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Barbara Mann Mumma
541 Bridgeview Drive
Lemoyne, PA 17043
1
1 Q And you made a motion to Mr. Buckley of some
2 kind?
3 A Yes. There's motions -- they are back there
4 in my file.
5 Q And you got no action on it?
5 A None. And in one case where he did instruct
7 them to turn over four out of five items, apparently he
8 later then instructed the Court -- or advised the Court that
9 they shouldn't be turned over.
10 Q And this is of record?
11 A I don't know what he said to the Court. I
12 don't know what or how he advised the Court, it just says in
13 the Court's order that the Court, Your Honor, had been
14 advised by Mr. Buckley not to allow this discovery when he
15 told us in court -- he told the estate to provide these
16 issues, and one of the important documents is a post-nuptial
17 agreement between my mother and father and grandparents, I
18 believe, regarding the disposition of my grandfather's
19 shares and ownership interests in Pennsylvania Supply
20 Company, and this took place back in the 1950's, and I think
21 it is a very important document because it would amount to
22 control of the shares of Pennsylvania Supply Company.
23 Q Okay.
24 A And his comment was, I don't think it exists
25 so I'm not going to make him produce it. And clearly --
12
1 Q That is on the record?
2 A It all runs together for me. I know that is
3 what he said.
4 THE COURT: Okay. Mr. Green, do you have any
5 questions of Mr. Mumma?
6 EXAMINATION
7 BY MR. GREEN:
8 Q Just briefly. Mr. Mumma, your argument with
9 respect to th e Silver Springs Quarry is, in fact, that the
10 ownership of that corporation -- of that property was not
11 properly what your father said it was; is that right?
12 A What my father said it was?
13 Q Right.
14 A No. What your law firm and the estate -- my
15 father's estate said it was.
16 Q Okay. So you would agree that whatever
17 records showed as of your father's death were correct as to
18 what -- as to who owned the Silver Springs Quarry?
19 A I'm not agreeing to that at all.
20 Q So the records -- you are saying what your
21 father said about who owned the Silver Spring --
22 A I never said anything about what my father
23 said.
24 Q Answer my question. Your argument is that
25 what your father said about who owned the S~lver Springs
13
1 put them into the estate. I would like to cross-examine him
2 on that.
3 THE COURT: I understand that.
4 MR. MUMMA: If we're going to talk about
5 bias, why shouldn't I be able to ask him why that's his
6 mindset, that my sister has a right to take my sister and
7 mine inheritance from a grandfather and take it and give it
8 to my mother.
9 THE COURT: I don't know that he said that.
10 He said he hoped that your sister had operated properly.
11 MR. MUMMA: No. He hoped she converted our
12 assets.
13 THE COURT: I will look at the record and see
14 if it implies that.
15 MR. MUMMA: You have to read the record about
16 -- the dialogue about the books of Kim Company and
17 Pennsylvania Supply Company, the way they cheated us from
18 the liquidation by reversing course. They didn't follow the
19 agreement. And when I get into that -- well, their position
20 was they will do whatever they can to convert our assets to
21 estate assets. He says, I hope they did.
22 THE COURT: We will see if the record
23 supports that interpretation.
24 MR. MUMMA: Well, that is why I would like to
25 ask him what it was -- I think I should have a right to do
18
1 that. If you are going to decide what he meant, why
2 shouldn't I be able to ask him?
3 THE COURT: Your objection is preserved.
4 Ms. Mumma, was there anything that you wanted to present?
5 MS. MUMMA: Yes, there is.
6 THE COURT: Okay.
7 Whereupon,
8 BARBARA MANN MUMMA
9 having been duly sworn, testified as follows:
10 BY THE COURT:
11 Q Would you state your name, please?
12 A Barbara Mann Mumma.
13 Q And you live at 541 Bridgeview Drive,
14 Lemoyne, Pennsylvania?
15 A I do.
16 Q Okay. Did Mr. Jacobs represent you
17 previously?
18 A He did.
19 Q He did, but he is no longer in the case?
20 A No.
21 THE COURT: Okay.
22 MR. GREEN: Your Honor, I guess -- I don't
23 know whether it is quite an objection, but Ms. Mumma has
24 not, to my know ledge, filed a statement as to whether she is
25 opposing or supporting the motion, and, therefore, I am not
19