HomeMy WebLinkAbout10-19-04IN RE: ESTATE OF : IN THE COURT OF COMMON PLEAS OF
MILDRED J. GERBER : CUMBERLAND COUNTY, PENNSYLVANIA
: ORPHANS' COURT DIVISION
: NO. 21-01-92
IN RE: :
MILDRED J. GERBER TRUST : NO. 21-2002-0540
UNDER AGREEMENT DATED :
DECEMBER 19, 1997 :
IN RE: :
FRED E. GERBER, SR. TRUST : NO. 21-1998-0195 V/
UNDER AGREEMENT DATED :
JULY 29, 1994 :
MOTION FOR PAYMENT OF LEGAL FEES
AND NOW, comes Jacqueline M. Vemey, Esquire and files this Motion for
Payment of Legal Fees and in support thereof represents thc following:
1. Jacqueline M. Vemey. Esquire, whose office address is 44 South Hanover
Street, Carlisle, Pennsylvania 17013, was substituted for PNC Bank for purposes of
prosecuting the objections filed by PNC Bank in the Fred E. Gerber, Sr. Trust, docketed
at No. 21-1998-0195 and the Mildred J. Gerber Trust, docketed at No. 21-2002-0540 by
Order of Court of President Judge George E. Holler dated June 27, 2003. Said Order of
Court is attached hereto as Exhibit "A."
2. Movant, Jacqueline M. Verney, Esquire has undertaken her duties and
responsibilities pursuant to said Order of Court and has amassed bills for said ;york in
connection with the objections against the above referenced Trust accountings.
3. Movant requests this Honorable Court authorize payment to Jacqueline M.
Verney, Esquire for reasonable attorney's fees incurred pursuant to the Order of Court of
June 27, 2003 from the Estate of Mildred J. Gerber.
WHEREFORE, Jacqueline M. Verney, Esquire requests this Honorable Court
amhorize the payment of reasonable legal fees to Jacqueline M. Verney, Esquire from the
Estate of Mildred J. Gerber.
Respectfully submitted,
', ~
',N'cqu~line M. Verney, Esquire #25~ 67
44 South Hanover Street
Carlisle, PA 17013
(717) 243-9190
IN RE: MILDi~ED J. ~ERBER : IN THE COURT OF COMMON PLEAS
?RUST UNDER AGREEMENT : CUMBERLAND COUNTY
dated December 19, 1997 : COMMONWEALTH OF PENNSYLVANIA
: ORPHANS' COURT
: NO. 21-2002-0540''/
IN RE: FRED E. GERBER TRUST : IN THE COURT OF COMMON PLEAS
UNDER AGREEMENT, dated : CUMBERLAND COUNTY
July 29, lC~94 : COMMONWEALTH OF PENNSYLVANIA
: ORPHANS' COURT DIVISION
: NO. 21-1998-0195
ORD~.R
the Frederick E. Gerber, Ii, accountant and trustee in the above ~eferenced
Tru~t~, and upo~ c~n~ent~ of Jac~ueline Verney Esquire and PNC ~ank,
Guardian of the E~tate ~f Mildred J. Gerber, n~ deceased,
IT IS HE~.EBY ORDERED:
Jc~cquellne M. Verney, Esquire, is hereby substituted for PNC
Bank in the above captioned actions for purposes of prosecuting the
objections filed by PNC Bani<.
~Copies of this ORD~I~ shall be served upon all interested p~rties.
VERIFICATION
I verify' that the facts included in thc within pleading are true and correct based on
information known to me or received from reliable sources. I understand that t:alse
statements herein are made subject to the penalties of 18 Pa. C. S.A. § 4904 relating to
unsworn falsification to authorities.
Dated:
~Jacqu?eline M. Vemey, Esquire d
CERTIFICATE OF SERVICE
1, Jacqueline M. Vemey, Esquire, hereby certify that a true and correct copy of the
attached was served upon the following on the date indicated by placing same in the
United States Mail, postage prepaid addressed as follows:
Richard Rupp, Esquire
355 North 21~t Street
Suite 205
Camp Hill, PA 17011
Marilyn Gerber
717 Market Street #317
Lemoyne, PA 17043
Joanne Book Christine, Esquire
Rhoads & Sinon, LLP
One South Market Square, 12th Floor
Harrisburg, PA 17108
William A. Duncan, Esquire
One Irvine Row'
Carlisle, PA 17013
Date: /r- '/? ~ /
Jacqu~line M. Vemey, Esquire #2~ 67
44 South Hanover Street
Carlisle, PA 17013
(717) 243-9190