HomeMy WebLinkAbout11-19-13 1N RE: VELMA B. GEBHARD, : 1N THE COURT OF COMMON PLE�� OF �
REAL PROPERTY OWNER : CUMBERLAND COUNT�PENNS�;VA�I�
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: FILE NO. 2013-00765 � .xri � —" ,
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: JUDGE THOMAS A. PLA(��; � �� �iF� .�-_
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PETITION TO WITHDRAW AS COUNSE�. ::''� ; �-,
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AND NOW, comes Petitioner, Bradley L. Griffie, Esquire, and the law firm of Griffie &
Associates, P.C., and petitions the Court as follows:
1. Your Petitioner has been retained by Respondent in the above captioned action, Terry J.
Gebhard, to represent him in the instant proceedings.
2. A hearing is scheduled in this matter for Wednesday,November 27, 2013, at 1:30 p.m. in
courtroom number 6 of the Cumberland County Courthouse, Carlisle, Pennsylvania,"
before The Honorable Thomas A. Placey.
3. Since his initial engagement in this matter, Petitioner has made repeated attempts to
provide legal advice and assistance to Terry J. Gebhard, hereinafter "Respondent," in an
effort to resolve the matters at issue without the need for litigation.
4. It has become evident that the positions taken by Petitioner, and Respondent, reflect
irreconcilable differences in their positions, not only relative to the approach in this case,
but also relative to the proposed final outcome of this case.
5. Petitioner's advice to Respondent has not be accepted and Petitioner is unable to
represent Respondent in the circumstances where Petitioner's legal advice, counsel, and
direction is ignored by Respondent.
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6. Due to the extensive and thorough difference of opinion between Petitioner and
Respondent, efforts to resolve this pending action by agreement and compromise have
been virtually non-existent.
7. Due to the extensive and thorough difference of opinion between Petitioner and
Respondent, trial preparation has been virtually non-existent.
8. It is virtually impossible for Petitioner to represent Respondent further in this matter.
9. A copy of this Petition has been forwarded by email and regular mail to Terry J. Gebhard
and to opposing counsel, David A. Baric, Esquire, together with a detailed explanation to
Respondent, Terry J. Gebhard of what necessitated this action.
WHEREFORE, Petitioner requests your Honorable Court to enter an Order allowing
Petitioner to withdraw as counsel in this matter.
Respectfully submitted,
Br iffie, Esquire
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Supreme Court ID No. 34349
GRIFFIE &ASSOCIATES, P.C.
200 North Hanover Street
Carlisle, PA 17013
(717) 243-5551
(800) 347-555
VERIFICATION
I verify that the statements made in the foregoing document are true and correct. I
understand that false statements herein are made subject to the penalties of 18 Pa.C.S. Section
4904, relating to unsworn falsification to authorities.
DATE: ( � �
IE, Petitioner
1N RE: VELMA B. GEBHARD, : 1N THE COURT OF COMMON PLEAS OF
REAL PROPERTY OWNER : CUMBERLAND COUNTY, PENNSYLVANIA
: ORPHANS COURT DIVISION
: FILE NO. 2013-00765
: JUDGE THOMAS A. PLACEY
CERTIFICATE OF SERVICE
I, Bradley L. Griffie, Esquire, hereby certify that I did, the �� day of November,
2013, cause a copy of the Petition to Withdraw as Counsel to be served upon Terry J. Gebhard,
by email and by first-class mail, postage prepaid, and opposing counsel, David A. Baric, Esquire,
by first-class mail,postage prepaid at the following addresses:
Terry J. Gebhard
402 Howell Street
Exton,PA 19341
Email: t_gebhard@hotmail.com
David A. Baric, Esquire
Baric & Scherer
19 West South Street
Carlisle, PA 17013
DATE: 1 � 13
, Esquire
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IE ASSOCIATES, P.C.
200 North Hanover Street
Carlisle, PA 17013
(717)243-5551
(800)347-5552