HomeMy WebLinkAbout06-11-13 7.
In the Court of Common Pleas of Cumberland County, Pennsylvania
Orphans' Court Division
In re: the Estate of William L. Gouse, deceased
Late of South Middleton Township No. 2011-00528
Counsel's Petition for Leave to Withdraw
Now comes the petitioner, Flower Law, LLC, and prays for leave to withdraw as counsel
for the respondent, Lisa M. Minnich, in her capacity as executrix for the William L. Gouse
Estate, stating in support the following:
1. The petitioner is Flower Law, LLC, a law firm operated as a partnership with
mailing address of 10 W. High Street, Carlisle, PA 17013
2. The respondent is Lisa M. Minnich, in her capacity as executrix for the William L.
Gouse Estate, with mailing address of 381 Criswell Drive, Boiling Springs, PA 17007.
3. The respondent has refused all reasonable offers to purchase real property of the
estate,which has no cash, while inheritance and real estate taxes remain unpaid and delinquent.
4. The respondent refuses to communicate with the petitioner;
5. The respondent owes the petitioner unpaid legal fees, as wells as costs advanced
by the petitioner to prepare the estate's real property for sale.
6. The petitioner lacks information necessary to file the Rule 6.12 Status Report
now overdue.
WHEREFORE, the petitioner prays this Court issue a Rule upon the respondent to show
cause why leave should not be granted to the petitioner to withdraw as counsel for the
respondent in her capacity as executrix for the William L. Gouse Estate.
Respectfully submitted:
Flower Law, LLC
Dated: , / By: �/ to C
Thomas E. Flower
° C— a S. Ct. #83993
� o FLOWER LAW, LLC
10 W. High St.
Carlisle, PA 17013
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In the Court of Common Pleas of Cumberland County, Pennsylvania
Orphans'Court Division
In re: the Estate of William L. Gouse, deceased
Late of South Middleton Township File No. 2011-00528
VERIFICATION
I, Thomas E. Flower, hereby verify that the statements made in the foregoing petition are
true and correct, to the best of my knowledge, information and belief. I understand that false
statements herein are made subject to the penalties of 18 Pa. C.S.A. § 4904, relating to unsworn
falsification to authorities.
Dated: 2013
Thomas E. Flower
1
1
In the Court of Common Pleas of Cumberland County, Pennsylvania
Orphans' Court Division
In re: the Estate of William L. Gouse, deceased
Late of South Middleton Township No. 2011-00528
CERTIFICATE OF SERVICE
A-
On this�day of June, 2013, I, Thomas E. Flower, hereby certify that I served a
true and correct copy of the foregoing Com upon Lisa M. Minnich, the
respondent, by placing a copy of same in the United States Mail, first class, postage
prepaid, addressed as follows:
Lisa M. Minnich
381 Criswell Drive
Boiling Springs, PA 17007-9695
Dated: 4° 7j By:
Thomas E. Flower
S. Ct. #83993
FLOWER LAW, LLC
10 W. High St.
Carlisle, PA 17013
(717) 243-5513
Counsel for the plaintiff