HomeMy WebLinkAbout06-09-04
IN THE COURT OF COMMON PLEAS
CUMBERLAND COUNTY, PENNSYL VANIA
IN RE: ESTATE OF
ROBERT M. MUMMA,
Deceased
ORPHANS' COURT DIVISION
NO. 21-86-398
PETITION TO WITHDRAW AS COUNSEL FOR PLAINTIFF
AND NOW, comes MILLER LIPSITT LLC, and hereby files this Petition to Withdraw
as Counsel for Plaintiff, and, in support thereof, states:
I. Petitioner has been representing Plaintiff in numerous actions, including the
instant, since March of2003.
2. For the most part, the first year of Petitioner' s relationship with Plaintiff was
positive with litigation proceeding in a professional manner.
3. However, more recently disputes have arisen over strategies and the
reasonableness of Plaintiff's expectations.
4. These disputes have caused the attorney-client relationship to become estranged
as a result of the foregoing to the extent that Plaintiff no longer believes that Miller Lipsitt LLC
is adequately representing him.
5. Currently, Plaintiff is indebted to Miller Lipsitt LLC in an amount in excess of
$42,000.00 and has failed to pay this debt despite Plaintiff's repeated promises to make payment.
6. Based on the foregoing, it is clear that the relationship between Plaintiff and
Petitioner is beyond repair.
7. Plaintiff will not be prejudiced by Petitioner's withdrawal.
WHEREFORE, Petitioner, MILLER LIPSITT LLC, respectfully requests that its petition
to withdraw as counsel for Plaintiff be granted.
Respectfully Submitted,
MILLER LIPSITT LLC
Date: 6(' 10'1
By c~\o~ . \SZjr
Attorney J.D. No.: 83755
P.O. Box 959
Camp Hill, P A 1700 I -0959
(717) 909-5920
2
, .
CERTIFICATE OF SERVICE
The undersigned hereby certifies that on this date a true and correct copy of the foregoing
Petition to Withdraw as Counsel for Plaintiff was served via first-class, United States mail,
postage pre-paid, upon the following:
Ivo V. Otto, III, Esquire
Martson DeardorffWiIIiams & Otto
Ten East High Street
Carlisle, P A 17013
Joseph A. O'Connor, Jr., Esquire
Brady L. Green, Esquire
Morgan, Lewis & Bockius, LLP
1701 Market Street
Philadelphia, PA 19103-2921
Robert M. Mumma, II
6880 SE Harbor Circle
Stuart, FL 34996-1968
(Plainti ff)
Dated: () 1010'6 }{)'-I
I I