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Duncan & Hartman, P.C. ~n -- r
Susan J. Hartman, Esquire
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1 Irvine Row, Carlisle, Pennsylvania 17013 ~ n ~ "'~ {_ , ,
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717.249-7780 ~Q '"`
717.249-7800 FAX
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Attorney ID 65184
IN RE: Estate of Sara D. Strong : IN THE COURT OF COMMON PLEAS
:CUMBERLAND COUNTY, PENNA.
ORPHANS' COURT DIVISION
N0.21-11-0984
MOTION FOR SCHEDULING OF A STATUS CONFERENCE
Petitioner, Geoffrey S. Yuda, Executor of the Estate of Sara. D. Strong, by his attorney,
Susan J. Hartman, sets forth the following:
1. Petitioner filed a Petition to Gather. and preserve estate assets with this Court on March 12,
2012.
2. Service on David Strong was returned "not found" by the Lancaster Sheriffis Office dated
March 29, 2012. A copy of the return is made a part hereof and attached hereto as Exhibit "A".
3. Petitioner forwazded a copy of the Petition to Mazgazet Stuski, Esquire, who had previously
contacted Petitioner's attorney concerning the Estate. Petitioner's attorney has on several occasions
inquired as to whether Ms. Stuski is still the attorney for David Strong with no response forthcoming.
4. David Strong contacted Susan J. Hartman, Esquire by telephone and told her he was now living
in the Pittsburgh azea but refused to give an address.
5. When questioned, Mr. Strong affirmed that he still had the same a-mail address.
6. Susan J. Hartman, Esquire e-mailed a copy of the filed petition to David Strong on April 6,
2012.
7. The mortgage on 405 Walnut Bottom Road, Cazlisle, Pennsylvania continues to remain in
default.
8. David Strong continues to receive rent payments from the tenants he installed in the property
located at 405 Walnut Bottom Road, Cazlisle, Pennsylvania.
9. Petitioner believes that a Status Conference is necessary for the purpose of seeking judicial
guidance concerning any further notice required with regard. to David Strong as well as a time schedule
in order that the property may be protected from imminent foreclosure proceedings.
10. Petitioner avers and believes that the Estate of Sara Strong will suffer irreparable harm and
a waste of assets if the Court cannot rule upon the previously filed Petition to Gather and Protect
Assets.
WHEREFORE, Petitioner requests your Honorable Court set a Status Conference in this matter
Respectfully submitted,
Dated: ~6~ ~°~ ~
Attorney ID 65184
1 Irvine Row, Carlisle, PA 17013
717-249-7780
SHERIFF'S OFFICE OF CUMBERLAND COUNTY
Ronny R Anderson
Sheriff
Jody S Smith
Chief Deputy
Richard W Stewart
Solicitor
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in Re: Estate of Sara D. Strong Case Number
vs.
David M. Strong 21-11-984
SHERIFF'S RETURN OF SERVICE
03/13!2012 Ronny R. Anderson, Sheriff who being duly sworn axording to law states that he made a diligent search
and inquiry for the within named defendant, to wit: David M. Strong, but was unable to locate him in his
bailiwick. He therefore deputized the Sheriff of Lancaster County, Pennsylwanfa to serve the within Notice
and Petfion to Gather and Preserve Estate Assets according to law.
03/29/2012 Lancaster County Return: And now, March 29, 2012 I, Mark Reese, Sheriff of Lancaster County,
Pennsylvania, do hereby cefify and return, that 1 made diligent search and inquiry for David M. Strong the
defendant named in the within Notice and Petiton to Gather and Preserve Estats Assets and that I am
unable to find him in the County of Lancaster and therefore return same NOT FOUND. Request for
service at 302 8. Manor Street, Mountviile, Pennsylvania 17608 the Defendant was not found.
SHERIFF COST: $37.45
April 03, 2012
SO ANSWERS,
RON R ANDERSON, SHERIFF
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