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HomeMy WebLinkAbout13-7096 Supreme Cottff6f`PennSylvania Court 'O .C For Prothonotary Use Only: Civil: COVe1" :S E1 6t Docket NO: CV& e u � ;`' " County — jig. Ul G 13 The informaliatl collected on this form is used solely for court adrninist7 pinposes. This form does not suppletnent or replace the filing and service of pleadings or other papers as required by Imv or roles of court. Commencement of Action: © Complaint TK Writ of Summons ❑ Petition S_ ❑ Transfer from Another Jurisdiction ❑ Declaration of Taking Lead Plaintiff's Name: Lead Defendant's Name: C- '.T :. Dollar Amount Requested: ❑within arbitration limits Are money damages requested? ;Yes ❑ No (check one) ,outside arbitration limits O, Is this a Class Action Suit? El Yes No Is this an MDIAppeal? ❑ Yes No Name of Plaintiff /Appellant's Attorney: Clieck here if you have no attorney.(are a Self- Represented [Pro Sel Litigant) _ A Nature of the Case Place an "X" to the :left of the ONE case category that most accurately describes your - P.RI11L4RY CASE. If you are making more than one type of claim, check the one thaf you consider most. important. TORT (do not include Klass Tort) CONTRACT (do not include Judgments) CIVIL APPEALS AN ❑ Buyer Plaintiff Administrative Agencies ❑ Malicious Prosecution ❑ Debt Collection: Credit Card Board of Assessment M. Motor Vehicle ❑ Debt Collection: Other ❑Board of Elections Nuisance F-1 Dept. of Transportation Premises Liability ❑ Statutory Appeal: Other Product Liability (does not include El Employment Dispute: mass tort) Discrimination = ❑Slander /Libel/ Defamation ❑ Employment Dispute: Other ❑ Zonin Board Other: El Other:_ �:: ;: ❑ Other: MASS TORT ® ❑ Asbestos ❑ Tobacco rl Toxic Tort - DES ❑ Toxic Tort - Implant REAL PROPERTY MISCELLAI�TEOUS Toxic Waste ❑ Ejectment ❑ Common Law /Statutory Arbitration Other: ❑ Eminent Domain /Condemnation ❑ Declaratory Judgment Ground Rent ❑ Mandamus El Landlord /Tenant Dispute ❑ Non - Domestic Relations Mortgage Foreclosure: Residential Restraining Order PROFESSIONAL LIABLITY ❑ Mortgage Foreclosure: Commercial ❑ Quo Warranto ❑ Dental ❑ Partition Replevin ❑ Legal F] Quiet Title © Other: Medical ❑ Other: ❑ Other Professional: Updated 11112011 IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL DIVISION Plaintiffs & Address es) Robert M. Mumma, If 6880 S E Harbor Circle Stuart Florida 34996 Case No. 13 Q Civil Term VS. Civil Action Defendant(s) & Address(es) Jeffrey G Brooks, No Otto III, Richard F : Rinaldo, Joseph D Buckley, Brady Green. Morgan Lewis and Bockius, Marston Law group, Minto Law Group, Williams C-_ t^ni ilcnn r?t al rn'Z K .Z PRAECIPE FOR WRIT OF SUMMONS :t�- __j t TO THE PROTHONOTARY /CLERK OF SAID COURT: :2- 5 Issue summons in the above case" y' Writ of Summons shall be issued and forwarded to Att Sheriff. lease Circle choice December 2, 2013 - Date : RO r t'1t� f Auttre I I Print Name: p se Box F Address: G rantham, PA 17027 Telephone #: 717 448 1127 Supreme Court ID Number: /�__ � a! , C..T W, �RIIT OF SUMMONS TO: l e e lh c h C YOU ARE NOTIFIED THAT THE ABOVE -NAMED PLAINTIFF(S) !� S�/HAVE COMMENCED AN ACTION AGAINST YOU. +� Prothonotary/Clerk, Civil Division Date: qy__�� D � eputy Defendants Addresses Jeffery G Brooks and Minto Law Group Two Gateway Center 603 Stanwix St, Suite 2025 Pittsburgh, PA 15222 No V Otto, III and Marston Law Group 10 East Hight Street Carlisle, PA 17013 Richard F. Rinaldo One Gateway Center, 16th Floor Pittsburgh, PA 15222 Joseph D. Buckley 1237 Holly Pike Carlisle, PA 17013 Brady Green Wilbraham Lawler & Buba 31St Floor 1818 Market Street Philadelphia, PA 19103 Morgan Lewis and Bockius 17 N Second Street, 14th Floor Harrisburg, PA 17101 VERIFICATION I, Robert M. Mumma, II , verify that the statements made in the foregoing PRAECIPE FOR WRIT OF SUMMONS are true and correct to the best of my knowledge, information and belief. I understand that false statements herein are made subject to the penalties of 18 Pa. Cons. Stat. Ann. Sec. 4904 relating to unsworn falsification to authorities. Date: Robert M. Mumma, II F:\FILES\C1ients\5844 Mumma Estate\5844.35.ML0\5844.35.praecipe.wpd i Revised: 1216/13 1 39P George B. Faller, Jr., Esquire F;L E D-0 F I MARTSON LAW OFFICES 01 THE PR0THON0T,`-'; ` I.D. 49813 10 East High Street 2513 DEC —6 PM 2: lye Carlisle, PA 17013 (717) 243-3341 CUMBERLAND COUI � Attorneys for Defendants N All Otto III and P E P#P S Y L 4'A I A Martson Law Offices incorrectly captioned Ly nN as Marston Law Group ROBERT M. MUMMA II IN THE COURT OF COMMON PLEAS OF Plaintiff CUMBERLAND COUNTY, PENNSYLVANIA V. NO. 2013-7096 CIVIL ACTION - LAW JEFFREY G. BROOKS, IVO OTTO III, RICHARD F. RINALDO, JOSEPH D. BUCKLEY, BRADY GREEN, MORGAN LEWIS AND BOCKIUS, MARSTON LAW GROUP, MINTO LAW GROUP, WILLIAMS COULSON ET AL, Defendants PRAECIPE TO THE PROTHONOTARY OF CUMBERLAND COUNTY: Enter the appearance of MARTSON LAW OFFICES on behalf of Defendants No Otto III, and Martson Law Offices, incorrectly captioned as Marston Law Group, in the above matter and issue a rule upon the Plaintiff to file a Complaint within twenty (20) days from service thereof or suffer judgment of non pros. MART ON LAW OFFICES By George Faller, Jr., Es ire I.D. No. 49813 10 East High Street Carlisle, PA 17013 (717) 243-3341 Dated: December 6, 2013 Attorneys for Defendant RULE AND NOW, this (i day of December, 2013, a Rule is issued upon the Plaintiff to file a Complaint within twenty (20) days from service hereof. Prothonotary �P CERTIFICATE OF SERVICE I, Tricia D. Eckenroad, an authorized agent for Martson Law Offices, hereby certify that a copy of the foregoing Praecipe was served this date by depositing same in the Post Office at Carlisle, PA, first class mail, postage prepaid, addressed as follows: Mr. Robert M. Mumma II Box F Grantham, PA 17027 Mr. Robert M. Mumma, II 6880 S E Harbor Circle Stuart, FL 34996 Jeffrey G. Brooks, Esquire Minto Law Group Two Gateway Center 603 Stanwix Street, Suite 2025 Pittsburgh, PA 15222 Richard F. Rinaldo, Esquire Williams Coulson Johnson Lloyd Parker& Tedesco, LLC One Gateway Center, 16"Floor Pittsburgh, PA 15222 Joseph D. Buckley, Esquire 1237 Holly Pike Carlisle, PA 17013 Brady L. Green, Esquire Wilbraham Lawler& Buba 1818 Market Street, 31St Floor Philadelphia, PA 19103 Morgan Lewis &Bockius 17 North Second Street, 14th Floor Harrisburg, PA 17101 MARTSON LAW,OFFICES,, 4 By ,` Trici6 D. Ecke oad Ten East High treet Carlisle, PA 17013 (717) 243-3341 Dated: December 6, 2013 Robert M. Mumma, II Box F $ Ft\ S;: .? . oc Grantham, PA 17027 717 448 1127 rose EF SYL\INW rk P PEA IN RE: Robert M. Mumma, II : In the Court of Common Pleas of : Cumberland County, Pennsylvania vs :No. 2013-7096 Jeffrey Brooks (et al) PETITION TO EXTEND TIME TO FILE COMPLAINT Petitioner Robert M. Mumma, II requests a sixty day extension of time to file a complaint in this matter. The time is necessary to conduct Discovery as permitted under Rule 4003.8 . This matter regards the surrender of two million dollars of life insurance policies on the Petitioner's life. The defendants were participants in a conference where it was decided to surrender this insurance without any notice to the Petitioner. Only portions of the conference were recorded. Petitioner seeks to determine the matters considered at the conference and in particular whether the actual policies were available for inspection, review and discussion. Petitioner seeks to determine if any agreements, documents or other authority resulted from this conference. Petitioner seeks to clarify these issues before filing a complaint to avoid needless confusion as to the role of the individual defendants and their understanding as to what the their intentions were and the positions they conveyed to the Auditor.This discovery is required because the transcript is not complete and has been challenged as being inaccurate by some of the participants. WHEREFOR Petitioner request an additional sixty days for discovery and preparation of the complaint. Respectfully Submitted, . � )11i , Robert M. Mumma, II pro se December 17, 2013 VERIFICATION I, Robert M. Mumma, II ,verify that the statements made in the foregoing Petition to Extend Time for Filing a Complaint are true and correct to the best of my knowledge, information and belief. I understand that false statements herein are made subject to the penalties of 18 Pa. Cons. Stat.Ann. Sec. 4904 relating to unsworn falsification to authorities. Date: /07/i3 _4,1444A.AAA-Car Robert M. Mumma, II CERTIFICATE OF SERVICE I, Robert M. Mumma, II, hereby certify that a copy of the foregoing Petition to Extend Time to File a Complaint was served on this date, first class mail, postage prepaid, to the following: Jeffrey G. Brooks, Esquire and Richard F. Rinaldo, Esquire Minto Law Group, LLC Williams Coulson Johnson Lloyd Two Gateway Center Parker& Tedesco, LLC 603 Stanwix Street, Suite 2025 One Gateway Center, 16th Floor Pittsburgh, PA 15222 Pittsburgh, PA 15222 Brady Green Joseph D. Buckley, Esquire Wilbraham Lawler and Buba 1237 Holly Pike 1818 Market St, 31st Floor Carlisle, PA 17013 Philadelphia, PA 19103 No V. Otto, III, Esquire Martson Law Offices Morgan Lewis & Bockius 10 East High Street 17 N. Second Street, 14th Floor Carlisle, PA 17013 Harrisburg, PA 17101 A ROBERT M. MUMMA, II DATE: gr.. / C O/ 672149 No. 13-7096 ._,3D C 23 E L 'EHSYLV11 ; IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA ROBERT M. MUMMA, II, CIVIL DIVISION Plaintiff, No. 13-7096 v. JEFFREY G. BROOKS, et al., PRAECIPE FOR ENTRY OF APPEARANCE Defendants. Filed on Behalf of• Defendants Richard F. Rinaldo and Williams Coulson Johnson Lloyd Parker & Tedesco, LLC Counsel of Record for these Parties: Richard F. Rinaldo, Esquire Pa. I.D. No. 33222 Williams Coulson Johnson Lloyd Parker & Tedesco, LLC One Gateway Center, 16th Floor Pittsburgh, PA 15222 (412) 454-0200 672149 No. 13-7096 w- Vr IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA ROBERT M. MUMMA, II, CIVIL DIVISION Plaintiff, No. 13-7096 v. JEFFREY G. BROOKS, et al., Defendants. PRAECIPE FOR ENTRY OF APPEARANCE To: David D. Buell, Prothonotary/Clerk, Civil Division Please enter our appearance in the above-captioned civil action on behalf of Defendants Richard F. Rinaldo and Williams Coulson Johnson Parker Lloyd & Tedesco, LLC. WILLIAMS COULSON JOHNSON LLOYD PARKER & TEDESCO, LLC By: ,/ ,G Richard F. Rinaldo Dated: December 18, 2013 Attorneys for Defendants 672149 No. 13-7096 wr CERTIFICATE OF SERVICE I hereby certify that a true and correct copy of the foregoing Praecipe for Entry of Appearance was served by first-class United States mail, postage prepaid, this 18th day of December, 2013 to the following: Robert M. Mumma, II Robert M. Mumma, II 6880 S.E. Harbor Circle Box F Stuart, Florida 34996 Grantham, PA 17027 George B. Faller, Jr., Esquire Martson Law Offices 10 East High Street Carlisle, PA 17013 Jeffrey G. Brooks, Esquire Minto Law Group Suite 2025, Two Gateway Center 603 Stanwix Street Pittsburgh, PA 15222 Brady L. Green, Esquire Wilbraham Lawler & Buba 31st Floor, 1818 Market Street Philadelphia, PA 19103 Morgan, Lewis & Bockius 14th Floor, 17 North Second Street Harrisburg, PA 17101 Richard F. Rinaldo Counsel for Defendants - 2 - 672149 No. 13-7096 214 JU _S 1111 10: 41 t1'PE ttNSYLDAIUNTY A IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA ROBERT M. MUMMA, II, CIVIL DIVISION Plaintiff, No. 13-7096 v. JEFFREY G. BROOKS, et al., OPPOSITION TO PLAINTIFF'S PETITION TO EXTEND TIME TO Defendants. FILE COMPLAINT Filed on Behalf of: Defendants Richard F. Rinaldo and Williams Coulson Johnson Lloyd Parker & Tedesco, LLC Counsel of Record for these Parties: Richard F. Rinaldo, Esquire Pa. I.D. No. 33222 Williams Coulson Johnson Lloyd Parker & Tedesco, LLC One Gateway Center, 16th Floor Pittsburgh, PA 15222 (412) 454-0200 672149 No. 13-7096 IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA ROBERT M. MUMMA, II, CIVIL DIVISION Plaintiff, No. 13-7096 v. JEFFREY G. BROOKS, et al., Defendants. OPPOSITION TO PLAINTIFF'S PETITION TO EXTEND TIME TO FILE COMPLAINT Defendants Richard F. Rinaldo and Williams Coulson Johnson Lloyd Parker & Tedesco, LLC ("Williams Coulson") hereby object to the Petition to Extend Time to File Complaint which was filed on December 18, 2013 by Plaintiff, Robert M. Mumma II, acting pro se. Defendants Rinaldo and Williams Coulson respect- fully state as follows: 1. Plaintiff, Robert M. Mumma II ("Robert Mumma") commenced this civil action by the filing of a Praecipe for Writ of Summons on December 2, 2013. By commencing this civil action, Robert Mumma seeks to embark upon yet anoth- er chapter in his lengthy litigious career as a pro se litigant in this court by suing the Auditor appointed by this Court, by suing lawyers and law firms who never represented Mr. Mumma at all, but who have represented other parties in proceed- 672149 No. 13-7096 ings before this Court, and, sadly, by suing one of his own lawyers and law firm who attempted to provide legal advice and representation to Mr. Mumma. When faced with a Rule to File Complaint, Mr. Mumma's response has been to file a dis- ingenuous one-page petition for a 60 day extension, during which time Mr. Mum- ma implies that he will burden five law firms and four individual lawyers with pro se discovery filings, including Joseph D. Buckley, Esquire, an auditor appointed by this Court. Defendants Rinaldo and Williams Coulson, who have never represent- ed Mr. Mumma at any time or for any purpose, respectfully request that this Court deny Mr. Mumma's petition to extend time and order him to file a complaint or to suffer a judgment of non pros pursuant to Pa. R.C.P. 1037(a). 2. The various named Defendants in this civil action are Jeffrey G. Brooks, Esquire, Minto Law Group, No Otto III, Esquire, Martson Law Group, Richard F. Rinaldo, Esquire, Williams Coulson Johnson Lloyd Parker & Tedesco, LLC (identified as "Williams Coulson et al" in the Praecipe), Brady Green, Es- quire, Morgan Lewis & Bockius, and Joseph D. Buckley, Esquire. Except for At- torney Brooks and Minto Law Group, who represented Robert Mumma for a peri- od of time, none of the Defendants represents Robert Mumma. 3. On December 6, 2013, a Rule was issued on Plaintiff Robert Mumma to file a Complaint within 20 days of service upon him. - 2 - 672149 No. 13-7096 4. On December 18, 2013, Plaintiff Robert Mumma apparently filed a Petition to Extend Time to File Complaint, which thereafter has been served on the Defendants. Defendants Rinaldo and Williams Coulson subsequently received a copy of the petition during the holidays. 5. The one-page Petition, which consists of three paragraphs, reveals that Mr. Mumma's allegations in this, his latest lawsuit, apparently arose from a con- ference conducted by Auditor Buckley in an Orphans' Court Matter which has been pending in the Court of Common Pleas of Cumberland County, Orphans' Court Division since 1986, In re Estate of Robert M Mumma, Deceased, Case No. 21-86-398, and which remains pending before Senior Judge Oler. The Petition does not identify the Orphans' Court matter or docket number, but references a "conference" and the "Auditor," without explanation. 6. From these references and the use in the Petition of the term "Audi- tor" it is reasonable to assume that Robert Mumma is referencing Auditor James Buckley, the auditor appointed by Judge Oler to oversee the Orphans' Court mat- ter, and whom Robert Mumma has now sued in this case and who now has become a Defendant. The other named Defendants include Jeffrey G. Brooks, Esquire and his law firm, which represented Robert Mumma in the Orphans' Court proceeding for a time, but whose petition to withdraw was filed December 14, 2012 (Docket No. 689) and which was granted by Order of Court dated March 14, 2013 (Docket - 3 - 672149 No. 13-7096 No. 702) without objection or response by Robert Mumma. The remaining De- fendants are all attorneys and law firms who have never represented Robert Mum- ma in the Orphans' Court litigation but who have entered appearances and have represented and continue to represent other parties in the litigation. 7. It appears from the second paragraph of the Petition that Robert Mumma seeks to revisit a conference held during 2012 which resulted in an Order of Court entered July 30, 2012 (Docket Nos. 682-684) by Senior Judge Oler. 8. Plaintiffs Robert Mumma now seeks 60 days in which he purportedly will conduct pre-complaint discovery pursuant to Pa. R.C.P. 4003.8. Mr. Mumma has not identified the discovery he proposes to seek, but any such discovery is like- ly to violate Pa. R.C.P. 4003.8(a) by causing "unreasonable annoyance, embar- rassment, oppression, burden and expense" to a multitude of individuals and law firms, including but not limited to James Buckley, the auditor appointed by this Court to oversee the Orphans' Court matter. There is no doubt whatsoever that, in the event that Robert Mumma actually serves such discovery, there will be a large number of motions for protective orders and objections filed to such discovery. See Pa. R.C.P. 4003.8(b). 9. From the second and third paragraphs of the Petition, it is fairly obvi- ous that Plaintiff Robert Mumma has a copy of the transcript of the conference he references. The petition for liquidation of assets filed on behalf of Lisa Morgan by - 4 - 672149 No. 13-7096 Defendants Otto and Martson Law Group and Defendants Green and Morgan, Lewis & Bockius which led to the conference before Auditor (now Defendant) Buckley is a matter of public record (Docket No. 661) as are the response in oppo- sition filed on behalf of Barbara M. Mumma (Docket No. 665) by Defendants Rinaldo and Williams Coulson and the response in opposition filed on behalf of Robert Mumma himself (Docket No. 666) by Defendants Brooks and Minto Law Group. The Replies to New Matter filed on behalf of Lisa Morgan are also matters of public record. See Docket Nos. 670, 671. The recommendation made by Audi- tor Buckley (Docket No. 681) which led to the Order entered by Senior Judge Oler (Docket Nos. 682-684) is also a matter of public record. In short, Robert Mumma has failed to demonstrate why any additional discovery, even construed liberally, is "necessary to the filing of the complaint." Pa. R.C.P. 4003.8(a). Instead, Robert Mumma now seeks to have this court validate his most recent attempt to require a variety of attorneys and law firms, including the court-appointed auditor himself, to respond to and expend time and effort to deal with yet another spurious set of absurd allegations and claims which has led both the Superior Court of Pennsylva- nia in In re Estate of Robert M Mumma, Deceased, 41 A.3d 41, 43 n.2 (Pa. Super. 2012) and this Court itself, per Oler, S. J., in In re Estate of Robert M Mumma, Deceased, No. 21-86-398, [August 30, 2013 Opinion Pursuant to Pa. R.A.P. 1925, p.1 n.2] to describe Robert Mumma as "litigious," adding that "[i]n addition to - 5 - 672149 No. 13-7096 numerous periods in which [Mr. Mumma] has proceeded pro se, he has variously been represented by at least 15 different attorneys." See id. 10. In short, there is no legitimate purpose to be served by permitting Robert Mumma to misuse the court system yet again to further his own quixotic fantasies about how he has been ill served by the judicial and legal community for the past quarter century. His petition to extend time to file complaint is meritless. WHEREFORE, Defendants Richard F. Rinaldo and Williams Coulson John- son Lloyd Parker & Tedesco, LLC, respectfully request that the Petition to Extend Time to File Complaint filed by Plaintiff Robert M. Mumma II be denied. WILLIAMS COULSON JOHNSON LLOYD PARKER& TEDESCO, LLC By: ichard F. Rinaldo Dated: January 6, 2014 Attorneys for Defendants Richard F. Rinaldo and Williams Coulson Johnson Lloyd Parker & Tedesco, LLC - 6 - 672149 No. 13-7096 IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA ROBERT M. MUMMA, II, CIVIL DIVISION Plaintiff, No. 13-7096 v. JEFFREY G. BROOKS, et al., Defendants. ORDER OF COURT And Now, this day of January, 2014, upon consideration of the Plain- tiff's Petition to Extend Time to File Complaint and the Opposition filed thereto, it hereby is ORDERED that said Petition is DENIED. Plaintiff is directed to file a complaint within ten (10) days of the date of this Order. BY THE COURT, , J. - 7 - 672149 No. 13-7096 CERTIFICATE OF SERVICE I hereby certify that a true and correct copy of the foregoing Opposition to Petition to Extend Time to File Complaint was served by first-class United States mail, postage prepaid, this 6th day of January, 2014 to the following: Robert M. Mumma, II Robert M. Mumma, II 6880 S.E. Harbor Circle Box F Stuart, Florida 34996 Grantham, PA 17027 Joseph D. Buckley, Esquire 1237 Holly Pike Carlisle, PA 17013 George B. Faller, Jr., Esquire Martson Law Offices 10 East High Street Carlisle, PA 17013 Jeffrey G. Brooks, Esquire Minto Law Group Suite 2025, Two Gateway Center 603 Stanwix Street Pittsburgh, PA 15222 Brady L. Green, Esquire Wilbraham Lawler & Buba 31St Floor, 1818 Market Street Philadelphia, PA 19103 Morgan, Lewis & Bockius 14th Floor, 17 North Second Street Harrisburg, PA 1710 • 'chard F. ' naldo - 8 - IN RE: : IN THE COURT OF COMMON PLEAS OF : CUMBERLAND COUNTY, PENNSYLVANIA ROBERT M. MUMMA, II, : • V. JEFFREY BROOKS, et al : NO. 2013 —7096 CIVIL TERM ORDER OF COURT AND NOW, this 15TH day of JANUARY, 2014, upon consideration of Plaintiffs Petition to Extend Time to File Complaint and the response thereto, it is GRANTED in part. Plaintiff shall file his complaint on or before February 7, 2014. By th>/'ourt, Edward E. Guido, J. Robert M. Mumma, II Box F Grantham, Pa. 17027 Jeffrey G. Brooks, Esquire Two Gateway Center - = 603 Stanwix Street, Suite 2025 Pittsburgh, Pa. 15222 ` ' -mm Xseph D. Buckley, Esquire 1237 Holly Pike Carlisle, Pa. 17013 Brady L. Green, Esquire 1701 Market Street Philadelphia, Pa. 19103 organ Lewis & Bockius 17 North Second Street, 14TH Floor Harrisburg, Pa. 17101 V. Otto, III, Esquire 10 East High Street Carlisle, Pa. 17013 chard F. Rinaldo, Esquire One Gateway Center, 16TH Floor Pittsburgh, Pa. 15222 :sld CC?Ce..4 /is/I SHERIFF'S OFFICE OF CUMBERLAND COUNTY Ronny R Anderson Sheriff ytrofCumber", Jody S Smith Chief Deputy e} ! 7 'P 2, Richard W Stewart Solicitor rw. . l = re �/if ` � � 3� ' 4aei al".w1 i �... ��k1 !i1 Robert M. Mumma, II vs. Case Number Jeffrey G Brooks (et al.) 2013-7096 SHERIFF'S RETURN OF SERVICE 12/05/2013 Sheriff Ronny R Anderson, being duly sworn according to law, states he made diligent search and inquiry for the within named Defendant to wit: Jeffrey G Brooks, but was unable to locate the Defendant in the Sheriffs bailiwick.The Sheriff therefore deputizes the Sheriff of Allegheny, Pennsylvania to serve the within Writ of Summons according to law. 12/05/2013 Sheriff Ronny R Anderson, being duly sworn according to law, states he made diligent search and inquiry for the within named Defendant to wit: Minto Law Group do Ralph Minto, but was unable to locate the Defendant in the Sheriffs bailiwick. The Sheriff therefore deputizes the Sheriff of Allegheny, Pennsylvania to serve the within Writ of Summons according to law. 12/05/2013 Sheriff Ronny R Anderson, being duly sworn according to law, states he made diligent search and inquiry for the within named Defendant to wit: Richard Rinaldo, but was unable to locate the Defendant in the Sheriffs bailiwick.The Sheriff therefore deputizes the Sheriff of Allegheny, Pennsylvania to serve the within Writ of Summons according to law. 12/05/2013 Sheriff Ronny R Anderson, being duly sworn according to law, states he made diligent search and inquiry for the within named Defendant to wit: Morgan Lewis and Bockius, but was unable to locate the Defendant in the Sheriffs bailiwick. The Sheriff therefore deputizes the Sheriff of Dauphin, Pennsylvania to serve the within Writ of Summons according to law. 12/05/2013 01:21 PM - Deputy Shawn Gutshall, being duly sworn according to law, served the requested Writ of Summons by handing a true copy to a person representing themselves to be Tricia Eckenroad, Legal Assistant, who accepted as"Adult Person in Charge"for No Otto, Ill at 10 East High Street, Carlisle Borough, Carlisle, PA 17013. c41TATI'GUTS L, DEPUTY 12/05/2013 01:21 PM- Deputy Shawn Gutshall, being duly sworn according to law, served the requested Writ of Summons by handing a true copy to a person representing themselves to be Tricia Eckenroad, Legal Assistant, who accepted as"Adult Person in Charge"for Martson Law Group at 10 East High Street, Carlisle Borough, Carlisle, PA 17013. UTSH:LL, DEPUTY 12/05/2013 04:11 PM - Deputy Shawn Gutshall, being duly sworn according to law, served the requested Writ of Summons by handing a true copy to a person representing themselves to be Karen Buckley, Wife, who accepted as"Adult Person in Charge"for Joseph D. Buckley at 1237 Holly Pike, South Middleton Township, Carlisle, PA 17013. 4 47 71_i ► _i TSH LL, i '1 t! l'ju 0 F )s0µ.aiG. 12/10/2013 10:20 AM -The requested Writ of Summons served by the Sheriff of Dauphin County upon Sharon Pearson, who accepted for Morgan Lewis and Bockius, at 17 N. Second Street, 14th Street, Harrisburg, PA 17101. Jack Lotwick, Sheriff, Return of Service attached to and made part of the within record. 12/12/2013 10:05 AM -The requested Writ of Summons served by the Sheriff of Allegheny County upon Mary Hodges, Secretary, who accepted for Minto Law Group c/o Ralph Minto, at Two Gateway Center, Suite 2025, Pittsburgh, PA 15222. William Mullen, Sheriff, Return of Service attached to and made part of the within record. 12/12/2013 10:20 AM -The requested Writ of Summons served by the Sheriff of Allegheny County upon Susan Stewart, who accepted for Richard Rinaldo, at One Gateway Center, 16th Floor, Pittsburgh, PA 15222. William Mullen, Sheriff, Return of Service attached to and made part of the within record. 01/09/2014 Sheriff Ronny R Anderson, being duly sworn according to law, states he made diligent search and inquiry for the within named Defendant to wit: Brady Green, but was unable to locate the Defendant in his bailiwick. The Sheriff therefore returns the within requested Writ of Summons as"Not Served"at 1818 Market Street, 31st Floor, Philadelphia, PA 19103 Plaintiff did not bring in the service fee of$116 required to deputize Philadelphia County and the Writ has now expired. 01/13/2014 10:05 AM -The requested Writ of Summons returned by the Sheriff of Allegheny County, the within named Defendant Jeffrey G Brooks, not found. William Mullen, Sheriff, Return of Service attached to and made part of the within record. SHERIFF COST: $152.02 SO ANSWERS, January 13, 2014 RONR ANDERSON, SHERIFF r -u NN SHERIFF'S OFFICE OF CUMBERLAND COUNTY £xp W3/ Ronny R Anderson ��t�tn of C r+r e, ,p,, Sheriff Jody S Smith Richard W Stewart Chief Deputy 3 Dt& 3 i Ti°_- uP'P. Solicitor Robert M. Mumma, II Case Number vs. Jeffrey G Brooks (et al.) SERVICE COVER SHEET 0 Service Details: ' —4 - `• Category: Civil Action -Writ of Summons Zone: x Manner: Deputize Expires: imasinw Warrant: w < Notes: a -iv F Serve To:- . Final Service: ' "' ,, CL Name: Served: Personally• Adult In Charge • Posted alial o Primary Adult In Addres Charge: Phone: DOB: Relation: H Alternate Date: l2 12(121 13 Time: to Or w Z Address: - - -- Q Phone: Deputy: ,q-y Mileage: i Attorney!Originator,. '-1 _ " , 0 Name: Phone: Service AtY ts: v Eae: s.bto HHHH .„,,, H M N Deputy: 1111111111111 Notes/S ecialInstruc€ions: 11 `, ' , ` �, 1 DC�ci►A MT iia La>j6c.t 14)(4)110 c 'nil! DPiCJJ 0 , , / Ill I/ �0 COMMONWEALT910F F6 tvaJ? iv,�N Notarial Seal w I-40,111- lc 020? Eda Jean VtNotariard;iVntai} Public adty of P�'tsiturgh,ADeuner,y County x ___91■/1//(' LL '* i ' y,. -r i sin Expires May 28,2016 LL No , •- - ■ , : I, hen of um e and Co + t itejbtize the Sheriff of Allegheny Count w p�,� �,.� ,v�,, ,.. 9 Y Y -, to -, - 4 ice of the documents herewith and ma&re urn thereof according to law. vi OReturn To: O Cumberland County Sheriffs Office m One Courthouse Square Carlisle, PA 17013 Ronny R Anderson, Sheriff //piA) , E)(1) I C)1 3 I SHERIFF'S OFFICE OF CUMBERLAND COUNTY Ronny R Anderson ,4�,,,o, at i4..mil+Ote4,4,, Sheriff y 6? Jody S Smith Richard W Stewart Chief Deputy 2 % 3 r ~'.- ,“EP,FI Solicitor Robert M. Mumma, II Number vs. Jeffrey G Brooks(et al.) SERVICE COVER SHEET O Service Detail s: . `� .l u..., .. col Category: Civil Action -Writ of Summons Zone: •- 9 rl'- '1'<.' Manner: Deputize Expires: Warrant: < Notes: a O m c. r_ Serve To: ,�' Fin ervi ; � Name: dillogamniiiiiiiiir Served: Personally CAdult In Charge) Posted . Other N Primary r Adult In M/ fl�Q w Address. Charge: 7.... . Relation: co Phone: DOB: s GCRC(Y1it7 1— Alternate Date: i 2 J,2,113 Time: 1 A0 w Address: O ..___ >” Phone: Deputy: C Mileage: 1 Attorney/Originator:-� ,,, , ., ,: O Name: Phone: 0 Service Attempts:�j J" `. - .. i ..�: _.. a, t 3 : »°�.o : �:,s k, 7, `�,� '�`n. p,,.._,.... `��H ,„,,:4:a:_ Date: I i I ) I I I 1 i Time: MIIIIIIII Cg.';'. Mileage: MIN HHHH IIIIIIIIIIIII M c Deputy: liaIIIIII MI. N Notes!Special Instructions: y r 'f----:,- ..: _ ' ,'L1 IYi*y t ,-__-'''':4,,,,,_:-._ '..w„ d / ,i , II / // / flnal Sealward,tNotary PubC i h,Aleheny C:our�ty 2/ , I MEMBER,PENP Si A ASSOCIATION OF NOTARI fYc , O Now, D=1 _ -.-,t , 2013 I, Sheriff of Cumberland County, Pennsylvania do hereby deputize the Sheriff of Allegheny County ato execute sere of the documents herewith and make return thereof according to law. J O Return To: z Cumberland County Sheriffs Office One Courthouse Square 1( Carlisle, PA 17013 Ronny R Anderson, Sheriff L(P is/3/ Wilt/N SHERIFF'S OFFICE OF CUMBERLAND COUNTY Ronny R Anderson , 01 C ,t,�efi114 Sheriff /' 'Y T) uar Jody S Smith 1 (, Richard W Stewart Chief Deputy 1 3 r),,P r-',1.- =�,1€-; Solicitor • Robert M. Mumma, II vs. �m Jeffree y G Brooks(et al.) el 0 SERVICE COVER SHEET Service Details: , 4` ,,,P: 4 3 N Category: Civil Action -Writ of Summons Zone: g wManner: Deputize Expires: Warrant: a Notes: re m m Serve Tod f.',', ' Final$ , ' ,- nE, ,, ..� '14 _ ce‘ Name: Served: Personally dlt ICh arg Posted ' Other _ , a H Primary ..r Adult In SUS STfw A AT Address: F Charge: � �.,... . . Phone: DOB: Relation: S eeAc 1 - Alternate Date: /2. 12. 11 Time: Z Address: `0 2_0 ui >- Phone: Deputy: (Alt; Mileage: Ili Attorney/Originator ; - CD Name: Phone: Service Attempts: =. *to,_. ...,E , & Date: L .] , ...... .. ..._, to m Time: I ?0 Mileage: [EE] M .o Deputy: Csi Notes/Special Instruc ons - '', ':,COMMON 1 )3{Ak do 044AL14041Alit Notarial Seal i , . fJ 1�c}k t1I�� d6 Eda Jean Woodward,Notary Public / 1 n �'"�_� f City of P,ttsburgh,Allegheny County O ,1 1, ,aO I My Comcrssion Expires May 28,2016 �,[ f Ce I MEMBER,PENP�SI'LVANIA ASSOCIATION OF NOTARIES Now, l ecemb I , 20 eri e d County, Pennsylvania do hereby deputize the Sheriff of Allegheny County to exe _4--- 'il ce of the documents herewith and make return thereof according to law. O D Return To: z Cumberland County Sheriffs Office Ec One Courthouse Square .9.., 2(.' Carlisle, PA 17013 Ronny R Anderson, Sheriff ( fitt of .. ` ` :: Shelley Ruhl �\� l ' , Jack Duignan 1 _ Real Estate Deputy .40 ����,,• • W ■ Chief Deputy Matthew L. Owens �G��� Michael W. Rinehart Solicitor Assistant Chief Deputy Dauphin County 101 Market Street Harrisburg,Pennsylvania 17101-2079 ph:(717)780-6590 fax:(717)255-2889 Jack Lotwick Sheriff Commonwealth of Pennsylvania ROBERT M. MUMMA, II VS County of Dauphin MORGAN, LEWIS & BOCKIUS Sheriffs Return No. 2013-T-3130 OTHER COUNTY NO. 2013-7096 And now: DECEMBER 10, 2013 at 10:02:00 AM served the within WRIT OF SUMMONS upon MORGAN, LEWIS & BOCKIUS by personally handing to SHARON PEARSON * 1 true attested copy of the original WRIT OF SUMMONS and making known to him/her the contents thereof at 17 NORTH 2ND STREET, 14TH FLOOR, HARRISBURG, PA 17101 * SECRETARY So Answers, NOTARIAL SEAL yD�?� � JULIE STOESSEL (/�7S_9 Notary Public SWATARA TWP,DAUPHIN COUNTY My Commission Expires Apr 15,2015 Sheriff of Dauphin County, Pa. -/115 By �l L taiS \ituLu\540e_e(g_k.i a De P Sheriff Deputy: JESSICA KARL Sheriff s Costs: $41.25 12/9/2013 MARSHALL DENNEHEY WARNER COLEMAN & GOGGIN Edwin A.D. Schwartz, Esquire PA Attorney ID# 75902 C!/, PN Nicole M. Ehrhart, E Esquire � q P PA Attorney ID# 200538 VA 100 Corporate Center Drive, Suite 201 Camp Hill, PA 17011 717-651-3700 Email: easchwartzgmdwc ;com Attorney for Defendants Jeffrey G Brooks and Minto Law Group ROBERT M. MUMMA, II, IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA Plaintiff NO. 13-7096 V. CIVIL ACTION - LAW C-) JEFFREY G. BROOKS, IVO OTTO, III, RICHARD F. RINALDO, JOSEPH D. yn1 BUCKLEY, BRADY GREEN, MORGAN Ur' a LEWIS AND BOCKIUS, MARSTON LAW r`< �� iR = GROUP, MINTO LAW GROUP, WILLIAMS c� COULSON ET AL., C, _ 5'cz w CD Defendants —+ 5-! ENTRY OF APPEARANCE TO THE PROTHONOTARY: Kindly enter our appearance on behalf of Jeffrey D. Brooks and Minto Law Group, in the above-captioned matter. MARSHALL, DENNEHEY, WARNER, COLEMAN & GOGGIN Date: By: EDWIN A.D. SCHWARTZ, Attorney ID 75902 NICOLE M. EHRHART, ESQUIRE Attorney ID 200538 100 Corporate Center Drive, Suite 201 Camp Hill, PA 17011 (717) 651-3700 easchwartzn mdwcg com CERTIFICATE OF SERVICE I hereby certify that I am this day serving a copy of the foregoing document upon the person(s) and in the manner indicated below, which service satisfies the requirements of the Pennsylvania Rules of Civil Procedure, by depositing a copy of same in the United States Mail, first-class postage prepaid, addressed as follows: Robert M. Mumma, II Robert M. Mumma, II Box F 6880 S. E. Harbor Circle Grantham, PA 17027 Stuart, FL 34996 Richard F. Rinaldo Williams Coulson Johnson Lloyd Parker & Tedesco, LLC One Gateway Center, 16th Floor Pittsburgh, PA 15222 George B. Faller, Jr. Martson Law Offices 10 East High Street Carlisle, PA 17013 Joseph D. Buckley, Esquire 1237 Holly Pike Carlisle, PA 17013 Brady L. Green, Esquire 1818 Market Street, 31st Floor Wilbraham Lawler & Buba Philadelphia, PA 19103 [THE REMAINDER OF THIS SECTION IS INTENTIONALLY LEFT BLANK] Morgan Lewis & Bockius 17 North Second Street, 14th Floor Harrisburg, PA 17101 MARSHALL,DENNEHEY,WARNER, COLEMAN & GOGGIN Date: /— z -// By: EDWIN A.D. SCHWAR QUIRE Attorney ID 75902 NICOLE M. EHRHART, ESQUIRE Attorney ID 200538 100 Corporate Center Drive, Suite 201 Camp Hill, PA 17011 (717) 651-3700 easchwartzgx mdwcg.corn Counsel for Defendants Jeffrey G. Brooks and Minto Law Group Robert M. Mumma,II In the Court of Common Pleas of Cumberland County, Pennsylvania No.2013-7096 Civil Term vs Jeffrey G Brooks et al PRAECIPE TO THE PROTHONOTARY OF CUMBERLAND COUNTY: You are directed to withdraw,without prejudice,the Writ of Summons filed in this matter. C) r rri 't CI7 c, 3>--CZ a mil.. • • David D. Buell, Prothonotary d .6,pzas, aaer 20 Attorney Info: %Z4, Lt - I ' 4 Robert M. Mumma,II Box F Grantham,PA 17027 717 448 1127 VERIFICATION I, hereby verify that the statements made in the foregoing document are true and correct to the best of my knowledge, information and belief. I understand that false statements herein are made subject to the penalties of 18 Pa. C.S. §4904 relating to unsworn falsification to authorities. /A4-51A-4—/ Date: ISZ-f` (L By: Robert M. Mumma, II CERTIFICATE OF SERVICE I Robert M. Mumma, II hereby certify that a a copy of the foregoing Praecipe to withdraw Writ of Summons was served on this date, first class mail, postage prepaid, to the following. Jeffrey G. Brooks, Esquire Two Gateway Center 603 Stanwix Street Suite 2025 Pittsburgh, PA 15222 Joseph D. Buckley, Esquire 1237 Holly Pike Carlisle, PA 17013 Brady L. Green, Esquire 1701 Market Street Philadelphia, PA 19103 Morgan Lewis and Bockius 17 North Second Street Harrisburg, PA 17101 George Faller, Esquire Marston Law 10 East High Street Carlisle, PA 17013 Richard F Rinaldo, Esquire Wilson Coulson One Gateway Center, 16th Floor Pittsburgh, PA 15222 Date: February 5, 2014 _ �'' '�� l'_