HomeMy WebLinkAbout12-31-14 (2) ��
ESTATE OF GEORGE W. HOWARD : IN THE COURT OF COMMON PLEAS
Deceased : CUMBERLAND COUNTY PENNSYLVANIA
: N0. 21-13-1143
: ORPHANS' COURT DIVISION
PETITION FOR ENLARGEMENT OF TIME
�v
OF THE DISCOVERY PERIOD � `=�
-� o -� �' r�i
� � � � �
�'� � c� � v> �r
:.;� � r_ W .._.� �
Now comes Petitioner, Mark A. Mateya, Esquire and respectfully requests ari;; `'�' ►—� "',? t,�
, �::�
enlargement of time of the Discovery period and in support avers the following: ��' � � �`' -�
W _.�-� ca f= r i
1. A status conference was held before the Honorable Judge M. L. Ebert,�Jr., on August "' -�
13, 2014, at which time the discovery deadlines were established for October 31, 2014 and a trial
date was set for February 4, 2015.
2. Discovery between the parties was not completed and the approaching deadline for the
discovery period was approaching, Attorney Mark A. Mateya filed a Motion to Compel
Responses to Discovery Requests upon Attorney McKnight. A hearing was held before Judge
M. L. Ebert, Jr., and the discovery deadline was enlarged with a deadline of December 31, 2014.
3. A settlement or the entire matter was reached just prior to the taking of depositions.
4. Robert Howard is now refusing to cooperate with Attorney Mateya or to adhere to the
Settlement Agreement.
5. Concurrently herewith, Petitioner Mark A. Mateya, has filed a Petition for Withdrawal
of his Appearance in this matter on behalf of Robert Howard and Dennis Howard. Robert
Howard wishes to move forward with the case.
t �
5. Mark A. Mateya, Esquire has sought concurrence from Marcus A. McKnight, III,
Esq., in this Petition for Enlargement of Time of the Discovery Period; Attorney McKnight does
not concur in this request for an enlargement of time of the discovery period.
WHEREFORE, it is respectfully requested that the Petition for Enlargement of Time of
the Discovery Period be granted allowing Robert Howard to retain new counsel and any further
discovery which may be needed.
Respectfully submitted,
� � �._.
;in,�� "�
Mark A. Matey q.
55 W. Church Avenue
Carlisle, PA 17013
(717) 241-6500
(717) 241-3099 Fax
Date: ��- �� � �
�J •
CERTIFICATE OF SERVICE
I, Mark A. Mateya, Esquire, hereby certify that I have served a copy of the foregoing
document on the following person(s) by depositing a true and correct copy of the same in the
United States Mail, by way of United States Mail, first class, postage prepaid, at Carlisle,
Cumberland County, Pennsylvania addressed to:
Ivo V Otto III Esq
Martson Law Offices
10 East High Street
Carlisle PA 17013
Marcus A McKnight, III Esq
Irwin& McKnight Law Offices
60 West Pomfret Street
Carlisle PA 17013
Robert Howard
942 Mountain Meadow Road
Libby MT 59923
Dennis Howard
6016 Snowdens Run Road
Eldersburg MD 21784
�� � ` ��.. `�
Mark A. Mateya, Es ire
55 W. Church Avenue
Carlisle, PA 17013
(717) 241-6500
(717) 241-3099 Fax
Dated: t� �Z�` I�'