HomeMy WebLinkAbout12-17-09ESTATE OF MARYANN COLOMBO, REGISTER OF WILLS
deceased
CUMBERLAND COUNTY
• ESTATE NO. 21-08-015 "'
. o
. . . . . . . . . . . . . . . . . . . . . . . : . ,~ ~.., c-m,
. ~,~ ~ 'J
MOTION FOR LEAVE TO WITHDRAW ~c-~~, ~
To the Honorable Judges of said Court: ;n ..--+`.J ^..'
N
Patrick N. Coleman, Esquire, Tellie & Coleman, PC, hereby moves to withdraw
as counsel for the Estate of MaryAnn Columbo, deceased, in the above-captioned
case, respectfully represents:
1. Petitioner is Patrick N. Coleman, Esquire of Tellie & Coleman, P.C.,
attorneys at 310 East Drinker Street, Dunmore, PA.
2. Respondent is Russell Columbo, Administrator of the Estate of MaryAnn
Columbo with an address of 2064 Lake Ariel Highway, Lake Ariel, PA 18436.
3. Petitioner was appointed as attorneys of the Estate of MaryAnn Columbo
by Russell Columbo on or about February 14, 2008.
4. Petitioner seeks to withdraw due to lack of cooperation by Respondent
to conclude the business of the estate and inability to obtain monies from Respondent
in order to pay the appropriate inheritance tax and also for payment of the outstanding
counsel fees and expenses.
5. At the end of November, 2009, Petitioner has notified Respondent of
withdrawal notifying him to obtain replacement counsel.
6. Respondent has been advised by Petitioner of the filing of this Petition to
Withdraw by letter. A true and correct copy of this Petition has been sent to Plaintiff by
~:- -~~?
~_.~
,.~ , .,:.
r ~ t ,.._`.;ti
_ ~~ ~ -:
.c. '
-:..~..~
certified mail, return receipt requested and by a-mail.
7. No prejudice will be suffered by the Respondent as he has had ample
opportunity to secure alternate counsel.
WHEREFORE, under Rule L1.2C. Petitioners respectfully request that their
appearance be withdrawn for Respondent, personal representative of the Estate of
MaryAnn Columbo, and that Tellie & Coleman, P~e~emoved as attorneys of record.
Date:
P14TRICK N. COLEMAN, ESQUI
Tellie & Coleman, PC
310 East Drinker Street
Dunmore, PA 18512
570/969-2828
ESTATE OF MARYANN COLOMBO, REGISTER OF WILLS
deceased
CUMBERLAND COUNTY
ESTATE NO. 21-08-0159
.. ....................... ... .... ...
..............................:.....:...
WITHDRAWAL OF COUNSEL
Tellie & Coleman, PC, hereby withdraws as couns f r e Estate of MaryAnn
Columbo, in the above-captioned matter.
PATRICK N. COLEMAN, ESQUI
Tellie & Coleman, PC
310 East Drinker Street
Dunmore, PA 18512
570/969-2828
N
s-s
"
"~ :
~::
"
~
~ 7
:L,_r
.--~' - ~_-z
~. -.
r ^'~y
ESTATE OF MARYANN COLOMBO, REGISTER OF WILLS
deceased •
CUMBERLAND COUNTY
ESTATE NO. 21-08-0159
...................... .... ....... ..
......................:.....:........:..
CERTIFICATE OF SERVICE
I, Patrick N. Coleman, Esquire, do hereby certify that I served a true and
correct copy of the foregoing Petition of For Leave To Withdraw on Respondent by
United States Postal Service, First-Class Mail on the date and at the
address indicated below.
Russell Columbo
2064 Lake Ariel Highway
Lake Ariel, PA 18436
DATE: 2'~- 0~1
T
COLEMAN, P.C.
Patrick N. Coleman, Esquire
Tellie & Coleman, PC
310 East Drinker Street
Dunmore, PA 18512
570/969-2828
c~ °'
; J ~:
-~CI3T +
~'7 ~ ""Ca --,.
•.A
T~