HomeMy WebLinkAbout06-19-12~~BOM ~'
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Jason P. Kutulakis, lisquire
Attorney LD. #: 80411
2 West High Street
Carlisle, P;1 17013
(717) 249-0900
IN RE: THE ESTATE OF
MARLIN L. MARSH a/k/a
MARLIN LEROY MARCH
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CUMBERl.,~f~ CO., PA
IN THE COURT OF COMMON PLEAS OF
CUMBERLAND COUNTY PENNSYLVANIA
CIVIL DOCKET NO.: 21-11-0068
ORPHANS' COURT DIVISION
TO THE HONORABLE CHRISTY LEE PECK, JUDGE OF SAID COURT:
MOTION FOR CONTINUANCE
AND NOW, this 19th day of June, 2012 comes 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 the Petition For Removal of Susan Ann Kuhn as Co-
Administrator and Petition For Removal of Judy Ann Estill as Co-Administrator, and in support
thereof avers the following:
1. Judy Ann Estill, co-administrator of the Marlin L. Marsh estate, is an adult individual
residing at 2829 South Queen Street, Dallastown, Pennsylvania 17313.
2. Susan Ann Kuhn, co-administrator of the Marlin L. Marsh estate, is an adult
individual residing at 151 South East Street, Carlisle, Pennsylvania 17013.
3. By Orders of Court dated May 8 and June 6, 2012, respectively, a hearing before The
Honorable Christy Lee Peck was scheduled for Friday, June 22, 2012, at 10:45 a.m.
4. On June 19, 2012, undersigned counsel filed Preliminary Objections to Judy Estill's
Petition to Remove Susan Ann Kuhn as Co-Administrator of the Estate of Marlin L.
Marsh and a Petition to Remove Marc Roberts, Esquire, as counsel for the Estate of
Marlin L. Marsh.
5. On May 15, 2012 and May 25, 2012, undersigned counsel wrote to Marc Roberts,
Esquire, requesting that copies of his file be forwarded to undersigned counsel. See
letters attached hereto as Exhibits "A" and "B", respectively.
6. As of the filing of the instant Motion, undersigned counsel has not received Attorney
Roberts' file, including Attorney Roberts' failure to provide an accounting of the
estate.
7. Undersigned counsel respectfiilly requests the hearing be continued to a later date.
8. Undersigned counsel has contacted Marc Roberts, Esquire, who does oppose this
Motion.
WHEREFORE, undersigned counsel prays this Honorable Court to continue the hearing on
the above-captioned matter to a date to be determined by the Court to allow Attorney Roberts to
respond to the Preliminary Objections and Petition to Remove Marc Roberts, Esquire, as counsel
for the Estate of Marlin L. Marsh, and for Attorney Roberts to provide undersigned counsel with
the requested documentation and appropriate accounting for the estate.
Respectfully Submitted,
t,.
Date: ~~---
as n P. utulakis, squire
At orney I No: 80411
Abom & Kutulakis, LLP
2 West High Street
Carlisle, PA 17013
(717) 249-0900
(717) 249-3344 facsimile
CERTIFICATE OF SERVICE
AND NOW, this 19`h day of June, 2012, I, Shannon Freeman, of ABOM d~ K(.TTTILr1HIS, T .T .P,
hereby certify that I did serve a true and correct copy of the foregoing 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
Carlisle, PA 17015
4' ~
annon Freeman