HomeMy WebLinkAbout08-17-05
IN RE: TRUST UNDER WILL OF
WARREN F. COOLIDGE FOR BENEFIT
OF THOMAS E. COOLIDGE,
DEVYN L. COOLIDGE. JOSHUA W.
COOLIDGE. et al.
IN THE COURT OF COMMON PLEAS
CUMBERLAND COUNTY, PENNSYLVANIA
ORPHANS COURT DIVISION
NO. 21-01-0684
MOTION FOR EXTENSION OF TIME TO FILE RESPONSE TO
COURT'S ORDER OF .JULY 31. 2006
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AND NOW. comes Patricia R. Brown, Esquire, as Guardian, ad litem for Josep~,M.
Stoltz. a minor. and files this Motion for Extension l1rTime to File Response to Court's Oraer of
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July 31,2006. in support of which she avers as foIIO\\s:
1. Movant. Patricia R. Brown. Esquire was appointed as Guardian ad litem for Joseph M.
Stoltz, a minor. at the request of this Court and by this Court's Order of July 31,2006.
2. Also by this Court's Order of July 31. 2006. this Court issued a rule to show cause why
the relief sought by Petitioners should not he granted, returnable within twenty (20) days
of service of said Order. being August 2 L 20()6.
3. As of the date of this Motion. Movant is not sut1iciently familiar with the issues involved
to form a response and has not been served with nor otherwise received a copy of any
documents by which any party has sought relief from this Court in the above captioned
matter.
4. R. Mark Thomas. Esquire. counsel for Julia M. Stoltz, mother of Joseph M. Stoltz, is
unavailable and Movant has been informed that he will not be available until August 21,
2006.
5. Movant needs additional time to consult \vilh R. Mark Thomas and to procure and review
the Petitioner's request for relief in order to protect the interests of Joseph M. Stoltz.
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6. An extension of time to reply to the Order of July 31, 2006 until August 28, 2006 would
be adequate to allow Movant to adequately protect the rights of Joseph M. Stoltz.
WHEREFORE. Movant prays this Honorable Court to grant an extension of time to
August 28,2006. to tile a response to the Court's Order of July 31,2006.
Respectfully Submitted,
SALZMANN HUGHES, P.c.
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Patricia R. Brown, Esquire
Attorney 1.0. No. 27474
354 Alexander Spring Road, Suite 2
Carlisle. PA 17015
(717) 249-6333
Guardian ad litem for Joseph M. Stoltz
CERTIFICATE OF SERVICE
I hereby certify that on this _ day of August, 2006, I served a true and correct copy of
the foregoing Motion for Extension of Time to Fi Ie Response to Court's Order of July 31, 2006
via United States maiL first class, postage prepaid ,lddressed as follows:
Robert G. Frey, Esquire
5 South Hanover Street
Carlisle. P A 17013
R. Mark Thomas. Esquire
101 South Market Street
Mechanicsburg. P A 17055
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Patricia R. Brown, Esquire