HomeMy WebLinkAbout11-15-11IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY
REGISTER OF WILLS
IN RE:
WILLIAM G. SHOPE JR. ) PA No. 21-10-0182
Michael S. Travis, )Motion Withdraw as Counsel
Movant/Attorney Executors)
vs. }
c7 ~ ,
~~
Gregory M. Merrill and ) .z~ c
Kathleen A. Merrill, } `i>` n v,
Respondents/Co-Executors) ~ -
~~ ~
MOTION TO WITHDRAW AS COUNSEL a~
NOW COMES, Michael S. Travis, Attorney for the Executors, and moves
this Honorable Court as follows:
1. The above estate was opened on February 24, 2010.
2. Gregory M. Merrill and Kathleen A. Merrill have been acting as Co-
Executors as provided for in the Will of the Estate of William G. Shope, Jr.,
Michael S. Travis has been acting as their attorney throughout.
3. Movant has repeatedly requested information required to close the
estate of the Decedent.
4. Movant desires to withdraw as counsel as Respondents have. not
provided in formation necessary to complete the estate.
5. Respondents are sophisticated business people who have taken it
upon themselves to complete much of the work required to complete the estate.
6. On information and belief, Respondents have filed the
Pennsylvania Inheritance Tax return and are negotiating with the Department of
Revenue regarding disputed tax items.
7. It is believed and therefore averred that Respondents are capable
of handling the final administration of the estate pro se.
;x' r*-r
-,
' ._.J
"" -:~
,,-:
,_,
-~,
~~
8. The Executors are also the sole heirs.
9. Respondent d~e-rte# concur with this request.
WHEREFORE, Movant, Michael S. Travis, prays this Honorable Court that
he be removed as counsel, and that the Respondents, Gregory and Kathleen
Merrill act as their own counsel.
Attorney for Executors
Date: 1~,~./~ r/
oyu~+ ~ nnaie rsoaa
Camp Hill, PA 17011
717-731-9502
mst@mtravis/aw.com
IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY
REGISTER OF WILLS
IN RE:
WILLIAM G. SHOPE JR. ) PA No. 21-10-0182
Michael S. Travis, )Motion Withdraw as Counsel
Movant/Attorney Executors)
vs. )
Gregory M. Merrill and )
Kathleen A. Merrill, )
Respondents/Co-Executors)
VERIFICATION
The statements made in this Motion are true and correct to the best of my
knowledge, information and belief. I understand that false statements made
herein are subject to the penalties of 18 Pa.C.S. Sect. 4904 relating to unsworn
falsification to authorities. r
~chael S. Travis
Attorney for Executors
Date: /l~ //_ i/
IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY
REGISTER OF WILLS
IN RE:
WILLIAM G. SHOPE JR. ) PA No. 21-10-0182
Michael S. Travis, )Motion Withdraw as Counsel
Movant/Attorney Executors)
vs. i
Gregory M. Merrill and )
Kathleen A. Merrill, )
Respondents/Co-Executors)
CERTIFICATE OF SERVICE
I certify that a true and correct copy of the foregoing document was served
on the below persons by first class U.S. Mail, postage prepaid:
Estate of William G. Shope, Jr.
care of Gregory and Kathleen Merrill
2160 Canterbury Drive
Mechanicsburg, PA 17055
/i, ~/- i~
` ~ is ael S. Travis
3904 Trindle Road
Camp Hill, PA 17011
717-731-9502
mstC~Jmtravis/a w. com
Attorney for Executors