HomeMy WebLinkAbout09-13-10-,_,
SALZMANN HUGHES, P.C.
George F. Douglas, III, Esq.
Atty. Id No. 61886
354 Alexander Spring Rd., Suite 1
Carlisle, PA 17015
(717) 249-6333
IN RE:
ESTATE OF EDWARD B. CARRAI,
Deceased
2010 SEP 13 AM I i ~ 26
CLERK OF
oR~uw~s couRT
CUMBERLAINC ~0„ PP.
IN THE COURT OF COMMON PLEAS OF
CUMBERLAND COUNTY, PENNSYLVANIA
ORPHANS' COURT DIVISION
No. 21-09-1155
PETITION TO WITHDRAW AS COUNSEL
To the Honorable Judges of Said Court:
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AND NOW, this ~ 3 day of S~ 2010, George F. Douglas, III, Esquire of Salzmann
Hughes, P.C., avers the following in support of this Petition for Leave of Court to Withdraw as
Counsel:
1. Petitioner is George F. Douglas, III, an attorney with the law firm of Salzmann Hughes, P.C.,
located at 354 Alexander Spring Road, Suite 1, Carlisle, Pennsylvania, 17015.
2. On or about January 11, 2010, Edward B. Carrai, II, Administrator, retained the professional
services of George F. Douglas, III, to assist Mr. Carrai in the administration of the estate of his
late father, Edward B. Carrai.
3. Petitioner has informed the Administrator of his personal liability if he fails to administer this
estate to the best of his ability. Petitioner did cooperate in the estate administration from
approximately January 11, 2010 until April, 15, 2010. Petitioner has attempted on numerous
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occasions to contact the Administrator by email, telephone and first class mail. The
Administrator has not responded and has failed to administer this estate and has failed to
compensate the law firm for services provided.
4. The last written correspondence to the Administrator was a letter sent September 8, 2010,
advising the Administrator that he needed to contact Attorney Douglas, otherwise Attorney
Douglas would have no other choice but to Petition to Withdraw as Counsel. (See, Exhibit
"A", attached.)
5. Because of the lack of response and complete silence from the Administrator, the
administration of the Estate has been unable to move towazd a 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 filed.
6. There aze irreconcilable differences between Petitioner and the Administrator of the Estate in
the administration and conclusion of the Estate.
7. 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.
Respectfully submitted,
SALZMANN HUGHES, P.C.
Dated: R I ~3 1 ~ a By. ~, u~
George F. Douglas, III, squire
Atty. ID No. 61886
354 Alexander Spring Road, Suite 1
Cazlisle, PA 17015
(717)249-6333
A~N[~'~NN
GHES,P.C.
Attorneys at Law
6XP6RIENC6 1N'FCGRITY INNOVATION
79 St. Paui Drive'• Chambersburg, PA • 17201 • (717)263-2121 • Fax: (717) 263-0663
354 Alexander Spring Road • Suite 1 • Carlisle, PA • 17015 • (717) 249-b333 • Fax: (717) 249-7334
239 & Main St. ~ Waynesboro, PA • 17268 • (717) 762-3170 • Fax: (717) 762-0988
105 N. Front St. • Suite 401 • Harrisburg, PA • 17101. • (717j 234-6700 • Fax; (717) 249-7334
*Please reply to Carlisle Office
September 8, 2010
Edwazd B. Carrai, II
610 25ih Street South
Arlington, VA 22202
Re: Estate of Edward B. Carrai
Dear Eddie,
I am contacting you to inform. you that our office must :withdraw our appearance on
behalf of the above-referenced estate due to the non-payment of an overdue invoice.
During our last correspondence, you informed me that you were forwazding me the
payment due in the amount of $5,654.16 which has not been received. The withdrawal of our
appearance does not mean that the current payment .due is being forgiven. A claim on behalf of
our firm will be filed against the estate and other legal means may be necessary in order to collect
the current balance from you. It is not uncommon that heirs of the decedent need to use life
insurance proceeds to administer the estate.
You have been notified imthe past that the Internal Revenue Service and the Pennsylvania
Department of Revenue are both looking to the estate forpayment of tax they feel is due. I have
enclosed the'latest correspondence I have received from them. I am going to send out a notice
that you are now the responsible party for the payment of any obligations of the estate.
Please inform me if you will be using another law firm for the completion of the estate. I
will work with them in transferring the file o their attention.
I recently requested an extension for the estate to file thePennsylvania Inheritance Tax
return which may be filed by February 15, 2011.
ATTORNEYS
G. Bryan Salzmann, Esq..
James D. Hughes, Esq.
Adam R. Schellhase, Esq.
Charles E. Zaleski, Esq.
'Thomas J. Finucane, Esq.
Eileen C. Finucane, Esq.
Stephen E• Patterson, Esg.
Nancy H. Meyers, Esq.
Ann F. DePaulis, Esq.
Patricia R. Brown, Iisq.
William W.'Ihompson, Esq.
Rebecca R. Hughes, Esq.
Susann B. Morrison, Esq.
Laura Rebecca Ables, Esq.•
David H. Martineau, Esq.
Kurt E. Williams, Esq.
Samuel. E. Wiser, Jr., Esq.
George F. Douglas, III, Esq.
Donald E. I.eFever, Esq.
E. Lee Sifnnett, Esq.
Michael J. Imbornone, Esq.
'Also Admitted to Georgia Bar
"~'°' WWW. SALZMANNHUGHES.CQM
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EXHIBIT "A"
Edward B. Catxai, II
September 8, 2010
Page Two
Please contact me with any questions or to instruct me on how you plan to proceed.
Sincerely,
SALZMANN HUGHES, P.C.
,-~---
George F. Douglas, III, Esquire
GFD/kar
Enclosures
CERTIFICATE OF SERVICE
I, George F. Douglas, III, Esquire, hereby certify that a true and correct copy of the foregoing
Petition to Withdraw as Counsel was served this date upon the below referenced individual at the
below listed address via United States Mail, first-class, postage prepaid addressed as follows:
Edwazd B. Carrai, II
610 25`~ Street South
Arlington, VA 22202
Date: By:
George F. Douglas, III, Esquire