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HomeMy WebLinkAbout04-05-12 .~~ r.~ c~ ~-,, ~: ~ ;~ 0 ~~ ~ ~ 4 ~~n ~ ~'" M ~1 ? t ' 1 tJl r,-~ ~ ;- .s~' C? J t, ~ -' ~ Jason P. Kutulakis, Esquire ~ ~!? f- Attorney I.D. No.: 80411 ~ ~„~ ``~ ~j 2 West High Street C7 Carlisle, Pennsylvania 17013 (717) 249-0900 IN RE ESTATE OF IN THE COURT OF COMMON PLEAS PETER N. KUTULAKIS :CUMBERLAND COUNTY, PENNSYLVANIA REGISTER OF WILLS NO.: 1997-00716 TO THE HONORABLE EUGENE E. FIKE, II, JUDGE OF SAID COURT: AND NOW, comes the Petitioner, Jason P. Kutulakis, Esquire, and moves this Honorable Court for a continuance of Trial that is cutcently scheduled for Apri112~' and Apri113`~, 2012, and in support thereof avers the following: 1. On February 27, 2012, this Honorable Court issued an Order directing that Trial be scheduled for April 12~' and Apri113s', 2012, in the above-captioned matter. 2. Petitioner has previously arranged and paid for a vacation out of state from Apri16, 2012 to Apri113, 2012. 3. Undersigned counsel has attempted to contact Attorney Dean Reynosa, counsel for Mary D. Kutulakis, to obtain his position on the within motion; however, no response has been received as of the filing of this motion. WHEREFORE, the Petitioner respectfully requests that this Honorable Court reschedule the trial scheduled for Apri112`~ and Apri113, 2012. Respectfully submitted, &SUTULAR7S, LLP Da'rE ~ ~~` ~. Jaso P. Kutulakis, Esquire 2 est High Street Carlisle, PA 17013 (717) 249-0900 ID No. 80411 AND NOW, this 5~' day of April, 2012, I, Shannon Freeman, of ABOM & KUTLTLAKIS, LLP, hereby certify that I did serve a true and correct copy of the foregoing MOTION FOR CONTINUANCE OF TRIAL by first class mail addressed to the following: Dean Reynosa, Esquire ~_ SAIDIS, SULLIVAN & ROGERS, P. C. 26 W. High Street Carlisle, PA 17013 ~~n S on Freeman