HomeMy WebLinkAbout03-07-08
IN RE:
IN THE COURT OF COMMON PLEAS OF
CUMBERLAND COUNTY,
COMMONWEAL TH OF PENNSYL VANIA
ESTATE OF GARY LEE BREMER, JR.,
DECEASED
ORPHANS' COURT DIVISION
ESTATE NO. 2006-00906
>:.1
I
_J
':,:';:,t
MOTION TO MAKE RULE ABSOLUTE
-::1
"';'1_
'-"-)
AND NOW comes Andrew H. Shaw, Esquire, attorney of record and avers as follow6::::
1. On or about February 13, 2008, Counsel filed a Petition to Withdraw as Counsel.
2. On or about February 15, 2008, the Honorable Kevin A. Hess issued a Rule to
Show Cause ordering the Executrix to file an answer to Counsel's Petition to Withdraw as
Consel "20 days after service". A copy of the Order is attached hereto and incorporated by
reference as "Exhibit A."
3. To date, Executrix has failed to file said answer.
4. The time permitted by the Court in its Order, attached as Exhibit A, for Executrix
to file an answer has expired.
5. Pursuant to the Court's Order, "the relief requested by Counsel shall be granted
upon the Court's receipt ofa Motion requesting Rule be made Absolute."
WHEREFORE, Counsel requests this Honorable Court to enter an Order making the
Court's Order dated February 15,2007 be made absolute, thereby granting Counsel's Request to
Withdraw.
c~
Respectfull y Submitted:
Date: S -- 7 -- OR'
By:
drew H. Shaw, Es uire
Sup. Ct. LD. No. 87371
200 S. Spring Garden St., Suite 11
Carlisle, P A 17013
(717) 243-7135 (phone)
(717) 243-7872 (facsimile)
~~~~,,=.,
FEB 142008 ,I
~
~.,...;
IN RE:
IN THE COURT OF COMMON PLEAS OF
CUMBERLAND COUNTY,
COMMONWEAL TH OF PENNSYL VANIA
ESTATE OF GARY LEE BREMER, JR.,
DECEASED
ORPHANS' COURT DIVISION
ESTATE NO. 2006-00906
RULE TO SHOW CAUSE
,
AND NOW, this ~ day of February, 2008, upon consideration of Counsel's Petition
To Withdraw As Counsel,
IT IS HEREBY ORDERED AND DIRECTED THAT:
1. A rule is issued upon the Executrix, Stacy A. Miller-Lobdell, to show cause why
the Petition To Withdraw As Counsel, filed by counsel For the Estate of Gary Lee
Bremer, Jr., should not be granted.
2.
.l cJ 04., r
The Executrix shall file an Answer OF} or b@fore
~ .Pvv,'.-
, 2008.
3. If no Answer to the Rule to Show Cause is filed by the required date, the relief
requested by Counsel shall be granted upon the Court's receipt ofa Petition
requesting Rule be made Absolute. If Executrix files an Answer to this Rule to
Show Cause, and the Answer raises disputed issues of material fact, an
evidentiary hearing will then be scheduled.
4.
The Orphans' Court is directed to forward said Answer to this Coutt~ i--:)
._C..:'
, ..-TI
-'~-t
r-<-'
(~.:;
..'
Y FROM RECORO
0., TRUE CoP , hereunto
In Testimony Wherot'\h8 seal
set rl.y hand andCarl." PA
of said Court at · 20 cfj
This _!J y of m;J -
1.
,',,)
P,)
EXHIBIT
I
A
'~'~1 \
\~
CERTIFICATE OF SERVICE
I, Andrew H. Shaw, Esquire, do hereby certify that a true and correct copy of the
following document, Motion to Make Rule Absolute, was served this date on the below
named, by placing same in the United States mail, first-class, postage prepaid thereon,
addressed as follows:
Stacy A. Miller-Lobdell
13 Park Street
Mt. Holly Springs, P A 17065
Kristen B. Hamilton, Esquire
Arnoult, Taccino & Hamilton, LLC
14 N. Main Street, Suite 140
Chambersburg, P A 17201
Attorney for Heather Bremer
Date: ] ~. '7 -- 0 g
Andrew H. Shaw, squire
Sup. Ct. J.D. No. 87371
200 S. Spring Garden Street
Suite 11
Carlisle, P A 17013
(717) 243-7135