HomeMy WebLinkAbout07-09-15 Johnson, Duffie, Stewart &Weidner
By: Mark C. Duffie, Esquire
I.D. No. 75906 Attorneys for Petitioner
301 Market Street
P. O. Box 109
Lemoyne, Pennsylvania 17043-0109
(717) 761-4540
mcd@jdsw.com
IN RE: MADISON RAE GOULD . IN THE COURT OF COMMON PLEAS OF
. CUMBERLAND COUNTY, PENNSYLVANIA
: ORPHANS' COURT DIVISION
. DOCKET NO. 21-15-562
MOTION TO CONTINUE
AND NOW, comes the Petitioners, Adrianna R. Brumbaugh, Madison Rae Gould, a minor,
and Adrian R. Frodge by and through their a@orneys, Johnson, Duffie, Stewart 8 Weidner, and file
this Motion for a general continuance, and in support of their said Motion, aver as follows:
1. The Petitioners, by and through the undersigned counsel, filed a Petition for the
Appointment of Guardian for the Estate of a Minor pursuant to Pennsylvania Orphans' Court Rule
12.5, on May 20, 2015.
2. This Honorable Court, on May 28, 2015, entered an Order of Court appointing Robert
P. Kline, Esquire as Guardian ad litem for the minor child, Madison Rae Gould.
3. By that same Order of Court, a hearing was scheduled for July 9, 2015 at 930 a.m. in
Courtroom No. 6 in the Cumberland County Courthouse.
c� � a
a
; o ` m �
m � c � o
mzc� � cn �
� � � � o
r � m � m m
;_ N -, x o
_ ' _ o 0
= np � 'n �t
c� o -� 3 � -n
� � _ �
�i � � m
_� -� r
s � o
� y T
�
4. Robert R Kline, Esquire, the Guardian ad litem for Madison Rae Gould, a minor, and
the undersigned counsel for the Petitioners have drafted a Proposed Decree for review and approval
by the Court and, as a result, a hearing should not be necessary in this matter.
5. Robert P. Kline, Esquire, the Guardian ad litem for the minor child, Madison Rae
Gould supports this request for a general continuance.
WHEREFORE, the undersigned respectfully requests this Honorable Court to continue
generally the hearing scheduled for July 9, 2015 at 9:30 a.m. in Courtroom No. 6 of the Cumberland
County Courthouse.
Respecttulty submitted,
JOHNSON, DUFFIE, STEWART& WEIDNER
Date: 7 $ �:; gY: _ �
Mark -. Duffie, �
Attomey I.D. No. 75906
301 Market Street
P.O. Box 109
Lemoyne, PA 17043-0�09
Telephone (717) 767-4540
i
CERTIFICATE OF SERVICE
I HEREBY CERTIFY that I served a true and correct copy of the foregoing Petition, by
depositing a copy of same in the United States Mail at Lemoyne, Pennsylvania, with first-class
postage prepaid on the ��� day of " � �,,, , 2015, addressed to the following:
Adrianna R. Brumbaugh
706 Henry Street
Mechanicsburg, PA 17055
Madison Rae Gould
706 Henry Street
Mechanicsburg, PA 17055
Adrian R. Frodge
4152 Nantucket Drive
Mechanicsburg, PA 17050
Robert P. Kline, Esquire
714 Bridge Street
P.O. Box 461
New Cumberland, PA 17070-0461
JOHNSON, DUFFIE, STEW RT& WEIDNER
By �'
Mark C. Duffie
7izsm