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IN RE: ESTATE OF IN THE COURT OF COMMON PLEAS
SHARON A. KEEFE, :ORPHANS' COURT DIVISION, OF
Deceased :CUMBERLAND COUNTY, PENNSYLVANIA
NO. 2007-00542
PETITION FOR LEAVE TO WITHDRAW AS COUNSEL
TO THE HONORABLE, THE JUDGES OF SAID COURT:
AND NOW, comes Snelbaker & Brenneman, P. C., and respectfully represents as
follows:
1. The Petitioner herein is Snelbaker & Brenneman, P. C., a professional corporation of
attorneys having its office at 44 West Main Street, Mechanicsburg, PA 17055.
2. Sharon A. Keefe (hereinafter called "Decedent") died intestate on May 17, 2007, in
Cumberland County, Pennsylvania.
3. Decedent's sole heir is her son, namely, Thomas W. Milisavic (hereinafter called
"Respondent') whose last known address is 339 Orchard Street, Old Forge, PA 18518-1946.
4. Respondent engaged Petitioner to represent his interests with regard to the
administration of Decedent's estate.
5. Letters of Administration were duly issued to Respondent on June 4, 2007, by the
Register of Wills of Cumberland County, PA. At the same time, Petitioner entered its
appearance as counsel to Respondent and Estate.
6. Petitioner provided all necessary services to Respondent and the Estate to the time for
LAw o~icES making final distribution, at which latter time, Respondent ceased communicating with
SNELBAKER BC
BRENNEMAN, F.C.
Petitioner.
7. On or about June 16, 2010, the Clerk of Your Honorable Court sent "Notice of Failure
to File Status Report" to Petitioner and presumably to Respondent.
8. Because of Respondent's failure to communicate with Petitioner, Petitioner was
~ unable to respond to said Notice in any meaningful manner.
9. On June 22, 2010, Petitioner communicated with Respondent by letter, a true copy of
which is attached hereto marked "Exhibit A" and incorporated by reference thereto, requesting
Respondent's contact with Petitioner in order to respond to the Clerk's notice cited in paragraph 7
above.
10. Respondent has not contacted the Petitioner in response to the request of June 22,
2010, or for any other reason.
11. Respondent has failed and refused to pay a balance owing for Petitioner's
professional services.
12. Without Respondent's cooperation and communication, Petitioner cannot perform
any further services to Respondent or the Estate and requests leave to withdraw as counsel of
record in said Estate and as attorney for Respondent.
WHEREFORE, Petitioner respectfully requests your Honorable Court to grant it-leave to
withdraw as counsel to the Decedent's estate and as attorney for Respondent.
SNELBAKER & BRENNEMAN, P. C.
LAW OFFICES
SNELBAKER EC
BRENNEMAN, F.C.
By:
Ric and C. Snelbaker, Esquire
44 W. Main Street
Mechanicsburg, PA 1.7055
(717) 697-8528
Petitioner
Date: Juf~ / a, ~•,~~
-2-
VERIFICATION
COMMONWEALTH OF PENNSYLVANIA)
COUNTY OF CUMBERLAND
SS.
Richard C. Snelbaker, Esquire, being duly sworn according to law, deposes and says: that
he is a principal in Petitioner's professional corporation and is authorized to make this
verification on Petitioner's behalf; and that the facts set forth in the foregoing Petition are true
and correct to the best of his knowledge, information and belief.
Ric and C. Snelbaker
Sworn to and subscribed before me
this /.?~ day of July, 2010.
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Notary Pu li
~~;At'1'M GF ~' N Y ANW
Notarial Sep
Susan L Matraa, iJohary Public
~anicsburg Boro. Cumberland County
Mh-C9mmission E~ires Nov. 24.2011
1`alrer. Pyerntylv,~ Assodraitnn of Nol~lpt
LAW OFFICES
SNELBAKER &
BRENNEMAN, P. C.
SNELBAKER ~ BRENNEMAN, P.C.
A PROFESSIONAL CORPORATION
ATTORNEYS AT LAW
44 WEST MAIN STREET
MECHANICSBURG. PENNSYLVANIA 17055
RICHARD C. SNELBAKER
KEITH O. BRENNEMAN
717-697-8528
P. O. BOX 318
FACSIMILE (717) 697-7681
Thomas W. Milisavic
339 Orchard Street
Old Forge, PA 18518-1946
Re: Estate of Sharon A. Keefe
Dear Mr. Milisavic:
June 22, 2010
Enclosed is a copy of a notice from the Clerlc of the Orphans' Court of Cumberland
County, Penns~~lvania requiring the filing of a status report pursuant to law as cited in the notice.
This is the second such notice; see n1y notice to you dated April 30, 2010.
Unless you contact me by telephone by noon on Friday, June 2~, 2010, we will initiate
the required procedures to withdraw as your attorney and counsel to your mother's estate. Please
refer to my letter of May 15, 2009, in which this course of action was also indicated.
You will receive no further r~_otice from our office before commencing the withdrawal
process.
RCS:sks
Enclosure
V rv r-aly vorzrs,
Richard C. Snelbaker
EYHIBIT A