HomeMy WebLinkAbout11-21-03
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IN THE COURT OF COMMON PLEAS
OF CUMBERLAND COUNTY, PENNSYLVANIA
IN RE ESTATE OF
ROBERT M. MUMMA
ORPHAN'S COURT DIVlSION
Deceased.
NO. 21-86-398
MOTION FOR HEARING ON peTITION FOR REMOV AIr-
AND NOW, comes Robert M. Mumma II, by and through his counSel, MILLER
upsm LLC, and files this Motion for Hearing on Petition for Removal and, in support
thereof, states:
1. On or about May 14, 2003, Robert M. Mumma II filed a petition for
removal of Barbara McK. Mumma and Lisa M. Morgan as executrixes and!trustees in
the above-captioned matter.
2. On or about May 16, 2003, this Honorable Court ordered Barbara McK.
Mumma and Lisa M. Morgan to show cause within 60 days why they should not be
removed as executrixes and trustees in the above-captioned matter.
3. On or about July 28, 2003, Barbara McK. Mumma and Lisa M. Morgan
filed an untimely answer to Robert M. Mumma II' spetition seeking their removal as
executrixes and trustees in the above-captioned matter.
4. On or about August 19, 2003, Robert M.Mumma II filed an answer to
Barbara McK. Mumma and Lisa M. Morgan's new matter.
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5. Based on the foregoing, Robert M. Mumma II's petition for removal of
Barbara McK. Mumma and Lisa M. Morgan as executrixes and trustees in the above-
captioned matter is ready to be heard.
WHEREFORE, Robert M. Mumma II respectfully requests that this Honorable
Court fix a time for a hearing on his Motion for Removal of Barbara McK. Mumma and
Lisa M. Morgan as Executrixes and Trustees.
Respectfully submitted,
MILLER LIPSnT LLC
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Chadwick O. Bogar
Attorney I.D. No.: 83755
Bradley A. Schutjer
Attorney I.D. No.: 15954
2157 Market Street
Camp Hill, P A 17011
(717) 737-6400
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CERTIFICATE OF SERVICE
The undersigned hereby certifies that on this date a true and correct copy of the
foregoing was served via first class United States mail, postage pre-paid upon the
following:
Ivo V. Otto, III, Esquire
Martson Deardorff Williams -&Otto
Ten East High Street
Carlisle, P A 17013
Joseph A. O'Connor, Jr., Esquire
Brady L. Green, Esquire
Morgan, Lewis & Bockius, LLP
1701 Market Street
Philadelphia, PA 19103-2921
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