HomeMy WebLinkAbout05-28-04
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IN THE COURT OF COMMON PLEAS OF THE 9th JUDICIAL DISTRICT
OF PENNSYLVANIA
Cumberland County
IN RE: Estate of Loy T. Hempt
Orphan's Court Division
No. 21-77-231
VERIFIED STATEMENT OF JOEL R. ZtJLLIHGBR, ESQUIRE
IN SUPPORT OF REQUEST FOR ATTORNEYS' FEES AND EXPENSES
I, Joel R. Zullinger, hereby verify and state as follows:
1.
Iam a graduate of Dickinson School of Law in 1973. I' was
admitted to the Bar of the Supreme Court in 1973 and since that
time have been engaged in the private practice of law in
Chambersburg, Franklin.. County, pennsyl vania,. and Shippensburg,
Cumberland County, Pennsylvania. From 1.973 through 1976 I.was an
associate in the law office of Mower and Davis', Chambersburg,
Pennsylvania. From 1976 to 1981, I was in partnership with William
R. Davis, Jr., in Chambersburg and Shippensburg , Pennsylvania.
From 1981 to 1986 I was a sole practitioner in Shippensburg,
Pennsylvania. From 1986 to the present I have been a shareholder
in the firm of Zullinger - Davis, PC, the other shareholder in the
firm being Hamilton C. Davis, with practice in Chambersburg and
Shippensburg, Pennsylvania.
2.
The practice centers largely on the areas of estate planning
and estate administration.
3.
I have represented. Robert Mark, Steven E. Mark and Forrest H.
Mark in objecting to the first and final account for ~he Estate of
LOY,T. Hem~tFa.~ciresid~ary trust _un~e_r~i~l !ofL9X,"t. Hemptf,?,rJ=~e,
per~Od:~b~gln~lng;~~~(!h~"1.9r~()J197?, an~ ;,~8.~~~~_:~Y-}~,': ~R?2',j~':f.~::';LJ
, .'" -., ," . ~~.. - - . -- -. -'-." - "
4.
-, ~;- ,.:"'_8' c: (:
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The fee 'incurred on behalf of the Mark Brothe'rs ob] ecticlIls"
through May 28, 2004, is $12,000.00. Total out-of-pocket expenses
,
,
incurred during that time is $803.15. My fees and costs will
continue to accrue in the future since the litigation is ongoing.
5.
I have worked 80 hours on this matter and my billing rate is
$150.00 per hour, which is customary in the Chambersburg and
Shippensburg legal community for an individual with my number of
years in the practice of law.
6.
The work that I have performed, and the expenses that have
been incurred on behalf of the Mark Brothers obj ections are
reasonable and necessary.
I verify that the facts set forth above are true and correct
to the best of my knowledge, information and belief, and are
subject to the penalties of 18 Pa. C.S. Section 4904 relating to
unsworn falsification to authorities.
Dated:
S/2rj~r
ull'
Supreme Cour
14 North Main
Suite 200
Chambersburg, PA 17201
..
.
CERTIFICATE OF SERVICE
I certify that I am this day serving a copy of the foregoing
document upon the persons and in the manner indicated below, which
service satisfied the requirements of the Pennsylvania Rules of
Civil Procedure, by facsimile and by depositing a copy of the same
in the United States Mail at Chambersburg, Pennsylvania, with
first-class postage, prepaid, as follows:
Ivo V. Otto, III, Esq.
MARTSON, DEARDORF, WILLIAMS & OTTO
10 East High Street
Carlisle, PA 17013
Donald Kaufman, Esq.
McNEES, WALLACE & NURICK
100 Pine Street
P. O. Box 1166
Harrisburg, PA 17108-1166
Howell C. Mette, Esq.
METTE, EVANS & WOODSIDE
3401 North Front Street
P. O. Box 5950
Harrisburg, PA 17110-0950
William A. Duncan, Esq. ~
DUNCAN, HARTMAN & DOUGLAS, PC
One Irvine Row
Carlisle, PA 17013
Respectfully submitted,
Zullin
Su reme Court
14 North Main
Suite 200
Chambersburg, PA 17201
Dated: May 28, 2004