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HomeMy WebLinkAbout11-08-04 IN RE: MILDRED J. GERBER IN THE COURT OF COMMON PLEAS TRUST, UNDER AGREEMENT CUMBERLAND COUNTY, PENNSYLVANIA dated, December 19,1997 ORPHANS' COURT DIVISION an incapacitated person NO. 21-2002-0540 IN RE: FRED E. GERBER,SA. IN THE COURT OF COMMON PLEAS TRUST, UNDER AGREEMENT CUMBERLAND COUNTY, PENNSYLVANIA dated, July 29,1994 ORPHANS' COURT DIVISION NO,. 21-1998-0195 FIRST SET OF INTERROGATORIES DIRECTED TO FREDERICK E. GERBER,II, TRUSTEE FOR THE MILDRED J. GERBER TRUST AND THE FRED E. GERBER,SA. TRUST BY MARILYN GERBER, THE OBJECTOR. TO: Mr. Richard Rupp 355 North 21 st Street Camp Hill, PA 17011 ~--".-- -:-.J -. ~ d .- , .", 2.0 Cj <: I co :'0 ~ MARIL YN GERBER'S FIRST SET OF INTERROGATORIES ADDRESSED TO FREDERICK E. GERBER,II TRUSTEE PLEASE TAKE NOTICE that you are hereby notified and required to answer separately, fully in writing, and under oath, within thirty (30) days of receipt of this Notice and to serve your answers thereto on the undersigned in accordance with Pennsylvania Rule of Civil Procedure NO. 4001 ,et seg. Please take notice that Mr. William Duncan, Auditor for the hearings scheduled on November 15,16,17,2004 for the above stated Trusts, ordered that the Objector Marilyn Gerber could issue interrogatories upon Frederick E. Gerber,1I and that it is presumed that these Interrogatories must be answered prior to the hearings. If there is any objection to this or any question as to the due date of these Interrogatories, please address them to the Objector and to Mr. William Duncan. These Interrogatories shall be deemed to be continuing Interrogatories. If between the time of filing your answers and the time of trial of this matter,yOu, or anyone acting on your behalf, learn of any further information not contained in your answers, or if you learn that any information set forth in your answers is or has become inaccurate or incorrect, you shall promptly file and serve supplemental answers. The following Interrogatories are listed sequentially and not on se~.arate pages. Each question Interrogatory shall be answered individually and completely. ALL INTERROGATORIES ARE TO INCLUDE ANSWERS FOR THE TWO ABOVE STATED TRUSTS AND FROM THE TIME PERIOD OF JANUARY 1998 TO JULY 8,2002 AS ORDERED BY THIS COURT IN JUNE 2002. PLEASE NOTE: There are questions for each Trust and there are questions regarding both Trusts. All of the questions that ask questions about a check that was written in each of the Trusts, are asked in an individual question for clarity and for the Trustee to understand the question regarding each check. Therefore, if the Trustee and the attorney object to the number of Interrogatories as being excessive or cumbersome, please understand that all of the questions about the checks is actually only one question under the section of checks written on the Fred E. Gerber,Sr. Trust and the Mildred J. Gerber Trust and the rest of the Interrogatories are individual questions. Any multiple questions as questions regarding the Tenants of the Administration of the Fred E. Gerber,Sr. Trust and the Baltimore property are also one question but written in several issues for clarity and so the Trustee will understand the question. As the Auditor has not stipulated when these Interrogatories are due, this Objector has written the Auditor and requested such a due date. As the hearings are scheduled for November 15,16, 17,2004, it is presumed by this Objector that these Interrogatories shall be answered prior to the hearing date. If the Trustee or his attorney have any questions regarding these Interrogatories. please contact the Objector by fax with your questions at 717 737-7116 and the Objector shall clarify and answer any questions concerning the follOwing Interrogatories. 1. Identity each person who participated in furnishing any information with respect to these Interrogatories and state the number and subpart of the Interrogatory for which each person furnished information: 2. State a. your full name b. Any other name by which you are known; c. The address of your present residence and the name and address of each residence you have had from January 1998 to the present. d. Your present occupation and the name and address and phone number of your employer and the name and address of each employer with the address and phone number since January 1998. e. your date of birth f. the schools you have attended since graduation from High School and for each school, identify the degrees or certificates you have obtained or been awarded,if any, and in what year obtained or awarded; 3. State with particularity the factual basis for each Objection that PNC Bank and Marilyn Gerber filed on the Accountings for the Mildred J. Gerber Trust and the Fred E. Gerber,Sr. Trust that you assert is not factual and why. Clearly delineate which answer applies to which Objection and which account. 4. Identity any and all documents which refer, relate or in any way pertain to the Accountings which you filed for the above stated two Trusts or are related in any way to your acting as Trustee for the above stated Trusts for the time period ordered by this Court from January 1998 to July 8,2002. Clearly identify which account you are identifying your document for. 5. Identify each person who: a. Has knowledge or information or with whom you have discussed as to any facts or issues pertaining to the circumstances and manner of your position as Trustee for the above stated Trusts or your responses to the Objections filed by PNC Bank and Marilyn Gerber and b. With respect to each person so identified, state that person's name, address telephone number and which interrogatory # this answer applies to. 6. Identify each person you intend to call as a non expert witness at the trial of this case and for each person identified state the name and address of the witness, your relationship with the witness, the substance of the facts as to which the witness is expected to testify, and all documents which relate to the witness's testimony whether or not you expect to introduce the document at trial: 7. Identify each expert you intend to call as a witness at the trial of this matter, and for each expert, state: a. The subject matter about which the expert is expected to testify; and, b. The substance of the facts and opinions which the expert is expected to testify and a summary of the grounds for each opinion. (You may file as your answer to this Interrogatory the report of the expert or have the interrogatory answered by your expert. 8. Identify all exhibits, including documents, photographs, tape recordings and or video recordings you mayor you intend to use at trial of this matter. For any photographs and/or recordings, state the date such item was taken or made, by whom and the subject matter of such item: 9. If you intend to use any admission(s) of a party at trial, identify such admissions 10, State what is your financial experience and with respect to your answer, state as follows: a. Name each employer its address, and telephone number with whom you gained or used your financial experience; b. Name each supervisor for each employer in your answer above. 11. State what financial experience you employed in fulfilling your duties as Trustee for the above two stated Trusts. a. did you perform all of the accounting for the two Trusts and if so please explain what duties you performed to generate the accounting. b. did you act as the investment director for the two Trusts in the sense did you manage the investment portfOlio and make all of the investment decisions for the two Trusts. IF yes, please explain each and every investment decision that you made with the following particularity. 1. please explain each sale of any investment or assets for each Trust and provide the date, the amount that was sold and the total shares as well as all commission costs that were incurred. Please provide the name of the investment company and where these investments were held. 2. please explain each purchase of each Trust of any asset or investment and the provide the date, the amount that was purchased and the total shares purchased as well as any commissions that were incurred. Please provide the name of the investment company and where these investments were held. 3. please explain each loss that you reported in the Accountings and the name of the investment, the 5. Please explain each gain that you reported in the Accountings and for each gain, please state the amount of gain, the date of the gain, the name of the investment, the amount of shares that created the gain and the company that held these investments. Please state if any commissions were incurred in any gains for any of the two above stated Trusts. 12. Have you ever been the executor, administrator, or power of attorney for any person and if so, state that person's name, address, age and date of the instrument. 13. State whether you have any experience or involvement with any entity's budget or any employer's budget, and if so, state the name of the employer, the nature of our involvement with the budget, the dates of your involvement and the name of your supervisor as well as the dates that you were employed by such employer or supervisor. 14. State with particularity the receipt and provide a copy of each receipt for each check that was written from both of the Trusts. For each receipt, please provide the following information. a. the date of the receipt b. the owner of the receipt who purchased any item on the receipt c. each and every item for the total amount of such receipt d. the account number of each receipt e. the total amount for each receipt that reflects the amount written on the check f. any financial document that reflects any association with each check written g. the reason that items for purchased and for whom it was purchased for h. state the reason why the check for each receipt was written from a specific Trust. i. a copy of the front and back of each check that was written for each receipt j. if you do not have a receipt for a check written, indicate why not and explain how a check was written and for what purpose and for which beneficiary. 15. Define unrealized loss as you use it in the Accountings for the two Trusts. Please list the unrealized losses that you mention in the two Accountings and indicate where these unrealized losses occurred within the monthly Statements of Charles Schwab by the date, the year and the circumstance that these unrealized losses occurred and if they relate to any investments that were unrealized losses, please indicate which investments by the shares, the value of the shareslinvestments and the total amount of each unrealized loss and whether you reported any of the unrealized losses on any Federal or State income tax or estate/trust reports. 16. State what litigation as either a moving party or a defending party or as a witness you have been involved in and with respect to your answer, please provide the following. State the other party's name or names, their address(es), the court involved, the date of commencement of the litigation. This question is for any legal action that the Trustee was involved in, initiated, was supposed as a witness for any legal actions in any state, any county in the USA or in any country in the world. In your deposition, you stated that you have been deposed in civilian and military courts, therefore please identify the dates and reason that you were deposed, the state and Court that you were deposed in, including the name of the case and the attorney that represented you in any of your depositions. If you have been a witness in any court either civilian or military, please answer the same questions as to the date, Court, state and court case that was asked in the question about being deposed. 17. Have you ever filed suit against the Objector. If yes, please state the name of the law suit, the date of the law suit and the nature and reason of the law suit. Please provide all pleadings and legal documents, letters of correspondence from any attorney regarding this law suit that are in the possession of you or your attorney and if any moneys from any of the two Trusts were used to pay for the legal services of this lawsuit or any service connected with this lawsuit. If you used only our own moneys, please provide documentation and checks or financial data to show the Objector that you paid for all legal services regarding this law suit with your own funds. 18. Have you ever been ordered to file any Accounting for any reason in any Court for any estate, Trust, or fiduciary's account, and if so, state the name of the estate or Trust or account, state the fiduciary, state the court involved, state the date you were ordered to file. 19. Do you have any paperwork that would show that you are entitled to the ownership of your parents' marital residence at 623 Hilltop Drive, New Cumberland, PA and if so, specifically identify it how your acquired it, the date of it, if any. Do you have any document that would show that Marilyn Gerber does not have any ownership in the 623 Hilltop Drive, New Cumberland property and if so, please provide such documents or explain you believe that she does not have an ownership in such referenced property. Does Marilyn Gerber have any beneficiary right to any share of the residence or the sale of the residence at 623 Hilltop Drive, New Cumberland, PA and if so, please provide the document that indicates that she has a beneficiary share and how much that would be. If the residence has been sold, please provide all documents related to the sale of this property and where the moneys are being held in escrow at this time and who controls this account. 20. Do you have any paperwork that would show that Marilyn Gerber is entitled to any property, tangible or intangible from the Estate of Fred E. Gerber, Sr. or Mildred J. Gerber and if so, please specifically identify it, how you acquired it the date of it, if any. 21. Do you have in your possession any attache cases with financial documents of any nature or any materials that belonged to Fred E. Gerber,Sr that you obtained or removed from any residence of Fred E. Gerber,Sr. at any point in time and if so, please provide the originals for review and copies of all such documents that you removed. 22. Do you have in your possession any wills of your parents from any time period or of any version and if so, please provide a copy. 23. Do you have a copy of the deed of ownership for the property of 623 Hilltop Drive, New Cumberland, PA and the Baltimore Property on Wedgewood Drive and if so, please provide a copy and indicate who owns each property. 24. Do you have any documents which show that the Baltimore property was funded in the any of the two Trusts and a letter of instrument or direction from anyone that states that this property was specifically designated to be funded into the Fred E. Gerber, Sr. Trust and if so, please provide such document. 25. Please provide the document that shows where the moneys that Fred E. Gerber, Sr. inherited from Florence Cappe were deposited, what date they were received and where they were deposited, Please provide documents that show where they were ever transferred to, to whom, on what date, and to what financial institution. Please provide all tax information of taxes, Federal or State that were paid on this inheritance. Please provide all documents of any advance distribution of any inheritance that was distributed to anyone of the Gerber family or to Mildred J. Gerber and if so please provide the date, the amount and how and where it was distributed and to whom. 26. Please provide the document that directs you to deposit the moneys from the Florence Cappe inheritance into the Fred E. Gerber,Trust. Please provide documents that would indicate why Mildred J. Gerber did not receive the Florence Cappe inheritance directly in 1999. With reference to these moneys that were transferred out of the Fred E. Gerber,Sr. Trust and given to Mildred J. Gerber, please indicate where these moneys were deposited, what bank and under what circumstances these moneys were taken from the Fred E. Gerber,Sr. Trust. Were these moneys ever deposited into the Mildred J. Gerber Trust and if so, please indicate the deposit slip and date of these moneys. 27. Please explain why a handwriting analysis was done and for what purpose, the name of the expert, the amount that was charged, the date of the report, the circumstances of the handwriting analysis and the actual report of the analysis. Please indicate who initiated this analysis and who paid for this report. Please provide the actual item that was analyzed by this handwriting expert and for what reason. 28. Please explain and provide a copy of the deposition of Marilyn Gerber deposition that you used in the Guardianship of Person hearing in 2001 from the San Francisco Rent Board. Please explain how and why you obtained a copy of this deposition, from whom you obtained it from, for what purpose, how much you paid for it, and how you obtained information that this document existed. Please state the amount of legal fees that were billed for the receipt of this deposition and from what Trust it was charged to. 29. Please provide the name of any person or company or attorney that you obtained information from or was connected to the residence of Marilyn Gerber at 1830 Gough Street, #2, San Francisco,CA 94109. Please explain the purpose of this information and the amount of legal fees that were charged to any of the Trusts and for what purpose. 20. Please provide any correspondence from Marilyn Gerber requesting any moneys from any of the two Trusts, the amount she requested, any financial documents that she provided to you and please state with specificity why you did not grant any of her financial requests. If you did give any moneys from the two Trusts, please provide the amount, the check, the reason for the granting of moneys, the purpose that the moneys were used and how Marilyn Gerber received these moneys. Please provide a copy of the checks. Please provide a copy of the legal fees that were billed to any Trust for any of the stated information in this question and who were the attorneys involved by name, address, date, amount they received in legal fees. 21. Please explain how each and every beneficiary of the two Trusts was allowed to communicate with you in any manner for any purpose. Please explain if they could contact you directly and the telephone number and the address that you used or currently use for any beneficiary to contact you either by telephone, cell phone, fax or address. Please provide the name of each and every beneficiary that ever contacted you and if they communicated to by telephone, fax, letter,or through any attorney. 22. Please provide documents of every financial request from any beneficiary for moneys from the two Trusts and state with particularity what these moneys were for, did you require a financial statement from each beneficiary's request, and if so, please provide the document, the date of the document and the amount that was requested and how much was given to each beneficiary. 23. Have you or any of your attorneys ever provided any document, data of any type or means or correspondence of any type regarding the two Trusts or any of the beneficiaries; to anyone at PNC Bank which would include PNC Bank on Bridge Street in New Cumberland, and PNC Financial Advisors or any other office or entity of PNC Bank or Rhoads & Sinon and if so please explain why, the date, and the copy of each document or correspondence. IF so, please describe the reason for providing such documents, the date the document wa provided and the legal fees attached to any attorneys' fees for such activity. 24. Have you or any of your attorneys every provided any document(s) or correspondence to Ms. Jacqueline Verney regarding the two Trusts or any beneficiary of the two Trusts and if so please provide the document(s), or correspondence. This question would include any documents related to the Trusts, the Objections filed by PNC Bank or Marilyn Gerber or any accountings of the two Trusts. 25. Did the Trustee pay Ms. Jacqueline Verney for any legal services from either of the Trusts and if so,please provide the detailed billable hours that Ms. Verney billed and explain: a. the date for each service that Ms. Verney billed b. the date that she met with any individual, the circumstance of her legal service and who it was for as well as the date that each service was provided. c. did Ms. Verney provide any documents, correspondence while she was engaged as an attorney for any individual that the Trusts paid for her services and if so please provide copies of all correspondence and documents. To whom did Ms. Verney provide her correspondence and documents to during the course of her services and provide the name, address and telephone number of such person(s). e. did Ms. Verney provide correspondence or documents to the Trustee and if so please provide copies. t. did Ms. Verney provide copies of documents to any attorney who represented Frederick E. Gerber," or the Trust and if so please provide the name, address and phone number of such attorney(s). g. did you, acting as the Trustee or individual ever meet with Ms. Verney and if so please provide the dates, the circumstances of your meeting and for what purpose as well as the billable hours she charged. h. did you acting as Trustee or an individual provide Ms. Verney with information, data, correspondence, or any documents, financial information, or documents regarding any member of the Gerber or Flanagan family who are beneficiaries of the Two Trusts or will of Mildred J. Gerber or Fred E. Gerber,Sr. i. Who secured the services of Ms. Verney for any purpose or reason for any member of the Gerber family and provide that person's name, address, telephone number. j. Did Ms. Verney represent any member of the Gerber family and if so please explain who this person was and for what purpose, if you present during any of the meetings with this individual and how much Ms. Verney was paid for her legal services for this person along with all of the documents that you were given from Ms. Verney or from this person that was represented by this person. 26. Did the Trustee employ Ms. Lindsay Baird and if so, please explain under what capacity and for whom she was retained to represent and provide the billable hours including the dates of each service and for what purpose each service was billed, the total amount, and the amount of by hour that Ms Baird charged for each service and explain: a. did Ms. Baird provide any documents or correspondence for any service for any member of the Gerber family or the Trustee and if so please provide copies of all documents that Ms. Baird generated and sent to anyone. b. did you provide any information to Ms. Baird including documents, or correspondence regarding any member of the Gerber family. c. did you meet with Ms. Baird regarding the Trusts or any member of the Gerber family for any reason and if so please provide a copy of any documents or correspondence of such meetings as well as the bill for Ms. Baird's service including her billing hourly rate. 27. Did you as the Trustee engage the services of attorney(s) for any matter concerning Mildred J. Gerber, Fred E. Gerber,Sr or any other beneficiary of the Trusts and if so, please provide: a. the name of each attorney, including the address and phone number b. the purpose of hiring each attorney and the dates and services that each attorney provided as well as all correspondence and documents that each attorney provided and billed for hislher services. c. the total amount of legal fees that were billed to the Trusts and provide a detailed breakdown of each billable hour, including for what service each hour was charged for. 28. While you were acting as Trustee for the two Trusts, did you at any time live in any residence other than the residence of your spouse, Petra Gerber and if so please provide the following information: a. did you and your spouse, Petra Gerber ever live apart from 1998 to 2002 and if so please explain the circumstances. b. did you pay for a residence for you separately than from your spouse, Petra Gerber when you were Trustee from 1998 to 2002 and if so please provide the amount for each and every residence that you paid for such residence and state the address of each residence that you paid for. c. are you and your spouse, Petra Gerber separated as a husbandlwife either legally or informally and please explain you definition of your separation. d. did you ever pay your spouse Petra Gerber any moneys from the Trusts and if so, please explain the circumstances and for what purpose, identify each check and explain for what purposes the moneys were given to her. THE FOLLOWING QUESTIONS ARE FOR CHECKS WRITTEN ON THE FRED E. GERBER TRUST. 29. Please provide the receipt for check #102 and explain why this purchase was made and paid for from the Mildred J. Gerber Trust. 30. Please provide the documents on the Acacia Life Insurance policy for Jane Heflin and explain why a check was written from this Trust. Check # 104, #121. Please provide a visible and complete copy of all bills and pOliCies from this Insurance Company. 31. Please provide the documents on the Acacia Life Insurance policy for Marilyn Gerber and explain why a check was written from this Trust. Check #105,#120. Please provide a complete and visible copy of all bills and policies from this Insurance Company. 32. Please explain why check # 106 was written and provide a receipt for such moneys and why this check was written from this Trust. Please indicate to whom this check was written. Please provide a receipt for the Aug. Sept., Oct. stipend and if a financial statement or budget was submitted to this Trust for such stipend payment. 33. Please explain why check #107 was written and why this check was written from this Trust. 34. Please explain why a check was written for Amanda Heflin for check #108 and provide the receipt for the room and board. Did Amanda Heflin ever provide a financial statement or budget to the Trustee and did the Trustee ever verify her financial needs and if so, please provide such document. 35. Please provide the receipt for check #109 and explain why a check was written from this Trust. 36. Please explain why check #101,103, was written from this Trust and provide copies of all checks written for payment as well as all receipts for all services. 37. Please explain why check #111 was written from this account and provide a complete copy of the receipt identifying the name of the person billing, the date, for what purpose and for whom was this bill sent on. 38. Please explain why check #114 was written from this account and for whom it was paid for whom it was paid for. 39. Please explain why check #115 was written from this account and provide a copy of the policy and all payment history on this policy and for what residence this policy was issued. 40. Please explain why check #119 was paid from this account and provide a clear receipt that is readable and has no other receipts overlaid on top of the receipts as you provided in documents to Marilyn Gerber on September 3,2004. Please explain who Maj. Larry Shaw is and provide a copy of the Fred E. Gerber Memorial Trust Award and all persons who have received moneys from this Memorial Trust and who funded this Memorial Trust and who is the Trustee. Please provide the date that this money was given to Maj. Larry Shaw and for what purpose. Please provide the address and telephone number of Maj. Larry Shaw along with an explanation why he received this award, If Maj. Larry Shaw is an officer in the military, please provide the name of his duty station, his commanding officer and the circumstances of his receiving this award. 41. Please provide the receipt for tuition expenses for check # 128 to Amanda Heflin and explain why this check was written from this Trust. 42. Please explain why check # 126 was voided? 43, Do you have in your possession any canceled checks or notes that Fred E. Gerber, Sr ever wrote to his four grandchildren, Amand, Sascha, Mischa or Sean for birthdays, Christmas, tuition or room and board and if so, please provide a copy of each canceled check, note, letter or correspondence. 44. Did Fred E. Gerber,Sr give you any moneys in 1998 for tuition, room and board or care of your son, Mischa Gerber and if so, please provide the amounts, the date that such a check was written, or the deposit date that you deposited such a check into any of your individual or joint checking or savings account with your spouse, Petra Gerber. 45. Did you give Marilyn Gerber a check for her birthday, Christmas or for any other purpose in 1998, 1999, 2000,2001, 2002 and if so, please indicate the amount, the check number and the amount. If you did not give Marilyn Gerber any moneys for the stated questions, please indicate why not. Do you have any knowledge whether Fred E. Gerber,Sr ever gave Marilyn Gerber birthday or Christmas gifts over his life and if so, how much and for what years. 46. Did you request from Marilyn Gerber a financial statement or budget of her finances as a condition for requesting any moneys from this Trust and if so please provide the document of such request, the correspondence surrounding such a request or form and if Marilyn Gerber ever supplied you with any such financial statements for the year 1998,1999, 2000, 2001, 2002. 47. What specific financial information did you request from Marilyn Gerber when she would ask the Trustee for money and provide a copy of such document request, with the date and what answer(s) Marilyn Gerber provided to any such requests for the year 1998,1999,2000,2001,2002. 48. Did you request of any other beneficiary including Mildred J. Gerber, Jane Heflin or the 4 grandchildren any financial statement or budget of his or her finances as a condition for requesting any moneys from this Trust and if so please provide the document of such request, the correspondence surrounding such a request or form and if any of the above mentioned individuals ever responded with any such financial statements for the year 1998,1999,2000,2001 and 2002. 49. What specific financial information did you request from Mildred J. Gerber, Jane Heflin and the 4 grandchildren before you would give them moneys from this Trust and provide a copy of such document or correspondence. 50. Please state with particularity if any of the four grandchildren of Fred E. Gerber, Sr. ever received any scholarship moneys, grants, student 10ans,ROTC scholarship or ROTC tuition assistance that was used by each grandchild for their high school, college or any other instructional tuition for the year 1998, 1999,2000, 2001 or 2002 and if so please provide all documents on the amount of each scholarship, grant, student loan, ROTC scholarship or ROTC tuition for each grandchild stating with particularity the amounts of any moneys received from any source stated above by year, date and the amount. 51. Please provide copies of all tuition and room and board charges including the name of the educational institution, the yearly tuition, the copy of the rent or college or high school room and board or educational supplies such as books, supplies but not limited to such stated items with the name of the grandchild, the date and year of such expenses and the receipts for all such stated expenses for the year 1998,1999,2000,2001 and 2002. 52. Please provide any moneys which any grandchild earned themselves by working and receiving income for the year 1998,1999,2000,2001,2002 and a copy of their Federal Income and State Income Tax form for the above stated years for each grandchild. 53. Please provide a receipt and all documents for the check # 136 to the PA Department of Revenue and identify whose Social Security Number is written on the bottom of this check and why such a check was paid for a 1997 State Income Tax. Please provide a copy of the referenced 1997 State Income Tax why this check was written from this Trust. Please indicate why these moneys were paid to PA State Revenue and provide all receipts and information that was used to complete this PA Income Tax document. 54. Please provide a receipt and all documents for the check #137,#138,#139,#140 to the PA Department of Revenue and whose social security number is written on the bottom of this check and the PA State Income Tax document for which this check was written and for what purpose these moneys were written for and provide all receipts and information to complete this PA Income Tax document. 55. For the above questions #53,#54, did the Trustee employ the services of a CPA, Accountant or any income tax service to prepare and complete the PA Income Tax documents for which checks #136,137 were written and if so please identify the the name of such CPA, accountant or income tax service,or attorney with the name of the individual, the address and telephone number and the bill for their services listing their hourly service and all of their work product. 56. Please provide a complete receipt of the statements from Acacia Life Insurance Company for check #144,#145 and provide a copy of the policy for each check. 57. Please provide a complete receipt and list of all charges for the Bell Atlantic Mobile phone for check #148 and explain who owns this mobile phone and for what purpose this mobile phone was charge to this Trust. Did the Trust purchase this Mobile phone, what is the mobile phone telephone number, the date it was purchased and the receipt for the purchase of this mobile phone and why it was used for this Trust. 58. Please explain the check # 149 to the IRS and provide all documents and work product from you or any CPA, Accountant, or income tax service or attorney that prepared this IRS document including all of the bills with hourly rate for any fees that you paid for the preparation of this IRS report. Please provide a copy of this IRS document and explain its relevance to this Trust. 59. Please answer the same questions for 158 above for check #150. 60. Please explain why check # 153, #158 ,#1 260, #263,#265, written to your spouse, Petra Gerber and indicate why this check was written to your spouse and not to the recipient of this check and identify and provide the recipient of this check. 61. Please provide a receipt for the check to Lord & Taylor for check #154 and explain why this check was written from this check. 62. Please explain why check #155 was written to LTC Randy Randolph and indicate this check was written from this Trust and provide documents from the Fred E. Gerber Memorial Fund explain the authority you have to give moneys from this Trust to this military officer. Please answer all of the questions from question,lnterrogatory #40 and where it says, Maj. Larry Shaw, insert the name LTC Randy Randolph. Please provide a clear and readable copy of the receipt on the page in your receipt section of the page that has 155 Receipt for Gerber Tools X6 and on the bottom of the page the notation: Dad's Memorial Fund Sperandis Conference. Please explain what the Sperandid Conference is and where the entire and readable receipt is for this check #155. Was LTC Randy Randolph the Executive Officer for US Army Surgeon General Peake? Is or was LTC Randy Randolph one of your superior officers in the office of the US Army Surgeon General? Please explain in what capacity LTC Randy Randolph received these moneys as an employee of the US ARMY and Department of Defense. 63. Please explain for check #157 if Frederick Gerber is yourself or your son and how you distinguish the difference between the two of you and provide a receipt for this check. 64. Please proVide the entire and complete receipt and statement along with the insurance policy for the American Amicable Life for check #161,#203 and state who whom this insurance policy was paid for including the name, address and phone number of the policy owner. Please provide who the beneficiary is of this insurance policy and how much this policy is for, whether it pays dividends and if so, how much and where this money is deposited and if this policy has ever been cashed out and distributed to any beneficiary providing all of the documents associated with any distribution or payout. Please indicate when this insurance policy was purchased and the terms of this policy and for whom it was purchased and why it was paid for by this Trust. 65. Please provide all information on the payment of $5,000 to Jane Heflin and for what educational fund was this check #166 paid for, for whose benefit, why this amount was paid, was this amount of $5,000 paid to anyone for the entire amount, and was this a loan or a gift. 66. Please provide copies of all medical,dental bills that were paid for anyone from this Trust for the year 1998,1999,2000,2001,2002 and provide a copy of the medical insurance policy and the co-payments that each individual owner of each medical insurance policy was responsible for and indicate why this Trust paid for any medical payments for anyone from this Trust. Please provide an explanation why a medical bill, check # 172, for Frederick Gerber went to collection and was not paid on a timely basis and why this bill was paid by the Trust. Please explain why check # 164 for medical expenses was paid by this Trust. 67. Please indicate any correspondence or memo indicating that Mildred J. Gerber a beneficiary of the Fred E. Gerber, Sr. Trust had the authority to authorize and make decisions about the Fred E. Memorial Fund, the payment of educational and support moneys to the issues of this Trust as well as make decisions on large distributions of funds for anyone grandchild such as check #169. Please provide information for how many months this check paid for tuition for Sean Heflin. Please provide a complete receipt for this bill. 68. With reference to the $5,000 educational fund that you sent to Jane Heflin, was this check in addition to the Missouri Military Academy bills that you paid or was this $5,000 used to pay this Military Academy's bills in addition to the bills that you paid. Has Jane Heflin itemized for what purposes she used this $5,000 educational fund and was it solely used for Sean Heflin or was it used for any other purposes or individuals including herself. 69. Please provide the entire and complete bills for the Acacia Life Insurance Co. for checks #186 and #187. 70. With reference to the Fred E. Gerber,Sr. Trust, was this Trust established for the sole purpose of providing moneys for the four grandchildren: Amanda Heflin, Sean Heflin, Mischa Gerber and Sascha Gerber and if so, please site in the Trust that this was specifically indicated and if so, who interpreted this Trust for you and if anyone did so, please identify this individual, whether they were an attorney and what they charged you in billable hours for such an interpretation and provide the address, and telephone number of any such individual(s) who provided you with an interpretation either legal or non-legal opinion. 71. With reference to the Fred E. Gerber, Sr. Trust what criteria did you use to make the decision to distribute any moneys to any beneficiary of this Trust. Do you have in your posseSSion any letters from Fred E. Gerber, Sr specifically giving you instructions as to how to distribute these monyes from his Trust and if so, please provide copies of all such letters, correspondence or memos. 72. With reference to the Fred E. Gerber Irrevocable Trust, tenants for Administration, 73. Please provide a receipt and work product, including reports for the check # 220 to Daniel G. Gilliland for Trust Accounting and provide what Trust Accounting that he performed, for what purpose and the reports for this Trust Accounting. Did this Trust Accounting provide any Federal or State Income Tax work or preparation of tax reports that were filed with the IRS or any State Revenue Department and if so, please provide copies of such documents and reports. Please provide copies of all correspondence and bills from this Accounting firm. Please provide the name of the individual accountant that performed this accounting and all the reports. 74. With reference to check # 194, the receipt that was provided in your receipt section of the discovery that you provided to Marilyn Gerber on September 3,2004 was a collection bill to John Heflin, the spouse of Jane Heflin. Was John Heflin a beneficiary of this Trust and if so, please provide the copy of bill and receipt for the medical service that this collection company sent this notice. 75. With Reference to check #225, please provide all documentation regarding the legal judgment of the bill for $2,833.19 that Jane Heflin was billed by the law firm of Wexler and Wexler for a judgment RE: Kovitz,Shifrin & Waitzman,P.C. Please explain why this Trust paid for the legal bills of Jane Heflin and if so what was the total amount that this Trust paid for Jane Heflin's legal bills and responsibilities. Are you in possession of the legal documents regarding this bill and if so please provide them. 76. With Reference to a check written for $489.50 noted on a DePaul University bill, please indicate which check from this Trust was written for this bill. Is this bill that you provided from the receipt section of your discovery that was sent to Marilyn Gerber on September 3,2004 a bill or is this merely a statement of financial aid and if so, please provide the actual bill for the tuition money of $489.50 that was provided to Amanda Heflin. 77. With reference to check # 227, please provide copies of all accounting reports, the accountant who performed the report and service and all the receipts and work products that were used to prepare any Trust Accounting for this check. Were there any Federal or State Income Tax reports made and if so, please provide a copy of all documents and reports. Please explain the notation at the bottom of the check that states Trust Accounting #4179. 78. Can you explain why only one beneficiary received a Christmas gift for the year 1999 and if so who is this beneficiary and what was the amount of the check. If any other beneficiary received any Christmas gifts for the year 1999, please provide copies of the checks. 79, Did you give any moneys for Christmas gifts to any beneficiary in the year 2000,2001 or 2002 and if so, please provide copies of all checks or notes of cash that you gave from this Trust and identify each beneficiary who received moneys for Christmas. Please do the same for birthday gifts for the year 1998,1999,2000,2001 and 2002 providing the same copies of checks, and the name of the individual. 80. Did you send to Mildred J. Gerber any monthly or quarterly checks from any income or principal from this Trust and is so, please indicate where this Trust indicates that she is to received monthly, quarterly or any income from any income or principal from this Trust and if moneys were given to her,please provide a copy of the checks, cash, and amount with the date and reference to where the income was earned in this Trust or from what principal. 81. Were you ever ordered by the Court of Cumberland County to provide accounting regarding the Fred E. Gerber, Sr. Trust and if so, please provide all the legal documents, pleadings, legal correspondence, and all the legal fees that were paid surrounding this order with the detailed billable hours and the reports and documents that were provided to anyone surrounding this order. Please state the name of the attorneys that were involved with this order and provide their name, address, and telephone number and in what capacity that they represented you. Please provide a copy of all the documents that you submitted to the Court or to any attorney or individual that you were ordered to provide any financial information at anytime from 1998 to 2002. 82. With reference to check # 267 to Mr. Richard Rupp, please provide all the bills along with the billable hours for the legal services that he provided for this check and reference the legal services that were provided for the Fred E. Gerber, Sr. Trust and for what purpose and provide all the documents, letters of correspondence, the legal pleadings and the legal decisions that resulted from the payments of this check for legal services. Please explain why this check was written from this Trust and cite in the Trust documents where it is indicated that such an expense is authorized. 83. With reference to check # 270, to Mr. Sam Roder, please provide the bill and where this service was provided for a chimney and why this check was written from this Trust. 84. With reference to check # 271 to Millie Scott, please indicate why this Trust paid Millie Scott when PNC Bank was the Guardian of Estate and paid all of Mildred J. Gerber's bills and expenses and were in charge of all financial decisions. Please provide a clear and readable receipt for the receipt that was submitted by Millie Scott and a complete and readable page of the document that was underneath the Giant receipt marked Check #5396 that is underneath this page of the receipt page that you provided to Marilyn Gerber for discovery on September 3,2004. 85. With reference to each check written for this Trust, can the Trustee verify that there are receipt(s) for each and every check written and if not, please explain why there are not receipts for each check. 86. With reference to the Fred E. Gerber, Sr. Trust, does the Trustee have the the amount of the original financial funds which funded this Trust from 1994 and all of the subsequent years, 1995,1996,1997 and January 1 to January 31,1998 and if so,please provide a copy of all such monthly statements from Charles Schwab or any other financial institution. 87. With reference to the Fred E. Gerber,Sr. Trust did the Trustee have an appraisal done on the Baltimore Property at 1127 Wedgewood Avenue, Baltimore, MD and if so when and provide a copy of any or all appraisals done. 88. With reference to the Baltimore property stated above,does the Trustee have any document that indicates that this property was funded in the Fred E. Gerber,Sr. Trust and if so please provide a copy of such document. 89. With reference to the Baltimore property stated above, does the Trustee have copies of all real estate taxes paid for this property for the year 1998,1999,2000, 2001 and 2002 and if so please provide copies of all such real estate taxes, city taxes or any expense that was required to be paid to any entity for the stated years along with a copy of the check and the source of the check and from which Trust it was paid. 90. With reference to the Baltimore property stated above, who is the beneficiary of this property upon the death of Mildred J. Gerber and please provide any and all documents which indicates the answer to this question. 91. With reference to the Baltimore property stated above, if this property was never funded to the Fred E. Gerber,Sr. Trust then to what Trust or Estate was it funded and please provide the documents which indicate where this property was funded or in what estate this property was accounted for and the value and taxes that were paid on this property at the death of Fred E. Gerber,Sr. on February 22,1998. 92. With reference to the Baltimore property stated above, please provide a deed to the property indication who the owner of this property was at the time of death of Fred E. Gerber,Sr on February 22,1998 and to whom this property passed to. 93. With reference to the Baltimore property stated above, please indicate what the monthly rent was from February 1,1998 to the present, the rental agreement, who rents the property, and where each and every rent check was deposited, to whom it was given, how each rent check was accounted for, if there was a rent check ledger sheet kept by the Trustee and explain why the rent checks were given to Mildred J. Gerber and at times sent to PNC Bank. 94. With reference to the Fred E. Gerber,Sr. Trust please cite within the Trust under what authority Mildred J. Gerber could dictate the tenants of the administration of this Trust or how moneys were given to anyone. Was Mildred J. Gerber given authority by any documents of this Trust. Did anyone else have authority other than the Trustee to dictate the tenants or administration of this Trust and if so, please provide such a document and explain why Mildred J. Gerber was asked to sign the Tenants of the Trust Administration for this Trust. 95. With reference of the Tenants of the Administration of the Trust, how did the Trustee define and determine if a beneficiary was truthful, honorable, honest members of the Gerber,Flanagan family name. How did the Trustee determine if all of the members incontestably viewed each other as Friends, Advocates of the Gerber family. How did the Trustee determine if any beneficiary ever dishonored or disrespected the family or individual family members thru words, actions and deeds, directly or indirectly and how was the judgment made that any beneficiary was not a Friend or Advocate of the Gerber Family. Did the Fred E. Gerber,Sr. Trust document make these conditions on any beneficiary of the Trust, and if so please explain where. Did this Trust stipulate that the Flanagan family was involved in this Trust agreement and if so where is this cited in the Trust. How did the Trustee supervise, observe or make his decisions and how did he communicate to any beneficiary that they were in violation of the Tenants of the Administration of the Trust. Does the Trustee have any documents to assert any beneficiaries misconduct or violation of these Tenants and if so please provide copies of such correspondence or document. 96. With reference to the Trustee, did he communicate to Ms. Gerber the Tenants of the Administration of this Trust and did he send to her frequent accountings, updates and information about this Trust and if so, please provide evidence of such correspondence being mailed. 97. With reference to the Trustee, did he take a honest, thorough and fair, open book and open management style in relation to Marilyn Gerber and her requests for moneys from this Trust and if so, please provide copies of correspondence for this Trust to and from Marilyn Gerber. 98. With reference to the Trustee, did he inform Marilyn Gerber that she was a beneficiary of this Trust and how much she would be allowed to receive from this Trust upon the death of Fred E. Gerber, Sr. and if so, please provide copies of such correspondence and documents. 99. With reference to the Trustee, did he provide Marilyn Gerber with his address,telephone number and a method of contacting the Trustee in order to make requests from the Trusts or to inquire about the Trust and if so, please provide such a document or correspondence. 100. With reference to the Trustee, were other members of the Trust provided with direct contact with the Trustee, with his address, and telephone number in order to make requests for moneys from the Trust and if so, please provide a copy of such document. 101. With reference to the Trustee, did he demand that Marilyn Gerber go through the expense of contacting his Trust attorney if she wanted any moneys or information about the Trust and if so, please explain why and how much money his attorney(s) charged the Trust and provide copies of the bills with the hourly rate and the billable hours. 102. With reference to the Trust, did the Trustee make a spreadsheet, report, or notes of the moneys that were given to each beneficiary over the years, 1998,1999, 2000, 2001,2002 and if so, please provide a copy of such report. 103. With reference to the Trust, did the Trustee keep a notation of the monthly income from investments from the Charles Schwab Account for each month and if so,please provide a copy of such document. 104. With reference to the Trust, did the Trustee keep a notation of the monthly margin interest that was being charge to this Trust and if so please provide a copy of such a document. 105. With reference to the Trust, please explain why the Trustee wrote checks on moneys that were not in the Trust and why he incurred margin interest payments that a money wasting decision by the Trustee and provide any financial document to support this question or oppose this question. 106. With reference to the Trust, did the Trustee report any losses from this Trust in any Federal or State Tax or Estate report or depreciate the reported losses on the Accounting that he provide to the Court and if so, please provide a copy of such reports. 107. With reference to this Trust, did the Trustee review any documents concerning this Trust that are or were in the posseSSion of PNC Bank at any time or furnished any copies of any documents or reports that are or were in the possession of PNC Bank at any time from 1998 to 2002 and if so please identify which document the Trustee has been provided by PNC Bank or seen at PNC Bank. Did the Trustee authorize the Accounting company of Daniel Gilliland to furnish any reports or accounting for this Trust to PNC Bank and does the Trustee have a copy of any or all documents given to PNC Bank and if so please provide copies of such documents and why they were given to PNC Bank. 108. With reference to this Trust, did the Trustee or his attorney(s) have any meetings or discussions or make any decisions about the Objections which PNC Bank filed against this Trust and if so, please indicate when these meetings occurred, the correspondence surrounding these meetings, were any other beneficiaries ever invited to these meetings, were there any decisions or agreements made during these meetings, was the Trustee present at any of these meetings and if so please document each meeting, date, who was present and and any correspondence regarding these meetings or decisions that were made. 109. With reference to this Trust, were any loans taken from this Trust and were any investments sold from this Trust to pay for funding of any loans for any purpose to anyone and if so, please provide the name of the loan, the individual who received the loan and the amount of investment assets that were sold to grant this loan and any margin interest that was paid subsequently to fund this loan. Please provide a copy of any such loan agreements and the terms of repayment and if any repayments have been made. 110. With reference to letter dated December 28,2000 to PNC Bank and signed by Mildred J. Gerber, please indicate who typed this letter and why Jennifer Conway name is on this letter and the letter was notarized and the circumstances of this letter. Please provide all of the checks that you ordered and received from PNC Bank as referenced in this letter. Please indicate why this letter was copied to Mr. Rupp and to Ms. Baird and if legal fees were assessed in the receipt of this letter or any actions were taken by receipt of this letter by either attorney, please indicate the amount of the legal bills and what actions were taken and copies of all correspondence to and from Mr. Rupp, Ms. Baird and you. Please provide all documentation that you have concerning the Performance Money Market Account No. 50-0088-3096. 111. With reference to a letter dated January 2,2001 signed by you, Frederick E. Gerber,1I please indicate the circumstances of this letter to MBNA Bankcard Services and proof that Mildred J. Gerber did not authorize Marilyn Gerber the use of her credit chard or issue a credit card to her and where the Trustee obtained such information. Please indicate and provide all correspondence from MBNA as the result of this letter and what actions MBNA took as a result of this letter. Did MBNA credit this account for the moneys you stated were unauthorized by Marilyn Gerber and did you contact Marilyn Gerber and ask her about these charges and if not, why not? Please provide all the documents, including the credit card monthly statements and any correspondence that you have for the credit card granted by MBNA including the account number, and the documents that you received from them. 112. With reference to a letter to Chief Kauffman dated January 2,2001 please provide the rest of the pages of this letter as the Objector has only received the front page of this letter as part of the discovery that was sent to her on September 3,2004.Please explain who made the statement that Marilyn Gerber attempted to pass a forged document removing you as trustee/executor. Please provide all evidence that Marilyn Gerber forged a document and a copy of such document. Please provide all documents as to who paid the repair of Mildred Gerber's car, the amount that was paid, who paid it, and copies of all documents of information you stated as fact regarding the accident of Mildred's Gerber Oldsmobile sedan. Please provide all documents that list Marilyn Gerber's driver license, the names of the witnesses who allegedly made police complaints, the report to USAA, and proof that Marilyn Gerber refused to provide information about the whereabouts of the referenced car. Was it you or Marilyn Gerber who paid the repairs on this referenced car and please provide proof of such payment. Please explain why $2,397.91 was deposited into the Fred E. Gerber,Sr. Trust at Charles Schwab in account number 3441-2934 on January 6,2001 and the name Garrett Wynne is written on the USAA check statement along with Mr. Garrett Wynne's e-mail address. Did this Trustee provide any information about this USAA check to the office of corporate counsel of Charles Schwab in San Francisco and if so, please provide copies of all documents or correspondence or the substance of any information that was passed onto Mr. Wynne in San Francisco. With reference to this USAA Check for the repair of Mildred J. Gerber's automobile please provide a complete and full page of this check for $2,397.91, the date that it was received and why it was not deposited until January 6,2001 for payment of repairs for the automobile. Please indicate who owns the automobile reference in the letter dated January 2,2001 and provide a copy of such ownership and car insurance. 113. Please indicate why letters to Ms. Jacqueline Verney are in the miscellaneous section of the Fred E. Gerber Trust and if so, how does it relate to the Fred E. Gerber,Sr. Trust. and if any moneys were paid from the Fred E. Gerber, Sr. Trust for these letters. Please provide any document or evidence that there was a restraining order prohibiting Marilyn Gerber from seeing Mildred J. Gerber dated after November 3,2000 and if so, please provide such a document. Did Mildred J. Gerber pay an attorney to revoke an old restraining order preventing her daughter from seeing Mildred J. Gerber and do you have a copy of such a restraining order. Please indicate the significance of letters that appear to have been dictated to Mildred J. Gerber to write out to Ms Verney on February 2,2001 and to you on January 22,2000 that were placed in the miscellaneous section of the Fred E. Gerber, Sr Trust. Were checks written from this Trust for payment of legal services to Ms. Verney and if so why from this account and provide copies of all legal bills sent from Ms. Verney to the Trustee and indicate from which Trust moneys were paid to Ms. Verney. 114. Please indicate why a check for #30,115.78 was paid to Mr. Richard Rupp on December 18,2001 and please provide the legal bills with the detailed account of each billable hour and why this check was written from the Fred E. Gerber,Sr. Trust and provide all correspondence and documents that were generated by Mr. Richard Rupp for the receipts of such moneys. 115. Please indicate why a wire transfer was made to Marilyn Gerber for $6,750.00 and for what purposes this money was wired to Marilyn Gerber. Did you require that she provide you with a detailed budget and financial information in order to receive these moneys and if so,please provide the documents or correspondence. Please explain why an account number was blackened out and for what purpose. 116. Please indicate for what purpose why a cashiers check was made out to Marilyn Gerber for $9,300.00 and indicate for what purpose this check was mailed to her and if she cashed this check or it was debited to the Charles Account and why this check was mailed to Mildred J. Gerber at her residence. Did you request a detailed financial budget or information from Marilyn Gerber prior to have this check sent to her and did you inform her that this check was being sent to her mother and if so, please provide any documents. Did Mildred J. Gerber in fact write a check to Marilyn Gerber and for how much and was this cashier check ever returned to you from Mildred J. Gerber written to Marilyn Gerber. 117. PLease explain why you have not provided any checks for the year 2002 as ordered by this Court yet you do provide a receipt of a wire transfer for $2,247.00 from the Fred E. Gerber,Sr. Trust to Jane Heflin for a washer, furnace, and medication for Mildred J. Gerber on March 8k,2002. Why was this wire transfer made from the Fred E. Gerber,Sr Trust for services surrounding Mildred J. Gerber and given to PNC Bank who was the Guardian of Estate and Trustee of the Mildred J. Gerber Trust and where is the receipt for such a wire transfer and if you have it, please provide a copy. 118. Please explain why a wire transfer and not a check was sent to Rupp and Meikle for $5,000 and why this was taken from the Fred E. Gerber, Sr. Trust and where is the bill for this money and the billable hours and the purpose of legal fees for $5,000 when Mr. Richard Rupp had just received $ 30,115,78 on December 18, 2001 and please provide all documents related to this question. PNC Bank was the Guardian of the Estate for Mildred J. Gerber and her Trustee, was this wire for $5,000 related to Mildred J. Gerber and if so, please explain why this money came out of the Fred E. Gerber Trust. and if not, how is this wire related to the Fred E. Gerber Trust and for what services on March 14,2002. 119. Please explain why several wire transfers were made to Jane Heflin to her bank in Lombardlllinois on requested by you on 18 January 2002 for $1,500, on March 15,2002 for $2,000 and on April 1 ,2002 for $2,200 and for what purpose were moneys wired to Jane Heflin from the Fred E. Gerber,Sr. Trust and where are the receipts for such moneys and was this connected with the care of Mildred J. Gerber and if so, please explain why PNC Bank was not notified as they were the Guardian of Estate and Trust of Mildred J. Gerber. If these moneys were related to the Mildred J. Gerber, did PNC Bank reimburse the Fred E. Gerber, Sr. Trust and if so, when and for how much and provide copies of all correspondence to this question. If these wire transfers were for Jane Heflin, did you request a detailed financial statement or budget from her for such moneys and if so please provide such documents. 120. Please provide an explanation of who received the wire transfer for $1,000 on May 22,2002 , $3,800.41 on July 12,2002 and $25,000 on March 3,2003 for the copies that were provided in discovery for the Fred E. Gerber, Sr. Trust and provide receipts for all such wire transfers, who received these moneys, and billable hours if any such wires are for legal services for the Fred E. Gerber, Trust. 121. Please indicate who typed up the document dated, January 23,2001 in which Mildred J. Gerber is giving her automobile to Jane Heflin and who witnessed this letter that was only signed by you and Mildred J. Gerber and was this car given to Jane Heflin and if not, did anyone tell you either an attorney or a friend that this document was not valid and identify the name of such an attorney or friend and if any legal fees were incurred in creating this document or interpreting this document. Was Mildred J. Gerber diagnosed with Alzheimer on or around January 23,2001 and did you not file an emergency petition in Orphans' Court of Cumberland County, stating that Mildred J. Gerber was incapacitated and unable to make financial decisions and if so, please provide copies of all medical evaluations, medical experts, medical tests or expert opinions on the mental capacity of Mildred J. Gerber around the time of January 23,2001. 122. Please provide any letters of correspondence that were sent to you from the New Cumberland Police Department, with the dates and copies of such correspondence from 1998 to 2002 and the relevance to any Trust. 123. Please indicate with detail the number of hours that you spent acting as Trustee, and the hours that you spend on Trust Management, Trust Administration and how you abstracted your fees that you took from this Trust. Did anyone assist you in the determination of what fees you were allowed to take or did take and were these fees taken on the value of the Trust for each month, for each year and if so please indicate the financial figures to support your fees and if not please indicate how you assessed your fees. Please provide all documents and spreadsheets, reports that you used to take your fees and assess your time for the year 1998,1999,2000,2001, and 2002 for the entire question of 123. THE FOLLOWING QUESTIONS ARE FOR CHECKS WRITTEN ON THE MILDRED J. GERBER TRUST AND MATTERS CONCERNING THE MILDRED J. GERBER TRUST. 124. With reference to check # 102, please provide all bills, letters of correspondence, documents, pleadings for the $8,870.?? that was paid to the firm of Rupp & Meikle and for what purpose were these moneys used and why was this money paid from this Trust and not the estate of Mildred J. Gerber and provide all billable hours, hourly rates for the moneys paid from this check. Were all of the billable hours related to this Trust and if so provide copies of bills to support this question and your answers. 125. With reference to check #101, please provide a complete and readable copy of the receipts, including the receipt in its entirety indicating the name of the hotel, the address of the hotel, the date that anyone stayed at the hotel, the individual that stayed at the hotel, the reason that anyone stayed at a hotel, the room rate, who paid for the hotels and restaurants and show the entire credit card with the identity of the cardholder. On the back of the receipt page for check #1, please provide the original and the entire receipt for the four receipts that are listed and appear to be restaurants. On page one of the receipt for check #1, there appears to be a receipt underneath the top receipt that reads, Hampton Inns for $338.40. Please provide the receipt that is underneath the Hampton Inns receipt. Please provide the calculation for the check that was written for $649.29. Please indicate why this receipt was paid from this Trust. 126. With reference to check # 103, please indicate where this TV is located now and why this check was written from this Trust. 127. With reference to check #104, please provide a copy of the entire page of this receipt, indicate the purpose of this receipt and why it was paid from this Trust. 128. With reference to check # 105, please a provide a readable copy of this check and a receipt for the private school in Vermont for the amount of $8,8????? and why this check was written from this Trust. 129. With reference to check #106, please provide a copy of the receipt for this International School Iceland College for this check and does this check include any travel, room and board, or other expenses other than the college expense and explain why this check was written from this Trust. 130. With reference to check #107, please provide a receipt for the bill from Daniel G. Gilliland and copies of all the work product and the income tax preparation and for what year, this bill prepared any income tax preparation and indicate what the numbers at the bottom left corner of this check mean and refer to,"lncome #2743/2744. 131. With reference to check #108, please provide a readable check and provide the receipts for the travel expenses for Jane Heflin. Explain why Jane Heflin asked you to pay her credit card company directly rather than pay her and why Jane Heflin did not provide any receipts for this travel and if she did, please provide such receipts and explain why at the bottom left of the check, information is blackened out. Please explain why this check was paid from this Trust. 132. With reference to check #109, please provide the receipt for the supplies for Trust management and what Trust management did you perform on or about May 30,1999 and if so please list these activities, the hours that you spend in the Trust management, were these supplies for only one Trust or both Trusts. Did you create any Trustmanagement reports or documents and if so, please provide copies of all documents. If you purchased supplies for both Trusts, how did you divide the moneys for such supplies for each Trusts and keep an accounting of such and if so, please provide all documents on this accounting and separation of moneys and duties for each Trust. 133. With reference to check #110, #111 please provide copies of the Acacia Insurance Policy for Marilyn Gerber and Jane Heflin and the entire page of each bill and explain why a check was paid from this Trust when you also wrote checks from the Fred E. Gerber,Sr Trust for Marilyn Gerber and Jane Heflin for Acacia. 134. With reference to check #112, please provide the entire Bell Atlantic Mobile bill including all of the calls that are receipts that were paid for the use of Mildred J. Gerber and explain the circumstance of this Mobile phone, when it was purchased along with the receipt of purchase, where this bill was sent to, to whom was this bill sent to, who owned this mobile phone, if Mildred J. Gerber used this mobile phone and why a check was written from this Trust 135. With reference to check #113, please include the bill with an explanation of the charges, hourly rate and copies of all reports for tax preparation that this bill was paid. There is a note from a Lisa indicating that this bill was 61-90 days due and that it was reference to tax preparation of 1998 tax returns and 1998 Trust Income Tax Returns for Frederick Gerber. Please provide copies of all such reports that this check and bill paid for and indicate if Frederick Gerber refers to you or to Fred E. Gerber,Sr and please provide evidence of such distinction. If these tax preparations were for the Fred E. Gerber,Sr. Trust, then why was this check written from this Trust and explain. 136. With reference to check #114, please provide receipts for this check and explain why a check was written from this account. 137. With reference to check #115, please provide receipts for this check and explain why !,082.51 was spent for the purchase of supplies for Trust management and provide an accounting of your hours of Trust management, duties you performed on or about August 1999 and copies of all documents that you created for the Trust management, faxing, copier and identify to whom you would fax, make copies of any document and provide such copies as well as provide receipt for the supplies and identify what a supply is. Did you use this equipment exclusively for the management of the Trust and if so for what Trust and how did you bill each Trust for such equipment and supplies and did you depreciate this equipment or supplies or deduct such equipment and supplies on any tax form either Federal or State and if so, please provide all accounting work product and tax preparation. 138. With reference to check #116, please provide receipts for this check for all items purchased and explain why this check was written from the Trust. Please indicate why this check does not have the name of an individual or party or company written in the appropriate section and provide a copy of the back of this check. who purchased these items, the Trustee or Sascha and if the Trustee purchased these items please indicate why he has not provided a receipt. 139. With reference to check #118, please provide receipts for this check for all items purchased and explain why this check was written from the Trust. Please indicate why this check does not have the name of an individual or party or company written in the appropriate section and provide a copy of the back of this check. Who actually purchased the items, the Trustee or Sascha and explain if the Trustee purchased these items why he did has not provided a receipt. 140. With reference to check #119,#120, #121 please provide receipts for such purchases and explain why these checks were written from this Trust. 141. With reference to check #122, please proVide information or a receipt for this check to CPT John Hansey and why this check was written from this Trust. Please explain why this check paid to this military officer and why this check was not paid from the Fred E. Gerber,Sr. Trust as the checks that were written to LTC Randolph, and Major Larry Shaw. Please provide all documents on the Fred E. Gerber Memorial Fund, when it was established. 142. With reference to check #123, please provide the loan document that was issued to Jane Heflin for debt reduction and provide any correspondence, documents that list the debt relief of all items that Jane Heflin submitted for this loan. 143. With reference to check #124, please provide the receipt for this check and the car repair, and why this check was written from this Trust. 144. With reference to check #125, where are the receipts for the AT &T telephone bill and the check for this bill and why this check was written from the Trust. 145. With reference to check #127 to 150, please explain why these checks were skipped and not used. 146. With reference to check #151 ,please explain why this check was written for the Baltimore Property from this Trust and not the Fred E. Gerber Trust and if you have rectified the accounts by reimbursing the Mildred J. Gerber Trust and if so,please provide the documentation and if not, please explain why not. Please provide the document for which this check was written and how many times a year a fee for this bill does the Baltimore property require payments. 147. With reference to check # 152, #197, please provide the entire bill for this receipt along with the insurance policy for the Fire and Dwelling Policy and explain why this check was written from the Mildred J. Gerber Trust and not the Fred E. Gerber Trust. 148. With reference to check #153,#154, please provide the insurance policy and the entire receipt for the Acacia Life Insurance policy for Jane Heflin and Marilyn Gerber and why this Trust paid for this bill. 149. With reference to check # 155, #158, #163, #165, #167, #171, #183, #187, #192, #196, #199, #208, #231, please provide the entire receipt along with the entire pages listing the phone calls as well as the name of the account holder, the account number, the telephone of this mobile phone and please indicate when and where this mobile phone was purchased, who owns this mobile phone and where this mobile phone is now. Please explain where are all the other bills and accounting for the two Mobile phones from Verizon, Bell Atlantic and AT&T from 1998 to 2002 and provide the missing bills for these telephones. 150. With reference to check # 156, please indicate why a check was written for cash for $200.00 to Mildred J. Gerber and the circumstances of how Mildred J. Gerber received cash at a bank from this Charles Schwab account and why this check was written from this Trust and not the personal PNC Checking account of Mildred J. Gerber. Please tell the date of this missing check that is was written and who wrote this check. 151. With reference to check # 157, please indicate the date that this check was written and provide all receipts for the PA Income Tax payment and to whom this check was written to and provide all documents surrounding this missing check. 152. With reference to check #159, please provide a full and entire receipt and readable receipt for each expense providing the name of the receipt, the date of the 160. With reference to check # 176, please provide the policy, the premiums, any dividends that were paid from this policy, who owns this policy, when it was purchased, who is the beneficiary, and why this Trust paid this bill. 161. With reference to check #177, please provide a receipt for the services of Mr. Joe Cross for roof repair, who repaired the roof, the date of the roof repair and why this Trust paid for this check when it is associated with the Baltimore Property. 162. With reference to check #180, please provide a copy of the receipt for the items purchased for this check and why is was written from the Trust. 163. With reference to check #182, please provide a copy of the receipt for the home repair and what did this home repair consist of and why the Trust paid for this check. 164. With reference to check #188, #189,#200, please provide a receipt for this check and explain why this Trust paid for the Baltimore Property when it was not part of this Trust. 165. With reference to check #193, #194 please provide a copy of all documents, including the 1999 Income Tax report and explain why moneys were paid on a 1999 Tax issue on July 28, 2000 and were any late fees charged to Mildred J. Gerber and if so, please provide the document to explain. Was this check to pay for the Mildred J. Gerber Trust or for Milldred J. Gerber's personal income tax in 1999 and why was this income tax paid two years late. Please provide the name of the individual who prepared this income tax and all the documents and bills associated with the preparation of this income tax accounting and filing. The same questions apply to check #194 to the PA Dept. of Revenue. 166. With reference to check #195, please indicate why this Trust paid for a birthday gift to Sascha Gerber when the Fred E Gerber Trust paid birthday gifts to all of the grandchildren. Did this Trust also pay birthday gifts to the grandchildren and under what authority of this Trust. 167. With reference to check #198, please provide a receipt for this bill and explain why the Trust paid for this bill. 168. With reference to check #201, #202, please explain why these checks are marked VOIDED, then NOT VOIDED is written on them. Did these checks actually clear and if so, please provide the receipts, bills for these items and why the Trust paid for these items. 169. With reference to check #203,204, please provide copies of all receipts for all expenses that you paid Jane Heflin and please account for the time that Jane Heflin was paid for the care of Mildred J. Gerber and at what hourly rate Jane Heflin was paid and provide the airline ticket, the parking receipt, the rental care receipt, and what does the notation on the side of the check mean by guardianship and trial and explain expense, the items on each receipt, a full copy of the airline ticket, the entire lodging receipt, the care rental, and the fees paid to Jane Heflin for a court appearance for this check. Please explain why the receipt page for this check has many items overlaid ontop of each other and are not fully visible and the receipts are not complete for every item that Jane Heflin itemizes and why this Trust paid for these expenses and explain the circumstances that these travel expenses were paid. 153. With reference to check #160, please provide all bills including the billable hours for the legal fees paid to Mr. Herbert Rupp and the circumstances of these legal services and explain how they were related to the Mildred J. Gerber Trust and why this Trust paid for these services. 154. With reference to check #161 , please provide the receipt for this bill and explain why the Trust paid for this bill and not the Fred E. GerberSr. Trust. 155. With reference to check #162, # 164, #168, #174,#178, #179, #181, to the Missouri Military Academy, please provide the entire and complete receipt for the checks written, especially the missing receipts for check #174,178,179,181 and explain why this Trust paid for these checks. Was the $5,000 granted to Jane Heflin from the Fred E. Gerber Trust part of the additional moneys paid for the educational fund of Sean Heflin and if so, please explain how the $5,000 educational fund was used for Sean Heflin and provide the documents to account for the $5,000 educational fund that was paid to Jane Heflin for Sean Heflin from the Fred E. Gerber Trust. Were all of the requested checks in this question a loan from this Trust and if so, please explain and provide any loan document or agreement. Also please provide readable checks as these checks are not clear and the amounts cannot be read. 156. With reference to check # 166, please provide a copy of the bill for this check and why this Trust paid this bill. 157. With reference to check # 172, # 209 please provide the bills for this check along with all of the billable hours, the hourly rate, and the services that were provided for this bill and why this Trust paid this bill when Ms. Baird was the attorney for the Fred E. Gerber Trust and the circumstances that Ms. Baird was hired including the date, who hired her and all the correspondence that was created by Ms. Baird for this bill as well as all documents, pleadings or Court actions that were associated with this bill. 158. With reference to check #173, please provide the bills for this check along with all of the billable hours, the hourly rate, and the services that were provided for this bill and why this Trust paid this bill and for what purpose and the circumstances of the services that generated this bill as well as all of the correspondence, the documents, the pleadings that were associated with this bill. 159. With reference to check # 175, please provide a receipt for this bill and all documents related to this bill for this check and why the Trust paid this bill. the circumstances that Jane was paid for guardianship and trial and why this Trust paid for these expenses. 170, With reference to anyone who was paid for the care of Mildred J. Gerber from 1998 to 2002, was Marilyn Gerber ever paid for caring, feeding and providing items to Mildred J. Gerber and did any Trust ever pay Marilyn Gerber for her services for Mildred J. Gerber or Fred E. Gerber, Sr. and if so please provide receipts and if not, please explain why Marilyn Gerber was not compensated for the care of Mildred J. Gerber or Fred E. Gerber,Sr from 1998 to 2002. 171. With reference to check #205, please provide receipts for all items paid for by this check such as noted, eyeglasses, food, office supplies, gasloil, as well as $500 Christmas gift to Mom and the 3 grandchildren. How much money was given to the 4 grandchildren and was it cash and how can you verify that moneys were given to Mom and the 4 grandchildren and why weren't individual checks written to each person as you had done with the Fred E. Gerber, Sr. Trust. Please explain why you started paying the 4 grandchildren gifts from the Mildred J. Gerber Trust and under what authority you paid the 4 grandchildren when Mildred J. Gerber was suffering from Alzheimer and was declared incapacitated in March 2001.Please provide the copy of the Wachovia bill that is noted for all of the expenses noted on this check. 172. Please explain why check # 206 was paid by you and not PNC Bank who were the Guardian of Estate and provide the receipt for this check. 173 Please explain why check #207 was paid by you when PNC Bank was the Guardian of Estate and provide the receipt for this life insurance policy along with a copy of the policy and who was the beneficiary of this policy. 174. With reference to check # 210, please provide all receipts for the bills and expenses for Mom's trip to Chicago, including the airline, food, clothing and a suitcase. Did Mildred J. Gerber not have sufficient suitcases in her home and why this Trust paid for these items when PNC Bank was the Guardian of Estate. 175. With reference to check #211, please provide a full and complete page of receipts that identify each item that was paid, the receipts for each item purchased, the stamps, the food, the gas, and the travel. Did you charge this Trust for mileage and gas when you drove your car to come see Mildred J. Gerber and if so what did you charge by mile and how did you determine the milage for the gas bills and provide the restaurant bills and explain why this Trust paid for such expenses and not PNC Bank. 176. With reference to check # 212, please provide all receipts for all items purchased as noted for this check and explain why this Trust paid this bill and not PNC Bank. 177. With reference to check #213, please explain what diplomas were framed and any other pictures and provide the receipt for this bill and why the Trust paid for this item and not PNC Bank. 178. With reference to check # 214, please indicate what it means that this check was not cashed and if it was not cashed, then please explain who paid this bill to Derr's and if this Trust paid this bill and if so, what items that amounted to two truck loads of material were removed from the home of Mildred J. Gerber and account for the items removed along with what metal was removed from the estate of Mildred Gerber. Please explain if you informed and received permission from the Guardian of Estate,PNC Bank and did they give you authority to remove items and if so, please provide the document and explain why this Trust paid for this check and not PNC Bank. 179. With reference to check # 215, please provide the loan agreement for this check to Sascha and the receipt for this check and it was determined that this was a loan. 180. With reference to check # 216, #218, #219, #220, #221, #223, #224, #251,#255, #256, please provide receipt for this check and explain why this Trust paid for this check and not PNC BANK. 181. With reference to check # 217, please provide an entire receipt for the rail tickets, the account that it was charge to when they were purchased, who purchased them, and why this Trust paid for this and not PNC Bank. 182. With reference to check # 220, #225, #226, #254, that were all paid to Millie Scott, please identify who Millie Scott is and provide the receipts for all bills submitted to you by Millie Scott and why this Trust paid for these bills and not PNC Bank. 183. With reference to check #221 , again why was this check paid for from this Trust and not PNC Bank who had been the Guardian of Estate since March 2001 and provide a reason why this Trust paid for this bill and not the Fred E. Gerber Trust. 184. With reference to check #222, # 228, please provide receipts for the food, pharmacy, gas and postage that was billed to this Trust and why didn't you submit these bills to PNC Bank and provide entire receipts that are complete which identify who is the card holder, the date of the purchase, the account number and the receipts from each purchase. 185. With reference to check #229, why wasn't this check submitted to PNC Bank for payment or is this check for the Baltimore property and if so, explain why this Trust paid this bill. 186. With reference to check # 230 to #251 , why were these checks skipped and explain why. 187. With reference to check # 251, why wasn't PNC Bank asked to pay this bill and why did this Trust pay this bill. 188. With reference to check #252, did PNC Bank authorize the purchase of this equipment when they were the Guardian of Estate and the Trustee of this Trust and did you inform PNC Bank that you were purchasing equipment for Trust management and what Trust management did you perform that required an additional copier, fax machine and supplies. What Trust documents did you create and did you provide any documents, copies of any checks to PNC Bank or to any other individual or company that required this equipment. Did you amortize or depreciate this equipment and if so, please indicate on what document you did this, Please indicate where this equipment is now. 189. With reference to check #253, please provide clear, complete and entire receipts that identify the date, the items purchased, food, clothing, bedding that was purchased by Jane Heflin. Did Mildred J. Gerber not have enough bedding and please indicate what bedding was purchased. Why was this check authorized by PNC Bank and if not, why wasn't these receipts submitted to PNC Bank for payment. Do all of the receipts that you provided to this Objector add up to $631,01 and please provide a copy of a readable check. 190. With reference to check #257, was this bill for the Baltimore Property and did PNC Bank authorize payment of this check and if not, why was this check written on this Trust. 191. With reference to check #258, please provide a copy of all receipts showing clearly the entire receipt with the date of purchase, what was purchased, the owner of the charge account, the account number and the accounting of miles driven, gas purchased, food and groceries. Again, did PNC Bank authorize the payment of this check and is not, why was a check written to this Trust and not submitted to PNC Bank. 192. With reference to check #259, please provide a copy of this complete policy and for whom this policy was billed to as well as indicate if any other Global Life Insurance policies existed for Marilyn Gerber, Jane Heflin, Mildred J. Gerber or any other member of the Gerber family and when they were purchased and who paid for them from 1998 to 2002. Please indicate who is the beneficiary of this policy that this check paid for. 193. With reference to check #260, please provide a receipt for Somerset Pointe and indicate what Somerset Pointe is, an apartment building, a college, a tuition bill and explain why this Trust paid for this bill, and not submitted to PNC Bank. 194. Did the Trustee known as Frederick E. Gerber pay for any college expenses for his two children known as Sascha and Mischa Gerber and if so, please provide copies of the checks that he paid along with the receipts that he paid for the education, college, technical training for his two children from 1998 to 2002. 195. Did the Trustee pay any income taxes on the investments that no longer fell under the tax exempt status for the two Trusts and if so, please indicate the tax report or document that indicates where these taxes were paid, when they were reported and how much was paid and what the amount of non-tax exempt investments existed by month, year, investment and Trust. 196. With reference to all tax exempt investments and income from these tax, exempt investments, please list them, the amount, and the income earned on these tax exempt investments for the two Trusts. Please provide the documents for the answer to this question. 197. With reference to the two Trusts, please indicate how much money was paid out for the care of Mildred J. Gerber from the trusts and provide the checks, receipts for the care of Mildred J. Gerber from 1998 to 2002 and indicate this total by each Trust. 198. With reference to the two Trusts, please indicate how much money was paid out for the care of the Baltimore Property and provide the checks, receipts for this property from 1998 to 2002 and indicate this total by each Trust. 199. With reference to the two Trusts, please indicate how much money per grandchild, was paid to each grandchild from 1998 to 2002 and indicate this total by each Trust. 200. With reference to the two Trusts, please indicate how much money was given to Jane Heflin, Marilyn Gerber, and Frederick E. Gerber,1I from 1998 to 2002 and provide this total by each Trust. 201. With reference to the income earned for each Trust, please indicate the total amount earned from investments for each Trust from 1998 to 2002. Please indicate how much money was lost through investments from 1998 to 2002 and how much margin interest was paid for each Trust from 1998 to 2002. Please indicate the total amount of money that was written in the form of checks that was written on margin when there were no moneys from income to write these checks from 1998 to 2002 for each Trust and explain why this income wasting occurred. 202. With reference to the Met Life Insurance Policy Acct #403-1101942, please indicate if this policy pays any dividends and if the dividends from this policy was funded into any of the t\'\I? Trusts, and if so please explain and provide all of the documents for this insurance policy. Please indicate who the beneficiary is of this policy. If this policy does belong with any of the two Trusts, was this policy declared to PNC Bank as part of the Mildred J Gerber estate and if so, please provide documents that indicate this and all copies of dividends that were given to PNC Bank. 203. With reference to the Mildred J. Gerber Trust, did you as Trustee ever notify any of the beneficiaries that you were taking out a loan for yourself from the Mildred J. Gerber Trust and if so,please explain why you did or did not. 204. With reference to this loan that you took out from the Mildred J. Gerber Trust, please show where in this Trust document that you had authority to take this loan and how have you repaid this loan and provide any documents associated with this loan. 205. With reference to this Trust, have you or your attorney ever had any discussions with anyone regarding the Objections that PNC Bank filed regarding this Trust and if so, please provide all copies of all correspondence, documents or any decisions that were made regarding their Objections. 206. With reference to the two Trusts, have you or your attorney ever had any discussions with anyone regarding the Objections that Marilyn Gerber filed regarding the Trustee's Accounting for the two Trusts and if so, please indicate when, where and who was present to discuss these referenced objections and provide any documents or decisions that were made regarding these objections or decisions. 207. Please explain why from June 2000 to April 2001, when Marilyn Gerber was disabled from a motor vehicle accident, that you refused to provide any moneys to her in order to pay her expenses, living expenses, medical bills despite the requests of Marilyn Gerber and her attorney, Michael Kane. Please provide any documents of financial request from Marilyn Gerber, Michael Kane to you or your attorney(s) ie. Mr. Rupp, Ms Lindsay Baird and any documents that any attorney corresponded with Michael Kane or Marilyn Gerber. 208. Please explain why in September 2001, you agreed to pay Marilyn Gerber the amount of $10,000 but then only wired $7,500 to her attorney, Michael Kane and not directly to her and provide the wire transfer for the transfer of this money and all documents connected with this wire transfer and moneys sent to Marilyn Gerber. Please indicate where this money was transfered to, the document of this wire transfer and why when Marilyn Gerber requested the balance of the $2,500 on numerous occassions that you refused to provide this money or any answer regarding her request. Please provide copies of all correspondence from Ms. Lindsay Baird, Michael Kane and any other attorney or individual who produced any document or correspondence regarding any moneys or issues surrounding Marilyn Gerber and you as the Trustee, 209. With reference to letter to Charles Schwab requesting several wire transfers for the amount of $1,500 to Ms. Verney, $1,000 to PNC Bank and $30,000 to Sun Trust, please indicate when these wire transfers occured, and identify who at Sun Trust received $30,000 and fOr whom this money was given to along with any documents connected to these wire transfers, letters of correspondence, legal fees associated with these wire transfers, any legal agreements for a retainer of moneys from any attorney. This is for the Mildred J. Gerber Trust. Please answer the same questions for the wire transfer from your letter to Charles Schwab dated March 17,2001 to Ms Verney for Jacqueline Verney. 210. With reference to ALL WIRE TRANSFERS for the TWO Trusts, please provide a who requested each wire transfer, to whom it was transferred to, all wire transfer fees connected with each wire transfer, all bills and receipts for any services connected to any wire transfer and explain why you did not write checks for the amount of each wire transfer and instead wired moneys to any individual rather and incur costs for such wire service rather than create a check and send it out overnight delivery. 211. Please provide the total amount of wire transfers that you ordered for the two TRUST BY EACH TRUST, the total amount of wire transfer fees from 1998 to 2002 and list the subtotal for each of the requested years. 212. Please provide a total amount of moneys by each Trust of moneys that you paid to each attorney for each year 1998,1999,2000,2001 ,and 2002. 213. Please provide all documents that indicate what the original assets, funds, investments, moneys were from the original funding of the Mildred J, Gerber Trust. 214. Please indicate if Charles Schwab was the only financial institution that held any of the assets or investments for the two Trusts from the beginning that the two Trusts were written and funded and the documents which indicated what was funded in each of the two Trusts and were the moneys or assets were that funded each Trust. If Charles Schwab was not the only financial institution that held moneys or assets for the two Trusts, please indicate where the other assets or moneys are and identity these financial institutions, the assets, the moneys, all statements regarding the management of these assets and moneys and all other documents that are related to these other assets and moneys that are part of the two Trusts from the beginning of the creation of the two Trusts and from 1998 to 2002, If any moneys or assets were added to the two Trusts, please indicate the documents that instruct this to occur and what was added to the two Trusts and provide copies of such documents including all of the statements, correspondence and documents regarding the addition of assets and moneys. 215. Please indicate the amount of time that you spent managing the Mildred J. Gerber Trust, how you assessed your fees and administration costs for the Mildred J. Gerber Trust and how you kept track of your time and fees for the Mildred J. Gerber Trust. Date: W &( .?etY--! VERIFICATION I, FREDERICK E. GERBER,II also known as Frederick Edward Gerber II, and Fred E. Gerber,1I verify that: my statements in the foregoing document are true and correct to the best of my knowledge, information and belief. Said documents are based on my own knowledge, belief or information and that I have supplied copies of all requested documents, correspondence as requested in these Interrogatories by Marilyn Gerber that are in my possession or I have identified where these documents exist that are not in my possession and have made every attempt to order, retrieve and secure any of the documents that I know exist which I have not provided to Marilyn Gerber. I understand that false statements herein are made subject to penalties of 18 Pa. C.S.A. 4904 relating to unsworn falsification to authorities. /' Date: ~._," CERTIFICATE OF SERVICE AND NOW, this 1- day of November, 2004, I hereby certify that I have served a copy of the within document on the following by delivering a true copy of the Interrogatories to Frederick E. Gerber,1I to the office of his attorney, Mr. Richard Rupp, Esquire at 355 North 21 st Street, Camp Hill, PA 17011 and hand delivered a true and correct copy to Mr. William Duncan, Esquire to his office a,t One Irvine Row, Carlisle, PA 17103 and have placed a copy of this document to: Ms. Jacqueline VerneyEsquire 44 S. HanoVer Street Carlisle, PA 17103