HomeMy WebLinkAbout06-19-08IN THE COURT OF COMMON PLEAS ~__ cn
CUMBERLAND COUNTY, PENNSYLVANIA ~ ` ~ ~ `.~
ORPHANS' COURT ''- ~ ~ ~ -' -
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IN RE: ROBERT G. TRAVER
and O.C. No. 21-2008-OS~t ~' ._
LOIS J. TRAVER ^~
CONSENT MOTION TO CONTINUE ARGUMENT ON
PETITIONER'S MOTION FOR SUMMARY JUDGMENT
AND NOW, comes Ronald E. Traver, by and through his attorneys, James, Smith,
Dietterick & Connelly, LLP, and files this Motion to Continue the hearing for the above-
captioned matter as follows:
1. Petitioner, HCR ManorCare-Camp Hill ("Petitioner") commenced this action by
filing a Petition for Removal of the Agents and Appointment of Trustee to sell Real Property on
or about May 23, 2008.
2. Ronald E. Traver, the son of Robert G. Traver and Lois J. Traver, has been
subpoenaed to testify by Petitioner pursuant to a subpoena signed on June 12, 2008, and received
on June 18, 2008.
3. Ronald E. Traver just retained undersigned counsel to represent him with respect
to matters related to this hearing.
4. Ronald E. Traver has concerns with respect to actions taken by Anna Messimer as
agent under the Power of Attorney for their father, Robert G. Traver; specifically, as it relates to
the Property that was transferred out of Robert G. Traver's name on or about January of 2008,
which is the issue in the Petition.
5. Undersigned counsel is unavailable on Friday, June 20, 2008, due to being out of
town for a family wedding.
6. Undersigned counsel is requesting that this hearing be postponed until the
afternoon of Tuesday, June 24, 2008, or at this Honorable Court's convenience.
7. Petitioner's counsel, Kirk Sohonage, concurs with this motion.
WHEREFORE, undersigned counsel respectfully requests that the hearing be continued
to Tuesday, June 24, 2008 at 1:00 p.m., or at such other time as is convenient for the Court.
Respectfully Submitted:
Date: ~
JAMES, SMITH, DIETTERICK & CONNELLY, LLP
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Attorney ID No. 76084
555 Gettysburg Pike
Suite C-400
Mechanicsburg, PA 17055
717-533-3280
Neil W. Yahn, Esquire
Attorney ID No. 82278
134 Sipe Avenue
Hummelstown, PA 17036
717-533-3280
IN THE COURT OF COMMON PLEAS
CUMBERLAND COUNTY, PENNSYLVANIA
ORPHANS' COURT
IN RE: ROBERT G. TRAVER
and O.C. No. 21-2008-0564
LOIS J. TRAVER
CERTIFICATE OF SERVICE
The undersigned hereby certifies that a true and correct copy of the foregoing Consent
Motion for Continuance was served on the following this 19th day of June, 2008 via facsimile
and First Class Mail to:
Kirk Sohonage, Esquire
Fax: 717-909-5925
417 Walnut Street
4th Floor
Harrisburg, PA 17101
Lowell R. Gates, Esquire
Fax: 717-731-9627
Gates, Halbruner & Hatch, P.C.
1013 Mumma Road
Suite 100
Lemoyne, PA 17043
Respectfully Submitted:
JAMES, SMITH, IETTERICK & CONNELLY, LLP
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1:>ate: C.~ ~ By:
ward P. Seeber, Esquire
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