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Shaun E.O'Toole
LD.No.44797
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220 Pine Street
Harrisburg,Pennsylvania 17101
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IN THE COURT OF COMMON PLEAS cy')
OF CUMBERLAND COUNTY,PENNSYLVANIA
IN RE: ESTATE OF ORPHANS' COURT DIVISION
ROBERT M.MUMMA,
Deceased No. 21-86-398
Petition for Leave to Withdraw as Legal Counsel
Shaun E. O'Toole,Esquire of the Law Office of Shaun E. O'Toole ("Petitioner"), files
this Petition to Withdraw and in support thereof states as follows:
1. Petitioner entered has previously entered his appearance in the above-captioned
matter on behalf of Robert M. Mumma, 11 ("Mumma").
2. The attorney-client relationship between Petitioner and Mumma has deteriorated
to the point that Petitioner can no longer provide Mumma with adequate legal representation.
3. By e-mail dated October 27,2014,Petitioner informed counsel for the opposing
party and counsel for other parties in this matter of his intention to withdraw as counsel for
Mumma in this and other matters and requesting that such parties inform Petitioner whether they
object to his withdrawal as counsel to Mumma and their responses are as follows:
(a) George B. Faller of the Martoff Law Offices, legal counsel to Lisa M.
Mumma, co-executrix of the Estate of Robert M. Mumma and trustee of the two
testamentary trusts set forth in Decedent's Will, e-mailed Petitioner and indicated that he
did not object to Petitioner's withdrawal,"but would object to any request to use the
withdrawal as a basis for any extension of any deadlines in trial or appellate courts."
(b) Brady L. Green of Wilbraham, Lawler&Buba,also legal counsel to Lisa
M. Mumma, co-executrix of the Estate of Robert M. Mumma and trustee of the two
testamentary trusts set forth in Decedent's Will, did not respond.
(c) Richard F. Rinaldo, of Williams Couslon,legal counsel to Barbara M.
Mumma, a co-administrator of the Estate of Robert M. Mumma and a beneficiary of the
Estate of Robert M. Mumma did not respond.
4. Mumma has since terminated Petitioner as his legal counsel in this matter.
5. Mumma has represented himself on many occasions before this Court, and
therefore his interests will not be adversely affected should he proceed pro se as a result of
Petitioner's withdrawal.
WHEREFORE,Petitioner requests this Court award a Citation directed to the legal
counsel of each party in this matter and to each party not represented by legal counsel to show
cause, if any there be, why this Petition should not be granted and Petitioner be permitted to
withdraw as legal counsel for Robert M. Mumma,II in the above-captioned matter.
Date: 1% /14
Shaun E. O'Toole
Attorney Registration No. 44797
220 Pine Street
Harrisburg, Pennsylvania 17101
(717) 695-0389
2
CERTIFICATE OF SERVICE
The undersigned hereby certifies that on this date a true and correct copy of the foregoing
Petition was served by first class United States mail, postage prepaid, upon the following:
Ivo V. Otto, 111, Esquire
George B. Faller, Jr., Esquire
Martson Law Offices
10 East High Street
Carlisle;Pennsylvania 17013
(717) 243-3341;
Brady L. Green, Esquire
Wilbraham, Lawler&Buba
1818 Market Street, 31 St Floor
Philadelphia, Pennsylvania 19103;
Richard F: Rinaldo, Esquire
Williams Coulson LLC
One Gateway Center, 161h Floor
Pittsburgh, Pennsylvania 15222;
Linda M. Mumma
P.O. Box 70
Mechanicsburg, Pennsylvania 17101;
Anthony L. DeLuca, Esquire
113 Front Street
Boiling Springs, Pennsylvania 17007
(717) 258-6844; and
Mr. Robert M. Mumma II
P.O. Box F
Granthem, Pennsylvania 17027.
aun E. O'Toole
Attorney Registration No. 44797
220 Pine Street
Harrisburg, Pennsylvania 17101
(717) 695-0389
VERIFICATION
The undersigned hereby verifies that the statements of fact in the foregoing
document are true and correct to the best of my knowledge, information and belief.
I understand that any false statements therein are subject to the penalties contained
in 18 Pa.C.S.A. §4904, relating to unsworn falsification to authorities.
Date:
haun E. O'Toole
Attorney ID 44797
220 Pine Street
Harrisburg, Pennsylvania 17101
717.695.0389