIDAVIT OF MAILING AND PROOF OF PUBLICATION ~r~~ dtwrn.-:r~~~~~ ~krw;~ 15022 Hfc/ma 1 - 1 c 6/18/71 IN THE COURT OF COMMON PLEAS OF WASHINGTON COUNTY,PENNSYLVANIA. ORPHANS'COURT DIVISION IN RE:ESTATE OF MANIE MOFFITT, x X No.60 of 1971 an incompetent.X AFFIDAVIT OF MAILING COMMONWEALTH OF PENNSYLVANIA ) SS: COUNTY OF WASHINGTON ) Before me,the undersigned authority in and for said County and State,personally appeared HOWARD F.CARSON,ESQUIRE, who being duly sworn according to law,deposes and says that he did cause a copy of the attached Notice for Private Sale of Real June 15,1971,to Estate,in the above captioned case to be mailed on/Delphia Moffitt,by Certified Mail No.813662,at 344 Townsend Road, Baltimore,Maryland,21221;Thomas E.Moffitt,by Certified Mail No.813660,at 2706 Rocks Road,Forest Hill,Maryland,21050; Madaline Litzau,by Certified Mail No.813661,at 5013 Greenhill Avenue,Baltimore,Maryland,21206;Fred Moffitt,by Certified Mail No.813664,at 974 Martin Road,Baltimore,Maryland,21221; James W.Moffitt,by Certified Mail No.813660,at Route 10,Box 524 A,Baltimore,Maryland,21219;Kenneth K.Moffitt,by Cert- ified Mail No.813667,at Route 1,Box 418,Frostburg,Maryland, 21532;Mary Hoye,~by Certified Mail No.813668,at 344 Townsend Road,Baltimore,Maryland,21221;Harold G.Moffitt,by Certified Mail No.813666,at 136 Nottingham Road,Hagerstown,Maryland, 21740.Each envelope was sent "Return Receipt Requested". Service was accepted by each of said individuals as will appear by the Return Receipts attached hereto. i .Howard F.Carson = Sworn to and subscribed • before me this ~day of .::Iuly ,1971. .'91 WashmgtOHJl Co1lJlHJlfty }Reports ..,.", Washington,Pennsylvania NOTICEINTHECOMMONPLEAS COURT OFWASHINGTONCOUNTY,PENN-SYLVANIA.ORPHANS'COURT DIVISIONNo.60 of 1971. IN RE:ESTATE OF MANIEMOFFITT,an incompetent MELLON NATIONAL BANK ANDTRUSTCOMPANY,Guardian of theEstateofMANIEMOFFITT,an in-competent,has filed a petition at theabovenumberaskingforpermissionoftheOrphans'Court to sell certain realestatedescribedinsaidpetitionandbelongingto'its ward,to wit,a dwell-ing and a lot of ground known as 613CrestAvenue,Charleroi,Pennsylvania,15022 (more particularly bounded anddescribedinD.B.VoL 583.page 585)at private sale to Collins-Hall Agency,Inc.,Charleroi,Pa.,as principal oragent,for the sum of $14,500.00,as setforthinsaidpetition.Monday.July 12.1971.at 11:00o'clock,A.M.,has been fixed as thetimeforahearingonthispetitionintheOrpl1'lns'Court Room,Court House,Washington.Pennsylvania,at whichtimetheCourtwillentertainhigherbidsforsaidproperty,subject to therulesofCourt,as to the acceptance ofhighert>ids.If there are no higherbidstheCourtwiliberequestedtoconfirmsaidsaIeabsolutely. ...................J.u.ne.ll..7••••29..,..l.9.7...l.. ...................~.MJ.Y.....J...t•••.J.9..ZJ... (PUBLISHED BY WASHINGTON COUNTY BAR ASSOCIATION) PROOF OF PUBLICATION In compliance with the Newspaper Advertising Act of May 16,1929, P.L.1784 Sec.3,paragraphs (3)and (25). COUNTY OF WASHINGTON}SS. STATE OF PENNSYLVANIA Personally appeared before me,a Notary Public in and for said County and Commonwealth,CHARLES C.KELLER,who,being duly sworn,deposes and says:that he is the Editor of the WASHINGTON COUNTY REPORTS, the official legal periodical for said Washington County,published weekly having its place of business at Washington,Washington County,Pennsylvania, and is acting as its agent in this behalf;that the said WASHINGTON COUNTY REPORTS was established on March 31,1920,and was designated as the official legal publication for Washington County,Pennsylvania,by order of the several courts of said County,dated November 11,1920;that the printed notice or advertisement attached hereto is a copy of a notice or advertisement, exactly as printed or published,which appeared in the said legal periodical in its regular issues on the following dates: MELLON NATIONAL BANKANDTRUSTCOMPANY, that the affiant or the corporation in behalf of which he is acting is not Guat:dian of.the Estate of.d'h b'f 'd t'd'. d h all f th Mallie Moffitt,IDtereste ID t e Stl Ject matter 0 sal no lee or a vertlSIDg an t at 0 e an incompetent. allegations of this affidavit as to the time,place and character of the publication Howard F.Carson are true.r:Jla (Q Attorney-at-Law,212 Fourth Street_~.............~t&~l Charleroi,Pa.15022 6)42-3 ,~----~~Sworn to and subscribed before e ~~-~ ........!.§J day Of~·.·;ztY.,19..1..L~.. ~er!~if;~ JOSEPHINE T.SCIAMANNA Notary Public,Washington,Washington Co. My Commission Expires July 1,1974_____________________________~"""...."""_.....,_......"""....__lIIIIIIllI!IIilI!I__1IIllil11Hill ~./ .' Under Act No.587,Apprewod May US,1929,P.L 1784, asamendocl "y Act No.51 of April 24,1931,P.L 67 State of Pennsylvania },M"County of.Westmoreland .. Personally appeared before me William H.Pore,General Manager of The Valley Independent,who being duly sworn,deposes and says that The Valley Independent is a daily neWSpaper of general circulation in Fayette,Washington and Westmoreland counties;.Pennsylvania,and elsewhere,published in the City of Mones~n,Westmoreland County,Pennsylvania,that it was established June 28,1902,since which date The Valley Independent hels been regularly issued in said county,and that a copy of the printed notice or publication is attached hereto exactly as the same was printed and published in the regular editions and issues of The Valley Independent on the following dates,June 17 J 1971 June 24 and July 1,1971 Affiant further ~s and says that he is General Manager of The Valley Independent,a daily newspoper of general circulation,and as such is authorized to verify the foregoing statement under oath,and Affiant is not interested in the subject matter of the aforesaid notice or advertisement,and that all ollegations in the foregoing statements as to time,place and character of publication are true. COPY of NOTICE Swom ta and subscribed before me this 2n d 212 Fourth Street Charleroi,Fa.15022 TO THE VALLEY INDEPENDENT,OR. For publishing the notice or advertisement attached hereto in The Valley Independent an above stated dates .~~..:p..$34.50 Notary ;'. . ...$.75 day af_J ;....u......1 1Y:.--,19 ~~O.~~ ~Notary Public MARY A.EVANS,Nofary Public My commIsSIon expires Monessen WedmNgliRsi Ce.,Pa. My Commission Expires July 30,191a STATEMENT OF ADVERTISING 'COSTS: Howard F.Carson,Attorney at Law $35.25...................................................................Tatal \ IN THE COMMON PLEAS COURT OF,WASHINGToN COUNTY.PENNSYLVA· NIA.ORPHANS'COURT DiViSiON .... flo.60 of 1971., IN RE:ESTATE OF MANIE MOFFITT.an incompelent;MELLON NATIONAL BANK AND•~TRUST COMPANY.Guardian of the Es·tate of MANIE MOFFITT••an'Incompe·,tent,has filed a ,petllion at Ihe abovenumberaskingforpermissionofIheOr-hans'Courl 10 sell cerlein real esl~le;~escribed In said petllion and belongmg10ilsward.,to wit••dwelling and a lotofgroundknownas613CrestAvenue., Charleroi,Pennsylvania..15022.(mo~e ,articularly !bounded·'and de~c"bed m'~.B.Vol.583.pag~585),at private,sal.e to Collins Hall Agency,Inc.•CharlerOI. pa'.•as principal or 'agent•.for t~e ,urr of ,$14,500.00.as s~t forth m said pell- t1~~Onda:.July 12.1971.~1·.il:00 o·clock. A.M..has been fix.e~as Ihetfme fo~a hearing on Ihis petition m the Orphans I.Court Room.Court ~ou;e..washington. Pennsylvania.at which time th~Court,will entertain higher bids for said prop- erty ;ubiect to the rules of Court.as to Ihe •acceptance of higher bids.If,there are no higher bids Ihe Court will be reoquested'to confirm said sale absolutely. MELLON NATIONAL BANK AND TRUST COMPANY.Guardian of ,the Estate of,Manie Moffit!,an incompetent. Howard F.Carson'Attorney·at·Law212FourthStreetCharleroi.Pa.15022 6;17,2U;1 aOeEIPT Fott ADVERTISING COSTS The Valley,Independent,a daily newspaper of general circulation,hereby acknowledges receipt of the aforesaid odv~rti~ing and publication costs and certifies that the same have been duly paid. THE VALLEY INDEPENDENT By.~_ I ~~ &frfC~;<,Wn/ June 15,1971 .s:1'f1i/nU;Y/'ff4ld{/()wn:Jellor""t~w/ ffk/rltYNH/,/!i1ffWl;r~ 15022 SJfrea'-t-k///~ ~#Wne'//,gS-6'SIJS TO THE POTENTIAL HEIRS OF MANIE MOFFITT: We have had considerable difficulty in selling the house of your aunt at 613 Crest Avenue,Charleroi,Pennsylvania.Our difficulty arose because we had an offer of $15,000.00 whi.ch evidently scared .••..•......l..~off other interested buyers,then,the'person who made that o:(fer withd~ew his offer alleging that damage was done to the house during the auctibn of-the furniture.w-nile I 'did not agree with this allegation,it was determined that rather than have ~law suit over the"matter,that we would attempt to secure another,buy~r. Mr.Ott,of the Mellon Bank,Mr.Hall of the Collins-Hall Agency, and myself have spent countless hours in trying to secure a new bidder in the range of $15,000.00.We were finally able to secure a firm bid of $14,500.00;under the circumstances,we felt we were quite fortunate.On Tuesday,June 15,1971,on behalf of the Mellon National Bank,Guardian of the Estate of Manie Moffitt, an incompetent,I present~d a petition to the Orphans'Court re- questing approval of tne sale"'a~t '$ljL~/?OO.00.The Orphans'Court has set Monday,July 12,1971,'.]'atPO o'clock,A.M.as the time for the consideration of the p ~lti(. You will find enclosed a photo~.10pyf the Notice of the Sale which is presently being published in\,\t,r/newspapers of Washington County. This notice is being sent to you,!conformance with the instructions given to me by Judge Marino to ~D~fy you of the proposed sale and the confirmation hearing on July 1]2,1971.Should you have any questions,please feel free to cJ~tact me concerning the same. Very truly yours, !I~r~ Howard F.Carson HFC/ma Enc. I ~J:.{t' .. IN THE COMMON PLEAS COURT OF WASHINGTON COUNTY,PENNSYLVANIA. . .~.,., ,', ),.'f ,\," ,!MELLON NATIONAL BANK AND TRUST COM-,,' PANY,Guardian of the Estate of i Manie Moffitt,an incompetent.' " I ,,';I".::,;" ,( I,"I i,I j No.60 of 1971. ESTATE OF MANIE MOFFITT, an incompetent ORPHANS'COURT DIVISION IN'RE: ,Howard F.Carson Attorney-at-Law 212 Fourth Street Charleroi,Pa;15022 I I I,· ilIIIiIi, I I' I [J:rC;2 ~EL~N~t;~~IONAL BANK AND TRUST COMPANY,Guardian of the Esta~I 1 I I 1 ::0::~:::e:O:::::~::r i::::::::::,O:a:h:i~::h:n~t::::::::::1 ." certain real estate described in said petition and belonging to I,its ward,to wit,a dwelling and a lot of ground known as 613 Crest Avenue,Charleroi,Pennsylvania,15022 (more particularly II'II bounded and descrioed in D.B.Vol.583 ,page 585 )at privateI"I II sale to Collins-Hall Agency,Inc.,Charler~i,Pa.,as principal I I',,I I or agent,for the sum of $14,500.00,as set forth in said petition. ,", I I II,July I,:b,1971,at ;/,(;Do'CloCk,f{.M.,I II has been the time for ahearing on this petition .in the i Orphans'Court Room,Court House,washington,Pennsylvania,atl IwhichtimetheCourtwillentertainhigherbidsforsaidpropertY1 ,subject to the rules of Court,as to the acceptance of higher I 'I Ibids.If there are no higher bids the Court will be requested tol "I 1Iconfirms~id sale absplutely.~',i Ii ::II,~,,; " I ,," f ,".".•!.'.",t. '1 I ' ':',i i,• " .,; " Iv ~-z_.6""'() o --::::--;r' ~~c i ~,-=-~ 21221 2r ~-~.\)e(fp.>-1'~~~ Return (Jj!'ec J.pt Reguested @ Mary~Oe 344 To send Road BaIt"ore,Maryland ~-.,. r·--·.-.... J ". "1*'._yQiili§Qf¥¥f$i&ifijiEb ¥bM $I,is jp flt]ilii"_~ 15022 -'---_.--.-.©@:~lfO[?,O~@ [No 813668] !XiJ~O [b , I,. ~@apd'§r.l',jO,/t ~I'''''''A~aAd 9f::aA~tJ//o...al'~az ~a/".&/"oe;.9J/t/t~~a/t&a ) " ,'"--:,.",;...l~,~.-'-'"'...:..__~~".~{"~_'"10..---_."'"".......''itt."'.~.--~~...~ PLEASE FURNISH SERVICE(S)INDICATED BY CHECKED BLOCK(S). REQUIRED FEE(S)PAID.. O Show to whom,date and address 0 Deliver ONLY where delivered to addressee ...--~---.--- "'- RECEIPT Received the numbered article described below. I I,._.r"', e55-16-71S48-11 347-198 GPO A SHOW WHERE DELIVERED (only if requesf~d) ~I REGISTERED NO.SIGNATURE OR NAMEOF ADDRESSEE (Must always b~fill~d in) CERTIFIED NO. 813668 SIGNATURE OF ADDRESSEE'S AGENT,IF ANY INSURED NO. DATE DELIVERED '., \." "..', ""',......>..~'-~~:il \..~~\ \1')l)~II\t~~'./......$,(~~. IN ,THE COURT OF COMMON PLEAS OF WASHINGTON COUNTY,PENNSYLVANIA ORPHANS'COURT DIVISION IN RE: ESTATE OF MANIE MOFFITT, an alleged incompetent. ) ) ~ ) ) ) ) No.,60 of 1971 I \ \ ~BEFORE:I-~z·iUl<:( ~APPEARANCES:t 0:I-!!lc ~TIME:§c:J., J:......... THE HONORABLE P.VINCENT MARINO,Judge of the said Court HOWARD F.CARSON,ESQ.,of Crn rleroi, Pa.,representing the Petitioner. Monday,March 8,197~,at 10:00 o'clock A.M.,EDST. is the time set in re:the Estate of Manie Moffitt,an alleged incompetent.And as I started to say,this is the ceeding? MR.CARSON:I am,Your Honor.For the reccrd,this Mr.'Carson,are you ready with your proaiTHECOURT:It:IIII-0:oII.III0: f-0::JoU oJc(Uii:II.o I .f."1\ time set for the hearing on the Petition ~ed on January 18 by me on.behalf of Harold G.Moffitt,who has petition d for,the appointment of a guardian.First of all,I have a Affidavit of Service of the Petition and the Citation UpOl Miss'Moffit at the Charleroi-Monessen Hospital and under the same cover I have an Affidavit of Mailing of copie so;:> the Petitionmd Citation to all of the nersons listed in he 2 initial petitimand its accompanying Order and Decree. THE COURT:The Affidavit of Service having complie with the 'Court's Interlocutory 0:r:der and with statutory r~quirements','the same is ordered filed and made part of this record. MR.CARSON:Thank you,Your Honor.If the Court,pIe se, ~z«>..>-Ul ZZIIIII. would it be p0ssible for us to call Dr.Si)rri out of turnD .. He's come over this marring and if we could do it,we'd appreciate it. ,. MR.CARSON: ig THE COURT: t'z:rUl<~ We will hear the doctor first. All right. EXAMINATION BY MR.CARSON: ~oii:I-Ulii..«o Q ;DR.CARLO SIIrRI IS CALLED AND SWORN. ~N iiiII:EQoL:l A l-n:: 5 Qo..~A ii:IL o Q A Q A Q A Wha tis your full nare? Carlo S~rri. What is your profession? I am a physician.I am a Psychiatrist working in CharIer i. Are you licensed to practice medicine in the State of Pennsylvania? Yes. IEbelieve you specialize in Psychiatry. That's right. And where is your private office? In Monongahela. 3 That would be of tre Mental Health Facility. The Washington Medical Society. That would be the Washington County Medical Society? You are the clinical director? Yes. Yes. The Psychiatrist at the Mental Health Center at Charleroi So in other words,you are practicing Psychiatry both as a private practice and in a public nature there with the ~on What is your position there? I am Clinical Director at the Mon Valley Health Center in Charleroi. Yes. Clinical Director! And do you have any positions with any public bodies s~ch as any mental health agency? Any position with any mental agency? Q Now are you affiliated with any hospitals? A Ye s.With the Charleroi-Mone s sen Hosp i tal and the Mononga ~ela Memorial Hospital. Are ~u a member.of any medical societies?Q A Q =!:Az0(>,J Q>-IIIZZIIIII. i0 A..t'Z i:QUl0( ~ ..:Auii:..III Q ,J 0(QQ Q ::l"'l A:I:...... 01 ai Q II:III..AII:0II.IIIII:Q..II:::l0 Au ,Jclu Qii:...0 Valley United Health. A Q That's right. Do you know Manie Moffitt? A Yes.I've seen Miss Moffit.I saw her the first time on J~nuary 23rd. Q Where was that? 4 A At the Charleroi-Monessen Hospital.She was a patient of Dr.Qunningham and he asked me to come to see her on cons 1- tation • .Q If the Court please,we have two matters that should be c lIed to the Court's attention.First of all,paragraph two of the Petition sets forth that Miss Moffit was a patient 1n <z<>..I>-IIIZZiiiII. Ze~zxUl; tii:I-!!! Cl ..I<§ Cl ::l'"l :tt:.til the Brownsville Golden Age Nursing Home at Brownsville,Pc. NOw,however,she never got there.I believe I mentioned this to the Court informally.She was in the Charleroi-Mo essen Hospital at that time and it had been planned that she w011d be transferred to Brownsville on the same day that till Pet ition waspresented to the Court and that's why I said Brownsvil e. But for various administrative reasons she just never got there and as the doctor will relate,she was eventual~y' transferred to the Havencrest Rest Home in Carroll Townsh p just outside 'of Monongahela. iii~THE COURT:Do you wish to correct that allegation?a:o~MR.CARSON:I would like to amend paragraph two so sa: I-a:5 to read that the patient,that the alleged incompetent is u ..I 0(a patient in the Havencrest Rest Home in Carroll Townshipuii:~Washington County,Pa. THE COURT: MR.CARSON: The amendment is permitted. Thank you.Now,Doctor,when did you la:t see Miss Moffit professionally? A I saw her last Friday.I went to the nursing nome where she is now. Q That would be March 5th. 5 .A Ye s. Q And I think you just said you saw her at the Havencrest R st Home. Yes. Yes. or designing persons? Ye s,I do. We understand. Now do you agree with that diagnosis yourself? Incidentally,when you first examined her,did you receiv any history from the patient? time the Petition itself was filed,Dr.Cunningham signed the form of Affidavit that in his opinion she was likely to become the victim of unscrupulous or designing persons I would call the Court's attention to the fact that at thE in which she was likely to become the victim of unscrupulcus The patient was so confused that she couldn't give any reliable information.The information I got was from Dr . Cunningham and from the ward personnel. Very well.Thank you.Now,Doctor,did you know that Dr . Cunningham had diagnosed Miss Moffit's condition as one Would you tell the Court why you agree with it?In other and I might point out to the Court that I discussed with Dr.Cunningham the need of his coming to Court,and he suggested at that time it might beoore appropriate to havE her examire d by Dr.:s.~rri in his capacity as Psychia trist COURT: A Q <8 ~Az0(>.J>-IIIZZIIIl1. i ~Q"Z :I:III 0( ~ .,:ui..III 0-.J0( ~ 0 ::;)., :tI-"N oj II:III..II:0..III THEII:..II:8Q .J0( 0ii:IL0 -A Q A Q words,what findings did you make? 6 A Yes.Well,both times,January 23 and the last one,she (idn't know where she was;she thought she was in her own house. The first time she was at Charleroi Hospital and the othe time at the Havencrest Nursing Home'.She thought she was in that house.She thought she had been there for about 3 ) years she said.She was waiting for her mother to come. She was talking to her brother who has been dead for more than 30 years,like he was coming to see her regular y. And she was disori~nted as to time.She couldn't really concentrate in anything,any conversation.I tried to car y on,.she was getting lost while talking. signs of confusion. And she showed Q In your 9pinion as a p:'lysician,was she physically able to come to Court here today? A I don't think so.She was in a wheelchair last Friday. And I didn't even try to make her walk.But "the nurses to d me there she can,with support,go for small walks.But I think it would be detrimental to her. Q Especially in light of the weather we have this morning. A Yes. Q Am I correct then it is your own professional opinion t ha she is likely to become the victim of unscrupulous or ~designing persons? A She could. Q Do you see any possibility of improvement in the future? A No.She will never be well enough to handle her own affa rs and to make sound judgments. - ~z<>,J>-IIIZZ111Q. i0I-\!I Z i:III<~ ..=~ 0::I-!!!a-,J<Ua:::l., J:l-I'<til iiia::111I-0::0Q.III0:: I-0:::::l 0U ,J<Uk:...0 - 7 Q Would you attribute her pre sent condition to senility or 0 any other cause? A I think"it's senility and also arteriosclerotic involveme t of the brain vessels. Q Does the Court have any questions of Dr.Si,rri? EXAMINATION BY THE'COURT: Q Doctor,her condition of arteriosclerosis is one due main y to age,is it not? A That's right. Q It's not a congenital condition? A No.In this case,no. Q And her age is,as I uni erstand,about 82? A 81,I think it is • Q And would you feel that at her age the prognosis in her Ci se would be what?. A The prognosis is poor as far as mental capabilities is concerned. Q So that she would be expected to decline mentally if anytr ing. J A That's right. Q And you feel definitely that she is unable to handle her personal and business affairs? A Yes,sir. Q If she were permitted to handle her business affairs,wou d she become the victim of designing individuals? A Yes,she could. 8 Q .How many times,Doctor,have you seen her? A Two times.The,first time in January when she was a patie t at the Charleroi-Monessen Hos~tal.And I went to see her without stopping to talk to her,but,other times while sh was in the hospital in Charleroi~And then I went to see er las t Friday. Q The Court ha s no further quest ions. MR.CARSON:Thank you,Doctor~You are excused. .(Witness excused). HAROLD G.MOFFITT IS CALLED AND SWORN. EXAMINATION BY MR.CARSON: Q Wha t is your nare? A Harold G.Moffitt. Q And where do you live,Mr.Moffitt? A Hagerstown,Maryland. Q Do you know Miss Manie Moffitt? A Yes,I do. Q Are you.related to her? A A nephew. Q What was your father's name? A Thomas Edgar Moffitt. Q And he would be what to Miss Moffitt?. A A brother. Q Did your father,and of course Miss Moffitt,have any othEr brothers oor sisters?You can just answer that yes or no. 9 A Yes. Q Are any of them living today with the exception of Miss Moffitt herself? A Q-A ~.Q«>..I A>-III Zz QIIIII. No.~here's none living whatsoever. Incidentally,was one of your uncles an attorney? Yes. What was his name? Guy Moffitt. Perhaps the Court may recall GUy Moffitt.He used to be i or sisters. A No. A No. Q In other words,then Miss Moffitt has no living brothers Yes,we do. Charleroi. Q Copies of tm Petition and the Cita~ion were serv~d upon these people:first of all Delphia Moffitt.Who is she? Q They would all be nieces and nephews? A That's right. Q Other than your own brothers and sisters,to the best of your knowledge,does she have any other living relatives? THE COURT: Q""Do you know when he died,approximately? A Approximately 39 years ago. i 0I-ClZxIII«~ .,:uii!I-III a-..I«0 a :J"'l J:~"til uiII::IIIl-ll:0II.IIIIt: l-ll::J0U ..I:50iLII.0 <I A That's my mother. Q And Thomas E.Moffitt is who? A My brother. Q Madaline Litzan? 10 Yes. I understand she passed away yesterday. A.sister. A brother. No. brothers or sisters? Now as I went down the list have we missed any of your owr And yourself,Harold G.Moffitt. Mary Hoye? Brother. A brother. Kenneth K.Moffitt? Fred Moffitt? James W.Moffitt? Right. Yes. know who you were? How l(;mg have you lived in Hagerstown? 16 years. During that period of time,have you had occasion to visit your Aunt Manie? Yes,quite frequently.I would say two or three times a year. And on those occasions prior to last October,did she always ·Sister'. And up to that time,did you ha~any 'reason to doubt her mental faculties? in A No.She seemed/fairly goodmape. A Q A Q ,A-Q ~Az<>...Q>-IIIZz AIII0.. ie Ql?Z *A<~ .,:Qua::I-AIII Q-...~Q Q :l.., :z:t-"~A"UlII:III~Q00..~A I-a:::l8 Q...c( i3 ii:... °A <It Q A Q 11 Now what happened in October? As I understand it,she went to the hospital. I see.In other words,you weren't here at the time. No.I was in the West Indies. Did you ever visit her in the hospital? was On the It)th of January I/called home from the West Indies When you say you were calledrome~ho called you? My wife. Who had contacted her? Mr s.Kinnaird. That would be Mrs •.Evelyn Kinnaird? .That's right;a neighbor. When you visited your Aunt on that date,did she know you' No,she has never kriowed me since then. ,At that time,at my suggestion did you S1l5gest to your au t that she should ha~a guardian appointed for her? I believe that was on the next day,that wason the 7th 0 the 19th,more or less suggested that. You did make such a 8uggestion?' Yes. What was her reply?I'm referring to the fact that she l1 d mentioned her brother at that time,her brother Guy. Yes.She said she had things to do;she would have her. brother take care of any legal matters or anything of tha kind,Guy Moffit,which is an attorney. Q And now is that the same brother a moment ago you said ha been dead for about 39 years? A Yes.' 12 Q And was it following that or at least in conjunction withthat visit that you retained me to prepare the Petition for tqE appointment of a guardian? A -Q ~z c(>.J~Azz~Qz0~AziUlQc( 3 '.=uii:I-!!!AQ-.Jc( §Q Q:J.., J:I-"til viII:IIIl-ll:0LIIIlI: l-ll::J0 Au .Jc(u Qii:IL0 - Yes. In the Petition it alleges that she owns real"esta te in Charleroi amounting to approximately $10,000.That house is where? 613 Crest Avenue. And that has been her home for a good many years,hasn't t? About 45 or 50 years. And the $10,000 value was actually one that was suggested by myself,wasn't it? Tha t 's right . In paragraph four of the Petition I have set forth that s e has personal property cons~ting of a checking account in the Charleroi Office of the Mellon National Bank and Trus~ Company of approximately $10,000.I believe that's inform tion that you got indirectly from the bank,is that right? Yes. And also,in the Petition was listed two Social Security checks'dated December 3 and January 3,1971.And I believ3 those are checks that Mrs."Kinnaird y'-had",';received and Q And what is your understanding of any other assets that y)ur aunt may have?Or do you have any definite understanding Jf I&- them? A I understand there's some bonds;outside of that,that's the ~.for Miss Moffitt prior to that time?z~~A No,sir. 1lIz~Q Has a Petition ever been filed to have her mental capacitJ I (It I A Q zol-I'Z~Ac(~ ..=Q~- 0:.1- 1lI Q .J.~A ~ Q ::Q %..."N A vi0:~QoLIII0: I-0:;)oU .Jc( U ii:IL o A Q Not exactly. To the best of your knowledge has a guardian ever been aplointed determined to the best of your knowledge? No,sir. Based on your observations of her as a layman,incidental y, when was the last time you saw her? Yesterday.I visited her yesterday at the rest home • Did sm know you? She didn't. As I started to ask you,based upon your observations of our aunt,and I presume that would be comparing your observaticns of her in recent months to how she had been previously thEreto, do you believe that she is able to handle her own affairs No,sir. Prior to last October,w~she able to handle her own affa rs so far as you could determine? A You mean since October? Q No,before. A I believe so,yes. Q Incidentally,I should have asked you,what is your occu- A pa.tion? Semi-retired. 14 Q Well,before you retired what did you do? A Painting contractor. ,Q Do you have any work as such now other than painting? A ::!:Q zc(>.J>-UIZZ'"II. ZoI-CI ?:AxUl c( ~Q ~itl-UI Q .J::!: 2Q :J"\ :J:SA iii~QI-a:oa.IIIa: I-a: :Joo ~Ai3ii:~Q No,sir. In other words,your church activities are strictly as a matter of a hobby so to speak or at least a matter of your religious activities.In other words,youdon't have any professional status as far as your church is concerned. No,sir. I thought tta t in the Petition you have suggested to the Court tha t the Mellon National Bank a nd Trust Company be appointed as guardian of the estate of Miss Moffit~Why did you choose Mellon? That's where her assets or whatever is located. To the best of your knowledge does the Mellon Bank have a y interests which would be adverse or hostile to Miss Moffi tIs own welfare? Not as I know of. Does the Court have any questions to ask of Mr.Moffitt? c15 EXAMINATION BY THE COURT: Q Mr.Moffitt,do you know whether Manie Moffitt has a safe deposit box at the bank or at any other bank? A I do not know. Q You speak of certain a sse ts that she has ±l the way of Uni i ed states Savings Bonds.Now if those are not in a bank in a '~z safe deposit box,where would they be located now?Who~...~would have them?zz~A The "H"Bonds you mean? zo~Q Whatever the Government Bonds are,who has possessionof'tl em?zx~A I gue ss---~ ~MR.CARSON:If the Court please,I think really Mrs i..~Kinnaird has them • ...~THE COURT:possessionof the Bonds? Q:J~MR.CARSON:Yes,sir.She's,here and we will be glac to~C\I America? came into her possession. put her on the stand and she will be able to tell you how they other que stion of Mr .Moffitt.Has Manie.'Moffit at any til e been a member of the Armed Forces of the United States of We will defer that question then.OneCOURT: ai0:III..0:o..III~THE0::Joo...<u~o A No,sir. Q That's all the questions we have. MR.CARSON:Thank you,Mr.Moffitt. (Witness excused). 16 EVELYN KINNAiIRD IS CALLED AND SWORN. EXAMINATION BY MR.CARSON: Q A -Q A ~Qc(>..l~Azz~Qz0~Az x~Q~ ..,:Au 0:I-ur Q0-..lc(~A 0;)., x......til ui Qtr:IIII-0:0LIII 0:AI-0:;) 0U ..l0( 0ii:... 0 -Q A What is your name? Evelyn Atkinson Kinnaird. Where do you live,Mrs.Kinnaird? 612 Meadow Avenue,Charleroi. Do you know Miss Maniee Moffit?· Yes. Do you know where she lives in Charleroi? Yes.613 Crest. Now where is her home with respect to your'home? Across the alley down. And how long have you known Miss Moffit? Well,I've really known her slightly since 1941.But I've knowh her very well since 1967.No,'66. What was the occas~n for you to become,as you put it, well acquainted with her? Well,Mr.Powell roomed at her house.He had roomed there for 40 or Y5'years and when he passed away then she seemec to want ssomeone to be friendly with her and then I rentec her garage and I still rent it. And since? And as soon as I started going to her house she gave me a slip of paper and it had written on it,IIIf anything happEns to me,please call my niece,Edna and my nephew,Harold.ll Now that's Mr.and Mrs.Moffit. Q That would be the Mr.and Mrs.Moffit who are here in Cou t 17 today • .A Ye s. Q So when she said her niece Edna she is actually referring to Harold's wife. Harold's wife.But I knew by that that she thought a lot cf her by calling her "my niece." Since 1967 how frequently have you had occasion to visit Miss Moffit? Oh,I would run in probably sometimes I'd run in everyday in the week or a couple times a week just for a few minutes cr an hour or two. For the Court's information am I correct that you have a 1 king for older people? Yes,I do. For e~ample,I think'you visited my aunt who lives nextdocr to you almost as frequently as you did Miss Moffit. Yes. When you first became well acquainted with Miss Moffit wa; there any problem with her mental faculties as you could tell? Not at all. How about physically;?How was she? Well,she seemed---she did all of her own work and worked in the yard. Q Did she ever visit your home? A Once,and that was all. Q How long did this matter of your visiting her several timE s a week continue? ,-------...-------------------~-----_.__.- 11) A Ever since I rented her garage.And I knew that she needec someone to talk to. Q Well,did this continue up to October of 1970? A Yes. Q And up until.October of 1970,what had she done to show hEr trust in you? A Well,now she never told her personal,her financial cond tions I had no idea that she had any money at all except enough to live on.I always paid her gas,electric and telephone bill for her when I paid mine and paid~ur aunt's. Q Where would you get the money to pay Miss Moffitt's bill? AShe always gave it to me. Q Would it be cash or check? A Cash. Q And other than paying those bills did y'ou ever do any of er- banking business for her? A No,except when she was in the hospital,the second day s e was in the hospital,well,I paid her fire insurance or s om~thing for her,but she had the cam for'that and-she gave me that before,;,'she went to the hospital.And she h d to pa¥Metropolitan Insurance Policy.She told me where tp find her'checkbooks.I got her checkbook,I made QIt the check and she signed ,it to ,pay her Metropolit;~m Insurance Q When you say she told you where to find it you mean'it wa in her home? A Yes. Q And how did}Ou ge t in the house? 19 A Her cellar door was not locked.She never---you couldn't'u lock any door in her house from the outside.She had some kind of a lock inside,but no key for any door.She went out her cellar way and when she went out her cellarway,it was Ie t unlocked and when I went up in to get that checkbook,sm told me'where some other money was.And I got it. And how much money was that? $1200.00. Where is it now? In my safe deposit box. Now so the Court will underst and alittle more of your ow background,you have a son-in-law,Donald Gadd. Yes. And who does he work for? Western Pennsylvania National Bank. And I believe that before I got into this picture,your son-in-law advised you as to what to do with these assets Yes. Wnat did he advise you to do? Well,he ~ked a lawyer what to do,to be sure.And he sa d to take those things,make a note of them,a list of them wrap them up,tie them up and it would be okay to put then in my safe deposit box because Miss Moffitt does not have a safe deposit box.I a~kkd~h~r if I could put--rent a b<x for her and she says no',I don't believe in having safe dE posit boxes.Well,'I wasn't having tla t in my house. Q Did Miss Moffitt know what ,you -d:id,'wi th these items? -------...---------------_._--- A No. you had these items? Yes. Can you tell us approimately when it was tm.t youtold then? Well,there's $1200.00 in cash. I mean when.When did you tell them?Do you ha~any idea? No.The first time thEY came up. 20 I see.And I believe at that time you also told me about t. Yes. In this package are there any bank books or check books tl~t you recall? No.I have her checkbook. I see. Because I took it to the rospital and she signed tha t ete c . Am I correct that I suggested to you that assuming the Co rt did a pprove the appointment of Mellon Bank this morning we would stop over to see Mr.ott,the Bank's Trust OfficI r, after we left the Court? Yes.• And you readily agreed to that suggestion. Yes. When is the last time you saw Miss Moffitt? February 15. Q Is there any particular reason why you haven't re en him since then? 21 A Q-A Q c(z Ac(>oJ>-QUIzZ IIIDo i0l-e Az iUIc( ~ .,:-l) itI-UI 0-oJc( ~Q0 :l... :r AI-....N iii II:IIIl-f Q IIIIl: l-ll::l0l) oJc( Uii:IL0 -Q The weather has been too bad for me to drive doWn there. And did she know you on that occasion? Ye s,she di d • Did her conversation make sense? It did for awhile.And then it drifted to the past. Can you give the Court an example of how it drifted in thE past? Well,of course,I didn't stay long that day.But she tol( how she came to the hospital,which·was not true.She sai she came in a truck and like that,but no~when ~u as~ed me to go to see her about having a guardian,she got very an ry. Is that the same time Mr.Moffitt testified about? Yes.They were with me and she got very angry and she sai< nobody is going to tend to my affairs e~cept my brother ~y. You see,Your Honor,I was hopeful that we might have a voluntary proceeding here,but when we had that type of reaction,it was obvious it wouldn't work. (At the direction of the Court,off-the record discussion was not recorded by the stenographer). Mrs.Kinnaird,among the items in this package in your' safe deposit bo~,are there any bonds? A No.I got the bonds later. Q I see.And where are those bonds now? 22 Q Now these assets that you have do you haw any persona+ claim upon them? A No. Q Are y.ou perfectly willing to relinquish them to whoever t e Court appoints to be guardian of Miss Moffitt? A Certainly. .; No. have some idea of their denomination and number. this by working backwards.We received a statement from You may inquire about the bonds.I'd li e to Incidentally,are you related to her yOU:bS'fI1f'? the face value of these bonds or as to the total of th6u? Ail right.Can you give us any of the details as to elthe There's eigljlt $1,000 bonds,and there's another one but it's $22,000.I don't know,there's a slip of paper in t ere, I don't know if that's a bond or not. the Mellon Bank showing iTIErest which had been paid and If the Court please,I think that this $22,000 is a type of certificate deposit from the Mellon Bank and we comput d it would appear that was the type of an obligatbn itself, Does the Court have any further questions of Mrs.Kinnair<? COURT: ~Q ~~AIIIzZ~Q ze THE~z:z:III~ ~Q 0::I-IIIQ oJ. ij A D:J., :I:~\II ui0::III~Q .11.'bi 0:: I-0:::loU oJ0( Uii:II.o Mrs.Kinnaird and I have been acting somewhat unofficiall,, but still effac±ive;;Lyrthat she's been picking up her mail nd in turn gives it to me and I have opened most of it and that's how we happened to determine that this information had come from the Mellon Bank. THE COURT:Are,there any other bond's othpY'th::m th -------~-------~--~-~--- 23 eight $1,000 bonds? Q Did you hear the Court's question? A Not that I know of.I gon't know.All I know is just wh,t I hsve. THE COURT:Did you see any bonds of smaller denomi ations A No. by the Court,do I urrerstand correctly? ~ords,you have nooclaim on any of these assets? it would appear that Miss Moffitt's assets would be far :ir one of the items that the guardian will have to inventory That is right.Mrs.Kinnaird,in other So in other words,if the Court please, Such as $500.00 or $25.00? Did you start to say you never really 1 8ked ! And this witre ss is perfectly willing to turn •No.These were in an envelope like. over all assets that"she now has to the guardian appointe long time.Then I did open them up,..but that's what "was in memo excess of the $20,000 we put in the Petition.But this is through these papers or did I misunderstand you? ·Those bonds,I had them in the .house until,well,for a CARSON: COURT: MR.CARSON: ~THEz 0(~A>-Ul Z~MR.a. ioI-oZ ~A ~ ui~THE COURT:II:oII.IIIII: l-II::JoU... 0(oii:ILo tiii:.~MR.CARSON: Q ..I0( U Q:J"'\ Xt:.N A No. MR.CARSON:Perhaps this is a matter of the future, Your Honor.Mrs.Kinnaird can correct me if I am wrong, but one of the things that she would like to talk to Mr. ott this morning,i..~as'.:to whether or not the bank wants her or someone else to continue looking after the house and 24 if so,why,there may be a matter of some nominal conside ation _invo:eved.She mentioned to me the fact she lil like to at :east get reimbursed for her rent for each month which is the large sum of $5.00 a month.So obviously the 'lady has no big ideas of compensation. THE COURT:We will permit the guardian to make suc1 it with that money because she doesn't owe me my thing. I'll tell you what my son-in-law did.Her cellar d.oor was unlocked when she went to ·'the hospital.Anybody could ge arrangements with her,as long as there is no claim made on the guardian or against theestate fo r past services • in that house because there was no way to ,lock it;itWlid It even close tight.So my son-in-law ch:isekea the ·door down, Have you ever been reimbursed for that? The se will all be among the items.we Yes,because she gave me $40.00 when she went to the hosp tal to pay her bills with and things at that time.And I boug t will discuss with Mr.'Ott so as to give him a full aCODun Jing as to what has happened,is that right? Yes.I didn't bring that list though that I had to keep track of all the money I had spent. whatever you call it,and I bought a lock and we ha~a 1 ck like you put on a barn door on her cellar door so that people can It get in the house. CARSON: CARSON: A ~z 0(>..J .~ Zz~A zo'"t' Z XVI0(~ ~it:'"!!! Q ..J 0( § c :;)., J: I:.N fIi MR. II:III~A LIIIII: '"II::;)oU ..J0( ~MR. ILo THE COURT:We would Slg ge st that she tum over all assets as soon as PJ ssible to the appointed guardian and GO receive proper.receipts for same. 25 MR.CARSON:Yes,sir.I will take care ofthat.Than you very much,Mrs.Kinnaird.If the C01ITt please,Mrs. Harold Moffitt is here in Court,but I believe anytbhg she could testify to would be merely duplication and cumulative to what has already been testiffud to. THE COURT:Yes,I can't see 'that it is necessary t I hereby certify that the proceedings and evidence are s:ontained full why,tre Petitioner has reached the end ofhis case and re ts. I might a dd,of cOUl'se,that in the original Petition we have suggested the Mellon Bank and they have signed the usual fcirm of their willingness ~o serve • ., That being the situation,Your Honor, Very well.The hearing is closed. (Proceedings Closed). call her. CARSON: 0(z.0(>~MR. (/)zZ 111II, ioI-~Z X (/)~ ..=u·ii:l;}THE COURT: a .I0( § a:J"I :t~(\I iii and accurately in the notes taken by me on the hearing of the above cause,0:IIII-0:~and that this copy is a correct tran cript of the same. III 0: I-0::JO.U .I0( UiL The foregoing record of the oceedings upon the hearing of the abov ILo cause is hereby approved and directed to be filed. J. -..' -. ,'. .. " -• Afi\,'~ , ,. " ,, ,.....'. '.> .,, --.:.l.;:1 '.~.f '1 :-'i (-.,C)c...: '-, V'1 '...~:;'".,.......! f ,,:; "'.(~J..t. .J c )\1,~)I 'J -;J -,.;......;..,......,-"c'l ,'···v '~I~".1;;.'J.~.......J II -~.....1:,)..'~ JuS J 1 f~(...... J -'"_._- , I ~J (.~,,...tJ ~.~f:_ .~Ij';J~~ ~,.).(I .....1.r , ,'. ." " .~.... ,,'L: -, j' PLEASE FURNISH SERVICE(S)INDICATED BY CHECKED BLOCK(S). REQUIRED FEE(S)PAID. O Show to whom,date and address 0 Deliver ONLYwheredeliveredtoaddressee RECEIPT Received the numbered article described below. REGISTERED NO.SIGNATURE DR NAME OF ADDRESSEE (Must always b~fill~d in) CERTIFIED NO. 813663 INSURED NO. DATE DELIVERED JUN 21 1971 .55-16-71548-11 347-198 GPO HOWARD F.CARSON ATTORNEY AT LAW au FOURTH STREET CHARLe:ROI,PENN!!YLVAUIA ~~022 ~~ pm ••"".""".<NT ,~_.-..0""''''-s""",___"~:~ /\',c rOIA~/....~...........~-..~"'--t!.l ~..----'-.T';:::"-J~.«-;__[~_-.",'*"-~*.;,--1:(;~~".",,~·PRIVlTE~u.~TOJ.mD~~_(/)/:N \~"'-'PAYMENT OF POSTAGE.$300 "'"'-!,,-.....#:r-....'""~~.,~--....,.,~....~ 7""1 -.....--'",)I -- -~'-I •'.......-",~,~~,,POSTM).RKOF.E.ELIVERING OFFICE J .........,"...._~__~.., Priqt your t>;l1li$;iAa.-a'ddress .belo~:--lf you /w:j.l1t to •-~ restrict.delivery,"0£,to li30ve the 'address of delivery RETURN .... shown on th.is receipt,.,heck block(s)"on other side.~_,"''..Moisten gummed·ooik and attach thIS card to back of TO ......~article.~,~.-.:a M E~~~ II.: .... D Deliver ONLY to addressee .S5-1l1-71Si8-1t 347-198 GPO SHOW WHERE DELIVERED (only if reqmfted) RECEIPT Received the numbered article described b~lolV. PLEASE FURNISH SERVICE(S)INDICATED BY CHECKED BLOCK(S). REQUIRED FEE(S)PAID. D Show to whom,date and address where delivered REGISTERED NO.SIGNATURE OR NAME OF ADDRESSEE (Must alwaJs be filled in) CERTIFIED NO. 813662 INSURED NO. DATEmuY.ER~ VlJM :3 19 ,---------, I""" I I I\. I II I I II~. !I~ POST OFFICE DEPARTMENT ,OFFICIAL.BUSINESS iI~POSTMARKOF DELIVERING OFFICE.,>,-------------------------, ~t. \.. t'_-., HOWARD F.CARSON ATTORNEY AT LAW Ilia FOURTH STRJJ:IlT 'CHARLEROI,PJEN~~rI.VA~~~~~{!a Print your name and address below.If you want torest,ric.t delivery,or to have the address of delivery shown on this receipt,check block(s)on other side.Moisten gummed ends and attach this card to back ofarticle. en~ ~-.: .-f=M E..~ "oc. ( .i "'-~--~~--------------~--- :~ \ PLEASE FURNISH SERVICf,(S)IND~CATED BY CHECKED BLOCK(S). REQUIRED FEE(S)PAID. D Show to whom,date and address 0 Deliver ONLY where delivered to addressee r REGISTERED NO. CERTIFIED NO.813660 INSURED NO. DATE DELIVERED SHOW WHERE DELIVERED (only if requested) .55-16-71548-11 347-IVg GPO I I II I "I I I"o !I POST OFFICE DEPARTMENT OFFICIAL.BUSINESS . I "I I .; ·....·~.M'. ;~')'.t'< TO HOWARD F.CARSON AnORNEY AT LA.W 212 FOURTH STREIfT i::HARLEROI.~E~NSYL'VANIA f BOa! Print your name and address below.If you want to restriCt delivery,or,to have,the address of delivery shown on this receipt,check block(s)on other side.Moisten gummed ends and attach this card to back of article. :'ll~ ..i f~POSTMARKOF DELIVERING OFFICE "i "i .: 0.<0:\ pt = M I ~ E..r.: t:l() C. .. ! .. i,. . )" PLEASE FURNISH SERVICE(S)INDICATED BY CHECKED BLOCK(S). REQUIRED FEE(S)PAID. D Show to whom,date and address D Deliver ONLY where delivered to addressee·. REGISTERED NO. CERTIFIED NO. 813661 INSUREO NO• Clli5-16-71fttS-11 347-198 I HOWARD F.CARSON ATTORNEY AT LAW lua I"OURTH STRElET CHARLlEROr.PENNSYLVAUIA 16022 i.l "51k~', PENALTY FOR PRIVATE USE TO AVOID j PAYMENT OF POSTAGE,$300 POSTMARKOFDEI.IVERING OFFICE .; ) RETURN TO~ ...... ~-~/~_B~!~;.I~~~'"':'~~~-. Print your name and addr.ess below.If you want to restrict delivery,or to have the address of deliveryshownonthisreceipt,check block(s)on other side. Moisten gummed ends and attach this card to back ofarticle. POST OFFICE DEPARTMENT OFFICIAl.BUSINESSq I -)..~~..~...~'"" enco~ ..:Co-.: ;::l 00M !.: 0 0~ $0 ,.i'i .J.\-• 1 .......".."Ij I/'..I. f I I I I , I., ,..1 ,f l •'t /\.: \J''I' rr.. PLEASE FURNISH SERVICE(S)INDICATED BY CHECKED BLOCK(S). REQUIRED FEE(S)PAID. O Show to whom,date and address 0 Deliver ONLYwheredeliveredtoaddressee ($ RECEIPT Received the numbered article desCI'ibed beloll'. 4),.., ~.,. SIGNATURE OF ADDRESSEE'S AGENT,IF e:J ~ CERTIFIED NO. 813667 REGISTERED NO.1\SIGNATURE:OR NAME OF ADDRESSEE (Mllst a/ways be jilted in) INSURED NO. .,DATE DELIVERED SHOW WHERE DELIVERED (only if m!siited)I~\,JUN 17 197 ~.~(C"" L~'__~__......cS5-16-71548-11 347"'198 GPO ..-'..# ,,;'. "'7 -----PENALIi fOR Fk(OAT~D-J '['IT 95 smr~"'_............-'], ~.. HOWARD F.CARSON ATTORNEY AT LAW lua P'OUJt1'H S1'RUa:1' CHARLIEAOI.PI!NNlIJYi.ltAI;1'A '8022 I v' ..... ~~ RETURN TO~ '~irht"t your name and address below.If you want to restrict delivery,or ro have the address of delivery shown on this receipt.check block(s)on other side. Moisten gummed ends and attach ~is card to back of article. ..PST O.FFICE DEPARTM£NT OFFICfAL."BUSINESS ",.It " I,..... "'f~L~'"" enCD~-=Co--=........00M E...,. (II. "0I:!a l ~·h PLEASE FURNISH SERVICE(S)INDICATED BY CHECKED BLOCK(S). REQUIRED FEE(S)PAID. O Show to whom,date and address 0 Deliver ONLYwheredeliveredtoaddressee RECEIPT Received the numbered article described below. ,:'I I,'l I j "~/ ~-r 'v - II".',-7--?--c-./ ,/ 055-16-71548-1t 347-198 GPO (Ii_r1 -SIGNATURE OF ADDRESSEE'S SHOW WHERE DELIVERED (only if fe'i/lested) &-~-j B-'7f CERTIFIED NO. 813666 REGISTERED NO."SIGNATURE OR NAME OF ADDRESSEE (Must always h~fill~d in) INSURED NO. DATE DELIVERED '" ~ l f i "JI RETURN TO~ HOWARD F.CARSON ATTORNEY AT LAW nUl VOURTH OTAQOT 'OQRLlXROI.Pl%NNSYLVA...tA 16022 .I,,.~,~~~i ,.~~FMoa.~y FO~PRIYATE USE TO AYOID •J JIlo..~~"".'fMENt OF POSTAGE.$lOO\.\\'\~T~l_;"~Q POSTMARKOFDELIVERING OFFICE \.f>.i:..,0 Cj c;;::I Print your name and address below.If you want to restrict delivery,or to have the address of deliveryshownonthisreceipt,check block(s)on other side.Moisten gummed ends and attach this card to back ofarticle~ POST OFFICE DEPARTMENT OFFICIAL BUSINESS ...'i'~I~ en<0en 0-0=:........OC) (II) E.. ,r:.: 00'" , l.l ~I• I•I I GPO /_~')o:.~ .55-16-71518-11 347-198 SHoW WHERE DELIVERED (only if requested) RECEIPT Received the numbered article described below. PLEASE FURNISH SERVICE(S)'I~DICA:rED BY CHECKED BLOCK(S). REQUIRED FEE(S)PAID. O Show to whom,date and address D Deliver ONLY where delivered to addressee REGISTERED NO.I\.SIGNATURE OR NAME OF ADDRESSEE (Must always be fi!!ed in) CERTIFIED NO. 813664 INSURED NO. I' <. I..,DAT:JUNERf D8 197~® i \I .\' L_. ~... "..,:~- ~->i PENALTY FOR PRIVATE USE TO AVOID PAYMENT OF POSTAGE.$300 HOWARD F.CARSON i"ATTORNEY AT LAW. 11*'4,%112 P'OURTHSTl1Ei:T' eJnmUR()I.PENNOYL,VAIl;1I4 l50Ba •:~".I , ~ RETURN TO~ _L b"IQ~.:'ql~u want torestrictdelivery,or to ha.ve ~-of deliveryshownonthisreceipt,check block(s)on other side. Moisten gummed ends and attach this card to back of article. POST OFFICE DEPARTMENT OFFICIAL BUSINESS ,......il~ 1I'3 me:..;Coco; 'P'f'f"'I00M t E...: ~c \:~ J'r~...~Io.a -~, '"(~I" "'....... ~\.", ') .•~• I '. "~ ")l,,