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Home My WebLink About08-16-10",t' S ~. ~ ~. t C~ 2Q10 AUG 16 PH I ~ ! 9 GLERK OF ORPHAN'S COURT IN RE: ESTATE OF IN THE COURT OF COMMON PLEAS SHARON A. KEEFE, :ORPHANS' COURT DIVISION, OF Deceased :CUMBERLAND COUNTY, PENNSYLVANIA N0.2007-00542 MOTION TO MAKE RULE ABSOLUTE TO THE HONORABLE, KEVIN A. HESS, P.J. AND NOW, comes Snelbaker & Brenneman, P.C., Petitioner in Petition for Leave to Withdraw as Counsel and respectfully represents as follows: I . In response to the aforementioned Petition, President Judge Hess issued an Order of Court on July 15, 2010, in the nature of a rule to show cause, a true copy of said Order being attached hereto as "Exhibit A". 2. In keeping with said Order, Petitioner sent duly certified copies of said Petition and Order to Respondent Thomas W. Milisavic by both certified mail (return receipt requested) and regular first-class mail, on July 20, 2010, copies of Petitioner's cover letters being attached hereto marked "Exhibit B". 3. Attached hereto as "Exhibit C" are the following: A. a true copy of the Certified Mail Receipt addressed to Respondent indicating mailing on July 20, 2010; and B. a true copy of the face of the envelope indicating (1) the Respondent as addressee, (2) the same certified mail number as on the Certified Mail Receipt, (3) that notice was given to Law o~cEs SNELBAKER 8C BRENNEMAN, P.C. addressee on July 21, 2010, August 5, 2010 and August 13, 2010 of the attempted delivery of the certified mail, and (4) that Respondent failed to claim the mail ("UNCLAIMED"). 4. The Notice sent by regular first class mail has not been returned to the sender; therefore, it is presumed that said notice was indeed delivered to and received by Thomas W. Milisavic. 5. The said Thomas W. Milisavic has not contacted Snelbaker & Brenneman, P.C. at any time since the sending/mailing of the notice aforesaid, nor has he filed any response to the rule to show cause. WHEREFORE, Snelbaker & Brenneman, P. C. respectfully requests your Honorable Court to order that the rule to show cause be made absolute and that Snelbaker & Brenneman, P.C., is given leave to withdraw as counsel to the Decedent's Estate and as attorneys for the Administrator. SNELBAKER & BRENNEMAN, P.C. By: Ric d C. e aker, Esquire 44 West Main Street Mechanicsburg, PA 17055 (717)697-8528 Date: August 16, 2010 -2- LAw o~cEs SNELBAKER 8C BRENNEMAN, P.C. 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 the law firm of Snelbaker & Brenneman, P.C., a Petitioner's professional corporation and is authorized to make this verification on said corporation's behalf; and that the facts set forth in the foregoing Motion are true and correct to the best of his knowledge, information and belief. Sworn to and subscribed before me 1~~~ Ric 'd C. Snelbaker this ~~~iay of August, 2010. .~ =~ .% Notary ublic 7H W1/111- Norwaw 3~alrt L IA1~d, N0111y Puhla lOio.~ImdCeu~r ~yy F~pr.sNw.z4,2m1 LAW OFFICES SNELBAKER 8C BRENNEMAN, P.G. ~J JllL ~ 3 2010 IN RE: ESTATE OF : IN THE COURT OF COMMON PLEAS SHARON A. ICEEFE, :ORPHANS' COURT DIVISION, OF Deceased :CUMBERLAND COUNTY, PENNSYLVANIA N0.2007-00542 ORDER OF COURT AND NOW, this ~'~ day of ~~~ , 2010, upon consideration of the within Petitioner for Leave to Withdraw as Counsel, a rule is hereby issued on Thomas W. Milisavic, .Administrator of the Estate of Sharon A. Keefe, Deceased, to show cause why the prayer of said Petition should not be granted. , 2 0 ~ °~1 s ~ .C~i d eru ~ RULE RETURNABLE , at ., ia. Petitioner is directed to serve duly certified copies of said Petition and this Order on r- ~s~ l.J C~ ~StJ ~ ; N Cs ~~~; ~ t..l.. C~ ..:' 'C LA i C" `; ; ~~ ~: c~ J , C ~`~ ~-u ' -~'7 vw,~i~ s o r SNEL AKER BC O BRENNEMAN. P.C. Respondent by (a) certified first class mail,. return receipt requested and (b) by regular first-class mail. 4 C _' ~i_q~~ U ~.],~ Y C!7 u~.a =t .J ~. Cr_. U ~~.- O A TRUE COPY FROM RECUt~iO In Testimony wherof, i hereunto set my hand and the seal of spill court at cariisie, Pa day of 20~ Clerk of the Orp Court Cumberland Craunty E}C~iIBIT A ~~ BY THE COURT: SNELBAKER FS BRENNEMAN, P.C. A PROFESSIONAL CORPORATION ATTORNEYS AT LAW 44 WEST MAIN STREET MECHANICSBURG, PENNSYLVANIA 17055 RICHARD C. SNELBAKER P. O. BOX 318 KEITH O. BRENNEMAN 717-697-8528 FACSIMILE (717) 897.7881 July 20, 2010 Thomas W. Milisavic VIA REGULAR FIRST CLASS MAIL 339 Orchard Street Old Forge, PA 18518-1946 Re: Estate of Sharon A. Keefe, Deceased Dear Mr. Milisavic: On June 22, 2010, we wrote you advising of the need for you to contact us relative to the requirement to file a status report of your administration of your late mother's estate. We advised that we would withdraw as counsel to the estate and you if you did not contact us by June 25, 2010. We received no call, correspondence or other contact as requested. Accordingly, we filed a petition with the local Orphans' Court on July 12, 2010, seeking leave to withdraw as indicated above. The court issued an Order on July 15, 2010, directing that a rule be issued upon you to show cause why the request in the above mentioned petition should not be granted. You are allowed twenty (20) days from your receipt of this letter to file with the Court your reasons, in writing, if any, why the withdrawal should not be granted. A copy of any writing must be served on our firm. Enclosed is a duly certified copy of the above mentioned Petition for Leave to Withdraw as Counsel together with a copy of the Court's Order of July 15, 2010. This notice is being served by both certified mail and regular first class mail in accordance with the Court's Order. Ve • ruly yours, Richard C. Snelbaker RCS/sm Enclosure EXHIBIT B-1 SNELBAKER F3 BRENNEMAN, P.C. A PROFESSIONAL CORPORAII ON ATTORNEYS AT LAW 44 WEST MAIN STREET MECHANICSBURG, PENNSYLVANIA 17055 RICHARD C. SNELBAKER P. O. SOX 318 KEITH O. BRENNEMAN 717-697.8528 FACSIMILE (717) 697.7681 July 20, 2010 Thomas W. Milisavic VIA CERTIFIED MAIL, RETURN RECEIPT 339 Orchard Street REQUESTED, #7004 1350 0004 1256 4811 Old Forge, PA 18518-1946 Re: Estate of Sharon A. Keefe, Deceased Dear Mr. Milisavic: On June 22, 2010, we wrote you advising of the need for you to contact us relative to the requirement to file a status report of your administration of your late mother's estate. We advised that we would withdraw as counsel to the estate and you if you did not contact us by June 25, 2010. We received no call, correspondence or other contact as requested. Accordingly, we filed a petition with the local Orphans' Court on July 12, 2010, seeking leave to withdraw as indicated above. The court issued an Order on July 15, 2010, directing that a rule be issued upon you to show cause why the request in the above mentioned petition should not be granted. You are allowed twenty (20) days from your receipt of this letter to file with the Court your reasons, in writing, if any, why the withdrawal should not be granted. A copy of any writing must be served on our firm. Enclosed is a duly certified copy of the above mentioned Petition for Leave to Withdraw as Counsel together with a copy of the Court's Order of July 15, 2010. This notice is being served by both certified mail and regular first class mail in accordance with the Court's Order. V my yours, Richard C. Snelbaker RCS/sm Enclosure ::EHBIBIT B-2 ~ ~. ~ , , . /~. ru °o c«a"°d Fee 2.80 Q~~~~ n O Req~m Rsclspt Fee c~"'~" v (Enmreesbnt Rea~a~.d) 2.30 ~ ~~ ,°n aeemcua ouw«y Fes .r 5y ,-a ~En0or0e1M"~ Requuedl ~ '` ``~ ~e~eu Posmcs a Fea $ 5-5~ .7 ~~~~~ ~ ~ ~, o ° Thomas W. Milisavic '~~^-339 Orchard Street aPOeancHa _ _ cihssiare;iiw's--~jl~-forge, PA-~$~~$-I946 ------ z ~~ ~~ ° ~' ~ ~ ~ ~° o S> z -~ " ,. ~;, ~ z r~ '~ , v,, y O Z ~ h ~ ~^ ~b _ ,7 r ~ D O. 0 ~ -aDi~- ~ . ~~ ~ , C ~=tDl~= /~ 0 0 ~a~^ ~~~ -DQS- DNr= ~ ~ ~ = wm~_ o'o -m.{ n ~ - as = - ~~ ~~ °~ ~'~~ ~ ~ ~~ O C EXHIBIT C Z A 0 0 a r ru a- Ln Ez >~ '~ N f1 ~ FO a 0 Z ~ n r ._~~. ~, '~__ H,~6LER ~ a n r V EA ~ ~ .o o 3 'v ~ ~ ~ ~ cn JS POSTAGE ^ CERTIFICATE OF SERVICE I hereby certify that I am this date serving a true and correct copy of Motion to Make Rule Absolute upon the Respondent by serving the same by regular first-class mail, postage paid addressed to: Thomas W. Milisavic, Administrator 339 Orchard Street Old Forge, PA 18518-1946 SNELBAKER & BRENNEMAN, P. C. Ric C. Snelbaker, Esquire Snelbaker & Brenneman, P. C. 44 West Main Street P. O. Box 318 Mechanicsburg, PA 17055 Attorneys for Petitioner Date: August 16 , 2010 LAW ~~ SNELBAKER 8C BRENNEMAN, P.G.