HomeMy WebLinkAbout06-20-14 . __ _ _ .
Shaun E.O'Toole c� � �
Attorney I.D.#44797 � �, -`= r� ►n
220 Pine Street �,�� =�� � �_� �
....
Harrisburg,Pennsylvania 17101 ='� �� �-. z c:� �'�
Attorney for, Petitioner, Robert M. Mumma, 11 "'= ' !,�; tv � � ���
"; �, . ,
� a �.�
IN THE COURT OF COMMN PLEAS OF �' � :i � -�^r �
CUMBERLAND COUNTY, PENNSYLVANIA �:� �� —
: � ►-' :,:_ ���
ORPHANS' COURT DIVISION � —+ t--�' ;--= rn
;., H-+ Ct� o
F-•+ 'n
IN RE: ESTATE OF ROBERT .
M. MUMMA,Deceased . NO. 21-86-398
MOTION FOR CONTINUANCE
AND NOW comes Shaun E. O'Toole, attorney for Petitioner, Robert M. Mumma, II, a
beneficiary of the Estate of Robert M. Mumma, Deceased, and files the following Motion for
continuance and in support thereof sets forth the following:
1. On Apri130, 2014, this Court entered an Order scheduling a hearing For June 25,
2014 at 9:30 A.M. to determine the attorneys' fees and costs access against Robert M. Mumma,
II in relation to the hearings conducted by the court-appointed auditor.
2. Petitioner requests that the hearing be continued and rescheduled in order to give
his counsel,the undersigned, an adequate opportunity to prepare for the hearing. Although
Petitioner retained said counsel about one month ago, in light of the numerous matters before this
court in the past two weeks as well as two appeals in the Pennsylvania Superior Court(one
recently filed and the other to be argued next week) Petitioner's new counsel has not and will not
have adequate time to prepare for the June 25, 2014 hearing.
3. On the morning of June 17, 2014, counsel for the Petitioner e-mailed opposing
counsel requesting their positions regarding this requested continuance and did not receive a
response from such counsel stating a position on this request.
Wherefore, Petitioner requests that this Court grant this motion for continuance and
reschedule the matter.
Respectfully submi±ted:
Dated: Ob �20 �I 4 �• �
aun E. O'Toole
Attorney I.D. #44797
220 Pine Street
Harrisburg, Pennsylvania 17101
Attorney for Petitioner
CERTIFICATE OF SERVICE
The undersigned hereby certifies that on this date a true and correct copy of the foregoing
Brief was faxed to each of the following attorneys and served by first class United States mail,
postage prepaid, upon the following:
Ivo V. Otto, III, Esquire
George B. Faller, Jr., Esquire
Martson Law Offices
10 East High Street
Carlisle, Pennsylvania 17013;
Brady L. Green, Esquire
Wilbraham, Lawler& Buba
1818 Market Street, 31St Floor
Philadelphia, Pennsylvania 19103;
Richard F. Rinaldo, Esquire
Williams Coulson LLC
One Gateway Center, 16�' Floor
Pittsburgh, Pennsylvania 15222; and
Linda M. Mumma
P.O. Box 30436
Bethesda, Maryland 20824.
Date: 0�12�/�4 �O•
aun E. O'Toole
Attorney Registration No. 44797
220 Pine Street
Harrisburg, Pennsylvania 17101
(717) 695-0389
Attorney for Robert M Mumma, II
VERIFICATION
I hereby verify that the statements of fact made in the foregoing document are true and
correct to the best of my knowledge, information and belief. I understand that any false
statements therein are subject to the penalties contained in 18 Pa.C.S.A. §4904, relating to
unsworn falsification to authorities.
Date: O<o�Zo 1 1� �. �
aun E. O'Toole