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ESTATE OF GEORGE W. HOWARD, : IN THE COURT OF COMMON PLEAS OF
Deceased, : CUMBERLAND COUNTY, PENNSYLVANIA
NO. 21-13-1143
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ORPHANS' COURT DIVISIOCR C> M n
ANSWER OF JOHN C. OSZUSTOWICZ, '
EXECUTOR OF THE ESTATE OF GEORGE W. HOWARI3:
TO MOTION TO COMPEL RESPONSE
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AND NOW, comes John C. Oszustowicz,Executor of the Estate of Georgi^W. Hoy ard,by M
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and through his attorneys, MARTSON LAW OFFICES, and files his Answer to the Mo ion of
Petitioners; Robert Howard and Dennis Howard, to Compel Response to Discovery Requests as
follows:
1-8 Admitted.
9. Admitted. By way of further response, the parties have been in frequent contact
regarding a possible settlement. Respondent did not timely respond due to the ongoing negotiations.
10. Admitted. By way of further response,Respondent does not object to the discovery
requests and served his Answers contemporaneously with the filing of this Answer.
11-13. Denied as conclusions of law to which no response is required.
14. Denied. After reasonable investigation respondent is without information sufficient
to admit or deny the averments of this paragraph.
15. Denied as stated. Counsel for Respondent discussed with Petitioners' counsel the
possibility of continuing the discovery deadline in this case prior to Petitioners' counsel filing the
instant Motion. By way of further response,Respondent has contemporaneously served his answers
with the filing of this Answer. Moreover,Respondent was not contacted regarding his concurrence
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prior to the filing of the instant Motion; if he had been contacted,Respondent would have provided
his Response to Petitioners' discovery earlier.
16. Admitted and by way of further response,Respondent does not oppose the extension
of the discovery deadline.
WHEREFORE,Respondent believes that Petitioners'Motion is now moot as he has supplied
responses to Petitioners' discovery requests. Respondent respectfully requests cancellation of the
argument scheduled for November 5, 2014, as moot.
MARTSON LAW OFFICES
By:
Ivo V. Otto, 111, Esquire
Attorney I.D. No. 27763
10 East High Street
Carlisle, PA 17013
(717) 243-3341
Attorneys for John C. Oszustowicz, Executor of
The Estate of George W. Howard
Date:
CERTIFICATE OF SERVICE
I,Mary M.Price,an authorized agent for Martson Law Offices,hereby certify that a copy of
the foregoing Answer to Motion was served this date by depositing same in the Post Office at
Carlisle, PA, first class mail, postage prepaid, addressed as follows:
Mark A. Mateya, Esquire
55 West Church Avenue
Carlisle, PA 17013
Marcus A. McKnight, III, Esquire
IRWIN & McKNIGHT, P.C.
60 West pomfret Street
Carlisle, PA 17013
MARTSON LAW OFFICES
By_
/
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M. Price
Ten East High Street
Carlisle, PA 17013
(717) 243-3341
Dated: