HomeMy WebLinkAbout12-18-12IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY
PENNSYLVANIA
THE ESTATE OF LEON G.
RAMSEY, JR., DECEASED
ORPHANS COURT DIVISION
No. 2011-00772
MOTION FOR CONTINUANCE OF HEARING ON PETITION FOR
RULE TO WITHDRAW COUNSEL
NOW COMES the Petitioner, Marvin Abrams, Esquire, and moves this Honorable
Court to continue the hearing on the Petition for Rule to Withdraw Counsel and in support
thereof avers the following:
Petitioner filed a Petition for Rule to Withdraw Counsel on December 10, 2012.
2. A Rule Returnable hearing in this matter has been scheduled for January 8, 2013, at
9:30 a.m.
3. Due to circumstances beyond his control, Marvin Abrams, the attorney of record
for the Estate of Leon G. Ramsey, Jr., Deceased, had been previously scheduled to be out
of the jurisdiction in Atlanta, Georgia on that date, and as a result will not be able to attend
the scheduled hearing. If the court needs verification of this previously scheduled trip, it
will be provided.
4. Petitioner requests that Respondent file a response and/or objections to the
Petitioner's Petition for Rule to Withdraw as Counsel for the Estate of Leon G. Ramsey,
Jr., deceased, within a time period that shall be determined by the court.
WHEREFORE, Petitioner requests this court to continue this action to the next
available date.
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Attorney for Plaintiff
IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY,
PENNSYLVANIA
THE ESTATE OF LEON G. ORPHANS COURT DIVISION
RAMSEY, JR., DECEASED
No. 20 1 1-00772
MOTION FOR CONTINUANCE
OF HEARING ON PETITION
FOR RULE TO WITHDRAW
COUNSEL
Filed on behalf of Petitioner:
Marvin Abrams, Esquire
Counsel of Record for this Party:
MARVIN ABRAMS, Esquire
Pa. I.D. #35942
Allegheny Law Group, LLC
1034 Fifth Avenue, Suite 200
Pittsburgh, Pennsylvania 15219
(412) 471-4420
CERTIFICATE OF SERVICE
It is hereby certified that a true and correct copy of the foregoing Motion to
Continue Rule Returnable was delivered via U.S. First Class Mail this ~ d~ f
December, 2012, to the following:
TRACY L. RAMSEY
1 16 ELM STREET
CARLISLE, PA 17013
TIMONTHY SHOLLENBERGER
2225 MILLENNIUM WAY
ENOLA, PA 17025
By:
MARVIN ABRAMS, Esquire
Allegheny Law Group, LLC