HomeMy WebLinkAbout12-31-09IN THE COURT OF COMMON PLEAS
OF CUMBERLAND COUNTY, PENNSYLVANIA
ORPHANS' COURT DIVISION
IN RE:
Estate of Robert J. Noonan, Jr., Deceased
No. 2008-00906
PETITION FOR COURT APPROVAL
TO WITHDRAW AS COUNSEL FOR
THE ESTATE OF ROBERT J. NOONAN. JR.
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AND NOW, COMES The Law Offices of Peter J. Russo, P.C., attorneys for the
Estate of Robert J. Noonan and Executor, Thomas P. Noonan, (hereinafter "Counsel")
and files this Petition for Court Approval to Withdraw, and in support thereof, states the
following:
1. Counsel was retained by Thomas Noonan who currently resides at
331 Stumpstown Rd, Mechanicsburg, PA 17055, on or about August 1, 2008.
2. On or around August 6, 2008 Counsel prepared a Petition for Probate and
Grant of Letters and the Estate Information Sheet for Thomas to file.
3. On or around September 8, 2008, Cumberland County Register of Wills,
Glenda Farner issued Certificate of Grant of Letters certifying Thomas Noonan as the
Executor of the Estate of Robert J. Noonan, Jr.
4. Counsel continued to represent the Estate of Robert J. Noonan, Jr. and
collect the necessary information to file the Revenue 1500 and close the pending
estate.
5. Counsel has tried to contact Thomas Noonan numerous times requesting
documents for the Revenue 1500 and Thomas Noonan has failed to respond.
g. Counsel is unable to finalize the estate or Revenue 1500 without the
information requested.
7. Despite number of letters, telephone calls and a-mails to Thomas Noonan
disclosing the need to withdraw from the case in the event he fails to contact Counsel's
office, Thomas Noonan continues to be recalcitrant and willingly disregard Counsel's
requests.
8. The attorney client relationship has broken down to the point where
Counsel is unable to continue to represent Thomas Noonan as the Executor of the
Estate of Robert J. Noonan, Jr.
WHEREFORE, the Law Offices of Peter J. Russo, P.C. respectfully requests this
Honorable Court to grant its Petition to Withdraw as Counsel for the Estate of Robert J.
Noonan, Jr. in the above-captioned matter.
Respectfully submitted,
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Date: 1 LAW OFFICES OF P . RUSSO, P.C.
Petitioners
Peter J. Russo, Esquire
ID No. 72897
Elizabeth J. Saylor, Esquire
ID No. 200139
5006 E. Trindle Road, Suite 100
Mechanicsburg, PA 17050
PH: 717-591-1755
FX: 717-591-1756
IN THE COURT OF COMMON PLEAS
OF CUMBERLAND COUNTY, PENNSYLVANIA
IN RE:
: No. 2008-00906
Estate of Robert J. Noonan, Jr., Deceased
CERTIFICATE OF SERVICE
I, Ashley R. Sipe, hereby certify that I am on this day serving a copy of the
attached Petition upon the person(s) and in the manner indicated below:
US Regular Mail and First Class Certified Mail
Thomas Noonan
331 Stumpstown Rd
Mechanicsburg, PA 17055
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shley . S pe, Paraleg I
Date: