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Home My WebLink About05-06-14 � � � s � rn � o rn ,^� � � �°� o r�-, � �-, —c :=7 :� ...., �. r_` _....: ......., r--�y � � � j-` �....t U� �� .... •_ ., C:J ._w _.., , . « <1': _. , _. . , . �..-? �7 ,- ' ,.., ._. � �_,� —� d �,� �> c� _,,,� � —,1 V r,- -.,. _._ ` _� H _; �"j � a,.. rrl _v �..� ,�• .L G'> O Ronald L. Finck, Esquire ~' �' Pa. Sup. Ct. I.D. No. 89985 METTE, EVANS & WOODSIDE 3401 North Front Street P.O. Box 5950 Harrisburg, PA 17110-0950 Phone: (717) 232-5000 Fax: (717) 236-1816 rlfinck@mette.com � �: : IN THE COURT OF COMMON PLEAS OF ESTATE OF DOROTHY MARIETTA : CUMBERLAND COUNTY, PENNSYLVANIA a/k/a DOROTHY J. MARIETTA : : ORPHANS' COURT DIVISION : FILE NO. 2008-01132 MOTION OF RONALD L. FINCK, ESQUIRE AND THE LAW FIRM OF METTE, EVANS & WOODSIDE, P.C., FOR LEAVE TO WITHDRAW AS COUNSEL FOR TRUDY MINTZ The, undersigned counsel, Ronald L. Finck and the law firm of Mette, Evans & Woodside, P.C., ("Counsel"), respectfully file this Motion to Withdraw as Counsel, pursuant to Rule No. 1012(c) of the Pennsylvania Rules of Civil Procedure in support of which it is averred as follows: 1. On October 3, 2008, Trudy Mintz ("Mintz") retained the law firm of Mette, Evans & Woodside ("Counsel"), to represent her interests with regard to the above-captioned Estate. 2. Mintz's mother porothy Marietta a1k/a Dorothy J. Marietta, deceased ("Decedent") passed away on May 13, 2008. 3. Mintz is an attorney and is the Administratrix of the Decedent's Estate. Mintz requested that Mette, Evans & Woodside assist with the administration. 4. Mintz agreed to accept responsibility for all fees incurred in said representation. 5. On September 9, 2009, Mintz supplied an address at 236 E. Main Street, Mechanicsburg, PA 17055. This is the address that is on file for Mintz with the Pennsylvania Supreme Court Disciplinary Board. 6. Mintz also maintains an office address at 14 North Walnut Street, Suite 1, Mechanicsburg, PA 17055. 7. The primary asset in the Decedent's estate is an ancillary claim that is believed to be pending in New Mexico. 8. By letter dated May 3, 2011, the undersigned requested a status report from Mintz regarding the ancillary litigation. 9. Mintz did not respond to the May 3, 2011 letter. 10. By letter dated March 9, 2012, the undersigned, again, requested a status report from Mintz. 11. On April 25, 2012, the undersigned sent Mintz a letter indicating that he had not heard back from her following his March 9, 2012 letter as to the status of the ancillary action and that he needed a response as soon as possible. 2 12. On May 30, 2012, Mintz contacted the undersigned and requested that the Estate remain open and that Mette, Evans & Woodside evaluate potential additional claims the Estate may have that would be adjudicated in Pennsylvania. 13. On July 12, 2012, the undersigned sent Mintz a comprehensive letter concerning the potential claims the Estate may have against various individuals and asked Mintz to call the undersigned to advise whether she wished to pursue any such claims. 14. Mintz did not respond to the July 12, 2012 letter. 15. On April 15, 2013, the undersigned received a letter from the Cumberland County Register of Wills indicating that a Status Report by Personal Representative under Rule 6.12 was due by May 14, 2013. 16. On Apri126, 2013, the undersigned notified Mintz of the April 15, 2013 letter from the Cumberland County Register of Wills informing her of a delinquency in her account with the law firm, and requesting instructions concerning whether the Estate should be marked closed. 17. Mintz did not respond to the April 26, 2013 correspondence. 18. On May 14, 2013, the undersigned sent a Status Report to the Cumberland County Register of Wills' office for filing. 19. Also, on May 14, 2013, the undersigned sent a letter to Mintz enclosing a copy of the Status Report and indicating that he had received a response to his letter dated Apri126, 2013. The undersigned notified Mintz that if Mintz did not respond within ten days, he would file a Petition to Withdraw the appearance of Mette, Evans & Woodside as Mintz's counsel. 3 20. On May 15, 2013, the undersigned sent a letter to Mintz at both of her known addresses, via facsimile and e-mail stating that he has tried to reach her several times via regular mail and phone messages and instructing Mintz to contact him immediately. 21. Mintz has failed to respond to the undersigned's most recent correspondence and has failed to bring her delinquent account current. 22. The last known contact information for Mintz is: Trudy Ann Mintz, Esquire 14 North Walnut Street, Suite 1 Mechanicsburg, PA 17055 and Trudy Ann Mintz, Esquire 236 East Main Street Mechanicsburg, PA 17055 work phone: (717) 458-5921 cell phone: (717) 919-5992 Fax: (717) 458-5954 tmintz(a�Trud,yMariettaMintzLaw.com 4 WHEREFORE, Ronald L. Finck, Esquire and the law firm of Mette, Evans & Woodside, respectfully request this Honorable Court to grant them leave to withdraw as counsel on behalf of Trudy Ann Mintz. Respectfully submitted, METTE, EVANS & WOODSIDE By: �/J/�t,p-�- oC_ �.�•%�'ti Ronald L. Finck, Esquire Sup. Ct. I.D. #89985 3401 North Front Street P.O. Box 5950 Harrisburg, PA 17110-0950 Phone: (717) 232-5000 Fax: (717) 236-1816 Rlfincknmette.com Date: May 5, 2014 5 CERTIFICATE OF SERVICE I certify that I am this day serving a copy of the foregoing document upon the person(s) and in the manner indicated below, which service satisfies the requirements of the Pennsylvania Rules of Civil Procedure, by depositing a copy of same in the United States Mail at Harrisburg, Pennsylvania, with first-class postage, prepaid, as follows: Trudy Ann Mintz, Esquire Trudy Ann Mintz, Esquire 14 North Walnut Street 236 East Main Street Suite 1 Mechanicsburg, PA 17055 Mechanicsburg, PA 17055 METTE, EVANS & WOODSIDE By: ��- �_�,�� Ronald L. Finck, Esquire Sup. Ct. I.D. No. 89985 3401 North Front Street P. O. Box 5950 Harrisburg, PA 17110-0950 (717) 232-5000 - Phone Date: May 5, 2014 ��zs��