HomeMy WebLinkAbout11-04-13 Robert B. Eyre, Esquire Attorneys for Robert M. Mumr�;, II
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IN THE COURT OF COMMON PLEAS OF CUMBERLAND
COUNTY, PENNSYLVANIA
I� re: ESTATE OF ROBERT M. .
MUMMA, Deceased. : ORPHANS' COURT DIVISION
: No. 21-86-398
SUPPLEMENTAL STATEMENT ON MOTION ON BEHALF OF
ROBERT M. MUMMA, II TO ADJOURN DATES FOR
BRIEFING AND ARGUMENT OF
OBJECTIONS TO AUDITOR'S REPORT
Robert B. Eyre, Esquire Robert B. Eyre, Esquire, as counsel for Robert M.
Mumma, II, ("Mr. Mumma"), hereby supplements the Motion on Behalf of Robert M.
Mumma, II to Adjourn Dates for Briefing and Argument of Objections to the Auditor's
Report("Motion") as follows:
l. Petitioner filed the Motion in the above matter on October 30, 2013.
2. Petitioner was advised to supplement the Motion and contemporaneous
Petition of Robert B. Eyre, Esquire and Foehl & Eyre, P.C. to Withdraw as Counsel
("Petition for Withdrawal") with a statement concerning the position of the other parties
on same.
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3. Via email sent yesterday to the parties or their counsel, the undersigned
has requested the position of the other parties with respect to the Motion, and can advise
the Court of the following:
a. Lisa Morgan, through counsel, has filed a written response to the Motion,
that the undersigned interprets as follows: Lisa Morgan objects to any
delay in the proceedings.
b. Counsel for Barbara Mumma, Richard Rinaldo, Esquire, has advised that
he "consent[s] to the adjournment of the briefing and argument of the
objections in order to give Mr. Mumma a reasonable opportunity to either
engage other counsel or to file a brief pro se."
c. The undersigned has no reply to his email from Linda Mumma and has
not been able to find a telephone number for her, so cannot report her
position on the matter.
4. The undersigned is filing a separate Supplemental Statement concerning
the position of the other parties on the contemporaneous Petition for Withdrawal. Since
the objection of Lisa Morgan to the Motion refers to the Petition for Withdraw, the
undersigned desires to comment briefly on the relationship of the two.
5. While the circumstances behind Petitioner's request to withdraw as
counsel are relevant, even compelling reasons for the request for adjournment of the
briefing and argument of the Objections to the Auditor's Report, the Motion to Adjourn
is supported by additional cause: the difficulty of the undersigned, given the magnitude of
the task, his workload and limited staffing, to complete the project, and Mr. Mumma's
report that he is unavailable on and after today for medical reasons.
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6. It is important to resolve the Objections to the Auditor's Report and move
the administration of this Estate forward toward conclusion. But given the time it has
taken to get to this climactic point, and the obvious importance of Mr. Mumma's full
participation in the adjudication of his Objections, it is respectfully submitted that
allowing some additional time for Mr. Mumma to do so is not only fair and equitable, but
best for the procedural and substantive integrity of the final adjud' tion.
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Dated: October 31, 2013
Robert yre, Esquire
Foehl Eyre, P.C.
27 East Front Street
Media, PA 19063
610-566-5926
Attorneys for Robert M. Mumma, II
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CERTIFICATE AND PROOF OF SERVICE
I hereby certify that a true and correct copy of the foregoing Supplemental Statement has
been served by first-class United States mail, postage prepaid, and via email, this 31 St day
of October, 2013, on the following:
Ivo 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
31 St Floor
1818 Market Street
Philadelphia, PA 19103
Richard F. Rinaldo
Williams Coulson, LLC
16�' Floor, One Gateway Center
Pittsburgh, PA 15222
Ms. Linda M. Mumma,
P.O. Box 30436
Bethesda, MD 20824
Robert M. Mumma, II
Box F
Grantham, PA 17027
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Ro ert B yre
Cou for Robert M. Mumma, II
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