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HomeMy WebLinkAbout04-04-05 IN RE: MILDRED J. GERBER TRUST UNDER AGREEMENT DATED DECEMBER 19, 1997 : IN THE COURT OF COMMON PLEAS : CUMBERLAND COUNTY, PENNSYLVANIA : ORPHANS' COURT DIVISION : NO. 21-2002-0540 IN RE: MILDRED J. GERBER ESTATE :IN THE COURT OF COMMON PLEAS :CUMBERLAND COUNTY, PENNSYLVANIA :ORPHAN'S COURT DIVISION :NO.21-2001-92 TRUSTEE'S REQUEST FOR EXTENSION OF FILING DATE AND NOW, comes the Trustee, Frederick E. Gerber, II, by and through his attorney, Richard C. Rupp, Esquire, and respectfully avers as follows: 1. A Rule to show cause in the above action was served upon the Trustee in March 2005. 2. Trustee's twenty days in which to return Rule ends on April 4 or 5, 2005. 3. Trustee and his attorney have not conferred in this matter since before filing of this Rule in January 2005. 4. Trustee is presently out of the country. 5. Marilyn Gerber has filed four other Petititions to be answered. I ...... """'f:i -;"._,,~ 1',) .. en -J 6. A fax has been sent to Jacqueline Verney, Esquire,Lindsey Dare Baird, Esquire and Joanne Book, Esquire and we have not received their response in time for filing this Motion, but they are believed not to oppose Trustee's request. We were unsuccessful in reaching Marilyn Gerber. It is believed Marilyn Gerber opposes this Motion. WHEREFORE, Trustee respectfully request an extension in the time to file. 355 N. 21st Suite 205 Camp Hill, PA 17011 (717) 761 -3459 VERIFICATION I, Richard C. Rupp, verify that the statements in the foregoing document are true and correct to the best of my knowledge, information and belief. Said statements are based on my own knowledge, belief or information. They are made for the Trustee who is out of the country and is unable to sign in time for filing. I understand that false statements herein are made subiect to penalties of 18 Pa. C.S.A. * 4904 relating to unsworn falsification to authorities. Date: 4 !DI( 16~ CERTIFICATE OF SERVICE AND NOW, this 4- ~ay of April, 2005, I hereby certify that I have served a copy of the within document on the following by depositing a true and correct copy of the same in the U. S. Mail at Harrisburg, Pennsylvania, postage prepaid, addressed to: Ms. Marilyn J. Gerber 717 Market St., No. 317 Lemoyne, PA 17043 Joanne Book Christine, Esquire Rhoads & Sinon, LLP One South Market Square P. O. Box 1146 Harrisburg, PA 17108-1146 Jacqueline Verney, Esquire 44 South Hanover Street Carlisle, PA 17013 Lindsay Dare Baird, Esquire 37 South Hanover Street Carlisle, PA 17013 ~h?~<