HomeMy WebLinkAbout01-31-08r
iN THE COURT OF COMMON PLEAS
OF CUMBERLAND COUNTY, PENNSYLVANIA
IN RE: ESTATE OF ORPHAN'S COURT DIVISION
ROBERT M. MUMMA,
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Deceased
NO. 21-86-398 ~ ~~ ~.
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SUPPLEMENTAL OBJECTIONS 1
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Pursuant to the Order of October 3, 2007 issued by the Orphan's Court per the Honorable
J. Wesley Oler, Jr., the undersigned Objector hereby files the following supplemental objections
pro se and avers as follows:
1. Any and all prior objections to any account or accountings previously filed in the above-
captioned matter are hereby incorporated in their entirety as if fully set forth herein. With
respect to said prior filings in this matter, the instant incorporation by reference includes
all passages (including all introductory provisions, `wherefore' clauses, and text) as well
as any exhibits, documents, records, schedules, returns, or attachments referenced or
otherwise set forth therein.
2. Barbara McK. Mumma and Lisa M. Morgan, in their capacities as executrices and
trustees (hereinafter "the Executrices"), have grossly undervalued the assets of the estate.
3. The Executrices have disproportionately allocated the assets of the estate into the Marital
Trust.
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4. By virtue of withdrawals from the Marital Trust, the interests of the beneficiaries
have been substantially diminished while the interests of the Executrices have been
greatly enhanced.
5. The Executrices undertook unilateral and unauthorized actions on behalf of corporations
and corporate enterprises and otherwise failed to comply with applicable state law and
regulations.
6. The Executrices have not recognized or have concealed shareholder agreements that
govern the ownership of corporate stock.
7. The Executrices' actions and omissions with respect to shareholder agreements would
have precluded the estate from acquiring stock in multiple corporations, including, but
not limited to, Pennsylvania Supply Company, Pennsy Supply Inc., Bobali Corp.,
Lebanon Rock, Inc., High-Spec., Inc., Nine-Ninety-Nine, Inc., and/or 999, Inc.
8. The Executrices have engaged in corporate transactions which conveyed assets out of
Pennsylvania Supply Company, Kim Company, Pennsy Supply Inc., Bobali Corp.,
Middle Park, Inc., Nine-Ninety-Nine, Inc., and/or 999, Inc., and other unknown
transactions.
9. The Executrices fraudulently terminated the corporate existence of Middle Park, Inc. via
merger with another corporate entity.
10. The Executrices knowingly concealed corporate records that were known to be altered in
their effort to conceal the identity of true stock ownership.
11. The Executrices concealed their knowledge of the Decedent's activities prior to April 12,
1986 which became known to them and their accountants, and which they further
concealed via the Stradley Ronin law firm, without any explanation of same or without
otherwise disclosing same to the shareholders.
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12. The Executrices fraudulently misappropriated life insurance proceeds rightfully owned
by Pennsylvania Supply Company and Pennsy Supply Inc.
13. The Executrices individually assumed corporate designations which were not set forth in
any corporate by-laws; they likewise assumed corporate positions to which they were not
elected and which were not otherwise authorized.
14. The Executrices have awazded themselves salaries and health insurance benefits that
were never authorized.
15. The Executrices have continued to engage in a systematic pattern of self-dealing and
personal enhancement.
16. The Executrices have engaged in and continue to perpetuate a scheme of fraudulent
conveyances of estate assets.
17. The Executrices have refused to account for these questioned transactions.
18.Objector reserves the right to raise any additional issues or pursue any additional
evidence that may be discovered subsequent to the filing of the instant supplemental
objections, as additional facts, documentation or other evidence warrants or becomes
available.
Respectfully submitted,
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Robert M. Mumma, II -pro se
P. O. Box 58
Bowmansdale, PA 17008
(717) 612-9720
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IN THE COURT OF COMMON PLEAS
OF CUMBERLAND COUNTY, PENNSYLVANIA
1N RE: ESTATE OF ORPHAN'S COURT DIVISION
ROBERT M. MUMMA,
Deceased N0.21-86-398
CERTIFICATE OF SERVICE
On this 31st day of January 2008, I, Daryl E. Hewitt, Assistant to Robert M. Mumma, II,
hereby certify that I served the foregoing supplemental objections via U.S. Mail, first class,
postage prepaid, addressed to:
Ralph Jacobs, Esquire
215 South Broad Street
Philadelphia, PA 19107
George B. Faller, Jr., Esquire
No V. Otto, III, Esquire
10 East High Street
Carlisle, PA 17013
Brady Green, Esquire
1701 Market Street
Philadelphia, PA 19103-2921
Taylor Andrews, Esquire
Court-Appointed Auditor
78 West Pomfret Street
Carlisle, PA 17013-3216
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Daryl E. Hewi
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