HomeMy WebLinkAbout02-07-14 ESTATE OF ANN W. GORDON : IN THE COT�RT OF COMMON PLEAS
: CUNIBERLANll �OUNTY, PENNSYLVANIA
: ORPHt'��1S' COURT DIVISION
MARIO R. GORDON � " ��
Executor : N0. 2011-00079 � --- '' �r'
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MARIELLE F. HAZEN, Esquire � !� x• �' ;,;.� ��.,�
Petitioner � r �' � -� •'�� `������' �
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PETITION FOR LEAVE TO WITHDRAW-� �: ` r--� ;=.`n
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AND NOW comes Marielle F. Hazen, Esquire, and files the wit}�in Petitior�r Leav� To
��Vithdraw as Counsel of Record for the F,xecutor of the Estate of Ann W. Gordon, and in support
hereof, respectfully represents as follows:
1. On December 2, 2010, Mario R. Gordon, of 11 White Birch Lane, Mechanicsburg,
PA 17050 (hereinafter referred to as "Executor") consulted with Petitioner, Marielle F. Hazen,
Esquire,of Hazen Elder Law,2000 Linglestown Road,Suite 202,Harrisburg, Pennsylvania 17110,
(hereinafter referred to as "Petitioner") regarding settlement of the Estate of Ann W. Gordon,
(hereinafter referred to as the "Estate�'.)
2. On January 19, 2011, Letters of Administration were granted to Executor by the
Register af Wills of Cumberland County, Penns}�lvania.
3. On January 11, 2011,Petitioner was formally retained by Executor to represent him
in the administration oi the Estate. Attached as Exhibit"A"is the fee agreement signed by Executor.
4. Petitioner has completc.d the prabate process,inchzding but not limited to,preparation
of the Petitior. for Prabate, preparation of the 5.6 notices and certificate, advertising the Estate,
gat'r.iering date of death asset and liability values,preparation and filing of the inheritance tax return,
obtair.in� creditor agreements on payment of decedent's outstai�ding debts and preparation of a
FdIT1iIV Settlement Agreemer�t and accounting.
5. On or about March,2012, Executor indicated by email that he had paid all the debts
and was closing the estate account. He also indicated that the services of Petitioner were no longer
required, and that he was leaving the state for an extended period of time to travel with his family
and that he would have limited access to any means of communication.
6. In an effort to finalize the estate, Petitioner emailed and mailed a hard copy of the
Family Settlement Agreenlent to Executor on October 8,2012 with a letter explaining the final steps
in the administration of his mother's estate. To date, Executor has not responded to the letter sent
by Petitioner's office.
7. In October of 2012,Petitioner received a collection notice from Healthport regarding
payment of an estate debt. Petitioner tried to contact Executor to confirm whether or not the debt
was paid,but to date Executor has not responded.
8. Petitioner is not able to continue representing Executor to finalize the estate because
of his failure to respond to communications. Petitioner further believes Executor no longer desires
to be represented by Petitioner.
9. Withdrawal of counsel can be accomplished without material adverse effect or
prejudice to the interest of Executor.
WHEREFORE, Petitioner respectfully requests that this Court grant Petitioner leave to
��vithdrati��h�:- apg�arance �o:-the Exetiutar, Mar'r:, I:. C:,rucn, in ��iis act:en.
Respectfully submitted,
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Date: .e�D• � o� �
ar e e . H zen, Esquire
Attorney I.D. No. 68003
2000 Linglestown Rd. Suite 202
Harrisburg, PA 17110 �
(717) 540-4332
ESTATE OF ANN W. GORDON : IN THE COURT OF COMMON PLEAS
: CUMBERLAND COUNTY, PENNSYLVANIA
: ORPHANS� COURT DIVISION
MARIO R. GORDON �
Executor : NO. 2011-00079
MARIELLE F. HAZEN, Esquire :
Petitioner :
CERTIFICATE OF SERVICE
I, M�rielle F. Hazen, Esquire, certify that on � , 2014, I served a
true and correct copy of the within Petition for Leave to Withdraw on the parties named below,
by depositing same in the United States mail, first class, postage prepaid, addressed as follows:
Mario R. Gordon
11 White Birch Lane
Mechanicsburg, PA 17050
Karl Gordon
3033 5`h Ave.
Parkville, MD 21234
Robert Gordon
2612 194t" Ave. KPS
Lakebay, WA 98349
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By �-� �
ariel e F. azen, Esquire
Hazen Elder Law
2000 Linglestown Road
Suite 202
Harrisburg, PA 17110
(7l7) 540-4332