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Home My WebLink About08-08-14 Stephen D.Tiley,Esquire Attorney for St.John's Episcopal Church 5 South Hanover Street Tel: 717-243-5838 Carlisle Penns lvania 17013 Fax: 717-243-6441 IN RE: : IN THE COURT OF COMMON : PLEAS OF CUMBERLAND COUNTY, SARAH McCREA CHAPMAN JONES, : PENNSYLVANIA TRUST UNDER WILL f/b/o : ORPHAN'S COURT DIVISION .... -.-. CHAPMAN LODGE : NO. 21-09-0329 �C' =� ' '`',� � �t � -�-: ��"' y r - , ;-', -� .. � � _- �f•, ,' � �E�;_ .�.y C)!' ;- .�: -�- O` � - -E.; �,.,a s._ ,;^ MOTION TO CONTINUE ORAL ARGUMENT � ^J' ,� �''n c�� AND NOW comes St. John's Episcopal Church, Carlisle, Pennsylvania, residuary beneficiary of the trust created pursuant to paragraph 19 of the Last Will and Testament of Sarah McCrea Chapman Jones, and files this request for the rescheduling of the oral argument concerning the objections filed by Henry L. Chapman, guardian of Alfred McCrea Chapman. 1. On or about May 16, 2014 M&T Bank as Co-Trustee of the Trust under Will of Sarah McCrea Chapman Jones for Chapman Lodge (Paragraph 19) filed a "Supplement to the Third and Final Account." 2. In June of 2014 Henry L. Chapman, guardian of Alfred McCrea Chapman, filed Objections to the Supplement to the Third and Final Account. 3. By Order of Court dated June 17, 2014 the Court set a briefing schedule, and scheduled oral argument for Friday, August 15, 2014, at 1:30 p.m. Motion to Continue Oral Argument Page 1 4. On July 21, 2014 the undersigned counsel entered his appearance on behalf of the trust's residuary (and only present) beneficiary, St. John's Episcopal Church of Carlisle, Pennsylvania. (hereinafter the "Church") 5. Contemporaneous with the filing of this Motion the undersigned counsel filed a Reply Brief on behalf of the Church. 6. The undersigned counsel is scheduled to be away on vacation on Friday, August 15, 2014, returning to the office on Monday, August 18, 2014. 7. The undersigned counsel desires that oral argument be rescheduled. 8. The undersigned counsel has contacted Objector's counsel, Rosemary R. Ferrino, Esquire, and she has no objection to this Motion. 9. The undersigned counsel has contacted Ivo V. Otto, Esquire and Seth T. Mosebey, Esquire, counsel for the co-trustee, and they have no objection to this Motion. 10. The undersigned counsel has contacted Mark A. Pacella, Esquire, on behalf of himself and Michael T. Forester, Esquire, both of the Pennsylvania Office of Attorney General, and they have no objection to this Motion. 11. The undersigned counsel has contacted interested party John McCrea, III and he has no objection to this Motion. 12. The undersigned counsel respectfully represents that he has scheduling information for some of the attorneys involved in this matter and requests that the Court contact him in the event the Court decides to reschedule oral argument. Motion to Continue Oral Argument Page 2 WHEREFORE, St. John's Episcopal Church of Carlisle, Pennsylvania, prays Your Honorable Court for an Order rescheduling oral argument for a date on or after August 18, 2014. Respectfully submitted, , August 8, 2014 � ' �� Step en . Tiley, Esquire Attorney for St. John's Episcopal Church FREY AND TILEY 5 South Hanover Street Carlisle, PA 17013 Tel. No. (717) 243-5838 Sup. Ct. ID 32318 Motion to Continue Oral Argument Page 3 � Stephen D.Tiley,Esquire Supreme Court I.D.No.32318 Attorney for St.John's Episcopal Church 5 South Hanover Street Tel: 717-243-5838 Carlisle Penns lvania 17013 Fax: 717-243-6441 IN RE: : IN THE COURT OF COMMON PLEAS : OF CUMBERLAND COUNTY, SARAH McCREA CHAPMAN JONES, : PENNSYLVANIA TRUST UNDER WILL f/b/o : ORPHAN'S COURT DIVISION CHAPMAN LODGE : NO.21-09-0329 CERTIFICATE OF SERVICE I hereby certify that I served a true and correct copy of: (a) the Reply Brief of St.John's Episcopal Church,Carlisle,Pennsylvania,in opposition to the Objections of Henry L. Chapman, Guardian of Alfred McCrea Chapman,to the Supplement to the Third and Final Account filed by Co-Trustee M&T Bank concerning the Trust under Will of Sarah McCrea Chapman Jones for Chapman Lodge (Paragraph 19); and (b) The Motion to Continue Oral Argument filed by St. John's Episcopal Church,Carlisle,Pennsylvania; On August 8,2014,by placing a true and correct copy of the same in the United States mail,postage pre-paid,addressed: Ivo V.Otto,III,Esquire Rosemary R.Ferrino,Esquire 10 East High Street 1501 Lower State Rd., Suite 205 Carlisle,PA 17013 North Wales,PA 19454 Katherine C.Michalka Karen E. Chapman 250 Loche Lloyd Parkway 1858 San Lorenzo Avenue Belton,MO 64042 Berkley,CA 94707 John McCrea,III Michael T.Forester,Esquire 221 Doubling Gap Road Office of The Attorney General Newville,PA 17241 14th Floor- Strawberry Square Harrisburg,PA 17120 Respectfully ubmitted, Date: �r�rJ �' o�� " v Stephen D.Tiley,Esquire Attorney for St.John's Episcopal Church FREY AND TILEY 5 South Hanover Street Carlisle,PA 17013 Tel.No. (717) 243-5838 Sup. Ct. ID 32318