Reply to Motion

October 9, 2021

STATE OF INDIANA ) IN THE DAVIESS COUNTY CIRCUIT COURT 

COUNTY OF DAVIESS )

RELIASTAR LIFE INSURANCE COMPANY, )

Plaintiff,     )

Vs. )

MICHELLE J. DUNCAN, Individually; )

ALLAN VANCLEEF as executor of THE )

 ESTATE OF DAVID WAYNE DUNCAN ) Cause No. 14C01-1901-MI-000031

Defendants.

DEFENDANT MICHELLE J. DUNCAN

REPLY IN SUPPORT OF PLAINTIFF’S STIPULATED MOTION TO DEPOSIT LIFE INSURANCE PROCEEDS WITH COURT AND TO BE DISMISSED

On……., Defendant Michelle J. Duncan (“First Defendant”), filed a Motion to Compel Plaintiff, ReliaStar Life Insurance Company to pay First Defendant all policy proceeds accruing under the subject Insurance.  The mainstay of that Motion was that the Executor of the Estate of David Wayne Duncan, Alan Vancleef, filed before this Honorable Court a response to the Interpleader Complaint in which he stated that the Estate of my deceased husband does not lay any claim to the subject proceeds, thus vindicating the position that I am legally entitled to the proceeds. 

Subsequently, Plaintiff filed a stipulated motion to deposit life insurance proceeds, plus interest, with court and to be dismissed from this Cause.

In response thereto, First Defendant avers that she no objection whatsoever to the Motion and supports it. 

PRAYER

For the reasons stated above, First Defendant respectfully prays that this Honourable Court grants the orders sought in the Motion and further prays that the Court directs payment of the policy proceeds, plus interest, forthwith without any further delay

 

Respectfully submitted

____________________

Michelle J. Duncan, 

First Defendant

 

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