HomeMy WebLinkAbout04-01-05 (3)
F:IFILESIDATAF1LEIMumma 5844.1 (estate) 8747 (Kim)\5844.I.Mumma Estate\5844-revisedreqpro3
Cre.ted: 3/22/05' 9:35AM
Revised: 4/1/05 1\ :53AM
IN THE COURT OF COMMON PLEAS
OF CUMBERLAND COUNTY, PENNSYLVANIA
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
THIRD SET OF REOUESTS FOR PRODUCTION OF DOCUMENTS TO THE
EXECUTRICESITRUSTEES
Barbara McK. Mumma and Lisa M. Morgan hereby object as follows to the thjni set of
requests for production of documents served upon them by Robert M. Mumm~,ir1perein~~r
Mumma, IT").
,I: I
1.
Objection.
f"'<)
..
e...-,
N
Mr. Mumma, IT's foregoing request for production of documents to BarbaraMcK. Mumma
and Lisa M. Morgan is overly broad, unduly burdensome and largely duplicative of discovery
previously served in this and other proceedings.
Mr. Mumma, IT requests bills and invoices for the years 1986 through 2004 from Haile, Shaw
& Pfaffenberger, P.A. fIkIa Haile, Flemming & Shaw, P .A. The Respondents and their counsel have
already produced thousands of pages of documents responsive to Mr. Mumma, IT's discovery
request. Furthermore, Mr. Mumma, IT has been provided documentation regarding the subjects
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, IT is equally able to obtain the information
he has requested from such documents. Further, some ofthe information he seeks is protected from
disclosure by one or more privileges.
......c:.....~
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 ofthe
auditor. These are matters that may only be addressed by the auditor.
MARTSON DEARDORFF WILLIAMS & OTTO
BY~
Ivo V. Otto Ill, 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:\FILES\DATAFILElMununa 5844.1 (estate) 8747 (Kim)15844.1.Mununa EstaleI5844-1.398.cert.service
Created: 312110S 4: 13PM
Revised: 411105 !0:33AM
CERTIFICATE OF SERVICE
I, Hillary A. Dean, an authorized agent of Marts on Deardorff Williams & Otto, hereby certify that
a copy of the foregoing Response of Barbara McK. Mumma and Lisa M. Morgan to Objector's Third Set
of Requests for Production of Documents to the Executrices/Trustees was served this dateby 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 SE Harbor Circle
Stuart, FL 34996
MARTSON DEARDORFF WILLIAMS & OTTO
B~(J j)f)fl0
. ary A. Dean, E re '
Attorney J.D. No. 92878
10 East High Street
Carlisle, PA 17013
(717) 243-3341
Dated: April 1, 2005