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INRE:
MILDRED J. GERBER TRUST
UNDER AGREEMENT DATED
DECEMBER 19, 1997
: IN THE COURT OF COMMON PLEAS OF
: CUMBERLAND COUNTY, PENNSYLVANIA
: ORPHANS' COURT DIVISION
: NO. 21-2002-0540
INRE:
FRED E. GERBER, SR. TRUST : NO. 21-1998-0195
UNDER AGREEMENT DATED
JULY 29, 1994
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PETITION TO EXTEND DISCOVERY
AND NOW, comes, Jacqueline M. Verney, Esquire, Objector in the above
captioned matters and files this Petition to Extend Discovery and in support thereof avers
the following:
1. Production of Documents in the above captioned matters was to be
concluded on or before May 16,2005.
2. Accountant requires additional time to respond to Objector's request for
the following Production of Documents:
A. Copies of Margin Account Agreements with Charles Schwab.
B. Billable hours of all counsel listed as payees in all of the Accounts filed to
date.
C. Copies of Notes evidencing loans to family members.
D. Consents of all beneficiaries to distributionslloans to beneficiaries.
E. Income/expense ledgers for Baltimore property.
F. Any and all documents evidencing the sale of the Baltimore property
(sales agreement, HUD-l, etc.)
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G. All investment company documents not previously provided where Trust
assets were invested (Salomon Brothers, Equiserve, municipal
funds/accounts, Nuveen, etc.)
3. Objector requests leave to designate an expert witness following close of
discovery .
WHEREFORE Objector requests the Auditor to enter an Order in the form as
attached.
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acq eline M. Verney, E~;r~O
44 S. Hanover Street
Carlisle, PA 17013
Objector by Order of Court
Dated June 27, 2003
VERIFICATION
I verify that the facts included in the within pleading are true and correct based on
information known to me or received from reliable sources. I understand that false
statements herein are made subject to the penalties of 18 Pa. C. S.A. ~ 4904 relating to
Unsworn falsification to authorities.
Dated: S- - '^- tf - 6 S--
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CERTIFICATE OF SERVICE
I, Jacqueline M. Verney, Esquire, hereby certify that a true and correct copy of the
attached was served upon the following on the date indicated by placing the same in US
mail, first class, postage prepaid.
Richard C. Rupp, Esquire
355 N. 21 sl Street Suite 205
Camp Hill, P A 17011
Lindsay D. Baird, Esquire
37 S. Hanover Street
Carlisle, PA 17013
Marilyn Gerber
717 Market Street, #317
Lemoyne, PA 17043
William A. Duncan, Esquire
I Irvine Row
Carlisle, PA 17013
Date: b-;)..'-f--o~-
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ac line M. Verney, Esquire #2316~
44 South Hanover Street
Carlisle, P A 17013
(717) 243-9190
Objector