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HomeMy WebLinkAbout05-28-14 IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA ORPHANS' COURT DIVISION In re: No. 21-13-154 QJ Estate of E. JEANNE (HOGUE) RECHT, ° rn deceased s rn rn o� 0 2 o zc� cn :7J > r 0 MOTION FOR A CONTINUANCE ?' v, Ti co G � c � AND NOW comes Marc Roberts, Esquire, attorney for!-2 §nifgT, A. r rn Margush, and requests your Honorable Court as follows> ~trn o 1 . A Petition for Citation to show cause why appeal from the Decree of Register of Wills, dated February 7, 2013 , admitting to probate the purported writing of E. Jeanne (Hogue) Recht should not be sustained was filed on April 10, 2014, by Appellant, Jan Recht Stogsdill . 2 . An Answer to said Petition was filed on or about April 29, 2014, by the Executor, Jennifer A. Margush. 3 . An Order of Court was issued by the Honorable Thomas A. Placey scheduling a hearing on the Petition for Citation for June 18 , 2014, at 1 :30 p .m. 4 . Trial counsel for the Executor, Marc Roberts, Esquire, has a pre-existing commitment on Wednesday, June 18 , 2014, and Thursday, June 19, 2014, to attend freshman orientation with his son at Penn State University (main campus) . 5 . Attorney Roberts has spoken to the Appellant' s counsel, Kathleen Misturak Gingrich, Esquire, as well as to Richard R. Reilly, Esquire, the Executor' s counsel in the estate administration, and they have no objection to this request for a continuance . 6 . Attorney Roberts will have his staff take responsibility for identifying a new hearing date that is agreeable to the Court and to the parties . WHEREFORE, it is respectfully requested that the hearing in the above captioned matter be rescheduled to a mutually agreeable date and time . Respectfully submitted, Marc Robert , Esquire Attorney for Jennifer Margush 149 East Market Street York, PA 17401 (717) 843-1639 I .D. No. 34355 IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA ORPHANS' COURT DIVISION In re : No. 21-13-154 Estate of E. JEANNE (HOGUE) RECHT, deceased CERTIFICATE OF SERVICE I, MARC ROBERTS, ESQUIRE, attorney for Jennifer Margush, hereby certify that I have on the 27th day of May, 2014, served the attached Motion for a Continuation by first class mail, postage prepaid, upon the persons and to the addresses indicated below: Kathleen Misturak Gingrich, Esquire THE LAW OFFICES OF PETER J. RUSSO, P.C. 5006 East Trindle Road, Suite 203 Mechanicsburg, PA 17050 Richard R. Reilly, Esquire 54 North Duke Street York, PA 17401 John M. Recht, Jr . 5520 Dansby Place Tallahassee, FL 32311 Jane Recht 37 Randal Avenue West Hartford, CT 06110 James Recht P . 0. Box 308 Roxbury, CT 06783 Joan R. Wolf 411 Limestone Road Carlisle, PA 17015 Jan Recht Stogsdill 25 Country Club Road Shalimar, FL 32579 MARC ROBERTS, ESQUIRE