HomeMy WebLinkAbout04-17-12IN THE COURT OF COMMON PLEAS
OF CUMBERLAND COUNTY
PENNSYLVANIA ~~_
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I n Re: No. 21-12-398 ~ ~ u
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WALTER F. RAAB LIVING TRUST :ORPHANS' COURT ==
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In Re: No. 21-12-399
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BERNICE J. RAAB LIVING TRUST
In Re:
ESTATE OF BERNICE J. RAAB
ORPHANS' COURT
No. 21-11-842
ORPHANS'COURT
MOTION FOR CONTINUANCE
Petitioner Wendy Robbins, by and through her counsel, McNees, Wallace &
Nurick LLC, hereby moves the Court to continue the hearing to consider Petitioner's
Amended Petition for Injunctive Relief ("Amended Petition") and, in support thereof,
states as follows:
1. A hearing to consider the Amended Petition is scheduled to occur on April
17, 2012, 9:15 a.m.
1. The parties are attempting to resolve multiple issues relating to
administration of the Walter F. Raab Living Trust and the Bernice J. Raab Living Trust
("Trusts") and the Estate of Bernice J. Raab ("Estate")
2. Petitioner and Respondents are co-trustees and equal co-beneficiaries of
the Trusts.
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3. Petitioner and Respondents are also co-executrixes of the Estate, the
beneficiary of which is her Trust.
4. The parties have agreed to keep the April 3, 2012 Preliminary Decree in
place and extend the applicable restrictions to Petitioner as well as to the Respondents,
pending further Order of Court.
5. The primary remaining issue to be addressed in the Amended Petition is a
request to remove Respondents as trustees of the Trusts and executrixes of the Estate.
6. Respondents have not yet responded to the Amended Petition, which may
include New Matter raising other issues or requests for relief, nor have the parties
briefed the issues raised therein.
7. Counsel for Petitioner requests that this matter be continued to the next
available date or dates to consider the primary remaining issue set forth in the Amended
Petition or other issues as may be raised by the Respondents in their Reply, including
New Matter.
8. Respondents' counsel concurs in this request.
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WHEREFORE, Petitioner Wendy Robbins requests that the Court continue the
hearing scheduled for April 17, 2012 at 9:15 a.m. to consider her Amended Petition for
Injunctive Relief.
McNEES WALLACE & NURICK LLC
By ~ O .~ C~/1
Alan R. Boynton, J
I. D. No. 39850
Alexis I. Snyder
I. D. No. 308778
100 Pine Street
P.O. Box 1166
Harrisburg, PA 17108
(717) 232-8000
Attorneys for Petitioner Wendy Raab Robbins
Dated: April 16, 2012
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CERTIFICATE OF SERVICE
I certify that I have this day served a copy of the foregoing document via a-mail
and U.S. mail, postage prepaid, upon the following:
Neil E. Hendershot, Esq.
Serratelli, Schiffman & Brown P.C.
2080 Linglestown Road, Ste. 201
Harrisburg, PA 17110-9693
Date ~ ~ CYI
d April 16, 2012
Alan R. Boynt , Jr.