HomeMy WebLinkAbout04-10-08In Re: Estate of J. Robert Dougherty : IN THE COURT OF COMMON PLEAS OF
:CUMBERLAND COUNTY, PEN~SYLVAI~A _~
:ORPHANS COURT DIVISION ~ o ~' ~~~~~ `~;
NO. 2006-00171 ~-' ~ !° ~" ;
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MOTION FOR LEAVE TO WITHDRAW AS COUNSEL ~ --
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Ronald E. Johnson, Esquire respectfully represents the following in support of this N~o~ion:
On or about February 23, 2006 Petitioner met with James J. Dougherty and his uncle
David M. Strong regarding the above captioned estate.
2. At that conference it appeared that James J. Dougherty had little understanding of what
was required in administering the estate and David M. Strong took charge of all proceedings thereafter.
3. Your Petitioner's attempts to contact James J. Dougherty were unsuccessful and in fact
your Petitioner is led to believe that he moved at least at one point in time to an unknown address in
South Carolina and he has never had any contact with this office following the probate of the Will.
4. David M. Strong handled all matters pertaining to the estate including but not limited to
selling the real estate using a Power of Attorney executed by James J. Dougherty.
5. At some point the relationship between your Petitioner and David M. Strong became
somewhat contentious and David M. Strong indicated he no longer wanted the estate represented by the
Petitioner.
6. On June 29, 2006 David M. Strong executed a letter releasing your Petitioner from any
further responsibility for representation of the estate and acknowledged receipt of the J. Robert
Dougherty file. A copy of said letter is attached hereto marked Exhibit "A" and made a part hereof.
7. Since that time your Petitioner has had absolutely no contact from David M. Strong or
James J. Dougherty in spite of sending David M. Strong several letters and placing a phone call to him
which was not returned.
WHEREFORE, Petitioner prays Your Honorable Court to grant Ronald E. Johnson, Esquire
lf;ave to withdraw as counsel in the above captioned estate.
ANDREWS & JOHNSON
By:
Ronald E. son, Esq.
Attorney r Plaintiff
78 W. Pomfret Street
Carlisle, PA 17013
(717) 243-0123
ANDREWS & JOHNSON
Attorneys at Law
78 West Pomfret Street
Carlisle, PA 17013-3216
TAYLOR P. ANDREWS
RONALD E. JOHNSON
June 29, 2006
David M. Strong
405 Walnut Bottom Road
Carlisle, PA 17013
RE: Estate of J. Robert Dougherty
Dear Mr. Strong:
Telephone (717) 243-0123
Telefax (717) 243-0061
For and in consideration of the sum of $1,750, I hereby release to you the file of the J. Robert
Dougherty estate. As a result of releasing this to you I will have no further responsibility as the
attorney for the estate to file the Pennsylvania Inheritance Tax or any additional documents that
maybe due and they are now your responsibility. I further acknowledge that upon the receipt of the
$1,750 fee that all payments due to Andrews & Johnson have been paid in full.
Should you have any questions, please feel free to contact me.
Very truly yours,
ANDREWS & JOHNSON
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R nald E. Johnson
REJ:ss
Enclosure
I hereby acknowledge receipt of the J. Robert Dougherty file
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David M. Strong
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