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IN THE COURT OF COMMON PLEAS
OF CUMBERLAND COUNTY, PENNSYL VANIA
IN RE ESTATE OF
ROBERT M. MUMMA
ORPHAN'S COURT DIVISION
Deceased.
NO. 21-86-398
Witness and Exhibit List
AND NOW, pursuant to this Court's Order of March 24,2004, Robert M.
Mumma, II (hereinafter "Objector"), provides the following Witness and Exhibit List.
Objector reserves the right to supplement this list as discovery proceeds:
Witness:
I. Jonathan M. Crist, Esq. (J.D., LLM-Taxation)
2. Susan Stott, Stott & Stott
3. Robert M. Mumma, II
4. Barbara Mck. Mumma
5. Lisa Morgan -
. ~-'
-....,
6. Scott Morgan
7. George W Hadley
8. David Landrey
9. E. Joseph Hochreiter
10. Representative(s) of the Department of Revenue
II. Donald Cromwell, Dauphin Deposit Bank
12. Barbara Mann Mumma
13. Linda Roth
14. Any and all employees, agents or representatives of Morgan Lewis & Bockius
identified or to be identified during discovery in this matter as having provided
services to the Estate or Marital Trust
15. Any and all employees, agents or representatives of Stanley, Ronon, Stevens &
Young identified or to be identified during discovery in this matter as having
provided services to the Estate or Marital Trust
Exhibits:
I. Pennsylvania Inventory Form.
2. Federal Estate Tax Return Form 706 wi Attachments.
3. Pa Inheritance Tax Return wI Attachments.
4. All documents attached to the Expert Report provided by Objector.
5. Closing Letter with all Attachments (Re: Change of Federal Return).
6. Documents from Department of Revenue (Re: Changes to Pa.
Inheritance Tax Return).
7. July 17, 1987 Memo regarding misfiling of Estate Tax Return.
8. Any and all share books and records for various corporations in which the Estate
has or had an interest.
9. Documents from Dauphin Deposit Bank evidencing entry into decedent's Safe
Deposit Box No. 3332.
10. Depositions, filings and exhibits from Robert M. Mumma II v. Dauphin Deposit
Bank and Trust Company, No. 4753-S-1993 (Dauphin County).
II. Pa. Revenue Form 485 - Safe Deposit Box Inventory Filed With Pa.
Department of Revenue.
12. Federal and State Fiduciary Income Tax Returns for the Estate (All Years).
13. April 27, 1989 Memorandum from David Landrey of Stanley, Ronon, Stevens &
Young.
14. Morgan Lewis & Bockius Invoices for Services Rendered to both the Estate and
Marital Trust.
15. Stanley, Ronon, Stevens & Young Invoices for services rendered to both the
Estate and Marital Trust.
16. Depositions, filings and exhibits from, Robert M. Mumma, II v. CRR, pic., et al.
No. 99-1546 (Cumberland County)
17. Depositions, filings and exhibits from High-Spec, Inc., et ai v. Robert M. Mumma,
et ai. litigation filed in Florida.
18. Any and all documents evidencing the transfer, sale or liquidation of any assets
owned by, controlled by or allegedly owned or controlled by the Estate or Martial
Trust including those documents which are produced during discovery in this
matter.
19. Any and all depositions, filings and exhibits from any litigation in which the
Estate, the Marital Trust, or any beneficiary of the Estate or Trust is a party.
Respectfully submitted,
Dated OS/:n JrY-j
By
MILLER LIPSITT LLC
t~-
r ey . Schutjer
Attorney J.D. No.: 75954
P.O. Box 959
Camp Hill, PA 17001
(717) 909-5921
CERTIFICATE OF SERVICE
The undersigned hereby certifies that on this date a true and correct copy of the
Witness and Exhibit List was served via first class United States mail, postage pre-paid
upon the following:
Ivo V. Otto, Esquire
Martson Deardorff Williams & Otto
Ten East High Street
Carlisle, PA 17013
Joseph A O'Connor, Jr., Esquire
Brady L. Green, Esquire
Morgan, Lewis & Bockius, LLP
1701 Market Street
Philadelphia, PA 19103-2921
Date:~~~
By: