HomeMy WebLinkAbout05-04-12 (2)ABOM &'
ICurur.Axls
)anon P. Kutulakis, Esquire
Am>mcy LD. #: 804ll
2 West High Street
Carlisle, PA 17(113
(71~ 249-1)900
IN RE: THE ESTATE OF
MARLIN L. MARSH a/k/a
MARLIN LEROY MARCH
+~~E a~
Ct,ERK ; ;
ORPH.A~d'S ~:OUF
~h'~. ~ ~ ., „ PA
IN THE COURT OF COMMON PLEAS OF
CUMBERLAND COUNTY PENNSYLVANIA
CIVIL DOCKET NO.: 21-11-0068
ORPHANS' COURT DNISION
TO THE HONORABLE CHRISTY LEE PECK, JUDGE OF SAID COURT:
AMENDED MOTION FOR CONTINUANCE
AND NOW, this 4``' day of May, 2012 comes the Respondent, Susan A. Kuhn, by and
through her counsel, Jason P. Kutulakis, Esquire, of Abom & Kutulakis, L.L.P., and respectfully
moves This Honorable Court to continue the hearing on Petitioner's Petition For Removal of Susan
Ann Kuhn as Co-Administrator, and in support thereof avers the following:
1. Petitioner is Judy Ann Estill, co-administrator of the Marlin L. Marsh estate.
2. Respondent is Susan Ann Kuhn, co-administrator of the Marlin L. Marsh estate.
3. By Order of Court dated February 27, 2012, a hearing before The Honorable Christy
Lee Peck was scheduled for Monday, May, 7, 2012, at 9:30 a.m.
4. Respondent was unhappy with her previous counsel, David Baric, Esquire who
subsequently withdrew in December 2011.
5. Present counsel, Jason P. Kutulakis, Esquire, of Abom & Kutulakis, L.L.P., was just
recently retained on Thursday, May 3, 2012.
6. Present counsel has also just received the file from the previous attorney on Friday,
May 4, 2012.
7. Having received the file on Friday, May 4, 2012 does not give present counsel
adequate time to prepare fully for the hearing on Monday, May 7, 2012.
8. Respondent respectfully requests the hearing be continued to a later date.
9. Undersigned counsel has contacted Marc Roberts, Esquire, counsel for Petitioner,
Judy Ann Estill, who does oppose this Motion.
WHEREFORE, Petitioner prays this Honorable Court to continue the hearing on the
above-captioned matter to a date to be determined by the Court since undersigned counsel was just
retained.
Respectfully Submitted,
Date: ~ y
J on P. Kutulakis, Esqu
torney ID No: 80411
A om & Kutulakis, LLP
2 West High Street
Carlisle, PA 17013
(717) 249-0900
(717) 249-3344 facsimile
CERTIFICATE OF SERVICE
AND NOW, this 4`'' day of May, 2012, I, Shannon Freeman, of ABOM e~KUT[,TLAI:IS, T .T "P,
hereby certify that I did serve a true and correct copy of the foregoing AMENDED MOTION
FOR CONTINUANCE by depositing, or causing to be deposited, same in the United States Mail,
First-class mail, postage prepaid addressed to the following:
Marc Roberts, Esquire
149 East Market Street
York, PA 17401
Attorney for Judy Ann Estill
Brenda Sue Slaybaugh
8 Thornhill Court
Caxlisle, PA 17015
1
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~~~~
annon Freeman