HomeMy WebLinkAbout04-19-11IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PE]~~,YI,VAAA ~r ~°
77 _ :J
-c-t --- C7 ~ ~;
''°_>i
IN RE: ) ORPHANS' COURT DIVIS`~ ~
MARITAL TRUST UNDER WILL ) ^' `-' -'-' "" " ' '
OF ROBERT M. MUMMA, ) Number 21-86-0398 ~ ~ ~~ -- rT~'
~.~~ c~
Deceased ~' `~ "-~
c_
RESPONSE OF BARBARA M. NhUMMA
TO EMERGENCY MOTION OF LISA MORGAN FOR DISCOVERY SANCTIONS
This response is filed to the Emergency Motion filed by Lisa Morgan on Friday afternoon, April
15, 2011 for discovery sanctions relating to the proposed testimony of Hartford Kittel or Joseph
Wilson at the upcoming hearings in this matter scheduled for the first week of May.
On Monday afternoon, Apri118, 2011, we all participated in a conference call with
Auditor Buckley at which this subject was discussed and resolved. If Mr. Kittel, a questioned
document examiner, is able to reach a conclusion as to certain signatures, he will provide me
with a report and I will distribute it to Mr. Otto, Mr. Green and my brother on Friday or, at the
latest, no later than Monday morning (I do not think that during the conference call anyone
focused on the fact that this Friday is actually Good Friday). The same is true for Mr. Wilson
concerning a report. Mr. Otto was actually in Mr. Buckley's office during the conference call.
and participated in the conference, and he expressed no objections to this schedule. Brady Green
also seemed satisfied with this schedule. Thus it would not seem that the court would need to
rule on the Emergency Motion in these circumstances.
Respectfully submitted,
Dated: a2~s~~ i9 , 2011 ~1_
Bazbaza M. Mumma
Certificate of Service
I hereby certify that the Response of Barbara Mumma to the Emergency Motion was served this
date by a-mail to No V. Otto, II, Jennifer L. Spears, Auditor Buckley, Brady Green and Robert
M. Mumma, II and by United States first-class mail, postage prepaid, addressed as follows:
No V. Otto, II, Esquire
Martson Deardorff Williams Otto Gilroy & Faller
Martson Law Offices
10 East High Street
Carlisle, PA 17013
Dated: April 19, 2011 ~ ~, ~~
Barbara M. Mumma
541 Bridgeview Drive
Lemoyne, PA 17043