HomeMy WebLinkAbout12-24-08E~FILES'~Clients\Mumma 5844.1 (estate) 8747 (Kim)\5844. LMumma Estate\5844.1.398secondpetition
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Reeised: 12!24108 8:~6AM
George B. Faller, Jr., Esquire n
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Jennifer L. Spears, Esquire ~' ,..~
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MARTSON DEARDORFF WILLIAMS OTTO GILROY & FALLER _ ~ ~ r-
MARTSON LAW OFFICES - ;
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10East High Street _ _ --
Carlisle, PA 17013 y rv ~ ~ ` ~~
(717) 243-3341 '~'
Attorneys for Barbara McK. Mumma and Lisa M. Morgan
IN THE COURT OF COMMON PLEAS OF
CUMBERLAND COUNTY, PENNSYLVANIA
IN RE:
Estate of Robert M. Mumma, NO. 21-86-398
Deceased
ORPHAN'S COURT DIVISION
SECOND PETITION FOR JUDICIAL NOTICE
AND NOW, come Lisa M. Morgan and Barbara McK. Mumma, by and through their
attorneys MARTSON DEARDORFF WILLIAMS OTTO GILROY AND FALLER, and bring this
Petition for Judicial Notice pursuant to PA Rule of Evidence 201, and avf;r as follows:
1. Petitioners are Lisa M. Morgan and Barbara McK. Mumma ("the Executrices").
2. Respondent is Robert M. Mumma, II.
3. On May 30, 2008 Petitioners filed a Petition for Judicial Notice requesting that Court
take judicial notice of the following Court Orders, which were attached to that Petition:
a. On February 13, 1989, this Court entered an Order and Opinion in Barbara
McK. Mumma, et al. v. Robert M. Mumma II et al., No. 66 Equity 1988
(Cumberland County Court of Common Pleas) and No. 21-86-398
(Cumberland County Court of Common Pleas -Orphan's Court Division).
b. On March 24, 1992, this Court entered an Order and Opinion in Barbara
McK. Mumma, et al. v. Robert M Mumma II et al., No. 66 Equity 1988
(Cumberland County Court of Common Pleas).
c. On November 5, 1992, this Court entered an Order and Opinion in Barbara
McK. Mumma et al. v. Robert M. Mumma II et al., No. 66 Equity 1988
(Cumberland County Court of Common Pleas).
d. On August 4, 1993, this Court entered an Order anti Opinion in In Re: Estate
of Robert M. Mumma, Deceased, No. 21-86-398 (C'umberland County Court
of Common Pleas -Orphans' Court Division).
e. On July 29, 2002, this Court entered an Order and Opinion in Robert M.
Mumma, II v. Pennsy SUppl~nc , No. 99-2765 (Cumberland County Court
of Common Pleas). 4. The Executrices are unaware of any response filed to
that Petition, or any Order entered as a result.
The Executrices also move for the Court to take Judicial Notice of the memorandum
Opinion of the Superior Court in Barbara McK. Mumma, et al. v. Robert M. Mumma, II, et al., No.
56 Harrisburg 1993, affirming the Order entered November 5, 1992 in Barbara McK. Mumma et
al. v. Robert M. Mumma II et al , No. 66 Equity 1988 (Cumberland County Court of Common
Pleas). A copy of the Order and Opinion is attached hereto as Exhibit "A."
6. The contents of certified copies ofpublic records are deemed. to beself-authenticating
pursuant to PA Rule of Evidence 902(4).
The Honorable J. Wesley Oler, Jr., has ruled in this action.
8. Counsel for Barbara McK. Mumma and Lisa M. Morgan have not contacted Mr.
Mumma, II as to his concurrence to this Motion; however, it is assumed hey would have opposed it.
WHEREFORE, Petitioners respectfully request that this Honorable Court take judicial notice
of the above-listed orders and decisions, specifically including the Superior Court Order and Opinion
attached hereto.
MARTSON LAW OFFICES
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M
may` ._ V '
By r
George B Fa er, Jr., Esquire
Jennifer L. Spears, Esquire
10 East High Street
Carlisle, PA 17013
(717)243-3341
Attorneys for Attorneys for Barbara McK. Mumma and
Lisa M. Morgan
Date: December 24, 2008
J. A37040/'93
BARBARA MCK. MUMMA AND ,
LISA M. MORGAN, ,
INDIVIDUALLY AND AS ,
EXECUTRICES OF AND TRUSTEES
UNDER THE WILL OF ROBERT M.
MUMMA, DECEASED AND LINDA .
M. BOTH, ,
APPELLEE ,
v.
ROBERT M. NlLTMMA, II AND ,
BARBARA M. MC CLURE, .
APPEAL OF : ROBERT M . MUNA9A, I I
IN THE SUPERIOR COURT OF
PENNS~'LVANIA
N0. 56 HARRISBURG 1993
Appeal from the Order entered November 5, 1992
docketed November 6, 1992 in the Court of
Common Pleas of Cumberland County, Civil
Division, at No. 66 Equity 1988.
BEFORE: DEL SOLE AND HOFFMAN, JJ.
MEMORANDUM:
F 1 L E D NOV -- 51993
This is an appeal from the February 13, 1989, March 24, 1992
and November 5, 1992 trial court orders in an eQU;r_v arr;r,n
concerning Appellant's threatened attempts to disrupt a proposed
sale of stock and realty held by himself and Appellees as tenants-
in-common. Finding no abuse of discretion or error of~ law by the
trial court, we affirm.
The parties to this action are members of the Mumma family,
which has been in the construction and concrete business in the
central Pennsylvania area for generations. In 1921, Walter Mumma
founded Pennsylvania Supply Company, Incorporated, and in 1947,
his son, Robert M. Mumma, Sr. founded Kim Company, Incorporated.
EXHIBIT "A"
J. A37040/93 - 2
Robert M. Mumma, Sr. and his wife, Barbara McK. Mumma ("Mrs.
Mumma"), who is an appellee in this action, had four children:
Robert M. Mumma, II ("Bob"), who is the appellant in this action;
Lisa M. Morgan ("Lisa") and Linda M. Roth ("Linda"}, who are
appellees in this action; and Barbara M. McClure ("Barbara"). The
underlying facts in the present action have been aptly summarized
by the trial court as follows:
Mrs. Mumma and Lisa Mumma Morgan are
executrices of the Estate of Robert M. Mumma
[Sr.].1 They, .along with plaintiff Linda M.
Roth, Robert M. Mumma, II, and nominal
defendant Barbara M. McClure, are the former
shareholders of Kim Company and Pennsylvania
Supply Company, Harrisburg, Pennsylvania. On
December 19, 1986, those two corporations were
liquidated and their respective assets were
conveyed to the former shareholders of the
corporation as tenants-in-common. Two written
agreements among tenants-in-common were
executed by the former shareholders
contemp raneously with the liquidation of the
corporations. Bob signed those two
agreements, commonly referred to as MRA I and
MRA II, on December 19, 1986. By it:s terms,
MRA I expressly governed the properties
previously held by Kim Company, and MRA II
governs the assets of Pennsylvania Supply.
The liquidation of Pennsylvania Supply
and Kim Company were motivated solely by tax
considerations and not by any desire to alter
the management and control structures of the
corporations. The parties sought to retain
structures functionally resembling as; closely
as possible the pre-existing corporate
arrangement. The shares of the family members
in the tenancies-in-common thus remained
identical to their proportional stock
ownership in the corporations. 'The MRA
agreements also maintained the majority-based
decision-making arrangement which existed in
the corporations.
Pursuant to Section I of the MRA
agreements, MRA, Inc. was appointed manager of
both tenancies-in-common. Mrs. Mumma ,and Lisa
1Robert M. Mumma died testate on April 12, 1986.
J. A37040/93 - 3
are the officers and directors of MRA, Inc.
On October, 19, 1986, Bob executed a power of
attorney...pursuant to Section 14 of the MRA
Agreements. The MR.A power cif attorney named
the other tenants-in-common, including the
Estate, Mrs. Mumma and Lisa, as Bob's
attorneys in fact to execute on his behalf any
deeds or other instruments necessary to carry
out any of the purposes under the MRA
agreements. The MRA power states on its face
that it is coupled with an interest and is
irrevocable. Similar powers of attorney were
executed by the other family members.
The Estate, Mrs. Mumma, Lisa and Bob are
also among the shareholders of the Nine Ninety
Nine, Inc. (999}, a privately held
corporation. The Estate owns the largest
interest in 999. Pennsy Supply, Inc. (Pennsy}
is, in turn, a wholly owned subsidiary of 999.
On June 30, 1987, the tenants-in-common under
the MRA agreements held a meeting to discuss
the proposed sale by Mrs. Mu~~mma and Lisa, as
officers of MRA, Inc., of Lot 1-B located in
Lemoyne, Pennsylvania. To facilitate the
sale, and in order to avoid the necessity of
filing the MR.A agreements, Mrs. Mumma and Lisa
sought to procure from the other owners powers
of attorney specifically referring to the
Lemoyne property. Bob agreed to, and did,
sign the new power of attorney. Bob
subsequently demanded .the return of the later
power, and Lisa complied with the request.
The sale of the Lemoyne lot was completed in
July of 1987. In order to effectuate the
sale, Mrs. Mumma and Lisa usedi the still valid
MR.A power of attorney executed by Bob in
December, 1986, rather than the June, 1987
power.
Following his agreement to sign the new
power of attorney for use in the sale of the
Lemoyne lot, Bob requested that he be given a
right of first refusal to purchase Pennsy,
should Mrs. Mumma and Lisa decide to sell it.
Mrs . Mumma and Lisa stated that they might be
willing to grant Bob a right of first refusal
as to Pennsy, but that they would not consent
if their financial and legal advisors did not
approve the step. Mrs. Mumma and Lisa's
attorneys counseled them that granting the
first refusal right would nat be in their
financial or legal interests because it would
impair the value of the Estate by rendering
Pennsy, one of the Estates largest assets,
J. A37040/93 - 4
virtually impossible to sell for its full
market value.
In November, 1988, while Mrs. Mumma and
Lisa were engaged in negotiations with a
prospective buyer for a sale of stock of 999,
and thus Pennsy, and real property owned by
the MRA tenancies, Bob sent a letter to
Barbara in which he claimed that he held a
right of first refusal stemming from the June
30, 1987 meeting. On December 27, 1988, Mrs.
Mumma and Lisa commenced this ,action in
equity, upon information and belief: that Bob
would attempt to disrupt a proposed sale of
stock of 999 and real properties owned by the
MRA tenancies. Mrs. Mumma and Lisa sought a
declaratory judgment removing Bob's threatened
obstruction of the transfer and declaring the
MRA agreements and the MRA power of attorney
signed by Bob on December 19, 1986, were valid
and enforceable.
Following three and one-half days of testimony, the trial
court entered a lengthy opinion and order on March 24, 1992.
Based upon its detailed findings of fact and conclusions of law,
the trial court entered a declaratory judgment. The court held
that the two MRA agreements signed by Bob on December 19, 1986,
were binding upon him and did not grant him any right of first
refusal as to any transfers by Mrs. Mumma and Lisa, as
executrices, of the realty held by MRA tenants-in-common when
there was approval by a majority in interest; ghat the MRA general
power of attorney which Bob executed on December 19, 1986, was
valid and irrevocable, and empowered Mrs. Mumma and Lisa to
transfer properties held by the MRA tenancies-in-common, pursuant
to Section 14 of the MR.A agreements; and that Bob was never
granted an oral right of first refusal to purchase Pennsy Supply
in June, 1987, in exchange for his promise to execute a power of
' J. A37040/93 - 5
attorney for Lot 1-B in Lemoyne. Bob filed a motion for post-
trial relief, seeking reconsideration of the matter. Following
the denial of his motion, Bob brought this appeal, which raises
the following issues:2
1) Whether the two MRA agreements are binding and valid
tenancy-in-common agreements when Bob did not sign
them?
2) Whether the best evidence rule requires the
executrices to produce ,the original tenancy-in-common
documents or provide a satisfactory explanation for
their absence?
3) Whether a common law right of first refusal is
available to Bob as a tenant-in-common, and whether such
right was waived unambiguously?
4) Whether, assuming that the tenancy-in-common
agreements are enforceable, the agreement.. give each co-
tenant a right of first refusal?
5) Whether the parties have revoked the tenancy-in-
common agreements?
6) Whether the trial court misunderstood the
interworkings of the tenancy relationship?
7) Whether the general power of attorney executed by Bob
on December 19, 1986 empowers the executrices to
transfer properties held by the tenancies-in-common?
8) Whether Bob was granted an oral right of first
refusal in regard to the sale of Pennsy Supply?
9) Whether the law firm of Morgan, Lewis & Bockius
should be disqualified from representing t:he executrices
when the firm gave the family advice with regard to the
MRA agreements while at the same time advising Bob in
his personal estate planning?
The scope of this court's review of a decree in equity
rendered by the trial court is particularly limited. Volunteer
Fire Co. of New Buffalo v Hilltop Oil Co 4:12 Pa. Super. 140,
2In his reply brief, Appellant raises additional issues of fact,
which we find to be meritless in light of the trial court's
findings of fact in its thorough opinion.
J. A37040/93 - 6
145-46, 602 A.2d 1348, 1351 (1992). On appeal, the findings of
~"
the trial judge must be accorded the same weight as a jury
verdict, Linnet v Hitchcock, 324 Pa. Super,. 209, 212, 471 A.2d
537, 538 (1984), and these findings should not: be disturbed unless
they are not supported by evidence in the record or are the result
of an abuse of discretion. ,~.; Hostetter v. Hoover, 378 Pa.
Super. 1, 6, 547 A.2d 1247, 1250 (1988) , aff ~, 523 Pa. 642, 565
A.2d 11 67 (1989). Furthermore:
..the party favored by the findings of the .
trial judge is entitled to have the evidence
viewed in the light most favorable to him;
that is, all the evidence and the proper
inferences favorable to him must be taken as
true, and all unfavorable inferences
rejected.
Linnet v. Hitch-oqk, 324 Pa
Super
at 213
471 A
d
.
.
,
.2 at 538,
quoting Brenna v Nationwide Insurance Company, 294 Pa. Super.
564, 440 A.2d 609 (1982).
In the instant case, nearly all of the issues relate to the
factual findings of the trial court. A finding of fact will not
be disturbed on appeal unless unsupported by competent evidence or
predicated on errors of law. Eddystone Fare Co No 1 v
Continental Insurance Companies, 284 Pa. Super. 260, 425 A.2d 803
(1981). Moreover, a final decree in equity "will not be disturbed
unless it is unsupported by the evidence or demonstrably
capricious." Sack v. Feinman, 489 Pa. 152, 166, 413 A.2d 1059,
1066 (1980). Having carefully reviewed the record, we find all of
the trial court's factual conclusions to be supported by competent
evidence. Appellant's testimony, which he cites in his brief as
the basis for his argument that the trial court erred in making
~ ..
J. A37040/93 - 7
its findings of fact, was heard by the trial court and was not
found to be as credible as that of Appellees and their witnesses.
The trial court, in its well-reasoned opinion, has cited the
portions of the record which support its factual findings, and we
hold that such evidence provides a credible basis for the court's
verdict. It is not the function of this court to substitute its
judgment or evaluation of evidence where the2-e is some credible
evidence on which to base the verdict. Eldridge v. M lcher, 226
Pa. Super. 381, 313 A.2d 750 (1973). Accordingly, we affirm the
factual issues raised by Appellant on the basis of the trial
court's excellent opinion.
The sole legal issue raised by Appellant concerns the
application of the best evidence rule to the MRA agreements. The
trial court found that the Appellees had made a satisfactory
explanation for the failure to produce the original agreement.
(See 2 McCormick on Evidence §237, at 76 (1992),; 1 Packel & Poulin
§1001.3, at 598-99 (1987): Destruction or loss is a satisfactory
explanation for failure to produce an original writing.) We find
no error of law in the trial court's reasoning, nor do we find
that the trial court abused its discretion in ,its ruling on this
issue. Therefore, we affirm this issue on the basis of the
court's reasoning in its opinion.
Orders affirmed.
Fr FILESd'Iients Mumma 5844.1 (estate) 8747 (Kim)~5844.LMumma Estate\5644-1.396.cettservice
CERTIFICATE OF SERVICE
I, Tricia D. Eckenroad, an authorized agent of Martson Law Offices, hereby certify that a copy
of the foregoing Second Petition for Judicial Notice was served this date by depositing same in the Post
Office at Carlisle, PA, first class mail, postage prepaid, addressed as follows:
Mr. Robert M. Mumma, II
Box F
Grantham, PA 17027
Mr. Robert M. Mumma, II
6880 S.E. Harbor Circle
Stuart, FL 34996-1968
Mr. Robert M. Mumma, II
840 Market Street, Suite 164
Lemoyne, PA 17043
Ralph A. Jacobs, Esquire
JACOBS & SINGER, LLC
1515 Market Street, Suite 705
Philadelphia, PA 19102
(Attorney for Barbara Mann Mumma)
Brady L. Green, Esquire
MORGAN, LEWIS & BOCKIUS LLP
1701 Market Street
Philadelphia, PA 19103-2921
(Attorney for Estate and Executrixes)
Joseph D. Buckley, Esquire
1237 Holly Pike
Carlisle, PA 17013
(Court Appointed Auditor)
Ms. Linda M. Mumma
212 North Duke Street
Durham, NC 27701
MARTSON LAW OFFICES
By
ricia D. Eckenroad
10 East High Street
Carlisle, PA 17013
Dated: December 24, 2008 (717) 243-3341