HomeMy WebLinkAbout11-20-14 IN RE: IN THE COURT OF COMMON 4EAS
CUMBERLAND COUNTY, PET*ScYLVANFA 7
ESTATE OF r n � n
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JOHN E. BAKER, ORPHANS' COURT DIVISIONS-' ? r-a p
Late of Mechanicsburg Borough ' '" :7) `
Deceased 6/8/2008 No. 21-08-0760 f-.> `-) [ :13 W
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MOTION FOR LEAVE TO WITHDRAW AS COUNSEL OF RECORIV1 71
AND NOW, this a-U-�h day of November, 2014, comes Sean M. Shultz, Esquire,
attorney for the estate of John E. Baker, and presents this Motion for Leave to Withdraw
as Counsel of Record, representing as follows:
1. Movant is Sean M. Shultz,Esquire,attorney for the Estate of John E. Baker,
with offices at Saidis, Sullivan & Rogers, 26 West High Street, Carlisle, Cumberland
County, Pennsylvania 17013.
2. John E. Baker departed this life on June 8, 2008.
3. On July 18, 2008, his daughter-in-law, Deborah Jo Baker was appointed as
Executrix of his estate.
4. Deborah Jo Baker is an adult individual residing at 101 Walnut Street,
Mechanicsburg, Pennsylvania 17055.
5. On June 6, 2014, Movant filed a Petition to Withdraw as Counsel of Record
in the above-captioned matter.
6. On June 13,2014,a Citation was issued directing Deborah Jo Baker to show
cause why the relief requested should not be granted within twenty (20) days of the date of
service of the Citation.
7. The Citation was served on Deborah Jo Baker on August 8, 2014, as
V
evidenced by an Acceptance of Service filed to the above-captioned matter on August 11,
2014.
8. Twenty days have expired and Deborah Jo Baker has not responded to the
Citation.
9. Judge Thomas A. Placey has been assigned to this matter.
WHEREFORE, Movant requests your Honorable Court to grant him leave to
withdraw as counsel of record for the Estate of John E. Baker.
Respectfully submitted,
S IS, SULLIVAN & ROGERS
can M. Shultz, Esquire
Attorney ID No. 90946
26 W. High Street
Carlisle, Pennsylvania 17013
(717) 243-6222
Movant
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IN RE: IN THE COURT OF COMMON PLEAS
CUMBERLAND COUNTY, PENNSYLVANIA
ESTATE OF
JOHN E. BAKER, ORPHANS' COURT DIVISION
Late of Mechanicsburg Borough
Deceased 6/8/2008 No. 21-08-0760
VERIFICATION
The foregoing Motion is true and correct to the best of my knowledge, information
and belief. I understand that false statements made herein are subject to the penalties of 18
Pa. C.S.A. Section 4094, relating to unsworn falsification to authorities.
Date: November ' 2014
Sean M. Shultz, Esq i e
Movant
IN RE: IN THE COURT OF COMMON PLEAS
CUMBERLAND COUNTY, PENNSYLVANIA
ESTATE OF
JOHN E. BAKER, ORPHANS' COURT DIVISION
Late of Mechanicsburg Borough
Deceased 6/8/2008 No. 21-08-0760
CERTIFICATE OF SERVICE
AND NOW, this ��day of November, 2014, I, Dolly M. Hockenberry, hereby
certify that I have this day served the following person with a copy of the foregoing Motion
for Leave to Withdraw as Counsel of Record by first class, United States Certified Mail,
Return Receipt Requested, postage pre-paid, addressed as follows:
Deborah Jo Baker
101 S. Walnut Street
Mechanicsburg, Pennsylvania 17055
Executrix of the Estate of John E. Baker
SAIDIS, SULLIVAN & ROGERS
A /'
Dolly M. ck 6 be y, aralegal
26 W. High Street
Carlisle, Pennsylvania 17013
(717) 243-6222