HomeMy WebLinkAbout04-01-05 (2)
F:\FILESIDATAFILEIMumma 5844.1 (estate) 8747 (Kim)\5844.1.Mumma Estale\5844-revisedreqpro2
Created: 3121105,3:59PM
Revised: 4/1105 11:54AM
IN THE COURT OF COMMON PLEAS
OF CUMBERLAND COUNTY, PENNSYL VANIA
IN RE ESTATE OF
ROBERT M. MUMMA,
ORPHANS' COURT DIVISION
Deceased.
NO. 21-86-398
RESPONSE OF BARBARA McK. MUMMA AND LISA M. MORGAN TO OBJECTOR'S
SECOND SET OF REQUESTS FOR PRODUCTION OF DOCUMENTS TO THE
EXECUTRICES/TRUSTEES
Barbara McK. Mumma and Lisa M. Morgan hereby object as follows to th~ entire seP;gnd set
'_~ (',") j:::.~<"1.-_-,:,_.;1.
of requests for production of documents served upon them by Robert M. Mumnia~; II (her{ijilafter
'. ~...' '""1
1-6. Objection.
"Mr. Mumma, II").
f'.)
C)
The foregoing request for production of documents to Barbara McK. Mumma and Lisa M.
Morgan is overly broad, unduly burdensome and largely duplicative of discovery previously served
in this and other proceedings.
Mr. Mumma, II requests bills and invoices for the years 1986 through 2004 from numerous
sources- attorney Jordan Fields, the law firm Crary Buchanan Bowdish Bovie Beres Elder &
Thomas, the law firm Goldberg Katzman, P.C., the law firm of Boswell, Tinter, Piccola & Alford,
the law firm Saul Ewing LLP, and the accounting firm Hadley & Company. The Respondents and
their counsel have already produced thousands of pages of documents responsive to Mr. Mumma,
II's discovery request. Furthermore, Mr. Mumma, II has been provided documentation regarding the
subj ects covered in his requests for production of documents through informal and formal discovery
in the past.
Additionally, the information requested in this instance is not only over broad, it directly
relates to issues pending in other courts. Mr. Mumma, II is equally able to obtain the information
he has requested from such documents. Further, some ofthe infonnation he seeks is protected from
disclosure by one or more privileges.
Q S'?-
Finally, Taylor Andrews has been appointed auditor for the Estate. It is only appropriate that
discovery be conducted solely upon the permission of and pursuant to the schedule and plan of the
auditor. These are matters that may only be addressed by the auditor.
MARTSON DEARDORFF WILLIAMS & OTTO
BY~
Ivo V. Otto III, Esquire
Attorney J.D. Number 27763
Hillary A. Dean, Esquire
Attorney J.D. Number 92878
10 East High Street
Carlisle, P A 17013
(717) 243-3341
Date: April 1, 2005
Attorneys for Barbara McK. Mumma and
Lisa M. Morgan
F:IFILESIDATAFlLElMumma 5844.1 (estate) 8747 (Kim)\5844.1.Mumma Estate\5844-t.398.cert.seMce
Created: 3/21/05.4:13PM
Revised: 4/1/05 !0:33AM
CERTIFICATE OF SERVICE
I, Hillary A. Dean, an authorized agent of Marts on Deardorff Williams & Otto, hereby certify that
a copy ofthe foregoing Response of Barbara McK. Mumma and Lisa M. Morgan to Objector's Second
Set of Requests for Production of Documents to the Executrices/Trustees 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, IT
Box 58
Bowmansdale, P A 17008
Mr. Robert M. Mumma, IT
6880 SE Harbor Circle
Stuart, FL 34996
MARTSON DEARDORFF WILLIAMS & OTTO
BdfJ~aA)
Attorney J.D. No. 92878
10 East High Street
Carlisle, PA 17013
(717) 243-3341
Dated: April 1, 2005