HomeMy WebLinkAbout01-26-110
_..
~Q .:~
.-
-
~
~,
,
r_
r ~ ~ ~~
.
z ~ CT_` ~
,
~ ~; ,-~
LLC
KOPE & ASSOCIATES _ ,--. _ -
-~ ~ ' _ ~ 1 ~~'
:
. ~
~
, ~
.
BY: HILARY P. VESELL, ESQUIRE ~.~. °"
ATTORNEYJD 308358
395 ST. JOHNS CHURCH ROAD, SUITE 101
CAMP HILL, PA 17011
(717) 761-7573
IN RE: ESTATE OF : IN THE COURT OF COMMON PLEAS OF
PETER YANDRIC, :CUMBERLAND COUNTY, PENNSYLVANIA
DECEASED
:ORPHANS COURT DIVISION
:.NO. 21-10-1097
MOTION FOR CONTINUANCE
AND NOW, comes Petitioner, Joan A. Disante, by and through her attorney, Hilary P.
Vesell, Esquire and Kope & Associates LLC, and files this Motion for Continuance as follows:
1. On or about January 3, 2011, David P. Yandrich, Executor of the Estate of Peter
Yandric, commenced this action by filing a Petition to Stay Transfer of Estate Assets and to
Determine Ownership of Transferred Funds in the Amount of $179,853.00 Prior to Decedent's
Death.
2. An Order of Court was received on or about January 11, 2011, scheduling the
Petition to be heard on February 17, 2011.
3. Petitioner, however, needs to obtain complete discovery of all relevant issues.
4. Petitioner will subpoena relevant medical information, a copy of decedent's
current will, and a copy of all prior wills.
5. Obtaining these documents by subpoena will require 20 day advance notice to
each party, including time to issue the actual subpoena, and time to analyze the documents
once received.
6. Petitioner, therefore, respectfully requests that, given her inability to obtain full
discovery before the scheduled hearing date, the Court reschedule argument allowing
Petitioner time to complete full and complete discovery in the interest of justice.
7, Counsel for the Estate has indicated that he does not have an objection to a 60
day continuance.
8. We have also attempted to obtain the concurrence of the Niece's Counsel, but
have been unable to reach her attorney.
WHEREFORE, Petitioner respectfully requests that the Court grant her Motion for
Continuance.
Respectfully Submitted,
KOPE & ASSOCIATES, LLC
Dated: ~ aC~
HILARY P. SELL, ESQUIRE
KOPE ~ ASSOCIATES, LLC
BY: HILARY P. VESELL, ESQUIRE
ATTORNEY ID 308358
395 ST. JOHNS CHURCH ROAD, SUITE 101
CAMP HILL, PA 17011
(717) 76.1-7573
IN RE: ESTATE OF : IN THE COURT OF COMMON PLEAS OF
PETER YANDRIC, :CUMBERLAND COUNTY, PENNSYLVANIA
DECEASED
:ORPHANS COURT DIVISION
NO. 21-10-1097
CERTIFICATE OF SERVICE
I, Hilary P. Vesell, Esquire, hereby certify that on January ~, 2011, I served a
copy of the foregoing Motion for Continuance by first class, United States mail to the following:
Andrew C. Sheely, Esquire
127 S. Market Street
P.O. Box 95
Mechanicsburg, PA 17055
Charles E. Shields, III, Esquire
Attorney at Law
6 Clouser Road
Mechanicsburg, PA 17055
YC~
Hilary P. Vesel squire
ID# 308358-
395 St. Johns Church Road, Ste. 101
Camp Hill, PA 17011
(717) 761-7573