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HomeMy WebLinkAbout02-22-08 INRE: IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLV ANIA ESTATE OF ADAM B. MANOCK NO. 2006-00861 (~J PETITION FOR LEAVE OF COURT TO WITHDRAW AS COUNSEL (;, t;o f'..) N ; < -W:--r -.;.::. AND NOW comes the Petitioner, Mark T. Silliker, Esquire, and 4"-:, respectfully requests this Honorable Court grant the following relief: C-,; 1. Petitioner, Mark T. Silliker, is the attorney for the above-captioned estate, having been retained by the Personal Representative, Heather Manock, on or about September 29,2006. 2. Attorney Silliker accompanied the Personal Representative, Heather Manock to the Cumberland County Register of Wills Office on September 29, 2006, at which time a Petition was filed with this Honorable Court, and Letters of Administration were granted. 3. The value ofthe estate in question is approximately $2,000 to $3,000, consisting only ofa 1988 Volkswagen Jetta, a small bank account, as well as a small number of bills. The main purpose of opening an estate was to be able to dispose of the title to the vehicle as well as pay any bills and liquidate the few remaining assets. 4. Since the Petition was filed to open an estate, Attorney Silliker has written four letters to the Respondent/Personal Representative, Heather Manock, requesting that she contact Attorney Silliker in order to complete the administration of the estate. Unfortunately, Respondent, Heather Manock, has not contacted Attorney Silliker. Please see Exhibits "A ", "B", "C", and "D". 5. There is a possibility that sanctions will be entered against Heather Manock as well as Attorney Silliker for failure to proceed with the administration of the estate. Unfortunately, Attorney Silliker cannot proceed without the assistance ofthe Personal Representative, Heather Manock. 6. It is impossible for Petitioner, Mark T. Silliker, to properly represent Heather Manock and the Estate of Adam B. Manock due to the failure of the Personal Representative, Heather Manock, to respond or cooperate. 7. Based upon the aforegoing, Petitioner, Mark T. Silliker, Esquire, respectfully requests this Court permit him to withdraw as counsel for the Estate of Adam B. Manock. WHEREFORE, Attorney Silliker would respectfully request this Honorable Court allow him to withdraw as counsel for the Estate of Adam B. Manock. Date: ;} / IS/ ,? I Respectfully submitted, THE LAW OFFICES OF SILLIKER~R~_~L~_ /~'-... ,/ ,.. Mark T. S illiker, Esquire 5922 Linglestown Road Harrisburg, PA 17112 (717) 671-1500 J.D. No. 33671 SILLlKER & REINHOLD LAW OFFICES 5922 L1NGLESTOWN ROAO HARRISBURG, PENNSYLVANIA 17112 MARK T SILLlKER KRISTIN R. REINHOLD PHONE: (717] 671-1500 FAX: (717] 671-8968 November 1, 2006 Heather Manock 1011 North Front Street, #7 Harrisburg, PA 17102 Dear Heather: I trust you are well. I have enclosed two Short Certificates that I have received from Cumberland County. This should allow you to sell your husband's Volkswagen or otherwise dispose of it. It should also allow you to take possession of his bank accounts. Thereafter, if you could please be so kind as to give me a call, I would be extremely appreciative. In essence, I will need to know an approximate value of the car, an approximate value of his personal property, the exact amount in his bank accounts at the time of his death, and the amount of any and all bills which he had, including funeral expenses. Thereafter, we will prepare a tax return and then the estate will be closed. If there are any questions or problems, please do not hesitate to contact me, and I will be more than happy to assist as best I can. Otherwise, I look forward to hearing from you. ~..'" ......". "".,,, /,- Sincerely, MTS/jkh Enclosures EXHIBIT I ufl" SILLlKER & REINHOLD LAW OFFICES 5922 L1NGLESTOWN ROAD HARRISBURG, PENNSYLVANIA 17112 MARK T. SILLlKER KRISTIN R. REINHOLD PHONE: (717) 671-1500 FAX: (717) 671-8968 March 9, 2007 Heather Manock 2450 Baker Street Harrisburg, PA 17103 Dear Heather: I trust you are well. I have enclosed a copy of a form which I have filed with the Cumberland County Register of Wills. In essence, this certifies that I have informed you that you are entitled to the proceeds of your husband's estate. Obviously, this is a lot of foolish legalese paperwork. However, it is required by law that I advise you of this. In addition to this, if you could please give me a telephone call next week so we can get together in order to fmalize this estate, I would be extremely appreciative. Sincerely. MTS/rsd- Enclosure EXHIBIT i qf;" SILLlKER & REINHOLD LAW OFFICES 5922 lINGLESTOWN ROAD HARRISBURG, PENNSYLVANIA 17112 MARK T SILLlKER KRISTIN R. REINHOLD PHONE: [717) 671-1500 FAX: [717J 671-8968 December 31, 2007 Heather Manock 2450 Baker Street Harrisburg, P A 17103 Dear Heather: I trust you are well. I have enclosed a copy of a letter which I received from the Cumberland County Register of Wills office. In essence, you and I have to do some work on Adam'.s estate, or we are both going to get fined for not complying with the law. Therefore, please give me a call. The forms are fairly simple, and they will not take much time. However, it does have to be done within the next 2 weeks. I would add, Ihope that you and your family had a wonderful Christmas holiday, and I hope that 2008 will be a good year for you. Sincerely, Mark T. Silliker MTS/jc Enclosure EXHIBIT i ~C II SILLlKER & REINHOLD LAW OFFICES 5922 L1NGLESTOWN ROAD HARRISBURG, PENNSYLVANIA 17112 MARK T. SILLlKER KRISTIN R. REINHOLD PHONE: (717] 671-1500 FAX: (717] 671-8968 February 6, 2008 Heather Manock 2450 Baker Street Harrisburg, P A 17103 Dear Heather: I trust you are well. I have enclosed articles of correspondence which I received from the Cumberland County Courthouse. Please contact me immediately. If we do not move ahead and file some papers regarding your husband's estate, each of us could be fined. Please give me a telephone call as soon as possible. MTS/jc Enclosures EXHIBIT I to q