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lIv` RE: ESTATE OF IN THE COURT OF COMMON PLEAS i~~`~ -~-
LUTHER D. JUMPER :CUMBERLAND COUNTY, PENNSYL~~~
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ORPHANS COURT DIVISION ~~'~-' ~ y f - ~ - `
NO. 2010-00043 '~, ~ ," ' ~ ~ '
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PETITION TO MAKE RULE ABSOLUTE
AND NOW comes Petitioner, Bradley L. Griffie, Esquire, and the law firm of Griffie and
Associates and petitions the Court as follows:
1. Your Petitioner is attorney of record for the Estate of Luther D. Jumper in the above-
captioned matter.
2. Your Respondent is James A. Gross, the named administrator of the Estate, and an
adult individual, whose current address is 101 Army Heritage Drive, Carlisle,
Cumberland County, Pennsylvania, 17013.
3. Petitioner has filed a Petition to Withdraw as counsel on April 21, 201 1, resulting in
the entry of an Order of Court and Rule to Show Cause dated April 28, 2011, a copy
of said Petition and Order of Court and Rule to Show Cause being attached hereto
and incorporated herein by reference as Exhibit "A."
4. As per the Affidavit of Service filed of record, service of the Petition and resulting
Order of Court and Rule to Show Cause was made be certified mail, restricted
delivery, upon Respondent on July 12, 2011.
5. More than twenty (20) days has passed since the service of the Petition, Order of
Court and Rule to Show Cause and no response has been filed of record.
F
WHEREFORE, Petitioner requests your Honorable Court to make the Rule absolute
allowing Petitioner to withdraw as counsel for Respondent, James A. Gross, in the above
captioned action.
Respectfully submitted,
Esquire
~RIFF,Y~ & ASSOCIATES
200 orth Hanover Street
Carlisle, PA 17013
(717) 243-5551
(800) 347-5552
VERIFICATION
I verify that the statements made in the foregoing document are true and correct. I
understand that false statements herein are made subject to the penalties of 18 Pa.C.S. Section
4904, relating to unsworn falsifications to authorities.
DATE: +
~~
D L. FFIE, ESQUIRE
IN RE: ESTATE OF IN THE COURT OF COMMON PLEAS OF
LUTHER D. JUMPER :CUMBERLAND COUNTY, PENNSYLVANIA
ORPHANS COURT DIVISION
N0. 2010-00043
ORDER OF COURT
AND RULE TO SHOW CAUSE
-~
AND NOW, this ~~ day of ~ ~ 20 l ~ , upon
presentation and consideration of the within Petition, a Rule is hereby issued upon
Respondent; James A. Gross; to show cause, if any he has, as to why Bradley L. Griffie,
Esquire and the law firm of Griffie & Associates should not be permitted to withdraw as
counsel in the above captioned matter.
Rule returnable ~ ~ days after service by first-class mail, postage prepaid
upon the Respondent to his last known address.
BY THE COURT,
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Cc: Bradley L. Griffie, Esquire _- ~-'-;
Petitioner/Attorney for Estate n o ~~ , `= _--
James A. Gross, ~=~
Respondent ~~-= rn ~, ..- ___
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Exhibit "A" , ` ,
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IN RE: ESTATE OF IN THE COURT OF COMMON PLEAS OF
LUTHER D. JUMPER :CUMBERLAND COUNTY, PENNSYLVANIA , ~ ~~
ORPHANS COURT DIVISION ,coo ~.. -,~; ~-
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PETITION TO WITHDRAW AS COUNSEL ~r,_L;,~ --' ~ ~~
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AND NOW; comes Petitioner, Bradley L. Griffie, Esquire, and the la~,~trm of.y ~:-= '=r;
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Griffie '~ Associates; and petitions the Court as follows:
1. Your Petitioner is attorney of record for the estate of Luther D. Jumper in the
above captioned action.
2. Respondent is James A. Gross, an adult individual whose last known address is
101 Army Heritage Drive, Carlisle, Cumberland County, Pennsylvania.
3. Petitioner was retained by Respondent to represent the above referenced estate.
4. Petitioner initiated the process of probating the estate, including securing Letters
of Administration, giving advertised notice of the estate, giving Rule 5.6 Notice
to heirs, contacting creditors; consolidating assets; researching the eAistence of
assets and preparing a draft of an Inheritance Tax Return.
5. Petitioner has made repeated attempts to gain the cooperation of Respondent to
execute the Pennsylvania Inheritance Tax Return, to secure comment on the
Return, to make payment for services rendered, to pay for the inheritance tax due,
and otherwise to assist in completed and finalizing the within estate.
6. Despite Petitioner's repeated requests for cooperation and responses from
Respondent. Petitioner has been unable to gain Respondent's cooperation for
more than four months.
7. Fees are due for services rendered and the investigation of the estate evidences
that the only financial resources available to the estate, for the payment of fees
and otherwise, were resources that were held jointly by Respondent and the
decedent, which resources are under the control of Respondent.
8. Petitioner has no other means to secure the cooperation of Respondent, nor to
secure payment for services, payment. for fees and costs and payment of the
inheritance tax in this matter, without the cooperation of Respondent.
). As Petitioner was able to secure an extension of time for filing the Inheritance
Tax Return in this matter, Petitioner has provided a copy of the within Petition to
the Department of Revenue.
WHEREFORE, Petitioner requests your Honorable Court to enter Rule upon
Respondent to show cause, if any he has, as to wh}' Petitioner should not be permitted to
withdraw as counsel in the above captioned matter.
Respectfully submitted,
B e~ L. G~fffie, Esquire
- - torney fc~f Petitioner
200 North Hanover Street
Carlisle, PA 17013
(717) 243-5551
(800) 347-552
I verify that the statements made in the foregoing document are true and correct. I
understand that false statements herein are made subject to the penalties of 18 Pa.C.S.
Section 4904, relating to unsworn falsification to authorities.
DATE: y ~I~I a~
- ey L. Griffie, Esquire
IN RE: ESTATE OF IN THE COURT OF COMMON PLEAS OF
LUTHER D. JUMPER :CUMBERLAND COUNTY, PENNSYLVANIA
ORPHANS COURT DIVISION
N0. 2010-0004
CERTIrICATE OI' SERVICE
I, Bradley L. Griffie, Esquire hereby certify that I did, the~~~ay of April, 2011,
did cause a copy of the within Petition to Withdraw as Counsel to be served upon the
Respondent, James A. Gross, and upon the Department of Revenue by serving them by
first class mail, postage prepaid, at the following addresses:
James A. Gross
101 Army Heritage Drive
Carlisle, PA 17013
DATE: "~ ~' ~-!(
Claudia Maffei, Supervisor
Inheritance Tax Division
Commonwealth of Pennsylvania
Department of Revenue
Bureau of Individual Taxes
PO Box 280601.
Harrisburg, PA 17128-0601
~, riffie, Esquire
rney fo ~ Petitioner