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IN THE COURT OF COMMON P YLV �A UMBERLAND COUNTY,
PENNS
ORPHANS' COURT DIVISION
In re: Estate of Cheri Eileen Keiter,Deceased .
NO. 2013-0848
MOTION TO WITHDRAW AS COUNSEL
AND NOW,comes Petitioner,Shawn M.Stottlemyer,Esquire,and files this Motion to Withdraw
as Counsel,whereof the following is a statement,to wit:
1. Mooney & Associates LLC had previously entered an appearance in the above matter
through Jeff R. Lawrence,Esquire.
2. Jeff R.Lawrence,Esquire withdrew as counsel and Shawn M.Stottlemyer,Esquire entered
his appearance on behalf of Mooney& Associates,LLC.
3, Petitioner is Shawn M. Stottlemyer,Esquire, counsel for Kenneth Lee Keiter,Jr.who was
appointed Administrator of the Estate of Cheri E. Keiter, on August 5,
2013.
4, Respondent is Kenneth Lee Keiter,Jr.,Administrator of the Estate of Cheri Eileen Keiter.
5, Good cause exists under Rule 1.16 of the Rules of Professional Responsibility(204 Pa.
Code 81.4) for Petitioner to withdraw as counsel of record.
(. Respondent has had no contact with Petitioner despite repeated con-espondences and phone
calls to Respondent.
'7, Respondent has failed to cooperate with requests to execute the REV-1500 Inheritance Tax
Return and to proceed with this estate despite repeated requests.
g, Petitioner's representation of Respondent has been and will continue to be rendered
unreasonably difficult by Respondent, as he does not comply with Petitioner's requests.
9, On information and belief,withdrawal will not delay any stage of the estate.
10. All parties are notified if they desire to file an objection to the withdrawal of counsel, a
written objection must be filed with the Orphans' Court Office within ten (10) days of the filing of the
within Motion and serve a copy on all parties.
WHEREFORE, Shawn M. Stottlemyer, Esquire, requests leave of Court to withdraw his
appearance as counsel of record for Kenneth Lee Keiter,Jr.,Administrator, in the above-captioned case.
Respectfully submitted,
MOONEY& ASSOCIATES
`��2� �J
By.� // "`
Shawn M. Stottlemyer,Esquire
Attorney for Administrator
I.D. # 312794
MOONEY & ASSOCIATES
2 South Hanover Street
Carlisle,PA, 17013
(717)243-4770
VERIFICATION
I verify that the statements contained in the foregoing Motion to Withdraw as Counsel are true and
correct based on my personal knowledge or information and belief. I understand that false statements are
subject to the penalties of 18 Pa. C.S. 4904 relating to unsworn falsification to authorities.
_ �3 C�{ �2�
Date:� E uire
Shawn M. Stottlemyer, sq
IN THE COURT OF COMMON PLEAS OF ADAMS COUNTY, PENNSYLVANIA
ORPHANS' COURT DIVISION
In re: Cheri E. Keiter,Deceased . NO. 2013-0848
CERTIFICATE OF SERVICE
I, Shawn M. Stottlemyer,Esquire,counsel for Kenneth Lee Keiter,Jr.,hereby certify that on this
`�� day of f� `�t y , 2014, I have forwarded a copy of the Motion to Withdraw as
Counsel, in the above-captioned action to the following individual(s) by regular U.S. Mail as set forth
below:
Kenneth Lee Keiter, Jr.
30 Carlisle Road
Newville,PA 17241
Respectfully submitted,
MOONEY&ASSOCIATES
By: ��
Shawn M. Stott emyer, Esquire
Attorney for Administrator
I.D. #312794
MOONEY & ASSOCIATES
2 South Hanover Street
Carlisle,PA, 17013
(717) 243-4770