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HomeMy WebLinkAbout01-31-11 o ~=- a~ .- t1, ,L~ c7 tea . ~~~ ~ y C/` --- ~ ~ r-j ~~ .. _.. ~'~rf - _. ~_•~ G. `7"1 IN RE: ESTATE OF IN THE COURT OF COMMON PLEAS CAROL H. HAYES, :ORPHANS' COURT DIVISION, OF Deceased :CUMBERLAND COUNTY, PENNSYLVANIA N0.2011-0023 PETITION FOR LEAVE TO WITHDRAW AS COUNSEL TO THE HONORABLE, THE JUDGES OF SAID COURT: AND NOW, comes Snelbaker & Brenneman, P. C., and respectfully represents as follows: 1. The Petitioner herein is Snelbaker & Brenneman, P. C., a professional corporation of attorneys having its office at 44 West Main Street, Mechanicsburg, PA 17055. Richard C. Snelbaker, Esquire is a member of said firm and is a co-petitioner herein. 2. Carol H. Hayes (hereinafter called "Decedent") died testate on December 18, 2010, in Cumberland County, Pennsylvania. 3. Decedent's Will was duly probated on January 5, 2011 in the Office of the Register of Wills of Cumberland County, PA. Letters Testamentary were issued on the same date to Sharon E. Brown (hereinafter called "Executrix") whose address is 55 Long View, Carlisle, PA 17013. 4. Executrix engaged Petitioner to represent her legal interests with regard to the probate and administration of Decedent's estate. 5. Petitioner has entered its appearance as counsel to Executrix and Decedent's Estate. LAW OFFICES SNELBAKER 8C BRENNEMAN,P.C. 6. Executrix has decided that she does not need further services from Petitioner and has directed Petitioner to render no further services to her or the Decedent's estate. 7. Attached hereto is the Joinder of Executrix indicating her affirmation of the averments in paragraph 6 above. WHEREFORE, Petitioner (joined by Executrix) respectfully requests your Honorable Court to enter an order permitting Petitioner and Richard C. Snelbaker, Esquire, to withdraw as counsel to the Executrix and the Estate of Carol H. Hayes, Deceased. SNELBAKER & BRENNEMAN, P. C. By: Richard C. Snelbaker, Esquire 44 W. Main Street Mechanicsburg, PA 17055 (717) 697-8528 Date: .Sa Nw,+ •~ 31 , 2011 LAW OFFICES SNELBAKER 8C BRENNEMAN. P.C. -2- 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 Petitioner's professional corporation and is authorized to make this verification on said Petitioner's behalf; and that the facts set forth in the foregoing Petition are true and correct to the best of his knowledge, information and belief. Richard C. Snelbaker Sworn to and. subscribed before me this 3/3~ day of .~iN,,,,,t , 2011. Notary Public t s~ Susan L. MaYazi, Notary Prlric Meohanicsbrxg t3oro, Cumt~erland oourrly tay t~orrNniseton E~ires Nov 24, 2011 MNMw. Acsnr'~~don LAW OFFICES SNELBAKER SC BRENNEMAN, F.C. IN RE: ESTATE OF IN THE COURT OF COMMON PLEAS CAROL H. HAYES, :ORPHANS' COURT DIVISION, OF Deceased :CUMBERLAND COUNTY, PENNSYLVANIA the Last Will and Testament of Carol H. Hayes, Deceased, and avers as follows: that she does JOINDER OF EXECUTRIX AND NOW, comes Sharon E. Brown in her capacity as Executrix of the Estate and under not need any further legal services from Petitioner and so advised Petitioner to render no further services to her and/or the Decedent's Estate, and further, said Executrix hereby joins in the prayer of Petitioner's Petition to which this Joinder is attached. ~~ ~ Sharon E. Brown Executrix of the Estate and under the Last Will and Testament of Carol H. Hayes, Deceased COMMONWEALTH OF PENNSYLVANIA) COUNTY OF CUMBERLAND NO.2011-0023 SS. On this the ~Sf1, day of JQn~, ~~~~ , 2011 before me, a Notary Public in and for the above County and Commonwealth, the undersigned officer, personally appeared SHARON E. BROWN, known to me (or satisfactorily proven) to be the person whose name is subscribed to the within instrument and acknowledged that she executed the same as her act and deed for the purposes therein contained. IN WITNESS WHEREOF, I hereunto set my hand and official seal. GOM~~~ p~~ p~dMniplpurpq C+~mwwon )an. 5, ioy Notary Public LAW OFFICES SNELBAKER EC BRENNEMAN, P.C. CERTIFICATE OF SERVICE RICHARD C. SNELBAKER, on behalf of Snelbaker & Brenneman, P. C., Petitioner, hereby certifies that he duly served a true and correct copy of the foregoing Petition by serving the same this date by first-class mail, postage paid, from the Post Office in Mechanicsburg, PA 17055, to Executrix addressed as follows: Sharon E. Brown 55 Long View Carlisle, PA 17013 G~~ Richard C. Snelbaker Snelbaker & Brenneman, P. C. 44 West Main Street Mechanicsburg, PA 17055-0318 Date: January 31, 2011 LAW OFFICES SNELBAKER 8G BRENNEMAN, P.C.