HomeMy WebLinkAbout09-28-12
RFC~~r'cf? C'=~ILE OF
[~[n ~~--r +!
In the Court of Common Pleas ~~~~ SEP 28 A~9 I f ~ 53
Cumberland County, Pennsylvania
~JLI. :.i r
In Re: Estate of : OR~R ANA UH?'
Robert L. Brown Orphans' Court_ ~5ivision ~•~ ~
No.: 21-12-0427
MOTION TO WITHDRAW AS COUNSEL
1. Robert L. Brown died on November 7, 2011.
2. The Will of Robert L. Brown was probated in Cumberland County on
April 13, 2012 as estate 21-12-0427 and Amy E. Brown, formerly known as Amy E.
Lane, was appointed Executrix of the Estate of Robert L. Brown.
3. Aaron C. Jackson, Esquire and TuckerArensberg, P. C. were retained by
Amy E. Brown as counsel for the estate.
4. Aaron C. Jackson and TuckerArensberg, P.C. have represented Amy E.
Brown during the administration of the estate.
5. Aaron C. Jackson was advised on August 3, 2012 to cease representation of
the estate by Amy E. Brown, Executrix before the completion of the administration.
Attached as Exhibit "A" is a General Release signed by the Executrix demonstrating this
fact.
WHEREFORE, it is respectfully requested that the Court grant Aaron C. Jackson and
TuckerArensberg, P.C. leave to withdraw as counsel for the Estate of Robert L. Brown in
the above-captioned case. TUCKER ARENSBERG, PC.
Aaron C. Jackson, Esq.
Attorney I.D. No. 200490
2 Lemoyne Drive, Suite 2
Lemoyne, PA 17043
(717) 234-4121
,+
GENERAL RELEASE
WHEREAS, the parties to this full and final release Amy E. Brown, (hereinafter, "Amy"); and
Tucker Arensberg, P.C., a law firm and Aaron C. Jackson, an individual and Anthony J. Foschi,
an individual (collectively hereinafter, "Tucker"); and
WHEREAS, previously Tucker had provided legal representation to Amy relating to the Estate
of Robert L. Brown (hereinafter, "Estate") and the Brown Living Trust dated August 11, 1999,
(hereinafter, "Trust") and
WHEREAS, as of August 3, 2012 Tucker ceased representation of Amy and at that time advised
Amy that Tucker could no longer represent Amy regarding the Estate or Trust; and
WHEREAS, in connection with the ending of the Tucker representation of Amy, Tucker advised
Amy one half (1 /2) of the value of the Trust should be divided equally between the two surviving
beneficiaries of the Estate and Trust namely, Amy E. Brown and Walker Koppleman-Brown and
Amy is responsible for all communications, notices, filings, distributions, accountings, tax
payments, and due diligence as required by Pennsylvania or other applicable law; and
WHEREAS, Amy has advised Tucker that she wishes to proceed without counsel representing
her;
THEREFORE: It is understood and agreed that I, Amy E. Brown, hereby declare that the terms
of this agreement have been completely read by me and are fully understood and voluntarily
accepted by me. I hereby disengage Tucker Arensberg, P.C. as legal counsel in this matter.
In witness wh reof, wi the intent to be legally bound hereby, I have hereunto set
my hand and seal this :3 day of , 2012.
WITNESS:
-, C
Amy E. Brown
ACKNOWLEDGMENT
COMMONWEALTH OF PENNSYLVANIA
COUNTY OF CUMBERLAND ~
Qn this ~ day of , 2012, before me ersonall
appeared, 7`r~t p y
known or sufficiently identified to me
to be the person(s) named herein and who executed the above agreement and acknowledged that
she executed the same as a free act and deed.
Witness my hand and notaries seal this date f h said.
COMMONWEALTH OF PENNSYLVANIA
NoWial Seal NOTARY LIC M Commission Expires: ~ ! ~~
Fakh D. Henry, Nohry PubNc
New Cumberland Boro, Cumberland Count
h`'~ ~ ~a ~. 9' X12 EXHIBIT
Member, Pennsylvania Assoclatlon of Nomries
CERTIFICATE OF SERVICE
I, Aaron C. Jackson hereby verify that I served a true and correct copy of the
foregoing document on Amy E. Brown by U.S. Mail, First-Class, Postage Prepaid, on
the __~~~ day of September, 2012, addressed as follows:
Amy E. Brown
511 Penn Ayr Road
Camp Hill, PA 17011
Aaron C. Jacks
Attorney for the
wire
of Robert L. Brown