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IN THE COURT OF COMMON PLEAS
OF CUMBERLAND COUNTY, PENNSYLVANIA
Deceased.
ORPHANS' COURT DIV~BN
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IN RE ESTATE OF
ROBERT M. MUMMA,
NO. 21-86-398
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MOTION IN LIMINE OF BARBARA MCK. MUMMA ANQ\~-""
LISA M. MORGAN TO EXCLUDE ARGUMENT AND .-
EVIDENCE AS TO MATTERS PREVIOUSLY ADJUDICATED
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Barbara McK. Mumma and Lisa M. Morgan move as follows for an order in limine
excluding all evidence and argument in support of positions or arguments contrary to matters
previously adjudicated in the Mumma family litigation:
1. Mrs. Mumma and Mrs. Morgan believe, based upon statements made by Mr. Mumma,
II in various contexts, that Mr. Mumma, II intends, in these proceedings, to attempt to relitigate
matters previously decided by the Courts.
2. Mrs. Mumma and Mrs. Morgan believe that Mr. Mumma, II may seek to revisit
factual findings and legal conclusions in some or all of the following decisions, and perhaps
others:
Barbara McK. Mumma, et at. v. Robert M Mumma, II, et al., No. 66 Equity 1988,
Opinion and Order [In re Robert M. Mumma, II's Motions to Disqualify Morgan, Lewis
& Bockius from Legal Representation ofthe Estate of Robert M. Mumma, Deceased]
(C.P. Cumberland Feb. 13, 1989) (also captioned in In re Estate of Robert M Mumma,
Deceased, No. 21-86-398 (O.c. Cumberland), post-trial motion denied andfinal decree
entered, Opinion and Order (C.P. Cumberland Nov. 5, 1992), aff'd, 433 Pa. Super. 660,
639 A.2d 846 (1993), allocatur denied, 539 Pa. 679, 652 A.2d 1324 (1994).;
In re Estate of Robert M Mumma, Deceased, No. 21-86-398, Opinion and Order [In re
Robert M. Mumma, II's Preliminary Objections to Petition for Declaratory Judgment]
(O.C. Cumberland Mar. 8, 1989) (finding provision in will that "[i]t is my desire that if
expedient and possible, the businesses which I have personally directed in my lifetime
and of which I have had an interest be continued for the benefit of and under the
management and control of my immediate family" to be precatory and nonbinding),
appeal dismissed (May 17, 1989);
Barbara McK. Mumma, et al. v. Robert M Mumma, IL et al., No. 66 Equity 1988,
Opinion and Order [In re Declaratory Judgment] (C.P. Cumberland Mar. 24, 1992),post-
trial motion denied andfinal decree entered, Opinion and Order (C.P. Cumberland Nov.
5, 1992), aff'd, 433 Pa. Super. 660, 639 A.2d 846 (1993), allocatur denied, 539 Pa. 679,
652 A.2d 1324 (1994);
In re Estate of Robert M Mumma, Deceased, No. 21-86-398, Opinion and Order of Court
[In re Request for Preliminary Injunction] (O.C. Cumberland Aug. 4, 1993), aff'd, 437
Pa. Super. 672, 649 A.2d 467 (1994); and
Robert M Mumma, II v. Pennsy Supply, Inc., No. 99-2765 Equity, Opinion and Decree
Nisi (C.P. Cumberland May 17, 2002), post-trial motions denied andfinal decree
entered, Opinion and Final Decree (July 29,2002), aff'd, 833 A.2d 1156 (Pa. Super.
2003), allocatur denied, 577 Pa. 723, 847 A.2d 1287 (2004).
3. A list of material factual matters that have been adjudicated in prior proceedings is
attached as Exhibit "A". Mrs. Mumma and Mrs. Morgan will, upon a more complete articulation
of the evidence and positions that Mr. Mumma, II intends to advance in support of his
objections, provide a statement of any additional facts and issues which have been the subject of
previous adjudications and which they request be deemed established for purposes of the instant
proceedings, and identify any additional decisions which they believe have preclusive effect.
4. Any attempt to relitigate in the instant proceedings legal or factual matters previously
decided would be foreclosed by collateral estoppel.
5. Additional factual background, argument and legal authority in support of this motion
is set forth in Mrs. Mumma and Mrs. Morgan's accompanying memorandum oflaw, which is
incorporated by reference herein.
F:\FILES\Clients\Mumma 5844.1 (estate) 8747 (Kim)\5844, I ,Mumma ~tate\5844, I ,Motion in Limine re Collateral Estoppel- May 30, 2008
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WHEREFORE, Mrs. Mumma and Mrs. Morgan request that the Court enter an order
precluding Mr. Mumma, II from advancing any argument or evidence contrary to matters
previously adjudicated by the Courts.
Res,e.ctful\lY S~Ubmitted'
~
By: \ ._..
Ivo . Otto, III
LD. No. 27763
George B. Faller, Jr.
LD. No. 49813
MARTSON DEARDORFF WILLIAMS OTTO
GILROY & FALLER
MARTSON LAW OFFICES
10 East High Street
Carlisle, P A 17013
(717) 243-3341
Joseph A. O'Connor, Jr.
Brady L. Green
MORGAN, LEWIS & BOCKIUS LLP
1701 Market Street
Philadelphia, P A 19103-2921
215-963-5212,5079
Attorneys for Barbara McK. Mumma
And Lisa M. Morgan
F:\FILES\Clients\Mumma 5844.1 (estate) 8747 (Kim)\5844.I.Mumma ~state\5844.I.Motion in Limine re Collateral Estoppel - May 30, 2008
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EXHIBIT A TO MOTION IN LIMINE TO EXCLUDE ARGUMENT
AND EVIDENCE AS TO MATTERS PREVIOUSLY ADJUDICATED
HISTORY OF PENNSY SUPPLY, INC. AND NINE NINETY-NINE, INe.
On December 29, 1961, the two shareholders ofPennsy Supply Inc., Kim Company and Jerry T.
Simpson, entered into a shareholders' agreement, which limited the ability of current
shareholders to transfer shares without first offering the shares for sale to the corporation. 1
On August 1, 1963, the two shareholders, Kim Company and Jerry T. Simpson, entered into a
termination agreement, which provided, in pertinent part: "[S]aid parties hereto agree that said
shareholder's Agreement of December 29, 1961 between Kim [Company] and [Jerry T.]
Simpson is hereby cancelled, annulled and terminated.,,2
The termination agreement further provided that "upon transfer of all of the shares of stock of
[Jerry T.] Simpson to [Robert M.] Mumma, [Plaintiffs father,] all rights, obligations and
conditions of said Agreement shall cease.3
F AMIL Y STOCK OWNERSHIP
At the time of [Robert M.] Mumma's death the following conditions existed with respect to the
family owned business, Pennsylvania Supply Co[mpany]:
a) The Estate owned approximately 98 percent ofthe stock ofPennsy[lvania] Supply
[Company].
b) Pennsy[lvania] Supply [Company] owned more than 82 percent of the outstanding
stock of Kim Company, the second tier holding company.
c) Kim Company was the largest shareholder of Nine Ninety-Nine, Inc. . . .,
d) The Estate controlled, through its majority stock holdings, both Pennsy[lvania] Supply
[Company] and Kim Company.
e) Pennsy Supply[, Inc.] was a wholly-owned subsidiary of 999.
t) The Estate, [Barbara McK.] Mumma, Lisa [M. Morgan], Linda M. [Mumma], Robert
M. Mumma II. . . and Barbara M. McClure (Barbara) were the shareholders of Kim Company.
2
Robert M Mumma, II v. Pennsy Supply, Inc., No. 99-2765 Equity, Opinion and Decree Nisi, Finding
of Fact 4 (C.P. Cumberland May 17, 2002), post-trial motions denied andfinal decree entered,
Opinion and Final Decree (July 29,2002), aff'd, 833 A.2d 1156 (Pa. Super. 2003), allocatur denied,
577 Pa. 723, 847 A.2d 1287 (2004).
Id., Finding of Fact 6.
Id., Finding of Fact 7.
g) The Estate, [Barbara McK.] Mumma, Lisa [M. Morgan], Linda [M. Mumma], [Robert
M. Mumma, II] and Barbara were also the shareholders of [Nine Ninety-Nine, Inc.].4
The shareholders of Kim Company were as follows: Pennsylvania Supply Company (7,241
shares), [Robert M.] Mumma[, II] (334 shares), Mrs. McClure (333 shares), [Linda M. Mumma]
(333 shares), [Lisa M.] Morgan (333 shares), and [Barbara McK.] Mumma (106 shares).5
The shareholders of Pennsylvania Supply Company were as follows: the decedent (700 shares),
Robert M.] Mumma[, II] (3 shares), Mrs. McClure (3 shares), [Linda M. Mumma] (3 shares),
and [Lisa M.] Morgan (3 shares).6
THE MRA AGREEMENTS
On the afternoon of December 19, 1986, a meeting was held at the offices ofPennsy Supply[,
Inc.] in Harrisburg to execute the two tenancy-in-common agreements and other documents
concerning the liquidations of Kim Company and Pennsy[lvania] Supply [Company]. Another
purpose of the meeting was to take the necessary steps to create the two new corporations,
Mumma Realty Associates, Inc. and Hummelstown Quarries, Inc.7
[Barbara McK.] Mumma and [Robert M. Mumma, II] signed the two tenancy-in-common
agreements (MRA I and MRA II) at the December 19, 1986 meeting. The signature pages were
attached to the original agreements when [Barbara McK.] Mumma and [Robert M. Mumma, II]
signed them. 8
Lisa [M. Morgan] signed the MRA agreements on the evening of December 18,1986. . . .9
Linda [M. Mumma] signed both MRA agreements around Christmas, 1986.10
4
Barbara McK. Mumma, et aI. v. Robert M. Mumma, II, et aI., No. 66 Equity 1988, Opinion and
Order, Finding of Fact 3 (C.P. Cumberland Mar. 24, 1992), post-trial motion denied andfinaI decree
entered, Opinion and Order (C.P. Cumberland Nov. 5, 1992), aff'd, 433 Pa. Super. 660, 639 A.2d
846 (1993), allocatur denied, 539 Pa. 679, 652 A.2d 1324 (1994).
Barbara McK. Mumma, et al. v. Robert M. Mumma, II, et aI., No. 66 Equity 1988, Opinion and
Order, Finding of Fact 22 (C.P. Cumberland Feb. 13, 1989), post-trial motion denied andfinaI
decree entered, Opinion and Order (C.P. Cumberland Nov. 5, 1992), aff'd, 433 Pa. Super. 660, 639
A.2d 846 (1993), allocatur denied, 539 Pa. 679, 652 A.2d 1324 (1994).
Id., Finding of Fact 23.
Barbara McK. Mumma, et aI. v. Robert M. Mumma, II, et aI., No. 66 Equity 1988, Opinion and
Order, Finding of Fact 31 (C.P. Cumberland Mar. 24, 1992), post-trial motion denied and final
decree entered, Opinion and Order (C.P. Cumberland Nov. 5, 1992), aff'd, 433 Pa. Super. 660,639
A.2d 846 (1993), allocatur denied, 539 Pa. 679, 652 A.2d 1324 (1994).
Id., Finding of Fact 37.
Id., Finding of Fact 40.
Id., Finding of Fact 44.
6
7
9
10
2
Barbara signed both MRA agreements. . . . II
The two tenancy-in-common agreements MRA I and MRA II signed by Robert M. Mumma, II
on December 19, 1986, are binding upon him and grant him no right of first refusal as to any
transfers by the executrices, Barbara McK. Mumma and Lisa M. Morgan, of the real estate held
by the MRA tenants-in-common when there is approval by a majority in interest. 12
One tenancy-in-common agreement would govern the properties formerly owned by Kim
Company (agreement commonly referred to as MRA I) and the other tenancy-in-common
agreement would control the properties formerly held by Pennsy Supply (agreement commonly
referred to as MRA II). I3
The signature pages of MRA I and MRA II agreements differed because each agreement set
forth the percentage interest of each tenant-in-common. The percentages used corresponded with
the percentage interests of the tenants-in-common as shareholders ofPennsy[lvania] Supply
[Company] and Kim Company. 14
. . . Section 4 [ofthe MRA agreements among tenants-in-common] applies when the majority in
interest of the tenants-in-common (i.e., the Estate and executrices) vote to dispose of one or more
pieces of property owned by the tenants-in-common. Under Section 4 the decision to sell is
made by majority rule. The Estate, therefore, being the largest shareholder of both
Pennsy[lvania] Supply and Kim Co., would exercise majority control over the properties because
the properties held by the tenants-in-common were to be based upon the interests of the
respective tenants in the pre-existing corporations ofPennsy[lvania] Supply and Kim
Company. 15
[Robert M. Mumma, II] hold[s] 4.24708 percent ofMRA and .47847 percent ofMRA II. By
contrast, however, [Barbara McK.] Mumma and Lisa [M. Morgan], through their individual or
representative capacities, hold 87.28 percent in MRA I and 98.56 percent in MRA ILI6
Under the majority rule of Section 4 of the MRA agreements, [Robert M. Mumma, II] therefore
has no right of first refusal with respect to any transfers ofMRA assets, and because of his
minimal holdings he also has no effective control over these assets. The intent of the MRA
agreements was to place the power and control of the MRA assets with the majority-in-interest
because this paralleled the set up in the pre-existing majority-controlled corporations of Kim
Company and Pennsy[lvania] Supply Co[mpany]. Under the MRA agreements, as with the pre-
11
12
Id., Finding of Fact 45.
Id., p. 27.
Id., Finding of Fact 16.
Id., Finding of Fact 21.
Id., pp. 22, 23.
Id., p. 23.
13
14
15
16
3
existing corporations, [Robert M. Mumma, II], therefore, has no right of first refusal or control
over the transfer of MRA assets. [Robert M. Mumma, II] is only entitled to a share of the assets
held by the MRA tenancies- in-common that are proportionate to his percentage interest. 17
OTHER MRA-RELA TED DOCUMENTS AND ACTIONS
In addition to the execution of the MRA agreements on December 19, 1986, the shareholders of
Kim Company and Pennsy[lvania] Supply, including [Robert M. Mumma, II], executed a bill of
sale transferring certain real and personal property of Kim Company and Pennsy[lvania] Supply
[Company] to themselves in proportion to their respective shareholdings in the two
. 18
corporatlons.
On December 19, 1986, [Robert M. Mumma, II] in his capacity as Vice-President of Kim
Company and Pennsy[lvania] Supply [Company], also executed a joint deed transferring all real
estate owned by Kim Company and Pennsy[lvania] Supply [Company] to their shareholders as
tenants-in-common under the MRA I and MRA II agreements.19
In addition to the master deed, [Robert M. Mumma, II], in his capacity as Vice-President of
Pennsy[lvania] Supply [Company], also executed on December 19, 1986, four deeds transferring
various rights and interests from Pennsy[lvania] Supply to Hummelstown Quarries, Inc?O
The shareholders took possession of the transferred property as tenants-in-common under the
fictitious name of Mumma Realty Associates.21
A certificate of incorporation for Hummelstown Quarries, Inc. was also filed with the Secretary
8 22
of State on December 19, 19 6.
Pursuant to Section 1 of the MRA agreement, Mumma Realty Associates, Inc. was appointed
manager of both of the properties governed by MRA I and MRA n?3
[Barbara McK.] Mumma and Lisa [M. Morgan] are the officers and directors of Mumma Realty
Associates, Inc.
17
Jd., p. 23.
Barbara McK. Mumma, et al. v. Robert M. Mumma, II, et al., No. 66 Equity 1988, Opinion and
Order, Finding of Fact 52 (C.P. Cumberland Mar. 24, 1992), post-trial motion denied andfinal
decree entered, Opinion and Order (C.P. Cumberland Nov. 5, 1992), aff'd, 433 Pa. Super. 660, 639
A.2d 846 (1993), allocatur denied, 539 Pa. 679, 652 A.2d 1324 (1994).
[d., Finding of Fact 53.
[d., Finding of Fact 54.
[d., Finding of Fact 55.
[d., Finding of Fact 57.
Id., Finding of Fact 58.
18
19
20
21
22
23
4
[Barbara McK.] Mumma is the sole shareholder of Mumma Realty Associates, Inc.24
Section 14 of the MRA agreements requires that the individual tenants-in-common execute
documents or perform other necessary actions to carry out the intent of the agreement or to
effectuate decisions of the majority in interest.25
On December 19, 1986, [Robert M. Mumma, II] executed a Eower of attorney (the MRA power
of attorney) pursuant to Section 14 of the MRA agreements. 6
The MRA power of attorney named the other tenants-in-common, including the Estate, [Barbara
McK.] Mumma and Lisa [M. Morgan], as [Robert M. Mumma, II]'s attorneys in fact to execute
on his behalf any deeds or other instruments necessary and desirable to carry out any of the
purposes under the MRA agreements.27
The purpose of the MRA powers of attorney signed by the tenants-in-common was to enable a
majority in interest of the tenants to proceed with transactions pursuant to the majority control
provisions of Section 4 of the MRA agreements and effectuate decisions with or without the
subsequent cooperation of an individual tenant.28
THE UNSUCCESSFUL TRANSACTION WITH CRH
Lisa [M. Morgan] and Barbara McK. [Mumma] as officers of the corporations entered into
negotiations to sell various assets and properties comprising the Pennsy Supply businesses to
CRH Industries in the latter part of 1988.29
CRR offered to buy Pennsy Supply, but the deal fell through because of threats oflitigation
made by Robert costing Pennsy Supply approximately $20 million dollars.3o
THE SUCCESSFUL TRANSACTION WITH CRR
During the Spring of 1992, Lisa [M. Morgan] and Barbara McK. [Mumma] went forward and
tried to market the Pennsy Supply businesses to several other people.3!
24
Id., Finding of Fact 60.
Id., Finding of Fact 51.
Id., Finding of Fact 61.
Id., Finding of Fact 62.
!d., Finding of Fact 65.
In re Estate of Robert M. Mumma, Deceased, No. 21-86-398, Opinion and Order of Court, Finding
of Fact 11 (O.C. Cumberland Aug. 4, 1993), aff'd, 437 Pa. Super. 672, 649 A.2d 467 (1994).
Id., Finding of Fact 12.
In re Estate of Robert M Mumma, Deceased, No. 21-86-398, Opinion and Order of Court, Finding
of Fact 18 (O.C. Cumberland Aug. 4, 1993), aff'd, 437 Pa. Super. 672, 649 A.2d 467 (1994).
25
26
27
28
29
30
31
5
In the summer of 1992, negotiations resumed with eRR. 32
January 5, 1993, Lisa [M. Morgan] and Barbara McK. [Mumma] entered into a confidentiality
agreement. 33
As of May 8, 1993, Lisa [M. Morgan] and Barbara McK. [Mumma] entered into a letter of
intent. 34
In July 1993, pursuant to a majority vote of shareholders, all shares of Nine Ninety-Nine, Inc.,
along with other corporate assets denominated collectively as the "Pennsy Supply Businesses,"
were sold to another corporation, CRH plc.35
The terms of the sale include:
(a) In exchange for the $32 million dollars from CRH, these five separate business
interests were sold;
(i) stock in Nine Ninety-Nine, Inc., the holding company for the Pennsy Supply
businesses,
(ii) stock in Hummelstown Quarry, the corporation that actually holds the real
estate which Pennsy Supply leases,
(iii) one hundred per cent ownership of Benders Quarry in Mt. Holly Springs,
(iv) the Paxton Street yards, the main office building in Harrisburg, and
(v) for an additional $2 million dollars, CRH would be given 120 days from the
date of closing to exercise an option to buy a 50% in Lebanon Rock, Inc., raising the total
purchase price to $34 million dollars.
(b) The money from the sale would be allocated over the five separate business interests
and distributed according to each shareholder's percentage of ownership with an escrow account
for dissenting shareholders.
(c) CRH insisted that a corporation be formed so that they could buy the five business
interests as a whole from a single seller in order to maximize tax benefits and to avoid law suits
32
35
Id., Finding of Fact 19.
Id., Finding of Fact 21.
Id., Finding of Fact 22.
Robert M Mumma, II v. Pennsy Supply, Inc., No. 99-2765 Equity, Opinion and Decree Nisi, Finding
of Fact 22 (C.P. Cumberland May 17, 2002), post-trial motions denied andfinal decree entered,
Opinion and Final Decree (July 29, 2002), aff'd, 833 A.2d 1156 (Pa. Super. 2003), allocatur denied,
577 Pa. 723, 847 A.2d 1287 (2004).
33
34
6
with Robert over the sale of each interest. Kodie Corporation was formed to comply with this
demand.
(d) By purchasing the separate interests through Kodie Corporation, CRH assumes all of
the liabilities of each individual interest.
(e) Non-business assets were retained by Pennsy Supply in proportion to the stock
owners' percentage of ownership for future development.
(f) CRH agreed to honor existing long term contracts including employment contracts
protecting long term employees and a cap on CRH's right of indemnification.
(g) CRH would own no interest in Union Quarry and could only obtain a 50% interest in
Lebanon Rock by paying an additional $2 million dollars.
(h) The purchase price was fixed at $32 million dollars, no adjustments, no financing, no
pledging ofPennsy Supply's assets, the full amount in cash.36
. . . Lisa [M. Morgan] and Barbara McK. [Mumma] received no separate consideration,
employment contract or consulting contract, or separate benefits. 37
The closing of the sale was set up into two stages: Stage I was scheduled for July 8, 1993, and
completion of the sale closing; Stage II was scheduled at least ten days after the notice of Stage I
was mailed.38
By way of power of attorney, Barbara McClure signed on as a participating stockholder leaving
Robert [M. Mumma, II] as the only non-participating shareholder.39
Stage II ofthe sale closing was completed July 21, 1993. . . .40
The proceeds from the sale were allocated over each of the five business interests and distributed
according to each shareholder's percentage in ownership of those interests with an escrow
account for dissenting shareholders.41
On March 17, 1995, [Robert M. Mumma, II] joined the sale of the "Pennsy Supply Businesses"
through the execution of an "irrevocable" consent and joinder.42
39
In re Estate of Robert M. Mumma, Deceased, No. 21-86-398, Opinion and Order of Court, Finding
of Fact 23 (O.C. Cumberland Aug. 4, 1993), aff'd, 437 Pa. Super. 672, 649 A.2d 467 (1994).
Id., Finding of Fact 25.
Id., Finding of Fact 26.
Id., Finding of Fact 29.
Id., Finding of Fact 39.
!d., Finding of Fact 41.
36
37
38
40
41
7
On March 17, 1995, [Robert M. Mumma, II] sold his outstanding shares in Nine Ninety-Nine,
Inc., to CRH pIc and received approximately $3 million in proceeds from the sale.43
As of March 17, 1995, [Robert M. Mumma, II] retained no ownership interest in Nine Ninety-
N. I 44
me, nc.
[Robert M. Mumma, II]'s share certificate, bearing the name Pennsy Supply Inc., does not
represent an ownership interest in any corporation in the Commonwealth.45
[Robert M. Mumma, II']s share certificate, bearing the name ofPennsy Supply Inc., does not
entitle Plaintiff to exercise any shareholders' rights with respect to any corporation in the
Commonwealth.46
The shareholders' agreement, executed by shareholders in Pennsy Supply Inc. in 1961 and
terminated by the same shareholders in 1963, did not operate to void. . . the March 17, 1995,
sale ofthose shares by [Robert M. Mumma, II] to CRH plc.47
[Robert M. Mumma, II] is not entitled to the exercise of any shareholders' rights with respect to
the option to purchase shares in a corporation known as Pennsy Supply Inc., or any derivation
thereof.48
42
Robert M. Mumma, II v. Pennsy Supply, Inc., No. 99-2765 Equity, Opinion and Decree Nisi, Finding
of Fact 23 (C.P. Cumberland May 17, 2002), post-trial motions denied andfinal decree entered,
Opinion and Final Decree (July 29,2002), aff'd, 833 A.2d 1156 (Pa. Super. 2003), allocatur denied,
577 Pa. 723, 847 A.2d 1287 (2004).
Id., Finding of Fact 24.
Id., Finding of Fact 26.
Id., Conclusion of Law (a).
Id., Conclusion of Law (b).
Id., Conclusion of Law (d).
Id., Conclusion of Law (e).
43
44
45
46
47
48
8
CERTIFICATE OF SERVICE
I, Tricia D. Eckenroad, an authorized agent of Martson Law Offices hereby certify that a
copy of the foregoing Motion in Limine of Barbara McK. Mumma and Lisa M. Morgan to
Exclude Argument and Evidence as to Matters Previously Adjudicated was served this date by
depositing same in the Post Office at Carlisle, P A, first class mail, postage prepaid, addressed as
follows:
Mr. Robert M. Mumma, II
Box 58
Bowmansdale, P A 17008
Mr. Robert M. Mumma, II
6880 S.E. Harbor Circle
Stuart, FL 34996-1968
Mr. Robert M. Mumma, II
840 Market Street, Suite 164
Lemoyne, P A 17043
Ralph A. Jacobs, Esquire
JACOBS & SINGER, LLC
1515 Market Street, Suite 705
Philadelphia, PA 19102
(Attorney for Barbara Mann Mumma)
Brady L. Green, Esquire
MORGAN, LEWIS & BOCKIUS LLP
1701 Market Street
Philadelphia, PA 19103-2921
(Attorney for Estate and Executrixes)
Ms. Linda Mumma Roth
P.O. Box 480
Mechanicsburg, P A 17055
Taylor P. Andrews, Esquire
ANDREWS & JOHNSON
78 West Pomfret Street
Carlisle, P A 17013
(Court-Appointed Auditor)
y C
Tricia D. Eckenroad
10 East High Street
Carlisle, P A 17013
fltUf 30102008'
F:\FILES\Clients\Murnma 5844.1 (estate) 8747 (Kim)\5844.I.Mumma ijstate\5844.1.Motion in Limine re Collateral Estoppel - May 30, 2008
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