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Ralph A. Jacobs (I.D. No. 21387)
Ralph A. Jacobs & Associates LLC
1515 Market Street
Suite 705
Philadelphia, PA 19102
(215) 789-3110
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Counsel fo
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ara Mann Mumma
IN RE: ESTATE OF
ROBERT M. MUMMA, DECEASED
IN THE COURT OF COMMON PLEAS
: CUMBERLAND COUNTY
ORPHANS COURT DIVISION
NO. 21-86-398
OBJECTIONS OF BARBARA MANN MUMMA
Barbara Mann Mumma hereby objects to the Accounts filed by the
Executrices/Trustees in this matter on the following grounds:
1 • The selection of assets to be distributed to the Marital Trust and the
Residuary Trust was inappropriate inasmuch as assets for which rapid appreciation could
be expected were placed in the Marital Trust, not the Residuary Trust, thereby
prejudicing the interests of beneficiaries and creating the potential for unnecessary estate
tax liability upon the death of Barbara McKim Mumma.
2• Assets distributed to Barbara McKim Mumma as income distributions,
including the Fulton Bank property, appear to have been undervalued thereby prejudicing
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the interests of other beneficiaries.
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3• Inadequate valuation was made of certain assets distributed to Barbara
McKim Mumma pursuant to her power to receive an annual distribution of 5% of the
value of the Marital Trust, thereby prejudicing the interests of other beneficiaries.
4• Discretionary distributions were made to Barbara McKim Mumma from
the Marital Trust despite her indication that she did not want distributions unless re ui
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for her immediate expenses, thereby prejudicing other beneficiaries and creatin the
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potential for unnecessary estate tax liability
5• Estate assets and entities in which estate had an interest, including Bobali,
were not managed efficiently resulting in a failure to maximize income and value,
unnecessary exposure to liability, and the burdening of beneficiaries with expenses to
prevent tax sales and to take other steps to preserve assets that should have been better
protected.
6.
unnecessary legal and other expenses and prejudicing the interests of beneficiaries.
~• The Estate was administered in a manner that exacerbated friction among
family members thereby delaying the administration of the estate, increasing legal and
other expenses, failing to effectuate the intent of the Testator, and otherwise prejudicin
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beneficianes.
The Estate was not wound up promptly or efficiently, instead incurring
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Permission is requested to submit additional objections in the event further
information is received at the postponed deposition of Joseph A. O'Conner, Jr., Es uire
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or other discovery proceedings in this matter.
Respectfully submitted,
Ralph A. Jacobs
Attorney I.D. No. 21387
Ralph A. Jacobs & Associates LLC
1515 Market Street
Suite 705
Philadelphia, PA 19102
(215) 789-3110
Counsel for
Barbara Mann Mumma
Dated: January 30, 2008
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CERTIFICATE OF SERVICE
I, Ralph A. Jacobs, hereby certify that I caused a copy of the foregoin Ob'ecti
of Barbara Mann Mumma to be served via United States First Class mail u n t J °ns
following on this 30th day of Janu P he
ary, 2008:
No V. Otto, III, Esquire
Martson Deardorff Williams & Otto, P.C.
Ten East High Street
Carlisle, Pennsylvania 17013-3015
Brady L. Green, Esquire
Morgan, Lewis & Bockius LLP
1701 Market Street
Philadelphia, PA 19103-2921
Robert M. Mumma, II, pro se
Box 58
Bowmansdale, PA 17008
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