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Home My WebLink About04-24-13 IN RE: IN TI IE COURT OF COMMON PLEAS CUMBERLAND COUN2' , PENNS�L 1gA ESTATE OF ® -0 `--' c� =c � CO E. MAI BALTIMORE, a/k/a ORPHANS' COURT DI 9 ' ry r,r s t ELLA MAI BALTIMORE, A Cf) Late of Shippensburg Borough, Deceased 11/21/2010 No. 21-10-1207 <, rM —9 c� C a cn PETITION TO WITHDRAW AS COUNSEL OF RECORD NOW comes this �3 'day of April,2013,comes Sean M. Shultz,Esquire,attorney for the estate of E. Mai Baltimore, a/k/a Ella Mai Baltimore, and presents this Petition to Withdraw as Counsel of Record, representing as follows: 1. Petitioner is Sean M. Shultz, Esquire, attorney for the Estate of E. Mai Baltimore,a/k/a Ella Mai Baltimore,with offices at Saidis,Sullivan&Rogers,26 West High Street, Carlisle, Cumberland County, Pennsylvania 17013. 2. E. Mai Baltimore, a/k/a Ella Mae Baltimore died intestate on November 21, 2010. 3. On December 9,2010,the Decedent's son,Julian T.Baltimore was appointed as Administrator of his Mother's estate. 4. Julian T. Baltimore is an adult individual, residing at 410 Westover Road, Law Offices of Sa.idis Shippensburg, Pennsylvania 17257. Sullivan & Rogers 5. An Inheritance Tax Return was due on August 23, 2011. 26 West High Street Carlisle,rn 17013 6. The only valuable asset of the Estate was the Decedent's real estate which was sold on April 14, 2011. The proceeds to the Estate from that sale were $29,051.23. 7. To date no Inheritance tax has been paid. 8. Petitioner has sent the Administrator numerous letters regarding filing the Inheritance Tax Return and paying the inheritance tax. To date he has not responded. Those letters are dated August 4,2011, September 12,2011,November 4,2011,February 1,2012, and July 16, 2012. Copies of these letters are attached hereto as Exhibit "A." 9. The Administrator also failed to pay invoices for Petitioner's legal fees. 10. Due to the Administrator's unresponsiveness to Petitioner,Petitioner cannot effectively represent the Estate of E.Mai Baltimore,a/k/a Ella Mai Baltimore,and wishes to terminate his representation of the Estate. 11. Petitioner wishes to withdraw his appearance as the Estate's counsel of record. 12. No Judge has been assigned to this matter. WHEREFORE, Petitioner requests your Honorable Court to provide leave of Court and Order that Petitioner is withdrawn as counsel of record for the Estate of E. Mai Baltimore, a/k/a Ella Mai Baltimore. Respectfully submitted, MV - Saidis S Law Offices of Sean M. Shultz Sullivan Attorney ID No. 90946 26 W. High Street & Rogers Carlisle, Pennsylvania 17013 26 West High Street (717) 243.6222 Carlisle,PA 17013 Petitioner IN RE: IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA ESTATE OF E. MAI BALTIMORE, a/k/a ORPHANS' COURT DIVISION ELLA MAI BALTIMORE, Late of Shippensburg Borough, Deceased 11/21/2010 No. 21-10-1207 VERIFICATION The foregoing Petition is true and correct to the best of my knowledge, information and belief. I understand that false statements made herein are subject to the penalties of 18 Pa. C.S.A. Section 4094, relating to unsworn falsification to authorities. Date: � l�j !3 3=A R— Sean M. Shultz, Esquire Petitioner Law Offices of Saidis Sullivan & Rogers 26 West High Street Carlisle,PA 17013 Exhibit "A"' Law Offices of Saidis Sullivan & Rogers 26 West High Street Carlisle,PA 17013 4 Irvine Row Phone: 717.701.8412 Carlisle,PA 17013 VAw OFFICE Fax: 717.701.8416 OF SEAN M. SHULTZ,i�c contact @Shu1tzLaw0ffice.com August 4, 2011 Julian Baltimore 410 Westover Road Shippensburg, Pennsylvania 17257 RE: Estate of E. Mai Baltimore Our File No. 1439.1 Dear Julian: Please be advised that the deadline to file the Inheritance Return in the above-referenced matter is August 22, 2011. To date we have not received the updated information from you needed to complete the return. Please provide an update of any assets or debts of the estate by August 11, 2011. Once the Return is drafted you will be contacted to schedule an appointment to review and sign it. If the Return is not filed and the inheritance tax paid by August 22, 2011, interest will begin to accrue on the amount of inheritance tax that is due. I cannot determine the amount of inheritance tax due until I get the requested information from you to complete the Return. Should you have any questions or wish to discuss this further, please do not hesitate to contact me. Very truly yours, LA-W OF SEAN M. SHULTZ, P.C. Sean M. Shultz SMS/dmh THE ADVICE YOU NEED.THE RESPECT YOU DESERVE. 4 Irvine Row Phone: 717.701.8412 Carlisle,PA 17013 LAW OFFICE Fax: 717.701.8416 OF SEAN M. SHULTZ,r.c. contact@ShultzLawOffice.com September 12,2011 Julian Baltimore 410 Westover Road Shippensburg,Pennsylvania 17257 RE: Estate of E. Mai Baltimore Our File No. 1439.1 Dear Julian: As you are aware, on August 23, 2011, interest began to accrue on the amount of inheritance tax that is due, because the Return was not filed and tax was not paid within nine months of the date of your mother's death. I received your updated list of expenses for the estate. On September 6, 2011, my assistant left you a voicemail that we need specifics on these expenses. Please provide the following: 1. Truck usage and maintenance - $510.00. Usage of what truck and what was it used for? Provide details regarding the maintenance on the truck? 2. Gas - $630.00. Was this gas for your vehicle? If so, for how many trips, to where, and how many miles? 3. Storage Rental — totaling $685.00. What was being stored? We need the copy of the agreement signed with the storage rental company. 4. Miscellaneous - $190.00. Were these expenses related to cleaning out your mother's house? We need more details. 5. Labor for 3 weeks of moving, cleaning house and outside work - $1,600.00. Who provided this labor and how much did you pay them per hour, or what was the basis for the calculation of $1,600.00 (time and hourly rate)? 6. Dump fees-$300.00. Is this for garbage from your mother's home? Do you have a receipt? Please provide this information as soon as possible. Very truly yours, OFFICE OF SE M. SHULTZ, P.C. an M. Shultz SMS/dmh THE ADVICE YOU NEED. THE RESPECT YOU DESERVE. �Aw Opprcz, SPAN M. SHULTZ,rc. November 4, 2011 Julian Baltimore 410 Westover Road Shippensburg, Pennsylvania 17257 RE: Estate of E. Mai Baltimore Our File No. 1439.1 Dear Julian: As you are aware, on August 23, 2011, interest began to accrue on the amount of inheritance tax that is due, because the Return was not filed and tax was not paid within nine months of the date of your mother's death. I have not received a response to my letter to you dated September 12, 2011, requesting more information on the list of expenses you provided to my office. I have enclosed a copy of that letter for your convenience. Please respond to the letter as soon as possible. Interest is accruing daily on the amount of inheritance tax that is due. Very truly yours, OFFICE OF SEAN M. SHUT P.C. S M. ul SMS/dmh Enclosure 4 Irvine Row Carlisle Pennsylvania 17013 717-701-8412 717-701-8416 fax Law Offices of SA.IDIS, SULLIVAN & ROGERS A PROFESSIONAL CORPORATION 26 WEST HIGH STREET CARLISLE,PENNSYLVANIA 17013 ROBERT C.SATDIS LEMOYNE OFFICE: DANIEL L.SULLIVAN TELEPHONE:(717)243-6222-FACSIMILE:(727)243-6486 635 NORTH 12TH STREET,STE.400 ELYSE E.ROGERS EMAIL:attorney®ssr-attorneys.com LEMOYNE,PA 17043 JOHN A.FEICHTEL www.ssr-attorneys.com TELEPHONE:(717)612-5800 DEAN E.REYNOSA FACSIMILE: (717)622-5805 TODD F.TRUNTZ Of Counsel MARYLOU MATAS SEAN M.SHULTZ JOHN SL L.G STEPHE N LROSS .G JASON E KELSO E REPLY TO CARLISLE February 1, 2012 Julian Baltimore 410 Westover Road Shippensburg,Pennsylvania 17257 RE: Estate of E. Mai Baltimore Our File No. 81087-S880127 Dear Julian: I have written to you multiple times shortly before the deadline for the filing of an Inheritance Tax Return and then twice since that deadline has passed. I informed you in those letters that the Pennsylvania Department of Revenue will continue to assess interest and penalties since the date that the Return was due. You have been utterly unresponsive. If you do not reply to my office within one week of the date of this letter, I will assume that you no longer wish to avail yourself of my services. I will then seek to withdraw from representing the Estate. The Pennsylvania Department of Revenue will, at some point in the future, eventually seek to enforce the tax, interest and penalties against you. For your convenience, I have enclosed the previous , two letters that I sent to you. I look forward to hearing from you very soon. Very truly yours, SA , SULLIVAN &ROGERS can M. Shultz SMS/dmh Enclosures : Law Offices of SAIDIS, SULLIVAN & ROGERS A PROFESSIONAL CORPORATION 26 WEST HIGH STREET ROBERT C.SAIDIS CARLISLE,PENNSYLVANIA 17013 LEMOYNE OFFICE: DANIEL L.SULLIVAN TELEPHONE:(717)243-6222-FACSIMILE:(717)243-6486 635 NORTH 12-STREET,STE.400 ELYSE E.ROGERS EMAIL:attorney @ssr-attorneys.com LEMOYNE,PA 17043 JOHN A.FEICHTEL www.ssr-attorneys.com TELEPHONE:{717}612-5800 DEAN E.REYNOSA FACSIMILE: (717)612-5805 TODD F.TRUNTZ MARYLOU MATAS Of Counsel SEAN M.SHULTZ JOHN E.SLIKE ROBERT B.HAMILTON STEPHEN L.GROSE HANNAH WHITE-GIBSON REPLY TO CARLISLE July 16, 2012 Julian Baltimore 410 Westover Road Shippensburg, Pennsylvania 17257 RE: Estate of E. Mai Baltimore Our File No. 81087-5880127 Dear Julian: This letter is to confirm in writing that you agreed to pay $50.00 by July 13, 2012, towards your current balance due of$312.80. You have also agreed to pay $50.00 per month towards the balance due until it is paid in full. Due to your history of non-payment and difficulty in reaching you, I am requesting a $500.00 retainer from you, after the payment of the $312.80 currently due, before I will do any further work on your mother's estate. In previous letters to you, I informed you that the Pennsylvania Department of Revenue will continue to assess interest and penalties against you from August 23, 2011, the date that the Inheritance Tax Return was due. They can and will seek payment from you as a beneficiary of the estate. Should you have any questions or wish to discuss this matter further, please do not hesitate to contact me. Very truly yours, SAIDIS, SULLIVAN & ROGERS Sean M. Shultz SMS/dmh IN RE: IN TTIE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA ESTATE OF E. MAI BALTIMORE, a/k/a ORPHANS' COURT DIVISION ELLA MAI BALTIMORE, Late of Shippensburg Borough, Deceased 11/21/2010 No. 21-10-1207 CERTIFICATE OF SERVICE AND NOW,this 23r-j-day of April,2013,I,Sean M. Shultz, Esquire,hereby certify that I have this day served the following persons with a copy of the foregoing Petition to Withdraw as Counsel of Record by U.S.Certified Mail,Return Receipt Requested,addressed as follows: Julian T. Baltimore 410 Westover Road Shippensburg, Pennsylvania 17257 Administrator of the Estate of E. Mai Baltimore, a/k/a Ella Mai Baltimore SAIDIS, SULLIVAN & ROGERS Sean M. Shultz Attorney ID No. 90946 26 W. High Street Carlisle, Pennsylvania 17013 Law Offices of (717) 243-6222 Saidis Petitioner Sullivan & Rogers 26 West High Street Carlisle,PA 17013