HomeMy WebLinkAbout10-19-07
PETITION FOR PROBATE and G~NT OF LETTERS
Estate of Walter T. Morrison No. '-07 -Qg5D
also known as To:
Register of Wills for the
, Deceased. County of Cumberland in the
Social Security No. 189-36-7261 Commonwealth of Pennsylvania
The petition of the undersigned respectfully represents that:
Your petitioner(s), who is/are 18 years of age or older and the execut rix named
in the last will of the above decedent, dated June 28. 2006
and codicil(s) dated
(state relevant circumstances, e.g. renunciation, death of executor, etc.)
Decedent was domiciled at death in Cumberland County, Pennsylvania, with
h is last family or principal residence at 510 Partridge Court. Mechanicsbura. Pennsvlvania 17050
(list street, number and municipality)
Decedent, then 59 years of age, died 8/27/2007
at Harrisbura Hosoital. South Front Street. Harrisbura. Pennsvlvania
Except as follows, decedent did not marry, was not divorced and did not have a child born or adopted
after execution of the will offered for probate; was not the victim of a killing and was never adjudicated
incompetent:
Decedent at death owned property with estimated values as follows:
(If domiciled in Pa.) All personal property
(If not domiciled in Pa.) Personal property in Pennsylvania
(If not domiciled in Pa.) Personal property in County
Value of real estate in Pennsylvania
situated as follows:
$
$
$
$
10.000.00
WHEREFORE, petitioner(s) respectfully request(s) the probate of the last will and codicil(s)
presented herewith and the grant of letters testamentary
thereon. (testamentary; administration c.I.a.; administration d.b.n.c.t.a.)
~J~P~
Jul P. Morrrson
510 Partridge Court
Mechanicsbura
PA 17050
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OATH OF PERSONAL REPRESENTATIVE
COMMONWEALTH OF PENNSYLVANIA } 55
COUNTY OF Cumberland
The petitioner(s) above-named swear(s) or affirm(s) that the statements in the foregoing petition are
true and correct to the best of the knowledge and belief ofpetitioner(s) and that as personal represen-
tative(s) of the above decedent petitioner(s) will well and truly administer estate according to law.
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subscribed {
day of
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Estate of Walter T. Morrison , Deceased
DECREE OF PROBATE AND GRANT OF LETTERS
AND NOW OC.-1uho /\.... dd.
!1(Y) -,
, in consideration of the petition on
the reverse side hereof, satisfactory proof having been presented before me,
IT IS DECREED that the instrument(s) dated 6/28/2006
described therein be admitted to probate and filed of record as the last will of Walter T. Morrison
and Letters T estamentarv
are hereby granted to
Julie P. Morrison
FEES
Probate, Letters, Etc.. . . . . . . . $ 45 ,{ ~")
Short Certificates ( }...... $ 1...\. 00
~.W\\\. .. .. . .. $ IS"'.CJ::>
Jc..P . IQ. uu
. ~t/l~ 6,()C)
TOTAL _ $1<1.60
Filed. . .19.1 ?-~...JL.0?:1. . . . . . . . . . . .
, HL111M- '4r4" t~ (J1w~r
R'g""" of Will, ~~ ~.~
Amy M. Moya, Esq. :ro
91402
ATTORNEY (Sup. Ct. LD. No.)
4811 Jonestown Road, Ste 226
Harrisbura PA 17109
ADDRESS
717-652-7323
PHONE
RECORDED OFFICE OF
REGISTER OF WILLS
2007 OCT 19 PM 3:31 \
CLERK OF iY
ORPHANS' COURT .'""(\
CUJ'vlliERL\ND CO., PA
I(il/I'~ .
LOCAL REGISTRAR'S CERTIFICATION OF DEATH
WARNING: It is illegal to duplicate this copy by photostat or photograph.
Fee for this certificate, $6.00
P 13822866
Certification Number
Hl05.143 REV t112006
TYPE / PRINT IN
PERMANENT
BlACK INK
This is to certify that the information here given is
correctly copied from an original Certificate of Death
duly filed with me as Local Registrar. The original
certificate will be forwarded to the State Vital
Records Office for permanent filing.
-/.........~,~lQ'M ~lyl!d1
\:cal Registrar . . Date Issued '
RECORDED OFFICE OF
REGISTER OF WILLS
2007 OCT 19 PM 3:31~. .
CLERK OF .
ORPI-L-\NS' COURT
CUMBERLAND CO., PA
COMMONWEALTH OF PENNSYLVANIA. DEPARTMENT OF HEALTH. VITAL RECORDS
CERTIFICATE OF DEATH
(See Instructions and examples on reverse)
5 Age (lasl Birthday)
1, Name of Decedenl (FirSl, middle, lasl, suffix)
Walter T. Morrison
6, Dale of DiM (Month, de ,
7.~j and.....or
59
October 17,1947
v"
Sb. County of Death
Dauphin
8d FaciiIy Name I' noI"""",", jjve..... and.......)
Harrisburg Hospital
11 Decedent's Usual Occ 'lion Kind 01 work dooe
Kind of Wul1I
Cheif Auditor
Iile, Do not Slaltfebr
12. Wa$ Oecederd ever in lhe
U.S. Atmed Forces?
DVe, 5iIto>
Ileceder(,
AclualResidence 17a, Slale
13. llecedenr, EdrJce"'"ISpedly only higlles'!18do_ed)
Elementaly I Socoodruy 10-121 CoIege (1-4 Of 5+1
12 4
. 16. Decedent', MWlg Address (S1teel, city flown, stale, zip code)
510 Partridge Court
Mechanicsburg, PA 17050
PA
Cumberland
170 Counly
19. UoIher's Name (Fil'st, midtIe, maiden 1UITIIA'le)
Vera McGoff
18 Falhe(s Name (Flfst. middle, last, sultix)
Vern Morrison
201. Inlormant's Name (Tw>e / Prim)
14.......SIa.."_,__,
WIdowed, -($J>ocI)I
Married
Oid_
Uveina
Township?
17e, jiI Yes, OecedenIlivecl i1
17dtJ No,_"""_
_UolIiIscl
Twp.
ClOy/Bore
Julie Morrison
20>. blbmant'MailngAddr'" ISIt.... ciIy/_ -,zipoodol
510 Partridge Court Mechanlcsburg, PA 17050
21d. lor:IlionIClOy/_,_, zip_)
Schaefferstown, Pa. 17088
21c. PlaceclOisposilion IName 01 cemelery,_"'_"""I
Conolite Crematory
August 30. 2007
22<:. Name "" Address cI F_
Myers Funeral Home, Inc. 37 East Main Street Mechanlc.burg, PA 17055
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Last Will and Testament
of
Walter T. Morrison
I, Walter T. Morrison, a resident of Mechanicsburg, Cumberland County,
Pennsylvania, revoke any prior wills and codicils made by me and declare this to be my
Last Will and Testament.
Article One
Family Information
I am married to Julie P. Morrison. We were married on October 28, 1972. Any reference
in my will to my wife is to Julie P. Morrison.
I have two children. Their names and dates of birth are:
Nicole D. Smith, born on February 12, 1975
Erik M. Morrison, born on January 31, 1978
All references to my children in my will are to these children.
References to my descendants are to my children and their descendants.
Article Two
Specific and General Gifts
Section 2.01
Disposition of Tangible Personal Property
I give all my tangible personal property, together with any insurance policies covering
such property and claims under such policies in accordance with a "Memorandum for
Distribution of Personal Property" or other similar writing directing the disposition of
such property, which shall be dated and signed by me.
Page 1
RECORDED OFFICE OF
REGISTER OF \VILLS
2007 OCT 19 PM 3:31 ;
CLERK OF
ORPHANS' COURT
CUlvIBERLAND CO., PA
Section 2.05
Nomination of Substitute Custodian
I nominate Nicole Smith as Substitute Custodian for all Uniform Transfer to Minor's Act
accounts for which I am acting as Custodian. I also nominate Nicole Smith as Owner of
any 529 college savings accounts or plans for which I am the owner. If Nicole Smith is for
any reason unable to serve, I nominate Mark Smith as Substitute Custodian and Owner.
Article Three
My Residuary Estate
Section 3.01
Definition of My Residuary Estate
All the remainder of my estate, including property referred to above that is not effectively
disposed of, shall be referred to in my will as my "residuary estate."
Section 3.02
Disposition of My Residuary Estate
If my wife predeceases me, my residuary estate shall be administered as provided in
Article Five entitled "Distribution to My Beneficiaries."
If my wife survives me, I give my residuary estate to my wife.
Section 3.03
Disposition Upon Disclaimer by My Wife
My wife shall have the right within the time and in the manner provided by law to
disclaim her right to receive a specific portion or all of the property passing to or for her
benefit under my will. If my wife disclaims any portion of the property that would
otherwise be allocated to her, my Executor shall allocate the disclaimed property to the
Non-Marital Share and the Non-Marital Share shall be administered as provided in
Article Four entitled "the Family Trust." Ifmy wife disclaims any interest she has in any
portion of the Family Trust, my Executor shall dispose of the disclaimed interest under
the provisions of my will as though she had predeceased me.
Article Four
The Family Trust
My Trustee shall hold and administer the Non-Marital Share in trust as provided in this
Article. The trust will be referred to as the "Family Trust."
Page 3
Section 4.01
Family Trust Beneficiary
My wife shall be the only beneficiary of the Family Trust during her lifetime.
Section 4.02
Distribution of Income
My Trustee shall distribute all of the net income of the Family Trust to my wife at least
quarter-annually during her lifetime.
Section 4.03
Distribution of Principal
My Trustee shall distribute to my wife as much principal of the Family Trust as my
Trustee determines is necessary or advisable for her health, education, maintenance and
support.
Section 4.04 Guidelines to My Trustee
In making discretionary distributions under this Article, my Trustee should bear in mind
that my primary concern and objective is to provide for the well-being of my wife and the
preservation of principal is not as important as the accomplishment of this objective.
Section 4.05 Termination of the Family Trust
The Family Trust shall terminate upon the death of my wife. My Trustee shall administer
the balance or remainder of the Family Trust as provided in Article Five entitled
"Distribution to My Beneficiaries."
Article Five
Distribution to My Beneficiaries
Upon the death of the survivor of my wife and me, the Distribution to My Beneficiaries
shall be administered under the terms of this Article.
Section 5.01
Division of Remaining Trust Property
My Executor or my Trustee, as the case may be, shall divide all property allocated to this
Article into shares as follows:
Page 4
Name
Relationship
Share
Nicole D. Smith
Daughter
50%
Erik M. Morrison
Son
50%
Each beneficiary's share shall be administered as provided in the Sections that follow.
Section 5.02
Distribution of the Share for Nicole D. Smith
The share set aside for Nicole D. Smith shall be distributed to her outright.
If Nicole D. Smith is deceased, her share shall be distributed per stirpes to her living
descendants or, if none, pro rata to the other beneficiaries named in this Article. If there
are no other named beneficiaries her share shall be administered as provided in Article
Six entitled "Remote Contingent Distribution."
Section 5.03
Distribution of the Share for Erik M. Morrison
My Trustee shall administer the share set aside for Erik M. Morrison in trust as provided
in this Section.
(a) Distributions of Net Income
At least quarter-annually, my Trustee shall distribute to Erik M. Morrison
all of the net income of his trust.
(b) Distributions of Principal
My Trustee shall distribute to Erik M. Morrison as much of the principal
of his trust as my Trustee determines is necessary or advisable for his
health, education, maintenance and support.
(c) Guidelines for Discretionary Distributions
In making discretionary distributions to Erik M. Morrison, it is my desire
to provide for his well-being and happiness. Although I request that my
Trustee consider the other known resources available to Erik M. Morrison
before making distributions, I also request that my Trustee be liberal in
making any distributions to, or for his benefit. I acknowledge that the
principal of the trust established for Erik M. Morrison may be exhausted
in making such distributions.
(d) Right to Withdraw Principal
At the intervals set forth below, Erik M. Morrison may withdraw from his
trust, at any time or times, amounts not to exceed in the aggregate:
Page 5
50% of the accumulated trust income and principal, upon
the funding of the trust created for Erik M. Morrison; and
All or any portion of the accumulated trust income and
principal, 3 years after funding of the trust created for Erik
M. Morrison.
These withdrawal rights are cumulative and the amount of each successive
withdrawal right shall be added to any then existing withdrawal right. The
amount of each withdrawal right shall be determined by applying the
applicable fraction to the trust's principal and accumulated income as of
the date Erik M. Morrison first has the right to exercise the withdrawal
right.
Erik M. Morrison may exercise this right at any time by delivering written
notice to my Trustee, setting forth the amount he desires to withdraw.
Upon receiving a notice, my Trustee shall convey and deliver to Erik M.
Morrison, free of trust, the amount requested in the notice. This right of
withdrawal is a privilege that may be exercised only by Erik M. Morrison
and shall not be subject to the claims of any creditor or to legal process
and may not be voluntarily or involuntarily alienated or encumbered. This
provision shall not limit the exercise of any power of appointment Erik M.
Morrison may have.
(e) Distribution Upon the Death of Erik M. Morrison
If Erik M. Morrison should die after the establishment of his trust, but
before the complete distribution of his trust, my Trustee shall distribute the
remaining trust property per stirpes to the descendants of Erik M.
Morrison. If Erik M. Morrison has no living descendants, my Trustee
shall distribute the balance of the trust property per stirpes to my
descendants.
If I have no living descendants, my Trustee shall distribute the balance of
the trust property as provided in Article Six.
(f) Distribution if Erik M. Morrison is Deceased
If Erik M. Morrison should die before the establishment of his trust, my
Trustee shall distribute Erik M. Morrison's share per stirpes to his living
descendants or, if none, pro rata to the other beneficiaries named in this
Article. If there are no other named beneficiaries my Trustee shall
distribute the remaining property under the terms of Article Six.
Page 6
Article Six
Remote Contingent Distribution
If, at any time, there is no person or entity qualified to receive final distribution of my
probate or trust estate or any part of it, then the portion of my probate or trust estate with
respect to which the failure of qualified recipients has occurred shall be distributed to
those persons who would inherit it had I then died intestate owning the property, as
determined and in the proportions provided by the laws of Pennsylvania then in effect.
Article Seven
Designation of Fiduciaries
Section 7.01
Executor
I name my wife as my Executor. If Julie P. Morrison fails or ceases to act as my
Executor, I name Nicole D. Smith as my Executor.
Section 7.02
My Trustee
I appoint my wife as my Trustee to serve as Trustee of any trusts created under my will.
If Julie P. Morrison fails or ceases to act as Trustee, I appoint Nicole D. Smith as my
Trustee.
Article Eight
Trust Administration Provisions
The provisions of this Article pertain to any trust created under my will.
Section 8.01
No Court Proceedings
Any trust created under my will shall be administered expeditiously, consistent with the
provisions of my will, free of judicial intervention, and without order, approval or action
of any court. A trust shall be subject to the jurisdiction of a court only if my Trustee or
another interested party institutes a legal proceeding. A proceeding to seek instructions
or a court determination shall be initiated in the court having original jurisdiction over
Page 7
matters relating to the construction and administration of trusts. Seeking instructions or a
court determination shall not subject a trust to the continuing jurisdiction of the court.
Section 8.02
Resignation of a Trustee
A Trustee may resign by giving notice to the income beneficiaries of the trust and to any
other Trustee then serving.
Section 8.03
Removal of a Trustee
No Trustee can be removed by any beneficiary, except for cause, which removal must be
approved by a court of competent jurisdiction upon the petition of any beneficiary.
In no event shall the court petitioned to approve the removal of a Trustee acquire any
jurisdiction over the trust except to the extent necessary to approve or disapprove
removal of a Trustee.
If a beneficiary is a minor or is incapacitated, the parent or legal representative of the
beneficiary may act on behalf of the beneficiary.
Section 8.04
Default of Designation
If the office of Trustee of a trust created under my will is vacant and no designated
successor Trustee is able and willing to act as Trustee, my wife shall appoint an
individual or corporate fiduciary as successor Trustee.
If my wife is unable or unwilling to act, a majority of the income beneficiaries of the trust
shall appoint an individual or corporate fiduciary as successor Trustee.
Any beneficiary may petition a court of competent jurisdiction to appoint a successor
Trustee to fill any vacancy remaining unfilled after a period of 30 days. By making such
appointment, the court shall not thereby acquire any jurisdiction over the trust, except to
the extent necessary for making the appointment.
If a beneficiary is a minor or is incapacitated, the parent or legal representative of the
beneficiary may act on behalf of the beneficiary.
Section 8.05
Notice of Removal and Appointment
Notice of removal shall be in writing and shall be delivered to the Trustee being removed
and to any other Trustees then serving. The notice of removal shall be effective in
accordance with its provisions.
Notice of appointment shall be in writing and shall be delivered to the successor Trustee
and any other Trustees then serving. The appointment shall become effective at the time
of acceptance by the successor Trustee. A copy of the notice shall be attached to my will.
Page 8
Section 8.06
Appointment of a Cotrustee
Any individual Trustee may appoint an individual or a corporate fiduciary as a Cotrustee.
A Cotrustee so named shall serve only as long as the Trustee who appointed the
Cotrustee (or, if the Cotrustee was named by more than one Trustee acting together, by
the last to serve of those Trustees) serves, and that Cotrustee shall not become a successor
Trustee upon the death, resignation, or incapacity of the Trustee who appointed the
Cotrustee, unless so appointed under the terms of my will. The Trustee appointing a
Cotrustee may revoke the appointment at any time with or without cause.
Section 8.07
Corporate Fiduciaries
Any corporate fiduciary serving as a fiduciary under my will must be a bank, trust
company, or public charity that is qualified to act as a fiduciary under applicable federal
and state law and that is not related or subordinate to any beneficiary within the meaning
of Section 672( c) of the Internal Revenue Code.
Section 8.08
Incapacity of a Trustee
If any individual Trustee becomes incapacitated, it shall not be necessary for the
incapacitated Trustee to resign as Trustee. A written declaration of incapacity by the
Cotrustee, if any, or, if none, by the party designated to succeed the incapacitated
Trustee, if made in good faith, will terminate the trusteeship.
Section 8.09
Appointment of Independent Special Trustee
If for any reason the Trustee of any trust created under my will is unwilling or unable to
act with respect to any trust property or any provision of my will, the Trustee shall
appoint, in writing, a corporate fiduciary or an individual to serve as an Independent
Special Trustee as to such property or with respect to such provision. The Independent
Special Trustee appointed shall not be related or subordinate to any beneficiary of the
trust within the meaning of Section 672( c) of the Internal Revenue Code. The Trustee
may revoke the appointment at will.
An Independent Special Trustee shall exercise all fiduciary powers granted by my will
unless expressly limited elsewhere in my will or by the Trustee in the instrument
appointing the Independent Special Trustee. An Independent Special Trustee may resign
at any time by delivering written notice of resignation to the Trustee. Notice of
resignation shall be effective in accordance with the terms of the notice.
Section 8.10
Majority Action of Trustees
If two Trustees are eligible to act with respect to a given matter, the concurrence of both
shall be required for action to be taken; if more than two Trustees are eligible to act with
respect to a given matter, the concurrence of a majority of my Trustees shall be required
for action to be taken.
Page 9
A nonconcurring Trustee may dissent or abstain from a decision of the majority. A
Trustee shall be absolved from personal liability by registering its dissent or abstention in
the records of the trust. After doing so, the dissenting Trustee shall then act with my
other Trustees in any way necessary or appropriate to effectuate the decision of the
majority.
Notwithstanding any provision of my will to the contrary, a Trustee may disclaim or
release, in whole or in part, by an instrument in writing, any power it holds as Trustee,
irrevocably or for any period of time that the Trustee may specify. The Trustee may
make the relinquishment of a power personal to the Trustee or may relinquish the power
for all subsequent Trustees.
Section 8.11
Disclaimer by Beneficiary Serving as Trustee
Notwithstanding any provision of my will to the contrary, any beneficiary serving as a
Trustee may disclaim or release, in whole or in part, by an instrument in writing, any
power such beneficiary holds as Trustee, irrevocably or for such period of time as such
Trustee may specify, without affecting the continuance of the power in any other Trustee.
Section 8.12
Exoneration of My Trustee
My Trustee is not obligated to examine the accounts, records or actions of any previous
fiduciary. My Trustee shall in no way or manner be responsible for any act or omission
to act on the part of any previous fiduciary.
Unless my Trustee has received notice of removal, my Trustee shall not be liable to any
beneficiary for the consequences of any action taken by my Trustee that would have
been, but for the prior removal of my Trustee, a proper exercise by my Trustee of the
authority granted to my Trustee under my will.
My Trustee may request and obtain from the beneficiaries or from their legal
representatives, agreements in writing releasing my Trustee from any liability that may
have arisen from my Trustee's acts or omissions to act and indemnifying my Trustee
from liability for the acts or omissions. An agreement described in this paragraph, if
acquired from all the living beneficiaries of my will or from their legal representatives,
shall be conclusive and binding upon all parties, born or unborn, who may have, or may
in the future acquire, an interest in my will.
My Trustee may require a refunding agreement before making any distribution or
allocation of the income or principal of a trust created under my will and may withhold
distribution or allocation pending determination or release of a tax lien or other lien. This
refunding agreement provision shall not apply to any distribution that qualifies for the
federal estate tax unlimited marital deduction or the federal estate tax charitable
deduction.
Page 10
Section 8.13
Benefits Payable to My Trustee
My Trustee may exercise any right to determine the manner and timing of payment (by
lump sum or otherwise) of any benefits or assets payable by reason of my death to my
Trustee or to any trust created under my will. This includes, but is not limited to, such
benefits under life insurance policies, employee benefit plans, retirement plans or other
contracts, plans or arrangements providing for payment or transfer at death to such trust.
My Trustee shall not be liable to any beneficiary for the death benefit election selected.
My Trustee shall not be obligated to undertake litigation for collection of any benefits or
assets payable to such trust unless it is indemnified to its satisfaction against any liability
and expense of such litigation.
Persons or entities dealing in good faith with my Trustee shall not be required to see to
the proper application of proceeds delivered to my Trustee, or to inquire into any
provision of my will. Payment to my Trustee and the receipt of or release by my Trustee
shall fully discharge the person or entity making such payment.
Notwithstanding anything in my will to the contrary, no benefits or assets payable by
reason of my death to my Trustee or to any trust created under my will shall be subject to
the claims against my estate, nor shall such benefits be subject to the control of my
Executor nor be included in the property administered as a part of my probate estate.
Section 8.14
Certificate by Trustee
A written statement of the Trustee of any trust established under my will at any time as to
any facts relative to the trust may always be relied upon and shall always be conclusive
evidence in favor of any transfer agent and any other person dealing in good faith with
the Trustee in reliance upon such statement.
Section 8.15
Funeral and Other Expenses of Beneficiary
Upon the death of an income beneficiary of a trust created under my will, my Trustee
may pay the funeral expenses, burial or cremation expenses, enforceable debts and other
expenses incurred due to the death of the beneficiary from trust property. This Section
shall only apply to the extent the income beneficiary has not exercised any testamentary
power of appointment granted to him under my will.
My Trustee may rely upon any request by the personal representative or members of the
family of the deceased beneficiary for payment without verifying the validity or the
amounts and without being required to see to the application of the amounts so paid. My
Trustee may make decisions under this Section without regard to any limitation on
payment of expenses imposed by statute or rule of court and may be made without
obtaining the approval of any court having jurisdiction over the administration of the
deceased beneficiary's estate.
Page 11
Section 8.16
Trust Accounting
Except to the extent required by law, my Trustees shall not be required to file annual
accounts with any court or court official in any jurisdiction.
Upon the written request of a beneficiary, my Trustee shall render an accounting at least
annually to the income beneficiaries of the trust during the accounting period that
includes the date of the written request. The accounting shall include the receipts,
disbursements, and distributions occurring during the accounting period and a balance
sheet of the trust property if no tax return is filed, or may consist just of the tax return for
the accounting period if a tax return is filed for the trust.
In the absence of fraud or manifest error, the assent by all income beneficiaries to an
accounting of an Independent Trustee shall make the matters disclosed in the accounting
binding and conclusive upon all persons, both those in existence on the date of my death
and those to be born in the future who have, or will in the future have, a vested or
contingent interest in the trust property. In the case of a minor or incapacitated
beneficiary, that beneficiary's natural guardian or legal representative shall give the
assent required under this Section.
The failure of any person to object to any accounting by giving written notice to my
Trustee within 60 days of the person's receipt of a copy of the accounting shall be
deemed to be an assent by such person.
The trust's financial records and documentation shall be available at reasonable times and
upon reasonable notice for inspection by trust beneficiaries and their representatives. My
Trustee shall not be required to furnish trust information regarding my trust to any
individual, corporation, or other entity that is not a beneficiary or the representative of a
beneficiary, and is not requesting the information pursuant to a valid court order.
Section 8.17
Authority to Terminate Trusts
If, at any time, my Trustee, other than an Interested Trustee , in its sole and absolute
discretion, determines that a trust created under my will is no longer economical or is
otherwise inadvisable to administer as a trust, or if my Trustee, other than an Interested
Trustee, deems it to be in the best interest of my beneficiaries, my Trustee, without
further responsibility, may terminate the trust and distribute the trust property, including
any undistributed net income, in the following order of priority:
To my wife, if then a beneficiary of the trust;
If my wife is not then a beneficiary of the trust, to the beneficiaries then
entitled to mandatory distributions of net income of the trust and in the
same proportions; and
If none of the beneficiaries are entitled to mandatory distributions of net
income, to the beneficiaries then eligible to receive discretionary
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distributions of net income of the trust, in such amounts and shares as my
Trustee, other than an Interested Trustee, may determine.
Section 8.18
Marital Deduction Qualification
I intend that the marital gift as described in Article Three of my will qualify for the
federal estate tax marital deduction, and the provisions of my will shall be construed to
reflect this intent. To the extent that giving effect to a provision of my will would result
in the marital gift not qualifying for the federal estate tax unlimited marital deduction,
that provision shall be ineffective.
Article Nine
General Administrative Provisions
The provisions of this Article apply to my probate estate and to any trust created under
my will.
Section 9.01
No Bond
No Fiduciary shall be required to furnish any bond for the faithful performance of the
Fiduciary's duties. If a bond is required by any law or rule of court, no surety shall be
required on such bond.
Section 9.02
Fiduciary Compensation
An individual serving as my Fiduciary, other than my wife, shall be entitled to fair and
reasonable compensation for the services rendered as a fiduciary. A corporate fiduciary
shall be compensated by agreement with an individual Fiduciary or, in the absence of an
individual Fiduciary or in the absence of an agreement, in accordance with the corporate
fiduciary's published schedule of fees in effect at the time the services are rendered.
In addition to receiving compensation, my Fiduciary may be reimbursed for reasonable
costs and expenses incurred in carrying out its duties under my will.
Section 9.03
Employment of Professionals
My Fiduciary may appoint, employ and remove, at any time and from time to time,
investment advisors, accountants, auditors, depositories, custodians, brokers, consultants,
attorneys, expert advisers, agents, and employees to advise or assist the Fiduciary in the
performance of its duties. My Fiduciary may act upon the recommendations of the
persons or entities employed with or without independent investigation.
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My Fiduciary may reasonably compensate an individual or entity employed to assist or
advise my Fiduciary regardless of whether the person or entity shall be a fiduciary under
my will or a corporate affiliate of a fiduciary and regardless of whether the entity shall be
one in which a fiduciary is a partner, member, stockholder, officer, director or corporate
affiliate or has any other interest.
My Fiduciary may pay the usual compensation for services contracted for under this
Section out of principal or income of the trust as my Fiduciary may deem advisable. My
Fiduciary may pay compensation to an individual or entity employed to assist or advise
my Fiduciary without diminution of or charging the same against the compensation to
which the fiduciary is entitled under my will. Any fiduciary who shall be a partner,
stockholder, officer, director or corporate affiliate in any entity employed to assist or
advise my Fiduciary shall nonetheless receive the fiduciary's share of the compensation
paid to the entity.
Section 9.04
Exercise of Testamentary Power of Appointment
A testamentary power of appointment granted under my will may be exercised by valid
will, valid revocable living trust or by any other written instrument that specifically refers
to the power of appointment. The holder of a testamentary power of appointment may
exercise the power to appoint property among the permissible appointees in equal or
unequal proportions, and on such terms and conditions, whether outright or in trust, as the
holder of the power designates. The holder of a testamentary power of appointment may
grant further powers of appointment to any person to whom principal may be appointed,
including a presently exercisable limited or general power of appointment.
My Trustee may conclusively presume that any power of appointment granted to any
beneficiary of a trust created under my will has not been exercised by the beneficiary if
my Trustee has no knowledge of the existence of a valid will, valid revocable living trust
or by any other written instrument exercising the power within 3 months after the
beneficiary's death.
Section 9.05
Determination of Principal and Income
The Pennsylvania Uniform Principal and Income Act shall govern beneficiaries' rights
among themselves in matters concerning principal and income. If the Pennsylvania
Uniform Principal and Income Act contains no provision concerning a particular item,
my Fiduciary shall determine in a fair, equitable and practical manner what shall be
credited, charged, and apportioned between principal and income.
Section 9.06
Spendthrift Provision
Neither the income nor the principal of any trust established under my will shall be
assigned, anticipated or alienated in any manner by any beneficiary, nor shall it be subject
to attachment, bankruptcy proceedings or any other legal process, or to the interference or
control of creditors or others.
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Nothing contained in this Section shall restrict in any way the exercise of any power of
appointment granted in my will.
Section 9.07
Distributions to Incapacitated Persons and Persons Under
Twenty-One Years of Age
If my Fiduciary is directed to distribute any share of my probate estate or trust principal
to a beneficiary, other than my wife, who is under the age of21 years or is in the opinion
of my Fiduciary, under any form of incapacity that renders the beneficiary unable to
administer distributions properly when the distribution is to be made, and if no other trust
is then to be held under my will for the beneficiary's primary benefit, my Fiduciary may,
as Trustee, in my Fiduciary's discretion, continue to hold the beneficiary's share as a
separate trust until the beneficiary reaches the age of 21 or overcomes the incapacity.
When the beneficiary reaches the age of 21 or overcomes the incapacity, my Fiduciary
shall distribute the beneficiary's trust to him or her, outright free of trust.
While any trust is being held under this Section, the Trustee shall pay to the beneficiary
for whom the trust is held such amounts of the net income and principal as the fiduciary
determines to be necessary or advisable for the beneficiary's health, education,
maintenance and support.
Upon the death of the beneficiary before that time, the Trustee shall distribute the trust,
including any accrued and undistributed income, to the beneficiary's then living
descendants, per stirpes, or, if none, to my then living descendants, per stirpes. If I have
no then living descendants the property shall be distributed under the provisions of
Article Six entitled "Remote Contingent Distribution."
Section 9.08
Maximum Term for Trusts
Notwithstanding any other provision of my will to the contrary, unless terminated earlier
under other provisions of my will, each trust created under my will shall terminate 21
years after the last to die of the descendants of my maternal and paternal grandparents
and the descendants of my wife's maternal and paternal grandparents who are living at
the time of my death.
At that time, the remaining trust property shall vest in and be distributed to the persons
entitled to receive mandatory distributions of net income of the trust and in the same
proportions. If no beneficiary is entitled to mandatory distributions of net income, the
remaining trust property shall vest in and be distributed to the beneficiaries entitled to
receive discretionary distributions of net income of the trust, in equal shares per stirpes.
Section 9.09
Representative of a Beneficiary
The guardian of the person of a beneficiary may act for such beneficiary for all purposes
under my will or may receive information on behalf of such beneficiary.
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Section 9.10
Distributions to Beneficiaries
Whenever my will authorizes or directs my Fiduciary to make a distribution of net
income or principal to a beneficiary, my Fiduciary may apply for the benefit of the
beneficiary any property that otherwise could be distributed directly to the beneficiary.
My Fiduciary shall have no responsibility to inquire into the beneficiary's ultimate
disposition of the distributed property unless specifically directed otherwise by my will.
My Fiduciary may make distributions in cash or in kind, or partly in each, in proportions
and at values determined by my Fiduciary. My Fiduciary may allocate undivided
interests in specific assets to a beneficiary or trust in any proportion or manner that my
Fiduciary determines, even though the property allocated to one beneficiary may be
different from that allocated to another beneficiary.
My Fiduciary may make these determinations without regard to the income tax attributes
of the property and without the consent of any beneficiary.
Section 9.11
Ancillary Administration
In the event ancillary administration shall be required or desired and my domiciliary
Executor is unable or unwilling to act as an ancillary fiduciary, my domiciliary Executor
shall have the power to designate, compensate, and remove the ancillary fiduciary. The
ancillary fiduciary may be either a natural person or a corporation. My domiciliary
Executor may delegate to such ancillary fiduciary such powers granted to my original
Executor as my Executor may deem proper, including the right to serve without bond or
surety on bond. The net proceeds of the ancillary estate shall be paid over to the
domiciliary Executor.
Section 9.12
Delegation of Authority; Power of Attorney
Any Fiduciary may, by an instrument in writing, delegate to any other Fiduciary the right
to exercise any power, including a discretionary power, granted the Fiduciary in my will.
During the time a delegation under this Section is in effect, the Fiduciary to whom the
delegation was made may exercise the power to the same extent as if the delegating
Fiduciary had personally joined in the exercise of the power. The delegating Fiduciary
may revoke the delegation at any time by giving written notice to the Fiduciary to whom
the power was delegated.
The Fiduciary may execute and deliver a revocable or irrevocable power of attorney
appointing any individual or corporation to transact any and all business on behalf of the
trust. The power of attorney may grant to the attorney-in-fact all of the rights, powers,
and discretion that the Fiduciary could have exercised.
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Section 9.13
Merger of Corporate Fiduciary
If any corporate fiduciary acting as my Fiduciary under my will is merged with or
transfers substantially all of its trust assets to another corporation or if a corporate
fiduciary changes its name, the successor shall automatically succeed to the position of
my Fiduciary as if originally named my Fiduciary. No document of acceptance of the
position of my Fiduciary shall be required.
Article Ten
Powers of My Fiduciaries
Section 10.01 General Grant of Powers
My Fiduciary may perform every act reasonably necessary to administer my estate and
any trust. My Fiduciary may execute and deliver any and all instruments in writing,
which my Fiduciary considers necessary to carry out any of the powers granted under my
will.
Section 10.02 Investment Powers in General
My Fiduciary may invest in any type of investment that my Fiduciary determines is
consistent with the investment goals of my estate or any trust, whether inside or outside
the geographic borders of the United States of America and its possessions or territories,
taking into account the trust's overall investment portfolio.
Without limiting my Fiduciary's investment authority in any way, I request that my
Fiduciary exercise reasonable care and skill in selecting and retaining investments. I also
request that my Fiduciary take into account the following factors in choosing investments
for my estate or any trust:
The potential return from the investment, both in the form of income and
appreciation;
The potential income tax consequences of the investment;
The investment's potential for volatility; and
The role the investment will play in my estate or the trust's portfolio.
I request that my Trustee, in arranging the investment portfolio of any trust, also consider
the possible effects of inflation or deflation, changes in global and U.S. economic
conditions, transaction expenses, and the trust's need for liquidity.
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My Fiduciary may delegate its discretion to manage investments to any registered
investment adviser or corporate fiduciary.
Section 10.03 Banking Powers
My Fiduciary may establish bank accounts of any type in one or more banking
institutions that my Fiduciary may choose. My Fiduciary may open accounts in the name
of my Fiduciary (with or without disclosing fiduciary capacity) or in the name of my
estate or the trust. When an account is in the name of my estate or the trust, checks on
that account and authorized signatures need not disclose the fiduciary nature of the
account or refer to my estate, any trust or Fiduciary.
An account from which my Fiduciary makes frequent disbursements need not be an
interest bearing account. My Fiduciary may authorize withdrawals from an account by
check, draft or other instrument or in any other manner.
Section 10.04 Contract Powers
My Fiduciary may sell at public or private sale, transfer, exchange for other property, and
otherwise dispose any property contained in my probate estate or any trust for
consideration and upon terms and conditions that my Fiduciary deems advisable. My
Fiduciary may grant options of any duration for any such sales, exchanges, or transfers of
trust property.
My Fiduciary may enter into contracts, and may deliver deeds or other instruments, as my
Fiduciary deems appropriate.
Section 10.05 Common Investments
For purposes of convenience with regard to the administration and investment of any
trust, my Trustee may invest part or all of the property jointly with trust property of other
trusts for which my Trustee is also serving as a Trustee. For this purpose, a corporate
fiduciary acting as my Trustee may use common funds for investment.
When trust property is managed and invested in this manner, my Trustee shall maintain
records that sufficiently identify that portion of the jointly invested assets that constitute
the property of the trust.
Section 10.06 Environmental Powers
My Fiduciary shall have the right to inspect property held directly or indirectly by my
probate estate or any trust to determine compliance with or to respond to any
environmental law affecting the property. "Environmental law" shall mean any federal,
state, or local law, rule, regulation, or ordinance relating to protection of the environment
or of human health.
Page 18
My Fiduciary may refuse to accept additional property if my Fiduciary determines that
the property is or may be contaminated by any hazardous substance or is or was used for
any purpose involving hazardous substances that could create liability to my estate, any
trust or to my Fiduciary.
My Fiduciary may use the income and principal of my probate estate or a trust to (i)
conduct environmental assessments, audits or site monitoring; (ii) take remedial action to
contain, clean up or remove any hazardous substance including a spill, discharge or
contamination; (iii) institute, contest or settle legal proceedings brought by a private
litigant or any local, state, or federal agency concerned with environmental compliance;
(iv) comply with any order issued by any court or by any local, state, or federal agency
directing an assessment, abatement or clean-up of any hazardous substance; and (v)
employ agents, consultants and legal counsel to assist my Fiduciary in these actions.
My Fiduciary shall not be liable for any loss or reduction in value sustained by my
probate estate or a trust as a result of my Fiduciary's retention of property on which
hazardous materials or substances requiring remedial action are discovered unless my
Fiduciary contributed to the resulting loss or reduction in value through willful
misconduct or gross negligence.
My Fiduciary shall not be liable to any beneficiary or to any other party for any decrease
in the value of probate or trust property as a result of my Fiduciary's compliance with any
environmental law, including any reporting requirement.
My Fiduciary may release, relinquish or disclaim any power held by my Fiduciary that
my Fiduciary determines may cause my Fiduciary to incur individual liability under any
environmental law.
Section 10.07 Litigation and Settlement Powers
My Fiduciary, in its discretion and at the expense of my probate estate or the trust, may
institute, join, compromise, settle dismiss and defend any probate or trust property in any
judicial or administrative proceeding. This shall include specifically, but not limited to
proceedings or class actions brought against any public entity or government agency or
brought by any such entity for attachment, recoupment, levy, invasion, reformation, or
access of any kind to property of my probate estate or a trust. My Fiduciary is authorized
to retain such legal counsel and ancillary personnel, as my Fiduciary deems appropriate
in the exercise of its discretion.
Section 10.08 Loans and Borrowing Powers
My Fiduciary may make secured or unsecured loans to any person (including a
beneficiary), entity, trust or estate, for any term or payable on demand, with or without
interest. My Fiduciary may enter into or modify the terms of any mortgage or security
agreement granted in connection with any loan and may release or foreclose on the
mortgage or security.
Page 19
My Fiduciary may borrow money at interest rates and on other terms that it deems
advisable from any person, institution or other source including, in the case of a corporate
fiduciary, its own banking or commercial lending department.
My Fiduciary may encumber estate and trust property by mortgages, pledges and other
hypothecation and shall have the power to enter into any mortgage, whether as a
mortgagee or mortgagor even though the term may extend beyond the termination of the
trust and beyond the period that is required for an interest created under my will to vest in
order to be valid under the rule against perpetuities.
My Fiduciary may purchase, sell at public or private sale, trade, renew, modify, and
extend mortgages. My Fiduciary may accept deeds in lieu of foreclosure.
Section 10.09 Nominee Powers
My Fiduciary may hold real estate, securities and any other estate or trust property in the
name of a nominee or in any other form without disclosing the existence of my estate, the
trust or fiduciary capacity.
Section 10.10 Payment of Taxes and Expenses
Except as otherwise provided in my will, my Fiduciary is authorized to pay all property
taxes, assessments, fees, charges, and other expenses incurred in the administration or
protection of my estate or any trust. All paYments shall be a charge against estate or the
trust, as the case may be, and shall be paid out of income and to the extent that income is
insufficient, then out of principal. The determination of my Fiduciary with respect to the
paYment of expenses shall be conclusive upon the beneficiaries.
Section 10.11 Real Estate Powers
My Fiduciary may sell at public or private sale, purchase, exchange, lease for any period,
mortgage, manage, alter, improve and in general deal in and with real property in such
manner and on such terms and conditions as my Fiduciary deems appropriate.
My Fiduciary may grant or release easements in or over, subdivide, partition, develop,
raze improvements, and abandon, any real property.
My Fiduciary may manage real estate in any manner that my Fiduciary deems best and
shall have all other real estate powers necessary for this purpose.
My Fiduciary may enter into contracts to sell real estate. My Fiduciary may enter into
leases and grant options to lease trust property even though the term of the agreement
extends beyond the termination of a trust and beyond the period that is required for an
interest created under my will to vest in order to be valid under the rule against
perpetuities. For such purposes, my Fiduciary may enter into any contracts, covenants
and warranty agreements that my Fiduciary deems appropriate.
Page 20
Section 10.12 Retention and Abandonment of Trust Property
My Fiduciary may retain, without liability for depreciation or loss resulting from
retention, any property contained my estate or any trust at the time of its creation or as the
result of the exercise of a stock option. My Fiduciary may retain property,
notwithstanding the fact that the property may not be of the character prescribed by law
for the investment of assets held by a fiduciary, and notwithstanding the fact that
retention may result in inadequate diversification under any applicable Prudent Investor
Act or other applicable law.
My Fiduciary may hold property that is non-income producing or is otherwise
nonproductive if holding the property is, in the sole and absolute discretion of my
Fiduciary, in the best interests of the beneficiaries. My Fiduciary is permitted to retain a
reasonable amount in cash or money market accounts in order to pay anticipated
expenses and other costs and to provide for anticipated distributions to or for the benefit
of a beneficiary.
My Fiduciary may abandon any trust property that my Fiduciary deems to be of
insignificant value.
Section 10.13 Securities, Brokerage and Margin Powers
My Fiduciary may buy, sell, trade and otherwise deal in stocks, bonds, investment
companies, mutual funds, common trust funds, commodities, options and other securities
of any kind and in any amount, including short sales. My Fiduciary may write and
purchase call or put options, and other derivative securities. My Fiduciary may maintain
margin accounts with brokerage firms and may pledge securities to secure loans and
advances made to my Fiduciary or to or for the benefit of a beneficiary.
My Fiduciary may place all or any part of the securities held by my estate or a trust in the
custody of a bank or trust company. My Fiduciary may have all securities registered in
the name of the bank or trust company or in the name of its nominee. My Fiduciary may
appoint the bank or trust company as the agent or attorney in fact to collect, receive,
receipt for and disburse any income and generally to perform the duties and services
incident to a custodian of accounts.
My Fiduciary may employ a broker-dealer as a custodian for securities held by my estate
or the trust and may register the securities in the name of the broker-dealer or in the name
of a nominee with or without the addition of words indicating that the securities are held
in a fiduciary capacity. My Fiduciary may hold securities in bearer or uncertificated form
and may use a central depository, clearing agency or book-entry system, such as The
Depository Trust Company, Euroclear or the Federal Reserve Bank of New York.
My Fiduciary may participate in any reorganization, recapitalization, merger or similar
transaction. My Fiduciary may exercise or sell conversion or subscription rights for
securities of all kinds and description.
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My Fiduciary may give proxies or powers of attorney that may be discretionary and with
or without powers of substitution. My Fiduciary may vote or refrain from voting as to
any matter.
Section 10.14 Tangible Personal Property and Residences
My Fiduciary may acquire, maintain and invest in articles of tangible personal property,
whether or not the property is income producing, and may pay the expenses of the repair
and maintenance of the property.
My Fiduciary shall have no duty to convert the property referred to in this Section to
productive property except as required by other provisions of my will.
My Fiduciary shall have no liability for any depreciation or loss as a result of the
retention of any property retained or acquired under the authority of this Section.
My Trustee may acquire, maintain and invest in any residence for the use and benefit of
the beneficiaries of the trust, whether or not the residence is income producing and
without regard to the proportion that the value of the residence may bear to the total value
of the trust property and even if retaining the residence involves financial risks that
trustees would not ordinarily incur. My Trustee may payor make arrangements for
others to pay all carrying costs of the residence, including, but not limited to, taxes,
assessments, insurance, expenses of maintaining the residence in suitable repair, and
other expenses relating to the operation of the residence for the benefit of the
beneficiaries.
My Trustee may permit any income beneficiary of the trust to occupy any real property
or use any personal property owned by the trust on terms or arrangements that my
Trustee may determine, including rent free or in consideration for the payment of taxes,
insurance, maintenance, repairs, or other charges.
Section 10.15 Power of Executor to Disclaim and to Distribute Directly to
a Beneficiary
If such disclaimer can be treated as a Qualified Disclaimer, I give my Executor the power
to disclaim any interest, in whole or in part, which my estate may acquire (including an
interest in any other estate, trust, insurance proceeds, annuity, contract or pension plan)
for any purpose (including overall reduction in death taxes) and without regard to
whether such disclaimed property will pass to the same persons, at the same time or in
the same manner as if there had been no disclaimer.
If at my death, the terms of a trust created under my will provide that property is to be
distributed outright to a beneficiary, my Executor may make the distribution to the
beneficiary without the intervention of my Trustee.
Page 22
Section 10.16 Fiduciaries' Powers Act
In addition to all of the above powers, my fiduciaries may, without prior authority from
any court, exercise all powers conferred by my will or by common law or by any
fiduciary powers act or other statute of the Commonwealth of Pennsylvania or any other
jurisdiction whose law applies to my will. My Executor shall have absolute discretion in
exercising these powers. Except as specifically limited by my will, these powers shall
extend to all property held by my fiduciaries until the actual distribution of the property.
Section 10.17 Alternative Distribution Methods
My Fiduciary may make any payment provided for under my will or under the terms of
any trust established under my will as follows:
Directly to the beneficiary;
In any form allowed by applicable state law for gifts or transfers to minors
or persons under a disability;
To the beneficiary's guardian, conservator, agent under a durable power of
attorney or caregiver for the benefit of the beneficiary; or
By direct payment of the beneficiary's expenses, made in a manner
consistent with the proper exercise of the fiduciary's duties hereunder. A
receipt by the recipient for any such distribution shall fully discharge my
Fiduciary.
Section 10.18 Limitation on My Trustee's Powers
All powers granted to my Trustee under my will or by applicable law shall be limited as
set forth in this Section, unless explicitly excepted by reference to this Section.
(a) An Interested Trustee Limited to Ascertainable
Standards
An Interested Trustee may not exercise or participate in the exercise of
discretion with respect to the distribution of income or principal, or the
termination of the trust to or for the benefit of a beneficiary, to the extent
that the exercise of such discretion is other than for the health, education,
maintenance or support of a beneficiary as described under Sections 2041
and 2514 of the Internal Revenue Code.
(b) No Distributions in Discharge of Certain Legal
Obligation
My Trustee may not exercise or participate in the exercise of discretion
with respect to the distribution of income or principal that would in any
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manner discharge a legal obligation of my Trustee, including the
obligation of support.
If a beneficiary or any other person has the power to remove a Trustee,
that Trustee may not exercise or participate in the exercise of discretion
with respect to the distribution of income or principal that would in any
manner discharge a legal obligation of the person having the power to
remove the Trustee, including that person's obligation of support.
Article Eleven
Provisions for Payment of Debts, Expenses and Taxes
Section 11.01 Payment of Debts and Expenses
I direct that all my legally enforceable debts, secured and unsecured, be paid as soon as
practicable after my death.
Section 11.02 No Apportionment
Except as otherwise provided in this Article or elsewhere in my will, my Executor shall
provide for payment of all estate, inheritance and succession taxes payable by reason of
my death ("death taxes") from my residuary estate as an administrative expense without
apportionment and shall not seek contribution toward or recovery of any death tax
payments from any individual.
Section 11.03 Protection of the Marital Deduction
Notwithstanding anything to the contrary in my will, no death taxes shall be paid from or
allocated to any property qualifying for the federal estate tax marital deduction under my
will unless there is no other property available to pay the taxes.
My Executor shall not pay any administrative expenses from the net income of any
property qualifying for the federal estate tax marital deduction under my will if the
payment would require a reduction in the estate tax marital deduction under Section
2056(b) of the Internal Revenue Code.
Section 11.04 Property Passing Outside of My Will
Except as to Qualified Retirement Benefits, death taxes imposed with respect to property
included in my gross estate for purposes of computing the tax and passing other than by
my will shall be apportioned among the persons and entities benefited in the proportion
that the taxable value of the property or interest bears to the total taxable value of the
Page 24
property and interests received by all persons benefited. The values as finally determined
in the respective tax proceedings shall be the values used for the apportionment of the
respective taxes.
Section 11.05 Tax Elections
In exercising any permitted elections regarding taxes, my fiduciaries may make such
decisions as they deem to be appropriate in all the circumstances and my fiduciaries shall
be under no duty to make any compensatory adjustment as a consequence of any such
election. My Executor may also execute such joint tax returns and pay such taxes or
interest and deal with any tax refunds, interest, or credits as it shall deem necessary or
advisable, whether in the interest of the other joint tax payer or in the interest of my
estate.
My Executor, in its sole and absolute discretion, may elect to have all, none, or part of the
property comprising my estate for federal estate tax purposes qualify for the federal estate
tax marital deduction as qualified terminable interest property under Section 2056(B)(7)
of the Internal Revenue Code (the "QTIP election") and for any state death tax marital
deduction under the law of any state (the "state QTIP Election"). My Executor is not
required to make the same election for both federal estate tax purposes and for state death
tax purposes. If my Executor makes a partial QTIP election, my Executor shall divide
the trust on the basis of the fair market value of the assets of the trust at the time of the
division.
Article Twelve
Definitions and General Provisions
Section 12.01 Definitions
For purposes of my will and for the purposes of any trust established under my will, the
following definitions shall apply:
(a) Adopted and Afterborn Persons
A legally adopted person in any generation and his or her descendants,
including adopted descendants, shall have the same rights and shall be
treated in the same manner under my will as natural children of the
adopting parent, provided such person is legally adopted prior to attaining
the age of 18 years. A person shall be deemed to be legally adopted if the
adoption was legal in the jurisdiction in which it occurred at the time that
it occurred.
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(b) Descendants
The term "descendants" shall include a person's lineal descendants of all
generations.
(c) Education
The term "education" is intended to be an ascertainable standard in
accordance with Section 2041 and Section 2514 of the Internal Revenue
Code and shall include, but not be limited to:
Enrollment at private elementary, junior and senior high
school including boarding school;
Undergraduate and graduate study in any field at a college
or university;
Specialized, vocational or professional training or
instruction at any institution, including private instruction;
and
Any other curriculum or activity that my Trustee may deem
useful for developing the abilities and interests of a
beneficiary including, without limitation, athletic training,
musical instruction, theatrical training, the arts and travel.
The term "education" shall also include distributions made by my Trustee
for expenses such as tuition, room and board, fees, books and supplies,
tutoring and transportation and a reasonable allowance for living expenses.
(d) Fiduciary
My "Fiduciary" or "Fiduciaries" shall refer to my Executor and my
Trustee, or if they are different persons, either of them. My "Executor"
shall include any executor, ancillary executor, administrator, or ancillary
administrator, whether local or foreign and whether of all or part of my
estate, multiple Executors, and their successors.
(e) Incapacity
Except as otherwise provided in my will, a person shall be deemed
incapacitated in anyone of the following circumstances.
(1) The Opinion of Two Licensed Physicians
An individual shall be deemed incapacitated whenever, in
the opinion of two licensed physicians, the individual is
unable to effectively manage his or her property or
Page 26
financial affairs, whether as a result of age, illness, use of
prescription medications, drugs or other substances, or any
other cause.
An individual shall be deemed restored to capacity
whenever the individual's personal or attending physician
provides a written opinion that the individual is able to
effectively manage his or her property and financial affairs.
(2) Court Determination
An individual shall be deemed incapacitated if a court of
competent jurisdiction has declared the individual to be
disabled, incompetent or legally incapacitated.
(3) Detention, Disappearance or Absence
An individual shall be deemed incapacitated whenever he
or she cannot effectively manage his or her property or
financial affairs due to the individual's unexplained
disappearance or absence for more than 30 days, or
whenever he or she is detained under duress.
An individual's disappearance, absence or detention under
duress may be established by an affidavit of any fiduciary.
The affidavit shall describe the circumstances of an
individual's detention under duress, disappearance or
absence and may always be relied upon by any third party
dealing in good faith with my fiduciary in reliance upon the
affidavit.
An individual's disappearance, absence or detention under
duress may be established by an affidavit of my Executor.
(f) Income Beneficiary
The term "income beneficiary" means any beneficiary who is then entitled
to receive distributions of the net income of the trust, whether mandatory
or discretionary.
Unless otherwise provided in my will, the phrase "majority of the income
beneficiaries" means any combination of income beneficiaries who, if all
accrued net income were distributed on the day of a vote by the
beneficiaries, would receive more than 50% of the accrued net income.
For purposes of this calculation, beneficiaries who are eligible to receive
discretionary distributions of net income shall be deemed to receive the
income in equal shares.
Page 27
References to a "majority" refer to a majority of the entire trust
collectively until my Trustee allocates property to separate trusts or trust
shares. After the allocation of property to separate trusts or trust shares,
references to a "majority" refer to a majority of each separate trust or trust
share.
(g) Independent Trustee
The term "Independent Trustee" means a Trustee who is not an Interested
Trustee as defined in subsection (h). Only an Independent Trustee may
exercise those powers granted exclusively to an Independent Trustee and
when the phrase "other than an Interested Trustee" is used. Whenever my
will specifically prohibits an Interested Trustee from exercising discretion
or performing an act, then only an Independent Trustee may exercise that
discretion or perform that act. An Independent trustee shall not be liable
to any person for any good faith exercise or nonexercise of its discretion
under my will.
(h) Interested Trustee
The term "Interested Trustee" means (1) a Trustee who is a transferor of
property to the trust (including a person whose qualified disclaimer
resulted in property passing to the trust); (2) a Trustee who is a beneficiary
of the trust; or (3) a Trustee whom a beneficiary of the trust can remove
and replace by appointing a Trustee that is related or subordinate to the
beneficiary within the meaning of Section 672( c) of the Internal Revenue
Code.
For purposes of this subsection "a beneficiary of the trust" means a person
who is or in the future may be eligible to receive income or principal from
the trust pursuant to the terms of the trust. A person shall be considered a
beneficiary of a trust even if he or she has only a remote contingent
remainder interest in the trust; however, a person shall not be considered a
beneficiary of a trust if the person's only interest is as a potential
appointee under a testamentary power of appointment.
(i) Internal Revenue Code
References to the "Internal Revenue Code" or to its provisions are to the
Internal Revenue Code of 1986, as amended from time to time, and the
corresponding Treasury Regulations, if any. References to the "Treasury
Regulations," are to the Treasury Regulations under the Internal Revenue
Code in effect from time to time. If a particular provision of the Internal
Revenue Code is renumbered, or the Internal Revenue Code is superseded
by a subsequent federal tax law, any reference shall be deemed to be made
to the renumbered provision or to the corresponding provision of the
subsequent law, unless to do so would clearly be contrary to my intent as
Page 28
expressed in my will. The same rule shall apply to references to the
Treasury Regulations.
(j) Legal Representative
As used in my will, the term "legal representative" means a person's
guardian, conservator, personal representative, executor, administrator,
Trustee, or any other person or entity personally representing a person or
the person's estate.
(k) Per Stirpes
Whenever a distribution is to be made to a person's descendants per
stirpes, the distribution shall be divided into as many shares as there are
then living children of such person and deceased children of such person
who left then living descendants. Each then living child shall receive one
share and the share of each deceased child shall be divided among such
child's then living descendants in the same manner.
(I) Qualified Retirement Plan
The term "qualified retirement plan" means a plan qualified under Section
401 of the Internal Revenue Code, an individual retirement arrangement
under Section 408 or Section 408A or a tax-sheltered annuity under
Section 403. The term "qualified retirement benefits" means the amounts
held in or distributed pursuant to a plan qualified under Section 401, an
individual retirement arrangement under Section 408 or Section 408A, a
tax-sheltered annuity under Section 403 or any other benefit subject to the
distribution rules of Section 401 (a)(9).
(m) Shall and May
Unless otherwise specifically provided in my will or by the context in
which used, I use the word "shall" in my will to command, direct or
require, and the word "may" to allow or permit, but not require. In the
context of my Trustee, when I use the word "may" I intend that my
Trustee may act in its sole and absolute discretion unless otherwise stated
in my will.
(n) Trust
The term "trust," shall refer to any trusts created under the terms of my
will.
Page 29
(0) Trustee
The term "my Trustee" refers to any person or entity that is from time to
time acting as the Trustee and shall include each Trustee individually,
multiple Trustees, and their successors.
(p) Trust Property
The phrase "trust property" shall be construed to mean all property held by
my Trustee under my will, including all property that my Trustee may
acquire from any source.
(q) Other Definitions
Except as otherwise provided in my will, terms shall be as defined under
Pennsylvania law.
Section 12.02 Survivorship Presumption
If my wife and I die under circumstances in which the order of our deaths cannot be
established, my wife shall be deemed to have survived me.
If any other beneficiary shall be living at my death, but die within 30 days thereafter, then
such beneficiary shall be deemed to have predeceased me for all purposes of my will.
Section 12.03 General Provisions
The following general provisions and rules of construction shall apply to my will:
(a) Singular and Plural; Gender
Unless the context requires otherwise, words denoting the singular may be
construed as plural and words of the plural may be construed as denoting
the singular. Words of one gender may be construed as denoting another
gender as is appropriate within the context. The word "or" when used in a
list of more than two items may function as both a conjunction and a
disjunction as the context requires or permits.
(b) Headings of Articles, Sections, and Subsections
The headings of Articles, Sections, and subsections used within my will
are included solely for the convenience and reference of the reader. They
shall have no significance in the interpretation or construction of my will.
(c) Governing State Law
My will shall be governed, construed and administered according to the
laws of the Commonwealth of Pennsylvania as from time to time
Page 30
amended. Questions of administration of any trust established under my
will shall be determined by the laws of the situs of administration of such
trust.
(d) Notices
Unless otherwise stated, whenever my will calls for notice, the notice shall
be in writing and shall be personally delivered with proof of delivery, or
mailed postage prepaid by certified mail, return receipt requested, to the
last known address of the party requiring notice. Notice shall be effective
on the date personally delivered or on the date of the return receipt. If a
party giving notice does not receive the return receipt but has proof that he
or she mailed the notice, notice shall be effective on the date it would
normally have been received via certified mail. If notice is required to be
given to a minor or incapacitated individual, notice shall be given to the
parent or legal representative of the minor or incapacitated individual.
(e) Severability
The invalidity or unenforceability of any provision of my will shall not
affect the validity or enforceability of any other provision of my will. If a
court of competent jurisdiction determines that any provision is invalid,
the remaining provisions of my will shall be interpreted and construed as
if any invalid provision had never been included in my will.
I, Walter T. Morrison, having signed this Will in the presence of ~-..J~ E . ~ <L~
and cJAqrelAh.t U'Y\.,(,c..L who attested it at my request on this day,
. \//1"\.2 9-&- , 2006, at Harrisburg, Pennsylvania, declare this to be my Last
Will and Testament.
UhlLj M~
Walter T. Morrison, Testator
Page 31
The above and foregoing Will of Walter T. Morrison was declared by Walter T. Morrison
in our view and presence to be his Will and was signed and subscribed by the said Walter
T. Morrison in our view and presence and at his request and in the view and presence of
Walter T. Morrison and in the view and presence of each other, we, the undersigned,
witnessed and attested the due execution of the Will of Walter T. Morrison on this day,
<S vYLL ~ ~ , 2006.
~~. ~ residingat S:S;--O'2.. F',€-/)~~~. .y,
p",,^^,,~ ~ >--L. C)' IJA " I \ ,
residing at ~~~ (~
PENNSYL VANIA SELF PROVING AFFIDAVIT
COMMONWEALTH OF PENNSYLVANIA )
)
COUNTY OF DAUPHIN )
I, Walter T. Morrison, the testator whose name is signed to the attached or foregoing
instrument, having been duly qualified according to law, do hereby acknowledge that I
signed and executed the instrument as my Last Will; and that I signed it willingly and as
my free and voluntary act for the purposes therein expressed.
Sworn to or affirmed and acknowledged before me by Walter T. Morrison, the testator,
this day, "C)'V I\t... '1-~ ,2006.
'{fWSr~
alter T. Momson, Testator
COMMONWEALTH OF PENNSYLVANIA
Notarial Seal
Amy M. Moya, Notary Public
Lower Paxton Twp., Dauphin County
My Commission Expires Jan. 29, 2008
Member, Pennsytvanla Association of Notaries
Page 32
.
COMMONWEALTH OF PENNSYLVANIA )
)
COUNTY OF DAUPHIN )
We, ~../Sc.-. e.. L~Q.,\S and ~I/'t~~ ~\J..Rclythe witnesses whose names are
signed to the attached or 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 Will; that the testator signed willingly and executed it as his free and
voluntary act for the purposes therein expressed; that each subscribing witness in the
hearing and sight of the testator signed the will as a witness; and that to the best of our
knowledge the testator was at that time 18 or more years of age, of sound mind, and
under no constraint or undue influence.
~
Witness
C'~~A
-
~,('D ^.~~
Wi ess I ~
COMMONWEALTH OF PENNSYLVANIA
Notarial Seal .
AM Moya, Notary Public
my . T Dau~hin County
Lower paxton wp., . 008
My Commission EXplfes an. 29,2 .
Member. Pennsylvania Association of Notanes
Page 33