HomeMy WebLinkAbout08-28-09KOPE & ASSOCIATES, LLC
By: Shane B. Kope, Esquire
Attorney ID 92207
395 St. Johns Church Road, Suite 101
Camp Hill, PA 17011
(717) 761-7573
sbkope@kopelaw.com
IN RE: ESTATE OF DONALD A
LITTLE,
Deceased
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Attorney for Respondent
IN THE COURT OF COMMON PLEAS OF
CUMBERLAND COUNTY, PENNSYLVANIA
ORPHAN'S COURT DIVISION
No. 2007-00798
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, Emma Kerchner, in the above-captioned matter (hereinafter
referred to as "Petitioner".)
2. Respondent is Emma Kerchner, personal representative, in the above-captioned
matter, with the address of 314 East Main Street, Mechanicsburg, PA 17055
(hereinafter referred to as "Respondent".)
3. Petitioner has represented Respondent, pursuant to the above-docketed estate
action since on or about July 27, 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
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 her.
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, Emma
Kerchner.
Date:
Shane e, Esquire
KO & ASS IATES, LLC
S preme Court ID 2207
CERTIFICATE OF SERVICE
I, Shane B. Kope, Esquire, hereby certify that on Augusta", 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:
Emma Kerchner
314 East Main Street
Mechanicsburg, PA 17055
(Personal Representative)
Respectfully Submitted,
KOPE & ASSOCIATES, LLC
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By:
Shane e, Esquire
39 t. Johns hurch Rd.
uite 101
p Hill, PA 17011
(717) -