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HomeMy WebLinkAbout94-00508 No 21 - 94 - 508 . Estate of John I!~. Eberle , Deceased DECREE OF PRODA TE AND GRANT OF LETTERS AND NOW JUNE 8. 19..2.L, In consideration of the petition on the reverse side hereof, satisfactory proof having been presented before me, IT IS DECREED that the Instru'11ent(s) dated ;Iune 18,1986 ilnd June 22,1989 described therein be admllled to probate and filed of record as the last will of .1ohn E. Eberle and Lellers TeA tamentary are hereby granted to Ruth N. Eberle FEES Probate, Letters, Etc. ".'"." $ 40,00 Short Certlflcates(5) ...... .... $ 15.00 _ Rmunflation ",..""""." $ ~oa ell 10. 50 X-Pages $ 21.00 JCP TOTAL -- $ 5 aa Filed ,. ~.U.~~, ~,., .1 ~~.4" '.' , , . , . . !l1: 50.. , /rJ' I?r . ,;('v/~' U. '){A...l.)JJ7.C~ Reline' of II. MARY C. LEWI S Henry W, Rhoads U07240 ATTORNEY (Sup. Ct, 1.0, No.) Rhoads & Sinon P.O. Box 1146. Harrisbura, PA 17108- ADDRESS 114 6 (717) 233-5731 PHONE 1'- '1'.- "j ~ I, I ':i~ ,., " r,: c, 0 : ,., I ;,:~i , , , ."2 (.1: " i.: U. PI '::> Gu ,Mailed letters and order to attorney on June 8. '994 . ' .' ~~f JliU mtb QJ:~$htm~ttf oJ JOHN E. EBERLE I, JOHN E. EBERLE, a legal resident of Cumberland County, Pennsylva- nia, revoke all prior Wills or Codicils and make this Last Will. ARTICLE 1 1.1) I appoint as Executor, without bond, my wife RUTH N. EBERLE. Upon her failure to qualify or the termination of such duties then my son DAVID O. EBERLE and my daughter KAREN A. EBERLE shall be substituted as Executors, also w1thout bondl or if either one fails to qualify or becomes incapacitated, resigns or dies then the surviving child shall continue as sole Executor. 1.2) Notwithstanding the provisions of Article 1.1), if my wife survives me and could qualify as Executor but decides that such office could be filled better by a corporate executor then she may decline and DAUPHIN DEPOSIT BANK AND TRUST COMPANY, Harrisburg, Pen- nsylvania shall be substituted as Executoq or, if my wife fails to survive me, or survives but fails to complete her duties as Executor, and my children or one of them could qualify as substituted Executor (s) but decllne for any reason or become incapacitated, resign or die before one of them completes the duti~s of such office, then said bank shall thereupon become substituted Executor. ARTICLE 2 2.1) Except as may otherwise be directed in a written memoran- dum signed, by me, I give and bequeath to my wife RUTH N. EBERLE, if she survives me by sixty days, all of my tangible personal property and personal effects and all insurance policies thereon, with the request that she distribute such items that she does not desire or need among our two children. 2.2) I further give and bequeath to my wife all of my house- hold furniture and furnishings located in our home at 617 Allen Street, New Cumberland, Pennsylvania 17070, or in such other home in Page One ~ Pennsylvania that we may occupy at my death, if she survives me by sixty days. 2.3) I make no bequest of the furniture and furnishings in our winter residenoe at 144 Regent's court, Melbourne, Florida 32940 as all of such items are already owned by my said wife. 2.4) If my wife fails to survive me or dies within sixty days of my death, then all property described in Article 2.1), 2.2) and 2.3) is hereby devised in equal shares to our two children, or if either is deceased then to his or her issue per stirpes, or if none then to the surviving child, exoept as may otherwise be direoted in sai~ written memorandum signed by me. ARTICLE 3 3.1) All death taxes upon or in relation to any of my property, whether passing under this Will or otherwise, as well as debts and expenses of aUroinistration shall be paid out of my probate assets, elccept tangible personal property, without repayuent or reimbursement by any beneficiary or recipient! if such assets are insufficient therefor my executor may call upon the trustee of a hereinafter ~entioned trust for the sums needed. 3.2) Notwithstanding the provisions of Article 3.1) above, if any Qualified Terminal Interest Property passing under my wife's Trust or Will is included as a part of my taxable estate by reason of my life income from such QTIP assets, then I direct that the share of my taxes applicable to such QTIP assets shall be paid therefrom rather than from my own probate or trust assets. 3.3) My exeoutor shall file with Internal Revenue Servioe an eleotion to have such marital share treated as Qualified Terminal Interest Property for the marital deduction for Federal Estate Tax purposes, EXCEPT if in the judgment of my executor there would be more than nominal savings for the estates of myself and my wife to eleot to have less than all of the marital share treated as Qualified Terminal Interest Property then said executor may file the election as to only a specific portion of suoh marital share. If such election could more properly be made by my Page Two 'fY - executor joining therein with the trustee of my trust desoribed in A~ticle S.l) said executor shall do SOl or, my executor may author- ize such election and filing by vaid trustee alone if under the then applicable provisions of the Internal Revenue Code such procedures can effectively be made by said trustee. ARTICLE 4 4.1) In addition or supplemental to the powers provided by law, aD amended, my executor in the prudent exercise of discretion and good judgment, and without order of court, may: A. Sell, at public or private sale, or option, any property for cash or upon reasonable terms and security/ and, execute leases on any trust property upon such terms and conditions and for such peri- ods of time as trustee deems proper and desirable. B. Invest in all forms of property (including, rut not by way of limitation) real estate, all types of stocks, bonds, options and money market accounts without being confined to investments pre- scribed by statute, and without being required to have the extensive diversification that otherwise may be usual or customary for trusts of this size. And, Common Trust Funds maintained by my corporate executor may also be invested in except that any fund of equities (common stocks or similar securities without fixed dividends) may be purchased only for a trust, or trust share, having a total fair market value of less than Four Hundred Thousand Dollars. C. Place securities in a margin or brokerage account and main- tain money-market accounts upon which checks or drafts may be drawn. D. Delegate trading authorization to investment advisors, brokers or agents and authorize them to sell and reinvest any assets on a discretionary basisl and pay reasonable compensation therefor. E. Borrow money from the commercial department of my corporate executoror others, upon reasonable terms, and mortgage, hypothecate or pledge assets as security therefor, including short selling and contracts for the future delivery of any security. F. Enforce or compromise claims against othersl and, settle or Page Three ~ , . ~ , , .. pay demands that executor deems proper. G. Manage, repair or improve probate assets. H. Execute and deliver such instruments as may be necessary to effect all duties and undertakings herein. I. Employ lawyers, accountants, agents or other assistants necessary to the proper administration hereof, and pay reasonable compensation for such services. J. Vote and otherwise exercise all rights and options incident to the ownership of stocks, bonds and other securities and hold title in the name of a nominee. K. Purchase property from anyone, including a beneficiary, at a price and upon terms determined by executor to be fair. L. Pay premiums on any type of insurance policies retained or purchased herein, and exercise any rights thereunder. M. Open checking and savings accounts, make deposits therein, and draw checks or other debits against such accounts. N. Distribute assets in cash or kind or partly in each. O. Retain assets already a part of my probate estate, PROVIDED HOWEVER, that inasmuch as more than sixty peroent of my present total assets consiat of common shares in AMP, Inc. (including AMP, Inc. "endorsed common shares") a Delaware corporation having its principal place of business in Harrisburg, Pennsylvania, I urge, but do not direct, that my executor proceed in an orderly but not precipitous manner to sell such part or all of said shares that may be among my probate assets so that, when combined with the remaining shares in the hereinafter mentioned trust, the total thereof will have been re- duced by at least fifty percent. This request is made, not because of my lack of faith in the continued growth of AMP, Inc. with which I have been associated for forty years, but in recognition of the fact that sales can be made after my death without large capital gain taxes to assure funds for more diverse investments and to provide liquidity in my estate and cash needed to pay at least part of the withdrawals to which my children become entitled under said trust. Page Four ~ ARTICLE 5 ';' ' 't,' ';1, " 5.1) I devise and bequeath the residue of my probate estate to DAUPHIN DEPOSIT BANK AND TRUST COf.lPANY, Harrisburg, Pennsylvania l7lQS, as successor trustee to be added to the trust created by me , ~, I i',' as Settlor .~ith myself as 'fruotee, said Trust Agreenlent being dated ~/I , 1986, or as the same may be amended at the date of my death. WITNESS my hand and seal this ~ /8 day of , 1986. ~t',~ JOHN E. EBERLE, Testator We, the undersigned witnesses, hereby certify that the foregoing Will was willingly signed, sealed, pUblished and declared by the above-named Testator as and for his Last Will and Testament, in the prose nee of us, who, at his request and in his presence and in the presence of each other, have hereunto set our hands and seals the day and year first abov~ wri ~ten, and we certify that at the time of the execution thereof, the said Testator was of sound and disposing mind and memory. ~(/. ~L-. (SEAL) Residing at/I'I! ;It(;itm( r;-~ eM ~ I ~d:t." ,. r:(.t;~? _ / (SEAL) LlSiding atl!/..O , .-1. ~0t;t-r<~ COMMONWEALTH OF PENNSYLVANIA) We, JOHN E. EBERLE,.f. P 7>u!Jv COUNTY OF DAUPHIN ) and _ 71. It!..r<. A a..1 L-1;l , the Testat.or and the witnesses respectively, whose names e.re signed to the foregoing instrument, being duly qualified according to law, do depose and say that we were present and saw the Testator sign and execute the instrument as his Last WillI that the Testator signed willingly and executed it as his free and voluntary act for the pur- poses therein expressed I that each sUbscribing witness in the hearing and sight of the Testator signed the Will as witnessesl and that to the best of our knowledge the Testator was at that time eighteen or more years of age, of sound mind and under no constraint or undue ~~, W ness , ~~.~ JOHN E. EBERLE, Testator-- (SEAL) '~'" Wit.ne S BSCRIBED AND SWORN to Commonwealth and County before.~p, a Notar~ Public in and for said thi s .i..1r.- day of ~; Jce:.-- , 1986. L;,~~ttr~~~>~~ / M^RY ^tltl MIOU~Sntl. t1lJ1ARY 1'1IULlC MJ' ~()I1,!l1i,,: Orl' 'lIlli''; Orlobl'l JO, H)8G ",,'llhUlI:,I'^ II.,uphll,CoUIIIY ~ Page Five . ... ).,\ :J\ i. 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' " "I, " ,.<, 'I" ;,':' , '.:' ~,_, I " " ,*~ ~ lj ~~ I~U "~d ~(t~ l'tI 'jJ ~,J lW~ I~ \~': , l 'i ~ , r~) . ,\,'1.:/ ,.'1' I', ';':':,::' 'I", ,._,0 , ":/i::'('::i(:' . Ii ' '11:,[, .1:"i"" " , "" i ":;~. '.'1/ .,,' I; ,1'., "I" .I,': ,';',11 1(,' " .. ;11' i, ''',i'' , '-"\' f', '" ,I, , , ) ! 'I" .' ' " ~j" " 'I, ,\_,,;1, I,,:" ~:. ,"", \ ' '" I'i' Il"f "" "~i' ";.,,.., ..,' '1",1; " 'I: '. li.'\ f'l; . .. ,-,\ COMMONWEALTH OF PENNSYLVANIA I. COUNTY OF C~hfIflb\NO , J -:cJL<t"P' ;,c.._ RUTH N. 1\IlERLE ('0 . "' b.lng dulV sworn .ccording to I.w, d,poltl 'ood "VI th.t she j s Exceu t rlx of the Elt.t. 0' John E, Eberle I.t. 0' __ .N~_Cumluu:J.uLld..- ,__ __'_'_ , Cumb..l.nd County, P.., d.ctt..rl .nd thtt the within Is.n Inv.ntorv m.d. bV her ,__ ___, the uld Executrix 01 the .nli.. "I.t. of uid d.c.d.nt, conliltlng of .11 the pmonll p,op.,tv .nd rtal tlt.to, '"C.pt ...1 tlt.t. ouhid. th. Commonwttlth at P~"n'I'I.'MI., .nd th.t the figu,,, oppollt. .uh it.m al the Inv.ntory ..pr.unt iI's I.ir v.lu. U 01 th. dal. 0' dH' I" .,', da.tl.. SWORN '1 l-a ku<-",/ I~ r)e-7L," ;1 . ,J2u,o/-./..- '.' .r,u IUbIC,lb.d b,'or. m., I f (?b' '.-19'~ ~ dr..rJ ~~ ' /' t....I.. ~"".J~P'l (~ uth N. Eber~~~cu ~ c/o Rhoads & Sinon NtYr hlh\t SU\1. YVON~IF H: rll.Hlfl.'\~11. 1"')!<1I"'/ rlltllir. IbHl'.111Uf\1 [1'101\.lill\ Crlllnll ~1tG:2!.I.~r~':'_."'"" ;", I, Il.I:/.L..!:~2Z- P.O. Box 1146. Harrlsbur~. PA 17108-1146 "'~~"" D.t. 0' D..th 21 0., 05 M.,th 94 y.., INSTRUCTIONS I. An In..ntory mUlt b. 'i1.d withIn thll. month I ./t.r .ppolntm.nt 0' perlon.1 r.prtl.ntttl.., 2. A luppl.m.nt Inv.ntory mUll b. fiI.d within thirty d.V' 0' dllcovtry 0' .ddltlon.1 tI..h. 3. Addltlonolsh..h m.v b. .tt.eh.d tI to ptrlon.lly or r..lty ~, 5.. Artlcl. IV, Flduci.ritl Act 0' 1949. ~ -d w " . .. 00 ~ 3 ~ . w '" ~ 0 ... ~ ... .. '" 0 \.< ~ 0 0 w ., C ... I :t '" ... III ~ % 110 t.J .Q . 0 oj I'" ..I II. o:l ~ . ~ '" ~ 0 t.J 0. 0 I II. ..I :: W 0 ~ u ... > or: . .:. 0( N t.J ) .. Z 0 C III 0 ~ :!: ~ - l'l ~ 0 0 U .... % w 0 110 ., , - ~ 0 ~ ~ .A .,. oil ~ E . 0 .. ~ if 0 . ... U III cfJ-' .;l.i'!i -/6 .. r-.. "....... In, lory of the real and personal eslato o. . JOHN E. E8ERLE deceased 1. 1982 Hercedes Dsnz 30011 wi th VIN IIWDBAB33A9CB004298 5,200 00 1,1" , " " " " , " , , ,,' 'f; ",' '~~ t5\. :n:J:I " <)'8 ,,' l.o:J, ..., ,\~:. : ' rn "" ~J. lV '.;;;' n, ... I..l. , I",. ::l ..' ~ ,.) (' , c;..' .. h .~, b/': .-0 :;;./ .....\' ~ ~) -- iifo t..' ~~ ff, .... " , ,,: " " , " , " "; ...' , ~V.l!l47 EX AFP 112.94* C~AITH ~ PEHHSVIYANIA DEPARTHEHT Of REYENUE IUREAU Of INDIYIDUAI TAMES DEPI. 110601 IWllUII_. PA lIlla-am fSTAT! OF EBERLE = :JDirN FILE NO. DAT! OF DEATH 05-21-94 COUNTY CUMBljRLAND NOTE I TO INSURE PROPER CREOIT TO YOUR ACCOUNT, SUBHIT TNE UPPER PORTION OF TNIS FORH WUH YOUR TAM PAYHENT TO THE REGISTER OF WILLS. HAMe CtlECK PAVABLE TO "REGISTER OF WILLS, AGENT" REMIT PAVMENT TO: . ~- /,13-2.., ;1./, )(5-'/~ NOTICE OF INtlERITANCE TAR APPRAISEHENT, ALLOWANCE OR OISALLOWANCE OF OEOUCTIONS ANO ASSESSHENT OF TAM ACN HENRY W RHOADS ESQ 1 S MARKET SQ PO BOX 1146 HBG PA 1710S 7- \~tl/ 101 DAT! 05-08-95 REGISTER OF WILLS CUMBERLAND CO COURT HOUSE CARLISLE, PA 17013 r-- ^~ount Ro~lttod CUT ALONG THIS LINE ... RETAIN LOWER ,"ORTION FOR YOUR RECORDS ..... iiilj: i5cii "Eif"AFpUn'F94Y-NOTicr-op" iNHEiiifANCi"TAX" A"P' iiiiA"isEifiNT~uAr.rOWAiiC!-'b-Rmmmm_u.. DISALLOWANCE OF DEDUCTIONS AND ASSESSMENT OF TAX ESTAT! OF EBERLE JOHN E FILE NO. 21 94-0508 ACN 101 DATE 05-08-95 If an ......m.nt WI' 1..u.d prav1ou.ly, 11n.. 14, 15 and/or 16, 17 .nd 18 will r.fl.ct figure. that 1nolud. th. tot.l of Ahk return. a.....ad to d.t.. ASSESSMENT OF TAX: 1&. A.ount of L1no 14 ot SpoulOl roto (151 16. Aoount of Llno 14 to.oblo ot Llno.l/Cloo. A r.to 1161 17. Aoount of Llno 14 t..oblo .t Collotorol/Cloo. H r.t. 1171 II. Prlnolp.l T.. Ouo TAX CREDITS I PAYHENT OATE 08-17-94 02-21-95 TAX RETURN WAS I (X) ACCEPTEO AS FILEO RESERVATION CONCERNING FUTURE INTEREST . SEE REVERSE APPRAISED VALUE OF RETURN BASED ONI ORIGINAL RETURN 1. Rool E.toto (Schodulo Al (1) 2. stock. and Bond. ISchodulo BI (2) 3. Clo.oly Hold Stock/P.rtnor.hlp Intoro.t ISch.dulo CI ISI 4, Hcrta.ao./Noto. Roool..blo ISoh.dulo 01 (41 5. C..h/Bank Oopo.lt./HI.o. Por.on.l Prcp.rty (Sohodulo E) (51 6. Jointly Ownod Proporty ISch.dule FI (61 7. Tran.f.ro ISohodul. GI (71 B. Totol Au.to APPROVED DEDUCTIDNS AND EXEMPTIONS: 9. Funn.l E.pono../AdJo. Co.to/Hllo. Expen... (Soh.dul. HI (9) 10. Oobt./Horta.ao Llobllltlo./LI.n. ISoh.dulo I) (10) 11. Tot.l Ooduotlon. 12. Not Volu. of T.x Rotu,'n IS. Ch.rlt.blo/Go..rn..ntol B.quo.t. (Soh.dul. J) 14. Not V.luo of E.t.to Subjoot to T.. NOT! I RECEIPT NUHBER MM912831 AA022853 DISCOUNT 1+) ItITEREST I - I 6,842.11 ,00 I CHANGED 00 5 (il,QO Kl .00 00 :.. . ~ .O!l.. I 5.200.00 Ul I . 00 .~, 2, 591. ~4. 39 :,~: :{;..., uut1i . - r--..\ 61.019.19 - 122.366,97 Ill) (12) liS) 1141 .00 R .00. 2,413,378.23 X.06. .00 X .15. UBI AMOUNT PAID 130,000.00 7,960.58 TOTAL TAX CREDIT BALANCE OF TAX DUE INTEREST TOTAL DUE . IF PAID AFTER DATE INDICATED, SEE REVERSE FOR CALCULATION OF ADDITIONAL INTEREST. ,:0 ,Den I,', 1-' , , 2 J;9i~, 764.39 183,386 16 ~.413,378,23 ,00 2,413,378.23 .00 144,802.69 .00 144,802,69 144,802.69 .00 .00 .00 IF TOTAL DUE IS LESS THAN fl, NO PAYHENT IS ~EQUIRED. IF TOTAL DUE IS REFLECTED AS A "CREDIT" IC~), YOU HAY BE OUE A REFUND. SEe REVE~se srDE OF THIS fO~H FO~ INSTRUCTIDHI.I IlEKRYATlOI.. PURPllSI!Of NOTICE' PAYMENT. IlEfl.110 (CRl' OIJECTlIl!CS. AIl!tIN 'ITRATlYE CllARl!CTIIl!CS. OllCllUNT. 'NTEIlEIT. ( "I""~ ,,' " , ' , I E,'It,. of deoldtfth dvlnt on or'~far. Denllbtr 12, 1912". If anv future Int.rllt In thl ..tit. h tran.ftrrtd ' In po.....lon ar .nJoy..nt to CI,.. I (oollllterl1) bln.flal.rl,. of thl dlcld.nt ,H.r thl IlCplr.UcNl of tny IItltt far 11'. or far v..r., the CGlIOnw.llth hereby 'lepr..,lv r...rVI. thl right to appral.. Ind ....,. trln,'.r Inherltanae riM" It the lawful CII.. I (0011It,t.l) tit. on anv 'UGh future lnt.r..t. To fulfill the r.qult..."t. of Slotlon Zl~O of thl Inheritance end E,t,t, rllC Act, Aot 22 of 1991. 72 P.'. '..lIon 21~0. DetlCh the top portion of thh HoUe. and luaU with your ply..nt to thl Rlght,r 0' Willi prlnhd on thl nv,r.. .Ide. ..NII<. ch.ok or .on.. ordor ..,.bl. to. REaISTER OF NILLS, AaENT All Ply"n'. r.oelved .hlll fir.' b, Ippll,d to eny Int.r..t which .IY bl due with any "..Inar IpplI.d to the tllC. A r.fund of . tlM cr.dlt, which WI' not r.qu..t.d on the TIM R.turn, .IV bl reque.t.d by c~l.tlna an "Appllcltlon for R.fund of p.nn.vlvenll Inh1rlt~. Ind Est.t. Tax" (REV-1]1]). Appllcltlon. Ir. IV81lable It thl Offlc, of the R.gI.t.r of Will., In~ of thl 25 Rlvenu. DI.trlct Offlc.., or b~ cllllng the 'PIOI81 l~-hour anlW4rlnt l.rvlol ou.bIr. for for.. orderlngl Jn penn.vlvanl8 1-800"562-2050, out.ldl PlnnlvlYInI. Ind within 10011 H.rrl.burg Ir.1 (717) 787-8094, TOO' (717) 712-2252 (Helrlng JIPllred Only). Anv plrtv In Interllt not "tllfled with thl .,prll"Hnt, .110Manoe or dlllllowanol of deductlone, or ''''lIunt of t'M CJnoludlng dllcount or tnterelt) II .ho"," on thlt Ntltloe ault objlot within sixty (60) d.U 0' rlcelp, of 'hi. MoUoe bVI '''written pro tilt to thl PA D.p.rtHnt of R.Ylnue, laerd 0' Appelll, Dlpt, 281021, Hlrrhburg, PA 17121-1021, OR --.tIOtion to hlVI the 'Ittlr dltllr.lned .t audit of thl IOCrMlt of the perlonll rlprll.ntltlvl, OR ' -~IPP'11 to thl Orphan.' Court. Feo'uel .rror. dlscovlred on thlt ........nt .hould bl Iddr....d In writing tOI PA DIp.rt.tnt of AIV'nue, lur'MI of J~lvldu.1 TIX", ATTNI po.t A"I'I""t Alvlew Unit, Olpt. 210601, Hlrrllburg, PA 17121-0601 Phone (717) 717-6505. S'I Pili 5 0' the bookllt "In.tructlonl for JnhtrltlhO. Tox Rlturn for I A..ldtnt Dtclldlnt" (REV-IS01) far an tMpltn.tlon of ~tnl.trltlv.lv ccrreotibl. trror.. If any tlX due II plldwlthln thr.. CS) oll.nder IOnthl IH.r the d41oldlnt'l dt,th, I flv. p.rclnt CSJO dhclVlt of tM tllC p.ld II .llowed. Jnt.rllt II oh.rged HIIMlnl Mlth first dlV af dellnqu.ncv, cr nlnt (9) aonthl and OM (l) d.V frOll the de'l 0' ,je.th, to thl dlt. of P'V""t. T.~.. Nhloh beo... dlllnquent blfor. J.nulrv I, 1982 bllr Int.r..t .t thl ntl of .IK (6X) peroent p.r ~ olloul.ttd It I dillY rate of .000164. 411 tlICII which biG'" dellnqulnt on'lncllner Jtr'lu.rv 1, 19.2 will bltr Intlrllt It I rltt Mhlch wl11 vlr~ frOll olltnd.r Vllr to ollendlr v..r with that'nte ~td b~ the PA Olplrteent of AIVenu., ThI app1lcabl, Intlrl.t rat.. for 1912 through 1991 Irlt !!!r Int.rllt Altt 0111~ Jnt.r..t Factor ~ Intlrllt R.t. Olllv Int.rl.t Ftctor I'll m ,OOU~I 1917 ,~ .0002~7 1915 161 .000lSI 1911-1991 Il~ .001ll01 19M IIX .001ll01 1992 9~ .000247 1911 ISX .001llS6 I19S-199ol 7X .000192 1916 lOX .00027~ 1995 9~ .0002~7 --lnt.rll' It olloullted II fol1~', IHTERElT . IALANCE OF TAM UNPAID M HUHIER OF DAYS DELINQUENT M DAILY IHTERElT FACTOR --Anv Ma'h. IlIutd 'ftlr thl tlX becOHI delinquent wlU r.fleot '" Int.rllt c.lClul,Uon to flft.", nl) dlYI bt~ond thl dlt. of thl ...."ttnt. l' PIV,,"t I. .~ Iftlr thl Intlr'lt ootpUt.tlon ~tl ,hown on thl Notla., eddltlon.l Interllt IUlt be ollcul.ted. , I . , "'.-, ,i' .' "t, " ~OI' MOllCEl 10 fulfill the roqulrooonl. of ..,llon 114S (b) of the Inherll.... end E.I.I. I.. Aol, AoI II of 1"1. (71 P.I. ..,llon ZI4SI. PAYltEH'lI Dolooh the IlltI porllon of Ihh Noll.. end .uboll vl\h vour p._1 to the MOIhl.r of Willi prlnlld on 111I river.. .lde. -- Hok.._ or -.ov ordor p.vobll 10' AllOllTEI OF MULl, AGENT. All ,Ivant. rlCtlved .hlU be IIPPl1ld flnt to MY lnt.rllt which HY b. due,wlth MY ,....1,..,. ""lied to thl tUI IllEPUIlD (CRI, A refund 0' . II. .rldll IIV bo roquo.lld bv ....I.1I1lfj on ""'plI..llon 'or R.fund 0' Ponn.vlvonl. Inherll..... end E.I.I. I.." lIllEY-lSlSl. Appll..llon. or. ,v'lhbh .t lho Dlfl.. ., lho ROIhlor of Will., ~y of thl !J A.v~ DI.trlot O'flo.. or frOl the oeplrt8lnt'l 24-hour ,"tv.r!nt ..rvl01 nuIbIr. for for.. order!ntl In Penn.vlv,"', 1-100-562.1050, out.lde Penn'vl"lnl. Ind within loc.. Htrr..bur. .r.. (117) 7"-1094, 100. (7171 771-ml (HNrlllll h..lrld DnIVl. DIJECTlllltIl Any p.rty In Int.rut. not "UffIN with the 1..II..."t of tlJ( II Ihown on thh noUee MY obJ"t tdthhl .I.ty ('0) dlv. ., r...lpl of \hI. Noll.. bVI ..wrltten protl.t to the PA Dep.rteent of A.vtnul, laird of Appel.., Dept. 211021, Hlrrl.bur.. PA 1112'-1021, OR .....llMlting to hive the AU.,. Ht.r.lned It ."cUt of thl perlOnll reprllentlUvl, OR --~1 to the Orphenl' Court. 'AIII!IN- 111~ATlI'l! C_CTlDMI, Featuel Irror. dJloav.rld on thll fl....lltlnt Ihould be eddrllnd In wrlU,. tal PA DlplrtMnt af RlYenue, lureeu of tndlvlduel TIXI.. ATTNI po.t A....tllnt Rlvlew Unit, Dlpt. t.0601, Htrrltbur'f PA 171t.-0601, PhoM (717) 717-001. 1M P'" 5 0' thl bookllt "tn.trucUon. 'or tnhlrlbnot TIJC Rlturn for I R..Ie,."t DealChtnt" (~V-1SD1) for en 'Mpl~tJon of IdIlnl.tratlvllv oorraotlbll .rror.. 1N1tRt:IT. For dati' 0' dteth on or .ft.r 10-5-'1, Ptnn.vlvenl. E.tat, 'I. ba.ed Rn the Flder'l Eltlte TaM r.turn bea... dlllnQUent It thl 'Mplr.Uon of nIne (09) ItOnth. frOll thl otl of delth. For dltl' of dtlth prior to 10-5-'1, Penn.vlvtnl, E.tlt. '1M bl.ad on thl Flder.1 e~tatl 'aM r.turn boo_I dollnqu..,1 .1 lho 'Jqllrellon of .1"'1_ lIl) _Ih. fr.. lhe d.l. .f do.th. '1.11 which beo.. delinquent blfor' Jlnutr~ I, 19'2 belr Int.r..t at thl r.tt of It. ('X) pero.,t per enr'UI ..I.ul.lld .1 . dolly r.l. of .000164. All I.... which boO... d.llnquenl on .r .,t.r Jonuorv I, I'll viii bIIr Int.r..t It . rlt. which will varv frOll a.llndtr Yllr to a.l~r v..r with thlt ratl ennounotd bw the PA Dlp8rt.ent of R.vtnUl. The tppllotbll Inter. at rlt.. for 1912 through I'" .rll '!!!!: Intlr..t R.t, O.llw tnt.rl.t FlOtor !!!!' tnter..t Ratl Dlllv tnt.r..t ,..tor - 1"1 lOX .0001<\. 1117 9X .000147 illS . UX ,000411 1'''-1''1 m .000501 1914 m .000501 1"1 'X .000147 1"1 ISX .OOOS" 1"'-1994 7X .0001" 11M lOX .000174 1"1 'X .000147 --tnttr'lt i. allouleted .. follOM.1 INTIRIIT . BALANCE OF TAX UNPAID X NUXIBI OF OAYI DELINqUENT X DAILY INTBRBIT FACTOR --Any Noll.. 11_ .flor the I.. boo.... dollnquenl vm "fllOl on Inlor'.1 ..1.01.lIon I. flIl_ liS) diva boyond 111I dlt. of 111I '.01._1. If PI_I I. _ .lIor the Inll".1 .....I.llon dll. -. on 111I NotJOI, ~ltJontl Int.r..t lU.t be alloul.ted. no ~ :xl ~iii :tl8 -, 01 .' ). eJ' " t!:' ( I ~ ..n ~, IIJ n [, (i: dl , U, ( ~ ~.. , I ( ...;;1 9 ";/. <:'l .l. .. , ::;(v i, CI Vi' :U'- (.oj \J )>;:.+ .... 0\ _Of NOTICE I To fulfJ11 the r,qulr..,ntl of SteUon Zl~S (b) of th_ InherUlnel and Eltltl TIne Act. Act ZZ of 1991. l12 P,S. Slotlon 21ltS), PAlIENT, OItlch thl top portion of thll Hotiol and lubalt with y~ur ply..nt to the Rlgl,',r of Willi printed on the rlVlr'l lid,. ... Hike chick or lonlY order ply'blt tOI REOI8TER OF MILLS, AGENT. All Ply..nt. r.c.I~.d ,hell bt applied flr.t to any Int.r..t which ..y bl dUI with any r'..lnd.r applied to thl tlX. REfUNll ICRl, A r.fund of . tl~ crldlt '.y bt r.quI.tld by cOlplttlnG an "ApplJcatlon for R,fund of Plnntvlvl")' Inh,rltancl end E,tlte Tax" (REV"UU), ApplJclUonl art l\,fellable .t the Offlol of the Alght.r of NUh, eny of the Z] RIYlnue Dhtrlct OffiCII cr frol thl OIPlrt..nt'. 24-hcur anlwlrlng ..rvlet nu.buI for far. I ordlrlOlI tn Plnnlylvanla 1-100-362.2050, out,lde Plnnlylvanla and within local tlarrhburg aria e7l7} 787-1094, TOOl (717) 772-2252 (Heerlng tMp.lr.d Only). OBJECTIONSl Any pertv In lnt.r.,t nat ..tl.flad with the ........nt of taw a. .hown on thl. notice ..y obJ.ct within I1xty (60) day. of r,cllpt of thlt NoUc. bYI --wrJttln protelt to thl PA D,p.rt..nt of Rlw,nu., lIolrd of IpPllh, Olpt, ZAIOU, tterrltburg, PA 17121"1021, OR ",I.otlng to hive th. .attlr d.ter.in.d It audit of the perianal repr..entaUv', OR --Ippe.l to the Orph.nl' Court ADltIN' IIIRATlVE CORRECTIONS I Faotual error, dllcover.d on thl. ........nt Ihould b. addr....d In writing tal PA O.pert..nt of R.vlnue, Bure.u af Indlvldull TIXII, ATTNI Po.t A.......nt R,vlew Unit, O,pt. 2&0601, Herrl.burg, PA 17121-0601, Phone (717) 717-6505. Se, pagl 5 of the bookJ.t "In.truotlons for Inhlritancl T.x R,turn for. RI.ldent Otr.ldlnt" (REY-1501J for an uplanaUon of adlJnhtrttlvlty corrtfltlbl. urot'l. INTEREST, Addltlonll Plnn,YIYlnla E.tat. Tax ~1'1...d a. II rl.ult of . chang. on the Fldlral E,tate Tlx olollng I.tter b.eo... d.llnqulnt et thl Ixplretlon of on. (1) tonth fro. thl dati thl flnel noUe. 0' thl Inor.... In Fldlrel Elt.tl ,.x I, rlelivld. Tax"". which ble... dlllnqllnt b.fore January I, 1912 bur lnter.,t .t thl rite of ,he (6X) ~uclnt pu IMUI (lllcul.tleI .t a dilly ratl of .000164. All text. which blca.. dlllnqulnt on or after JanulrY I, 19ar will bl.r int.r..t at . ratl which will vary fto. calender YI.r to clllndar Ylar with thlt rate announ~ld by th. PA Olpert.,nt of Rlvenul. Thl appllcablt Inttrllt retl' for 198Z through 1996 Irtl 'tw tnt.r.llt Art. 01111\1 Inhr.llt FAlltnr \:ur Int.rallt Rata nallv Inhrallt F.lltllr 198! lOX .00D548 1'87 'X .OOO!OI I'U 16X .0004!8 1981-1991 !IX ,OOOlO! 198' !IX ,000lOI 1992 9% .000247 1915 m .D00556 1993-1994 IX .000192 1.16 lOX ,OOO!7< 1995'1996 9% ,000201 "lntere.t It cllcul.tld II followal INTEREST = BALANCE OF TAX UNPAID X NU"BER OF DAYS DELINQUENT X DAILY INTEREST FACTOR "'Any Notlcl illuld after thl tax b,ool" d,1Jnqu.nt will r.fI,ot an Interllt clloul.tlor! to fift"n (IS) day II beyond the dl" of tM ......-.nt. If pay.ent it .adl .ftlr the Int""t COlputltlon dati .hown on thl NoUn, Idditlonll Inttrut IUlt bCl cllcul.tld. , ( , I I " I .-1' I I " I '\ " ,I , " I' , I " " , " , , I" " :I' ii" , .~.. , " : , , " " , il<' , , " , ,~j ; " ,., :1..' " " " " " '" l'l' " '" " I' " , ' " r~ ,J,. ,',' i', I' \. " I. " \\ ",r' . .,~.. "., '.,... ~~~....., ....... '" " '," ",: ,,;' !\ I' "'I " 'I " " , "\-' !' , " " Ii ft '.. 'f'" "f ',";'.','1-" ''''.. i ;, "Ii' '-f'." ii' I' " -'~ ,:....... " , " "i , ' " " . , " I, " "i' ,i' l' " " ~ ,.' , ;'1 ;'1 " .' , ~~. , ". I" " )' ,I> .' ,I, \ H\ " ! I,; , " 'I , " '.I I I " '" ;11 , ~'\ '~\ ."".,t . , I" ,. 'pi , r i I " ,', , " " , 'ft "I , t .f " , ,'f ,~ I " ." . 0\ " I;' , " ,l "\' " #) ,/', , , ."~ 'j, 1 / . '" ~~ I" .' , '/' " Ii " I', '.-..-1 .,---' I ~ -:-"'~'f"Yi' j I; " ""-::~.--r'~':'."'''''''''''''''c:t~ '!' " ',' I . '':',',:r-,.'. 'JJ , 51111 '.. I IN REI JOHN E. EBERLE TRUST UNDER AGREEMENT I IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA I ORPHANS' COURT DIVISION NO. 508 of 1994 DISCLAIMER AND RENUNCIATION I, Ruth N. Eberle, an Cldult individual of 617 Allen Street, New Cumberland, Pennsylvania, do hereby exercise the rights granted to me under Chapter 62 of the Pennsylvania Probate, Estates and Fiduciaries Code, 20 Pa. C,S.A. ~6201 ~ ~., and 552046 and 2518 of the Internal Revenue Code of 1986, as amended (the "Code"), and hereby irrevocably and absolutely, and without qualification, disclaim and renounce any and all right, title, claim or interest I possess under ARTICLE FOURTH(b) [QTIP Trust No.2] of the John E. Eberle Trust Under Agreement dated June 18, 1986, as amended (hereinafter the "Trust"), including, but not limited to (il all assets, including principal and income, to be held or distributed to me or for my benefit under the provisions of said ARTICLE FOURTH (b) [QTIP Trust No.2] of the Trust; and (ii) the right of my estate to receive any payments or contributions under ARTICLE FOURTH (b) (2) (Al of the Trust. I intend this disclaimer and renunciation to constitute a "qualified disclaimer" under ~2518 of the Code of my entire interest under ARTICLE FOURTH(b) [QTIP Trust No.2] of the Trust. The foregoing disclaimer and renunciation shall not include a disclaimer or renunciation of any other interests passing to me under the Trust, or as a consequence of the death of John E. v" " HI,.."'- W "HOAD' LItOI.fIl' H LONO, .I". IHIJIIILLt,lo4on" ..AN ~ ~ADIN "'CHAfIlO' WOOD LAWltCHee . "'I"""" III' oJ ...,uel 'NolLTlIt JOHN (It ......N.ICI!. "'''N.J. LII." " IU(ltHIH .H..I.... C.''''/IIIL'' L IIICK' .....UL A LUNDelN JAC"'. HUIIIl.CY, .I" NA'HAN H WAlIIII,..,I" DAVID' OOWLIIoIO PAVID " O'l,UltV 0......100 'WADDILL CHA"LUJ'IIIUIV "AHL'V A ....ITH J~H' H D"'~O."","O' PIII"I\I 0 NiCHOL.... tHO,...... A. '"INCH 0"104 11 OU"NI.'Ull OOHNA "',j. CLA"K CHAIUU' OUTlHALL LUCY I "H'IC\.IV .....UI.,. wlIlILL 'HAWN 0 LOCHINOU JUl." IIIUML LOIIII.J Io4CIL"OV 1\11041.lIIL'f ...L....OI1T NOlL \l11IO."l.... (It IICHICHIL .v....,.. I. ICHW..I OIA"", "1'''IoI"n,1 TQDO J 'HILL .JIHNIJUIIo4 MCHUGH KINHllH L .,lOlL ....~to AOfl41UID TO 'HI '1.0"ID'" ...11 RIIOADH ,. SINON ATTORNEYS AT LAW DAUPHIN BANK BUILDING TWELrTH ~-LOOR ONE SOUTH MARKET SQUARE P,O, 80X l144e HARRISBURO. PA 17108"1146 or touHln '''ANII A IIHOH JOH" C OOWWIC. "AU" H. iltHQ,ADI Ito'.III. JeoHN ~, MVllnWAH 11'.1110 CU~I ilIl HINDllIIHOl """10 TELEPHONE (717) 233.15731 rA)( NOS: GENERAL: 711'131'10488 MUNICIPAL GROUP: 117'131.8810 LI'tIOA,.ION GROUP: 717'131'IUI37 tHilIllCT 0tA" NO 231-6671 "1.1 NO 2937/03 RE: Estate of John Eberle Your File ~. 21-1994-0508 CERTIFIED MAIL Mary C. Lewis Register of Wills Cumberland County Court House Carlisle, PA 17013 Dear Ms. Lewis: Estate: February 21, 1995 Enclosed are the following in connection with the above-oaptioned (1) Pennsylvania Inheritance Tax Return, in'duplicate, showing a balanoe due of $7,960.58. (2) (3) o~ (4)~ ,.... ", ; ~.~ (5)u.. (:','i,: :. ;. '\ ~ ~ "'II ;; (6)f:tl -;')";; ,., (J <,"';J 0(1) ~ &!Q; CheQk in payment of tax. Estate Inventory. co~~f D,S. Estate Tax Return. , Chec~j in the amount of $25.00 in payment of your filing fee in connbetion with the above Return and Inventory. A cory of this letter, with first page of Pennsylvania Return attached, which we ask that you time stamp and return to us in tha self~"addreSged stamped envelope provided. Ci.l G Very truly yours, RHOADS & SINON, , ' C\ - I By: )-7"'0 '1\.1 1/, (jl'IIr1111Wl'L' Diane T, Cerminara Legal Assistant to Lucy E. Kniseley LEK/jdf/uD2I Enclosures cc: Mrs. Ruth N. Eberle (w/encls.) Mr. David Eberle (w/ancls.) Lucy E. Knise1ay, Esquire LANCASTE:R OHle[: 15 NONTH L.IME STAEtT, LANCASTER, PA 1115011 TeL.EPHONe f1171 aD7'5117, FAle (1171 JQ7.ue7 AFflLIATtO OFFICE: BUITE JOI, ZDSt W. CAMINO OARDENS 8LVD" BOCA RATON, n 33432, TELePHONE 14011 3D!- !!S1!, FAX 14071 3D!' Sl4&7 ': . 'r"~: , ..:~ , I," "~' '.. 'L', !'I: , ,,'" \ , ", I t;; 'j 1 I'" ' , " :\;1., L.;,\ I 1;'1',', I ; ~ " i 1./ . , :r,~~i'~';i:,n,p), ~', , ,~- ~)':'I:'/:: ;~'. : ;') r',:, ,'\ '~r(.I:',~'LI'{~ -';.:.1c, \',~ (J' "",,' ; lr,'-.il., 'I \,' ,\ 'l!i}l, ij'~' ",f;\,' ,'~(, tl~ I t, I I 1'.Ij,~~)"." "./ 1'..1'<' .11/" I "", 1'"".,' ClerK.l, i, ' '. G Court CUmbi)I:,jfld ,Co" PA .'1 . ., Reo(lrdel~ [,'f,u" of Regl(llllI 0: Wills, " , , .. " '95 FEB 22 PI :07 i: " ' ., ,I 'I,' ,; l__' J ',"'" " , , ' 1,',_ " " " , " I' " ' :!, ','-,' ,." " Ii , I' ~" j , , = ~ ~ Qj ~ ~ . ~ 0 :<l rlJj~~~ ...., " ~ " \, ~ r- Qj , . ~ ~ ~ 8 ~ <"\ , ::I'" " ! I P I /I) :>.. 1:1'0 .......Ul.... ", , , :;:1 g Qj.... " .P8 ~<ll 1''- . o i( w a: ~..., 0 I>< ~ z a: O'1:l'S " o ~ ~ I< ~ ~ ai . Q,I r-t M U'" I< 0 /I) ',i, /I) Qj U'" I, ~." 1 ... ~ ~ 8~' ~u U "I' .. I'" ~ i " " , " " " , ';,'1 " " ' "'"""(''',-''' , Ii', '\ \~} \' , '\" ,.. "'":'.......-. ...\",1' I \' , ' ~, ;( :,.\ , ~:;' : "I, '.." ",I'rl; , ;'", "..}..1, :r I' 'I,; l!'l~ If.!e_:. r\~\ r::I:~i '\.'" , , , ", " ' d. '. I " f ,~ ,r "r' ,t'" ~ r-- Act '41 of 1994 prauld.. for tho roductlon of tho tall rat..lmpo.od on tho n.t ual~ of tran"'" to or for tho u.. of tho .pou... Th. rat.. a. prolCrlbod by tho .tatut. will HI . 3~ (.Ia) will H appllcablo for ..tat.. of d.c.dont. dying on or aft. 7/1/94)lnd Hforo 111/96 o 2~ (.12) wHI H applicable for .liat.. of deced.nte dying on or oft., 11119' 01Ml Hforo 1/1/97 . 1~ (.01) wHI H appllcablo for ..tat.. of d.c.d.nte dying on or aftor 111/97 _ Hforo 1/1/91. I SINU'" ....n...,. occurring on ar aft.r 111191 wIN b. 'll.mpt from Inh.rltlnco to.. PLEASE ANSWER THE FOLLOWING QUESTIONS IY PLACING A CHECK MARK (~) IN THE APPROPRIATE ILOCKS. . 1. Did doced.nt makl a trand.r andl b, rotoln the right to dlllgnatl who shall UII th. prClp'rty trand.rr.d or I.. Incom.1 ............... , I ., , X X X II I a. r.taln the u.. or Incom. of thl property transf.rr.d, ..O...........tl".."..tll..'.."....tll....lI11tt... X , c. r.tlln a r.verslonary 1nt.r..t; or .....1".........111..'.'"'"'...."1.1"11........11..'111......,"'lot'tUtHIlIt d, roc.lu.th. proml.. for llfo of .Ith.r paym.ntl, b.nlfltl or car.' .................,..................... 2. If _th occurr.d on or before Dec.mber 12, 1982, did dlCld.nt within two yta,. procldlng doatll trandor flroPlrty without rec.lvlng ad.quat. consideration' If doath occurr.d alt.r DICOtllHr 12, 1982, did decod.nttrand.r prop.rty within on. ytar of cloath without rocllvlng. X adequate c'"lld.rotion' II.t' ""'11111111"11"" 1'1'111 'f.... t.,.. Ot, 01 ,. 10 ..'"11 ..1111 tilt .tll,I'1111 I""" IIII ...,.,111'1 3. Did cIoc:.dont own an 'In trult for' bank account elt his or hlr d.ath'...................................... X .IF THE ANSWER~(,.NVO~:I ABOVE QUESTIONS IS YES, YOU MUST COMPLETE WCHlbULI G D PILE IT AS PART ()fI THI RETURN. so: I d ~z mil S6. aU!M jl! }YI:i!fiDI:! jCl ~.)~I'u.l-'(lplo:)a8 I" ~ f". SCHEDULE "0" TRANSFERS Continuation Sheet 1 ESTATE OF 1 , 1 John E, Eberle 1 . .. .. .. . . . . . . . .. .. . . .. . .. . . - - . . . . - . - -- I I I ITEM I INUMBER I DESCRIPTION OF PROPERTY ..................................... FI LE NUMBER 1 1 21.1994-0508 1 . -...... -.. - -"I DOLLAR VALUE 1 OF DECEDENT'S 1 INTEREST 1 '....'.-......-1 208,33 1 I TOTAL VALUE OF ASSET DECO. , INT, EXCLUSION Accrlled Interest on Jersey Shore PA SCH D 1,000 shs, of Apex Mun, Fund @ 9.718750 per share 9,718,75 Apex Mun Fund . accrued dividend 60,71 1,000 shs, Muni Insured Fund, Inc. @ 9,312500 per share I 1 1 1 I I 1 1 I 1 1 I I 1 1 ,I 1 1 1 1 91312.50 Muni Insured Fund, Inc. . accrued dividend 1.6.10 1,000 shs. Nuveen Municipal Value Fund @ 10.187500 per share 10,187,50 Nuveen Municipal Value Fund . accrued dividend 55,00 1,000 ahs. Nuveen PA Invest- ment Quality Municipal Fund 5.468750 per share l5,468,75 Nuveen PA Investment Quality Municipal Fund . accrued dividend 103,00 5,798 ahs. Merrill Lynch Municipal Bond @ 10,18 per share 59,023,64 489,071 shs, Merrill Lynch Dragon Fund @ 16.31 per share .7 ,97.6,75 I ......................................"........................ ............................................ .......... ........................ Total for this page 112,161,03 .....................................................................................................io........... ........................... 6260. i. , ~ ~ SCHEDULE "H" FUNERAL EXPENSES, ADMINISTRATIVE COSTS AND MISCELLANEOUS EXPENSES 1. Executor's Commission: none Year Commission Paid: 2, Attorney Fees . Rhoads 6c Sinon 3, Family Exemption Claimsnt: ~th N. Eberle Relationship Soouse Address of Claimant at decedent's death Street Address: 617 Allen Street City: New Cumberland State 6c Zip 17070 4, Probate Fees . Cumberland County Register of Wills C. Miscellsneous Expenses 1, Real Estate appraisal fee payable to William J, Daylor, MAl, for Pennsylvania realty CONTINUED 62660 Total from continuation sheet 45,000.00 2,000,00 91. 00 250,00 57,160,00 3,859,19 Total (Also enter. on line 9, Recapitulation) .............................................................................................-....................... $61,019,19 ............................................................................................................................. , ,," ,01, 'I " '.' ~ " " ':1 " , .J~ r I ',! 8 i '! '\. " 'I,. , I,'i " " '" .. " I,",'" ~ ", d '" ,.; .' ',', ,"', " i' " ,. " ;'.1 .. " j. \.\ " I'", " " , " " " 'Ii. ,. " I,,' ,Ii, , "j '" '"~ ,1'", \' .. , " , " 'I. " " , , ',J. " ., , , " " h ,. "I' " , , " , 'I'. I,'..' 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I. .. ,I' " ,:; ., , I" .", dt~/lllaSIJ.nu.r, as, " 1', I, 1, 2. 3, 4' , ' U""S ~ r't JOHN E, EBERLE SSN 171-07-8095 PENNSYLVANIA INHERITANOE TAX ATTAOHMENTS Dooummnt Last Will and Testament & Oodicil John E. Eberle Trust Under Agreement dated June 18, 1986, as amended Appraisal for Mercedes Benz 3000 Dhclaimer of Ruth N. Eberle .' .', , ., . " " ,. ", H I" ,1! , '. I, "~I, I', " " 'I 1\ " , ,,' I ~ 1,;I;e!. "I " >I, " I " , " " " " ,: ,,' " Pennsylvania tnheritanoe Tex Re(erence Page 1 Page 1 Schedule E, Item 1 Schedule J. .. " ,I', " ,. , 1/.' , , " '" " " ". " " " ;!i " 'I"" " I, >1' 11; I' H '", " " " , " " " ,I; " L " " o! , , " .' " 'I, ,1.\ ,,;.' \1 '.1\' '1', ,. .II, I' " 'II,\,. ' , ,', '" " "" '" ,II , " "', 'II, ..' "I' I. " (", It 'j, 'j, " .,., /.. \,':'" I,. ;('" \. 1/' j, , " !': ,.1', I',' ,I I', ',I' ,'" , ,",' .. , j'i, 'j , j"1 ','". x' , , " ,. ,,/'\ 'I' '. 'II' I'" " ,~ , ,,' It', " " .. 'I I' 1,1" ,I' 1\' I, ' LAST WILL AND TESTAMENT AND CODICIL , " " P,; ',l' .:- \' '," I':' \' " I;', " " I. ", " "," " q. ,. ',' Ih I' I'"~ " .., " i, ",' ,', ,.. " " " , , ,', " , " , , ,i\ ',I. ,il ,. " , ,:,n" "',1' " ..' "' " ',;n ('" \\ ,I', "I, , " /( "'3 " ,i' " ;;,,1' "/,; /, '" " " ',\ ,,' 1,0" h. ',',t I' 'i\ , , ,. I:,!" I:" " :1 . , , ~ ; 'I'" ," 'I' , , ,.:". ./' ,,,, " " .. , , , j,,; I'. '", , " l :,' A: i' I'" .. , ii.l- " '" ,.. '0' t." I;" 'j! I, \1" " ,) ;':; I' I: " . ',. ""1' 'L, I, " .'" '" 1[1 i ~ " '/,'1 "",1 " " 1/, " , : , , " " " , " , " ;'i' , 'I 'j, " , ,,' " , I' " " " "1\ , li' , ...- t ," . I\e . ': .,1' '" .,1' OF .,', , , I" ' " JOHN'E. EBERLE ,0' D~t.dl , ~ I': 1986. '" ," " rI!\ST EXECUTOR, RUTH N. EBERLE ',.! .. , ,. SUCCESSOR EXECUTOR I DAVID o. EBERLE and KAREN A. EBERLE ALTERNATE EXECUTOR, DAUPHIN DEPOSIT BANR AND TRUST COMPANY HARRISBURG, PENNSYLVANIA I" , I, I;. '" " " , , ," " \1 I. ", ., '. . . . ~~f ~iU mtb '&~$htm~m oJ JOHN E. EBERLE I, JOHN E. EBERLE, a legal resident of Cumberland County, Pennsylva- nia, revoke all prior Wills or Codicils and make this Last Will. ARTICI,E 1 1.1) I appoint as Executol, without bond, my wife RUTH N. EBERLE. Upon her tailure to qualify or the termination of such duties then my son DAVID O. EBERLE and my daughter KAREN A. EBERLE shall be substituted as Executors, also without bond,. or if either one fails to qualify or becomes incapacitated, resigns or dies then the surviving child shall continue as sole Executor. 1.2) Notwithstanding the provisions of Article l.l), if my wife survives me and could qualify as Executor but decidel that such office could be filled better by a corporate executor then she may decline and DAUPHIN DEPOSIT BANK AND TRUST COMPANY, Harrisburg, Pen- nsylvania shall be substituted as Executorl or, if my wifG faill to . survive me, or survives but fails to complete her duties a. Executor, and my children or one of tnem could qualify as substituted Executor (s) but decline for any reason or become incapacitated, resign or die before one of them completes the duti~s cf such office, then said bank Ilhall thereupon become substituted Executol:. ARTICLE 2 2.1) Except al may otherwise be directed in a written memoran- dum signed, by me, I give and bequeath to my wife RUTH N. EBERLE, if she survives me by sixty days, all of my tangible personal property and personal effects and all insurance policies thereon, with the reauest that AhA distribute such items that she does not desire or need among our two children. 2.2) I further give and bequeat~ lo my wife all of my house- hold furniture and furnishings located in our home at 617 Allen Street, New Cumberland, Pennsylvania ',7070, or in such other home in Page One ~ . . penn.ylvania that we may occupy at my death, if she survives me by liKty days. 2.3) I make no bequest of the furniture and furnishings in our winter residence at 144 Regent's Court, Melbourne, Florida 32940 as all of such items are already owned by my said wife. 2.4) If my wife fails to survive me or dies within sixty days of my death, then all property described in Article 2.1), 2.2) and 2.3) is hereby devised in equal sha,"ea to our two children, or if either i9 deceased then to his or her issue per stirpes, or if none then to the surviving child, except as may otherwise be directed in said written memorandum signed by me. ARTICLE 3 3.l) All death taxes upon or in relation to any of my property, whether passing under this Will or otherwise, as well as debts and expenses of aUministration shall be paid out of my probate assets, except tangible pelsonal property, without repa~~ent or reimbursement by any beneficiary or recipient I if such assets are insufficient therefor my executor may call upon the trustee of a hereinafter ~entioned trust for the sums needed. 3.2) Notwithstanding the provisions of ArtiCle 3.i) above, if any Qualified Terminal Interest Property passing under my wife's Trust or Will is included as a part of my taxable estate by reason of my life income from such QTIP asseta, then I direct that the share of my taxes applicable to s~~h QTIP assets shall be paid t~erefrom rather than from my own proLate or trust assets. 3.3) My executor shall file with Internal Revenue Service an election to have such marital share treated as Qualified Terminal Interest Property for the marital deduction for Federal Estate Tax purposes, EXCEPT if in the judgment of my executor there would be more than nominal savings for the estates of myself and my wife to elect to have less than all of the marital share treated as Qualified Terminal Interest Property than sa~d executor may file the election as to only a specific portion of such marital share. If such election could more properly be made by my Page Two ~ . . executor joining therein with the trustee of my trust delcribed in Article 5.1) said executor shall do SOl or, my executor may author- ize such election and filing by said trustee alone if under the then applicable provisions of the Internal Revenue Code such procedures can effectively be made by said trustee. ARTICLE 4 4.1) In addition or supplemental to ~ne powers provided by law, as amended, my executor in the prudent exercise of discretion and good judgment, and without order of court, mays A. Sell, at public or private sale, or option, any property for cl\sh or upon reasonable terms and securitYI and,' execute leases on any trust pl'operty upon such terms and condi tions I!nd for such per i- ods of time as trustee deems peoper and desirable. B. Invest in all forms of property (including, but not by way of limitation) real estate, all types of stocks, bonds, options and money market accounts without being confined to investments pre- scribed by statute, and without being required to have the extensive diversification that otherwise may be usual or customa~y for trusts of this size. And, Common Trust Funds maintained by my corporate executor may also be invested in except that any fund of equities (cornmon stocks or similar securities without fixed dividends) may be purchAsed only for a ~rust, or trust share, having a total fair market value of leos ~han F~Thous~nd Dollars. C. Place securities in a margin or'b-rokerage account and main- \ tain money-market accounts upon which checks or drafts may b~ drawn. D. Delegate trading authorization to investment advisors, broktlrs or agents and authorize them to sell and reinvest any assets on a discretionary basisl and pay reasonable compensation therefor. E. Borrow money fr.om the corrmercial 1epartment of my corporate executor1r others, upon reasonable ter~s, and mortgage, hypothecate or pledge assets as security therefor, in~ludlng short selling and contracts for the future delivery of any security. F. Enforce or compromise claims against others; and, settle or Page Three . . pay demands that executor deems proper. G. Manage, repair or improve probate assets. H. Exe~ute and deliver such instruments as may be necessary to effect all duties and undertakings hprein. I. Employ lawyers, accountants, I~geflts or other assistants necessary to the proper administration hereof, and pay reasonable compensation for such services. J. Vote and otherwise exercise all rights and options incident to the ownership of stocks, bonds and other securitiee and hold title in the name of a nominee. K. Purchase property from anyone, including a beneficiary, at a price and upon te~ms determined by executor to be fair. L. Pay premiums on any type of insurance policies retained or purchased herein, and exercise any right.s thereunder. H. Open checking and savings accounts, make deposits therein, . and draw ohecks or other debits against such accounts. N. Distribute assets in cash or kind or partly in each. O. Retain asset~ already a part of my probate ..tate, PROVIDED . HOWEVER, that inasmuch as more than sixty percent of my present total assets consist of common shares in AMP, Inc. (including AMP, Inc. "endorsed common sharps") a Delaware corporation having its principal place of business in Harrisburg, Pennsylvania, I urge, but do not direct, that my executor proceed in an orderly but not precipitous manner to sell such part or all of said shares that may be among my probate assets so that, when combined with the remaining shares in the hereinafter mentioned trust, the total thereof will have been re- duced by at least fifty percent. This request is made, not because of my lack of fa! th in the continued growth of AMP, Inc. wi th which .L nctvt! Of:1ttdO cuulur..;idt.~U J..UL rUL 1.'1 yea...." LuL lu l.'C1'~9.;~Liv.. :;f :h: fact that sales can be made after my death without large capital gain taxes to assure fUlIas for more diverse investments and to provide liquidity in my estate and cash needed to pay at least part of the withdrawals to whi;~ my children become entitled under said trust. Page Four ~ . . ARTICLE 5 5.1) I devile and bequeath the residue of my probate estate to DAUPHIN DEPOSIT BANK AND TRUST CO~lPANY, Harrisburg, Pennsylvania 17105, as successor trustee to be added to the trust Qreated by me as Settlor with myself as Trustee, said Trust AgreeMent being dated ~/I , 1986, or as the same may be amended at the date of my death. WITNESS my hand and seal this II day of ~ , 1986. ~ t.', ~ JOHN E. EBERLE, Testator We, the undersigned witnesses, hereby certify that the foregoing Will was willingly signed, sealed, published and declared by the above-named Testator as and for his Last Will and Testament, in the presence of us, wl~, at his request and in his presence and in the presence of each other, have hereunto sat our hands and seals the day and year first above written, and we certify that at the time of the execution thereof, the said Testator was of sound and disposing mind and memory. ~~~ (SEAL) Residing atl/~f~ ~ ,~ .~(SEAL) COMMONWEALTH OF PENNSYLVANIA) We, JOHN E. EBERLE, f. PH/LIJP "Dt.JiJv COUNTY OJ: DAUPHIN ) II:nd 1l, /(:."" A 4ft L. 1:> ..L t l'l Testator and the witnesses respectively, whose names are signed to the fore~oing instrument, being duly qualified according to law, do depole and say that we were present and saw the Testator sign and execute the instrument as his Last WillI that the Testator signed willingly and executed it as his free and voluntary act for the pur- poses therein expressed; that each subscribing witness in the hearing and sight of the Testator signed the Will as witnesses, and that to the best of our knowledge the Testator was at that time eighteen or more years of age, of sound mind and under no constraint or undue ~~ /;~ 1\ ~""'1 r't' ,~"" w,~ne~s . '{-ll:fli'<J,I/ft/,/':Z. / Wi tne.:l..t SUBSCRIBED AND SWORN to before me, a Notary Public in and for said Commonwealth and county this ~ day of \~' )~,:....... , 1986. /A2 ft . ~Uc:!:fjt:,; ~r~~ ~ / MAR~ ~~!'I ~~ln: ^'NI ~1~1 !,R~ PUBLI~ I ~ ..1" .1., 110 1986 M', r.l~\"";: 'I' ,,1\ " . H.,,"l'"":, r~ OJUo~" CountY ~ ~ ~. L'~ JOHN E. EBEnLE, Testator (SEAL) Page Five " 'I" ," " " , , ,.1' :, "-I 'j; " 1'-\, ,'j " 1'1' .' " " " j' " . " '~ " " .1', ["Ii i' " ", /: " I' H , ~ '_;1", " ,', "11, I'. " , . " !'; j,' 1,' , ' ," " " " 'I' ,I' . I .". ,I' , "" " "" . '" , , ,i' JOHN E. EBERLE TRUST UNDER AGREEMENT DATED JUNE 18, 1986, AS AMENDED ,\ ;'1' ",' '[- r_,_ "", '0/ , , , "" " " I;' . I; q 'II " Ie I"~ \\ ., r " , " , , q " I', , ii " 'I, :J, I,', , '" " " !' , " " " " , , , , , , , , , , , , , , , " , , , , " ",,' , , ., ii,l '" .... ,,', '. ij II " , j,' ,1,1' " , , I", '_1, ;;,\ 'nl.; " t' "i.. 'I , I, " " i I; \ i, ~ 'r, . " " II. '..1' " " " ,[',' '; ';,;' ',1 ,.. " ..' " '.", I.: L,t , , , , i),j ;1 ' /, " '1'1 II' \, "; ",I'; ''i , " -,,' ,Ii !Ij' u .. " , " II . " "J, "~I , ,'i I, I I:, "'II , " . f " . . ,1 TRUST AGREEMENT OF JOHN E. EBERLE I, JOHN E. EBERLE, a legal resident of Cumberland County, ~ennsyl- vania, currently 617 Allen Street, New Cumberland, Pennsylvania 17070 in my individual capacity as SETTLOR, by this Agreement of ~ II , 1986, have transferred to JOHN E. EBERLE, in my representa- tive capacity as TRUSTEE, certain property which, together with all other property transferred or bequeathed hereto by me or any other person, and any life insurance proceeds made payable ~ereto, shall be held by trustee upon the terms and for the uses and purposes set forth herein and in any duly executed amendment. ARTICLE 1 ... Family 1.1) For the purpose of identification but not to limit or ex- clude issue of my children named below who may become entitled to share as beneficiaries herein, or ot~er named beneficiaries, I record that as of thi,s date my wife and children herein designated as bene- ficiaries are I ,. RU~H N. EBERLE " 617 Allen Street New Cumberland, Pennsylvania 17070 Son - Daughter KAREN A. EBERLE 627 Allenview Drive Mechanicsburq, PennsyLvania 17055 Wife - DAVID O. EBERLE 1815 Oak Drive North Rockledqe, Florida 32955 , '::::::-... ~. , Subsequent references to my "wife", "son" or "dauqhter" are intended to be the family members just named. ARTICLE 2 ... Successor Trustee(s) .2.1) Upon my resignation or incapacity as trustee, or if neither occurs then upon my death the successor truste~ or trustees shall bel A. DAUPHIN DEPOSIT BANK AND TRUST COMPANY, Harrisburg. Pennsyl- vania 17105, Which shall automatically and immediately succeed to such office without the necessity of a formal written acceptanoe un- less required by some intere8ted party or applicable law. B. My wife RUTH N. EBERLE if she so elects by filinq her written Page One f f, . . ,1 TRUST AGREEMENT OF JOHN E. EBERLE I, JOHN E. EBERLE, a legal resident of Cumberland County, ~ennsyl- vania, cur~ently 617 Allen Street, New Cumberland, Pennsylvania 17070 in my individual capacity as SETTLOR, by this Agreement of ~ II , 1986, have transferred to JOHN E. EBERLE, in my representa- tive capacity as TRUSTEE, certain property which, together with all other property transferred or bequeathed hereto by me or any other person, and any life insurance proceeds made payable ~ereto, shall be held by trustee upon the terms and for the uses and purpoles set forth herein and in any duly executed amendment. ARTICLE 1 .. . Family 1.1) For the purpose of identification but not to limit or ex- clude issue of my ohildren named below who may become entitled to share as ben~ficiaries herein, or other named beneficiaries, I record that as of this date my wife and children herein designated as bene- ficiaries are I . Wife -- Dauqhter KAREN A. EBEPLE 627 Allenview Drive Mechanicsburg, Pennsylvania 17055 RUTH N. EBERLE " 617 Allen Street New Cumberland, Pennsylvania 17070 Son - DAVID O. EBERLE 1815 Oak Drive North Rockledge, Florida 32955 '~ , Subsequent references to my "wife", "son" or "daughter" are intended to be the family members just named. ARTICLE 2 '0' Successor Trustee(s) .2.1) Upon my resignation or incapacity as trustee, or if neither occurs then upon my death the successor truste~ or trustees shall bel A. DAUPH1.N DEPOSIT BANK AND TRUST COMPANY, Harrisburg, Pennsyl- vania 17105, which shall automatically and immediately succeed to such office without the necessity of a formal written acceptance un- leiS required by some interested party or applicable law. B. My wife RUTH N. EBERLE if she so elects by filing her written Page One , .' . . acoeptance of luch office with laid corporate trultee within thirty days of my termination al trustee. 2.2) Any luccelsor trustee shall be and is hereby relieved of all responlibility for my acts as trustee, an' I waive an accounting as a condition precedent to all undertaking. 2.3) If my wife becomes a co-trustee she shall reply in writing to any investment advice or action recommended by said corporate trustee within twenty days of mailing or personal delivery thereof I upon her failure to respond the corporate trustee may act in accord- anoe with such advice or elect to forego the recommended action if it deems that more prudent. Said corporate trustee shall have no lia- bility for failure to obtain a response from said co-truBtee without clear knowledge of her illness or. absence from home. 2.4) The duties of my wife as a co-trustee shall term\~ate upon her resignation, incapacity or death, whichever event first occurs. 2.5) Compensation shall be paid to my corporate trustee as pro- . vided for in its standard fee schedule in effect from time ~o time as it. services are performed, except as may otherwise be stipulated in a separate fee agreement between the parties in interest. 2.6) A corporate trustee may resiqn at any time upon giving thirty daYB written notice to the then adult income.beneficiary or beneficiaries. In such event a majority the~eof shall, within such period, appoint in writinq a substituted corporate trustee, and such appointee shall succeed to all of the rights, powers and duties of the first successor corporate trustee and be relieved of responsibility for the acts of all preceding trustees. 2.7) I hereby waive the posting of security by any corporate trustee and by my wife if she elects to become a successor co-trustee. ARTICLE 3' ... Life Estate of Settlor J.!I uurlng my !lretlme -- A. All of the net income hereof shall be paid to me as requested of trustee, or upon my demand to the successor trustee. B. In the event of my physical or mental disability, as much of the net income and principal as ttustee deems nec~~sary and proper for my maintenance, comfort and medical care shall be paid to me or Page Two , " . . duly applied tor such purposes. 3.2) If during m~' lifetime an ASset of this trust is the present home at 617 Allen Street, New Cumberland, Pennsylvania l7070, I dir- ect as follows with reference theretol A. Trustee shall continue to hold such asset in trust and permit m8 and my wife to reside therein during my lifetime or so long ~s I desire, without payment of rent to the trust. B. Should I elect to no longer live in such home trustee, a~ my direction, shall sell it and purchase another suitable home, or in- vest the net proceeds as otherwise provided for herein. If I am in- capable of making such eleotion the advice of my wife.. if living, to trustee shall control I otherwise the deoision of trustee shall be decisive botn as to the retention or sale of said present home or any home substituted therefor as an asset herein. C. All taxes, insurance and other expenses necessary to properly maintain such home, or any substituted home, shall bp. paid directly or to me from trust income, or principal if neoessary. ARTICLE 4 ... Qualified Terminal Interest Property Trust (Marital Deduction) ~ 4.1) Following my death and if my wife ROTH N. EBERLE survives me, (which shalL be presumed if there is insufficient evidence to show which of us survived) trustee shall divide the principal into two shares, a marital deduction trust share and a residuary trust share. ("marital" and "residuary", respeotively). A. The marital ghare shall be composed of the smallest fraction- al share of principal which, when added to all assets otherwise pass- ing or having passed to my said wife whioh are includable in my gross estate and qualify for the marital deduotion, will reduce the Federal Estate Tax payable because of my death to the minimum, after taking into account all other deduotions allowed on my Federal. !:;state Tax Return and all credits against the Federal Estate Tax, including the unified credit and the state death tax creditl provided that the state death tax credit shall not be taken into account to the ex- tent that it would increase sta~e de~th taxes. The formula con- tained herein shall be d~termined as though my executor elects to Page Three , t. , . . . \'1, Qualify all qualified tarminable interest property .for the Marital Deduotion pursu~nt to the applicable provisions hereof. I intend that the formula herein shall be construed as referring to the un- .lfmited Marital Deduotion provided fur in Section 2056 of the Inter- nal Revenue Code, al amended by Section 403 of the Economio Reoovery Tax Act of 1981 and as the same may be further amended. B. The reYiduary share shall be held as a separate n:3iduary Trust under ARTICLE 5 and shall be composed of the remaining prin- oipal or, if my sAid wife fails to survive me the entire prinoipal. 4.2) My executor, or trustee if then authorized, shall file with Internal Revenue Service an election to have such marital share treated as Qualified Terminal Interest Property for Federal Estate Marital Deduction Tax purpososl EXCEPT, if ir lhe jUdgment of my ex- ecutor (trustee) there would be major tax savin7s for the estates of mys.lf and my wife to elect to have less than ~ll of the marital share treated as Qualified Terminal ,Interest Pru~erty then said .x- doutor(tru.tee) may file the election as to only a specific portion of suoh marital share. All provisions of this Agreement shall b. . oon.trued to effect my intention to qualify this marital trust share (or any portion) for the Federal Eatate Tax Marital Deduction. 4.3) Should assets of this qualified marital share at any time consist of unproductive property my wife may require that trustee either mako the property productive, co~vert it within a reasonable time to productive property, or provide equal benefits by payment to her from the principal of such trust. No asset, or the proceeds of any asset, shall be allocated to the marital share as to whioh a Marital Deduction is not allowed. 4.4) Notwithstanding the fractional share allocation of trust principal set forth in Article 4.1) above, I diroct that it at my , I death a trust asset is my present home at 617 Allen Street, New Cumberland, Pennsylvania 17070, or any substituted home in Pennsyl- vania then occupied by me and my wife (as provided for in ArtiCle 3.2)-A,B & C) then such home property shall be allocated to this marjtal deduction trust share in its entirety, subject only to the Page Four , . . . following terms and conditionsl A. Said wife shall be permitted to reside therein for the re- mainder of her lifetime, or so long as she so elects. B. My wife shall also enjoy complete use and occupancy of such home without payment to trustee of any rent. Taxes, insurance and other maintenance costs shall be paid by said wife from her own in- come, or income of the marital share if she so requ~sts of trustee or if necessary for her full use and enjoyment thereof. C. At any time during her lifetime my wife m~y direct trustee to sell said home after which the net proceeds thereof shall be added to the other assets of this marital share for investment and payment of income therefrom as directed in Article 4.6) and Article 4. B) . 4.5) Further notwithstanding the fractional share allocation of trust principal as set forth in Article t.l) abov~, I direct that if at my death a trust asset is shares ,of stock representing partial or complete ownership of EXECUTIVE RENTALS, an apartment complex at 627 Allenview Drive, Mechanicsburg, Pennsylvania 17055, ~r a partial or complete ownership in kind of said real estate by virtue of a deed to trustee, then any such asset shall be excluded from the marital share and allocated in its entirety to the residuary share. 4.6) Commencing with my death the trustee shall pay to or apply all net income from this marital share, in quarterly or other more frequent installments, to my wife RUTH N. EBERLE for the remainder of her lifetime. 4.7) Unless my wife directs otherwise by her Will, trustee shall pay from the assets of this marital share to the executor of my wife's eetate the amount by which the Federal and State Estate and Inheritance Taxes assessed by reason of the death of my wife shall be increased as a result of the inclusion of this trust in my wife's taxable e3tate for those taxes. The trustee shall also pay any in- terest on the tax payable by such trust. The trustee may rely upon the certification of the execu~or of my wife's estate as to whether she has otherwise directed in her Will and as to the amount of tax Page Five , . . . to be paid by this trust. 4.8) Notwithstanding any other provision hereof, all inoome of this marital share accrued or undistributed at the death of my wife shall be paid to h8~ estate. 4.9) Following the death of my wife the assets then constituting the principal of this ma=ital trust share shall be added to the re- siduary trust share provided for next below, to be administered as therein directed. AR~ICLE 5 ... Residuary Trust 5.1) Following my death the assets of this residuary trust share, determined as provided for in Article 4, shaLl be continued in trust upon the terms and conditions set forth in this Article. 5.2) If my executor determines that there is insufficient cash in my probate estate to meet the requirements for funeral and admin- istration expenses, all legally enforceable debts, federal and state estate, succession, inheritance and generation skipping transfer taxes chargeable to my estate the trustee, upon the written request of my Ixecutor, may distribute to my executor principal hereof in an amount equal to the insufficiency I or the trustee may ~ake any part or all of such payments directly. 5.3) After setting aside a contingency reserve for the require- ments of Article 5.2) and the amounts of any specific dollar bequests to named beneficiaries trustee shall divide said residuary trust in- to two separate but equal shares, one for my son DAVID O. EBERLE, and one for my daughter KAREN A. EBERLE, the variations in precise equal- ity being as follows: A. Trust holdings in EXECUTIVE RENTALS referred to in Article 4.5) above, if an asset, shall be allocated to the share of my d~u6h~~~ ao ~hQ h~Q '~n0 han a ~~r~onal oart in its manaqement. B. The home at 617 Allen Street, New Cumberland, Pennsylvania 17070, or any substituted P~~nsylvania residence that becomes an asset hereof either upon my death if my wife fails to survive me, or upon her death if she survives me, shall be allocated to the share of my child who expresses a particular interest therein to trustee if such allocation is agreeable to the other child. If Page Six , I ~ . . , my children are unable to agree on such division then the decision of trustee to allocate said residence or sell it and add the pro- ceede to this residuary truet shall be final. C. Allocation of assets in kind sh~ll be at their fair market (or appraised) values on the date(s) of allocation and any differ- ence equalized with cash. 5.4) Trustee shall hold one such share for each child of mine allocated as required by Article 5.3) and -- A. Pay the net income from each child's respective share to said child in quarterly or more frequent installments, for the re- mainder of his or her lifetime. B. Permit each child to withdraw principal from his or her trust share upon written reauest to trustee, as follows: (a) One Hundred Thousand eollars at the end of one year after my deAth, and, (b) One Hundred Thousand Dollars at the end of two years after my death. Such rights of withdtawal shall be cumulative and may be exercieed by each child at any time after the right accruee. If a .ohild eleote by written notice to true tee to let any p~rt or all of . a withdrawal remain in hie or her truet such principal amount, or parte thereof, may b. later withdrawn by said child, or in event of death his pereonal representative may withdraw any balance thereof. If the total value of each child's one-half trust share of this reeiduary trust is initially less than Two Hundred Thousand Dollars the first principal withdrawal hy a child s;.all be limited to one- half of hie or her truet share until said shares are augmented under para. .C. below. Each second withdrawal shall be reduced to the o , trust ehare balance unless the respective trust shares have in the meantime been augmented, or until augmented, when each child shall have the right to w1thdraw tne excess Ot ~wo Kunorea tnousand Dollars over amounts previously withdrawn. C. Should my wlLe survive me then upon her subsequent death all aesets of the Marital Deduction Trust will be transferred to this residuary trust by ~4~icle 4.9) and such additional assets shall be allocated to the two truet shares for my children under Article 5.3) Page Seven ,. " . . A,S' C in the .ame manner and for the same beneficiaries as though .uch auet. were originally a part of the residuary tru.t. 5.5) After three years from my dellth, the corporate truste~l in. itl .ole discretion may use or apply principal from each trust share of my ohild~an for their respective benefits, as followsl A. For the support and medical care of said child, or anyone whom he or .he may be legally obligated to support. I B. To assist in the purchao~ of a home in the name of said child suitable to his or her needs and standard of living. c. To assist in the purchase of a going business or to start a new business of a type in which said child has some past experienoe and which appears to offer reasonable expeotations of success. D. Such discretionary uses of principal shall be exercised by the oorporate tru.t~o with due regard for the age and health of said child, and my desire to retain balances in each trust share to as- sure the .upport and medical care of oach child throughout his and her normal lifetimes I s~ch discretion shall be exercised in favor of a child of mine rather than lIny unreasonable preservation of princi- pal for the issue of either of my children, but only after taking in- . to acoount the personal assets of such child and other inoome or prin- cipal available to him or her, including substantial distributions from the e.tate o~'their Mother, Ruth N. Eberle. 5.6) In the event a child of mine dies before the time for set- ting apart share~~this residuary trust, or if a child for whom a ~ share has been set aside dre&.: thet'eafter but before his or her prin- , \ cipal has been used or withdrawn, the then principal of such trust share .hall be distributed and paid over absolutely as follows: A. To or in trust for such child's surviving spouse to the ex- tent of twenty-five percent of his,or her trust share as said child may appoint by WillI and the remainder, or all thereot 1T tnere 1S no appointment to a surviving spouse, to or in trust for such one or more of said child's issue in such proportions as said child may ap- point by Will. Any such Will mUlt contain a specific reference to th,is limitee.. power of appointment. In default of appointment or Page Eight '. \. . . insofar as it is ineffectual, then, (1) to luch child's then living issue per stirpes, orj in de- fault of such issue, (2) to my issue per stirpes then living, the share for any child or issue per stirpes of mine for whom trustae holds a trust share to be ad6ed thereto I or in the absence of issue per stirpe~ of mine, (3) to lIlY heirs at law as may then be provided by intestate statutts of the state in which I die legally domiciled. 5.7) If my wife survives me, until the Marital Deduction trust under Article 4 and the Residuary Trust under Article 5 are finally funded in accordance with the provisions of said Articles, my trus- tee shall estimate the approximate amounts of each trust annually, and, based on such estimate, shall determine as fairly as possible the share of net income attributable to each trust and shall pay the share of net income thus determined in accordance with the provisions I applicable to each trust. Such determination shall be made in the .absolute discretion of my trustee except that any diminution of in- come occasioned by the payment of death taxes, shall be attributable to the trust under Article 5.2) to which such taxes shall finally be allocated. My trustee shall not be held liable for any difference between the amounts of income so paid and tha exact amount of income of the trusts a. finally determined, which was produced prior to the time the trusts were finally funded, other than as hereafter set forth. If the amount of income paid to my said wife pursuant to my trustee's determination exceeds that to which she may be entitled, no recoupment shall be made from the subsequent income to which she may be entitled. If the amount of income paid to her is less than that to which she was actually entitled, my trustee shall immediately pay to h~: ~~=h ~:fioicnci~c out ~~ ~hA i~~nm~ frnm nr prtnnioal of the trust under Article 4. S.~) In the event a residuary trust share becomes so small that it cannot be economically administered for the person or purpose ori- ginally intended, trustee, in its discretion, may terminate such trust share by distributing the remaining principal and income thereof Page Nine . , ~ . . . to the beneficiary or beneficiaries then entitled to income there- from, directly or by means of any alternative s~t forth in Article 6.2) . AR'UCLE 6 ... !1inority and Disability 6.1) If a trult share terminates in favor of a beneficiary who il a minor, il incompetent or has not been adjudicated inoompetent but beoause of illness or disability is in the trustee's judgment unw able to manage the property distributable to him, the t=ultee may pOltpone the termination distribution. Such postponement shall last until the attainment of. his majority, the removal of ,his incompeten- oy or until, in the trultee's judgment, he is able to manage the property. During such postponement the property shall be held and administered al a separate trult and trustoe shall pay to the bene- ficiary as much of the net income or prinoipal or both as trustee de- termines is appropriate for his health, maintenance, support and edu- cation, inclUding anyone whom he, is legally obligated to support. If the beneficiary diel while the property is 10 hel~ the trult as- .etl shall be distributed to his estate. . 6.2) Additionally, trustee may distribute income and principal of a truet Ihare held pursuant to Article 6.1) by making payments for such beneficiary tOl (a) His guardian, (b) a relative or friend having care or custody of him to be used and applied for his bene- fit, or (c) a custodianship under the Uniform Gifts to Minors Act in the state where he resides, established for him by trultee or an- other interested person. The trustee may also make payments direct- ly for his benefit. A receipt for payment by any of the above per- sone shall be a complete discharge of trustee. .lI.P,T!'=!.~ ., "',..,,'1t.... PnWlIr!'l 7.1) In addition or supplemental to the powers provided by law, II L~ended, tru.tee in the prudent exercise of discretion and good jUdgment, and without order of court, may: A. Sell, at publjc or private sale, or option, any property for cash or upon reasonable terms and security, and, execute leases on any trust property upon such terms and conditions and "or such . . " . . periodl of time as trultee deems proper and desirable. B. Invelt in all forms of property (including, but not by way of limitation) real estate, all types of stocks, bonds, options and money market ~ccounts without being confined to investments pre- Icribed by statute, and without being required to have the extensive divers~fication that otherwise may be usual or customary for trusts of thil lize. And, Common Trust Funds maintained by any corporate ~rustee may also be invested in except that any fund of equities (common Itocks or similar securities without fixed dividends) may be purchaaed only for a trust, or trust share, having a total fair market value of less than Four Hundred Thousand Dollars. c. Place securities in a margin or brokerage account and main- tain money-market accounts upon which che~ks or drafts may be drawn. D. Delegate trading authorization to investment advisors, brokers or agents and authorize them to sell and reinvest any assets on a discretionary basis, and pay reasonable compensation therefo~. E. Borrow money from the commercial department of my corporate trustee or others, upon reasonable terms, and mortgage, hypothecate or pledge alsets al security therefor, including short lelling and contract. for the future delivery of any security. F. Enforce or compromise claims against others and settle or pay demands presented herein. G. Manage, repair or improve trust assets. H. Execute and deliver such instruments as may be necessary to effect all duties and undertak1ngs herein. I. Employ lawyers, accountantB, agents or other assistants necelsary to the proper execution hereof and pay reasonable compen- sation for such services. J. Vote and otnerWlSe exercise aE d':jil\." . auy vtJ\..~v,.Q , " . ..u""..-..-....I.1o- to the ownership of stocks, bonds and other securities and hold title in the name of a nominee. K. Purchase prop~rty from my probate estate or a beneficiary at a price and upon terms determined by trustee to be fair. L. Add to the principal of any trust crBQted herein any prop- Page Eleven t . ~. . . erty received by beque.t or otherwise. M. Pay premium. on any type af insurance policies retained or puroha.ed herein, and exercise any rights thereunder. N. Open checking and lavings accounts, make deposits therein, and draw checks or other debits against such accounts. O. Di.tribute assets in cash or kind or partly in each. P. Retain alsets already included herein or that may be added upon my death, PROVIDED HOWEVER, that inASmuch as more than sixty percent of my prelent total assets consist of common shares in AMP, Inc. (inoluding AMP, Inc. "endorsed common Ihares") a Delaware cor- poration having its principal place of business in Harrisburg, pen- nlylvania, I urge, but do not direot, that trustee prooeed in an orderly but not precipitous manner to sell suoh n~~er of said .hare. that when added to the sales thereof by the exeoutor of my probate eltate the total of such lales will reduce the combined holding. in my estate and,trust by at least fifty percent. Thil re- que.t il made, not because of my lack of faith in the oontinued growth of AMP, Inc. withwhioh I have been allociated for forty year., but in recognition of the fact that sales can then be made without large capit~l gains taxel to aSlure funds for more diverse inve.tment. by trustee and to pravide liquidity in my e.tate and ca.h needed to pay at least part of the withdrawals to which my ohildren beoome entitled under Article 5.4)-B. AND, PROVIDED FURTHER, that no power of trustee shall be exer- oi.ed or applied if any part of the Qualified Terminal Interest Property would thereby be disqualified for the Federal Estate Tax ~arital Deduction. ARTICLE 8 ... procedural & Administrative provisions 8.1) The roLLoWlng pro~tiuuL~l ~Luvliiuno ch~ll ~~ ~rr'iA~ in , the administration of all trusts herein, exoept as limited to a partioular trust. A. The masculine gender shall be construed to inolude the fem- inine and the lingular as plural where consistent with the remain- ing text. Page Twelve , . . . 8. The term" issue per stirpes" of my children shall be con- strued to mean their child or children, grandchild or grandohildren and more remote issue thereof who are entitled to a parent's share ~y reprelentation, inclu~ing all who may be legally adopted when under the age of ten. C. The succelsor or corporate trustee shall call upon my medi- cal doctor for a certificate of my mental or physical dis~bility as authority for assuming the duties of trustee during my lifetime, Ixcept upon my voluntary resignation. D. In the event of my mental or physical disability, whether certified by a medical doctor or established by decree of court, the administration of this trust shall oontinue uninterruptedly as otherwile provided for herein. E. If my wife becomes a co-trustee and thereafter her mental or physical disabilities interfere with the performance of her duties, the corporate trultee may oall upon her medical doctor for a certificate to such effeot, which will relieve her of suoh office. F. The corporate trustee shall have the physical cUltody of all . property, documents, books and records herein and shall, at reason- able intervall, provide each beneficiary with detailed statements of income and principal receipts and disbursement together with a list of assets showing tax COAts and market valuationA. 0' G. Income from any residuary trustor any shar.e thereof need not be apportioned between successive beneficiaries. All income not actually paid to a beneficiary before termination of his inter- . elt may be treated al though it had accrued and become payable there- afterl likewise, no credit or accrual need be made for taxes, com- mtlsions or other charges theretofore made against income. H. Any residuary trust created herein (or as amended) I may au merged with any other trust establishf.d by me or under a Will or Trust Agreement of any other person if said trusts are for the same beneficiaries and estates and have the same trustee, provided that no adverse tax effects or other detriment to the parties in interest would result from such merger. Page Thirteen . . .. . . I. The term "child'. surviving mpouse" and "surviving spouse" uled in Article 5.6)-A above shall be construed to mean only the spoule to whom my son or daughter may be legally married at the time of such child's death. ARTICLE 9 ... Legal Restraints 9.1) No beneficiary shall have the right or power to sell, as- lign, encumber or otherwise anticipate the principal or income which he may at any time be entitled to receive, and no such in- terest Ihall be taken by legal or equitable process in satisfaction of any debt or liability of such beneficiary while in the posles- sion of trustee, or prior to the actual distribution thereof to the beneficiary DO entitled. 9.2) All trult shares herein shall veat and distributions finally made upon a date not later than twenty-one years following the death of all named and ascert~inable beneficiaries herein liv- ing at the date of my death unless a shorter poriod of time is re- quired by applicable state law to avoid violation of any rule against perpetuities. ARTICLE 10 ... Applicable State Law lO.l) The statutes and case l~w of the Commonwealth of Pennsyl- vania shall be applied to the interpretation of this Trust Agreement if any justiciable question arises that cannot be reasonably decided by trustee upon reference to the provisions hereof I PROVIDED HOWEVER~ that the statute. and case law of the State of Florida shall be ap- plied any time after this date if I become legally domiciled in laid State of Florida. ARTICLE 11 ... Reserved Powers and Rights 11.1) I reserve the following rights and powers, exercisable at any time, and from time to time whereby I may: A. Amend this Trust Agreement, or any amendment hereto, in whole or in part by written agreement similarly executed. B. Withdraw any part or all of the assets hereof at any time. C. Exercise any rights or options available under any life i~. lurance policy transferred to or made payable hereto by me as the Page Fourteen . . , . . . . owner or insurec1. D. Aocept or c1ilapprove within twenty c1ays of receipt, any ad- vice by succelsor trustee to sell, purchase or encumber any alset hQreof, otherwhe trustee may proceed in its discll'etion. E. Revoke this agreement by unilateral action while I remain trustee, or upon sixty days written notice to any successor trustee during my lifetime. IN WITNESS whereof, the parties hereunto have executed this Trust Agreement in two counterparts the day and year first' above written. ~t,~ JOHN E. EBERLE, Settlor (SEAL) ~4 [, !./A1./, (SEAL) JOHN E. EBERLE, as Trustee The foregoing Trust Agreement, on the day and year first above written, wu siqnec1, sealed and published by Settlor and Trultee . .in the presence of ~B, and the undersigned who attest as witnelses after said Settlor and Trustee had signed as hiB free and voluntary act in our presenoe anc1 we in the presence of each other. Ac1dreu C; Address fft STATE OF PENNSYLVANIA ) COUNTY OF DAUPHIN ) I HEREBY CERTIFY that on this day before me, an officer duly quali- fied to take acknowledgmentl, personally appeared JOHN E. EBERLE, ~o me known to be the perlon describec1 in and who executed the foregOing instrument and acknowledged before me that he executed the lame. WITNESS my hanc1 anc1 aforesaid this I; official seal in the County and State last day of '/L~~ , 1986. I,' " '. '~d~ L~(a~.r/.r. -t; ~~ Notary Public ..t, . """""'11""'1 .10T' ::v l.tJ~LI\' M!~ '. ' r. M'" .. . ., ~\r to (1\'IH' JO, 11456 , '~"";' ",,1''\ O."pll'" C,urlV .' .' '\ ."'..... PE1l7S RJWIWp 12/18/87 B. Exerolse any rights or options available under any lite 11IIuranoe polloy trallltel'1'ed to or made payable hereto by l1Ie as the owner or Insured. C. Aooept or disapprove within twenty days ot reoelpt, any advloe by suooessor trustee to seU, purchase or encumber any uset hereot, otherwise trustee may prooeed In Its dlsoretlon. (b) It during my IItetlme an asset at this trlat Is my prosent home at 617 Allen Street, New Cumberland, Penlllylvanla 17070, or the townhome at 144 Regent's Court, Melbourne, Florida 32940, ourrently oooupled by me and my wlte 15 our wInter home, or any substutlte therefore, I direct as toUows with reterence theretol 1. Trustee shall continue to hold such u.et ,In trust and permit me and my wlte to reside therein during my lItetlme or so long as I desire, without payment ot rent to the trust... 2. Should I elect to no longer live III suoh home, trustee, at my dlreotlon, shall seU It and purohase another suitable home, or Invest the net proceed.s as otherwise provided tor herein. It I am Inoapable of --'<'::';,-_maklnr suoh eleotlon, the advloe of my wlte, It livIng, to trustee shall oontroll otherw~' the deolslon of trustee shall be deolslve both as to the retention or sale at said pre..nt homes or any home substituted theretor as an uset herein. 3. All taxes, Insuranoe and other llC{lellles neoenary to properly maintain suoh homes, or any substituted home, shall be pall1 dlreotly or to me trom trust Inoome, or prlnolpallt neoesstl'Y. -2- """) ,r-., PEll1S RJWlwp 12/18/87 :, 4. The provisions of this subparei\'aph are Intended by me to provide all metlme rights of use and oooupanoy by me and to thereby qualify said home or substituted Florida home, for homestead tax eXllmptlon under the Constitution and statutes of the Stllte of Florida, If I beoome lelaUy domloUed therein at some future date. SECONDI ~ettlement of My Estate. Upon my death, Trustee may make suoh payments from the prlnolpal of the Trust, prior to Its division, as Trustee deems desirable to faollltate the settlement of my estate, and In the exerolse of this power Trustee may pay, In whole or In part, any or a.!l of (I) my lelaUy enforoeable debts; (II) my funeral and burial expenses and (Ill) administration expense. In oonneotlon with my utat., ev.n tholllh they do not relate to property subjeot to this TrUlt. Neither the persona.! representatives of my estate nor any beneflolary of my estate shall b. r.qulred to relmburs. Trustee for any suoh expenditures. THIRDI Clvillon of Prlnoloal. Upon my deathl (a) If my wife, RUTH N. EBERLE, survives m. (whloh shall b. presumed If there Is Insufflolent evld.noe to show whloh of us survlv.d), my Trustee shall divide the prlnolpal Into two separate trusts, a Quallfltcl Termlnabl. Interest Trust under Paral1'aph FOURTH and a Residuary Trust under Paral1'aph FIFTfI. (b) The QUa.!lfled Terminable Interest Trust shall be oomposed of the smallest fraotlona.! share of prlnolpal whloh, when added to all -3- " ,,-) ,,.-...\ PE1178 RJWIWp 12/18/87 " ....U'otherwls. passing or havIng passed to my said wit. whloh are Inoludable In '\\y gross estate and quality tor the marital deduotlon, wIll reduce the Federal Estate Tu payable beoause at my death to a minimum, atter taking Into account all other deductions allowed on my Federal Estate Tu Return and all credits against the Federal Estate Tax, Including the unified credit and the state death tax credltl provided that the state death tax credit shall not be taken Into aocount to the extent that It would Increase state death taxes. The formula "ontalned herein shall be determined as though my Executor .I.ots to qualify all qualified termInable Interest property for the marital deduction pursuant to the provIsions ot my Will. (c) Th. Residuary Tl'UIt shall bfI oomposed at the remaining princIpal or, If my said wife falls to survlvl me, the entire principal. (d) It my Exeoutor elects to quality thl QUalified . Terminable Interest Trust or any portion thereat tor the marital deduction, any p,rovlslon of this Arreement of Trust which may app.ar to conflict with my Intention to quality thl Qualified Terminable Interest Trust or such portion. thereof for the marital deduction shall be construed so as to accomplish that Intention. Ifsuoh .llotlon Is made In whole or In part, all property allocated to or held In suob trust shall b. the type of property which qualities for the marital dlduotlon. In addition, If such el.otlon Is made In whole or In part and If assets of suoh tl'UIt' at any time consist SUbstantially of unproductive property, my said wlte maY,requlre that my Trustee either make the property produotlve, oonv.rt It within a reasonabl. time to productive property, or provld. the required b.n.tlolal -4- , ,\ ,,", r PE1178 RJWIWp 12/18/87 enjoyment from the trult to my said wife by payments to her from the prlnolpal of such trust. FOUR"tHI Qualified Terminable Interest Trust. At to the prlnolpal puslng hereunder, I direct my Trustee further to divide the prlnolpallnto two separate trusts, QTIP Trust No.1 and QTIP Trust No. 2. QTIP Trust No. I shall be oomposed of the maximum amount of principal whloh, after aocountlng for that portion of my GST Exemption (as defined In seotlon 2831 of the Internal Revenue Code) whloh la allooated to tile prlnolpal pwlng under Pararraph FIFTH (a) I. and FIFTH (a) 3. of the Residuary Trust, can be paid to QTIP Trust No. I without oauslng the Inoluslon Ratio (u defined In section 2842(a) of the Internal Revenue Code) with respeot to suoh Trust to be greater than zero (0). QTIP Trust No.2 shall be oomposed of the remaining prlnolpal. The formula oontalned herein shall be determined after taking Into oonslderatlon the deolslons of my Exeoutor whether (I) to allooate my GST Exemption to the prlnolpal puslng under Paragraph FIFTH (a) 1. and FIFTH (a) 3. of the R~9Idue.ry Trust to the extent neoessary to result In Il'llnoluslon ratio of Zlro for suoh prlnolpal, (II) to allocate the remaining unused portion of my GST Exemption (as of my death but after the allocation undaf (I) above) to QTIP Trust No.1, (Ill) to tile or not tile an eleotlon pUl'luant to slOtlon 2832(b)(3) of the Internal Revenue Code, and (Iv) to tile Of not ru. a speolal election with respeot to QTIP Trust No. 1 pursuant to seotlon 28112(a)(3) of the Internal Revenue Code. (a) As to QTIP Trust No.1, I direct my Trustell -5- ,'"" ,,......, PEll76 RJWlwP 12/Z3/87 1. To pay tha net Inoome at least quarterly to my wife, RUTH N. EBERLE, for life, In addition, my Trustee may pay to or apply for the benefit of my said wife as muoh of the principal as my Trustee deems advisable for her malntenanoe, eduoatlon, health, and support, after first oonslderlng funds available to her from other sourcesl provided that no such payments of principal shall be made to my said wife until QTIP Trust No.2 Is completely exhausted, 2. Upon the death of my said wife, A. To the extent, and only to the ," extent, the funcls passing under subparagraph (b)2.A hereof are lnsuttlolent to do so, to deduot and pay to the personal representatives of my said wife's estate (without responsibility for the applloatlon thereof) an amount certified by suoh personal representatives to be equal to the additional death taxes (and any Interest and penalties thereon) and administration expenses whloh would not have been payable from her estate If the value of the remaining prlnolpal of the Qualified Terminable Interest Trust (Including both QTIP Trust No. I and QTIP Trust No.2) had not been Included In her estate, unless my said wife dlrect~ In her Will that suoh taxes and expenses shall be paid out of her estate or another 30uroe by a provision for the payment (If guoh taxes and expenses which Is sufficient to Includ. tho.. relating to this trust. B. To add the remaining principal to the Exempt aSTT Trust under Paragraph SIXTH, to be held or distributed under the terms thereof as applied to circumstances' then existing. -6- . , .'~'\, PEWS RJWlwp 12/18/87 1'-, (b) M to QTIP Trust ~o. 2, I dh'eot my Trusteel I. To pay the net Inoome at leut quarterly to my wife, RUTH ~. EBERLE, tor Ilte. In addition, my Trustee may pay to or apply tor thlt benetlt ot my said wltfl u muoh of the prlnolpal u my Trustee deeml advisable tor her maintenance, eduoatlon, hea.lth and support atter first oonslderlnr tunda (other than tunda In QTIP Trust ~o. 1) available to her trom other souroes. 2. Upon the death ot my said wife, A. To deduot and pay to the personal reprelentatlves ot my said wlte's estate (without responsibility tor the applloatlon thereof) an amount oertlfled by suoh personal representatives to be equa.l to the addltlona.l death tues (and any Interest and pena.ltlel thereon) and admlnlltratlon expensll whloh would not have been payable tram her IItate It the va.lue ot the remalnlnr \)rlnolpa.l ot the Qua.llfled Terminable Intemt Trust (Inoludlnr both QTIP Trust ~o. I and QTIP Trust ~o. 2) had not been Inoluded In her estate, unlesa my laid wlte dlreotl In her Will that suoh tuel and expenles shall be paid COI.t ot , her estate or another souroe by a provision tor the payment ot suoh taxlll and expensel whloh II suttlolent to Inolude those relatlnr to suoh trust. B. To add the ba.lanoe of the prlnolpa.l to the Nonu.mpt asn Trust under the terml ot Parail'aph SEVENTH. FlrTHl Residuary Trult. As to the prlnolpa.l pUllnr hereunder, 1 d.lreot my Trultee, ," , + , " '"\ /"..... PCl176 RJWlwp 12/18/87 (a) It my wlte, RUTH N. EBERLE, survives me, upon my death to divide the principal Into as many equal shares as there are ohlldren ot mine who survive me and ohlldren of mine who fall to survive me but who are represented by descendants who survive me, and 1. To add the share ot e child who tallA to survive me to the Exempt GSTT Trust under Paragraph SIXTH to be held under the terms of subparagraph (0) thereot as applied to olroumstances then existing. 2. To set aside In a further sep&":lt.. trust trom the share of a ohlld who survives me the lelllcr of TWO HUNDRED THOUSAND DOLLARS ($200,000) or the amount ot said share; and ,A. To pay the net Income thereicG;ft at least quarterly to such ohlld. B. One year from the date of my death, to pay to such ohlld upon his or her written request the lesser of ONE HUNDRED THOUSAND DOLLARS ($100,000) or one-half the then talr market value ot the principal. \ C. Two years trom tha date ot my death, to pay to suoh ohlld the remalnlnr principal. D. Upon the death ot any such ohlld before the .ntlr. principal ot his or her trust haa been distributed, to pay the remllnlnr prlnolpal to such persons, Inoludlng suoh ohlld's estate, In ~uch manner and shares, for such estates, or upon such trusts as suoh ohlld may appoint In his or her last WIU by speolflc reterenoe to this ieneral power, and to add the remaining -s- '"" PE1l76 RJWlwp 12/18/87 prlnolpal not effeotlvely so appointed to the NOllexempt CJSTT Trust under Parqraph SEVENTH to be held under the terms thereof u applied to olroum- stanoe. then existing. E. Exoept u provided In Paragraph THIR1'EENTH (I), ill Inoome aoorued or undl,trlbuted at the death of In Inoome beneflolary shill be paid to the suooeedlnglnoome or prlnolpal beneflolarles. 3. To add the balanoe of eaoh share of a ohlld who survives me to the Exempt GSTT Trust to be held unl1-r the terms of Paralt'lph SIXTH u applied to olroumstlooes then elllstlnlf. (f my said wife falls to survlv. me, . 1. To set ulde and pay to the PllImpt OSTT Trust under Paralt'aph SIXTH (to be held under the terms th.reof u applied to (b) olroum.tanoes then existing) the maximum amount of prlnolpal whloh oan be paid to the Exempt GSTT Trust without oauslnr the Inoluslon Ratio (u defined In seotlon 2842(1) of the Internal Revenue Code) with respeot to suoh T\'USt to be greater than zero (0). The formula oontllned herein shall be determined Ifter talclnglnto oOlllld.rltlon the deolslons of my Exeoutor whether (I) to allooate the remaining unus.d portion of my GSTT Exemption (u of my death) to the Exempt OSTT Trult and (II) to tile or not file an eleotlon pUl'!ulnt to seotlon 2832(b)(3) of the Intlrnal R.v.nu. Code. 2. To divide the balanoe of th\' prlnolplllnto aa mlny equal shares as there are ohlldren of mine who survive me and ohlldren of min. who fill to survive me but who are represented by desoendants who survive m., and -g- ~ 0. PE1178 RJWIWp 12/18/87 A. subJeat to Parall'aph SEVENTH (0), . to pay the shate of a then deaeased ahlld of mine to his or her thlln IIvlnr desaendants, per stirpes. B. To set uld. In a further separate . trust from tile share of a ahlld who survives me tile lesser of TWO HUNDRED THOUSAND DOLLARS ($200,000) or the amount of said share, to be held under . . the terms of subseotlon 2. of subparalfl'aph (a) hereof. C. To pay tht balanoe of the share of a then IIvlnr child to the trust for such child under Pararraph SEVENTH (b), to b. held und.r the terms thereof u applied to olrcumstance. then,exlstlnr. SIXTH, ExemDt GSTT TrUlt. I dlreot my Trust.. to divide the principal passlnl hereunder Into 1\.1 many equal sharel as there are children of mine IIvlnr at the time suah prlnalpalls added to this trust and ahlldren at mine then d.aeased repr..ented by desaendants then lIvlnr, and , , (a) To retain In a further separate trult the share of a then deaeued ahlld In aaaordanoe with the terms of subpararraph (0) hereof u applied to alraumatanaes then Ixl.tlnr. (b) To retain In a further separate trust eaah share of a tMllllvilll ahlld, and 1. To pay the net Inaome therefrom to suah ohlld at Ilut. qul11erly, for life, and In addition, at any time after three (3) years from the date ot my death, to pay as muah of the prlnalpal to him or h.r as he or -10- /"" PE1l78 RJWIWp 12/18/87 she 11I17 frolll tlm. to time request In wrltlnl not exoeedlngln any oalendar year Flv. Percent (596) of the value ot the prlnolpal at the end ot suoh oalendar year on I non-oumulatlve bulsl provided that no suoh payments ot prlnolpal shall be made until the trust for suoh ohlld under PlU'all'aph SEVENTH (b) Is oompletely exhausted. 2. At any time atter three years from the date ot my death, to pay to or apply tor the benefit of suoh ohlld or suoh ohlld's descendants so muoh ot the prlnolpal as my Trustee deems advisable, In my Trustee's sole dlsoretlon, for his or her maintenance, eduoatlon, health and support; provided, that no suoh payments shall be made tor such child until the trust for suoh ohlld under Parall'aph SEVENTH II oompletely exhlusted. In the exerolse ot this power, funds available to suoh ohlld from other souroes shall be oonsldered by my Trustee. 3. Upon the death ot suoh ohlld, to PlY the remllnlng principal to such of hll or hl!r spouse and desoendants, In such manlier and shlll'as, tor such eltltl!, or upon suoh trusts as such ohlld may appoint In his or her lut Will by specltlo refer .nce to this limited power; provided that any Interelt so appointed tc the spoue of a child of mine shall not exceed In value the allloUllt by which the combined value at such ohlld's death of the prlnolpal of the \ II" I' tl'Ultl tcr suoh child under Plll'lII'aph FIFTH (a) 2. (or FIFTH (b) 2. a.) and f..," : PUIfl'Iph SEVENTH Is leu than twenty-five percent (2596) ot the then oomblned value of the principal of the trusts for such ohlld under this plU'all'aph and under PUlfl'aph FIFTH (a) 2. (or FIFTH (b) 2. a.) and Parall'aph SEVENTH, and to retain -11- r") ~ I'Ell7a RJWlwp 12/18/87 the principal not effeotlvely so a!'Jpolnted under the terms of subparlrrlph (0) below. (0) To divide the prlnolpal pwlnr hereunder Into as many equal shar'l u there are ohlldren of the ohlld representlnr suah share of prlnolpal (rrandohildren of mine) then lIvlni and suah rrandahlldren then deoeued r.pre..nt.d by de.a.ndants then lIvlnr, and 1. To retain the share of a then deoeued rrlndohlld of min. In a fUl'ther 9'!rlarc&te tl'USt, and A. To pay the net Inaome th.r.from at leut quart.rly to suoh of suah rram:ahlld'. de.aendants u' ar. llvlnr on .Ioh quarterly distribution date, per stlrp... . B. To pay to or apply for the benetlt of any delaendant of suoh rrandahlld so muoh of the prlnalpal u my Trustee deem. advlllbl. for malnt.nanoe, .duaatlon, health and support after oonslderlnr funda available to him or her from other SOUl'ae.. So far u my Trustee deems It praatloable, payments so made shall be aharred aralnst the ,hare of prlnolpal r.pre.ent.d by the p'l'lllln beneflt.d thereby or his or her analltor or desoendants at the tlm. of any subse~uent division or distribution of the trust. C. One day before twenty-on. years aft.r thedtath of the survivor of suoh of my said wife and my desaendants u are llvlnr at my dtath. to pay the prlnalpal to the then lIvlnr desoendants of suoh grandohlld, per stlrpll. -12- , ,~\ (' PE1l76 RJWIWp 12/18/87 2. To retain the ~hare at a then living it'andohlld In a turther separate trust, and A. To pay so much at the net Inoome to such il'andchlld as my Trustee deems advisable. All net Inoome not so paid shall be aooumulated and added to principal. 8. To pay to or apply tor the benefit of such Irl'andchlld or any ot such Irl'andchlld's descendants so muah of the prlnl3lpal as my Trultee deems advlspbl~ for maintenance, health, eduoatlon and support after conalderlng funds available to him or her from other souraes. So far III my Trustee deems It praotloable, payments so made shall be ahll'led lIalnst the share ot prlnolpal represented by thll pt'rson benefited thereby or hit or her desoendanta or anaeator at the time of any subsequent division or distribution ot the trust. c. Upon the death ot such Irl'andahlld, to pay the remaining prlnolpal to such of such it'andchlld's desoendants, In suah mahner and shares, for suah estates, or upon such trusts as suoh il'andohlld may appoint In his or her last Will by, specific reterence to this limited powltr, and to retcaln the prlnalpal not eftectlvely so appointed under the terms of seotlon I. ot thla subparlil'aph (0) III appllad to olroumstanoes then existing. (d) If at any tlm. there Is no on. living who Is entitled to Inoome or prlnolpal upon the termination ot any separate trust hereunder, to pay said principal as followsl 1. To the then living descendants, per stll'tles, of the most Immediate anoestor (who Is a desoendant ot mine and who has -13- . " , , ''"1 (''\ PE1176 RJWIWP 12/18/87 desoenclalltl th.n lIvlnr) of the last' p.rson to whom the Inoome ot suoh termlnatlnr trust may b. dlstrlbut.d. Z. In default of suoh deso.ndants, to my th.n lIvlnr descendants, p.r stll1les. 3. Any additional share of a chIld or rrand- 'ahlld of mine for whom a trust Is then In exist.nc. und.r this paragraph shall b. added to suoh trust, and any eddltlonal share of a desoendant of a rrandchlld of min. shall b. adeed to the trUlt for such d.so.ndant und.r subseotlon 1. of subpararraph (a), to b. h.ld und.r the terms thereof as applied to clroumstanoe. then IXI.tlnr. 4. In d.fault of suoh d..aendants, to tho.e p.rsons who would b. entitled thereto under the Intestste laws of the Commonwealth of Pennsylvania then In effect had I then died Intestat., unmarried and without survlvllli de.oendantsl provided that any Inter.st whloh would otherwise paaa to suoh Commonwealth under suoh laws shall be paid to a aharlty or aharltles s.l.oted by my TrUlt.., In Trustee's sole dlsoretlon. (.) Exo.pt as provIded In Paragraph THIRTEENTH , (1), a1\ Inoome aoorued or undistributed at the death of any Inoome beneflolary shall be paid to the suooeedlnr Inoom. or principal beneflolarles. SEVENTHI Nonexempt aSTT Trust. I dlr.ct my TrUlt.. to divide the prinolpal pllslng hereund.r Into U many equal shares as there are children of min. living at the time suah prinolpalls add.d to thl. trust and ahlldren of mine then deceased represented by desoel)dants then lIvlnr, and -14- . /' ~,~ 'I; '-\ r--o, PE1178 RJWIWp 12/18/87 II (a) Subjeot to subpulll'aph (0) below, to pay the share of a then deoeued chIld to his or her then lIvlni' desoendanU, per stirpes. (b) To retain In a turther separate trust eaoh share of a then IIvlnl ohlld, and I. To pay the net Inoome at leut quarterly to suoh ohlld, tor lite, and In addition, at any time alter three (3) years trom the date ot my death, to pay u muoh ot the prlnolpal to him or her u he or she may trom time to time request In wrltlni not elloeedlnr In any oalendar year Five Peroent (596) of the oomblned value of the prlnolpal of this trust and the trust for suoh ohlld under Parlll'aph SIXTH at the end ot suoh oalendar year on a non- oumulatlve buls. 2. Two yelJ'l atter the date of my death, to pay to suoh ohlld an amount of prinolpal equal to the 81oell, If any, of TWO HUNDRED THOUSAND DOLLARS ($200,000) over the amount of prlnolpal suoh ohlld reoelves under Parlll'aph FIFTH (a) 2. or FIFTH (b) 2. B. 3. At any time after three years trom the date of my death, to pay to or apply for the benetlt of suoh ohlld so muoh of the . '~ prlnQrpti.:~, E1Y Trustee deems advisable tor his or her malntenanoe, eduoatlon, health and support 'WIthout oonslderlnr tunda available to him or her from other sauro... 4. Upon the death of suoh ohlld, to pay the remalnlnr prlnolpal to Sl~oh persons, Inoludlnr his or her estate, In suoh manner and shares, for suoh estates, or upon suoh trusts u suoh ohlld may appoint In his or -15- . r-., r-., PE1l78 RJWlwp 12/18/87 ~er lut WW by speolflo referenoe to this genera.l power and, subJeot to subpuarrlph (0) below, to pay the prlnolpa.l not effeotlvely so appointed to the then living desoendants of suoh child, per stlrpesl and In default of such desoendants, to my then living descendants, per stirpes, any additional shue of a desoendant of mine for whom a trust Is then In existence under this para(1'aph to be added to suoh trust, to be held under the terms thereof as applied to olroumstances then existing. (c) If any shue would otherwise be distributable under this parail'aph or under Parail'aph FIFTH (b) 2. A. to a il'andchlld of min. Wtlll hu not then attained age thirty-five (35), I direct my TrilJtee to retlln such shue In a further separate trust, and 1. To pay at least quarterly the net Income thllrefrom to such grandchild. 2. To PlY to or apply for the benefit of such rrandchlld so much of the prlnclpa.l as my Trustee, In Its sole discretion, deems advisable for maintenance, education, hea.lth and support alter considering fundi (other than funda pUling under Parail'aph SIXTH) available to him or her from other souro... 3. Upon such grandchild attaining Ilge thlrty- five (31), to PlY the remaining principal to him or her. 4. Upon the death ot any such i1'andchlld before the entire prlnclpa.l of his or her trust has been distributed, to pay the remaining prlnolpal to such persons, Inoludlng his or her estate, In suoh manner -16- ~ (', PE1178 RJWIWp 12/18/87 . and IIW'IIt for luoh eltatel, or upon suoh trUJts as such grandohlld may appoint In hll or her lut Will by speolflo referenoe to this general power. and to pay the prlnolpal not effeotlvely so appointed as followsl A. To the then IIvlnr descendants of suoh rrandohlld, per stirpes. B. In default of suoh desoendants, to the then IIvlnr desoendants, per stlrpe., of suoh grandohlld's parent who I. a deloendant of mine and who has desoendants then IIvlnr. C. In default of suoh doscendants, to my then lIvlnr desoendants, per stirpes. O. Any additional share of . ohlld or rrandohlld of mine for whom a trUJt Is then In existence under this pll'qraph shall be added to such tl'Ult, to be held under the terms thereof u applied to clrcumstancel then IIlstlnr. (d) If at any time there I. no one living who Is entitled to Inoome or principal under the forero1ni provlslolll of this pll'arraph, to pay said principal to those pel'lolll who would be entitled thereto under the Inte.tate lawI of the Commonwealth of Penn>>ylvanla then In effeot had I then died Inttttate, unmll'l'led and without surviving descendantsl provided that any Interttt "hioh wculd otherwise pw to suoh Commonwealth under suon laws shall be paid to a oharlty or oharltles seleoted by my Truste.. In Truste,'s sole dlsoretlon. -17- ~ 1"'"'\ PE1l78 RJWIWp 12/18/87 (e) Except u provided In Pararraph THIRTEENTH (I), all Income accrued or undistributed at the death ot an Income benetlclary shall , I be paid to the succeedlnllncome or principal beneficiaries. EIGHTHI Pel'[letultles Provision. If any trust hereunder hu not already terminated by Its terms, It shall terminate one day betore twenty-one years atter the death of the survivor of such of my said wife and my descendants II are \lvlnsat my death, and the principal shall then be distributed absolutely to the persona then recelvln, Income from such trust In proportion to their respective Interests In the Income. NINTHI Allocatlon of Income. If my wife, RUTH N. EBERLE, survives me, until the trusta under Pararraph FOURTH and FIFTH are finally funded In accordance with the provisions of Pararraph THIRD, my Trustee shall estlmatl thl approxlmatl amounts ot each trust annually, and, bued on such estimate, shall detlrmlne u fairly u possible thl share of net Income attributable to each tl'1lJt and shall pay thl share ot net Income thus determined In accordance with thl provisions applicable to eaoh trust. Such determlnatlon shall be madl In the absolutl discretion of my Trustee exclpt that any dlmlnutlon ot Inooml occulonld by thl pa7mlnt of death tues, shall be attributable tc the trust under Pararraph FIFTH to which .uch tUI. shall finally be allccated. My Trustee shall not bl hlld lIabll for any dlffel'lnce between the amounts of Income so paid and the exact amount of Incoml of the trusts II r1nally determined, which wu produced prior to the . time the trusts were r1na1ly tunded, other than II hereafter lit torth. It the -18- . , ~ f""., PE1178 RJWIWp 12/18/87 amount of Inooml paid to my said wife pUl'tuant to my Trustee's determination .xoelell that to whloh she may be entitled, no reooupment shall be made from the sub.equlnt Income to whloh she may be entitled. If the amount of Inoome paid to hlr t. Ie.. than that to which she was aotually entitled, my Trustee shall Immediately pay to her suoh deflolenoles out of the Inoome from or prlnolpal of thl trult undlr Pararraph FOURTH. TENTH. Dlsolalmer. If any person otherwise entitled to takl hereunder (or such person's leral repr..entatlve) tiles a written disclaimer, In whole or In part, with respect to any provlllon of thl. Trust with my Trustee within the' period allowed by Stotlon 2518 of thl Internal Revenue Code, suoh person (I) shall be treated u havlnr prldloeued me for purpo.e. of holdlnr or dlstrlbutlnr the disclaimed share, and (II) shall not partlolpatl In any decision to payor apply thl Inoome or prlnolpal of thl dlsolalmed Shari to or for thl benefit of any person hereunder, but suoh person sh.all not be treated as havlnr predeoeued me for p\ll1loses of holdlnr, dlstrlbutlnr or partlolpatlnr In any suoh decision under any provision to whloh the dlaolalmer does not extend. ELEVEUTHI Spendthrift Provision. .' '.~---..... , f\ No beneficiary shall have the rlrht or power to seU, uslm, ennumber or otbIrwtM antlolpatl the prlnolpal or Inoome whloh he may at any time bl entltlld to reo live, and no such Interlllt shall be taken by leral or equitable proOelS In satlsfaotlon of any debt or liability of suoh beneflolary while In the pOilU. Ion of trust.e, or prior to the aotual distribution thereof to the beneflolary so entitled. -19- . , ~ ~ PE1l76 RJWIWp 12/18/87 TWELFTHI Death Taxes. To the extent that they have not been paid from my testamentary estate as provided In my Will, death taxes (and Interelt and penaltlea thereon) Impo.ed u a result of my death upon the prlnolpal of this Trust, upon pro\'lerty paulnr under my Will and upon proceeds of Insuranoe on my life, but not otherwise, shall be paid out of the prlnolpal of the Rulduary Trust, eaoh share thereof, whether outright or In trust, to bear a pro rata portion of such taxesl provided that If my said wife falls to survive me, suoh taxes (and Interest and p.naltle. thereon) sh.all be paid out of the principal passlnr under Pararraph FIFTH (b) 2. A. and C., eaoh share thereof, whether outrlrht or In trust, to bear a pro rata portion of suoh taxes, and If suoh prlnolpalls Insufflolent, from Pararrapb FIFTH (b) 2. B. TffiRTEENTHI Administrative Powers. My Truatee shall have the foUowlnr ~wers In addition to thoee oonferred by law until all property Is dlstrlbutedl (a) To retain any real or personal property (Inoludln, stook of the oorporate Truatee 01' of a company oontroUlnr It) In the form In whloh It Is reoelvedl provided however, that lnumuoh II more than sixty peroent of my present total assets consist of oommon shares In AMP, Ino. (Inoludlnr AMP, Ino. "endorsed common shares") a Delaware corporatIon having Its principal plaoe of buslne.. In Harrl.burr, Pennsylvania, I urre, but do not dlreot, that trustee praoeed In an orderly but not precipitous manner to sell suoh number of SMld share. that when added to the sales thereof by the exeoutor of my probate estate the total of ,uoh sales wtll reduoe the combined holdlnp In my estate and trust by at leut ftft7 peroent. this reque.t Is made, not beoauae of my laok of faith In the contInued rrowth of AMP, Ino. with whloh I have been assoolated for forty years, but In reaornltlon of the faot that sale. oan then be made without larte oapltal ralna tu.. to assure funds for more diverse Investments by truatee and to provide liquidity In my estate and ouh needed to pay at least part of the withdrawals to whloh my ohlldren beoome entitled under Pararraph FIFTH. -20- , " ~ ,..,.., PEl178 RJWIWp :2/18/87 (b) To seU at ~ubllo or ~rlvate sale tor cuh and/or oredlt, to exchanre, and to leue tor any period of time, any Nal or personal property and to give options for suoh sales, exohanges, or leues. (0) To purohue all forms of property, Inoludlng but not limited to stooks, bonds, notes and other seourltles (lnoludlng stook of the oorporat. Trustee or of a company oontrolllng It), oom mon trust funds and real estate, or any variety of real or personal property, without belnl oontlned to so- oalled IlIallnvestmentJ and without regard for the principle of dlverslfloatlon. (d) To purohue seourltles at a premium or dlsoount and to chll'le suoh premium or oredlt suoh dlsoount to prlnolpal or Inoome. (e) To exerolse any option arlr,!nr trom the ownershll' of any lnvestmentl to join In any reoapltc~zatluii, m'J!'ier, reorranlzatlon, liquidation, dissolution, oonsolldatlon or voting trust plan affeotlng any Investment, to delegate powers with respeot theretol to deposit securities under arr..menta and pay usessmentsl to subsorlbe for stook and bond prlvlllflll and renerally to exercise all rlrhts of seourlty holders. (f) To hold property unregistered or In the name ot a nominee. (I) To mortgare, divide, alter, repair and Improve real property and generally to exerolse all rlrhts of real estate ownership. (h) To distribute In ouh, In kind, or partly In each, and to oausa any share to be oomposed of oash, property, or undivided traotlonal shares In property different In kind trom any other share. (I) To oompromlse olalms by or against the trust fund, Inoludlnr but not limited to tax Issues and disputes, without order of court or consent of any patty In Interest and without regard tor the etf."t of suoh compromise on any Intlrest hereunder. Ol To borrow money and to pledge any real o-r' ~ersonal property u seourlty for the repayment thereof. (k) To buy real and personal property from the personal representatives of my estate, and to lend money to them upon suoh terms and oondltlolll u my Trustee deems advisable, even If any of my personal representatives Is wo a Trustee of this Trust. (I) To apply 'noome tor the benefit of any Incapacitated Individual to whom Inoome mayor must be distributed tor any reuon durlnl the periOd of Inoapaolty. Inoome not so applied shall be -21- . , ''1 A PE1l76 RJ\'II"Np 12/18/87 ~' aooumulated, Invested, and If not sooner applied, paId to suoh Individual I pon ralnlnr ol4laolty or to hll or her personal representative If he or she die, b fore ralnlnc oapaolty! provided that alllnoome from the Qualified Terminable Interest Trull shall be paid to, or applied for the benefit of, my said wife at leut annually. (m) With respect to a prlnolpal share vestln, In a beneflolary who, In the opinion of my Trustee, Is Inoapaoltated by reuon of I11ness (mental or ph7l10al) when suoh share vests In him or herl to hold the share durin, hi. or her Inoapaolty and to Invest the share and all aooumulatlona thereonl to apply so muoh of the Inoome and principal as my Trustee deems advIsable for suoh beneflolary's benefit tor any reuon without oonslderlnr other tunds available to him or herl and to deliver the balanoe of prlnolpal and Inoome to the benetlolary at suoh time u he or she gains oapaolty. In addition, at any time to pay the entire share to the ifIlardlan of the person or the estate of the Inoapaoltated beneficiary to hold for his or her benefit, The reoelpt of a iUardlan or suoh other person u may be seleoted by my Trustee to receive a distribution under this subpararraph shall be a full and oomplete dlsohll'ie to my Trustee. (n) Whenever Trustee- determine. that the si... of any trust doel not warrant the oost of oontlnulnr It, or that Ita administration would be lmpraotloal tor .ny other reuon, to pay the prlnolpal without further responslbl11ty to the persons then entitled to any Inoome dlltrlbutlons thereunder In proportion to their respeotlve shares of Inoome, subjeot to the provisIons of subpararraph (m)1 provided, however, that no Trust.. sh.all partlolpate In any deolslon to termInate any trust of which he or she Is a current Income beneflolary hereunder. (0) To pool the wets of all separate trusts hereunder for Investment purposes, alloaatlng to eaoh suoh trust an undivided proportionate Interelt In the pooled wets. (p) To meree any trust hereunder with any other truat held by Trust.e created by my said wife by WI11 or Deed. If the trusts are for tha primary benaflt of the same persons and oontaln substantIally Identloal term.. (q) Unless a oorporate tlduolary II then servlnr, to emplCl1 aocountants, arents, Investment oounsel, brokers, bank or trust oompany to parform IIrvloes for and at the expense of any trust or tr\lSts hereunder for whloh suoh servloes are performed and to oarry or register Investments In the name of the nominee of suoh arent, broker, bank or trust oompany. The expenses and oharres for suoh servloes shall be oharred aralnst prlnolpal or Inoome or partly aralnat eaoh u my Trustee may determine. My Trustee Is expressly relieved of any liability or responsibility whatsoever for any aot or failure to aot by, or for followlnr the advloe of, suoh aooountants, qents, Investment oounsel, -22- I I' . t"""I I~ PE1178 RJWIWp 12/18/87 brokel'l, ban1c or trust oompany, so lonr u my Trustee exerolses due oare In their seleotlon. The faot that a Trustee may be a member, shareholder or employee of any aooountlnr, Investment or brokerage firm, agent, or bank or trust oompany so employed sh.all not be deemed a oontllot of Interest. Any OOmpflnSatlon paid purslWlt to this subpararraph shall not affeot In any manner the amount of or the rlltht of my Trustee to reoelve commissions u a flduolary. FOURTEENTHl Custodian under the Uniform Gifts to Minors Aot. I appoint the surviving puent of a desoendant of mine under the are of twenty-one (21) reoelvlng a prlnolpal shue hereunder custodian for suoh desoendant to reoelve suoh share under the Uniform Gifts to Minors Aot of the state where suoh desoendant resides. FIFTEENTHI Administrative Provlslol\J. (a) A beneflolary's Inoapaolty shall be determined solely by my Trustee. The Inoapaolty of a beneflolary who la alIo a Trust.. Ih.all be determined solely by my other Trustee. No Trustee who II alao a beneflolary hereunder, If Inoapaoltated In the opinion of my other Trustee, shall partlolpate In any deolslon. to apply Inoome for his or her benefit. (b) No Trustee hereunder shall putlCllpate In any deolslon to pay Inoome or prlnolpal to or for the benefit of himself or herself or any Individual whom he or she Islerally obllrated to support. (0) The reoelpt of any payee of a payment for the . benefit of an Ino..paoltatad beneflolary shall be a oomplete dlsohll'le to my Truat... SIXTEENTHl Life Insuranoe. (a) ~y Trustee Is not required to pay premiums or ohll'les on life Insuranoe polloles. ~y Trustee may settle disputes under suoh .23- " , ,A, ("'., , PE1l78 ltJWIWp 12/18/87 pollolelt but I. not required to sue on suoh polloles unlet. my Trustee holds fundi hereunder out of whloh my Trustee may be relmburled against all elqlensll ot suit, 'ncludlnr leral fees. (b) I release the life Insuranoe oompanles from any re.ponslblllty to see to the exeoutlon of the trusts created by this Arreement of Trust or the applloatlon of the prooeeds of the polloles. (0) I reserve all rights now or hereafter vested In me under the life Insuranoe polloles sUbJeot hereto, Inoludln, but not limited to the rllht to reoelve the prooeeds of any polloles whloh may mature and be payable before my death, the rlrht to ohange beneflolarles, to borr.Jw on the pollole., to surrender polloles and reoelve oash value thereof, to Ullm and pledle the pollole. for any loan, and to reoelve the dIvidendi and all other paymentl available to the Insured. SEVENTEENTH, Rllrtlt to Amend or nevoke. I reserve the rlrht at any time or times, by written 11IItrument other than a Will lodred with my Trustee, to amend or revoke this Arreement of Truat In whole or In part, provided that the dutl." powers and liabilities of my Trustee shall not be subttantlally Inoreued without my 'I'rustee's written oonsent. I may add otber property to this Trust and any other person may do the same, provided that my Truat.. consentlln wrltlnr to eaoh suoh addition. EIGH".'EENTHI ~etlnl tlons. (a) The word "Trustee" when used In thIs Arreement of Truat shall Inolude all genders and the singular and plural as the oontext may require. -24- , " I '" /""", PE1l78 RJWIWp 12/18/87 (b) The wordl "desoendants," "rrandohlld" and "rrandohlldren" when used In this Arreement of Trust shall Inolude adopted persona and their deso*ndant.. (0) The words "Incapaoltated" and "Inoapaolty" when used In this Arreement of Trust shall refer to an Inability to use funds by reason of are or Illness (mental or physloal). (d) When a "per stlrpe." distribution of Inoome or prlnolpal .to a dellmated Individual's desolndentl Is provided for under this 'Arreement of TrUlt, suoh Inoome or prlnolpal- shall be divided Into u many equal share. u there are then IIvlnr ohlldren of such Individual and then deoeutd chIldren represented by desoendants then IIvlnr. and eaoh then IIvlnr ohlld shall reoelve one share, and the share of eaoh deoeued chIld sh.all be divided amonr his 01' her desoendants In the same manner, repeatlnr this pattern with respeot to suooeedlnr reneratlons until all sharea are determined. (e) Pararraph hllCllnp In this Arreement of Trust are Uled for referenoe only and shall not affeot the meanlnr, oon.truotlon or effeot of this Arrllment of Trust. (f) All references In this Arreement of TrUlt to the Internal aevenue Code shall mean the Internal Revenue Cod. of 1988, u amended 01' rllll&Clted, and all oorreapondlnr provisions of any subsequent federal tax laws and rqu1atlons thereunder. -28- " , f""\ t"'l P E 1118 RJWlwP 12/18/87 NltfETEENTHI Trustee. (a) Upon my reslrnatlon or Inoapaolty u trustee, or If neither OOOUl't then upon my death, the sucoessor trustee or trustees shall bel 1. DAUPHIN DEPOSIT BANK AND TRUST COMPANY, Harrlsburr, Pennsylvania 17105, whloh shall automatloally and Immediately sucoeed to suoh offloe without the neoesslty 01 a formal written aoceptanoe unle.. required by some Interested party or applloablelaw. 2. ;.\y wife, RUTH N. EBERJ.E, It she so eleots by mlnr her written aooeptanoe of suoh offloe with said oorporate trustee within thirty days of my termination u t:'.:stee. (b) I appoint eaoh chIld of mine co-Trust.. of the trusts for such chIld under Pararraphs FIFTH(a)2., SIXTH and SEVENTH. (0) I appoint eaoh rrandchlld of mine oo-Trustee of the trusts for suoh rrandohlld under Pararraphs SIXTH and SEVENTH upon suoh rrandohlld aUalnlnr lie twenty-five (25). (d) Any suooessor trustee shall be and Is hereby relieved otall respol\llbllltv for my aots as trustee, and ( waive an aooountlnr u a oondltlon preoedent to the undertaklnr of suoh responsibility by the suooessor truat... (e) If my wife beoomes a oo-trustee, sh. shall reply In wrlUnr to any Investment advloe or aotlon reoommended by said corporate truat.. within twenty days of mailing or personal delivery thereof I upon her failure to respond the corporate trustee may aot In aooordanoe with such advloe -28- I, ,. " " :1, ;. I' I. ,. ", ,! '" " ,I t, n ~ COMMONWEALTH OF PENNSYLVANIA COUNTY OP On the 29th me, Lisa A. Miller SS. day of December PEWS RJWIWP 12/18/87 1987,betore , a Notary Publlo, personally appeared WITNESS my hand and notarial seal. "., ,I'. I, , , ,,, ". , JOHN E. EBERLE, and In dUll form of law acknowledred the. abovelnatrum.nt to be his lot and deed and desired the same mlrht be reoorded u suoh. , ,. ,I' I;. I, " to. " " , , ,.' " " , " I,. .,. d. " " " ," I, ., /. 'j,l ,. ., sl Lisa A. M~ler Rotary pu6l1o . , j,' , " " " , , , I , , i( , ;' . : . , . , , 'I; I. , " ,. ,1 " . " ..i , ': ,. " , " . ., " ji " " " , , "i ". " "I ." ,. ,. ., ., /, . ~ '""" FIRST ADDENDUM TO THE FIRST AMENDMENT TO AGREEMENT OF TRUST I, JOHN E. EBERLE, of New Cumberl.and, Pennsylvania, have entered into an Agreement of Trust dated June 18, 1986, as amended by a First Amendment to Agreement of Trust dated Deoember 29, 1987 (the Agreement of Trust and the First Amendment thereto hereafter referred to as the "Agreement"), with myself as Trustee. Under Paragraph SEVENTEENTH of the Agreement, 1 retained the right to l\mend or revoke the Agreement in whole or in part by written instrument, other than a Will, lodged with the Trustee. Retaining the further right to so amend or revoke the Agreement, I hereby amend the Agreement as follows: 1. I hereby revoke Paragraph FIFTH (a)2.D and in lieu thereof substitute the following Paragraph FIFTH (a)2.D: D. Upon the death of any such ohild before the entire principal of his or her trust has been distributed, to pay the remaining principal to suoh credi tors of the child I s estate, in such manner and shares, for suoh estates, or upcn such trusts as such child may appoint in his or her last Will by specific raference to this general power, and to add the remaining principal not effectively so appointed to the Nonexempt GSTT Trust under Paragraph SEVENTH to be held under the terms thereof as applied to circumstances then existing. 2. I hereby revoke Paragraph SEVENTH (b)4. and in lieu thereof substitute the following Paragraph SEVENTH (b)4.: ,,, , " ,,, 'I." " ,', ~, " 'i " .. ,. ,\ ,. , " , " .. " I'" " I', " ',I' , " " d'i ,) ,,1< ,! '." \. , , " ,. " " , " Q ,. ," , 'I, ;, i, .. ,,\1; ;" " " '-" " " " ,. ,. ,. " , I, , , , ' , '-', ' , APPRAISAL FOR MERCEDES BENZ 300D < -,. . , ".' .' ; , ,. " I' ,I,,' !-" , .,' " ". ". "'Ii i' :r, ",' '.' "ir_ }, " ,I,; " " ", " .'" " q I " ','. " , " ',i " , ,,' " ,1. "1", 1\ ": I, ,J j, ,,, \'. 'I ,( j: ,. q Ii. ,,! ..' " " " " , ,l-j-t, " .'i\ ;,.'" , ", " .. .1 I.t.' (' i" I/! " , " ,f: " I ~ ,. " " , '" '!' , , " " " :' " " '", ,. " ,q " '," \. " ," 'I' " 'f' . ,-', j " 'j. II., " ", " " ,I:" "I' ;,I',d' '1" ,. ',,'I' ,',' " (. I Ii " .\1' ,.' ':1' ,'1, \ ~ ,. ," i' " , (1" " " ll! ,.\" \-;. , i,',;', /1 '_I' " " " I , , " I .. " ./ ,/ ,/ ',. " " ,.1 _'_',.,t ........:.___...__ __,..I ._ .,-r,. __ ,ft{l!t~\~tlB!#l~W,M~lt\~f!i1r;rIN\MJi!H '.. '. _, _ .i. ,,''':>;' -'1-.. -" ,'-_1'\':'>' ~"lf {'/~:W),\liWjtl!', ),t,,'rj~rU:!J~1"~jftF--:~!fl~W:l1:'lf'id#\1,;'}.w-rtM~M~~- C h' " ,.-' ./, ~ '/, " ., " ,. ,. I:, ,. ,I " 'II DISCLAIMER OF RUTH N. EBERLE. '1-, f,. I ,: ,. " ., I' I,', " " ,f ,. /' l'lii ,. , " " " I'" ,. " i' I, ,. " I" 1'\: I' ',I i" ,. " ,. q J, " "1; I,'" ,',1 li " ./, ,-,1 " i!,I',o.\: ., j, " ii" ,'/ " " ,. , " " , ,. iL , , " " ,. ,. , ,. " ,I " " /, I , " , !; " il.," J!-' " , '"~ I' Ii " l',' 'J" It"" , , 'j 'i' , I, ,I" , I , 1'1 " .,'1, , I '. I "i' " , " " " ,'I' " 'I " " 't- ",\ \ I 't', ~', , "'1- 'i " " '.\; " 'I ,'; ,: i , , " " , I ,,1- ,It'L to. ,'; I' "i" 'i, p,l:' ", ;;' , , ,"i I' , "l, I, ,'fi " ,. II, Ii " " .'.' ", " " , " , " " '. .. .. " I " " 'II" , '"I< .. " '"~ ,. I' .' , , ."'" r."\ .~, C' , . ... '( IN THE COURT OF COMMON PLBAS CUMBERLAND COUNTY, PENNSYLVANIA ORPHANS' COURT DIVISION NO. 508 of 1994 IN REI JOHI I. EBERLE TRUST UNDO AGREEMENT '", i DISCLAna:R AND RIH1JKCIATION , ~I I, Ruth N, Eberle, an adult individual of 617 Allen street,' New~erland, Pennsylvania, do hereby exercise the rights granted to me under Chapter 62 of the Pennsylvania Probate, Estates and Fiduciaries Code, 20 Pa. C.S.A. 56201 ~ JIg., and 552046 and 2518 of the Internal Revenue Code of 1986, as amended (the "Code"), and hereby irrevocably and absolutely, and without qualification, disclaim and renounce any and 8.11 right, title, claim or interest I possess under ARTICLE FOURTH (b) (QTIP Trust No.2] of the John E. Eberle Trust Undflr Agreement dated June 18, 1986, as amended (hereinafter the "Trust"), including, but not limited to (i) all assets, including principal and income, to be held or distributed to me or for my benefit under the provisions of said ARTICLE FOURTH (b) [QTIP Trust No.2] of the Trustl and (ii) the right of my estate to receive any payments or contributions under ARTICLE FOURTH (b) (2) (A) of the Trust, I intend this disclaimer and renunciation to constitute a "qualified disclaimer" under 52518 of the Code of my entire interest under ARTICLE FOURTH(b) [QTIP Trust No.2] of the Trust. The foregoing disclaimer and renunciation shall not include a disclaimer or renunciation of any other interests passing to me under the Trust, or as a consequence of the death of John E. .. .~(.H , ,.". I', -""'.~ '.~---:"" " " " " - ~ .... , I'.. " I' .' .' " ,-' ~'\', I' " ,,. \ :.;~; ',I, ,,. , , '. 'II " ,: , I,L: I 'I ',', .' " " , " , " . " , " , \~ '\" I, ,'\' I. 'I"~ It ,'~\\ " 'L'<'I 'I !\ I, ".1 " " ,,!~ d(/- 9'1- RnOAp. .. SINON ATTO"NEV. AT LAW ONE SOUTH M."KET I)QUA..C p,O, BOK 1148 HA""I=..t_'!'l~, ..... 17108-11... Ms'. Mary C. Lewis Register of Wills Cumberland County Court House 1 Courthouse Square Carlisle, PA 17013 'HAND-DEl-IVERED ,I' "I';, " " " ", ~L, , ,. " l,r , " " , " .. , .. . ,.j d, , I , , I, . , " , " , .. I ,I' ,I WI' '" \I , I , i , I 'I I , , , i, ", ,': ; ~ , , , " " ',';! I, , .1..\'\ I , il , " ','~i I" I ,,; , , .- ", " f,i , , " 101\ I .. ,. ',if , I , ~ , .- 'If' i , , I " ''1'/ I i , .' , i' .- " ! '~ .- " " I I , \' ", , , , " I, I' . , '", )i" f,