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HomeMy WebLinkAbout11-06-08COYNE & COYNE, P.C. Lisa Marie Coyne, Esq. Pa. Supreme Ct. No. 53788 301 Market Street Camp Hill, PA 17011-4227 (717) 737-0464 IN RE: ESTATE OF DANA M. WINFREY, Deceased IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENLLVANI~ . ~~ m No. Z 1-OS-0321 ~ c7 , ~~ PETITION TO WITHDRAW AS COUNSEL (((~//~~~Q ~ ~ ~~ N T'o the Honorable Judges of Said Court: cx~ j ~ t _.s_ • ~ .. --- AND NOW, this 5TH day of November 2008, Lisa Marie Coyne, Esquire of Coyne & Coyne, P.C., avers the following in support of this Petition to Withdraw as Counsel: 1. Petitioner is Lisa Marie Coyne, an attorney with the Law Firm of Coyne & Coyne, P.C. located at 3901 Market Street, Camp Hill, Pennsylvania 17011. 2. On April 4, 2006, Diann Willey retained the professional services of Lisa Marie Coyne, Esquire to assist Mrs. Willey in the administration of the estate of Mrs. Willey's late daughter, Dana M. Winfrey. 3. Petitioner provided professional services to the Estate to include filing of the ][nheritance Tax Return. 4. Since that time, the Administrator advised Petitioner that she was seeking new representation and the Petitioner was to do, "no further work on the Estate". 5. The Cumberland County Register of Wi11s notified Petitioner as the attorney of record that status report filing is due. 6. There are irreconcilable differences between Petitioner and Administrator of the Estate in the administration and conclusion of the Estate. 7. No Judge has been previously assigned to this matter. ~F WHEREFORE, the Petitioner respectfully requests this Honorable Court to permit Petitioner to withdraw as attorney of record. Dated: /~~ 5~ ~~~ -T~ Respectfully, COYNE & COYNE, P.C. r? By: "V~--- L~ a Marie Coyn Esquire 3901 Market Street Camp Hill, PA 17011-4227 (717) 737-0464 Pa. S. Ct. No. 53788 Petitioner CERTIFICATE OF SERVICE I, Lisa Marie Coyne, Esquire, of Coyne & Coyne, P.C., hereby certify that true copy of the foregoing Motion to Withdraw as Counsel was served this date upon the below-referenced individuals at the below listed address by way of first class mail, postage pre-paid and facsimile: Ms. Diann Willey 41 Oak Avenue Camp Hill, PA 17011 ~ C~ ~- Dated:.~~ 5~ 7-f/~ r ~ a Marie Co e