HomeMy WebLinkAbout07-27-09k
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Ralph A. Jacobs, Esquire ~ '~ ~``'--~ ~ `'~
Attorney ID No. 21387 ~ ~.~ ~
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Jacobs & Singer LLC ,. ~~ /~^'~
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Suite 705
1515 Market St. ~, j ~ ~' ~ _
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Philadelphia, PA 19102
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Counsel for Resp w
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215-789-3111 ~
Barbara Mann 1Vlumma ra
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IN RE: ESTATE OF IN THE COURT OF COMMON PLEAS OF
ROBERT M. MUMMA, CUMBERLAND COUNTY, PENNSYLVANIA
Deceased
ORPHAN'S COURT DIVISION
N0.21-86-398
PETITION FOR LEAVE TO WITHDRAW APPEARANCE OF COUNSEL
Ralph A. Jacobs, Esquire, counsel for Barbara Mann Mumma, hereby
seeks leave of Court, pursuant to Pa.R.Civ.P. 1012(c), to withdraw as counsel, and in
support thereof states as follows:
1. Petitioner, Ralph A. Jacobs, Esquire, is counsel for Barbara M.
Mumma, a beneficiary under the will of he decedent and an objector in the pending estate
audit proceeding.
2. Ms. Mumma has indicated her wish that Petitioner withdraw his
appearance as counsel and has indicated her intention to appear pro se in future
proceedings in this matter.
3. Ms. Mumma's address is 541 Bridgeview Dr., Lemoyne, PA 17043.
4. The withdrawal of Petitioner as counsel will not delay any stage of the
proceedings.
5. Attached hereto is the Verified Statement of Ms. Mumma indicating
her agreement to the withdrawal of counsel and her intention to appear pro se in any
further proceedings in this matter.
WHEREFORE, it is respectfully requested that leave be granted for the
undersigned to withdraw as counsel for Barbara Mann Mumma, and for Ms. Mumma to
appear pro se in any further proceedings in this matter.
Respectfully submitted,
Ralph .Jacobs, Esquire
Attorney ID No. 21387
Jacobs & Singer LLC
1515 Market St., Suite 705
Philadelphia, PA 19102
215-789-3110
Counsel for Respondent,
Barbara Mann Mumma
Dated: July 21, 2009
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VERIFICATION
I, Ralph A. Jacobs, do hereby verify that the statements and averments
made in the foregoing Petition For Leave Of Court To Withdraw As Counsel are
true and correct to the best of my knowledge, information, and belief. I
understand that the statements made herein are subject to the penalties of 18 Pa.
C.S. §4904 relating to unsworn falsification to authorities.
Ralph A. Jacobs
Dated: July 21, 2009
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JUL-~4-2009 09:39 FROM:BMM 717667202 T0: 18563542245 P.2
VERIFIED STATEMENT OF BARBARA MANN MUMMA
I, Barbara Mann Mumma, in support of the Petition of Ralph A. Jacobs, Esquire,
for leave to withdraw as counsel, do hereby state as follows:
1. I am the daughter of Robert M. Mumma, the decedent in this matter.
2. I have filed objections to the Accounts filed by the Executors.
3. I reside at Bridgeview Dr., Lemoyne, PA 17043.
4. I. am currently represented by Ralph A. Jacobs, Esquire, in this matter.
5. It is my wish that Mr. Jacobs be permitted to withdraw and that I be permitted
to appear prv se in any future proceedings in this matter.
I do hereby verify that the foregoing statements are true and correct to the best of
my knowledge, information., and belief. l understand that the statements made herein are subject
to the penalties of 18 Pa. C.S. §4904 relating to unsworn falsification to authorities.
Dated: July. 21, 2009 ~ iy~ ~'-'
Barbara Mann Mumma
CERTIFICATE OF SERVICE
I, Ralph A. Jacobs, hereby certify that on July .2`}- , 2009, I caused a copy of the
foregoing Petition For Leave To Withdraw As Counsel to be served via first class U.S. Mail
upon the following:
George B. Faller, Jr., Esquire
Martson Deardorff Williams & Otto, P.C.
Ten East High Street
Carlisle, Pennsylvania 17013-3015
Brady L. Green, Esquire
Morgan, Lewis & Bockius LLP
1701 Market Street
Philadelphia, PA 19103-2921
Robert M. Mumma, II, pro se
840 Market Street
Suite 164
Lemoyne, PA 17043
Barbara Mann Mumma
541 Bridgeview Dr.
Lemoyne, PA 17043
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Ralph A. Jacobs