HomeMy WebLinkAbout01-31-13
IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY
PENNSYLVANIA
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THE ESTATE OF LEON G.
RAMSEY, JR., DECEASED
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ORPHANS COUR~' I~V~IO~
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2011-00772 ~' `~'
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MOTION TO MAKE RULE ABSOLUT ON PETITION FOR~YtCTLE
TO WITHDRAW AS COUNSEL
NOW COMES the Petitioner, Marvin Abrams, Esquire, and moves this Honorable
Court to make the rule absolute on the Petition for Rule to Withdraw as Counsel and in
support thereof avers the following:
1. Petitioner filed a Petition for Rule to Withdraw as Counsel on December 10, 2012.
2. A Rule Returnable hearing in this matter was scheduled for January 8, 2013, at
9:30 a.m.
3. Petitioner filed a Motion for Continuance of Hearing on Petition for Rule to
Withdraw as Counsel on December 18, 2012, wherein Petitioner requested that
Respondent be required to file a response and/or objections to Petitioner's Petition for Rule
to Withdraw as Counsel.
4. An Order of Court was signed on December 27.2012, instructing Respondent to
file a response and/or objections to the Petition for Rule to Withdraw as Counsel for the
Estate of Leon G. Ramsey, Jr., Deceased, within twenty (20) days of the date of the Order
of Court. (See attached Exhibit A)
5. As of January 25, 2013, Respondent failed to comply with the Order of Court date
December 27, 2012, and no responses and/or objections have been filed to Petitioner's
Petition for Rule to Withdraw as Counsel for the Estate of Leon G. Ramsey, Jr., Deceased.
WHEREFORE, Petitioner requests that the Rule be made absolute and Marvin
Abrams, Esquire be withdrawn as counsel to the Estate of Leon G. Ramsey, Jr., Deceased.
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CERTIFICATE OF SERVICE
It is hereby certified that a true and correct copy of the foregoing Motion to Make
Rule Absolute on Petition for ule to Withdraw as Counsel was delivered via U.S. First
Class Mail thi day o 2013, to the following:
TRACY L. RAMSEY
116 ELM STREET
CARLISLE, PA 17013
TYMONTHY SHOLLENBERGER
2225 MILLENNIUM WAY
ENOLA, PA 17025
Allegheny Law Group, LLC
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THE ESTATE OF IN THE COURT OF COMMON PLEAS OF
LEON G. RAMSEY, JR., DECEASED :CUMBERLAND COUNTY, PENNSYLVANIA
V.
21-11-772 ORPHANS' COURT
ORD~ OURT
AND NOW, this day of December, 2012, upon consideration of
the Motion for Continuance of Hearing.on Petition for Rule to Withdraw Counsel, it is
hereby ordered that the Rule Returnable hearing scheduled for January 8, 2013, at 9:30
a.m. is CANCELLED. Respondent shall file a response andlor objections to the
Petitioner's Petition for Rule to Withdraw as Counsel for the Estate of Leon G. Ramsey,
Jr., deceased within twenty (20) days of service of this order. If Respondent does not
file a response and/or objections, Petitioner will file the appropriate motion to make. the
rule absolute and/or other documents within ten (10) days.
By the Court,
Albert H. Maslan , J. --=-.--_---____
Marvin Abrams, Esquire
Timothy Shoilenberger, Esquire
Tracy L. Ramsey
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IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY,
PENNSYLVANIA
THE ESTATE OF LEON G. ORPHANS COURT DIVISION
RAMSEY, JR., DECEASED
No. 2011-00772
MOTION TO MAKE RULE
ABSOLUATE FOR RULE TO
WITHDRAW AS 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