HomeMy WebLinkAbout07-09-04
IN RE: ESTATE OF
ROBERT M. MUMMA,
Deceased
lN THE COURT OF COMMON PLEAS
OF CUMBERLAND COUNTY, PENNSYLV ANIA
ORPHANS' COURT DIVISION
NO. 21-86-398
PLAINTIFF'S ANSWER TO PETITION TO WITHDRAW
I. Admitted in part and denied in part. Miller Lipsitt entered into a contract to provide legal
services for several entities at agreed upon fixed fees. This agreement was entered into in October
2003.
2. Admitted.
3. Admitted in part and denied in part. Disputes arose over the reasonableness of
Petitioner's efforts and capability to provide the services after Chadwick 0.. Bogar removed
himself from the cases and attempted to "subcontract" the work to the other attorneys.
4. Admitted in part and denied in part. Plaintiff is unsure of Miller Lipsitt's poslion and the
position of Kennedy Bogar, Chadwick O. Bogar and Bradley Schutjer. :.
5. Denied.
6. Denied.
7. Denied. Plaintiff's efforts will be severally impacted.
NEW MATTER
Plaintiff incorporates 1-7.
8. In late May 2004, Bradley Schutjer informed Plaintiff that James Miller of Miller Lipsitt
had terminated both he and Bogar.
9. Plaintiff instructed that the files for his matters be kept in Plaintiff's offices, and
demanded a list of all outstanding matters and the current status of the cases.
10. Plaintiff contacted James Miller who denied that he had terminated Schutjer or Bogar.
That they had left his firm and he would not be able to provide the legal services without
replacement help.
11. James Miller agreed that no monies were outstanding to Miller Lipsitt.
12. Petitioners Bogar and Schutjer are not acting on behalf of Miller Lipsitt.
13. Petitioner Bogar and Schutjer have determined that the legal services contract is a burden
on them, and against the personal interests of Bogar.
14. Bogar is attempting to disrupt Plaintiff's cases because he had determined that he will
personally benefit from this disruption.
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WHEREFORE, Plaintiff respectfully requests that the Petition be denied and that Miller Lipsitt be
required to honor the legal services contract, and that Bogar and Schutjer cooperate in the effort to
replace them as counsel.
Respectfully Submitted,
Robert M. Mumma, II
6880 SE Harbor Circle
Stuart, FL 37996-1968
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IN RE: ESTATE OF
ROBERT M. MUMMA,
Deceased
IN THE COURT OF COMMON PLEAS
OF CUMBERLAND COUNTY, PENNSYLVANIA
ORPHANS' COURT DIVISION
NO. 21-86-398
CERTIFICATE OF SERVICE
AND NOW, this 8th day of July, 2004, 1 Robert M. Mumma, II hereby certifY that 1 this
day served the within answer by depositing copies of same in the United States mail,
postage prepaid, addressed as follows:
Chadwick O. Bogar, Esq.
P.O. Box 959
Camp Hill, PA 17001-0959
Ivo V. Otto, III, Esq.
10 East High Street
Carlisle, PA 17013
Brady L. Green, Esq.
1701 Market Street
Philadelphia, PA 19103
Robert M. Mumma, II
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