HomeMy WebLinkAbout07-06-11IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY
PENNSYLVANIA
ESTATE OF KATHRYN L. VANDALL, : REGISTER OF WILLS
deceased .
NO. 2110-0838
SSN:138-26-9762
MOTION FOR RULE TO SHOW CAUSE
1. The Movant is counsel of record for the Executrix, Lori Hartlaub whose
address is 235 Kuhns Road, Littlestown, PA 17340.
2. The decedent, Kathryn L. Vandall, SSN# 138-26-9762, died testate on
May 15, 2010.
3. The undersigned duly probated the will, the Register of Wills opened
the estate with the above number, the Register of Wills appointed Lori Hartlaub
as the executrix of the estate and the undersigned advertised the opening of the
aforesaid estate.
4. The undersigned has made numerous attempts to contact the
Executrix however the Executrix had failed to respond to the undersigned or pay
the advertising costs.
5. Without the co-operation of the Executrix, the undersigned cannot
represent the aforesaid estate and respectfully requests that Your Court
Honorable Court issue a rule to show cause upon the Executrix to show cause
why he should not be allowed to withdraw his representation of the above
Executrix and estate.
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WHEREFORE, the undersigned moves that Your Honorable Court issue a
rule to show cause on Lori Hartlaub, Executrix of the above estate to show cause
why the undersigned should not be allowed to withdraw as her counsel and
counsel for the above estate.
Respectfully submitted:
David W. Knauer, Esquire
Knauer & Associates, L.S.C.
Atty I d : 21582
1542 Lookout Springs Drive
Colorado Springs, Colorado 80921
(Tel) (719) 203-5980
E-Mail: daknauer@juno.com
IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY
PENNSYLVANIA
ESTATE OF KATHRYN L. VANDALL, : REGISTER OF WILLS
deceased
NO. 2110-0838
SSN:138-26-9762
CERTIFICATE OF SERVICE
I, David W. Knauer, Esquire, did this 22"d day of June, 2011, did serve on
the hereinafter person a true and correct copy of the attached motion and
proposed order of court by United States Mails addressed as follows:
Lori Hartlaub
235 Kuhns Road
Littlestown, PA 17340
-_ ~ ~ ~
David VC/. Knauer', Esquire
Atty Id: 21582
1542 Lookout springs Drive
Colorado Springs, Colorado 80921
(Tel) (719) 203-5980
E-mail: daknauer@juno.com