HomeMy WebLinkAbout05-31-05
INRE:
MILDRED J. GERBER TRUST
Dated: December 19, 1997
IN THE COURT OF COMMON PLEAS OF
CUMBERLAND COUNTY OF PENNSYLVANIA
ORPHAN'S COURT DIVISION
IN RE:
FRED E. GERBER, SR. TRUST
Dated: July 29, 1994
NO. 21-2002-0540
NO. 21-1998-0195
PETITION FOR DISCOVERY
AND NOW, comes Frederick E. Gerber, II, by and through his attorney, Lindsay D.
Baird, Esquire, and respectfully avers:
1. A status conference with Auditor Duncan was held on May 19, 2005.
2. Although the order is pending, the parties agreed to an extension of discovery to
June 20,2005.
3. Marilyn Gerber purports knowing of petitioner's hiding assets and commingling
trust funds as well as seeking documents for review by an expert.
4. Petitioner requests the production of:
A. Any documents, books, statements or any other tangible things Marilyn
Gerber has in support of her claim of hidden assets,
B. Any documents, books, statements or any other tangible things Marilyn
Gerber has in support of her claim of commingled funds.
C. The curriculum vitae of any or all experts Marilyn Gerber plans to utilize
for review of documents and/or present for testimony.
WHEREFORE, your Petitioner respectfully requests that Auditor Duncan grant this
petition and enter an order in the nature of the attached.
--""-? /"
Date: .5'-.) / dj
ectfully submitted,.)
~ "dW,;J~,~
indsay D. B~ird, Esquire -:-
37 South Hanover Street c..'
Carlisle, PA 17013
For Frederick E. Gerber, II
(.' "!
uR
I verify that to the best of my knowledge and belief, the statements in the foregoing document
are true and correct. I understand that false statements herein are made subject to the
penalties of 18 PaCS 94904 relating to unsworn falsification to authorities.
CERTIFICATE OF SERVICE
I hereby certify that on this S ~~y of May, 2005, I have caused a true copy of
the foregoing to be delivered by first class mail or in person to:
William A. Duncan, Esquire
One Irvine Row
Carlisle, PA 17013
Jacqueline M. Verney, Esquire
44 South Hanover Street
Carlisle, PA 17013
Richard Rupp, Esquire
355 N. 21st Street
Camp Hill, PA 17011
Marilyn Gerber
717 Market Street
Lemoyne, PA 17043
/..~ (
.<,J " ~//)
.., .. \ ~
" .tc-tl~I2<<,' . 1.~I
indsay Oar Bird, Es uire ---..
'--../ 37 South Ha over Street
Carlisle, PA 17013
Attorney for Frederick E. Gerber, II