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Home My WebLink About07-16-96 Jut 1 I 1996 IN RE: ESTATE OF ROBERT M MUMMA, DECEASED ORPHAN'S COURT DMSION IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA DOCKET NO.: 21-86-398 ORDER AND NOW, this _ day of , 1996, upon consideration of the Motion to withdraw as Counsel presented by Charles E. Shields III, and for good cause shown, said motion is hereby granted. BY THE COURT: J. '0 ~. CL '0 -' ~ ;:'J ~ run: 1.-0 0:: P'..2 5 00 Jut 1 , 1996 if INRE: ESTATEOF ROBERTM MUMMA, DECEASED ORPHAN'S COURT DIVISION IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA DOCKET NO.: 21-86-398 MOTION TO WITHDRAW AS COUNSEL AND NOW, Charles E. Shields, III (Shields), a member of the Cumberland County Bar, hereby moves this court for leave to withdraw as counsel for Robert M. Mumma, II, in the above- captioned action, and in support thereof avers as follows: 1. In or about 1990, Robert M. Mumma, II (Mumma) hired Shields as legal counsel. Shields subsequently entered an appearance in this action. 2. Shields agreed to serve as legal counsel on condition that Mumma pay specified agreed-upon hourly rates for all services rendered and to reimburse Shields for costs advanced and certain expenses incurred in connection with the legal services rendered 3. Shields has provided Mumma with competent and appropriate legal advice and other services in this matter. 4. Mumma has failed to fulfill his obligation to Shields in that he has failed and refuses to pay Shields in full and to reimburse him for all costs advanced. 5. In addition to his failure to make payment, Mumma has repeatedly failed and or refused to respond to letters and phone calls both from Shields and from his counsel William P. Douglas. 6. It is Shields's belief that this action has been essentially defunct for quite some time. However, Shields has recently received notice from Buchanan Ingersoll that it is also having trouble dealing with Mumma and that it has formally withdrawn from representation of this case. 7. Shields believes and avers that this action is no longer in need of legal counsel. However, in the event that it is, he believes that he is incapable of providing any further representation and further believes that Mumma is more than adequately represented by his other counsel in the matter. 8. Shields believes and avers that he has done everything he can under the circumstances for Mumma and that his withdrawal will have no material adverse effect upon Mumma's interest. WHEREFORE Shields respectfully requests that this court grant him leave to withdraw from the representation of Mumma in this matter. Respectfully Submitted, CJwJw I',,4.UcW -:Dr Charles E. Shields, III 2 West Main Street Mechanicsburg, PA 17055 Attorney 1.0. No. 38513 Phone: 717-766-0209 Date: July 10, 1996 VERIFICATION I verify that the statements made in the foregoing document are true and correct to the best of my knowledge or infonnation and belief. I understand that false statements herein are made subject to the penalties of 18 Pa.C.S. 4904, relating to unsworn falsification to authorities. CJlPJw !:.'.~ :ur CHARLES E. SHIELDS, III Date: July 10, 1996 -.. .-----,;-- .----.. CERTIFICATE OF SERVICE AND NOW, this lOth day of July, 1996, I, Charles E. Shields, III, hereby certify that I this date served the within Motion as counsel by depositing a copy of same in the U.S. Mail, first class, postage pre-paid, at Mechanicsburg, PA addressed to the Attorney or party of record as follows: Robert M. Mumma, II 614 North Front Street Harrisburg, PA 17101 Ivo V. Otto, III, Esquire Martson, Deardorff, Williams & Otto Ten East High Street Carlisle, PA 17013 Marc J. Sonnenfeld, Esquire Morgan, Lewis & Bockius Suite 2000 One Logan Square Philadelphia, PA 19103-6993 H. Robert Fiebach, Esquire Wolf, Block, Schorr and Solis-Cohen 12th Floor, Packard Building 15th and Chestnut Streets Philadelphia, PA 19102-2678 William C. Costopoulos, Esquire Costopoulos, Foster & Fields 831 Market Street P. O. Box 222 Lernoyne, PA 17043 John H. Young, Esquire Poner, Wright, Morris & Arthur 1233 20th Street, N.W. Washington, D.C. 20036-2395 Robert G. Frey, Esquire Frey & Tiley 5 South Hanover Street Carlisle, PA 17013 Richard W. Stevenson, Esquire McNees, Wallace & Nurick 100 Pine Street P. O. Box 1166 Harrisburg,PA 17108-1166 CJwJw t...xIUd-.J -:m:- Charles E. Shields, III GEORGE M. HOUCK (1912-1991) CHARLES E. SHIELDS III ATTORNEY-AT-LAW MELLON BANK BUILDING 2 WEST MAIN STREET MECHANIGSBURG. PA 17055 JUL 1 1 199df TELEPHONE (7' 7) 766-0209 July 10, 1996 Register of Wills Cumberland County Comthouse One Comthouse Square Carlisle, PA 17013-3387 Re: Estate of Robert M. Mumma Register of Wills: Enclosed herewith for filing in the above-captioned matter are my motions to withdraw as Counsel. Kindly time stamp the additional copies of the motions, and I will pick them up. I have also provided additional copies of the Orders, together with addressed envelopes, for service upon each of the Defendants once they have been signed by the Court. Thank you for your kind assistance in this matter. Very truly yours, ~ g.~-:Dr Charles E. Shields ill cc: Robt. M. Mumma II (all w. enc.) IvoV.Ottoill Marc 1. Sonnenfeld H. Robt. Fiebach Wm. C. Costopoulos John H. Young Robt. (l.'~y Rich. W;IStevenson