HomeMy WebLinkAbout02-22-08
INRE:
IN THE COURT OF COMMON PLEAS
CUMBERLAND COUNTY, PENNSYLV ANIA
ESTATE OF ADAM B. MANOCK
NO. 2006-00861
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PETITION FOR LEAVE OF
COURT TO WITHDRAW AS COUNSEL
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AND NOW comes the Petitioner, Mark T. Silliker, Esquire, and
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respectfully requests this Honorable Court grant the following relief:
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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:
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Respectfully submitted,
THE LAW OFFICES OF
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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.
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Sincerely,
MTS/jkh
Enclosures
EXHIBIT
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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
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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
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