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IN RE: ESTATE OF
ROBERT P. STROUS,
Deceased
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IN THE COURT OF COMMON PLEAS
ORPHANS' COURT DIVISION OF
CUMBERLAND COUNTY, PENNSYLVANIA
NO: 2007-00176
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
LAW OFFICES
SNELBAKER EC
BRENNEMP. N, P.C.
I 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.
2. Robert P. Strous (hereinafter called "Decedent") died testate on February 18,
2007, in Cumberland County, Pennsylvania.
3. Decedent's Will was duly probated on February 23, 2007 in the Office of the
Register of Wills of Cumberland County, PA. Letters Testamentary were issued on the same
date to Eric R. Strous and Zane P. Strous (hereinafter called "Respondents) whose last known
addresses are:
a. Eric R. Strous
2715 Heather Drive
York, PA 17402
b. Zane P. Strous
3263 Pebblewood Lane
Dresher, PA 19025
4. Respondents engaged Petitioner to represent their interests with regard to the
administration of Decedent's estate.
5. Petitioner has entered its appearance as counsel to Respondents and Estate.
6. Petitioner provided all necessary services to Respondents and the Estate to the
time for preparing the Inheritance Tax Return, at which latter time, Respondents effectively
ceased communicating with Petitioner.
7. Respondents have not responded to numerous written requests for information in
the past.
8. On or about March 1, 2012, the Clerk of Your Honorable Court sent "Notice of
Failure to File Status Report" to Petitioner and presumably to Respondents.
9. Because of the Respondents failure to communicate with Petitioner, Petitioner is
unable to respond to said Notice in any meaningful manner.
10. On March 3 and 6, 2012, Petitioner communicated with Respondents by
telephone messages, requesting Respondents contact with Petitioner in order to make a
meaningful response to the Clerk's notice cited in paragraph 7 above.
11. Respondents have not contacted the Petitioner in response to the requests of
March 3 and 6, 2012.
12. Respondents have failed to respond to Petitioner's requests for information in
order to complete its professional services.
13. Without Respondents' cooperation and communications, Petitioner cannot
perform any further services to Respondents or the Estate and requests leave to withdraw as
counsel of record in said Estate and as attorney for Respondents.
LAW OFFICES
SNELBAKER SC
BRENNF_MAN, P.C.
WHEREFORE, Petitioner respectfully requests your Honorable Court to grant it leave to
withdraw as counsel to the Decedent's estate and as attorney for Respondents.
SNELBAKER &BRENNEMAN. P.C.
By:
Richard C. Snelbaker, Esquire
44 West Main Street
Mechanicsburg, PA 17055
(717) 697-8528
Petitioner
Date: March 7, 2012
LAW OFFICES
SNELBAKER 8C
BRENNEMAN, P.C.
VERIFICATION
COMMONWEALTH OF PENNSYLVANIA)
SS.
COUNTY OF CUMBERLAND )
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
LAW OFFICES
SNELBAKER SC
BRENNF_MAN, P.C.
Sworn to and subscribed before me
this 7~ day of March, 2012
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Notary Public
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CERTIFICATE OF SERVICE
RICHARD C. SNELBAKER, ESQUIRE, 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 at
~ Mechanicsburg, PA 17055, to Respondents addressed as follows:
a. Eric R. Strous
2715 Heather Drive
York, PA 17402
b. Zane P. Strous
3263 Pebblewood Lane
Dresher, PA 19025
Richard C. Snelbaker, Esquire
Snelbaker & Brenneman, P.C.
44 West Main Street
P.O. Box 318
Mechanicsburg, PA 1705.5
Date: March 7 , 2012
LAW OFFICES
SNELBAKER EC
BRENNEMAN. P.C.