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HomeMy WebLinkAbout08-18-08KOPE & ASSOCIATES, LLC By: Shane B. Kope, Esquire Attorney ID 92207 4660 Trindle Road, Suite 201 Camp Hill, Pa 17011 (717) 761-7573 sbkope@kopelaw.com Attorney for Respondent Cam.? n cp r ~ ~, - ,y ,m y - ; Jam, ~ V~~` .) l 1 r ~ • _ T) _.. .. _ -" -~ t~ =-~ r.; . . .~-° r.; 1N RE: ESTATE OF JACK EDWARD : IN THE COURT OF COMMON PLEAS OF HENRY, Late of the Borough of :CUMBERLAND COUNTY, PENNSYLVANIA New Cumberland, Cumberland County Pennsylvania, Deceased :ORPHAN'S COURT DIVISION No. 21-08-0085 MOTION FOR CONTINUANCE TO THE HONORABLE KEVIN A. HESS, JUDGE OF SAID COURT; AND NOW comes the Respondent, Minerva P. Henry (hereinafter "Respondent"), by and through her attorney, Shane B. Kope, Esquire, and moves this court to grant a continuance of the hearing on the Petition for Citations in this matter, and represents as follows: 1. On or about May 29, 2008, a Petition for Citations was filed with the Orphans' Court Division. 2. On or about June 25, 2008, Respondent filed an Answer with New Matter to Petition for Citation. 3. On or about June 25, 2008, Respondent also filed an Election of Spouse to take Against Will and Conveyances. 4. Pursuant to this Court's Order of July 7, 2008, a hearing on the Petition for Citations is currently scheduled for August 29, 2008, at 9:30 a.m. 5. Counsel for Respondent is unavailable to appear for the hearing on the Petition for Citations due to a scheduled prepaid vacation. 6. In order to allow Respondent to appear for the hearing on the Petition for Citations with counsel, it is respectfully requested that the hearing on the Petition for Citations in this matter be continued. 7. Counsel for Petitioner, Edmund G. Myers, Esquire, concurs with this Motion for Continuance. WHEREFORE, the Respondent respectfully requests this Honorable Court to continue the hearing on the Petition for Citations in this matter. Date: August 11, 2008 I.D. 92207 4660 Trindle Road, Suite 201 Camp Hill, PA 17011 (717) 761-7573 Respectfully Submitted, KO SSOCIATES, LLC (( .i e . Kope, Esq. KOPE & ASSOCIATES, LLC By: Shane B. Kope, Esquire Attorney ID 92207 4660 Trindle Road, Suite 201 Camp Hill, Pa 17011 (717) 761-7573 sbkope@kopelaw.com Attorney for Respondent IN RE: ESTATE OF JACK EDWARD : IN THE COURT OF COMMON PLEAS OF HENRY, Late of the Borough of :CUMBERLAND COUNTY, PENNSYLVANIA New Cumberland, Cumberland County Pennsylvania, Deceased :ORPHAN'S COURT DIVISION No. 21-08-0085 CERTIFICATE OF SERVICE I, Shane B. Kope, Esquire, hereby certify that on August 12, 2008, I served a copy of the foregoing Motion for Continuance by first class, United States mail, to the following: Edmund G. Myers, Esquire Johnson, Duffie, Stewart & Weidner, P.C. 301 Market Street P.O. Box 109 Lemoyne, PA 17043 4660 Trindle Road, Suite 201 Camp Hill, PA 17011 (717)761-7573