HomeMy WebLinkAbout06-15-07
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IN RE: ESTATE OF
COLLEEN M. NICHOLSON
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: REGISTER OF WILLS OF: 1\'" ';",
: CUMBERLAND COUNTY~ PENNSYLVANIA
: NO. 2005 - 729
MOTION TO WITHDRAW APPEARANCE
AND NOW COMES, Jane Adams, Esquire, and respectfully represents the following:
1. Jane Adams, Esquire (hereinafter referred to as "Counsel") is currently representing
Amanda Nicholson, Executrix, (hereinafter "Executrix"), in the above-referenced matter.
2. Counsel believes that the Executrix's current address is 154B West Penn S1., 'Carlisle,
Pa., 17013.
3. James C. Nicholson, a beneficiary of the estate~ is represented by Christopher Rice,
Esquire.
4. This matter was previously ruled upon by Judge Oler.
5. Counsel has repeatedly attempted to contact the Executrix, by regular mail and
telephone.
6. For the past several months, Counsel has left voice mail messages for the Executrix,
which have not been returned.
7. Counsel has sent the Executrix regular mail, and the regular mail was accepted and
was not refused or returned by the post office; however the Executrix did not contact counsel.
8. Counsel has also gone to the Executrix's residence in an attempt to leave a message or
contact her, to no avail.
9. Counsel does not believe she can adequately represent the Executrix if she is unable to
contact her.
10. The Executrix has not honored her fee agreement with Counsel.
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11. Counsel was able to prepare and file the Inheritance taxes without assistance of the
Executrix; these taxes were accepted by the Department of Revenue; therefore, this issue is not
outstanding.
12. The Beneficiary's Counsel, Christopher Rice, was contacted regarding this matter,
and he has indicated that he would not oppose Counsel's request to withdraw.
WHEREFORE, Jane Adams, Esquire requests that this Honorable Court issue a rule to
show cause and permit her to withdraw her appearance from the above-captioned matter.
Respectfully Submitted,
Date: 0(?/IOI
By:
Jane Ad
I.D.No.
64 South itt St.
Carlisle, Pa. 17013
(717) 245-8508
ATTORNEY FOR EXECUTRIX
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CERTIFICATE OF SERVICE
AND NOW, thisIJiaay of June, 2007, I, Jane Adams, Attorney for Defendant, hereby
certify that a copy of this MOTION has been duly served upon the Plaintiffs counsel by placing
such in the custody of the United States Postal Service, via first class mail, postage pre-paid
addressed to:
Christopher Rice, Esquire
10 E. High St.
Carlisle, Pa. 17013
ATTORNEY FOR JAMES C. NICHOLSON
Amanda Nicholson
154 B. West Penn St.,
Carlisle, Pa. 17013
EXECUTRIX
e Adams, squire
.D. No. 79465
64 South Pitt 81.
Carlisle, Pa. 17013
(717) 245-8508
A TTORNEY FOR EXECUTRIX