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HomeMy WebLinkAbout07-11-08IN RE: ESTATE OF ROBERT M. MUMMA, Deceased IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA ORPHAN'S COURT DIVISION N0.21-86-398 N n ~ :.p~ ~ n -r_ ~ ---- -_5 s-- ~. ,-~, _, =:~: 3 (_; <~:_ ~,~ _; _, , ~, ~ 7 r-t i AND NOW comes Robert M. Mumma, II, pra se, and files the instant Answer and New Matter to the Motion of Barbara McK. Mumma and Lisa M. Morgam to Compel Disclosure, and in support thereof avers as follows: 1. Admitted in part; denied in part. It is admitted that a qualified disclaimer was filed with the Orphans' Court Division on January 12, 1987; it is denied that the undersigned filed same, caused same to be filed with the court, or otherwise authorized the filing of the disclaimer with the court. By way of further denial, the undersigned returned one executed copy of the disclaimer to Arthur L. Klein, Esquire with express handwritten instructions that said single executed copy was to be delivered to Lisa Morgan for her to hold as Executrix. (See, Exhibit "A" which was produced via discovery from Estate counsel). The filing at the court on January 12, 1987 was done by William Martson, Esquire who was never authorized by the undersigned to do so. On January 16, 1990, the undersigned filed a Praecipe with the Register of Wills office which states: "A Mr. William Martson filed a disclaimer without my authorization. I hearby revoke that disclaimer filed Jan. 12 1987. Book 115 Page 20-21." 1 2. Admitted in part; denied in part. It is admitted that the undersigned filed a petition to revoke the disclaimer which was granted by Judge Sheely on November 17, 1989 who thereafter issued an Opinion and Decree Nisi on March 21, 1991 permitting the revocation of the disclaimer. It is further admitted that Robert M. Frey had been appointed guardian ad litem of the undersigned's minor children and that Judge Sheely overruled Mr. Frey's exceptions to the final order of March 21, 1991 in an order dated July 21, 1993. It is denied as stated that Judge Sheely's rulings were over the objection of Robert M. Frey solely inasmuch as an Answer with New Matter in opposition to the petition to revoke the disclaimer was filed by the Executrices on August 24, 1989, and an Answer in opposition to the petition to revoke the disclaimer was filed by Linda M. Roth on August 28, 1989. Although the Executrices had filed an Answer with New Matter in opposition to the petition to revoke disclaimer and appeared via counsel in the proceedings before Judge Sheely conducted on August 28, 1989, the Executrices failed to file any exceptions to Judge Sheely's rulings unlike Mr. Frey and the Executrices failed to perfect any appeal to the Superior Court unlike Mr. Frey. 3. Admitted in part; denied in part. It is admitted that Paragraph #3 accurately quotes the Superior Court's opinion. The undersigned denies any inference intended by quoting said language of the Opinion as a conclusion of law to which no response is required. By way of further Answer, on July 18, 1994, the Superior Court dismissed the appeal filed by the guardian ad litem stating: "the attempt to represent the minor children with respect to the revocation of Robert Mumma's disclaimer is beyond the scope of Mr. Frey's limited appointment." 4. Denied. The averments of Paragraph #4 constitute conclusions of law to which no response is required. By way of further denial, this averment is vague, ambiguous, and disjointed, and not susceptible of a response. By way of further denial, the singulaz effect of the Superior Court's decision on July 18, 1994 was to dismiss an appeal upon determining that the appellant had lacked standing in the proceedings below. The dismissed appeal had been filed by the guazdian ad litem regarding a matter below which had involved a specific legal issue (i.e., the revocation of disclaimer issue) which was determined upon appellate review to be beyond the scope of the guardian ad litem's limited appointment: to wit, "Mr. Frey was appointed in anticipation of a dispute over the sale of the decedent's businesses from the estate. See Petition for Appointment of Guardian Ad Litem." Slip. op. p. 2. Noting that the minor children only becazne involved as a result of becoming remaindermen due to the disclaimer, the Superior Court further stated: "[i]t was essential that they have a representative in the event Robert opposed the sale. Mr. Frey's role was circumscribed to ensure the children's interests were best-served by either the sale or the failure to sell the businesses." Id. Footnote #1 of the Superior Court's decision further clarified that the revocation of disclaimer issue was not related to the issue of the sale of the businesses. By way of further denial, there is nothing remotely suggested by the Superior Court's opinion of July 18, 1994 which directly, indirectly, or otherwise renders the proceedings before Judge Sheely as a nullity inasmuch as the Executrices filed an Answer with New Matter in opposition to the petition and participated via counsel before Judge Sheely, yet voluntarily chose not to file exceptions or pursue an appeal. Therefore, the proceedings before Judge Sheely cannot be deemed a nullity as far as same respect the Executrices who filed responsive pleadings and who participated actively via counsel in the proceedings. Furthermore, the Executrices are estopped as a matter of law from attempting to relitigate the revocation issue inasmuch as same was either actually litigated or could have been litigated during the first proceedings as it constituted a part of the same action. 5. Admitted in part; denied in part. It is admitted that the Auditor authored a letter dated September 26, 2005 and that Paragraph #5 accurately quotes said two sentences. By way of further answer, the next sentence in said Auditor's letter states: "I will be evaluating this further." The final sentence of this pazagraph in said Auditor's letter states: "I am also interested to know if there should be an agreement by all that it would be desirable to have a final review of this issue before a final adjudication in this audit." It is further denied that there was an "attempt" to revoke the disclaimer: it actually was revoked pursuant to the final orders of two (2) President Judges of the court (President Judges Sheely and Hoffer) who permitted the revocation and restored the undersigned as a beneficiary who was entitled to an accounting. Similarly, it is denied that a "significant unresolved issue" exists given the law of the case and the prior adjudications by the Orphans' Court. By way of further denial, a two sentence passage from an informational letter sent nearly three (3) years ago by the Auditor during the earlier formative phases of his appointment does not constitute a Finding of Fact, a Conclusion of Law, or any similaz authoritative ruling issued as a result of any formal hearings with sworn testimony subject to cross-examination or any other formal adjudicative proceedings allowable under the PEF Code, and as such does not authorize the Orphans' Court at this juncture of the Auditor proceedings to enter an order granting a `motion to compel disclosure' as styled by Estate counsel. Paragraph #5 is further denied in that any inference intended by quoting said two sentences of the Auditor's letter constitutes a conclusion of law to which no response is required. 4 6. Denied. The averments of Paragraph #6 constitute conclusions of law to which na response is required. By way of further denial, Paragraph #6 sets forth a partial quotation of Footnote #1 of the Superior Court's opinion of March 7, 2006. Moreover, said Footnote #1 contains material misstatements of previously adjudicated and previously admitted facts. By way of further denial, other passages exist in Superior Court opinions which confirm that the disclaimer was validly revoked. See, Memorandum Opinion of July 18, 1994 ("For a number of reasons, Robert laterpetitioned to revoke his disclaimer, and the courtgranted this petition. Thereby Robert was restored as a remainderman under the trusts." Slip. op. p. 1, emphasis added); Memorandum Opinion of July 15, 1994 ("Robert II previously disclaimed his interest in the estate, and his minor children were named by the will as beneficiaries to replace him. Robert M. Frey was later appointed to represent the children in this dispute over the sale of the businesses. Subsequently, Robert II validly revoked his disclaimer; therefore, the children, through the guardian ad litem no longer have an interest in this dispute." FN 1, Slip. op. p. 1, emphasis added); Memorandum Opinion of March 7, 2006 ("In 1989, former President Judge Harold E. Sheely of this court granted petitioner's motion to revoke has disclaimer.... Robert M. Mumma, II, eventually asked for a complete accounting of the Estate, including an accounting of the Trusts in which he claimed an interest. Decedent's widow and Mrs. Morgan claimed in response that they could not provide an accounting to Robert M. Mumma, II because he did not have standing, and the issue of the revocation ofhis disclaimer had not been fully litigated.... This position of the executrices/trustees was r jetted by the court, and an accounting by the executrices/trustees was ordered on February 23, 2000." Slip. op. p. 2, quoting Judge Oler's trial court opinion of 3uly 15, 2005, emphasis added). Paragraph #6 is further denied in that any inference intended by quoting part of Footnote #1 of the Superior Court's opinion of March 7, 2006 constitutes a conclusion of law to which no response is required. 7. Admitted in part; denied in part. It is admitted only that Paragraph #7 contains a restructured quotation from the Auditor's letter attached as Exhibit "A". It is denied that this issue remains significant given that same as been previously adjudicated and constitutes the law of the case; the foregoing paragraphs of the instant Answer are incorporated herein. It is further denied inasmuch as said restructured quotation references only part of a complete sentence and does so out of context. Paragraph #7 is further denied in that any inference intended by quoting part of this sentence in the Auditor's letter constitutes a conclusion of law to which no response is required. 8. Denied. The foregoing paragraphs of the instant Answer are incorporated herein. During the course of pending Auditor's proceedings, alitigant /objector should not be compelled to submit a document which could constitute an admission against interest or otherwise be compelled to take action which could ultimately injure his interests and produce adverse and detrimental consequences in the context of pending or future litigation; accordingly, the undersigned denies that he is under any current legal obligation to provide the information in question and/or provide any other explanation as averred in Paragraph #8. WHEREFORE, the undersigned respectfully requests that the Motion to Compel Disclosure be DENIED. 6 NEW MATTER 9. Paragraphs #1 through #8 are incorporated herein by reference thereto. 10. The Executrices' claims are barred by estoppel. 11. The Executrices' claims are barred by laches. 12. The Executrices' claims are barred by res judicata. WHEREFORE, the undersigned respectfully requests that the Motion to Compel Disclosure be DENIED. Respectfully submitted, ~/ ~t ~7~/~'~~'U/ /~1,U1,M Robert M. Mumma, II ~ ~ P.O. Box 58 Bowmansdale, PA 17008 (717) 612-9720 PROSE ,,~ WAS MIN6TON NEW YORK LOS ANGELES ARTHUR L. KLEIN DIAL C~11CCT (z 16) 663-5444 FEDERAL EXPRESS MORGAN~ LEWIS & BOCKIUS COUNSELORS AT LAW 2000 ONE LQGAN SQUARE PMILAOELPHIA.PENNSYLVANIA 19103 Tc~EVwow[+(21S) 963-5000 Mr. Robert M. Mumma, 26 Stanton Lane Snowmass Village, Cc Re: Dear Bob: Qualified Estate of CA~1.E Aooucs s: MORLEBOCK i 0 81615 L~'" Disclaimer f IRtE Robert M. Mumr~ 1 Enclosed please f document which you ma.y use your interest in your dad's c op~e`~s o f a "qualified L`isclaimer disclaimer" MIAMI HARRISBURG LONDON As we have discussed, if you make a disclaimer of your interest in your dad's estate, then upon your mother's death the share of your dad's estate which would otherwise pass t4 you will pass to your issue. By making a "qualified disclaimer" under IRC g2S~18, you will not be making a taxable gift. Furthermore, since your dad died before enactment of the Tax Reform Act of 1986, the new generation skipping tax imposed by the Act will not apply when distribution is made to your issue. Accordingly, a qualified disclaimer of your interest in your dad's estate will result in the share of his estate which would have passed to you passing to your issue without any further wealth transfer taxation (other than the estate tax on your mother's death). ~ ~ -~ ~~~(~j 27 Z~ ~ ~-. Section 2518 of the Internal Revenue Code provides that the term "qualified disclaimer" means with respect to an interest under a Wfll an "irrevocable and unqualified refusal" to accept the interest but only if -- (i) such refusal is in writing, (ii) EXHIBIT "A" ~ ~Y~ 5 Mr. Robert M. M mma January 5, 198 Page the writing is received by the executors within nine months of the da e o ea , iii a erson ma zn the isc aimer has not accepted the interest or any o its enefits an iv as~a result o suc re usa t e interest asses without an direc ion on the par of t e person ma_ing the disclaimer to a bene iciary or "6ene~`i-ciaries other than him. In addi-- t--io as a matter of Pennsylvan~.a aw, a isclaimer to be effective must be filed with the Clerk of the Orphans' Court division of the county where the decedent was domiciled. You and I have discussed that any of your children born after your mother's death would not participate in the distribution of your disclaimed share of your father's estate. And there may even be an argument that a child of yours born after your father's death before your mother's should not participate. You plan to deal with the possible inequality in benefits among your children by providing an equalization gift in a trust you will create in the near future over a substantial portion of your Gemini stock. To follow through with a timely "qualified disclaimer" of your interest in your father's estate, sign four of the copies of the Disclaimer (keep the fifth), and return them to me, Federal Express, in the prepaid envelope provided. There is a Federal Express office at 209 Ventnor Avenue in Aspen, where a drop off can be made until 7:00 p.m. I will have copies delivered to your mother and Lisa, as Executors, and.a copy filed with the Court in Carlisle. If you have any question, please calla My home telephone number is (215-667-2844). Sincerely yours, /~i ~~~.~ Arthur L. Klein ' /rkb Enclosures RG Ew1S & BOCK! ~\~ '1 i 5~~~~~~ CERTIFICATE OF SERVICE I, Robert M. Mumma, II hereby certify that a copy of the foregoing Answer to Motion to Compel Disclosure was served this date by U.S. Mail, first class, postage prepaid, addressed to: George B. Faller, Jr., Esquire No V. Otto, III, Esquire Manson Law Offices 10 East High Street Carlisle, PA 17013 Brady Green, Esquire Morgan, Lewis & Bockius, LLP 1701 Market Street Philadelphia, PA 19103-2921 Ralph Jacobs, Esquire 1515 Market Street -Suite 705 Philadelphia, PA 19102 Linda Mumma Roth PO Box 480 Mechanicsburg, PA 17055 Taylor Andrews, Esquire Court-Appointed Auditor 78 West Pomfret Street Carlisle, PA 17013 DATE: ~ ~ ~ ~ g r~ ~ ~~~~ BY: ;~i' ~ ~~, Robert M. Mumma, II Box 58 Bowmansdale, PA 17008 717-612-9720 PROSE