HomeMy WebLinkAbout02-29-121N RE: ) TN THE COURT OF COMMON PLEAS
OF CUMBERLAND COUNTY,
ESTATE OF ) PENNSYLVANIA
MARGARET B. BROWN )
ORPHAN'S COURT DIVISION
FILE N0.21-11-0824
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PETITION TO WITHDRAW AS COUNSEL ~? =
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AND NOW comes Michael L. Bangs, Esquire, attorney for the Estate of
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Brown and files this Petition to Withdraw as Counsel based upon the following: ~np -a ~,,.}
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1. The Decedent, Margaret B. Brown, died on February 27, 2011. ~, M '
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2. The Decedent died testate and both of her daughters were named as Co-Executrixes of
the estate.
3. In June, 2011, Michael L. Bangs, Esquire was contacted by Barbara T. Brown and
agreed to assist Bazbaza T. Brown in the administration of the estate of her mother, Margaret B.
Brown.
4. On July 26, 2011, the Last Will of Mazgazet B. Brown was probated in the Register of
Wills Office in and for Cumberland County and Letters Testamentary were issued to Barbara T.
Brown.
5. Both Bazbaza T. Brown and her sister Virginia Brown were named as Co-Executrixes
on Decedent's Last Will. However, pursuant to an agreement reached between Virginia Brown
and her counsel, Mark C. Duffle, Esquire, Virginia Brown renounced her right to be a Co-
Executrix provided that Bazbaza T. Brown would proceed expeditiously to administer the estate.
6. The primary asset of the estate is the residence owned by the Decedent at 615 Hazding
Street, New Cumberland, Pennsylvania.
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7. Bazbaza T. Brown, the Executrix, resided with her mother prior to her death and
continues to reside there by herself.
8. In order for the house to be sold, Barbara T. Brown needs to find another living
arrangement; the accumulation of personal property in the house needs to be removed or sold;
and the house has to be generally cleaned up and put on the mazket for sale.
9. There aze other aspects of the estate administration that Bazbaza T. Brown needs to
complete.
10. Barbara T. Brown and the undersigned Michael L. Bangs, Esquire, have reached an
impasse in their ability to communicate as to the steps that are needed to wind up the estate to
such a degree that Barbara T. Brown refuses to have any discussions with Michael L. Bangs,
Esquire, at all concerning the resolution of the estate.
11. Michael L. Bangs, Esquire, has not been paid entirely for the work that he has
performed for the estate.
12. Bazbaza T. Brown continues to reside in the residence and it has yet to be placed for
sale.
13. The inability of the Executrix, Bazbaza T. Brown, to communicate with her legal
counsel Michael L. Bangs, Esquire, along with her failure to continue to pay for the legal
services provided, make it virtually impossible for Michael L. Bangs to continue to assist
Barbara T. Brown in the administration of the estate of Margaret B. Brown.
14. Michael L. Bangs requests that he be permitted to withdraw as legal counsel for the
Estate of Mazgazet B. Brown.
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WHEREFORE, Michael L. Bangs, Esquire, requests this Honorable Court to enter an
Order allowing him to withdraw as counsel for the Estate of Margaret B. Brown.
Respectfully submitted,
BANGS LAW OFFICE, LLC
MIC AEL L. BANGS (I.D. No 1263)
429 South 18th Street
Camp Hill, PA 17011
(717)730-7310
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