HomeMy WebLinkAbout12-17-08 (2)
IN THE COURT OF COMMON PLEAS
OF CUMBERLAND COUNTY, PENNSYLVANIA
IN RE: ESTATE OF ORPHAN'S COURT DIVISION
ROBERT M. MUMMA, ~ ~~
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Deceased NO. 21-86-398 ~ ~' ~ ~;
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AFFIDAVIT '~~ ~ ~
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AND NOW, comes Daryl E. Hewitt, Assistant to Robert M. Mumma, II, and provides
this statement.
1. On a number of occasions in the Autumn of 2005, I reviewed documents at the law
offices of Morgan, Lewis &Bockius in Philadelphia, Pennsylvania, for the purpose of selecting
c;ertain documents for copying as part of discovery in the case. Robert M. Mumma, II had
subpoenaed the Estate's attorneys for production of the Estate's files. It was our clear
understanding that we were reviewing documents in possession of the Estate's attorneys for the
purpose of managing the Estate.
2. In the Estate's files, in Box No. 68 of documents as marked by the Estate's attorneys
]Morgan, Lewis & Bockius, I found copies of the following documents that constituted
information on the personal finances of Robert M. Mumma, II:
Statement of Funds and Investment Assets
Statement of Funds and Investment Assets
Statement of Funds and Investment Assets
Statement of Funds and Investment Assets
Statement of Funds and Investment Assets
Statement of Funds and Investment Assets
Statement of Funds and Investment Assets
Statement of Funds and Investment Assets
Statement of Funds and Investment Assets
Statement of Funds and Investment Assets
As of 12/31/68
As of 12/31/69 (2 copies)
As of 12/31 /70
As of 12/31 /71
As of 12/31/72
As of 12/31 /73
As of 12/31/74
As of 12/31/75
As of 12/31 /76
As of 12/31/77
Statement of Funds and Investment Assets
Statement of Funds and Investment Assets
Statement of Funds and Investment Assets
Statement of Funds and Investment Assets
Statement of Funds and Investment Assets
Statement of Funds and Investment Assets
Statement of Funds and Investment Assets
Statement of Funds and Investment Assets
Statement of Funds and Investment Assets
Statement of Funds and Investment Assets
As of 12/31/78
As of 12/31 /79
As of 12/31/80 (2 copies)
As of 12/31/81
As of 12/31/82
As of 12/31/83
As of 12/31/84
As of 12/31/85
As of 12/31/87
As of 12/31/89
3. In addition, aside from Statements of Funds and Investment Assets, I located other
personal files of Robert M. Mumma, II. These included:
Prenuptial Agreement between Robert M. Mumma, II and Susan Regan
Personal Information Form for Robert M. Mumma, II
4. It is my understanding and belief that because these documents were in the possession
of the attorneys for the Estate of Robert M. Mumma, then they would have been accessible to the
Executors of the Estate of Robert M. Mumma, and anyone else who would have had access to
t:he files, including other parties conducting discovery during the ongoing litigation involving the
Estate.
5. At the time I uncovered these personal documents, I relayed this information to
]Robert M. Mumma, II, who appeared surprised and concerned about these discoveries.
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:Dated: December 15, 2008 BY: -~' `
Daryl E. Hewitt
VERIFICATION
I, Daryl E. Hewitt, Assistant to Robert M. Mumma, II and as an individual hereby verify
that the facts contained in the foregoing Affidavit, pursuant to Rule 76 of the Pennsylvania Rules
of Civil Procedure, are true and correct to the best of my knowledge, information and belief.
I understand that this verification is made subject to the penalties of 18 Pa. C.S.A. 4904
regarding unsworn falsifications to authorities.
Dated: December 15, 2008 BY: `~--
Daryl E. Hewitt