HomeMy WebLinkAbout01-09-15 : IN THE COURT OF COMMON PLEAS OF
: CUMBERLAND COUNTY
: PENNSYLVANIA
ESTATE OF GEORGE W. HOWARD .
DEC�A�ED : 1VT0. 2�-13-01143
: ORPHANS COUIZT DIVISION
MOTION IN LIMINE
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AND NOW, this 9�' day of January, 2015, comes Robert Surfield, the �rr�ficiary�th�? �
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Estate of Geor e W. Howard, b and throu h his attorne s Irwm & McKni ht,'^�'.. , �d �}�ke�:.'� �
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the following Motion in limine, averring as follows: , � ' •-� --'ri �n
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Robert Surfield, the beneficiary of the Estate of George W. Howard, represented by
Marcus A. McKnight, III, Esquire.
2.
Robert Howard and Dennis Howard are represented by Mark A. Mateya, Esquire.
3.
The Estate of George W. Howard is reprzse�ted by Ivo v. C�to, III, Esquire.
4.
On the eve of depositions Robert Howard and Dennis Howard agreed t� settle their claim
against the Estate of George W. Howard.
5.
Depositions were canceiied a��d the Court was notified�f the settiem�nt.
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6.
Robert Howard has refused to sign the settlement documents.
7.
For the reasons ci±ed abave, Rorert Surfi�lc?, the ben�ficiary of the Estate�f C=eorge W.
Howard, respectfully requests that this Honorable Court enter an Order precluding Robert
Howard, Dennis Howard and their legal counsel from offering evidence, or otherwise bringing
before the Court, any of the matters set forth below:
a. Any statement of the deceased George W. Howard, and
b. Any evidence not disclosed to counsel for the Estate of George W. Howard before
January 9, 2015.
�E'H�1�EFG�R�,�h� Roba� Surfield, the �enef cia:�of tke Estat�of�eo:ge W. �-�owa�d,
respectfully requests that this Honorable Court enter an Order precluding Robert Howard,
Dennis Howard and their legal counsel from offering evidence, or mentioning, referring to, or
otherwise bringing before the Court, directly or indirectly, any statements of the Deceased or any
evidence not disclosed to counsel for the Estate or Counsel for Robert Surfield prior to January
9, 2�15.
Respectfully submitt..d,
I�WIN &1VIcKiVIGHT .C.
By: � !
Marcus A. McKnigh , II, s .
Supreme Court I.D. No:
60 West Pomfret Street
Carlisle, Pennsylvania 17013-3222
717-249-2353
Date: January 9, �015 Attorney for Robert Surfield
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VERIFICATION
The foregoing document is based upon information, which has been gathered by my
counsel and myself in the preparation of this action. I have read the statements made in this
document and they are true and conect to the best of my knowledge, information and belief. I
understand that false statements herein made are subject to the penalties of 18 Pa.C.S.A. Section
4904 relating to unsworn falsification to authorities.
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By:
R BERT SURFIELD
Date: January 9, 2015
: IN THE COURT OF COMMON PLEAS OF
: CUMBERLAND COUNTY
: PENNSYLVANIA
ESTATE OF GEORGE W. HOWARD .
DECEASED : N0. 21-13-Oi143
: ORPHANS COURT DIVISION
CERTIFICATE OF SERVICE
I, Marcus A. McKnight, III, Esquire, hereby certify that a copy of attached document was
ser�ed to t��folicw�ing�y�ersar�al de�ivery and depositii�g a true anu correct�opy of the s��nc
in the United States mail, First Class, postage prepaid in Carlisle, Pennsylvania, on the date
referenced below and addressed as follows:
Mark A. Mateya,Esquire
55 West Church Avenue
Carlisle,PA 17013
Ivo-J. Oit�,III, Esqui��e
Martson Law Offices
10 East High Street
Carlisle,PA 17013
John C. Oszustowicz,Esquire
104 South Hanover Street
Carlisle, PA 17013
IRWIN & McKNIGHT,P.C.
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By:
i�1�.r . McILnight, Es�.
Supre e Court I.D.: 254
60 West reet
Carlisle, PA 17013
(717) 249-2353
Attorney for Robert Surfield,
Date: January 9, 2015
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