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Robert R. Church, Esquire n c ,~ ~~:
LD. # 4 385 ~ r~n w~: <_.:.,~.
Attorney 0 ,~.~ ~..,~ ~ , ,.;
Keefer Wood Allen & Rahal, LLP -~ { ~~'
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210 Walnut Street ~ ~ ~'"' ~~' i`_~~
P.O. Box 11963 ~ ~ ~~'~-~' ;~'~~'
Harrisburg, PA 17108-1963 ~ ~~ `~ `~~
(717) 255-8059 ~ ~ ~~"~
Attorney for Petitioners
IN THE MATTER OF THE
ESTATE OF MARY E. BURDGE,
DECEASED
IN THE COURT OF COMMON PLEAS
CUMBERLAND COUNTY,
PENNSYLVANIA
IN ORPHANS' COURT DIVISION
No. 2008-00305
MOTION TO CONTINUE
AND NOW, this 30th day of November, 2009, come the undersigned Petitioners, by and
through their legal counsel, Keefer Wood Allen & Rahal, LLP, and respectfully move for a
continuance of the hearing on Petitioner's Petition (for appeal of inheritance tax determination),.
as follows:
The Court (by Judge Guido) issued an Order on November 19, 2009, scheduling a hearing
on the Petition for February 12, 2010 at 9:30a.m.
Due to a prepaid vacation on the part of the undersigned counsel, it is respectfully
requested that the hearing be continued to a date in March 2010 or later.
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Pursuant to L.R. 208.2(d), the undersigned counsel certifies that counsel for Respondent,
the Pennsylvania Department of Revenue, concurs with this request.
Continuance of this matter until March or later will also provide the parties with
additional time for settlement discussions.
WHEREFORE, the Petitioners respectfully request this Honorable Court to continue the
hearing in this matter until March 2010 at a date and time determined by the Court.
Respectfully Submitted,
By: ~°- a
Robert R. Church
Attorney I.D. # 40385
Keefer Wood Allen & Rahal, LLP
210 Walnut Street
P.O. Box 11963
Harrisburg, PA 17108-1963
(717) 255-8059
Counsel for Randall D. Burdge and
Manufacturers and Traders Trust Company,
Co-Executors of the Estate of Mary E.
Burdge, deceased, Petitioners
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IN THE MATTER OF THE IN THE COURT OF COMMON PLEAS
ESTATE OF MARY E. BURDGE, :CUMBERLAND COUNTY,
DECEASED :PENNSYLVANIA
IN ORPHANS' COURT DIVISION
No. 2008-00305
VERIFICATION
The undersigned, Robert R. Church, Esquire, hereby verifies and states that:
1. He is counsel for Randall D. Burdge and Manufacturers and Traders Trust
Company, Co-Executors of the Estate of Mary E. Burdge, deceased, the Petitioners in this matter;
2. In such capacity he is authorized to make this Verification for the purposes
expressed in the Motion;
3. The facts set forth in the foregoing Motion are true and correct to the best of his
knowledge, information, and belief; and
4. He is aware that false statements herein are made subject to the penalties for
perjury pursuant to 18 Pa. C. S . § 4904.
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Robert R. Church, Esq.,
Counsel for Petitioner
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Robert R. Church, Esquire
Attorney I.D. # 40385
Keefer Wood Allen & Rahal, LLP
210 Walnut Street
P.O. Box 11963
Harrisburg, PA 17108-1963
(717) 255-8059
Attorney for Petitioner
IN THE MATTER OF THE IN THE COURT OF COMMON PLEAS
ESTATE OF MARY E. BURDGE, :CUMBERLAND COUNTY,
DECEASED :PENNSYLVANIA
IN ORPHANS' COURT DIVISION
No. 2008-00305
CERTIFICATE OF SERVICE RE: MOTION TO CONTINUE
I, Robert R. Church, Esquire, counsel for the Petitioner, hereby certify that I served the
above-described Motion in this matter upon the Respondent's counsel this date by depositing a
true and correct copy of the same in the United States mail, first-class mail, postage prepaid,
addressed as follows:
Office of Chief Counsel
Attn: Lora A. Kurlick, Assistant Chief Counsel
Pennsylvania Department of Revenue
P.O. Box 281061
Harrisburg, PA 17128-1061
KEEFER WOOD ALLEN & RAHAL, LLP
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Date: November 30, 2009 By: ~ ~
Robert R. Church, Esquire
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