HomeMy WebLinkAbout12-14-12 (2)r ~
Jeffrey G. Brooks
Pa. I.D. No. 43654
Minto Law Group, LLC
Two Gateway Center
603 Stanwix Street, Suite 2025
Pittsburgh, PA 15222
(412) 201-5525 phone
Attorney for Plaintiff
R~caR~~ ~~~'~`~ ~~
REGIS ~ v, o~ °. ~,
~c12 CEC 1`~ ?~ ' '~?
CLE~t~ ~ `~
ORPNAId5' C~~. i
GUMBE#tLAPaD Ct~?„ ~'~'
COURT OF COMMON PLEAS
CUMBERLAND COUNTY, PENNSYLVANIA
ORPHANS' COURT DIVISON
In re:
Estate of Robert M. Mumma, Deceased.
No. 21-86-398
Petition for Leave of Court to Withdraw Appearance of Counsel
Pursuant to Pennsylvania Rule of Civil Procedure 1012(c), the undersigned Minto
Law Group, LLC and Jeffrey G. Brooks hereby petition for leave to withdraw as counsel
for Robert M. Mumma, II in the within action and in support thereof, state as follows:
1. On April 23, 2012 the undersigned Counsel entered an appearance on behalf
of Mr. Mumma, II in this action.
2. Previously and at various times, Mr. Mumma had been represented by other
counsel and also had appeared pro se, which pro se appearance included,
but was not limited to, self-representation and participation in numerous
evidentiary hearings and conferences before Joseph Buckley, Esquire,
specially appointed by Court to conduct hearings and render one or more
1
T
Report and Recommendation to the Court with respect to various issues of
the Estate of Robert M. Mumma, Deceased.
3. Recent and irretrievable differences have arisen between Mr. Mumma, II and
the undersigned Counsel rendering continuing representation exceedingly
difficult, if not impossible and, as such, due professional considerations
require termination of representation.
4. Pursuant to this Court's local rules, the undersigned certifies that the full text
of the within Petition and Proposed Order, as well as the fact of the Counsel
to file such Petition have been disclosed to Mr. Mum~ra. Copies of the
Petition and Proposed Order also are being served on all represented Parties
through Counsel and all unrepresented Parties directly by means of electronic
communication and United States mail.
5. Despite inquiry, Counsel is not aware of Mr. Mumma's intention whether to
proceed with other counsel or resume his prior pro se participation. Mr.
Mumma has demonstrated in the past his awareness of the facts and issues
pertinent to his interests in the subject estate.
6. Wherefore, the undersigned Minto Law Group, LLC and Jeffrey G. Brooks
respectfully request that this Court grant leave for withdrawal of appearance
in this matter.
Je rey G. rooks
Pa. I.D. No. 43654
Minto Law Group, LLC
Two Gateway Center
603 Stanwix Street, Suite 2025
2
Pittsburgh, PA 15222
(412) 201-5525 phone
Attorney for Robert M. Mumma, II
Dated: December 10, 2012
_~, ~
CERTIFICATE OF SERVICE
I hereby certify that a true and correct copy of the foregoing document was served by
email and first-class United States mail, postage prepaid, December 10, 2012 upon
the following:
Joseph D. Buckley, Esquire
1237 Holly Pike
Carlisle, PA 17013
No V. Otto, III, Esquire
George B. Faller, Esquire
Jennifer L. Spears, Esquire
Martson Law Offices
10 East High Street
Carlisle, PA 17013
Brady L. Green, Esquire
Morgan, Lewis & Bockius, LLP
1701 Market Street
Philadelphia, PA 19403-2921
Richard F. Rinaldo, Esquire
Williams Coulson Johnson Lloyd Parker & Tedesco, LLC
One Gateway Center
Pittsburgh, PA 15222
Ms. Linda M. Mumma
P.O. Box 30436
Bethesda, MD 20824
I.D. No. 43654
into Law Group, LLC
Two Gateway Center
603 Stanwix Street, Suite 2025
Pittsburgh, PA 15222
(412) 201-5525 phone
Attorney for Robert M. Mumma, II