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HomeMy WebLinkAbout03-29-06 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