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HomeMy WebLinkAbout01-15-09KOPE & 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 c7 ~~ o r _ ' -t , c7 ~ -' -: ~-- -, ~; - ._ _ ~Ii ,~q ... , V i ... _._ ~ l ~ '~ ~ T. v o IN RE: ESTATE OF SANDRA K. : IN THE COURT OF COMMON PLEAS OF ROMBERGER, :CUMBERLAND COUNTY, PENNSYLVANIA Deceased ORPHAN'S COURT DIVISION No. 2007-00751 PETITION FOR LEAVE TO WITHDRAW AS COUNSEL AND NOW COMES Shane B. Kope, Esquire, and files the following Petition for Leave to Withdraw as Counsel and in support thereof avers as follows: 1. Petitioner is Shane B. Kope, Esquire, who is presently counsel of record for the personal representative, Christopher Arrigo, in the above-captioned matter (hereinafter referred to as "Petitioner".) 2. Respondent is Christopher Arrigo, personal representative, in the above- captioned matter, with the address of 68 Regency Woods North, Carlisle, PA 17015 (hereinafter referred to as "Respondent".) 3. Petitioner has represented Respondent, pursuant to the above-docketed estate action since on or about April 24, 2007. 4. During the course of Petitioner's representation of Respondent, Respondent has consistently ignored phone calls and attempts to communicate regarding the matter with C Petitioner. Petitioner has not communicated with Respondent for several months and has therefore been unable to effectively represent the Respondent. 5. Respondent has undermined Petitioner's ability to competently represent him. 6. Petitioner believes that there has been a breakdown in the attorney/client relationship as a result of the above and Petitioner accordingly requests permission to withdraw as counsel for Respondent. 7. Petitioner's withdrawal as counsel for Respondent will have no material adverse effect on Respondent's interests pursuant to Pennsylvania Rule of Professional Conduct 1.16. 8. Petitioner has supplied a copy of this Petition for Leave to Withdraw as Counsel upon Respondent. 9. Petitioner, Shane B. Kope, Esquire, respectfully request that he be allowed to withdraw as counsel for Respondent due to the mutual termination of the attorney/client relationship. WHEREFORE, Petitioner respectfully requests that this Honorable Court permit Shane B. Kope, Esquire to withdraw as counsel for the personal representative, Christopher Arrigo. Date: ~~i S ~p ~~ _ Respectfully submitted, ~fi"ane B. l~op~~ Esquire KOPE & ASSO~I~TES, LLC Supreme Court 1D 2207 CERTIFICATE OF SERVICE I, Shane B. Kope, Esquire, hereby certify that on January 14, 2009, I served a copy of the within Petition by depositing the same in the United States Mail, first class, postage prepaid in Camp Hill, Pennsylvania, addressed as follows: Christopher Arrigo 68 Regency Woods North Carlisle, PA 17015 (Personal Representative) Respectfully Submitted, KOPE & ASSOCIATES, LLC _._.... _a.... __ __ -- ~._ By: _H~k~epe; E~ ire 4660 Trindle Road Suite 201 Camp Hill, PA 17011 (717) 761-7573