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IN RE: MILDRED J. GERBER
TRUST UNDER AGREEMENT,
Dated December 19, 1997
IN THE COURT OF COMMON PLEAS OF
CUMBERLAND COUNTY, PENNSYL VANIA
ORPHANS' COURT DIVISION
No. 21-2002-0540 ~
IN RE: FRED E. GERBER,
TRUST UNDER AGREEMENT,
Dated July 29, 1994
IN THE COURT OF COMMON PLEAS OF
CUMBERLAND COUNTY, PENNSYLVANIA
ORPHANS' COURT DIVISION
NO. 21-1998-0195 /
IN RE: ESTATE OF
FRED E. GERBER, SR.,
Deceased
IN THE COURT OF COMMON PLEAS OF
CUMBERLAND COUNTY, PENNSYLVANIA
ORPHANS' COURT DIVISION
NO. 21-1998-0195 ./
PETITON FOR CONTINUANCE OF HEARING
Frederick E. Gerber, II, by his attorneys, Broujos and Gilroy, P.C., sets forth the
following:
1
Pursuant to this Court's Order of January 2, 2006, a hearing is scheduled on Thursday,
April 6, 2006 at 9:30 a.m. in Court Room No. 1.
2
The hearing is scheduled on the Petition to Enforce Settlement Agreement filed by
Marilyn J. Gerber.
3
The undersigned attorney has recently entered an appearance on behalf of Frederick E.
Gerber, II, and it is requested that the April 6, 2006 hearing be postponed to a later date
to give the undersigned counsel additional time to become familiar with the case and
adequately address the issues in this case.
4
The hearing is set on a Petition filed by Marilyn J. Gerber captioned "Emergency Petition
to Enforce and Stay the Personal Property of Marilyn Gerber and the Property from the
Mildred J. Gerber Estate" .
5
Prior counsel for Frederick E. Gerber, II filed Preliminary Objections to the Petition filed
by Marilyn J. Gerber.
6
Petition of Marilyn J. Gerber and the Preliminary Objections were originally set for a hearing
on January 19, 2006, but that hearing was postponed until April 6, 2006 at the request of
Marilyn J. Gerber.
7
Since the filing of the Petition by Marilyn J. Gerber, Marilyn J. Gerber has taken possession
of the items of personal property listed in her Petition and there is no urgency to conduct a
hearing at this time.
WHERFORE, Petitioner, Frederick E. Gerber, II, requests that the April 6, 2006 hearing in
this case be postponed to a later date.
Respectfully submitted,
Date: 7-df- () ?
JOHN H. BROU]OS
HUBERT X. GILROY
BROUJOS & GILROY, P.c.
ATIORNEYS AT LAW
4 NORTH HANOVER STREET
CARLISLE, PENNSYLVANIA 17013
TELEPHONE: (717) 243-4574
FACSIMILE: (717) 243-8227
jbroujos@broujosgilroy.com
hgilroy@broujosgilroy.com
NON-ToLL FOR HARRISBURG AREA
717-766-1690
March 29, 2006
Glenda Farner Strasbaugh,
Clerk of Orphans' Court
Cumberland County Courthouse
One Courthouse Square, 151 Floor
Carlisle, PA 17013
RE: Mildred E. Gerber, Trust Under Agreement Docket No. 21-2002-0540, Fred
E. Gerber,Trust Under Agreement Docket No. 210-1998-0195 and Estate of Fred
E. Gerber Docket No. 210-1998-0195.
Dear ~ <3 (t~~ ~
Enclosed for filing is a Praecipe for my Entry of Appearance in the above three
referenced matters on behalf of Frederick E. Gerber, II.
Sincerely yours,
srb
Enclosure
cc: Marilyn J. Gerber
Richard C. Rupp, Esquire
Jane N. Heflin
Frederick E. Gerber, II