HomeMy WebLinkAbout01-11-11r
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IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PV ~ t~ ~ ~
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In re: ) Orphans Court Division ~ '~ ~ ~ "-'•~
Estate of Robert M. M ~C^~ ~ ~' ~ `~'
umma, ) Number 21-86-398 --~ ~'' ~ =_~=. c-3
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Deceased ~ ~ N ~~ ~'
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RESPONSE BY BARBARA M. MUMMA TO ~ ~~'~
MOTION FOR PROTE~ORDER FILE~B~OF~SA ORGAN
On Friday, January 7, 2011, I received a copy of a Motion for Protectivle ~tder filed by
Attorney Faller on behalf of Lisa Morgan, requesting that this Court enter an order c,~anceling her
deposition scheduled for January 13, 2011 noticed by Maurice R. Mitts, Esquireb ipnsel for my
brother, Robert M. Mumma, II. I submit this response to express my position wlitl~ regard to the
deposition.
I have no objection to moving the date of the deposition to accommodate I~i~a's schedule.
However, I r~~pec fiilltfi y submit that the deposition should take place in Pennsyl~a~ and it cer-
tainly should take place prior to the resumption of the hearings before Mr. Buckley. ~I,
In addition, in the event that Attorney Mitts believes that Lisa's depositioh ~hpuld be tak-
en before the hearing on my brother's motion to disqualify Lisa as an executrix ' I 'light of the
changed conditions in this matter, I would think it appropriate to permit Lisa's d s~tion to take
place before the hearing on Bob's motion currently scheduled for January 28, 2011.
Respectfully submitted,
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Dated: January 11, 2011
Barbara M. Mumma
541 Bridgeview Drive
Lemoyne, PA 17043
717-730-2188
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Cerbificxte of Service
I hereby certify that the Response By Barbara M. Mumma To Motion for Furtive Order filed
on behalf of Lisa M. Morgan was served this date by first-class mail, postage pte~a~d, addressed
as follows: ~,I
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 '~
Manson Deardorff Williams Otto Gilroy & Faller
Martson Law Offices ~
10 East High Street ~
Carlisle, PA 17013 ~~,
I
Brady L. Green, Esquire '
Morgan, Lewis 8t Bockius LLP 'i
1701 Market Street ~,
Philadelphia, PA 19103-2921 ~'I
Maurice R. Mitts, Esquire ~'~~
Mitts Milavec, LLC ~~
Two Logan Square, 12a' Floor ~!,
Eighteenth ~ Arch Streets '~,
Philadelphia, PA 19143
Ms. Linda M. Mumma ~
212 North Duke Street II
Durham, NC 27701 ',
Dated: January 11, 2011
s
Barbara M. Mumma ~ ~ '
S41 Bridgeview Drivle ~~,
Lemoyne, PA 17043
-2-
ORPHANS' COURT DIVISION
COURT OF COMMON PLEAS OF
In Re: ROBERT M MUMMA, DECEASED CUMBERLAND COUNTY
PENNSYLVANIA
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N0.21-86-0398 ~,
CERTIFICATE OF SERVICE OF ORDER
ORDER DATE: O 1- ll -11
JUDGE'S INITIALS:
TIME STAMP DATE: O 1-11-11
IN RE: RESPONSE BY BARBARA M MUMMA TO MOTION FOR PROTECTI~
SERVICE TO: JOSEPH D BUCKLEY
METHOD OF MAILING:
® USPS
^ RRR
^ HAND DELIVERED
^ OTHER
MAILED: O 1-11-11
ENVELOPES PROVIDED BY:
^ PETITIONER
^ JUDGE
® CLERK OF ORPHANS COUR'ir
SERVICE TO:
METHOD OF MAILING:
^ USPS
^ RRR
^ HAND DELIVERED
^ OTHER
MAILED:
ENVELOPES PROVIDED BY: ~'
^ PETITIONER
^ JUDGE
^ CLERK OF ORPHANS COURT
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Clerk of Orphans' Court