HomeMy WebLinkAbout02-21-13Shelly J. Kunkel, Esquire
Supreme Court ID No. 64485
Wion, Zulli & Seibert
109 Locust Street
Harrisburg, PA 17101
(717)236-9301
IN THE MATTER OF
ESTATE OF KAREN A.
BRADSHAW,
ESTATE OF JOHN F.
BRADSHAW
t
..,v
o rn
~~ ~ ~~
rn=~ w ~
__~
z ~
~ f--- ~ ~
7C
~
C? ~ ~ ~y ~
"~+ -~ `~
~ ~ ~~~
tI
~ •-°I ~ {"' 1'Y`t
!"'
F-~ C!1 ~
IN THE COURT OF COMMAT PLEAS
CUMBERLAND COUNTY, PENNSYLVANIA
N0.21-12-1050 ORPHANS' COURT
N0.21-12-1051 ORPHANS' COURT
MOTION TO MAKE RULE ABSOLUTE
AND, NOW COMES Shelly J. Kunkel, Esquire, the Petitioner, who respectfully
represents the following:
1. On December 14, 2012 the Petitioner filed a Petition for Leave to
Withdraw Appearance Pursuant to Rule 1.16(b)(5) of the Pennsylvania Rules of
Professional Conduct in the Orphans' Court of Cumberland County to the above term and
number.
2. On December 20, 2012 the Court of Common Pleas of Cumberland
County, Orphans' Court Division, by the Honorable Christylee L. Peck, issued a
Preliminary Order and Rule directing that the Rule was returnable within thirty (30) days
of service.
3. Notice of the Petition was served by Petitioner upon all of the interested
parties by Certified Mail Return Receipt Requested on December 27, 2012.
4. Notice of the Preliminary Order and Rule was Petitioner upon all of the
interested parties by Certified Mail Return Receipt Requested on January 14, 2013.
5. Attached hereto is an Affidavit of Service indicating that all of the
Respondents were duly served with a copy of the Petition and Preliminary Order and
Rule.
6. The thirty (30) day period for responding to the Rule has now expired and
none of the recipients has filed an objection or answer to the Preliminary Order and Rule
nor filed an appearance in this matter.
WHEREFORE, it is respectfully requested that the Rule be made absolute and that
an Order be issued granting Shelly J. Kunkel, Esquire, leave and authority to withdraw
her appearance in the matter of both the Estate of Karen A. Bradshaw and the Estate of
John F. Bradshaw.
Respectfully submitted,
Date:~~~' ~ ab t
3
O , ZULLI & SEIBERT
By:
Shelly J. el, Esquire
Supreme Ct. ID# 64485
109 Locust Street
Harrisburg, PA 17101
Phone: (717) 236-9301
^ Complete Items 1, 2, and 3. Also complete
item 4 ff Restricted Delivery is de~red.
^ Print your name and address on the reverse
so that we can n~tum the card to you.
^ Attach this card to the back of the maiipie~e,
or on the front ff space permits.
1. Artie A/d`dre/s~sed to: /~/J///// /J]/_/ j/~~j / ~ /ate
~ ° ~~ ~ ~ y
~~~
asi _ ~_ __ _ i
,~
~ ~ ^ f
,!'_+ t* ^ Addressee
• ~~ l~ "'' ~ Date of Delivery
z~
D. Is address different trorr~item ? ^ Yes
H YES, delivery address Belo ^ No ~
Urp~
3 ce lype
1 `~ ~ l Mail D Express Mall
2. Article Number
f 1rertsfer from servJce /abeq
Registered ^ Return Recx~ipt for Merchandise
O Insured Mail ^ C.O.D.
4. Restricted DeUvery? (Ezba Feel ^ Yes
7111.1. I"ILt7r1 nnnn ooo~. ~~ .. ~ '
PS Form 3811, February 2004 Domestic Return Receipt ~~~~,,,
e.
V7 ~
~ ` e
~- ~,
r-~ • • • ~
~ •'
•
0" ~
Q' ~,j
Q' Postage $ ` Sa
~ Certified Fee , f"- ~ ~
~ C.~
0 Return Receipt Fee Postrnark
[~ (Endorsement Required)
Here
0 Restricted Delivery Fee
~ (Endorsement Required)
D Total Postage $ Fees ~ 6 • a o
~ nt To
r-~
~ S`{ieet, %~pt %Vo~; __ l?J2~el'~.~~ C!( C/C~~?~'r~,
o~POBoxNo. ` -------- - --------
t1: State, Z/P+4 ~ "°
-- ------------
- _ ~,------J-----
:t~ /~~~--// --
^ Complete items 1, 2, and 3. Also complete
item 4 if Restricted Delivery is desired.
^ Print your name and address on the reverse
so that we can return the card to you.
^ Attach this c~d'to the back of the mailpiece,
or on the front if space permits.
1. Article Addressed to:
~f ,
d~C~e / Y
t/ ~~~
A. Signatu
~ ^ Agent
R ~ Addressee
!•~ ~
Bf~ i ~ ( eJ C~p~e ~( I~ry .
D. Is delivery atid(kss dffferent from item 1? C~ Yes
If YES, enter delivery address below: O
3. Service Type
~Certifltad Mail O Express Mail
Registered ^ Return Receipt for Merchandise ,
~ Insured Mail ^ C.O.D.
4. Resfitcted Delivery? (Extra Fee) ^ Yes
2. Article Number
(Tta-uf+erfrom service ~1 7 011 0 4 7 0 o a a a 9 9 9 4 517 6
PS Form 3811, February 2004 Domestic Return Receipt tu259s-A2-nrt-~o' `
- _~
'•
~ ~
~ 1 ~ r
~~
~
~
~ •
•
~ . ~, ,,.
~ • • •
~- ~ ~~
iT'
~ Postage $
~ Certified Fee
O ~! . ~~ ~
~ Return Rece(pt Fee
O (Endorsement Required) t '-
Postmark
p Restricted Delivery Fee
~ (Endorsement Required) Here
~ Total Postage 8 Fees
._~~` '?~
~ Sent To
O _ /
fti .AP11Vo;- --------- / C
~
-
'
(
~
----°_
or PO Box No. ~ ~,Z -/
~_
.-~
Crty
Stat
4 -~ _.---- - j~2~
%? _
------
,
e
+
--- =-- :~` :~?-~_
IN THE MATTER OF
IN THE COURT OF COMMON PLEAS
:CUMBERLAND COUNTY, PENNSYLVANIA
ESTATE OF KAREN A. BRADSHAW :ESTATE N0.21-12-1050 ORPHANS' COURT
ESTATE OF JOHN F. BRADSHAW :ESTATE N0.21-12-1051 ORPHANS' COURT
AFFIDAVIT OF SERVICE
Commonwealth of Pennsylvania
County of Dauphin
SS
Shelly J. Kunkel, Esquire, the Petitioner, being duly sworn according to law, says
that on December 27, 2012 she served a true and correct copy of the Petition for Leave to
Withdraw Appearance and on January 14, 2013 she served a copy of the Preliminary Order
and Rule upon Kimberly A. Weindorf at her E. Northport, New York residence. Service of
both documents was achieved by U.S. certified mail, return receipt requested, as evidenced
by the certified mail receipts attached hereto a~~bit "A" and "B"
Shelly J. K~rkel, Esquir~ ~; ~;
C ~ rn rn
Sworn to and subscribed before ~ ~
.ao r~ " °
~
me this /~~~ day of ~ ~ ~ ~,
~ 2013. ~~~'
~~~ ~ ~'~
a
c~
....~,
/
c, o -,~
~
~
s ~
.~~,.
r- ~~n
(l Y_ ~C
.~
~
"'
Notary Public a ~ ~
My Commission Expires:
~.
C~~;~ ~~ ~;`::~~~~~:.~r~, ~44rrin scan
Fri` Gv~rm»si~n ~x ire March 19, 2014