HomeMy WebLinkAbout09-23-15 ABOM cS2'
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IN THE ESTATE OF . IN THE COURT OF COMMON PLEAS Q�
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. COMBERLAND COUNTY, PENNSYLV�IA�; .�
KELLY ANN CHEESEMAN . `" -"
. ESTATE NO.: 2L14-00350
MOTION TO WITHDRaW AC COUNSEL
AND NOW, this 23`d day of September, 2015, comes undersigned counsel, ABOM &
KUTULAKIS, L.L.P., by Brandon S. O'Donnell, Esquire, who respectfully requests this
Honorable Court grant this Motion to Withdraw as Counsel for the above-namcd Estate and, in
support diercof, respectfully avers the following:
1. Kelly Ann Cheeseman, Iate of Hampden Township, Cumberla�d County, Pcnnsyh�ania,
dicd on December 9, 2013.
2. Brandon 5. O'DonnelL Esquire of Abom & Kut�lakis, L.L.P., was retained to represent
the Estalc of Kelly Ann Cheeseman on or about March 4, 2014.
3. A CertiGcate of Grant of Letters of Adminis[ration was issued by Lisa M. Graysoo,
Esyuirc, Regis[er of Wills for Cumbedand County, Pennsylvania on April 14, 2014 [o
Amy Powers, as Administrator of the Estate of Kelly Ann Cheeseman.
4. The Administrator hns indicated to the Unders-igoed that shc will be paying all debts and
filing the Inheritance Tax Rctum and the 2013 income tax remm for the DecedenPs Estate
and no bnger�eeded the services of the undersigned.
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5. Despitc rcpcated attempts to correspond with thc Administrator to coufi�m that the debts
werc paid xnd [he Inheritance Tax Retum was tiled [imcly, no response has been
forthcoming.
6. On September 22, 2015, Undersigned Couosel contacted the Office of the Register of
Wills of Cumberland County, Pennsylvania aud confirmed that as of that date thc
Inheritance Tax Return has not been filed.
WHERERFORP, Undcrsigned Counsel respectfulty requests Hiis Honorablc Court grant
his requcst to withdraw as counsel for the Estate of Kelly Ann Cheeseman.
Respectfully submitted,
ABOM & KUTULAKIS, L.L.P.
Date � ?3 2d �/+ 'V � �Z"' �/
Brandon S. O'Donoell, Esquire
2 West High Street
Carlisle, PA 17013
(717) 249-0900
At[omey ID No. 316575
CFRTIFI AT OFSERVI
AND NOW, this 23`a day of Septcmber, 2015, I, Brandon S. O'Donnell, Esquire of
ABOM & KUTULAKIS, L.L.P., hereby certify that I did serve or cause to be served a true and
correct copy of ihe foregoing Motion to Withdraw as Counscl by First Class U.S. Mail addressed
to [he following:
Amy Powers
737 PrattRoad
New Milford, PA 18834
Administratar of lhe Estate q(
Ke71y Ann Cheeseman
Br do S. O'Donnell, Es9 ire