HomeMy WebLinkAbout08-18-10~J
IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYL-
VANIA
In re: ) Orphans Court Division ` ~ ~ ~ r -~,
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Estate of Robert M. Mumma, ) Number 21-86-398 -=,-'T'-.7 c~ `.~
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Deceased ) ~ ='
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UNOPPOSED MOTION TO EXTEND TIME ~'
FOR FILING POST-HEARING BRIEFS
As suggested by Mr. Buckley following our recent communications with him, I am
filing this Unopposed Motion to Extend Time for Filing Post-Hearing Briefs. The reasons
for filing this motion are stated below:
1. On July 17, 2010, our mother, Barbara McK. Mumma, passed away unex
pectedly. She was one of the two executrixes of our father's estate.
2. Before our mother's death, at the request of Mr. Buckley, a number of us
were beginning to discuss whether there might be a way to resolve and settle this matter
without further litigation.
3. Our mother's death made it both difficult and inappropriate for several
weeks to communicate with others involved in this proceeding on any subject, much less
the issues which have divided our family for so many years.
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4. On August 3, 2010, I communicated with Mr. Buckley and the others involved in
this matter and requested, in light of the circumstances, an extension of time to file the post-
hearing briefs which he has requested. The briefs aze currently due for filing on September
7, 2010.
5. In my a-mail to Mr. Buckley, I explained that our mother's unexpected
passing has been difficult for all of us, and that her death clearly constitutes a major change
in the circumstances and the environment of this proceeding. I also explained that, as a
non-lawyer, I was not sure that I understand the implications and the ramifications of
mom's death while this proceeding remains pending, and I am seeking advice on that
matter.
6. I also indicated to Mr. Buckley that these changed circumstances, as sad as
they are, might result in an increased possibility that everyone involved might realize that it
may be a positive thing for all of us if we can resolve our differences and go forward with a
fresh start. Since my e-mail to Mr. Buckley, I have already seen indications that others
may shaze this sentiment. A 30 day extension of time will give us an opportunity to make a
good faith effort to explore settlement of this matter.
7. In response to my a-mail requesting an extension of time, I have received responses
advising me that no one opposes my request fora 30 day extension of time for the filing of
briefs, and Mr. Buckley suggested that the appropriate way to make such a request is to file
this unopposed motion with a proposed order of court. Accordingly, I hereby request that
the time for filing post-hearing briefs be extended for thirty days until October 8, 2010, and
a proposed order of court is attached.
Respectfully submitted,
717.
Dated: August 18, 2010 Barbara M. Mumma
541 Bridgeview Drive
Lemoyne, PA 17043
717-730-2188
Certificate of Service
I hereby certify that the foregoing Unopposed Motion to Extend Time for Filing Post-Hear-
ing Briefs was served this date by first-class mail, postage prepaid, addressed as follows:
Joseph D. Buckley, Esquire
1237 Holly Pike
Carlisle, PA 17013
(Court Appointed Arbitrator)
No V. Otto, II, Esquire
George B. Faller, Jr., Esquire
Jennifer L. Spears, Esquire
Martson Deardorff Williams Otto Gilroy & Faller
Martson Law Offices
10 East High Street
Carlisle, PA 17013
Brady L. Green, Esquire
Morgan, Lewis & Bockius LLP
1701 Market Street
Philadelphia, PA 19103-2921
Robert M. Mumma, II
840 Market Street, Suite 164
Lemoyne, PA 17043
Ms. Linda M. Mumma
512 Creekview Lane
Mechanicsburg, PA 17055
Dated: August 18, 2010
Barbara M. Mumma
541 Bridgeview Drive
Lemoyne, PA 17043