HomeMy WebLinkAbout04-12-12 .. ,a
~
O '-`- ~
rw.
~n
~ rn r~.~
x_ __ ~-~
-- c ~ ~;
_ _; ~
-
~ _,
..._ ~_a~
-,
~., ,
_.
_
i C .~ 1 _ -h
_r_
~
-`1 ~ `
~
v~ ;-~
n
cs
IN RE: ESTATE OF DAVID R. HORN, IN THE COURT OF COMMON PLEAS
Deceased :ORPHANS' COURT DIVISION OF
CUMBERLAND COUNTY, PENNSYLVANIA
N0. 2011-0483
PETITION FOR LEAVE TO WITHDRAW AS COUNSEL
Snelbaker & Brenneman, P. C. submits this Petition For Leave to Withdraw As Counsel
and in support thereof states the following:
1. Petitioner herein is Snelbaker & Brenneman, P. C., a professional corporation of
attorneys having its offices at 44 West Main Street, Mechanicsburg, PA 17055.
2. David R. Horn (the "Decedent") died testate on February 5, 2011 in Cumberland
County, Pennsylvania.
3. Decedent's Will was duly probated on April 15, 2011 in the Office of the Register of
Wills of Cumberland County, Pennsylvania and Letters Testamentary were issued on the same
date to Kelly F. Stanley (the "Respondent")
4. Respondent has engaged Petitioner to represent her interests with regards to the
administration of the Decedent's Estate.
5. Petitioner has entered its appearance as counsel to Respondent and the Estate.
6. Respondent has on many occasions not responded to written requests for information
LAW OFFICES
SNELBAKER SC
BRENNEMAN. P.C
necessary for purposes of administering the Estate and otherwise gathering the information for
purposes of preparing an inheritance tax return.
7. Respondent has for more than ten months failed to make any payment on account of
services provided by the Petitioner and to reimburse more than $600.00 in costs advanced by
Petitioner.
8. Notice has been received by Petitioner of the delinquency of the filing of an
inheritance tax return in February 2012 from the Pennsylvania Department of Revenue. That
notice was forwarded to Respondent on February 16, 2012 to which no response was received
from Respondent.
9. Because of Respondent's failure to communicate with Petitioner, Petitioner is unable
to properly represent the Respondent and otherwise proceed with administration of the Estate in
any meaningful manner.
10. Respondent has failed to respond to Petitioner's requests for information in order to
complete its professional services.
11. Petitioner cannot perform services for the Respondent or the Estate without
Respondent's cooperation, communication and assistance; accordingly, Petitioner requests leave
to withdraw as counsel of record in the Estate and as attorney for Respondent.
WHEREFORE, Petitioner requests this Court grant leave to withdraw as counsel to
Decedent's Estate and as attorney far Respondent.
SNELBAKER & BRENNEMAN, P. C.
LAW OFFICES
SNELBAKER SC Date: April 20, 2012
BRENNEMAN, F.C.
BY: ~"
Keith O. Brenneman, Esquire
44 W. Main Street
Mechanicsburg, PA 17055
(717) 697-8528
Attorneys for Petitioner
-2-
VERIFICATION
I verify that the statements made in the foregoing Petition are true and correct. I
understand that false statements herein are made subject to the penalties of 18 Pa.C.S. Section
4904 relating to unsworn falsification to authorities.
~~~~
Keith O. Brenneman
Date: April 20, 2012
LAW OFFICES
SNELBAKER SC
BRENNEMAN, F.C.
CERTIFICATE OF SERVICE
I, KEITH O. BRENNEMAN, ESQUIRE, hereby certify that I have, on the below date,
caused a true and correct copy of the foregoing Petition to be served upon the person and in the
manner indicated below:
T.
Kelly F. Stanley
7000 Wertzville Road
Mechanicsburg, PA 17050
SNELBAKER & BRENNEMAN, P.C.
By:
' Keith O. Brenneman, Esquire
44 W. Main Street
P. O. Box 318
Mechanicsburg, PA 17055
Date: April 20, 2012 (717)697-8528
Attorneys for Petitioner
LAW OFFICES
SNELBAKER SC
BRENNEMAN. P.C.