HomeMy WebLinkAbout01-18-11~_,
IN RE: IN THE COURT OF COMMON PLE OF ~:
Estate of JAMES F. HULSE, SR. :CUMBERLAND COUNTY, PENNS ~ IA ~-r°
~-s ~ C7 .~
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ORPHANS COURT DIVISION ~ "~ X ~
. No. 10-778 ~ c 1 ~
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PETITION TO WITHDRAW AS COUNSEL ~ u
AND NOW, comes Petitioner, Bradley L. Griffie, Esquire and the l~vl~ firm of
Griffie & Associates and petitions the Court as follows:
1. Your Petitioner is attorney of record for the Estate of James F. Hulsel'~ 5r. in the
above captioned matter.
2. Respondent, James F. Hulse, a/kJa .James F. Hulse, Jr., is an adult '~, i#~dividual
whose last known address is 714 Hogestown Road, Mecl~apicsburg,
Pennsylvania, 17050.
3. Respondent, Donna J. Hulse, is an adult individual whose last known a~d~iress is 2
Park Avenue, Airmont, New York, 10952.
4. Respondent, Nancy Hulse, is an adult individual whose last known add~~ss is 100
Wyandanich Boulevard, Commack, New York, 11725.
5. Petitioner was retained by Respondents to represent the probating of th'~ Will and
the processing of the above referenced estate.
6. Since Petitioner initiated probating the estate, he has been inhibited fro'{nl actively
and aggressively pursuing the processing of this estate, including consolidating of
assets, the payment of debts and ~o forth, due to a lack of coop~tation of
Respondent, James F. Hulse, Jr.
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7. Because of the tremendous delays in responses from Respondent, Jams F. Hulse,
Jr., the processing of this estate has been unnecessarily delayed... and your
Petitioner cannot perform his services appropriately.
8. After repeated requests of Respondent, James F. Hulse, Jr., for coop~r~tion and
responses, those responses are not forthcoming, or, when they are fo~hcoming,
they are extremely delayed.
9. Petitioner previously represented Respondent, James F. Hulse, Jr., i~ a matter
related to this estate, which would create conflict if Petitioner atternp~ed to have
Respondent, James F. Hulse, Jr., removed as one of the current Admin~sttrators of
the estate.
10. Respondents, Donna J. Hulse and Nancy Hulse, have local counsel, li~onald. E.
Johnson, Esquire, through whom. they have and can continue to s~ct~re legal
advice relative to this Petition and further assistance in this estate.
11. Petitioner has been advised by Respondent, James F. Hulse, Jr.'s, childjr~n that he
is presently engaged in over-the-road truck driving and rarely sees hi$ mail, but
that Petitioner may contact him through his daughter at his daughter's Iaddress of
c/o Kerri Friedline, 222 West Simpson Street, Mechanicsburg, PA, 170$5.
12. Despite attempts to contact Respondent, James F. Hulse, Jr., th~dugh his
daughter's address as well, responses from Respondent, James F. Hulse, Jr., have
not be forthcoming.
13. Petitioner will provide a copy of this Petition and the resulting Order of ~,C~ourt and
Rule to Show Cause to the three ,named Respondents, as well asl Attorney
Johnson, with an additional copy being forwarded to the addressed noted in
paragraph 11 above.
WHEREFORE, Petitioner requests your Honorable Court to enter a Rlule upon
Respondents to show cause if any they have as to why Petitioner should not b~ permitted
to withdraw as counsel in the above captioned matter.
Res ectfull submitted, ~I
P y
B G ' e, Esquire
ney f Petitioner
200 North Hanover Street
Carlisle, PA 17013
(717) 243-5551
(800) 347-5552
._ _. _ ___ - _ _ _ __ _ __ __. i i_
I verify that the statements made in the foregoing document are true anQi correct. I
understand that false statements herein are made subject to the penalties of ''1$ Pa.C.S.
Section 4904, relating to unsworn falsification to authorities.
DATE: i ~ II
IN RE: IN THE COURT OF COMMON PLEAS OF
Estate of JAMES F. HULSE, SR. :CUMBERLAND COUNTY, PENNSY~,"VANIA
ORPHANS COURT DIVISION
No. 10-778
CERTIFICATE OF SERVICE
I, Bradley L. Griffie, Esquire hereby certify that I did, the ~~day ~f' January,
2010, cause a copy of the within Petition to Withdraw as Counsel and the resu~t~ng Order
of Court and Rule to Show Cause to be served upon the Respondents, James'F.!,I$ulse, Jr.,
Donna J. Hulse and Nancy Hulse, as well as. Ronald E. Johnson, Esquire, by se~,ing them
by first class mail, postage prepaid, at the following addresses:
James J. Hulse, Jr.
714 Hogestown Road
Mechanicsburg, PA 17050
James J. Hulse, Jr.
c/o Kerri Friedline ',
222 W. Simpson Street
Mechanicsburg, PA 17055
Donna J. Hulse
2 Park Avenue
Airmont, NY 10952
Nancy Hulse
100 Wyandanich Boulevard
Commack, NY 11725
Ronald E. Johnson, Esquire
78 West Pomfret Street
Carlisle, PA 17013
DATE: ~ ( I
5. VKlllV, lily YllV
for/Petitioner