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HomeMy WebLinkAbout03-26-91 (2) IN RE: ESTATE OF ROBERT M. MUMMA, late of Cumberland County, pennsylvania IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA NO. 21-86-398 : ORPHANS' COURT DIVISION CONSENT AND JOINDER OF SUSAN MANN MUMMA, A MINOR. BY ROBERT M. MUMMA, II, HER NATURAL FATHER, NATURAL GUARDIAN, NEXT OF FRIEND. AND NATURAL GUARDIAN, TO THE PETITION OF ROBERT M. MUMMA, II, SON OF DECEDENT. TO COMPEL FIRST AND PARTIAL ACCOUNTS AND CONTINUING ANNUAL ACCOUNTINGS Susan Mann Mumma, by her natural father, natural guardian, and next of friend of Susan Mann Mumma, by her attorneys, Charles E. Shields, III, William C. Costopoulos, and Pepper, Hamilton & scheetz, file the following Consent and Joinder to the Petition to Compel First and Partial Accountings: 1. Susan Mann Mumma, consentor herein, is a minor individual and is the natural daughter of Robert M. Mumma, II by Susan Regan Mumma, who resides with the said natural father. 2. Susan Mann Mumma resides with her said natural parents. 3. The said natural father, natural guardian, and next of friend of Susan Mann Mumma, has read the said PETITION TO COMPEL FIRST AND PARTIAL ACCOUNTS AND CONTINUING ANNUAL ACCOUNTINGS, has no conflict of interest on this issue with his natural daughter, and believes it in the best interests of and for the ultimate protection of his said daughter's interest in the Estate of 1 713 1- Robert M. Mumma, deceased, that such accountings be compelled. WHEREFORE, Susan Mann Mumma, by her natural father, natural guardian, and next of friend, Robert M. Mumma, II, consents to and joins in the prayer of the said PETITION TO COMPEL FIRST AND PARTIAL ACCOUNTS AND CONTINUING ANNUAL ACCOUNTINGS. Respectfully submitted, Charles E. Shields, III National Bank Building 2 West Main Street Mechanicsburg, PA 17055 (717) 766-0209 LD. #38513 William C. Costopoulos 831 Market Street Lemoyne, PA 17043 (717) 761-2121 By r;&.~~ f!~::K At orneys for Petitioner 2 714 VERIFICATION I, Robert M. Mumma, II, as natural father, natural guardian, and next of friend of Susan Mann Mumma, depose and say that the facts set forth in the foregoing CONSENT AND JOINDER are true and correct to the best of my knowledge, information and belief and I understand that the statements herein are subject to the penalties of 18 Pa. C.S. sec. 4904 relating to unsworn falsification to authorities. vkJ)u~~]J: ROBERT M. MUMMA, II 715 CERTIFICATE OF SERVICE CHARLES E. SHIELDS, III hereby certifies that on this /?!iL day of March, 1991, he served a true and correct copy of the CONSENT AND JOINDER OF SUSAN MANN MUMMA, A MINOR, BY ROBERT M. MUMMA, II, HER NATURAL FATHER, NATURAL GUARDIAN, AND NEXT OF FRIEND, TO THE PETITION OF ROBERT M. MUMMA, II, SON OF DECEDENT, TO COMPEL FIRST AND PARTIAL ACCOUNTS AND CONTINUING ANNUAL ACCOUNTINGS on the parties listed below by First Class mail, postage prepaid: Richard W. stevenson, Esquire McNees, Wallach & Nurick P.O. Box 1166 HarriSburg, PA 17108-1166, Attorney for Barbara M. McClure John Hardin Young, Esquire Porter, Wright, Morris & Arthur 1233 20th Street, N.W. washington, D.C. 20036-2395 Attorney for Linda M. Roth Attorney General Commonwealth of Pennsylvania Strawberry Square HarriSburg, PA 17120 William E. Zeiter, Esquire Morgan, Lewis & Bockius 2000 One Logan Square Philadelphia, PA 19103 Attorney for Barbara McK. Mumma and Lisa M. Morgan William F. Martson, Esquire Martson, Deardorff, williams & otto 10 East High Street Carlisle, PA 17013 Attorney for Barbara McK. Mumma and Lisa M. Morgan ~z~ CHARLES E. SHIELDS, III 716 CERTIFICATE OF SERVICE CHARLES E. SHIELDS, III hereby certifies that on this day of March, 1991, he served a true and correct copy of the CONSENT AND JOINDER OF SUSAN MANN MUMMA, A MINOR, BY ROBERT M. MUMMA, II, HER NATURAL FATHER, NATURAL GUARDIAN, AND NEXT OF FRIEND, TO THE PETITION OF ROBERT M. MUMMA, II, SON OF DECEDENT, TO COMPEL FIRST AND PARTIAL ACCOUNTS AND CONTINUING ANNUAL ACCOUNTINGS on the parties listed below by First Class mail, postage prepaid: Richard W. Stevenson, Esquire McNees, Wallach & Nurick P.O. Box 1166 Harrisburg, PA 17108-1166, Attorney for Barbara M. McClure John Hardin Young, Esquire Porter, Wright, Morris & Arthur 1233 20th street, N.W. Washington, D.C. 20036-2395 Attorney for Linda M. Roth Attorney General Commonwealth of Pennsylvania strawberry Square Harrisburg, PA 17120 William E. Zeiter, Esquire Morgan, Lewis & Bockius 2000 One Logan Square Philadelphia, PA 19103 Attorney for Barbara McK. Mumma and Lisa M. Morgan William F. Martson, Esquire Martson, Deardorff, Williams & otto 10 East High Street Carlisle, PA 17013 Attorney for Barbara McK. Mumma and Lisa M. Morgan CHARLES E. SHIELDS, III 717 o o '" 3: ~ n m z :I: " " J> $:"'~ ~'" ~;TE~ oln (')3;::t :Den m~~ Zm c:z::! rn. :D('J)O ~tn P::!~ ~:z: oUr- ,_ j! mil! S;J!! _~z :Ec ~ : en '" c: UI ;= _ o Z " 1..:.....", 0"", w::, u--- -.., u. - ~~.l... cv: 6c: WW 01--- a::ij) OG '-',--, ~a:: ..,- -Q.. ~~~~~ UI!~ In~j ~~~~~~ ~ ~~Ul ~i;~~ ~~~J~ OS:4H ..,~t' f:l S;! I I f;j ~ Ul - i ~ ~ :;:: i Ul H ~ '"" \() N C:: ~ ::-.q:: c.(... (J ": -..--..{~)o _ U :';::0 ..7:..". ::::< ~-~ 0"" ,l<l ",0) cc.1: ","" -l'-' '-' P\ , , IN RE: ESTATE OF ROBERT M. MUMMA, late of Cumberland County, pennsylvania IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA NO. 21-86-398 ORPHANS' COURT DIVISION CONSENT AND JOINDER OF MARGUERITE MANN MUMMA. A MINOR. BY ROBERT M. MUMMA. II. HER NATURAL FATHER. NATURAL GUARDIAN. NEXT OF FRIEND. AND NATURAL GUARDIAN. TO THE PETITION OF ROBERT M. MUMMA. II. SON OF DECEDENT. TO COMPEL FIRST AND PARTIAL ACCOUNTS AND CONTINUING ANNUAL ACCOUNTINGS Marguerite Mann Mumma, by her natural father, natural guardian, and next of friend of Marguerite Mann Mumma, by her attorneys, Charles E. Shields, III, William C. Costopoulos, and Pepper, Hamilton & Scheetz, file the following Consent and Joinder to the Petition to Compel First and Partial Accountings: 1. Margueri te Mann Mumma, consentor herein, is a minor individual and is the natural daughter of Robert M. Mumma, II by Susan Regan Mumma, who resides with the said natural father. 2. Margueri te Mann Mumma resides with her said natural parents. 3. The said natural father, natural guardian, and next of friend of Marguerite Mann Mumma, has read the said PETITION TO COMPEL FIRST AND PARTIAL ACCOUNTS AND CONTINUING ANNUAL ACCOUNTINGS, has no conflict of interest on this issue with his natural daughter, and believes it in the best interests of and 1 718 s- for the ultimate protection of his said daughter's interest in the Estate of Robert M. Mumma, deceased, that such accountings be compelled. WHEREFORE, Margueri te Mann Mumma, by her natural father, natural guardian, and next of friend, Robert M. Mumma, II, consents to and joins in the prayer of the said PETITION TO COMPEL FIRST AND PARTIAL ACCOUNTS AND CONTINUING ANNUAL ACCOUNTINGS. Respectfully submitted, Charles E. Shields, III National Bank Building 2 West Main street Mechanicsburg, PA 17055 (717) 766-0209 1.0. #38513 William C. Costopoulos 831 Market street Lemoyne, PA 17043 (717) 761-2121 BY~Z~~ Attorneys for Petitioner 2 '719 VERIFICATION I, Robert M. Mumma, II, as natural father, natural guardian, and next of friend of Marguerite Mann Mumma, depose and say that the facts set forth in the foregoing CONSENT AND JOINDER are true and correct to the best of my knowledge, information and belief and I understand that the statements herein are subject to the penalties of 18 Pa. C.S. sec. 4904 relating to unsworn falsification to authorities. ~VU.YkM~]C ROBERT M. MUMMA, II - 720 CERTIFICATE OF SERVICE CHARLES E. SHIELDS, III hereby certifies that on this 13~~ day of February, 1991, he served a true and correct copy of the CONSENT AND JOINDER OF MARGUERITE MANN MUMMA, A MINOR, BY ROBERT M. MUMMA, II, HER NATURAL FATHER, NATURAL GUARDIAN, AND NEXT OF FRIEND, TO THE PETITION OF ROBERT M. MUMMA, II, SON OF DECEDENT, TO COMPEL FIRST AND PARTIAL ACCOUNTS AND CONTINUING ANNUAL ACCOUNTINGS on the parties listed below by First Class mail, postage prepaid: Richard W. stevenson, Esquire McNees, Wallach & Nurick P.O. Box 1166 Harrisburg, PA 17108-1166, Attorney for Barbara M. McClure John Hardin Young, Esquire Porter, Wright, Morris & Arthur 1233 20th Street, N.W. Washington, D.C. 20036-2395 Attorney for Linda M. Roth Attorney General Commonwealth of Pennsylvania Strawberry Square Harrisburg, PA 17120 William E. zeiter, Esquire Morgan, Lewis & Bockius 2000 One Logan Square Philadelphia, PA 19103 Attorney for Barbara McK. Mumma and Lisa M. Morgan William F. Martson, Esquire Martson, Deardorff, Williams & otto 10 East High Street Carlisle, PA 17013 Attorney for Barbara McK. Mumma and Lisa M. Morgan ~f~)2 CHARLES E: SHIELDS, III 721 . -- -.- ~~~C3.,!~ 12 ~ S ~ Ij 0 Wt!~~ & ! ~ J '" 0 '~j~j~ 'I l:: ~ - ;:: l:: 0 o:l 0 g 0\ m z S i I () :; U~~.~ w j;"'lli >:0 '" ~~ 1!;~'::; g!;; o:l 03:':I: Den ~~~m ~ m).~ z'" :s: , ~ c::z::! ~. ~~i~;i :D(n~ .>" tJj ~"~~ 71: I ~ ~mtJJ );m ~~ ~~~ =;6 d ; en IS~II CJI c = I: 01 F _ " z " ~i~;s:~ Gl ~, . ,..., ,.~" ~~ - S.,i -' ~.j::'" W_I ""'" ~.) -: w::- el.. :"'18 -~ "-" Qt::, '-"'Z"crn. C<, \C) .q::z:: oe;:. N ,=-7=<::: kJ~"' C::: -..., c..-- 0::0;: Cl;;(/'. ~ Ow 05 ::::~ w..., ~cr: - "':::. P\ :::It.> W IN RE: ESTATE OF ROBERT M. MUMMA, late of Cumberland County, pennsylvania IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA NO. 21-86-398 : ORPHANS' COURT DIVISION CONSENT AND JOINDER OF ROBERT M. MUMMA. III. A MINOR. BY ROBERT M. MUMMA. II. HIS NATURAL FATHER. NATURAL GUARDIAN. NEXT OF FRIEND. AND NATURAL GUARDIAN. TO THE PETITION OF ROBERT M. MUMMA. II, SON OF DECEDENT, TO COMPEL FIRST AND PARTIAL ACCOUNTS AND CONTINUING ANNUAL ACCOUNTINGS Robert M. Mumma, III, by his natural father, natural guardian, and next of friend of Robert M. Mumma, III, by his attorneys, Charles E. Shields, III, William C. Costopoulos, and Pepper, Hamilton & Scheetz, file the following Consent and Joinder to the Petition to Compel First and Partial Accountings: 1. Robert M. Mumma, III, consentor herein, is a minor individual and is the natural son of Robert M. Mumma, II by sally Osler Songster, of 19 East Marble Street, Mechanicsburg, Cumberland county. 2. Robert M. Mumma, III, as per a shared legal custody agreement, resides with the said natural mother approximately sixty-five (65%) per cent of the time and with his said natural father approximately thirty-five (35%) per cent of the time. 3. The said natural father, natural guardian, and next of friend of Robert M. Mumma, III, has read the said PETITION TO 1 722 J: COMPEL FIRST AND PARTIAL ACCOUNTS AND CONTINUING ANNUAL ACCOUNTINGS, has no conflict of interest on this issue with his natural son, and believes it in the best interests of and for the ultimate protection of his said son's interest in the Estate of Robert M. Mumma, deceased, that such accountings be compelled. WHEREFORE, Robert M. Mumma, III, by his natural father, natural guardian, and next of friend, Robert M. Mumma, II, consents to and joins in the prayer of the said PETITION TO COMPEL FIRST AND PARTIAL ACCOUNTS AND CONTINUING ANNUAL ACCOUNTINGS. Respectfully submitted, Charles E. Shields, III National Bank Building 2 West Main Street Mechanicsburg, PA 17055 (717) 766-0209 1.D. #38513 William C. Costopoulos 831 Market Street Lemoyne, PA 17043 (717) 761-2121 By{j/~l~A E~:i2 Attorneys for Petitioner 2 723 VERIFICATION I, Robert M. Mumma, II, as natural father, natural guardian, and next of friend of Robert M. Mumma, III, depose and say that the facts set forth in the foregoing CONSENT AND JOINDER are true and correct to the best of my knowledge, information and belief and I understand that the statements herein are subject to the penalties of 18 Pa. C.S. sec. 4904 relating to unsworn falsification to authorities. WftC~ ROBERT M. MUMMA, II 724 CERTIFICATE OF SERVICE CHARLES E. SHIELDS, III hereby certifies that on this ~ day of March, 1991, he served a true and correct copy of the CONSENT AND JOINDER OF ROBERT M. MUMMA, III, A MINOR, BY ROBERT M. MUMMA, II, HIS NATURAL FATHER, NATURAL GUARDIAN, AND NEXT OF FRIEND, TO THE PETITION OF ROBERT M. MUMMA, II, SON OF DECEDENT, TO COMPEL FIRST AND PARTIAL ACCOUNTS AND CONTINUING ANNUAL ACCOUNTINGS on the parties listed below by First Class mail, postage prepaid: Richard W. stevenson, Esquire McNees, Wallach & Nurick P.O. Box 1166 Harrisburg, PA 17108-1166, Attorney for Barbara M. McClure John Hardin Young, Esquire Porter, Wright, Morris & Arthur 1233 20th Street, N.W. Washington, D.C. 20036-2395 Attorney for Linda M. Roth Attorney General Commonwealth of Pennsylvania strawberry Square Harrisburg, PA 17120 William E. Zeiter, Esquire Morgan, Lewis & Bockius 2000 One Logan Square Philadelphia, PA 19103 Attorney for Barbara McK. Mumma and Lisa M. Morgan William F. Martson, Esquire Martson, Deardorff, Williams & otto 10 East High Street carlisle, PA 17013 Attorney for Barbara McK. Mumma and Lisa M. Morgan ~ zdt;;p JT CHARLES E. SHIELDS, III 7Z5 , " r~ mE rn '2l I ~ I; 1)\' I n ~~~ f;l 0 ~~~ .. '" " ~ r.n f( ;: " 0 H~~~ co Tn ~ % ' ~ ~ 'i' C'l " ,. i ~"'~ 5:11 II~~ ~ ~ tB. w '" ~~ ~;E~ 0," I~l co O3:,::I: :DC'll t:l m~~ Zm ( CZ~ m. :s: ~ ' ~ :O(JJO ~tn .Gl:ti~ ~J: ~i i r.n ~m:; ~m 1!1~ ~ ~'d _~~ :!iG Iii .... " Ul ~~~ ~i ~ ~ = 01 r= - " ;; Gl J 5;J~ ~~~