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HomeMy WebLinkAbout05-14-10 C~ N © ~ - COYNE & COYNE P.C. C.~ ~"~ - - -t c~ - , , ~ ~:; , Lisa Marie Coyne, Esq. _ ~~ ~-=~ ~ , -~ ~' Pa. Supreme Ct. No. 53788 -~> ~, 1~; -- ~ - - 3901 Market Street ~ ~' ~'~~ _ _ r° ~ ~' Camp Hill, PA 17011-4227 ' `~ ~- `' '-~ (717) 737-0464 v a ~ ~' `~' IN RE: ESTATE OF HOWARD W. FULLER , Deceased IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA ORPHANS COURT DIVISION No. 21-07-00095 PETITION TO WITHDRAW AS COUNSEL To the Honorable Judges of Said Court: AND NOW, this day of May 2010, Lisa Marie Coyne, Esquire of Coyne & Coyne, P.C., avers the following in support of this Petition for Leave of Court to Withdraw as Counsel: 1. Petitioner is Lisa Marie Coyne, an attorney with the Law Firm of Coyne & Coyne, P.C. located at 3901 Market Street, Camp Hill, Pennsylvania 17011. 2. On or about January 31, 2007, Gerald W. Fuller retained the professional services of Lisa Marie Coyne to assist Mr. Fuller in the administration of the estate of his late father, Howard W. Fuller. 3. Since that time, Attorney Coyne and other employees of the law fine have corresponded and met with the Administrator in order to administer the Estate; however, despite those meetings and telephone calls to the Administrator as well as nLU~~erous written ~~ ~~ correspondence to the Administrator, the Administrator has not cooperated in anv manner so as to administer this estate, yet alone conclude this Estate. 4. Petitioner provided professional services to the Estate to include drafting Inheritance Tax Return and sending a letter to the Administrator with a request for additional information to complete the Inheritance Tax Return, but the Administrator has never provided this information. 5. Petitioner repeatedly attempted to contact the Administrator by telephone and with written correspondence concerning the need to administer this Estate; however, there has been no response from the Administrator except for the Administrator's adult son promising that his father would be in contact with me. 6. The last written correspondence to the Administrator was a memo advising the Administrator that he needed to contact Attorney Coyne by May 5, 2010 otheitivise Attorney Coyne would have no other choice but to Petition to Withdraw as Counsel. (See, Exhibit "A", attached.) 7. Because of the lack of response and complete silence from the Administrator, the administration of the Estate has been unable to move toward to conclusion through no fault of the Petitioner and because of the delay from the Administrator, additional expenses and penalties will, in all likelihood, be imposed once an Inheritance Tax Return is file. 8. There are irreconcilable differences between Petitioner and the Administrator of the Estate in the administration and conclusion of the Estate. 9e No Judge has been previously assigned to this matter. WHEREFORE, the Petitioner respectfully requests this Honorable Court to permit Petitioner to withdraw as attorney of record. Dated: ~ Respectfully submitted, COYNE & COYNE, P.Ce By. f t, Lis Marie Coyne, Es ire 1 Market Street Camp Hill, PA 17011-4227 (717) 737-0464 Pa. S. Ct. No. 53788 Petitioner COYNE & COYNE A PROFESSIONAL CORPORATION ATTORNEYS AT LAW Heny F. Coyne Lisa Marie Coyne Jaime L. High 3901 Market Street Camp Hill, Pennsylvania 17011-4227 717-737-0464 Fay;: 717-737-5161 Mr. Gerald W. Fuller Box 187 Etters, PA 17319 April 30, 2010 Re: Estate of Howard L. Fuller, Deceased Dear Mr. Fuller: On April 16, 2010 I sent you a letter asking for you to contact us immediately about your late father's estate. To date I have not heard from you. If I do not hear from you by WEDNESDAY, MAY 5, 2010, I will petition the court to be removed as the attorney for the estate and you will have to seek new legal representation. Very truly yours, COYNE & COYNE, P.C. . ~~~ ~~~ Lisa 'e Coyne LMC/j lh ~, ~(~1 ~ ~ r ~ ~~~ CERTIFICATE OF SERVICE I, Lisa Marie Coyne, Esquire, of Coyne & Coyne, P.C., hereby certify that true copy of the foregoing Petition to Withdraw as Counsel was served this date upon the below-referenced individuals at the below listed address by way of first class mail, postage pre-paid and facsimile: Mr. Gerald W. Fuller Box 187 Esters, PA 17319 __ J v Dated: ~, i { Lisa 1Vlarie Coyne __ %~