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HomeMy WebLinkAbout01-0149 c-~~J Register of Wills of Dauphin County, Pennsylvania PETITION FOR GRANT OF LETTERS Betty 1. Adler No. ~J-OI-Il/q Estate of also known as I Deceased Social Security No. 201-16-1582 PetltlOner{sL who Is/are' B years of age or older, appIY(le9) tor (COMPLETE" A" OR "B" BELOW:) ~ A. Probate an9. _G G"rant of Letters and aver that Petitioner(s) is/are the execut~ named in the Last Will of the Decedent, dated ~~'1 and codicil(sl dated 06-02- '"L.h){) .f?:J-c/ey -<~. /I/~./t /;:Jt"t:!.rfLd",~L ,46"[ 7-/7-C!2 /j (/ StBte relevant circumstances, e.g., renunciation, death of executor, ete Except as follows, Decedent did not marry, was not divorced, and did not have a child born or adopted after execution of the documents offered for probate; was not the victim of a killing and was never adjudicated incompetent: [J B. Grant of Letters of Administration le.t.a., d.b.n.c,t.8.: pendente hte; dllfante absentia; dlJiontt: rnmorilfH€) Petitioner(s) after a proper search has/have ascertained that Decedent left no Will and was survived by the following spouse (If any) and heirs: I Name Relationship Residence I (COMPLETE IN ALL CASES:) Attach additional sheets if necessar . y Decedent, then -=z..tL- years of age, died Odubt:I 2, 2000 County, Pennsylvania, with his/her last amily or principal J\,\ e e: iA~ "^ . ,; "? ~ U ~ r> {'1.;J 'i c't;J . 19_. at ML""'/IIW', t~..h (J~. P) (Location 1 Decedent was domiciled at death in residence at ; z. ..; U)~~ ..,t~ '~r CUIIlLt:IlauJ /list st,eel, I"t:Jfllber and muniCIpality) Decedent at death owned property with estimated values as follows: {If domiciled in PAl All personal property ............................ $ (If not domiciled in PAl Person31 property in Pennsylvania. . . . . . . . . . . . . . . . . . . . . . $ (If not domiciled in PAl Personal property in County. . . . . . . . . . . . . . . . . . . . . . .. $ Value of real estate in Pennsylvania ............................................... $ Total . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . ., $ Real Estate situated as follows: Ifl./} ()()C liJ~,7 {/t?L/ z.-; {j , (/ U 0 Wherefore, Petitioner{s) respectfully request(s) the probate of the last Will and Codicil{s) presented with this Petition and the grant of letters in the appropriate form to the undersigned: RW- 7 / L~ -.;2 (}f - (.. Oath of Personal Representative Cornmonwealth of Pennsylvania ; :' 1 1 County of tJuuphffi ~U~!....e-J;a-t~ The Petitioner(s) above-named swear(s) and affirm(s) that the statements in the foregoing Petition are true and correct to the best of the knowledge and belief of Petitioner(s) and that, as personal representative(s) of the Decedent, Petitioner(s) will well and truly administer the estate according to law. d?? Jo Sworn to and affirmed and subscribed ~~ ~~~ A. 4r before me this 6th day of .APY CLEWIS P /;/1 A,,' . PEGIS ' R OF WILLS /4Y1'J'T,'-'\UL/ . . DECREE OF RfGISTER ~L <T /(;LL;dW ~ Estate of BETTY _.11. ADT,F.R Deceased No. 21-2001-149 also known as Social Security No: 201-16-1582 Date of Death: October 02,2000 AND NOW, February 6th, , ~2001 , in consideration of the Petition on the reverse side hereon, satisfactory proof having been presented before me, IT IS DECREED that Letters iXJ Testamentary 0 of Administration (C,In, rlt.lllr: 1 . pendente Ille: dtJlilnTe ;ltlsenlla; dU!ilfllt: nll!I(JllId1,~) are hereby granted to Robert A. Adler and Paul J. Killion in the above estate and that the instrument(s), if any, dated 09-08-1989 Will, Codicil 06-02-2000 described in the Petition be admitted to probate and filed of record as the last Will of Decedent. FEES Letters........................... $ 270.00 ~~ e '~~~~f(-z I eg'''''' of Will, MARY C. LEWIS ~:;: . REGISTER OF WILLS {/ Short Certificate(s)... ~9.... $ 30.00 Renunciation.................. $ Affidavit ( )................. $ Extra Pages (19............ $ Codicil.......................... $ JCP Fee........................ $ Inventory & Tax Forms... $ Other............................ $ 45.00 10.50 5.00 Attorney: 1.0. No: Address: William L. Adler, Esq. 39844 P.O. Box 11933 Harrisburg, P Ii 17108 1933 TOTAL............... . 717-234-3289 DATE FILED: Februarv 6th,2001 CALL ATTORNEY WHEN LETTERS ARE FINISHED $ 360.50 Telephone: BW-7a REGISTER OF WILLS OF r...... U~A. ; COUNTY OATH OF SUBSCRIBING WITNESS codicil _ _ L (each) a subscribing witness to the will presented herewith, (each) being duly qualified ~ording to law, depose(s) and say(s) that '. ~sent and saw ~, / the testat , sign the same and that """, si ed as a witness at the "'-, request of testat_ in h presence and (in the'txesence of each oth other subscribing witness(es)). '~" ""'"" // f', /i ~me) ""-. (Addre~ Sworn to or affirmed and subscribed before me this day of 19_ Register I / (Name) I (Address) 21-2001-149 REGISTER OF WILLS OF ( -V- ~e...rI~ COUNTY OATH OF NON-SUBSCRIBING WITNESS R~ fz,~ A. AJ {eA- +- p~/ ~ /(,.((rt:7tY1... (each) a subscriber hereto, (each) being duly qualified according to law, depose(s) and say(s) that <Yk..e.~ 1Il...J-P familiar with the signature of ~fI!!.lIy .:r: .A~/ eJ'- codicil testat (;,r- of (one of the subscribing witnesses to) the ~ presented herewith and codicil that ~ believes the signature on the w+H is in the handwriting of f3tdIy J: AlfeJ- to the best of ft.e.rj-- knowledge and beliefd Sworn to or affirmed and subscribed before /y~ ~/c--:7'- L ~- h' 6th d t'I\.T me t IS C} _ ay 0 .. J _ fdam(}}..// / / ~ b. '( '4 -;4 c)/ " !lJ2001j~~ .e;;,-r /?'e..Ho..,:'~6'"7 ~P~r- MARY C. ~I~' ,;Hu<-&' ~;;;;~;;;:0 9'~ ~L ~/{~ REGISTER OF WILLS ? _ ~ ~ (Nf'me) 6)4J J: 7L~L -';: [c:.~ 43 11 ~ /7a B (Address) '~ fl) (erL h' that the intorrnarion here given is co[[ectly copied from an original Ct:rtitlc<ltt' of d.,\lrh dlll~' filed with me as 1 (<J Re~isrr:lI. The original certificate will be f()rwarded to the State \'iral Records OfTice f()l pernunt'!1l filing. WARNING: It is illegal to duplicate this copy by photostat or photograph. tel' t~)r rhi~ lcrritlctrc', SLOO d'li(*1~~QEf&~~ // ~/ ,<4'J;i.":. if~ ~/ "'~\ ~ ~~~ I' ~ ';. ,'P'~ !~ ~,' '~ ' "~% \,,~ 5\.l.:~ " .:b. ~ \\.*~,:.. ~..,~-; *$ \~a\. ..' ..~/ .~ ~'" /..tS\\~, '\-:. AlP~, .' ,,,\-r .'i ":--, dl~~~'-f.. '1\" l~' '<'~,;!'ENl \\',,~!!'ll' ~!!!.!!!'--' p S-,i(,:;'JQQ4 V\.JOv \; o. 21-2001-1Ag ~ ,?:)? d:-~ Co 7<U~T 1(1(;11 lZl'~lqr<lr OCT 0 3 2000 lhlC 2187 COMMONWEALTH OF PENNSYLVANIA · OEPARTMENT OF HEALTH · VITAL RECORDS CERTIFICATE OF DEATH SlAn FILE NUMBER SOCIAL SECURlrY NUM8ER OA1 E OF DEATH .MC/IIII. Oa). '1eaI) .. ~).u () ;) d NAME OF DECEDENT (f,rSl MldOIe, La5I) SEX 2. Fe.mal.e. Be.tty J. AdlVl UNDER I YEAR ~ Oap 1. AGE (lasl Blltlld.y) 3.201 - 16 1582 UNOER I 01i!f _ Minul.. 8IRTHPlACE (c.ry arod PlACE OF DEATH IC/'>eck ""'y """ -- _ ,n51rUCloOOS on """" So<l81 Slale 01 Fcre.qn CCYunul' A HOSPITAL; lopal""" 0 ER/OuIpallanl 0 7. ... FACILITY NAME (II nollnsNUl""'. 9"'" Slreel and numl:l8f. ~O g::lIylO Did ...,.". ..... ... CumbVlland towna/lIp? 17..0 ::=::'::01 MOTHER'S NAME IF.s1.Moddle. Malden Surname) I'. MaJl.tha GundeAman INFORMANT'S MAILING AOORESS (SltMl. CryITown. SlIo.., Zip CodlIl 2Olt. 2930 Mc.ona Road, Me.c.han{c.~bWl ,PA 17055 PlACE OF DlSPOSrTION . N~ 01 c.m.'.ry. C"m.cory LOCATION. Citylbon, Slala. rill Code ....om.rPYca CJr.e.mauon Soc.-<.e.tlj On 21e. PA CJr.ematoJr. 21d. HaJl.Jr.{~bUA PA 17109 NAMEANOAOORESSOFFACllIrY CJr."ma;t.i on ."OC{fltu 06 PA 220:. 4100 Jone.~town Koad; MaJ(Jt-<...60lVt ,Pi\ 17109 lICENSEN;}R c vU DATESIGNEO f2 ;L 17 0 0 / - (Mo/Ifl. Oa~ _I 2311. 23c. t WAS CAse REFERRED 10 MEDICAL EXAMINEAlCORONER? Yea~ F\) 76 y,.. 5. COlINrY OF OERH ~ CumbeAland Ie. LowVt Alfe.n Twp .... KINO OF 8USINESS/INDUSTRY oj(CEDENT'SUSUAL OCCUPATION (~":on.~~:i.. %"'u'::~:'r ~.~_ ~~m~m_ak~_____-c-_______ 1n~~ ------- oECiDiN'T;s r.tAA.ING AooAESS-tSr;.;;ft~ CItyITown SIaIa. ZIlI Codel DECEDENT'S ACTUAL 32 5 We.~le.!j VJr...tve. RESIDENCE h . b (See .nSllucIlrlna ... Me.c. an-<.c...6 UA 9 , P A 1 7 055 on QItlet SIde) 'ATHER'S NAME IF-st. MrOdIe. LaSlI I'. EaJl..f. F. Bowman 'lFOAMANT'S NAME IT YIJ4l/Pllnl) Ga. MJt. ROOVlt AdleA IETHOO OF DISPOSITION BurW 0 c,..-ion (g;l 0lh0M (Spec"'" 17b. .... 24.28 musl ~ compleled by ...... wIIO ptonounc:ea de.ln 02 2000 1E00ATl CAUSE (FInal as. 01 CondIflOn IIntJ on <l6aIh\- ./LL~ ~V/f-~ DUE 10 (OR AS A CONSEQUENCE Of)' .....>alIy IilIl conclItJona " -.g 10 IItIIMdiale . ERI.. UNOEALYIHO R (o.seas. 01 "'""y 'llllaIed eV8t\ls IflO III oeartJ) lAST DUE 10 lOR AS A CONSEQuENCE 01'): DUE TO (OR AS A CONSEQUENCE Of); AN AUTOPSY 'ORMED? d WERE AUTOPSY FINDINGS _1U<8lE PRIOR 10 COMPLETION OF CAUSE OF OERH1 Homeide MANNER Of DEATH DATE OF INJURY (MOI\\t). Day. 'l!3'1 ~ o o OTHER: fA Nursong Homo> W4SHCEDENTOF. HISfYo.NICORIGIN1 No \,Xl .... 0 "v-e. "PK.... Cuban. Meu:an, P_Ric.ln,"C: .. Wh{te. MAAITAl STATUS. Mamed N..., Marrill<l. WIdOwed. OMWced (Spec",,) '4. W{dowe.d SURVIVING SPOUSE <" ..... \jI1Ie ma.oen namel ""'. C1IyIbonl HoD H. I Appro"mate : l/Ilerval be_n I 0.- and dea'" I I I PART N: 0Iher signlllcanl condiIions contributing 10 dealh, buI 1101 ruuIIing in lhe """"'I>Q ~ yiveCI in PAAT I ~ ~ cAt> TIME OF INJURY INJURY AT WORK? OESCRIBE HOW INJURY OCCVAflEO. Ac:uleRl Pend"'lIln...ligallon o o o ~CE OF INJURY AI nom.. 'ar~~;e.l. factor,. offic. building. .,e ,Spec"v) 30e M. 300:. Naluta' o NotJ No~ SuICide Yea 0 Coutd nol be del8rmtned 21lb. :FlEA (C~ecJ< onoy one) ~TIFYING PHYSICIAN (Ph~s.c~C\ Cr.fhtY1ng cause 01 dealh wheft.}.t'lo\nef ptws..c,an has pronOlJoceo Oealh ana compleled lIero 23) the be.. 0' my know&edge. de.th OCCUlTed due 10 the c.u...~.) and milnn.,.. .tated. . :19. ONOUNCiNG AND CERTlfY'NO PHYSICIAN (Phv~l.4rt bolt., >.)1 :)/IOUfI(;I(IIJ lJf!dlh ,j,{I(j Cet"tlCYlny 10 Lih}Sc;t 01 Oedlfi) the b41It QI my koowledgft, c:fe.th occurred .lthe Um., d.le, ~nd pl.ce. And due to the cause(.) and manner Ii. I'aled OleAl EXAMINER/CORONER Ihe buia 01 ..am,nalion and/or inveslig..lion, in my op,nion, dulh occurred al Ihe lime. dal., and place, and due 10 Ihe cause(aland nner a. stated. . . . ~AT~~ - ~ I~/I~/I ....0 NoD 3Of. SIGNATURE AND TITLE OF CERTIFIER o 31b. ~~ LICENse NU~I}ER ~ [J 310: J~ OYl '41{ 31d. to NAME AND AOORESS Of PERSON WHO C9MPlETED CAUse OF DEATH (1lem 27) Type or Pllnl V IS (.1/l().. ~AI1~ 'I)." p,2.. (iJ" S I- [J J4. . 21-2001-149 LAST WILL AND TESTAMENT OF BETTY J. ADLER I, BETTY J. ADLER, of Upper Allen Township, Cumberland County, Pennsylvania, do hereby make this my Last will and Testament, revoking any former wills and Codicils made by me. FIRST: I am married to Stanley D. Adler, Jr., and all references to my husband in this will are to him. I have two children: Robert A. Adler (born December 29, 1961); and Stacy D. Adler (born August 20, 1965). These and any other children born to or adopted by my husband and me are described in this will as "my children." SECOND: I give my tangible personal property and all insur- ances thereon to my husband, Stanley D. Adler, Jr., or, if he does not survive me, I give said property to my children who are living at my death to be divided equally among them as they determine or, if they are unable to agree, as my Executor shall determine, after considering the wishes of such children. I have complete confidence that my husband or my Executor will honor any written instructions that I may leave with regard to said tangi- ble personal property. Any such property not so distributed should be sold and the proceeds added to my residuary estate and pass as hereafter described. THIRD: If my husband, Stanley D. Adler, Jr., shall survive me, I bequeath to my Trustee, hereinafter named, IN TRUST NEVER- ,/ //~,,-./' ,_//_~~~," -" /' , (/ I' c/t1 ,( L./ -1- THELESS, cash, securities or other property in the amount spec- ified below, to be known as the "Bypass Trust." (1) The bequest shall be $600,000, subject however, to subparagraphs (2) and (3) below. (2) The bequest shall increase or decrease, based upon the availability of my federal unified credit for estate and gift taxes and the maximum allowable federal estate tax credit for state death taxes (but only to the extent that the use of such state death tax credit does not increase the death tax payable to any state), whether due to statutory changes, lifetime gifts in excess of the federal unified estate and gift tax exemption- equivalent amounts, or any other transfer which affects the availability of my federal credits aforesaid. (3) The bequest shall decrease to zero, if necessary, to reduce federal estate tax payable as a result of my death to zero (excluding, however, any federal estate tax due as a result of an excess retirement accumulation under Section 4980A of the Internal Revenue Code of 1986, as amended, or such similar section as may then be in effect), considering that my intention is to fund the Bypass Trust by using my available federal unified credit for estate and gift taxes and my federal estate tax credit for state death taxes and to eliminate federal estate tax on the balance of my federal taxable estate by using the federal estate tax unlimited marital deduction. ) , /.-// It ; (," / (1 .,f /.~j , oJ: . {/ - { I , j '\ I // f' \.. / I ./ >/ ,;('( ,'J \.. i,t-' f~__ -2- FOURTH: I give, devise and bequeath the rest, residue and remainder of my estate, real, personal and mixed, to my Trustee, hereinafter named, IN TRUST NEVERTHELESS, to be known as the "QTIP Trust." However, should my husband not survive me, I give, devise and bequeath such rest, residue and remainder to my Trustee, hereinafter named, IN TRUST NEVERTHELESS, to be held, administered and distributed for all purposes as part of the Bypass Trust. FIFTH: The QTIP Trust shall be held, administered and distributed as follows: (1) Commencing with the date of my death, my Trustee shall pay to or apply for the benefit of my said husband during his lifetime all the net income from the QTIP Trust in convenient installments but no less frequently than annually. (2) In addition, my Trustee may pay to or apply for the benefit of my said husband such sums from the principal of the QTIP Trust as in its sole discretion shall be necessary or advisable from time to time for the medical care, comfortable maintenance, and welfare of my said husband, taking into con- sideration to the extent my Trustee deems advisable, any other income or resources of my said husband known to my Trustee. (3) Upon the death of my said husband, the entire remaining principal of the QTIP Trust shall be held, administered and distributed for all purposes as part of the Bypass Trust, , /' _J!-/ J <?', I 1/ '.._ l. ' i,1 " ////' I > f-'<;/~-(~ C (L /i l " f ') ~ ~.~. ,/ ,.'~ -3- provided that my Trustee may pay to the executor of my husband's estate an amount necessary to pay death taxes attributable to the QTIP Trust. (4) The income interest in the QTIP Trust is intended to qualify as a qualified income interest, and the property held in the QTIP Trust is intended to constitute qualified terminable interest property under Section 2056(b) (7) and (8) of the In- ternal Revenue Code of 1986, or such like section as is enacted from time to time. SIXTH: The Bypass Trust shall be held, administered and distributed as follows: (1) Commencing with the date of my death, my Trustee shall pay to or apply for the benefit of anyone or more of my said husband, my children and my issue, until division into shares pursuant to Paragraph (5), all of the net income from the Bypass Trust in convenient installments in such shares and proportions as my Trustee in its sole discretion shall determine primarily for the medical care, education, support and mainte- nance in reasonable comfort of my said husband, children and issue, taking into consideration to the extent my Trustee deems advisable, any other income or resources of my said husband, children and issue known to my Trustee, considering that my husband is the primary object of my bounty. -4- 1<)- /zz(/ I i .....~ ,/-' //~' ,,// / ,,')(~ <. c, ( ~ / \.. "/ ' , / t,./ (2) Prior to division into shares pursuant to Para- graph (5), my Trustee may pay to or apply for the benefit of any one or more of my said husband, children and issue such sums from the principal of the Bypass Trust in such shares and proportions as in its sole discretion shall be necessary or advisable from time to time for the medical care, education, support and mainte- nance in reasonable comfort of my said husband, children and issue, taking into consideration to the extent my Trustee deems advisable, any other income or resources of my said husband, children and issue known to my Trustee, considering that my husband is the primary object of my bounty. Any payment or application of benefits for a child or issue of mine pursuant to this Paragraph shall be charged against this Trust as a whole rather than against the ultimate distributive share of a bene- ficiary to whom or for whose benefit the payment is made. (3) In addition to the income and discretionary payments of principal from this Trust, there shall be paid to my said husband during his lifetime from the principal of this Trust upon his written request during the last month of each fiscal year of the Trust an amount not to exceed during such fiscal year the amount of Five Thousand Dollars ($5,000) or five percent (5%) of the aggregate value of the principal of the Bypass Trust on the last day of such fiscal year without reduction for the principal payment for such fiscal year, whichever is greater. ~' .- >-=~) / '-, / "".1. I ,-"'" I.. ?:~. . ...- ----:r-. ". 1'.-' -' /" ,- I .--c /' " ('/ , / ,-' / /"j<- L{j/Lr ( (- - -5- This right of withdrawal is noncumulative, so that if my said husband does not withdraw, during such fiscal year, the full amount to which he is entitled under this Paragraph, his right to withdraw the amount not withdrawn shall lapse at the end of that fiscal year. (4) My husband shall have a special power to appoint all or any portion of the Bypass Trust during his lifetime by written document, delivered to my Trustee, referring expressly to this Article, or by Will, validly executed and attested referring expressly to this Article, among such other person or persons hereinafter named or described absolutely or in trust, as he may indicate. This special power of appointment is exercisable only in favor of a child of mine as described in this Will or to the issue of any such child. My aforesaid spouse shall have no power to appoint the principal of this fund or income accumulated thereon to himself, his estate, to his creditors, or to the creditors of his estate. My Trustee may rely upon an attested will probated in any state, if executed in accordance with Pennsylvania formality and otherwise meeting the requirement of this Paragraph. (5) In default of the exercise of such power of appointment by my said husband, or insofar as any part of the Bypass Trust shall not be effectively appointed, then upon the death of my said husband, the entire remaining principal of the -6- ~~~--~~--- ) ;4] _j{-~ / l ./ \ " /" (f/ (/j;/ ~~~ ~ ( (> l Bypass Trust, or the part of such trust not effectively appointed shall be divided into equal separate shares so as to provide one (1) share for each then living child of mine and one (1) share for each deceased child of mine who shall leave issue then living. The share provided for a living child of mine shall be distributed to such child. The share provided for a deceased child of mine who shall leave issue then living, shall be dis- tributed per stirpes to such issue. (6) If at the time of my death, or at any later time prior to final distribution hereunder, my said husband and all my issue are deceased and no other disposition of the property is directed by this Trust, then and in that event only the then remaining property of this Trust, together with any undistributed income, shall be distributed fifty percent (50%) to the American Cancer Society, without restriction as to use, and fifty percent (50%) to the American Heart Association, without restriction as to use. SEVENTH: If any share hereunder becomes distributable to a beneficiary who has not attained the age of thirty (30) years, then such share shall immediately vest in such beneficiary, but notwithstanding the provisions herein, my Trustee shall retain possession of such share in trust for such beneficiary until such beneficiary attains the age of thirty (30) years, using so much of the net income and principal of such share as my Trustee deems / ,(/ ,.,,? . /' L )"; //:/;~~(L/(_ ;/./... ([. ('. (?/ /. l.' / ( ~./ / -7- necessary to provide for the proper medical care, education, support and maintenance in reasonable comfort of such benefi- ciary, taking into consideration to the extent my Trustee deems advisable any other income or resources of such beneficiary or his or her parents known to my Trustee. Any income not so paid or applied shall be accumulated and added to principal. Such beneficiary's share shall be paid over and distributed to such beneficiary upon attaining the age of thirty (30) years, or if he or she shall sooner die, to his or her executors or administra- tors. I recommend that my Trustee consider distributing all income from such share to such beneficiary upon attaining the age of twenty-one (21) years. My Trustee shall have with respect to each share so retained all the powers and discretions had with respect to the trusts created herein generally. EIGHTH: Anything in this will to the contrary notwith- standing, no trust created herein shall continue beyond twenty- one (21) years after the deaths of one, the last to die of my issue living at the time of my death; and two, all issue of the individual serving as President of the united States at my death and all then living issue of said individual's five (5) immediate predecessors in said office; upon the expiration of such period, all trusts shall terminate and all the assets thereof shall be distributed to those beneficiaries (and in the same proportions) as are then entitled to receive the income therefrom. ..' ..--;-- --.:1 ~~~- ) " ") //. //' L~-tt(I' J .. ('%;{L~_ / I -8- NINTH: If any beneficiary and I should die under such circumstances as would render it doubtful whether the beneficiary or I died first, then it shall be conclusively presumed for the purposes of this my will that said beneficiary predeceased me. TENTH: (1) I name as my Executor, herein referred to as my Executor regardless of number or gender, my husband, stanley D. Adler, Jr.; or if he is unable or unwilling to serve, I name Heath L. Allen and CCNB Bank, N.A. as my Co-Executors. If Heath L. Allen is unable or unwilling to serve, I name William E. Miller, Jr., as alternate Co-Executor. I direct that my Executor serve without bond in any jurisdiction in which called upon to act. (2) I name Heath L. Allen and CCNB Bank, N.A. as my Co-Trustees, herein referred to as my Trustee regardless of number or gender. If Heath L. Allen is unable or unwilling to serve, I name William E. Miller, Jr., as alternate Co-Trustee. I direct that my Trustee serve without bond in any jurisdiction in which called upon to act. (3) Except as otherwise provided herein, if Stanley D. Adler, Jr., Heath L. Allen and William E. Miller, Jr., or any successor as herein defined should fail to qualify as Executor or Trustee hereunder, or for any reason should cease to act in such capacity, the successor or substitute Executor or Trustee shall be some other attorney to be appointed by the law firm of Keefer, -9- , "' ) ~ /' t ,//"' " "{'/~/:- - ~:>;/' ,/7---.-1' '.' t'. .(1'.... ~. /.... " . A.. ( .(__ ......c/ ,--.-f::. , ~. c- t/ . _ . 0 /' ,/ ( Wood, Allen & Rahal. It is my intention that an attorney and a corporate fiduciary shall serve in the capacity of Executor and Trustee at all times. (4) My Trustee shall receive reasonable compensation. (5) The situs of all trusts created herein shall be Cumberland County, Pennsylvania. ELEVENTH: (1) I give to any Executor and to any Trustee named in this will or any Codicil hereto or to any successor or substitute Executor or Trustee all of the powers now applicable by law to fiduciaries in the Commonwealth of Pennsylvania and in particular, through the Pennsylvania Probate, Estates and Fidu- ciaries Code, as effective and as in effect on the date hereof, during the administration and until the completion of the dis- tribution of my estate, and until the termination of all trusts created in this will or any Codicil hereto and until the com- pletion of the distribution of the assets of such trusts. (2) My Executor shall have absolute discretion, but shall not be required, to make adjustments in the rights of any beneficiaries, or among the principal and income accounts to compensate for the consequences of any tax decision or election, or of any investment or administrative decision, that my Executor believes has had the effect, directly or indirectly, of pre- ferring one beneficiary or group of beneficiaries over others. In determining the federal estate and income tax liabilities of ~;Z~F; ;reel:} (/;;l;::~_ / // ' i ," -10- my estate, my Executor shall have discretion to select the valuation date and to determine whether any or all of the allow- able administration expenses in my estate shall be used as federal estate tax deductions or as federal income tax deductions and shall have the discretion to file a joint income tax return with my spouse. (3) If at any time any trust created hereunder (or any share thereof if the trust shall have been divided into shares) shall be of such value that, in the opinion of my Trustee, the administration expense of holding the assets contained therein in trust is not justified, my Trustee, in its absolute discretion, may terminate such trust and distribute the trust property to the person or persons then entitled to receive or have the benefit of the income therefrom or the legal representative of such person. If there is more than one income beneficiary, my Trustee shall make such distribution to such income beneficiaries in the proportion in which they are beneficiaries or if no proportion is designated in equal shares to such beneficiaries. (4) If there be any property located outside the Commonwealth of Pennsylvania, in which I may have an interest at the time of my death, which cannot be conveniently administered as provided herein, then I authorize, but do not require, my Executor to appoint a bank or trust company with trust powers, to administer such property according to the terms of this will. -11- ~Z\:citil I ,) , j/ /~- /' /~ /~ r. ((:l.{ ( {c. / (5) My Executor and Trustee are authorized and em- powered to retain, either permanently or for such period of time as my Executor or Trustee may determine, any assets, including the capital stock of any closely held corporation, which at any time shall come into the possession of my Executor and Trustee as a part of any Trust created herein, whether such assets are or are not of the character approved or authorized by law for investment by fiduciaries and whether such assets do or do not represent an overconcentration in one investment. TWELFTH: No interest of any beneficiary under this Will, any Codicil hereto, or any trust created herein shall be subject to anticipation or to voluntary or involuntary alienation. THIRTEENTH: All estate, inheritance, succession and other death taxes imposed or payable by reason of my death and interest and penalties thereon with respect to all property comprising my gross estate for death tax purposes, whether or not such property passes under this will, shall be paid out of the residue of my estate, as if such taxes were expenses of administration, without apportionment or right of reimbursement. I authorize my Executor .--;7 LL. ;9/' I /'Z'_~~) '-. (;.71~{/ / II ;'/ /) // (/ d 6>L -12- and Trustee to pay all such taxes at such time or times as deemed advisable. IN WITNESS WHEREOF, I have set my hand and seal on this my (~ ~ Last will and Testament this <,.t> day O(.)t{:)/t/<Y;,1!! ('err 1989. " ,~/ --7--;>> /~). 1~1l; I' 4_, "- .- BETTY J. ADL /'., //' / I~l;Zl-/(SEAL) SIGNED, SEALED, PUBLISHED, and) DECLARED by BETTY J. ADLER, ) as and for her Last will and ) Testament, on the day and year) last above written, in the ) presence of us, who, at her ) request, in her presence, and ) in the presence of each other,) all being present at the same ) time, have hereunto subscribed) our names as witnesses: ) ) ) ) ) ) ) ) ) ) ) ) ) l. II /)/( ~ 1(. i. A n ~ -tit:{.(../,-. . M~~ c/~~ ."""'-" /IL,~, (/ , l't " '-' \ . .' J ,I \. '\.'-~-, 1 '-' . \-- ....~ '.- --,. -13- SELF-PROVING AFFIDAVIT COMMONWEALTH OF PENNSYLVANIA SSe COUNTY OF DAUPHIN WE, BETTY J. ADLER, and HEATH L. ALLEN DEBORAH L. RYAN , and GARY E. FRENCH , the Testatrix and the witnesses, respectively, whose names are signed to the attached or foregoing instrument, being first duly sworn, do hereby declare to the undersigned authority that the Testatrix signed and executed the instrument as her Last Will and that she had signed willingly (or willingly directed another to sign for her), and that she executed it as her free and voluntary act for the purposes therein expressed, and that each of the witnesses, in the presence and hearing of the Testatrix, signed the Will as witness and to the best of his or her knowledge the Testatrix was at that time eighteen (18) years of age or older, of sound mind, and under no constraint or undue influence. -- ---;-) /~J~_'e~7~ BETTY J. A /JiL/( L Aicl '... wItness ') ~ / ::/'. /) hd~u:L-h _ L/~ w.it-ness ,/ .... . , r:-/.... ~ 'l .f .-.' . '. / ..' . 'L-'- -" lc~A-' \ ',-.. '.f ',L ..~ Witfi e s s.._)--' Subscribed, sworn to, and acknowledged before me by BETTY J. ADLER, the Testatrix, and subscribed and sworn to before me by HF.ArrH T. A T,T.RN DEBORAH L. RYAN , and GARY E. FRENCH of September , witnesses, this 8th day , 1989. ~/! ' I,. / . . . ,)--Ltc 't\~.A:'I C ",,-- -14- NOTARIAL SEAL KATHRYN C. HOLLINGER, Notary.Publlc Harrisburg, Dauphin County My Commission Expires Marcil 14, 1991 21-2001-149 SOLE CODICIL OF BETTY J. ADLER I, BETTY J. ADLER, of Upper Allen Township, Cumberland County, Pennsylvania, do hereby make this Sole Codicil to my Last will and Testament dated September 8, 1989. 1. I revoke Item ELEVENTH of my Last will and Testament in its entirety, and provide, in lieu thereof, as follows: ELEVENTH: (1) I name my son, Robert A. Adler, and Paul J. Killion, Esquire, as my Co-Executors. If either is unable or unwilling to serve, the individual serving as my Co-Executor shall appoint a substitute Co-Executor so that there are two individuals serving at all times. I direct that my Co-Executors (one of whom shall be an attorney) serve without bond in any jurisdiction in which called upon to act. (2) I name my son, Robert A. Adler, and Paul J. Killion, Esquire, as my Co-Trustees. If either is unable or unwilling to serve, the individual serving as my Co-Trustee shall appoint a substitute Co-Trustee so that there are two individuals serving at all times. I direct that my Co-Trustees (one of whom shall be an attorney) serve without bond in any Jurisdiction in which called upon to act. (3) My Co-Trustees shall receive reasonable compensation. 2. In all other respects, I hereby ratify, confirm and republish my Last will and Testament dated September 8, 1989, together with this Sole Codicil, as and for my Last Will and Testament. ~ff,~/ -1- IN WITNESS WHEREOF, I have set my hand and seal on this the Sole Codicil to my Last Will and Testament this , 2000. SIGNED, SEALED, PUBLISHED, and DECLARED by BETTY J. ADLER, as and for the Sole Codicil to her Last will and Testament dated September 8, 1989, on the day and year last above written, in the presence of us, who, at her request, in her presence, and in the presence of each other, all being present at the same time, have hereunto subscribed our names as witnesses: day of 2~/~.C(d~ (SEAL) BETTY J OA'oLER '~- #~&cI~ /''/;/ f //1 Ii ; /('! t'~/) L L./. v"'- (.- :l))LIJ./)~:"/ /' 1Zt(iJ r -2- ~ SELF-PROVING AFFIDAVIT COMMONWEALTH OF PENNSYLVANIA SS. COUNTY OF CUMBERLAND WE, BETTY J. ADLER, , and , the Testatrix and the witnesses, respectively, whose names are signed to the attached or foregoing instrument, being first duly sworn, do hereby declare to the undersigned authority that the Testatrix signed and executed the instrument as the Sole Codicil to her Last will and that she had signed willingly (or willingly direct- ed another to sign for her), and that she executed it as her free and voluntary act for the purposes therein expressed, and that each of the witnesses, in the presence and hearing of the Testa- trix, signed the Codicil as witness and to the best of his or her knowledge the Testatrix was at that time eighteen (18) years of age or older, of sound mind, and under no constraint or undue influence. ~ fJ-,~ BETTY J. ADLER, Testatrix d&kOt/~ Wltne~s, /r /__', /; / ( . ,/ ,/ \ r-.- ./ I /.., I \."1 / " /1 f~;;;' /' t ,/ , " hi!e~!)l (7), \~;ll/}l/uJf?'IL w/l!!i! F Subscribed, sworn to, and acknowledged before me by BETTY J. ADLER, the Testatrix, and subscribed and sworn to before me by and 0p1~ , witnesses, this ~ day of , 2000. ~~tJL)J. C'J \..3,"S'\~r~0Ll(_Q\)~, Notary Pub'iic .-...'"~>-9't-"''''___''_.~'-'-'--'-''''->'''.''''~''''''''-' ...."......,-' .. ".-- -3- t- L)t::Fo: :',1; ~~~(~;:-tt Shellv l\. f';.a;l!c;I;~ ., C;~lf~J)u(q ? i\fty Ccm,'ni:::,k:'1 L_~._.-_.._---.... .... .. ~',i; () r-r ' 1 '_' r ~::.. ',_~' 1 ~)"~~):;" ~ (y FEB 0 6 20n,1 ~ ESTATE OF BETTY 1. ADLER, Deceased IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY : PENNSYLVANIA, INRE: : ORPHANS' COURT DIVISION : ESTATE NO, 21-01-149 : Hon. George E. Hoffer, PJ. '" ORDER AND NOW, this -It---= day of February, 2003, the within Petition for Determination of Finality is denied. BY THE COURT: 1.40 . I ESTATE OF BETTY 1. ADLER, Deceased IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY PENNSYLVANIA, INRE: ORPHANS' COURT DIVISION ESTATE NO. 21-01-149 Hon. George E. Hoffer, P.l. PNC BANK'S ANSWER TO PETITION FOR DETERMINATION OF FINALITY AND NOW COMES, PNC Bank, N.A., in opposition to the Petition of William L. Adler, Esquire, for determination of finality, and by way of Answer, respectfully represents the following: 1. Admitted. 2. Admitted. 3. Admitted. 4. Admitted. 5. Admitted. 6. Denied. Pa. R.A.P., Rule 342 does not authorize a determination of finality as to orders not otherwise final that determine the propriety of "payments made or to be made" for fees, commissions and administration expenses. 7. Denied. Pa. R.A.P., Rule 342 does not authorize a determination of finality as to orders not otherwise final that determine the propriety of "payments made or to be made" to secured creditors. 8. Pa. R.A.P., Rule 342 authorizes a determination of finality to an order not otherwise final, only where such order determines "an interest in realty, personalty, the status of individuals or entities or an order of distribution...." Neither title to property, nor status of individuals or entities, nor distributions to beneficiaries was determined by this Court's Orders of December 31, 2002. 9. Ordinarily, "[i]n a decedent's estate, the confirmation of the final account of the personal representative represents the final order, subject to exceptions being filed and disposed of by the court." In re the Estate of Habazin, 451 Pa. Super 421,423,697 A.2d. 1293,1295 (1996 ). 10. "A determination that an immediate appeal of a non-final order is appropriate should be made only in the most extraordinary circumstances.... Courts are cautioned to refuse to classify orders as final except where the failure to do so would result in an injustice which a later appeal can not correct." Pullman Power Products of Canada Limited v. Basic Engineers, Inc, 713 A.2d 1169,1172-3 (1998 Pa. Super.) (citing Liberty State Bank v. Northeastern Bank of Pennsylvania, 453 Pa.Super. 231, 683 A.2d 889 (1996) and McKinney v. Albright 429 Pa.Super. 440, 632 A.2d. 937 (1993). 11. To require the executors to comply with this Court's Orders of December 31, 2002, pending the confirmation of their final account, would not "result in an injustice which a later appeal can not correct." Id. WHEREFORE, P.N.C. Bank, N.A. respectfully requests that the within Petition for Determination of Finality be denied. Respectfully submitted, SAlOIS, SHUFF, FLOWER & LINDSAY BY:~~~1 Geoffrey S. Shuff, Esquire \ Supreme Court ID #24848 Thomas E. Flower, Esquire Supreme Court ID #83993 2109 Market Street Camp Hill, PA 17011 (717) 737 - 3405 Attorney for Respondent, PN C Bank, N .A. '" . INRE: IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY PENNSYLV ANIA, ESTATE OF BETTY J. ADLER, Deceased ORPHANS' COURT DIVISION ESTATE NO. 21-01-149 Hon. George E. Hoffer, P.J. CERTIFICATE OF SERVICE r- AND NOW, this .~ day of February, 2003, I, Thomas E. Flower, Esquire, of the firm of Saidis, Shuff, Flower and Lindsay, hereby certify that I this day served a true and correct copy of the PNC Bank's Answer to Petition for Determination of Finality upon the parties listed below via United States Regular Mail, postage prepaid, in the above-captioned matter as follows: William Adler, Esquire ADLER & ADLER P.O. Box 11933 125 Locust Street Harrisburg, PAl 71 08-1933 Respectfully submitted, SAIDIS, SHUFF, FLOWER & LINDSAY /-:\ -" 1~7 By:Jj h-Ai,^-,U4 ~/{-<JVl'-U~ Thomas E. Flower, Esquire . Supreme Court ID #83993 2109 Market Street Canlp Hill, P A 17011 (717) 737-3405 Attorney for Petitioner ~. 1'1 g' ~.r.! 4l.}. /1 ~ (}./--' . j , f" : ~ ~}J)' l~) '"'U'.- ~.3\.O'J- c IN RE: IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA ESTATE OF BETTY J. ADLER, DECEASED ORPHANS' COURT DIVISION NO. 21-01-149 ORDER OF COURT AND NOW, this 31st day of December, 2002, upon consideration of PNC Bank, National Association's Petition for Rule to Show Cause Why Execution Should Not Issue on Judgments Entered Against, Inter Alia, Betty J. Adler, Deceased, and Attachment Be Made Upon Any and All Ownership Interest of Decedent, Betty J. Adler, in Certain partnerships Subject to Bank's Priority Perfected Security Interest Pursuant to 20 P.S. 3377(a)(2), and the Reply of the Estate's Executors thereto, an after hearing thereon, IT IS HEREBY ORDERED, ADJUDGED AND DECREED THAT PNC Bank, National Association, is authorized to, and may at any time and from time to time hereafter execute on any, some or all of the Judgments described in the Bank's Petition, and garnish, attach, and/or otherwise levy upon any right, title and/or interest of the Estate to or in the Partnerships and/or the Corporations described in the Bank's Petition, including without limitation the rents, issues, income, profits and proceeds thereof. By the Court, (ULUd2 C~/~1i J J ; {{ 1~-:3fU Geoffrey S. Shuff, Esquire Saidis, Shuff, Flower & Lindsay 2109 Market Street Camp Hill, PA 17011 William L. Adler, Esquire Adler and Adler 125 Locust Street Harrisburg, PA 17101 . . c IN RE: IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA ESTATE OF BETTY J. ADLER, DECEASED ORPHANS' COURT DIVISION NO. 21-01-149 ORDER OF COURT AND NOW, this 31st day of December, 2002, upon consideration of the First and Partial Account of Robert A. Adler and Paul J. Killion, Executors of the Estate of Betty J. Adler, and after consideration of and hearing on PNC Bank, National Associations' Objections to the Account, IT IS HEREBY ORDERED, ADJUDGED AND DECREED THAT: 1. Confirmation of the First and Partial Account, as filed, is hereby denied, but without prejudice to the future filing by the Executors, Robert A. Adler and Paul J. Killion, of an account providing for the payment of expenses of the Estate; and 2. The Executors shall immediately turn over to the law firm of Saidis, Shuff, Flower & Lindsay on behalf of PNC Bank, National Association, to the extent of its claim, any and all distributions, payments, proceeds and other amounts of any nature which have been received by or on behalf of the Estate, and/or are being held by or on behalf of the Estate, from, through, under or otherwise on account of the Partnerships and/or the Corporations described in the Banks' Objections to the Account; and 3. The Executors are hereby surcharged for any and all amounts which r the Executors paid to themselves or to any other person or entity out of distributions, payments, proceeds and other amounts of any nature which have been received by or on behalf of the Estate, and/or were or are being held by or on behalf of the Estate, from, through, under or otherwise on account of the Partnerships and/or the Corporations described in the Bank's Objections to the Account, and all such amounts shall be immediately paid by the Executors to the Law firm of Saidis, Shuff, Flower & Lindsay on behalf of PNC Bank, National Association, to the extent of its claim; and 4. The Executors shall promptly turn over to the law firm of Saidis, Shuff, Flower & Lindsay on Behalf of PNC Bank, National Association, to the extent of its claim, any and all distributions, payments, proceeds and other amounts of any nature which are received by or on behalf of the Estate, from, through, under or otherwise on account of the partnerships and/or the Corporations described in the Bank's Objections to the Account, on and after the date of this Order; and 5. As part of any account filed by the Executors in the future, the Executors shall account for the household furnishings, vehicles and other personal property of the Decedent at the time of her death. By the Court, 4' Geoffrey S. Shuff, Esquire Saidis, Shuff, Flower & Lindsay 2109 Market Street Camp Hill, PA 17011 William L. Adler, Esquire Adler and Adler 125 Locust Street Harrisburg, PA 17101 JY~Llt40 ^ ' - f" -1 I' U t ' ~_ ~l-'~i~/~C"-- I~,jl -CA ~w .- 53_ Page 1 Petition where decedent left a WILL. In the Orphans' Court Division of the Court of Common Pleas of J?~utpbirr County ~-<.m tUrtaAct COMMONWEALTH OF PENNSYLVANIA No. 21-01-0149 Estate of BETTY J. ADLER , deceased. The petition of ROBERT A. ADLER AND PAUL J. KILLION (Name of Petitioner) respectfully represents: 1. The decedent, WIDOW , late (State whether Married or Unmarried at time of Death) of the LOWER ALLEN TOWNSHIP of CUMBERLAND COUNTY died on OCTOBER 2 (Date) ~~ 2000 , , having made a WILL, and ONE CODICIL(s), duly probated on lQ{ 2001, and recorded in Roll FEBRUARY 6 (Date) , on which the present letters (Date) TESTAMENTARY , were granted on FEBRUARY 6 ){}t~1tO 1 (Date) , to ROBERT A. ADLER AND PAUL J. KILLION and leaving to survive a spouse and/or issue as follows.l .:-"" '... CHILDREN--ROBERT A. ADLER STACI SMITH ISURVIVING SPOUSE OR ISSUE: If married, state whether a husband or wife survived and his or her name. State \Nhether the decedent left issue and their names, when material. If none, so state. State whether surviving spouse has elected to take under or against the will, according to 20 Pa. C.S.A. Section 2201, et. seq., as amended and if such an election has oeen made, whether it has heen t:led, where recorded, and furnish a copy thereof. ~ Page 5 XI. The parts of the will of the decedent which require interpretation, and the questions which are to be adjudicated are as follows:1o PRIORITY OF PAYMENT TO CREDITORS. XII. No share of any party in interest has been assigned or attached. 11 SEE ATTACHED XIII. There are attached hereto the following: 12 (X) Original Proofs of Publication regarding Grant of Letters; ( x.) Attorney's Certificate of Notice; and (X) Proposed Decree Nisi. XIV. The distributive shares of principal and income, and the persons thereunto entitled, are suggested as follows: 13 SEE ATTACHED 'OQUESTIONS FOR ADJUDICATION: If none, insert the word "none". If any, refer to the parts of the will which require interpretation. State any questions which are to be adjudicated, presenting all material facts not already given, and a statement that the persons affected thereby have had notice that they will be submitted for adj udication. II ASSIGNMENT OR ATTACHMENT: State exceptions, if any, giving facts, with copy of assignment, certi fied by counsel, and the record of proceedings in which the attachment issued. I~RECORDS: Indicate with cross (x) mark, those submitted. '3DISTRIBUTION: (1) Give names, value, and proportionate share of distributees; (2) Give name of guardian, committee, trustee, or other fiduciary, if any; (3) If the distribution of income is different from that of principal, state the fact; (4) If distribution is to be made to an individual as trustee, state the Trustee's residence; and (5) If any advancements, or prior payment of share, or debts due estate, name distributee and state amount received or due. ( Page 6 Your petitioner, therefore, asks that distribution be awarded to the persons thereunto entitled, as their respective interests may appear. /.// /7/ / <:~,/./ /~/ AI' .....~. //~.~.~ h ~ // _ . ~YL--- '-1.-. ~ (Signature of Petitioner) COMMONWEALTH OF PENNSYLVANIA COUNTY OF c) (\-''-f \- \ r,- : 55.: The above named petitioner, being duly sworn, does depose and say that the facts set forth in the foregoing petition which are within the personal knowledge of the petitioner are true, and as to facts based on the information of others, the petitioner, after diligent inquiry, believes them to be true. Sworn to and subscribed before me this ~).. \ . ~~ day of ,'1,\ a. t-U--. .1'9 u:C 1- \ -) ""'\.~,~~~~ '-'- ';"\ \ \---, --'- ) \ \ \ \-.) ~ ~ ~, \ '( ~ \ L ~/-:;;;? a/::;~~ /_ //~' -..~e~~ (Signature of Petitioner) I DCSA OC Forms AdJudcn. fnn: \testate. fr4 (Rev: 11/93)J ,f.'-~o~~m~~:~L~bIiW~ --~ ; Harr&S~rg.' Dauphin County. PA ! My CommISSIon Expires Nov. 03 2005 ..,-_..._._...._-------~- Assignments of other partnership interests in favor of PNC Bank are attached hereto and are subject to the proposed schedule of distribution and the court's approval of the distribution of estate assets. XIV. The distributive shares of principal and income are set forth in the proposed schedule of distribution attached to the First and Partial Account. FIRST AND PARTIAL ACCOUNT OF ROBERT A. ADLER and PAUL 1. KILLION, EXECUTORS FOR ESTATE OF BETTY J. ADLER, DECEASED Date of Death: Date of Executor's Appointment: Date of Advertising of Estate: October 2, 2000 February 6,2001 Patriot News - April 4, 11, and 18,2001 Cumberland Law Journal- April 6, 13, and 20,2001 October 2, 2000 to March 19, 2002 Accounting for Period: Purpose of Account: Robert A Adler and Paul 1. Killion, Executors, offer this account to acquaint interested parties with the transactions that have occurred during their administration. The account also indicates the proposed distribution of the estate. It is important that the account be carefully examined. Requests for additional information or questions or objections can be discussed with: William L. Adler, Esquire 125 Locust Street Harrisburg, P A 17101 (717) 234-3289 -1- SUMMARY OF ACCOUNT Page Current Value Cash Flow Proposed Distribution to Beneficiaries Principal Receipts $1,144,917.00 Net Gain (or Loss) on Sales or ($425,000.00) Other Disposition Less Disbursements: Debts of Decedent ($1,338,004.41 ) Funeral Expenses Administration Expenses ($884.81) Federal and State Taxes Fees and Commissions ($3,459.63) Balance before Distribution Distribution to Creditor Principal Balance of Hand Income Receipts $4,636.00 Less Disbursements Balance Before Distribution Distribution to Beneficiaries Income Balance on Hand I-- C :7 ($618,087.41 ) $291. 56 I-- ~ j- ..". E j . $57,539.38 '---- I. f . f'''' j ;-t:!c c/ . /fL<) Z~~~:Llfc' L /Lv;K " J _" ~-{.", ~l L ~.(., , ~_? -2- './;/.1 i / 1;/ rj't" .: /./{ 1./../>/')1 c.-. [-vU{/ L// ':~ () ~ RECEIPTS OF PRINCIPAL Assets Listed in Inventory Valued as of Date of Death Fiduciary Acquisition Value ADLER JOINT VENTURE, P A Partnership 3401 Walnut Street Harrisburg, P A $43,700.00 25% Interest 4001-4005 Jonestown Road $103,592.00 Harrisburg, P A 25% Interest 315 Market Street $37,214.00 Harrisburg, P A 25% Interest 1800 Columbia Avenue $44,125.00 Lancaster, P A 25% Interest 2930 Arcona Road $425,000.00 Mechanicsburg, P A 17055 FRONT STREET EQUITY AS SOCIA TES, a Pennsylvania Partnership Park City Mall Lancaster, PA 25% interest $186,075.00 ALBEFORE REALTY, a Pennsylvania General Partnership 3556 Old Gettysburg Road Camp Hill, PA $276,795.00 45% interest -3- ZAL REALTY ASSOCIATES Land and Building described in the deed attached as exhibit 38 $28,416.00 50/0 interest TOTAL INVENTORY $1, 144,91 7 . 00 Receipts Subsequent to Inventory: GAINS AND LOSSES ON SALES OR OTHER DISPOSITIONS DATE LOSS GAIN 12/26/0 I 2930 Arcona Road sold at sheriff's sale ($425,000.00) pursuant to mortgage foreclosure, deeded to Bank of Hanover and Trust Co. Total ($425,000.00) -4- DATE DISBURSEMENTS OF PRINCIPAL Debts of Decedent Meridian Bank v. Stanley D. and Betty 1. Adler clo Dimitri L. Karapelov, Esquire KLEHR, HARRISON, HARVEY, BRANZBURGT ELLERS LLP 260 S. Broad Street Philadelphia, P A 19102 (215) 568-6060 V2 interest of Betty Adler $713,000.00 PNC Bank v. Stanley D. Adler and Betty 1. Adler cia Karl M. Ledebohm, Esquire SAIDIS, SHUFF, FLOWER & LINDSA Y 2109 Market Street Camp Hill, PA 17011 1h interest Decedent 2,274.070.50 Robert G. Smith, Jr. v. Stanley & Betty Adler 1h interest decedent $32,254.75 Bank of Hanover and Trust Co. c/o Beverly Points, Esquire BARLEY, SNYDER, SENFT & COHEN, LLC 14 Center Square Hanover, P A 17331 1,Iz share of Decedent Secured by mortgage on York Mini Mall $541,097.50 -5- Commonwealth of Pennsylvania Bureau of Individual Taxes Dept. 280431 Harrisburg, P A 17128-0431 1998 P A Income Tax $11,836.94 Judgment 00-8842 Balance as of March 18, 2002 Commonwealth of Pennsylvania Bureau of Individual Taxes Dept. 280431 Harrisburg, PA 17128-0431 1999 P A Income Tax $7,254.32 Commonwealth of Pennsylvania $289.70 Bureau of Individual Taxes Dept. 280431 Harrisburg, PA 17128-0431 2000 P A Income Tax Internal Revenue Service $602.13 l;2 of 2000 Taxes CITY CARDS P. O. BOX 20432 KANSAS CITY, MO Account No. 54911303 49143610 $9,013.08 Alert Pharmacy at Bethany Village $1,954.69 Bethany Village, final bill $18,427.23 TOTAL $1,338,004.41 -6- Administration Expenses 5/3/01 Robert Adler $360.50 Return of Probate Costs 5/3/01 Patriot News $211.26 Advertise estate 9/7/01 Bank Service Charge $8.00 9/12/02 Clarke American Check Order $14.90 10/7/01 Bank Service Charge $8.00 10/30/01 William L. Adler $125.00 Reimbursement for Y2 appraisal fee for house 11/7/0 1 Bank Service Charge $8.00 12/7/01 Bank Service Charge $8.00 1/2/02 Rapid Offset $82.15 Exhibit s for 706 and Inheritance Tax Return 1/2/02 Register of Wills $35.00 Filing Inheritance Tax Return 1/7/02 Bank Service Charge $8.00 2/7/02 Bank Service Charge $8.00 3/7 /02 Bank Service Charge $8.00 TOTAL $884.81 Fees and Commissions 5/3/01 William L. Adler Attorney Fee $1,309.63 6/19/01 William L. Adler Attorney Fee $840.00 -7- 8/1 7/0 I William L. Adler Attorney Fee $810.00 10/5/01 William L. Adler Attorney Fee $500.00 TOTAL $3,459.63 DISTRIBUTIONS OF PRINCIPAL TO BENEFICIARIES PRINCIP AL BALANCE ON HAND RECEIPTS OF INCOME 2/8/01 PMl, Albefore Realty $2,565.00 2/8/01 Social Security, September 2000 $1,201.00 2/8/01 Adler Joint Venture $820.00 2/8/01 PMI, $50.00 3433 Trindle Road, Camp Hill See accounting from PMI with $57,539.38 amounts currently held in escrow by them attached as Exhibit A Balance as of March 19,2002 Balance on hand in Estate $291.56 checking account TOTAL $4,636.00 $57,830.94 -8- Above total $57,539.38 DISBURSEMENTS OF INCOME DISTRIBUTIONS OF INCOME $0.00 TO BENEFICIARIES PROPOSED DISTRIBUTIONS $0.00 TO BENEFICIARIES EXPENSES TO BE PAID UPON THE APPRO V AL OF THE ACCOUNT William L. Adler, attorneys' fees $5,290.00 owmg Robert A. Adler, $7,500.00 Executors' fees owing Trout, Ebersole and Groff, $1,150.00 accountants, for 1041 Alert Pharmacy at Bethany $1,954.69 Village Health care Bethany Village, final bill $18,427.23 Health care P A Dept of Revenue $5,918.47 1/2 of 1998 taxes due P A Dept of Revenue $3,627.16 1/2 of 1999 taxes due P A Dept of Revenue $394.03 2000 taxes due -9- Internal Revenue Service $602.13 1/2 of balance due for 1040 for 2000 income taxes due Fee for filing first and partial $155.00 account Reserve $2,500.00 Total Amounts to be Paid from $47,518.71 ($47,518 . 71 ) PMI Escrow Balance remaining for PNC Bank $10,020.67 from checking and escrow from this accounting -10- PROPOSED SCHEDULE OF PAYMENT OF EXPENSES AND DEBT IN ORDER OF PAYMENT I . Ongoing administrative expenses and fees; and those due and past due as set forth above to be paid from PMI escrow and future income; 2. Debt secured by mortgages upon sale of properties; 3. Income and Personal Taxes due: local, state, federal, as set forth above; 4. Health care expenses due as set forth above; 5. Remainder to PNC Bank from income and sales of all assets in which they hold a priority security interest. This excludes the Adler Joint Venture. 6. Proceeds from the sale of Adler Joint Venture properties to be distributed pro rata to lienholders of record based on lien priority. Income from all properties is to be released from escrow, paid to the Estate of Betty Adler until administrative expenses are paid, properties sold, and the proceeds distributed. Income from the Adler Joint Venture has not been assigned to PNC Bank. -11- Robert A. Adler and Paul 1. Killion, Executors under the Last Will and Testament of Betty J. Adler, hereby declare under oath that they have fully and faithfully discharged the duties of their office; that the foregoing First and Partial Account is true and correct and fully discloses all significant transactions occurring during the accounting period; that all known claims against the estate have been paid in full; that, to their knowledge, there are no claims now outstanding against the Estate; and that all taxes presently due from the estate have been paid. ~ /d/~..&~ Robert A. Adler Paul 1. Killion -12- Exhibits PMI ACCOUNTING, EXHIBIT "A" PROOFS OF PUBLICATION, EXHIBITS "B" DECREE NISI, EXHIBIT "C" ASSIGNMENT OF PARTNERSHIP INTERESTS, EXHIBITS "D" CERTIFICA TE OF NOTICE TO ALL INTERESTED PARTIES OF THE FILING OF THE ACCOUNT, EXHIBIT "E" U:1 U:J 02 1~:53 FAX 717 730 4140 PMI i]002 006 ~.=-.~t= 9::: ,=: CHECK FLGISTER BY VENDOR \.E:~=R .DLBST THRU 1I.DLBET J.SH :0JE THRU 1 FEE:C:; B/e] ':'HRU 03/02 As of H.GE SYSTEM DA:'E: 03/19/2002 SELECT DATE: 03/19/2002 "-4:27:17 M.lI.R, 19, 2002 ~YFE :OJES 8-COMPUTER CHECK CC - F,,:J IN"JJI:':E PO. # 3-~Nru.ru. CHECK 4-VOID CHECK INV ;).~TE CHK,DATE CHECK-## c ~ AMOUNT PAID DESCRIPTION G/L ".CCOUNT D P PER, VOUCHER-;j:i ~L:.SE:- 38TTY ,-, ADLER 1_,-_":t;~::J 9i8' 00 09/19/00 09/20/00 185342-01 640.00 DRAW ACCOlJNT- 3050 0 09/0C ::'556C7-~:ll ';15 9/8 09/19/00 09/20/00 185312-02 2,565.00 DRAW ACCOUNT- 3050 0 09/0C l55607- )2 2C- 417 9/8/00 09/19/00 09/20/00 185342-03 460.00 DRAW ACCOUNT- 3055 0 09/00 155607-03 ce. 41'0 10/6/00 10/10/00 10/11/00 186723 - 01 200.00 DRAW ACCOUNT- 3050 0 10/00 156793-01 416 1 DO :'0/10/00 ::"0/11/00 186723-02 2,565.00 DRAW .r.CCOUNT - 3050 0 10/00 156793-02 -41" 10 5/GO lO/l:J/CO 10/11/00 186723-03 400,00 DRAW ACCOUNT- 3055 0 10/ ,::) 0 156793-03 CC--tlS 11 7/00 ll/08/00 11/08/00 188571- 01 340.00 DPJl.W ACCOUN1' - 3050 0 0 11/00 158742- ::-';15 11: '7/00 ::1/08/00 :"1/0S/00 188571-02 2,565.00 DRAW ACCOUNT- 3050 0 0 1:'/00 ::"58742-02 ce-417 11/7/00 U/08/00 n/oe/oo 188571-03 1,260,00 DRAW ACCOUNT- 30S5 0 0 11/00 158742-:3 ~C--i15 12/""/00 12/0B/00 12/08/00 190647-01 240,00 DRAW ACCOTJNT- 3050 0 0 12/00 16C732-J1 CC-';:5 12 '7/00 12/108//CO 12/08/00 190647-02 2,565,00 DRAW ACCOUNT - 3050 0 0 12/00 160732-02 ::-41"i 12/7/'00 12/08/00 12/08/00 190647-03 620 00 DRAW ACCOUNT- 3055 0 0 12/00 :"60732-J] :C--115 12/00 CASH 01/16/01 01/17/01 192718-01 255,00 DRAW ACCOUNT- 3050 0 0 01/J1 2.630C7-:<. ::C - 4 : 6 L~/OO CASH 01/16/01 01/:7/01 192718-02 2,520.00 DRAW ACCOUNT- 3050 0 01/01 163007-02 ':C-417 12/ OJ CASH 01/16/01 01/17/01 192718-03 800,00 DPJl.W ACCOUNT- JOSS 0 01/01 1<03007-03 CC - 415 01/01 CASH 02/07/01 02/07/01 194048-01 220.00 DRAW ACCOUNT- 3050 '0 02/Gl 164S46- 2C-416 01 '01 CASH 02/07/01 02/07/01 194048-02 1,530.00 DRAW AceoUNT- 3050 0 02/ 01 164546-02 :C - 417 0:/01 CASH 02/07/01 02/07/01 194048-03 800.00 DRAW ACCOIDIT - 3055 0 02/ C1 164546-03 2C - -H 5 01/01 CASH 02/07/01 02/07/01 194048-01 220,00- DRAW ACCOIDJT - 3050 02, C1 164546-0::' CC - 416 01/01 CASH 02/07/01 02/07/01 194048-02 1,530.00- DRAW ACCOUNT- 3050 02; 01 164546 -02 CC-41i 01/01 CASH 02/07/01 02/07/01 194048-03 800,00- DRAW ACCOUNT- 3055 02/01 164~4", -03 CC-41S 01/01 Cl\.SH 02/07/01 02/07/01 194072 01 220 00 DRAW ACCOTJNT- 3G50 02/C1 164546- 01 CC-416 G1/01 CASH 02/07/01 02/07/01 194072 02 1,530,00 DRAW ACCOUNT- 3050 02/01 164546- ce-41"' 01'01 CASH 02/07/01 02/07/01 194072-03 800.00 DRAW ACCOUNT- 3055 02/01 164546- 03 CC-~:5 )2/0: CASH 03/09/01 03/09/01 196148-01 215,00 DRAW ACCOill~T- 3050 03/01 166360- ':C-416 )2/01 CASH 03/09/01 03/09/01 196148-02 1,530.00 DRAW ACCOUNT- 3050 03/01 166360-'02 CC - 417 02,/01 CASH 03/09/01 03/09/01 196148-03 1,700.00 DRAW ACCOUNT- 3050 03/01 166360-03 ::::-415 J4; 06 01 04/06/01 04/06/01 198222-01 260,00 DRAW ACCOUNT- 3050 04/01 168126-01 CC-41"" 04, 06; 01 04/06/01 04/06/01 198222-02 120,00 DRAW ACCOUNT- 3055 04/01 168126-n ::::-415 '04 en CASH 05/09/01 05/09/01 200070-01 150.00 DRA~1 ACCOUNT- 30:30 05/01 170347-0::' CC - -11 ~,' 04 '01 CASH 05/09/01 05/09/01 200070-02 1,000.00 DRAW ACCOUNT- 3050 05/01 170347-02 ((-US 05/01 CASH 06/08/01 06/13/01 202240-01 195,00 DRAW ACCOUNT- 3050 06/01 172242-01 CC-415 05/01 CASH 06/08/01 06/13/01 202240-02 1,890.00 DRAW ACCOUNT- 3050 06/01 172242-02 C:':-\I1 "7 05/01 CASH 06/08/01 06/13/01 202240-03 1,520.00 DRAW ACCOUNT- 3055 06/01 172242-03 CC-415 05/01 CASH 07/09/01 07/11/01 203968-01 165,00 DR.l\.W ACCOUNT- 3050 87/01 174115-0: C::-416 D6/G1 CASH /09/01 07/11/[ll 203968-02 2,655,00 DR.lI.W ACCOillJT- 3050 07/IOl 174115~02 C'~-41-: 06" 01 CASH 07/09/01 07/11/01 /.03968-03 1,200,00 DRAW ACCOUNT. 3050 0 0 07/01 174115-03 e-2-415 0'7 I 01 CASH DB 14/01 OB/15/01 206441-01 745,00 DRAW .n.CCQUNT - 3050 08/01 176406-01 '-~ 415 I) 7 ''Jl CASH 08/14/01 08/15/01 205441-02 2,745.00 DRAvl .r.CCOID~T - 3050 0 C8/01 176406- '-~ ~17 07 /01 CASH 08/14/01 08/15/01 206441-03 3,320.00 DRAW ACCOUNT- 3055 0 08/01 176406-DJ H7 08/C'1 CASH O;:J/L/01 09/12/01 208153~01 400.00 DRAW ACCOUNT- 3055 0 09/01 178150-0: H5 09/01 CASH -.i u / 09/01 10/10/01 209868-01 220.00 DRAW ACCOUNT- 3050 0 10/01 180031-0'- 41"' 09/01 w.-SH 1 C /' 0 9 / 0 1 10/10/01 209868~02 920 00 DRAt'! ACCOUNT- 305'0 0 1G/01 180031-02 'us 10/01 CASH 11/07/01 n/07/01 21162'1 - 01 265,00 DRAW ACCOUNT- 3050 0 11/0: 181803-0: ::-41--; 10 ' 0 1 CASH 11/0' /01 11/07/01 2116:n-02 700 00 DRI\W ACCOUNT- 3055 0 0 n/Ol 181803-02 ::-415 11/01 Cl-.SH 12/0""/0: 12/07/01 213722-01 260,00 DRI..W ACCOUNT- 3050 0 c 12/01 183734-01 :::-417 11/01 CASH 12/0""/01 12/07/01 213722-02 1,980,00 DRAW ACCOID1T - 3055 0 12/0::" 18373'1-02 CC-41S ::1/01 CASH 12/0""/01 12/07/01 213722-01 260.00- DRArtl ACCOUNT- 3050 0 12/0: 183734-0l ~'- 417 11/01 CASH 12/0""/0:" 12/07/01 213722 - 02 1,980,00- DRAW ACCOUNT - 3055 0 12/01 183734-02 ~C - 4lS 11/01 DIST 12/10/01 12/10/01 213742 - 01 260.00 DRAW p.CCOIDrr - 3050 0 12/01 133892-0: :;:-41' ::'1. 01 DIST 12/10/01 12/10/01 213742-02 1,980.00 DRAW ACCOUNT- 3055 0 12/0::' 183892-02 CC-415 12/01 CASH 121/1::/02 01/11/02 215757-01 280.00 DRAW ACCOUNT- 3050 0 01/02 18591::'-01 :C-41 i 12/01 CASH 01/1::'/02 01/11/02 215757-02 1,620,00 DRAW ACCOillJT- 1055 01/02 18591::..-02 CC-415 :J 1/' 02 Cl,SH 02/06/02 02/06/02 216992-01 265.00 DRAW ACCOUNT- 305(') 0 02/02 187627-01 ::: - 4 1 6 D}/02 CASH 02/06/02 02/06/02 216992-02 2,700.00 DRAW ACCOilln - 305CJ 0 02/02 187627-0;: C:--115 02 102 CASH C3/0~/02 03/08/02 219118-01 1%.00 DRAW ACCOtJNT- 3050 0 03/02 189485-0: .:': - -+:. 6 '-.l.c.." 02 CASH 03, 0~'/02 03/08/02 219118-02 6,570,00 DRAW ACCOUNT- 30se 0 03/02 189486-02 C:.: - 41 'I D2 02 CASH 0"/02 03/0B/02 219118-03 680.00 DRAW ACCOUNT- 3055 0 0 03/02 189486-03 57,010, 00 TOTAL PAID ITEMS 57,010, 00 &1NIL-:LNi. 5;;..9. 38 -- Cc.. '-{ 1-5 - Z. 4 <'lftA L. Tcr 57)539. :J? CC ~ ( b At.,l3z~ oILS ;<b4L-7'f VT YE;Jru~ ~x~ L~4 ... t ~e4 ( 7 ..- 4])LU<, 03 19 02 1~:5~ FAX 717 730 ~1~0 PMI 4J 005 006 03/02 03/02 o 09/00 CHECK REGISTER BY PROJECT ADLER JOINT VENTURE ADLER JOINT VENTURE As of MAR. 19, 2002 PF.GE ~'C.~?99: ..1'" Cur. ?er.l.od. Sel Per.l.od CAS:"'! :::OJ3 FR:,,1 ?E,,-IOD SYSTEM DATE C3/13,2JJ2 SELECT DATE' C3/19/2002 14:42-12 THRU 1 THRU 03/02 TYFE :O~~S: [-COMPUTER CHECK ~l\TtlAL CHECK 4-VOID CHECK :NVOICE # P.O. # IN'J. DATE DUE DATE CHK.DATE CHECI<-jj# PAID AMOUNT G/L ACCOUNT C.n.SH TYP PER VOUCHER #'1 ,:.r:::"S2T SETTY J ADLER 9/8/00 09/19/00 09/20/00 09/20/00 185342-03 460 00 3055 09/00 155607 -::13 1.0/6/00 10/10/00 10/11/00 10/11/00 186723 - 03 400 00 3055 0 0 10/00 156793-03 11/08/00 11/08/00 11/08/00 1885'11-03 1,260 .00 3055 0 0 ll/OO 158742-03 :'2/7/00 12/08/00 12/08/00 12/08/00 190647-03 620 .00 3055 0 0 12/00 160732-03 12/00 CASH 01/16/01 01/17/01 01/17/01 192718-03 800. 00 3055 0 0 01/01 163007-03 n.'o:. CJl.5H 02/07/01 02/07/01 02/07/01 19<1048-03 800 .00 3055 0 0 02/01 164546- 01/01 CASH 02/07/0: 02/07/01 02/07/01 19<1072-03 800. 00 3055 0 0 02/01 164546-0] 01/01 CASH 02,/C7/01 02/07/01 02/07/01 194048-03 800 00- 3055 0 4 02/01 164'046-03 J2 '01 C.r..SH 03/09/01 03/09/01 03/09/01 196148-03 1, 700 00 3050 lJ 0 03/Cl 166360-03 04/06/01 04/06/01 04/06/01 04/06/01 198222-02 120 00 3055 0 04/01 168126-J2 04/01 CASH 05/C9/01 05/09/01 05/09/01 200070-02 1,000. 00 3050 0 05/01 170347-02 05/01 CASH 06/08/01 06/08/01 06/13/01 202240-03 1,520. 00 3055 0 06/01 172242~;J] 06/01 CASH 07/09/01 07/09/01 07/11/01 203968-03 1,200. 00 3050 0 07/01 174115-;J3 :17/01 CASH 08/14/01 08/14/01 08/15/01 206441-03 3,320 .00 3055 0 08/01 176406-03 :18 01 C.~SH 09/11/01 09/11/01 09/12/01 208153-01 400. 00 3055 0 09/01 178150-0: J9 01 CASH 10/09/01 10/09/01 10/10/01 209868-02 920. 00 3055 0 10/01 180031-02 10/ 01 C.~H 11/07/01 11/07/01 11/07/01 211627 - 02 700 00 3055 0 11/01 181803-02 11 '01 CASH 1,2/07/01 12/07/01 12/07/01 213722 02 1, 980 00 3055 0 12/Jl 183731-102 11 ' 0:' C.r..SH 12/07 01 :2/07/01 12/07/01 213722-02 1,980 00- 3055 4 12/01 183734-J2 , ~ I [] 1 D18T 12/10 01 12/07/01 12/10/01 213742-02 1, 980. 00 3055 0 12,/01 183892-02 :'2, 01 CASH 01/11 02 01/11/02 01/11/02 215757-02 1,620 00 305S 0 I] 1 1/ 02 185911-02 02; 02 CASH 03/07 02 03/08/02 03/08/02 219118-03 680. 00 ]055 0 03/02 189~86-03 TOTAL VENDOR PAID ITEMS 19,500. 00 TOTAL PROJECT PAID ITEMS 19,500. 00 ~ xL, .1+ ,I 03 19 02 1~:5~ FAX 717 730 4140 PMI 4]00~ 006 ~I-- CHECK REGISTER BY PROJECT ALBEFORE REALTY ALBEFORE REALTY As of MAR. 19, 2002 FAGE SYSTEM DATE: 03/19/2002 SELECT ~ATE' C3/19/2002 14: 42 n QCA:C9 :L 415 ,Cur ?erlod: 03/02 Sel. Period: 03/02 ~~~ CODE THRU 1 FF~"'1 ?ERIODDS/OO THRU 03/02 ~Y?2 CODES O-COMPUTER CHECK UNOICE # P.O. II 12/00 CASH ClJ./Ol CASH )::'/01 CASH )ll)::. Cl,S H 02/0::' CASH OS' 01 Cll.5H 06 101 CASH J7 01 CASH 01 02 CASH J2 02 CASH 3 - t1.ZL'.J"JAL CHECK 4-VOID CHECK IN'l.DATE DUE D.ll.TE CHK.DATE CHECK-## PAID AMOUNT G/L ACCOUNT CASH TYP PER VCUCI-iEl<. - ;HI 09/19/00 09/20/0C 09/20/00 185342-02 2,565. 00 3050 0 0 09/00 155607-J2 10/10/00 10/11/00 10/11/00 186723-02 2,565 00 3050 0 0 10/00 156793-n 11/08/00 11/08/00 11/08/00 188571-02 2,565 .00 3050 0 0 11/00 158742-02 12/08/00 12/08/00 12/08/00 190647-02 2,565 .00 3050 0 0 12/00 160732-02 01/16/01 01/17/01 01/17/01 192718-02 2,520 .00 3050 0 0 01/01 163007-]2 02/07/01 02/07/01 02/07/01 194048-02 1,530 .00 3050 0 0 02/01 164546- 02/07/01 02/07/01 02/07/01 194072-02 1, 530. 00 3050 0 02/01 164546 J2 02/07 '01 02/07/01 02/07/01 194048-02 1r53O 00- 3050 0 02/01 164546 J2 03/09, 01 03/09/01 03/09/01 196148-02 1,530 00 3050 0 03/01 166360 J2 06/~'8/ 01 06/08/01 06/13/01 202240-02 1,890 00 3050 0 06/01 172242 02 07/J9/ 01 07/09/01 07/11/01 203968-02 2,655 00 3050 0 07/01 174115- 03/14 01 08/14/01 08/15/01 206441-02 2r745 00 3050 08/01 1764::16 ,J2 02/06 02 02/06/02 02/06/02 216992-02 2,700 00 3050 02/02 187627 :J2 03/D7 02 03/08/02 03/08/02 219118-02 6,570 00 3050 0]/D2 189486-02 TOTA:" VENDOR Pl<. ID ITEMS ]2, 400. 00 TOTAL PROJECT PAID ITEMS 32, 400 .00 .~LBET BETTY J .~LER 9/8/00 10/6/00 11/7/00 12/:/00 EyJ, /t" 03 19 02 14:53 FAX 717 730 4140 P'I I 4: 00:) 006 :CAP9S: CHECK REGISTER BY PROJECT ZAL REALTY 3433 TRINDLE ROAD, CAMP HILL As of MAR. 19, 2002 H.~E SYSTEH DATE: 03/19/2002 SELECT DATE: 03/19/2002 14:42:43 ..; l~, '=~J.r . Per-ioC: 03/02 Sel ?e:cioG: 03/02 ::,~SH :O:)E THRU 1 FR:'J--1 PERIOD 09/00 THRU 03/02 ~l?~ ::O~ES: O-COHPUTER CHECK W\'OICE # P.O. # 3-t'-lANUAL CHECK 4-VOID CHECK INV.DATE D~~ DATE CHK,DATE CHECK-## PAID AHOUNT G/L ACCOUNT CASH TYP PER VOIJCHER-II;: ArLBET BETTY J. ADLER 9/8/00 0~/19/00 09/20/00 09/20/00 leS.H~-Ol 540.00 ~OSO 09/00 155507-01 1:] v I 00 10/10/00 10/11/00 10/11/00 186723-01 200 00 3050 10/00 156793-0: , , '1/00 11/08/CO 11/08/00 11/08/00 188571-01 340 DC 3050 11/00 158742-0:' 1~ 7/00 12/08/00 12/08/00 12/08/00 190647-01 240 00 3050 12/00 16'0732-0:' 12 00 CASH 01/16/01 01/17/01 01/17/01 192718-01 255.00 3050 01/01 163007-0: 01;01 CASH 02/07/01 02/07/01 02/07/01 194048-01 220.00 3050 02/01 164545- J:.. Ol/Dl CASH 02/07/01 02/07/01 02/07/01 194072-01 220. OC 3050 02/01 1645<16-')':' 01 01 CASH 02/07/01 02/()7/01 02/07/01 194048-01 220. 00- 3050 0 02/01 164546-0::' J2 ' '01 CASH 03/09/01 03/09/01 03/09/01 196148-01 215 .00 3050 0 03/01 16636)-0: )4, 06/01 04/06/0:' 04/06/01 04/06/01 198222-01 260 00 3050 0 04/01 168126-0':' 04, 01 CASH 05;'09/01 05/09/01 05/09/01 200070-01 150. 00 3050 0 05/01 17,0347-0':' 05,' 0 1 CASH 06/08/01 06/08/01 06/13/01 202240-01 195. 00 3050 06/01 172242 -J.:. 06/01 CASH 07/09/01 07/09/01 07/11/01 203968-01 165 .00 3050 07/01 174115- .~ C} '7 / Dl CASH 08/14/0: OB/14/01 08/15/01 206441-01 745 00 3050 oa/Ol 176406-01 )901 CASH 10/09/01 10/09/01 10/10/01 209868-01 220. 00 3050 le/Ol 180031-0: 10/01 CASH 11/07/01 11/07/01 11/07/01 211627-01 265 00 3050 '1/01 1818B-0':' ll/Dl CASH 12/07/01 12/07/01 12/07/01 213722-01 260. 00 3050 :..2/01 183734-0: 1l/ 01 CASH 12/07/0: 12/07/01 12/07/01 213722-01 260 '00- 3050 12/01 183734-J1 11< 01 DIST 12/10/01 12/07/01 12/10/01 213742-01 260.00 3050 12/01 183892-0: 12 :n CASH 01/11/02 01/11/02 01/11/02 215757-01 280.00 3050 01/02 185911-01 )1 02 CASH 02/06/02 02/06/02 02/06/02 216992-01 265. 00 3050 82/02 187627-J~ 'J ~ Ci2 CASH 03/07/02 03/08/02 03/08/02 219118-01 195. 00 3050 03/02 1894B6-D~ TO':'AL VErmOR PAID ITEMS 5,110. 00 TO':'AL PROJECT PAID I'l'EMS 5,110. 00 .-' ,I ~)1 i' t:-..X L:\. . PROOF OF PUBLICATION OF NOTICE IN CUMBERLAND LAW JOURNAL (Under Act No. 587, approved May 16,1929), P. L.1784 ST ATE OF PENNSYL VANIA : SSe COUNTY OF CUMBERLAND : Roger M. Morgenthal, Esquire, Editor of the Cumberland Law Journal, of the County and State aforesaid, being duly sworn, according to law, deposes and says that the Cumberland Law Journal, a legal periodical published in the Borough of Carlisle in the County and State aforesaid, was established January 2, 1952, and designated by the local courts as the official legal periodical for the publication of all legal notices, and has, since January 2, 1952, been regularly issued weekly in the said County, and that the printed notice or publication attached hereto is exactly the same as was printed in the regular editions and issues of the said Cumberland Law Journal on the following dates, VIZ: APRIL 6, 13, 20, 2001 Affiant further deposes that he is authorized to verify this statement by the Cumberland Law Journal, a legal periodical of general circulation, and that he is not interested in the subject matter of the aforesaid notice or advertisement, and that all allegations in the foregoing statements as to time, place and character of publication are true. t>>Y1/L "_ RogetM. Morgenthal, Editor Adler, Betty J.t dec'd. Late of Lower Allen Township. Executors: Robert A. Adler and Paul J. Killion. 2930 Arcona Rd.. Mechanicsburg. PA 17055. Attorneys: William L. Adler. Es- quire. Adler & Adler. P.O. Box 11933. 125 Locust Street, Har- risburg, PA 17108. SWORN TO AND SUBSCRIBED before me this 20 day of APRIL. 2001 Not r. ''--'~NOTAR1Al SEAL lOll,S E, SNYDER, Notary ~PubUc Caii~a Bern, ~5 1 My Comn:'dssion Expires ......... , G:)< ~ (:; ,. "'" THE PATRIOT NEWS THE SUNDAY PATRIOT NEWS Proof of Publication Under Act No. 587, Approved May 16, 1929 Commonwealth of Pennsylvania, County of Dauphin} ss Michael Morrow being duly sworn according to law, deposes and says: That he is the Asst. Controller of The Patriot News Co., a corporation organized and existing under the laws of the Commonwealth of Pennsylvania, with its principal office and place of business at 812 to 818 Market Street, in the City of Harrisburg, County of Dauphin, State of Pennsylvania, owner and publisher of The Patriot-News and The Sunday Patriot-News newspapers of general circulation, printed and published at 812 to 818 Market Street, in the City, County and State aforesaid; that The Patriot-News and The Sunday Patriot-News were established March 4th, 1854, and September 18th, 1949, respectively, and all have been continuously published ever since; That the printed notice or publication which is securely attached hereto is exactly as printed and published in their regular daily and!or Sunday! Metro editions which appeared on the 4th, 11 th and 18th day(s) of April 2001. That neither he nor said Company is interested in the subject matter of said printed notice or advertising, and that all of the allegations of this statement as to the time, place and character of publication are true; and That he has personal knowledge of the facts aforesaid and is duly authorized and empowered to verify this statement on behalf of The Patriot-News Co. aforesaid by virtue and pursuant to a resolution unanimously passed and adopted severally by the stockholders and board of directors of the said Company and subsequently duly recorded in the office for the Recording of Deeds in and for said County of Dau hin in Miscellaneous Book "M", Volume 14, Page 317. NOTICE LETTERS Testamentary FOR the Estate of e.tty J. Adler. deceased, late of Lower Al- Ien Township. Cumberlancl County, Pennsyl- vania, having been granted to the under- signed, all persons Inclebted to the Estate ore requested to make immediate paYment and those having claims aoolnst ttte Estate ore requested to present them for settlement with- out deloy to: Robert A. Adler and PaUl J. Killion 2930 Arcona Rd. Mecttaftlcsbuf'9, PA 17055 or to: William L. Adler, ESlllulre ADLER & ADLER P.O. Box 11933 125l-ocust Street HClrl'fguf'9, PA 171. Sworn to an s Notarial Seal Terry l. Russell, Notary Public Harrisburg. Dauphin County My Commission Expires June 6. 2002 Member, Pennsylvania Association 01 Notaries /~ PUBLICA TION COpy My commission expires June 6, 2002 ADLER & CLARAVAL, ATTORNEY 125 LOCUST STREET P.O. BOX 11933 HARRISBURG, PA. 17108 Statement of Advertising Costs To THE PATRIOT-NEWS CO., Dr. For publishing the notice or publication attached hereto on the above stated dates $ Probating same Notary Fee(s) $ Total $ 209.76 1.50 211.26 Publisher's Receipt for Advertising Cost The Patriot News Co., publisher of The Patriot-News and The Sunday Patriot-News, newspapers of general circulation, hereby acknowledge receipt of the aforesaid notice and publication costs and certifies that the same have been duly paid. By.................................................................... { t::> ~XlA IN RE : ESTATE BETTY J. ADLER IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA ORPHANS' COURT DIVISION NO. 21-01-149 AND NOW, 2002, proper notice having been given of the filing of the First and Partial Account in the above-captioned matter and of the call thereof for audit and no objections having been filed, the Account is hereby confirmed and distribution decreed in accordance with the proposed Schedule of Distribution. This is a nisi order which shall become absolute as of course unless written exceptions are filed within ten (10) days after the date of the filing hereof. J. Certified from the record as Absolute Clerk of the Orphans' Court Division F J.: fr. C- ~cnb\adler\assign&.tra . March 28, 1991 Assignor: Stanley D. Adler, Jr. and Betty J. Adler Partnership: Front street Equity Associates ASSIGNMENT AND TRANSFER For value received, the Undersigned (the "Assignor"), hereby assigns and transfers to CCNB Bank, N.A., its successors and assigns (the "Assignee"), all of the Assignor's individual interest in the partnership of: Front street Equity Associates Upon the execution of this assignment, the Assignee shall have the immediate right to receive from the partnership that share of partnership distributions which the Assignor would otherwise be entitled to receive. Provided, however, that so long as Assignor shall make such payments upon his obligations to Assignee in the amounts required to maintain such obligations on a "current status", Assignor may continue to receive all partnership distributions herewith assigned. Upon a default in any obligation of Assignor to Assignee, Assignee shall give Assignor ninety (90) days written notice to cure the default. Upon Assignor's failure to cure the default within said ninety (90) days, all partnership distributions shall be paid to Assignee until the Assignor's debt obligation to Assignee shall be maintained on a current status for ninety (90) 1 r:= .:, 1.\ V ,,""-'-" ,,,,.... ..........". Ib\adler\assign&.tra --..,arch 28, 1991 --' days at which time the partnership distributions may be paid to Assignor. This assignment is for the sole purpose of providing collateral for Assignor's obligations to Assignee, including but not limited to those set forth in a document captioned Surety Agreement and Cross Collateralization and Cross Default Agreement. Assignee shall not be deemed for any purpose to be a partner of the aforementioned Partnership by reason of this Assignment but shall remain at all times merely a secured creditor. Assignor shall continue as a partner of the said partnership and be responsible for all duties thereby imposed upon him. Powers of assignee. For purposes of effecting execution of this assignment, the Assignor hereby irrevocably appoints the Assignee his attorney in fact, with power of substitution and revocation, with complete authority to demand of and receive from any person all property, debts, and demands belonging and owing to the Assignor as partner or as an individual, and to give acquittances and discharges therefor; to sue for, prosecute, defend, and interplead on account of all such property, debts, and demands; to sign or endorse the name of the Assignor or the partnership upon any check, draft, note, or other instrument for the payment of money, and upon any instrument necessary to effectuate the purposes of this assignment; and to execute, acknowledge, and deliver all deeds, instruments of conveyance, receipts, and releases necessary or proper. A copy of this Assignment shall be sufficient evidence of Assignee's power of attorney. 2 tX"'_V ......' ,.... -. --- .....,........... . .-a'. ~,,- 1.-t' __:cnb\adler\assign&.tra ., t1arch 29, 1991 ~ Construction. When the context so requires: (i) the singular shall include the plural and conversely; and (ii) use of any gender shall include all genders. INTENDING tO~~legallY b~(~he Assignor has executed this Assignment this /" day of T1~.... , 1991. (Seal) Betty J. WITNESS: ~ d(c'ti]( C'\llLtri AC0 .\9 .. PClL/ Assignee: ~/~!r' p / /,';' /Z --~ ./., ,vJ - (Seal) 3 kJ< l~ 0 ,,~,. 0..; . ii = ;j I ~ ,. '!! I I ,. I I Ii It \\ Ii Assignor: Stanley D. Adler.. Jr., and Betty J. Adler Partnership: ~before Realty ASSIGNMENT AND TRANSFER For value received, the Undersigned (the "Assignor"), hereby assigns and transfers to CCNB Bank, N.A., its successors and assigns (the "Assignee"), all of the Assignor IS individual interest in the partnership of: Albefore Realty Upon the execution of this assignment, the Assignee shall have the immediate right to receive from the partnership that share of partnership distributions which the Assignor would otherwise be entitled to receive. Provided, however, that so long as Assignor shall make such payments upon his obligations to Assignee in the amounts required to maintain such obligations on a "current status", Assignor may continue to receive all partnership distributions herewith assigned. Upon a default in any obligation of Assignor to Assignee, Assignee shall give Assignor ninety (90) days written notice to cure the default. Upon Assignor t s failure to cure the default within said ninety (90) days, all partnership distributions shall be paid to Assignee until the Assignor I s debt obligation to Assignee shall be maintained on a current status for ninety (90) 1. c\ ~-'-,,~ lr-- u..) .J............~tl~-_...._~ -' :# days at which time the partnership distributions may be paid to -;7 Assignor. This assignment is for the sole purpose of providing collateral far Assignor's obligations to Assigneer including but not limited to those set forth in a document captioned Surety Agreement and Cross Collateralization and Cross Default Agreement. Assignee shall not be deemed for any purpose to be a partner of the aforementioned Partnership by reason of this Assignment but shall remain at all times merely a secured credi tor. Assignor shall continue as a partner of the said partnership and be responsible for all duties thereby imposed upon him. Powers of assignee. For purposes of effecting execution of this assignmentr the Assignor hereby irrevocably appoints the Assignee his attorney in factr with power of substitution and revocation, with complete authority to demand of and receive from any person all property, debts, and demands belonging and owing to the Assignor as partner or as an individual, and to give acquittances and discharges therefor; to sue fort prosecute, defendr and interplead on account of all such property, debts, and demands; to sign or endorse the name of the Assignor or the partnership upon any check, draft, note, or other instrument for the payment of money, and upon any instrument necessary to effectuate the purposes of this assignment; and to execute, acknowledge, and deliver all deeds, instruments of conveyance/ receipts, and releases necessary or proper. A copy of this Assignment shall be sufficient evidence of Assignee's power of attorney. 2 f>~ \) ~.-L:.......-L.""""" Construction_ When the context so requires: (i) the singular shall include the plural and conversely; and (ii) use of any gender shall include all genders. INTENDING to be legally bou~Q, the Assignor has executed this Assignment this ~1 day of ~ ' 199L Assi L (Seal) f"-- '~----LL ,/1 ~' 'l: //~-;/: t~;/ ~f~ :.,.~/0z:.-U- ::.-' (Seal) Betty J .~dter WITNESS: ~Cl,\O--:K c:-!{A.u j.UC J....) Assignee: ~$' 1// (~ /i..p./. J,-v I (Seal) 3 \. :\0.. lr-. D jal.doc.ccnb.asgn.pld 1.2?91 Assiqnment and Transfer For value received, ...F77IIVt.-F1(]J, 4p,-q.~'f1e "Assignor"), hereby assigns and transfers to its successors and assigns (the "Assignee"), all of the Assignor's individual interest in the partnership of Zit '- REAL.--,-tj Upon the execution of this assignment, the Assignee shall have the right to receive from the partnership the share of profits or other compensation to which the Assignor would otherwise be entitled, and all other rights and privileges which Assignor had in the partnership. Provided, however, that so long as Assignor shall make such payments upon his debt obligations to Assignee in the amounts required to maintain such debt obligations on a "current status", Assignor may continue to receive all distributions of profits and other compensation which Assignor was entitled to receive prior to this Assignment. Upon a default in payment upon any debt obligation, Assignee shall give Assignor ninety (90) days written notice to bring the account current. Upon Assignor's failure to make the required payment or payments within said ninety (90) days, all distributions of profits and other compensation shall be paid to Assignee until the Assignor's debt obligation to Assignee shall be maintained on a current status for ninety (90) days at which time the distributions of profits and other compensation may be again paid to Assignor. -1- :" It-, D '" jal.doc.ccnb.a:;gn.pld 1 _,25 . 91 TIlis ~ssignmcnt is for the solo purpose of providing collntoral for debt obligations of Assignor to Assignee. Assignee shall not be deemed for any purpose a partner of the aforementioned Partnership by reason of this Assignment. Assignor shall remain a partner of the said partnership and be responsible for all duties thereby imposed upon him. Powers of assignee. For the most effectual execution of this assignment, the Assignor hereby irrevocably appoints the Assignee his attorney in fact, with power of substitution and revocation, and with complete authority to do anything necessary for the full execution of this assignment; to demand of and receive from any person all property, debts, and demands belonging and owing to the Assignor as partner or as an individual, and to give acquittances and discharges therefor; to sue for, prosecute, defend, and interplead on account of all such property, debts, and demands; to sign or endorse the name of the Assignor or the partnership upon any check, draft, note,: or other instrument for the payment of money, and upon any instrument necessary to effectuate the purposes of this assignment; and to execute, acknowledge, and deliver all deeds, instruments of conveyance, receipts, and releases necessary or proper. A copy of this Assignment shall be sufficient evidence of Assignee's power of attorney. Assignor acknowledges that: the Assignee hereby accepts the assignment on the following condition: that Assignee shall only be liable to Assignor for breach of a fiduciary responsibility and -2- f:;x lA {) ~~""I..!.I'.~,.-'~..... ~ jol.doc.ccnb.asgn.pld 1.,5.91 shall not be liable to Assignee for any action based upon the exercise of a business decision. this IN WITNESS WHEREOF, the Assignor has executed this Assignment frH day of I11l1.ri:~ 1991. ~--NOT~RIALSEAL LORPAINE ANN BOBB. No1ary Public Harri&bUrg, Dau..hIn ~n:Y Wf,T. NESS,: , " N'.,'J, ~ml6Sion Expires June':SJDt992 a ,t{ It ~ C:CC " ,l ^'--~ Assig~QF: f r . I ~ ----l /' (I /.f / /./ V ' /\ j ~,'if. C,-{.. ) 1{'.Y..(("1~' (Seal) -- 11,/ ( subscribed to:me fhis78th day of March, 1991. , ! ;/'I{I Ie! /11 ( r?;1.,!~/) 16/~i / Ass ignee: Nota ry Pub 1 i c (Seal) -]- ,lr D I hereby certity that written notice of the filing of this Account, and of the date, time and place when the same will be presented to the Court for conformation and of the last day to file the written objections to said Account, has been given to every unpaid claimant and to every other person known to the accountant to have or claim an interest in the estate as creditor, beneficiary, heir or next of kin. I Ii . ) /Llt//) 'L v 't ;IJ ~}cu./( /; f 'gil' JC/i~ '. . f/Vv' William L. Adler, Esq. March 21, 2002 ,".^ \^ ~ .- ADLER & ADLER ATTORNEYS AT LAW 125 LOCUST STREET P.O. BOX 11933 HARRISBURG, PENNSYLVANIA 17108-1933 TELEPHONE (717) 234-3289 FAX (717) 234-1670 WILLI:\.\:l L. ADLER CRAIG 1. ADLER * . ..\LSO AD\!ITTED TO PRACTICE IN 0<1 OVERNIGHT MAIL ADDRESS: LEWIS F. ADLER (1934-1984 ) DAVID S KOH"\" (1934-1985) LOUIs:r.- ADLER (1959-1999) 125 LOCUST STREET HARRISBURG, PENNSYLVANIA 17101 KOHN AND ADLER ( 1934-1960) KOHJ\, ADI ,ER & ADLER (1960-1981 ) April 15, 2002 Cumberland County Courthouse Register of Wills 1 Courthouse Square Carlisle, PA 17013 RE: Estate of Betty Adler Date of Death: October 2, 2000 Dear Register of Wills: Enclosed please find original signature pages for the First and Partial Account for the above estate to be attached to the First and Partial Account of Betty Adler. These are the signatures of the coexecutor who was out of town when the account had to be filed. Thank you. Very truly you;-s, -i!~ IUlte-(. William L. Adler WLA Enclosure Robert A Adler and Paul 1. Killion) Executors under the Last WiII and Testament of Betty 1. Adler, hereby declare under oath that they have fuIIy and faithfully discharged the duties of their office; that the foregoing First and Partial Account is true and correct and fully discloses all significant transactions occurring during the accounting period; that all known claims against the estate have been paid in fuII; that, to their knowledge, there are no claims now outstanding against the Estate; and that all taxes presently due from the estate have been paid. Robert A. Adler L~q4$~ Paul 1. KiIIion / -12- Page 6 Your petitioner, therefore, asks that distribution be awarded to the persons thereunto entitled~ as their rl;spective interests may appear. :< COMMONWEALTH OF PENNSYL V AN1A COUNTY OF f):-t.L\..,? ~\ v""- : S5.: The above named petitioner, being duly 5\VOrn, does depose and say that the facts set (or~h in the foregoing petition which are within the pen;onal knowledge of the petitioner are true, :lnd as to facts based on the infonnalion of others, the petitioner, after diligent inquiry, believes rhe!n to be tnle. Sworn to and subsc{ibed before me thls ____:L~~~____ day of \"y\(:,'1-<' \.--.-. H -.4 ~ '4- \ ' ------ - \ '. ~ .~y ~\ -/'~ ~~\.c.~r~ rl t \ \ N o.,\-c'- C'-" \( l,_.J~~\ \ ~_ (Signat I DCllr\ uc hJllllS. .\JJlIJ.:n.fnn:\lcSll1lc.tr4(Rcv: 11193)J ._-"' ..~- NOTARIAL SEAL JODY GOLDRING, Notary Public Harrisburg, Dauphin County, PA My Commission Expires Nov. 03. 2005 ....__.~~.............~_.._-_._- :. "'~~~~ '. '. ,-.:. ,., , .. .....'" , "" .,. ~. ... , "I: ~~,,' .", --, ..,- - - '1 r --, -,- II .).... ~ a') ~ cO o ~ r- ~ ~3t; ~ ~ 3~~~ O~tn:::.~ '< ~tn~z 06~8g.~ -"' ~ 0 0. c.. ~ 0 ,..J eM \3 ~t::'A ~ l-"'\ ~ ~ ';) o ~ '< C2 ~ n. u C' -:S ~ o ~ r..) ~ (<'l ~ 6-6 S~iflr-- O~ ~.- U~rfj4.. --d~6p.. ~ 0 .p nS -~~'"@ 'o)~6~ '% ''bnr..) ~ ';j~.-U r..)~ N r.:~ ('.\ (i \') i',1 ,;.- 1'.',\ ...~ \51 t'.. "'""' c , INRE: IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA ESTATE OF BETTY J. ADLER, DECEASED : ORPHANS' COURT DIVISION : ESTATE NO. 21-01-149 PNC BANK, NATIONAL ASSOCIATION'S OBJECTIONS TO THE FIRST AND PARTIAL ACCOUNT OF ROBERT A. ADLER AND PAUL J. KILLION, EXECUTORS FOR THE ESTATE OF BETTY J. ADLER AND NOW COMES, PNC Bank, National Association, ("Objector") by and through its undersigned attorneys, and asserts the following Objections to the First and Partial Account of Robert A. Adler and Paul J. Killion, Executors for the Estate of Betty 1. Adler (collectively "Executors"): 1. a. Objector holds perfected security interests evidenced by a certain Surety Agreement and Cross Collateralization and Cross Default Agreement dated April 3, 1991 signed by Decedent and Decedent's wife, Betty J. Adler (the "Surety and Cross Collateralization Agreement") and evidenced by UCC Financing Statements properly filed of record in, inter alia, all of the Partnerships and Corporations (the "Partnerships and Corporations") in which Decedent held an ownership interest. Objector's perfected, priority security interest is acknowledged by the Executors' for the Estate in their Proposed Schedule of Payment of Expenses and Debt in Order of Payment (the "Proposed Schedule of Payment") under item number 5. Objectors priority security interest includes, without limitation, the Estate's interest in any and all income distributions and , any proceeds of dissolution of the Partnerships and Corporations (collectively "Objector's Collateral"), and excepting only the periodic income distributions from Adler Joint Venture (the Estate's interest in the underlying assets of Adler Joint Venture are subject to Objector's mortgages of record as more particularly described below). b. Contrary to Executors' assertion at item 5 of the Proposed Schedule of Payment at page 17 that Adler Joint Venture is excluded from the assets in which Objector holds priority security interests, Objector holds mortgages of record against all interests of Decedent and her husband, Stanley D. Adler, Jr., (also deceased) in the following properties, which are believed to constitute all of the assets of Adler Joint Venture: 1. 4005 Jonestown Road, Harrisburg, Dauphin County, P A 11. 315 Market Street, Harrisburg, Dauphin County, P A 111. 3401 Walnut Street, Harrisburg, Dauphin County, PA IV. 1800 Columbia Avenue, Lancaster, Lancaster County, P A c. Objector's acknowledged, perfected, priority security interest secures to Objector payment of, inter alia, the amounts due to Objector under the following Judgments entered against Decedent and/or Decedent's husband, Stanley D. Adler, Jr., (also deceased) during their respective lifetimes on certain corresponding demand Notes: 1. Judgment entered on September 11, 1991, before the Cumberland County Court of Common Pleas to docket number 3124 Civil 1991, in the original principal amount of One Million Nine Hundred Forty-Nine Thousand Nine Hundred Seventy-Seven and 34/100 Dollars ($1,949,977.34) which judgment was properly revived by Writ of Revival filed January 29, 1998 before the Cumberland County Court of Common Pleas ("Judgment A"). 11. Judgment entered on May 21, 1998, in the original principal amount of Three Hundred Ninety Thousand Thirty-Five and 82/1 00 Dollars ($390,035.82) before the Cumberland County Court of Common Pleas to docket number 98-2854 ("Judgment B"). 111. Judgment entered on May 21, 1998, in the original principal amount of Nine Hundred Ninety-One Thousand Five Hundred Fifty-Five and 551100 Dollars ($991,555.55) before the Cumberland County Court of Common Pleas to docket number 98- 2853 ("Judgment C"). Judgment A, Judgment B and Judgment C are collectively referred to herein as the "J udgments". d. Executor's Proposed Schedule of Payment at page 11 of the Account would improperly impair Objector's liens to the extent that ongoing administration expenses and fees, health care debts or federal income taxes are proposed to be paid out of any of the collateral subject to Objector's perfected security interests. Only the $25,060.00 in the PMI escrow account that is shown in the Account as rental income received from Adler Joint Venture (and interest thereon) may properly be applied toward payments in order of priority under PEF Code S 3392. The order of priorities set forth under PEF Code S 3392 does not control where, as here, its application would impair Objector's validly perfected lien which existed at the date of death (PEF S 3381). e. For the above reasons, Objector is entitled to receIve payment, prior to the payment of any and all other expenses of the Estate or Creditors of the Estate including, without limitation, any and all administration expenses, the family exemption, health care debts and federal income taxes set forth in the Proposed Schedule of Payment, of all disbursements by the Estate for fees, commissions and expenses of administration - from any source other than the periodic rental income received from Adler Joint Venture and the $6,000 income distribution from Garstan Associates, as shown in the Account, to which Objector gave its consent by prior agreement. f. For the above reasons, Objector objects to any payments made or to be made out of Objector's Collateral proposed by Executors' ahead of Objectors secured claim as improperly impairing Objector's liens, contrary to PEF Code S 3381. 2. The Executors acknowledge that the Estate's interests in the Partnerships and Corporations are subject to Objector's perfected security interest; nevertheless, Executors propose to pay ongoing administrative expenses and fees, health care debts and federal income taxes out of Objector's Collateral. These proposed payments from Objector's collateral would violate the protection of pre-existing liens required by PEF Code S 3381. 3. According to the Account, $57,830.94 is being held in escrow by PMI (which is not further identified), and the account of PMI, attached to the Executors' Account as Exhibit "A," indicates that of the foregoing total, $25,060.00 represent rental income from Adler Joint Venture, and this flow of income is not encumbered by Objector's lien. However, the remaining principal balance in the PMI escrow account of $32,241.56, is subject to Objector's lien, and must not be applied to payment of administration expenses or debts of the Decedent, which would constitute impairment of Objector's lien, contrary to PEF Code S 3381. 4. Attorney's fees of $27,010.63 are excessive, unreasonable and out of proportion to the value of the services provided to the Estate. The attorney was aware of the estate's deep insolvency, and it should have been clear that such legal expenses would far exceed any unencumbered funds that would be available to the estate from which to make payment. 5. Objector objects to the proposed payment of federal income taxes ahead of Objector's acknowledged, perfected security interest. Specifically, as the holder of security interests under 26 D.S.C. 9 6323, Objector's liens must not be impaired by payment of federal income taxes, except as to any tax lien that may have been recorded prior to the perfection of Objector's security interests (no federal tax liens are believed to have been recorded prior to any of Objector' s liens). 6. Executors' commissions, claimed in the Account as "owing" and proposed to be paid, of $7,500.00 are excessive, unreasonable and out of proportion to the value of the services provided to the estate. (a) Executors were aware of the estate's deep insolvency, and it should have been clear that such management fees would far exceed any unencumbered funds that would be available to the estate from which to make payment. (b) In addition to executors' commISSIOns claimed in the Account, the Executors claim additional commissions of $23,055.00 (to date) for . . administration in the Estate of Stanley D. Adler, Jr. of many of the same business interests, which Betty J. Adler held jointly with Stanley D. Adler, Jr. 7. Attorney's fees of $3,459.63, paid, and an additional $5,290.00, claimed, are excessive, unreasonable and out of proportion to the value of the services provided to the estate, where the attorney was aware of the estate's deep insolvency, and should have known such legal expenses would far exceed any unencumbered funds that would be available to the estate from which to make payment. 8. Executors have failed to inventory or declare as assets of the estate any household furnishings, vehicles or personal belongs whatsoever of Decedent; the value of such items should be included it the Account. WHEREFORE, Objector, PNC Bank, National Association, prays this Court grant the following relief: a. Deny the requested confirmation of the First and Partial Account; b. Order the Executors, Robert A. Adler and Paul J. Killion, to file a First and Partial Account providing for the payment to Objector, to the extent of its claim, of all amounts received and to be received by the Estate from the Partnerships prior to the payment of any and all other expenses, fees, commissions and Creditors of the Estate. c. Order Executors to pay to Objector, to the extent of Objector's claim, any and all amounts received from the Partnerships In connection with Decedent's ownership interest in those entities In which Objector possesses a perfected security interest. . . Date: d. Surcharge the Executors, Robert A. Adler and Paul J. Killion, for any and all disbursements for administration expenses, health care debts, legal fees and Executors' fees which have been and which may hereafter be paid by the Executors out of Objector's Collateral. e. Order the Executors to account for the household furnishings, vehicles and other personal effects owned by Decedent at the time of her death. f. Determine and reduce to a reasonable amount Executors' fees and legal fees claimed by Executors. Respectfully submitted, Lf -" '2.-:7 -- Cl ? ./....L,~ ~_../ (_.-' SAIDIS, SHUFF, FLOWER & LINDSAY /..' /~... 7 .' /;) ..()~J2 / / // j/ Ij /~j// 1 . ~j t / . ,,' /"/" .----~.. By: arl M. Ledebohm, Esquire Supreme Court ID #59012 2109 Market Street Camp Hill, PA 17011 (717) 737-3405 Attorney for PN C Bank, National Association ESTATE OF BETTY J. ADLER, DECEASED IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYL VANIA INRE: : ORPHANS' COURT DIVISION : ESTATE NO. 21-01-149 VERIFICATION I, Eric D. Krimmel, Vice President of PNC Bank, National Association being authorized to do so on behalf of PNC Bank, National Association, hereby verify that the statements made in the foregoing pleading are true and correct to the best of my information, knowledge and belief. I understand that false statements herein are made subject to the penalties of 18 Pa. C.S. Section 4904, relating to unsworn falsification to authorities. PNC BANK, NATIONAL ASSOCIATION Date: Lf (2.1 fol.. By: (~~ L~ Eric D. Krimmel, VIce Presl ent . n~RE: IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYL VANIA EST A IE OF BETTY 1. ADLER, DECEASED : ORPHANS' COURT DIVISION : ESTATE NO. 21-01-149 CERTIFICATE OF SERVICE AND NOW, this 22nd day of April, 2002, I, Karl M. Ledebohm, Esquire, of the firm of Saidis, Shuff, Flower and Lindsay, hereby certify that I this day served a true and correct copy of PNC Bank, National Association's Objections to the First and Partial Account of Robert A. Adler and Paul J. Killion, Executors' for the Estate of Betty 1. Adler upon the parties listed below by delivering copies to the following office: William Adler, Esquire ADLER & ADLER P.O. Box 11933 125 Locust Street Harrisburg, P A 17108-1933 Respectfully submitted, SAlOIS,S".. ~F. 'FL.OWE~~D.SAY (" f- f) ( / By: 1.--..-'/.1 1 f (.l r I / ).; L--.. /Karl M: Ledebohm, Esquire / Supreme Court ID #59012 2109 Market Street Camp Hill, P A 17011 (717) 737-3405 Attorney for Petitioner IN RE: ESTATE OF BETTY 1. ADLER, DECEASED IN THE COURT OF COMMON PLEAS ORPHANS' COURT DIVISION CUMBERLAND COUNTY, PENNSYLVANIA NO. 21-2001-149 CITATION WE COMMAND, you that laying aside all business and excuses whatsoever, you be and appear in your proper person before the Honorable Judges of the Court of Common Pleas, Orphans' Court Division at a session of the said Court there to be held, for the County of Cumberland to show cause why the Petitioner is not entitled to the relief requested; 2. The Respondent shall file and serve upon Petitioner clo the law firm of Saidis, Shuff, Flower & Lindsay an answer to the Petition within 20 days of the service of this Order upon Respondent; 3. Notice of the entry of this Order shall be provided to all parties bv the Petitioner. Witness my hand an official seal of office at Carlisle, Pennsylvania, this 2nd day of May, 2002. " \ j. \ I r'-_',~ \ \ ;:'.' V i A/ J <i---i " J ./ , /\-/'...,.~ \~ \../V...~v l CI~k, 0 hans' Court Division Cumberland County, Carlisle, P A My Commission Expires on the 1st Monday January, 2006 ":, ' <' .'. ;, /' . D i !: rl~A'U)l1.~ / l'./J1- "/- /,f ~ ,/1 :.~ \tX'\"~ ~ ,,) t( APR 2 6 n)Or3 INRE: IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA ESTATE OF BETTY J. ADLER, DECEASED ORPHANS' COURT DIVISION ESTATE NO. 21-01-149 I~O AND NOW, this _ day of , 2002 upon consideration of the Petition ofPNC Bank, National Association it is 1. A citation is issued upon the Respondents, Robert A. Adler and Paul J. Killion, Executors for the Estate of Betty J. Adler, deceased to show cause why the Petitioner is not entitled to the relief requested; 2. The Respondent shall file and serve upon Petitioner c/o the law firm of Saidis, Shuff, Flower & Lindsay an answer to the Petition within U days of the service of this Order upon Respondent; 3. Notice of the entry of this Order shall be provided to all parties by the Petitioner. ....; 1 ... INRE: IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA , ESTATE OF BETTY J. ADLER, DECEASED ORPHANS' COURT DIVISION ESTATE NO. 21-01-149 PNC BANK, NATIONAL ASSOCIATION'S PETITION FOR RULE TO SHOW CAUSE WHY EXECUTION SHOULD NOT ISSUE ON JUDGMENTS ENTERED AGAINST, INTER ALIA, BETTY J. ADLER, DECEASED AND ATTACHMENT BE MADE UPON ANY AND ALL OWNERSHIP INTEREST OF DECEDENT, BETTY J. ADLER, IN CERTAIN PARTNERSHIPS SUBJECT TO BANK'S PRIORITY PERFECTED SECURITY INTEREST PURSUANT TO 20 P.S. SECTION 3377(A)(2) AND NOW COMES, PNC Bank, National Association ("Bank") through its attorneys, Saidis, Shuff, Flower and Lindsay, and files its Petition for rule to show cause why execution should not issue and attachment be made upon Decedent's, Betty J. Adler's, ownership interest in certain partnerships subject to Bank's priority perfected security interest pursuant to 20 P.S. 3377(a)(2) and sets forth in support thereof as follows: 1. At the time of the Decedent's death, Decedent was obligated to Bank under, inter alia, a Demand Note dated November 28, 1990, in the original principal amount of One Million Seven Hundred Six Thousand Three Hundred Thirty-Seven and 52/100 Dollars ($1,706,337.52) (the "Note"). The Note is attached hereto as Exhibits "A" and made part hereof. 2. On or about April 3, 1991, Betty J. Adler (the "Decedent") and Stanley D. Adler, Jr. (also deceased) husband and wife, executed and delivered to Bank a Surety Agreement and Cross-Collateralization and Cross-Default Agreement (the "Surety and Cross-Collateralization Agreement"). A copy of the Surety and Cross-Collateralization Agreement is attached hereto as Exhibit "B" and made part hereof. 3. By signing the Surety and Cross-Collateralization Agreement, Decedent and her husband guaranteed payment to Bank of all amounts due to Bank under, inter alia, the Note and 1 granted to Bank, among other things, a security interest in, inter alia, any and all interest which , the Decedent and/or her husband had in the various partnerships (the "Partnerships") and corporations (the "Corporations") listed on Exhibit "A" attached to the Surety and Cross- Collateralization Agreement and made part thereof as well as any and all, ". . . collateral presently deposited with the Bank and collateral deposited simultaneously with the execution of this Guaranty, and all other property of Debtor of like kinds or types previously, presently, or in the future deposited with the Bank, and the proceeds of the collateral, (hereinafter collectively referred to as "Collateral")." 4. Contemporaneous to Decedent and Decedent's husband's execution of the Surety and Cross-Collateralization Agreement, Decedent and/or Decedent's husband also executed and delivered to Bank individual Assignments for, inter alia, the following partnerships: a. Adler Partnership. b. Adler, Scalera and Adler. c. American Sentinel Realty Associates. d. Albefore Realty. e. Equico Realty Group. f. Franklin Carroll Associates. g. Front Street Equity Associates. h. Garstan Associates. 1. Zal Realty. A representative copy of one of the above-referenced Assignments is attached hereto as Exhibit "c" and made part hereof by reference. The remaining assignments are in Bank's possession and available for inspection. 5. Bank perfected its security interest in the Partnerships under the Surety and Cross- Collateralization Agreement, by inter alia, filing financing statements in the Offices of the Secretary of the Commonwealth on April 22, 1991, and the Prothonotary for Dauphin County on 2 April 18, 1991 and by filing continuation statements in the Office of the Prothonotary on April 6, t 1996, and on March 15,2001, and in the Office of the Secretary of the Commonwealth on April 11, 1996, and on March 15, 2001. Copies of the DCC Financing Statements filed in the Dauphin County Prothonotary's Office are attached hereto as Exhibit "D" and made part hereof. 6. Robert A. Adler and Paul J. Killion, executors for the Estate in their First and Partial Account (the "First and Partial Account") acknowledge the Bank's priority security interest in Decedent's interest in the Corporations and the Partnerships under the Surety and Cross Collateral Agreement. 7. Bank entered Judgment on the Note on September 11, 1991, before the Cumberland County Court of Common Pleas to docket number 3124 Civil 1991, in the original principal amount of One Million Nine Hundred Forty-Nine Thousand Nine Hundred Seventy- Seven and 34/1 00 Dollars ($1,949,977.34) which judgment was properly revived by Writ of Revival filed January 29, 1998 before the Cumberland County Court of Common Pleas (the "Judgment"). 8. Pursuant to the First and Partial Account the Estate is insolvent. 9. The Executors propose in the First and Partial Account to, inter alia, improperly pay ongoing administrative expenses, the family exemption, health care expenses for Decedent and federal income taxes out of Bank's Collateral ahead of the amounts due to Bank under its priority perfected security interest in direct violation of 20 P.S. Section 3381 which specifically provides: "Nothing in this Code shall be construed as impairing any lien or charge on real or personal estate of the Decedent which existed at his death." 20 P.S. Section 3381. 10. Bank has filed contemporaneously herewith, Bank's objections to the Executors' First and Partial Account, a copy of which is attached hereto as Exhibit "E" and made part hereof. 11. But for Decedents death and 20 P.S. Section 3377(a), Bank would be permitted to immediately issue execution on the Judgment and attach and immediately receive from the 3 Partnerships any and all distributions to which Decedent would have been entitled as an equity owner of the Partnerships (collectively referred to herein as the "Bank's Collateral"). 12. To the extent of the amounts due to Bank under the Judgment and Bank's admitted priority security interest, distributions made or to be made by the Partnerships do not benefit the Estate since Bank is entitled to receive such distributions ahead of any of the payees set forth in 20 P.S. Section 3392 including, without limitation, ongoing administrative expenses of the estate incurred as a result of accounting for distributions from the Partnerships which is Bank's Collateral. 13. The continued distribution to the Estate of amounts by the Partnerships subject to Bank's security interest only serves to unnecessarily burden the Executors of the Estate who act merely as a conduit to distribute such funds to Bank under Bank's perfected security interest. 14. Bank believes and therefore avers that any administrative expenses incurred or claimed by the Executors for the Estate in connection with distributions from the Partnerships will be avoided by allowing Bank to issue execution on the Judgment against the Partnerships and to attach and receive directly from the Partnerships any and all such distributions on account of Decedent's ownership interest in the Partnerships to the extent of the amounts due to Bank under the Judgment and Bank will not require the Executors' assistance in collecting such distributions. 15. The distributions to the Estate by the Partnerships do not constitute property of the Estate and do not benefit the Estate in any way. 16. The continued distribution of amounts subject to Bank's security interest to the Estate by the Partnerships serves only to unreasonably delay the paYment of such amounts to the Bank on account of the indebtedness due to the Bank under the Judgment and Bank's security interest to Bank's detriment and to generate unnecessary expense to the Estate. WHEREFORE, PNC Bank, National Association hereby respectfully requests this Honorable Court to issue a citation upon Robert A. Adler and Paul J. Killion, Executors for the Estate of 4 Betty J. Adler, deceased to show cause why PNC Bank, National Association should not be . permitted to immediately issue execution on the Judgment and attach any and all ownership interest of Decedent, Betty J. Adler, in the Partnerships including, without limitation, any and all distributions to be made by the Partnerships on account of Decedent's ownership interests therein and grant such other relief which this Court deems necessary and equitable. Respectfully submitted, SAIDIS, SHUFF, LOWER & LINDSAY Date: L( _ ? ,) ,7 ~ )-~ L L,. By: ::;- K M. LedebohIn, Esquire S preme Court ID #59012 2109 Market Street Camp Hill, P A 17011 (717) 737-3405 Attorney for PNC Bank, National Association 5 t- '91139-'113 17l1" 77., "S:!7 c C ~I g 29 -r ~11 ~~?~~.33.7. fst. 0..", ~J'71.4_~L-. t/1 th~ llrd~r of.cL;u ~ cl4....JV~~:..~.___. .__ .___ ____ CCI'-IEI \t:\\' Cl\lltF IH.\..\.'IJ. I'ES,\.'.\. """py~~",; ... s: I ~ 'fa - arkr datt". -t:' we. l)r ~ithl'r ()( us. promi~~ t..l p:.l)" (ll the \";CN.Jl)J OAN~ N~.L). .rZ- the .sum of O,.,c. m"/'.~ SDII~IV "",.,Ir/...I J,.if ~"J~_ J' 7AlohN.,,,,.I_./ ~'...f'..r,,,,,.-, ,.<1~'; ~ DOLL.~RS 100 Wjt"Ql.Il 4.f"c.tlf,'ft. ".'''~ ',,"~i..td___. .._ ,.____.._ .lo"~ rurU,,,, h ~~ ..do ft.',by au\horiv .,1" ,...""...... .... ..10"..... .1 ~"r .....t of ,,,,,',,oJ v, r.n/1.yl"~I\"" u' rl......".,.. In "l.fl"l\' 'u' .,,,t tu ,.nt.o, jud""""1 .tainst _~ rur \1\00 .Iw.... "'-. ..;1/1 .. _;,k..... Jtt'...'i.... .;\1. "..... vf 'ult. r~ltll" of f'(Ors. willlout '\:11 of ,....,."1".". anlf "'Ill I:. :_. "",1 .,<ldt'<f Inr cull.dion I... .n" ~-"',"" ....i.. '''t I i.h' .., '"",Ulllllon on an1 ,...1 "nalt tllll\ ma~ br I",ird u~n 10 ,'vllf'<t IlIi. .m.., l,,4 J.. h~r..b, '31"PIIaPlt~ ....ooA.'"I1I II.. ..-<<. ...<i _\l'h,..i.. 'II.. IIrulhOnOf.a,y to "nt.r ..00" lilt Ii. fa. Q.~ .'Aid ....III.u ,...11,1."",,,,,,,,.. c..J ~A._ l\o,,~.'r -tl',.. t".~ .alel r..1 -.f-.1I.c m.7 .... .u1.J: uu It ,.. ra. and _ ~":=::-I\f'r,.b1 _....If' ."d r..I"...~ .11 ,..Ii ..~ .='" ".,,) "i..~.......n'. ._." ...' '....rn~.ll"n , .... '-Ie ."7 ,ta'". ft.... oft 'o.e... v, h..r....tt.r to ~ C\...f4. . , \lITNESS: ~~.:Y':. / LL . - "F. r- /l._ ~. '"7 / .3 ;L, 7 J I f., -,' rJ 0 # 7~ 0 .~ " SO ~O' I !oi~;AL ~~;AL SF-AT. Exhibit "A .. . EXHIBIT -..:- ~ ~ -~..__....:.,.'^ l,i}';k~'~~, \,.<.IIU\dUlt:1 - :::'l. dill March 26, 1991 SURETY AGREEMENT AND CROSS COLLATERALIZATION AND CROSS DEFAULT AGREEMENT IN CONSIDERATION of One Dollar and other good and valuable consideration, including consideration of credit and or forbearance granted or to be granted by CCNB BANK, N.A., 331 Bridge street, New Cumberland , Pennsylvania (hereinafter referred to as "Bank") to CHARLES A. ADLER & SON, INC., (tjd/b/a Pennsylvania Commercial Properties) , Equico Realty Group, Franklin-Carroll Associates, Hamilton Park Associates, Limekiln Associates, SDA & Associates, Second Yorkshire Associates, 8376 Associates, SRR Realty Associates, Hampden Hearth, Inc., Hamer-Adler Partners and First Realty Company (hereinafter, collectively referred to as "Debtor"), THE UNDERSIGNED (each jointly and severally if more than one hereinafter jointly and severally referred to as "Guarantor") hereby agree as follows: 1. OBLIGATIONS OF GUARANTOR. Guarantor becomes an unconditional surety to Bank, its successors, endorsees and assigns for the prompt payment when due of all amounts due to Bank pursuant to several Notes previously executed and delivered by Debtor to Bank on several occasions pursuant to several loan agreements ("Loan Agreements"), continuing interest thereon and any reasonably costs and legal expenses incurred by Bank in the enforcement thereof (hereinafter collectively referred to as the "Debtor Liabilities") ; Exhibi t "~I March 26, 1991 2. CHARACTER OF OBLIGATION. This Surety Agreement shall be a continuing one and shall be binding upon Guarantor regardless of how long before or after the date hereof any of the Debtor Liabilities was or is incurred but only for so long as any of the Debtor Liabilities are outstanding and remain unsatisfied. This guaranty is an absolute, continuing, and unlimited guaranty of payment, and not of collection, without regard to the regularity, validity, or enforceability of any liability or obligation of the Debtor; and the Bank shall not be obliged to proceed first against the Debtor or any other person, firm or corporation, or against any collateral held by the Bank. 3. COLLATERAL. As collateral security for the obligation of the Guarantor hereunder, the Guarantor grants to Bank a security interest in collateral consisting of all that certain collateral listed on Schedule "A" attached hereto and made a part hereof by reference. The Collateral Security for this obligation shall consist of the collateral presently deposited with the Bank and collateral deposited simultaneously with the execution of this Guaranty, and all other property of Debtor of like kinds or types previously, presently, or in the future deposited with the Bank, and the proceeds of the collateral, (hereinafter collectively referred to as "Collateral"). If at any time the Bank shall, in its absolute discretion, consider the collateral security held by it hereunder unsatisfactory or insufficient, the Debtor shall on demand furnish such further security as shall be satisfactory to Bank. 2 '-'wlt~ \o.",",,"'~1 March 26, 1991 4. REALIZATION ON SECURITY. Upon any failure of the Debtor to furnish such additional security, or upon the happening of any of the events enumerated in paragraph 8 the Bank may, in addition to its rights and remedies under the Uniform Commercial Code as in force in the Commonwealth of Pennsylvania on the date hereof, forthwith appropriate, collect, and realize upon any or all property held by it as collateral hereunder, and may sell, deliver, or make any agreement in respect of such property, any such sale or sales to be publ ic or private, at such prices and on such terms as it may deem best; and the Bank shall have the right to purchase any or all of such property. The Bank may apply the proceeds of any such sale or other transaction to the payment in such order as the Bank may elect, toward anyone or more of its claims against the Debtor or Guarantor. 5. AFFIRMATIVE COVENANTS. The Guarantor will furnish in writing to the Bank: a. Ten days prior written notice that any partnership, represented by pledged partnership interest intends to make a distribution to partners. b. Ten days prior written notice that any partnership, represented by pledged partnership interest intends to mortgage or otherwise encumber its properties or sell or lease any of its properties. c. Ten days prior written notice that he intends to resign, retire, or withdraw as a partner from any partnership represented by pledged partnership interest. 3 March 26, 1991 d. will disclose to the Bank immediately that he has received a distribution from a partnership, if his interest in that distributing partnership is pledged as collateral to the Bank. e. will furnish the Bank with a copy of all financial statements distributed to him by any partnership or other entity represented by interest pledged collateral. f. Require all partnerships, represented by pledged partnership interests to provide to him no less frequently than quarterly, financial statements prepared in accordance with generally accepted accounting practices. 6 _ PERFORM AS PARTNER. Guarantor agrees to observe and faithfully perform all of the obligations and undertakings imposed upon Guarantor under any Partnership Agreement referred to in the collateral. From and after the date hereof, no Partnership Agreement relating to a partnership referred to in the collateral may be altered, amended or cancelled in any material fashion without the prior written consent of Bank. 7. INDEMNITY. Bank shall not be deemed in any manner to have assumed any liability in connection with the Collateral. Guarantor shall remain a partner of the respective partnerships and shall be responsible for all duties thereby imposed upon him. Guarantor agrees to indemnify and hold Bank harmless of and from any liability, loss or damage which is mayor might incur by reason of any claim or demand asserted against Bank by reason of the assignment of collateral. 4 ..........,...J\O\".il\CI ;:Il...Clll March 26, 1991 8. CROSS DEFAULT. The occurrence of an Event of Default under the terms of any Debtor or Guarantor Note or its accompanying loan documents shall constitute an Event of Default under all other Notes of Debtor or Guarantor in favor of Bank. Any notice or grace period if provided for in the terms of a particular Note or accompanying loans documents shall apply. In the event of a conflict of time periods the grace period shall be ten (10) days. 9. CROSS COLLA~ZATION. Guarantor agrees that any and all collateral provided by Guarantor as security for any Debtor or Guarantor obligation due Bank shall constitute collateral for all Debtor and Guarantor Notes and obligations to Bank and all collateral shall be under and subject to any and all security agreements given Bank by Guarantor and/or Debtor. 10. WARRANTY AS TO COLLATERAL. Guarantor covenants that there exists no event, condition or occurrence which constitutes, or which with notice and/or the passage of time would constitute, a breach by guarantor of, or default by Guarantor under any term or condition of any of the Collateral. Guarantor hereby covenants not to engage in any action which would destroy or impair the Bank's rights in the Collateral. 11. CONSENT TO LENDER'S ACTS. The Guarantor consents that, without notice to the Guarantor, and without the necessity for any additional indorsement, consent, or guaranty by the Guarantor, the liability of the Debtor may, from time to time, be renewed, extended, modified, compromised, or released by the Bank and any collateral security for Debtor's obligations, may be exchanged, sold 5 March 26, 1991 or surrendered by the Bank, and any balances to the credit of the Debtor may be surrendered by the Bank, all without impairing or affecting in any way the liability of the Guarantor hereunder. 12. WAIVER. The Guarantor waives notice of acceptance of this guaranty, and further waives protest, presentment, demand for payment, notice of default or nonpayment and notice of dishonor. The Guarantor acknowledges that it is Guarantor's responsibility to be informed of the financial condition of Debtor and the Bank has no duty to advise the Guarantor of any information known to it in that regard. 13 . LIABILITY ON DEFAULT. All liability of the Guarantor to the Bank shall at the Bank 1 s option mature immediately, without notice or demand, and become due and payable forthwith upon the occurrence of any of the following acts or events: a. default by Debtor on any Note executed and delivered to Bank; b. default by Guarantor on any Note executed and delivered to the Bank: c. upon the occurrence of the Event of Default under the Loan Agreements, or any of the agreements, documents or instruments executed in connection therewith. 14. WARRANT OF ATTORNEY. Guarantor, and each of them if more than one, hereby irrevocably authorize and empower any Attorney or any Clerk of any court of record, upon the occurrence of any of the 6 ccnb\adler-st.anl March 26, 1991 events enumerated in the preceding paragraph or any time thereafter, to appear for and confess judgement against Guarantor, in any action of replevin instituted by Bank to obtain possession of any collateral securing Guarantor's liability hereunder or any collateral in Guarantor's possession which secures any of the Debtor Liabilities, in either case with or without declaration, with cost of suit. Guarantor: (1) waives and releases all relief from any and all appraisement, stay, exemption or appeal laws of any state now in force or hereafter enacted; and (2) releases all errors in such proceedings. If a copy of this Agreement, verified by affidavit by or on behalf of Bank, shall have been filed in such action, it shall not be necessary to file the original Agreement as a Warrant of Attorney. The authority and power to appear for and enter judgment against Guarantor shall not be exhausted by the initial exercise thereof, and the same may be exercised from time to time, as often as Bank shall deem necessary and desirable, and this Agreement shall be a sufficient Warrant therefor. 15. CONSTRUCTION. When the context so requires: ( i) the singular shall include the plural and conversely; and (ii) use of any gender shall include all genders. 16. SUCCESSORS AND ASSIGNS. This Surety Agreement shall be binding upon Guarantor and Guarantor's heirs, successors, assigns and other legal representatives, and shall inure to the benefit of the Bank , its endorsees, successors and assigns forever. If any provision of this Agreement shall for any reason be held to be invalid or unenforceable, such invalidity or unenforceability shall 7 March 26, 1991 not affect any other provision hereof, but this Agreement shall be construed as if such invalid or unenforceable provisions had never been contained herein. Guarantor intends this to be a sealed instrument and to be legally bound hereby. All issues arising hereunder shall be governed by the laws of the Commonwealth of Pennsylvania. This Agreement in intended to constitute a document under seal. INTENDING to be legally bound hereby this Surety Agreement the ~ day of has executed , 1991. WITNESS: \~G-~.\~U A. ,L~' ~"'O_~~L~ ~r -/ / tf 0,-1;:,:--., (seal) 8 ~~'\U\C\,.l\.Cl ;)\..011- Mar c h 27 I 1 99 1 SCHEDULE "A" LIST OF COLLATERAL ASSIGNED AND PLEDGED UNDER A SECURITY AGREEMENT BY STANLEY D. ADLER, JR. AND BETTY J. ADLER, HUSBAND AND WIFE 1. Partnership interest in ATW Associates. 2. Partnership interest in Diamond Realty Group. 3. partnership interest in Eastgate Realty Associates. 4. Partnership interest in Equico Realty Group. 5. Partnership interest in Fairview Industrial Park Associates. 6. Partnership interest in Franklin-Carroll Associates. 7. Partnership interest in Hamilton Park Associates. 8. Partnership interest in Hartzdale Associates. 9. Partnership interest in Limekiln Associates. 10. Partnership interest in Limekiln Associates-Society Hill Apartment Project. 11. Partnership interest in "0" Associates. 12. Partnership interest in Penn Maclay Associates. 13. shares of Charles A. Adler and Son, Inc. 14. Partnership interest in SA/AG Associates. 15. partnership interest in SDA/AG Associates. 16. Partnership interest in SDA and Associates. 17. Partnership interest in SERR Associates. 18. Partnership interest in SERRI Associates. 19. Partnership interest in SERR/AG Associates. 20. Partnership interest in Second Yorkshire Associates. 21. Partnership interest in 8376 Associates. 22. Partnership interest in SRR Realty Associates. 1 ccnb\adler-st.an- . ~arch 27, 1991 23. 24. 25. 26. 27. Ie>(J shares of Barclay Development corporation. Partnership interest in Executive Leasing Adler Associates. Partnership interest in 100 Cameron Associates. Partnership interest in Union station Associates. Partnership interest in Adler, Scatora and Adler. 28. Partnership interest in American sentinel Realty Associates. 29. 30. 31. 32. 33. 34. 35. 36. 37. 38. 39. Partnership interest in Front street Equity Associates. Partnership interest in Garston Associates. Partnership interest in Rostan Associates. J?~ shares of 4301 corporation. I Partnership interest in Executive Park. shares of Hampden Hearth, Inc. Partnership interest in paxtang Associates. Partnership interest in Adler Partnership. Assignment of corporate note of Charles A. Adler and SOn, Inc. dated in the amount of $1,024,605.00. Partnership interest in Albefore Realty. Partnership interest in Zal Realty Associates. ./ :;? ,1 I ~~p ~j , 1991 . I ~Cl;\G- K&lLWul Witness Date: // " ~~ I / ~ - ". ~~ . .' 7 / / /~_--,Cj /1, l./ stanley D. dler, Jr. v '~_ ~~~GA(~6~tlLL'--~- ltness 77d; \! ' Betty J. /}<'dler OC!;~~-'L' I.---' 2 '\ Assignor: stanley D. Adler. Jr. and Betty J. Adler partnership: Albefore Realty ASSIGNMElIT AND TRMiSFER For value received, the Undersigned (the "ASsignor"), hereby assigns and transfers to CCNB Bank, N.A., its successors and assigns (the "ASsignee"), all of the Assignor'S individual interest in the partnership of: Albefore Realtv Upon the execution of this assignment, the ASsignee shall have the immediate right to receive from the partnership that share of partnership distributions which the Assignor would otherwise be entitled to receive. provided, however, that so long as Assignor shall make such payments upon his obligations to Assignee in the amounts required to maintain such obligations on a "current status", Assignor may continue to receive all partnership distributions herewith assigned. upon a default in any obligation of Assignor to ASsignee, ASsignee shall give Assignor ninety (90) days written notice to cure the default. upon Assignor I s failure to cure the default within said ninety (90) days, all partnership distributions shall be paid to ASsignee until the Assignor'S debt obligation to ASsignee shall be maintained on a current status for ninety (90) 1 Exhibit " e" ~ h;' days at which time the partnership distributions may be paid to Assignor. This assignment is for the sole purpose of providing collateral for Assignor's obligations to Assignee, including but not limited to those set forth in a document captioned Surety Agreement and Cross Collateralization and Cross Default Agreement. Assignee shall not be deemed for any purpose to be a partner of the aforementioned Partnership by reason of this Assignment but shall remain at all times merely a secured creditor. Assignor shall continue as a partner of the said partnership and be responsible for all duties thereby imposed upon him. Powers of assignee. For purposes of effecting execution of this assignment, the Assignor hereby irrevocably appoints the Assignee his attorney in fact, with power of substitution and revocation, with complete authority to demand of and receive from any person all property, debts, and demands belonging and owing to the Assignor as partner or as an individual, and to give . acquittances and discharges therefor; to sue for, prosecute, defend, and interplead on account of all such property, debts, and demands; to sign or endorse the name of the Assignor or the partnership upon any check, draft, note, or other instrument for the payment of money, and upon any instrument necessary to effectuate the purposes of this assignment; and to execute, acknowledge, and deliver all deeds, instruments of conveyance, receipts, and releases necessary or proper. A copy of this Assignment shall be sufficient evidence of Assignee's power of attorney. 2 Construction. When the context so requires: (i) the singular shall include the plural and conversely; and (ii) use of any gender shall include all genders. INTENDING to be legally bou~, the Assignor has executed this Assignment this 3tcfl day .of ~ ' 1991. (Seal) /!l~ :l (/c'--L't!1e- (Seal) Betty J .~dJ;er WITNESS: ~fu~*~ J.UC~ Assignee: ~$' 1// I ~ rI. -'.;-~ J,,v r (Seal) 3 ~-;,~~e (last name first if mdrvrdual) aM mailing at1dre~s stanley D. Adler, 2505 North Front 'Harrisburg, Pa Jr. Street 17110 Debtor name (Iasl name hrsl it indivIdual) and mililillg adclrl!SS: Betty J. Adler 2505 North Front Harrisburg Pa Street 17110 OtlltlJr r.nme (last name fllst it individual) and mallillg address: Sllr.ured Party(ies) ot Record name(s) (last name first if individual) and a;1rl,p.ss tor ~I!curity inlerest information: CCNB Bank N A now known as PNC Bank through merger 4242 Carlisle Pike ~amp Hill Pa 17011 Sp~cial Tvpes 01 PartIes (check ir applicable): o The terms "Debtor" and "Secured Party" mean "Lessee" and "Lessor." '''c:ptctivefy. o The terms "Oebtor" and "Secured Party" mean "Consignee" and "Consignor'" respeCtively. o Debtor is a Transmitting Utility. SIGNATURE(Si Debtor Slgnature(l) (only ir Amendment): Secured ~~SIOnlltU~;'~ )~/' ----?/:>A .', / ~~.. , STANDARD FORM UCC.3 ADllfmed lly ~r.'el~ 01 Commflnwe~1!tl 01 Penn~vlvaflia Uniform Commercial Code Fonn UCC-3 IMPORl ANT - Pleasp. read Instructions on reverse side 1ge 4 before completlng Filing No, (~talllpp.d hy lilil\Q otlicer): D/lte, Time. Filing Office (slampell by I.' "J ' ~JCf6 ~t I qq0 ?C"j 01 J<P ~ C"'., .... -, ("": J( c: .1'\\ ( f ~ ... - - - - -I' en This flnllm:1nll Stlllement Chanve is presented tor filing pursuant to ltle tmWorm~ Commercial Cnoe. and j. t... ,':,: with the (check apf1licilble bo~): fi 1 '':: - f'" ~"'" ( .r')}l ( ::::- -0 ';0 o Ser.ftt2ry of the Commonwealth. [iJ Prol~~notilry of na Up h ; n o Real Estate R!'corns of N W ::....... .:-: ""'- ~; ~,': -;'I.:C~l~~j ~_C"....t'i == 1a Humber ot Addltl""al SlIeets (iI any): Optional Special IdentIJlCltlon (Milx. 10 characters): ORIGINAL FINANCING STATEMENT BEING CHANGED c..D Thi~ rin:w:ino Slalr.m,mt Chang!! relilte~ 10 an o"oinal Financino Slatement No. ---B..D.~~ .9.1___ riled with the: D Sp.crl'tary of the Commonwp.alth on (n:!Ir.) [iJ Prothonotary 01 D;:\ , , r n ; n o Real Estate Records of County on (d:lte) County on (date) .1 18-9~_ DESCRIPTION OF FINANCING STATEMENT CHANGE lb [Z] CnntlnllatJon . The original Financing St;ltemfmt identified above is still effective, o Tem1lnl1l1on. The Secur!!d Party of Record no longer claims a security intere~t under the original F'inanr.ino St~,,," ider.:;tied at>ove. o R.I..... 1hll l;f'ctl,nn 1'1\f1Y (II R"corr1 hm: r"IIlIf!"'n thA r.nllM"':t1 dll&cri~ in block 11 Imm Ihp. co"al,,'~1 ~"l.,r' by fhe orip,":!1 FimlOctnfJ SIatement Identified above. o o Asslonment - The Secured Pilrty ot Record has assigned to the Assion8e. whose name Ifnd ad!1rc~s ~,,, "'",'''i, in hlock ". ri.,ht!; in the collateral described in block 1 1 under the original Rnancing Statement identif"'" ;>\"", Amendment - The original Financing Statement identified above is amended as set lonh in block 11 f~!O""fl""'. Op.btor and Sl!cmen Pllrty of ReCOIn are reQuired), 2 Description of collateral released. rights assigned. Assignee (name and address). or amendment ras indiCillrri in !ll'" , 10): 3 RETURN RECEIPT TO: R A Babula FNC Bank. PO Box 8874 Camp Hill Pa 17001-8874 4 FILING OFfiCE ORIGINAL NOTE - This p;o:t!Jf! will not be returned by the Department of State. Exhibit "n" PARTIES .....aSl name first if individual)"and mailing address: .//~ . " ~\iler, . Stanley D., ,Jr .'-,:, 2?05. ,:JHJrth Front Stteerl Harrisburg, FA 171'10 FINANCING STATEMENT CHANGE Uniform Commercial Code Form UCC-3 IMPORTANT - Please read instructions on reverse side of page 4 before completing Allng No. (sta"'ped by filing office~: 1-/ . l.fl../ _ S Dfm:JZQ;j!j''''''d by filing offi, i~1 ;0' ..... .p<l Debtor> nil me. (Ia~f oamiifirsrw individfl~k. nd This FinanclnOSlatttl'l1ell Change is presented for filing pursu;lnt to the Uniform with the (check applicable box): Dsecretary of the Commonwealth. ~ Prothonotary of Dauohin D Real Estate Records of NUllIber OfA.ddlllonal. Sheets (if any): Optional Special Identification (Max. 10 characte~): ORIGINAL FINANCIN'(lSJA'tEMENT. BEING CHANGED/ hiYinMcirtg~t~~._I~~te~lq'~llro'tlal ,~a"%j"l;~!~erJ1en~ fJ~'.'vt ~9~~l.Sr.~J~ 1 filea with the: .". ' o Secretary of the Commonwealth 011 (date) LiJ.. Prothonotary of D~uph1n County on (date) 4/18/91' ~n~i:::~~~= ofiled,.. on It .ifi:96/~nN(;-.(da~98", ST -tv9o DESCRIPTIONOP)(NANCING STATEMENt 'CHANGE County. County. Adler, .setty J. 2505 North Front Street Harrisburg, PA 17110 ~:\, :'-';"-"~ ~conunU~loh.- The. onginal finanCIng; ~tatem~~t .identifiect. above, is. still. effective. . ..1~qJeWin~tiOh"~T~esectJred partyot Recbrdnalongerclaims a .securityinterestunderth~ anginal financing State/hen {.~i,~meijd~.~t~~. T~'~'~~~i~atPipa~~ciD~~fat~n1eQ . .. .....Pebt1lr~nd' secureQ. Part}{llf'RElCQrd4WJ~q'LJ( " ,'Record ~~{I1~~)';{I~st'fl~me)~rit. ifindivi1tuall-and 1nterest infci~~tlqn( 'Jflilfti~4! ": ...... ~' (f 2 10 Oescriplionof collateral released, nghts aSSigned, AS~ignee(n~me-!~~d address), or3mendment (as indicated in block 10): ,,~~; Special Types of Parlies,(check it applicable): D The terms "Debtor" and "Secured Party" mean "Lessee" and "Lessor," respectively. D The terms "Debtor" and "Secured Party" mean "Consignee" and "Consignor," respectively. .D,~ Debtor~i~ a Tra~smittin, ~.t~li~'J \ , -0 (.:-~ ~ c.n l. ....~ ;-,:;1' . fLa \t ~. ;~4! " ,~ SIGNATURE(S) -r..l :::r Debtor Signature(s) (only if Amendment): .. c::;:) ~ RETURN RECEIPT TO: 11 Secured Party Signature(s): \] (Baflk , Association Kf;lrll~l!> LedebQhnl;\E~~ri;re SAl.oIS ,.. SHUFF;FLOWE1Y.,&'1.,!NDSA Y 2109 t"1arket.Stre~t: Camp Hill, PA 17011 4 12 STANDARD FORM UCC.3 Approved by Secretary 01 Commonwealth 01 Pennsylvania flUNG OffiCE ACKNOWLEDGEMENT - County only. NOTE - This page will not be returned by the Deoartment of State. PENNSYLVANIA DEPARTMENT OF STATE CORPORATION BUREAU UNIFORM COMIJlERCIAL CODE P.O. BOX 8721 HARRISBURG, PA 17105-8721 KARL M LEDEBOLM ESQ SAIDIS SHUFF FLOWER & LINDSAY 2109 MARKET ST CAMP HILL PA 17011 DEBTOR: AD.LER, S'I'ANIJEY D JR 2505 N FRONT ST HARRISBURG, PA 17110 ADLER, BETTY J 2505 N FRONT ST HARRISBURG, PA 17110 SECURED PARTY: PNC BANK NA 4242 CARLISLE PIKE CAMP HILL, PA 17011 EFFECTIVE DATE: MARCH 15, 2001 AT 01:07 PM ORIGINAL FINANCING STATEMENT NUMBER: 19610620 CONTINUATION MICROFILM NUMBER: 33720457 .., ~ ". I... '''11.11;'';1 name 11151 111l1t1IVllhl;1;) ;llltl rJl.1ih:19 ~d(iless: Uniform COlnmercicl Cod~ Form UCC.l "'i.n.ley D. Adler, Jr. IMPORTANT _ pi ~se read instructions on reverse side 0 ge A before completing 05 !'Jorth Front Street rrisburg, PA 17110 Filill!) No. (~;I;lll'llI)/f l1y lill/lQ offir:f'I): DOle, lime, Filing Office (Slillllprc1 /Iv .. ~(1 '-': -- ;C'p; 1 I ':'InlP (last nilllle first Ii ilJdlvlrluill) illHJ 1J1;lIh:1Y iHjrhess: <.... '. ' , ,J ,.-) \ \ ~~l\ ") ..::ty J. Adler ~' c\\ .C7V 05 North Front Street rrisburg, PA 17110 this Finollcin9 Slo'eml'''' i5 11Ip.!;r~llled 101 fill/l!) plllSlIill1f 10 the Unilorm Cnmmercl:l1 Cort~, :md I 1;1 wilh till' (Chp.ck Tlpphr.;'lblp, box): , n;lIllP (I<1st n;Jnlp. lirsl " InrJivirlllill) (11111 n1;'llilll(J ;lrl(tress: o Sf!r:rr.I;lIY 01 Ihr. Cnmmn,.'wC;1/1h '. ~ ',- ~ rrolllonnl:1IY 1.11 Dauphin " :- o 11":l1 C!slalr. Irr:nrrl~ or -.., <. .. r-r' . - ~.Iurnber of Addiliollnl S"'~els (if allY): - ( .' lLJ -. ..-:/ Parly(iesl flalll"l~1 (I:l~;lllamc '."":1 iI IfIOl\Ir!lr:llj ;11 III ilddress 101 seCIIllly Oplionol Sreciol fdcIltj(icclion (M"x. tU rh:ll:ll:ter!;) (-., ~,.. /'.;) I,' ,.. .----~I\"'1. "'...,7 '1J.\'r-f'I"tr" 23 ;Tn I,;' fl(~ 25 rIa 'i It, . 1"'1 ~ r. 'I ('~1 (l" ,olll,rn .1010n CCNB Bank, N.A. 331 Bridge Street l'Jt::W Cumber land, PA 1 7070 COllA TERAl ~... ,...:IJ....,.(sl.,1 Secured Porry nilme(sl (1;]<;111;]1:1(' flf~;1 if ill(lIvi(hl;Jl) ;lI1d ;)(jd,/"!';" ,','wlly IlltCIA.Sl infolfll<llion '.l.'nlil y cn/ln,..,al fly IIr.lll :lllll/nl typP.: ..., .. Partnership in terests, general Jnta.egii+les, contract rights, present and futu.r'e account!;: and assignment of accounts, including but n0t limited to those arising out of the sale or lease of real estate, including rents receivable under leased rental agreements, ..;;,~ 1 rre s 01 Porties (t;lir;J" if ;tpplu;;liJlp.) 2;. I "'f' l!"'me: "()rhl/l'. :1lll1 "Srrllrrrl r,'IIy' 1"""'111 ''I.p.'':~r~'' ;1I1rl "L(!<;r;p.l'" "'" ': :^Iy SECURED PARTY SIC:!:'0JU~.ISl [] u ",.(~ Iml'), if d"~ill'cI\ PIlH!IIr.I<; or IIlI' r.0I1:1t.~,:,! ;'lIe ;1hfl r:llvcled. Idl'ntily r..lot.,! ...,,1 ",ICltr., ,i arl'lir.;lllie. 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St,"'!1 ^rH,,,<<: ',.1 :>"'1"l!,'rj ,,11('1 n ch""O" 01 n,:,m,.. id"Illi'}' nr r"'rp"loll! struel",,. /II 1ft" [lr'ntol f\".r,;I,cc! ~!: f'c "~ ((11___ [] n"-.rnl"'" ":1 1..,!,lilil'l'l::I ~:, ,.! 01 irhrGk !llln) 0 Dp'prj~ 0 MOII~ppn, ;l! r',"''!I';'' 1__, . rOflnry Unifn'm r~Hr.p' Incntifirr_ r ' L.J i1~ 10 whiG!: 'lIp. filing hes lopsed. ~. . '''1.,. :;:'b;~i.1 to ;l ~(,CII'lly Illlf'rr.:il :11 onolh~r county III "(,1\I1<:ylv;I'1I:1 rl wllrll tll.. ("Ihi,.,ol was mov,!~ Ir" !IIi,,: ''111111\' ! I '1111"" Itl" O..b'or' \ rt'sirl~n(r- or plm'(: or b,,<in~H w~< ",,,,,,.-4 I.. Ih''', r:GII'I'Y . "ty <;If,,:..r:t 1':1 il ~!'Clllilv l"I~!f'<::t III ollol\"" i..ri~dicliolt - J '.~'I'''n Ill" collotrro/ wn, mov..rl In !'''''T ,-1-'.'11;:1 , I ';+'-'1 "'~ D,.I"o,'s locotion .....m ",.,v~d ;.. f'''f1w;','!'::lIl1:l, ','.1,,,:, I": r,orr-"r!~ 'l~ filE' (",II,'I!(":I: ./ ",' "I...!! III t',f'ld, 8, ''I ....!li, h :' ~,'" !:l ;Iy in'''I''';1 W;1'; ['lr.\'lrlll"I'1 [l'" "",..1 f.:,I':') dr":r:;;i'''' l'tlH"'''''~ ill 1.1 ~: ". If 1"11' !';I",.,l '.',ill, r.:l'" i"'''"''''o. ;1",1 Illl' ;l:Irl]lI:1:"I., t1"-:"f1b"'! ("I Ih~ III jur!I:l! hll,1rH"II'',J -.1:1"'11"",1, Nome 01 retord OIN,,!"r (lp.qUllen Dilly if lIe Dd.llor h;l!'; illl Illlcre:;1 of rcr;o~c1J: ,/' D:B yep. SIGN,,' TURE(S) 111'1,11'1 ('/1f"">'~-8 -. .~. .....'i~~ " v -, .. _ /'. '. 1/ /, y:: -~- _. =- c.C '-::'-t;' - r: - ~ ,/-0<:::=.---- _~:___2~~..(~~~~.2 (,/~./~.(t::_:!~/ ..=~--=~\ . ~ ,/ // ill I:r: IIr:tJ ill (., '. i ,II S.''''ed Purfy ~i~"ol"'I"'<l (11"1I1'i,,,(i I'IIIV ir !In'((p<;ll; r!''-,'I''II iilln'.',,)' CCNB Bank, N.A. 331 Bridge Street New Cumberland, PA 17070 Attention: Commercial Loan Department Sue McCoy, Lending Operations .-. . - ------- -~ I Jf'jl f fllH.~ r(}!~~~ "'"1 I -. r.....'"nllwr.:lf!lt (If r'r't,1I' ,'::"":1 ESTATE OF BETTY J. ADLER, DECEASED IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA INRE: : ORPHANS' COURT DIVISION : ESTATE NO. 21-01-149 PNC BANK, NATIONAL ASSOCIATION'S OBJECTIONS TO THE FIRST AND PARTIAL ACCOUNT OF ROBERT A. ADLER AND PAUL J. KILLION, EXECUTORS FOR THE ESTATE OF BETTY J. ADLER AND NOW COMES, PNC Bank, National Association, ("Objector") by and through its undersigned attorneys, and asserts the following Objections to the First and Partial Account of Robert A. Adler and Paul J. Killion, Executors for the Estate of Betty J. Adler (collectively "Executors") : 1. a. Objector holds perfected security interests evidenced by a certain Surety Agreement and Cross Collateralization and Cross Default Agreement dated April 3, 1991 signed by Decedent and Decedent's wife, Betty J. Adler (the "Surety and Cross Collateralization Agreement") and evidenced by UCC Financing Statements properly filed of record in, inter alia, all of the Partnerships and Corporations (the "Partnerships and Corporations") in which Decedent held an ownership interest. Objector's perfected, priority security interest is acknowledged by the Executors' for the Estate in their Proposed Schedule of Payment of Expenses and Debt in Order of Payment (the "Proposed Schedule of Payment") under item number 5. Objectors priority security interest includes, without limitation, the Estate's interest in any and all income distributions and Exhibit "E" any proceeds of dissolution of the Partnerships and Corporations (collectively "Objector's Collateral"), and excepting only the periodic income distributions from Adler Joint Venture (the Estate's interest in the underlying assets of Adler Joint Venture are subject to Objector's mortgages of record as more particularly described below). b. Contrary to Executors' assertion at item 5 of the Proposed Schedule of Payment at page 17 that Adler Joint Venture is excluded from the assets in which Objector holds priority security interests, Objector holds mortgages of record against all interests of Decedent and her husband, Stanley D. Adler, Jr., (also deceased) in the following properties, which are believed to constitute all of the assets of Adler Joint Venture: 1. 4005 Jonestown Road, Harrisburg, Dauphin County, P A H. 315 Market Street, Harrisburg, Dauphin County, P A HI. 3401 Walnut Street, Harrisburg, Dauphin County, PA IV. 1800 Columbia Avenue, Lancaster, Lancaster County, PA c. Objector's acknowledged, perfected, priority security interest secures to Objector payment of, inter alia, the amounts due to Objector under the following Judgments entered against Decedent and/or Decedent's husband, Stanley D. Adler, Jr., (also deceased) during their respective lifetimes on certain corresponding demand Notes: 1. Judgment entered on September 11, 1991, before the Cumberland County Court of Common Pleas to docket number 3124 Civil 1991, in the original principal amount of One Million Nine Hundred Forty-Nine Thousand Nine Hundred Seventy-Seven and 34/100 Dollars ($1,949,977.34) which judgment was properly revived by Writ of Revival filed January 29, 1998 before the Cumberland County Court of Common Pleas ("Judgment A"). 11. Judgment entered on May 21, 1998, in the original principal amount of Three Hundred Ninety Thousand Thirty-Five and 82/100 Dollars ($390,035.82) before the Cumberland County Court of Common Pleas to docket number 98-2854 ("Judgment B"). 111. Judgment entered on May 21, 1998, in the original principal amount of Nine Hundred Ninety-One Thousand Five Hundred Fifty-Five and 55/100 Dollars ($991,555.55) before the Cumberland County Court of Common Pleas to docket number 98- 2853 ("Judgment C"). Judgment A, Judgment B and Judgment C are collectively referred to herein as the "Judgments". d. Executor's Proposed Schedule of Payment at page 11 of the Account would improperly impair Objector's liens to the extent that ongoing administration expenses and fees, health care debts or federal income taxes are proposed to be paid out of any of the collateral subject to Objector's perfected security interests. Only the $25,060.00 in the PMI escrow account that is shown in the Account as rental income received from Adler Joint Venture (and interest thereon) may properly be applied toward payments in order of priority under PEF Code g 3392. The order of priorities set forth under PEF Code S 3392 does not control where, as here, its application would impair Objector's validly perfected lien which existed at the date of death (PEF S 3381). e. For the above reasons, Objector is entitled to receIve payment, prior to the payment of any and all other expenses of the Estate or Creditors of the Estate including, without limitation, any and all administration expenses, the family exemption, health care debts and federal income taxes set forth in the Proposed Schedule of Payment, of all disbursements by the Estate for fees, commissions and expenses of administration - from any source other than the periodic rental income received from Adler Joint Venture and the $6,000 income distribution from Garstan Associates, as shown in the Account, to which Objector gave its consent by prior agreement. f. For the above reasons, Objector objects to any payments made or to be made out of Objector's Collateral proposed by Executors' ahead of Objectors secured claim as improperly impairing Objector's liens, contrary to PEF Code S 3381. 2. The Executors acknowledge that the Estate's interests in the Partnerships and Corporations are subject to Objector's perfected security interest; nevertheless, Executors propose to pay ongoing administrative expenses and fees, health care debts and federal income taxes out of Objector's Collateral. These proposed payments from Objector's collateral would violate the protection of pre-existing liens required by PEF Code S 3381. 3. According to the Account, $57,830.94 is being held in escrow by PMI (which is not further identified), and the account of PMI, attached to the Executors' Account as Exhibit "A," indicates that of the foregoing total, $25,060.00 represent rental income from Adler Joint Venture, and this flow of income is not encumbered by Objector's lien. However, the remaining principal balance in the PMI escrow account of $32,241.56, is subject to Objector's lien, and must not be applied to payment of administration expenses or debts of the Decedent, which would constitute impairment of Objector's lien, contrary to PEF Code S 3381. 4. Attorney's fees of $27,010.63 are excessive, unreasonable and out of proportion to the value of the services provided to the Estate. The attorney was aware of the estate's deep insolvency, and it should have been clear that such legal expenses would far exceed any unencumbered funds that would be available to the estate from which to make payment. 5. Objector objects to the proposed payment of federal income taxes ahead of Objector's acknowledged, perfected security interest. Specifically, as the holder of security interests under 26 V.S.C. S 6323, Objector's liens must not be impaired by payment of federal income taxes, except as to any tax lien that may have been recorded prior to the perfection of Objector's security interests (no federal tax liens are believed to have been recorded prior to any of Objector's liens). 6. Executors' commissions, claimed in the Account as "owing" and proposed to be paid, of $7,500.00 are excessive, unreasonable and out of proportion to the value of the services provided to the estate. (a) Executors were aware of the estate's deep insolvency, and it should have been clear that such management fees would far exceed any unencumbered funds that would be available to the estate from which to make payment. (b) In addition to executors' commISSIOns claimed in the Account, the Executors claim additional commissions of $23,055.00 (to date) for administration in the Estate of Stanley D. Adler, Jr. of many of the same business interests, which Betty 1. Adler held jointly with Stanley D. Adler, Jr. 7. Attorney's fees of $3,459.63, paid, and an additional $5,290.00, claimed, are excessive, unreasonable and out of proportion to the value of the services provided to the estate, where the attorney was aware of the estate's deep insolvency, and should have known such legal expenses would far exceed any unencumbered funds that would be available to the estate from which to make payment. 8. Executors have failed to inventory or declare as assets of the estate any household furnishings, vehicles or personal belongs whatsoever of Decedent; the value of such items should be included it the Account. WHEREFORE, Objector, PNC Bank, National Association, prays this Court grant the following relief: a. Deny the requested confirmation of the First and Partial Account; b. Order the Executors, Robert A. Adler and Paul J. Killion, to file a First and Partial Account providing for the payment to Objector, to the extent of its claim, of all amounts received and to be received by the Estate from the Partnerships prior to the payment of any and all other expenses, fees, commissions and Creditors of the Estate. c. Order Executors to pay to Objector, to the extent of Objector's claim, any and all amounts received from the Partnerships In connection with Decedent's ownership interest in those entities In which Objector possesses a perfected security interest. Date: d. Surcharge the Executors, Robert A. Adler and Paul 1. Killion, for any and all disbursenlents for administration expenses, health care debts, legal fees and Executors' fees which have been and which may hereafter be paid by the Executors out of Objector's Collateral. e. Order the Executors to account for the household furnishings, vehicles and other personal effects owned by Decedent at the time of her death. f. Determine and reduce to a reasonable amount Executors' fees and legal fees claimed by Executors. Respectfully submitted, ~f -- "7 -:7. ,..- 0 ry . G/L~ .. (.- \ SAIDIS, SHUFF, FLOWER & LINDSAY !t4 .f<A !J2--,._ ad Nt Ledebohm, Esquire Supreme Court ID #59012 2109 Market Street Camp Hill, P A 17011 (717) 737-3405 Attorney for PNC Bank, National Association By: INRE: IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA ESTATE OF BETTY J. ADLER, DECEASED : ORPHANS' COURT DIVISION : ESTATE NO. 21-01-149 VERIFICATION I, Karl M. Ledebohm, Esquire, of Saidis, Shuff, Flower & Lindsay being authorized to do so on behalf of PNC Bank, National Association, hereby verify that the statements made in the foregoing pleading are true and correct to the best of my information, knowledge and belief. I understand that false statements herein are made subject to the penalties of 18 Pa. C.S. Section 4904, relating to unsworn falsification to authorities. PNC BANK, NATIONAL ASSOCIATION Date: t.,( r 1/ L--- () ~ By: ESTATE OF BETTY J. ADLER, DECEASED IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA WRE: . : ORPHANS' COURT DIVISION : ESTATE NO. 21-01-149 CERTIFICATE OF SERVICE AND NOW, this 22nd day of April, 2002, I, Karl M. Ledebohm, Esquire, of the firm of Saidis, Shuff, Flower and Lindsay, hereby certify that I this day served a true and correct copy of PNC Bank, National Association's Objections to the First and Partial Account of Robert A. Adler and Paul 1. Killion, Executors' for the Estate of Betty J. Adler upon the parties listed below by delivering copies to the following office: William Adler, Esquire ADLER & ADLER P.O. Box 11933 125 Locust Street Harrisburg, PA 17108-1933 INRE: IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA ESTATE OF BETTY J. ADLER, DECEASED : ORPHANS' COURT DIVISION : ESTATE NO. 21-01-149 VERIFICATION I, Eric D. Krimmel, Vice President of PNC Bank, National Association being authorized to do so on behalf of PNC Bank, National Association, hereby verify that the statements made in the foregoing pleading are true and correct to the best of my information, knowledge and belief. I understand that false statements herein are made subject to the penalties of 18 Pa. C.S. Section 4904, relating to unsworn falsification to authorities. PNC BANK, NATIONAL ASSOCIATION Date: y 6-1 (OL By: ~Q e:---S2 Eric D. Krimmel, Vice President -" cZ j-- 0/ - / <./9 v . . IN THE COURT OF COMMON PLEAS OF CUMBERLAND County, PENNSYLVANIA ORPHANS' COURT DIVISION File No. 5491130349143610 Estate of BETTY .J ADLER SSN- 201-16-1582 , Deceased NOTICE OF CLAIM by Universal Bank~ NA., filed pursuant to Section 3532 (b) (2) of the Probate, Estates, and Fiduciaries Code, 20 Pa.C.S.A. B3532 (b) (2). TO THE CLERK OF THE ORPHANS' COURT DIVISION: Enter the claim of Universal Bank~ NA., in the amount of $9013.08, against the above- captioned estate. The Decedent, who resided at 2930 ARCONA RD CUMBERLAND County, Pennsylvania, died on 10/02/2000. Written notice of said claim was given to: PAUL KILLION 545 S 3RD ST LEMOYNE,P A 17043 WILLIAM L ADLER POB 11933 HARRISBURG,PA 17108 on March 5,2001. Universal Bank, NA Account TAMMY A for Citicorp it Services, under limited power of attorney for Universal Bank, NA No. 5491130349143610 Claimant's Counsel: nla P.O. Box 20432 Kansas City, Mo. 64195 Address Your A1I3' Universal Statelnent September 15 - October 12, 2000 BETTY J ADLER Account 5491 1303 4914 3610 Calling Card 8451277695+ PIN No Annual Fee/Platinum Card Quick Reference Minimum Payment Due ................ ................ ............ $737.00 Due Datell( ................................................ November 6, 2000 'Payment must be received by 1:00 pm local time on the payment due date. Amount Past Due ......................................................$550.00 Credit Line ..,'..,........."."............'".......,'..".....',......',...,. $0,00 Available Credit ..........'..', ..... ......"".. .........'"..........',,'... $0.00 Cash Advance Limit ........"..........."."......"........"....,..... $0.00 Account Summary Previous Balance Payments and Adjustments MasterCard@Activity Total AT&T Services New Balance Note: Detailed activity starts on page 2. $9,013.08 -om 0,00 0.00 $9~OlJ~08 Payment Record Amount Paid: - ,..- "ATs.T ':.J ~ Page 1 of 2 How to Reach Us Account Online: www.universalcard.com Account OnCall: 1 800 636-8330 (For Automated Service Only) Customer Service: 1 800423-4343 or write Universal Card Services Corp" PO Box 441137 Jacksonville, FL 32231-4167 Your account is now 3 MONTHS PAST DUE and currently closed. Please call the toll-free number shown above to learn about our special payment options, Date Paid: Check Number: Please follow payment instructions in the "Important Instructions for Making Payments' section of the original statement. Account Number Pa ment Due New Balance Minimum Pa ment Enter Amount Enclosed 5491 1303 4914 3610 11/06/00 $9,013.08 o E5 5<;9113 09 00 H BETTY J ADLER ATTNY ACCOUNT-CODE=DU71 MECHANICSBURG PA 17055-5907 54911303491436100000737000009013081 $737.00 $ Make changes to address and phone number below: Address Apt.lSuite City State Zip Home phone ( ) Business phone Make check payable to: Universal Card PO BOX 8209 SOUTH HACKENSACK NJ 07606-8209 PROOF OF CLAIM ORPHANS COURT DIVISION COURT OF COMMON PLEAS CUMBERLAND COUNTY O.C.No 5491130349143610 EST ATE OF: BETTY J ADLER DECEASED Social Security Number: 201-16-1582 Date of Death: 10/0212000 Name, Address & Phone No. of Person Filing Claim: Tammy Anzelone Agent for Claimant Citicorp Credit Services PO Box 20432 Kansas City, Mo. 64195 1 800215-6061 Citicorp Credit Services, Inc. . , Citicorp Credit Services, A Subsidiary of Citicorp Inc. Kansas City Regional Center 7920 N. W. 110th St Kansas City MO 64153 March 19, 2001 CUMBERLAND COUNTY COURTHOUSE 1 CRT HOUSE SQ RM 102 CARLISLE, PA 17013-3387 RE: The Estate of BETTY ADLER File Number: 212001-149 Dear Sir/Madam, Please find enclosed our claim against the above mentioned estate. return a FILED stamped copy in the enclosed envelope. Please Thank you for your attention to this matter. Very Truly Yours, Tammy Anzelone Manager, of Citicorp Credit Services, Inc. under limited power of attorney for Universal Bank, N.A. v JRD/June 30,1992/17858 JUN 1 2 zoo@ti Estate No.: 21-01-149 ORPHANS' COURT DIVISION COURT OF COMMON PLEAS OF CUMBERLAND COUNTY PENNSYLVANIA In Re: Estate of Betty J Adler Late of Lower Allen Township NO. NOTICE OF FAILURE TO FILE CERTIFICATION AND REQUEST TO CONDUCT A HEARING PURSUANT TO RULE 5.6(e), SUPREME COURT ORPHANS' COURT RULE Personal Representative: Robert A Adler Counsel for Personal Representative: William L Adler Esq Date of Grant of Original Letters: February 6, 2001 Date of Delinquency Notice: May 16, 2001 The undersigned, Mary C. Lewis, Register of Wills, in accordance with Rule 5.6, Supreme Court Orphans' Court Rules, hereby notifies the Orphans' Court Division, Court of Common Pleas of Cumberland County, that neither the above named personal representative nor the above named counsel for the personal representative have filed with the Register of Wills or Clerk of the Orphans' Court his, her or its certification required by Rule 5.6(e), Supreme Court Orphans' Court Rule and that the requisite notice, pursuant to Rule 5 .6( e), Supreme Court Orphans' Court Rules, was given by the Register of Wills on May 9, 2001, and that the ten (10) day notice to file the certification has expired. Accordingly, in accordance with Rule 5.6( e) the Court is hereby notified of such delinquency and the undersigned requests that a Court conduct a hearing to determine whether sanctions should be imposed upon the delinquent personal representative or counsel for the delinquent personal representative. Date: June 11, 2001 ~.-\ ttzU\ / /i ..)" i IU j( <7 U '- 1)1J /.. . tjlfl . Lewis, Register of Wills {j/ {/ Distribution: Personal Representative Counsel for Personal Representative Estate File A hearing is scheduled for~:t~~ in Courtroom No.3. If the Certification of Notice is filed prior to the hearing d~te, the hearing will automatically ~'".. \ . CERTIFICATION OF NOTICE UNDER RULE 5.6(a) Name of Decedent: Betty J. Adler Date of Death: October 2, 2000 Admin. No. "-:0 c.- -UI-" IY'j To the Register: I certify that notice of beneficial interest required by Rule 5.6(a) of the Orphans' Court Rules was served on or mailed to the following beneficiaries of the above-captioned estate on *; Name and Address: Robert A. Adler 2930 Arcana Rd. Mechanicsburg, PA 17055 Staci Smith 519 Castle Rd. Mount Pleasant, SC 29464 Notice has now been given to all persons entitled thereto under Rule 5.6(a). Date: June 28, 2001 /1;/ /1, ,I, L'~, v v William L. Adler, Esquire ADLER & CLARAVAL 125 Locust street P. O. Box 11933 Harrisburg, PA 17108 717-234-3289 Supreme Court ID # 39844 ~ ,'J " t1fJ / /// c--- Counsel for Personal Representative ADLER & ADLER ATTORNEYS AT LAW 125 LOCUST STREET P.O. BOX 11933 HARRISBURG, PENNSYLVANIA 17108-1933 TELEPHONE (717) 234-3289 FAX (717) 234-1670 \\'ILLIA.\l L .'illLER CRA1G 1. ADLER* . .\1 .Sl' .\D\IlTTED TU PRA,CTICE IN "'1 OVERNIGHT MAIL ADDRESS: 125 LOCUST STREET HARRISBURG, PENNSYLVANIA 17101 January 2, 2002 Cumberland County Courthouse Register of Wills 1 Courthouse Square Carlisle, PA 17013 RE: Estate of Betty Adler Dear Register of Wills: (Lc (. LEWIS F. ADLER (1934-198'1) DA VlD S. KOI-lr\ ( 1934-1985) LOUsr-ADLER (] 959-1999) KOlIN A:\'D ADLER (1934-1960) KOH\", ADLER & ADLER (1960- 1981) . ! ("{ " / '- l Enclosed please find the inheritance tax return for the estate of Betty Adler together with the filing fee of $35.00 for filing with your office. Please return a clocked copy to me in the envelope provided. Thank you. Very truly / //) c'( 1 \. William L. WLA Enclosure yours, A," ~. //, '.(/. . / ~. I .. ,... :." (I ' - / ,l.: . Adler QC.i :; (C ::5 -, (7 d N c~- ::0 CD C- :;r:-; :z I \0 -".J .~::~ o co \ /6 -02t!:JR-t? )-!-' (.: l/' COMMONWEALTH OF PENNSYLVANIA DEPARTMENT OF REVENUE BUREAU OF INDIVIDUAL TAXES DEPARTMENT 280601 HARRISBURG, PA 17128-0601 July 3, 2001 Telephone (717) 787-3930 FAX (717) 772-0412 Law Offices of Alder & Alder 125 Locust St. P.O. Box 11933 Harrisburg, Pa.17108-1933 Re: Estate of Betty J. Adler File Number 2101-0149 Dear Mr Adler: This is in response to your request for an extension of time to file the Inheritance Tax Return for the above estate. In accordance with Section 2136 (d) of the Inheritance and Estate Tax Act of 1995, the time f filing the return is extended for an additional period of six months. This extension will avoid the imposition of a penalty for failure to make a timely return. However, it does not prevent interest frorr accruing on any tax remaining unpaid after the delinquent date. The return must be filed with the Register of Wills on or before January 2,2002. Because Section 2136 (d) of the 1995 Act allows for only one extra period of six (6) months, no additional extension(s) will be granted that would exceed the maximum time permitted. Sincerely, ,(~ Jeffrey D. Hollenbush, Sup~rvisor Document Processing Unit Inheritance Tax Division IN RE: IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA ESTATE OF BETTY 1. ADLER, DECEASED ORPHANS COURT DIVISION ESTATE NO. 21-01-149 REPLY TO RULE TO SHOW CAUSE OF PNC BANK. N.A. AND NOW COMES, Robert A. Adler and Paul 1. Killion, Co-executors of the estate of Betty J. Adler, through their attorneys, Adler & Adler, representing the following in response to the Rule to Show Cause: 1. Admitted. 2. Admitted. 3. Admitted. 4. Admitted. By way of further answer thereto, the partnership interests assigned to Bank only include those listed in paragraph 4 and not the Adler Joint Venture. 5. Denied. The estate has never seen the original financing statements filed with the Secretary of the Commonwealth, and they were not attached to the Rule. Whether Bank's security interest is perfected is a matter of law to be determined. 6. Admitted in part and denied in part. The executors believe that Bank has a priority security interest over other class six creditors as defined in 20 Pa. C. S. Section 3992 Executors deny that Bank has priority over the first five classes of creditors as defined in that statute. 7. Admitted. 8. Admitted. -1- 9. Denied. Class 1 through 5 claims should be paid before Bank is paid. 10. Admitted. 11. Denied. Bank's interests are subject to the priority of payment schedule as set forth in 20 P A. C. S. Section 3992 and as outlined in the First and Partial account for the estate. 12. Denied. Funds are needed for the ongoing administration of the estate. Income tax returns must be generated for the partnerships and the estate, and income tax paid. There are thousands of dollars worth of costs involved in administering this estate. The estate is responsible for administering the following partnership interests and underlying commercial real estate interests: a. Adler Joint Venture 1. 315 Market Street, Harrisburg, P A 11. 4001 - 4005 Jonestown Road, Harrisburg, PA 111. 3401 Walnut Street, Harrisburg, P A IV. 1800 Columbia Ave., Harrisburg, P A b. Albefore Realty 1. 3556 Old Gettysburg Rd., Camp Hill, PA 11. 3435 Simpson Ferry Road, Camp Hill, PA c. Front Street Equity Associates 1. Park City, Lancaster d. ZAL Realty Associates 1. AAA Building, November Drive, Camp Hill (Betty Adler estate) e. 2930 Arcona Road, Mechanicsburg, P A Property Management, Inc. ofLemoyne, PA handles the day to day management of many of these real estate investments, but the overall management responsibility is with the estate of -2- Betty J. Adler together with the other partners. 13. Admitted in part and denied in part. It is admitted that the executors are burdened with the administration of the estate. It is denied that the estate must act as a mere conduit for the funds. Detailed time records have been provided to counsel for the Bank showing the level of work required to administer the above partnership interests. Accountants must be paid to file appropriate returns. Taxes must be paid whether or not income is being passed on to Bank. The executors have, in fact, delivered proceeds from the sale of the F. Ress, Inc. property to Bank, and income from Garstan Associates is being paid to Bank. Executors have tried to balance the interests of Bank and the estate and retain enough funds for ongoing administration while paying what it feels is prudent to Bank. Executors have been attempting to work with Bank for the orderly liquidation of the assets. 14. Denied. Bank is requesting an assignment of the income generated by the partnerships. Bank refuses and continues to refuse to take an assignment of any partnership interests, or to aid or become involved with the management of any partnership interests. Bank's proposal is to take all the income and to have the partnership interests remain in the name of the estate of Betty 1. Adler, so that any management decisions and administrative tax burdens would remain with the estate while the Bank received all the income. 15. Denied. If the Bank was willing to take an assignment of the partnership interests and apply its tax identification number to them, then after all tax returns to the end of the year in which the transfer occurred were filed, and taxes paid, and estate administration for those assets completed, then Bank could receive all income and take care of all administrative burdens. Neither the P A Department of Revenue, -3- nor the Internal Revenue Service, has sent confirmation that the inheritance tax returns and federal estate tax returns were accepted as of May 15, 2002. The distributions are property of the estate under 20 Pa.C.S. 3992, and they benefit the estate for all of the above reasons. 16 Denied. Again, depositing the funds is not much of an administrative burden. Making management decisions, monitoring the properties, filing the income tax returns, paying the taxes on the income and handling ongoing estate administration business are all significant burdens of administering an estate such as this. WHEREFORE, the executors of the estate of Betty 1. Adler respectfully request that the Rule to Show Cause be dismissed, and that the administration of the Estate of Betty 1. Adler proceed as set forth in the First and Partial Account. 11/~ ?J ~ 5'ufLUt~. 0 William L. Adler, Esquire '-- ADLER & ADLER P.O. Box 11933 125 Locust St. Harrisburg, P A 17108 717-234-3289 Supreme Court ID Number 39844 Dated: May 15, 2002 -4- VERIFICA TION I VERIFY THA T THE STATEMENTS MADE IN THE FOREGOING PLEADING ARE TRUE AND CORRECT. I UNDERSTAND THAT FALSE STATEMENTS HEREIN ARE MADE SUBJECT TO THE PENALTIES OF 18 Pa.C.S.A. Section 4904 RELATING TO UNSWORN FALSIFICATION TO AUTHORITIES. DATE: c;'/z-z 't~ r I l --; // /~ iI /I 1~ 1l/1htv< z.. dtt' v W~ / William L. Adler, EsqUIre ~~~-4 Robert A. d 'r, Executor Q Paul 1. Killion, -5- CERTIFICATE OF SERVICE I, William L. Adler, Esquire, Attorney for the estate, hereby certify on the 'Z.-,3 day ofM~ ' 2002, I served a copy of the within Reply to ule to Show Cause upon the following person by first class mail, postage prepaid, addressed as follows: Karl M. Ledebohm, Esquire SAlOIS, SHUFF, FLOWER & LINDSAY 2109 Market St. Camp Hill, PA 17011 &. If ~ ~.~ ~ [:. ~--- William L. Adler, Esquire -6- t~ INRE: IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA ESTATE OF BETTY J. ADLER, DECEASED : ORPHANS' COURT DIVISION : ESTATE NO. 21-01-149 ACCEPTANCE OF SERVICE I, William Adler, Esquire, attorney for Paul J. Killion and Robert Adler, Executors for the Estate of Stanley D. Adler, Jr., Deceased, hereby accept service of the PNC Bank, National Association's Petition for Rule to Show Cuase why Execution Should not Issue on Judgments Entered Against, inter alia, Betty J. Adler, Deceased and Attachment be Made Upon any and all Ownership Interest of Decedent, Betty 1. Adler, in Certain Partnerships and Corporations Subject to Bank's Priority Perfected Security Interest Pursuant to 20 P.S. Section 3377(A)(2) and Citation on behalf of Paul 1. Killion and Robert Adler, Executors for the Estate of Stanley D. Adler, Jr, Deceased, filed in the above-captioned matter and certify that I am authorized to do so. ., ,. , Date: / ' ~ /6/ c -L--- By: " I , 'J !. ....! /11 ii ~/" . .' ..' l U(,\AA/l;~ . ' . v v. ~ _'" William Adler, Esquire Attorney for Paul J. Killion and Robert Adler, Executors for the Estate of Stanley D. Adler, Jr., Deceased ESTATE OF BETTY 1. ADLER, DECEASED IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA IN RE: ORPHANS COURT DIVISION ESTATE NO. 21-01-149 ORDER ..,.f". , 2003, the December 3 1, 2002 AND NOW, this day of.. orders issued to the above estat~.art(declared final and appealable. ;:r:~f ;":;//:-<"'. / 1 INRE: EST ATE OF BETTY 1. ADLER, DECEASED IN THE COURT OF COMMON PLEAS CUNlBERLAND COUNTY, PENNSYLVANIA ORPHANS COURT DIVISION ESTATE NO. 21-01-149 PETITION FOR DETERMINATION OF FINALITY PURSUANT TO PA.R.A.P. 342 AND NOW COMES, William L. Adler, attorney for the estate of Betty 1. Adler, and represents the following: 1. On December 3 1, 2002, the above Court issued two orders concerning the above estate, copies of which are attached as Exhibits" A" and "B." 2. The order denying confirmation of the First and Partial Account of the Executors ordered all distributions, payments and proceeds of the estate to be turned over to PNC Bank, NA. 3. The order also surcharged the executors for all distributions made by them and to them from the estate. 4. This surcharge includes payment of attorneys' fees and similar ongoing administration expenses which had been incurred over approximately two years of estate administration, involving approximately $4,600.00. 5. PA.R.A.p.7~~tes that an order of the Orphans' Court Division determining an interest in realty, personalty, the status of individuals or entities... shall constitute a final order upon a determination of finality by the Orphans' Court Division. 6. The order denying confirmation of the First and Partial account determines the status of payments made and to be made and should constitute a final order pursuant to Rule 342. 7. Similarly, the order permitting execution by PNC Bank, NA, also is a determination of the -1- status of payments to be made to PNC Bank, and should be considered a final appealable order. WHEREFORE, Petitioners respectfully request that the above referenced orders be declared final appealable orders. Dated: January 29, 2003 -2- CERTIFICATE OF SERVICE I, William L. Adler, Esquire, Attorney for the estate, hereby cert i fy on the 7(J day 0 fTb..IA,;V'S ' 2003, I served a copy of the within Petition upon the followlng person by first class mail, postage prepaid, addressed as follows: Geoffrey Shuff, Esquire SAIDIS, SHUFF, FLOWER & LINDSAY 2109 Market st. Camp Hill, PA 17011 ?1A/Ji~r q ~ William L. Adler, Esquire -3- IN RE: IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA ESTATE OF BETTY J. ADLER, DECEASED ORPHANS' COURT DIVISION NO. 21-01-149 ORDER OF COURT AND NOW, this 31st day of December, 2002, upon consideration of the First and Partial Account of Robert A. Adler and Paul J. Killion, Executors of the Estate of Betty J. Adler, and after consideration of and hearing on PNC Bank, National Associations' Objections to the Account, IT IS HEREBY ORDERED, ADJUDGED AND DECREED THAT: 1. Confirmation of the First and Partial Account, as filed, is hereby denied, but without prejudice to the future filing by the Executors, Robert A. Adler and Paul J. Killion, of an account providing for the payment of expenses of the Estate; and 2. The Executors shall immediately turn over to the law firm of Saidis, Shuff, Flower & Lindsay on behalf of PNC Bank, National Association, to the . extent of its claim, any and all distributions, paymEtnts, proceeds and other amounts of any nature which have been received by or on behalf of the Estate, and/or are being held by or on behalf of the Estate, from, through, under or otherwise on account of the Partnerships and/or the Corporations described in the Banks' Objections to the Account; and 3. The Executors are hereby surcharged for any and all amounts which ~Jf} t.---x bt the Executors paid to themselves or to any other person or entity out of distributions, payments, proceeds and other amounts of any nature which have been received by or on behalf of the Estate, and/or were or are being held by or on behalf of the Estate, from, through, under or otherwise on account of the Partnerships and/or the Corporations described in the Bank's Objections to the Account, and all such amounts shall be immediately paid by the Executors to the Law firm of Saidis, Shuff, Flower & Lindsay on behalf of PNC Bank, National Association, to the extent of its claim; and 4. The Executors shall promptly turn over to the law firm of Saidis, Shuff, Flower & Lindsay on Behalf of PNC Bank, National Association, to the extent of its claim, any and all distributions, payments, proceeds and other amounts of any nature which are received by or on behalf of the Estate, from, through, under or otherwise on account of the partnerships and/or the Corporations described in the Bank's Objections to the Account, on and after the date of this Order; and 5. As part of any account filed by the EX(9cutors in the future, the . " Executors shall account for the household furnishings, vehicles and other personal property of the Decedent at the time of her death. By the Court, A TRUE COPY FROM RECORD In Testimony wherof, 'hereunto set my hand and the seal of said Court a~isle. PAO)... ~~fLW5~O~L Clerk of the Orphans Court n..l~ a cumberland County 'V In Geoffrey S. Shuff, Esquire Saidis. Shuff, Flower & Lindsay 2109 Market Street Camp Hill, PA 17011 William L. Adler, Esquire Adler and Adler 125 Locust Street Harrisburg, PA 17101 . . ,I . , IN RE: IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA ESTATE OF BETTY J. ADLER, DECEASED ORPHANS' COURT DIVISION NO. 21-01-149 ORDER OF COURT AND NOW, this 31st day of December, 2002, upon consideration of PNC Bank, National Association's Petition for Rule to Show Cause Why Execution Should Not Issue on Judgments Entered Against, Inter Alia, Betty J. Adler, Deceased, and Attachment Be Made Upon Any and All Ownership Interest of Decedent, Betty J. Adler, in Certain partnerships Subject to Bank's Priority Perfected Security Interest Pursuant to 20 P.S. 3377(a)(2), and the Reply of the Estate's Executors thereto, an after hearing thereon, IT IS HEREBY ORDERED, ADJUDGED AND DECREED THAT PNC Bank, National Association, is authorized to, and may at any time and from time to time hereafter execute on any, some or all of the Judgments described in the Bank's Petition, and garnish, attach, and/or otherwise levy upon any right, title and/or interest of the Estate to or in the Partnerstlips and/or the Corporations . ,I income, profits and proceeds thereof. described in the Bank's Petition, including without limitation the rents, issues, A TRUE COpy FROM RECORD In Testimony wheref, I hereunto set my hand and the seal of said Court at CarHsle, p~~ This3/ day of "l)ec. 2u-..:- -;n,.Utv S ' Clerk of the Orphans ou Cumberland County By the Court, Geoffrey S. Shuff, Esquire Saidis, Shuff, Flower & Lindsay 2109 Market Street Camp Hill, PA 17011 f:ylt William L. Adler, Esquire Adler and Adler 125 Locust Street Harrisburg, PA 17101 , -----/ ~ ~ v / 0 -D)0 c~-? - 6 BUREAU OF INDIVIDUAL TAXES INHERITANCE TAX DIVISION DEPT. 280601 HARRISBURG. PA 17128-0601 COMMONWEALTH OF PENNSYLVANIA DEPARTMENT OF REVENUE NOTICE OF INHERITANCE TAX APPRAISEMENT, ALLOWANCE OR DISALLOWANCE OF DEDUCTIONS AND ASSESSMENT OF TAX DATE ESTATE OF DATE OF DEATH FILE NUMBER COUNTY ACN 05-27-2002 ADLER 10-02-2000 21 01-0149 CUMBERLAND 101 WILLIAM L ADLER ~'SQ I i ADLER & ADLER PO BOX 11933 HBG PA 17108 REV-1547 EM AFP (01-02) BETTY J Amount Remitted CHANGED (1) (2) (3) (4) (5) (6) (7) 425.000.00 .00 .00 .00 719.917.00 .00 .00 (8) MAKE CHECK PAYABLE AND REMIT PAYMENT TO: REGISTER OF WILLS CUMBERLAND CO COURT HOUSE CARLISLE, PA 17013 CUT ALONG THIS LINE ~ RETAIN LOWER PORTION FOR YOUR RECORDS ~ REV = ls4j-Ex-AFP--(Cff=o21--NcfficE--oF-'rNHEifiTANcE-"-Ax-'A-ppR'AisEMENT-,--Aii-oWANCE-cfi------------ - - - -- DISALLOWANCE OF DEDUCTIONS AND ASSESSMENT OF TAX ESTATE OF ADLER BETTY J FILE NO. 21 01-0149 ACN 101 DATE 05-27-2002 TAX RETURN WAS: (X) ACCEPTED AS FILED RESERVATION CONCERNING FUTURE INTEREST - SEE REVERSE APPRAISED VALUE OF RETURN BASED ON: ORIGINAL RETURN 1. Real Estate (Schedule A) 2. Stocks and Bonds (Schedule B) 3. Closely Held Stock/Partnership Interest (Schedule C) 4. Mortgages/Notes Receivable (Schedule D) 5. Cash/Bank Deposits/Misc. Personal Property (Schedule E) 6. Jointly Owned Property (Schedule F) 7. Transfers (Schedule G) 8. Total Assets APPROVED DEDUCTIONS AND EXEMPTIONS: 9. Funeral Expenses/Adm. Costs/Misc. Expenses (Schedule H) 10. Debts/Mortgage Liabilities/Liens (Schedule I) 11. Total Deductions 12. Net Value of Tax Return 13. Charitable/Governmental Bequests; Non-elected 9113 Trusts (Schedule J) 14. Net Value of Estate Subject to Tax NOTE: If an assessment was issued previously, lines reflect figures that include the total of ALL ASSESSMENT OF TAX: 15. Amount of Line 14 at Spousal rate (15) 16. Amount of Line 14 taxable at Lineal/Class A rate (16) 17. Amount of Line 14 at Sibling rate (17) 18. Amount of Line 14 taxable at Collateral/Class B rate (18) 19. Principal Tax Due TAX CREDITS: 54,247.00 3.560.475.00 (11) (12) (13) (14) (9) (10) NOTE: To insure proper credit to your account, submit the upper portion of this form with your tax payment. 1,144,917.00 3.614.722 00 2,469,805.00- .00 2,469,805.00- 14, 15 and/or 16, 17, 18 and 19 will returns assessed to date. .00 X 00 = .00 X 045 = .00 X 12 = .00 X 15 = (19)= .00 .00 .00 .00 .00 r'''n~rll t(~1.~~r'1 (+J AMOUNT PAID DATE NUMBER INTEREST/PEN PAID (-) TOTAL TAX CREDIT .00 BALANCE OF TAX DUE .00 INTEREST AND PEN. .00 TOTAL DUE .00 . IF PAID AFTER DATE INDICATED, SEE REVERSE FOR CALCULATION OF ADDITIONAL INTEREST. ( IF TOTAL DUE IS LESS THAN $1, NO PAYMENT IS REQUIRED. IF TOTAL DUE IS REFLECTED AS A "CREDIT" (CR), YOU MAY BE DUE A REFUND. SEE REVERSE SIDE OF THIS FORM FOR INSTRUCTIONS.) ADLER & ADLER ATTORNEYS AT LAW 125 LOCUST STREET P.O. BOX 11933 HARRISBURG, PENNSYLVANIA 17108-1933 TELEPHONE (717) 234-3289 FAX (717) 234-1670 WILLIAM L. ADLER CRAIG 1. ADLER* 'ALSO ADMITTED TO PRA.CTICE IN NJ OVERNIGHT MAIL ADDRESS: LEWIS F. iillLER (1914- 1984) DAVID S. KOH~ (1934-1985) LOUIST:"WLER (1959-1999) 125 LOCUST STREET HARRISBURG, PENNSYLVANIA 17101 KOHN AND <WLER (1934-1960) KOHN, ADLER & <WLER (1960-1981 ) March 18, 2002 Cumberland County Courthouse Register of Wills 1 Courthouse Square Carlisle, PA 17013 RE: Est~te~etty J. Adler ~--21-01-()149 ,---------- Dear Register of Wills: Enclosed please find a copy of the 706 for the above estate. I believe I neglected to file this with the inheritance tax return. Thank you. Very truly your~, ,1tLvr I~ William L. Adler t._ WLA Enclosure ~")~'I c:5 1'.) '.(:'l PRAECIPE FOR LISTING CASE FOR ARGUMENT (Must be typewritten and submitted in duplicate) TO THE PROTHONOTARY OF CUMBERLAND COUNTY: Please list the within matter for the next Argument Court. CAPTION OF CASE (entire caption must be stated in full) o i'-...' In Re Estate of Betty J. Adler, Deceased (Plaintiff) vs. (Defendant) Orphans' Court Division No. 21-01-149 civil 19 1. State matter to be argued (x.e., plaintiff's motion for new trial, defendant's demurrer to complaint, etc.): 1) PNC Bank National Association's Objections to the First and Partial Account of Robert A. Adler and Paul J. Killion, Executors for the Estate of Betty J. Adler and 2) PNC Bank, National Association's Petition for Rule to Show Cause why Execution should not issue on Judgments entered against, inter alia, Betty J. Adler, deceased and attachment be made upon any and all ownership interest of decedent, Betty J. Adler, in certain partnerships and corporations subject to Bank's priority perfected security interest pursuant to 20 P.S. Section 3377(A)(2). "Please consolidate with argument to be scheduled on PNC Bank, National Association's Objection to the Executors' Account and Petition for Rule to Show Cause filed in the matter styled In Re Stanley D. Adler, Jr., to Docket No. 21-01-145. 2. Identify counsel who will argue case: ( a ) for P 1 a ~ ~ t iff: Karl M. Ledebohm, Esquire for PNC Bank National Association (b) for defe~~ant: William Adler, Esquire for the Estate 3. I will notify all Parties in writing within two days that this case has been listed for argument. Dated: ltJ ?o r(l L 4. Argument Court Cumberland County - Register Of Wills One Courthouse Square Carlislel PA 17013 Phone: (71 7) 240 - 6345 Date: 9/14/2006 ADLER WILLIAM L 125 LOCUST STREET PO BOX 11933 HARRISBURG I PA 17108 RE: Estate of ADLER BETTY J File Number: 2001-00149 Dear Sir/Madam: This notice is to serve as a reminder that the Status Report by Personal Representative under Rule 6.12 is due on the below listed date. As per the AMENDMENTS TO SUPREME COURT ORPHANS' COURT RULES I NO. 103 SUPREME COURT RULES DOCKET NO. 11 for decedents dying on or after July 11 19921 the personal representative or his counsell within two (2) years of the decedent's deathl shall file with the Register of Wills a Status Report of completed or uncompleted administration. This filing lS due by: 10/02/2006 Please feel free to contact this office with any questions you may have. If you have already filed your Status Report, please disregard this notice. Sincerely, In L~~ . .~' / fJ ~ ~JU .w;fi;i~4J Glenda Farner Strasbaugh Clerk of the Orphans' Court cc: File Personal Representative(s) ~ Cumberland County - Register Of Wills One Courthouse Square Carlisle, PA 17013 Phone: (717) 240-6345 Date: 9/14/2006 ROBERT A ADLER 2930 ARCONA ROAD MECHANICSBURG, PA 17055 RE: Estate of ADLER BETTY J File Number: 2001-00149 Dear Sir/Madam: This notice is to serve as a reminder that the Status Report by Personal Representative under Rule 6.12 is due on the below listed date. As per the AMENDMENTS TO SUPREME COURT ORPHANS' COURT RULES, NO. 103 SUPREME COURT RULES DOCKET NO. I, for decedents dying on or after July I, 1992, the personal representative or his counsel, within two (2) years of the decedent's death, shall file with the Register of Wills a Status Report of completed or uncompleted administration. This filing is due by: 10/02/2006 Please feel free to contact this office with any questions you may have. If you have already filed your Status Report, please disregard this notice. Sincerely, (.~ ".LI- ,/ 17 t~~'ijJ4ZUt.~I.9I~ ~'1 , Glenda Farner Strasbaugh Clerk of the Orphans' Court cc: File Counsel ~ Cumberland County - Register Of Wills One Courthouse Square Carlisle, PA 17013 Phone: (717) 240-6345 Date: 9/14/2006 PAUL J KILLION 545 SOUTH THIRD STREET LEMOYNE, PA 17043 RE: Estate of ADLER BETTY J File Number: 2001-00149 Dear Sir/Madam: This notice is to serve as a reminder that the Status Report by Personal Representative under Rule 6.12 is due on the below listed date. As per the AMENDMENTS TO SUPREME COURT ORPHANS' COURT RULES, NO. 103 SUPREME COURT RULES DOCKET NO. I, for decedents dying on or after July 1, 1992, the personal representative or his counsel, within two (2) years of the decedent's death, shall file with the Register of Wills a Status Report of completed or uncompleted administration. This filing is due by: 10/02/2006 Please feel free to contact this office with any questions you may have. If you have already filed your Status Report, please disregard this notice. Sincerely, it.-- l e 1t.l5Ut~ .. /~.A /f /1 C Glenda Farner Strasbaugh Clerk of the Orphans' Court cc: File Counsel \ ~ . ~E. ';'':~G E\ '~-'--' COMMONWEALTH OF PENNSYLVANIA DEPARTMENT OF REVENUE DEPT. 280601 HARRISBURG, PA 17128-0601 INHERITANCE TAX RETURN RESIDENT DECEDENT L~-~-L COUNTY CODE YEAR ~L--A-~- NUMBER t- Z W o W U w o DECEDENTS NAME (LAST, FIRST, AND MIDDLE INITIAL) ADLER, BETTY J. DATE OF DEATH (MM-DD-YEAR) 10/02/2000 e REV-1500 /b-~{)7- " FILE NUMBER SOCIAL SECURITY NUMBER 201 -16 1582 DATE OF BIRTH (MM-DD-YEAR) 01/12/24 THIS RETURN MUST BE FILED IN DUPLICATE WITH THE REGISTER OF WILLS SOCIAL SECURITY NUMBER (IF APPLICABLE) SURVIVING SPOUSE'S NAME (LAST, FIRST, AND MIDDLE INITIAL) W I- ~~(I) UC::~ wc..U J:OO uC::.J c..lXl 0.. <t I- Z W C Z o 0.. (I) W c:: a:: o U z o ~ ...J :J l- n:: <( (.) w a::: z o ~ ~ :::) c.. ~ o (.) X ~ [X] 1. Original Return D 4. Limited Estate [R] 6. Decedent Died Testate (Attach copy of Wlil) D 9. Litigation Proceeds Received D 2. Supplemental Return D 4a. Future Interest Compromise (date of death after 12-12-82) D 7. Decedent Maintained a Living Trust (Attach copy of Trust) D 10. Spousal Poverty Credit (date of death between 12-31-91 and 1-195) D 3. Remainder Return (date of death prior to 12-13-82) [X) 5. Federal Estate Tax Return Required JL 8. Total Number of Safe Deposit Boxes D 11. Election to tax under Sec. 9113(A) (Attach Sch 0) NAME WILLIAM L. ADLER, ESQUIRE FlfWtJt~~ ApplrbleAD L ER TELEPHONE NUMBER 717-234-3289 1. Real Estate (Schedule A) 2. Stocks and Bonds (Schedule B) 3. Closely Held Corporation, Partnership or Sole-Proprietorship 4. Mortgages & Notes Receivable (Schedule D) 5. Cash, Bank Deposits & Miscellaneous Personal Property (Schedule E) 6. Jointly Owned Property (Schedule F) D Separate Billing Requested 7. Inter-Vivos Transfers & Miscellaneous Non-Probate Property (Schedule G or L) 8. Total Gross Assets (total Lines 1-7) 9. Funeral Expenses & Administrative Costs (Schedule H) 10 Debts of Decedent, Mortgage Liabilities, & Liens (Schedule I) 11. Total Deductions (total Lines 9 & 10) 12. Net Value of Estate (Line 8 minus Line 11) COMPLETE MAILING ADDRESS 125 LOCUST STREET P. 0 BOX 11933 HARRISBURG (1)425,000.00 (2) (3) (4) (5) 71 9 , 9 1 7 . 0 0 ~~,r" " ....t'\... .I" ~ (~, '--' :c: , '{) u "'. (6) (7) (8) 1, 1 44 , g 1 7 00 (9) 54 , 2 4 7 . 0 0 (10) 3 , 560 , 475 . 00 (11 ) 1 ';14 7?? 00 (12) (13) (14) 0.00 13. Charitable and Governmental Bequests/See 9113 Trusts for which an election to tax has not been made (Schedule J) 14. Net Value Subject to Tax (Line 12 minus Line 13) SEE INSTRUCTIONS ON REVERSE SIDE FOR APPLICABLE RATES 15. Amount of Line 14 taxable at the spousal tax rate, or transfers under Sec. 9116 (a)(1.2) 16. Amount of Line 14 taxable at lineal rate 17. Amount of Line 14 taxable at sibling rate 18 Amount of Line 14 taxable at collateral rate 19 Tax Due x .0 _ (15) 0.00 x .0 _ (16) x .12 (17) x .15 (18) (19) o 00 20.0 CHECK HERE IF YOU ARE REQUESTING A REFUND OF-AN OVERPAYMENT > > BE SURE TO ANSWER ALL QUESTIONS ON REVERSE SIDE AND RECHECK MATH < < SCHEDULE "A" REAL ESTATE Estate of Betty J. Adler File Number 21-01-0149 ITEM NUMBER DESCRIPTION VALUE AT DEATH 2930 Arcona Rd. $425,000.00 Mechanicsburg, PA 17055 (See attached appraisal, exhibit 40 ) TOTAL REAL $425,000.00 ESTATE " SCHEDULE E CASH, BANK DEPOSITS AND MIse PERSONAL PROPERTY Estate of Betty J. Adler File Number 21-01-0149 ITEM NUMBER DESCRIPTION VALUE AT DEATH Adler Joint Venture See attached Exhibits 1 and 2, partnership agreement Betty Adler - 25% interest in partnership Assets of Adler Joint Venture 1) Note Payable to Adler Joint Venture from 4301 Corporation - $7,000.00 3401 Walnut st., Harrisburg, PA as set forth in Deed Book S, Volume 51, Page 497. Stanley D. Adler, Jr. and Betty J. Adler held an undivided 1/2 interest in the property as tenants by the entirities. Deed lS attached as Exhibit 3 Value as of date of death was $174,800.00 (See exhibit 4) 25% of value representing Betty Adler's interest is $43,700.00 4001-4005 Jonestown Road, Harrisburg, PA, as set forth in Deed Book Q, Volume 51, Page 406 and Q-51-408. Stanley D. Adler, Jr. and Betty J. Adler held an undivided 1/2 interest In the property as tenants by the entirities. Deed is attached as Exhibits 5 and 6 Value as of date of death (See exhibits 7 and 8) : $414,368.00 25% of value representing Betty Adler's share - $103,592.00 315 Market Street, Harrisburg, PA See Record Book 9, Page 383, recorded 2/2/79 Stanley D. Adler, Jr. and Betty J. Adler held an undivided 1/2 interest In the property as tenants by the entirities. (Exhibit 9) Total value was 148,856.00 (See Exhibit 10) Betty Adler 1/4 interest was $37,214.00 Adler Joint Venture, continued. 1800 Columbia Ave. Lancaster, PA Deed Book S-55-57 Lancaster County, PA See Exhibit 11 Stanley D. Adler, Jr. and Betty J. Adler held an undivided 1/2 interest in the property as tenants by the entirities. Recorded 5/26/66 Total value was 176,500.00 See Exhibit 12 Betty Adler's 1/4 interest was $44,125.00 Total Value Adler Joint Venture Front street Equitv Associates Decedent had 25% interest in Partnership, Front Street Equity Associates, owns part of Park City Mall, Lancaster, PA Only the building is owned by Front Street Equity Associates, not the land. The land lS leased from a trust with M. James Spitzer and Ernest Greenberger as Trustees. See Exhibit 30A See exhibits 31 and 32 for allocation of partnership interests. The building is valued at $744,300.00 25% of this value would be $186,075.00 See Exhibit 33 for Value. Albefore Realtv Decedent owned a 45% interest in Albefore Realty, a Pa general partnership. See Exhibit 34 Albefore Realty owns 3556 Old Gettysburg Rd. Camp Hill, PA, Cumberland County, Lower Allen Township (See deed, Exhibit 35 ) Said land lS valued at $615,100.00 (See exhibit 36) $228,631.00 $186,075.00 $276,795.00 ZAL Realtv Associates $28,416.00 Decedent owned a 5% interest is ZAL Realty Associates (See exhibit 37) ZAL Realty owns the land and building described In the deed attached as exhibit 38. The property is valued at $568,320.00 (See exhibit 39) TOTAL $719,917.00 SCHEDULE "H" FUNERAL EXPENSES, ADMINISTRATIVE COSTS AND MISCELLANEOUS EXPENSES Estate of Betty J. Adler File Number 21-01-0149 ITEM NUMBER DESCRIPTION AMOUNT 1 . Funeral Expense 2 . Personal Representative $25,000.00 Commission (Estimate) 3. Attorneys' Fees $25,000.00 (Estimate) 4. Family Exemption Claimant, $3,500.00 Relationship to Deceased 5. Address of Claimant at Decedent's Death Robert Adler 2930 Arcona Rd. Mechanicsburg, PA 17011 6 . Probate Fees $360.50 7 . Advertising estate $211.26 8 . Reserve $175.00 $54,246.76 SCHEDULE I DEBTS OF DECEDENT, MORTGAGE LIABILITIES AND LIENS Estate of Betty J. Adler File Number 21-01-0149 ITEM NUMBER DESCRIPTION AMOUNT Judgment, Meridian Bank v. Stanley D. Adler and Betty J. Adler No. 95-7141, Entered in Cumberland County, PA in the amount of $1,426,000.00. 1/2 interest of Betty Adler in the debt See attached Exhibit "D-1" This debt was assigned to Huskie Portfolio, LLC, October 2001 $713,000.00 ENTERED IN CUMBERLAND COUNTY, PA PNC Bank v. Stanley D. Adler and Betty J. $2,274,070.50 Adler 3124 Civ 1991 Writ of revival entered 1/30/98 In Cumberland County, PA Total value judgment as of date of death: $4,548,141.10 1/2 interest of Betty Adler $2,274,070.50 See Exhibit D-2 Robert G. Smith, Jr. v. Stanley D. Adler, $32,254.75 Jr. and Betty J. Adler 1997-4964 Dauphin County Writ of revival from 4321 Civ 1992 filed 9/12/97 Total value judgment 64,509.50 1/2 interest 32,254.75 Bank of Hanover and Trust Co. $541,097.50 Joint debt with spouse Secured with mortgage on York Mini Mall and 2930 Arcona Road, Mechanicsburg, PA Total debt: $1,082,195.00 1/2 of debt: 541,097.50 Exhibit D-6 VNA of Central Pa $52.00 6/9/00 Skilled nursing TOTAL DEBT $3,560,474.75 SCHEDULE J BENEFICIARIES Estate of Betty J. Adler File No.21-01-0149 ITEM NUMBER NAME AND ADDRESS RELATIONSHIP AMOUNT OR OF BENEFICIARY TO DECEDENT SHARE OF ESTATE A. Taxable Bequests Robert A. Adler Child 2930 Arcona Rd. Mechanicsburg, PA 17055 Staci Smith Child 519 Castle Rd. Mount Pleasant, SC 29464 ITEM NUMBER NAME AND ADDRESS OF AMOUNT OR SHARE OF BENEFICIARY ESTATE A. Charitable and Governmental Bequests L' v .'V\'~'-J~/.:t ..../ Register of Wills of Dauphin County, Pennsylvania c INVENTORY Estate of BETTY J. ADLER No. 21-01-0149 also known as Date of Death 1 0 / 0 2 / 2 0 0 0 I Deceased Social Security No. 201-16-1582 Personal Representative(s) of the above Estate, deceased, verify that the items appearing in the following inventory include all of the personal assets wherever situate and all of the real estate in the Commonwealth of Pennsylvania of said Decedent, that the valuation placed opposite each item of said Inventory represents its fair value as of the date of the Decedent's death, and that Decedent owned no real estate outside of the Commonwealth of Pennsylvania except that which appears in a memorandum at the end of this inventory. I/We verify that the statements made in this Inventory are true and correct. I/We understand that false statements herein are made subject to the penalties of 18 Pa. C.S. Section 4904 relating to unsworn falsification to authorities. Personal Representative: Name of Attorney: WILLIAM L. ADLER, ESQUIRE ROBERT A. ADLER /#-/~~ II z- I,;. -z-- f ' C Y--c' G- c_:7J-e--- 39844 125 LOCUST STREET HARRISBURG, PA 17101 Telephone: (717) 234-3289 1.0. No.: Address: Dated Description Value SEE ATTACHED ,........ <""" ... J "-.,..1 -;; ~~~. 2 :.:0 ro c C- ~ I '...0 -0 ..t:~ .:...:.. --" Total: I, I 4 If I ~ ( 7, {) () (Attach Additional Sheets if necessary) NOTE: The Memorandum of real estate outside the Commonwealth of Pennsylvania may, at the election of the personal representative, include the value of each item, but such figures should not be extended into the total of the Inventory. RW-8 INVENTORY Estate of Betty J. Adler File Number 21-01-0149 ITEM NUMBER DESCRIPTION VALUE AT DEATH 2930 Arcona Rd. $425,000.00 Mechanicsburg, PA 17055 (See attached appraisal, exhibit 40 ) TOTAL REAL $425,000.00 ESTATE INVENTORY Estate of Betty J. Adler ITEM NUMBER DESCRIPTION File Number 21-01-0149 VALUE AT DEATH Adler Joint Venture See attached Exhibits 1 and 2, partnership agreement Betty Adler - 25% interest In partnership Assets of Adler Joint Venture 1) Note Payable to Adler Joint Venture from 4301 Corporation - $7,000.00 3401 Walnut st., Harrisburg, PA as set forth in Deed Book S, Volume 51, Page 497. Stanley D. Adler, Jr. and Betty J. Adler held an undivided 1/2 interest In the property as tenants by the entirities. Deed is attached as Exhibit 3 Value as of date of death was $174,800.00 (See exhibit 4) 25% of value representing Betty Adler's interest is $43,700.00 4001-4005 Jonestown Road, Harrisburg, PA, as set forth in Deed Book Q, Volume 51, Page 406 and Q-51-408. Stanley D. Adler, Jr. and Betty J. Adler held an undivided 1/2 interest in the property as tenants by the entirities. Deed lS attached as Exhibits 5 and 6 Value as of date of death (See exhibits 7 and 8) : $414,368.00 25% of value representing Betty Adler's share - $103,592.00 315 Market Street, Harrisburg, PA See Record Book 9, Page 383, recorded 2/2/79 Stanley D. Adler, Jr. and Betty J. Adler held an undivided 1/2 interest in the property as tenants by the entirities. (Exhibit 9) Total value was 148,856.00 (See Exhibit 10) Betty Adler 1/4 interest was $37,214.00 Adler Joint Venture, continued. 1800 Columbia Ave. Lancaster, PA Deed Book S-55-57 Lancaster County, PA See Exhibit 11 Stanley D. Adler, Jr. and Betty J. Adler held an undivided 1/2 interest in the property as tenants by the entirities. Recorded 5/26/66 Total value was 176,500.00 See Exhibit 12 Betty Adler's 1/4 interest was $44,125.00 Total Value Adler Joint Venture Front street Equitv Associates Decedent had 25% interest in Partnership, Front Street Equity Associates, owns part of Park City Mall, Lancaster, PA Only the building lS owned by Front Street Equity Associates, not the land. The land is leased from a trust with M. James Spitzer and Ernest Greenberger as Trustees. See Exhibit 30A See exhibits 31 and 32 for allocation of partnership interests. The building is valued at $744,300.00 25% of this value would be $186,075.00 See Exhibit 33 for Value. Albefore Realtv Decedent owned a 45% interest In Albefore Realty, a Pa general partnership. See Exhibit 34 Albefore Realty owns 3556 Old Gettysburg Rd. Camp Hill, PA, Cumberland County, Lower Allen Township (See deed, Exhibit 35) Said land is valued at $615,100.00 (See exhibit 36) $228,631.00 $186,075.00 $276,795.00 ZAL Realtv Associates $28,416.00 Decedent owned a 5% interest is ZAL Realty Associates (See exhibit 37) ZAL Realty owns the land and building described in the deed attached as exhibit 38. The property is valued at $568,320.00 ( See exhibit 39) TOTAL $719,917.00 ~ 114 ..."'~ - :"...~ --~""-'~ ;'~. .' PA":' ,..~ ~':'\..:' _~,,1' "'- ...../ / \ .~. .. "_1. . \' / ri . .~o;':;". ""~. E"~"'. :a..... ~ -"~~ y.. i (~ '-.J t'.~ ~. I , '~, "'v' \ "-.~~ '::J- ~ ~ - ~1) ("") ("") 0- ~ ...1 < >- 8 < ~ ~::>I- .,.. ~~ili(""')<( <--8=dZ ~~';:=3 U~50~) ~ZOcDZ aa3...Jci~ ~ t:: ~ ~ n... ~ 4. ~ (:) ...1 ~ o ~ < ~ J: ~ f.f) o o ::r: E-i ~ o o o fL1 ~('0 >"f.f)~~ E-i...:lOO z...:lOlr- OH(j)~ os: o j:i\~ ~f.f)P-I 000 Z 0'" ~~::r:~ ...:l~E-iH ~E-i~f.f) j:i\f.f)OH o:;lHOH 'Zt90~ o~ ~ o~~o o I- ~ .. v~ v STATUS REPORT UNDER RULE 6.12 Name of Decedent: Betfy T. .Adrv- Date of Death: It; / L- /O{) , Will No. -Z 5/0 I - Oc:) rf{ 'I Admin. No. 2-1 --0(-- Orttf Pursuant to Rule 6.12 of the Supreme Court Orphans' Court Rules, I report the following with respect to completion of the administration of the above-captioned estate: 1. State whether administration of the estate is complete: Yes No ~ 2. If the answer is No, state when the personal representative reasonably believes that the administration will be complete: '- &/0 7 3. If the answer to No.1 is Yes, state the following: a. Did the personal representative file a final account with the Court? Yes No b. The separate Orphans' Court No. (if any) for the personal representative's account is: c. Did the personal representative state an account informally to the parties in interest? Yes No d. Copies of receipts, releases, joinders and approvals of formal or informal accounts may be filed with the Cerk of the Orphans' Court and may be attached to this report. Date: 1/1 % z- W~~~ Signature UJ;'(I,~~ L. .A//~ Name (Please type or print) f ""l- 7 L~ ~ 41 '-'1' ff-{" ~ 4 Address ( 7 17 ) 'Z- ':> V ~ -Z-q ? Te 1. No. (MAH:rmf/AM3) Capacity: Personal Representative ~Counsel for personal representative ,. Cumberland County - Register Of Wills Hanover and High Street Carlisle, PA 17013 Phone: (71 7) 240 - 6345 ~ Date: 9/04/2002 ROBERT A ADLER 2930 ARCONA ROAD MECHANICSBURG, PA 17055 RE: Estate of ADLER BETTY J Pile Number: 2001-00149 Dear Sir/Madam: It has come to my attention that you have not filed the Status Report by Personal Representative (Rule 6.12) in the above captioned estate. As per the AMENDMENTS TO SUPREME COURT ORPHANS' COURT RULES, NO. 103 SUPREME COURT RULES DOCKET NO. I, for decedents dying on or after July I, 1992, the personal representative or his counsel, within two (2) years of the decedent's death, shall file with the Register of Wills a Status Report of completed or uncompleted administration. This filing will become delinquent on: 10/02/2002 Your prompt attention to this matter will be appreciated. Thank You. Sincerely, ~ /ll6&-r4- 44Jtw MARY C. LEWIS ~ ~. REGISTER OP WILLS & cc: .IPile Counsel Judge Register of Wills of Cumberland County STATUS REPORT UNDER RULE 6.12 Name of Decedent: 13~~ T. AiJ~ lOr ..diU! 'ZO[; I ~ O()/ Y q Date of Death: Estate No.: Pursuant to Rule 6.12 of the Supreme Court Orphans' Court Rules, I report the following with respect to completion of the administration of the above-captioned estate: 1. State whether administration of the estate is complete: Yes 0 No ~ 2. lfthe answer is No, state when the personal representative reasonably believes that the administration w11l be complete: r '(~I a .r-?7 3. If the answer to No.1 is Yes, state the following: a. Did the personal representative file a final account with the Court? Yes 0 No 0 b. The separate Orphans' Court No. (if any) for the personal representative's account is: c. Did the personal representative state an account informally to the parties in interest? Yes 0 No 0 Date: c. Copies of receipts, releases, joinders and approval of formal or informal accounts may be filed with the Clerk of the Orphans' Court and may be / / attached to this report..q /. '. /) ff 1I1? r1 (U /7-;./(~ ( ~ (/{ /~~ W_-t/t(.k / i---" Signature UI;(/,~ VVl M(~./'- Name Address ! '2:-- c..- L:.,: G <- / ?;;> f II/i) ;' L/ "7 ----,. c:2 J.07'., -- --=s I- ~~> c/ . ( ):) "/ /:>1- j '~.J Telephone No. " i i Capacity: 0 Personal Representative 9 Counsel for personal representative \ <1 Cumberland County - Register Of Wills One Courthouse Square Carlisle, PA 17013 Phone: (717) 240-6345 Date: 9/14/2006 ADLER WILLIAM L 125 LOCUST STREET PO BOX 11933 HARRISBURG, PA 17108 RE: Estate of ADLER BETTY J File Number: 2001-00149 Dear Sir/Madam: This notice is to serve as a reminder that the Status Report by Personal Representative under Rule 6.12 is due on the below listed date. As per the AMENDMENTS TO SUPREME COURT ORPHANS' COURT RULES, NO. 103 SUPREME COURT RULES DOCKET NO. I, for decedents dying on or after July I, 1992, the personal representative or his counsel, within two (2) years of the decedent's death, shall file with the Register of Wills a Status Report of completed or uncompleted administration. This filing is due by: 10/02/2006 Please feel free to contact this office with any questions you may have. If you have already filed your Status Report, please disregard this notice. Sincerely, ~ :;t;WJu&;;4~/ML Glenda Farner Strasbaugh Clerk of the Orphans' Court cc: File Personal Representative(s) 1'-1 ,,. .. [: y. I i if; ~ j ~_ELJb,-~LA"~- :()JkJ(2cL~~- ~-~~~~ kJ2{Z".,J........=-_f:Z.!.Z,.,....~..~'i,.......,' ..,_.___~,.'..._. 1 ,estD Ie " the aIE\VCr to No, J is acc()-u.nl is: c. to this -ILI.<A tl~~ ~__JdLi/ {t.< VV\. Ai/e-el_ j .~. i;1- (c' CA:/~ i' ~ T' .. LtL<:'::J:.f~ /''''9.-~e~. LZLflj .,..,.,..,__.-:1,l..J",-~:"..~"~'t__:.:,',.'?.~~L..,.. Datt ~1.1~5 'n () c_ C' \-J Cumberland County - Register Of Wills One Courthouse Square Carlisle, PA 17013 Phone: (717) 240-6345 Date: 9/15/2005 ADLER WILLIAM L 125 LOCUST STREET PO BOX 11933 HARRISBURG, PA 17108 RE: Estate of ADLER BETTY J File Number: 2001-00149 Dear Sir/Madam: It has corne to my attention that you have not filed the Status Report by Personal Representative (Rule 6.12) in the above captioned estate. As per the AMENDMENTS TO SUPREME COURT ORPHANS' COURT RULES, NO. 103 SUPREME COURT RULES DOCKET NO.1, for decedents dying on or after July 1, 1992, the personal representative or his counsel, within two (2) years of the decedent's death, shall file with the Register of Wills a Status Report of completed or uncompleted administration. This filing is due by: 10/02/2005 Your prompt attention to this matter will be appreciated. Thank You. Sincerely, e ~ ,. ~ ~L~&/J~~/,e I / I:j' GLENDA FARNER STRASBAUGH REGISTER OF WILLS cc: File Personal Representative(s) Judge \- DO~f\~\'^-"\~ Name of Decedent: STATUS REPORT UNDER RULE 6.12 ,~;e4:hr . T AJie-;- iu /-z-/~ t7 Date of Death: Will No.: 7, I -v ( - (J f t( V, Admin. No.: Pursuant to Rule 6.12 of the Suprelne Court Orphans' Comi Rules, I report the following with respect to completion of the administration of the above-captioned estate: 1, State whether administration of the estate is complete: Yes 0 No .EJ 2. If the answer is No, state when the personal representative reasonably believes that the administration will be cOlnplete: .z,.~ (P 3. lithe answer to No.1 is Yes, state the following: a. Did the personal representative file a final account with the Court? Yes No 0 b. The separate Orphans' Couli No. (if any) for the personal representative's account is: c. Did the personal representative state an account informally to the parties in interest? Yes 0 NoD Date: c. Copies of receipts, releases, joinders and approval of formal or infonnal accounts may be filed with the Clerk of the Orphans' Court and may be attached to this report. .. lV} 1~ !l-dt~ - SIgnature Li// I(r~ ,,,^ u/~ Name Pd. ~~ 1(6/ s?? JL-6'7 Address "'/ .v?l(?;2~9 Telephone No. / Capacity: n Perso Representative ounsel for personal representative Cumberland County - Register Of Wills One Courthouse Square Carlisle, PA 17013 Phone:(717) 240-6345 D<~te: 9/11/2008 ADLER WILLIAM L 125 LOCUST STREET PO BOX 11933 HARRISBURG, PA 17108 R:E: Estate of ADLER BETTY J File Number: 2001-00149 Dear Sir/Madam: ~,~ ~._, _ _. ~~ C.~ ..~,~ _ C/) '~_~ -.. r 1 `°~3 r _n _. , . ___ ~.., _ _ . _ - _~ ,. ;~ <_ ~ ~ _ , _> ~ _~ - }- ~,. cn This notice is to serve as a reminder that the Status Report by Personal Representative under Rule 6.12 is due on the below listed date. As per the AMENDMENTS TO SUPREME COURT ORPHANS' COURT RULES, N0. 103 SUPREME COURT RULES DOCKET NO. 1, for decedents dying on or after July 1, 1992, the personal representative or his counsel, within two (2) years of the decedent's death, shall file with the Register of Wills a Status Report of completed or uncompleted administration. This filing is due by: 10/02/2008 Please feel free to contact this office with any questions you may - -- have. If you have='already filed your `Status `Report, please disregard this notice. Sincerely, ~~~~a Glenda Farner Strasbaug Clerk of the Orphans' Court c;c : File Personal Representative(s) Cumberland County - Register Of Wills One Courthouse Square Carlisle, PA 17013 Phone:(717) 240-6345 D<~te: 9/11/2008 ROBERT A ADLER 2930 ARCONA ROAD MECHANICSBURG, PA 17055 RE: Estate of ADLER BETTY J File Number: 2001-00149 Dear Sir/Madam: C~ N `_ - C~ ,. `, ' ,~ -m1 ; T.> ,' ' ~ ~ :: ~ ~ ~ !_-1 ..~ f._ _ ~> -~ !~ - , l- .c: c~ Tlzis notice is to serve as a reminder that the Status Report by Personal Representative under Rule 6.12 is due on the below listed date. A:~ per the AMENDMENTS TO SUPREME COURT ORPHANS' COURT RULES, N0. 103 SiJPREME COURT RULES DOCKET N0. 1, for decedents dying on or after July 1, 1992, the personal representative or his counsel, within two (2) years of the decedent's death, shall file with the Register of Walls a Status Report of completed or uncompleted administration. This filing is due by: 10/02/2008 Please feel free to contact this office with any questions you may have. If: you have already filed your Status--.Report, please disregard this notice. Sincerely, l.~~i~~~i~'~4~b Glenda Farner Strasbaugh Clerk of the Orphans' Court cc: File Counsel Cumberland County - Register Of Wills One Courthouse Square Carlisle, PA 17013 Phone:(717) 240-6345 Date: 9/11/2008 PAUL J KILLION r7 ~:.C~ c~ 545 SOUTH THIRD STREET ~ -~ r ~, s-. ~ f -.. L EMOYNE , PA 17 0 4 3 w ,--~ __,_ _:,~ 1 f -- _.~ -, Y__ i ~` j ~~ _~.~ - `~ _~" RE: Estate of ADLER BETTY J Q1 File Number: 2001-00149 Dear Sir/Madam: This notice is to serve as a reminder that the Status Report by Personal Representative under Rule 6.12 is due on the below listed date. As per the AMENDMENTS TO SUPREME COURT ORPHANS' COURT RULES, N0. 103 SUPREME COURT RULES DOCKET N0. 1, for decedents dying on or after July 1, 1992, the personal representative or his counsel, within two (2) years of the decedent's death, shall file with the Register of Wills a Status Report of completed or uncompleted administration. This filing is due by: 10/02/2008 Please feel free to contact this office with any questions you may --.have . I f you have--- already.-=fx~ed--yo-u~=Sto-tus ==i~~ao~=t-, p=l~a~e-~l~~regard ___ this notice. Sincerely, ~~~~~Z~ Glenda Farner Strasbaugh Clerk of the Orphans' Court cc: File Counsel "'~'~ I:e;;i~trr• uf~\~ ills ~at~~~unll~erl~u~cl Cc>uni~ _ _ ~ .' _ ~~'4'~ :o` r1 _ _ _ _ __ tfc? ~;, ~ ~~ ,P_. ~ry(l~ 1~~ iC~ S.Nb~Nd~O 9 I ~ ! I«?d L I d~S ~~~ Cumberland County - Register Of Wills One Courthouse Square Carlisle, PA 17013 Phone:(717) 240-6345 Date: 9/21/2009 ~'~' :~ fix? , - ~ ~~~ ADLER WILLIAM L ~~~ ~ -v ~'~``-~ z~~ -~' 125 LOCUST STREET ~ ~' i ~ 7 PO BOX 11933 ;~ ~ ? z HARRISBURG, PA 17108 ~~~ ~ ~ = ~..,~ ` ~ K_~ > p ' ~ ~' ~_rn r i ' ~ GJ1 fiV.. > : RE: Estate of ADLER BETTY J File Number: 2001-00149 Dear Sir/Madam: This notice is to serve as a reminder that the Status Report by Personal Representative under Rule 6.12 is due on the below listed date. As per the AMENDMENTS TO SUPREME COURT ORPHANS' COURT RULES, NO. 103 SUPREME COURT RULES DOCKET NO. 1, for decedents dying on or after July 1, 1992, the personal representative or his counsel, within two (2) years of the decedent's death, shall file with the Register of Wills a Status Report of completed or uncompleted administration. This filing is due by: 10/02/2009 Please feel free to contact this office with any questions you may have. If you have already filed your Status Report, please disregard this notice. Sincerely, /~I.~~~~ifGGLfOKJiV~Nir4~ Gle nda Farner Strasbaugh Clerk of the Orphans' Court cc: File Personal Representative(s) Cumberland County - Register Of Wills One Courthouse Square Carlisle, PA 17013 Phone: (717) 240-6345 Date: 9/21/2009 ROBERT A ADLER rya 2930 ARCONA ROAD n ~~ ~ ~ -~'. ~,t;;> MECHANICSBURG, PA 17055 i;i~~ 'o ~'_'~^ c.. ' .7 w N rt ~ i7 V~~ ~:'CJ f-1nQ ~7~T1 Q ~ _;.~..~ _ _.91 n:~" ~ ~ ~ O .. r` r°n 7 i RE: Estate of ADLER BETTY J ~ N , File Number: 2001-00149 Dear Sir/Madam: This notice is to serve as a reminder that the Status Report by Personal Representative under Rule 6.12 is due on the below listed date. As per the AMENDMENTS TO SUPREME COURT ORPHANS' COURT RULES, N0. 103 SUPREME COURT RULES DOCKET NO. 1, for decedents dying on or after July 1, 1992, the personal representative or his counsel, within two (2) years of the decedent's death, shall file with the Register of Wills a Status Report of completed or uncompleted administration. This filing is due by: 10/02/2009 Please feel free to contact this office with any questions you may have. If you have already filed your Status Report, please disregard this notice. Sincere/ Glenda Farner Strasbau h Clerk of the Orphans' Court cc: File Counsel Cumberland County - Register Of Wills One Courthouse Square Carlisle, PA 17013 Phone: (717) 240-6345 Date: 9/21/2009 PAUL J KILLION 545 SOUTH THIRD STREET ~ N o ~ ::-3 LEMOYNE, PA 17043 ' ~-~ to rr~+'~ ~ ~'*+ u,, c _~ ~ f~' i . L~ 'O N G i :'Cl , C:J ~ Q RE: Estate of ADLER BETTY J ~ ~ y ~ r' r File Number: 2001-00149 ~ ~,> r-a ° ro Dear Sir/Madam: This notice is to serve as a reminder that the Status Report by Personal Representative under Rule 6.12 is due on the below listed date. As per the AMENDMENTS TO SUPREME COURT ORPHANS' COURT RULES, N0. 103 SUPREME COURT RULES DOCKET NO. 1, for decedents dying on or after July 1, 1992, the personal representative or his counsel, within two (2) years of the decedent's death, shall file with the Register of Wills a Status Report of completed or uncompleted administration. This filing is due by: 10/02/2009 Please feel free to contact this office with any questions you may have. If you have already filed your Status Report, please disregard this notice. Sincerely, Glenda Farner Strasbaugh Clerk of the Orphans' Court cc: File Counsel Pa. O.C. Rule 6.12 STATUS REPORT Name of Date ofDeath:_ /O~ Dl~ __ FileNumber:_7~~ -~Q/ ~ 9 Pursuant to Pa. O.C. Rule 6.12, I report the following with respect to completion of the administration of the above-captioned estate: I . State whether administration of the estate is complete :.................... ~ Yes .~'No 2. If the answer is No, state when the personal representative reasonably believes that the administration will be complete: 3. If the answer to No. I is YES, state the following: a. Did the personal representative file a final account with the Court? ....... Yes ~No b. The separate Orphans' Court No. (if any) for the personal representative's account is: c. Did the personal representative state an account informally to the pazties in interest? ............ DYes ~ No ................... d. Copies of receipts, releases, joinders and approvals of formal or informal accounts maybe filed with the Clerk of the Orphans' Court and may be attached t this report. Drtte ~ o i\/1i Signnnrre o~Person Filing (hit Farm try Capacity: ©Personal Representative ~unsel i .. ¢ a /~ r _, ~_ ~ G"r ~_- Q ~OV L Nmne ojPerton F~hng lhrs Form / L ~ i ~' y / _ ~. ~ _J N W~ ' Address ~, ~, ~ ~; / r 7 O r r~ o 0 o ` N 7 r 7- ~4 3Z~~ Telephone REGISTER OF `VICES OF t'iyw~. ~ COUNTY, PENNSYLVANIA _ _ _ _ _ , ,. Cumberland County - ke~ister O~ Wills One Courthouse Square Carlisle, PA 17013 Phone : (717 ) 2 4 0 - 6 3 4 5 ~w !`(+F~ 1~~? ~ `EFL=fit ~~ (fit '"?C~4~~ s C~f ~~ #~~4 .~: ZQIO SEP 23 PM IZ= 10~' CLERK o~ ORPHAN'S COURT Date: 9/22/2010 Ct1MEEf?~,~D '~., ~'~~ ADLER WILLIAM L 125 LOCUST STREET PO BOX 11933 HARRISBURG, PA 17108 RE: Estate of ADLER BETTY J File Number: 2001-00149 Dear Sir/Madam: ', This notice is to serve as a reminder that the Status Repo~~ by Personal Representative under Rule 6.12 is due on the belo, listed date. As per the AMENDMENTS TO SUPREME COURT ORPHANS' COURT RULE, N0. 103 SUPREME COURT RULES DOCKET NO. 1, for decedents dying on o~ after July 1, 1992, the personal representative or his counsel, ithin two (2) years of the decedent's death, shall file with the Reg ster of Wills a Status Report of completed or uncompleted administ ation. This filing is due by: 10/02/2010 Please feel free to contact this office with any questionslyou may have. If you have already filed your Status Report, pleas disregard this notice. Sincerely, ,- ~/N~C.~ F Glenda Farner Stras~augh Clerk of the Orphans' Court cc: File ~ Personal Representative(s) Cumberland County - register` Of One Courthouse Square Carlisle, PA 17013 Phone:(717) 240-6345 Date: 9/22/2010 ROBERT A ADLER 2930 ARCONA ROAD MECHANICSBURG, PA 17055 RE: Estate of ADLER BETTY J File Number: 2001-00149 Dear Sir/Madam: Wi11s ~ (, }'' ~~f ~~~My'++ iii±~i (~ 2QiQ SEP 23 r M !~M ! 0 CLERK OF oR~lv~s cau ~ cuM~r_-R~.,~~~ ~ PA. I This notice is to serve as a reminder that the Status Rep rt by Personal Representative under Rule 6.12 is due on the bel~w listed date. As per the AMENDMENTS TO SUPREME COURT ORPHANS' COURT R~7LIS, NO. 103 SUPREME COURT RULES DOCKET NO. 1, for decedents dying oM r after July 1, 1992, the personal representative or his counsel, within two (2) years of the decedent's death, shall file with the I~e~ister of Wills a Status Report of completed or uncompleted adminis ration. This filing is due by: 10/02/2010 i Please feel free to contact this office with any questio ~s you may have. If you have already filed your Status Report, please disregard this notice. Sincerely, ,~/ ~:,~ I Glenda Farner Str ~baugh Clerk of the Orgh r~s' Court i cc: File I Counsel I I -. _ Cumberland County - Register 0~ Wills ~.7_l-`" One Courthouse Square Carlisle, PA 17013 Phone: (717) 240-6345 ~~-,~ ~~ Date: 9/22/2010 PAUL J KILLION 545 SOUTH THIRD STREET LEMOYNE, FA 17043 RE: Estate of ADLER BETTY J File Number: 2001-00149 Dear Sir/Madam: irlj~ l C~f f..,~ ~t3~ ~ r J "~ 1,~~ 2aIQ SAP 23 ~~112= t ~ CLERK F ~~W'S t~C~JRT CUMBFRLAflID ~~..,C , PA. I This notice is to serve as a reminder that the Status Repojrt by Personal Representative under Rule 6.12 is due on the be~o~d listed date. As per the AMENDMENTS TO SUPREME COURT ORPHANS' COURT RUL ~, N0. 103 SUPREME COURT RULES DOCKET NO. 1, for decedents dying on' r after July 1, 1992, the personal representative or his counsel, within two (2) years of the decedent's death, shall file with the R~e~ister of Wills a Status Report of completed or uncompleted admini t$ration. This filing is due by: 10/02/2010 Please feel free to contact this office with any question you may have. If you have already filed your Status Report, plea ~ disregard this notice. Sincerely, Glenda Farner St~z Clerk of the Orphe F Hugh ' Court cc: File Counsel itECISTEi:I:F 1^i'a' LS Gr ~v~,Ot~i~CQU:vTi', P:'•;?,;SY'i''-`':~.~:?. 1`i3nle GI DeCed Zr?t: Date o: n°atll:____ ~ ~ Z ~ File i`;ur::beT° 7~O,L._'d ~ ~' 1_ airJUallt 4n D f i (' D,.le i. 1~ T ~~~.~;t t `~ {~11:~1sn r.O t:;'tth r~Cn~:~, in nrrr r_,'2`,ir.l f!f tll~ ~.11.~i1~?i1113t!'3tl l~l? O1 file above-captioned estate: 1. Stag whether administration of the estate is complete: ................... . 2. if the ans~veris V'o, state when the personal representative reasonably L-elieves t hat the adrninistratiorzvill be con;ple~s: c'es .~1~~ 3. If the ai?s:ver to I~'o.. l is YES, state ti~?e followinj: - ~! ~ c ~~ r ' ' F ~ ,~No z. Did the personal repre.,enlat:ve >.r.e a f..~al~accel.~nt with th.. Court_ .... , .. es b. The separate Orphans' Court No. (if any) for tl:e personal • '~, ', representative's account is: ~ II ', -- II -- c. Did the personal representative state an account informally to the parties in it?teresi? .:............................. ~ ~~.'es ~ No II' d. Copies of receipts, releases, joinders and approvals of forTr121 or informal acc I u is may L-e filed with the Clerk of the Orphan,' Court and rrlay be at.ached to this report. o~,e Z~ ~Q S(gner.:: t of ?er;a, ili,:g tiii; f•'orm ~- O ~- ~ Capacity: QPerso::al Representative ounsc] -.. ~_, , __ ~ ~~ - ~_ L~ ~,QC~ :`~.^.,^e of?erson Fili,:g l:it ror,ir _J C; 7-~ N CC - ~ ,( - - __ r ~~~~ ~.ic'rest Obi 3HtHSN 6ti6ti -_ h V E-'~c~1.7~ ~..~ reit;.;wne ~ I I 1 •_ Pa. O.C. Rule 6.12 STATUS REPORT REGISTER OF WILLS OF ~~~^^ ~'~~~a r~,~/ COUNTY, PENNSYLVANIA Name of Decedent: ~~~ Date of Death: /U ~.~ File Number: ~lJ~~ ~ /~~,~~,~ Pursuant to Pa. O.C. Rule 6.12, I report the following with respect to completion of the administration of the above-captioned estate: 1. State whether administration of the estate is complete :.................... ^Yes ~To 1. If the answer is No, state when the personal representative reasonably believes that the administration will be complete: S v ~~ 3. If the answer to No. 1 is YES, state the following: a. Did the personal representative file a final account with the Court? ....... ^Yes ~] No b. The separate Orphans' Court No. (if any) for the personal representative's account is: c. Did the personal representative state an account informally to the parties in interest? ............................... ^Yes ^ No d. Copies of receipts, releases, joinders and approvals of formal or informal accounts may be filed with the Clerk of the Orphans' Court and may be attached to this report:. ,- ~ ~ ~ - Date _ Signature of Person Filing Ihls Form Capacity: ^Personal Representative ,Counsel . ~,:. "_ _._ ._~ti r~~_. ~. _' l.Ll r_.'. _.. ~. ,_ F. - c ~f cF- ~`,. ~~. --- U Form RW-l0 rev. l0.13.06 Nance ojPerson t r 4949 DEVONSHIRE RD /t (lll7'eSS ~ ~s~~ ~9~~ Telephone Cumberland County - Register Of Wills One Courthouse Square Carlisle, PA 17013 Phone:(7i.7) 240-6345 Date: 9/08/2011 ADLER WILLIAM L 4949 DEVONSHIRE RD HARRISBURG, PA 17109 RE: Estate of ADLER BETTY J File Number: 2001-00149 Dear Sir/Madam: This notice is to serve as a reminder that the Status Report by Personal Representative under Rule 6.12 is due on the below listed date. As per the AMENDMENTS TO SUPREME COURT ORPHANS' COURT RULES, N0. 103 SUPREME COURT RULES DOCKET NO. 1, for decedents dying on or after July 1, 1992, the personal representative or his counsel, within two (2) years of the decedent's death, shall file with the Register of Wills a Status Report of completed or uncompleted administration. This filing is due by: 10/02/2011 Please feel free to contact this office with any questions you may have. If you have already filed your Status Report, please disregard this notice. Sincerely, ~~ ",'f '~-/...S~~Ft4~!//Vi :.U>"V ~~m "Cri.nv.^m/..-. .- Glenda Farner Strasb~u'gh Clerk of the Orphans' Court cc: File Personal Representative(s) Cumberland County - Register Of Wills One Courthouse Square Carlisle, PA 17013 Phone:(717) 240-6345 7 _~~ -~ Date: 9/08/2011 " . -,= ,- ~ - , rr i _. --.-.7 r;~.. ROBERT A ADLER ~~ ,~- _. 2930 ARCONA ROAD _ - - - --. MECHANICSBURG, PA 17055 =~~ -- - ~-; ~ RE: Estate of ADLER BETTY J File Number: 2001-00149 Dear Sir/Madam: This notice is to serve as a reminder that the Status Report by Personal Representative under Rule 6.12 is due on the below listed date. As per the AMENDMENTS TO SUPREME COURT ORPHANS' COURT RULES, N0. 103 SUPREME COURT RULES DOCKET NO. 1, for decedents dying on or after July 1, 1992, the personal representative or his counsel, within two (2) years of the decedent's death, shall file with the Register of Wills a Status Report of completed or uncompleted administration. This filing is due by: 10/02/2011 Please feel free to contact this office with any questions you may have. If you have already filed your Status Report, please disregard this notice. Sincerely, Glenda Farner Strasbaug~ Clerk of the Orphans' Court cc: File Counsel Cumberland County - Register Of Wills One Courthouse Square Carlisle, PA 17013 Phone: (717) 240-6345 c ~ _,-: _- ~. -~ ~-~ - - _,_ Date: 9/08/2011 ~-'~~ _ _ ,, ~; PAUL J KILLION _:. ~ . _~ 545 SOUTH THIRD STREET ~' ;_.~> `_ ; LEMOYNE, PA 17043 '' _. '' RE: Estate of ADLER BETTY J File Number: 2001-00149 Dear Sir/Madam: This notice is to serve as a reminder that the Status Report by Personal Representative under Rule 6.12 is due on the below listed date. As per the AMENDMENTS TO SUPREME COURT ORPHANS' COURT RULES, N0. 103 SUPREME COURT RULES DOCKET NO. 1, for decedents dying on or after July 1, 1992, the personal representative or his counsel, within two (2) years of the decedent's death, shall file with the Register of Wills a Status Report of completed or uncompleted administration. This filing is due by: 10/02/2011 Please feel free to contact this office with any questions you may have. If you have already filed your Status Report, please disregard this notice. Sincerely, Glenda Farner Strasbau Clerk of the Orphans' Court cc: File Counsel Cumberland County - Register Of Wills One Courthouse Square Carlisle, PA 17013 Phone:(717) 240-6345 ,...., ~ ~; ~~ ~ o ~ -~1 -,-'~ , c, ~ ~ ; ~~ Date: 9/17/2012 ~~ ~ ~, ' , ~A , . ROBERT A ADLER "' - ~%~-; , ~,, { _, - ; , C7 C' - 2 9 3 0 ARCONA ROAD o =~ -,' C? ~-- rr' MECN_ANICSBURG, PA 17055 A ~ `~ RE: Estate of ADLER BETTY J File Number: 2001-00149 Dear Sir/Madam: This notice is to serve as a reminder that the Status Report by Personal Representative under Rule 6.12 is due on the below listed date. As per the AMENDMENTS TO SUPREME COURT ORPHANS' COURT RULES, N0. 103 SUPREME COURT RULES DOCKET NO. 1, for decedents dying on or after July 1, 1992, the personal representative or his counsel, within two (2) years of the decedent's death, shall file with the Register of Wills a Status Report of completed or uncompleted administration. This filing is due by: 10/02/2012 Please feel free to contact this office with any questions you may have. If you have already filed your Status Report, please disregard this notice. Sincerely, `~ ~ '~ ~iLrl~/~ l Glenda Farner Strasbaugh Clerk of the Orphans' Court cc: File Counsel Cumberland County - Register Of Wills One Courthouse Square Carlisle, PA 17013 Phone:(717) 240-6345 C'7 t~~Q CC7 "C7 ~3 w` r ~~~; Date: 9/17/2012 ~~~' ~C-.,, C7 ~~~ PAUL J KILLION a~-- ~~~ 545 SOUTH THIRD STREET LEMOYNE, PA 17043 RE: Estate of ADLER BETTY J File Number: 2001-00149 Dear Sir/Madam: .~:, 4 N --x_;1 ""C1 c::^ ~ .~ 7 ~} ~, z~ ~' ~; w `n ~~,, This notice is to serve as a reminder that the Status Report by Personal Representative under Rule 6.12 is due on the below listed date. As per the AMENDMENTS TO SUPREME COURT ORPHANS' COURT RULES, N0. 103 SUPREME COURT RULES DOCKET NO. 1, for decedents dying on or after July 1, 1992, the personal representative or his counsel, within two (2) years of the decedent's death, shall file with the Register of Wills a Status Report of completed or uncompleted administration. This filing is due by: 10/02/2012 Please feel free to contact this office with any questions you may have. If you have already filed your Status Report, please disregard this notice. Sincerely, Glenda Farner Strasbaugh Clerk of the Orphans' Court cc: File Counsel Cumberland County - Register Of Wills One Courthouse Square Carlisle, PA 17013 Phone:(717) 240-6345 Y•s.,Y O '~ -~) ~1 I"''IT!~ ~ C'_^. 47 Date : 9/17/2012 ~ -.~. ,~,~ ; f- ~ ~.> . METZ JOSEPH U ~E-~ _ CSC; . _ 112 MARKET STREET ~~ ~~ c~ -- ; n ~-~~ ~` 8TH FLOOR ~ ^' ~-~~ HARRISBURG, PA 17101 ~ „ ~ -- , RE: Estate of WERTZ KENNETH R File Number: 2002-01127 Dear Sir/Madam: This notice is to serve as a reminder that the Status Report by Personal Representative under Rule 6.12 is due on the below listed date. As per the AMENDMENTS TO SUPREME COURT ORPHANS' COURT RULES, N0. 103 SUPREME COURT RULES DOCKET NO. 1, for decedents dying on or after July 1, 1992, the personal representative or his counsel, within two (2) years of the decedent's death, shall file with the Register of Wills a Status Report of completed or uncompleted administration. This filing is due by: 10/14/2012 Please feel free to contact this office with any questions you may have. If you have already filed your Status Report, please disregard this notice. Sincerely, Glenda Farner Strasbaugh Clerk of the Orphans' Court cc: File Personal Representative(s) Pa. O.C• Rule 6.12 STATUS REPpRT REGISTER OF WILLS OF ~"'"" ~`~' COUNTY, PENNSYLVANIA Name Date Pursuant. to Pa. O.C. Rule 6. l2, I report the following with respect to completion of the administration of the above-captioned estate: 2. If the answer is No, state when the personal representative reasonably believes that the administration will be complete: 3. If the answer to No. 1 is YES, state the following: 1. State ~~hether administration. ofthe estate is complete :.... . ............... ^Yes ~ No ~ ~ a. Did the personal representative file a final account with the Court? ....... ^Yes .~N° b. The separate Orphans' Court No. (if any) for the personal representative's account. is: c. Did the personal. representative state an account informally to the parties in interest? ............................... ^Yes ^ No File Number: U -~~'"'~' ~ `/~G'/ ~~ d. Copies of receipts, releases, joinders and approvals of formal or informal accounts maybe filed with the Clerk of the Orphans' Court and may be attached to this report. 9/19!12 William L. Adler tare Signature ojPersvn Filing thin Form Capacity: ^Personal Representative ,~ounsel ~j ~~ N ,, .. t~~.ij~~_ ~ Z ~~--' 4.. .3 aL ~.Y~ ~~ N ~~ ~ N i~ r"r t +.9 ~. ~ ~o J _ll~ 6 a _,~~ Nnme ojPerson r , x949 OEV~NSHIRE RD Addras ~ ~~z~9' Telephone Fornrr Rlf'-!Q rc». 10.I3.f16 i �'a. O.C. Rule G,12 STATUS R�T'OTtT ; 'REGISTGR OF�VILL$ Ol��'�•u U�la.ri,A/ . COU�TY,PL-\�SYLVAN(t\ �ame o(D'eceUenti �r�T��/1(.�ei�' . _ 1 � , 'Dato of'Deatls; a fJ.O. File'ri�mbcF. �!� / /��f.�_, ; r '' 'Pursuant to Pa. O.C. Rulc b.12,1'repoK flic followinS�vilh resnect to conipletion ofthe admii�istiation of ' i I the aboi�e-captioned esial,c: " ; i � , � � 1. State whetl�er a�minislration o(ihe estaie is completc: . . . : . . . : ... . . . . .. . .. . �Ycs. GKi �'o 3. 'lf ihe ans�t�er is No; `si5fc when thc personal represCniative � � , reasonaUly Uclicbes that thc adniinisiraiion will be complcic: _ . __. S Y � , ... _. ; ' �_ lf the anstvcr to\ro. 1 is YGS, statc lhc follo�Jing: a. Did fhe personai represcnfativ.e fiVe a 6na1 ascouril �witli tlic Couri? . . . . . . . ❑1'es , \o � ( � '; b, Thc scpamtc Orphans'Courl�Jo, (ifanj�) for lhc personal � I representatiac"s accou�u is: � � c. D'ii1 ihe pe'rsomi �cprescntativc state an accoimf i 'iiiforniall��to thc parties in interest? . :. . :, . . :�. . . . .. . . . . . . ... . .. . ... .: .�Yes �A?o i d. Copics of reacipts, rcicascs,joinders and nNpiovals of fon»al or ii�Connal accounts may be � Gled wfth the Clerk of thc Orphans' Court nnd maybe attachccl to tl�is report._ William L..Adler ' - -- - - - -- i Unm �.i a� lL - � ,/ ✓Q -- S�Gnrt�ure ofPerton FJmg It�t honn . �� o �n F a i �, � � v � � = o Capaciry: �QPcrsonal Reprcscmati��e �w�scl � i � ' � � � oUC> + I ' ' O O Y . Z jYnq�Ce�/'erran � ^' . r , I W w � w � � 4949 'DEVONSHIRE RD� I ��� � A �. �—+ � � � �i<<�r.�u , , 9 � � y . U 2 W i , a � W � o � _ + ! � � = = C.S � � °o, �. . } ,� U . .Trlephunt f 'i . 1 I � �fidrmR)t'-10 rcv../0./3.OG ,,.. '.... ; � �I � _ _—'__— __ ��� � ? I �: � � ?�. li.r. i Li: i,.i� 5�rci j�::.:,T.'i'�=:! �i � . P.iQfST"c?:l'�:Prii.LSG� Cv+u,�i�rrie•.�( CD��:iT'i'.;`�:v?�5Y�`:P.�?n �;mr,:at De:ed:; �'�a... ��r—"��/� -�� -- - � �=:t e:�:.��,:�r y o o �_ � zo� o� � Y�� _ r� •x�,:-�z- /- .L,— � iu�ouY.i:i'v7'.r'.v. ::���.��� I�_ .y�t�� itll_.�qi�.� �::� .if.1 ;,�I•i. � f�� ?• � :i " � � �l`.: . k:� �va-+. O?: '7 ? l:i_6niliSli.:.J00i i (i:G e(10Yf•C0rII0llC4�LSC2{L: � . � �. �lEi=S'.'�i:I�f : 11:5!i2i: , � 1 i i2�!S I '.:i O�fil:G:�.vt IS COli7D�::E: .............. ... ... ❑Y t5 ,�f�'C I _. li A:e xa's�,vec is;�o,sta:c wi!cn iir rc:;eczl rcpr_s:;:;x,E�e � 4 � r.=_;e;.ablq b:lie:cs ti�:,Ete zd�ninissation�ci11 be co::rl:::: , � F y /� • • I r �• LU� ./ � � I � -. �l ipt 2!ISWCi��]1:0. ] Ii}C��51?i:L�1'_!Jl�OI'+lC�y: , • �. �ICQi=�'.{ciJf:::�Ctvi.5C:i701iYC!!}J'a:f?t?I2[C6lliiCicj:ii��CCG7!il ....'... JY'.S L1�0 ' I� b. 7hc sepa;ata O�pl:ans'Couri t�o.(i�an;)fo;.ihc pr;:a;ci re�usc»,zrv.'s aeeour.t is: � ' � � . . . �� c. ���Q�c�;2i5G!li.j IE�^,p:.iqi!]t11'_<_i!t_7tl L^c0'ditt I' . 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U � � � m ��.,�._ , ° � �(J=6S Z - k''.�� � � � � � Cumberland County - Register Of Wills One Courthouse Square-- y Carlisle_ PA nr-FICE OF Phone : (.71.'��ugt- - � REGISTER OF WILLS 2019 8EP 15 Af'I 10 38 CLERK OF ORPHANS' C " CUMBERLP',` .- Date : 9/15/2014 ADLER WILLIAM L 4949 DEVONSHIRE RD HARRISBURG, PA 17109 RE : Estate of ADLER BETTY J File Number: 2001-00149 Dear Sir/Madam: This notice is to serve as a reminder that the Status Report by Personal Representative under Rule 6 . 12 is due on the below listed date. As per the AMENDMENTS TO SUPREME COURT ORPHANS ' COURT RULES, NO. 103 SUPREME COURT RULES DOCKET NO. 1, for decedents dying on or after July 1, 1992 , the personal representative or his counsel, within two (2 ) years of the decedent ' s death, shall file with the Register of Wills a Status Report of completed or uncompleted administration. This filing is due by: 10/02/2014 Please feel free to contact this office with any questions you may have . If you have already filed your Status Report, please disregard this notice . Sincerely Lisa M. Grayson, Clerk of the Orphans ' Court r Pa. O.C. Rule 6.12 STATUS REPORT REGISTER OF WILLS OF Cumberland COUNTY,PENNSYLVANIA Name of Decedent: Betty J.Adler Date of Death: October 2, 2000 File Number: 2001-00149 Pursuant to Pa. O.C. Rule 6.12, I report the following with respect to completion of the administration of the above-captioned estate: 1. State whether administration of the estate is complete: . . . . . . . . . . . . . . . . . . . . ❑Yes No 2. If the answer is No, state when the personal representative reasonably.believes that the administration will be complete: 3. If the answer to No. 1 is YES, state the following: a. Did the:personal representative file a final account with the Court? . . . . . . . ❑Yes ❑No b. The separate Orphans' Court No. (if any)for the personal representative's account is: c. Did the personal representative state an account informally to the parties in interest? . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . []Yes ❑No d. Copies of receipts,releases,joinders and approvals of formal or informal accounts maybe filed with the Clerk of the Orphans' Court and may be attached to this report. Date O �J' Signature of Person Filing this Form LU —JC= - c� -} '� ci Capacity: ❑Personal Representative �ounsel William L.Adler u- LL- n- U O O Name of Person Filing this Form 4 �--t - 4949 Devonshire Road Lj to tUJ GJ W Address c> IL C3 Harrisburg, PA 17109 la.r � C= cJ 717 652 8989 cv Telephone Form RIP--10 rev.10.13.06 PETITION FOR GRANT OF LETTERS REGISTER OF WILLS OF CUMBERLAND COUNTY,PENNSYLVANIA Petitioner(s) named below, who is/are 18 years of age or older, apply(ies) for Letters as specified below, and in support thereof avers)the following and respectfully request(s)the grant of Letters in the appropriate form: Decedent's Information Name: Betty J.Adler File No: 2001-149 a/k/a: (Assigned by Register) a/k/a: a/k/a: Social Security No: Date of Death: October 2.2000 Age at death: 76 Decedent was domiciled at death in Cumberland County, PA (state)with his/her last principal residence at 2930 Arcons Rd., Upper Allen Ta Cumberland Street address,Post Onice and Zip Code City,Township or Borough County Decedent died at Bethany Village Lower Allen Ta Cumberland PA Street address.Post office and Zip Code City,Township or Borough County State Estimate of value of decedent's property at death: Ifdomlciled in Penmylvania............................ All personal property S 200000 If not domidled in Pennsylvania. ....................... Personal property in Pennsylvania s If not domiciled in Pennsylvania. ....................... Personal property in County $ Value of real estate in Pennsylvania......................................................... $ TOTAL ESTIiitATED VALUE.... $ 200000 Real estate in Pennsylvania situated at: (Attach additional sheeu.ifnecessary) Street address,Post Office and Zip Code City,Township or Borough County Q A. Petition for Probate and Grant of Letters Testamentary Petitioner(s)aver(s)he/she/they is/are the Executor(s)named in the last Will of the Decedent,dated September 8. 1989 and Codicil(s) thereto dated June 2 2000 State relevant circumstances(ag.renunciation,death afexecutor,etc.) Except as follows:after the execution of the instruments)offered for probate Decedent did not marry,was not divorced,was not a parry to apending divorce proceeding wherein the grounds for divorce had been established as defined in 23 Pa.C.S.§3323(g),and did not have a child born or adopted;and Decedent was neither the victim of a killing nor ever adjudicated an incapacitated person. Q NO EXCEPTIONS ❑EXCEPTIONS ❑ B. Petition for Grant of Letters of Administration (Ifapplicable) at.a.,d.b.n.,d.b.n.c.t.a.,pendente lite,durante absentia,durante minorifate If Administration,c.t.a. or d b.n.c.t a.,enter date of Will in Section A above and complete list of heirs. Except as follows: Decedent was not a party to a pending divorce proceeding wherein the grounds for divorce had been established as defined in 23 Pa.C.S.§3323(g)and was neither the victim of a killing nor ever adjudicated an incapacitated person. ONO EXCEPTIONS ❑EXCEPTIONS Petitioner(s),after a propce search has/have ascertained that Decedent Icft no Will and was survived by the following spouse(if any)and heirs(attach additional sheeu,ijnecessary): Name Relationship Address RECORDEDOFFICE REGISTEROF VVM Form RIV-02 rev.10/1112011 �, 23 `�� Page 1 of 2 CLERK OF ORPHANS'COURT CUMBERLAND COUNTY,PA Oath of Personal Representative official Use only COMMONWEALTH OF PENNSYLVANIA I I SS: COUNTY OF Cumberland _- ) l'ctitioncr(s)Printed Name Petitioners)Printed Address Paul J. Killion 545 S.Third St.,Lemoyne, PA 17043 The Pctitioncr(s)above-narned sn-ear(s)or affIMI(s)IIIc statctncnts i c for oing P ili9n ar9 true and correct to the best of the knowledge and belief of Petitioners)and that,as Personal Represcntntive(s)of the Dc c t,t ct i c s)w v d tauly administer the estate according to law. Sworn to or affirmed anA subscribed beforc x ��a4Ll Date 61 me this I& lay of � cbl Date By: J 1 1t.�:�`1( ?1 �_ f;�,,.1 2��.____ - Date !'or the Register Date BOND Required:©YES Q✓ NO To the Register of Wills: FEES: Please enter my appearance by my signature below: Letters. . .4. . ... ............ . S Attorncy Signature: ( )Short Ccrtifcatc(s)..... . { )Renunciation(s).. . ... ... ( )Codicil(s). .... ... .... . { )Affidavit(s)... . ... ..... Bond... .... ......... . .... ... Printed Dame: William L.Adler Commission. .. ... . . .... .... .. Supreme Court Other ... .... ID Number: 39844 . .. . Firm Dame: .... . Address: 4949 Devonshire Rd. ..... Harrisburg. PA 17109 ... . . Phone: 717 652 8989 Automation Fee. .. . . . .. . .. . ... Fax: 717 307 3343 !CS Fee. ... ...... . .... ... .. . Email: bal@billadlerlaw.com TOTALL. .......... . . .. ... ... S DECREE OF THE REGISTER Estate of File No: a/k/a: AND NOW ___ , ,in consideration of the foregoing Petition, satisfactory proof having been presented before me, IT IS DECREED that Letters are hereby granted to in the above estate and(if applicable)that the instrumcnt(s)dated described in the Petition be admitted to probate and filed of record as the last Will (and Codicil(s))of Decedent. Ci P•MONWEALTH OF PENNSYLVANIA Notarial Seal RECORDED OFFICE Marcee D.Sloan,Notary Public { C o sib i up��Counts REGISTERRO3FF WU-LS r' Page 2 of 2 r[i 'Fig PENNSYLVANIA ASSOl7ATI0N OF NOTARIES i L+��� CLERK OF ORPHANS'COURT CUMBERLAND COUNTY,PA Oath of Personal Representative 011,1 al Use Only C0N4MO,N1VEALTI1 OF PENNSYLVANIA I } SS: COUNT)' t)F Cumberland I Pclitioner(s)Printed Name Peinioner(s)Printed Address Stacy Adler Smith 1993 United Dr.,Huger, SC 29450 SC -wioncr 0 abt'wc-t ncd su"caif s)ar affian(s)the siatcrncnls m the foregoing Petaion are true and correct to the best orthc kno+eiccige and belief v et d that,alPersonal Kcincsemative(s)of the Dtcedem.the Petitioner(s)wtll cc cll and!ruty ndminisscr the estate according to law CAA t 1 or, Iffi and subscribed bcforr x /(,J h .. te /d /5 I ri; S "�� �'� Date �kJ3:,�'••. ir = _ Date i���,i �� 1•.r i��'`, fate flNiiititlli� BOND Required: )'LS Q'N0 To the Register of 11711s: FEES: Please enter mv appearance by my signature below: Letters. . . ... . . . . .. . . . . . . . . . . S Attorney Signature: f )Short Certificate(s). . . . . ( )Renunciation(s).. . . .... ( )Codicil(s). . . . . . . . . . . .. { )Aff`tdnrit(s).. .. .. . . .. .. Bond... . . . . . . . . .. . . . . . . .. . . Printed Name. William L. Adler Commission. . . . ... . . . . . . . .. . . Supreme Court Other i)),Number: 39844 Firin Narne: . . . . . . Address: 4949 Devonshire Rd. Harrisbura. PA 17109 Phone: 717 652 8989 Automation Fee . . .. . . Fax: 717 307 3343 ICS Fe: . . . . . . . . .. . . . iimail: bal(cDbilia dlerlarv.com TOTAL . . . S DECREE OF 'rHE RECISTER [:state or bile No: a1k/, AND NOW, in consideration of the foregoim, Petition, satisfactory proof having been presented before Inc, I'I' IS DECREED that Letters are hereby grunted to _ - in the above estate anti (if applicable)that the instrument(s)dated described in the Petition be admiltc.d to probate and filled of record as the last Will (arid Codicil(s))of Decedcnt. RECORDEDOFFICE Fora:Rtt'.0 rev. 101i/Mit REGISTER OFWIL.LS Page 2 of 2. 2015MB23 CLERK OF ORPHANS'COURT ,All CUMBERLAND COUNTY,PA IN RE: IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, ESTATE OF Betty J. Adler, DECEASED PENNSYLVANIA ORPHANS COURT DIVISION ESTATE NO. 21-01-149 AFFIDAVIT WHEREAS, Betty J. Adler died on October 2, 2000; and WHEREAS, Letters Testamentary were granted to Robert A. Adler and Paul J. Killion,Esquire on February 6, 2001; and WHEREAS, Robert A. Adler died on February 20,2012; and WHEREAS,the estate of Robert A. Adler is probated in Cumberland County;Pennsylvania to number 21-12-0252; and WHEREAS, the probated codicil of the will of Betty J. Adler provides in the amended I Ph article that in the event one co-executor is unable or unwilling to serve as co-executor,the surviving executor may appoint a substitute co-executor provided that one of the co-executors is an attorney; and WHEREAS,Paul J. Killion is an attorney licensed to practice law in the Commonwealth of Pennsylvania. Paul J. Killion, as the surviving co-executor under the sole codicil to the will of Betty J. Adler, hereby appoints Stacy Adler Smith, of 1993 United Dr., Huger, SC 29450, as co-executor of the estate of Stanley D. Adler, Jr. Witness: Paul J. Killion, qdire 545 S. Third St. Lemoyne, PA 17043 Dated: February 10, 2015 1, Stacy Adler Smith,hereby consent to serve as co-executor of the estate of Betty J. Adler. Witness: X Stacy Adler Smith if Date: RECORDIDOFFICE REGISTEROPWni-S 2015FM23 CLERK 0FORPHANS'COURT CUMBERLAND COUNTY,PA IN RE: IN 'I*IiE COURT OFCOMMON PLEAS CUMBERLAND COUNTY. ESTATE OF Betty J. Adler, DECEASED PENNSYLVANIA ORPHANS COURT DIVISION ESTATE NO, 21-01-149 AF,1�IDAVIT WHEREAS, Betty J. Adler died oil October 2. 2000: and WHERE-AS, Letters Testamentary, were granted to Robert A. Adler and Paul J. Killion, Esquire oil February 6, 2.001; and WHEREAS, Robert A. Adler died oil February 20, 2011and WHEREAS, the estate of Robert A. Adler is probated in Cumberland County, Pennsylvania to number 21-12-0252; and WHEREAS, the probated codicil of tile will ol'Bettv J. Adler provides in the amended I I" article that in the event one co-executor is unable or unwilling to serve as co-executor, the surviving executor may appoint substitute co-executor provided that one of the co-executors is an attorney; and WHEREAS, Paul J. Killion is an attorney licensed to practice law, in the Commonwealth of Pennsylvania. Paul J. Killion, as the surviving co-executor under the sole codicil to the Nvill of'Betty J. Adler, hereby appoints Stacy Adler Smith, of 1993 United Dr.. Huger. SC 29450, as co-executor of the estate of Stanley D. Adler, Jr. Witness: Js Paul .1, Killion. Esquire 545 S. Third St. Lemoyne, PA 17043 Dated: Februan, 10, 2015 1, Stacy r Smith, hereby consent to serve as co-executor of the estate of Betty J. Adler. y Date: Z — ) 0-15 RECORDEDOFFICE REGISTEROFWU-LS 2015 FEB 23 CLERK 0FORPHANS'COURT' CU1v1BhRLANDcOUNiy,PA IN THE COURT OF COMMON PLEAS OF THE NINTH JUDICIAL DISTRICT CUMBERLAND COUNTY, PENNSYLVANIA I ORPHANS' COURT DIVISION IN RE: ESTATE OF I rly OF 6V O I BETTY J. ADLER, I " - DECEASED I 1760 I I DOCKET NO. 21-01-0149 I CERTIFICATION OF RECORD TO COURT AND NOW, this 2nd day April, 2015, upon consideration of the Petition to Grant Letters of Paul J. Killion and Stacy Adler Smith, filed on February 23, 2015, the Clerk of the Orphans' Court does hereby certify this action to court pursuant to 20 Pa. C.S. §907, because granting the Petitioner's request may have a substantial effect on the Robert A. Adler Estate, 21-12-0252, and correlative civil action Stacy Adler Smith v. Nataliia Tykhonova Adler, Docket 21-14-01027, currently pending before this Honorable Court. This petition should be taken under consideration in those matters. --' . Lisa M. Grayson, Esq., Register of Wills & Clerk of Orphan ' urt Distribution: ©,. William L. Adler, Esq., Counsel for Betty Adler Estate, 21-01-0149 rn N Counsel for Robert Adler Estate, 21-12-0252 ., , Paul J. Killion, Esq., Co-Executor and Co-Trustee, Betty Adler Estate, 21-01-0149 ~ -,rn Stacy Adler Smith, cry Proposed Co-Trustee and Proposed Co-Executor, Betty Adler Estate, 21-01-0149 Pro Se Plaintiff, Smith v. Adler, Civil No. 21-14-1027 Pro Se Second Petitioner, Robert Adler Estate, 21-12-0252 Thomas P. Gacki, Esq., Counsel for Administratrix, Nataliia Tykhonova Adler, Robert Adler Estate, 21-12-0252 Counsel for Defendant, Nataliia Tykhonova Adler, Smith v. Adler, Civil No. 21-14-1027 ORPHANS' COURT DIVISION COURT OF COMMON PLEAS OF In Re: BETTY J ADLER CUMBERLAND COUNTY PENNSYLVANIA NO.21-01-0149 CERTIFICATE OF SERVICE OF ORDER ORDER DATE: 4/2/2015 JUDGE'S INITIALS: LMG TIME STAMP DATE: 04/02/2015 IN RE: CERTIFICATION OF RECORD TO COURT ,,,,,,,,,,,,,,,,,,,,,,,,,,,,,,,,,,,,,,,,,,,,,,,,,,,,,,,,,,,,,,,,,,,,,,,,,,,,,,,,,,,,,,,,,,,,,,,,,,,,,,,,,,,,, SERVICE TO: WILLIAM L ADLER 4949:DEVONSHIRE RD HBG PA 17109 PAUL J KILLION 545 SOUTH THIRD ST LEMOYNE PA 17043 STACY ADLER SMITH 1993 UNITED DR HUGER SC 29450 THOMAS P GACKI 213 MARKET ST 8TH FLOOR HBG PA 17101 METHOD OF MAILING: ENVELOPES PROVIDED BY: ®USPS ❑PETITIONER ❑ RRR ❑ JUDGE ❑ HAND DELIVERED ®CLERK OF ORPHANS COURT ❑ OTHER MAILED:4/2/2015 ,,,,,,,,,,,,,,,,,,,,,,,,,,,,,,,,,,,,,,,,,,,,,,,,,,,,,,,,,,,,,,,,,,,,,,,,,,,,,,,,,,,,,,,,,,,,,, SERVICE TO: METHOD OF MAILING: ENVELOPES PROVIDED BY: ❑USPS ❑PETITIONER ❑ RR.R ❑ JUDGE ❑ HAND DELIVERED ❑ CLERK OF ORPHANS COURT ❑ OTHER MAILED: Deputy Clerk of Orphans' Court IN THE COURT OF COMMON PLEAS. CUMBERLAND COUNTY, PENNSYLVANIA ESTATE OF BETTY J. ADLER, : ORPHANS' COURT DIVISION DECEASED NO 21-01-0149 IN RE: CERTIFICATION OF RECORD TO COURT ORDER OF COURT AND NOW, this 10th day of June, 2015, upon consideration of the Certification of Record to Court, by Lisa M. Grayson, Esq., Register of Wills, and no objection having been made, the court finds that the petition of Stacy Adler Smith for appointment as Co-Executor in the instant matter does not conflict with the Robert Adler Estate matter currently pending before this court. IT IS HEREBY ORDERED that the record is remanded back to the Register of Wills for further action. BY THE COURT v 70 Edward E. Guido, Jdge c Distribution: William L. Adler, Esq., "r c Counsel for Betty Adler Estate, 21-01-0149 Counsel for Robert Adler Estate, 21-12-0252 Paul J. Killion, Esq., Co-Executor and Co-Trustee, Betty Adler Estate, 21-01-0149 c� Stacy Adler Smith, Proposed Co-Trustee and Proposed Co-Executor, Betty Adler Estate, 21-01-0149 Pro Se Plaintiff, Smith v. Adler, Civil No. 21-14-1027 Pro Se Second Petitioner, Robert Adler Estate, 21-12-0252 Thomas P. Gacki, Esq., Counsel for Administratrix, Nataliia Tykhonova Adler, Robert Adler Estate, 21-12-0252 Counsel for Defendant, Nataliia Tykhonova Adler, Smith v. Adler, Civil No. 21-14-1027 r A - � . ORPHANS' COURT DIVISION COURT OF COMMON PLEAS OF In Re: BETTY J ADLER CUMBERLAND COUNTY PENNSYLVANIA NO. 01-149 CERTIFICATE OF SERVICE OF ORDER ORDER DATE: 06/10/2015 JUDGE'S INITIALS: EEG TIME STAMP DATE: 06/10/2015 IN RE: ORDER OF COURT SERVICE TO: WILLIAM ADLER 4949 DEVONSHIRE RD,HARRISBURG PA 17109 PAUL KILLION 545 SOUTH THIRD ST,LEMOYNE PA 17043 STACY ADLER SMITH, 1993 UNITED DRIVE,HUGER SC 29450 THOMAS GACKI 213 MARKET ST, 8TH FLOOR,HARRISBURG PA 17101 METHOD OF MAILING: ENVELOPES PROVIDED BY: ®USPS ❑PETITIONER ❑ RRR ❑JUDGE ❑HAND DELIVERED ® CLERK OF ORPHANS COURT ❑ OTHER MAILED: 06/10/2015 ,,,,,,,,,,,,,,,,,,,,,,,,,,,,,,,,,,,,,,,,,,,,,,,,,,,,,,,,,,,,,,,,,,,,,,,,,,,,,, SERVICE TO: METHOD OF MAILING: ENVELOPES PROVIDED BY: ❑ USPS ❑PETITIONER ❑RRR ❑JUDGE ❑ HAND DELIVERED ❑ CLERK OF ORPHANS COURT ❑ OTHER MAILED: ADeputy ' ourt i