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IN THE COURT OF COMMON PLEAS
OF CUMBERLAND COUNTY, PENNSYLVANIA
In Re:
WALTER F. RAAB LIVING TRUST
No. 21-12-398
ORPHANS'COURT
In Re:
BERNICE J. RAAB LIVING TRUST
In Re:
ESTATE OF BERNICE J. RAAB
No. 21-12-399
ORPHANS'COURT
No. 21-11-842
ORPHANS'COURT
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MOTION FOR CONTINUANCE AND APPROVAL OF CONSOLIDATION
Petitioner Wendy Robbins, by and through her counsel, McNees Wallace &
Nurick LLC, and with the concurrence of Respondents, hereby moves to continue
generally the hearing scheduled for May 10, 2012 to consider Petitioner's Amended
Petition for Injunctive Relief ("Amended Petition") and, in support thereof, states as
follows:
1. Petitioner and Respondents are co-trustees and equal co-beneficiaries of
the Walter F. Raab Living Trust and the Bernice J. Raab Living Trust ("Trusts"), as well
as the Estate of Bernice J. Raab ("Estate").
2. On April 2, 2012, the above-captioned matters were initiated by the filing
of an Emergency Petition for Injunctive Relief to Prevent Dissipation and Comingling of
Assets ("Emergency Petition").
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3. On April 3, 2012, the Court granted the Emergency Petition and scheduled
a hearing for April 17, 2012, to consider a request for final decree.
4. On April 4, 2012, Petitioner moved to consolidate the three above-
captioned matters under Pa.R.Civ.P. 213.
5. On April 11, 2012, Petitioner filed the Amended Petition.
6. On April 16, 2012, the Court continued to May 10, 2012 the hearing to
consider the Amended Petition.
7. The parties are continuing to negotiate resolution of numerous issues
relating to administration of the Trusts and the Estate.
8. The parties desire to continue the negotiation process and, to facilitate the
process, have agreed to generally continue the hearing on the pending Amending
Petition, provided that the restrictions set forth in the previously issued Orders of the
Court otherwise remain in effect.
9. Respondents' counsel concurs in this request for a general continuance.
10. Also currently before the Court is Petitioner's Motion to Consolidate the
three above-captioned matters.
11. Respondents' counsel concurs in this request for consolidation.
12. Respondents' counsel concurs in the form of the proposed order
submitted with this Petition.
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WHEREFORE, Petitioner Wendy Robbins requests that the Court (1) continue
generally the hearing scheduled for May 10, 2012; and (2) consolidate the above-
captioned actions.
McNEES WALLACE & NURICK LLC
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By G~
Alan R. Boyn n, Jr.
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: May 9, 2012
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CERTIFICATE OF SERVICE
The undersigned hereby certifies that on this date a true and correct copy of the
forgoing document was served via a-mail and first class mail, postage prepaid,
addressed as follows:
Neil E. Hendershot, Esq.
Serratelli, Schiffman & Brown, P.C.
2080 Linglestown Road, Suite 201
Harrisburg, PA 17110-9670
nhendershot(a)ssbc-law.com
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Alan R. Boynton,
Dated: May 9, 2012