HomeMy WebLinkAbout10-24-05
."
Robert M. Mumma, II
BoxE
Bowmansdale, P A 17008
r-..>
C::1
,-~-.
c...-'
,~-')
--.-_....
, ,
Pro Se
IN RE: ESTATE OF
ROBERT M. MUMMA, deceased
IN mE COURT OF COMMON PLEAS
CUMBERLANDCOUNT~
PENNSYL VANIA
ORPHANS' COURT DIVISION
No. 21-86-398
MOTION FOR RECONSIDERATION
AND NOW, comes the Beneficiary, Robert M. Mumma, II, pro se, and files this Motion
for Reconsideration of the Court's order of October 10,2005, and in SUpport thereof avers the
following:
1. Upon the recommendations of Auditor Taylor P. Andrews, Esquire, this Court
issued an order on October 10, 2005, with regard to discovery pertaining to the Objections that
have been filed to the Accounts filed in this matter.
2. Specifically, all documents, records, and other materials in response to the
discovery requests of Robert M. Mumma, II are to be made available by Executrices/Trustees by
November 7, 2005, and then inSpected and copied by all Objectors by December 12,2005.
3. The documents, records, and other materials that have already been requested by
Robert M. Mumma, II span decades of work on the estate from 1986 until present.
4. A portion of the documents, records, and other materials requested by Robert M.
Mumma, II have akeady been made avaHable, but bave sub<equently been commingled with jJ.~
other documents that were not previously produced. ~
.
(=l
f'..::
.'
5. The sheer size of the amount of documents is extensive, and the fact that
documents previously produced have been commingled with other documents will delay the task
of inspecting and copying the new records and documents.
6. Many of the documents and other discovery materials are located at the offices of
Morgan, Lewis & Bockius in Philadelphia, Pennsylvania. In order to inspect and copy these
materials, a minimum of four hours drive time is necessary to travel from Harrisburg to
Philadelphia and back again.
7. Morgan, Lewis & Bockius maintains local offices in the Harrisburg area. Simply
transferring the requested documents to these offices would greatly eliminate much of the travel
time involved in regard to inspecting and copying these documents.
8. Due to business responsibilities, Robert M. Mumma, II does not have the time or
resources to devote a full-time commitment to inspecting and copying the new records and
documents.
9. For the above reasons, the December 12,2005 deadline to inspect and copy the
documents and records is unreasonable and should be reconsidered.
WHEREFORE, Robert M. Mumma, II respectfully requests that this Court reconsider the
Order of October 10,2005, and extend the period to inspect and copy the documents, records,
and other materials pursuant to the discovery requests and production for a period not less than
120 days from the December 12,2005 date of the Order.
RESPECTFULL Y SUBMITTED,
Filed: October 21,2005
te/ltt ~~J7-
Robert M. Mumma, II
BoxE
Bowmansdale, P A 17008
Pro Se
."
CERTIFICATE OF SERVICE
I, ROBERT M. MU1\1MA, II, hereby certify that on October 21,2005, I served a true and
correct copy of the foregoing Motion for Reconsideration by first class mail, postage prepaid
upon the following addresses:
The Honorable 1. Wesley Oler, Jr.
Cumberland County Courthouse
One Courthouse Square
Carlisle,PA 17013
(hand-delivery)
Taylor P. Andrews, Esquire, Auditor
Andrews & Johnson Law Offices
78 West Pomfret Street
Carlisle, PAl 70 1 3
Joseph A. O'Connor, Jr., Esquire
Brady L. Green, Esquire
Morgan, Lewis & Bockius, LLP
1701 Market Street
Philadelphia, PAl 9103
Ivo V. Otto, III, Esquire
Martson, Deardorff, Williams & Otto
Ten East High Street
Carlisle, P A 17013
Ralph A. Jacobs, Esquire
Ralph A. Jacobs & Associates LLC
215 South Broad Street, 10th Floor
Philadelphia, PA 19107
Date: October 21,2005
74jr'j), ~~ir
Robert M. Mumma, II
.,'
'.
IN RE: ESTATE OF
ROBERT M. MUMMA, deceased
IN THE COURT OF COMMON PLEAS
CUMBERLAND COUNTY,
PENNSYLVANIA
ORPHANS' COURT DIVISION
No. 21-86-398
ORDER
AND NOW, this _ day of
, 2005, upon consideration of the
Motion for Reconsideration by the Beneficiary Robert M. Mumma, II, it is hereby ordered that
the October 10, 2005 Order by this Court be amended as follows:
All documents, records, and other materials that are made available by
Executrices/Trustees in response to the discovery requests of Robert M. Mumma, II shall be
made available by November 7, 2005, and shall be inspected and copied by all Objectors by
, 20_. Counsel for the Executrices/Trustees shall provide the
Auditor with a detailed list of the documents and records that are made available.
Robert M. Mumma, II's response to any objections to the discovery shall be filed with
the Clerk of Orphan's Court by
, 20_ with copies to the Auditor and
all counseL The response shall be specific to each objection and shall include legal authorities
and written argument.
BY THE COURT
J Wesley Oler, Jr., Judge