HomeMy WebLinkAbout08-19-10IN THE COURT OF COMMON PLEAS OF
CUMBERLAND COUNTY, PENNSYLVANIA
ORPHANS COURT DIVISION
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In Re: Estate of Harold F. Wiley, Sr. No. 21-08-1129 -o-z, ~ r,,, ,
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MOTION FOR CONTINUANCE ~ ~ ~ ° ~=-
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And now, this 19 day of August, 2010, comes Bernadine Wiley, Movant, by her counsel, '
Sean M. Shultz, Esquire, and respectfully represents the following:
1. Movant, Bernadine Wiley is the daughter of the Decedent, Harold F. Wiley, Sr., and
resides in Urbandale, Iowa.
2. A Rule was issued by the Court on June 4, 2010, and a Hearing in the above-
captioned case is scheduled for August 20, 2010, at 9:30 a.m. before the Honorable Kevin Hess.
3. Peggy Nieves, Executrix of the Estate of Harold F. Wiley, Sr., has filed for
bankruptcy and the instant matter is subject to the automatic stay under the Bankruptcy Code.
4. Lee Oesterling, Esquire, attorney of record for the Estate of Harold F. Wiley, Sr.,
concurs with the request for continuance.
5. The Honorable Kevin Hess has been assigned to this matter.
6. Movant requests that the hearing be continued for a minimum of ninety (90) days
from August 20, 2010.
WHEREFORE, Movant respectfully requests this Honorable Court continue the Hearing
scheduled for August 20, 2010, at 9:30 a.m.
Respectfully Submitted,
LAW OFFICE OF SEAN M. SHULTZ, PC
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Sean M. Shultz, Esquire
Attorney ID No. 90946
4 Irvine Row
Carlisle, Pennsylvania 17013
(717)701-8412
Attorney for Movant
IN THE COURT OF COMMON PLEAS OF
CUMBERLAND COUNTY, PENNSYLVANIA
ORPHANS COURT DIVISION
In Re: Estate of Harold F. Wiley, Sr. No. 21-08-1129
VERIFICATION
I VERIFY that the statements set forth in the attached Motion are true and correct to the best
of my knowledge, information and belief. I understand that false statements herein are made subject
to the penalties of 18 Pa. C.S. § 4904 relating to unsworn falsification to authorities.
Date: August 19, 2010
M. Shultz, Esquire
IN THE COURT OF COMMON PLEAS OF
CUMBERLAND COUNTY, PENNSYLVANIA
ORPHANS COURT DIVISION
In Re: Estate of Harold F. Wiley, Sr. No. 21-08-1129
CERTIFICATE OF SERVICE
AND NOW, this 19th day of August, 2010, I, Sean M. Shultz, Esquire, hereby certify that I
have this day served the following person with a copy of the foregoing Motion for Continuance by
first class, United States Mail, postage pre-paid, addressed as follows:
Lee E. Oesterling, Esquire
Lee E. Oesterling & Associates, LLC
42 East Main Street
Mechanicsburg, Pennsylvania 17055
Attorney for Estate of Harold F. Wiley, Sr.
Respectfully submitted,
Sean M. Shultz, Esquire
Attorney ID No. 90946
4 Irvine Row
Carlisle, Pennsylvania 17013
(717)701-8412
Attorney for Movant
LAW OFFICE OF SEAN M. SHULTZ, P.C.