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Home My WebLink About07-24-12i ~ ~ ` 7,1 ~ ~) ..a '.T't i. ! r ~ ' IT7 `T' ~..._ _ ~~I ['a) _ _ , ,. ."',l _ I~~~ ~ . ~....' _ _ i~, ~ _ ~,7 ~Tj III, r -' i I ~ D ._ ~ ~ ~---' ~ 'r ~'~~ IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, YENN~YLVANIA ',~ ORPHANS' COURT DIVISION '~, I • No. 21-11-0068 ~~~ 111 the Estate of: - MARLIN L. MARSH a/h/a MARLIN LEROY MARSH Deceased ~,~~~ Judge Assigned or Previous Judge(s): Christvlee L. Peck i~ I,I ~~ Attorney for Petitioner: I, ~~~ Clyde W. Vedder, Esquire 32 N. Duke St. iI PO Box 544 ~~ York, PA 17405 ~ ~~ ~ Attorney for Susan A. 'Kuhn, Co-Administrator: I ~i~ Jason P. Kutulakis, Esquire ~i~ 2 W. High St. ~~~ Carlisle, PA 17013 ~~ Attorney for the Estatte of Marlin L. Marsh: I I ~~~ Marc A. Roberts, Esquire MORRIS&VEDDER,L~P~,~ 149 E. Makret St. 32 N. DUKE ST. 1. '1. ~l (~rl\, 17 ~ 1 / 401 YORK, PA I~~i MOTION FOR CONTINUANCF. Submitted by Clyde W. Vedder, Esquire I'~, T, NIA I~ I~; IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENI~SYLVA !' ORPHANS' COURT DIVISION ~, ~! ~I ~~'~~~~ In the Estate of: No. 21-11-0068 MARLIN L. MARSH a/lc/a MARLIN LEROY MARSH Deceased MOTION FOR CONTINUANCE ~~I TO THE HONORABLE CHRISTYLEE L. PECK: AND NOW, TO WIT, this 23rd day of July, 2012, come your Petitioner, Judy A. Estill, by her attorneys, Morris & Vedder, LLP, and file the within Motion for Continuance, to which the following is a statement: ~I ~I '~li 1. Your Petitioners are Judy A. Estill ("Petitioner"), Co-Administrator of the state ,'~ ~~ of Marlin L. Marsh (the "Deceased"). ~~~ 2. By Orders of Court dated May 8, 2012 and June 6, 2012, respectively, a hearing I 2012 at 10:45 a.m. June 22 ~I; was scheduled for Friday, ~, ~ 3. On June 18, 2012, Susan A. Kuhn, Co-Adminstrator of the Estate of Marlin L. ~;' i~'~ Marsh, through counsel, tiled Preliminary Objections to Petitioner's Petition to Remove her as MORRIS & VEDDER, ~~P~'u 3zN p„KEST, ~~~~~ Co-Administrator of the Estate of Marlin L. Marsh and a Petition to Remove Marc Roberts, ~~ YORK, PA ~','~, Esquire, as counsel for the Estate of Marlin L. Marsh. 'II ~~~~ r abour June 19, 2012, Ms. Kuhn, through counsel filed a Motion for ~ ~~~, 4. On o I Ali Continuance requesting the hearing scheduled for June 22, 2012 be continued to allow Attorney '~~ I I I ~, Roberts adequate time to respond to the Prelminary Objections and Petition to Remove. II 5. By Order of Court dated June 21, 2012, the hearing was rescheduled to Friday. ;,~ ,' I ~',~ August 3, 2012 at 1:30 p.m. ~ ~~~ ilakis has forwarded a proposed resolution to the hearing which your ~~ (, Attorney Kutt i i~ ~il,; Petition is in the processing of considering. ~~ ~~~ ~~`~~ 7, The undersigned was just retained today to represent Petitioner with regard to the ~I ~,,I ~I above-referenced estate and has not had adequate time to review the case and prepare for sue 1 hearing. g, The undersigned is scheduled to be out-of-town on vacation the week of July 30, 2012, returning to the office until Monday, August 6, 2012 and the week of August 20, 20]2, returning the office on Monday, August 27, 2012, the scheduling of which has been long- ~'; standing. ~~~i, 9. Petitioner's undersigned counsel has received verbal confirmation fiom ttorney i. ~~~~~~, Roberts that he is amenable to such a continuance. ~, MoRRis &vEOOER, ~~P~'~, 1 ~ petitioner has made a telephone call to Attorney Kutulalas to discuss t Ze same. 32 N. DUKE ST. ~i~ YORK, PA '' but is awaiting a return call. 11. This is your Petitioner's first rgeust for a continuance. 2 ~~ ~ ~~ ii 12. The granting of such continuance will not prejudice any party, but should result in '~ I jLidicial economy. ~, ill WHEREFORE, Petitioner respectfully requests that this Honorable Court grant a I'' I~~ continuance of the hearing schediiled for August 3, 2012. ~ Respectfully submitted, P 'R LL 'DDF VE MORRIS ~ '~ i i ~~ ~,, By: ~~ Clyde W. Vedder, quire ~ i~~ 32 North Dulce Street I ~~ P.O. Box 544 ~~ '' York, Pennsylvania 17405 ~, ~, i, (717) 843-9815 ~~ Supreme Court No. 32098 Doc. No. Cwv42470 IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA ~ ORPHANS' COURT DIVISION iIn the Estate of: No. 21-11-0068 MARLIN L. MARSH a/k/a ' MARLIN LEROY MARSH ~~Deceased II CERTIFICATE OF SERVICE I, Stephanie M. Warehime, Secretary to Clyde W. Vedder, Esquire, of the law firm of Morris & Vedder, LLP, 32 North Duke Street, PO Box 544, City of York, York County, Commonwealth of Pennsylvania, 17405, do hereby certify that on this 23rd day of July, 2012, I served a true and correct copy of Motion for Continuance, by placing the same in the United States mail, postage prepaid to: Jason P. Kutulakis, Esquire Marc A. Roberts, Esquire 2 W. High St. 149 E. Market St. ..,Carlisle, PA 17013 York, PA 17401 MORRIS & VEDDER, LLP MORRIS &VEDDER, L~ 32 N. DUKE ST. YORK, PA BY L _ ephanie M. Warehime, Secretary to Clyde W. Vedder, Esquire