HomeMy WebLinkAbout08-14-13 Robert B. Eyre, Esquire Attorneys for Robert M. Mumma, II
I.D. No. 41990 0
Foehl & Eyre, P.C. -RZ
27 East Front Street � , ? o
Media, PA 19063
610-566-5926 = :
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IN THE COURT OF COMMON PLEAS OF CUMBERLAND 3
COUNTY, PENNSYLVANIA
In re: ESTATE OF ROBERT M. .
MUMMA, Deceased. : ORPHANS' COURT DIVISION
No. 21-86-398
MOTION OF ROBMERT M. MUMMA II FOR EXTENSION OF
TIME TO FILE OBJECTIONS TO AUGUST 7 2013 REPORT OF
AUDITOR JOSEPH D. BUCKLEY, ESQUIRE
Robert M. Mumma, II, ("Movant") by and through his undersigned
counsel, hereby moves for an extension of the time to file exceptions or
otherwise respond to the August 7, 2013 Report of Auditor Joseph D.
Buckley, Esquire (the "Auditor's Report"), and in support thereof alleges the
following:
1. Movant is a beneficiary under the Will of the Decedent, his
father, Robert M. Mumma, and filed objections to the Accounts that are the
subject of the Auditor's Report.
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2. The Auditor requested, and was granted, numerous extensions,
resulting in years of cumulative extensions of the presumptive 90 day time
frame prescribed by Supreme Court Orphans' Court Rule ("O.C.R.") 8.2 for
filing of an auditor's report.
3. The Auditor's Report is 127 pages long, covers fourteen
Accounts dating back to 1986 and recommends 478 findings of after 41 days
of hearings, the last of which was completed over two years ago (June 2011)
and most of which occurred three to four years ago.
4. The undersigned has represented Movant only for the last year,
and was only tangentially involved in the Estate matters until May of this
year.
5. The twenty (20) days allowed by Local Orphans' Court Rule
Rule 8.7-2 for objections to an auditor's report is insufficient time to digest,
evaluate and respond to the Auditor's Report in this case.
6. Pursuant to O.C.R. 2.2, this Court may, upon its own motion or
the motion of any party, extend the time for objections to the Auditor's
Report.
7. Movant and his counsel believe that an extension of 55 days—
to October 14, 2013—bringing the total time period for objections or other
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' response to the Auditor's Report to 75 days, is necessary and appropriate for
Movant and his counsel to evaluate and respond to the Auditor's Report.
WHEREFORE, Movant requests this Court enter an order in the form
submitted with this Motion, extending the time to object to the Auditor's
Report to October 14, 2013.
Dated: August 14, 2013
Robert B. Esquire
Foehl & re, P.C.
27 East Front Street
Media, PA 19063
610-566-5926
Attorneys for Robert M. Mumma, 11
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IN THE COURT OF COMMON PLEAS OF CUMBERLAND
COUNTY, PENNSYLVANIA
In re: ESTATE OF ROBERT M. .
MUMMA, Deceased. : ORPHANS' COURT DIVISION
No. 21-86-398
CERTIFICATE AND PROOF OF SERVICE
I hereby certify that a true and correct copy of the foregoing Motion has
been served pursuant to Pa. R.A.P. 906(a) by first-class United States mail,
postage prepaid, this 14'h day of August, 2013, on the following:
Hon. J. Wesley Oler, Jr.,
Senior Judge
Court of Common Pleas of Cumberland County
One Courthouse Square
Carlisle, PA 17013
(via hand delivery)
Amy R. Fritz, Court Reporter
Central Pennsylvania Court Reporting Services
P.O. Box 508
Carlisle, PA 17013
Joseph D. Buckley, Esquire
1237 Holly Pike
Carlisle, PA 17013
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f (Certificate of service continued)
No V. Otto, IV, Esquire
George B. Faller, Esquire
Jennifer L. Spears, Esquire
Martson Law Offices
10 East High Street
Carlisle, PA 17013
Brady L. Green, Esquire
Wilbraham Lawler & Buba
3151 Floor
1818 Market Street
Philadelphia, PA 19103
Richard F. Rinaldo
Williams Coulson, LLC
16th Floor, One Gateway Center
Pittsburgh, PA 15222
Ms. Linda M. Mumma,
P.O. Box 30436
Bethesda, MD 20824
Robert B yre
Cou for Robert M. Mumma, II
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