HomeMy WebLinkAbout10-23-09I
IN RE:
ESTATE OF LOTTIE IVY DIXON,
DECEASED
Q-TIP TRUST U/A GEORGE F
DIXON, JR
IN THE COURT OF COMMON PLEAS OF
CUMBERLAND COUNTY,
PENNSYLVANIA
ORPHANS' COURT DIVISION
No. 21-2007-0686
21-1994-0754
INSTITUTIONAL TRUSTEE, M&T BANK'S RESPONSE TO RULE TO SHOW CAUSE
WHY DISCOVERY DEADLINE SHOULD NOT BE EXTENDED
As institutional Trustee, M&T Bank takes no position on the merits of the pending
motion.
However, M&T Bank reiterates its previously articulated concerns that the fees and
expenses which have already been incurred in this dispute appear disproportionate to the
amounts apparently in controversy, and seem certain to exceed any sum which any party is
reasonably likely to recover. As such, M&T Bank is constrained to note that further delay in the
ultimate resolution of this dispute will inevitably lead to the further escalation of costs to all
parties.
Date: October 22, 2009
Mark D. Bradshaw
Attorney I.D. $61975
STEVENS & LEE
17 North Second Street
16th Floor
Harrisburg, PA 17101 ~~~~ ~ ~~
(717) 255-7357
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Counsel for Institutional Trustee, M&T Bank ~ _.,; ~ c
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CERTIFICATE OF SERVICE
I, MARK D. BRADSHAW, ESQUIRE, certify that on this date, I served a
certified true and correct copy of the foregoing Institutional Trustee, M&T Bank's Response to
Rule to Show Cause Why Discovery Should Not Be Extended upon the following counsel of
record, by depositing the same in the United States mail, postage prepaid, addressed as follows:
Elizabeth P. Mullaugh, Esquire
Kimberly M. Colonna, Esquire
100 Pine Street
P.O. Box 1166
Harrisburg, PA 17108-1166
Attorneys for Executor
Daniel L. Sullivan, Esquire
223 Lincoln Way East
Chambersburg, PA 17201
Hubert X. Gilroy, Esquire
10 East High Street
Carlisle, PA 17013
Wayne F. Shade, Esquire
53 West Pomfret Street
Carlisle, PA 17013
Auditor
Date: October 22, 2009 Mark s~taw
SL 1 955891 v 1 /066255.00089