HomeMy WebLinkAbout04-09-12
IN RE ESTATE OF
PETER N. KUTULAKIS
IN THE COURT OF COMMON PLEAS
CUMBERLAND COUNTY, PENNSYLVANIA
Register of Wills No.: 1997-00716
Respondent Mary D. Kutulakis' Response to Motion for Continuance of Trail
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And now comes Respondent Mary D. Kutulakis and hereby states as
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response to Petitioner's Motion for Continuance of Trial: ~~~ x„ _
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1. Admitted with further explanation. The trial dates were circulated to couns~hby
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e-mail as early as February 15, 2012.
2. Denied. Respondent is without sufficient information to form a belief as to the
truthfulness of this averment.
3. Respondent does not concur with the request to continue the trial dates.
Respondent has been attempting to sell her property since the summer of 2010.
She has been precluded from doing so by this lawsuit and another unrelated
lawsuit that was terminated in the September of 2011.
New Matter
4. Respondent incorporates the foregoing responses as if fully set forth at length
herein.
5. Respondent's stress level has been steadily increasing over the past 2 years as
a result of the two lawsuits.
6. Respondent has a consult with a neurosurgeon to schedule surgery as a result of
her pain.
Wherefore, Respondent Mary D. Kutulakis respectfully requests that this
Honorable Court deny Petitioner's Motion for Continuance of Trial.
Respectfully submitted,
SAIDIS, SULLIVAN & ROGERS
IIean E. Reynosa, Esquire
Attorney Id. 80440
26 West High Street
Carlisle, PA 17013
(717) 243-6222
Counsel for Respondent Mary D. Kutulakis
CERTIFICATE OF SERVICE
I hereby certify that on this ~~ day of April, 2012, a true and correct copy of the
foregoing document was served upon the party listed below, via First Class Mail, postage
prepaid, and facsimile addressed as follows:
The Honorable Eugene E. Fike
Somerset County Courthouse
111 E. Union Street
Somerset, PA 15501
(814) 445-1455
Jason P. Kutulakis, Esquire
Two West High Street
Carlisle, PA 17013
(717) 249-3344
SAIDIS, SULLIVAN & ROGERS
Dean. Re~nesaT-E
Attor ey Id. 80440
26 West High Street
Carlisle, PA 17013
717-243-6222