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Home My WebLink About04-03-14 : In the Court of Common Pleas of � �: : Cumberland County, ,.,, c � � �' Pennsylvania � � �, � � Estate of Robert M. Mumma, Deceased : � m � �' � � s" � rn W --�''`~.� � : No. 21-86-398 =P=� `" �'- <�_, a . � ° � � �-� "' ` _.�'..i °° r' m : : Orphans' Court Di�ision c.� c� o w � RESPONSE OF ROBERT M. MUMMA, II TO MOTION OF LISA MORGAN FOR AN ORDER CLARIFYING HER RIGHT TO VOTE SHARES OF BOBALI CORPORATION STOCK OWNED BY THE RESIDUARY TRUST UNDER THE WILL OF ROBERT M. MUMMA, SR. Robert M. Mumma, II (Bob) objects to granting Lisa Morgan any rights to vote the Bobali Stock she contends is held by the Residuary Trust. 1. The Bobali Stock was not listed as an asset of Robert M. Mumma in any Estate accountings. 2. The order of Judge Bratton is not a final order. ��. � 3. The Executors of the Estate have pretended to be holders of Bobali stock pursuant to a merger of Bobali into Middle Park Inc. Lisa contends that the estate had the power to effect such a merger in 1987. Neither the Bobali stock or the Middle Park stock is listed in the inventory of the estate or any trust during that period of time. 4. The actions of the Executrix to appoint themselves officers and directors of Bobali are fraud and not supported by the Estate accountings. 5. Robert M. Mumma clearly saw Middle Park/Bobali as a family business and conveyed equal ownership interests to each of his children and none to his wife. It was his intention that the four children manage Middle Park1 Bobali as a real estate investment company. A recently discovered letter from Robert Schmidt an insurance agent to Equitable of Iowa underwriters details this plan. (See e�ibit B) 6. Barbara McKimmie Mumma had no rights to purchase stock in Bobali as and then convey that interest to a Florida trust solely for the Morgan family. 7. Lisa Morgan withheld the existence of an additiona1300,000 shares of Middle Park Stock from Judge Bratton. These shares were owned by Pennsylvania Supply Company and are not listed as an asset of the Estate. Pennsylvania Supply Company was thus the single largest shareholder of Middle Park stock. The existence of these shares was not known until months after the conclusion of the Bratton hearings. 8. The Cumberland County Orphans Court needs to determine how the Residuary Trust acquired the claimed interest in Bobali since it was not part of Robert M.Mumma's Estate inventory. 9. Immediate distribution of the voting rights to the Bobali stock claimed to be held in the Residuary Trust will continue the desire of Robert M. ..� .�� Mumma that each child have an equal interest in the Bobali assets and equal say in how they are handled. lO.At the January Shareholders meeting the election of directors were voted on in two ways. A first vote was taken with Lisa Morgan voting the Residuary Trust shares and then again votes were taken with Barbara and Bob Mumma voting those shares owned by them but not distributed. The results were clearly different. 11.Lisa voted to elect herself and George Faller, her attorney, as directors. Barbara and Bob voted to elect themselves directors. Lisa Morgan is clearly using her failure to distribute these shares of Bobali to maintain control and deny Barbara and Bob their rights to participate in corporate decision making. By appointing her attorney rather a sibling she clearly disregards Robert M. Mumma's intention that the assets by managed by the family members. WHEREFORE: Robert M. Mumma requests that the Court deny Lisa Morgan's right to vote the Bobali Stock and immediately convey voting rights to all stock held by the Residuary Trusts to the four beneficiaries one quarter each. Respondent asks the Court to hold a hearing to determine how the Bobali stock became an asset of the Residuary Trust when it was not in the inventory of the Estate. �� Robert M. Mumma, II Apri12, 2014 Box F Grantham, PA 17027 717 448 1127 VERIFICATION I, Robert M. Mumma, II ,verify that the statements made in the foregoing Response to Motion to clarify voting rights of Lisa Morgan are true and correct to the best of my knowledge, information and belie£ 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: 1 � 2, �i� Robert M. Mumma, II CERTIFICATE OF SERVICE I, Robert M. Mumma, II, hereby certify that a copy of the foregoing Response to the Motion of Lisa Morgan to clarify voting rights was served on this date, first class mail,postage prepaid, to the following: Richard F. Rinaldo, Esquire Williams Coulson Johnson Lloyd Parker& Tedesco,LLC One Gateway Center, 16t" Floor Pittsburgh, PA 15222 Brady Green Anthony De Luca, Auditor Wilbraham Lawler and Buba 113 front Street 1818 Market St, 31 St Floor Boiling Springs, PA 17007 Philadelphia, PA 19103 Ivo V. Otto, III, Esquire Martson Law Offices 10 East High Street Carlisle, PA 17013 Linda Mumma P.O.Box 30436 Bethesda, MD 28824 �' � ROBERT M. 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