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HomeMy WebLinkAbout04-25-08 INRE: IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA EST A TE OF ADAM B. MANOCK NO. 2006-00861 PETITION TO MAKE RULE ABSOLUTE AND NOW comes the Petitioner, Mark T. Silliker, Esquire, and respectfully avers the following: 1. Petitioner, Mark T. Silliker, is the attorney for the above-captioned t~ = ,--" c;;;> estate, having been retained by the Personal Representative, Heather Manock/oroor about -- :-rJ :::..... ,:\ '--J :;::', --'--1 September 29,2006. ('0 Ul -' ~--:=~:i C~~ -a . .. :..,;. J: 2. Since the Petition was filed to open an estate, Attorney Sillikt~1Vrote ":7 four letters to the Respondent/Personal Representative, Heather Manock, requesting that U1 she contact Attorney Silliker regarding this estate. Unfortunately, Respondent, Heather Manock did not contact Attorney Silliker. Copies of the letters are attached to the Petition for Leave of Court to Withdraw as Counsel. 3. As a result of the aforegoing, Petitioner, Mark T. Silliker, filed a Petition for Leave of Court to Withdraw as Counsel on or about February 22, 2008. A Rule to Show Cause was then issued by this Honorable Court on February 27, 2008. 4. A copy of the Rule to Show Cause was then mailed to Respondent, Heather Manock on March 4, 2008, by Certified Mail to her present address. Respondent accepted service of the Certified Mail on March 27, 2008. ~ 5. A second copy of the Rule to Show Cause was mailed to Heather Manock by regular mail with a Certificate of Mailing. That letter has not been returned by the post office. 6. At this point, Heather Manock was advised by Certified Mail on March 27,2008, as well as by regular mail on March 28, 2008, as per the Rule to Show Cause. Unfortunately, she has not responded. 7. It is respectfully averred that Attorney Silliker has made a good-faith effort to make contact with the Respondent. Indeed, Attorney Silliker has achieved valid service upon the Respondent, and she has been given notice of his Petition to Withdraw as Counsel. Unfortunately, Respondent, Heather Manock, has not contacted Attorney Silliker to cooperate in any way. Therefore, Attorney Silliker is unable to proceed in this case. WHEREFORE, Petitioner, Mark T. Silliker, respectfully requests this Honorable Court make said Rule Absolute and allow Mark T. Silliker to withdraw as attorney for the Estate of Adam B. Manock. Date: L., / ;,/; /' d Respectfully submitted, THE LAW OFFICES OF SILLIKER & REINHOLD .~ ~/?''''''' ///,.,v- _' Mark T. Silliker, Esquire 5922 Linglestown Road Harrisburg, PA 17112 (717) 671-1500 J.D. No. 33671 INRE: : IN THE COURT OF COMMON PLEAS : CUMBERLAND COUNTY, PENNSYLVANIA ESTATE OF ADAM B. MANOCK : NO. 2006-00861 CERTIFICATE OF SERVICE The undersigned, Joanna Cain, hereby certifies that a copy of a Petition to Make Rule Absolute was mailed to Heather Manock on April 22, 2008, by first-class mail, addressed as follows: Heather Manock 2450 Baker Street Harrisburg, P A 17103 I hereby certify that the aforegoing is true and correct to the best of my knowledge, information and belief. I understand that false statements herein are made subject to the penalties of 18 Pa.C.S. ~4904 relating to unsworn falsification to authorities. Date: 1-/ C);) /0 i?, I / .' 'v tcJu..,'\. INRE: : IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA ESTATE OF ADAM B. MANOCK NO. 2006-00861 CERTIFICATE OF SERVICE The undersigned, Renee Dreisbach, hereby certifies that a copy of a Petition for Leave of Court to Withdraw as Counsel as well as Rule to Show Cause was mailed to Respondent, Heather Manock, on March 4, 2008, by Certified Mail, as well as on March 28, 2008, by first-class mail, postage pre-paid, Certificate of Mailing attached, addressed as follows: Heather Manock 2450 Baker Street Harrisburg, PA 17103 I hereby certify that the aforegoing is true and correct to the best of my knowledge, information and belief. I understand that false statements herein are made subject to the penalties of 18 Pa.C.S. ~4904 relating to unsworn falsification to authorities. Date: q (;2 { fa$? ~A~~ Renee Dreisbach U.S. Postal Service TM CERTIFIED MAILTM RECEIPT (Domestic Mail Only; No Insurance Coverage Provided) I"- ....D ru [J"" ru ..D .:r ....D Certified Fee Cl Cl Return Receipt Fee Cl (Endorsement Required) Cl Restricted Delivery Fee ! Cl (Endorsement Required) (,: <0 ..D Total Postage & Fees $ ru Sent To., ", C' .' I"- L eC'l.'~zl?,-:- 1;y1,O( V1 r"Y' k Cl Si;eei.Apnvo~- _'__n_ nL.@"/~(;fl::,"\3~~----J--l-~'-'-----oo----'_----- Cl or PO Box No. t.:) I j <<:::1.... Q.."'t.-. ,- s- _________________~ :::l J~ Uei \ I"- City, State, ZIP+4 _'n 0. moo. b~-- -fJ./T4---oo:::,--j--Ci":;;--mn Postmark Here i~ . ;" ~! ~ . . :.... All............. U.S. POSTAL SERVICE CERTIFICATE OF MAILING or ~. MAY BE USED FOR DOMESTIC AND INTERNATIONAL MAil, DOES NOT. . P.O.l.~ ~..~..~. . PROVIDE FOR INSURAN,CE-."OSTMASTER . \Jl~" '. Received From: t t 1\U. r t- ,-€"'l(l Cl 'Q"-i .' . ;,:. \ ~ ~+ W:vJ ,,~. · ,'-; ~~ri&:ry~ ;t{~~~ ~~~Nl' PS Form 3817, Mar. 1989 GPO : 1993 0 - 151-051 Page 1 of 1 H2ffili! I !i~1P Track & Confirm Search Results Label/Receipt Number: 7007 2680 0000 6462 9267 Status: Delivered TtaCt& Collfirm ~ Your item was delivered at 10:58 AM on March 27, 2008 in HARRISBURG, PA 17112. C~~-'!~!!!:) r R~_l!~~f!!!!!'~~) Enter Label/Receipt Number. I_...._.~_..~..... ........._.....~............ ( Site. M'lP Cpn!aGtlJ$ Forms Gov'!S",rviG",s Jobs priv!\GY PPI!cy TElmw.Qf Us", N!\Jioni\1 il.PrElmit;lrACGp@IS Copyright@ 1999-2007 USPS. All Rights Reserved. No FEAR Act EEO Data FOIA . ! 'm-iU hl"t"";w.,.; . ~ \;~:V'l"'l,.~~l:4-~ 'ti'.ri- _ IW1~~:~<ll..~:,~j .. i'!l<liNllii~lli' http://trkcnfrml.smi.usps.com/PTSlntemetWeb/InterLabelInquiry .do 04/21/2008 INRE: : IN THE COURT OF COMMON PLEAS : CUMBERLAND COUNTY, PENNSYLVANIA ESTATE OF ADAM B. MANOCK : NO. 2006-00861 CERTIFICATE OF SERVICE The undersigned, Renee Dreisbach, hereby certifies that a copy of a Petition for Leave of Court to Withdraw as Counsel as well as Rule to Show Cause was mailed to Respondent, Heather Manock, on March 4, 2008, by Certified Mail, as well as on March 28, 2008, by first-class mail, postage pre-paid, Certificate of Mailing attached, addressed as follows: Heather Manock 2450 Baker Street Harrisburg, PA 17103 I hereby certify that the afore going is true and correct to the best of my knowledge, information and belief. I understand that false statements herein are made subject to the penalties of 18 Pa.C.S. ~4904 relating to unsworn falsification to authorities. Date: !:[ (;2 f /Oq ~~~p~ Renee Dreisbach f- [ -- 'C) o~ "}c,= - ::0 :-,,-l :,} :> . '.> 1._' . c.' U.S. Postal Service TM CERTIFIED MAILM RECEIPT (Domestic Mail Only; No Insurance Coverage Provided) l'- .J] ru IT" ru .J] ::r .J] c:J c:J Return Receipt Fee c:J (Endorsement Required) c:J Restricted Delivery Fee c:J (Endorsement Required) otl .J] Total Postage & Fees $ ru ""-'..'1.'-:;.'\\1}. '--~ .~-~";.. -~:~stmark ~~ ~ \C~7/~J4/-,:\;!!f:; l'- ~~~~_~~ ------Hqa~. ... . -:- ~.. . ;-, . _ j.,l g Street. Apt. No.; RT ~ ___f1_c:t::~________________ l'- ~t~~~~;-;~+f2l-y.5Q.--- CL -~:____~r_______________________ . - h (J71 J at. U.S. POSTAL SERVICE CERTIFICATE OF MAILING MAY BE USED FOR DOMESTIC AND INTERNATIONAL MAil, DOES NOT PROVIDE FOR INSURANCE-POSTMASTER Received From: PS Form 3817, Mar. 1989 GPO : 1993 0 - 151-051 .I. Hl\,..l\. OC L-onnrm Page 1 of 1 HQme IH@!p Track & Confirm Search Results Label/Receipt Number: 7007 2680 0000 6462 9267 Status: Delivered Tl'8Ctca Confirm ~ Enter Label/Receipt Number, L Your item was delivered at 10:58 AM on March 27,2008 in HARRISBURG, PA 17112. C A~~ >;1 fRetum to U$P$.cqm'Ht1tIto >") -~-,--,"----~-_...", '..,~-~_.__..-----,,--------_.~ Site Map Contact Us Forms Gov't Services Jobs PriVacy Policy Terms of Use National & Premier Accounts Copyright@) 1999-2007 USPS. All Rights Reserved. No FEAR Act EEO Data rOIA . _ i"'l!n,,,iiI~r!!" http://trkcnfrm1.smLusps.comIPTSlntemetW eb/InterLabelInquiry .do 04/21/2008