HomeMy WebLinkAbout09-22-09~ ~' : IN THE COURT OF COMMON PLEAS
:CUMBERLAND COUNTY, PENNSYLVANIA
ESTATE OF :ORPHANS' COURT DIVISION
JAMES REED DONITHAN,
Deceased. :FILE NO.2006-00845
PETITION TO WITHDRAW c~ o
AS COUNSEL OF RECnRn ~ N ~, ,z
.. , N ~: 3
AND NO W comes Gates Halbruner Hatch & Guise, P. C., (hereinafter the P~' `J ~
~r, )bond ~ ~ ,'-
requests that this Honorable Court release Gates, Halbruner, Hatch & Guise, P.f~~~un~of ~=n~ Win`
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record for Roberta P. Gilley, Administratrx of the Estate of James Reed Donithan, and in support ' ~ ~'
thereof avers the following:
Craig A. Hatch, Esquire, of Gates, Halbruner, Hatch & Guise, P.C., met with
Roberta P. Gilley on September 25, 2006, to review the administration ofthe estate ofher late father,
James Reed Donithan, who died on September 14, 2009.
On September 27, 2006, the Register of Wills issued Letters of Administration to
Roberta P. Gilley as Administratrx (hereinafter the "Administratrix") of the Estate of James Reed
Donithan (hereinafter the "Decedent's Estate").
On October 3, 2006, Roberta P. Gilley countersigned the letter of representation
provided to her by the Petitioner.
4. The Petitioner prepared Notices of Estate Administration and filed the Certification
of Notice Under Rule 5.6(a), published notice of the estate in the Cumberland Law Journal and the
Patriot-News, and sent the required notice to the Department of Public Welfaze on behalf of the
Administratrx.
5. Creditor claims have been filed against the Decedent's Estate and the Petitioner
has received notice of the claims and forwazded the notices to the Administratrx.
6. The Petitioner has sent several letters to the Administratrix, and has requested
information from the Administratrix, at her last-known address of 767 Merritt Lewis Lane,
Clarksville, TN 37042, but to date has received no response.
7. The Petitioner has not received any communication, either written or verbal, from
the Administratrix since the November 2006.
8. The Petitioner is currently owed legal fees and is unable to represent the Estate
or aid in the administration of the Estate.
WHEREFORE, Petitioner respectfully requests that the Court issue a rule upon the
Administratrix, Roberta P. Gilley, to show cause why the this Court should not grant the Petitioner's
request to withdraw as counsel of record.
Respectfully,
GATES, HALBRUNER, HATCH & GUISE, P.C.
Dated: September ~, 2009
S E. McCarroll, Esquire
Atty. ID #91102
1013 Mumma Road, Suite 100
Lemoyne, PA 17043
(717)731-9600
E-mail: S.McCanoll(a~GatesLawFirm com
(Attorneys for Estate)