HomeMy WebLinkAbout07-20-07
IN RE: ESTATE OF
COLLEEN M. NICHOLSON
WHEREFORE, this
: REGISTER OF WILLS OF
: CUMBERLAND COUNTY, PENNSYLVANIA
: NO. 2005 - 729
ORDER
19Kt day of "J'.1 \ '\
, 2007 it is hereby ORDERED AND
DECREED that Jane Adams, Esquire, may withdraw her appearance on behalf Amanda J.
Nicholson, Executrix in the above-captioned matter.
cc: Jane Adams, Esquire
Chris Rice, Esquire
BY THE COURT:
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IN RE: ESTATE OF
COLLEEN M. NICHOLSON
: REGISTER OF WILLS OF
: CUMBERLAND COUNTY, PENNSYL V@NIA
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: NO. 2005 - 729 . ~c.
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MOTION TO MAKE RULE ABSOLUTE
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AND NOW COMES, Jane Adams, Esquire, and respectfully represents thifollowin~
1. Jane Adams, Esquire (hereinafter referred to as "Counsel") is currently representing
Amanda J. Nicholson, Executrix, in the above-referenced matter.
2. Counsel believes that the Executrix's current address is 154B West Penn St., 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 Wesley Oler, Jr.
5. Chris Rice was previously contacted and indicated that he did not oppose Counsel's
request to Withdraw.
6. On June 19,2007, a Rule was issued by Judge Wesley Oler, Jr., to show why Counsel
should not be allowed to withdraw her appearance. Said Rule was returnable fourteen days after
mailing upon Executrix, via first class mail.
7. Counsel mailed a copy of her Petition and Rule to Show Cause on June 20, 2007.
(Please see Affidavit of Service, Exhibit A).
8. Themail containing the Rule to Show Cause and Petition was not returned, and
Counsel believes that Executrix received her copy.
9. Counsel has attempted to contact Defendant the telephone numbers previously
provided; one number was disconnected and the other number did not allow Counsel to leave a
message.
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10. Counsel still has not received any communication from the Executrix, since the filing
of the initial Petition.
11. Counsel does not believe she can adequately represent Executrix if she is unable to
contact the Executrix.
WHEREFORE, Jane Adams, Esquire requests that this Honorable Court enter an Order
permitting her to withdraw her appearance in this matter.
Respectfully Submitted,
Date: ry.. / a . 0 l
IN RE: ESTATE OF
COLLEEN M. NICHOLSON
: REGISTER OF WILLS OF
: CUMBERLAND COUNTY, PENNSYLVANIA
: NO. 2005 - 729
AFFIDAVIT OF SERVICE
AND NOW, this July 12,2007, I, Jane Adams, Esquire, hereby certify that
on June 20, 2007, a certified true copy of the Petition and Rule to Show Cause were mailed to the
Executrix, via regular mail, at the following address:
Amanda Nicholson
154 B. W. Penn St.
Carlisle, Pa. 17013
EXECUTRIX
U.S. POSTAL SERVICE
CERTIFICATE OF MAILING
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MAY BE USED FOR DOMESTIC AND INTERNATIONAL MAil, DOES NOT
PROVIDE FOR INSURANCE-POSTMASTER
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One piece of ordinary mail addressed to:
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PS Form 3817, January 2001
Respectfully Submitted:
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ne Adams, Esquire
~ .D. No. 79465
, 64 South Pitt Street
Carlisle, Pa. 17013
(717) 245-8508
A TTORNEY FOR PLAINTIFF
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CERTIFICA TE OF SERVICE
AND NOW, this 12TH day of July, 2007, I, Jane Adams, Attorney for Executrix, hereby
certify that a copy of this MOTION has been duly served upon the Plaintiffs counsel and
Executrix 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
CCJ/i~JI $4~~
Jpne Adams, Esquire
J.D. No. 79465
( 64 South Pitt St.
Carlisle, Pa. 17013
(717) 245-8508
A TTORNEY FOR EXECUTRIX
In Re: COLLEEN M NICOLSON
ORPHANS' COURT DIVISION
COURT OF COMMON PLEAS OF
CUMBERLAND COUNTY
PENNSYLVANIA
NO. 21-05-0729
CERTIFICA TE OF SERVICE OF ORDER
ORDER DATE: 07-19-07
JUDGE'S INITIALS: JWO
TIME STAMP DATE: 07-20-07
IN RE: ORDER
SERVICE TO:
JANE ADAMS
CHRISTOPHER RICE
METHOD OF MAILING:
ENVELOPES PROVIDED BY:
[8J USPS
DRRR
D HAND DELIVERED
D OTHER_
[8J PETITIONER
D JUDGE
D CLERK OF ORPHANS COURT
MAILED: 7-20-07
SERVICE TO:
METHOD OF MAILING:
ENVELOPES PROVIDED BY:
D USPS
DRRR
D HAND DELIVERED
D OTHER_
D PETITIONER
D JUDGE
D CLERK OF ORPHANS COURT
MAILED:
Deputy
Clerk of Orphans' Court