HomeMy WebLinkAbout07-02-14 IN THE COURT OF COMMON PLEAS OF
CUMBERLAND COUNTY,PENNSYLVANIA
IN RE:
EDITH S. RIFE TRUST ORPHANS' COURT DIVISION
NO. 21-11-0325 o ri
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NO. 21-10-1006
NO, 21-83-0773
MOTION TO MAKE ORDER TO SHOW CAUSE ABS0UUi'E ,.._. r>
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NOW COME, Steven A. Maxwell, Sherri Maxwell, Douglas Maxwell, and Barry
Maxwell, (hereinafter "Movants") by and through their undersigned counsel, moving this Court
to make Petitioners' Motion to Make Order to Show Cause Absolute, stating in support thereof
the following:
1. Petitioners' counsel filed a Petition for Rule to Show Cause directing Fred H. Junkins,
Executor of the Estate of Charles J. Rife, deceased, to show what cause he may have that the
Petitioners' responses to the Request for Admissions should not be accepted as timely.
2. On May 16, 2014, the Court entered an Order directing service of the Rule to Show
Cause to be made upon Fred H. Junkins by regular first class mail to counsel for the Estate of
Charles J. Rife, Murrell R. Walters, III, Esquire, and Wayne F. Shade, Esquire, with courtesy
copies mailed to James D. Cameron, Esquire and David A. Fitzsimmons, Esquire.
3. Petitioners' counsel served all of the aforementioned counsel by first class mail on or
about May 16, 2014.
4. Petitioners' counsel did not receive notice from the U.S. Postal Service that any of
these mailings were returned as undeliverable.
5. Petitioners' counsel filed a Certificate of Service with the Orphans' Court on May 22,
2014.
6. The requisite twenty (20) days have lapsed after service of the Rule to Show Cause.
WHEREFORE, Petitioner respectfully requests this Honorable Court to make the Order
to Show Cause Absolute.
Respectfully submitted,
LAW OFFICES OF CRAIG A. DIEHL
Date: 3p By:
Craig A(Mehl, Esquire
Attorney I.D. No. 52801
3464 Trindle Road
Camp Hill, PA 17011
Tel: (717) 763-7613
Fax: (717) 763-8293
Attorney for Petitioners
CERTIFICATE OF SERVICE
AND NOW, the 30th day of June, 2014, the undersigned hereby certifies that a true and
correct copy of the foregoing Motion to Make Order to Show Cause Absolute was served upon
the opposing parties by way of United States first class mail, postage prepaid, addressed as
follows:
Murrell R. Walters, III, Esquire
54 East Main Street
Mechanicsburg, PA 17055
Attorney for Fred H. Junkins
Wayne F. Shade, Esquire
53 W. Pomfret Street
Carlisle, PA 17013
Co-counsel for Fred K Junkins
James D. Cameron, Esquire
1325 North Front Street
Harrisburg, PA 17102
Attorney for John W. Maxwell
David A. Fitzsimmons, Esquire
Martson Law Office
10 East High Street
Carlisle, PA 17013
Co-counsel for John W. Maxwell
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Debra A. Fike, Legal Secretary