HomeMy WebLinkAbout06-12-13 IN RE: IN THE COURT OF COMMON PLEAS
CUMBERLAND COUNTY, PENNSYLVANIA
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ESTATE OF � o rn m
E. MAI BALTIMORE, a/k/a ORPHANS' COURT DIVRIC c " o
ELLA MAI BALTIMORE. a r z --Cn
Late of Shippensburg Borough, z R r\-) °
Deceased 11/21/2010 No. 21-10-1207 o o
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MOTION TO MAKE. RULE ABSOLUTE "' 'z
NOW comes this tzt� day of June, 2013, comes Petitioner, Sean M. Shultz,
Esquire, attorney for the estate of E. Mai Baltimore, a/k/a Ella Mai Baltimore, and
respectfully moves this Court to make absolute the Rules to Show Cause which was issued in
the above-captioned matter on April 29, 2013, and in support states the following:
I. Movant filed a Petition to Withdraw as Counsel of Record on April 24,2013.
2. On April 29, 2013, this Court issued a Rule to Show Cause on Julian 1'.
Baltimore, the Administrator of the above-captioned estate, to show cause why the relief
requested in the Petition ought not be granted.
3. The relief requested in the Petition was that Sean M. Shultz, Esquire be
granted leave to withdraw as counsel of record for the above-captioned estate.
4. The Rule to Show Cause was served on Julian T. Baltimore by Certified
United States Mail, Return Receipt Requested, on May 2, 2013.
5. To date, Julian 1'. Baltimore has not responded to the Rule to Show Cause.
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WHEREFORE, Movant requests your Honorable Court to make the Rule to Show
Cause absolute and grant the relief requested in the Petition allowing Scan M. Shultz,
Esquire to withdraw as counsel of record for the Estate of E. Mai Baltimore, a/k/a Ella Mai
Baltimore.
Respectfully submitted,
SAIDIS. SULLIVAN & ROGERS
Sean M. Shultz
Attorney ID No. 90946
26 W. High Street
Carlisle, Pennsylvania 17013
(717) 243-6222
Movant
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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 Motion 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: G� I C 3�77
(((( Sean M. Shultz, Esq e
Movant
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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
CERTIFICATE OF SERVICE
AND NOW,this&./day of June, 2013, I, Sean M. Shultz, Esquire, hereby certify
that I have this day served the following persons with a copy of the foregoing Motion to
Make Rule Absolute by First Class U.S. Mail, 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
(717) 243-6222
Movant